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Ref: P/2012/0708 Address: Part of the South Acton Estate, Acton W3, including the following addresses:

Anstey Court; 1-66 Arlington Court; 1-22 Arundel House; 98-100 (inclusive) Avenue Rd; Barrington Court; Barwick House; Beaumaris Tower; Bennett Court; 347-371 Bollo Lane; Bollo Brook Youth Club; 81-95 Brouncker Rd; Buchan House (including Hanbury Rd commercial units); 1-10 Buckland Walk; Caine House; Carisbrooke Court; Carroll Court; Charles Hocking House; Chesterton Court; Cheltenham Place; Blocks at 81-139 Church Rd; 1-20 Clandon Close; Conrad Tower; Corfe Tower; Doyle House; 2-16 Enfield Rd; 79-83 Enfield Rd; Frampton Court (Belgrave Close); Galsworthy Court; 1-16 Glamis Court; Grahame Tower; Hardy Court (including commercial units at 96-118 Bollo Bridge Road); Harlech Tower, Harleyford Manor; Jerome Tower; Ludlow Court; Meredith Tower; Oak Tree Community Centre; 32 and 274-292 Osborne Rd; The (former) Osborne Public House; Pembroke House; 1-16 Pevensey Court; 1-40 Ragley Close (including commercial units at 1-3 Ragley Close); St Margaret's Lodge; 1-6 Telfer Close; Webb Court; Wodehouse Court; Woolfe Court; and South Acton Working Men’s Club; Public Open Space including Bollo Brook Park, South Park, Avenue Rd Recreation Ground and allotments at Jerome Tower and Enfield Rd.

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Ward: South Acton Proposal: Outline planning application (with all matters reserved) for the continued

regeneration of the South Acton Estate comprising the demolition of buildings at the locations specified in the site address (including residential units, 521sqm of A1 (retail) floorspace; 2,434sqm of (D1) community/ (B1) office facilities; hotel accommodation (C3); garages and associated areas) and the erection of a maximum of 2,350 residential units, a maximum of 1,050sqm of flexible retail (A1) / restaurant and café (A3) / office (B1) / community (D1) uses, of which a minimum of 600sqm is to be retail (A1) use, a further 2,348sqm of community (D1) / office (B1) floorspace (to include a minimum of 926sqm for provision of a community centre and youth club), energy centre, alterations to allotments, re-sited and enhanced open space and play facilities, landscaping, highway works and car parking.

Drawing numbers: SAE-AL-001-F Existing site plan – application boundary

SAE-AL-003-E Existing site plan – demolition plan SAE-AL-004-B Existing site plan – phasing land parcel plan SAE-AL-005-B Existing site plan – Tree retention plan SAE-AL-006-B Existing Site Plan - Tree removal plan SAE-AL-100-C Parameter Plan - Development zones SAE-AL-101-E Parameter Plan - Building heights SAE-AL-102-F Parameter Plan - Main development use – ground floor SAE-AL-104-E Parameter Plan - Access and circulation

SAE-AL-105-E Parameter Plan - Public Open Space and

allotments SAE-AL-108-E Parameter Plan - Strategic Landscape Plan SAE-AL-002-C Existing Site Plan- Study area boundary (illustrative only) SAE-AL-109-B Illustrative – Master plan (illustrative only) SAE-SK-200-A Proposed site sections – North (illustrative only) SAE-SK-201-A Proposed site sections – South (illustrative only) Summary Document (Terence O’Rourke Ltd); Planning Supporting Statement (Terence O’Rourke Ltd); Planning Supporting Statement (Terence O’Rourke Ltd) including Statement of Community Involvement (L&Q and HTA), Affordable Housing Statement (L&Q), Estate Management Strategy (L&Q), Health Impact Assessment (ERM), Retail Statement (Burnett Planning and Development); Design and Access Statement (HTA) (amended and received 18/06/2012) including Services Strategy (Aecom), Arboricultural Survey (CBA), Climate Change Mitigation Strategy (Aecom), Climate Change Adaptation Strategy (Aecom), Sustainability Statement, including completed SPG1 sustainability checklist (Aecom), Design Code (HTA); Environmental Statement (Terence O’Rourke Ltd) including: Non Technical Summary (Terence O’Rourke Ltd), Technical Appendix A – Scoping (Terence O’Rourke Ltd), Technical Appendix B – Cultural Heritage (Terence O’Rourke Ltd), Technical Appendix C – Natural Heritage (Terence O’Rourke Ltd), Technical Appendix D – Traffic and Transport (SKM Colin Buchanan) and additional information comprising of: Technical Note - TfL Consultation Response prepared by SKM Colin Buchanan, 22/05/2012; Revised Collision Analysis, prepared by SKM Colin Buchanan, 30/05/2012;

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Technical Note - LB Ealing Response, prepared by SKM Colin Buchanan 07/06/2012; Revised Technical Note - LB Ealing Response, prepared by SKM Colin Buchanan 21/06/2012; Framework Delivery and Servicing Plan and Framework Construction Logistics Plan, prepared by SKM Colin Buchanan 25/06/2012; Technical Appendix E – Air Quality (Aecom), Technical Appendix F – Noise and Vibration (Aecom), Technical Appendix G – Ground Conditions and Groundwater (Aecom); Technical Appendix H – Flood Risk Assessment (SKM Colin Buchanan), Technical Appendix I – Waste (Aecom), Technical Appendix J – Microclimate (Aecom) and additional information ‘Townscape and Visual Effects’, dated June 2012 (Terence O’Rourke Ltd), received 15/06/2012; Letter ref 180603b/JP12 responding to Natural England response to outline planning application, dated 30/03/2012; Letter responding to comments submitted by third parties and issues raised by case officer, ref: 180603B/ATB dated 12/06/2012 (Terence O’Rourke Ltd), received 15/06/2012; Letter regarding Open Space Timing of Delivery, Quantum of Open Space, Phasing Changes, Urban Design Officer comments (response), Bus Driver Facilities, Updated DAS, Design Code and Parameter Plans (un-dated and no reference); received 14/06/2012 (Sally Lewis, HTA); Density Calculations – Overall (drawing) dated 12/10/2011 (HTA), received 15/06/2012; Letter responding to comments submitted by the GLA, ref: 180603B/ATB dated 12/06/2012 (Terence O’Rourke Ltd), received 15/06/2012; Technical Note relating to Climate Change Mitigation Strategy (Job No: 60140203) dated 01/05/2012 (Aecom), received 15/06/2012; Acton Gardens LLP Financial Viability Assessment (Private & Confidential).

Type of Application: Outline application – Environmental Impact Assessment Application Received:

20/02/2012 Revised: 15/06/2012

Report by: Elizabeth Piper Executive Summary

The application site comprises an existing municipal housing estate. The majority of existing estate buildings are in poor physical condition resulting from their inadequate design and poor maintenance. There is also a poor mix of dwelling types and tenures across the site. The existing estate is dominated by social rented one and two bedroom units. In 2005, 80% of residential units were in social rented tenure and were two-bed or smaller. According to the Council’s own 2008 review, Decent Homes works alone would not provide the transformational effect that the area requires and therefore the South Acton Estate was considered to require a higher level of intervention. The current outline application proposes the phased demolition of all existing residential dwellings constructed before 2001 and their replacement with up to 2,350 residential units across Phases 2-11 of the masterplan. The proposal would reprovide community facilities and a relatively small amount of flexible floorspace for retail, café / restaurant and office uses

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of a local nature. The impact of this small provision of commercial and community uses on the viability and vitality of the Acton district centre is considered to be insignificant. The South Acton Estate is identified as an area for regeneration on Map 2.5 of the London Plan. Policy 2.14 of the London Plan states that “Within areas for regeneration shown on Map 2.5 the Mayor will work with strategic and local partners to co-ordinate their sustained renewal by prioritising them for neighbourhood-based action and investment”. Policy 2.3 of Ealing’s Development Strategy provides explicit support for the continued regeneration of the South Acton Estate. The need for, and importance of, housing provision within Ealing is very significant. Policy 1.1(a) of Ealing’s Development Strategy states, “By 2026, we aim to provide 14,000 additional homes…”, sub-point (b) identifies that the development of these new homes will be primarily concentrated in the Uxbridge Road / Crossrail corridor, town centres, around key railway stations and the municipal housing estates, including South Acton. Policy 3.3 and Table 3.1 of the London Plan set out a housing provision monitoring target of 8,900 additional homes in Ealing between 2011-2021. The proposed development would provide an additional 821 units (2,643 hr) in private sale tenure, and an additional 440 habitable rooms in affordable tenure. The regeneration programme is considered to be essential to Ealing's housing trajectory, particularly in ensuring housing delivery in the early stages of the Development Plan. The outline application has been accompanied by a confidential Financial Viability Appraisal to justify the level of affordable housing being provided across the masterplan proposals. The S106 Agreement includes obligations to secure the amount of affordable housing proposed within the outline application submission and also provides a mechanism for further financial viability testing, to ensure that the maximum reasonable amount of affordable housing is secured on a phase-by-phase basis. The indicative bed size mix of the affordable accommodation would include a significant proportion of family-sized accommodation. It is considered that the proposed bed-size mix would provide a good range of housing choice, broadly in accordance with policy 3.8 of the London Plan and the Council’s adopted SPD1. The standard and quality of the proposed housing would be very high. Based on the information provided in the Design and Access Statement, the proposed development would be designed to be tenure blind and the internal space standards of the residential units would meet or exceed the London Plan standards. All units would meet the Lifetime Homes standards and 10% of housing, across the different tenures and bed-size mix, would be constructed to Wheelchair Adaptable or Accessible standards. The masterplan proposals also respond to Secured by Design principles. A calculation of the indicative semi-private amenity space to be provided for the proposed flat buildings is 23,350sqm; an under provision of 10,525sqm against the Council’s SPG 13 requirements. However, it is considered that the indicative approach to the layout and quantum of semi-private amenity space within the masterplan would be broadly acceptable particularly when considered alongside the improvements that would be made to publicly accessible open space and children’s play facilities within the site, and desire to increase the quantum of housing within the site. The vision for the redevelopment and significant re-planning of the residential neighbourhood is consistent with good urban design principles. The South Acton Estate would be integrated into its surroundings and the permeability through the site would be significantly improved. Streets within the site would be defined by a building layout that is well structured and legible. The density of development in some parts of the site would exceed London Plan density matrix recommendations. However, the Mayor’s Housing SPG acknowledges that increased density may be necessary to generate sufficient value from market development to support the replacement of affordable housing.

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Matters relating to the quality of the external design of new development and the impact on the townscape, as well as the impact of the development on neighbours would need to be addressed in further detail as part of the reserved matter applications. The current outline application provides details of the maximum heights of buildings and their indicative layout, which are considered to be broadly acceptable. Open spaces within the estate currently lack definition, function and quality. Parks are well used but the lack of clearly defined frontages and natural surveillance can make them feel unsafe. The masterplan proposes a number of improvements to existing public open space, but significantly, proposes to develop on existing spaces and reprovide new parks elsewhere. The proposals would result in an additional 8,533sqm of public and community open space (providing a total of at least 49,386sqm), which is comparable on a per capita basis to the existing provision. The proposals incorporate the re-configuration, replacement and small increase in area of allotments, which is considered to be acceptable. A large proportion of existing trees would be retained and where it is necessary that trees are felled, appropriate mitigation has been proposed. Overall, The impact of the development on neighbours has been considered and no significant issues are raised. The Daylight and Sunlight Assessment identifies that the proposed building height strategy may result in some limited loss of daylight and sunlight by neighbours. However, these issues would need to be explored in further detail at the reserved matters application stage. The vehicle trip generation from the development would not be significant and the results of the detailed modelling indicate that the existing road network could accommodate the additional flows from the development and operate with spare capacity. Car parking as with earlier phases is proposed on a parking ratio of 0.48 per unit. Improvements to the cycle and pedestrian network and planned improvements to the local bus network, which may be re-routed through the site, would assist to encourage residents away from private vehicles. The proposal incorporates a centralised energy centre, which is intended to be the district-heating network for the overall development and would have capacity for developments outside of the application site to link into the network. The development would be constructed to (minimum) Code for Sustainable Homes Level 4 and would include renewable energy technologies. The proposal would also contribute to the urban greening of the site and enhance biodiversity. The Environment Agency has confirmed that the proposed sustainable urban drainage systems are acceptable and the development would be capable of achieving greenfield run-off rates. Officers consider that, with the recommended planning conditions and S106 Agreement obligations that the proposals are broadly consistent with the development plan policies and it is recommended that outline planning permission be granted.

RECOMMENDATION Grant outline planning permission subject to Stage II referral to the Mayor of London, completion of a S106 agreement and subject to conditions of consent. S106 Draft Heads of Terms Subject to the applicant and any other person having an interest in the land entering into an Agreement under Section 106 of the Town and Country Planning Act 1990, as amended, with the Council to secure the following;

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Housing A1. Provision of affordable housing comprising a minimum of 3922 affordable habitable rooms, of which 3014 habitable rooms would be in rented tenure to include 174 habitable rooms for over 55s, and the balance of 908 habitable rooms provided in intermediate tenure. Notwithstanding this there is a wider aspiration to provide the maximum reasonable level of affordable housing and each reserved matters application would need to be accompanied by a financial viability assessment and affordable housing statement to justify the level of provision, as well as the prevailing housing needs within the London Borough of Ealing. The financial viability assessment shall respond to policy 3.12 of the London Plan, demonstrating that the maximum reasonable amount of housing is being secured. The overall level of provision would not be limited to the indicative amount of affordable housing contained within the outline application. A2. All affordable units to be provided through a Registered Provider and be ready for occupation before the occupation of 51% of the private sale units within each relevant development zone or phase of the development (as relevant). A3. The bed-size mix of rented tenure accommodation to provide a minimum of 35% family-sized accommodation (3-bedroom+). A4. Compliance with the Council’s Deed of Nomination Rights in respect of the affordable housing. Apprenticeships, Training and Community Fund B1. Participation in an Apprentice and Placement Scheme, providing a minimum of 36 placements over Phases 3-11 of the development programme. The Apprentice and Placement Scheme shall provide opportunities across the construction, design and post-construction management of the development. Details of the Apprentice and Placement Scheme to be submitted to the Council for written approval. B2. An annual total contribution of £50,000 towards a community development fund for the provision of employment / skills development opportunities, community engagement, the provision of suitable space for community activities and enterprise employment, in accordance with the provisions specifically set out within the Principal Development Agreement (PDA) between the London Borough of Ealing and Acton Gardens LLP. The annual payment of the contribution shall be taken from the date of the Phase 1 planning permission (31/03/2011) and the index linking for the contribution shall accord with the PDA provisions. The annual contribution shall be made during the development period up-to and including 2026. Transport C1. A detailed Framework Travel Plan for the development, including a Travel Plan for each phase of the development. In addition to the standard requirements of the Travel Plan, it shall also make provision for the following: - Monitoring the uptake of parking spaces for wheelchair users: In addition to the provision of 112

marked and designated wheelchair accessible parking bays provided on the first occupation of the development (which accounts for approximately 5% of parking spaces in each phase of the development), a new disabled bay is to be provided on an incremental basis up to the full quota of 235 spaces when occupancy rates of the marked disabled bays reaches 90%.

- Monitoring the uptake of Electric Vehicle Charging Points: In addition to the 20% of parking bays equipped with active charging points for electric vehicles, new active charging points shall be

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provided on an incremental basis up to the full quota of an additional 20% of the total parking bays when the use of the existing active Electric Vehicle Charging Points reaches 90%.

- A Parking Management Plan to provide details of the criteria for parking (permit) eligibility and allocation of off-street parking spaces. The underlying principle is that the number of households that will be eligible for permits should not exceed the number of available off-street spaces and that off-street parking will be allocated on an equitable basis across the different housing tenures.

- Details of a car club scheme, which is to be provided by an accredited car club operator. C2. A contribution of £10,000 towards the monitoring and review of the Framework Travel Plan. C3. Within the first three years of occupation of new dwellings within the development, payment of membership of a local Car Club for each initial household of the development who wishes to take up the offer of membership. C4. Provision of 8 Car Club spaces. C5. A restriction on the issuing of resident car parking permits within the South Acton Estate Controlled Parking Zone (CPZ) to one permit per household containing an Existing Resident of the South Acton Estate to be re-housed in the development, and none being issued to a household containing an Existing Resident with an off-street car parking space. The eligibility to purchase a parking permit shall then remain with the land title or lease of the relevant property and any future occupiers of the relevant unit shall be eligible to purchase a parking permit. No other resident or business shall be eligible to purchase a parking permit within the South Acton Estate CPZ. The monitoring of the uptake of parking permits shall be undertaken as part of the Travel Plan. C6. A contribution of £67,000 towards pedestrian, cyclist and road safety improvements identified within the applicants’ submitted Pedestrian Environment Review Systems (PERS) audit and the introduction of a 20mph speed limit in the surrounding area. C7. A contribution of £450,000 towards funding the introduction or diversion of bus services through the site by Transport for London. C8. A contribution of £40,000 for two pairs of new bus stops along the proposed new bus route within the site by Transport for London. C9. Payment of the necessary highways reinstatement works following the construction of each phase or development zone, based upon pre and post work condition surveys. The level of payment will be mutually agreed by the developer and Local Highways Authority. C10. Provision of TfL bus driver unisex disabled toilet as near as practicable to the location of the proposed bus stand, the details of which are required by condition of this outline planning permission. Management Plan – Community Centre, Jerome Tower (reconfigured and new) Allotments, Central Plaza and Hope Gardens D1. The submission of a Management and Maintenance Plan for the new community facilities located in the application site. Details of the facility charges shall be included in the submission. D2. The submission of a Management and Maintenance Plan for the reconfigured and new Jerome Tower Allotments. Details of the use charges (if applicable) shall be included in the submission. D3. The submission of a Management and Maintenance Plan for Central Plaza. Landscaping / Public Open Space

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E1. Permanent access to the open space, recreation facilities and throughout areas of the estate that are not adopted by the Council (which may include Central Plaza and Jerome Tower Allotments). E2. A contribution of £169,438 for the provision of a Multi-Use Games Area (MUGA) in the Bollo Brook Park by Ealing’s Parks & Countryside Service, to be paid on the commencement of the development in Phase 3. E3. A contribution of £370,000 for the refurbishment of the reconfigured Avenue Road Public Open Space by Ealing’s Parks & Countryside Service, to be paid on the commencement of the development indicatively shown in Phase 8. E4. A contribution of £60,000 as a commuted sum for the up-keep of the artificial sports pitch and MUGA in Bollo Brook Park, to be paid on the commencement of the development indicatively shown in Phase 4 in the application submission. E5. A contribution of £45,800 for the maintenance of 280 new street trees (excluding the first five years of establishment, which Acton Gardens LLP will be required to undertake). Payments to be equally divided between phases 3 –11 and paid on the first occupation of each phase of the development. E6. A contribution of £31,000 as a commuted sum for the maintenance of the additional playground at North Park (excluding the first 5 years of establishment, which Acton Gardens LLP will be required to undertake). Payment to be triggered on the fifth anniversary of the practical completion of North Park. Education and Health F1. A contribution of £729,360 towards the improvement of local education provision for school age children. Payments to be equally divided between phases 3 –11 and paid on the first occupation of each phase of the development. F2. A contribution of £550,285 towards healthcare provision in the local area. Payments to be equally divided between phases 3 –11 and paid on the first occupation of each phase of the development. Environmental Health

G1. A contribution of £73,300 for Air Quality monitoring by London Borough of Ealing Environmental Health Service. Other H1. All contributions to be index linked. H2. Payment of the Council’s reasonable legal and professional fees incurred drawing up the S106 agreement. AND

That outline planning permission be GRANTED for the development subject to the following conditions and informatives: TIME LIMITS, RESERVED MATTERS AND COMPLIANCE WITH OUTLINE PARAMETERS 1. Time limit of outline element

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a) Applications for approval of Reserved Matters must be made no later than the expiration of nine (9) years beginning with the date of this outline planning permission, and b) The development to which the permission relates must be begun no later than the expiration of two (2) years from the final approval of the Reserved Matters, or in the case of approval on different dates, the final approval of the last such matter to be approved. Reason: To comply with Section 92 of the Town and Country Planning Act 1990 (as amended). 2. Reserved Matters Approval No part of the development in Phases 3-11, as illustrated on approved Parameter Plan SAE_AL_100 Rev C and Section 5.4 of the approved Design and Access Statement, shall commence until all of the following reserved matters for that Phase have been approved by the Local Planning Authority:

A) Appearance B) Means of Access C) Landscaping D) Layout E) Scale

Should the Phase 2 development not be carried out in accordance with full planning permission ref: P/2012/0711, then a reserved matters application in accordance with sub-points A) – E) shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of the development. The relevant Phase of development shall be carried out in accordance with the approved documents and plans, unless otherwise agreed in writing by the Local Planning Authority. Reason: To ensure that the Local Planning Authority may be satisfied with the details of the proposal as provided for in Article 4 and 5 of the Town and Country Planning (Development Management Procedure) Order 2010, as this application is in outline form only. 3. Approved Plans and Documents The development hereby approved shall be carried out in accordance with the following approved plans and documents insofar as they will be amended subject to the approved plans and documents necessary to support the reserved matters application(s) required by the various conditions of this permission: SAE_AL_001-F; SAE_AL_003-E; SAE_AL_004-B; SAE_AL_005-B; SAE_AL_006-B; SAE_AL_100-C; SAE_AL_101-E; SAE_AL_102-F; SAE_AL_104-E; SAE_AL_105-E; SAE_AL_108-E; and illustrative drawings – SAE_AL_002-C; SAE_AL_109-B; SAE_SK_200-A; SAE_SK_201-A; SAE_SK_202-A; SAE_SK_203-A. Summary Document (Terence O’Rourke Ltd); Planning Supporting Statement (Terence O’Rourke Ltd); Planning Supporting Statement (Terence O’Rourke Ltd) including Statement of Community Involvement (L&Q and HTA) as Appendix 1, Affordable Housing Statement (L&Q), Estate Management Strategy (L&Q), Health Impact Assessment (ERM), Retail Statement (Burnett Planning and Development); Design and Access Statement (HTA) (latest amendment issued under cover of letter dated 12/06/2012) including Design Code as Appendix 6 (HTA), Services Strategy (Aecom), Arboricultural Survey (CBA), Climate Change Mitigation Strategy (Aecom), Climate Change Adaptation Strategy (Aecom), Sustainability Statement, including completed SPG1 sustainability checklist (Aecom); Environmental Statement (Terence O’Rourke Ltd) including Non Technical

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Summary (Terence O’Rourke Ltd), Technical Appendix A – Scoping (Terence O’Rourke Ltd), Technical Appendix B – Cultural Heritage (Terence O’Rourke Ltd), Technical Appendix C – Natural Heritage (Terence O’Rourke Ltd), Technical Appendix D – Traffic and Transport (SKM Colin Buchanan) and additional information comprising of: Technical Note - TfL Consultation Response prepared by SKM Colin Buchanan, 22/05/2012; Revised Collision Analysis, prepared by SKM Colin Buchanan, 30/05/2012; Technical Note - LB Ealing Response, prepared by SKM Colin Buchanan 07/06/2012; Revised Technical Note - LB Ealing Response, prepared by SKM Colin Buchanan 21/06/2012; Framework Delivery and Servicing Plan and Framework Construction Logistics Plan, prepared by SKM Colin Buchanan 25/06/2012; Technical Appendix E – Air Quality (Aecom), Technical Appendix F – Noise and Vibration (Aecom), Technical Appendix G – Ground Conditions and Groundwater (Aecom); Technical Appendix H – Flood Risk Assessment (SKM Colin Buchanan), Technical Appendix I – Waste (Aecom), Technical Appendix J – Microclimate (Aecom) and additional information ‘Townscape and Visual Effects’, dated June 2012 (Terence O’Rourke Ltd), received 15/06/2012; Letter ref 180603b/JP12 responding to Natural England response to outline planning application, dated 30/03/2012; Letter responding to comments submitted by third parties and issues raised by case officer, ref: 180603B/ATB dated 12/06/2012 (Terence O’Rourke Ltd), received 15/06/2012; Letter regarding Open Space Timing of Delivery, Quantum of Open Space, Phasing Changes, Urban Design Officer comments (response), Bus Driver Facilities, Updated DAS, Design Code and Parameter Plans (un-dated and no reference); received 14/06/2012 (Sally Lewis, HTA); Density Calculations – Overall (drawing) dated 12/10/2011 (HTA), received 15/06/2012; Letter responding to comments submitted by the GLA, ref: 180603B/ATB dated 12/06/2012 (Terence O’Rourke Ltd), received 15/06/2012; Technical Note relating to Climate Change Mitigation Strategy (Job No: 60140203) dated 01/05/2012 (Aecom), received 15/06/2012. Reason: For the avoidance of doubt and in the interests of proper planning. 4. Reserved Matters Details Development shall not commence on any Phase or Development Zone (as relevant) until details of the following matters have been submitted to and approved in writing by the Local Planning Authority relative to that phase / reserved matters area:

A) Updated Design and Access Statement and supporting Design Code, which shall provide details of how the design principles and commitments established by the approved Design and Access Statement and Design Code are achieved;

B) Floor, elevation and section plans; C) Details of ground floor level shopfronts (where proposed); D) Details of the internal space standards, unit-size mix, Lifetime Homes and Wheelchair

Standards of residential units; E) Code for Sustainable Homes Pre-Assessment; F) BREEAM Pre-Assessment; G) Daylight and Sunlight Report, including shadow plot diagrams; H) Details of playspace, amenity space and landscaping strategy (not including public open

space, the details of which are required by separate condition); I) Details of parking and servicing, both off-street and on-street and including details of Electric

Vehicle Charging Points, wheelchair accessible parking, and car club spaces; J) Details of bicycle storage for residential accommodation; bicycle storage for staff and bicycle

parking for visitors to the non-residential floorspace; K) Details of the works to the public realm and highways, including any traffic calming measures; L) Planning Statement; M) Statement of Community Involvement; N) Affordable Housing Statement; O) Updated Phasing Strategy (if relevant); P) Estate Management Plan.

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The scope and detail of each reserved matters application shall be in proportion to the amount and scale of development proposed. The development shall thereafter be carried out in accordance with the approved plans and details. Reason: In order that the LPA could be satisfied with the details of the proposed development. 5. Landscaping - Public Open Space No development shall commence in relation to any relevant Phase of development that incorporates altered, reconfigured or new public open space or allotments, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C and Section 5.4 of the approved Design and Access Statement, until the detailed design of the public open space and /or allotments have been submitted to and approved in writing by the Local Planning Authority. The submission shall include details of the following matters:

A) Updated Design and Access Statement and supporting Design Code, which shall provide details of how the design principles and commitments established by the approved Design and Access Statement and Design Code are achieved (the information shall be limited to the public open space and / or community open space);

B) soft landscaping: including grass and turf areas, shrub and herbaceous areas; C) hard landscaping: including ground surfaces, kerbs, edges, ridge and flexible paving, seating

or other public realm furniture, steps, and any synthetic surfaces; D) enclosures and boundary treatments, including types, dimensions and finishes of walls, fences,

screen walls, barriers, bollards, rails, retaining walls and hedges; E) play equipment, including safety surfacing; F) details of public art (in accordance with the strategy contained within the approved Design and

Access Statement); G) a statement detailing how the landscaping proposals contribute to the indicative mitigation

measures for nesting birds and ecological enhancements detailed within the approved Environmental Statement Technical Appendix C – Natural Heritage (prepared by Terence O’Rourke Ltd);

H) management and maintenance strategy for the first five years; and I) work phasing plan.

The development shall thereafter be carried out in accordance with the approved plans and details. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. NOTE: The details of tree protection, external lighting, soil contamination remediation and SUDS are required by separate planning conditions, however it would assist if the indicative details of such installations / measures could be provided with the above. Reason: In order that the Local Planning Authority could be satisfied with the design of the public and community open space and because the provision of the public and community open space and the associated children’s play space is required in order to provide mitigation for the loss of public and community open space within the site as a result of the proposals to develop on existing areas of designated public and community open space and in order to ensure that the resulting development is provided with an acceptable scheme of replacement public and community open space, in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.18, 7.19 and 7.21 of the London Plan 2011; 1.1(e), 1.1(i), 1.2(d), 2.1(c) and 5.5 of Ealing’s adopted Development (or Core)

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Strategy 2012; and 3.4 and 4.5 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 6. Interim Energy Strategy Notwithstanding the approved Climate Change Mitigation Strategy (Aecom) and Climate Change Adaptation Strategy (Aecom) (including the additional clarifying information), a revised Energy Strategy shall be submitted to the Local Planning Authority for written approval prior to the commencement of development on Phases 3 – 6 (inclusive). The Energy Strategy shall outline the measures to be incorporated into the development to achieve an overall (minimum) reduction in carbon dioxide emissions by 25% (regulated carbon dioxide emissions) above Building Regulations 2010, or the relevant Building Regulations at the time of the submission of the relevant Reserved Matters application. Compliance with the emissions saving target may be shown based on the calculation of carbon savings at the time that the phase is connected to the proposed district heating network. The Energy Strategy should be based on the provision of a communal heating system comprising a heat-only boiler or Combined Heat and Power (CHP) plant. The details shall include:

A) location, specification, flue arrangement, operation/management strategy; B) the method of how the facility and infrastructure shall be designed to allow for the future

connection to the heating network provided in Phase 7 of the masterplan; and C) renewable energy provision.

The relevant phase of development shall be carried out strictly in accordance with the details so approved, and the communal heating system shall be installed and operational prior to the first occupation of the development. Reason: In the interest of sustainable development and to ensure that the Local Planning Authority may be satisfied that C02 emission reduction targets by energy efficient measures/features and renewable energy are met in accordance with policies: 5.2; 5.3, 5.5, 5.6, 5.7 and 5.9 of the London Plan 2011; 1.1(k), 1.2(f), 2.1(e) and 2.3(b) of Ealing’s adopted Development (or Core) Strategy 2012. 7. Energy Strategy for dwellinghouses Notwithstanding the approved Climate Change Mitigation Strategy (Aecom) and Climate Change Adaptation Strategy (Aecom) (including the additional clarifying information), prior to the commencement of development to provide dwellinghouses, a revised energy strategy shall be submitted to and approved in writing by the Local Planning Authority. The Energy Strategy shall outline the measures to be incorporated into the development to achieve an overall (minimum) reduction in carbon dioxide emissions by 25% (regulated carbon dioxide emissions) above Building Regulations 2010, or the relevant Building Regulations and Mayor’s carbon dioxide emissions targets at the time of the submission of the relevant Reserved Matters application. In demonstrating compliance with the percentage reduction in CO2 emissions the applicant should consider the use of measures in line with the Energy Hierarchy including the incorporation of on-site renewables. The development shall thereafter be carried out in accordance with the approved details and plans. Reason: The submission of a revised energy strategy is necessary following the applicant’s confirmation that the dwellinghouses would not be connected to the site-wide heat network; to ensure that the development is energy efficient and contributes to reducing the use of fossil fuel or other primary energy generation capacity, and to reduce emissions of greenhouse gases in accordance with policies 5.2, 5.3, 5.7 and 5.9 of the London Plan 2011, policies 1.1(k), 1.2(f) and 2.3(b) of Ealing’s adopted Development (or Core) Strategy 2012.

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PRE-COMMENCEMENT CONDITIONS 8. Construction Method Statement

Prior to the commencement of development on each Phase or Development Zone (as relevant), a site construction method statement shall be submitted to and approved in writing by the Local Planning Authority. The submission shall include the following:

A) The number of on-site construction workers and details of the transport options and parking

facilities for them; B) anticipated route, anticipated number, frequency and size of construction vehicles

entering/exiting the site per day; C) delivery times and booking system (which is to be staggered to avoid morning and

afternoon school-run peak periods); D) route and location of site access for construction traffic and associated signage; E) management of consolidated or re-timed trips; F) details of the noise / vibration and dust mitigation measures to accord with the Mayor’s

'Best Practice Guidance: The control of dust and emissions from construction and demolition ' (2006) and BS 5228-1:2009 – Code of practice for noise & vibration control on construction & open sites – Part 1:Noise;

G) wheel washing facilities; H) details of site security and the erection and maintenance of security hoarding including

decorative displays and facilities for public viewing, where appropriate; I) secure, off-street loading and drop-off facilities; J) vehicle manoeuvring and turning, including swept path diagrams to demonstrate how

construction vehicles will access the site and be able to turn into and emerge from the site in forward gear and including details of any temporary vehicle access points;

K) details as to the location(s) for storage of building materials and construction debris and contractors offices;

L) procedures for on-site contractors to deal with complaints from members of the public; M) measures to consult cyclists, disabled people and the local schools (in particular

Berrymede Middle School and Berrymede Infant & Nursery School) with regard to delivery times and necessary diversions;

N) details of all pedestrian and cyclist diversions; O) a commitment to be part of Considerate Constructors Scheme; and P) confirmation of use of TfL's Freight Operator Recognition Scheme (FORS) or similar

Prior to the commencement of any site work, all sensitive properties surrounding the site shall be notified in writing of the nature and duration of the works to be undertaken, and the name and address of a responsible person to whom enquiries / complaints should be directed.

The development shall be carried out strictly in accordance with the details so approved. Any areas to be used for the storage of building materials or other site activities outside of the relevant phase of the development shall be returned to the original condition immediately following the practical completion of the development.

Reason: To ensure appropriate mitigation measures to protect the amenity of local residents and ensure adequate highway and site safety, in accordance with policies 5.18, 6.3 and 7.15 of the London Plan 2011; 1.1(f) and 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; and policies 4.4, 4.11, 9.1 and 9.9 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and the provision of SPG 10: Noise and Vibration.

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9. Site Waste Management Plan and Green Procurement Plan

Prior to the commencement of development on each Phase or Development Zone (as relevant), a Site Waste Management Plan including a Green Procurement Plan shall be submitted to and approved in writing by the Local Planning Authority. The Site Waste Management Plan and Green Procurement Plan shall demonstrate how the procurement of materials for the development would promote sustainability, including by use of low impact, sustainably sourced, reused and recycled materials, including reuse of demolition waste, use of local suppliers and by reference to the BRE’s Green Guide Specification.

The development shall be carried out in accordance with the particulars so approved.

Reason: To ensure sustainable procurement of materials which minimises the negative environmental impacts of construction in accordance with policies 5.3 and 5.18 of the London Plan 2011, policies 1.1 (k) and 1.2 (f) of Ealing’s Development (or Core) Strategy 2012 and policies 2.1 and 2.10 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 10. Mitigation of light spill and glare from any external lighting scheme Prior to the commencement of development on each Phase or Development Zone (as relevant), details to demonstrate that the proposed external lighting scheme will comply with the advice given at BS 5389 Part 9, with regards to upward light and light pollution and lighting of public amenity areas and ILE guidance on ‘Reduction of Obtrusive Lighting 2005’, shall be submitted to and approved in writing by the Local Planning Authority. The development shall thereafter be carried out in accordance with the approved details. Reason: In the interests of protecting the living conditions of existing and new residents of the development and neighbours from intrusive light spill and also ensuring that sufficient light is provided to the areas of public realm and to building entrances in the interests of safety and security, in accordance with policies 1.1(h) of Ealing’s adopted Development (or Core) Strategy 2012; 4.1, 4.4 and 4.12 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004 and the Council’s SPG 8: Safer Ealing, and policy 7.13 of the London Plan 2011. 11. Mitigation to protect habitable rooms and external amenity spaces against noise impacts Prior to the commencement of development on each Phase or Development Zone (as relevant), details in line with the criteria specified in Ealing’s adopted Supplementary Planning Guidance 10 (Noise and Vibration) shall be submitted to and approved by the Local Planning Authority, including, as appropriate, the noise exposure category and the BS4142 rating noise. The details shall also include the building envelope noise mitigation measures with windows closed and other means of ventilation provided and screening for external amenity areas where necessary. The details as approved shall be implemented prior to the first occupation of any residential units in the relevant Phase or Development Zone. Reason: To ensure a satisfactory standard of residential amenity is provided for future occupiers, in accordance with policies 3.2 and 7.15 of the London Plan 2011; policy 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; and policies 4.1 and 4.11 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004 and the Council’s SPG10: Noise and Vibration. 12. Mitigation from external plant and machinery

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Prior to the commencement of development on each Phase or Development Zone (as relevant) where plant and machinery are proposed, details shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the rating noise level emitted from the proposed plant and machinery at the proposed development, as assessed under BS4142: 1997, shall be lower than the existing background noise level by at least 5 dBA as measured at 3.5 m from the nearest ground floor sensitive facade and 1m from upper floor noise sensitive facades, during the relevant periods of operation. The details as approved shall be implemented prior to the first occupation of any residential units in the relevant Phase or Development Zone. Reason: To ensure a satisfactory standard of residential amenity is provided for future occupiers, in accordance with policies 3.2 and 7.15 of the London Plan 2011; policy 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; and policies 4.1 and 4.11 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004 and the Council’s SPG10: Noise and Vibration. 13. Air Quality Mitigation Details of the measures for air pollution mitigation for habitable rooms with frontages to Bollo Bridge Road and / or Bollo Lane and in the vicinityof the termination of the flue for the communal heating plant and the combined heat and power (CHP) plant, shall be submitted to the Local Planning Authority for written approval prior to the commencement of development of the relevant Phase or Development Zone.

The approved air pollution mitigation measures shall be incorporated into the development prior to first occupation.

Reason: The Air Quality Stage 4 Review and Assessment for the London Borough of Ealing has highlighted that this area currently experiences or is likely to experience exceedences of Government set air quality standards and air quality mitigation for the units fronting Bollo Bridge Road and Bollo Lane and in close proximity to the communal heating and CHP plant is required. It is necessary that future occupiers are not exposed to poor air quality that could have a negative impact on health and as such, mitigation would be necessary in accordance with policies: 3.2 and 7.14 of the London Plan 2011; 1.1(e) and 1.1(j) of Ealing’s Development (or Core) Strategy 2012, and 2.6 and 4.1 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 14. Piling Risk Assessment

Prior to the commencement of development on each Phase or Development Zone (as relevant), a piling risk assessment and method statement shall be submitted to and approved in writing by the Local Planning Authority.

The piling risk assessment shall demonstrate that the chosen method would not increase the risk of near-surface pollutants migrating into deeper geological formations and aquifers. The Piling Method Statement shall provide details of the type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface water or sewage infrastructure.

Reason: To ensure that any proposed piling methods do not pose a pollution risk to controlled waters, water or sewage infrastructure in accordance with policy 5.14 of the London Plan 2011, policy 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; and policy 2.1 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004).

15. Contaminated Land Investigation and Remediation

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Prior to the commencement of development on each Phase or Development Zone (as relevant), the further works described at chapter 7 of the Phase 1 Geotechnical and Geo-environmental Desk Study Report, prepared by Aecom (Job No: 60216282, July 2011) shall be undertaken and a report providing this further information along with a risk assessment, following the CLEA guidance, which shall describe the proposed methods of removal, neutralising or sealing of the contamination shall be submitted for the written approval of the Local Planning Authority.

The approved remedial works shall be implemented before any other works commence on the relevant Phase or Development zone (including public and community open space) or in accordance with an agreed works programme.

Following the completion of the approved remediation works, a verification report that demonstrates the effectiveness of the remediation carried out shall be submitted to the Local Planning Authority. The verification report shall be in accordance with the Environment Agency guidance ‘Verification of Remediation of Land Contamination’ Report: SCO30114/R1.

Reason: To remove contamination from the site in the interests of the health of the prospective occupants and to prevent pollution of the water environment in accordance with policy 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; policies 2.7 and 4.1 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and policy 5.21 of the London Plan 2011. 16. Flood Risk Assessment – Mitigation Prior to the commencement of development on each Phase or Development Zone (as relevant), a detailed surface water drainage scheme shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall be consistent with the approved Flood Risk Assessment and additional drawings and calculations prepared by SKM Colin Buchanan and shall follow the hierarchy for Sustainable Urban Drainage Systems in policy 5.13 of the London Plan, unless otherwise agreed in writing. The approved scheme shall be implemented and subsequently maintained in accordance with the approved phasing arrangements. Reason: To ensure that the site is adequately drained to reduce the risk of flooding to the proposed development and locality, and to enhance water quality and biodiversity, in accordance with the objectives of Section 11 of the NPPF; policies 5.3, 5.12, 5.13 and 5.14 of the London Plan 2011; policy 1.2(m) of Ealing’s adopted Development (or Core) Strategy, and policy 4.1 of the adopted Ealing Unitary development Plan ‘Plan for the Environment’ (2004). 17. Bat Surveys Prior to the demolition of buildings or the felling of trees identified as having a medium to high potential to support bats, the following information shall be submitted to and approved in writing by the Local Planning Authority:

A) The results of a detailed internal and external inspection of all buildings within the site with medium to high potential to support bats, as identified within the Phase 1 survey report;

B) The results of a detailed inspection for the trees identified as having potential to support bats, as identified within the Phase 1 survey report;

C) If necessary, as evidenced through the findings of sub-points (A) and (B), the results of evening emergence and dawn re-entry survey for all buildings assessed as having medium to high potential to support roosting bats; and

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D) Details of measures that have or will be incorporated into the scheme to avoid contravention of The Wildlife and Countryside Act 1981 (as amended) and The Conservation of Habitats and Species Regulations 2010

Note: The relevant buildings and trees have been identified within Chapter 6 ‘Natural Heritage’ of the approved Environmental Statement (paragraph 6.32 – one building in Phase 7, two in Phase 8, four in Phase 9, and one in Phase 10; and paragraph 6.34 – trees within Phase 3 and Phase 9) and Technical Appendix C – Natural Heritage (Phase 1 Habitat Survey, March 2011) (Terence O’Rourke Ltd). The measures identified under sub-point (D) shall be implemented in accordance with the recommendations as approved. Reason: To ensure that protected species are appropriately safeguarded, in accordance with the relevant National legislation, including The Wildlife and Countryside Act 1981 (as amended) and The Conservation of Habitats and Species Regulations 2010; and policies 5.3 and 7.19 of the London Plan 2011; 1.1(e) of Ealing’s adopted Development (or Core) Strategy 2012; and policy 3.9 of Ealing’s adopted Unitary Development Plan 'Plan for the Environment' (2004). 18. Tree Protection

No development shall commence on any Phase or Development Zone (as relevant) until details of the retention and adequate protection of all trees and tree root systems within, bordering and adjacent to that phase / development zone have been submitted to and approved in writing by the Local Planning Authority and enacted (retention/protection shall be in accordance with BS 5837, 2005 'Trees in Relation to Construction'). The details shall include a site plan identifying all trees to be retained and removed in accordance with the Arboricultural Impact Assessment ref: CBA7683 (May 2011), CBA7668 v1 Area 3 (June 2011) and approved drawings SAE_AL_100-C and SAE_AL_006-B. The details shall also including the location of Root Protection Area (RPA) and Construction Exclusion Zone (CEZ) and the erection of hoardings. The tree protection measures shall be in place prior to the commencement of the development and retained until the development has been completed. The areas enclosed by the tree protection measures shall not be used for any storage and the levels within these areas shall not be altered. Tree protecting fencing shall consist of a rigid 2.4 metre high hoarding. Heras fencing in concrete, rubber or similar foot plates are not acceptable as a form of tree root protection.

Reason: To safeguard the future of these trees and shrubs in the interests of the visual amenities and the biodiversity value of the area and the setting and character of the proposed development in accordance with policies: 7.21 of the London Plan 2011; 1.1(i) of Ealing’s adopted Development (or Core) Strategy 2012; and 4.1 and 4.5 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and SPG 9: Trees and Development Guidelines. 19. Refuse / Recyling Storage No development shall commence on any Phase or Development Zone (as relevant) until details of the dedicated refuse / recycling enclosures for that part of the development are submitted to the Local Planning Authority for written approval. The refuse and recycling facilities, as approved, shall be provided prior to the first occupation of the relevant core of development or residential unit that the enclosure serves.

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Reason: To secure the necessary recycling and waste enclosures to support the residential and non residential development and to ensure that responsible waste management practices are adhered to in the interests of the visual amenity of the area and in accordance with policy 1.1(j) of Ealing’s adopted Development (or Core) Strategy 2012; and policy 5.17 of the London Plan 2011 and policies 2.10, 4.1 and 5.5 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004), and SPG 4: Refuse and Recyling Facilities. 20. Archaeological Investigation No development shall commence on any Phase or Development Zone (as relevant) until the applicant has secured the implementation of a programme of archaeological mitigation in accordance with a Written Scheme of Investigation for that phase / development zone, which shall be submitted to and approved in writing by the Local Planning Authority. No development or demolition shall take place other than in accordance with the approved Written Scheme of Investigation. The development shall not be occupied until the site investigation and post investigation assessment has been completed in accordance with the programme set out in the approved Written Scheme of Investigation, and the provision made for analysis, publication and dissemination of the results and archive deposition has been secured. Reason: Heritage assets of archaeological interest may survive on the site. The planning authority wishes to secure the provision of archaeological investigation and the subsequent recording of the remains prior to development, in accordance with Section 12 (Conserving and enhancing the historic environment) of the National Planning Policy Framework; policy 7.8 of the London Plan 2011; policy 1.1(h) of Ealing’s adopted Development (or Core) Strategy 2012; and policy 4.9 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 21. Biodiversity Roofs and Green Walls No development shall commence on any Phase or Development Zone (as relevant) until details of biodiversity (green / brown) roofs and / or green walls, and the measures within the design of the building to support such provision are submitted to and approved in writing by the Local Planning Authority. The biodiversity roof shall:

A) Be biodiversity based with extensive substrate base (depth 80-150mm); B) Have sufficient depth of soil or growing medium for the relevant planting, including the re-use

of any demolition material where feasible; C) Be planted / seeded with an agreed mix of species within the first planting season following the

practical completion of the building works. The seed mix shall be focused on wildflower planting and shall contain no more than 25% sedum;

D) Have relevant efficient and effective drainage and irrigation to sustain the vegetation. The biodiversity roofs shall not be used as an amenity or sitting out area and shall only be accessed in the case of essential maintenance or repair. The biodiversity roofs and / or green walls shall be provided strictly in accordance with the details so approved. Reason: To ensure the development provides the maximum possible provision towards the creation of habitats and valuable areas for biodiversity in accordance with policies 5.3, 5.10, 5.11, 5.12 and 7.19 of the London Plan 2011; 1.1(j), 1.1(k) and 1.2(m) of Ealing’s adopted Development (or Core) Strategy 2012; and 3.8 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004).

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22. Rainwater / Greywater Recycling No development shall commence on any Phase or Development Zone (as relevant) until details of the further investigation of the incorporation of rainwater and / or greywater recycling systems and details of such provision within that phase / development zone are submitted to and approved in writing by the Local Planning Authority. The details shall also demonstrate the maximum level of recycled water that can feasibly be provided to the development. The rainwater and / or greywater recycling system shall be carried out strictly in accordance with the details so approved, installed and operational prior to the first occupation of the building to which it forms part, or the first use of the space in which they are contained and shall be maintained as such thereafter. Reason: To ensure the sustainable use of water in accordance with policies: 5.3, 5.13 and 5.15 of the London Plan 2011, 1.1(j), 1.1(k), 1.2(f) and 1.2(m) of Ealing’s adopted Development (or Core) Strategy 2012. DETAILS REQUIRED PRIOR TO SUPERSTRUCTURE WORKS 23. Samples of Materials Details and samples of all facing materials shall be submitted to and approved in writing by the Local Planning Authority prior to any work commencing on the superstructure of the relevant Development Zone. The samples and details shall include:

A) brickwork (including brick panels and mortar courses); B) cladding materials, including roof finishes; C) all window treatments (including sections and reveals); D) building entrance details and material samples; E) balcony structures and balustrading treatment (including sections); F) privacy screen treatment; G) energy centre, sub-station, refuse and bicycle store entrance doors and ventilation louvres; H) entrance gates to on-site car parking areas; I) any other materials to be used.

The development shall be carried out strictly in accordance with the details so approved.

Reason: In the interest of securing sustainable development and to ensure that the resulting appearance of the development is of a high standard in accordance with policies: 7.4 and 7.6 of the London Plan 2011; 1.1(h), 1.1(k), 1.2(f), 1.2(h) and 2.3(a) of Ealing’s Development (or Core) Strategy 2012, and 4.1 and 5.5 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 24. New Street Trees – Pit Details

Full details of all street tree pits including their locations, dimensions and depths in relation to ground levels, underground services, car-parking bays and hard landscaping shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of superstructure works on the relevant Development Zone. New tree planting shall accord, where feasible following further detailed investigative surveys, with the mitigation strategy contained at section 4.3 of the approved Design and Access Statement. The replacement and new tree planting within the site shall be agreed under the detailed submission of information required via conditions 4 and 5 of this permission.

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The development shall be carried out strictly in accordance with the details so approved.

Reason: To secure the appropriate provision and development of the proposed street-trees and to ensure that the life of the trees would not be unduly constrained in accordance with policies 5.10, 7.4, 7.5 and 7.21 of the London Plan 2011; policy 1.1(i) of Ealing’s adopted Development (or Core) Strategy 2012; and policies 4.1 and 4.5 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and SPG 9: Trees and Development Guidelines. 25. Boundary Treatment Details of boundary treatment(s) shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of superstructure works on the relevant Development Zone. The details shall include all walls, fencing, gates, footings, their design, appearance and materials. The boundary treatments shall be carried out strictly in accordance with the details so approved, installed/erected/operational prior to the first occupation of the development. Reason:To ensure that the resulting boundary treatment(s) is functional, attractive and secure in accordance with policies: 7.3, 7.4, 7.6 and 7.13 of the London Plan 2011 and 4.1, 4.4 and 5.5 of Ealing’s adopted Unitary Development Plan ‘Plan for the Environment’ (2004) and 1.1(h)of Ealing’s adopted Development (Core) Strategy 2012. 26. CCTV/Lighting/Security Lighting/Secure Entrances/Post Boxes Details of the general security measures shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of superstructure works on the relevant Development Zone. The details shall incorporate:

A) CCTV; B) Security Ligting; C) Location, access and design of post-boxes; and D) Design, location and details of entry systems

The agreed security features shall be installed and be operational prior to the first occupation of the development. Reason: To ensure that the security lighting and CCTV cameras are appropriately located and designed to not unduly affect the residential amenity of the occupiers of the development and neighbouring properties, are appropriate to the overall design of the building and are adequate to promote safety and security, in accordance with policies 7.3, 7.6 and 7.13 of the London Plan 2011, policy 1.1(e) and 1.1(h) of Ealing’s adopted Development (or Core) Strategy 2012 and policies 4.1, 4.4 and 4.12 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and the Council’s SPG 8: Safer Ealing. PRESCRIPTIVE STANDARDS OF THE DEVELOPMENT 27. Electric Vehicle Charging Points

Each Phase of development shall provide a minimum of 20% of the parking spaces with equipped active charging points for electric vehicles with an additional 20% of spaces equipped with passive charging provision prior to the first occupation of the development. The details of such provision shall be submitted in accordance with the requirements of condition 4 of this permission.

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The measures to monitor the uptake of the electric vehicle charging points and need to bring into use the passive charging provision shall be undertaken as part of the Travel Plan review, the details of which are set out within the S106 agreement.

Reason: In the interest of the environment and improving air quality, in accordance with policy 6.13 of the London Plan 2011 and policy 1.2(k) of Ealing’s Development (or Core) Strategy 2012.

28. Lifetime Homes

Residential units shall be constructed to Lifetime Homes Standards, the details of which shall be provided in accordance with the requirements of condition 4 of this permission.

Reason: To ensure that the development is adaptable, flexible, convenient and appropriate to the changing needs of the future occupiers, in accordance with policies: 3.5, 3.8 and 3.9 of the London Plan 2011; 1.1(h) of Ealing’s adopted Development (or Core) Strategy; and 4.1, 4.3 and 5.3 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004) and Supplementary Planning Guidance 7 'Accessible Ealing'.

29. Wheelchair Housing

10% of the residential units shall be provided to Wheelchair Adaptable / Wheelchair Accessible Standards and such provision shall be provided across a mix of bed-sizes and tenures within each Phase of the development. The details of such provision shall be submitted in accordance with the requirements of condition 4 of this permission. The Wheelchair Accessible / Wheelchair Adaptable units shall be provided prior to the first occupation of the development.

Reason: To ensure the provision of wheelchair housing as agreed in a timely fashion that would address the current unmet housing need; produce a sustainable mix of accommodation; and provide appropriate choices and housing opportunities for wheelchair users and their families, in accordance with policies: 3.5, 3.8, and 3.9 of the London Plan 2011; policy 1.1(h) of Ealing’s adopted Development (or Core) Strategy; and policy 5.3 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004), and SPG 7: Accessible Ealing. 30. Code for Sustainable Homes The development shall achieve a Code of Sustainable Homes rating of no less than ‘Level 4’. The details of the Code for Sustainable Homes pre-assessment shall be submitted in accordance with the requirements of condition 4 of this permission. Within six months of the commencement of the development on each phase or development zone, evidence that the development is registered with the Building Research Establishment (BRE) (or similar approved body) under the Code for Sustainable Homes and an Interim Code for Sustainable Homes Assessment and Interim Design Certificates shall be submitted to the Local Planning Authority for written approval.

A Post-Construction Code for Sustainable Homes Assessment and Certificates shall be submitted to the Local Planning Authority as soon as practically possible following the completion of the development, confirming that the agreed sustainability measures have been achieved. Reason: In the interest of addressing climate change and securing sustainable development in accordance with policies: 3.5, 5.1; 5.2; 5.3 and 5.9 of the London Plan 2011; 1.1 (k) and 1.2(f) of

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Ealing’s adopted Development (or Core) Strategy 2012; and 2.1; 4.1; and 5.5 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 31. BREEAM The development shall achieve a BREEAM New Construction rating (2011) of no less than 'Excellent’, unless otherwise agreed in writing by the Local Planning Authority. The details of the BREEAM pre-assessment shall be submitted in accordance with the requirements of condition 4 of this permission. Interim Design Certificates shall be submitted to and approved in writing by the Local Planning Authority within six months of the commencement of the development on each phase or development zone. The development shall be carried out strictly in accordance with the details so approved, shall achieve the agreed rating(s) and shall be maintained as such thereafter. Reason: In the interest of addressing climate change and securing sustainable development in accordance with policies: 5.1; 5.2; 5.3; and 5.9 of the London Plan 2011; 1.1 (k) and 1.2(f) of Ealing’s adopted Development (or Core) Strategy 2012; and 2.1 and 4.1 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). OPEN SPACE AND COMMUNITY FACILITY PROVISION 32. Restrictions on the commencement of Block 3.2 – Caine House Temporary Open Space No development shall commence in relation to Block 3.2, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C and Section 5.4 of the approved Design and Access Statement, until the detailed design of the temporary public open space on the former Caine House site has been submitted to and approved in writing by the LPA. The submission shall include details of the following matters:

A) soft landscaping: including grass and turf areas, shrub and herbaceous areas; B) hard landscaping: including ground surfaces, kerbs, edges, paving, seating and other public

realm furniture, steps, and any synthetic surfaces; C) enclosures and boundary treatments, including types, dimensions and finishes of walls, fences,

screen walls, barriers, bollards, rails, retaining walls and hedges; D) play equipment, including safety surfacing; E) management and maintenance strategy; and F) work phasing plan.

The approved scheme shall be completed / planted during the first planting season following the demolition of Caine House, or in accordance with the approved work phasing plan. No residential units within Blocks 3.1 or 3.2 shall be occupied until the temporary public open space is ready for use. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. The temporary open space shall be maintained in accordance with the approved management and maintenance strategy until such time that the site is required for development purposes in accordance with the approved phasing strategy. Reason: The provision of the temporary public open space (estimated to be 1,670sqm) and associated children’s play space is required in order to provide mitigation for the temporary loss of

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public open space within the site as a result of the proposals to develop on existing areas of designated public open space and in accordance with the requirements set out at paragraph 74 of the NPPF and policies 7.18 of the London Plan 2011; 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012; and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 33. Restrictions on the commencement of Block 3.2 – Bollo Brook Youth Centre No development shall commence in relation to Block 3.2, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C and Section 5.4 of the approved Design and Access Statement, until details of the temporary replacement youth centre, which shall have a minimum gross internal area of at least the equivalent gross internal area of the existing facility, are submitted to and approved in writing by the LPA. The submission shall include details of the following matters:

A) Siting of the youth centre within Bollo Brook Park; B) Detailed design of the centre, including floor, elevation and section plans; C) Details of access to the youth centre from Bollo Bridge Road (to the south), Osborne Road (to

the north) and Berrymede Middle School (if relevant); D) Details of any access restrictions, external lighting and CCTV (the requirements should be

discussed with the Crime Prevention Design Officer); E) Management strategy for the day-to-day operation of the centre (which may need to be

prepared in consultation with the Council’s Youth Service). II) The temporary youth centre shall be completed and ready for use prior to the demolition of the existing Bollo Brook Youth Centre and maintained until alternative provision is provided within Phase 6 of the development or as otherwise agreed in writing with the LPA. III) The temporary youth centre shall not operate outside of the hours of 9:00am and 10:00pm Monday to Friday and 9:00am and 8:00pm on Saturday, Sunday and Public / Bank Holidays. IV) Following the relocation of the youth centre to the permanent facility within Phase 6, the temporary centre shall be removed from Bollo Brook Park within three months of the opening of the permanent facility and the area shall be landscaped in accordance with a landscape strategy to be submitted to and approved in writing by the Local Planning Authority. Reason: To ensure continuity of the provision of essential community facilities within the site; to ensure that the LPA could be satisfied with the layout, design, management and operation of the facility in the interest of protecting the amenity of the neighbouring residential properties and also protecting the primary function of the public open space; to ensure that the facility is designed to be accessible by wheelchair users; to ensure that adequate security features are installed; and in accordance with policies 3.1, 3.2, 3.16, 7.1, 7.2, 7.3, 7.6, 7.13 and 7.15 of the London Plan 2011; 1.1(e), 1.1(h) and 6.2 of Ealing’s adopted Development (or Core) Strategy 2012; and 4.1, 4.3, 4.4, 4.5, 4.11, 8.1 and 8.6 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 34. Restrictions on the Occupation of Phase 3 – Station Square Open Space Station Square shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the first occupation of the residential units in Block 3.1, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season.

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Station Square shall be maintained in accordance with the approved management and maintenance strategy (required by condition 5) until such time that the Local Highways Authority adopts the area, or in perpetuity in the case that the area is not adopted by the Council. Reason: Station Square is an integral and significant part of the development within this southern periphery site that is required in order to mitigate the interim loss of public open space within the application site as a result of the indicative phasing of the masterplan. The delivery of Station Square would substantially improve the quality, usability and appearance of the public realm outside of South Acton Overground Station, and the completion of this area of public realm works will signal the last phase of the development within this part of the estate. The provision of Station Square is required in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan 2011 and 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012, and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 35. Restrictions on the Occupation of Phase 4 – West Park West Park shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the occupation of 51% of the residential units in Block 4, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. West Park shall be maintained in accordance with the approved management and maintenance strategy (required by condition 5) until such a time that the Council adopts the area, or in perpetuity in the case that the area is not adopted by the Council. Reason: The provision of West Park is an integral and significant part of the development required in order to mitigate the loss of the existing South Park designated Public Open Space, and to ensure that open space is provided for the benefit of the local community, and in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan 2011 and 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012, and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 36. Restrictions on the Occupation of Phase 6 – Central Plaza Central Plaza shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the occupation of 51% of the residential units in Block 6.2, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. Central Plaza shall thereafter be maintained in perpetuity in accordance with the approved management and maintenance strategy required by the accompanying S106 agreement, unless the area is adopted by the Council.

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Reason: The provision of Central Plaza is an integral and significant part of the development required in order to mitigate the loss of the existing South Park designated Public Open Space, and to ensure that open space is provided for the benefit of the local community, and in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan 2011 and 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012; and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 37. Restrictions on the Demolition in Phase 6 – Community Centre re-provision The Oak Tree Community Centre shall not be demolished until a replacement community facility of at least 750sqm gross internal area has been constructed, fully fitted out and is ready for use, in accordance with the design principles and phasing strategy set out in the approved Design and Access Statement and supporting Design Code, and with the details so approved under the relevant reserved matters application (required by conditions 2 and 4 of this permission), unless otherwise agreed in writing by the Local Planning Authority. The community centre shall thereafter be maintained in accordance with the approved management and maintenance strategy required by the accompanying S106 agreement in perpetuity Reason: To ensure continuity of the provision of essential community facilities within the site, in accordance with the objectives outlined in Section 8 of the NPPF; policies 3.1, 3.2 and 3.16 of the London Plan 2011; 6.2 of Ealing’s adopted Development (or Core) Strategy 2012; and 8.1 and 8.6 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 38. Restrictions on the Occupation of Phase 7 – Hope Gardens Hope Gardens shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the occupation of 51% of the residential units in Block 7.4, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C. Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. Hope Gardens shall be maintained in accordance with the approved management and maintenance strategy (required by condition 5) until such time that the Council adopts the area, or in perpetuity in the case that the area is not adopted by the Council. Reason: The provision of Hope Gardens is an integral and significant part of the development required in order to ensure that open space is provided for the benefit of the local community, and in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan 2011 and 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012, and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 39. Restrictions on the Occupation of Phase 8 – North Park North Park shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the occupation of 51% of the residential units in Block 8.1, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C.

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Any trees or shrubs that die within five years of planting shall be replaced with the same species or an approved alternative and to the satisfaction of the Local Planning Authority during the next planting season. North Park shall be maintained in accordance with the approved management and maintenance strategy (required by condition 5) until such a time that the Council adopts the area, or in perpetuity in the case that the area is not adopted by the Council. Reason: The provision of North Park is an integral and significant part of the development in order to mitigate the loss of the existing designated Public Open Space, particularly as a result of the reconfiguration of Avenue Road Park, and to ensure that open space is provided for the benefit of the local community, and in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan 2011 and 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development (or Core) Strategy 2012; and 3.4 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 40. Restrictions on the Occupation of Phase 9 – Allotments The re-configured Jerome Tower allotments and new allotments shall be provided in accordance with the details so approved under the relevant reserved matters application (required by conditions 2 and 5 of this permission) prior to the occupation of 51% of the residential units in Block 8.1, as illustrated on the approved Parameter Plan SAE_AL_100 Rev C. The allotments shall thereafter be maintained in accordance with the approved management and maintenance strategy required by the accompanying S106 agreement in perpetuity. Reason: The provision of the community allotments is an integral and significant part of the development in order to mitigate the loss of the existing designated Community Open Space, and to ensure that allotments are provided for the benefit of the local community, and in order that the development is provided in accordance with the policy requirements set out at paragraph 74 of the NPPF and policies 7.22 of the London Plan 2011 and 3.6 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 41. District Heating Network No more than 1300 new dwellings shall be occupied within the development prior to the construction and operation of the main Energy Centre (comprising the district-heating network), which shall have a minimum floor area of 650sqm and contain combined heat and power (CHP) plant that will total, when the overall development is built out, at least 800 kilowatts electrical capacity. After the energy centre is operational, all new residential buildings within the Development, with the exception of dwelling houses, shall be connected to the district-heating network before first occupation unless otherwise agreed in writing by the Local Planning Authority. Prior to the occupation of 85% of the residential units in Phase 8, the connection of the residential and non-residential units in Phases 1, 2, 3 (south), 6, 7 and 8 of the overall development to the district- heating network shall be provided, which shall thereafter be the sole source of heat to these properties. Prior to the occupation of 85% of the residential units in Phase 9, the connection of the residential and non-residential units in Phases 3 (west), 4, 5 and 9 of the overall development to the district -heating network shall be provided, which shall thereafter be the sole source of heat to these properties.

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Reason: In the interest of securing the centralised energy centre for the site and its sustainable connection to the various uses within the development in accordance with policies: 5.2; 5.3 and 5.6 of the London Plan 2011; 1.1(k), 1.2(f), 2.1(e) and 2.3(b) of Ealing’s adopted Development (or Core) Strategy 2012. NON – RESIDENTIAL USES 42. Quantum of non-residential floorspace & Hours of Use The gross internal floor areas of the non-residential development shall comply with the details indicated on Parameter Plan SAE_AL_102-F and set out below: Area 1 (Phase 3) – (maximum) 200sqm flexible A1 (retail) / A3 (restaurant and café) / B1 (business) / D1 (non-residential institutions) Use Classes. Area 2 (Phase 6) – (minimum) 926sqm D1 (non-residential institutions) Use Class, for the re-provision of Bollo Brook Youth Centre and Oak Tree Community Centre. Area 2 (Phase 6) – (maximum) 1,422sqm flexible D1 (non-residential institutions) / B1a (office) Use Classes. Area 2 (Phase 6) – (maximum) 450sqm A1 (retail) and (maximum) 200sqm flexible A1 (retail) / A3 (restaurant and café) / B1a (office) Use Classes. Area 3 (Phase 9) – (maximum) 200sqm flexible A1 (retail) / A3 (restaurant and café) / B1a (office) / D1 (non-residential institutions) Use Classes. Should the flexible commercial units hereby approved be used in an A1 (retail), A3 (café / restaurant) or D1 (non-residential institutions) Use Class, the units shall not operate outside of the hours of 7:00am and 11:00pm Monday to Saturday and 9:00am and 10:00pm on Sunday and Public / Bank Holidays. The community centre premises shall not be used other than between the hours of 8:00am and 11:00pm Monday to Saturday and 9:00am-10:00pm on Sunday and Public / Bank Holidays. Reason: To ensure that the proposed development is carried out in accordance with the approved details; in the interests of safeguarding the viability of the Acton District Centre whilst providing commercial and leisure facilities of a local nature to meet the day-to-day needs of the residents of the development; to ensure that community facilities are reprovided for the residents of the estate; and to ensure that the operation of the proposed retail, food and drink and leisure facilities does not adversely impact on neighbouring residential amenity in accordance with policies 3.1, 3.2, 3.16 and 4.8 of the London Plan 2011; 1.1(a), 1.1(b), 1.1(c), 1.1(d), 1.1(e), 1.2(c), 1.2(d) and 6.2 of Ealing’s Development (or Core) Strategy 2012; and 4.1, 4.2, 4.11, 7.3, 7.5, 7.6, 7.7, 8.1, 8.6, 8.7 and 8.8 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 43. D1 Use Excluding Place of Worship Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 1987 (or any order revoking and re-enacting that Order with or without modification), the D1 (non-residential institutions) floorspace shall be strictly limited to uses within Use Class D1(a-g) only. No planning permission is hereby granted for purposes within Use Class D1(h) – Place of Worship, of the Schedule to the Town and Country Planning (Use Class) Order 1987, as amended (or the equivalent use within any amended / updated or subsequent Order).

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Reason: To prevent the use of the D1 floorspace as a place of worship in the interest of protecting existing and future residential amenity; to ensure that the future occupation and use of the premises shall be in accordance with the policies on protecting amenity; and in accordance with policies 3.1, 3.2 and 3.16 of the London Plan 2011; 6.2 of Ealing’s Development (or Core) Strategy 2012; and 4.1, 4.2, 4.11, 8.1, 8.6, 8.7 and 8.8 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004). 44. Extract equipment for odour control – A3 use

Details shall be submitted for the written approval of the Local Planning Authority prior to the first use of any proposed A3 (café and restaurant) Use Class, for the installation, operation, and maintenance of the best practicable odour abatement equipment including an extract system, the height of the discharge, and the efflux velocity of the effluent at the point of discharge.

The system, as approved, shall be completed and operational before the first use of the A3 premises and thereafter permanently retained.

Reason: To protect the living conditions of the occupiers of neighbouring properties in accordance with policies 1.1(h) of Ealing’s adopted Development (or Core) Strategy and 4.1 and 7.6 of the adopted Ealing Unitary Development Plan 'Plan for the Environment' (2004). 45. Removal of Permitted Development Rights - Houses

Notwithstanding the provision of the Town and Country Planning (General Permitted Development) Order 1995 (or any order revoking and re-enacting that Order with or without modification) no development to any dwellinghouse provided within the development falling within Schedule 2, Part 1, Classes A, B, C, D or E shall be carried out except with the prior permission of the Local Planning Authority.

Reason: To enable the Local Planning Authority to maintain control over extensions and other alterations to dwellinghouses in the interests of the design and character of the properties, the visual amenities of the locality and amenities of occupiers of neighbouring properties in accordance with policies 7.1, 7.4 and 7.6 of the London Plan 2011, policies 4.1, 5.5 and 5.9 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ (2004) and policies 1.1(h), 1.2(f) and 2.3(a) of the Ealing’s adopted Development (or core) Strateg 2012.

REASON FOR GRANT

1. The decision to grant outline planning permission has been taken by the Council’s Planning Committee following consultation with the Mayor of London and taking into consideration the relevant National, Strategic and Local Planning policies contained within the Development Plan, and the information provided in the applicant’s Environmental Statement. - The South Acton Estate is identified as an area for regeneration on Map 2.5 and corresponding policy 2.14 of the London Plan and policy 2.3 of Ealing’s adopted Development Strategy. The council's Estates Review report and policy 2.3 of Ealing’s Development Strategy confirm that South Acton Estate is in need of a holistic approach to regeneration to create a new neighbourhood and to tackle the existing problems, including the poor condition of the housing and blocks, poor layout, lack of cohesion on the estate and disintegration with the surrounding locality and its status as a largely mono-tenure estate and associated stigma. In considering the failings of the existing estate and the site’s opportunities, it was accepted that the proposed redevelopment approach would provide the necessary opportunities in terms of masterplanning; architectural cohesion and proper co-ordination and planning and long-term management and maintenance of the new neighbourhood. The significant opportunities provided by the redevelopment approach were considered to outweigh the individual objections to the proposals.

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- The residential-led proposals would replace all existing affordable accommodation on a habitable room basis and would also indicatively provide an additional number of habitable rooms in affordable tenure, subject to further financial viability testing on a phased basis. The proposal would also re-provide housing suitable for elderly residents, which was considered as part of the affordable housing provision. The delivery of affordable housing and the requirement for the submission of a financial viability assessment on a phased basis is secured within the accompanying S106 Agreement. The proposal was considered to be broadly in accordance with policies 3.10, 3.11, 3.12, 3.13 and 3.14 of the London Plan; policies 1.2(a) and 2.3(a) of Ealing’s adopted Development Strategy; and policy 5.2 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The proposal would also fully re-provide residential units in private sale tenure and provide additional private sale units, in accordance with policy 3.14 of the London Plan; policies 1.1(a), 2.1(a) and 2.3(a) of Ealing’s adopted Development Strategy; - South Acton Estate forms an integral part of Ealing's estate regeneration programme and is planned to deliver a large proportion of the 1400 net additional units that this programme will provide over the next 5 years. The regeneration programme in turn is essential to Ealing's housing trajectory, particularly in ensuring housing delivery in the early stages of the adopted Development Strategy. The development was therefore considered to comply with the relevant considerations under paragraph 47 of the National Planning Policy Framework (NPPF) and policies 3.3, 3.11, 3.12 and 3.14 of the London Plan and policies 1.2(a) and 2.1 of Ealing’s adopted Development Strategy. - The masterplan proposals would provide a range of unit sizes appropriate for family and non-family occupation and in a range of tenures, helping to create mixed and balanced communities. The proposals would also indicatively comply with, and in some circumstances exceed the London Plan minimum internal space standards for new development; would be designed to achieve the Secured by Design accreditation post-completion; would meet a minimum Level 4 of the Code for Sustainable Homes; would be built to Lifetime Homes Standards and 10% of housing would be suitable for wheelchair users. The development would also be tenure blind so that there would be no distinguishable difference between the appearance of the various tenures of accommodation. Conditions requiring that appropriate mitigation for contaminated land remediation, noise, vibration and air pollution mitigation were included within the recommendation, in the interest of protecting residential amenity and health. Consequently, the proposals were considered to comply with sections 6 and 7 of the NPPF; policies 3.5, 3.8, 3.9, 5.2 and 7.3 of the London Plan; policies 1.1(h), 1.1(k) and 1.2(f) of Ealing’s adopted Development Strategy; and policies 2.7, 4.3, 4.4, 4.11, 5.3 and 5.5 of the adopted Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The indicative layout, scale and density of the development was considered to be acceptable and broadly consistent with good urban design principles, delivered through the integration of the site to its surroundings, re-establishing a street grid with improved north-south links, creating a network of open spaces and responding to context and scale, and helping to reinforce the different character areas of the application site. The impact on the townscape character and adjoining conservation areas was also considered to be acceptable, subject to the detailed design of the development at reserved matters stage. The proposals would be guided by a Design and Access Statement and Design Code. The proposals were considered to be in general conformity with sections 6 and 7 of the NPPF, policies 7.1, 7.2, 7.3, 7.4, 7.5, 7.7 and 7.8 of the London Plan; policies 1.1(h), 1.2(g) and 1.2(h) of Ealing’s Development Strategy; and policies 4.1, 4.5 and 5.5 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The impact of the masterplan proposals on neighbouring occupiers was considered, particularly in relation to outlook, privacy, sunlight and daylight. The applicant’s Environmental Statement also considered the impact of the development on air quality, noise and vibration, and traffic. It was acknowledged that the application was made in outline with all matters reserved for later determination

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and that further consideration of the impacts of the development on neighbours would be necessary. However, it was considered that the proposals would be unlikely to have a detrimental impact on the amenity of neighbouring occupiers, in accordance with policies 4.1 and 5.5 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The masterplan would re-provide community, retail, café / restaurant and office uses mainly within a central hub, adjoining the existing Berrymede Infant and Junior Schools and areas of public open space. The location, phasing and adequacy of the proposed community facilities was considered to be acceptable and to be in accordance with policies 1.1(e) and 1.2(d) of Ealing’s adopted Development Strategy and policies 8.1, 8.2, 8.3 and 8.6 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004. The proposed re-provision and small uplift in retail floorspace raised no significant land use concerns. Although it was acknowledged that there are suitable and viable sites for new retail development in Acton district centre, it was considered that the amount of retail floorspace proposed within the development would not have an unacceptable impact on the district centre and is likely to be occupied by convenience retailers mainly serving residents of the completed development. It was considered that the proposals were in general conformity with section 8 (and in particular paragraph 70) of the NPPF; policies 3.1, 4.8, 7.1 and 7.5 of the London Plan; policy 1.1(a), 1.1(b) and 1.1(d) of Ealing’s Development Strategy; and policy 7.5 of Ealing’s UDP. - The proposals for private and semi-private amenity space, play space, and the re-provision and phasing of public and community open space were considered to be broadly acceptable and to accord with paragraph 74 of the NPPF; policies 7.2, 7.3, 7.5, 7.18 and 7.22 of the London Plan; policies 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s adopted Development Strategy; and policies 3.4, 3.5, 3.6, 3.8, 4.1, 4.5, 5.5 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004. It was also considered that the proposals for tree retention, removal and re-provision were broadly in accordance with policy 7.21 of the London Plan and policies 3.8, 3.9 and 4.5 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The proportion of car parking (including wheelchair accessible spaces and electric vehicle charging points) was considered to be acceptable, subject to proposed improvements to the pedestrian and cycling network, provision of car club spaces and other measures to reduce the reliance on the private motor vehicle, to be secured through a Travel Plan. TfL have indicated that they have plans to provide a re-routed or extended bus service through the site and appropriate contributions have been sought through the S106 Agreement to assist with the funding of such services. The Council’s Transport Service confirmed that the vehicle trip generation from the development would not be significant and the results of the detailed modelling indicate that the existing road network could accommodate the additional flows from the development and operate with spare capacity. It was considered that the proposals were in conformity with section 4 of the NPPF and policies 6.2, 6.3, 6.5, 6.7, 6.9, 6.10, 6.11, 6.12 and 6.13 of the London Plan; policies 1.1(f), 1.1(g), 1.1(j), 1.2(f), 1.2(h) and 1.2(k) of Ealing’s Development Strategy; and policies 9.1, 9.4, 9.7, 9.8 and 9.9 of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004; - The masterplan would incorporate a site-wide district heat network, in accordance with policies 5.5 and 5.6 of the London Plan, and policy 2.3(b) of Ealing’s adopted Development Strategy. The sustainability measures to be incorporated into the development to reduce the energy use of the development, minimise on-site carbon dioxide emissions, enhance biodiversity, and reduce the risk of flooding include green roofs, sustainable urban drainage systems, renewable energy technologies, enhanced building fabric and efficient building services. Such measures were considered to be acceptable and broadly in accordance with the requirements of policies 5.2, 5.3, 5.7, 5.10, 5.12 and 5.13 of the London Plan; policies 1.1(e), 1.1(j), 1.1(k) and1.2(f) of Ealing’s Development Strategy; - Consideration was given to the objections made to the proposed development. It was considered that none of the objections were sufficient to outweigh the reasons for granting planning permission.

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INFORMATIVES 1) This planning permission is also subject to a Legal Agreement under Section 106 of the Town and

Country Planning Act 1990. 2) In addition to S106 contributions and other requirements, the Mayor’s Community Infrastructure

Levy (CIL) was adopted on 01/04/2012. This has introduced a charging system within Ealing of £35 per sqm of gross internal area of the additional floorspace created by the development to be paid to the Council. The liable sum for each phase of the development will be determined at detailed reserved matters stage.

3) Construction and demolition works, audible beyond the boundary of the site shall only be carried

on between the hours of 0800 - 1800hrs Mondays to Fridays and 0800 - 1300hrs on Saturdays and at no other times, including Sundays and Bank Holidays.

The maximum permitted noise levels are:

not greater than 72 dB LAeq,10hr Mondays to Fridays not greater than 72 dB LAeq,5hr Saturdays

4) Vibration from demolition, breaking of concrete and piling etc., as measured in the vertical direction

on any floor in surrounding noise sensitive buildings, shall not exceed an overall peak particle velocity level of 1mm/s.

5) Prior to commencement of construction works details of noise/ vibration and dust mitigation

measures shall be submitted to the planning authority for approval, as required by the relevant condition of this permission. The information submitted should directly cross-reference with the best practice and mitigation measures as detailed in following guidance:

London Councils/Greater London Authority Best Practice Guidance The Control of Dust and Emissions from Construction and Demolition, 2006. BS 5228-1:2009 - Code of practice for noise & vibration control on construction & open sites-Part 1: Noise

6) No bonfires shall be lit on site. 7) Stone crushing plant may require authorisation under the Environmental Protection Act

(Prescribed Processes and Substances) Regulations 1991, SI 472. Contact the LBE Pollution Control Section on 020 8825 5633.

8) The applicants’ attention is drawn to the comments provided by Thames Water (and subsequently

made available to Terence O’Rourke Ltd) regarding water infrastructure capacity. It is noted that Thames Water has confirmed that arrangements have already been made with the applicant for a further study into the water infrastructure requirements for the development.

10) The Council’s Transport Planning Service have recommended that the two-way running lane of the

new Boulevard, which will accommodate the re-routed bus service between Avenue Road and Bollo Bridge Road should be increased to 11m. If this is found to be feasible, the details shall be submitted in accordance with the requirements of condition 4 of this permission. If this road width is not provided, this would need to be justified as part of the details.

11) The exhaust stack (or equivalent) serving the Combined Heat and Power boilers will most likely

require an application for the approval of the chimney height under Section 6 of the Clean Air Act

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1993; details shall therefore be submitted to the Pollution Control Section of the Environmental Health Department for approval before the development is commenced. Please contact Dr John Freeman, Tel 020 8825 7226 if further information or discussion is required.

12) The applicant should be mindful that existing shopkeepers and the hotelier on the estate have

objected to the proposals principally due to the loss of their existing businesses. Whilst the Development Plan does not contain any policies that seek to protect individual business owners, the applicant is encouraged to continue an open dialogue with the owners of the local businesses in relation to the options that may be available to them for re-provision within the Acton Gardens masterplan or alternative provision.

13) The London Fire and Emergency Planning Authority advise that the development will need to

comply with Part B of the Approved Documents of Building Regulations. 14) An easement agreement for access to service underground storm water tanks under land adopted

by the Council will be necessary. 15) The applicant is advised that it will be necessary to enter into a S278 / S38 Agreement(s) with the

Local Highways Authority (LHA) in relation to the various proposed works to existing adopted highways and other areas that have been identified as potentially being adopted by the LHA. A summary of the works may include: - Provision of new footpaths, signage and tactile paving to Bollo Lane and Avenue Road, as

identified within the submitted PERS audit; - Provision of a wheeling ramp at the pedestrian footbridge providing access between the northern

and southern sides of the London Overground railway line and Kingswood Terrace; - Provision of a bus stand and new bus stops within the application site; - Provision of new roads within the application site and Station Square at the southern end of

Palmerston Road; - Provision of traffic calming measures, including but not limited to a raised table on Bollo Bridge

Road between the junctions with Stanley Road and All Saint’s Road; - Provision of new footpaths throughout the application site.

APPLICATION SITE AND BACKGROUND Site Description South Acton Estate is the largest municipal housing estate currently owned and managed by the London Borough of Ealing. The estate is located within the South Acton Ward and covers an area of approximately 28.68ha. The outline planning application site covers a smaller area of approximately 21.07ha, which excludes the existing schools (Berrymede Infant & Nursery School, Berrymede Middle School, and South Acton Children’s Centre) and other residential buildings constructed within the estate since 2001. It is estimated that there are currently 339 residential units in a combination of leashold and freehold tenure, and 1356 units in social rented tenure within the application site (total of 1695 units). The extensive area of the site is broadly bound to the north by Mill Hill Road; to the south by the London Overground railway line and Rowley Industrial Estate; to the east by Brouncker Road and the rear of predominantly Victorian housing in Church Road and Berrymead Gardens; and to the west by properties in Avenue Road, Avenue Gardens, Heathfield Road (all within the Mill Hill Park Conservation Area) and Bollo Lane. The estate is mainly comprised of flatted development in medium to high-rise blocks (up to 17-storeys) constructed in the 1950s, 60s and 70s following clearance of 19th century Victorian properties. The majority of existing buildings are in poor condition. The central part of the site comprises 1960’s tower

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and slab blocks, includes a small number of non-residential uses and community uses including the Oak Tree Centre. Berrymede Middle School, which dates from the Victorian period, and Berrymede Infant & Nursery School are also located in the centre of the site. The northern part of the site is known as the ‘red brick’ area and dates from the 1970’s and comprises blocks of flats between 3 and 11 storeys and unused undercroft parking areas. The red brick area is closest to Acton district centre, which is approximately 5-minutes walk to the north. The western part of the estate consists of 1960’s slab blocks, Hanbury Road shops and other community facilities, Jerome Tower Allotments and South Park. The Bollo Bridge Youth Centre is currently located in South Park. The Osborne Hotel, a former public house, is also located within the western part of the site along Osborne Road. The hotel was granted planning permission first in 1999 and later in 2005 for a change of use to a 12-room hotel. The southern part of the estate, to the south of Bollo Bridge Road, has been substantially redeveloped since 2007 and includes 2 and 3 storey houses and flat buildings of between 4, 6, 7, 8 and 10 storeys. Phases 1 and 2 of the Acton Gardens masterplan proposals are also sited within with southern part of the estate. South Acton Recreation Ground is located on the western side of All Saint’s Road, opposite the Phase 1 site. The South Acton allotments are located alongside the London Overground railway line, at the southern end of Palmerston Road and Stanley Road. The site contains a number of designated areas of open space and community space, including South Park, Bollo Brook Park, Avenue Road Recreation Ground, and South Acton Recreation Ground, the South Acton Allotments and Jerome Tower Allotments. There is also the newly designated Bollo Bridge Rest Gardens within the northern part of the former Blackmore Tower site. This now vacant overall site presently enclosed by hoardings comprises the Phase 2 application site. There are equipped areas of play and sport facilities distributed across the estate. A key finding of the applicants’ pre-application consultation was that the majority of existing residents consider the existing open spaces within the site as an asset to the area, but that they require a great deal of attention and upgrading. South Acton Overground station is located at the southern periphery of the site and Acton Town Underground station is located a short distance to the northwest of the site. Bus stops serving the eastbound and westbound 440 bus route are located along Bollo Bridge Road, which provides the main east-west link through the site. Acton district centre is located immediately to the north of the site. The GLA’s Stage I response confirmed that the Public Transport Accessibility Level (PTAL) of the site varies between three to six, with the northern part of the site generally having a higher PTAL then the other areas of the site. The Mill Hill Park and Acton Town Conservation Areas abut the northern and western parts of the site. There are statutory listed buildings in close proximity to the site in the two conservation areas, and in particular, Avenue Road, Church Road and Crown Street. Part of the site, to the west of Bollo Brook Park and to the north of Cheltenham Place, fall within an Archaeological Interest Area (AIA). The residential area of Acton Green lies to the south of the London Overground railway line. The low-rise housing to the south and east predominantly dates from the Victorian era. A range of community services and facilities and retail shops and commercial uses are located to the north of the site within Acton district centre. The Acton and West London College and Acton High School are also in close proximity of the site. Gunnersbury Park is located approximately 650m to the west of the site, within the London Borough of Hounslow.

Background – Housing Regeneration

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Although not material to the consideration of the outline planning application, the following useful background information is relevant insofar as it provides a summary of the recent work undertaken by the Council’s Housing Regeneration Service in pursuing the option of regenerating the South Acton Estate with a development partner, Acton Gardens LLP (Countryside Properties and London & Quadrant Housing Association). The information in the subsequent paragraphs is a summary of relevant information contained with a report prepared by the Housing Regeneration Service for the Council’s Cabinet meeting, dated 22/03/2011. Ealing Council’s housing regeneration strategy was developed following the 2008 review of 34 of the Council’s largest estates. The review identified 8 estates where the Decent Homes works alone would not provide the transformational effect that the areas demanded and therefore required a higher level of intervention. These estates are referred to as the High Intervention Estates. Detailed resident consultation on the High Intervention Estates looked at the potential and capacity for regeneration and resident aspirations for their neighbourhoods. The Council’s broad objectives for the housing regeneration programme are: - Put residents at the heart of delivering regeneration; - Transform deprived and run down neighbourhoods; - Provide mixed tenure developments (including socially rented, intermediate and private homes); - Provide environmentally sustainable urban development and improve the public realm; - Provide a better mix of bed sizes; - Contribute to the reduction of the Housing Revenue Account investment gap.

Following Cabinet authority to enter into a formal legal agreement with Acton Gardens LLP in December 2010, authority was subsequently given by the Council’s Cabinet in March 2011 to undertake enabling actions to allow progression of the first five phases of the regeneration programme. Of the first phases of development, Phase 1 benefits from planning permission (ref: P/2010/4201) and is under construction; Phase 2 is subject to a separate full planning application (ref: P/2012/0711) to be considered with this application and Phases 3, 4 and 5 are specifically covered by the current outline planning application. Phase 3 relates to the redevelopment of Woolf and Wodehouse Courts; Phase 4 is sited on the existing designated South Park; and Phase 5 would necessitate the demolition and redevelopment of Carroll Court, Meredith Tower, Galsworthy Court and Conrad Tower. The Housing Regeneration Service explained the rationale for choosing these areas for early redevelopment as: - Woolf and Wodehouse Courts are the only remaining blocks south of Bollo Bridge Road that

have not been redeveloped. Demolishing these blocks would enable a more coherent design and layout for the area and a higher density of development to be achieved. Estimated refurbishment costs per unit are also very high.

- The redevelopment of the under-used South Park site would provide a further head of supply for

future phases of the scheme and redevelop an under-utilised open space, to be returned later on in the regeneration programme. Integral to the proposals is the reprovision of a high quality permanent youth facility in Phase 6 of the regeneration programme.

- Demolition of the existing blocks in the proposed Phase 5 area would remove the pressing need

for elemental renewal and environmental investment, and address inherent design failings that cannot be resolved through refurbishment.

In order to test the proposals, the South Acton Joint Working Group requested that residents in the blocks proposed for demolition be asked their opinion. A door-to-door survey of all Secure Tenants

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conducted during October and November 2010 showed overwhelming support for the redevelopment proposals. The findings of the survey also illustrate that earlier phases of the regeneration programme have been successful in changing resident perception and opinion of their neighbourhood. Whereas nearly three quarters of residents in earlier phases chose to move away from the area, around 80% now say they wish to stay in the neighbourhood and move to a new property in the area. Additionally, Phase 3 would include the demolition of Caine House, which has been brought forward in the programme for demolition due to the substantive works required in order to bring the block up to fire safety standards. It is proposed that this site be used to provide a temporary public open space, in view of the proposals to develop on other areas of existing public open space and their re-provision later in the programme of works. The Housing Regeneration Service completed an outline Equality Impact Assessment for the entire regeneration scheme in May 2007, and this was updated in January 2008. A further Equalities Impact Assessment has also been undertaken for Phases 1-5 of the regeneration proposals. Further details of the Equalities Impact Assessment for the South Acton Estate regeneration proposals and Housing Regenerations’ consideration of the Human Rights Act and responsibilities towards Community Cohesion can be obtained from the Housing Regeneration Service. Relevant Planning History The regeneration of the South Acton Estate began in 2001 with the demolition of Barrie House, a 21-storey flat building. Planning application ref: P/2000/3962 was granted planning permission on 16/07/2001 for a part three and four storey flat building containing 54 no. 1-bedroom flats and rows of two to three storey houses (Hope Gardens, Park Road North and Newport Road) all in affordable tenure. The redevelopment of Barrie House also included the re-arrangement of streets and public realm improvements. This early phase of development is outside of the current South Acton Estate masterplan site area. There are a number of more recent planning applications that relate to the application site, including the reserved matters applications pursuant to the now expired outline planning permission (P/2004/5577), which is known as the Phase 2 regeneration masterplan. Only the most relevant planning applications have been listed below:

Planning Ref.

Date Decision Proposal Description

P/2004/5577 31/03/06 Grant with conditions & S106

Outline planning application for approval of means of access, with all other matters to be reserved for Phase 2 of the 15 year Regeneration of South Acton Estate, consisting of the demolition of Bollo, Maugham, Lawrence, Reade, Shaw, Hardy and Verne Courts, Blackmore and Kipling Towers, Working Men's Club, garages and storage units east side of Shaw Court; construction of 756 residential units, 2490m² retail (Class A1), 625m² office (Class A2 & B1) / food & drink (Class A3/A4/A5), 997m² live / work units, 100m² general industry (Class B2), 1775m² community / leisure (Class D1 & D2) and a maximum of 617 car parking spaces. Some residential units provided on southern part of South Acton Recreation Ground and existing allotments with relocation of allotments / open space (no net loss in open space). (Environmental Impact Assessment Planning Application).

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P/2005/0547 30/09/2005 Granted with conditions

Change of use of ground floor and basement from A3 (bar) to C1 (hotel) (managers accommodation in basement); excavation of basement; installation of light wells; alteration to ground floor pedestrian access; external stairs to basement with associated ballustrading; and external alterations.

P/2007/2310 29/11/07 Grant with conditions

Details of reserved matters of phases 2.1A and 2.1B for the siting, design, external appearance and landscaping of 129 dwellings (74 rented and 55 shared ownership) including 13 disabled in 4 blocks; Block B2, a part 2 and 4-storey block containing 19 flats (5 x 1 bed and 14 x 2 bed) and 8 x 4 bedroom houses; Block C, a part 5, 6 and 10-storey block with basement plant containing 64 flats (16 x 1 bed, 22 x 2 bed and 26 x 3 bed) both located between Palmerston Road, Stanley Road, Blackmore Tower and Woolf Court; Block F, a 4-storey block containing 22 flats (10 x 1 bed and 12 x 2 bed) and Block G, a part 2 and 4-storey block of 8 x 1 bed flats, 4 x 3 bed houses and 4 x 4 bed houses located between the railway and allotments, the Recreation Ground and All Saints Road, together with car parking, cycle parking and waste and recycling storage, in pursuance of conditions 1 and 5 of Outline planning permission ref P/2004/5577 dated 31st March 2006 for Phase 2 of the 15 year Regeneration of South Acton Estate.

P/2008/4713 09/04/09 Grant with conditions

Details of reserved matters of phase 2.2 for the siting, design, external appearance and landscaping, comprising 125 affordable flats in two blocks (Block E, a six-storey building containing 41 flats; Block H, a part 6, 7 and 8 storey building with 84 flats and basement parking with vehicular access from All Saints Road) located at the southern part of South Acton Estate, together with car parking (includes minor revision to parking layout approved as reserved matters to phase 2.1), cycle parking, private and communal amenity space and waste and recycling storage, in pursuance of condition 1 and 5 of Outline Planning Permission ref P/2004/5577 dated 31st March 2006 for Phase 2 of the 15 year Regeneration of South Acton Estate.

P/2010/1994 16/06/2010 Environmental Statement not required

Redevelopment of the site containing Kipling Tower and the former Bollo Court with a part 3 to part 10-storey building containing 163 units, together with an energy centre, communal and private gardens; 49 on-site car parking bays; 14 on-street car parking bays (provided along the western side of All Saints Road), refuse, recycling and bicycle storage (EIA Screening Request).

P/2010/4201 21/03/2011 Grant with Redevelopment of the vacant site, formerly occupied

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conditions & S106 Agreement

by Bollo Court and Kipling Tower with a new perimeter block building (3 to 9 storeys) containing 167 new flats and houses (comprised of 57 x one-bedroom, 83 x two-bedroom, 19 x three-bedroom flats and 8 x four-bedroom houses) together with an energy centre, communal and private gardens, 75 car parking bays including 53 on-site car parking bays (including 10 disabled bays) within the undercroft of the building, and 22 on-street car parking bays (15 bays provided along the western side of All Saints Road, including 2 disabled bays, and 7 spaces provided as part of the proposed Home Zone to the south), refuse, recycling and bicycle storage. (Phase 1 of the Acton Gardens LLP masterplan)

P/2011/1127 20/04/2011 EIA Scoping Opinion

Request for Scoping Opinion pursuant to Regulation 10 of the Town & Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 for Environmental Impact Assessment in respect of: Demolition of the majority of the existing buildings comprising approximately 2000 residential units and comprehensive redevelopment of the site to provide a residential-led mixed use development, comprising residential use (approximately 2675 residential units), new units in retail use and community facilities (including replacement of Bollo Youth Centre) or public services; provision of an energy network, car parking provision, new roads and new pedestrian access, open space, landscaping and public realm/environmental improvements.

P/2012/0711 Under consideration

Grant with Conditions & S106 Agreement

Construction of a part two to eight storey flat building comprising 106 residential units (26 x 1-bed, 53 x 2-bed, 22 x 3-bed and 5 x 4-bed) with accompanying podium-level private and semi-private amenity space, car parking (total of 49 spaces - 15 spaces on-street, 34 spaces within the undercroft), cycle and refuse storage, associated highways works and landscaping.

P/2012/2688 Under consideration

Berrymede Infant School - Removal of trees and partial demolition of building to accommodate the erection of a part single and two storey extension to the North West corner of school to allow for an expansion from 3 to 4 form entry, adjacent below ground sprinkler tank, canopy extension to East side of building, canopy over entrance, resiting of metal shed, erection of buggy shelter, cycle shelter, enlargement of bin storage area and associated works to provide retaining walls, play area, path, pond and landscaping. (Deemed Consent)

PRESENT APPLICATION

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Proposal Description The current outline planning application is intended to act as a framework to coordinate the continued regeneration of the estate over Phases 3-11. The development includes the phased demolition of all residential units and the various non-residential buildings within the application site, of which it is calculated that there are 1,695 residential units; 521sqm of retail (A1) floorspace, 2,434sqm of community (D1) / office (B1) floorspace; hotel (C3) accommodation comprising of 12 rooms (Osborne Hotel); garages and associated areas. The redevelopment proposals include the construction of a maximum of 2,350 dwellings in a number of new blocks and terraces. The proposed height strategy for the new residential buildings is established within the outline application and would comprise of two and three storey houses and up to 12-storey high flat buildings. When combined with the retained residential units, the overall number of dwellings within the estate would increase to 2,771. Up to a maximum of 1,050sqm new retail floorspace is proposed, including one food store with a maximum floorspace of 450sqm, and three smaller units of up to 200sqm. The retail floorspace would be located within three separate areas of the site. The first provision would be located at ground floor level of Phase 3, next to the South Acton Overground station. The indicative proposal for this area is for a café (A3 use class) with flow-out space next to the South Acton allotments and proposed Station Square. The 450sqm food store would indicatively be located at the southwest corner of the central hub in Phase 6, fronting Bollo Bridge Road; whilst a further small shop of up to 200sqm would be located at ground floor level in one of the new blocks on Osborne Road, as part of Phase 9. It is noted that the application has been made on the basis that the 1050sqm commercial floorspace would be available in a flexible range of uses, including retail (A1) / restaurant and café (A3) / office (B1) / community (D1) Use Classes, of which a minimum of 600sqm is to be retail (A1) use. A further 2,348sqm of community (D1) / office (B1) floorspace (to include a minimum of 926sqm for provision of a community centre and youth club) is proposed. The reprovided Oak Tree Centre and new community / office floorspace would be located at the ground level of the residential flat buildings in Phase 6; at the centre of the site opposite Bollo Brook Park and Central Plaza. The proposed site-wide energy centre would be located at basement and ground floor level of the proposed 12-storey flat building in Phase 7, opposite the new North Park. The energy centre would contain two gas-fired combined heat and power (CHP) boilers, supplying a district heating system across the residential and non-residential development in Phases 1-11 of the Acton Gardens masterplan. There would also be opportunities for future connection to the energy centre by buildings outside of the site, and specifically Acton Town Hall, the Priory Centre and the Oaks Shopping Centre. The proposal also incorporates improved, reconfigured and new public open space. In total, the development would provide access to 44,833 sqm (4.4833ha) of public open space, excluding the allotments. There would be a net increase in allotment space of approximately 673sqm. In addition, the former Caine House site would be used to provide a temporary public open space with children’s play equipment and limited landscaping. The public and community open space is in addition to the private and communal amenity space provided within the individual development plots. Summary Phasing Strategy

As a result of the large area of the application site and the various distinctive edge conditions, the applicant has identified four proposed character areas comprising West Gardens, North Gardens, South Gardens and Central Gardens. The identification of character areas aims to establish and reinforce the distinct characteristics of the different geographical locations within the broader application site and to respond to the character of the adjoining area.

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The Design Code is structured into sections that describe each of the character areas, including the character aspirations, key elements, townscape views, open space, streets, building form and interfaces of each of the character areas. The following information provides a summary of the development to be delivered across Phases 3-11 and identifies the character area in which the relevant phase would be delivered.

PHASE SUMMARY DESCRIPTION (SUBJECT TO RESERVED MATTERS APPLICATION)

DEMOLITION / LOSS OF

DELIVERY

3 SOUTH GARDENS and WEST GARDENS A) Construction of approximately 188 residential units B) Delivery of flexible commercial unit next to South Acton Overground Station C) Delivery of Station Square Public Open Space D) Temporary Youth Centre relocated to Bollo Brook POS E) Provision of a temporary park on the former Caine House site, to incorporate children’s play equipment F) Delivery of the multi-use games area in Bollo Brook Park by the Council, through S106 contributions

South Park Public Open Space Caine House Bollo Brook Youth Club Woolf Court Woodhouse Court

2014-2015

4 WEST GARDENS A) Construction of approximately 103 residential units B) Delivery of West Park Public Open Space

Graham Tower Chesterton Court

2014-2017

5 WEST GARDENS A) Construction of approximately 233 residential units

Carroll Court Meredith Tower Galsworthy Court Conrad Tower

2014-2017

6 CENTRAL GARDENS A) Construction of approximately 281 residential units B) Delivery of the main community and commercial floorspace, allowing the re-provision of the Oak Tree Community Centre prior to its demolition C) Delivery of main retail floorspace, including the proposed ‘anchor store’ (450sqm) D) Delivery of qualitative and quantitative improvements to Central Plaza Public Open Space

No’s 32 and 274-292 Osborne Road Charles Hocking House Hardy Court Oak Tree Community Centre

2016-2019

7 NORTH GARDENS A) Construction of approximately 466 residential units and relocation of elderly residents into new dwellings near Acton town centre B) Construction of northern part of the new north - south ‘Boulevard’ connecting the new neighbourhood to Acton High Street C) Anticipated delivery of the re-routed bus service through the estate D) Delivery of Hope Gardens Public Open Space E) Construction of the main Energy Centre (site- wide CHP network)

No’s 98-100 (inclusive) Avenue Road 1-20 Clandon Close Cheltenham Place 1-10 Buckland Walk Frampton Court (Belgrave Close) 1-40 Ragley Close

2017-2021

8 CENTRAL GARDENS & NORTH GARDENS Avenue Road Public 2019-2023

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A) Construction of approximately 391 residential units; B) Completion of the new North Park and reconfigured Avenue Road Park; C) Completion of the new north – south ‘Boulevard’ connecting Bollo Bridge Road to Avenue Road and streets to the north; D) Demolition of South Acton Working Men’s Club and delivery of the new street connection between Stafford Road and Brouncker Road; E) Demolition of Carisbrooke Court and delivery of new street connection between new ‘Boulevard’ and Brouncker Road; F) Connection of Phase 1, 2, 3(south), 6, 7 and 8 developments to the main Energy Centre (site-wide CHP network)

Open Space Harleyford Manor Barrington Court 1-66 Arlington Court 1-6 Telfer Close 81-139 Church Rd St Margarets Lodge Pembroke House Ludlow Court Carisbrooke Court Barwick House South Acton Working Men’s Club (& flat) No’s 81-95 Brouncker Road

9 WEST GARDENS A) Construction of approximately 364 residential units; B) Completion of re-configured Jerome Tower allotments and new allotments adjoining the Mill Hill Conservation Area C) Connection of Phases 3(west), 4, 5 and 9 developments to the main Energy Centre (site-wide CHP network)

Doyle House 32 Osborne Rd Jerome Tower Buchan House 2-16 Enfield Rd 79-83 Enfield Rd Garages on Enfield Road Anstey Court Bennett Court The (former) Osborne Public House, now the Osborne Hotel 347-371 Bollo Lane Webb Court

2022-2025

10 NORTH GARDENS A) Construction of approximately 176 residential units

1-16 Pevensey Court 1-22 Arundel House 1-16 Glamis Court Corfe Tower Harlech Tower

2023-2026

11 NORTH GARDENS A) Construction of approximately 42 residential units

Beaumaris Tower 2026-

Environmental Impact Assessment Planning applications for development that are covered by Environmental Impact Assessment (EIA) Regulations are termed ‘EIA applications’. The relevant regulations are the Town & Country Planning (Environmental Impact Assessment) Regulations 2011 (hereafter referred to as the ‘Regulations’). The requirement for an EIA is based on the likelihood, nature and extent of environmental effects arising from the development. EIA applications are divided into Schedule 1 and Schedule 2 applications under the Regulations, which govern all applications submitted after the 14 March 1999.

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Notwithstanding that the applicant has concluded that an EIA was required for the outline planning application and did not request a Screening Opinion, it is necessary for the Local Planning Authority to consider the proposal against the Regulations and make its own conclusions as to whether or not an EIA is required.

Screening The Regulations identify two types of development projects: Schedule 1 developments for which an EIA is mandatory, and Schedule 2 developments for which an EIA may be required. The proposed redevelopment of the South Acton Estate is not Schedule 1 development, but is a Schedule 2 development under paragraph 10(b), being an ‘urban development project’ with a site area of more than 0.5 hectares. Selection criteria for screening Schedule 2 development are contained at Schedule 3 of the Regulations and comprise of three main types of cases: a) for major developments which are of more than local importance; b) for developments which are proposed for particular environmentally sensitive or vulnerable locations; and c) for developments with unusually complex and potentially hazardous environmental effects. It is considered that the proposed development would not have unusually complex and potentially hazardous environmental effects, and accordingly, criterion (c) is not considered to apply in this case. This is not to say that the development would not have environmental effects that need to be considered as part of the appraisal of the application.

With regard to criteria (b), the application site has some environmental sensitivity and vulnerability. It includes a Site of Nature Conservation Value; it abuts the Mill Hill Park and Acton Town Conservation Areas and tall buildings would be visible from Gunnersbury Park Conservation Area (located within the London Borough of Hounslow); and includes land that is within an Archaeological Interest Area. The existing Jerome Tower allotment is a Site for Nature Conservation. The consideration of the potential impacts of the outline proposals on nature conservation, the effect of the development on the special character and appearance of the nearby conservation areas, and archaeology are material planning considerations. However, it is not considered that the likely impact of the development would result in an EIA being required under the provisions of criterion (b). Criteria (a) relates to development that would have ‘wide ranging environmental effects’ due to its scale. Advice about the need for an EIA for an urban development project is provided at Annex A18 of Circular 02/99; “In addition to the physical scale of such developments, particular consideration should be given to the potential increase in traffic, emissions and noise. EIA is unlikely to be required for the redevelopment of land unless the new development is on a significantly greater scale than the previous use, or the types of impact are of a markedly different nature or there is a high level of contamination”. Notwithstanding the fact that the site is currently developed and that the proposal is not of a significantly greater scale than the previous use of the site, it is clear that the proposed development is ‘of more than local importance’ and accordingly it is considered that an EIA is required under criterion (a). The applicant has submitted an Environmental Statement (ES) to assess the likely significant environmental effects of the proposal. The Local Planning Authority cannot grant planning permission for any development that is subject to an EIA before taking the environmental information into consideration. The external and internal consultees; including (but not limited to) the Greater London Authority, Environment Agency, Natural England, Thames Water, Transport for London, and Ealing’s Transport Officer, Environmental Health Officer, Conservation Officer and Urban Design Officer have considered the ES as part of their consideration of the planning application.

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Scoping The Local Planning Authority gave an EIA Scoping Opinion (ref: P/2011/1127) dated 20/04/2011 in response to the formal request made by the applicant. The Council’s Scoping Opinion was completed following consultation with statutory and non-statutory consultees. The applicant has submitted an Environmental Statement in support of the application. The Environmental Statement has been carried out for Phases 2-11, in order to ensure that the cumulative impacts of all phases of development are taken into account. Environmental Statement Documents The Masterplan Environmental Statement is supported by the following documents:

Environmental Statement (Terence O’Rourke Ltd) Non-Technical Summary (Terence O’Rourke Ltd), Technical Appendix A – Scoping (Terence O’Rourke Ltd), Technical Appendix B – Cultural Heritage (Terence O’Rourke Ltd), Technical Appendix C – Natural Heritage (Terence O’Rourke Ltd), Technical Appendix D – Traffic and Transport (SKM Colin Buchanan), Technical Appendix E – Air Quality (Aecom), Technical Appendix F – Noise and Vibration (Aecom), Technical Appendix G – Ground Conditions and Groundwater (Aecom), Technical Appendix H – Flood Risk Assessment (SKM Colin Buchanan), Technical Appendix I – Waste (Aecom), Technical Appendix J – Microclimate (Aecom). Environment Statement The assessment methodology used in the EIA took a three-stage approach. Firstly, baseline desk and / or field studies were undertaken to establish the existing situation; then the effects of the proposed development were evaluated; and lastly, mitigation measures were recommended where the degree of an effect necessitated mitigation. The effects of the proposed development were evaluated using a method that compares the sensitivity and importance of receptors with the likely magnitude of change to establish the effect. If the degree of effect is moderate or above, then the effect is considered to be significant. Slight or negligible effects were not considered to be significant. A summary of the key findings of the applicants’ ES is set out below. Additionally, the findings of the ES are addressed in the ‘Evaluation’ section of this report, as an integral part of considering the merits of the proposals. Townscape and visual effects Within the application site the ES identified three areas designated as public open space (Bollo Brook Park, South Park and Avenue Road Recreation Grounds) and two areas designated as community open space (South Acton allotments and Jerome Tower allotments). In addition, a fourth area of open space has been designated since the application was submitted - Bollo Bridge Rest Gardens. The South Acton Recreation Ground is located to the east of the site. There are also a considerable number of trees within the application site, but no tree preservation orders. The site contains no listed buildings or conservation areas; however there are two listed buildings in the surrounding area; Woodlands Ice House and Gunnersbury Park Museum. Five conservation areas are located within the wider area; the closest are Mill Hill Park (north-west) and Acton Town (north), and Gunnersbury Park (west), Acton Park (east) and Turnham Green (south) are further afield. No significant effect is expected on the landscape / townscape of these conservation areas except Mill Hill Park, which would be considered to have a moderate beneficial landscape / townscape effect as a result of the construction of low to mid rise development adjacent to the conservation area boundary, along with proposed structural planting and open space in key locations.

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A moderate beneficial landscape / townscape effect has been predicted for the majority of the character areas identified in the townscape and visibility assessment. 12 viewpoints in the surrounding area were selected in order to test the impact of the proposals. Two of these views are not considered to have a significant visual impact. Of the ten remaining views, which have a significant impact, four have a beneficial visual effect. The remaining six views have a significant adverse visual effect. (Further details of the Townscape effects are evaluated in the Urban Design section of this report). The extent of the zone of visual influence (ZVI) of the proposals indicates that the proposals will have a very slight increase in the extent of visibility compared to the status quo. The additional areas of potential visibility are from Gunnersbury Park, Ealing Common and Acton Park. The resulting slight increase in the ZVI is based on the retention of mid-rise buildings of 7 to 9 storeys, the introduction of two 12-storey buildings, the existing sloping topography and low rise development to the south of the site. All mitigation measures have been included within the design proposals. Further detailed consideration of lighting, treatment of streetscenes and the landscape proposals are required. Cultural heritage The EIA has assessed the potential for the redevelopment to affect the cultural heritage of the surrounding area. The site does not include or adjoin any nationally designated heritage assets. However, there are three Archaeology Interest Areas (AIA) in the 500m-study area. Where archaeology survives, it is considered that it will be of local significance and therefore of low-medium value. It was recommended that any potential effects on archaeology during construction could be fully mitigated through a watching brief and no residual effects on cultural heritage are predicted. Listed buildings are located within the Acton town centre and comprise a range of commercial and civic buildings, a church, and gentry-scale houses from the 18th and early 19th century, which are of high importance. Mill Hill Park conservation area directly abuts the proposed site and is divided from South Acton Estate by a wall belonging to the early 19th century estate. Conservation areas are of medium importance. Gunnersbury Park, a statutory listed landscape, lies to the south west and is considered to be of high importance. To ensure the protection and enhancement of the adjacent conservation areas the masterplan proposed a reduction in heights of development adjacent to the boundary, in particular the removal of the 17-storey Jerome Tower, and a reduction from 11 to 5 storey development on Mill Hill Road. The proposed road layout is also intended to reintegrate the estate into the surrounding area. The assessment concludes that the changed form of development at the estate and the reduction in visibility of the high-rise elements will result in a slight beneficial effect on the conservation areas. The assessment of potential effects of the visual change in form, height and distribution of the development on heritage assets in the wider-area predicts no significant effects. Natural heritage A Phase 1 habitat survey was undertaken, which recorded vegetation and wildlife habitats. The survey identified the requirement for further bat survey recording.

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Richmond Park Special Area of Conservation (SAC) and National Nature Reserve (NNR) is located approximately 5km from the site, and there are two Sites of Special Scientific Interest (SSSIs) within approximately 3.5km. There are locally designated Sites of Importance for Nature Conservation within 1km of the site. The demolition of existing buildings would create dust, which may impact on habitats. Dust deposition over a long period can effect vegetation, but as periods of dust generation are likely to be relatively short-term and wind and rain remove dust accumulations, this is not considered to be significant. The new and enhanced areas of open space within the site will be planted with grass mixes including a proportion of native wild flowers. The new habitats will provide better habitats for wildlife than those currently available. New tree planting will include native and naturalised varieties, and will mitigate the loss of the trees as a result of the proposals. The mitigated effect will reduce the effect to slight and not significant. The new trees along the new Boulevard and Osborne Road, and northern edge of Bollo Bridge Road will provide foraging areas and commuting routes for the local bat population. This will reduce the impact of the loss of existing trees on bats and the mitigated effect will be slight and therefore not significant. Further, a proportion of new buildings will include artificial roosts for bats, which represents a slight to moderate beneficial effect. A proportion of new buildings would also contain green roofs, which will provide additional valuable habitats for a range of plants and invertebrates and would also be used by foraging birds. The effect could be a slight to moderate beneficial effect. A proportion of the buildings on site will be designed to incorporate suitable nesting features for urban Biodiversity Action Plan (BAP) species such as house sparrow and starling. Traffic and transport Detailed assessments of the construction and post construction effects on traffic flows indicate that the development would not generate discernible environmental effects on any part of the existing network. The additional demand from the development on public transport has also been assessed and it is predicted that the additional demand for bus services, LUL Underground services and Overground services will be easily accommodated within existing capacity. It is predicted that the pedestrian environment, the links and crossing points designed in the South Acton Estate masterplan will accommodate the additional pedestrian trips and will result in an improvement to pedestrian safety within the site. Secure cycle parking, improved cycle route connections and the implementation of a Travel Plan are considered likely to increase pedal cycle trip generation. To ensure good working practices are adopted during construction, a Construction Management Plan (CMP) would be prepared for each phase of the development. The CMP will include details of construction vehicle routes and the duration of works. Framework Travel Plans (FTP) have been prepared for Phases 2-11. Measures are proposed to reduce car use. The conclusion of the detailed Transport Assessment was that the traffic and transport effects of the proposal has demonstrated that the increases in traffic are small in comparison with the existing baseline traffic flows on the surrounding road network. Therefore no significant effects were identified. Air quality

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Traffic related pollutants and fine particulate matter were the main focus of the air quality assessment, as well as construction dust and the operation of the new energy centre. It was identified that the whole of the Borough has been designated as an air quality management area (AQMA) for both nitrogen dioxide and fine particulate matter since December 2000. The potential effect of dust and particulate matter on residential properties during demolition and construction phases was assessed as being significant. A range of specific mitigation measures have been proposed, which would ensure that there is no significant residual effects arising from the construction activities. By 2025, both the with and without development scenarios show that levels of nitrogen dioxide will have dropped below air quality objectives, due to reductions in background concentrations and improved vehicle engine technology. Fine particulate matter levels would not exceed air quality objectives at any of the tested locations within the site. Once complete, it is predicted that the development would result in slightly higher levels of nitrogen dioxide and fine particulate matter than the without development scenario. However, the masterplan would not result in any exceedences of the air quality objectives and the changes from the 2025 future baseline are imperceptible or negligible. Nitrogen dioxide modelling associated with the operation of the new energy centre demonstrated that no significant effects will arise. Noise and vibration Noise monitoring was undertaken in order to understand the existing noise environment, which is currently dominated by traffic noise. Rail noise is also present close to the Overground and Underground railway lines. During construction, noise and vibration may be experienced by adjoining sensitive receptors, and best practice construction methods and measures will be put in place to minimise the nuisance from this. The post-construction development would not include any significant sources of noise generation. The flue of the proposed energy centre may generate noise, although it is considered unlikely to be at a significant level at any of the nearby receptors. Ground conditions The desktop study for the contaminated land assessment identified that the site could contain asbestos materials, unexploded ordnance or ground gases and further investigations and appropriate mitigation was recommended on a phase-by-phase basis. Water environment The water environment assessment focused on the quality of groundwater and the potential flood risk at the estate. It was considered that groundwater in this area is not considered to be at risk from activities undertaken on the site. No specific risk of flooding was identified and the submitted Flood Risk Assessment provides details of how the runoff rates could be managed through the use of sustainable drainage options (SUDS). Waste The applicant has estimated that the construction phase would generate approximately 12,500 tonnes of construction waste and 138,000 tonnes of demolition waste over the whole period of development. This is not significant in the context of the total construction and demolition waste arising in the Ealing area. A range of mitigation measures are proposed to manage the short term issues regarding this

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waste, including requirements for storage, handling and recycling, which will be set out in a Site Waste Management Plan. No residual effects are predicted from the construction phase. Once completed, the development may generate an additional 603 tonnes of household waste per year and an additional 16.5 tonnes per year from the commercial and community uses. This level of additional waste is not significant when considered in the context of the total waste Ealing Council manages each year. Community, economic and social effects The current population of the estate is estimated at 4,443 people, using the population factors from Wandsworth’s 2007 New Housing Re-survey. The redevelopment will lead to a total of 2,771 dwellings (including 421 units already constructed under phases 2.1, 2.2 and Phase 1), which represents an increase of 31% from the existing number. The provision of new dwellings was considered to result in a moderate, significant, beneficial effect on housing in Ealing. 1,688 existing units are affordable housing. The masterplan reduces this by 9% on a ‘unit’ basis, which would have a change of small magnitude and will be a moderate, adverse, significant effect. The proposal would improve the mix of affordable and private dwellings, which should create a more balanced community. The affordable units will be in a mix of bed sizes that will meet existing need (e.g. more family-sized units). The site has a slightly higher unemployment rate than the average for the ward and the national average. Approximately 150 people will be employed on site at any one time during the 15-year construction period, which would result in a moderate, beneficial, significant effect on employment. Once complete, the development will create approximately 24 jobs in the proposed food store, which would not result in a significant effect. The proposed retail provision within the site would fall within the definition of a 400m walkable neighbourhood store and therefore the proposed retail uses on the site would be unlikely to result in a significant loss of trade to Acton High Street. Education facilities within the site will be affected by the increased child yield and contributions for additional education provision would be required. There are eight GP surgeries and six NHS dental practices within half a mile, all of which are accepting new patients. The capacity of existing health facilities should not be effected by the relatively small population increase. A substantial, beneficial significant effect is predicted for open space provision. The proposal includes a 43% increase in public open space, additional allotments, semi-private and private gardens. The proposal also includes re-provision of floorspace for existing community uses that are currently on the estate. This will improve the quality of the facilities and will accommodate the potential increase in demand associated with the increased population. No significant effects on community uses are predicted. Once completed, the new buildings would provide new higher-quality buildings and reduce the potential for anti-social behaviour. This will result in a substantial, beneficial significant effect. During construction there may be reduced amenity for those immediately adjacent to the construction as a result of noise, dust and vibrations. This will be a short-term, substantial adverse effect, which is significant. The proposed development has the potential to improve the quality of life for the estate’s residents in a number of ways, as it will affect several of the factors that make up the indices of multiple deprivation.

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In particular, there is the potential for improvements to the indices relating to barriers to housing and services, crime, the living environment and health (through improvements to housing conditions and public open space). Overall, a small magnitude of change is predicted, which will be a moderate, beneficial, significant effect. Land use The existing land uses within the South Acton Estate include residential, education, retail, a hotel, community and public open space. The masterplan will lead to the rearrangement, rationalisation and intensification of existing land uses on the estate, which would lead to a small magnitude of change and will not result in a significant effect. Microclimate An assessment of the predicted effects of the proposed development on patterns of wind, daylight and sunlight has been undertaken. The wind assessment does not anticipate any effects on pedestrian comfort during the construction phase. Modelling shows that the majority of the site will comply with the requirements of category F (suitable for people sitting). There may be several locations across the site where wind may be slightly accelerated as it is split around corners of buildings. However, this is not considered to cause any significant problems for pedestrian comfort as categories D (people standing) and E (entrance doors) are still met. No significant effects are therefore predicted with respect to the wind microclimate. The daylight and sunlight assessment focussed on the impact of the proposed development on neighbouring buildings, rather than the proposed buildings themselves. The assessment identified a total of 460 buildings close to the proposed development site that could potentially be affected, with over 5,000 individual reference points (e.g. windows). It was considered that a more careful investigation of the impact(s) should be undertaken at the detailed reserved matters application stage once building massing is further developed. Areas with adverse impact are expected to reduce to negligible with careful building design. Conclusion The ES does not suggest many significant environmental impacts arising from the redevelopment of the estate and indicates mitigation can be undertaken where some effects do arise. PRE-APPLICATION CONSULTATION BY THE APPLICANT Under Section 122 of the Localism Act 2011, developers proposing to submit an application for planning permission are required to carry-out pre application consultation when the proposed development is of a description specified in a development order. Although no such order has been published by the Department for Communities and Local Government (and therefore the pre application consultation is not yet mandatory), the applicant has provided details of their pre application consultation within a Statement of Community Involvement (SCI). In addition, Ealing’s Housing Regeneration Manager for the South Acton Estate provided a summary of the consultation exercise undertaken jointly between the Council and applicant. The summary is provided below:

In summer 2008, a letter was sent to all residents on the estate advising them of the decision of the Council’s Cabinet to select a developer partner for all remaining phases of the regeneration programme. Residents were invited to join a resident-led Developer Selection Panel. The former governance body for the regeneration programme, the Joint Working Group (JWG) chaired by the portfolio Holder for Housing, endorsed this approach and members of the JWG were also invited to join the Panel.

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The Developer Selection Panel assisted the Council in drawing up criteria for the selection process, interviewed prospective bidders, visited developments built by short listed bidders and scored each bid, including their outline proposals for the regeneration of the estate. In December 2009, Acton Gardens LLP (a partnership between London & Quadrant housing association and Countryside Properties) were confirmed as the developer partner for South Acton Estate and, again, a letter was sent to all residents advising them of this. Since their appointment, Acton Gardens LLP have spent over 10 months consulting residents on their proposals for the future of the estate. Working to a ‘Consultation Plan’ approved and overseen by the Council, which has included: - Door-knocking every home in South Acton Estate to discuss the proposals with residents and

completing a questionnaire to determine what people want to see changed and retained. Where residents were not at home, Acton Gardens LLP left calling cards with their details. The applicants’ SCI advises that the applicant undertook one to one surveys with residents on over 30 occasions and spoke to 600 residents to gather feedback, ideas and opinions on the future of South Acton Estate.

- Three major exhibitions at key stages of the preparation of the outline proposals were held at

weekends, advertised through leaflets through every letterbox in South Acton Estate, notices in communal areas of blocks and in prominent places throughout the estate. Up to 200 residents attended each of these events.

- Quarterly newsletters to each household, with details of the proposals and how to give views and

become involved. - London & Quadrant established a presence on South Acton from April 2010, and occupied an

office at 114 Bollo Bridge Road in July 2011. Staff were available Monday – Friday from 9.30am – 5.00pm each day to show people around the permanent exhibition located in the office. This has been widely advertised and has continued throughout the period of the current application.

The establishment of South Acton Community Board has also been a key milestone. The Board was established in August 2010 as a successor to the Joint Working Group. The Board has wide representation including residents, ward councillors, representatives from the local voluntary and community sector, churches and head teachers of both local schools. The purpose of the Board was to guide the regeneration process and help make important decisions about the future shape of South Acton and monitor progress of the development of proposals for the estate. In November 2011 the Community Board held its first Annual General Meeting, which was open to all members of the public. This was widely publicised in newsletters, flyers to every household and block notices. Resident representatives on the Board were elected through majority voting at this meeting. The Community Board has met nine times since it was formed, on a bi-monthly basis. A letter of support for the outline application proposals from the Acton Gardens Community Board is contained within the applicants’ SCI.

In addition to the full board meetings, the Community Board also approved the formation of two sub-groups to look at issues outside of the scope of the full board meetings. The Housing Management Sub-Group was established to look at key issues such as rents, service charges, and tenant choices to customise new homes. The group met in April, July and October 2011.

The Masterplan & Design Sub-Group was established to look at and advise on how Acton Gardens consult with residents in relation to the masterplan and design. This group made recommendations concerning the consultation plan and looked at the Phase 2 (former Blackmore Tower site) proposals

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in detail. The group was attended by the project architects for Phase 2 (Alison Brooks Associates) and HTA (the lead master planners). The group met in April, May, September and December 2011.

A website (www.yoursouthacton.co.uk) was also developed at an early stage in the preparation of the proposals. The website provided information about the proposals and publicised details of forthcoming events. There was also the ability for members of the public to email comments directly to the design team from the website.

The applicants’ SCI provides a comprehensive overview of the consultation undertaken leading up to the date of the submission of the outline planning application, including:

Questionnaires (one to one interviews) Exhibitions and events Newsletters Website Walkabouts Resident’s Community Board and Design Sub-Group meetings Small focus group meetings Formal meetings Text messaging

The applicant met with the following groups during the pre-application consultation programme:

Acton Gardens community board Bollo Youth Club Acton Community Forum and TALLO Ealing Civic Society Action Acton South Acton Allotment Gardeners Society Mill Hill Residents Association Campaign for Action in Sheltered Housing United Anglo Caribbean Society Ward Forum Berrymede Infant and Junior Schools Acton Green Residents Association SARAG Oak Tree Community Centre steering group South Acton Working Men’s Club

The SCI provides information about the focus group meetings with these groups and the actions arising from the meetings, including how the scheme changed or responded to the suggestions and concerns raised by the various stakeholders. PUBLIC CONSULTATION BY THE LOCAL PLANNING AUTHORITY Consulting Members of the Public Consultation was initiated on 09/03/2012. 4040 existing properties on the existing estate and neighbouring properties were consulted about the full and outline planning applications by letter. A bespoke consultation letter was produced that advised interested parties a full set of application documents, including the Environmental Statement, were available in hard copy at the Council’s offices (Perceval House) and at the applicants’ regeneration site office on the estate. The full set of information was also available on the Council’s website and the applicant also provided a link to the Council’s website on the Acton Gardens LLP website (www.yoursouthacton.co.uk). The consultation

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letter also included the names and mobile telephone numbers of the two dedicated officers employed by Acton Gardens LLP to co-ordinate community engagement on the site. The following groups were consulted as part of the neighbour notification consultation -

Acton History Group; Ealing Civic Society; Ealing Community Network; Acton Green Residents Association; Acton Town Residents Association; Mill Hill Park Conservation Area Advisory Panel; South Acton Residents Action Group (SARAG); Action Acton; Acton Garden Association; Acton Community Forum; South Acton Allotment Gardeners Society.

Other groups on the estate, including the Berrymede Infant & Nursery School, Berrymede Middle School (North & South), and South Acton Children’s Centre, were consulted by virtue of the letters being sent to all addresses within the estate boundary. The London Borough of Hounslow consulted the following addresses within their Borough about the proposals: No's 46 - 74 The Ridgeway, W3 8LR (even numbers) No's 89 - 103 The Ridgeway, W3 8LP (odd numbers) No's 106 - 160 Princes Avenue, W3 8LU (even numbers) Gunnersbury Park Resident's Association Gunnersbury Park and Museum Twelve (12) site notices were displayed in different locations within and bordering the South Acton Estate (i.e. outside of South Acton Overground and Acton Town Underground stations; on the perimeter of the Public Open Spaces within the site; at the entrance to Berrymede Junior and Infant Schools; and at the street entrances to the site). The intention was to locate the site notices in areas that have the greatest footfall and therefore have the greatest likelihood of being seen by residents and members of the public. Press notices were published in the Ealing Gazette on 09/03/2012 and 16/03/2012. The second Press Notice was necessary because the first Press Notice contained an incomplete proposal description. The consultation period therefore formally ended on 06/04/2012. At the time of completing this Planning Committee report, the Planning Service had received correspondence from 22 individuals and one petition (32 signatures of residents of Clandon Close, Buckland Walk, Barwick House, Mill Hill Road, Belgrave Close, Cheltenham Place and Avenue Road). Of the responses, four individuals wrote either in support of the proposals or to request information about re-housing, compensation and the programme of works. Responses from SARAG and Mill Hill Park Conservation Area Advisory Panel were also received. Mill Hill Park Conservation Area Advisory Panel provided generally positive comments about the proposals but identified two areas where they considered that the proposals could be improved. SARAG raised various objections to the proposals, as well as providing information about their group, Right to Manage proposals, and the history of the estate. A summary of the issues raised by objectors is provided below:

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Key issue Number of respondents

Planning Officer’s response

A Housing

A1 In combination with the housing already constructed and the other uses proposed, the masterplan proposals would be an overdevelopment of the site. It is not acceptable that elements of the proposals would not sit within the London Plan Density Matrix.

1 resident SARAG

It is considered that the outline application proposals are capable of striking an acceptable balance between increasing the number of properties within the site in order to assist with cross-subsidising the construction of new affordable housing and meeting the Borough’s housing target; providing accommodation that is capable of meeting or exceeding the Mayor’s minimum internal space standards in residential blocks of an appropriate urban scale; providing amenity space and car parking appropriate to the type of housing proposed and the site’s location in close proximity to public transport and Acton district centre. It is not considered that the development, in combination with the earlier phases of development would be an overdevelopment of the site.

A2 Concern over the internal arrangements and residential space standards, in comparison to existing properties. The replacement units would have smaller rooms with an open plan kitchen / dining room / living room which would provide one less room than residents of the red brick area currently have.

2 residents Petition SARAG

The detailed design of affordable housing will be formulated in consultation with existing residents. The outline application does not establish aspects such as room layouts, except to make commitments within the Design and Access Statement to meet or exceed the London Plan minimum space standards (Table 3.3, policy 3.5), or any updated standards in place at the time the reserved matters applications are submitted. The applicants have advised in the Statement of Community Involvement that they are eager for existing residents to continue to participate in the pre-planning consultation and to be involved in the formulation of detailed design proposals for future phases of development.

A3 Garages or storage for car maintenance tools and equipment, as well as prams is needed

1 resident The proposed houses could potentially accommodate sheds in the rear gardens. Subject to further design development, the internal parking courts could potentially accommodate storage areas in addition to bicycle and bin storage requirements. It is anticipated that the Mayor’s new Housing SPG will contain additional requirements for increased storage in homes.

A4 Concern about the ability of freeholders and leaseholders to stay on the estate and implications for community cohesion and displacement of residents

3 residents Petition SARAG

Acton Gardens have advised that resident leaseholders and freeholders will have the opportunity to purchase an equity share in a similar sized property at the equivalent price of their buyback value. Further details are available from Acton Garden’s regeneration office or from the

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Council’s Housing Regeneration Service.

A5 It is not sustainable (environmentally and economically) to demolish buildings that are either newly constructed (Oak Tree Community Centre) or those that have been recently refurbished. The ‘rub the slate clean’ approach breaches the principles of good Urban Regeneration. A resident of St Margaret’s Lodge has objected to the demolition of this block. The residents of the ‘red brick’ area have objected to the demolition of the buildings north of Avenue Road. An explanation of how planning permission was granted for the Oak Tree community centre, which is of such poor quality was authorized, if it is not ‘fit for purpose’ after five years.

5 residents SARAG

The masterplan proposes the demolition of the majority of existing buildings as they are in poor condition and do not generally meet the needs of residents. The applicant has advised that 80% of properties are two-bedroom or smaller and this mix of unit sizes doesn’t meet requirements. The Oak Tree community centre, whilst relatively new and well utilised is unpopular with the centre management and users for a variety of reasons. Pre-application consultation revealed support for its replacement with a larger centre in Phase 6 (due to commence in 2016). SARAG have specifically identified that six blocks have been extensively refurbished since 2001 and consider their demolition would be a waste of public money. The six blocks are identified below with their indicative demolition date: Beaumaris Tower – 2026 Corfe Tower – 2023 Harlech Tower – 2023 Doyle House – 2022 St Margaret’s Lodge – 2019 Jerome Tower – 2022 These blocks will not be demolished for between seven and 14 years, and this would ensure value for money is secured for the essential refurbishment works that have already been provided. The applicants’ Statement of Community Involvement includes the results of the masterplan event, when residents were specifically asked whether they thought the Oak Tree community centre, Beaumaris, Harlech and Corfe Tower blocks and the properties in Brouncker Road should be retained or replaced. Of the 32 residents who completed the questionnaire, there was

support (80% of respondents) for the demolition of the buildings and their replacement.

A6 Will the leaseholders in St Margaret’s Lodge receive the money they paid towards refurbishing this block back from the Council? Note: The objector advised that they would be in full

1 resident The refurbishment works and condition of properties will be reflected in the valuation of these properties.

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support of the proposals on condition that the major works charge is waived, they are given a replacement flat, and the costs of any interim accommodation are covered.

A7 What are the timescales for the redevelopment

2 residents Broadly, the development will be undertaken between 2013-2026.

A8 Residents of the red brick area, located on the northern fringe of the estate, do not wish to be moved to a location away from their current location.

4 residents Petition

It is proposed that residents in Arlington Court, Barrington Court, Harleyford Manor, Telfer Close and Church Road would remain north of Avenue Road, close to their existing homes. Those residents decanted to the new residential blocks in Phases 4 and 5, within the western part of the site, would be located approximately 650 meters (about 5 minutes walk) from their current homes and the Acton district centre.

A9 Some people will be required to move twice.

SARAG The proposed demolition and reprovision phasing plan has been developed in order to minimise the requirement for double decant.

A10 ‘Inside stairwells’ and a large number of six-storey buildings are a repeat of the 1970’s estate design that has previously failed leading to drugs, crime and robbery.

2 residents Petition

The masterplan proposals are being developed in conformity with the Metropolitan Police guidance, ‘Secured by Design’ and other contemporary planning policy requirements. The detailed design of new buildings will be the subject of reserved matters applications and pre-planning consultation with residents.

A11 Phasing should be driven by the blocks that are in most need of attention, i.e. worst should be demolished first.

SARAG Blocks that have had more recent refurbishment works have been left to later phases. Nearly all of the other blocks within the site are in need of some form of intervention.

A12 There will be a 10% reduction in affordable housing

SARAG There will not be a decrease in affordable housing on a habitable room basis. The masterplan proposes a decrease in the number of smaller units (including 81 studio units), but overall, and with the cumulative affordable units delivered in the earlier phases of the regeneration proposals there would be a net gain in the amount of affordable housing within the site.

A13 The management and maintenance of the development should be by residents. Promising to

SARAG This comment is noted. The applicants have advised that the South Acton Community Board has been established, along

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build an estate management office is no substitute for the Right to manage.

with the Housing Management Sub-Group. These groups will continue to be active and to help shape the development and on-going maintenance / management of the estate.

B Design

B1 The proposed buildings are too high, particularly those proposed adjoining Brouncker Road, Bollo Bridge Road and adjoining the Mill Hill Park Conservation Area Specifically, residents of properties within the Mill Hill Park CA have requested that taller buildings are located closer to the industrial area (to the south-west) and to the non-CA residential areas.

7 residents Petition Mill Hill Park CAAP

The outline application sets out broad parameters for the type, scale and massing (including maximum heights) of the proposed development. The overall indicative height and massing of the scheme is considered to provide an efficient use of land, is of a reasonable scale, and avoids adverse impacts on the adjacent conservation areas, subject to further detailed design development. The strategy of placing the taller elements (10 and 12 storeys) near Acton Town and South Acton stations, and the Acton town centre is appropriate and follows London Plan and Ealing’s Development Strategy policy requirements, which are further addressed later in this report. The proposal to replace existing two-storey properties with buildings of a maximum height of 3-storeys within Brouncker Road is considered acceptable in principle.

B2 The height of buildings will affect amenity

4 residents The proposal generally minimises the height of replacement and new buildings around the perimeter of the site and this approach is considered to be broadly acceptable, subject to detailed considerations of appearance, scale, and materials. The Daylight and Sunlight Assessment indicates that properties to the east may be affected by the proposals if careful consideration is not given to the scale and massing of new development at the reserved matters application stage.

B3 Loss of tall buildings is regrettable as tall buildings provide good views

1 resident There would be a range of heights of new buildings that would provide pleasant views.

B4 Roofspace should be fully utilised for amenity space, green roofs and photovoltaic panels

1 resident This is consistent with the proposals.

B5 The buildings would create an urban heat island (UHI)

1 resident At a masterplan level the proposals incorporate: Street trees - the large number of mature trees to be retained will be enhanced through significant new planting to provide cooling both from shading and from evaporative transpiration. Existing

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recreational green spaces will also be increased to provide a network of green open spaces and connected tree lined streets. Landscaping - Podium planting, private rear gardens and front and side gardens with hedge planting to the maisonettes will all assist in mitigating the UHI effect. Green (& brown) roofs - Green roofs will be incorporated throughout the master plan in a planned way offering the following benefits: - Rainwater retention reducing peak run-off and providing evaporative cooling; - Cooling through evapo-transpiration from vegetation; - Cooling due to lower albedo and reduced thermal mass; - Low albedo materials selection - Materials will be selected with an awareness of the likely exposure to solar gain and impact on the UHI effect.

B6 The development in

Brouncker Road should be designed in an Edwardian style

1 resident The detailed design of the new properties along Brouncker Road would need to respond to their context. The detailed design of the properties would be subject to further consideration under a reserved matters application.

B7 The level of amenity space is deficient when assessed against the Council’s requirements

SARAG The masterplan provides a significant uplift in usable semi-private and secure open space. Family houses and ground floor maisonettes will have their own gardens. Flats would each have balconies or roof terraces, and flat blocks would also have semi-private communal courtyards, typically providing doorstop play space. An assessment of the proposal amenity space provision against the Council’s requirements is provided in the main body of this report and will be subject to further consideration under the reserved matters applications and balanced against the need to provide off-street car parking.

B8 The buildings within the broader development should be individual and have their own character. The development should seek to lift the housing stock in the area beyond ‘acceptable’ to ‘desirable’

Mill Hill Park CAAP

The comments are noted and supported. However, it is a matter for the detailed reserved matters applications to establish the ‘architecture’ of proposed buildings. The applicants’ Design Code establishes the idea of ‘distinct character areas’ within the different locations of the site and this will shape the architectural approach to development within the distinct character areas.

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C Open Space

C1 Allotments should be retained

2 residents The masterplan provides an increase in the space provided for allotments.

C2 Would like better green links

1 resident It is proposed that the new north-south ‘Boulevard’ will be generously planted with new trees and will connect many of the proposed parks and open spaces. All streets will be tree lined, and existing retained trees will enhance the green corridors.

C3 South Acton is deficient in green space and this would not be addressed by the proposals. The application documents include and exclude some existing key spaces

SARAG The masterplan accounted for designated public open space in its baseline assessment of open space. Many of the other open spaces do not have a specific function. The proposed masterplan ensures that the overall provision of designated public open space is significantly increased and this is complemented with numerous additional semi-private courtyards, which provide high quality, safe, and useable amenity spaces for residents.

C4 New open space should be provided before the existing is removed. It is particularly unacceptable that Avenue Road Park, the most popular open space within the site, will be reduced in size.

SARAG Temporary re-provision of open space will be provided on the Caine House site and the works to enhance the facilities in Bollo Brook Park will be provided early in the phasing plan. Station Square, outside of the South Acton Overground station would also be provided early in the development programme and would provide a new hard landscaped area that would enhance the usability and function of this area for leisure purposes. Avenue Road Park would be reduced in order to provide a much improved layout of development adjoining properties in Brouncker Road. New areas of open space and play equipment will be provided in the new North Park, Hope Gardens and the re-provided Avenue Road Park.

D Access

D1 The site is not as accessible by public transport as the applicant suggests

1 resident The accessibility of the site has been assessed in accordance with public transport accessibility level (PTAL) methodology as recommended by Transport for London (TfL). The site benefits from the 440 bus service; is a short distance from South Acton Overground station and within a short distance of Acton Town Underground station. The site is also located adjacent to Acton district centre, with a plethora of bus routes along the Uxbridge Road corridor. The masterplan has been designed to maximise pedestrian permeability along safe and attractive streets and routes and also makes provision for an enhanced bus service to be re-routed through the

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centre of the site.

E Parking

E1 Proposed parking levels are insufficient

1 resident Car parking proposals accord with the earlier phases of development and are considered to be acceptable by the Council’s Transport Officer’s, the GLA and TfL in consideration of the site’s accessibility to public transport and the Acton district centre.

E2 On street car parking should not be counted

1 resident A combination of on and off street parking is proposed which makes optimal use of available space; the use of on street parking is consistent with the residential nature of the surrounding roads and counting such provision within the overall car parking provision is an approach that the Council’s Transport Officer’s have accepted.

E3 Car parking should be equitably shared between the different tenures of housing.

1 resident It is agreed that car parking should be equitably shared between the different tenures of housing and an additional clause in the Travel Plan requires information to be submitted setting out the applicants’ parking strategy. The underlying principle is that the number of households that will be eligible for permits should not exceed the number of available off-street spaces and that off-street parking should be allocated on an equitable basis across the different housing tenures.

F Transport / Amenity

F1 Concern about the proposed new bus route at Brouncker Road and potential for noise, fumes and general disturbance

2 residents To enhance the accessibility of the site it is proposed to re-route the 440 service along a new north-south Boulevard. In addition, TfL are reviewing the entire South Acton bus network and wish to have the flexibility to introduce a new service which would start / finish within the estate, which may use Brouncker Road as part of a loop to turnaround. Thus, should a bus service be introduced which uses Brouncker Road, buses would only route in one direction within the southern part of the street (south of No. 79 Brouncker Road) and would not stop for passengers. It will be of particular importance to ensure that TfL do not allow their bus drivers to run engines whilst waiting at the proposed bus stand, in the interests of residential amenity for existing and future occupiers.

F2 There is potential for increased rat running and pedestrian footfall at Brouncker Road, which is considered to be undesirable for adjoining

1 resident The overall regeneration would result in modest increases in traffic, which can be accommodated on the existing road network with no noticeable impact or delay. Further, the overall design philosophy encapsulated within the Design Code would ensure a low speed vehicle environment

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residents within the site, which would deter through-vehicle movement. It is not considered that a potential increase in pedestrian permeability to Brouncker Road would be likely to cause detrimental amenity impacts to existing occupiers. Routes to community and retail facilities within the site, the Acton district centre and public transport would be the main areas of increased footfall.

G Sustainability

G1 The development should be environmentally sustainable

1 resident The sustainability of the masterplan has been considered throughout its development including social, environmental and economic elements. All phases are required to meet Code for Sustainable Homes Level 4. Homes will be built to high levels of energy and water efficiency with low energy lighting, low water use fittings and low carbon heat. Photovoltaic panels will be installed on suitable unshaded areas of roof to generate renewable electricity. The proposed energy strategy will achieve at least a 25% reduction in emissions of CO2 compared to the requirements of the current building regulations.

H Local Businesses

H1 Loss of Osborne Hotel and associated employment

1 resident It is proposed that Osborne Hotel is retained until Phase 9, whilst discussions continue between the owner and Acton Gardens LLP to establish whether a new facility could be located within the site, or alternative arrangements could be made. The development plan does not contain any policies that seek to protect a hotel use within the site, nor are there any policies that protect individual business owners.

H2 Loss of local shops and associated employment

2 residents SARAG

The retail floorspace proposed would allow local retailers a number of opportunities to continue trading on the Estate, should they wish to. A number of different locations are available, including 200sqm gross of Class A1 floorspace, or other suitable uses, within Phase 3 (new Station Square), 200sqm gross Class A1 floorspace in Phase 6, 450sqm A1 anchor store (community hub) and 200sqm gross of Class A1 floorspace, or other suitable uses, at Phase 9 (close to Buchan House). All of these units would provide opportunities for local independent businesses to set up or remain at the estate.

H3 What employment would be generated by the proposals;

1 resident The applicants have advised that at any one time during the demolition / construction phases, there

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will there be apprenticeships available?

will be at least 150 people employed in construction on the estate, with a minimum of 25 jobs associated with the new retail/ commercial activities. Countryside (the applicant) have made a commitment to employing 2 new apprentices from the local area for each phase of development. In addition, local businesses will be given the opportunity to tender for some sub-contract packages.

H4 There is a need for a café, bar and restaurant. The demolition of retail units in Hardy Court should not be undertaken until there is replacement provision to ensure continuity of retail use in the site.

1 resident The masterplan provides a number of opportunities to provide a café and local shops. In particular, the applicants have suggested that the 200sqm of floorspace within Phase 3 at new Station Square would be an appropriate location for a small, local café with potential spill-out space onto Station Square. The development in Phase 6, which includes the main retail and community uses, would be phased to ensure the continuity of community uses, but it may be more difficult to ensure the continuity of retail uses. The detailed application for Phase 6 would need to provide further details of the demolition and construction phasing.

I Environment

I1 Need for specific targets for bat roosts

1 resident A condition is included to address this requirement.

I2 Green walls should be incorporated into the proposals

1 resident A condition is included to address this requirement.

I3 Loss of valuable top soil from existing Jerome Allotments, which will be partially redeveloped

SARAG The applicants have advised that prior to this phase being designed in detail, they will consult with allotment users, and potentially relocate this topsoil to the new location if possible.

J General comments

J1 Money has been wasted on recent renovations

2 residents SARAG

Works to the renovated bocks were largely completed in 2006. The phasing strategy ensures that the refurbished blocks will be redeveloped towards the end of the 15 year programme, by which stage the refurbished blocks would be likely to require further costly maintenance and renewal works.

J2 The proposals to redevelop the estate would have an adverse impact on community cohesion

SARAG The applicants have provided a response to this objection, which is considered to demonstrate that community cohesion has been considered by the applicant:

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The aim of Acton Garden is to provide a truly mixed community that builds on what is best about South Acton i.e. the strong and vibrant 3rd sector and the tradition of residents doing it for themselves. We will achieve this in the following way: Ensuring that we reach out to the community –We have done this by consulting with over 600 people through the masterplan surveys. Residents were asked what they would like to see to improve the community through the new build Capacity building strong governance at the heart of the community –The masterplan development was overseen by the Acton Garden’s Community Board. The Board was established in September 2010 and is made up primarily of residents, local ward councillors, SARAG, representatives from the 3rd sector and Berrymede Infants & Junior Schools. The Board members are currently undergoing a training programme to ensure that they can actively influence issues around community cohesion and participation Acton Gardens as a partnership has established a community chest of £50,000 per annum, which is overseen by the Acton Gardens Community Boards and is intended to promote projects around community cohesion. So far the funding has gone towards projects to promote social inclusion and community cohesion e.g. Somali advice sessions, South Acton Party for All, sewing for disadvantaged women and the United Anglo Caribbean Luncheon Club In addition to the above, in 2011 Acton Gardens Commissioned a £90,000 project for Acton Community Forum to develop and support a sustainable community. Action Acton and Ealing CVS were also invited to bid for this piece of work. Key themes of the piece of work were around sustaining community activity at grass roots level, increasing participation, support for the voluntary sector and providing training around community cohesion In 2010 Acton Gardens commissioned Tallo Information Centre to carry out a piece of consultancy work to promote the participation of Somali residents within the regeneration. This has lead to a number of consultation events and two Somali representatives on the Community Board

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J3 The applicant should have looked at South Acton demographic information instead at Ward level information

SARAG The applicants have advised that the most accurate demographic data available to inform the Environmental Impact Assessment was National Statistics data, which is only available at ward level. No accurate, meaningful demographic data was available for the South Acton Estate as a separate entity.

J4 The South Acton population

is not transient, as suggested

SARAG This comment is noted.

J5 Providing community facilities in the centre of the site will not improve quality of life

SARAG The new facilities should provide better scope for flexibility of use and inclusiveness for a wide range of users. The facilities would be built to contemporary sustainability and accessibility standards.

J6 The proposal will not contribute to economic, social or environmental wellbeing of the area

1 resident The masterplan seeks to address many of the existing problems at the estate, including through the provision of substantially improved, high quality housing with an increased range of dwelling types, especially larger units. Not only will this help create a more balanced community but it will also bring private investment into the area, which would help maintain a high quality environment at the estate. Providing opportunities for people to live at the estate throughout their life in a mixed community will help address many of the issues that the estate has experienced in the past, including high levels of crime and anti-social behaviour. The proposals also include qualitative and quantitative improvements to public and private open space, larger and improved community facilities, local shops and a district-heating network.

J7 An Equalities Impact Assessment is required

SARAG A copy of the Equalities Impact Assessment can be obtained from the Council’s Housing Regeneration Service

J8 The proposals should be independently reviewed

SARAG The London Borough of Ealing and the Mayor are the decision-making authority in respect of the proposals. Statutory and non statutory consultation has been carried out in accordance with the requirements of the Town and Country Planning (Development Management Procedure) (England) Order 2010 and Town and Country Planning (Mayor of London) Order 2008.

J9 Consultation has been insufficient, particularly in relation to those residents

4 residents SARAG

The details of the pre-application consultation programme, which was coordinated between the applicant and the Council’s Housing Regeneration

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within the red brick area Petition Service, is outlined within the Statement of Community Involvement and is considered to have been sufficient for the scale of development proposed.

J10 The application consultation period was insufficient to allow proper consideration of the application documents

1 resident Consultation was initiated on 09/03/2012 and formally ended on 06/04/2012. This exceeds the statutory period required for consultation, which is 21-days. Further, the Planning Service will take into account any representations made up until the time that the applications are heard at a Planning Committee meeting.

J11 Not all residents have been able to move into new accommodation in the earlier phases of development and this is likely to be the case under the current proposals, even though the applicants states that all residents could remain on the estate.

SARAG It is acknowledged that not all existing Council tenants will be able to move into new accommodation within the regenerated estate. This will be particularly the case for residents with a need for 1-bedroom accommodation, as the number of smaller units (including studios) has been reduced in the materplan proposals in preference for family-sized accommodation. Ealing’s Housing Regeneration Service conducted a door-to-door survey of all Secure Tenants affected by Phases 3-5 of the masterplan during October and November 2010 and this showed that around 20% of residents say they wish to move from the estate.

STATUTORY CONSULTATION

Greater London Authority The current outline application is referable to the Mayor of London pursuant to the Town and Country Planning (Mayor of London) Order 2008. The outline planning application is considered to be of Potential Strategic Importance (PSI) and is referable under the following categories:

1A 1 “Development which comprises or includes the provision of more than 150 houses, flats, or houses and flats”; 1B 1(c) “Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings outside Central London and with a total floorspace of more than 15,000 square metres”; 1C 1(c) “Development which comprises or includes the erection of a building of… more than 30 metres high and is outside the City of London”; and, 3A 1(a) “Development which is likely to result in the loss of more than 200 houses, flats, or houses and flats (irrespective of whether the development would entail also the provision of new houses or flats)”. The Mayor’s Stage I planning report was given reference PDU/2871/01, and dated 12/04/2012. The case officer’s summary recommendation was that “The principles underpinning this important estate regeneration scheme are strongly supported, however, further information and commitments are

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required with respect to housing, open space, inclusive access, sustainable development and transport, to ensure accordance with the London Plan”.

A summary of the Mayor’s Stage I response is set out below: Housing: The overall approach to housing renewal is supported. The outline application would make appropriate reprovision of housing and affordable housing in line with London Plan policy 3.14. Matters of tenure, unit mix and residential standards are also acceptable in accordance with London Plan policies 3.5, 3.8, 3.9 and 3.11. However, further information and commitments are sought with respect to maximum reasonable amount of affordable housing, children’s playspace and density, to ensure accordance with London Plan policies 3.4, 3.6 and 3.12. Specifically, the Council should confirm that the applicants’ financial viability assessment is robust, that the private-sale dwellings will cross-subsidise the affordable housing and that should there be any financial surplus, that this will be subject to London Plan affordable housing requirements. In relation to the children’s playspace proposals, the Council are specifically required to secure the phasing, timing of delivery, and equipping of open spaces and play spaces within the S106 agreement to ensure that there would be no net loss of children’s play space, or temporary under provision while the various phases of development are being constructed. Further detailed information is required from the applicant in relation to the density calculation of the areas of the application site that have different Public Transport Accessibility Levels (PTAL), however, it is noted that an average density of 470 habitable rooms per hectare, as proposed, would broadly fit with the ranges recommended by the London Plan. Planning Officer’s response: An appraisal of the applicants’ confidential viability assessment is provided in the ‘Evaluation’ section of this report. In summary, the maximum reasonable amount of affordable housing that could be supported by the development is being secured via both the S106 Agreement and the Principal Development Agreement between the London Borough of Ealing Housing Service and Acton Gardens LLP. The details of the layout, design and equipment to be provided within the communal amenity spaces and public open spaces of the development are required by condition 5 of the recommendation. The applicants’ Design and Access Statement provides indicative proposals for the equipped play and sports spaces within the masterplan area (page 132). This illustrates that the masterplan proposals are capable of achieving full compliance with the Mayor’s and Ealing Council’s requirements. The provision of equipped and informal play space will be monitored by the Local Planning Authority under each reserved matters application. Specifically, the applicant is required to provide an ‘updated’ Design and Access Statement and Design Code with each Reserved Matters application, which explains how each phase of development meets the design principles and commitments contained with the approved Design and Access Statement and Design Code. The applicant has responded directly to the GLA in relation to the density calculations across the masterplan area and varying PTAL of the site. Open space: The proposed net gain in open space is supported, however, commitments are sought to ensure accordance with London Plan Policy 7.18. Specifically, an open space strategy is required that manages the provision throughout the redevelopment process, to avoid temporary loss of open space between phases. This should be secured within the S106 agreement. Planning Officer’s response: Condition 5 requires the submission of landscaping details for the Local Planning Authority’s written approval (in consultation with the relevant internal departments), whilst other conditions require the completion of landscaping works before full occupation of residential buildings across the masterplan. Other conditions seek the provision of open space at specific phases of the development in accordance with the open space stragey. It is considered that an appropriate amount of open space will be maintained throughout the redevelopment.

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Mix of uses: The proposed mix of uses is broadly supported. The retail provision is acceptable in line with London Plan Policy 4.7 and the provision of community facilities is supported in line with London Plan Policy 3.16. Urban design: The proposed design of the outline masterplan is supported in line with London Plan policies 7.1, 7.3, 7.4, 7.6 and 7.7. Inclusive access: The approach to inclusive access is supported in principle, however, commitments and revisions are sought to ensure accordance with London Plan policies 3.8 and 7.2. More specifically, the scheme must ensure that the shared surfaces would not present unnecessary risks to the visually impaired or other disabled people and the applicant was asked to address this issue within the ‘Design Code’. Further, measures such as tactile paving to identify boundaries between pedestrians and vehicles should also be addressed in the ‘Design Code’. Planning Officer’s response: The Design Code was amended (received 18/06/2012) and now specifically includes a commitment that, “The detailed design of the tertiary streets shall ensure that shared surfaces can be used safely, easily and with dignity by all regardless of ability. The treatment and surfaces shall enable visually impaired and disabled people to differentiate between areas through the incorporation of measures such as tactile paving at the flush boundaries between pedestrians and vehicles.” (Pages 13, 22, 32 and 42 of the Design Code) The detailed design of tertiary streets and an updated Design and Access Statement and Design Code is required by condition 4 of the recommendation. Sustainable development: Further information, revisions and/or commitments are required with respect to district heating, combined heat and power, renewable energy technologies, urban greening and sustainable urban drainage in accordance with London Plan policies 5.6, 5.7, 5.10, 5.11 and 5.13. The applicant is asked to provide further information about the “substantial alterations and retrofitting” that would be required in order to serve the phase one, two, three and six development from the existing CHP, biomass boiler and supporting gas boilers in Catalyst’s Phase 2.1 development. Furthermore, the applicant is advised against their current approach to providing small combined heat and power plants in individual plant rooms prior to the establishment of the central energy centre in phase 7. Instead, the installation of combined heat and power should be delayed until later in the build out of the development, when a larger combined heat and power unit, of equivalent cumulative capacity and higher electrical efficiency, can be installed straight into the central energy centre. Renewable energy and urban greening proposals are supported and the Council should secure their provision by way of planning conditions. Planning Officer’s response: The applicant and Ealing’s Energy Officer met with the GLA to discuss their advice on 18/07/2012. It was agreed that the applicant should be required to review their energy strategy on a phase-by-phase basis and that the provision of a CHP wasn’t necessarily the most acceptable provision in the longer-term. Condition 6 requires the submission of an updated energy strategy to be submitted with each reserved matters application for Phases 3-6. The most crucial aspect of the applicants’ energy proposals is the provision of the main decentralised energy centre in Phase 7, which is to eventually provide all the heat and electricity for the comprehensive development. The GLA required an appropriately worded condition that restricted occupation of later phases of development until Phases 1-6 of the development was connected to the main energy centre. Conditions have been included to ensure the GLA’s advice is followed. Transport: Further information and/or commitments are required with respect to the transport assessment, car parking, cycling, walking, providing public transport capacity and travel planning in accordance with London Plan policies 6.2, 6.3, 6.9, 6.10, 6.11, 6.13 and 6.14. Specifically, the demand for Blue Badge parking spaces to be actively monitored, with a management plan secured to allow for an increase in provision, where necessary. The capacity of electric vehicle charging points

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across the masterplan should achieve 20% active and 20% passive provision. TfL recommends that the controlled parking zone currently in force across the majority of the site should be extended to cover the whole estate. In addition, a car parking management plan should be secured. The ‘Design Code’ should be updated to ensure that cycle parking will be provided in accordance with TfLs requirements. The recommendations within the pedestrian environmental review system audit should be implemented. Financial contributions to facilitate bus route changes through the site are required. The S106 agreement should also secure a framework travel plan for the whole site. Planning Officer’s response: Relevantly worded conditions and S106 obligations are included in the recommendation to address these comments.

OTHER EXTERNAL CONSULTATION British Gas Did not respond to the consultation letter. Crime Prevention Design Officer (Metropolitan Police) The applicants’ intention to adopt the principles of Secured by Design (SBD) is noted and welcomed. The one area that should be given particular consideration at this early stage in the development of the design principles is the number of flats accessed from each communal core entrance. SBD looks for 10 flats per core and if this is exceeded then additional security should be provided. It is strongly recommended that if more than 10 flats are accessed from one core then secondary access controlled doors be installed to create secure groups of up to 10 flats. Design Council CABE Did not respond to the consultation letter. English Heritage Recommended that the application be determined in accordance with national and local policy guidance, and on the basis of the Council’s specialist conservation advice. Environment Agency We are pleased that surface water will be discharged from the site at the greenfield run-off rate and that the Sustainable Drainage Systems (SUDs) will be implemented wherever possible throughout the site. Having reviewed the Flood Risk Assessment and additional drawings and calculations submitted by SKM Colin Buchanan the proposed development will only be compliant with the National Planning Policy Framework if a condition is imposed requiring the submission of a drainage strategy for each phase of the development. The details should comply with the submitted Flood Risk Assessment and follow the hierarchy for Sustainable Drainage Systems in policy 5.13 of the London Plan. Greater London Archaeology Advisory Service (GLAAS) Confirmed that the western part of the site and part of the northern part of the site are within an Archaeological Interest Area and recommended that a condition be included that requires a Written Scheme of Investigation prior to the commencement of the development in these areas. London Borough of Hounslow Raised no objection to the application, but considered that the main planning issues concerning the authority were: Impact on the character and setting of the Gunnersbury Park Conservation Area (in the LB Hounslow); - The site is located approximately 100m northeast of the borough boundary at Gunnersbury and is separated by the existing London Underground lines running between Acton Town and Chiswick Park stations. There are a number of designated conservation areas close to or adjoining the borough boundary with Ealing, including Thorney Hedge, Wellesley Road, Turnham Green, Bedford Park and Gunnersbury Park. The latter two are provided additional protection under an Article 4(2) Direction due to their historic and architectural character. Of these it is only considered that the Gunnersbury Park conservation area is close enough to the site to be affected.

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The applicants’ submitted ES considered the impact on the Gunnersbury Park Conservation Area could be classified as ‘negligible, beneficial’. Due to the distance involved, it was not considered that the development would have any impact on Gunnersbury Park itself. The site is closer to Gunnersbury Park Garden Estate, a predominantly residential area constructed in the interwar period. The proposed development would involve the demolition of existing buildings in the South Acton Estate. Some of which are tall and one of the replacement buildings would be up to 12-storeys in height on the south western side of the site, however it is noted that most would be lower. These buildings would form part of the gateway entrance to the site from Bollo Lane and would face towards the Gunnersbury Park Garden Estate. It is noted that some of the existing buildings on Bollo Lane reach up to nine storeys in height and are of little architectural merit. On balance, it is considered that the outline proposal would not have an adverse impact on the character and setting of the Gunnersbury Park conservation area. Traffic generation and implications for the LB Hounslow; - The post construction increases in car journeys within the immediate vicinity are forecast to be less than 1% on distributor roads during AM and PM peaks with the exception of Bollo Bridge Road and Acton Lane (PM only). Bollo Bridge Road does not lead directly into LB Hounslow and is an internal distributor road for the site. Acton lane runs north to south on the eastern side of the site and is predicted to experience a 1.3% increase in PM peaks. The key routes into Hounslow would experience traffic level increases well below 10% threshold set out by the Institute of Environmental Management and Assessment (IEMA) guidance. Accordingly it is considered that the proposed would not have an unacceptable impact on traffic within the London Borough of Hounslow. Education implications for LB Hounslow; - Due to the location of the development in close proximity to the LB Hounslow and the proposed increase in residents, it is noted that the proposed redevelopment should seek appropriate contributions towards education from the developer. Suggested that contributions should be sought in consultation with the LB Hounslow. Case Officer’s response: LB Hounslow’s comments are noted. Ealing’s Education Service have requested contributions towards the provision of education services within the borough, however did not consider that any of the contributions should be diverted to the LB Hounslow. London Fire and Emergency Planning Authority (LFEPA) Requested an informative be included on the decision notice reminding the applicant to ensure plans conform to Part B of the Approved Document of the Building Regulations. National Air Traffic Safeguarding (NATS) Confirmed that there would be no safeguarding issues. Natural England Initially raised an objection to the proposal due to concerns about the impact of the development on bats. Following the submission of further clarifying information from the applicant, Natural England provided a second response dated 19/04/2012. Natural England confirmed that the buildings with high potential to support roosting bats are located outside of the application site. Two buildings with medium potential to support roosting bats (buildings 3 and 13) are within the application site, however these buildings would not be impacted until late phases of the development. Given the low level of bat activity recorded across the application site, the likelihood of significant roosts being present was assessed as being low by the applicant. Natural England would normally recommend that all relevant ecological information be provided at the outline application stage to ensure that development would be in accordance with all relevant protected species legislation and Paragraphs 98

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and 99 of the ODPM Circular 06/2005. Should the Council consider that in this instance there are exceptional circumstances, it may be appropriate to append conditions to any consent requiring additional surveys to be undertaken. Planning Officer’s response: An appropriately worded condition has been included, requiring further bat survey work and necessary mitigation. Network Rail Did not respond to the consultation letter. Primary Care Trust (PCT) Confirmed that the increase in population as a result of the proposed development would have an impact on the existing health facilities in the local area and requested contributions towards a capital planning contribution and revenue planning contribution for Acton Health Centre, to be secured through the S106 agreement. Planning Officer’s response: The S106 Agreement makes provision for a reasonable contribution (£550,285) towards enhancement of healthcare facilities to take account of the increase in population from the estate redevelopment. Thames Water Advised that the existing water infrastructure has insufficient capacity to meet additional demands and required that an impact study be submitted prior to the commencement of the development, and that a piling method statement be required prior to the commencement of piling (if relevant). Thames Water also confirmed that they are in direct consultation with the applicant and discussions have already taken place in relation to developing a drainage strategy for the masterplan proposals. Thames Water confirmed that the applicant has agreed for an impact study to be completed. Planning Officer’s response: The comments are noted and a condition has been included in the recommendation in relation to the requirement for the submission of a piling method statement. An informative is also included reminding the applicant of their obligation to carry out the necessary water infrastructure impact study. Transport for London (TfL) The comments from TfL are subsumed within the Stage I response from the GLA. Twentieth Century Society Did not respond to the consultation letter. Southern Electricity Did not respond to the consultation letter. INTERNAL CONSULTATION Access All new residential units created through new development or conversion should meet the Lifetime Homes standards. 10% of residential units should be designed to wheelchair housing standards. The applicants’ commitments to achieve the required standards are welcomed. There should be lift access to all floors in the tall buildings. All units should preferably have access to two lifts. There should be provision for seating areas in the parks and within the semi-private amenity spaces. Tertiary streets: People with a visual impairment have difficulty using shared surfaces as there is no kerb to provide guidance or provide distinction between road and pavement. People with visual impairment would require training about how to use the shared surface environment. It is noted that the Design Code has been amended to address some of the points raised by the GLA’s Access Officer.

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New Community Hub: There should be level entrance and threshold. There should be an accessible toilet facility for each separate function area. There should be a hearing loop facility in main halls. There should be parking spaces for people with disabilities. There should be lift access to all floors. Café: There should be level access and threshold, and an accessible toilet facility. Shops: There should be level access and good circulation space. Conservation Generally the surrounding conservation areas within the boundaries of London Borough of Ealing will suffer negligible impact from these proposals, with the exception of Mill Hill Park Conservation Area (CA) and potentially Acton Town CA. It is likely that the new proposals will be highly visible from key parts of both conservation areas, since the tallest elements are placed between them. The proposed 12-storey tower in the north of the site, for instance, is directly in line with Avenue Road and will terminate the view along it. The impact of the development on Mill Hill Park CA would be greater than the existing estate i.e. significant, but the impact on Acton Town Centre CA will be similar i.e. the 12 storey block will impact on views from Market Square. Conditions will have to be imposed to impress upon the designer of the details of the scheme the importance of ameliorating any negative impact by careful siting and finish of blocks. It is considered that there is limited architectural merit in those buildings to be demolished and therefore the proposals could be swapping one detrimental backdrop to the conservation areas for another if the detailed design of the 12-storey tower at the northern part of the site is not carefully formulated. Effort must be made at the detail stage to ameliorate the undoubted impact of the taller towers on both Mill Hill Park CA and Acton Town Centre CA in particular. Planning Officer’s response: The detailed design of the buildings and their impact will be considered under the reserved matters for each phase. Education Using the Wandsworth model for calculating child yield, but making it more locally relevant, the Education Service anticipate a net child yield increase of 29.77 Primary and 21.25 Secondary age range pupils, which equates to a contribution of £729,360 for the outline application. Current projections that are supported by updated predictions by the Greater London Authority (GLA) indicate a significant increase in the number of school age children in the coming years. The contribution is based on 90% of the basic need allocation multiplier for the primary and secondary sectors. This should be secured through the S106 Agreement. Planning Officer’s response: This is included within the S106 Agreement. Energy (Summary) Recommended a condition relating to securing the construction and operation of the main energy centre in Phase 7 and subsequent connection of the comprehensive development to the decentralised energy centre. Also recommended the imposition of conditions relating to the need for a revised energy strategy, following consultation with the GLA. Planning Officer’s response: Appropriately worded conditions are included that require that each phase of the development is connected to the main energy centre. Environmental Health (Noise, Air Quality, Soil Contamination, Light) Recommended that the residential units with habitable rooms with facades on Bollo Lane and Bollo Bridge Road, and in the vicinity of the termination of the flue for the CHP plant(s) may require additional air pollution mitigation measures and noise mitigation measures are incorporated into the building envelope. The site is

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classed as high risk for noise and air emissions from the construction and demolition activities and a construction logistics plan should be secured by condition, which complies with best practice guidance. A monetary contribution for air quality monitoring should be sought through the S106 Agreement. Additional contaminated land investigation is required, on a phase-by-phases basis. The external lighting strategy should comply with best practice guidance and the details of the strategy should be required by condition. Planning Officer’s response: The comments are noted and conditions have been included in the recommendation. A contribution for air quality monitoring has also been addressed within the S106 Agreement. Environmental Services (Refuse) Did not respond to the consultation request. Planning Officer’s response: A condition requiring further details of the refuse and recycling storage for the residential and non-residential uses is included in the recommendation. Landscape Officer (Summary) Whilst the masterplan provides more public open space (POS), the ratio of space per capita marginally decreases as a result of the proposals. The applicant has justified this small decrease by saying that the quality of the space would be increased by the proposals. How this is measured and delivered over the long-term will be a matter for further consideration at the reserved matters application stage. It is disappointing that a local park of 2ha could not be accommodated within the proposals. However, the development would make provision for a series of smaller parks that will be clearly defined, provide strong identity and will be well overlooked by residential buildings. This approach works well with the phasing strategy. The Parks Service would be agreeable to adopting the following POS: West Park (new), North Park (new) and will retain Avenue Road Recreation Park (reconfigured). Station Square and Central Plaza appear to be dominated by hard landscaping and the Parks Service would not be likely to adopt these areas. Highways have indicated that they may adopt Station Square, subject to the detailed design of this area, which would need to be agreed under a S278 / S38 Agreement and also under a reserved matters application. The proposals utilise POS for storage of underground storm water tanks. The detailed design and location would need to be agreed with the Parks Service and the applicant would need to enter into an easement agreement with the Council. The inclusion of additional allotment space is welcomed, but it is unlikely that the Parks Service would adopt this new area of allotment space. It would be preferable if the new provision could be brought forward in the phasing programme. It is crucial that trees are adequately protected during demolition and construction, as there have been issues on the earlier phases of demolition. The replacement tree strategy should include more species adaptable to climate change and resistant to disease and tree species should be subject to condition. The play strategy as set out is acceptable. The detailed design of the play areas would need to be agreed with the Parks Service and a condition requiring the details to be submitted should be included in the recommendation. The proposals to include public art are welcomed. It is important that the local community is involved in the development of these proposals. This should be monitored through the details to be submitted with the reserved matters applications.

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Planning Officer’s response: The Landscape Officer’s comments are noted and a number of conditions requiring further details of the design of the public, semi-private and private open space; children’s play space; tree retention and planting proposals; and other landscaping related details have been included in the recommendation. There are also a number of contributions that have been sought under the S106 Agreement to address the officer’s comments. Planning Policy South Acton Estate forms an integral part of Ealing's estate regeneration programme and is planned to deliver over half of the 1400 net additional units that this programme will provide over the next 5 years. The regeneration programme in turn is essential to Ealing's housing trajectory particularly in ensuring housing delivery in the early stages of the plan. The proposals for the mixed-use, mixed-tenure redevelopment programme fit well with the Development (Core) Strategy's plans for the reintegration of this area with the rest of Acton and the wider Borough. The proposals for the inclusion of a retail element on site are particularly welcome as these look forward to policies emerging in the Development Management DPD that seek to encourage convenience retail in areas not immediately served by main frontages. The treatment of open space also accords well with the Development Strategy's objective to promote and enhance local parks, better integrating existing parks and offering a good mix of public, private and semi-private spaces. Overall the proposed development is considered to fit well with the Development Strategy ambition to achieve an attractive and popular residential locality, integrating the municipal and owner occupied residential areas and creating easy pedestrian access to Acton town centre. Planning Officer’s response: Various conditions and aspects of the S106 Agreement relate to these issues. Transport (Summary) The vehicle trip generation from the development would not be significant and the results of the detailed modelling indicate that the network could accommodate the additional flows from the development and operate with spare capacity. The development would result in an increase in pedestrian and cycle movements on the estate, which may increase pedestrian / vehicle conflicts, particularly at road junctions. To alleviate the potential safety risks to pedestrians and cyclists it is recommended that particular attention be paid to the area immediately surrounding the school and community facilities, as these are likely to be hot spots of pedestrian activity. The indicative treatment of these areas as shared surface restricted access routes would be consistent with Transport recommendations. Parking congestion and displacement could be a potential issue, given that parking provision is at a ratio of 0.48 and some roads on the estate are not in a controlled parking zone (CPZ). The recommendation to implement a CPZ across all roads within the site is therefore particularly important. The condition of footways within the site and in surrounding streets requires improvements based on the results of the applicants’ pedestrian environment review system (PERS) audit. The demolition and construction phases of development are likely to be disruptive to local residents and a Construction Management Plan should be conditioned. A number of contributions and other obligations should be sought under the S106 agreement to provide the necessary mitigation for the development. The Transport Officer’s full comments are provided within the ‘Evaluation’ section of this report.

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Urban Design (Summary) The vision for South Acton is consistent with good urban design principles;

and in summary is to integrate the site to its surroundings, re-establish a street grid with improved

north-south links, create a network of open spaces and respond to context and scale, in order to

establish and reinforce character areas.

This vision is based primarily on the provision of quality homes through a mix of building types

including family houses with private gardens, ground floor maisonettes with private courtyards, flats

with balconies/ roof terraces and over 55’s accommodation near to the Acton district centre.

To support the residential accommodation and build on the existing community and educational uses

at the centre of the site, a mixed-use community hub is proposed including a large shop (up to

450m2), a new community centre to replace the existing Oak Tree and a new Youth Centre to replace

Bollo Brook Youth Centre. The ground floor of both new buildings to the south and west of the central

square would be given to non-residential uses. This offer is welcomed as a way to provide a focus for

the development, a civic function to the square and retail presence on Bollo Bridge Road. The other

two smaller shops are proposed at Station Square and to the west end of Bollo Bridge Road. An

energy centre is also proposed to the basement and ground floor of the block facing North Park.

The indicative proposals show a variety of blocks that achieve the continuity of building lines to

adjoining streets and providing clear definition of public fronts and private backs, in accordance with

the classic Homes and Communities ‘Urban Design Compendium’. The scheme exploits the site’s

landscape, through the retention of nearly half of existing, mainly groups of trees where these do not

impose constraints to the perimeter block layout and clear street network.

The scheme generally integrates with existing roads, paths and surrounding development. New routes are created to improve north-south movement, supporting pedestrian desire lines to the High Street, Acton Town tube and South Acton Overground. Existing, well established routes through site are retained and enhanced. Remaining streets are arranged to form a logical network. Illustrative views and design objectives in the Design Code suggest building edges with frequent doors and windows overlooking spaces and routes, in order to promote safety and natural surveillance. Streets seem to work well for pedestrians and cyclists. Open spaces within the estate currently lack definition, function and quality. Parks are well used but the lack of clearly defined frontages and natural surveillance can make them feel unsafe. The most positive feature is the amount of trees there are within the site. The masterplan proposes to retain and upgrade the existing designated open spaces - South Acton Recreation Ground and Bollo Brook Park. Avenue Road Recreation Ground would be reduced in size and South Park would be relocated one block to the west, in order to serve better the west part of the site. Four additional spaces would be created as part of the masterplan – North Park and Hope Gardens, within the north of the estate, Central Plaza near the central community hub, and Station Square next to South Acton Overground station.

The strategy of spreading open spaces across the site, to ensure all residents are less than 5 minutes

walk to a park or square and maximising the amount of residential frontages overlooking public open

spaces is supported.

Youth, Connexions and Play Service Advised that their preference for the permanent Youth Centre would be for a facility that remains independent from the main community centre. Specific issues highlighted by officers’ in relation to the proposed temporary facility in Bollo Brook Park included the following:

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- Security: We currently have CCTV at all points of entry in and out of the building, as well as inside the reception area.

- All windows must be secure inside and out, if at all possible we would like to retain the ornate grills on the exterior of the building.

- Building and internal fabric must be made of durable materials, inside and out e.g. the kitchen cannot be a domestic one, this is to ensure cost effectiveness regarding repairs.

- Phone and internet must be installed with PCs networked to the Ealing server. - Entrance and exit of building and site should be placed away from any nearby residential

dwellings and the outside of the centre must be well lit including any pathway to and from the main road.

- Fully accessible for people with a disability. - Parking within close proximity to the centre, in particular when workers are running session that

finish late. - Memorial Garden, we would want to retain as much as possible of the garden, as the memorial

but also as a working project. Planning Officer’s response: The design of the temporary centre, including the details of CCTV, lighting and access, is required by condition. The permanent reprovision of the youth facility would be in Phase 6 and the full details of the design of the centre are also required by condition. The operational requirements of the centre, such as connection to the Council’s IT system, should be a matter of separate agreement between the relevant parties and is not a Planning consideration. There would be no dedicated car parking associated with the centre and it is anticipated that the members of staff would be able to park within on-street spaces or use public transport. PLANNING POLICIES National Planning Policy Framework

On 27 March 2012 the Government adopted the National Planning Policy Framework (NPPF). This document replaces most Planning Policy Statements and Planning Policy Guidance Notes, as well as some Circulars and other documents. The NPPF states that, “Local planning authorities should approach decision-taking in a positive way to foster the delivery of sustainable development” (paragraph 186). However, it reiterates that “the planning system is plan-led” and that applications must be determined in accordance with the development plan (paragraph 196). Where the Local Plan is absent, silent or relevant policies are out-of-date, planning permission should generally be granted unless adverse impacts demonstrably and significantly outweigh the benefits when assessed against the NPPF, or where specific policies in the NPPF indicate development should be restricted (paragraph 14). The adopted development plan in this instance includes the London Plan (July 2011), Ealing Development (or Core) Strategy (April 2012) and the saved policies of the Ealing Unitary Development Plan ‘Plan for the Environment’ 2004. It is anticipated that Ealing’s ‘Development Sites’ and ‘Development Management’ DPDs, and a new Proposals Map will supplement the adopted development plan in June 2013; at which point all Ealing UDP policies will expire. The development plan was prepared with the objective of contributing to the achievement of sustainable development and to this end is considered to be broadly consistent with the principles and policies set out in the NPPF, including the presumption in favour of sustainable development. The NPPF makes clear that development plans should provide clear policies that will guide how the presumption in favour of sustainable development should be applied locally.

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The following sections of the NPPF are considered relevant to this proposal: 1. Building a strong, competitive economy 2. Ensuring the vitality of town centres 4. Promoting sustainable transport 6. Delivering a wide choice of high quality homes 7. Requiring good design 8. Promoting healthy communities 10. Meeting the challenge of climate change, flooding and coastal change 11. Conserving and enhancing the natural environment 12. Conserving and enhancing the historic environment London Plan 2011

Context and Strategy 1.1 (Delivering the Strategic Vision and Objectives for London) London’s Places 2.6 (Outer London: vision and strategy) 2.7 (Outer London: economy) 2.8 (Outer London: transport) 2.14 (Areas for regeneration) 2.18 (Green infrastructure: the network of open and green spaces) London’s People 3.1 (Ensuring equal life chances for all) 3.2 (Improving health and addressing health inequalities) 3.3 (Increasing housing supply) 3.4 (Optimising housing potential) 3.5 (Quality and design of housing) developments) 3.6 (Children and young people’s play and informal recreation facilities) 3.7 (Large residential developments) 3.8 (Housing choice) 3.9 (Mixed and balanced communities) 3.10 (Definition of affordable housing) 3.11 (Affordable housing targets) 3.12 (Negotiating affordable housing on individual private residential and mixed use schemes) 3.13 (Affordable housing thresholds) 3.14 (Existing housing) 3.15 (Coordination of housing development and investment) 3.16 (Protection and enhancement of social infrastructure) 3.17 (Health and social care facilities) 3.19 (Sports facilities) London’s Economy 4.1 (Developing London’s economy) 4.6 (Support for and enhancement of arts, culture, sport and entertainment provision) 4.8 (Supporting a successful and diverse retail sector) 4.12 (Improving opportunities for all) London’s response to climate change 5.1 (Climate change mitigation) 5.2 (Minimising carbon dioxide emissions)

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5.3 (Sustainable design and construction) 5.5 (Decentralised energy networks) 5.6 (Decentralised energy in development proposals) 5.7 (Renewable energy) 5.8 (Innovative energy technologies) 5.9 (Overheating and cooling) 5.10 (Urban greening) 5.11 (Green roofs and development site environs) 5.12 (Flood risk management) 5.13 (Sustainable drainage) 5.14 (Water quality and wastewater infrastructure) 5.15 (Water use and supplies) 5.16 (Waste self-sufficiency) 5.18 (Construction, excavation and demolition waste) 5.21 (Contaminated land) London’s transport 6.1 (Strategic approach) 6.2 (Providing public transport capacity and safeguarding land for transport) 6.3 (Assessing effects of development on transport capacity) 6.5 (Funding Crossrail and other strategically important transport infrastructure) 6.7 (Better streets and surface transport) 6.9 (Cycling) 6.10 (Walking) 6.11 (Smoothing traffic flow and tackling congestion) 6.12 (Road network capacity) 6.13 (Parking) London’s living places and spaces 7.1 (Building London’s neighbourhoods and communities) 7.2 (An inclusive environment) 7.3 (Designing out crime) 7.4 (Local character) 7.5 (Public realm) 7.6 (Architecture) 7.7 (Location and design of tall and large buildings) 7.8 (Heritage assets and archaeology) 7.13 (Safety, security and resilience to emergency) 7.14 (Improving air quality) 7.15 (Reducing noise and enhancing soundscapes) 7.18 (Protecting local open space and addressing local deficiency) 7.19 (Biodiversity and access to nature) 7.21 (Trees and woodlands) 7.22 (Land for food) Implementation, monitoring and review 8.1 (Implementation) 8.2 (Planning obligations) 8.3 (Community infrastructure levy) 8.4 (Monitoring and review for London) London Plan Supplementary Planning Guidance /Documents - Housing - Accessible London: achieving an inclusive environment

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- Sustainable Design & Construction - Providing for Children and Young Peoples Play and Informal Recreation - The London Housing Strategy - The London Plan: Interim Housing Supplementary Planning Guidance (April 2010) - The Mayor’s Transport Strategy - The Mayor’s Biodiversity Strategy - The Mayor’s Energy Strategy - London Housing Design Guide (Interim Edition) (August 2010) - Draft Shaping Neighbourhoods: Children and Young Peoples Play and Informal Recreation (Feb 2012) - Planning for Equality and Diversity in London Local Development Framework Ealing’s Unitary Development Plan is to be replaced by the Development Plan Documents (DPDs) that will comprise the Borough’s Local Development Framework.

Ealing adopted the Development (or Core) Strategy and Atlas of Changes to the Adopted UDP Proposals Map 2004 in April 2012. The council has published for consultation the Development Sites, Development Management and Policies Map DPDs together with a number of supplementary planning documents. The consultation commenced on 29 June 2012 and will run for eight weeks up to 24 August 2012.

Ealing’s Development (or Core) Strategy, April 2012 1.1 Spatial Vision for Ealing 2026 - (a), (b), (d), (e), (f), (g), (h), (i), (j), (k) 1.2 Delivery of the Vision for Ealing – (a), (c), (d), (f), (h), (k), (m) 2.1 Realising the value of the Uxbridge Road / Crossrail Corridor 2.3 Regenerate South Acton 5.4 Protect the Natural Environment – Biodiversity and Geodiversity 5.5 Promoting Parks, Local Green Space and Addressing Deficiency 5.6 Outdoor Sports and Active Recreation 6.1 Physical Infrastructure 6.2 Social Infrastructure 6.3 Green Infrastructure 6.4 Planning Obligations and Legal Agreements Land Use Designations Ealing’s Development Strategy 2012 identifies the site as having the following designations: - Map 1: Development Corridor - Map 2: Uxbridge Road Corridor and Potential Housing Site - Map 3: Uxbridge Road Corridor Housing Site with capacity of 200+ units - Map 5: South Acton Development Area - Map 7: Public Open Space Ealing Unitary Development Plan ‘Plan for the Environment’ (saved policies) Chapter One: Strategy 1.10 Legal Agreements and Partnerships Chapter Two: Environmental Resources and Waste 2.1 Environmental and Other Sustainability Impacts

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2.5 Water – Drainage, Flood Prevention and Environment 2.6 Air Pollution and Quality 2.7 Contaminated Land 2.9 Energy 2.10 Waste Minimisation and Management Chapter Three: Green Space and the Natural Environment 3.4 Public and Community Open Space 3.5 Land for Sports, Children’s Play and Informal Recreation 3.6 (Allotments) 3.8 (Biodiversity and Nature Conservation) 3.9 (Wildlife Protection) Chapter Four: Urban Design 4.1 Design of Development 4.2 Mixed Use 4.3 Inclusive Design – Access for All 4.4 Community Safety 4.5 Landscaping, Tree Protection and Planting 4.8 Conservation Areas 4.9 Ancient Monuments and Archaeological Interest Areas 4.10 Commercial Frontages and Advertising Signs 4.11 Noise and Vibration 4.12 Light Pollution 4.14 Television Satellite Dishes, Radio Masts and other Apparatus Chapter Five: Housing 5.2 Affordable Housing 5.3 Lifetimes Homes and Wheelchair Housing 5.4 Range of Dwelling Sizes and Types 5.5 Residential Design 5.6 Small Dwellings and Flats 5.9 Extensions and Alterations to Private Houses and Gardens Chapter 6: Business 6.2 Proposals for Office Development Chapter 7: Shopping and Town Centres 7.2 New Shopping Development and the Sequential Approach 7.3 Designated Shopping Frontages 7.4 Non-Designated Shopping Frontages 7.5 Basic Shopping Needs 7.6 Eating, drinking and Entertainment 7.7 Other Shopping Centre Uses Chapter 8: Community Facilities 8.1 Existing Community Facilities 8.2 Major Developments and Community Facilities 8.3 Redundant Community Facilities 8.6 Facilities for Young Children Chapter Nine: Development, Access and Parking 9.1 Development, Access and Parking 9.4 Buses

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9.7 Accessible Transport 9.8 Low Car Housing and City Car Club 9.9 Highways and Traffic Management Ealing Supplementary Planning Guidance/Documents - SPG 1 Sustainability Checklist - SPG 2 Water, drainage and flooding (draft) - SPG 3 Air Quality (draft) - SPG 4 Refuse and recycling facilities - SPG 6 Plot Ratios - SPG 7 Accessible Ealing - SPG 8 Safer Ealing - SPG 9 Trees and development guidelines - SPG 10 Noise and Vibration - SPG 13 Garden space - SPG 20 Sustainable transport: transport assessments - SPG 21 Sustainable transport: green travel plans - SPD 1 Affordable housing - SPD 3 Low car housing in controlled parking zones - SPD 7 Car clubs - Draft SPD 9 Legal Agreements, Planning Obligations and Planning Gain PLANNING EVALUATION PRINCIPLE OF DEVELOPMENT The application site comprises an existing municipal housing estate. The layout, functionality and condition of the majority of existing estate buildings are in poor physical condition resulting from their inadequate design and apparent poor maintenance. According to the Council’s own 2008 review, Decent Homes works alone would not provide the transformational effect that the area requires and therefore this estate was considered to require a higher level of intervention. The South Acton Estate is identified as an area for regeneration on Map 2.5 of the London Plan. Policy 2.14 of the London Plan states that “Within areas for regeneration shown on Map 2.5 the Mayor will work with strategic and local partners to co-ordinate their sustained renewal by prioritising them for neighbourhood-based action and investment”. Policy 2.3 of Ealing’s Development Strategy provides explicit support for the continued regeneration of the South Acton Estate: (a) To regenerate South Acton to achieve an attractive and popular residential locality, integrating the municipal and owner occupied residential areas and creating easy pedestrian access to Acton town centre. This will lead to the provision of 862 additional mixed tenure homes. (b) To further explore opportunities for creating a district energy network. South Acton has been a regeneration priority for the council for some time, due to the poor condition of the housing and blocks, poor layout, lack of cohesion on the estate and disintegration with the surrounding locality, including the High Street, and its status as a largely mono-tenure estate and associated stigma. It also has low levels of resident satisfaction with the estate both as a place to live and with the management of homes, and also performs poorly on socio-economic measures. The council's Estates Review Report confirmed that South Acton is in need of a holistic approach to the regeneration of the estate to create a new neighbourhood and to tackle the problems above. Regeneration will also integrate the area with Acton town centre and contribute to the economic regeneration of the area, while increasing the supply of private and affordable homes.

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The South Acton Area and South Acton Estate have been identified, through the heat mapping study, as having a high potential for establishing a decentralised energy network. More specifically, the South Acton Estate can initiate an energy network, which is a substantial development with a total of 2,662 residential dwellings. Other developments in the vicinity which can act as catalysts are the Oaks Shopping Centre, Bollo Lane and Acton Town Hall Complex. Further information on establishing a district-heating network within this area can be found in the evidence base document. The site’s opportunities should be noted. The site is located in close proximity to Acton district centre and within an area that has relatively good access to public transport, including London Underground, Overground and bus services. The site offers good accessibility to a variety of retail, community, religious, educational and health services. The site provides access to a number of public and community open spaces and is also within 640 metres walking distance of Gunnersbury Park, a 75-hectare, Grade II listed landscape. Chiswick town centre is also in close proximity to the site. Being relatively well served by public transport facilities, the site has a public transport accessibility level (PTAL) of between 3 and 6, where residential development of a reasonably high density would be acceptable in accordance with Ealing’s Development Strategy policy 1.2(h), policy 3.4 and Table 3.2 of the London Plan. In consideration of the failings of the existing estate and the site’s opportunities, it is clear that significant work is appropriate and necessary. The options for refurbishment and partial redevelopment have been considered by the Council, applicant and existing residents. It was concluded and accepted that a high level of intervention was necessary and the outline planning application proposals have been prepared with the benefit of substantial public consultation with existing residents and other key stakeholders. This is not to conclude that all existing residents agree with the wholesale redevelopment approach, as demonstrated by the letters of objection to the application. However, the redevelopment approach brings with it opportunities in terms of masterplanning, architectural cohesion and proper co-ordination and planning of facilities, as well as benefits in terms of long-term management and maintenance. The significant opportunities provided by this approach are considered to outweigh the individual objections to the proposals, in view of the planning policy support for the regeneration of the South Acton Estate. The above considerations coincide with the GLA Stage I response, which provides strong support for this important estate regeneration scheme. Housing The need for, and importance of, housing provision within Ealing is very significant. Policy 1.1(a) of Ealing’s Development Strategy states, “By 2026, we aim to provide 14,000 additional homes…”, sub-point (b) identifies that the development of these new homes will be primarily concentrated in the Uxbridge Road / Crossrail corridor, town centres, around key railway stations and the municipal housing estates, including South Acton. Policy 3.3 and Table 3.1 of the London Plan set out a housing provision monitoring target of 8,900 additional homes in Ealing between 2011-2021. Policies 1.1(a) and 2.3 of Ealing’s Development Strategy are considered to accord with paragraph 47 of the NPPF, which requires that Local Planning Authorities identify key sites critical to the delivery of the housing strategy over the plan period. The ongoing need for affordable housing should also be noted. Ealing’s Development Strategy policy 1.2(a) requires that at least 50% of the housing developed in the borough up to 2026 to be affordable housing. This policy was developed following the Council’s Strategic Housing Market Assessment

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(SHMA, 2009), which identified a significant shortfall of affordable homes, particularly family-sized accommodation. The proposal would result in the phased demolition of all existing residential dwellings constructed before 2001 and their replacement with up to 2,350 residential units across Phases 2-11 of the masterplan. A significant issue with the existing estate housing is that there is a poor mix of dwelling types and tenures across the site. The applicant identified that the existing estate is dominated by social rented one and two bedroom units. In 2005, 80% of residential units were in social rented tenure and 80% were two-bed or smaller. Policy 3.14 of the London Plan resists the loss of housing, including affordable housing, without its planned replacement at existing or higher density. This policy also states that, at least, equivalent floorspace should be provided in housing redevelopments. Paragraph 3.82 in support of Policy 3.14 gives further advice on the Mayor’s approach to estate renewal and further detailed guidance is set out in Section 20 of the Mayor’s supplementary planning guidance ‘Housing’ (2005). This clarifies that there should be no net loss of affordable housing, which may be calculated on a habitable room basis, and should exclude right to buy properties. The guidance also states that replacement affordable housing may be of a different tenure mix, where this achieves a better mix of provision. The section on ‘Estate Renewal’ within the consultation draft ‘Housing SPG’ (2011) reinforces this approach, and clarifies that in order to support the strategic need for family housing, densities may be increased. Policy 3.11 of the London Plan and the sub-text to policy 1.2(a) of Ealing’s Development Strategy seek to secure 60% of the total affordable housing provision as social or affordable rent and the remaining 40% for intermediate tenure (shared ownership, intermediate rent or intermediate sale). Policy 3.8 of the London Plan requires that new development proposals offer a range of housing choices, in terms of the mix of housing sizes and types. This policy also highlights that the provision of affordable family housing should be addressed as a strategic priority in the Borough’s Local Development Framework policies. The general aspirational bed-size mix outlined within Ealing’s SPD1 (Affordable Housing) seeks to secure 27% 1-bedroom, 37% two-bedroom, 24% three-bedroom and 12% four-bed + accommodation in affordable tenure. SPD 1 must be read as a borough-wide, strategic document and clearly differences in need exist within the Borough. Applications must also be considered on their merits and against the various constraints imposed on them, which dictate their appropriateness for the type of varied dwelling mix achieved. In response to the planning policy requirements set out above, and to their own legal responsibilities set out under the Principal Development Agreement (PDA) with the Council, the applicant has proposed a significant level of affordable housing provision. The quantum, breakdown by tenure and size, and acceptability of the housing standards are appraised later in this report. Land Use The predominant use of the site is for residential accommodation, and this would not change as a result of the masterplan proposals. Residential unit numbers would increase from 1998 units in 2005, to 2,771 units following the completion of the masterplan proposals, and including the earlier development provided within the estate since 2005. Therefore, there would be no overall loss of housing from the site. The non-residential uses within the application site, including existing retail, office, hotel and community uses would be broadly similar to the existing provision, with the exception of the hotel use which would not be re-provided within the masterplan proposals. The applicants’ review of existing non-residential uses indicates that there is currently 2955sqm floorspace in a combination of retail (A1) / office (B1) / community (D1 / D2) Use Classes. The masterplan proposals would effectively re-

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provide a similar spread of uses, with a relatively small uplift in floorspace of 443sqm, mainly comprising a larger provision of community and retail floorspace. The location, phasing and adequacy of the proposed community facilities are considered to be acceptable. The provision of a community hub within the centre of the site is a fundamental aspect of the masterplan proposals. The new community centre in Phase 6 of the development would replace the various community (D1) uses that are currently provided in different areas of the site. It is proposed that a facility with a minimum gross internal area (GIA) of 926sqm, for the replacement of the Oak Tree community centre and Bollo Brook youth centre would be constructed and ready for use before the existing Oak Tree centre is demolished. In addition, the existing community uses located within Hardy Court, Buchan House and Ragley Close would also be accommodated within the new central hub. The total floorspace of these relocated uses would be 1422sqm. The applicants have advised that the relocated community groups, comprising the Tallo Centre, United Anglo Caribbean Society, Pupil Parent Partnership, Working Men’s Club, Action Acton, Acton Community Forum, SARAG and Ealing Council’s Regeneration office, would be accommodated within the central community hub. The reprovision of, and small uplift in floorspace to be used for community uses is considered to comply with policies 1.1(e) and 1.2(d) of Ealing’s adopted Development Strategy and policies 8.1, 8.2, 8.3 and 8.6 of the Ealing Unitary development Plan ‘Plan for the Environment’ 2004. Bollo Brook youth centre, which is currently located within South Park, would be temporarily relocated within Bollo Brook Park, between Phases 3 and 6. The implications of this on the public open space and neighbouring amenity are addressed in further detail within a subsequent section of this report. The proposed re-provision and small uplift in retail floorspace raises no significant land use concerns. Although there are suitable and viable sites for new retail development in Acton district centre, it is considered that the amount of retail floorspace proposed within the development would not have an unacceptable impact on the district centre and is likely to be occupied by convenience retailers mainly serving residents of the completed development. The applicants’ Retail Statement provides details of the key facts and figures of the existing Acton district centre, as set out within the West London Joint Retail Needs Study Update (WLRNS) (prepared by Tym & Partners, published May 2010). One of the conclusions of the Retail Statement is that, overall, Acton district centre is considered a vital and viable centre. The main development plan policies that support the re-provision of the retail facilities of a local nature within the site are Section 8 (and in particular, paragraph 70) of the NPPF; policies 3.1, 4.8, 7.1 and 7.5 of the London Plan; policy 1.1(a) and (b) of Ealing’s Development Strategy; and policy 7.5 of Ealing’s UDP. These policies, inter alia, seek to ensure that development does not lead to the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs. The application site currently has a designated retail frontage comprising the units at 96-108 Bollo Bridge Road (which is the ground floor of Hardy Court). This designated frontage provides approximately 542sqm of floorspace that could be used for retail use, although not all units are currently occupied for such use. In addition, five units are located adjacent to 96-108 Bollo Bridge Road and provide a further (approximately) 377sqm floorspace that the Local Planning Authority would be likely to give planning permission to be used in an A1 (retail) use class. There is currently 919sqm floorspace that is used for a number of commercial, office and community related uses. In addition, there is a small shop of 31sqm located within the northern part of the site, on Ragley Close. The indicative total retail floorspace within the proposed development would be 1,050sqm, and the largest single-unit would be a maximum of 450sqm floorspace. This overall provision represents an additional 100sqm of floorspace from the area available in Hardy Court and within the north of the site,

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which is considered to be an unsubstantial increase in the amount of retail floorspace that could be accommodated within the site. The proposed stacking of residential accommodation above the proposed non-residential uses raises no concerns in relation to compatibility, however amenity, access and servicing issues for the relevant development zones (Blocks 3.1, 6.1, 6.2 and 9.3) will need to be given further consideration at the reserved matters application stage. The existing owner of the Osborne Hotel, a 12-room hotel located on Osborne Road, has raised an objection to the outline application because the hotel is not re-provided within the masterplan proposals. Policy 4.5 of the London Plan supports hotel developments within town centres and opportunity and intensification areas, where there is good public transport access to central London and international and national transport termini. Emerging policies relating to economic development are contained within chapter 4 of Ealing’s Development Management Plan. Ealing’s corresponding policy to 4.5 of the London Plan identifies that hotel development in the Borough will be directed toward Acton, Ealing and Southall town centres, and to locations with good transport accessibility. As the site is located outside of the town centre, there may be some planning resistance to the re-provision of a hotel use within the site, as there is a clear preference for tourist accommodation to be provided in town centres. It would also be crucial that any re-provision within the site did not result in the loss of housing. The applicant has indicated that they will continue a dialogue with the owner of the Osborne Hotel to develop a proposal for re-provision of the hotel later in the regeneration programme, which would require separate planning permission. However, the current proposal does not make provision for the existing hotel to be reprovided and there are no development plan policies that would resist this loss in land use terms. HOUSING Introduction The ongoing need for housing, including affordable housing, has been set out above. In 2005, the South Acton Estate contained 396 units (1,425hr) in leasehold / freehold tenure, and 1,602 units (4,641hr) in a combination of social rented tenure and over 55’s accommodation. Since 2005, the following buildings have been demolished:

Right to Buy Units (habitable rooms)

Rented Units (habitable rooms)

Lawrence Court 4 (8) 8 (28)

Verne Court 8 (48) -

Shaw Court 12 (36) -

Reade Court 2 (10) 10 (34)

Maugham Court 8 (28) 33 (86)

Bollo Court 9 (43) 21 (95)

Kipling Tower 7 (19) 87 (203)

Blackmore Tower (Phase 2) 7 (19) 87 (203)

Total 57 (211) 246 (649)

Table 1: Demolitions within the South Acton Estate since 2005. Source: Data taken from a range of sources provided by Ealing’s Housing Regeneration Service It could therefore be estimated that there are presently 339 units (1,214hr) in private sale tenure, and 1,356 units (3,992hr) in social rented tenure within the application site, giving a total of 1,695 units (5,206hr) all of which will be demolished under the current masterplan proposal.

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The redevelopment that has taken place since 2007 within the southern part of the estate by Catalyst Housing Association, known as Phases 2.1 and 2.2 have incorporated 254 units (890hr) in affordable tenure. The Phase 1 development undertaken by Acton Gardens LLP, which is under construction, includes 87 units (269hr) in affordable tenure, as well as 80 units (223hr) in private sale tenure. The combination of these earlier phases of development has therefore re-provided a total of 341 units (1159hr) in affordable tenure, and this represents an additional 713 habitable rooms in affordable tenure in comparison to the housing that was accommodated within the relevant sites prior to redevelopment. Therefore, for the current masterplan to ‘break even’ in terms of the re-provision of housing, the proposal would need to re-provide 1,202 habitable rooms in private sale tenure, and 3,482 habitable rooms in affordable tenure, giving a total of 4,684 habitable rooms. The Phase 2 -11 development would provide a maximum of 2,350 units with 7,779hr. The applicant has indicated that the Phase 2-11 development could include 1,190 units (3,922 hr) in affordable tenure, subject to further financial viability testing. The balance of 1,160 units (3,857hr) would be provided in private sale tenure. The proposed bed-size mix, habitable room numbers, and tenure breakdown of the proposed Phase 2-11 development is summarised in the table below:

UNIT TYPE TENURE TOTAL

Private Sale Intermediate Social / Affordable Rent

1-bed 349 107 255 711

2-bed 449 153 353 955

3-bed 360 47 205 612

4-bed 2 0 70 72

Total by Tenure 1160 49.36% 307 13.07% 883 37.57% 2,350

Total HR 3857 49.5% 908 11.7% 3014 38.8% 7,779

Table 2: Proposed Phase 2-11 Housing and Tenure Mix. Source: Data taken from Planning Supporting Statement Appendix II Affordable Housing Statement (Feb 2012) (Terence O’Rourke Ltd) The proposed development within Phases 2-11 would provide an additional 821 units (2,643 hr) in private sale tenure, and an additional 440 habitable rooms in affordable tenure. Consequently, the proposal would not result in the loss of housing from the site, in accordance with policy 3.14 of the London Plan. Affordable Housing and Viability Based on the proposed unit numbers and habitable rooms, the combined affordable element (affordable / social rent, intermediate tenure and over 55’s accommodation) would represent 50.6% of the total development. This figure, overall, meets and exceeds the requirements prescribed under policy 1.2(a) of Ealing’s Development Strategy. However, each phase of the masterplan development would need to demonstrate that the maximum reasonable amount of affordable housing is being provided, and specifically, that 50% of the proposed uplift in housing being accommodated on the site would be provided in affordable tenure, over and above the reprovision of the existing affordable units. As noted above, the masterplan proposal would indicatively provide an additional 440 habitable rooms in affordable tenure, but likewise, would incorporate an additional 821 units with 2,643 habitable rooms in private sale tenure. The outline application has been accompanied by a confidential Financial Viability Appraisal to justify the level of affordable housing being provided across the masterplan proposals. The GLA Stage I response specifically highlighted that in accordance with the requirements of policy 3.12 of the London

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Plan, the applicant would be required to demonstrate that the private market units would cross subsidise the provision of affordable housing. Any financial surplus would be subject to the London Plan affordable housing requirements. In response, the Housing Regeneration Service, on behalf of the Local Planning Authority, commissioned an independent appraisal of the applicants’ Financial Viability Appraisal. The conclusion of the independent appraisal is that the model provided by Acton Gardens LLP shows a negative land value for the project phases 3-11. In this regard, the Council’s Housing Regeneration Service has confirmed that should the surplus from the open market housing sales improve from the surplus or deficit identified within the applicants’ pre - planning viability appraisal, the Council have put in place contractual arrangements with the developer within the PDA to ensure that the relevant land value, effective subsidy and overage is either returned to the Council or re-invested in future phases of the regeneration proposals. The Planning Service could be satisfied that such terms would not need to be repeated in the S106 agreement because the PDA is an existing legal agreement between the Council and Developer. One of the contractual obligations includes an independently assessed two stage viability appraisal which must be undertaken before the Council could transfer the relevant part of the site to the Developer, on a phase by phase basis. At the ‘Overage Calculation Date’, the calculation of ‘overage’ would be secured through an ‘open book’ provision within the PDA that requires Acton Gardens to demonstrate that it has properly incurred the expenditure in undertaking that phase of the development. Where additional surplus over the prescribe level is identified, the PDA ensures that the agreed amount is returned to the Council (post community hub Phase 6) or is used to support future phases of development (early phases leading to community hub-phase). In view of the above, it is considered that the financial viability appraisal demonstrates that the proposed quantum of affordable housing is the maximum that this masterplan proposal could provide. Notwithstanding this, it would be necessary for the reserved matters applications for each subsequent phase of the master plan to be accompanied by a financial viability assessment to support the relevant provisions within the PDA and also to ensure that the proposals comply with the requirements of policy 3.12 of the London Plan and policy 1.2(a) of Ealing’s Development Strategy; which is to secure the maximum reasonable amount of affordable housing on a case by case basis. A S106 obligation is included to secure such provision as well as the quantum of affordable housing that is set out within the application. Tenure

Phases 2-11 of the outline masterplan would indicatively introduce an additional 821 private sale units (with 2,643hr) and 307 units (with 908 habitable rooms) in intermediate shared ownership tenure. The GLA Stage I response confirmed that this would assist in providing a range of housing across the estate and to achieve a more balanced mix of tenures, in accordance with policy 3.9 of the London Plan. Policy 3.11 of the London Plan and the sub-text to policy 1.2(a) of Ealing’s Development Strategy seek to secure 60% of the total affordable housing provision as social or affordable rent, and the remaining 40% for intermediate tenure (shared ownership, intermediate rent or intermediate sale). The rented component of the outline proposal would comprise 74% of the total affordable housing, with the balance of 26% being provided in intermediate tenure. The first priority for estate regeneration schemes is to reprovide affordable housing to meet decant requirements, and whilst not in strict conformity with the London Plan and Ealing’s Development

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Strategy, an objection is not raised to the proposed split between the different affordable housing tenures as the proposals represent an appropriate response to the decant requirements of the site. The GLA have also confirmed that they are satisfied with this aspect of the proposal. Bed size mix and size of accommodation Policy 3.8 of the London Plan requires that new development proposals offer a range of housing choices, in terms of the mix of housing sizes and types. This policy also highlights that the provision of affordable family housing should be addressed as a strategic priority in the Borough’s Local Development Framework policies. The general aspirational bed-size mix outlined within Ealing’s SPD1 (Affordable Housing) seeks to secure 27% 1-bedroom, 37% two-bedroom, 24% three-bedroom and 12% four-bed + accommodation in affordable tenure. SPD 1 must be read as a borough-wide, strategic document and clearly differences in need exist within the Borough. Applications must also be considered on their merits and against the various constraints imposed on them, which dictate their appropriateness for the type of varied dwelling mix achieved. It is of further relevance that the Council does not have any specific bed-size mix requirements for private sale housing. Policy 3.8 of the London Plan encourages a full range of housing choice, with additional guidance provided in the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes. In addition, policy 1.1C of the ‘London Housing strategy’ sets a target for 42% of social rented homes to have three of more bedrooms. The indicative bed size mix of the affordable / social rented accommodation would include a significant proportion of family-sized accommodation, accounting for 31% of the total number of units. In combination with the earlier phases of development, there would be substantial uplift in the number of family-sized units within the site. The private sale accommodation would also include a significant proportion of family-sized accommodation, which also accounts for 31% of the total units. The applicants have agreed to a S106 obligation that requires that the proportion of family-sized units in affordable tenure be increased to 35% within masterplan proposals, in closer conformity with the Council’s SPD1 requirements (which is 36%). An objection to the outline application has been received in relation to the proportion of family-sized accommodation. The objector considers that the masterplan proposals fail to address the changing needs of families who are accommodated within the site. It is significant that in 2005, 80% of the total units in affordable tenure were one and two bedroom properties, including 81-studio units. It is clear that the masterplan proposal would provide a better mix of accommodation, including family-sized accommodation. Significantly, the development would not reprovide studio accommodation, which is now discouraged at a strategic level particularly in affordable tenure. An appropriate level of family accommodation is therefore proposed taking account of the make-up of the units within the existing estate. It is considered that the proposed bed-size mix would provide a good range of housing choice, broadly in accordance with policy 3.8 of the London Plan and the Council’s adopted SPD1. HOUSING STANDARDS Policy 5.5 of Ealing’s UDP requires that residential development provide good living conditions for residents by ensuring that the accommodation provides an attractive outlook and sense of privacy; adequate indoor living space and garden space related to the accommodation; adequate sunlight and daylight; and play space for children. The Council’s SPG 14 ‘Indoor Living Space’ has been replaced by policy 3.5 of the London Plan and supporting Table 3.3 ‘Minimum space standards for new development’. Policy 3.5 seeks to ensure that new development is of the highest quality internally, externally and in relation to its context. Table 3.3 sets the minimum indoor living space requirements

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for new development in relation to the number of occupants and taking account of the typical space required for furniture and different activities within the home. As the outline application has been submitted with all matters reserved for later determination, a detailed appraisal of the layout, outlook, access to daylight and sunlight and other qualitative indicators could not be made at the present time. However, the Design and Access Statement and Design Code provide the necessary commitments to ensure that the proposed residential accommodation would be provided broadly in accordance with the current development plan standards. Based on the information provided in the Design and Access Statement, the proposed development would be designed to be tenure blind and the internal space standards of the residential units would meet or exceed the London Plan standards. The Design and Access Statement (Section 8.1) also advises that given the evolving nature of the housing standards in London, particularly the London Housing Design Guide (Interim Edition), that future development of individual sites within the masterplan may be subject to revised requirements. Internal Space Standards The Design and Access Statement advises that the private, rented and intermediate housing would be designed to meet the criteria set out in Priority 1 of the London Housing Design Guide and to the following space standards:

Dwelling type (bedroom / persons)

London Plan Table 3.3 GIA (sqm)

South Acton Estate masterplan target GIA (sqm)

Single storey dwelling 1b2p 50 50

2b3p 61 61

2b4p 70 73 (increased)

3b4p 74 74

3b5p 86 94 (increased)

3b6p 95 95

4b5p 90 90

4b6p

99 99

Two storey dwelling 2b4p 83 83

3b4p 87 87

3b5p 96 110 (increased)

4b5p 100 120 (increased)

4b6p 107 107

Table 3: Internal Space Standards. Source: Section 8.2 of the Design and Access Statement (prepared by HTA) The provision of family-sized accommodation that exceeds the minimum space standards is supported. Stacking of development within individual blocks would also be a matter for later consideration, but is a matter that if not carefully considered, could potentially cause nuisance between the different floors of development. In this regard, living rooms and kitchens should not be located above bedrooms. Existing residents have raised concerns about the potential for new accommodation to be smaller than existing housing within the estate. The internal space standards of the new development would meet contemporary planning standards and it is considered that the new housing would be of a high

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standard of design and environmental sustainability. Consequently, a planning objection is not raised and it is not considered that the masterplan could be refused because a limited number of replacement dwellings could potentially be smaller than existing units. It is further noted that objections have been received from existing residents about the internal arrangements of new dwellings. In particular, some residents would have a strong preference for kitchens to be separate from living rooms, and also for bathrooms to be naturally ventilated. Concerns about internal storage have also been raised. The outline application does not provide details of the internal arrangements of units and is a matter for later consideration under the reserved matters applications. Standard 4.4.3 of the London Housing Design Guide (Interim Edition) (LHDG) recommends that dwellings with three or more bedrooms should have two living spaces, for example a living room and a kitchen-dining room, and both rooms should have external windows. This arrangement is recommended so that a degree of separation is provided, at least between the living space and work area of the kitchen. The LHDG also acknowledges that where housing is being designed for specific cultural needs, that designers may find a preference for the kitchen to be separated from the living and dining space and that different cooking methods may demand larger kitchens with better ventilation. Existing residents are encouraged to engage in the pre-application consultation events being managed by the applicant so that issues are raised at the appropriate time in the evolution of the detailed design of individual blocks, particularly any cultural requirements for sleeping arrangements and kitchen-dining-living room arrangements that may be necessary. Accessibility Policy 3.5 of the London Plan is concerned with the quality and design of housing developments and specifically requires that the housing be designed to meet the changing needs of occupiers over their lifetime. Policy 3.8 of the London Plan and 5.3 of the Ealing UDP requires that housing is built to ‘The Lifetime Homes’ standards and that 10% of housing, across all tenures and size mix are designed to be wheelchair accessible or easily adaptable for wheelchair users. The applicants have advised that they are committed to providing an inclusive design for safe and easy use for all future occupiers, regardless of ability. Whilst all new dwellings would be designed to meet the 16 design criteria that comprise the Lifetime Homes standards, the Design and Access Statement specifically highlights that some parts of the site, such as the northern character area (north of Avenue Road), has specific topographical or physical constraints that may require a site-specific relaxation of the Lifetime Homes gradients. The Council’s Access Officer has not raised a concern about this; however, pre-application discussions would be encouraged before the submission of the reserved matters applications for the relevant phases of development north of Avenue Road. In addition to all homes being designed to meet the Lifetime Homes standards, 10% of the proposed residential dwellings would be designed to meet Wheelchair design standards, in accordance with policies 3.8 of the London Plan and 5.3 of Ealing’s UDP. Of these units, the rented tenure housing would be wheelchair accessible, whilst the private and shared ownership wheelchair housing would be adaptable units, designed to the Habinteg Wheelchair Housing Design Guide 2006 and the GLA Best Practice Guidance – Wheelchair Accessible Housing 2007. This is considered to be acceptable. Secured by Design One of the criticisms of the existing estate highlighted during the pre-application consultation and also in letters of objection to the application is the fear of crime and anti-social behaviour particularly in areas of public open space and outside buildings. Areas of undercroft car parking within the ‘red brick’ area, in particular, have become disused due to historic misuse. It is crucial that the masterplan reduces opportunities for crime to occur.

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Policy 7.3 of the London Plan sets a strategic requirement that Boroughs seek to create safe, secure and appropriately accessible environments where crime and disorder, and fear of crime do not undermine quality of life or community cohesion. Policy 4.4 of Ealing’s UDP requires that the layout and design of new development be based on the promotion of a safe and secure environment, including the maximum possible adoption of natural surveillance of public spaces. The applicant has responded to this requirement by advising that each phase of development would be designed to achieve Secure by Design accreditation post-completion. The Design and Access Statement (Section 8.8) provides details of how the masterplan proposals respond to the seven attributes of sustainable communities, as set out in ‘Safer places – The Planning System and Crime Prevention’. Of the seven principles, all except two relate to urban design considerations such as designing new housing with clear ‘fronts’ and ‘backs’ and providing external spaces that are clearly defined, well overlooked and designed to be fit for purpose. The other two principles relate to physical protection (security features) and on-going management and maintenance of the development and public realm. The Crime Prevention Design Officer advised that the intention to adopt the principles of Secured by Design (SBD) is supported. The one area that should be given particular consideration at this early stage in the development of the design principles is the number of flats accessed from each communal core entrance. SBD looks for 10 flats per core and if this is exceeded then additional security should be provided. It is strongly recommended that if more than 10 flats are accessed from one core then secondary access controlled doors are installed to create secure groups of up to 10 flats. The reserved matters applications would provide the detailed layout of flat buildings, as well as car parking areas. A condition has been included that requires details of the security lighting; CCTV (where required); location, access and design of post-boxes; and design, location and details of entry systems. There are also conditions relating to the design of landscaping, street lighting and boundary treatments. Amenity Space Policy 5.5 of Ealing’s UDP states that residential development should provide good living conditions for residents and, inter alia, provide adequate indoor living space, and garden space well related to the accommodation. Section 4.2 of the Design and Access Statement provides an assessment of the indicative masterplan scheme against the Council’s private and semi-private (communal) open space requirements, as prescribed by Table 5D of Ealing’s UDP and Supplementary Planning Guidance Note 13: Garden Space. The proposed housing mix contains 2,254 flats, which in accordance with the Council’s current planning guidance would require 33,810sqm of semi-private amenity space. A calculation of the indicative semi-private amenity space to be provided to the rear of flats buildings is 23,350sqm; an under provision of 10,525sqm. This calculation excludes the following:

- Private amenity space to houses, which will typically be 50sqm; - A 3m offset from the building line for front gardens / privacy strip at street level; - A 3m offset from the building line within courtyards for private amenity space to ground floor /

podium level units. In addition, the applicants have proposed that all new flats have balconies of a size that complies with the London Housing Design Guide (Interim Edition) (LHDG). LHDG prescribes a minimum of 5sqm private outdoor space for 2 person dwellings, with an additional 1sqm being required for each additional occupant. The required minimum width and depth for all balconies and other private external spaces is 1500mm, which is sufficient space to allow occupants to have a meal around a

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small table, clothes drying, or for a family to sit outside with visitors. It may be necessary for balconies to be enclosed in locations within the site that are particularly noisy, such as those units fronting onto Bollo Lane or the railway line to the south. The Design and Access Statement provides a comparison of the amenity space in the masterplan proposals to the existing secure and enclosed semi-private amenity space within the application site. The existing provision has been calculated as 5,930sqm, whilst the proposed is 23,350sqm. Whilst noting the non-compliance with the Council’s own guidance on amenity space, it is considered that the indicative approach to the layout and quantum of semi-private amenity space within the masterplan would be broadly acceptable, particularly when considered alongside the improvements that would be made to publicly accessible open space and children’s play facilities within the site, and desire to increase the quantum of housing within the site. It is also considered that when compared to the existing layout of buildings and amenity space, that the proposed masterplan would provide a significant improvement to the quantum and quality of usable amenity space. The detailed design and layout of the amenity space is required as part of the reserved matters application submission. Playspace London Plan Policy 3.6 requires that development proposals that include housing make provision for play and informal recreation, based on the expected child population generated by the scheme and an assessment of future needs. The Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ (2008) provides a methodology for calculating the expected child population of the proposed development. This guidance sets a benchmark of ten square metres of useable child playspace to be provided per child, with under-five child playspace provided on-site. The applicant sets out an assessment of child yield, and the resultant playspace requirement, within Section 5.5 of the Design and Access Statement. This is augmented by supporting detail within the Design Code. The applicant has conducted the child yield assessment based on Wandsworth Council’s 2007 housing re-survey dataset, on the basis that it represents a more recent dataset than that used within the Mayor’s ‘Providing for Children and Young People’s Play and Informal Recreation SPG’ (2008). The predicted child yield using the 2007 dataset is 1,169 children. The methodology within the ‘Providing for Children and Young People’s Play and Informal Recreation SPG’ (2008) generates an estimated child yield of 1,612 children. This results in a requirement for 16,120 sq.m. of space for children’s play and informal recreation. The applicant has demonstrated that the outline masterplan would deliver 16,180 sq.m. of formal equipped play space and playable landscape, in addition to other public open space provided at the site. This would exceed the Mayor’s requirements. The outline masterplan seeks to provide a balance of doorstep playable space within semi-private courtyards, dedicated local and neighbourhood play spaces, playable open space, and sports facilities including an all-weather sports pitch and multi use games area in Bollo Brook Park. The overall strategy is supported, and in conjunction with the expanse of open space at nearby Gunnersbury Park, would respond well to the needs of the development. The timing of delivery of the playspace is critical to ensure that there is no interim loss of play facilities for children. The loss of South Park in Phase 3 of the masterplan would be replaced with the temporary provision of play equipment at the former Caine House site and also by the improved facilities at Bollo Brook Park and South Acton Recreation Ground. The Council’s Parks Service have secured contributions under the S106 Agreements accompanying Phase 1 (P/2010/4201) and Phase

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2 (P/2012/0711), as well as the current application, in order to provide enhanced play facilities, including the multi-use games area and all-weather sports pitch. Conditions are included in the recommendation to secure the detailed design of children’s play facilities and the timing of such provision, to ensure that the play strategy outlined within the Design and Access Statement and Design Code, is provided to the Council’s satisfaction. Contaminated Land Policy 2.7 of Ealing’s UDP requires that a contaminated land investigations is undertaken where a development site is known, or strongly suspected to be contaminated. A desktop study for the contaminated land assessment, contained within the Environmental Statement, identified that the site could contain asbestos materials, unexploded ordnance or ground gases. The Council’s Environmental Health Officer advised that the recommendations for further work detailed in Section 7 of the contaminated land assessment should be followed. Due to the historical potential contaminative uses of the site, further investigations on a phased basis would be required. This is particularly important in areas of the site that were previously inaccessible as a result of buildings and other above ground structures. A condition has been included that requires further details of the contaminated land investigation and remediation, as well as evidence that the remediation has been carried out in accordance with the approved details. Noise and Air Pollution

An Air Quality Assessment was submitted as part of the Environmental Statement. The assessment identified that the whole of the Borough is located within an Air Quality Monitoring Area (AQMA). Ealing have monitored air quality for more than 10-years and air quality objective exceedences of nitrogen dioxide and fine particulate matter have been found. Policy 2.6 of Ealing’s UDP states that developments will not be permitted in areas where air quality objectives are not currently being achieved, unless the effects on people can be demonstrated as acceptable in relation to air quality objectives. The applicants Environmental Statement identified that the development could potentially give rise to a substantial effect on human receptors from demolition, earthworks and construction, specifically in relation to the creation of dust and fine particulate matter. This impact would relate both to residents of the South Acton Estate and those neighbouring the site. The Environmental Health Officer considered the recommendations within the Environmental Statement and recommended that a condition requiring the submission of a Construction Logistics Plan, including compliance with best practice guidance on the suppression of dust. A condition has been included to this effect. The Environmental Health Officer also considered that residential units within the Bollo Lane and Bollo Bridge Road frontages, as well as those in close proximity to the proposed energy centres would require air pollution mitigation, likely to comprise mechanical ventilation. Appropriately worded conditions are included to ensure that further details of the necessary measures are provided with the reserved matters applications for the relevant development zones. A condition has also been included in relation to the restaurant / café (A3) uses to ensure that extract equipment for odour control is installed before the first use of the premises, in the interest of protecting residential amenity. The applicants Environmental Statement identifies that the post construction effect of the development on air quality would have an imperceptible magnitude of negligible significance and no further mitigation was identified as being required.

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Policy 4.11 of Ealing’s UDP states that noise-sensitive development will not be permitted where its users would suffer noise above acceptable levels, unless this can be acceptably attenuated. A Noise and Vibration assessment was undertaken as part of the Environmental Statement. This established that the dominant background noise source within the site was from traffic, aircraft and railways. The most significant adverse effect from the development on noise levels is predicted to be during the demolition and construction period. This impact would relate both to residents of the South Acton Estate and those neighbouring the site. The most significant adverse effect would be from groundwork and piling, which are predicted to exceed the adopted daytime noise criterion, as set out within the Council’s adopted SPG 10. The nature of demolition and construction work means that the worst-case situation with plant working in close proximity to residents within the site and also neighbouring the site would be over a short period. Details of the noise and vibration mitigation, which need to follow the guidance contained within SPG 10 and other best practice guidance is required as part of the Construction Logistics Plan, required by condition. The Environmental Health Officer advised that the residential units facing Bollo Lane and Bollo Bridge Road could potentially be exposed to noise exposure category C, where additional noise mitigation is required. The residential units above or adjoining the various non residential uses and the proposed energy centres (or other plant) may also require that additional noise mitigation measures be incorporated into the building envelope, to ensure that satisfactory internal conditions are provided. Conditions are included that require further details of the mitigation measures to be incorporated into the development. Hours of use (including servicing) of the non-residential units have been restricted by condition, to ensure that residential amenity is protected. The applicants Environmental Statement does not identify any significant post-construction effects from the development on existing receptors, including increases in road traffic noise from the development. Other residential quality issues

Other residential quality issues, namely outlook, privacy and natural light would need to be considered at reserved matters application stage. The Design Code provides details of the block typology, development zones, building heights and key principles relating to the four distinct character areas. It is proposed that a minimum separation distance of 18m would be provided between building frontages within the site, which is generally accepted, and that the height strategy would need to respond to site constraints and need to ensure natural light is provided into semi-private courtyards and into the residential development. It is relevant that there are no minimum requirements in the Building Regulations for daylight or sunlight provision in new buildings and the daylight credits in the Code for Sustainable Homes (CfSH) are optional, not mandatory. Ealing’s UDP policy 5.5 (Residential Design) states that residential development should provide good living conditions for residents that ensure adequate sunlight and daylight, and as such the results of the sunlight and daylight assessment are of material planning consideration. The CfSH recommends targets for the average daylight factor of at least 2% to be achieved in kitchens, and 1.5% for living rooms, dining rooms and studies. The submitted Climate Change Mitigation Strategy highlights that the average daylight factor of 1.5% may not be achieved by all new residential units. Whilst it may be unavoidable for a limited number of units to not fully comply with this guidance (i.e. ground floor accommodation which would otherwise have generous floor to ceiling heights, access to private open space and satisfactory outlook), it is considered that the majority (e.g. 80%) of dwellings should comply with the CfSH average daylight requirements. Conditions have been included that require the submission of a CfSH pre-assessment and a daylight and sunlight report for each reserved matters application submission.

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It would be necessary that the within-phase effect (i.e. the suitability of natural light within the proposed development and to existing development that is not the subject of redevelopment), as well as the between-phase effect (i.e. the effect on subsequent phases to ensure that the development would not unreasonably limit opportunities for the redevelopment of the neighbouring site), are addressed within the daylight and sunlight assessment. URBAN DESIGN

Introduction Policies within chapters 4 and 5 of the Ealing UDP (policies 4.1, 4.5 and 5.5) are concerned with guiding the design quality of Ealing’s urban form. Good urban design is considered to be fundamental to the provision of an attractive, safe, accessible and sustainable Ealing, in which people want to live, work and spend leisure time. It is also considered to be a key principle of urban renaissance, which aims to create well-designed cities that are more compact and connected. The policies within chapter 4 of Ealing’s UDP relate to the overall form of development, including the layout, integration of buildings with the public realm, landscaping, accessibility and perception of safety. Good design is central to all objectives of the London Plan and is specifically promoted by the policies contained within chapter 7, which address both general design principles and specific design issues. London Plan policy 7.1 sets out a series of overarching design principles for development in London. Other design policies in this chapter and elsewhere in the London Plan include specific design requirements relating to optimising the potential of sites, the quality of new housing provision, tall and large-scale buildings, views, built heritage and the public realm. New development is also required to have regard to its context, and make a positive contribution to local character within its neighbourhood. The NPPF also requires the achievement of high quality and inclusive design for all development (sections 6 and 7). In summary, the Mayor’s Stage I response to the masterplan proposals confirms that the applicants have responded positively to strategic design guidance provided as part of pre-application discussions with the GLA, and that the design of the outline masterplan accords with London Plan policies 7.1, 7.3, 7.4, 7.6 and 7.7. The Mayor was particularly supportive of the submission of a Design Code, to support the masterplan proposals. Section 5 of the Design & Access Statement (DAS) sets out the five themes underpinning the delivery of the vision for the regeneration of the South Acton Estate. The applicants state at paragraph 5.1.1 of the DAS that this vision was developed through consultation with the community and stakeholders. A summary of the five themes are provided below: i) Glimpses of green: It is intended that the new development will frame views into the areas of open space within the new neighbourhood. Existing mature trees will become part of the new street network, standing next to the new contemporary homes and giving the place permanence. ii) Pleasant, comfortable streets: Front doors will frame streets, providing a more traditional form of development. Every home will have a street address. Front gardens will allow residents to individualise their own space. Big windows and balconies will overlook the streets, improving the perception of safety. iii) A rich community: The masterplan will build on the strength of the existing community by providing parks and squares, community gardens and new improved sport grounds, a community hub with new community facilities, and new youth centre.

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iv) Convenient urban life: The best part of South Acton is its location; the masterplan will improve the street network, including a new bus route. A new local shop with fresh produce and a café on the square outside South Acton Overground station will bring more activity to the south, including better integration with the local residential neighbourhood to the south of the railway. v) Homes for the 21st Century: The building blocks for the new neighbourhood will be spacious, sustainable homes with generous balconies, terraces or gardens and lots of storage and utility space. Attractive apartment buildings will have big, secure entrances and less people sharing the lifts and stairs; all homes will be only a few minutes walk away from play spaces, parks and local shops. A large choice of different homes will make the neighbourhood accessible for all sectors of the community, encouraging existing residents to stay, and helping new residents settle and invest in South Acton. Design Concept and Use The vision for South Acton, which is consistent with good urban design principles, is to integrate the site to its surroundings, re-establishing a street grid with improved north-south links, creating a network of open spaces and responding to context and scale, in order to establish and reinforce character areas. This vision is based primarily on the provision of quality homes through a mix of building types including family houses with private gardens, ground floor maisonettes with private courtyards, flats with balconies/ roof terraces and over 55’s accommodation within the North Gardens (character area), close to the Acton town centre. To support the residential development and build on the existing community and educational uses at the centre of the site, a mixed-use community hub is proposed, including an anchor store (up to 450m2), a new community centre to replace the existing Oak Tree and a new youth centre to replace Bollo Brook Youth Centre. The ground floor of both new buildings south and west of the central square would be given to non-residential uses. This central provision of community facilities and retail uses would provide a focus for the development, a civic function to the square and retail presence on Bollo Bridge Road. Two smaller shops are proposed at Station Square, next to South Acton Overground station and within the West Gardens (character area) on Osborne Road, opposite the new West Park. An energy centre is also proposed to the basement and ground floor of the block facing North Park. The applicants have advised that this location was chosen in order to provide the best opportunity for buildings outside of the site to link into the energy centre, which is also an aspiration for the Council identified within the sub-text to policy 2.3 of Ealing’s Development Plan. Layout Streets within the site would be defined by a building layout that is well structured around the new north– south Boulevard, connecting the site to Acton High Street. Where this proposed Boulevard meets existing key west - east links, a central space is formed by the new community hub. These key routes would be punctuated by open spaces, which in turn would be framed and enclosed by building frontages. Landmarks and spaces would direct views, and the proposed layout would substantially improve way finding through the site. The Mayor’s Stage I response to the application considered that; The proposed development would significantly improve permeability through the estate by creating a well-connected street grid that allows for greater legibility of routes and improved movement. This is supported in line with London Plan Policy 7.1, part D, which sets out the requirement for developments to reinforce or enhance the permeability and legibility of neighbourhoods, so that communities can easily access community infrastructure, commercial services and public transport.

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The GLA and the Council’s Urban Design Officer initially raised a concern about the alignment of the new north-south Boulevard and route to South Acton Overground station. It was considered that this route might be weakened because the Boulevard would not link-up directly with Palmerston Road. The applicants have responded to this within the Design and Access Statement by providing key views of the route (taken by pedestrians and cyclists) from the southern periphery of the site, along Palmerston Road to the central hub. The indicative views illustrate that navigation along this route would be legible and would not present an issue that requires alterations to be made to the masterplan proposals. The GLA have confirmed that they are now satisfied with the approach to the design of the north-south route. Improved secondary routes to existing neighbouring streets would be provided by the proposed masterplan, particularly to the east. The demolition of estate properties in Brouncker Road would facilitate a new east-west street opposite the proposed Central Plaza (and community hub) and Brouncker Road. This new street would be lined with residential development of a maximum height varying between three and four storeys, which would assist with reinforcing the low-scale character of the adjoining residential neighbourhood. A new street would also be provided to the northern end of Brouncker Road following the demolition of Carisbrook Court. New street connections to the east are considered to blend well into the existing street network and would provide clearly defined urban blocks. A variety of block types are proposed, some with internal communal courtyards at grade, some with an internal communal landscaped podium over parking; and houses with back gardens. The strongest proposed block frontages would be to the various areas of public open space, which is encouraged, in order to provide a sense of enclosure to the spaces and provide the maximum level of natural surveillance of the public open space. Continuity of building lines and a clear definition of public ‘fronts’ and private ‘backs’ would be indicatively achieved with the proposed layout. The retention of the school and community buildings within the site, together with the retention of residential blocks constructed since 2001 would help to add variety to the townscape in terms of architectural style, age and type of buildings. The Design and Access Statement and Design Code have resisted suggesting an architectural response of the new development to the existing buildings, as this will be addressed in full detail as part of the reserved matters applications, and this is considered to be an acceptable approach in view of the nature of the outline application. The scheme exploits the site’s landscape, through the retention of nearly half of the existing, mainly groups of trees where these do not impose constraints to the perimeter block layout and clear street network. This approach is strongly supported and follows pre-application advice from the Council’s Tree Officer. Conditions are included that require further details of the retention of trees and new tree planting. Access, movement and parking The masterplan proposals generally integrate with existing roads, paths and surrounding development. New routes are created to improve north-south movement, supporting pedestrian desire lines to the High Street, Acton Town tube and South Acton Overground station. Existing, well established routes through the site are retained and enhanced. Remaining streets are arranged to form a logical network. Illustrative views and design objectives in the Design Code suggest building edges with frequent doors and windows overlooking spaces and routes, in order to promote safety and natural surveillance. Streets would appear to work well for pedestrians and cyclists. In relation to vehicles, the applicants have advised (and the Transport Officer has confirmed) that vehicle traffic around Berrymede School is currently a significant problem, even with the existing pedestrianised area between the primary school and community centre. The creation of a through-road for vehicles, which has been suggested by the Council’s Urban Design Officer, would be strongly

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opposed, as it would increase existing issues with people dropping off children by car. There is a vehicle route from both Castle Close and Osborne Road, and also vehicle access along the main north-south Boulevard. The form and character of the street between Osborne Road and the central hub would be designed to encourage safe pedestrian movement, particularly by children. Emergency and servicing vehicles (such as refuse collection) would continue to have access to the pedestrianised routes around the school. The masterplan proposes a hierarchy of streets through the site. Primary streets (Bollo Bridge Road, Avenue Road and the new Boulevard) would be wider, have regularly spaced larger trees, would support higher buildings and have parallel parking bays. Secondary streets would be more intimate in scale, with small to medium size trees every two on-street parking bays. Tertiary streets (or homezones) would be more domestic in scale and informal in character and may include shared surfaces and a combination of parallel and perpendicular parking bays. The masterplan suggests a car-parking ratio of 0.48 spaces per residential unit, in a combination of street, undercroft and courtyard parking. Finding the correct balance between gardens and car parking within level courtyards, whilst meeting parking needs for the indicative housing density in those blocks, will naturally be a challenge for future detailed design phases. Ensuring that parking in homezones and shared surfaces is well integrated so it supports the street scene should be a priority. Such considerations are matters that would be detailed within the reserved matters application for each phase (or development zone) of the masterplan. Density London Plan policy 3.4 seeks to optimise the housing potential of sites, having regard to local context, design principles and public transport accessibility. With regard to estate renewal proposals, the Mayor’s ‘Housing’ SPG (2005) acknowledges that increased density may be necessary to generate sufficient value from market development to support the replacement of affordable housing. Ealing’s Development Strategy policy 1.2(h) provides support for higher density development in areas with good transport accessibility levels and considers that the quality of the design, the location of the site and need to provide a suitable housing mix should be key to appraising the suitability of the amount and scale of development. Policy 1.2(h) also advises that tall buildings will be acceptable where they contribute positively to the urban environment and do not cause harm to existing heritage assets. The Mayor’s Stage 1 response identified that the site has a public transport accessibility level (PTAL) that varies across the site between three and six. The site is considered to be urban in character. The London Plan suggests a residential density range of between 200 and 450 habitable rooms per hectare under a PTAL 2-3 and between 200-700 habitable rooms per hectare under a PTAL 4-6. The applicants have provided density calculations across ten separate locations within the overall application site. This information could only provide an indicative density calculation, as the development parameters are a maximum indication of development. The lowest density area of 196 hr / ha is located adjoining the eastern boundary of the site, adjoining properties in Brouncker Road and Berrymede Gardens. This part of the site has a PTAL of 3 and the indicative density of development would appear to be marginally lower than the London Plan density matrix recommendations. The reason for the lower proposed density range in this part of the site is in response to the neighbouring development and need to reduce the scale of the development adjoining this sensitive boundary. Likewise, the indicative density of development adjoining the southern boundary of Heathfield Road (which is located within Mill Hill Park CA) would be 587 hr /ha, and the development zone to the east of the Mill Hill Park CA would vary between 380-411 hr/ha. These areas of the site have a PTAL that varies between 3 and 4, and the density of development would be higher than the recommended range for a site with a PTAL of 3, but within the range for a site with a PTAL of 4. Again, the density of

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development has been restricted in this area due to the need to respond to the context of the adjoining conservation area. Much higher indicative density calculations are shown within the development zones at the corner of Bollo Bridge Road and Bollo Lane, and within the central community hub. The density ranges for these development sites vary between 951 hr/ha and 1,217 hr/ha. The development has been maximised in these areas due to the desire to make a feature of the development in this visually important part of the estate, and to a lesser degree, because of their relative distance from the neighbouring conservation areas and also from neighbouring low-rise residential housing outside of the site. It is considered appropriate for density to be maximised in key locations where the impact of such development would have the least detrimental impact on sensitive neighbouring occupiers, and in view of the need to provide a significant uplift in housing accommodated within the site. It is also noted that density has been maximized where access to the Acton district centre is in close proximity and public transport is located. Matters relating to the quality of new housing and the impact on the townscape, as well as the impact of the development on neighbours would need to be addressed in further detail as part of the reserved matter applications. Scale, Height and Townscape Due to the heights of some of the existing buildings within the South Acton Estate there are a large number of buildings that are clearly visible outside of the site. This is particularly evident in the northern part of the site, where the tall towers (11-storeys) in the red brick area, and the three 14-storey towers along Avenue Road are highly visible when approaching the site from all directions. Jerome Tower, which is 17-storeys high, and Charles Hocking House, which is 13-storeys high are also visible from outside of the site and can be seen from the Mill Hill Park Conservation Area. The majority of the surrounding properties to the site are low-rise and are not therefore visible from within the estate. Glimpses of St Mary’s Church tower on Acton High Street are visible from the red-brick area. The new industrial buildings within Chiswick Business Park are visible from the southern part of the estate. In order to provide flexibility, the heights of buildings as illustrated on the parameters plan are the maximum for each plot to provide flexibility on the number of units that could be accommodated on individual sites to respond to site specific constraints and changes in circumstances. For the purposes of the assessment, the applicants have included a 2m zone to the top of each building to take account of parapets / passenger lifts. The principle of positioning lower 2 to 4-storey buildings adjoining Mill Hill Park CA is supported. An overall medium density development between 5 and 8-storeys with incidental 9 to 10-storeys markers to key routes and spaces is considered a sensible and realistic way to promote the desired integration to context in terms of massing and scale and, at the same time, deliver a viable scheme. The masterplan height strategy incorporates two blocks that could potentially be 12-storeys high. Buildings of 30m height are considered to be tall buildings. Policy 1.2(h) of Ealing’s Development Strategy states that tall buildings will be acceptable where they contribute positively to the urban environment and do not cause harm to existing heritage assets. The two 12-storey blocks are located within the northern part of the site, close to Acton High Street opposite the proposed North Park; and in the west, fronting Bollo Lane and close to Acton Town Underground station. The Council’s Urban Design Officer and Conservation Officer both consider that the 12-storey high blocks could potentially have a negative impact on the townscape and the special character and appearance of the adjoining Mill Hill Park and Acton Town conservation areas if not carefully designed. The Conservation Officer

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did not consider that the proposed development would have an adverse, negative impact on the setting of statutory listed buildings in the surrounding area. The London Borough of Hounslow acknowledged that the proposed 12-storey blocks within the western part of the site would be visible from Gunnersbury Park, but did not consider that the development would have a negative visual impact from their borough. Specific urban blocks that the Urban Design Officer has raised further concerns about include: - The existing buildings facing the south end of Palmerston Road close to the South Acton Overground station are between 6, 8 and 10-storeys high. Ideally, the 8 to 10- storey block proposed in Phase 3 (south) should be lower. The 10-storey element proposed facing the industrial estate should have a smaller footprint to be read as an individual building rather than a block frontage, consistent with the neighbouring 10-storey building to the north; - The 7 to 8-storey block between the Central Park and Bollo Brook Park seems too narrow to accommodate the heights proposed. One side or parts of both sides of this block will need to be lower to allow sufficient light inside the courtyard; - The 9-storey block immediately south of the Central Park might cast too much shade onto this key space; - The 7-storey north-eastern end on the block south of Avenue Road Park needs to drop down to provide a coherent transition to the 2-storey building adjacent on the east; - The 8-storey frontages on the blocks west and northwest of Avenue Road Park may vary in height to address the challenging angled shape and sense of enclosure within these blocks. It is relevant that the proposed height strategy provides details of the maximum heights of buildings and that the Local Planning Authority would need to be satisfied that a range of issues are addressed, not least the impact of the development on the local context. Other key considerations are set out under policies 7.6 and 7.7 of the London Plan, and seek to ensure that new development makes a positive contribution to a coherent public realm, streetscape and wider cityscape. The quality of the architecture of the tall buildings within the site will be critical to their acceptability at reserved matters stage. As will the consideration of the impact on amenity, particularly in relation to overshadowing, privacy and outlook. It is specifically noted that a number of residents to the north of the site within Mill Hill Park Conservation Area have raised an objection to the inclusion of a six-storey building where Anstey Court is currently located, on the southern side of Enfield Road. The proposed height strategy for the replacement block would be with a part three to part four storey building fronting Enfield Road, with the six storey element on the Osborne Road frontage (to the south). The existing Anstey Court is currently six-storeys high, as is the northern element of Caine House, which is located opposite Anstey Court. The proposal would significantly reduce the resulting height of buildings adjacent to the properties in Mill Hill Park Conservation Area, particularly with the demolition of the existing 17-storey Jerome Tower and 14-storey Beaumaris Tower, and replace these blocks with buildings of predominantly three-storeys height. It is not therefore considered that it would be reasonable or necessary to request any further reduction in the proposed heights of buildings adjoining the northern and western boundaries of the site. However, it would be particularly important that new buildings that would be visible from the conservation area are designed to reduce the visual impact on the character and appearance of the conservation area, in accordance with policy 4.8 of Ealing’s UDP, 7.8 of the London Plan and those considerations set out within chapter 12 of the NPPF.

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It is considered that the height strategy as proposed is broadly acceptable and that planning permission could be granted subject to the submission of reserved matters applications for further consideration by the Council’s Urban Design and Conservation Officers. Character and appearance Whilst the detailed appearance of buildings will be dealt with at detailed application stage for each phase of the development, the masterplan sets an overall feel for each of the character areas and this is expanded on in the Design Code. Four character areas are proposed, based on the site’s orientation and on the existing and new physical elements that give focus and identity to each area. South Gardens aspires to complement the character created by earlier development phases, which is built on the relationship with the South Acton Recreation Ground, the South Acton allotments and the Overground station, via Station Square. West Gardens builds on the character of Osborne Road with a more formal, grid layout around the new West Park and larger blocks enclosing more generous courtyards. The grain and scale reduces on the approach to the Mill Hill Park Conservation Area to the north. Central Gardens is the heart of the development at the crossroads between east-west and north-south routes. Community uses facing the key spaces – Central Plaza and Bollo Brook Park – will form a hub of activity. North Gardens is created around Avenue Road Park, the new North Park and the new tree lined Boulevard. The varying topography in this area will give it a distinctive character. The Design Code provides guidelines on open spaces, streets, building forms and interfaces, which are based on good urban design principles. Overall, the masterplan and Design Code suggest a design, which is specific to the scheme. The main obstacle to creating areas of distinctive character comes from the fact that the majority of the building types framing key routes and spaces will be apartment blocks of medium to high density. This similarity in typology and scale can make all areas look the same and the challenge for each detailed phase will be to create bespoke architecture to identify and distinguish each character area. Open spaces Open spaces can play a major part in improving people’s sense of wellbeing in the place they live, promote healthy living and the social development of children through play. Green spaces perform vital functions as areas for nature conservation, biodiversity and can assist in improving air-quality. Open spaces can become a focal point for community activities, bring together members of varied communities and provide opportunities for social interaction. Ealing UDP policies 3.8, 4.1, 4.5, 5.5 seek to ensure that new open spaces are provided and that they are accessible, attractive, ecologically diverse, well designed, inclusive and provide for appropriate activities. Policies 3.4, 3.5 and 3.6 of Ealing’s UDP seek to protect designated areas of public and community open space and safeguard their open character and usability. Ealing’s draft Green Space Strategy 2012-2022 will inform the relevant policies within the emerging Development Management Plan. The consultation version of Ealing’s Development Management Plan contains draft policy 7D ‘Open Space’, which requires that all developments that increase demand for open space will be expected to make an appropriate contribution towards meeting additional demand. The supporting table to this policy sets a target of 19.5sqm of open space per person to be provided by new development comprising 300+ units.

Policy 7.18(B) of the London Plan states, “The loss of local protected open spaces must be resisted unless equivalent or better quality provision is made within the local catchment area”. Paragraph 74 of the NPPF states, “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless…the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location”. Policy

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1.1(i) of Ealing’s Development Strategy seeks to protect and enhance the pattern of green spaces and ensure new development improves and adds to green space. Policy 5.5 of the Development Strategy seeks to protect open space of local value, address deficiency and to secure developer contributions to fund delivery of these proposals. Policy 3.4 in the UDP seeks to resist the loss of POS, unless it is directly related to the open space use of the land.

South Acton is designated as an area of Local Park deficiency. An early principle of the masterplan proposal was to try and address this deficiency by providing an open space of 2ha or more within the development site. During the pre-application discussions with the Local Planning Authority and Parks Service, the applicants demonstrated how a 2ha open space could have been incorporated into the site, however the implications of this on other aspects of the scheme were considered to outweigh the benefits of such provision. In particular, issues of accessibility, poor distribution, weak edges to the open space, and phasing were the principal reasons that proposed options were not taken forward. The four options for the inclusion of a 2ha park within the site are provided within the Design and Access Statement. The masterplan makes provision for a series of parks less than 2ha that will be clearly defined, provide strong identity and will be well overlooked. This approach also works well with regards to phasing of the development and overall the Council’s Landscape Officer considered the proposals to be acceptable. Open spaces within the estate currently lack definition, function and quality. Parks are well used but the lack of clearly defined frontages and natural surveillance can make them feel unsafe. The masterplan proposes a number of improvements to existing public open space, but significantly, proposes to develop on existing spaces and reprovide new parks elsewhere. The strategy of spreading open spaces across the site, to ensure all residents are less than 5 minutes walk to a park or square and maximising the amount of residential frontages overlooking public open spaces is supported. Each space would be clearly designed with a purpose in mind. The masterplan includes the following public open spaces, in comparison to the existing areas of open space within the site:

Public Open Space / Undesignated Existing Open Space

Existing (sqm) Proposed (sqm)

Difference (sqm)

South Acton Recreation Ground 13,930 13,930 -

Bollo Brook Park 5,281 5,608 +327

South Park (West Park) 4,747 4,872 +125

Avenue Road Park 8,940 4,954 -3,986

Bollo Bridge Rest Gardens (approx) 1700 - -1,700

Central Plaza (approx) 4075 9,979 +5,904

North Park - 4,136 +4,136

Hope Gardens - 740 +740

Station Square - 614 +614

TOTAL 36,973 44,833 +7,860

Temporary Caine House POS

-

1,670

+1,670

Community Open Space

Existing (sqm) Proposed (sqm)

Difference (sqm)

Jerome Allotments 3,880 2,262 -1,618

Allotments on Enfield Road - 2,291 +2,291

TOTAL 3,880 4,553 +673

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Table 4: Comparison of existing and proposed public open space. Source: Section 5.5 of the Design and Access Statement (prepared by HTA), Planning Officer’s own calculations and email prepared by A. Couch on behalf of HTA, dated 19/07/2012. The applicant has calculated that the existing population of the estate is 4,204 and that the existing provision of designated open space within the site is 0.782 hectares per 1000 head population. This compares to the proposed provision of public open space, which is 0.769 hectares per 1000 head population. The Landscape Officer has accepted that there would be a small deficit between the existing provision per capita and proposed. An objection is not raised to this in view of the expected qualitative improvements to public open space as a result of the proposals and also in view of the extensive work undertaken by the applicant to explore the provision of a public open space within the site and obstacles in achieving this and balancing this with the need to increase the housing provision within the site. There would be an interim loss of public open space from the site between the period of construction of Phase 2 (being considered under P/2012/0711) and the delivery of the new West Park in Phase 4, when a surplus of 709sqm of public open space above the existing baseline provision would be achieved. As set out within the Planning Committee report for Phase 2 (P/2012/0711), the designation of Bollo Bridge Rest Gardens was adopted following the submission of the masterplan and Phase 2 applications. It is of further relevance that Planning Policy has proposed the removal of this public open space designation from the Phase 2 site as part of the latest consultation of the emerging Policies Map. In any case, the masterplan proposal would result in the loss of the existing South Park as part of Phase 3, whilst only marginally replacing this loss through the provision of Station Square and the temporary park on the site of Caine House, which would need to be demolished to facilitate this provision. In addition, the Parks Service have secured contributions for the improvements to South Acton Recreation Ground and Bollo Brook Park under the Phase 1 application (P/2010/4201), Phase 2 (P/2012/0711) and under the S106 Agreement for this current outline application. Bollo Brook Park would incorporate a multi use games area and all-weather sports pitch. The improvements to Bollo Brook Park have been proposed as a result of consultation with local users as part of the pre-application consultation process, and following consultation with the Council’s Youth Service who currently have access to similar facilities (of a much reduced quality) within South Park. The provision of the proposed play facilities in Bollo Brook Park are acceptable under the provisions of policies 3.4 and 3.5 of Ealing’s UDP, which states that development directly related to the purpose of public open space and which accords with their open character, will be permitted. Acceptable uses include children’s play areas, including hard / artificial sports pitches. Conditions are included requiring the submission of further details of the design of the facilities, including any floodlighting, to ensure that residential amenity is not detrimentally affected by the proposal. Whilst not strictly in conformity with policies 3.4 and 3.5 of Ealing’s UDP, it is also considered that the temporary replacement of the youth facility from South Park to Bollo Brook Park to help facilitate the redevelopment proposals would be acceptable in view of this being a temporary provision between Phases 3 and 6 of the masterplan. A condition is included that would ensure that the temporary building is removed and the site re-landscaped following the completion of the permanent facility in Phase 6. Further, it is considered that there would be a mutual benefit between the Youth Centre and proposed multi-use games area and all-weather sports pitch in Bollo Brook Park, as the users are likely to be the same group. Restriction on the hours of use has been conditioned, to ensure that the neighbouring occupiers of properties fronting Bollo Bridge Road are not detrimentally impacted by the temporary use of part of Bollo Brook Park by the Youth Centre. In the circumstances of this complex proposal for the redevelopment of the estate, it is considered that the applicants proposed temporary provision of playspace and public open space within the Caine House site, as well as the provision of Station Square and funding of other improvements to existing open space is considered to be acceptable to provide adequate interim facilities until the delivery of the new West Park in Phase 4.

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The masterplan also proposes the reconfiguration and re-planning of public open space within the northern part of the site, including Avenue Road Park. As noted in Table 4, Avenue Road Park would be reduced by nearly 4,000sqm in order to provide development adjoining the rear of properties within Brouncker Road. The applicant’s Design Code provides an analysis of the Avenue Road Park, which is identified as being a large open space with sloping topography falling to the south. The existing park contains a fenced play area and additional play elements set out around a large artificial mound. SARAG have raised an objection to the loss of part of Avenue Road Park and advise that this park is the most well-utilised play space within the estate. The applicant also identified that Avenue Road Park makes a positive contribution to the estate and wider area through the pre-application consultation. The applicants have focused their proposals for this park on re-providing a large play area. The North Gardens area of the masterplan site would contain the new North Park and Hope Gardens, which in conjunction with Avenue Road Park would provide an additional 1,000sqm of public open space within the northern part of the site. It is considered that the interim and longer-term proposals for the re-provision and enhancement of public open space within the broader site would generally be in accordance with the relevant considerations contained at paragraph 74 of the NPPF, and policies 7.2, 7.3, 7.5 and 7.18 of the London Plan; policies 1.1(e), 1.1(i), 1.2(d) and 2.1(c) of Ealing’s Development Strategy, and 3.4 and 3.5 of Ealing’s UDP. There are a number of conditions included within the recommendation that secure the provision of the key areas of public open space in accordance with the indicative phasing strategy provided within the Design and Access Statement. Policies 3.4 and 3.6 of Ealing’s UDP and policy 7.22 of the London Plan resist the loss of community open space. Policy 3.6 specifically identifies that the Council will safeguard allotment sites and seek opportunities for improved provision. The proposed development in Phase 9 of the masterplan would reduce the size of the existing Jerome allotments and provide replacement allotments in close proximity, fronting Enfield Road. A Phase 1 habitat survey was undertaken as part of the Environmental Statement and at the time of the survey, the existing allotment was considered to have low value for wildlife despite being identified as a Site of Nature Conservation Value. Whilst the re-configuration and relocation of the allotments would represent an inconvenience for existing users, the new provision would provide an uplift of 673sqm, which is supported. The relocation of part of the Jerome allotments would also facilitate effective planning of development within this part of the site. It is proposed that two rows of low-scale housing are provided in this part of the site, with private rear gardens being provided in the area currently used as allotments. This arrangement would allow the retention of existing trees located within the existing allotment site. A number of conditions are included in the recommendation that require further details of the design of the public open space and community open space and for their timely provision. Trees and Biodiversity A characteristic of the existing estate is the abundance of significant trees that contribute to the visual amenities of the area. Policy 4.5 of the Ealing UDP and 7.21 of the London Plan requires the retention of trees that contribute to the character of an area. The applicants have carried out an arboricultural survey in accordance with British Standard BS5837: 2005 and this survey identified that there are currently 669 trees within the application boundary. Tree retention and removal plans and section 4.3 of the Design and Access Statement provides a summary of the existing trees to be retained and removed, and indicates that the majority of Grade A category trees would be retained (70 trees retained, in comparison to 14 to be potentially removed); as well as the majority of Grade B and C trees. In total, it is proposed that 343 existing trees would be

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retained, with a further 35 trees being considered for retention following further consideration on a site-specific basis. The principle of removing 291 trees was discussed in detail with the Council’s Tree Officer during the pre-application stage. The removal of trees was considered to be necessary in order to assist with fulfilling the masterplan aspiration of reinstating a well-connected traditional street network with efficient perimeter blocks. To determine which trees should be retained, layout options were discussed with Ealing’s Tree Officer and a number of site visits were also undertaken to inspect trees. The Landscape Officer has confirmed that the tree removal and retention strategy is acceptable. In order to mitigate the loss of trees from the site, a significant number of new trees would be planted within communal courtyards and along the key routes through the site. The tree strategy is supported on the basis that a greater number of trees will be planted across the masterplan area within the public realm than are required to be removed, particularly along the new north-south Boulevard. Details of tree protection and new planting have been secured by appropriately worded conditions. A contribution towards the long-term maintenance of street trees by the Council has also been secured under the S106 Agreement. Policies 3.8 and 3.9 of Ealing’s UDP and policy 7.19 of the London Plan seek to protect and promote nature conservation. The proposed Landscape, Climate Change Adaptation, Sustainability and Water Minimisation Strategies will combine to create a neighbourhood that promotes biodiversity and also provide good quality amenity for the residents of the site. Under the Code for Sustainable Homes Level 4, each development plot would be designed in conjunction with an ecologist to protect, enhance and reinforce the existing biodiversity of the site. The masterplan proposals incorporate significant new tree planting, with species being selected to attract flora and fauna specific to the London region and to enhance the local ecological value of the site, with an emphasis on local Biodiversity Action Plan (BAP) species. In addition, the applicants have identified that the proposals would incorporate greened walls using wire trellis systems and climbers to provide foraging habitat and nesting areas for birds; hedged boundaries to properties; extensive green roofs; and bird and bat boxes. Additional bat surveys are also recommended by the applicants Phase 1 habitat survey and Natural England have also confirmed that further surveys would be required. Appropriately worded conditions requiring further details of soft landscaping, tree planting, green roofs and green walls, and bat surveys have been included within the recommendation. IMPACT ON NEIGHBOURS

The site adjoins residential properties to the north, east and south and there are also existing properties within the South Acton Estate that are outside of the scope of the masterplan proposals. The Ealing UDP contains policies that seek to safeguard the amenity of adjoining residential properties. Ealing UDP policy 4.1 states that the Council will give consideration to the potential effects of development on visual privacy and safeguard the outlook from habitable room windows. Policy 5.5 requires that new residential development not only provide good living conditions for the future occupiers, but expects that new development provides an attractive outlook and sense of privacy for those existing residents neighbouring the development. Whilst the proposals have been made in outline, the application has undertaken a daylight and sunlight assessment based on the maximum parameters of the masterplan (height and layout of buildings). The results of the Daylight and Sunlight Assessment are provided later.

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The Environmental Statement (ES) also considers the impacts from the development on air quality, noise and vibration, and traffic, which have been addressed in other sections of this report. The ES concludes that the most significant effect on sensitive receptors (occupiers of the site and neighbouring the site) would be during the demolition and construction periods. An appropriately worded condition has been included in the recommendation requiring the submission of a Construction Logistics Plan, in the interests of reducing the associated impacts from demolition and construction activities on residential amenity. Overlooking Table 5C of policy 5.5 of the Ealing UDP recommends that a 21m separation distance is achieved between directly facing habitable room windows in order to safeguard the privacy and amenity of occupiers. The applicants have considered the requirement to provide sufficient separation between new buildings and existing residential properties adjoining the proposed development. The outline application has been made with all matters reserved for later consideration and it is considered that the development zone parameters plan has sufficient flexibility to ensure that impacts from overlooking and loss of privacy could be minimised. Daylight and Sunlight The applicants’ Daylight and Sunlight Assessment (Technical Appendix J of the Environmental Statement) considers the worst case scenario impact of the development in terms of daylight, sunlight and shadowing as building footprints have been extended to their maximum, building massing increased to maximum heights and any stepping minimised. This approach was considered to give flexibility to future designers of the individual phases of development to respond to site constraints, including microclimate impacts. The assessment has been carried out in accordance with the BRE Guidance ‘Site Layout Planning for Daylight and Sunlight’ (hereafter BRE Guidelines). The assessment compares modeled baseline conditions to model post-development conditions and assesses the impact of change resulting from the development. Over 460 buildings were modeled and 5300 separate reference points (window centres) were identified in the assessment. 87% of the buildings tested would pass both the daylight and sunlight criteria recommended by the BRE Guidelines. The daylight and sunlight assessment identifies that the residential properties to the east of the site would potentially experience the greatest impact from the development. The initial results of the daylight and sunlight assessment can be used to identify particular massed blocks that have the potential to impact the daylight and sunlight access of surrounding buildings. However, each of the separate phases of development would need to be examined in full detail as each reserved matters application is submitted. It is considered that the Local Planning Authority would have sufficient control over the detailed design of individual phases of development to ensure that the number of properties and extent of impact from the new development could be limited to an acceptable level. Condition 4 specifically requires that updated Daylight and Sunlight Assessments are provided with each reserved matters application.

TRANSPORT, PARKING AND SERVICING Following initial concerns over the methodology of the Transport Assessment (TA) submitted with this application, the applicant submitted an addendum to the original TA in June 2012 in response to questions and comments raised by Transport Officers. The addendum provides additional information to ensure conformity with Ealing's guidance on transport assessments (SPG 20: Sustainable transport: transport assessments).

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The additional work undertaken included the use of agreed TRAVL sites for outer London, use of recent traffic surveys allowing for committed developments, trip assignment based on existing turning proportions and sensitivity tests using 85 percentile trip rates. Parking Provision The South Acton Estate currently has an estimated total parking provision of 1,123 car spaces, of which only four spaces are dedicated disabled bays. Parking provision is mainly for the existing residential units and is provided in areas behind or in front of the existing residential blocks. An additional 149 controlled, short-term parking bays (30 minutes) are also located within the site. An average car-parking ratio of 0.48 spaces per residential unit is proposed. The masterplan proposes approximately 1,128 car spaces across the new neighbourhood, including on-street provision in marked bays. The layout and total number of car parking spaces would need to be further detailed as part of the reserved matters application submissions. A balance would need to be struck between providing off-street car parking, the retention of trees and the provision of amenity space. A restraint based approach to car parking is advocated by the Council’s Transport Service, TfL and the GLA, and would align with policy 6.13 of the London Plan, which seeks to prevent excessive parking that undermines walking, cycling and public transport use and Ealing’s adopted Development Strategy policy 1.1(f), which seeks to improve sustainable transport. The Council’s emerging DPD policies take a similar approach to encouraging a restrained approach to car parking within new developments. The GLA, TfL and the Council’s Transport Officer considered that the proposed car parking provision to be compliant with the London Plan and the Council’s car parking standards, which set a maximum limit for car parking provision. The applicant has proposed that 10% of the total car parking spaces would be dedicated as disabled parking spaces, indicatively providing 112 disabled car parking spaces. The table on parking standards within Ealing’s UDP requires that disabled parking bays be provided on a minimum basis of 1 space per 10 units, which equates to 235 disabled car spaces within the Phase 2-11 application site. The Council’s Transport Officer has recommended that the minimum disabled parking requirement is met by the provision of 235 larger bays suitable for disabled parking with only 112 marked and designated initially for disabled use. A new disabled bay should be provided on an incremental basis up to the full quota of 235 when occupancy rates of the existing marked disabled bays reach 90%. Occupancy rates of the disabled bays can be monitored via the Travel Plan, and this is covered as a provision in the draft S106 agreement. Such provision would greatly exceed the existing disabled parking provision currently provided within the application site. Transport have confirmed that the proposals for passive and active electric charging points, amounting to a maximum of 40% of the total proposed car parking, would accord with London Plan policy 6.13. In the first instance, 20% of the total car parking spaces would be equipped with active charging points and an additional 20% of spaces would be provided with passive provision. The passive provision would be upgraded to active charging spaces once the need arises, and this is to be monitored as part of the Travel Plan. The relevant provisions are set out within the draft S106 agreement. A local resident has objected to the proposals on the basis of the restrained parking proposals and the resident has specifically highlighted that off-street parking should be provided on an equitable basis, across the different tenures. The objector also considered that on-street parking, within the adopted highway, should not be counted towards the overall parking provision. In the circumstances of this estate regeneration proposal, which covers a vast urban area including existing adopted highways, the Transport Service and Local Highways Authority have taken the view that on-street car parking should be considered as part of the overall provision. Currently the majority of roads in and around the estate are within a Controlled Parking Zone (CPZ). Park Road North, Castle Close, Newport Road and the streets to the south of Bollo Bridge Road do not have parking controls. The other streets within the site

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are located (partly) within three separate CPZs, including Acton Central Zone K, Bollo Bridge Zone DD, and Acton Town Zone J. Acton Green Zone M CPZ covers the streets to the south of the site. The Transport Officer considered that parking restrictions should protect every road on the estate and recommended that the CPZ be extended to cover the entire estate, including the new streets. Transport advised that traffic consultation is only necessary where existing roads that do not have parking restrictions are proposed. It is anticipated that the new streets would have the CPZ restrictions in place prior to the first occupation of the development within the relevant phase under which the works to the public highway are being completed. A contribution of £10,000 is sought for the introduction and extension of the CPZ and this has been secured as part of the draft S106 agreement. Where consultation on the extension of the CPZ on existing streets is not accepted by residents, then the parking permit eligibility restrictions set out within the draft S106 agreement would not apply to these streets. A parking management plan is required as a provision within the draft S106 agreement and this would need to cover the criteria for parking permit eligibility and allocation of off-street parking spaces. The underlying principle is that the number of households eligible for permits should not exceed the number of off-street spaces and that parking is provided equitably across the different tenures of residential accommodation. With regard to cycle parking, the proposed provision is in the region of 1,567 spaces based on the Council’s standards (1 space per 1.5 dwellings). TfL, the GLA and the Transport Officer have recommended that the provision of 1 cycle space for 1 & 2 bed residential units and 2 cycle spaces per 3 or more bed units, in line with the London Plan cycle parking standards. The location and number of cycle parking spaces would need to be determined on a phase-by-phase basis at the detailed reserved matters stage and the details of this are required by condition 4. Short-stay cycle stands should be provided for visitors to the various non-residential uses within the proposed development. The number of stands should be determined at the detailed reserved matters application stage, once the total floorspace and proposed uses are known. Also, cycle parking for staff should be provided in a secure and sheltered environment located within the buildings. The type of stands used for visitor parking should allow both wheels and the frame of the bicycle to be locked. Cycle parking provision should be based on London Plan standards. The details of the cycle parking for the non-residential uses are also secured under condition 4. Car Club The applicant has agreed that they will fund the first three years membership of a car club for all initial residents of the site who wish to take up the offer, and it is also proposed that a total of eight car club spaces be provided within the application site. The Framework Travel Plan would provide the mechanism for the applicant to investigate the viability of a car club operating from the site and the provision of eight car club spaces would assist in attracting an accredited operator. Such provisions have been included within the draft S106 Agreement. A Traffic Order would need to be made by the Local Highways Authority (LHA) in relation to the car club spaces if they are to be located within the adopted highway. This would need to be covered by a S278 / S38 Agreement between the applicant and LHA. Travel Plan A Framework Travel Plan (FTP) has been prepared by the applicant to cover the entire masterplan area. The headline target in the FTP is to achieve a car driver mode share of 23%. The measures to encourage more sustainable modes of transport and reduced reliance on private cars are set out within the FTP, as well as timescales, roles, responsibilities and management structure for the implementation of the FTP have been identified.

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It is considered that the key principles and proposals form an appropriate basis for a detailed Travel Plan for each Phase of the development. The preparation, submission and implementation of a full Travel Plan is required by the draft S106 Agreement and a contribution of £10,000 is also secured to fund the monitoring of the Travel Plan. Street Principles, Deliveries and Servicing Transport considered the proposed highway network to be permeable, safe and provide direct routes through the application site. Transport welcomed the applicants’ commitment to incorporate features into the design of residential roads to create a self-enforcing 20mph speed zone The applicant has submitted details of the two-way swept path analysis for a single deck bus along the new north-south Boulevard (between Avenue Road and Bollo Bridge Road). In addition, Section 5.0 of the Design Code provides an indicative cross-section of the ‘Boulevard’ and this shows that the carriageway width would be 10m, comprised of a 6m wide two-way running lane and 2m parking to both sides of the street. Whilst the Transport Officer has not raised an objection to the proposed width of the Boulevard, the officer has recommended that the two-way running lane be increased by 1m (to 7m) and the overall width of the carriageway be increased to 11m. The applicant has been asked to investigate the viability of making this alteration to the carriageway width as an informative, and the details of the design of the new street would be required by conditions 2 and 4 and implemented under a S278 / S38 Agreement between the applicant and LHA. The Transport Officer has also recommended that all existing and proposed streets comply with the Manual for Streets guidance on vehicle speeds; forward visibility on links; and visibility splays at junctions. The detailed design of the public realm works and alterations to the highway are required by conditions 2 and 4. Transport and Highways have considered the proposed design and layout of the highway network within the site and advised that the Council would not object to adopting the primary and secondary routes through the site subject. However, the LHA would not adopt the tertiary road network, which will be designed to be a shared surface. The tertiary roads should be constructed to the relevant industry standards in order to maintain safety as pedestrians have a right of way on these sections of the network. Again, the approval of the layout and construction of these areas is covered by conditions 2 and 4. With regard to servicing of the main retail unit indicatively located in Phase 6 (within the community hub), the Transport Officer recommended the provision of a lay-by for servicing on Bollo Bridge Road. The Transport Assessment states that the 450sqm retail unit would require servicing provision for a 10m rigid delivery vehicle and the Transport Officer advised that they would prefer a full width lay-by be provided on Bollo Bridge Road, as there appears to be sufficient footway width within this part of the site. Transport would object to any arrangement requiring vehicles to reverse out onto Bollo Bridge Road, which is a classified road and bus route. The details of the servicing arrangements are specifically required by condition 4. In particular, a swept-path analysis would be required for the entrance and exit of goods vehicles deliveries, and for internal manoeuvring (if relevant). Servicing for the collection of refuse and recycling would typically be undertaken from the public highway and storage areas would need to be designed in accordance with the recommendations contained within the Council’s adopted SPG 4 ‘Refuse and Recycling Facilities’. A condition has been included that requires further details of the refuse and recycling storage. Road Safety

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London Plan Policy 6.3 (A) states that developments should not adversely affect safety on the transport network, and this aligns with Ealing’s adopted Development Strategy policy 1.1(f), which supports the provision of sustainable, safe and convenient transport networks. A total of 117 collisions were recorded within the original Transport Assessment study area. A wider study area was subsequently agreed with the Council’s Transport Officer and accident data for the extended study area showed that there were 167 collisions in 36-month period up to 31 May 2011. Accident data for the last 5 years obtained by the Council within the minor road network bounded by A4020, A4000, High Street and railway lines to the south and east of the South Acton Estate show a total of 14 collisions (13 slight and 1 serious); 2 on Bollo Bridge Road; 1 on Roslin Road; 3 on Avenue Road; 1 at Acton Lane junction with Winchester Street; 2 on Acton Lane junction with Gloucester Road; 1 on Oldham Terrace; 3 on Mill Hill Road junction with Langley Drive and 2 on Crown Street. Out of the 14 accidents; 4 involved vehicles; 1 passenger; 4 motorcycle, 2 cyclist and 5 pedestrian. Over 20% of the accidents were speed related. Local residents have raised concerns to the Transport Service about speeding, particularly in Mill Hill Road, Avenue Road and Bollo Bridge Road. The number of accidents recorded is relatively high for a predominantly residential area. Also, it is noted that the restraint-based approach to car parking provision adopted across the site is likely to lead to additional pedestrian and cycle trips. This could lead to increases to the potential risk of accidents within the estate. The poor accident history, complaints of speeding from local residents and the number of speed related accidents in the area indicate there is currently a road safety problem. The indicative 394 part or full walk trips generated by the development during the AM peak could potentially increase vehicle / pedestrian conflicts in the area and it is considered that there is a need for intervention to improve the existing pedestrian environment. To improve road safety on the estate and in surrounding streets, the applicant has recommended a series of area-wide road safety improvements. Improvements include the introduction of a speed limit of 20 mph, traffic calming measures, a home-zone and pedestrian crossing facilities within the estate. The Borough has a road safety target to reduce casualties from 1070 to 1013 by 2013 and it is considered that the above mitigation measures would contribute towards meeting this target. The proposed masterplan seeks to incorporate a home zone design on all tertiary roads and details of traffic calming measures on the secondary and primary roads are to be submitted under detailed reserved matters application for each phase and implemented via a S278 / S38 Agreement with the Council on adopted roads. Further, the details of the works to the public realm and highway, including any traffic calming measures, are required via condition 4 of the recommendation. In addition, contributions are sought under the draft S106 agreement, totalling £67,000 for improvements to footways, signage and tactile paving to reduce pedestrian accidents and the introduction of a 20mph zone over a wider area than the application site itself, which will become a 20mph zone as part of the masterplan proposals. The applicant has been asked to extend the raised table on Bollo Bridge Road to the west of Stanley Road and to incorporate and install a zebra crossing on Bollo Bridge Road under a S278 agreement, and a default contribution of £40,000 is required in order for the Council to undertake these works if an agreement could not be reached under S278. Public Transport London Plan policy 6.7 seeks London-wide improvements to the quality of bus, bus transit and tram services. Ealing’s adopted Development Strategy Policy 1.1(f) supports sustainable, safe and convenient transport networks to and through Ealing and this is complemented by policy 1.1(g), which seeks to improve public transport, cycle and pedestrian links to development corridors and neighbourhoods.

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The South Acton Estate is currently served by bus route 440, which is a 4 bus per hour (bph) service providing links to Gunnersbury, Acton, Park Royal and Stonebridge Park. There are long-term aspirations from TfL and the Council to improve bus services to this part of the Borough and the redevelopment of the estate is considered to be a catalyst to bring about positive change. TfL have identified two main bus proposals in association with the South Acton Estate development, which are: - Diversion of route 440 so that it goes through the middle of South Acton Estate; - Extend route 70 from Acton High Street to South Acton station, via Gunnersbury Lane and Bollo

Bridge Road. Diverting route 440 through the middle of the estate would provide better bus access to more people within the estate. Route 70 is a high frequency route at 6 bph so extending it into the site would provide a high frequency bus service and important links to Acton Town tube (for District and Piccadilly Lines), East Acton, Ladbroke Grove and central London. Both proposals would create benefit for the development in terms of providing improved bus services, which in turn would encourage increased public transport mode share in line with the relevant policies contained in the London Plan and Ealing’s Core Strategy. For this, TfL has requested a contribution of £450,000 towards bus network improvements. Furthermore, TfL require two new bus stops with associated infrastructure at a cost of £40,000 on the proposed bus loop within the site. TfL would need to deliver the new bus diversion and two new bus stops on the diversion route and the necessary contributions have been secured under the draft S106 Agreement. The bus network improvements could not be delivered until Phase 8, following the completion of the new north - south ‘Boulevard’, linking Avenue Road with Bollo Bridge Road. It is indicated within the application submission that a bus stand would be located along the existing Stafford Road, to the eastern side of Development Zone 6.2 (the community hub). The Transport Officer has not raised an objection to the provision of a bus stand, but the need for a facility as well as its precise location, layout and length would need to be set out within the reserved matters application for the relevant phase of development (indicatively Phase 6) and approved by the Council in consultation with TfL. However, it is also material that waiting buses should not cause unacceptable nuisance to nearby residents and this issue must be addressed when considering the most acceptable location of the proposed bus stand. The applicant has also provided a commitment to provide disabled toilet facilities for TfL bus drivers within the ground floor of block 6.2. This commitment has been addressed within the draft S106 agreement and it is anticipated that the on-going operation and maintenance of the bus driver facilities would be subject to separate agreement between the applicant and TfL. To promote bus use by residents and visitors to the estate, as well as inclusive accessibility for vulnerable people, the Transport Officer has requested that nine bus stops in and around the estate that do not currently meet DDA and accessibility standards should be upgraded. It was considered by the Transport Officer that the cost of this work, estimated to be £36,000, should be borne by the developer. This is considered to be unreasonable in consideration of the substantive works being provided within the site to increase use of buses, and it is also a material consideration that contributions totalling £100,000 were secured under the S106 agreement for Phase 1 of the Acton Gardens masterplan proposals (ref: P/2010/4201, dated 21/03/2011) to fund the introduction / alteration of bus service routes within the South Acton Estate or improvements to the existing bus facilities for passengers. Consequently, it is considered that contributions have already been secured for the necessary works to the bus stops in the local area for DDA compliance works.

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Cycle Network Policy 6.9 of London Plan seeks to bring about significant increases in cycling and this is reinforced by policy 1.1(g) of Ealing’s adopted Development Strategy, which seeks to improve public transport, cycle and pedestrian links to development corridors and neighbourhoods. There are existing signed cycle routes in the surrounding area and existing contra-flow cycle lanes are located on Langley Drive and Crown Street, to the north of the application site. The Transport Assessment recommends the use of quieter roads on the estate by cyclists. Improved north - south connections for cyclists to move between either side of the London Overground railway line and access to Kingswood Terrace are also recommended. The existing footbridge to the east of South Acton Station only has steps, which makes it difficult for cyclists to use. The alternative route for cyclists travelling to the other side of the railway line from the South Acton Estate involves a long detour on busy roads. The Council’s Highways Officer has advised that the applicant or Council would need to negotiate with London Overground Rail Operation Ltd (LOROL) to deliver wheeling ramps at the pedestrian footbridge to facilitate access for cyclist. The works would need to be implemented through a S278 agreement between the applicant and Local Highways Authority. It is recommended that the proposed cycle improvements set out above be incorporated into the detailed reserved matters applications for the relevant phases of the development. It is anticipated that the necessary works within the estate would be carried out as part of the development under a S278 / S38 Agreement with the Local Highways Authority. The details of the layout of the public realm and highways are required by condition 4. Transport has requested a substantial S106 contribution amounting to £53,000 for cycle training and direct support for cycling. It is considered that the Travel Plan initiatives would be capable of providing appropriate commitments to support cycle use and it is not considered that securing separate contributions would be necessary to make the development acceptable in planning terms. Pedestrian Facilities The Council’s Transport Officer and TfL welcomed the submission of a Pedestrian Environment Review System (PERS) audit of the study area. The PERS review of roads within the study area identified a number of roads that require attention in order to satisfy the aims of London Plan policy 6.9, which seeks to bring about significant increase in cycling; policy 6.10, which seeks to promote walking by ensuring an improved public realm; and policy 1.1(g) of Ealing’s adopted Development Strategy, which seeks to improve public transport, cycle and pedestrian links to development corridors and neighbourhoods. Berrymede Junior and Middle Schools, Acton High Street, and a large health centre are located within or on the boundary of the estate and the development would increase the child-aged population living within the estate, as well as the number of elderly and disabled residents. For this reason and to improve pedestrian safety, a contribution has been requested to address some of the issues identified by the PERS audit. The recommendations include the provision of appropriate pedestrian signage, new footways, with tactile paving on Avenue Road, Bollo Lane and Osborne Road. A contribution is sought from the developer to cover PERS audit recommended pedestrian improvements on Bollo Lane and Avenue Road. The remedial works identified consist of improved signage, new tactile paving and footway reinstatement. The affected sections of road include Bollo Lane (between Gunnersbury Lane and Bollo Bridge Road) and Avenue Road. The applicant should undertake the works under a S.278 agreement that are contained within the application site and contributions have been sought under the S106 agreement for the Council to undertake the necessary works outside of the application site.

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Traffic Modelling & Junction Capacity Assessment London Plan policy 6.11 recommends that a coordinated approach be taken by Borough’s to smoothing traffic flow and tackling congestion. Congestion relief is also one of Ealing’s Local Implementation Plan objectives. Trip generation and modal split information were agreed with the applicant and capacity assessments have been carried out for the four junctions listed below: a) Uxbridge Road (A4020)/Gunnersbury Lane (A4000) – Traffic Signals Junction b) High Street (A4020)/ Steyne Road (A4000) – Roundabout Junction c) Bollo Lane at junction with Osborne Road – Priority Junction d) Gunnersbury Lane (A4000)/ Bollo Lane – Roundabout Junction The assessments of the junctions have been carried out using the appropriate industry standard junction capacity analysis software. The ratio of flow to capacity (RFC) has been reported for each priority or roundabout junction assessment. RFC values of 0.85 and above are considered to indicate constrained junction queues begin to form; however a RFC value of 1.00 indicates the junction is congested. The assessment of each junction consists of examining its capacity during weekday AM and PM peak hours for the following scenarios: - 2011 Existing Traffic Flows - 2026 Baseline Flows (with committed Developments) - 2026 Baseline plus Development with average trip rates - 2026 Baseline plus Development with 85th %ile trip rates The Council’s Transport Service advised that they intend to implement the Acton Corridor Streetscape Improvements Scheme in 2013. The scheme will restrict the right turn from Uxbridge Road into Gunnersbury Lane and ban the left turn from Gunnersbury Lane into Uxbridge Road. The impact of these changes will be an increase in the volume of traffic u-turning at the Acton High Street/Steyne Road junction. The scheme will introduce a roundabout at this junction, which will facilitate this u-turning movement. Uxbridge Road/ Gunnersbury Road and High Street/ Steyne Road Junction: Preliminary modelling was carried out by the applicant for the AM and PM peak period using signal timing data provided by TfL, taking account of the changes created by the Acton Corridor Streetscape Improvements Scheme. The results indicate that with the proposed banned turning movements during the AM peak the junction operates within capacity with the highest degree of saturation of 91% recorded on the Gunnersbury Lane approach. During the PM peak all approaches operate within capacity with the highest degree of saturation of 88% recorded on Gunnersbury Lane. The result for 2026 AM & PM Peak Hour including committed Development with development traffic (average trip rates) indicate that with the proposed banned turning movements during the AM peak the junction operates within capacity with the highest degree of saturation of 90% recorded on Gunnersbury Lane and 89% on Acton High Street. During the PM peak all arms of the junction operate within capacity with the highest degree of saturation of 88% recorded on Gunnersbury Lane. 2026 AM & PM Peak Hour results indicate that with the proposed banned turning movements during the AM peak the junction operates within capacity with the highest degree of saturation of 91% recorded on the Gunnersbury Lane approach and 89% on Acton High Street approach. During the PM peak all approaches operate within capacity with the highest degree of saturation of 88% recorded on Gunnersbury Lane.

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Although the results show that the net impact of the proposed development is not significant, some of the links will operate above the 0.9-degree saturation. The results of the modelling show that in 2026, with the proposed development (85th percentile trip rates, worst case scenario), the proposed roundabout junction and pelican crossings during the AM peak will operate within capacity with the highest RFC of 0.838 on the Acton High Street (west approach). During the PM peak the junction operates within overall capacity, with the highest recorded RFC of 0.920 on the Acton High Street (east approach). Similarly, the results show that the net impact of the proposed development is not significant. However some arms will operate above a degree of saturation of 0.9, which is close to capacity. Gunnersbury Lane (A4000) / Bollo Lane - A Mini-Roundabout Junction: Capacity assessment of the Gunnersbury Lane/ Bollo Lane junction has been undertaken using appropriate computer modelling. The ratio of flow to capacity (RFC) has been reported for each approach. RFC values around 0.90 are considered to indicate a constrained link with its associated queues. The results show that with the additional loading from the development, the maximum increase in queues at this junction will be 1 vehicle during the AM Peak and 3 vehicles during the PM Peak. The results show that the net impact of the proposed development is not significant, however some arms will operate at degree of saturation of 0.9 and above. Bollo Lane/ Osborne Road: Existing turning counts were not available to undertake detailed capacity analyses of the existing Bollo Lane/ Osborne Road priority junction. However, link impact at the junction of Osborne Road for all scenarios was provided by the applicant. Link impact near the junction shows an increase of 2.9% from the baseline in AM for the 2026 with development for the average trip rate, while for the 85%ile, the increase is 5.5% in AM and 6.3% in PM. It is generally accepted that a development needs to generate 5% of the traffic on the adjoining highway for it to warrant further investigation. However, this only applies to networks that are not congested. The results indicate that at the junction the traffic generated by the development is less that 5% of the total flows on the adjoining highway using the average trip rates, but higher than 5% using the 85% trip rates. Notwithstanding the above, the results of the modelling show that the junction can accommodate the additional flows from the development and operate with spare capacity. In summary, the capacity assessments have demonstrated that traffic associated with the proposed development is low in comparison with those from other committed developments in the area. However, the additional loading from the development results in all four junctions operating within capacity but close to saturation, at RFC's of 0.9 and above. Demolition and construction traffic It is anticipated that a maximum of 2,350 residential units would be developed across Phases 2-11 covering a period of approximately 14 years, with completion in 2026. Whilst the rate of construction will vary during the masterplan period in response to the prevailing circumstances, on average it has been estimated that there would be approximately 150-200 units constructed each year. The construction of 167 units on Phase 1 of Acton Gardens LLP redevelopment scheme has been used as representative of the likely level of construction traffic throughout the regeneration programme. The average level of HGV movement associated with construction would be 30-40

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movements per day. Whilst the Transport Officer has not raised a concern about the impact of demolition and construction traffic on the highway network, it was recommended that a condition requiring the submission of a Construction Method Statement be required for the written approval of the Council prior to the commencement of each phase of the development. It was also recommended that the applicant make contributions towards highway reinstatement works following demolition and construction, which would fund the necessary reinstatement works, should the public highway be damaged during the works. Transport Summary The vehicle trip generation from the development would not be significant and the results of the detailed modelling indicate that the existing road network could accommodate the additional flows from the development and operate with spare capacity. The development would result in an increase in pedestrian and cycle movements on the estate, which may increase pedestrian / vehicle conflicts, particularly at road junctions. To alleviate the potential safety risks to pedestrians and cyclists it is recommended that particular attention be paid to the area immediately surrounding the school and community facilities, as these are likely to be hot spots of pedestrian activity. The indicative treatment of these areas as shared surface restricted access routes would be consistent with Transport recommendations. Parking congestion and displacement could be a potential issue, given that parking provision is at a ratio of 0.48 and some roads on the estate are not in a CPZ. The recommendation to implement a CPZ across all roads within the site is therefore particularly important. The condition of footways within the site and in surrounding streets requires improvements based on the results of the PERS audit. A series of mitigation measures are proposed and these include: 1) introduction and extension of a Controlled Parking Zone (CPZ); 2) restrictions on the eligibility of future residents and businesses from obtaining permits to park within the CPZ; 3) provision of 8 car club spaces 4) free 3 year membership of an appropriate car club for the initial residents who wish to take-up the offer; 5) highway and safety improvements; 6) travel plan; 7) bus improvements, including new bus stop and infrastructure; 8) new direction signs and improvements to the pedestrian and cycle network Appropriate conditions and S106 obligations have been included in the recommendation to address the Transport comments. ENERGY AND SUSTAINABILITY It is the Council’s objective when considering major applications that there is an achievement of a significant and measurable improvement in energy efficiency and a reduction in C02 emissions. London Plan policies 5.2 and 5.3 require the submission of an energy demand assessment, along with the adoption of sustainable design and construction measures and demonstration of how heating and cooling systems have been selected in accordance with the Mayor’s energy hierarchy. In particular, policy 5.2 requires that new development achieves at least 25% reduction in CO2 emissions above Building Regulations 2010. The 25% reduction target covers only regulated emissions and there is a priority for such reductions to be realised through ‘Lean’ measures (passive measures).

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The applicant has submitted a Climate Change Mitigation Strategy, Climate Change Adaptation Strategy, Sustainability Statement and Code for Sustainable Homes Pre-Assessment, to demonstrate compliance with the development plan policies. The Climate Change Mitigation Strategy has followed the London Plan energy hierarchy and demonstrates how the development would achieve the incremental CO2 emission reduction targets required by policy 5.2 of the London Plan. These targets generally conform to the changes to Building Regulations that are expected to be introduced in 2013, 2016 and possibly in 2019. Energy Efficiency The applicant has recommended a range of energy efficiency measures, such as improved U-values, 100% efficient lighting and controlled low-energy lighting in private and communal spaces, energy efficient appliances (A or A* rated), natural ventilation (with mechanical ventilation proposed where necessary), gas-efficient condensing boilers, heating controls, low thermal bridging, improved air permeability, and low use water fittings. The CO2 emission savings of the residential element of the development following the implementation of the energy efficiency measures have been estimated to be 2,343 tonnes per annum (regulated) and 5,804 tonnes per annum (regulated and un-regulated). The GLA Stage I response and Ealing’s Energy Officer have advised that these measures are supported in accordance with London Plan policy 5.3. District Heating The site is located within an area where there are no existing district heating networks. The applicant identified that there are two smaller heat networks within the site, including the ‘Red Brick’ heat network, and a CHP and biomass boiler that currently serves Phases 2.1 and 2.2 of the Catalyst Housing Association development within the southern part of the application site. It is clear from the scale of the proposals that the redevelopment of the site could act as a catalyst for an area-wide heat network, connecting all new buildings to the facility, as well as providing an opportunity for connection by buildings within the wider-area, particularly Acton district centre. Policy 2.3(b) of Ealing’s Development Strategy recognises the significant opportunity for the South Acton Estate to incorporate a district energy network. In accordance with policy 2.3(b), the proposal incorporates an energy centre of at least 650sqm within the basement and ground floor of a residential flat building in Phase 7 (opposite the new North Park). The application submission also includes details of the possible route for the network of piping and a phasing strategy for the connection of the comprehensive development to the site-wide heat network. The location of the proposed energy centre within the northern part of the site close to Acton district centre is considered to provide the best opportunity for buildings outside of the site to take advantage of this significant heat network. The applicant has identified that Acton Town Hall and Baths, Oaks Shopping Centre, and the Priory Centre could potentially connect to the energy centre. The applicant has provided information about the potential network routes that could serve the buildings outside of the site. The proposed gas-fired CHP plant would act as the lead heat source for the site heat network infrastructure. It is predicted that the CHP plant would reduce regulated carbon dioxide emissions of 521 tonnes per annum (22%).

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Prior to the establishment of the site-wide heat network, it is proposed that individual phases would be either built with their own energy generation equipment or connected to a mini-energy centre within an earlier phase of the masterplan. In this regard, the Catalyst Housing Association Phases 2.1 and 2.2 development incorporates a 150kWe CHP plant, 100kWe biomass boiler, and supporting gas boilers. The applicant has advised that they are continuing discussions with Catalyst to explore whether part of the development in Phases 3 and 6 could connect to the existing plant. The GLA and the Council’s Energy Officer are particularly supportive of this approach. Whilst the Council’s Energy Officer was satisfied with the applicants approach to providing mini-CHP plants in a limited number of the early phases of development, the GLA were concerned that this approach would be financially wasteful and act as a disincentive to the provision of the district energy network. A revised energy strategy for Phases 3-6 (inclusive) would be necessary and a condition is included to this effect. Renewable Energy The applicant has investigated the feasibility of a range of renewable energy technologies, in accordance with policy 5.7 of the London Plan. Solar photovoltaic (PV) panels have been identified as the most feasible technology. According to the submitted information, solar PV panels of a maximum 12,540sqm / 1,790kWp would be installed within the development to serve Phases 3-11, subject to sufficient roofspace being available. This would reduce the CO2 emissions from the development by 767.6 tonnes per annum, which equates to 40% of the total regulated emissions, or 23% of the overall regulated and unregulated emissions. The resulting emissions have been calculated using Part L of the 2010 Building Regulations carbon emission factor for displaced electricity. Cumulative Savings Improved energy efficiency measures together with the decentralised CHP system and solar PV would provide an overall reduction of 40% (regulated) and 30% (regulated and unregulated) CO2 emissions. The GLA Stage I response and Council’s Energy Officer confirm that the proposals exceed the minimum targets set within London Plan policy 5.2. Sustainability Statement, Climate Change Adaptation and Waste Report

The Council’s Energy Officer has confirmed that the Sustainability Statement responds to strategic and local policies in relation to the impact of development on the environment. A Code for Sustainable Homes Pre-Assessment has been submitted that demonstrates that all residential units would achieve a minimum of Level 4 (of the Code). The assessment indicates the potential final credit for terraced houses and flats of 68.2% and 70.9%, respectively. The Council’s Energy Officer considered that the applicants’ approach to reducing the impact of the development on the environment was particularly thorough and well thought through. Measures to promote green transport, conserve energy and reduce C02 emissions, reduce the risk of overheating, enhance biodiversity (through planting and provision of green roofs), provide sustainable urban drainage systems, reduce waste through the use of Green Guide materials (or materials with minimal emissions / recycled materials), reduce air pollution through the use of low Nox boilers, and reduce noise within the development through sensible stacking and improved noise mitigation are supported and encouraged. Conditions are included that address the provision of these measures within each phase of the development. Urban Greening

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Policy 5.10 of the London Plan promotes urban greening, such as new planting in the public realm and multifunctional green infrastructure to contribute to, and reduce the effects of climate change. In addition, policy 5.11 of the London Plan requires that major development proposals be designed to include roof, wall and site planting, particularly green roofs and walls, where feasible. The GLA Stage I response identified that the proposed reconfiguration of open space and provision of green roofs is expected to result in net gains of urban greening within the site. This is further confirmed within the findings of the ES. Conditions are included within the recommendation that require further details of the proposed urban greening and other ecological enhancement measures, in order to ensure they are consistent with the recommendations contained within Technical Appendix C – Natural Heritage, of the ES, as well as the other various reports submitted in support of the application. Some of the mitigation measures specifically identified within the ES relate to the replacement and additional tree and shrub planting, grassland planting, habitat for dead wood invertebrates, provision of replacement roosts for bats and birds and other proposals and monitoring by an ecologist. OTHER PLANNING CONSIDERATIONS

Archaeology The potential archaeological interests of the site have been considered in the Environmental Statement. Part of the site, to the west of Bollo Brook Park and to the north of Cheltenham Place, fall within an Archaeological Interest Area (AIA). A desktop assessment of the potential for archaeological features to be uncovered in the course of the construction concluded that the extent of disturbance likely to have already resulted from earlier phases of redevelopment meant the survival of significant archaeology was not likely. The Archaeological Advisor at English Heritage advised that the archaeological remains may be anticipated within the development boundaries, particularly to the west and north, near the centre of Acton. The applicants’ assessment has demonstrated that of particular interest are the potential for prehistoric activity, as a considerable number of sites and finds dating from the Palaeolithic to the Bronze Age (c. 50,000 – 2,000BC) are well documented in the South Acton area. The Officer noted that the extensive building programmes in the area from the 1950s onwards, including the present estate, would have had a considerable impact on any underlying archaeological deposits. In accordance with the recommendations given in NPPF paragraphs 135 and 141and policy 4.9 of Ealing’s UDP, a record should be made of the heritage assets prior to development, in order to preserve and enhance understanding of the assets. A condition has been included within the recommendation to this effect. Flood Risk and Water Supply Infrastructure The site has an area of more than 1ha and is located within Flood Zone 1 on the Environment Agency’s Flood Map. Land within Flood Zone 1 has an annual probability of river flooding of less than 1 in 1000 years. According to the NPPF, the sequential test gives preference to locating new development in Flood Zone 1, and as such, the use of this site to provide residential accommodation is accepted. A Flood Risk Assessment was provided in Chapter 10 (Ground Conditions and the Water Environment) of the Environmental Statement. Policy 5.13 of the London Plan requires that development utilise sustainable urban drainage systems (SUDS) in order to achieve greenfield run-off rates and ensure that surface water run-off is managed as close to its source as possible. The Environment Agency has reviewed the FRA and required additional information and calculations be submitted through the period of consideration of the application. The Environment Agency confirmed that they were satisfied that the surface water arising

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from the development would be discharged from the site at greenfield run-off rates and that Sustainable Drainage Systems will be implemented wherever possible throughout the application site. The Environment Agency confirmed that the development would only be compliant with the policies of the NPPF if a condition was included requiring that a detailed surface water drainage scheme be submitted prior to the commencement of each phase of the development. The Environment Agency advised that the drainage scheme should be consistent with the submitted FRA and follow the hierarchy for Sustainable Urban Drainage Systems set out under policy 5.13 of the London Plan. A condition has been included to ensure that the Environment Agency recommendations are followed. Thames Water responded to the consultation request and advised that the developer has been in consultation with them about developing a drainage strategy for the comprehensive application site. Further, Thames Water advised that the existing water supply infrastructure has insufficient capacity to meet additional demands for the proposed development and that a condition requiring the submission of an impact study of the existing water supply, which would need to identify the magnitude of any additional capacity required in the system and a suitable connection point. This has been included as an informative to notify the applicant of their responsibility to undertake this study in consultation with Thames Water. Thames Water also required that a condition requiring the submission of a piling method statement prior to the commencement of the development and this is included in the recommendation. Health Impact Assessment

Chapter 12 of the ES sets out an assessment of the implications of the masterplan proposals on the community, economic, social and lane use effects. In the context of the assessment, potential effects were considered to be related to the increase in population and associated demographic changes, provision of housing, open space and local facilities and the change to the estate’s amenity and residents’ quality of life. Many of these issues have already been addressed within the Evaluation section of this report. Ealing PCT confirmed that the increase in population as a result of the proposed development would have an impact on the existing health facilities in the local area and requested contributions towards a capital planning contribution and revenue planning contribution for Acton Health Centre, to be secured through the S106 agreement. The S106 Agreement makes provision for a reasonable contribution (£550,285) towards enhancement of healthcare facilities to take account of the increase in population from the estate redevelopment. PART 8: LEGAL AGREEMENTS AND COMMUNITY INFRASTRUCTURE LEVY Although the NPPF has replaced the planning obligations Circular 05/05, it has retained 3 of the 5 tests for the use of planning obligations that were set out in the Circular. The same tests are also included in Regulation 122 of the Community Infrastructure Levy Regulations 2010 (CIL). They require planning obligations to 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 The NPPF stresses the importance for local planning authorities to meet the infrastructure requirements needed to deliver future developments. Planning obligations are a critical way of ensuring that the objectives of the NPPF are met and future growth is stimulated.

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In accordance with policy 8.2 of the London Plan, policies 6.1, 6.2, 6.3 and 6.4 of Ealing’s Development Strategy, and policy 1.10 of Ealing’s UDP, financial contributions have been sought towards the provision of environmental, playspace, education and public open space improvements in the vicinity of the site. Other obligations are included in the S106 agreement to ensure that adequate management and maintenance strategies are put in place to safeguard the quality and amenity of the new community facilities, areas of public open space and community open space (not adopted by the Council). In addition to S106 contributions and other requirements, the Mayor’s Community Infrastructure Levy (CIL) was adopted on 01/04/2012. This has introduced a charging system within Ealing of £35 per sqm of gross internal area (GIA) of net additional floorspace created. The CIL Regulations (2010) state that affordable housing will be exempt from the charge. The liable sum for each phase of development is calculated at the reserved matters application stage. CONCLUSION The recommendation to grant planning permission has been taken having assessed the application against the relevant policies contained in the NPPF and the development plan, which is comprised of the London Plan 2011, Ealing’s Development Strategy 2012 and Ealing’s UDP 2004 and the findings and conclusions of the Environmental Statement, and in accordance with the considerations set out in the main body of this report. On balance, it is considered that planning permission should be granted, subject to the completion of a S106 Agreement to secure the obligations set out at the beginning of this report. Human Rights Act: In making your decision, you should be aware of and take into account any implications that may arise from the Human Rights Act 1998. Under the Act, it is unlawful for a public authority such as the London Borough of Ealing to act in a manner, which is incompatible with the European Convention on Human Rights. You are referred specifically to Article 8 (right to respect for private and family life), Article 1 of the First Protocol (protection of property). It is not considered that the recommendation for approval of the grant of permission in this case interferes with local residents’ right to respect for their private and family life, home and correspondence, except insofar as it is necessary to protect the rights and freedoms of others (in this case, the rights of the applicant). The Council is also permitted to control the use of property in accordance with the general interest and the recommendation for approval is considered to be a proportionate response to the submitted application based on the considerations set out in this report.