Perfume Factory phase 2, Acton - London - Greater London Authority

Strategic planning application stage 1 referral
planning report PDU/1198/01
13 July 2005
Perfume Factory phase 2, Acton
in the London Borough of Ealing
planning application no. P/2005/1647-ST
Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999; Town &
Country Planning (Mayor of London) Order 2000
The proposal
The proposal consists of two new buildings comprising 220 dwellings (18,385 sq.m.), 4,792 sq.m.
B1 offices, 685 sq.m. A1, A2 and/or A3 uses and 65 sq.m. D class uses.
Strategic issues
The site is located in an area that is identified as a Strategic Employment Location in the London
Plan, as well as in the draft SPG Industrial Capacity and in the draft West London Sub Regional
Development Framework. In addition it is within an LDA Priority Area. Park Royal is also an
Opportunity Area but the London Plan has not identified new homes for the area. The loss of
industrial employment capacity has not been fully justified and could result in further erosion of
available industrial employment land in the vicinity.
The scheme will, however, provide certain regeneration benefits close to an LUL station in terms
of housing and jobs. The success of these benefits is somewhat compromised by certain
shortcomings in the design of the scheme and these issues should be addressed. Although 50%
of the proposed dwellings will be affordable, there are concerns about the tenure split and the mix
of flat sizes. In addition, more information is needed in relation to sustainable design, inclusive
design, waste strategy, water efficiency, children’s playspaces, noise and air quality.
Recommendation
That Ealing Council be advised that the proposal is contrary to strategic planning policy to retain
industrial employment capacity in this part of London, and that, on the basis of the current
application material, the Mayor does not consider that exceptional circumstances have been
proven to justify the redevelopment.
Context
1 On 16 May 2005 Ealing Council consulted the Mayor of London on a proposal to develop
the above site for the above uses. Under the provisions of the Town & Country Planning (Mayor of
London) Order 2000 the Mayor has the same opportunity as other statutory consultees to
comment on the proposal. This report sets out information for the Mayor’s use in deciding what
comments to make.
2 The application is referable under Category 1B of the Schedule of the Order 2000:
“Development (other than development which only comprises the provision of houses, flats, or
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houses and flats) which comprises or includes the erection of a building or buildings – (c) outside
Central London and with a total floorspace of more than 15,000 square metres”; Category 1C:
“Development which comprises or includes the erection of a building in respect of which one or
more of the following conditions is met – (c) the building is more than 30 metres high and outside
the City of London”; and Category 3E: “Development which does not accord with one or more
provisions of the development plan in force in the area in which the application site is situated and
– (a) comprises or includes the provision of more than 2,500 square metres of floorspace for a use
falling within any of the following Classes in the Use Class Order: A1, A2, A3, B1, B2, B8, C1, C2,
D1, D2.”
3 If Ealing Council subsequently decides that it is minded to grant planning permission, it
must first allow the Mayor an opportunity to decide whether to direct the Council to refuse
permission.
4 The Mayor of London’s comments on this case will be made available on the GLA website
www.london.gov.uk.
Site description
5 The site is located in North Acton at the south end of Park Royal industrial estate, south of
the LUL railway for the Central Line and very close to North Acton Underground station. To the
north is the entryway to an adjacent business estate, and the Central Line railway. To the east,
down an embankment, is the adjacent business estate. To the south of the site is a residential
area, consisting of generally two to three storey houses. To the west of the site is an area that has
been, in the new Ealing Unitary Development Plan (2004) identified as a Special Opportunity Site
(SOS Southern Gateway site, Park Royal).
Details of the proposal
6 The application is for two separate buildings: the main building to the north of the newly
refurbished Perfume Factory (phase 1, so not part of this application) provides space for all
dwellings and for the majority of the commercial floorspace: circa 3,250 sq.m. B1 offices, all 685
sq.m. of A class uses and all 65 sq.m. of D class uses. To the south of the Perfume Factory a threestorey
building is proposed that provides circa 1,140 sq.m. floorarea for B1 uses. The ground floor
of this building is used for open car parking.
Case history
7 There is no case history for the site.
8 In March 2001 the GLA supported an outline planning application for Gypsy Corner (PDU
case number 0179), the area west of the site, across Wales Farm Road, that is now identified in the
Ealing UDP (2004) as the Southern Gateway site, Park Royal, Special Opportunity Site. The outline
application was for a phased development allowing a reorganised gyratory, car showroom and
ancillary workshop, B1 employment uses, hotel, retail, leisure, residences and parking. In February
2003 the GLA also supported a subsequent revision of phase 3 of the outline planning permission,
involving an increased number of dwellings from 110 to 398 and number of hotel beds from 200 to
237 (with all other items remaining unchanged), after the application increased the level of
affordable housing, substantially modified the design of the scheme and clarified the various
transport improvements.
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Strategic planning issues and relevant policies and guidance
9 The relevant issues and corresponding policies are as follows:
• Strategic employment capacity London Plan; PPG4; London’s Economic Development
Strategy, draft Industrial Capacity SPG
• Housing and affordable housing London Plan; PPG3; draft Housing Provision SPG
• Urban design and density London Plan; PPS1; PPG3; draft Housing Provision SPG
• Transport London Plan; the Mayor’s Transport Strategy; PPG13
• Access London Plan; PPS1; SPG “Accessible London: achieving an
inclusive environment”; ODPM Planning and Access GPG
• Waste/minerals London Plan; the Municipal Waste Management Strategy;
PPG10
• Sustainable development London Plan; PPS1, PPG3; PPG13; PPS22; the Mayor’s
Energy Strategy, draft Sustainable Design and Construction
SPG
10 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the
development plan in force for the area is the 2004 Ealing Unitary Development Plan and the 2004
London Plan. Also relevant are the GLA’s Draft SPG Industrial Capacity (GLA, September 2003),
the Draft West London Sub Regional Development Framework (GLA, July 2005) and the draft
Sustainable Design and Construction SPG, albeit all three with limited weight in development
control terms.
Strategic industrial capacity
11 London Plan policy 3B.5 states that the “Mayor will promote and manage the varied
industrial offer of the Strategic Employment Locations (SEL’s), set out in Annex 2, as London’s
strategic reservoir of industrial capacity”. Annex 2 identifies part of Park Royal as an SEL, noting
that within this general categorisation, part functions as a Preferred Industrial Location and part as
an Industrial Business Park. The London Plan does not provide a geographically specific definition
of Park Royal or its component parts – that is for the borough councils to develop in Local
Development Frameworks (LDF’s) in light of Supplementary Planning Guidance and the Sub
Regional Development Frameworks. This process of definition is currently underway, informed by
an LDA sponsored study covering the whole of Park Royal. The exercise has not so far suggested
that the present site should be excluded from the SEL and it is marked on the recent Ealing UDP as
being for industrial use.
12 The London Plan makes explicit reference to the Mayor’s Supplementary Planning
Guidance (SPG), currently in draft form, noting that this sets “out in more detail how the wider
policies in this plan bear on employment land, in line with national policy, including the national
requirement to review demand and supply of land. Surplus employment land should help meet
strategic and local requirements for other uses such as education activities and, in particular,
housing”.
13 The draft SPG provides guidance on implementing London Plan policy, especially policy
3B.5. As part of the process of managing SEL’s it makes clear that, as a general principle,
development of non-business uses within them should be resisted (draft SPG guidance point 2). It
also provides guidance on circumstances where exceptions can be made to this principle without
compromising the thrust of strategic policy. In line with national policy in PPG 3, the draft SPG
stresses that exercise of such exceptions must be informed by coordinated strategic and local
assessments of demand for industrial land. These exceptions are:
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• Releases from SEL’s which are managed through a coordinated review of SEL’s in the light
of strategic and local need, in the context of Sub Regional Development Frameworks (draft
SPG guidance point 1 and paragraphs 5.12 – 14, refined for application in West London by
the West London draft SRDF paragraphs 92 – 99, Action Points 1 G and paragraphs 127 –
128, Proposed Action 2D). This does not apply to the present proposal – see below.
• Releases as part of a strategically coordinated process of mixed use intensification (draft
SPG guidance point 2), which identifies “strategically recognised industrial sites or parts of
sites which have good public transport accessibility, especially those within or on the edge
of town centres. This redevelopment should not incur a significant net loss of industrial
employment capacity or compromise the offer of wider areas as competitive industrial
locations” (draft SPG guidance point 5). It could be argued that this exception might be
applied to the present proposal – see below.
• Provision of “local, small scale, ‘walk to’ services for industrial occupiers e.g. workplace
creches” (draft SPG guidance point 2). This self evidently does not apply to the present
proposal.
• Strategic proposals of essential benefit to London which cannot be planned for or delivered
on any other sites (draft SPG paragraph 5.13). This self evidently does not apply to present
proposal.
14 The draft SPG provides broad sub regional and borough level indications of industrial
demand. Boroughs are categorised to show those where demand is strong and transfer from
industry to other uses should be restricted, through to those where supply is likely to exceed
demand and there should be managed transfer to other uses. Ealing falls in the intermediate
category where there should be limited transfer of poorer industrial sites. This categorisation has
been tested by independent consultants. With only one firm exception (outside West London)
they confirm its general robustness and the more specific categorisation for Ealing. As an integral
part of a Strategic Employment Location, the present proposal cannot be considered to be a
‘poorer industrial site’ for the purposes of transfer.
15 The draft SPG also provides sub regional benchmarks to monitor release of industrial land.
In light of the London-wide release benchmark of 50 hectares per annum (ha. p.a.) put before the
EIP into the London Plan, these suggest that, on average over the term of the Plan, 6.4 – 9.5 ha.
might be released annually in West London, the lowest sub-regional level of release after that in
Central London. More recent research by independent consultants, while confirming the London
wide 50 ha. p.a. release benchmark, suggests that the industrial market in West London may be
even tighter. They suggest an average annual release of 2.7 ha. p.a. This figure is reflected in the
draft Sub Regional Development Framework for West London and, following consultation on it and
the draft SPG, will be recommended for inclusion in the final SPG.
16 The draft SPG emphasises the need to complement this broad strategic appraisal with
borough level demand assessments, which take into account demand variations within boroughs
and place it within the sub-regional context. It is understood that Ealing Council has not
undertaken such an assessment and the LDA sponsored assessment for Park Royal as a whole is
not yet complete. However, the applicant has submitted two more local appraisals.
17 The first, by a local estate agent, suggests that for units under 15,000 sq. ft. and for older
freehold industrial space the market “has been fairly strong” but “ for units greater than 15,000 sq.
ft., the take up has been much less” for both new and second hand provision. From a strategic
perspective this local appraisal raises technical concerns. It does not make the crucial link between
the wider and more local market; it is predicated on the experience of only one agent; and the case
studies on which it draws can be interpreted as illustrating market ‘churn’ and not necessarily low
demand.
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18 The second is by a firm of planners and development economists (Roger Tym and
Partners). This seeks to take a wider, more statistical view across Park Royal as a whole. On the
basis of their evidence the report states, “It is thus clear that there is no shortage of industrial sites
and premises at Park Royal”. However, the apparently large quantum of identified available
industrial floorspace in Park Royal is not placed in the context of the substantial stock in that part
of London. Neither does it show whether this is composed of a few large units or representative of
the stock as a whole. Furthermore it does not relate the findings to local demand or in the wider
context of demand in this sector of London generally.
19 Following national policy and the Economic Development Strategy, the draft SPG also seeks
to support clustering of related industrial activities by protecting strategically important business
locations such as Park Royal. It stresses the need for strategic coordination in any consolidation of
the SEL framework rather than approaching it on an ad hoc, site-by-site basis. This is intended to
minimise the possibility of generating ‘hope value’ which could undermine existing industrial uses.
The draft SPG also stresses the need to ensure that land releases or intensification does not
compromise the integrity of the industrial offer of SEL’s as a whole, especially in areas where
industrial capacity is constrained, as is the case in West London.
20 The current proposal can be seen as undermining an existing business cluster, being one of
several one-off, uncoordinated releases from this Strategic Employment Location and potentially
undermining the wider industrial integrity and offer of the SEL.
21 The London Plan designates Park Royal as an Opportunity Area as well as a Strategic
Employment Location. Unlike any of London’s other Opportunity Areas, the Plan does not
anticipate a mix of housing and employment uses there. It identifies capacity only for 10,000 jobs.
“The planning framework (for the Area) should build on the sheer scale of Park Royal and address
the need for site assembly and decontamination and improvements to local access and
environment. A longer term strategic perspective should take account of London’s future rail
freight requirements and their land use implications and the scope for improvements in strategic rail
accessibility”.
22 The Area is particularly well placed to serve London’s growing need for logistics and waste
management capacity, highlighted in the London Plan and underscored in the draft SPG. Research
on both points to the critical importance of securing provision for these to meet long term,
strategic requirements, especially in areas with constrained industrial capacity. Both potentially
have significant ‘external environmental costs’, which should be contained within areas that are
predominantly industrial in character like Park Royal. Conversely, their functions can be
constrained by more environmentally sensitive, nearby land uses like housing and offices, as
proposed by the applicant in this SEL.
23 The draft SRDF details these strategic principles for consideration in the specific
circumstances of Park Royal. It stresses the dangers of incremental erosion of the distinct
industrial offer of the area and suggests investigating its potential as a Strategic Logistics Park. It
advises that “pending alterations to the London Plan, borough councils should not release
significant industrial sites (generally over 0.5 ha.) until these are tested against strategic and local
needs and policies for waste management facilities” (Proposed Action 1 G).
24 The draft SRDF also provides guidance on implementing London Plan office policy – a
relevant consideration in light of the B1 office component of the present proposal. It points to the
relatively limited demand for office space in outer London and seeks to consolidate the subregion’s
office offer on a range of locations of the types specified in the London Plan where they
can contribute to wider planning objectives. The proposal site does not conform with this
locational typology.
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25 The proposal’s main point of conformance with guidance on implementing strategic policy
is its accessibility to public transport. This raises the possibility that it might be suitable for
“industry led, higher density mixed re-development” in the terms of draft SPG guidance point 5,
and thus be exempt from the thrust of policy reflected in draft SPG guidance point 2 which seeks
to resist development of significant non business uses in SEL’s. However, this site is not in or on
the edge of a town centre where this guidance is especially targeted. Of greater concern is the
effect of the proposal, directly and indirectly, on long term industrial capacity in West London and
the key role the London Plan expects Park Royal to have in sustaining this. There is specific
concern that capacity for waste management and logistics provision should not be compromised,
either in terms of an individual site, through environmental impact or by eroding the overall
integrity of a Strategic Employment Location.
26 On balance, the strategic merits of the proposal in terms of an aspect of draft SPG guidance
note 5 do not outweigh the conflicts and tensions it raises with the thrust of strategic policy for
SEL’s and guidance on its implementation set out in points 1, 2 and 5 of the draft SPG and in the
draft SRDF for West London.
Regeneration
27 The site is adjacent to Special Opportunity Site (SOS Southern Gateway site, Park Royal,
Ealing Council UDP 2004) in which “a suitable range or mix of uses will be permitted where the
proposal is consistent with sustainable development principles”. As mentioned before, however,
the site is not within this SOS.
28 Nevertheless, the proposal does, subject to the delivery of other relevant issues, accord
with several policies of the London Plan that stimulate mixed use regeneration on accessible sites.
Housing and affordable housing
29 Policy 3A.8 of the London Plan seeks the maximum reasonable amount of affordable
housing taking into consideration the regional target of 50% and site-specific constraints. The
London Plan aims to maximise the potential of sites in line with public transport capacity, as
established in policy 4B.3 of the London Plan.
30 The scheme proposes 110 (50%) units for affordable housing, which is consistent with the
London Plan target.
31 The London Plan has a London-wide target for tenure split within affordable housing
provision of 70:30 for social rented housing and intermediate housing respectively. This scheme
proposes 29 social rented housing units and 82 intermediate units, representing a 26:74 split. The
applicant is requested to provide a significant change from the current tenure mix to accord with
the specified ratio. The proposed tenure mix will require strong justification based on local need.
32 As the applicant is providing a large amount of intermediate housing to meet the 50%
provision target, it is requested that the applicant provide a financial appraisal for the
development.
33 The London Plan also seeks to ensure a mix of housing sizes and types. The draft Housing
Provision Supplementary Planning Guidance to the London Plan (GLA, December 2004) sets out
the requirements for London in terms of the mix of housing size. Overall these requirements
represent 32% 1-bedroom, 38% 2/3 bedroom and 30% for 4 or more bedrooms. These
percentages vary for market, intermediate and social housing, with market housing requirements
predominantly 2/3 bed housing, social predominantly 2 or more bedrooms, and intermediate
predominantly 1-bed housing.
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34 The application has recently been revised to provide fewer two- and three-bed units and to
provide more studios and one-bed units. Whilst keeping the dwelling numbers much the same
(from 228 to 220) there has been a reduction in habitable rooms from 664 to about 500. It is
assumed, therefore, that more floorspace is provided within the dwellings.
Number of Dwellings
S/1b S 1b 2b/3b 2b 3b 4b+
Desired (London-wide) 71 - - 84 - - 66
Original scheme 80 29 51 148 59 89 0
Revised scheme 123 45 78 97 94 3 1
Table 1, Overview of the proposed housing mix. The “desired (London wide)” row indicates the housing mix if the
percentages were applied from the draft SPG Housing Provision.
35 With regard to the revised scheme, the levels of provision and affordable tenure splits have
remained much the same. The main changes lie with the market housing where there has been a
great reduction in three-bed dwellings, a moderate reduction in two-beds and a large increase of
studios and one-beds. With regard to the social rented housing, there has been a substantial
reduction in three-bed dwellings and an increase in two beds and the addition of a few studios and
one 4 bed dwelling. There has been little change with the number and mix of intermediate
dwellings.
36 The revised proposal has shifted further from the desired dwelling mix ratios specified
within the Draft Housing Provision SPG. It is requested that the proposal provide a mix of
dwellings that closer represents these ratios. In particular, it is requested that the applicant provide
fewer studio and one bed flats and number of three and four bed dwellings.
Density
37 The application site is 1.163 hectares (which includes the site of the refurbished Perfume
Factory) and the number of dwellings is 220, therefore the proposed density is 190 units per
hectare. When only the northern part of the site (the site of the main building, circa 0.42 hectares)
is used for the calculation, the density is crica 524 units per hectare, or 1,190 habitable rooms per
hectare. The density in habitable rooms based on the current housing mix for the site is 430
habitable rooms per hectare. This falls within the range given in Table 4B.1 Density location and
parking matrix of the London Plan (165 – 275 units per hectare and 450 – 700 habitable rooms per
hectare for this site) and is therefore acceptable.
Urban design
38 At the start of chapter 4B Designs on London, the London Plan states that “Good design is
central to all objectives of this plan.” It identifies how good design has an influence on all
objectives. Policy 4B.1 - 4B.5 and 4B.7 are relevant for this proposal. The success of the delivery
of strategic objectives depends on the way the building is designed on every relevant scale-level.
39 In spatial terms, the frontage towards Victoria Road and Wales Farm Road is an appropriate
response to the context, being on an intersection and close to the Underground station. The
massing of the building eastward, however, is excessive in bulk, which, combined with the
architectural treatment and the detailing, could have a detrimental visual impact on the public
space.
40 The two wings of the proposal are, for a total of four floors and with different lengths
because of a staggered roofscape, only 16-18 metres apart. The applicant has opted for single
aspect flats, which has necessitated the introduction of angled facades there where the flats are
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opposite, so that the affected dwellings have no direct overlooking. The choice of building
typology has thus resulted in a loss of quality of life within the dwellings and this should be
addressed.
41 Only the west frontage is facing public space (Wales Farm Road and Victoria Road) but the
proposal will be very visible on the southern and northern approach to the site. The architects have
recently made improvements to the external appearance of the main building by increasing the
sizes of windows and by changing details in the facade. On balance, though, there remains
concern that the level of repetition on the scale it is proposed will render the building overly bulky.
The proposal from the southwest, with the main new building to the left, the refurbished Perfume Factory to the right
of the middle and the three-storey office block just visible to the right.
Open space
42 The proposal contains three communal garden decks on the south wing of the main
building, as well as three communal garden decks on the north wing and communal open space
between the wings, on the first floor. More information is needed, however, about the nature of
these spaces and their potential for playspaces for children of different ages.
Transport for London
43 The site is well served by public transport. North Acton underground station is located
within 200 metres allowing access to services on the central line. Acton Network Rail Station is
approximately 950 metres to the south and is served by local services on the London Paddington –
Greenford service. Bus routes 266, 260, 440 and 487 all operate in the vicinity of the site along
Victoria or Wales Farm Road. The 95 bus service also runs nearby. The site has an overall Public
Transport Accessibility Level (PTAL) of 4 (where 6 is the highest).
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44 Transport for London (TfL) believes that the approach used to assess future demand at
North Acton Station in the transport assessment is flawed. This is because the report did not fully
reflect the development that is already complete or is in the process of development. The station
currently has four ticketing gates. With the additional demand from new developments in the area
including this site, six gates will be required at the station. TfL would like to discuss with the
London Borough of Ealing and the developer a Section 106 pooling arrangement to contribute
towards the funding of the ticket hall improvements.
45 TfL is concerned that the pedestrian crossing at the new enlarged entrance is set back too
far from the footpath. A pedestrian island should be provided and the pedestrian crossing point
should be in line with the footpath.
46 TfL is concerned that bus operations in Wales Farm Road could be negatively affected by
overspill parking from the retail and residential land uses. Further information is required to ensure
overspill parking does not interfere with bus operations.
47 It is unclear how the car parking spaces will be allocated between the office development
site and Elizabeth Ardent House. In accordance with the London Plan there should be a maximum
of 45 car parking spaces allocated for office use. TfL is satisfied with the provision of 26 disabled
car parking spaces and 5 city car club spaces for the residential development.
48 TfL supports the provision of cycle parking within the development, however in accordance
with the London Cycle Design Standards the provision should be increased from a total of 90 to
151. These spaces should be covered, well lit and split between office and residential use.
Information is required to demonstrate that a standard configuration of bicycle stands fit the
available space.
London Development Agency
49 The London Development Agency (LDA) normally opposes any loss in strategic
employment land to other uses, particularly in those areas where availability of employment sites is
limited. The Agency is concerned about the rate of industrial land release in West London. Park
Royal is an LDA priority area and a strategic employment location (SEL) and it provides a variety of
employment opportunities in a deprived area. Demand for industrial space is tight relative to
supply, and vacancies are low.
50 London Plan policies 2A.7 and 3B.5 promote and aim to protect SEL’s as London’s strategic
pool of industrial employment land. Evidence suggests that under the latter policy Park Royal
should be nothing other – at least into the medium term – than an SEL. Policy 5D.2 identifies a
target of 10,000 new jobs for Park Royal and no new homes. This scheme could well have an
adverse impact on achieving this jobs target.
51 The draft Sub Regional Development Framework (SRDF) for West London suggests that
borough councils “…should not release significant industrial sites (generally over 0.5 ha) until
these are tested against strategic and local needs and policies for waste management facilities.”
While the draft SRDF proposes that borough councils should review the indicative boundaries of
SEL’s it also states that the “…development of significant non-business uses within them should be
resisted.”
52 Annex 2 of the draft SRDF strengthens the case for business uses and flags concerns over
any threats to this business offer. The LDA supports the urgent need for the production of an
Opportunity Area Framework to guide development in Park Royal and avoid piecemeal
development which erodes its unique business offer.
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53 It is not clear whether the proposed office space, in the proposed configuration of small
business units, is viable for this location. The Agency requests more information on demand for
office space in the proposed form for this location. Confirmation is sought that the viability of
these units does not impact the delivery of the affordable housing component of the development.
More information is requested about how the proposal would address the spectrum of local
employment demands. The Roger Tym & Partners report does not adequately satisfy the questions
and issues the LDA has raised below as it does not consider the implications of the proposed
development holistically.
54 The Agency would only be prepared to consider this proposal an exceptional case if the
applicant can provide detailed justification. In particular the LDA seeks more information on the
following questions and issues:
a How the proposal would not leave a shortfall of industrial employment land at the site
when compared with current and future demand for industry and related activities in the
area. The current proposal results in a loss of industrial land in an area of low vacancy.
b Demonstration that the cumulative effects of development of employment sites in the
Park Royal area for mixed use schemes or other uses would be acceptable by relating
demand for sites and premises for industrial and related activities to supply and by taking
account of the potential loss of similar sites to the Perfume Factory.
c How this site is considered to be less suited to wholly employment uses than others.
d Evidence of adequate marketing of the site for industrial uses. The Agency expects to
see details of a marketing history including information on which users and uses were
targeted and how they were targeted, what value the site has been marketed at, how
long the site has been marketed for etc. In addition, the LDA expects to see details of
what types of use for the site were considered as an alternative to residential and why
these were rejected.
e How unrestricted B1 use will not result in a net loss of space for industrial and related
activities and jobs in these sectors. The Agency is not satisfied with the assumptions on
employment densities, being as they are based only on office use, rather than the
creative workspace uses that we understand are being targeted.
f What safeguards would be put in place to enable industrial and related users to occupy
the remaining space at the site. In the event of consent being granted, the Agency
requests to be involved in the marketing and selection of nature of the business and
industry on the site and the specific occupiers.
g Where the applicant is seeking to attract creative industries the Agency would wish to be
satisfied that this will not dilute the creative offer of the adjoining Perfume Factory
Phase One nor impact upon creative uses elsewhere in west London, notably around
Ealing Studios and White City.
h In terms of introducing housing and other uses to the site the applicant should
demonstrate what the impact of this would be on the operations of industrial and related
businesses on the site itself and similar operations on adjoining and nearby sites and
propose safeguards to ensure that there would be no adverse effect.
i The applicants should also demonstrate how the proposal would not impact upon
industrial land values in the area and availability of premises for such activities in
consequence of hope that consent for residential or other higher value uses could be
obtained, particularly given that Park Royal is currently an affordable industrial area.
j What benefits an element of residential development would bring to the site and to Park
Royal generally and in particular the potential benefits for the industrial and related
businesses.
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k Demonstration of how (if at all) this scheme complies with Ealing Council policy and
objectives for this part of Park Royal and how it responds to the strategy for the area put
forward by the Park Royal Partnership. The Agency also suggests that the applicant
commits to making a financial contribution to the development of the Opportunity Area
Framework for the whole of Park Royal, which would provide the context for the
development of this site as well as others in the area.
l In the event of consent being granted the Agency also wishes to see appropriate
conditions and/or clauses in the Section 106 agreement to ensure that the industrial and
related space within the scheme is provided before any sale of the residential units is
completed; that the first letting of this work space takes place prior to the occupation of
any of the residential units and that the space is retained for industrial and related
activities for a minimum period of ten years. The Agency suggests that it is consulted on
the wording of such a condition and/or clauses in the Section 106 agreement.
m Given the inadequacy of some services and facilities in this area for employees,
demonstration should be made of the contribution the scheme would make to
addressing this issue including consideration of the provision of additional facilities,
directly and/or through support for provision elsewhere to support employment uses and
employees e.g. child care provision or a training centre.
n The applicants are also asked to commit to maximise opportunities for the use of local
employees and businesses during construction and subsequently to create or contribute
to targeted training; and to address other barriers to work. Again, the Agency would be
pleased to discuss and advise further on these proposals should the scheme proceed.
o The applicant should also commit to an open book assessment of the viability of the
scheme to enable assessment of acceptability of the affordable housing offer and other
elements of the Section 106 agreement and to demonstrate that the scheme is capable
of implementation in full.
Inclusive design
55 The applicant has provided an Accessibility Statement that elaborates on how the design
would achieve accessibility objectives but regard should be had to the London Plan SPG Accessible
London: achieving an inclusive environment. The Mayor requires a commitment to delivering an
inclusive environment in accordance with Policy 4B.5 of the London Plan.
56 All units are designed to Lifetime Homes standards and there is commitment to 10% of the
units to be accessible for wheelchair users, in line with Policy 3A.4 of the London Plan. Half of the
10% are proposed to be fully fitted for wheelchair users. More information is required to clarify if
the 10% applies to both market housing and affordable housing. Ideally, all affordable housing
wheelchair units should be fitted out for occupancy.
57 The 26 blue badge parking spaces are acceptable but the applicant should also demonstrate
that there is a management plan in place at the time of occupancy to monitor the use and demand
for blue badge spaces.
Air quality
58 A detailed Air Quality Assessment has been provided by the applicant. Based on the given
information it is unlikely that the development has a significant impact on local concentrations of
PM10 and NO 2 as a result of either direct or indirect emissions. The screening modeling
undertaken at three appropriate receptors indicate that concentrations of NO 2 and PM10 are likely
to remain unchanged with the development, largely as a result of the development proposal being
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‘car-free’. On this basis, the objectives of the development proposal meet those of the Mayor’s Air
Quality Strategy, in encouraging car-free development.
59 The proposal site is, however, located within the London Borough of Ealing’s air quality
management area. The A40 Western Avenue has been identified as being of particular significance
with respect to predicted excedeences of air quality objectives within the Borough. It is likely that
the annual mean NO 2 2005 objective will not be met; with or without the proposed development,
and the possibility of localised exceedences of the NO 2 annual mean Limit Value in 2010 is also
likely. In lieu of this, a number of specific conditions should be required of the applicant in order
to minimise the impact in terms of the exposure of future residents living within the development
to elevated concentrations.
60 The applicant intends to address the exposure of future residents through the following
measures:
• Limiting the opening of windows for natural ventilation on the roadside facade (to be
designed to the satisfaction of the Building Regulations);
• Installing mechanical ventilation in residential units closest to Wales Farm Road, and
• Locating air intakes away from roadside facades of the buildings.
61 The above measures are necessary to reduce the impact of the elevated concentrations on
those residents closest to Wales Farm Road. Any units within 20 metres of Wales Farm Road
should be provided with mechanical ventilation to reduce any such impact. It is therefore
recommended that the above mitigation be made a condition of planning consent for the proposed
development.
62 The Air Quality Assessment makes no reference to the construction phase of the
development. As with any development, the potential exists for short to medium term impacts
from construction and associated activities on health and the environment. Consideration should
be given to the potential impact from stationary and mobile construction plant and other such
activity. The following recommendations are therefore made:
• Off-road construction vehicles can contribute to local pollution concentrations, and the
Mayor encourages the use of low-sulphur fuel and retrofitted abatement equipment;
• Measures to reduce emissions from construction activities, such as on-site road sweeping,
vehicle and wheel washing, stockpile coverage etc. should be undertaken;
• Policies to reduce vehicle idling should be implemented, with particular relevance to any
sensitive receptors;
• Appropriate access routes and diversions should be explored to minimise disruption and
emissions from vehicles moving to and from the site, and
• A Considerate Contractor scheme (or an equivalent) should be implemented.
63 Further measures to minimise impacts from the site should be agreed with the London
Borough of Ealing, if not agreed already.
64 There is no evidence of any consideration of other development locally being taken in to
account in the modelling work, and more specifically traffic data used to facilitate the modelling
work. The Mayor recognises the need to address possible cumulative impacts from development
proposals, and this is particularly the case where development of residential property is proposed
within an air quality management area. The Mayor seeks assurances that the applicant has
considered such impacts as part of the proposal.
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Noise
65 There are no apparent strategic noise concerns with this proposal and any detailed noise
mitigation issues can be dealt with by Ealing Council using normal planning procedures. In
developing the detailed designs, the applicants should consider using building layouts (for
example, not placing habitable rooms on the noisiest facades), wherever possible, to protect
residents from noise, in preference to the use of acoustic glazing. Consideration should also be
given to ensuring amenity areas within the development are protected from high noise levels.
Given the mixed use nature of the site it will also be necessary to consider the impacts of noise
from plant or equipment, such as air handling units, on the dwellings.
66 Clarification is requested about Table 2 in section 4.3 of the Acoustics report on road and
rail noise - the noise levels seem to be free field values (as required by PPG 24) but are consistently
described as 'facade-incident', presumably meaning the free field noise levels at the position of the
future facades.
67 Ealing Council should satisfy itself that the design provides sufficient space for sound
insulation in party walls.
Sustainable design and construction
68 Policy 4B.6 of the London Plan states that new developments should meet the highest
standards of sustainable design and construction. Policy 4A.8 states that the Mayor will request an
assessment of energy demand of proposed major developments. This should demonstrate the
steps taken to apply the Mayor's energy hierarchy. Renewable energy should be considered first
(preferably to fuel combined heat and power and community heating); and secondly, community
heating with combined heat and power; and thirdly gas condensing boilers and gas central heating.
On all strategic referral applications, at least 10% of the site's energy needs should come from
renewable energy and design should incorporate passive solar design, natural ventilation, borehole
cooling, vegetation on and adjacent to buildings where technically feasible.
69 The applicant has submitted a sustainability report that sets out general energy efficiency
measures that could potentially be used on this site that could provide between 20% and 30%
carbon dioxide emissions savings. There is no indication, however, which measures have already
been designed in and the savings they are likely to achieve.
70 It is not clear what heating system is proposed, although the statement recognises that gas
heating is preferable to electric heating in carbon dioxide emissions terms. The applicant needs to
demonstrate it has considered the Heating hierarchy (Solar water heating; combined eat and power
(CHP); community heating; heat pumps; gas condensing boilers; gas central heating) and state
which system is proposed, incorporating the technology that is feasible in line with the hierarchy.
71 The applicant has set out a detailed consideration of renewable energy technologies in a
clear manner, demonstrating technical feasibility and the likely carbon dioxide savings for each
technology.
72 Biomass has been rejected on the grounds of level of fuel needed and the transport issues
this raises. Ground-source heating and cooling has been rejected on the limited space for
boreholing, given the element of retaining buildings, along with the small cooling load.
73 Photovotaics, horizontal wind turbines and solar water heating are technically feasible to
deliver 1.2-2%, 3-3.4% and 0.22% respectively. The delivery of these technologies will need to be
secured.
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74 The sustainability report makes reference to water conservation and –efficiency but more
information is needed to clarify which methods are actually committed to in the scheme.
Waste strategy
75 The Environmental Statement states that during construction waste production should be
minimised and unwanted materials should be recycled or disposed of in a way that is environmental
good practice. There is no mention of specific recycling targets set as a minimum for contractors
and no mention of the specific minimisation of hazardous materials or minimisation of material
being sent to landfill. There needs to be a commitment to these objectives.
76 There is no commitment to reclaim or reuse materials generated on site; to reuse materials
generated at another site; or to reuse materials from nearby developments where they cannot be
reused.
77 There is a commitment to provide internal and external recycling facilities for both the
offices and the residential areas but the statement in the Sustainability Statement should be
prefixed by ‘sufficient’ and accompanied with actual proposed volumes. Consideration will also
need to be given to the separation of organic food waste in both the residential buildings and the
office buildings, particularly where canteen facilities are to be included. This is a very important
waste stream in the delivery of the requirements of the Landfill Directive.
78 This statement from the sustainability report must be changed to read: “disposal of waste
will be in line with environmental good practice”. In addition, the waste hierarchy (Reduce, reuse,
recycle/compost, recover energy and, lastly, landfill) must be followed when deciding on the
appropriate treatment method for each waste stream.
79 Clarification is sought on the likelihood of any hazardous waste arising from the site. The
consideration of factors for final destination of hazardous wastes arising is welcomed but there is a
need to secure and/or identify suitable facilities for the management of hazardous waste given the
new restrictions which severely limit the landfilling of such wastes. A robust waste management
strategy can establish waste minimization and on site management.
80 The Mayor’s Municipal Waste Management Strategy and the London Plan state that waste
should be dealt with as near to the source of origin as possible. This is not currently reflected in
the proposal.
81 Where recyclables and waste cannot be managed on site, sustainable transport such as river
and rail should be investigated. Where river and rail cannot be utilised, where transportation by
road is the only option, then the distances travelled must be minimised and the use of alternative
fuelled vehicles should be considered.
Local planning authority’s position
82 Ealing Council officers have not yet indicated how they will recommend the scheme to
Ealing Council Planning Committee.
Legal considerations
83 Under the arrangements set out in article 3 of the Town and Country Planning (Mayor of
London) Order 2000 the Mayor has an opportunity to make representations to Ealing Council at
this stage. If the Council subsequently resolves to grant planning permission, it must allow the
Mayor an opportunity to decide whether to direct it to refuse planning permission. There is no
obligation at this present stage for the Mayor to indicate his intentions regarding a possible
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direction, and no such decision should be inferred from the Mayor’s comments unless specifically
stated.
Financial considerations
84 There are no financial considerations at this stage.
Conclusion
85 The site is located in an area that is identified as a Strategic Employment Location in the
London Plan, as well as in the draft SPG Industrial Capacity and in the draft West London Sub
Regional Development Framework. In addition it is within an LDA Priority Area. Park Royal is also
an Opportunity Area but the London Plan has not identified new homes for the area. Although the
development would provide certain regeneration benefits close to an LUL station in terms of
(affordable) housing and (non-industrial) jobs, the loss of industrial employment capacity has not
been fully justified and could result in further erosion of available industrial employment land in the
vicinity.
86 The success of the potential regeneration benefits is somewhat compromised by certain
shortcomings in the design of the scheme and these issues should be addressed.
87 The site is well served by public transport. Transport for London expects Section 106
contributions on a number of transportation improvements, as outlined in the appropriate section.
88 Although 50% of the proposed dwellings will be affordable, there are concerns about the
tenure split and the mix of flat sizes.
89 More information is required on sustainable design, inclusive design, waste strategy, water
efficiency, children’s playspaces, noise and air quality.
for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email colin.wilson@london.gov.uk
Widemar Spruijt, Senior Strategic Planner /Urban Design
020 7983 4926 email widemar.spruijt@london.gov.uk
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