PLANNING COMMITTEE 01 October 2020

Kiri.Shuttleworth@hounslow.gov.uk

References: P/2020/1508 00483/A/P4

Address: Frank Towell Court, Glebelands Road, Feltham TW14 9BL

(Feltham North)

Proposal: Demolition of existing garages and the erection of five blocks ranging between three and nine storeys (Block A - part four, five, eight and nine storeys , Block B - part four, eight and nine storeys, Block C - four storeys, Block D - three storeys and Blocks E & F - three storeys) to provide 102 new homes (Class C3); associated access and other works including new pedestrian footpaths, provision of car and cycle parking, refuse storage and landscaping including amenity space and play area

This application is being presented to planning committee as it is a major Council own application with objections and requires financial contributions, subject to a Legal Agreement.

1.0 SUMMARY

1.1 The proposal is for the demolition of existing garage buildings on site and redevelopment to provide 102 homes within six new buildings ranging between three and nine storeys on the existing Frank Towell Court estate. The 102 new homes are 100% affordable and the application has been submitted by the Council’s Housing department.

1.2 The proposed buildings are considered to be designed and located to ensure they do not detract from the character of the area and would not harm neighbours living conditions or the local highway network.

1.3 The proposed flats would provide an acceptable standard of accommodation in a sustainable location, and are highly sustainable achieving an 83% reduction in emissions over Building Regulations Part L compliant baseline.

1.4 Planning approval is therefore recommended subject to conditions and the satisfactory negotiation of a legal agreement.

2.0 SITE DESCRIPTION

2.1 The site relates to the existing Frank Towell Court estate, located to the north of Bedfont Lane and to the south of Glebelands playing fields. Vehicular is from Bedfont Lane to the south of the site, via Glebelands Road, an internal estate road. Pedestrian access is also from Bedfont Lane. It is also possible to gain access through to Glebelands Playing fields in the North West corner of the site.

2.2 Frank Towell Court is an existing LBH residential estate which is laid out around a central grassed area and access road with two four storey blocks on either side of the central area, an 11 storey tower block on the northern part of the site and 31 no. garages to either side of the tower block. The existing estate comprises 84 homes.

2.3 The site is bound to the north by the Longford River, Glebelands Playing Fields and Blenheim Park which are designated as Local Open Space; to the east by a part three, four and five storey block; to the south by Bedfont Lane; and to the west by the 10th Feltham Scout Group Hall, amenity space within Blenheim Park and two to three storey properties and their associated gardens.

2.4 Car parking for 141 spaces is provided on the estate including on-street parking spaces on Glebelands Road and within the garages. There are 31 garage spaces available on the estate.

2.5 An aerial image of the site is included below:

2.6 The site does not lie within any Conservation Area and there are no statutory or locally listed buildings on site or on the immediate surroundings.

2.7 The site has a Public Transport Accessibility Level (PTAL) of 3/4 (good).

2.8 The surrounding area is principally residential with some community and commercial uses on Bedfont Lane, with open space immediately to the north of the site.

2.9 More specifically this application relates to areas within the existing estate, and is split into four areas as below:

Site A - located to the eastern part of the Site and immediately to the east of the existing 11 storey tower block and comprises an area of hardstanding including two rows of garages and unmarked parking bays.

Site B - located immediately to the west of the existing 11 storey tower block and comprises an area of hardstanding including one row of garages to the west and a row of unmarked parking bays to the east. Access into Blenheim Park is achieved via the northern corner of Site B.

Site C - located to the west of the Site and comprises of scrub land, vegetation and trees. Site C is not part of the designated Local Open Space to the north.

Site F - located to the very southern edge of the Site and comprises the vehicular access point, areas of grass and pedestrian footpaths.

3.0 HISTORY

3.1 00483/A/NOT1 Replacement of 3 antennas and relocation of an existing communication dish with ancillary works (one month notice)

Planning permission not required – 14/08/2014

3.2 00483/A/P3 Erection of single storey rear extension to form caretakers storeroom

Approved – 13/02/1996

4.0 DETAILS

4.1 This application proposes the demolition of existing garage blocks within the estate and the erection of five new blocks, six new buildings, ranging between three and nine storeys in height and providing a total of 102 new homes, with associated access and other works including new pedestrian footpaths, provision of car and cycle parking, refuse storage and landscaping including amenity space and play area.

4.2 The homes would be accessed from the south, off Bedfont Lane, similar to the existing arrangement. 71 parking spaces are proposed,

made up of 59 general parking bays, eight disabled parking bays, and four visitor parking bays. The site plan identifies where a further four disabled parking bays can be provided in the future should demand dictate.

4.3 A new pedestrian access into Glebelands Playing fields will be provided in the northern corner of the site. In the centre of the estate a play area will be created.

4.4 An extract of the proposed site plan is included below:

4.5 Block A - this would be sited in the north east corner of the site, immediately to the east of the existing tower. The block would part four, five, eight and nine storeys. The block is stepped in height with the four storey element located on the eastern side, and the height increases to five, nine and then eight as you move westward; the part closest to the existing tower is eight storeys in height. The block is flat roof in design with a mix of inset and protruding balconies and finished primarily in brick. The entrance is located on the western corner of the building. The block comprises 42 homes.

4.6 Block B - this would be sited immediately to the west of the existing tower. The block would part four, eight and nine storeys. The block is stepped in height with the four storey element located on the southern side, and the height increases to eight and nine storeys to the north; the part closest to the existing tower is eight storeys in height. The block is flat roof in design with a mix of inset and protruding balconies and finished primarily in brick. The entrance is located on the southern corner of the building. The block comprises 37 homes.

4.7 Block C – this would be sited in the western finger of the site, along the northern boundary with the park. The block would be four storeys in height, with the top floor set back from the front elevation. The block is predominantly flat roof in design with a mono-pitch increase to the west, and inset balconies at second and third floor levels, it would be finished primarily in brick. Homes on the second and third floor levels would have deck access along the southern elevation; homes at ground and first floor are maisonettes with front doors at ground level. The block comprises 16 homes.

4.8 Block D - this would be sited in the western finger of the site, along the southern boundary and comprises five three storey mews houses arranged in two terraces. The block would be part two, part three storeys, with the two storey element flat rood to provide a terrace at second floor level for each house; they would also each have a front garden at ground level. The three storey element is designed with an asymmetric pitched roof, with the tallest part sited to the north; the houses would be finished primarily in brick with a metal standing seam roof which wraps over the third floor. The block comprises 5 homes.

4.9 Blocks E & F - sited to the south of the site, at the entrance to the estate along Bedfont Lane and comprises two three storey townhouses at the southern end of the two existing four storey blocks. The houses are three storey with pitched roofs and gables fronting Bedfont Lane. Each house would have a private garden at ground level. The houses would be finished primarily in brick with brick detailing, projecting bay windows at first and second floor and metal standing seam roof. The block comprises 2 homes.

4.10 Eleven wheelchair accessible homes are proposed as part of the scheme. The mix would break down as follows, with 100% of the homes being affordable rented:

One Two Two Three Three

5.0 CONSULTATIONS

5.1 712 neighbouring properties were consulted by letter on 22/05/2020. A press notice was posted on 03/06/2020 and a site notice posted on 08/06/2020.

5.2 Following the receipt of amended plans, re-consultation was sent to 724 neighbouring properties on 12/08/2020.

5.3 19 representations have been received, of which 16 object to the proposals. The comments received are summarised below:

bedroom Bedroom

(3 person)

bedroom

(4 person)

Bedroom

(4 person)

Bedroom

(5 person)

Affordable rent

(% of total)

26

(25.5)

1

(1)

53

(52)

8

(7.8)

14

(13.7)

Comment Response

Harm to neighbours; loss of privacy, loss of light, daylight/sunlight impacts, overbearing, noise, dust pollution

It is considered that the proposal would not have any unacceptable impact on the living conditions of any of the neighbouring properties; a full assessment is given in paragraphs 7.76-7.119.

Harm to character and appearance; design; It is considered that the proposal overall is acceptable in terms of design; a full assessment is given in paragraphs 7.22-7.40

Overdevelopment, overcrowding The scale of the development and number of homes is considered acceptable in terms of design, impact on neighbours and would provide sufficient communal amenity space across the

site for all residents of the estate.

Transport; insufficient parking, increase in traffic

The proposal is considered acceptable in terms of transport; a full assessment is given in paragraphs 7.120-7.147.

Insufficient infrastructure to cope – schools, medical facilities, police

The site is included as a site allocation in the emerging Local Plan Review and this is considered in the Council’s Infrastructure Delivery Plan.

Encroachment into park and damage by construction vehicles

The proposed development lies within the existing estate boundary, there would be no encroachment into the park. Conditions and obligations will secure best practice in terms of construction activities.

Impact on wildlife including on Longford River

The impact on ecology has been fully considered, and with mitigation measures secured is considered acceptable, an assessment is included at paragraphs 7.154-7.160.

Impacts of Blocks E & F on existing blocks – TV satellites, damage to walls of existing, blocks existing path to bins

The impact on living conditions for existing blocks has been considered and deemed acceptable. A path to the rear courtyards for the existing blocks will be provided from the front of the site. The impact on TV satellites is not strictly a planning issue, nevertheless the applicant is the Council who are responsible for the existing blocks and best practice will be employed

5.4 The application has been drawn to members' attention on the weekly pending decision list dated 21st – 28th August 2020 (Week 34) as a Council Own Major Scheme. There was no request to call this in to Bedfont, Feltham and Hanworth Area Forum.

5.5 The scheme went to Design Review Panel in July 2019 at which point the scheme was in the early stages of design, the main comments related to the brief for the site and the site layout. This later design has therefore been informed by the feedback from Design Review Panel, in particular in relation to the layout, landscaping and mix of typologies included.

External Consultees

5.6 Thames Water – With regard to the Foul Water sewerage network infrastructure capacity, we would not have any objection to the above planning application, based on the information provided.

With regard to Surface Water network infrastructure capacity, we would not have any objection to the above planning application, based on the information provided.

5.7 Affinity Water Company – No response received at time of writing.

5.8 Transport for London (TfL) – TfL initially objected to the level of parking proposed, stating it is not compliant with the ITPLP (Intend To Publish London Plan) Policy T6.1 which states that the maximum car parking provision for developments in PTAL 4 Outer London locations is up to 0.5 spaces per unit, which for this development would equate to 51 spaces and that car parking should therefore be reduced to a policy-compliant level.

5.9 Following discussion with the Council’s Transport team and a review of the proposal a revised response was received which sates “TfL have no objections so long as car parking over time is reduced and written into planning consent. We would recommend a Parking Design and Management Plan is secured by condition, and new residents should be exempt from applying for an on-street or residential parking permit for the existing spaces”.

5.10 Through their responses TfL requested conditions are attached to any consent, these are recommended accordingly (4, 5, 6, 7, 8).

during construction.

Concerns about breaches of lease agreement

This is not a material planning consideration; it is a legal; issue rather than a planning issue.

5.11 Design out Crime Officer – The Design Out Crime Officer is satisfied that the development could achieve the Silver Award accreditation of the Secured by design New Homes 2019 and has requested a condition. The condition has been recommended accordingly (9).

5.12 Environment Agency – No comments received at the time of writing.

5.13 Heathrow safeguarding – The proposed development has been examined from an aerodrome safeguarding perspective and could conflict with safeguarding criteria unless any planning permission granted is subject to the condition detailed. We will need to object to these proposals unless the above-mentioned condition is applied to any planning permission.

5.14 Heathrow have requested that a condition relating to a Bird Hazard Management Plan be attached to any permission, as well as an informative relating to cranes. The condition has been recommended accordingly (10).

5.15 NATS Safeguarding – The proposed development has been examined from a technical safeguarding aspect and does not conflict with our safeguarding criteria. Accordingly, NATS (En Route) Public Limited Company ("NERL") has no safeguarding objection to the proposal.

5.16 London Fire – no response at the time of writing

5.17 NHS – no response at the time of writing

6.0 POLICY

Determining applications for full or outline planning permission

6.1 The determination must be made in accordance with the development plan unless material considerations indicate otherwise. Local finance considerations must also be assessed.

The National Planning Policy Framework

6.2 The National Planning Policy Framework (NPPF) was revised on 19 February 2019. The April 2014 National Planning Practice Guidance (NPPG) is an online guidance resource that supports the NPPF. Where pertinent, the NPPF and NPPG are material considerations that will be taken into account in decision-making.

The Development Plan

6.3 The Development Plan for the Borough comprises the Council's Local Plan (adopted by the Council on 15 September 2015), the West London Waste Plan and the London Plan Consolidated with Alterations since 2011.

6.4 The draft New London Plan has been through Examination in Public, but has not yet been adopted. Thus, although it is a material

consideration, the weight given to it remains a matter for the decision maker at this stage.

6.5 The Council are currently undertaking two Local Plan Reviews; the West of Borough Local Plan review and the Great West Corridor Local Plan review. Consultation on the ‘Preferred Options Consultation’ document for both these reviews, and amendments to the adopted Local Plan, was undertaken between 23 October 2017 and 10 December 2017. The policies of these draft Plans are capable of being a material consideration in planning decisions. The Local Plan Reviews have now been through the formal Regulation 19 Public Consultation, which ran from 30 July to 24 September 2019. The policies will gain more weight as it moves through the examination process to adoption; however the weight given to them is a matter for the decision maker.

6.6 The Local Plan documents can be viewed on the Planning Policy pages of the Hounslow website.

6.7 London Plan- relevant policies

Policy 3.3 Increasing housing supply

Policy 3.4 Optimising housing potential

Policy 3.5 Quality and design of new housing (Table 3.3 minimum space standards)

Policy 3.6 Children and young people’s play and informal recreation

Policy 3.8 Housing Choice

Policy 5.2 Minimising carbon dioxide emissions

Policy 5.3 Sustainable Design and Construction

Policy 5.10 Urban Greening

Policy 5.13 Sustainable Drainage

Policy 6.13 Parking

Policy 6.9 Cycling

Policy 7.1 Lifetime neighbourhoods

Policy 7.4 Local Character

Policy 7.6 Architecture

Policy 7.13 Safety, Security and Resilience to Emergency

6.8 The draft London Plan - Intend to Publish Version December 2019

D3 Optimising site capacity through the design-led approach

D4 Delivering good design

D5 Inclusive design

D6 Housing quality and standards

D7 Accessible housing

D12 Fire safety

H1 Increasing housing supply

H4 Delivering affordable housing

H6 Affordable housing tenure

H10 Housing mix size

T2 Healthy Streets

T5 Cycling

T6.1 Residential parking

6.9 Relevant Local Plan policies

CC1 Context and Character

CC2 Urban Design and Architecture

CC3 Tall Buildings

EQ1 Energy and carbon reduction

EQ2 Sustainable design and construction

EQ3 Flood Risk and surface water management

EQ5 Noise

EQ6 Lighting

EQ7 Sustainable waste management

EQ8 Contamination

EC2 Developing a sustainable local transport network

ED2 Maintaining the Borough’s Industrial Land Supply

GB1 Biodiversity

SC1 Housing Growth

SC2 Maximising the provision of affordable housing

SC3 Meeting the need for a mix of housing size and type

SC4 Scale and density of new housing development

SC5 Ensuring suitable internal and external space

7.0 PLANNING ISSUES

7.1 The planning issues to consider are:

Acceptability in principle

Affordable housing

Sustainability

Design and Appearance

Suitability of Accommodation

Impact on adjoining occupiers

Highways Issues

Environmental Considerations

Trees

Planning Obligations Acceptability in principle

7.2 The site is not allocated within the adopted Local Development Plan. However the site is identified as a site allocation for residential development within the West of the Borough Local Plan Review (site allocation 56); the site allocation indicates a minimum development quantum of 70 homes.

7.3 Policy SC1 of the Local Plan seeks to maximise the supply of additional housing in the Borough in order to meet housing need, as supported by policy 3.3 of the London Plan. This proposal would contribute to the supply of housing within the Borough and would represent an increase of the homes currently on the site.

7.4 Consequently, a residential scheme, in the context of policies seeking addition dwellings within sustainable locations such as this is considered to be acceptable in principle subject to consideration of the other planning issues.

Housing Mix and Affordable Housing

7.5 The NPPF and the London Plan encourage new residential developments to provide a choice of housing with a mix of family and non-family housing needed to meet different community requirements.

7.6 The London Plan emphasises that affordable housing is a priority. London Plan Policy 3.8 says there should be a choice of homes that

people can afford and policy 3.9 seeks mixed and balanced communities in terms of tenure and household income to aid social inclusion and avoid segregation of populations by housing tenure.

7.7 London Plan policies 3.11 and 3.12 seek to ensure the maximum reasonable amount of affordable housing is provided having regard to affordable housing targets, the need to encourage rather than restrain residential development and the individual circumstances of the site. Policy 3.12(C) says affordable housing should normally be provided on site with off-site provision only acceptable in exceptional cases where it is robustly demonstrated on-site provision is inappropriate. Policy 3.13 of the London Plan requires developments of 10 or more dwellings to include affordable housing.

7.8 The policies within the Intend to Publish Draft London Plan also emphasise the need to provide genuinely affordable homes as well as a range of home size (policies H4, H6 and H10). Policy H8 relates to the loss of existing housing and estate redevelopment and requires any loss to be replaced by new housing at existing or higher densities with at least the equivalent level of overall. The proposal would increase the number of homes on the site and would be 100% affordable with no demolition of existing homes; therefore there is no conflict between the proposal and these policies.

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

7.10 The application proposes to provide 100% affordable housing at London Affordable Rent (LAR). The rent levels would be in line with the benchmarks set by the London Plan for London Affordable rents. For a one bedroom home this rent would be £159.32 per week, £168.67 per week for a two bedroom home and £178.05 per week for a three bedroom flat for the period 2020/21.

7.11 The proposed quantum of affordable housing exceeds the strategic target of 40% and ensures affordable housing is maximised on the site; the proposal would result in an uplift of 102 affordable homes over the existing number of homes on site. The scheme will therefore result in a positive contribution to the Borough’s affordable housing targets and is supported.

7.12 Local Plan Policy SC3 sets out the Council’s general housing need mix requirement and sets out that developments are expected to provide a mix of new housing to meet this need.

7.13 The proposal comprises a mix of one, two and three bedroom flats and houses. The Local Plan considers two bedroom (four person) flats and above to be family-sized units.

7.14 The proposed mix of twenty six one-bedroom, one two bedroom three person, fifty three two bedroom four person, eight three bedroom four person and fourteen three bedroom five person homes is considered acceptable and would provide a mix of home size to meet the Council’s identified need.

Sustainability

7.15 London Plan Policy 5.2 (Minimising Carbon Dioxide Emissions) applies to all developments and states that development should make the fullest contribution to minimising carbon dioxide emissions in accordance with the following energy hierarchy:

Be lean: use less energy

Be clean: supply energy efficiently

Be green: use renewable energy

7.16 As a major residential development we would expect the development to show a minimum 35% reduction in emissions on Building Regulations Part L compliant baseline (2013), where possible to achieve a carbon neutral standard, internal water use of 105L/Person/Day or less and sustainable material standards. The application was accompanied by an Energy Assessment.

7.17 The submitted documents show an onsite reduction in emissions of 83% below baseline.

7.18 The application proposes photovoltaic panels on blocks A, B and C, blocks D, E and F are not considered suitable for PV panels due to roof form or location. The proposed photovoltaic panels would have a PV rating of 113kWp and the performance is highly efficient with a panel power of 370W.

7.19 Demand reduction measures to be incorporated within the scheme include insulated building fabric with low air permeability, glazing with suitable U-value, g-value and daylight transmittance, mechanical ventilation with heat recovery and low energy lighting. The applicant proposes a 100% electric solution; Air Source Heat Pumps (ASHPs) would provide heating and hot water.

7.20 Conditions have been included to ensure that the development is carried out to deliver the 83% reductions as well as water efficiency and sustainable sourcing of materials (11, 12 and 13).

7.21 It is considered that the approach taken has maximised on site emission reductions and is considered highly sustainable; this is considered acceptable and fully supported. In order to achieve compliance with the ‘zero carbon’ homes standard, the applicant is required to make a financial contribution to the Council’s Carbon Offset

Fund, this will be secured through the legal agreement (Unilateral Undertaking).

Design and Appearance 7.22 Policy 7.1 of the London Plan requires the design of new buildings and

the spaces around them to reinforce or enhance the character of the neighbourhood. Policy 7.4 requires the design of the building to respond appropriately to the local character. Policy 7.5 requires the provision of a high quality public realm. Policy 7.6 requires high quality architecture and materials.

7.23 The above is echoed in policies D4 and D5 of the Intend to Publish Draft London Plan.

7.24 Policy CC1 of the Hounslow Local Plan seeks to ensure that all new development preserves conserves and enhances their special qualities and heritage. Policy CC2 of the Hounslow Local Plan seeks to retain, promote and support high quality urban design and architecture to create attractive, distinctive, and liveable places. Policy CC3 deals with tall buildings and seeks to preserve the predominantly two to three storey character of the borough, with limited scope for four to six storeys along main streets and where the opportunity exists for higher density development.

7.25 The emerging site allocation included within the West of the Borough Local Plan Review requires the height of new development to be in conformity with the West of Borough Feltham Place Policy, and should optimise density and promote an urban character with good street enclosure including improvements in the quality and access to on site and adjoining amenity spaces. The development should ensure it steps up from the existing height to form a sensitive and legible change in character, and ensures it does not overshadow or overlook existing properties.

7.26 The general character of the area around the application site is residential, although there are some community and commercial uses on Bedfont Lane. Within the site the existing buildings range between four and eleven storeys in height, there is a part three, four and five storey block to the east and the houses along Bedfont Lane are predominantly two storey. A number of taller buildings exist to the east of the site within the Feltham Town Centre boundary, including the ten storey Fairview scheme on the corner of Bedfont Lane and new Road. The proposed scheme would be seen in context with the existing buildings on the site and the schemes currently being built on nearby sites.

7.27 In proposing buildings between four and nine storeys, the application needs to comply with policy CC3 of the Local Plan, which deals with tall buildings. The proposed three and four storey buildings proposed (Blocks C, D, E and F) are comparable to the neighbouring buildings in their location; Blocks E and F sit alongside the existing four storey

blocks on the estate, and Blocks C and D will be seen in the context of the existing four and eleven storey blocks on site as well as the three storey New River House. This is considered to be a location where the opportunity exists for higher density development and taller buildings. This is on the basis of the good public transport accessibility afforded to the site and its proximity to a park and the town centre. The Council’s housing targets and ambitions to secure additional affordable housing mean that an increase in height is the direction of travel and this is supported provided it is well designed and responds sensitively to its context.

7.28 The scheme proposes two building with elements at eight and nine storeys which flank the existing eleven storey block on site; the buildings also have lower elements; part four and part five storeys on Block A and four storeys on Block B. Within the current application these buildings have been revised to sculpt the mass and the blocks step up from the neighbouring buildings, have the tallest element in the centre and step down one storey towards the existing tower. The stepping of the buildings reduces their bulk and ensures it appears proportionate and subordinate to the existing eleven storey block, which would remain the tallest building on the estate.

7.29 Blocks A and B have been sited along the northern edge of the site, adjacent to the park, in the case of Building B this is located adjacent to the new proposed link to the park; this approach is considered appropriate as it helps promote the legibility of the new park access. The blocks step down to the east and west and Blocks C, D, E and F, which are located closer to neighbouring sites with lower buildings are of a much lower scale being between three and four storeys in height. It is considered that the heights have been located appropriately within the site and the proposed buildings would not be overly tall given the generous site area and that it is set back from Bedfont Lane, adjacent to the park and in the context of some existing tall buildings; thus it is considered that the proposal would not be read as unduly imposing.

7.30 In addition the buildings within the blocks differ architecturally to respond to the differing characters across the site, including variance in the roof forms between the blocks. There is also variation within blocks in terms of materiality and colour.

7.31 The two taller buildings, Blocks A and B, have a clearly defined top, middle and bottom which helps ground and break down the massing and bulk. On both blocks the four storey element has a clear horizontal focus, distinguishing it from the eight and nine storey elements which have a more vertical emphasis; in the case of Block A this is continued in the five storey element. The banding above the first floor clearly defines the base of the building as the bottom two floors, and the architecture has been carefully considered to show these comprise maisonettes. The banding and detail at the ninth floor also clearly define the top of the building. In addition the tallest nine storey element

is to be treated differently to the remainder of the building in terms of materiality; this also helps to break up the bulk of the building.

7.32 Block C has also been designed to emphasise the maisonettes across ground and first floor and the flats at second and third floor. The asymmetric roof pitch which encompasses the second floor on Block D helps to break up the massing. On blocks E and F the use of bay window and brick detailing, as well as the change in colour are used.

7.33 Therefore it is considered that the mass and bulk of these buildings has been sufficiently broken down to respond to the surrounding development. The proposal would be highly visible within its surroundings, however the areas allocation as part of the Feltham Housing Zone and the emerging West of the Borough Plan, point toward the scale of development proposed as being the direction of travel for development in the area. On this basis the scale of the buildings is considered to be appropriate.

7.34 The use of bricks as the primary material for the blocks is consistent with the wider area and the feature brickwork helps to add interest and break down the massing of the proposed blocks. The pallet of materials would be similar to those used on the existing estate and in the surrounding area. The details of the brick and the detailed design features such as the brick, window reveals, bay windows and balconies, particularly the laser cut panels, will be secured by condition (2) to ensure a high quality finish and that the intended design rationale is realised in the final development.

7.35 The blocks have been designed to incorporate private front doors to serve the ground floor homes and to ensure the communal entrances are clearly legible from the communal areas of the site. The inclusion of these separate private entrances aids the legibility of the scheme and increases opportunities to meet neighbours. The design and orientation of the buildings has been carefully designed to ensure the facades fronting the public realm, contain entrances and windows to ensure that the communal open space and play areas, as well as the new park access benefits from natural surveillance. The orientation of Blocks A, B and C has also ensures the an active frontage is presented to the park, which is considered appropriate in terms of both providing good outlook, preserving privacy and providing natural surveillance for the park itself. The scheme is considered not to be of a scale or level of dominance that would appear overly dominant or detract from the parkland itself.

7.36 The proposed scheme retains significant open space within estate and facilitates a better access to the park, in addition Blocks E and F from the entrance to the estate and interact better with Bedfont Lane. It is therefore considered that the scheme interacts appropriately with the street and the surrounding pattern of development.

7.37 The proposed landscaping will ensure that the site has an open and green aspect. Whilst existing trees will be removed to facilitate the

development, these have been limited to those necessary and substantial additional planting is proposed. The final and full details of the landscaping, soft and hard will also be key to ensure that a high quality finish is achieved, and to realise the landscaped scheme design. This is secured by condition (14).

7.38 The plans show that the car parking would be located within the central courtyard. The applicant has provided indicative and illustrative landscaping plans which show how the access and parking areas will be delineated from the pedestrian and cycle paths and soft landscaping is also to be provided within this central courtyard area. The hierarchy of hardstanding and the layout of the planting help direct visitors to the main entrances and thus aids the legibility of the development. In general the layout of the scheme and the landscape principles are considered acceptable however it is considered necessary to retain the final details by condition (14) in order to ensure a high quality finish.

7.39 The plans show a new access to be provided along the northern edge of the site to the park at the rear. Whilst the detailed design of this access has not been provided, the plans submitted provide sufficient detail to demonstrate that the access is a minimum of 3m wide to allow pedestrian and cycle access to the park. The distinction between the public access route and the private amenity space associated with the development is clear whilst enabling natural surveillance of the access. Overall it is considered that the approach is acceptable and the detailed design of the public access route to the park can be secured as part of the landscaping condition (14) to ensure it is an attractive landscaped route.

7.40 As such the design of the schemes is considered to be acceptable.

Suitability of Accommodation

Internal space provision

7.41 Local Plan Policy SC5 requires the internal space of new homes to comply with the Nationally Described Space Standards (NDSS). The NDSS provide minimum internal floor areas for all new residential units and are mimicked in policy 3.5 of the London Plan.

7.42 All of the proposed homes would meet or exceed the minimum space standards with the one bedroom two person homes measuring between 51-75sq.m, the two bedroom three person measuring 73 sq.m, the two bedroom four person homes measuring between 70- 87 sq.m, the three bedroom four person homes measuring 87-107 sq.m and the three bedroom five person homes measuring between 96-120 sq.m.

7.43 Policy 3.5 of the London Plan also states that new homes should have adequately sized rooms and convenient and efficient room layouts which are functional and fit for purpose, meeting the changing needs of Londoners. All of the homes are well laid out with sufficient layout of

rooms ensuring bedrooms are located together and where possible away from living space; each home is afforded with storage space and private amenity areas.

7.44 All homes in block C are dual aspect, all homes in blocks D, E and F are triple aspect. Overall 76% of the proposed homes are dual aspect. Blocks A and B include maisonettes over ground and first floor and therefore whilst single aspect the homes would have a suitable outlook with windows on two floors and serving all habitable rooms. The number of single aspect homes has been minimised and none of the single aspect homes are directly north facing.

7.45 Policy 7.2 of the London Plan requires development proposals to be designed with the specific needs of disabled people integrated into the development.

7.46 The proposed development would provide eleven wheelchair accessible homes in accordance with building regulations Part M4(3) with the remaining homes all meeting building regulations part M4(2) meaning they are wheelchair adaptable units. There would be two, one bedroom two person wheelchair accessible home, six two bedroom four person wheelchair accessible homes and three bedroom five person wheelchair accessible homes. All would be provided at affordable rent.

Private amenity space

7.47 Local Plan policy SC5 and the Mayor’s Housing SPG state that each home of up to two people should be provided with at least 5sq.m of private amenity space and 1sq.m for each additional occupant. For houses, the usable amenity space should be provided to no less than the following standards: 50sqm per 3 habitable room house; 60sqm per 4 habitable room house; and 75 sqm per 5 habitable rooms and over.

7.48 Each home would be afforded private amenity space with direct access in the form of balconies/terraces at upper floors and gardens at ground floor. The proposed arrangement is considered acceptable. All the flats would meet the required private amenity space provision.

7.49 The townhouses in blocks E and F meet the 75 sqm private amenity space requirement through a front garden and private garden located to the side of the property. The majority of the amenity space is provided by the private side garden which is considered to be of a suitable shape, aspect and siting.

7.50 The three bedroom mews houses in block D would fall short of the private amenity space requirements (75sqm) however they would be provided with a private garden at ground floor and a terrace at second floor providing between approximately 40 - 48 sqm private amenity space each. The two bedroom mews house would have gardens and a terrace providing 29 sqm of private amenity space. It is acknowledged that these homes do not meet the standards; however they are located

close to the Town Centre and within an estate which provides communal spaces and children’s play area, in addition the houses have been designed to provide generous internal spaces which exceed the standards. All the homes would have access to the onsite communal amenity space, as well as having easy access to the playing fields which adjoin the wider estate, facilitated by the park entrance provided by this development. Therefore it is considered that in this instance the shortfall in private amenity space for these houses can be accepted.

7.51 The plans indicate how the amenity space for the flats at ground floor could be delineated from the general landscaping and ensure privacy for the occupants. In addition the design of the balconies has been refined to provide sufficient privacy for the residents of the development. The final details would be secured through the materials and landscaping scheme (conditions 2 and 14).

7.52 There is no private amenity space provided for any of the existing properties in Frank Towell Court as existing. However the rear communal courtyards serving the existing four storey blocks would be retained and improved as part of the proposal.

Communal amenity space

7.53 Communal amenity space should also be provided in line with Policy SC5 of the Local Plan which states that for each unit of up to 3 habitable rooms 25sq.m should be provided, 30 sq.m per flat with four habitable rooms and 40 sq.m per flat with five habitable rooms, less a reduction for the area of private space provided for each flat.

7.54 In this case the shortfall of private space for the houses has been added to the communal requirement given the location within the wider estate.

7.55 The table below provides details of the amenity space proposed, against the policy requirement for the proposed homes:

Amenity space type

Policy requirement

Sq. m

Adjusted requirement

(accounting for private space

provided) Sq. m

Proposed (net against policy requirement)

Sq. m

Private Gardens/ Balconies

1,122 N/A 1,185 (+63; 106%)

Communal Amenity

2,510

1,325 2,553.75 sq. m (+1228.75; 192.7%)

7.56 The above table has been calculated using only the amenity space which is available to all residents, and excludes public pathways. This exceeds the requirement for the development.

7.57 The residents of the existing blocks on site (two four storey blocks and the tower block) would also have access to the communal amenity space.

7.58 With regard to the existing flats on site, if built today these would require a total of 2,050 sqm communal space. It is noted that the residents in the two four storey blocks currently have access to communal rear courtyards behind the blocks and grassed areas to the front of the buildings surrounded by railings; in total these areas provide 1,473.5 sqm of communal amenity space. These would be retained and improved by the proposal including resurfacing of the rear yards and hedge planting to the front grassed areas. This provision (1,473.5) combined with the overprovision shown in the table (1,228.75) exceed the 2,050 sqm communal space required for existing residents. Therefore it is demonstrated that overall the proposal would ensure that there is sufficient on site communal amenity space to serve all existing and proposed residents.

7.59 Communal amenity space is provided on the ground floor in the form of communal central garden/play area, riverside garden, nature play area and green areas. The quantum of communal space ensures a high quality for existing and future residents and contributes to the scheme design. Part of the site would also be publically accessible from the footpath. The layout of the space is considered to be useable and acceptable.

7.60 It is acknowledged that the proposal is using areas which currently exist within the site however the proposal includes a site wide landscaping scheme and will provide facilities which are not currently present on site, such a play areas. Therefore the communal amenity space within the site would be a significant improvement in terms of quality over the existing site and is welcomed as a benefit of the scheme.

7.61 London Plan policy 3.6 and the Mayor’s SPG on Providing for children and young people’s play and informal recreation states that any development for housing should include play and informal recreation. The proposed development includes the provision of a children’s play space within the centre of the estate.

7.62 The GLA’s play space calculator shows that 944.2 sq. m of play space is required for this scale of development. The proposal includes integrated play space as part of the development, playable space is provided within the central garden and nature play is included within the North West corner by Block B. The required provision can be accommodated, particularly given the significant communal amenity space provided, and the proposal would include the provision of specific play equipment within the site and it is considered that this

arrangement would provide suitable play and recreation facilities for all residents.

Daylight/sunlight/outlook

7.63 The majority of homes would be either dual or triple aspect and therefore it is considered they would have good levels of daylight/sunlight and outlook. None of the single aspect homes are directly north facing.

7.64 The daylight and sunlight report submitted also shows that all the homes modelled complied with good practice for daylight with regard to average daylight factor and average sky view.

7.65 The results of the sunlight modelling and testing show that there is a 62% pass rate for the recommended annual summer and winter probably sunlight hours in main living rooms. This is a typical score for urban infill developments and considered acceptable given the site constraints.

7.66 In terms of open spaces the east facing courtyards on Block A, the gardens for Blocks E and F and the roof terraces for Block D meet the BRE guidelines in that they receive at least two hours on sunlight on 21 March. However the north facing courtyards in Blocks A, B, C and D do not meet the BRE guidelines this is due to the orientation of the site. Due to the location of the existing tower block and its shadow pattern and the fact that due to site constraints there is no other reasonable location for Blocks A and B it is inevitable that the courtyards serving these blocks would be partly shadowed. For Block D given that the roof terraces meet the BRE guidelines it is considered that this arrangement is acceptable.

7.67 In addition to private terraces and balconies, the residents have access to the communal open space on site; the central courtyard and the mews street between bocks C and D both receive well in excess of the BRE guidelines. Residents also have access to alternative recreation space at Glebelands Playing Fields and Blenheim Park. These are located immediately north of the site and access to this area will be improved as part of the proposals via the new footpath in the North West corner of the site. On balance it is therefore considered that the proposals are acceptable in providing affordable housing in a sustainable location and that across the site there are good levels of daylight and sunlight.

Noise and disturbance

7.68 Policy EQ5 (Noise) of the Local Plan states that the Council will seek to reduce the impact of noise from aviation, transport and noise-generating uses, and require the location and design of new development to have considered the impact of noise, and mitigation of these impacts on new users and surrounding uses according to their sensitivity.

7.69 The site lies outside of the sensitive Heathrow Noise Contours and therefore there is no objection to additional family housing in this location, provided that the development would include sufficient noise insulation to provide acceptable internal noise environments. The application has been accompanied by a Noise Impact Assessment; this report was based on detailed environmental noise measurements made at the proposed development site. An assessment of the external amenity areas is also included.

7.70 The submitted report provides guidance on external materials and glazing that could be used to achieve suitable internal noise levels. Following submission of additional details and a review of these specifications, they are considered appropriate for the scheme and will achieve suitable internal noise levels.

7.71 The report also outlines that the external amenity areas are likely to be between 52 and 55 dB LAeq,16hours during the daytime period; this is below the Lowest Observed Adverse Effect Level (LOAEL) which is the level above which adverse effects on health and quality of life can be detected and is therefore considered acceptable.

7.72 No assessment of proposed fixed plant has been provided although limits have been set based on plant achieving a rating level of 10 dB below measured background noise levels. At this stage of the development it is unlikely that any confirmed plant details will be available and so it is reasonable to condition this (15).

7.73 Consequently, the scheme is considered acceptable with regard to noise levels.

Fire safety

7.74 Policy 7.13 of the current London Plan and Policy D12 of the Intend to Publish Draft London Plan require development proposals to contribute to the minimisation of potential physical risks, including those arising as a result of fire. D12 goes further and requires all major development proposals should be submitted with a Fire Statement.

7.75 The applicant has submitted an outline Fire safety strategy, which has been prepared to address the requirements of the above policies and submitted by suitably qualified person. The Fire Safety Strategy covers the active fire safety systems, means of warning and escape, passive fire protection systems, external fire spread and access and facilities for the fire and rescue service and is considered acceptable.

Impact on adjoining occupiers Light, Outlook, Visual Intrusion and Privacy

7.76 London Plan policy 7.6 states that buildings and structures should not cause unacceptable harm to the amenity of surrounding land and

buildings, particularly residential buildings, in relation to privacy, overshadowing, wind and microclimate.

7.77 Policy CC2 of the adopted Local Plan seeks to protect existing residents’ amenity.

Block A

7.78 Block A is sited in the north east corner of the site, the existing tower block comprising no.’s 17-68 Frank Towell Court lies to the west, the eastern existing four storey block comprising 69-84 Frank Towell Court lies to the south west and a part three, part four storey block of 14 flats lies to the east on locomotive Drive and wrapping around to the south outside the application site.

7.79 No concerns arise from impact on land to the north, given that it is parkland.

7.80 Block A would be sited 18m to the east of the existing tower block (no.’s 17-68 Frank Towell Court) at the closest point; due to the siting of Block A and the relationship with the existing tower block it is considered that the proposal would be acceptable in terms of its impact on the living conditions of the existing residents with regard to visual intrusion and outlook; there would be no demonstrable impact which would cause concern.

7.81 The arrangement of the flats within Block A would result in a number of habitable room windows facing the existing tower block from two flats on each floor. However due to the position of block A, which projects to the north of the existing block, it would only be the windows of one flat on each floor which may align with those in the existing tower block and in any case all flats in Block A which have windows facing west are dual aspect with other windows facing north or south away from the neighbouring block. The windows facing west serve bedrooms or are not the only windows serving these rooms. There are no balconies proposed on the west elevation of Block A. As noted above the proposed building would be located 18m from these neighbours, this is in accordance with the 18- 21m guideline separation distance between windows in habitable room windows. As stated above the windows proposed within the development are not the only windows serving the flats, and it is acknowledged that the separation distance is similar to that found in more densely populated areas. The arrangement is therefore considered suitable.

7.82 The daylight and sunlight report tested the flats within the tower block which are likely to be most impacted by the proposed development due to their position within the building. The daylight and sunlight report demonstrates that whilst there may be a small reduction in daylight and sunlight for the existing flats in this block, these are minimal. All windows would exceed the good practice guidelines and the level of change is considered acceptable. In terms of sunlight all would continue to meet the good practice guidelines for both summer and

winter; therefore there would be no adverse effect on the existing dwellings.

7.83 The neighbouring block on Locomotive Drive to the east is sited 2.1m from the application boundary and is three storey in height at this point, Block A would be sited 2.6m from the boundary so there would be a separation distance of 4.7m between these buildings. At its eastern end Block A would be four storeys in height which is taller than the neighbouring block, however due to its siting and its projection to the north and that there are no habitable room windows which directly face towards Block A it is considered that there would be no harm caused through visual intrusion, loss of outlook or loss of privacy.

7.84 The daylight and sunlight report identifies that all windows in this neighbouring block facing north, east and south comply with the recommended VSC guidelines. However, the west facing windows fail the recommended guidelines due to its close proximity to Block A. An analysis of the floorplans for this block shows that of the three windows, one is located in the communal entrance stairway of the building and therefore does not directly impact the daylight of a specific home. The other two windows are located in the main living room areas, however these spaces have an additional main window on the opposite eastern façade which are not compromised and will receive adequate daylight. Therefore in the circumstances it is considered that a technical fail of the guidelines would not result in a degree of harm to the neighbouring living conditions which would warrant refusal of the application. All existing windows would continue to meet good practice guidelines in respect of sunlight.

7.85 No.’s 69-84 Frank Towell Court are located in the eastern existing four storey block on the estate, this is orientated east –west and there are no windows in the north side elevation which would face Block A. Consequently it is considered that there would be no loss of outlook, overbearing or visual intrusion caused to these neighbours by Block A.

7.86 The daylight and sunlight report demonstrates that whilst there may be a small reduction in daylight and sunlight for the existing flats in the four storey block, these are minimal and all meet the good practice guidelines. Therefore there would be no demonstrable harm caused to the existing residents by loss of light.

7.87 There would be windows and balconies facing south towards the existing four storey block, however these would not align with windows and whilst they would give some views over the rear courtyard this is a communal area and currently overlooked by the existing flats, as such it is not considered that this would cause any harm to the living conditions of existing residents.

Block B

7.88 Block B is sited in the North West corner of the site, the existing tower block comprising no.’s 17-68 Frank Towell Court lies to the east of this

and the western existing four storey block comprising no.’s 1-16 Frank Towell Court lies to the south west.

7.89 In relation to no.’s 1-16 Frank Towell Court, this existing building is orientated east –west and there are no windows in the north side elevation. The southern part of Block B is limited to four storeys in height and designed to chamfer away from this existing block with the integral balconies completing the form, the taller element of Block B is sited to the north; therefore it is considered that there would be no loss of outlook, overbearing or visual intrusion caused to these neighbours by Block B.

7.90 The daylight and sunlight report demonstrates that whilst there may be a small reduction in daylight and sunlight for the existing flats in the four storey block, these are minimal and all meet the good practice guidelines. Therefore there would be no demonstrable harm caused to the existing residents by loss of light.

7.91 There would be windows and balconies facing south towards the existing four storey block, however there are no windows in the north elevation of the existing block and whilst they would give some views over the rear courtyard this is a communal area and currently overlooked by the existing flats, as such it is not considered that this would cause any harm to the living conditions of existing residents.

7.92 With regard to the existing tower block, no.’s 17-68 Frank Towell Court, Block B would be sited 18m to the west of this and project to the north.

7.93 There are windows in the west elevation of the tower block facing Block B, however a separation distance of 18m between these and those within Block B is considered suitable given the location and that this is a typical arrangement found in more densely populated areas, in addition the window arrangement has been designed to minimise direct lines of sight between windows. The outlook from these windows would alter but it is considered that this would not be to a degree which would cause demonstrable harm to the living conditions of these neighbours. There would be balconies on the eastern elevation facing the existing tower block however there would only be four and these are only found between first and fourth floor , these balconies have been designed with laser cut panel surrounds to be more enclosed than the other railed balconies and thus mitigate overlooking opportunities.

7.94 The daylight and sunlight report tested the flats within the tower block which are likely to be most impacted by the proposed development due to their position within the building. The daylight and sunlight report demonstrates that whilst there may be a small reduction in daylight and sunlight for the existing flats in this block, these are minimal with all exceeding the good practice guidelines; therefore the level of change is considered acceptable; it would not adversely affect the daylight in these properties.

7.95 In terms of sunlight there would be a minimal reduction in the annual probable sunlight hours, with all continuing to meet the good practice guidelines for both summer and winter; therefore there would be no adverse effect on the existing dwellings.

Block C

7.96 Block C is located along the northern boundary within the western portion of the site. Block D would be sited between this block and the neighbours along Bedfont Lane. Therefore whist a storey taller it would not have any impact on these neighbours in terms of overbearing, visual intrusion, loss of light or outlook. The decked access to the flats at second and third floor within Block C would be sited on the south of the building but given that this is approximately 15m from the boundary with these neighbours and being partially screen by Block D there would be no loss of privacy caused.

7.97 Similarly due to the relationship between Blocks C and D and the location of New Rivers House it is considered that Block C would not result in harm to the living conditions of these neighbours.

7.98 The scout hut is sited to the west of Block C, however this is a less sensitive use, and the proposal has been designed to ensure this site is not sterilised for the future so there are no concerns.

7.99 To the north the block adjoins the park and therefore there are no neighbours in this direction.

Block D

7.100 Block D relates to the mews houses in the western portion of the site. These back onto the rear gardens of no.’s 144 - 154 Bedfont Lane to the south, New River House to the south west and the Scout Hut to the west.

7.101 Due to the design of Block D there would be no mews house directly along the rear boundary of no.’s 150 and 152 Bedfont Lane and therefore there would be no demonstrable impact on these properties. The cycle store would be built along the rear boundary in this location however due to its scale this would not impact these neighbours.

7.102 The gardens for 144-154 Bedfont Lane all measure over 30m in length between the rear elevation and the boundary with the site; therefore there will be over 30m between the rear elevations of the proposed houses and these properties which means that the mews houses will not have any overshadowing or overbearing or loss of light effect on these neighbours. The houses would also not result in visual intrusion or loss of outlook for these neighbours, whilst the view would change this does not equate to harm to outlook; views in themselves are not a planning consideration. There would also be no intervisibility between windows given the separation distance and that the windows proposed in the rear of Block D are sited 1.7m above internal floor area or

obscurely glazed; the exception to this is the door at ground level in the rear of the one bedroom house, however this is set off the boundary and would be obscured by the boundary treatment. Consequently there would be no overlooking or loss of privacy caused from these windows. The proposed windows allow light into the mews houses without compromising the privacy of the existing gardens.

7.103 Given that the neighbouring properties on Bedfont Lane are located to the south of the proposed development, there would be minimal shadowing of the rear gardens, and this would only affect the very end, as such this would not be considered to harm the enjoyment of these gardens. It is acknowledged that there is some overshadowing of these gardens from the existing four storey block on the estate; this is an existing situation and would not be made worse by the proposal.

7.104 Views to the south from the terraces at second floor will be shielded by a parapet wall of suitable height to avoid opportunities for overlooking or loss of privacy.

7.105 New River House is located to the south west of Block D and approximately 1.6m from the site boundary. There are no windows in the rear of the mews house which directly face this neighbouring building and those which face the amenity space associated with the block are positioned above eye level to avoid loss of privacy.

7.106 Due to New River House lying to the south west of Block D there may be some shadowing in the morning but this would not be present for the majority of the day, therefore this would not be to a degree which would harm the living conditions of these neighbours.

7.107 In terms of outlook and visual intrusion the mews houses would be sited in close proximity to New River House, however the flats within New River House have a primary east-west outlook and so the impact of Block D is lessened. It is considered that this would not harm the living conditions of these residents to a degree which would warrant refusal of the application.

7.108 The side elevation of the eastern most mews house would face the rear elevation of the block comprising no.’s 1-16 Frank Towell Court, however it would be sited over 10m from this block across the courtyard. There are no windows in the closest part of the mews house, and the windows at first and second floor which face towards the existing block are secondary windows and sited over 13m away, this is considered an acceptable arrangement given the location of the site and the density of development, in addition the window arrangement has been designed to minimise opportunities for intervisibility.

7.109 The daylight and sunlight report demonstrates that whilst there may be a small reduction in daylight and sunlight for the existing flats in this block, these are minimal and all meet the good practice guidelines.

Therefore there would be no demonstrable harm caused to the existing residents by loss of light.

7.110 The scout hut is a less sensitive use, not being a residential property however the proposal has been designed to ensure this site is not sterilised for the future.

Blocks E and F

7.111 Blocks E and F are sited to the south of the existing four storey estate blocks and match the existing depth of these, thus they do not project to the front or rear of the blocks and do not obscure any existing windows. Due to the siting of the townhouses there would be no intervisibility between windows in the existing block and those in the townhouses. Whilst the position of windows in the side elevations of the townhouses may give oblique views over the rear courtyards associated with the existing blocks, these courtyards are already overlooked by the existing windows and so this would not result in any loss of privacy compared with the existing situation.

7.112 With regard to the neighbour at 144 Bedfont Lane, Block E would have side facing windows facing this property. However both properties primary outlook faces Bedfont Lane and the townhouse would be set forward of the neighbour so there would be no direct intervisibility between windows. The townhouse would be sited approximately 10m from the boundary with this neighbour; therefore there would be no loss of privacy. Whilst the townhouse would be taller than the neighbour given the separation distance and that it would be sited to the east of the neighbour there would be no harm caused by overshadowing or overbearing.

7.113 To the east of Block F lies 118 Bedfont Lane, a part four, part five storey building containing 28 flats. The balconies associated with these flats front Bedfont Lane and the only windows facing the application site are small and secondary. Block F would be sited 10m from the site boundary and thus 15m from the side elevation of this neighbouring building, it would also be set forward of the building so none of the windows would line up, avoiding any intervisibility. Due to the scale and siting of Block F and the relationship with this building it is considered that there would be no harm caused to the living condition of the existing residents.

7.114 There are residential properties along the southern side of Bedfont Lane opposite the site; however they are set back from the road and thus sited 20m from the closest part of the site. Due to the scale of Blocks E and F and the separation distance as well as these neighbours being sited to the south no concerns arise from impact on these neighbours.

7.115 In conclusion it is considered that the proposed development would not have any unacceptable impact on the living conditions of any of the

neighbouring properties in terms of privacy, overlooking, visual intrusion, loss of outlook or loss of daylight/sunlight.

Noise

7.116 The proposal would increase the number of homes on the site and include larger family accommodation, this means that more people would reside on the site and thus activity on site would be more intense. Nevertheless the site is located in a predominantly residential area and backs onto an area of public open space; therefore it is considered that the proposal would not result in any noise or disturbance that would be unusual or unacceptable within this setting. Consequently there are no concerns with regard to noise and disturbance arising from the proposed development.

7.117 Concerns have been raised with regard to noise and disturbance during construction, some noise and disturbance is inevitable during the development of a site however it is not expected that this would be unusually noisy or prolonged. The hours of construction are controlled by condition. If there are complaints regarding the construction activities on site these can be dealt with under pollution controls, outside of the planning process.

Lighting 7.118 Policy EQ6 states that when considering proposals for lighting or

floodlighting the Council will seek to minimise light pollution and ensure there is adequate protection from glare and light spill to sensitive receptors.

7.119 The applicant has not included details of any proposed external lighting. Any proposals for external lighting could be dealt with as part of the detailed landscaping scheme secured by condition (14).

Highways issues 7.120 Policy 6.3 of the London Plan states that developments should ensure

that impacts on the transport capacity and the transport network are fully assessed.

7.121 Policy 6.9 of the London Plan states that development should provide secure, integrated and accessible cycle parking facilities. Policy 6.13 states that the maximum car parking standards in table 6.2 should be applied and developments must provide electrical charging points to encourage the uptake of electric vehicles. Provision should be consistent with objectives to reduce congestion and traffic levels and to avoid undermining walking, cycling or public transport.

7.122 Policy EC2 of the adopted Local Plan seeks to secure a more sustainable local travel network that maximises opportunities for walking, cycling and using public transport.

7.123 The site has a formal Public Transport Accessibility Level (PTAL) of 3/4. There are three bus services within 400m of the site, with a further five services within 600m. Feltham Station is within 400m. As such, it is considered that the proposal has good accessibility to public transport

7.124 Feltham Town Centre, as defined by the Local Plan, is within 350m of the site, and the high street is a 600m walk away

Access

7.125 Vehicular access and the main pedestrian access to the site are taken from Bedfont Lane. Both the vehicular access and pedestrian accesses on Bedfont Lane will be enhanced to facilitate better pedestrian movement along Bedfont Lane and into the site. A new, more legible shared-use access to the park to the north is proposed, via the southern side of the Longford River. These improvements are considered necessary and can be secured by a condition (16) requiring the submission of full details and that they are completed prior to occupation of the development.

7.126 A raised table crossing is proposed across the vehicular access from Bedfont Lane which is welcome as this slows vehicles and improves the pedestrian environment.

Car parking

7.127 There are currently 108 general parking spaces within the site boundary and a further two disabled bays. In addition there are 31 garages, of which 13 are let to residents of Frank Towell Court, eight are let to residents of the surrounding area, and the remaining ten are not in use.

7.128 Overnight, weekday, and Saturday parking surveys have been undertaken for the Frank Towell Court estate and the surrounding roads. The overnight surveys for the wider area found that the average parking stress over the two nights surveyed was 63%, which is not considered to constitute a heavy level of parking. However, the survey results included streets within the Bedfont Lane CPZ which would be unavailable to other residents Mon-Fri 09:30-18:30 when restrictions are in place. Therefore these are unlikely to be used regularly by nearby residents from outside the CPZ and should be discounted from the survey results. Doing so gives an average overnight parking stress of 67%, still below the 90% level that is generally regarded as the threshold for excessive parking stress.

7.129 Over both nights surveyed, the average number of cars parked in the Frank Towell Court estate, which constitutes Glebelands Road and the areas in front of the garages, was 59, whereas the overall number of spaces including disabled spaces is 110.

7.130 71 car parking spaces are proposed across the site, made up of 59 general parking bays, eight disabled parking bays, and four visitor

parking bays. The site plan identifies where a further four disabled parking bays can be provided in the future should demand dictate. The number of general parking spaces would provide for the average number of cars found to park in the estate over the two nights surveyed, essentially only re-providing spaces for the existing residents. It is unlikely that the let garages would be used for regular parking due to their restricted internal dimensions and the availability of unrestricted parking in the estate therefore it is not considered necessary to provide additional spaces for these. Other than disabled parking spaces, no parking would be provided for residents of the new dwellings.

7.131 The Intend to Publish London Plan prescribes a maximum of 0.5 car parking spaces per dwelling in areas with a PTAL of 4. As the site would accommodate 186 homes overall (84 existing and 102 proposed), the proposed parking provision would result in a parking ratio of 0.38 thereby satisfying the policy. However, given the accessibility of the site and that the proposed general parking provision is intended to satisfy the existing demand, there is scope to reduce the number of spaces over time as existing residents move out or their circumstances change.

7.132 Eight disabled parking bays would be provided from the outset with the plans indicating where another four could be provided if demand dictates. As there are already two disabled parking bays serving the site, the proposal would provide six additional disabled parking bays and four potential disabled bays for the new dwellings. This is one short of the overall 11 bays required by the Intend to Publish London Plan however there appears to be scope to accommodate this shortfall within the site and this can be secured by condition (17).

7.133 The Transport Statement commits to meeting the Intend to Publish London Plan standards in terms of EV charging provision. These require that 20% of the spaces are provided with active chargers, with the remaining spaces provided with a passive provision. Details of where the active chargers will be located and their specification can be secured by condition (18), with the provision installed and available for use prior to occupation.

7.134 To secure the proposed car-free nature of the additional homes, a CPZ should be advanced for the surrounding streets and a contribution secured to cover the cost of its consultation and potential implementation. The existing and future addresses in the Frank Towell Court estate will need to be made ineligible for parking permits for the CPZ; this can be secured within the legal agreement. It is not envisaged that the parking within the development would be included in the wider CPZ, if implemented, and instead would be available for residents of the estate solely.

7.135 If a CPZ isn’t advanced after consulting neighbouring residents, the additional parking demand of 38 would result in parking stress levels of

92%. This would be slightly above the 90% threshold that is generally regarded as constituting excessive parking stress. The additional demand could be reduced, thereby improving parking stress levels, through a Travel Plan and the allocation of the additional homes to non-car owners where possible.

7.136 A Parking Management Plan will need to detail how the spaces would be managed, how parking will be restricted to the marked bays only and how parking elsewhere will be enforced against, how the active EV bays will be allocated and when the passive bays are converted to active bays, and a scheme for reducing the parking over time in favour of landscaping and amenity areas. This can be secured by condition (5).

7.137 In terms of the parking layout, each of the parking spaces adheres to the relevant dimensional standards and would be provided with appropriate manoeuvring space. The scheme has been revised to improve visibility of pedestrians using the east-west route through the car parking area, directly south of the central children’s play park however to provide pedestrian priority the pedestrian route to the central courtyard area should be raised to slow vehicles where pedestrians are being guided to cross, however this can be finalised and secured through the landscaping condition (14).

7.138 The eight disabled parking spaces provided from the outset would be clustered around Frank Towell Court which is in close proximity to the proposed blocks and adjacent to where the two existing disabled parking spaces are situated therefore the locations are considered acceptable.

Trip generation

7.139 The TRICS database was interrogated for comparable sites to understand the likely trips that would be generated by the additional units proposed. Adjusting the results to reflect the intended car-free nature of the additional homes, the exercise found that there would be nine additional two-way trips by private vehicles in the AM peak and seven in the PM peak. Neither is likely to be perceptible over the existing traffic flows, equating to one additional trip every 6 minutes. However, this assumes that the proposed units would not have access to parking opportunities which is reliant on a CPZ being progressed on surrounding streets as referred to above.

7.140 If this were not the case, a very-much worst-case scenario whereby the additional units’ mode share mirrors the Travel to Work mode share from the 2011 Census data, the number of additional two-way car journeys in the AM and PM peaks rises to 95 and 88 respectively. This equates to three additional movements every two minutes approximately. Mitigation measures included in a Travel Plan, improvements to walking and cycling routes, and the provision of high quality cycle parking would reduce this worst-case scenario private car trip generation to more acceptable levels, while the imposition of a CPZ

on surrounding streets and effective management of the on-site parking would bring the levels down to those expected by the Transport Statement.

7.141 Accordingly the proposal is considered acceptable in terms of trip generation and traffic and would not warrant refusal of the application.

Highway status

7.142 Part of Block A will be built on public highway therefore this will need to be Stopped Up to remove the public right of way. The proposal includes the Stopping Up of the whole of Glebelands Road; this would allow the proposed parking to be more flexibly managed to better serve the needs of existing residents. An obligation within the legal agreement will secure and safeguard a public right of way from Bedfont Lane to the Longford River path for pedestrians and cyclists to benefit the wider area.

Cycle parking

7.143 Cycle parking is proposed to be provided in line with the Intend to Publish London Plan standards, and indicative layouts are shown on the ground floor plans. Additional cycle spaces are also being proposed for the existing flats which is welcome. The locations of the stores are acceptable, however there are some improvements that could be made so that the spaces are as convenient and accessible as possible: the two tier stands to have centre-to-centre distances of 500mm and the inclusion of more Sheffield-type stands. It is considered that there is sufficient space within the internal stores and the wider site to accommodate these and therefore the full details of the layout of the stores can be secured by condition (6).

Travel planning

7.144 A full Travel Plan will be secured by condition (8) to encourage more active forms of travel and the use of public transport in lieu of private car journeys.

Refuse storage

7.145 Each of the existing and proposed blocks will be provided with dedicated bin stores in appropriate locations. Swept path analysis has been provided showing that a refuse vehicle can get to within the 15m drag distance of the bin stores with an acceptable level of reversing (less than 12m).

Deliveries and servicing

7.146 An outline Delivery and Servicing Plan has been included in the Transport Statement which considers the expected number of servicing vehicles, their type, and the likely dwell times. There is sufficient space within the site for such deliveries to take place without impacting on the

public highway, access to the parking space, and pedestrian and cyclist movements.

Construction phase

7.147 An outline Construction Logistics Plan (CLP) has been included in the Transport Statement and is generally acceptable. A detailed CLP will be secured by condition (4), with specific measures to minimise disturbance to existing residents through the construction phase and needs to include a Staff Travel Plan to ensure that staff and contractors travel to the site by sustainable means and avoid parking within the Frank Towell Court estate or roads surrounding the site. The detailed CLP will need to be worked up with the main contractor, once appointed, to ensure that it is realistic and achievable.

Environmental Considerations

Air Quality

7.148 The Council’s Air Quality Action Plan (AQAP) designates the whole borough as an Air Quality Management Area (AQMA), and identifies road transport as the major source of air pollution, giving rise to nitrogen dioxide and particulate matter which can cause respiratory illnesses and other adverse health effects.

7.149 The applicant has submitted an Air Quality Assessment to support the application which has been reviewed by the Council’s Environmental Strategy officers.

7.150 The report states that the proposed development will use air source heat pumps and therefore will not have the potential to cause significant effects on local air quality. In addition the predicted concentrations of NO2, PM10 and PM2.5 within the proposed development are predicted to be below the relevant NAQOs. As such, residents will experience acceptable air quality. This is considered acceptable.

7.151 The revised Air Quality Assessment submitted has addressed the initial comments regarding background concentrations used and the HDV movements during the construction phase. As such there are no reasons for refusal on Air Quality grounds, however, as stated within the report a condition should be included to protect surrounding sensitive receptors, this is recommended accordingly (19 and 20).

Contamination

7.152 The site investigation submitted by the applicant does not any indicate significant risk to human health, controlled waters or ecology and wildlife associated with the development of the site as currently proposed. The Council’s Land Quality Team reviewed the report and considers it satisfactory, although a condition is required in relating to further investigation and remediation as concluded within the report;

this is standard given the low risk. Therefore no objections are raised to the scheme subject to the inclusion of a suitable planning condition; this is recommended accordingly (21).

Flood Risk/ Drainage

7.153 The site lies within Flood Zone 1 and is therefore has low probability of flooding. It is therefore considered suitable for residential development.

7.154 The applicant has submitted a drainage strategy to support the application; and this has been revised following initial comments from the Lead Local Flood Authority.

7.155 The Authority is satisfied that appropriate full details and detailed drainage designs can be secured by condition (22). It is recommended that evidence to demonstrate the development is carried out in accordance with the final approved details is also required by condition (23).

Ecology

7.156 The proposal would result in the removal of the southern portion of the broadleaved semi-natural woodland habitat located in the north-west of the site. Whilst generally this should be retained and protected wherever possible, in this instance it is not possible to retain this woodland and develop this part of the site, and given the pressing need for additional affordable homes and that appropriate offsetting could be incorporated into the landscaping plans, it is considered that suitable ecological enhancements can be included to off-set this loss.

7.157 As set out in the Preliminary Ecological Assessment (PEA) there is opportunity in the north-west and along the northern edge of the site, within the “Nature Play” and “Riverside Park” areas to create naturalistic planting and introduce wildlife features, such as:

Incorporation of native plants and those of wildlife importance in to landscaping scheme to provide foraging opportunities for a wide range of fauna

Creation of a pond or bird/bee bath to provide a static water source for fauna

Creation of log piles and compost heaps to provide additional shelter and foraging resources for a wide range of fauna

Improved connectivity of green infrastructure with new hedgerow planting and infill planting

Provision of new bat roosting, bird nesting (targeting species of conservation concern present locally, e.g. house sparrow) and invertebrate

sheltering opportunities within new buildings and on retained mature trees

Provision of hedgehog gaps in new fencing to promote habitat connectivity across and within the Site

Provision of hedgehog boxes to create sheltering opportunities

7.158 The landscaping strategy includes an ecological enhancement strategy which includes bat and bird boxes, log piles, hedgehog box, hedgehog gaps are proposed in close board fencing, bird/bee bath and compost heap as well as native and fruiting tree and shrub species and foraging resources for mammals and birds. This approach is considered acceptable, however full details will be required as part of a condition for an Ecological Management Plan (EMP) (condition 28) and this will include a re-calculation of the Urban Greening factor to increase this to 0.4 minimum and details for how this will be achieved.

7.159 The Longford River, which runs through the Blenheim Park, Feltham Arenas and Glebelands Playing Fields open spaces, is designated as a Site of Importance for Nature Conservation grade I and runs adjacent to the northern border of the site. To avoid run-off and pollution of the waterway during construction, such as from dust and debris, the PEA recommends that best practice construction methods should be applied and that a suitable Construction Environmental Management Plan (CEMP) is conditioned. The Council’s Ecological Expert agrees with this recommendation and a condition is recommended accordingly (24).

7.160 The Council also agrees with the recommendation set out in section 5.18: ‘Any habitat to be retained within or adjacent to the construction site should be protected from physical damage or root zone compaction with tree fencing in line with BS 5837:2012 Trees in relation to design, construction and demolition’. This will be secured by condition (25).

7.161 The PEA makes other recommendations with regards to when works should be carried out in relation to bats, birds and reptiles, as well as a precautionary check for water voles and mitigation advice provided as necessary should any physical works take place within c. 5m of the river. These are all agreed and will be secured by conditions (24, 25, 26, 27).

7.162 It is considered reasonable and necessary to require the submission of additional details by conditions, these will ensure the development is acceptable and ensure the preservation and maintenance of the environment.

Trees

7.163 The proposal would result in the removal of a total of fourteen trees, one tree group and part of a tree group. All of the trees proposed to be removed are category B or C trees and therefore not the best (category A).

7.164 Tree Group 2 which is to be removed relates to the woodland, this is a self-set copse and the value is as a collective rather than individual trees as many are suppressed, have deadwood etc. however there is wildlife value and this is addressed in the ecology section above.

7.165 Tree 1 is a memorial tree, although this is adopted rather than planted and consultation has taken place with a dedicated replacement to be planted. This will form part of the detailed landscaping proposals.

7.166 The landscape proposal include substantial new planting as part of the proposal, and the indicative species are considered suitable and include a mix of large, medium and small trees. This is considered acceptable in the circumstances.

7.167 The Arboricultural Assessment sets out measures to protect the retained trees, these are considered appropriate and therefore a condition (26) is recommended which requires works to be carried out in accordance with these. Therefore it is considered that the retained trees would be suitably protected.

Planning Obligations

7.168 Local Plan Policy IMP3 (Implementing and monitoring the local plan) seeks to ensure that development proposals fully mitigate the impacts of the development on the area through planning obligations. Such obligations are usually secured within a Section 106 agreement having regard to supplementary planning document and provide the CIL payments required by any charging scheduled, including the Mayor of London’s CIL. A payment or other benefit offered in a Section 106 agreement is not material to a decision to grant planning permission and cannot be required unless it complies with the provisions of the Community Infrastructure Levy Regulations 2010 (regulation 122), which provide that the planning obligation must be:

a) necessary to make the development acceptable in planning terms;

b) directly related to the development; and

c) fairly and reasonably related in scale and kind to the development.

7.169 A Section 106 agreement may not address all of the impacts of a development since some of these may be addressed by CIL, in order to satisfy the Regulation 122 tests above.

7.170 The NPPG provides guidance on use of planning obligations, which may impose a restriction or requirement, or provide for payment to make acceptable development proposals that might otherwise not be acceptable in planning terms. The Council’s Supplementary Planning Document on Planning Obligations (adopted March 2008) contains guidance on imposition of planning obligations in compliance with such guidance. These obligations may offset shortfalls in the scheme or mitigate a development’s impacts.

7.171 As the Council is the applicant and land owner as well as the responsible Local Planning Authority, it is not possible to complete a S106 agreement however the relevant planning obligations can be secured through a Unilateral Undertaking from the Council as landowner to the Local Planning Authority.

7.172 The recommendation to approve this application is subject to the legal agreement requiring the following:

Construction Training – onsite or contribution (£2,750 per £1m construction cost) £75,625

Carbon Offset Fund Contribution £55,675

Considerate Contractor Scheme

Secure and retain access to park for public (Glebelands Playing

Field)

Contribution for CPZ consultation (£5,000), and further

contribution (£35,000) for implementation if required. If the

consultation comes back negative or the CPZ is not progressed

for any reason, the implementation amount can be spent on

active travel improvements in the vicinity to help mitigate the

lack of a CPZ.

Restriction on all Frank Towell Court residents obtaining CPZ

permits

Travel Plan monitoring £2,318.40

8.0 EQUALITIES DUTIES IMPLICATIONS

8.1 The public sector equality duty applies to all council decisions.

8.2 A public authority or any person who exercises public functions must, in the exercise of those functions, have due regard to the need to:

(a) eliminate discrimination, harassment, victimisation and any other conduct prohibited by or under the Act;

(b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;

(c) foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

8.3 Having due regard to the need to advance equality of opportunity, this involves having due regard, in particular, to the need to:

(a) remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that are connected to that characteristic;

(b) take steps to meet the needs of persons who share a relevant protected characteristic that are different from the needs of persons who do not share it;

(c) encourage persons who share a relevant protected characteristic to participate in public life or in any other activity in which participation by such persons is disproportionately low.

8.4 This shall include, in particular, but is not limited to steps to take account of disabled persons' disabilities.

8.5 The exercise of public functions must have due regard to the need to foster good relations between persons who share a relevant protected characteristic and those who do not, in particular, to the need to:

(a) tackle prejudice; and

(b) promote understanding.

8.6 Compliance with these duties may involve treating some persons more favourably than others. This is not to be taken as permitting conduct that would otherwise be prohibited by or under the Act.

8.7 The relevant protected characteristics are: age; disability; gender reassignment; pregnancy and maternity; race; religion or belief; sex; marriage and civil partnership; and sexual orientation.

8.8 Due regard needs to be demonstrated in the decision making process and requires an analysis of the material with the specific statutory considerations in mind. It does not follow that the considerations raised will be decisive in a particular case the weight given to them will be for the decision maker. The equalities duty is not a duty to achieve a particular result. Some equalities considerations are covered under other legislation such as building control matters. Officers have in considering this application and preparing this report had regard to the public sector equality duty and have concluded that due regard has been given to the Council’s duty in respect of its equalities duties and that if approving or refusing this proposal the Council will be acting in compliance with its duties.

9.0 LOCAL FINANCE CONSIDERATIONS AND THE COMMUNITY INFRASTRUCTURE LEVY

9.1 Section 70(2) of the Town and Country Planning Act 1990 (as

amended) provides that a local planning authority must have regard to a local finance consideration as far as it is material. A local finance consideration means: a) a grant or other financial assistance that has been, or will or could be, provided to a relevant authority by a Minister of the Crown; or

b) sums that a relevant authority has received, or will or could receive, in payment of Community Infrastructure Levy (CIL).

9.2 The weight to be attached to a local finance consideration remains a matter for the decision maker. The Mayor of London's CIL and Hounslow CIL are therefore material considerations.

9.3 Most new development which creates net additional floor space of 100 square metres or more, or creates a new dwelling, is potentially liable to pay the CIL to Hounslow and the Mayor of London.

Floor space

(sqm)

Existing

lawful floor

space

Demolished

floor space

CIL liable

floor space

0 0 9,581

9.4 The above is calculated in relation to the new development, rather than the existing buildings which are to be retained and not altered as part of this permission.

9.5 This proposal would not be liable to pay the CIL which is index linked.

9.6 The estimated Hounslow CIL payable is £670,670 and Mayoral CIL payable is £862,290. This does not include any exemptions which may be sought. Given the scheme is for 100% affordable housing, it is likely that it will be exempt.

10.0 Conclusion

10.1 The proposal would provide 102 new homes of a suitable standard, 100% of which would be affordable in a highly sustainable scheme without adversely impacting on the character of the area, neighbour amenities, environmental conditions or the local highways network. The scheme would mitigate for its ecological impacts.

11.0 RECOMMENDATION:

1. That planning permission be granted subject to the following conditions (or minor variations of such) and securing the abovementioned planning

obligations by the prior completion of a satisfactory legal agreement or unilateral undertaking made under Section 106 of the Town and Country Planning Act 1990 and of highways agreements under Sections 38 and 278 of the Highways Act 1980 (at the appropriate time) or other appropriate legislation, the exact terms of which shall be negotiated by appropriate officers within the Housing, Planning and Communities Department on the advice of the Assistant Director Corporate Governance.

2. The satisfactory legal agreement or unilateral undertaking outlined above shall be completed and planning permission issued by 30/10/2020 or such extended period as may be agreed in writing by appropriate officers within the Housing, Planning and Communities Department or within Legal Services.

3. If the legal agreement or unilateral undertaking is not completed by the date specified above (or any agreed extended period), then the Chief Planning Officer or Head of Development Management is hereby authorised to refuse planning permission for the reason that the proposal should include planning obligations required to make the development acceptable in planning terms in accordance with Regulation 122 of the Community Infrastructure Levy Regulations 2010, development plan policies and the Planning Obligations SPD, as described in this Report.

4. Following the grant of planning permission, where (a) requested to enter into a deed of variation or legal agreement in connection with the planning permission hereby approved and by the person(s) bound by the legal agreement authorised in paragraph 1 above, and (b) where the planning obligations are not materially affected, and (c) there is no monetary cost to the Council, (d) make minor variation to wording of conditions, the Chief Planning Officer or Head of Development Management is hereby authorised (in consultation with the Chair of the Planning Committee and upon the advice of the Assistant Director Corporate Governance) to enter into a legal agreement(s) (deed of variation) made under Sections 106 and/or 106A of the Town and Country Planning Act 1990 and or other appropriate legislation.

5. If planning permission is refused following the failure to sign a legal agreement in time, the Assistant Director for Planning and Development or Head of Development Management (in consultation with the Chair of the Planning Committee) is hereby authorised to approve any further application for planning permission validated within 12 months of the date of refusal of planning permission, provided that it (a) duplicates the planning application, and (b) that there has not been any material change in circumstances in the relevant planning considerations, and (c) that a satisfactory legal agreement or unilateral undertaking securing the obligations set out in the Report is completed within any specified period of time.

Conditions:

1 A1A Three year time limit

2 B4 No development above ground level shall take place until samples of all materials to be used in the construction of the external surfaces of the development hereby permitted have been submitted to and approved in writing by the local planning authority.

- brick (including brick, feature brick panel, brick framing feature);

- Tiles/ Roof covering;

- window treatment (including sections/reveals);

- balcony details (including soffits, panels and frame)

- all privacy measures, (including obscure glazing details, privacy screens etc.); and

- balustrading treatment (including details/sections/materials);

- any other materials/details to be used.

The development shall then be carried out in accordance with the approved details and maintained as such thereafter.

Reason: In order that the Council may be satisfied as to the details of the development in the interests of the visual amenity of the area and to satisfy the requirements of policies CC1 and CC2 of the adopted Local Plan.

3 B5 In accordance with the submitted plans

4 Construction Logistics Plan

No development shall take place, including any works of demolition, until a Construction Logistics Plan has been submitted to, and approved in writing by, the local planning authority. The Plan shall accord with TfL guidance and shall include:

i. a site plan (showing the areas set out below)

ii. confirmation that a pre-start record of site conditions on the adjoining public highway will be undertaken with Hounslow Highways and a commitment to repair any damage caused

iii. provision for the parking of vehicles of site operatives and visitors

iv. provisions for loading, unloading and

storage of plant and materials within the site

v. details of access to the site, including means to control and manage access and egress of vehicles to and from the site for the duration of construction including phasing arrangements

vi. details of vehicle routeing from the site to the wider strategic road network

vii. the erection and maintenance of security hoarding including decorative displays and facilities for public viewing, where appropriate

viii. provision of wheel washing facilities at the site exit and a commitment to sweep adjacent roads when required and at the request of the council

ix. a scheme for recycling/disposing of waste resulting from demolition and construction works

x. measures to ensure the safety of all users of the public highway especially cyclists and pedestrians in the vicinity of the site and especially at the access

xi. commitment to liaise with other contractors in the vicinity of the site to maximise the potential for consolidation and to minimise traffic impacts.

xii. avoidance of peak hours for deliveries and details of a booking system to avoid vehicles waiting on the public highway

xiii. all necessary traffic orders and other permissions required to allow safe access to the site to be secured and implemented prior to commencement of construction

xiv. details of the construction programme and a schedule of traffic movements

xv. the use of operators that are members of TfL’s Freight Operator Recognition Scheme (FORS)

xviii. confirmation that all vehicles associated with

the works will only park/ stop at permitted locations and within the time periods permitted by existing on-street restrictions.

The approved Plan shall be adhered to throughout the construction period.

Reason. To ensure highway safety is maintained and preserved in accordance with policy EC2 of the Local Plan

5 Parking Management Plan Prior to occupation, a Parking Management Plan shall be submitted to and approved in writing by the Local Planning Authority. The Plan shall include the following:

i. details of parking allocations and how this will be operated and enforced

ii. details of measures proposed to restrict parking to designated bays only and prohibit parking on the access road

iii. a commitment to convert passive EV bays to active when demand requires.

iv. a commitment to remove parking spaces when residents that have a right to park move out or their circumstances change so that they no longer need a space

v. measures to ensure that all existing residents and prospective residents are informed of the Parking Management Plan and that all future residents will not be assigned a parking space or a right to park within the development other than blue badge holders.

The car parking areas shall thereafter be managed in compliance with the approved Parking Management Plan. Reason: In order to promote sustainable modes of transport and safeguard the amenities of surrounding residential properties and ensure minimal disruption of traffic in the locality, in accordance with policies CC1, CC2 and EC2 of the adopted Local Plan and Policy 6.13 of the London Plan 2015.

6 Cycle parking Notwithstanding the submitted details and prior to occupation, full details (including manufacturer’s specifications) of all cycle stands for the occupants of,

and visitors to, the development shall be submitted to and approved in writing by the Local Planning Authority. The approved facilities shall be fully implemented and made available for use before any part of the development is first occupied and thereafter retained for use at all times without obstruction. Reason: To support sustainable transport objectives; in accordance with Local Plan policy EC2.

7 Delivery and Servicing Plan Prior to the occupation of the development, a Delivery and Servicing Plan (DSP) shall be submitted to and approved in writing by the Local Planning Authority. The delivery and servicing for the development shall be carried out in accordance with the approved details at all times thereafter. Reason: In the interests of road safety, in accordance with Hounslow Local Plan Policy EC2.

8 Travel Plan Prior to occupation, a finalised Travel Plan shall be submitted to and approved by the Local Planning Authority. The Travel Plan shall be brought into effect upon occupation and shall continue in permanent operation thereafter, subject to any reviews and adjustments agreed with the Local Planning Authority. Reason. In order to promote sustainable modes of transport and ensure that the proposal complies with Local Plan Policy EC2.

9 Secure by Design

The development shall achieve 'Secured by Design' accreditation awarded by the Design-Out Crime Officer from the Metropolitan Police Service on behalf of the Association of Chief Police Officers (ACPO).

No dwelling shall be occupied until accreditation has been achieved and evidence of such accreditation has been submitted to and approved in writing by the Local Planning Authority.

Reason: In pursuance of the Council's duty under section 17 of the Crime and Disorder Act 1998 to consider crime and disorder implications in excising its planning functions; to promote the well-being of the area in pursuance of the Council's powers under section 2 of the Local Government Act 2000 and to ensure the development provides a safe and secure environment in accordance with London Plan (July 2011) Policies 7.1 and 7.3.

10 Bird Hazard Management Plan

Development shall not commence until a Bird Hazard Management Plan has been submitted to and approved in writing by the Local Planning Authority. The submitted plan shall include details of:

- Management of any flat/shallow pitched/green roofs on buildings within the site which may be attractive to nesting, roosting and “loafing” birds.

The Bird Hazard Management Plan shall be implemented as approved and shall remain in force for the life of the building. No subsequent alterations to the plan are to take place unless first submitted to and approved in writing by the Local Planning Authority.

Reason: It is necessary to manage the flat roofs to minimise its attractiveness to birds which could endanger the safe movement of aircraft and the operation of Heathrow Airport.

Information

The Bird Hazard Management Plan must ensure that flat/shallow pitched roofs be constructed to allow access to all areas by foot using permanent fixed access stairs ladders or similar. The owner/occupier must not allow gulls, to nest, roost or loaf on the building. Checks must be made weekly or sooner if bird activity dictates, during the breeding season. Outside of the breeding season gull activity must be monitored and the roof checked regularly to ensure that gulls do not utilise the roof. Any gulls found nesting, roosting or loafing must be dispersed by the owner/occupier when detected or when requested by Heathrow Airside Operations staff. In some instances it may be necessary to contact Heathrow Airside Operations staff before bird dispersal takes place. The owner/occupier must remove any nests or eggs found on the roof.

The breeding season for gulls typically runs from March to June. The owner/occupier must obtain the appropriate licences where applicable from Natural England before the removal of nests and eggs.

11 Energy Strategy

A) The development hereby permitted shall be implemented in accordance with the approved Energy Strategy.

B) Prior to first occupation of any dwelling within the development hereby approved evidence (e.g. photographs, installation contracts and As-Built certificates under the Standard Assessment Procedure/National Calculation Method) should be submitted to the Local Planning Authority and approved in writing to show that the development has been constructed in accordance with the approved Energy Strategy, and any subsequent approved revisions, and achieved a 83% reduction in emissions.

C) Upon final commencement of operation of any low and zero carbon technologies, suitable devices for the monitoring of the low and zero carbon technologies shall have been installed, and the monitored data shall be submitted automatically to a monitoring web-platform at daily intervals for a period of three years from the point of full operation.

Reason: To ensure that the development makes the fullest contribution to minimising carbon dioxide emissions in accordance with London Plan Policy 5.2 and the London Borough of Hounslow Local Plan Policy EQ1.

12 Sustainable sourcing of materials

A. No development above ground level shall take place until details have been submitted to and approved by the Local Planning Authority that demonstrate:

- At least three of the key elements of the building envelope (external walls, windows roof, upper floor slabs, internal walls, floor finishes/coverings) are to achieve a rating of A+ to D in the Building Research Establishment (BRE) The Green Guide of specification.

- At least 50% of timber and timber products are to be sourced from accredited Forest Stewardship Council (FSC) or Programme for the Endorsement of Forestry Certification (PEFC) scheme.

B. The development shall not be occupied until evidence (e.g. photographs and copies of installation contracts) has been submitted to the Local Planning Authority to demonstrate that the development has been carried out in accordance with the approved details under Part A of this condition. The development shall be maintained in accordance with the approved details at all times thereafter.

Reason: in order to ensure the sustainable sourcing of materials in accordance with the London Plan Policy 5.3 and the Mayor of London’s Sustainable Design and Construction SPG.

13 Internal water use Prior to first occupation of any dwelling evidence (schedule of installed fittings and manufactures literature) shall be submitted to and approved in writing by the Local Planning Authority to demonstrate that the development has achieved an internal water use of 105L/person/day or less. Reason: in order to protect and conserve water supplies and resources in accordance with London Plan Policy 5.15 and the London Borough of Hounslow Local Plan Policy EQ2.

14 Landscaping

Notwithstanding the submitted plans, prior to the commencement of above ground works, full details of both hard and soft landscape works, including for private and communal amenity spaces, and a landscape maintenance plan for the lifetime of the development shall be submitted to and approved in writing by the Local Planning Authority.

The works shall then be carried out as approved and maintained as such at all times thereafter.

The details shall include (proposed finished levels or contours; means of enclosure; car parking layouts; other vehicle and pedestrian access and circulation areas; hard surfacing material; minor artefacts and structures (eg. furniture, play equipment, refuse or other storage units, signs, lighting etc.); proposed and existing functional services above and below ground (eg drainage power, communications cables, pipelines etc. indicating lines, manholes, supports etc.); retained historic landscape features and proposals for restoration, where relevant).

Soft landscape works shall include (planting plans; written specifications (including cultivation and other operations associated with plant and grass establishment); schedules of plants, noting species, plant sizes and proposed numbers/densities where appropriate; implementation programme).

All landscaping comprised in the approved details shall be carried out during the first planting and seeding seasons following completion of construction works. Any trees or shrubs planted (including any such replacements) which die within three years from the date of planting shall be replaced in the next planting season with the same species, and of comparable maturity. The development shall be carried out strictly in accordance with the details so approved and shall be maintained in accordance with the approved management programme.

Reason: To ensure a satisfactory appearance of the site and the adjacent the area in accordance with Local Plan policies CC1, CC2 and GB7.

15 Fixed plant noise restriction

The design and installation of any fixed plant serving the development shall not exceed cumulative rating levels (LAr’Tr) of at least 10dB below the background noise level LA90,T when measured or predicted at 1m from the facade of the nearest noise sensitive premises. The measurement and/or prediction of the noise should be carried out in accordance with the methodology contained within BS 4142:2014+A1:2019 ‘Methods for rating and assessing industrial and commercial sound.’

Reason: To ensure that the future occupants of the development do not suffer an unreasonable level of noise and disturbance and to accord with Local Plan Policy EQ5.

16 Access Works Notwithstanding the details shown on the approved drawings full details of the proposed vehicular and pedestrian access, including the public footpath through the site to Glebelands Playing Fields, to and within the site shall be submitted to and approved in writing by the Local Planning Authority prior to the commencement of

development above ground level. No part of the development hereby permitted shall be occupied until the new means of access have been sited, laid out and constructed in accordance with the approved details. The approved details shall be carried out in accordance with the approved detail and so maintained at all times. Reason. In order to minimise danger, obstruction and inconvenience to users of the highway and of the access in accordance with adopted Local Plan Policy EC2.

17 Blue badge spaces No development above ground level shall take place until full details of thirteen blue badge parking bays (eight to be provided at the outset and plans to indicate where another five could be provided if demand dictates) are submitted to and approved in writing by the Local Planning Authority. The details shall include manufacturer’s specifications. The bays shall be installed in accordance with the approved details and so maintained at all times thereafter. Reason: In order to promote sustainable modes of transport, in accordance with policies CC1, CC2 and EC2 of the adopted Local Plan and Policy 6.13 of the London Plan 2015.

18 EV charging points No development above ground level shall take place until full details of the Electric Vehicle Charging Points, each capable of a minimum output of 7.2kW, are submitted to and approved in writing by the Local Planning Authority. The details shall include manufacturer’s specifications. The charging points shall be installed in accordance with the approved details and so maintained at all times thereafter. Reason: In order to promote sustainable modes of transport, in accordance with policies CC1, CC2 and EC2 of the adopted Local Plan and Policy 6.13 of the London Plan 2015.

19 Air Quality – HDV movements

Prior to the commencement of any construction or demolition works at the proposed site. A detailed air quality assessment of the max HDV movements associated with the construction phase of the development is to be undertaken. Surrounding sensitive receptors along the expected route (A30 Great Western Road, Staines Road and Bedfont Lane) are to be included within the assessment.

Reason: In order to ensure that surrounding sensitive receptors will not be exposed to a significant increase in poor air quality, in accordance with Local Plan Policies EC2 and EQ4.

20 Air Quality – NRMM

All Non-road Mobile Machinery (NRMM) used during the course of the development that is within the scope of the GLA ‘Control of Dust and Emissions during Construction and Demolition’ Supplementary Planning Guidance (SPG) dated July 2014, or any successor document, shall comply with the emissions requirements therein

Reason: In the interests of Air Quality and to satisfy the requirements of policy EQ4 of the adopted Local Plan.

21 Contamination

Before the development hereby permitted commences:

a. Details of an intrusive site investigation are required in addition to the phase 1 desk study previously submitted. These details shall be submitted to, and approved in writing by, the Local Planning Authority. The site shall be investigated by a competent person to identify the extent and nature of contamination. The report should include a tiered risk assessment of the contamination based on the proposed end use of the site.

Additional investigation may be required where it is deemed necessary.

b. If required, a scheme for decontamination of the site shall be submitted to the Local Planning Authority, for written approval. The scheme shall account for any comments made by the Local Planning Authority before the development hereby permitted is first occupied.

During the course of the development:

c. The Local Planning Authority shall be notified immediately if additional contamination is discovered during the course of the development. A competent person shall assess the additional contamination, and shall submit appropriate amendments to the scheme for decontamination in writing to the Local Planning Authority

for approval before any work on that aspect of development continues.

Before the development is first brought into use:

d. The agreed scheme for decontamination referred to in clauses b) and c) above, including amendments, shall be fully implemented and a written validation (closure) report submitted to the Local Planning Authority for approval.

Reason: Contamination is known or suspected on the site due to a former land use. The LPA therefore wishes to ensure that the development can be implemented and occupied with adequate regard for public and environmental safety, in accordance with policy EQ8 Contamination of the adopted Local Plan.

Supporting notes: a. An initial phase 1 desk study has been submitted with the original application and is considered satisfactory. A phase 2 intrusive investigation will need to be submitted and will include investigation into outstanding potential contamination issues to be communicated by the local planning authority and allow the development of a site Conceptual Model (CM), which identifies all potential pollutant linkages on the site. Risk assessments must adhere to current UK guidance and best practice. b. The scheme for decontamination shall provide details of how each potential pollutant linkage, as identified in the conceptual model, will be made safe. c. In some instances the LPA may require work on site to be ceased whilst the nature of additional contamination is investigated fully. d. The validation report shall revisit the site conceptual model, and provide evidence that each aspect of the decontamination scheme was carried out correctly and successfully. This report shall prove that the development is suitable for its new use. e. We request that site investigation reports or site plans be sent electronically to landquality@hounslow.gov.uk or by post on a cd or dvd wherever possible.

22 Drainage

Prior to commencement of development the final detailed drainage designs and associated full drainage maintenance plan shall be submitted to and agreed in writing by the Local Planning Authority. The proposed development shall be carried out in all respects in accordance with the approved details to limit surface water runoff from the site to 10.2 l/s. Reason: To demonstrate that surface water runoff will be managed for the lifetime of the development in line with, amongst others, in accordance with Local plan Policy EQ3, the relevant London Plan policies and Non-Technical Standards for Sustainable Drainage Systems requirements.

23 Implementation of drainage strategy Prior to occupation of any dwelling hereby approved, the applicant must submit for review and approval by the Local Planning Authority evidence that the drainage system has been built as per the approved final detailed drainage designs, approved under condition 22, through the submission of photographs and copies of installation contracts, and written confirmation that the drainage features will be managed as per the detailed maintenance plan for the lifetime of the development. Reason: To ensure that the methods to mitigate the risk of surface water flooding have been constructed as agreed and that the drainage system is suitably managed, in accordance with Local Plan Policy EQ3.

24 Construction Environment Management Plan

No development shall take place, including any works of demolition, until a Construction Environment Management Plan has been submitted to, and approved in writing by, the local planning authority. The Plan shall include:

i. measures to avoid any runoff and pollution (from dust and debris) impacting the water way (Longford River) during construction. Best practice construction methods should be applied ii. action that will be taken to ensure no operational phase impacts occur as a result of increased surface run off and or pollutants entering the Longford River. iii. a commitment to undertake a precautionary check by

suitably qualified ecologist for water voles and suitable mitigation advice be provided as necessary if any physical works take place within c.5m of the river corridor.

The approved Plan shall be adhered to throughout the construction period.

Reason. To ensure the protection of wildlife and supporting habitat and secure opportunities for the enhancement of the nature conservation value of the site in line with the NPPF and Local Plan Policy GB7.

25 Tree retention

In this condition ‘retained tree’ means any existing tree which is to be retained in accordance with the approved plans and particulars, and paragraphs (a) and (b) below shall have effect until the expiration of five years from the date of the occupation of any of the buildings hereby approved. (a) No retained tree shall be cut down, uprooted or destroyed, nor shall any retained tree be topped or lopped other than in accordance with the approved plans and particulars, without the prior written approval of the Local Planning Authority. Any topping or lopping approved shall be carried out in accordance with British Standard 3998 (Tree Work) or any other BS replacing this. (b) If any retained tree is removed, uprooted or destroyed or dies, another tree shall be planted at the same place and that tree shall be of such size and species, and shall be planted at such time, as may be specified in writing by the Local Planning Authority. (c) The erection of fencing for the protection of any retained tree shall be undertaken in accordance with the approved plans and particulars before any equipment, machinery or materials are brought onto the site for the purposes of the development, and shall be maintained until all equipment, machinery and surplus materials have been removed from the site. Nothing shall be stored or placed in any area fenced in accordance with this condition and the ground levels within those areas shall not be altered, nor shall any excavation be made, without the prior written approval of the Local Planning Authority. Reason: To enable the Local Planning Authority to

ensure the protection of retained trees from damage, in the interests of visual amenity, in accordance with Local Plan policies CC1, CC2 and GB7 and London Plan Policy 7.19.

26 Timing of vegetation clearance (breeding birds).

All removal of trees, hedgerows, shrubs, scrub or tall herbaceous vegetation shall be undertaken between September and February inclusive. If this is not possible then a suitably qualified ecologist shall check the areas concerned immediately prior to the clearance works to ensure that no nesting or nest-building birds are present. If any nesting birds are present then the vegetation shall not be removed until the fledglings have left the nest.

Reason. All wild birds, their nests and young are protected during the nesting period under The Wildlife and Countryside Act 1981 (as amended). In the interests of nature conservation and biodiversity, in accordance with Local Plan Policy GB7.

27 Ecological watching Brief

All removal of woodland or scrub shall be carried out in the reptile active season and under an Ecological Watching Brief prepared by a suitably qualified ecologist.

Reason. To ensure reptiles are protected during their hibernation period in the interests of nature conservation and biodiversity, and in accordance with Local Plan Policy GB7.

28 Ecological Management Plan

No development shall take place until an Ecological Management Plan has been submitted to and approved in writing by the Local Planning Authority.

The Ecological Management Plan shall incorporate:

(i) details of measures to protect breeding birds, nests and eggs from mortality/damage, injury and disturbance, including avoidance by timing and/or appropriate supervision;

(ii) details of the ecological clerk of works supervision to be put in place to monitor the clearance of vegetation to ensure no impact on undiscovered or other unexpected

faunal encounters;

(iii) an ecological lighting plan;

(iv) details of ecological enhancement and urban greening factor, including how the urban greening factor is to be delivered and achieved on site;

(v) details of how the enhancement measures will be monitored, managed and maintained, including the long- term design objectives, management responsibilities and maintenance schedules.

(vi) Additional detail on location and type of bird/bat boxes, maintenance and a commitment that any data collected is to be shared with the Council;

(vii) Species surveys within and around the site to demonstrate ecological enhancements

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

Reason: In the interests of Nature Conservation and in accordance with Local Plan policies CC1 and GB7, London Plan policy 5.10.

Informatives:

1) To assist applicants, the London Borough of Hounslow has produced planning policies and written guidance, all of which is available on the Council's website and which has been followed in this instance. The decision was made in a timely manner.

2) Given the nature of the proposed development it is possible that a crane may be required during its construction. We would, therefore, draw the applicant’s attention to the requirement within the British Standard Code of Practice for the safe use of Cranes, for crane operators to consult the aerodrome before erecting a crane in close proximity to an aerodrome. This is explained further in Advice Note 4, ‘Cranes and Other Construction Issues’ (available at http://www.aoa.org.uk/wp-content/uploads/2016/09/Advice-Note-4-Cranes-2016.pdf

Drawing numbers

Received on 18/05/2020:

1100 rev P10, 1150 rev P10, 1151 rev P10, 1300 rev P10, Design & Access Statement Rev P02 dated May 2020 prepared by Kendall Kingscott,Landscape Management Plan ref. 2902-MP-01 P1 dated May 2020

prepared by Allen Pyke, Statement of Community Involvement ref. 42899 rev AA dated April 2020 prepared by Stantec, Preliminary Ecological Assessment ref. CSA/4229/01 dated April 2020 prepared by CSA Environmental, Noise Impact Assessment ref. 42800/2005 rev. 0 dated April 2020 prepared by Stantec, Fire Safety Strategy Issue 01 dated 23 April 2020 prepared by Ashton Fire, Arboricultural Impact Assessment ref. 03284Rv3 dated May 2020 prepared by Tamla Trees, Phase 1 Ground Condition Assessment ref. R001/rev1a sated April 2020 prepared by Stantec, Planning Statement ref. 42800 rev. AA dated may 2020 prepared by Stantec , Energy Assessment ref. 42800 rev. P3 dated May 2020 prepared by Stantec and Transport Statement ref. 42800/5504 dated April 2020 prepared by Stantec.

Received 14/07/2020:

HUDU Planning for Health - Rapid Health Impact Assessment Tool

Received on 07/08/2020:

Air Quality Assessment ref. 42800/2002 Rev B dated August 2020 p[repared by Stantec,

Received on 10/08/2020:

1401 rev p11, 1402 rev p11, 1403 rev P11, 1404 rev P11, 1405 rev P11, 1406 rev P11, 1407 rev P11, 1408 rev P11, 1409 rev P11, 1410 rev P11, 1411 rev P11, 1412 rev P11, 1413 rev P11, 1414 rev P11, 1415 rev P11, 1416 rev P11, 1417 rev P11, 1418 rev P11, 1419 rev P11, 1420 rev P11, 1421 rev P11, 1422 rev P11, 1423 rev P11, 1424 rev P11, 1425 rev P11, 1426 rev P11, 1427 rev P11, 1428 rev P11, 1429 rev P11, 1430 rev P11, 1431 rev P11, 1432 rev P10, 1440 rev P11, 1441 rev P11, 1442 rev P11, 1600 rev P10, 1601 rev P10, 1602 rev P11, 1603 rev P11, 1620 rev P11, 1621 rev P11, 1622 rev P11, 1623 rev P11, 1630 rev P11, 1631 rev P11, 1632 rev P11, 1633 rev P11, 1640 rev P11, 1641 rev P11, 1642 rev P11, 1650 rev P11, 1660 rev P11, 1670 rev P01, 1671 rev P01, 1672 rev P01, 1673 rev P01, 1674 rev P01, 1675 rev P01, 1676 rev P01, 1677 rev P01, 1678 rev P01, 1679 rev P01, 8 x Visual Images, Design and Access Statement Addendum dated August 2020 prepared by Kendall Kingscott, Flood Risk and Surdace Water management Strategy ref. 42800 rev FINAL V2 dated July 2020 prepared by Stantec, Accommodation Schedule Rev P06, Daylight & Sunlight Statement V2 ref. 42800/4505 rev V2 dated August 2020 prepared by Stantec, Landscape and Public Realm Strategy dated July 2020 prepared by Allen Pyke, Technical Note GLA – Energy Assessment Update – Cooling and Overheating ref. TN002 dated 06/08/2020 prepared by Stantec and Technical Note GLA – Energy Assessment Update – Improvements using Triple Glazing and High-Performance PV ref. TN003 dated 07/08/2020 prepared by Stantec

Received on 03/09/2020:

42800/5502/004 rev C.

Received on 16/09/2020:

1400 rev P12 and 2902-LA-02 rev P3.