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planning report PDU/1033a/01
21 April 2010
Hillingdon Hospital, Uxbridge
in the London Borough of Hillingdon
planning application no.4058/APP/2010/133
Strategic planning application stage 1 referral (new powers)
Town & Country Planning Act 1990 (as amended); Greater London Authority Acts 1999 and
2007; Town & Country Planning (Mayor of London) Order 2008
The proposal
Application to extend the life of planning permission for a new 85,000sq.m hospital.
The applicant
The applicant is Hillingdon NHS Trust, and the architect is Day and England Stevensen
Marsh.
Strategic issues
Health: The hospital project follows the recommendations of the Strategic Health
Authority and will be part of London’s plan for NHS modernisation.
Transport: Concerns are raised that should be addressed.
Urban Design: To be satisfactory in design terms, a ‘design code’ is proposed to guide
future development in partnership with Hillingdon Council.
Climate Change: The applicant is required to submit energy strategy and address climate
change policies.
Access: The applicant and Hillingdon Council have agreed to provide a detailed study to
ensure the hospital is designed to be as inclusive as possible at the latter stage of the
‘reserved matters’.
Recommendation
That Hillingdon Council be advised that while the application is generally acceptable in
strategic planning terms the application does not comply with the London Plan, for the
reasons set out in paragraph 46 of this report; but that the possible remedies set out in
paragraph 48 of this report could address these deficiencies.
Context
1 On 16 March 2010 the Mayor of London received documents from Hillingdon Council
notifying him of a planning application of potential strategic importance to develop the above
site for the above uses. Under the provisions of The Town & Country Planning (Mayor of
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London) Order 2008 the Mayor has until 26 April 2010 to provide the Council with a
statement setting out whether he considers that the application complies with the London Plan,
and his reasons for taking that view. The Mayor may also provide other comments. This report
sets out information for the Mayor’s use in deciding what decision to make.
2 The application is referable under two categories of the Schedule of the Order 2008:
(1C) “ a building which is more than 30 metres high and outside the City of London;” and (1B) “a
development which is outside Central London and with a total floorspace of more than 15,000 square
metres.”
3 Once Hillingdon Council has resolved to determine the application, it is required to
refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his
own determination; or allow the Council to determine it itself.
4 The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken
into account in the consideration of this case.
5 The Mayor of London’s statement on this case will be made available on the GLA
website www.london.gov.uk.
Site description
6 The application relates to the site of an existing hospital in Uxbridge, Hillingdon. It is
in an area generally remote from public transport. The surrounding area is generally suburban
in character with two storey semi-detached inter-war housing at a low density, (see Figure 1).
7 The existing buildings are mostly of poor quality except for the hospital’s largest block,
constructed in the 1960s. There are many trees of amenity value in and around the site
however. The site is accessed off Pield Heath Road.
8 The site is in a location of low public transport accessibility.
Details of the proposal
9 The applicant is seeking to renew planning permission for a scheme originally
submitted in early 2005, which has already been renewed once before, resulting permission
being granted in 2007 requiring reserved matters to be approved before 29th April 2010. The
current application makes using of new planning rules introduced in October 2009, which allow
for an extension of the time limit for the submission of the reserved matters and the
implementation of permission.
10 The original proposal was for the phased redevelopment of existing hospital comprising
the erection of three linked blocks (85,000 sq. metres floor space), reconfiguration of on-site car
parking and access arrangements and landscaping (involving demolition of some existing
buildings) (Outline application). The proposal would demolish the majority of the existing
hospital campus leaving only the Furze, a building of historic interest, and the mental health
buildings. The proposal arises because the standard of hospital accommodation on the Pield
Heath Road campus is considered by the London Strategic Health Authority to be poor.
Case history
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11 On 22 March 2005, Hillingdon Council granted planning permission for the previous
outline application, which the current application is seeking to renew it. On 12 April 2005, the
previous Mayor advised the Council that he was content for it to determine the case itself,
subject to any action that the Secretary of State might take (ref: PDU1033/02).
Strategic planning issues and relevant policies and guidance
12 The relevant issues and corresponding policies are as follows:
Health London Plan
Urban design London Plan; PPS1
Access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a good
practice guide (ODPM)
Transport London Plan; the Mayor’s Transport Strategy; draft replacement
Transport Strategy; PPG13; Land for Transport Functions SPG
Climate change London Plan; PPS1, PPS Planning and Climate Change
Supplement to PPS1; PPS3; PPG13; PPS22; the Mayor’s Energy
Strategy; Sustainable Design and Construction SPG
13 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004,
the development plan in force for the area is the 1998 Hillingdon Unitary Development Plan
and the London Plan (Consolidated with Alterations since 2004).
14 The draft replacement London Plan, published in October 2009 for consultation is also a
relevant material consideration.
Principle of development
15 On 1 October 2009 a new temporary procedure was introduced to allow applicants to
apply to extend the life of a planning permission by seeking a new planning permission to
replace an existing one, which is in danger of lapsing. The Department of Communities and
Local Government published ‘Greater flexibility for planning permission: guidance’ in
November 2009 to help planning authorities and developers use this new procedure. It states
that development proposed in an application for extension will by definition have been judged
to be acceptable in principle at an earlier date and planning authorities should, in making their
decision, focus their attention on policy and other material considerations which may have
changed significantly since the original permission was granted.
16 The original application was determined prior to the new policies of climate change
mitigation and adaptation and some new transport policies of the London Plan came into effect.
Therefore it should be assessed against this new policy backdrop.
Health
17 Strategic Health Authority, together with Primary Care Trusts and NHS Trusts have
primary responsibility for achieving the service improvement and modernisation contained in
the NHS Plan and to improve the health of Londoners. London Plan policies support the NHS
in meeting these objectives, and particularly in meeting the spatial needs for new NHS
facilities. The Mayor is committed to work with NHS organisations and other partners,
especially through the London Health Commission, to promote health improvement in London.
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18 This development follows the recommendations of the Strategic Health Authority and
will provide more spacious and significantly more rational accommodation for all of the
departments in the hospital that will be relocated into it. As such, there is policy support in
principle for this development.
Urban Design
19 Good design is central to all objectives of the London Plan and is specifically promoted
by the policies contained within Chapter 4B which address both general design principles and
specific design issues. London Plan Policy 4B.1 sets out a series of overarching design
principles for development in London, and policy 4B.2 seeks to promote world-class, high
quality design and design-led change in key locations. In addition to Chapter 4B, London Plan
policies relating to density (3A.3) and sustainable design and construction (4A.3) are also
relevant.
20 The draft replacement London Plan (2009) reinforces these principles, with new
development required to have regard to its context, and reinforce or enhance the character,
legibility and permeability of the neighbourhood (Policy 7.1).
21 In the original application related to the design of the hospital the GLA and Hillingdon
officers had been involved at an early stage and had achieved significant improvements to the
landscaping and siting of the development. This had resulted in the incorporation of basement
parking for one of the blocks and a much improved landscape treatment. The most positive
aspect of the proposal was the use of individual blocks instead of one single mega-structure. But
despite being understandable in terms of meeting the brief, the layout of the new buildings was
not ideal. The principal aspect of the new buildings would be a sea of parking facing the public
realm. It was a function of its siting and landscaping, one of the matters for which approval was
sought. The new hospital’s ground plane would be an airport style ramp for emergency
vehicles that would provide a duplex ground floor interface. This was again logical and highly
practical but sat awkwardly with the hospital as a piece of architecture and urban design.
22 Although the original design was an outline application, the drawings clearly
represented the most likely design outcome, as there was no intention to depart from the
principles shown in the indicative drawings. However, the information submitted did not
provide sufficient reassurances that design was fully resolved and therefore it was unlikely to
meet the Mayor’s very high design quality aspirations at the time. Therefore, GLA and
Hillingdon officers had agreed to specify a ‘design code’ for the hospital so that the new
buildings would have a satisfactory appearance following the ‘reserved matters’ stage.
23 Hillingdon Council had, endorsed the previous Mayor’s proposed design code and had
agreed to notify the GLA of ‘reserved matters’ applications so that this objective could be
pursued jointly given the apparent poor quality of the existing outline proposals. This
arrangement should be secured again.
Access
24 The aim of London Plan Policy 4B.5 is to ensure that proposals achieve the highest
standards of accessibility and inclusion (not just the minimum), and this and all developments
should seek to better minimum access requirements. The design and access statement explains
the design thinking behind the application and demonstrates how the principles of inclusive
design, including the specific access needs of people with disabilities, have been integrated into
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the proposed development and how inclusion will be maintained and managed. Policy 7.2 of the
draft replacement London Plan reinforces the principles of inclusive access.
25 As the original application was in outline stage, it did not include details of floor plans
and the specifics of parking. However, the applicant had provided a statement of intent on
access and had indicated that an appropriate planning condition could require details of a fully
inclusive built environment. In view of these reassurances it is likely the Mayor’s inclusive
design policies will be fully implemented by Hillingdon Council at reserved matters stage.
Climate change
26 The London Plan climate change policies as set out in chapter 4A collectively require
developments to make the fullest contribution to tackling climate change by minimising carbon
dioxide emissions. The policies set out ways in which new developments must address
mitigation of, and adaptation to, the effects of climate change (Policy 4A.1).
Climate change mitigation and adaptation
27 London Plan policies 4A.4-11 focus on mitigation of climate change and require a
reduction in a development’s carbon dioxide emissions through the use of passive design,
energy efficiency and renewable energy measures. The London Plan requires developments to
make the fullest contribution to tackling climate change by minimising carbon dioxide
emissions, adopting sustainable design and construction measures and prioritising
decentralised energy, including renewables.
28 Draft replacement London Plan policy 5.2 provides a comprehensive framework for
minimising carbon dioxide emissions, and sets targets for carbon dioxide emissions reductions
for residential and non-residential buildings over the plan period.
29 The measures by which these requirements will be delivered should be clearly set out in
an energy strategy. The requirements can be found on the GLA website.
30 London Plan policy 4A.3 seeks to ensure future developments meet the highest
standards of sustainable design and construction, and policy 4A.9 identifies five principles to
promote and support the most effective adaptation to climate change. These are to minimise
overheating and urban heat island effects; minimise solar gain in summer; incorporate
sustainable drainage systems; minimise water use; and protect and enhance green
infrastructure.
31 The applicant is also referred to specific policies relating to overheating (4A.10), living
roofs and walls (4A.11) and sustainable drainage (4A.14). Additional guidance is provided in
the London Plan Sustainable Design and Construction SPG.
32 Whilst it is noted that this is an outline application, the applicant has not submitted the
required energy strategy or provided details of climate change adaptation. The climate change
mitigation and adaptation strategic issues, as set out above must be addressed. As these
requirements related to policies that have come into effect after the previous application was
determined, it is entirely appropriate for the GLA to require this.
Transport for London’s comments
page 5
33 The transport assessment supporting the proposed re-development of Hillingdon
Hospital dates from the original application in 2004 and therefore is not sufficient for TfL to
assess the proposals.
34 Since 2004, policy and best practice in transport planning has moved on and the
proposals should be in accordance with the most recent documentation, which includes The
London Plan (February 2004), consolidated with alterations (February 2008) and Replacement
London Plan (October 2009) and the Mayor’s draft Transport Strategy (October 2009) will all
be material considerations.
35 Conditions on the transport network have also changed since the assessments were
undertaken in 2004, which will need to be taken into account in the updated assessment work
with up to date data sources and surveys. On this basis, an updated transport assessment report
will be required which should be produced in accordance with TfL’s Transport Assessment
Best Practice Guidance document (May 2006) so that the full impact of the development can be
assessed.
36 The report should include a full multi modal trip generation assessment including an
assessment of the trips to and from the hospital by all modes of transport with appropriate
improvements to services brought forward as mitigation measures. This will be to ensure that
opportunities to maximise public transport provision is supported.
37 A full assessment of the bus services will need to be undertaken so that TfL can
determine what service improvements may be necessary to secure convenient access to the
hospital by bus.
38 Access to the hospital by the mobility impaired will need to be adequately assessed
including improved wheelchair accessible mobility bus access throughout the week.
Appropriate pedestrian routes within the site will need to be identified and improvements
external to the site will also need to be highlighted including a pedestrian environment review
system for routes to local bus stops.
39 The levels of car parking will need to be reviewed in light of current policy and changes
in the transport conditions in the area and an appropriate level of disabled parking and electric
vehicle charging points will need to be agreed. Cycle parking should be in accordance with the
standards in the Consultation Draft London Plan.
40 Dedicated taxi ranks within the hospital will need to be incorporated into the proposals.
41 An up to date travel plan document will need to be submitted to include management
issues such as car parking management and all measures to ensure ease of access to the site by
sustainable modes.
42 On submission of the revised and updated reports, TfL will be able to consider the likely
impacts of the scheme and identify the full package of mitigation measures and adjustments to
the scheme in order for the proposals to be considered acceptable in transport terms.
Local planning authority’s position
43 Hillingdon Council officers consider the application acceptable in principle.
Legal considerations
page 6
44 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor
of London) Order 2008 the Mayor is required to provide the local planning authority with a
statement setting out whether he considers that the application complies with the London Plan,
and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must
consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft
decision on the application, in order that the Mayor may decide whether to allow the draft
decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the
application, or issue a direction under Article 7 of the Order that he is to act as the local
planning authority for the purpose of determining the application and any connected
application. There is no obligation at this present stage for the Mayor to indicate his intentions
regarding a possible direction, and no such decision should be inferred from the Mayor’s
statement and comments.
Financial considerations
45 There are no financial considerations at this stage.
Conclusion
46 London Plan policies on health, urban design, access, climate change and transport are
relevant to this application. The application complies with some of these policies but not with
others, for the following reasons:
Health: Principle of use on site for health is supported and accepted.
Urban design: There is insufficient information to determine whether the application
fully complies with London Plan Policies 4B.1–4B.3 and 4B.5. This matter should be
dealt in line with the design code agreed through the approval of reserved matters.
Access: There is insufficient detail to fully assess the accessibility of the scheme.
However, an appropriate condition requiring the full details of inclusive design should
be imposed.
Climate Change: The applicant is required to submit energy strategy and address
climate change policies that have come into effect since the previous application was
determined.
Transport: The applicant is required to address concerns as detailed in TfL’s
comments section.
47 Whilst the application is broadly acceptable in strategic planning terms, on balance, the
application does not comply with the London Plan.
48 The following changes might, however, remedy the above-mentioned deficiencies, and
could possibly lead to the application becoming compliant with the London Plan:
Urban design: Agree to a condition requiring submission of a design code.
Access: Agree to a condition requiring submission of details of inclusive design.
Climate Change: Submit energy strategy and address climate change policies as
detailed in the climate change mitigation and adaptation section.
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Transport: Address the concerns as detailed in the transport section.
for further information, contact Planning Decisions Unit:
Colin Wilson, Senior Manager - Planning Decisions
020 7983 4783 email colin.wilson@london.gov.uk
Justin Carr, Strategic Planning Manager (Development Decisions)
020 7983 4895 email justin.carr@london.gov.uk
Tefera Tibebe, Case Officer
020 7983 4312 email tefera.tibebe@london.gov.uk
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