planning report PDU/0871a/01
7 July 2004
The Paragon (former Pilot Works) Site,
in the London Borough of Hounslow
planning application no. 01217/C/P27
Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Town & Country Planning (Mayor of London) Order
2000 – strategic planning application stage 1
Revised planning application for the demolition of Nos. 49-55 Boston
Manor Road and the erection of a mixed-use development comprising
12,049 sq.m. of educational (Use Class D1) floorspace, 849 study-rooms
with ancillary student accommodation, 221 key-worker flats and 304 sq.m.
of convenience retail/food and drink floorspace; together with associated
car parking space, pedestrian and vehicular access and related site works.
1 On 19 May 2004, Hounslow Council consulted the Mayor of London on a planning
application to redevelop the above site for the above uses. The proposal is a revised version
of a planning application originally considered by the Mayor on 14 April 2004. Under the
provisions of the Town & Country Planning (Mayor of London) Order 2000 the Mayor has
the same opportunity as other statutory consultees to comment on the revised proposal.
This report sets out information for the Mayor’s use in deciding what comments to make.
2 The application is referable under Category 1B (1c) of the Schedule of the Order
2000: “Development (other than development which only comprise the provision of houses, flats or
houses and flats) which comprises or includes the erection of buildings- outside Central London and
with a total floorspace of more than 15,000 square metres.”…and Category 1C (1c): “Development
which comprises or includes the erection of a building in respect of which… the following condition is
met- the building is more than 30 metres high and outside the City of London.”
3 If Hounslow Council subsequently decides that it is minded to grant planning
permission, it must first allow the Mayor an opportunity to decide whether to direct the
Council to refuse permission.
4 The 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 comments on this case will be made available on the GLA
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6 The 1.65-hectare site is within the gateway area of the West London sub-region. It
lies just north of the A4 Great West Road and to the immediate east of Boston Manor Road,
from which its main vehicular access is derived. The elevated section of the M4 motorway
traverses its southern and eastern boundaries at an estimated height of 12 metres. Boston
Manor underground railway station (Piccadilly Line) is situated approximately 1km north-
west of the site whilst the Brentford surface railway station lies within 800m to the
southeast, albeit across the intervening dual-carriage A4 Great West Road.
7 The site comprises a pair of two-storey houses constructed in red brick and currently
occupied as offices by Paragon Marketing; the remaining portion is occupied by a haulage
firm and consists of open storage, car parking and servicing areas.
8 Adjoining the main western entrance to the site is a Grade 2 Listed Building (No 67
Boston Manor Road) and the north-western boundary of the site is shared with Our Lady
and St John’s Roman Catholic Primary School. Access to the latter is from a service road
leading westwards from Boston Park Road to the east.
9 The surrounding area is typified by prestige head-office buildings (including Glaxo
SmithKline and Samsung) and some lower-quality commercial premises that form part of the
Great West Road strategic employment corridor. An area of predominantly residential
development is situated to the north and east, whilst the extensive Boston Manor Park is
situated slightly north and to the immediate west of Boston Manor Road.
Details of the proposal
10 The revised proposals were designed by Carey Jones Architects and submitted to
Hounslow Council by GMA Planning on behalf of Berkeley First Ltd (formerly Berkeley
College Homes Ltd), which is a subsidiary of the Berkeley Group Plc. They seek to provide
academic, student and associated key-worker accommodation for Thames Valley University
(TVU), whose main campuses are at St. Mary’s Road and Ealing Town Centre, some 15 to
20 minutes walk from the planning application site. The university is the largest single
provider of education and training for National Health Service (NHS) nursing staff in the
11 The most apparent change from the original scheme is a reduction in the scale and
massing of the principal buildings. Details of the revision are as follows:
12 The amount of student accommodation would be reduced from 998 to 849 study
rooms to be provided in four blocks around a courtyard. The formation would comprise two
12-storey blocks separated by a 10m-wide gap adjacent to the north-western boundary site, a
linked 17-storey block and a freestanding 5-storey block sited nearest to the elevated M4
13 A total of 221 key-worker flats would be provided for NHS staff in need of local
housing. This represents a reduction from the 232 key-worker units previously proposed.
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14 The provision would comprise 42 studio flats in a four-storey block (Block A) sited in
the south-eastern portion of the campus to replace a proposed six-storey building. The
remaining 179 units would be provided in a 4 to 8-storey block (Block B) with lower ground
floor, to be situated on the opposite (i.e. northern) side of the existing school access road via
Boston Park Road. The block will consist of 44 one-bedroom flats, 63 two-bedroom flats and
72 studio flats.
15 The revised layout retains the proposed academic building on the western portion of
the site, close to the main entrance. Although the original footprint would be reduced and its
overall mass broken up, the total floor area would be increased from 9,707 sq. m. to 11,441
sq. m. This would be achieved by replacing the original 7-storey design with a part 3/5-
storey and part 13-storey landmark building adjacent to the motorway flyover.
16 The development would include 304 sq. m. of convenience retail/food and drink
accommodation on the ground floor of a three-storey block fronting onto and directly
accessible from Boston Manor Road. The two upper floors would be allocated for ancillary
office or academic purposes. This revision replaces the 676 sq. m. of retail space originally
proposed over two floors.
Other communal facilities
17 The revised development would include 608 sq. m. of ancillary office space for
residential management and administration purposes. This represents a substantial increase
from the 151 sq. m indicated in the previous proposal. Additionally, the scheme would
provide on-site launderette, student common rooms, sports and leisure facilities.
Access and parking provision
18 The main vehicular and pedestrian entrances to the site would remain from Boston
Manor Road but a secondary pedestrian access would be available from the primary school
access road via Boston Park Road.
19 The revisions include an increase in the car parking provision from a previous total of
51 to a current proposal for 111 spaces. Of these, 66 (including 3 for disabled users) would be
allocated for staff and located adjacent to the academic block. The remaining 45 (including 6
for disabled users) would be allocated to key workers and sited at lower ground and
basement levels, beneath the courtyard of the student accommodation. The increased
number of parking spaces remains consistent with London Plan parking standards and is
largely in response to local residents’ concern about the possibility of overspill parking on
the adjoining streets. Cycle parking provision would also be raised from 115 to 230 spaces
and an area of 66 sq. m. would be provided for motorcycle users.
20 A Travel Plan associated with the development proposes amongst other things a no-
car policy be effected through the students’ tenancy agreements and a car share scheme for
key workers and neighbouring residents. In addition, Thames Valley University proposes to
run its own shuttle bus service between the site and its other campuses in Ealing and St
Mary’s Road, operating at half hourly intervals from 8.00 am to 8.00 pm and at hourly
intervals between 8.00 pm and midnight.
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21 There are two extant planning permissions on the site, either of which could be
implemented as an alternative to the current proposals.
22 Originally, the site had a variety of uses, including a brewery, industrial workshops
(including garages, printing and electronics manufacture) and a school.
23 In 1992, Hounslow Council granted planning permission for a ten-storey office
building (17,186 sq. m.) with multi-storey car park, industrial units, a school and caretaker’s
accommodation. The permission was subject to a legal agreement that secured the school, a
financial contribution to local employment opportunities and junction improvements to
Boston Manor Road, amongst other things.
24 The school was subsequently built and a substantial financial contribution paid to the
Council. However, the consented office development did not progress much further than the
ground preparation works. In 1997, a Certificate of Lawful Development was issued
confirming that the office development had effectively commenced and that the permission of
1992 can therefore be completed in perpetuity.
25 In May 2001, planning permission was granted for a redevelopment of the site to
provide 25,011 sq. m. of office and telecommunications-related accommodation (Use Class
B1), together with external plant, 200 car-parking spaces, associated access roads and
landscaping. The permission is still valid and can be implemented as an alternative to the
present development proposals.
Strategic planning issues and relevant policies and guidance
26 The relevant issues and corresponding policies are as follows:
Employment The London Plan; PPG4
Economic development &
Regeneration The London Plan; London’s Economic Development Strategy (LDA)
World city role The London Plan
Affordable housing The London Plan; PPG3
Density The London Plan; PPG3
Retail The London Plan; PPG6; PPG13; RPG3
Mix of uses The London Plan
Urban design The London Plan: PPG1
Tall buildings/views The London Plan; RPG3A; Strategic Planning Advice on Tall
Buildings and Strategic Views in London (LPAC)
Sustainable development The London Plan: PPG3; PPG13
Transport/parking The London Plan; the Mayor’s Transport Strategy; PPG13
Access/equality issues The London Plan
Ambient noise The London Plan; the Ambient Noise Strategy; PPG24
Air quality The London Plan; the Air Quality Strategy; PPG23
The Development Plan
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26 For the purposes of Section 54A of the Town and Country Planning Act 1990 (as
amended), the development plan is the Hounslow Unitary Development Plan, adopted in
28 Part of the site is designated as being within the Great West Road Employment Area
and as a Strategic Employment Location of West London Importance. There is a policy
presumption against the loss of employment uses in such locations as a matter of principle
(Employment Policy E1.5). For land outside the UDP employment designation, the policy
provides that housing would be considered as an acceptable alternative in cases where a
reuse of land for employment is unlikely (based on the evidence of vacancy and the supply of
alternative employment land) or the location and scale of the existing employment is
detrimental to the surrounding area. In all such circumstances, the Council would expect the
maximum reasonable proportion of affordable housing.
29 For sites that have previously been in employment use, the UDP (Housing Policy
H.2.1) requires an affordable housing provision in excess of 50%, and 100% in some
instances. The UDP (policy H.3.5) provides a set of criteria that would be applied in cases
where the release of an employment site for housing is considered acceptable. They include
accessibility to public transport, other employment opportunities and local services; its
potential contribution to affordable and key worker housing needs; and the appropriateness
of the area in terms of residential amenity.
Loss of strategic employment land
30 Whilst the university proposals for the site represent a departure from the UDP and
strategic designation of the site as part of the Great West Road Employment Area and an
employment location of sub-regional importance to West London, its continued protection
for this purpose has been compromised by a the failure to implement planning permission for
over 17,000 sq. m. of office space in 1992 and a 25,000 sq. m. office development in 2001; or
to market the site for an alternative use.
31 The applicant has listed in chronological order the futile efforts made to market the
site for use as a ‘trade park‘ (1999), as offices (2000/2001) and for hotel, conference centre
and mixed-use purposes (2002). For most of that period a site marketing board, erected in
1994 by the previous owners, was visible from the elevated M4 until June 2002, when
Hounslow Council served an enforcement notice requiring its removal. A full colour
brochure together and dedicated website were produced in March 2001 and an
advertisement was placed in the ‘Estates Gazette’ on 21July 2001. Following these failures,
the site has been grossly under-utilised for almost twelve years.
32 To strengthen the case for this development, the applicant points out that the
proposed increase in academic and ancillary office floorspace from 9,858 sq. m. to 12,049 sq.
m. would generate a corresponding increase in employment potential from 250 to 280 staff.
The latter includes a variety of teaching and lecturing posts, technical assistants to the
academic staff, research and development staff, library and learning resource employees,
administrative and other support (e.g. catering, cleaning and service) staff.
33 The estimated employment density (one job per 40 sq. m.) is below the level that
could be expected from a conventional office development and the revised educational and
ancillary office floorspace is substantially below the office development granted permission
in 2001. Nonetheless, the applicant considers that the latest proposals would generate
significantly more employment opportunities than the previously consented scheme, which
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would have been dominated by the storage of telecommunications equipment and plant
rather than employment.
Student/key worker housing
34 Both the London Plan and the Hounslow UDP support housing, especially affordable
housing, as an acceptable alternative to employment uses, on sites where a long-term
vacancy suggests that the reuse of land for employment-generating purposes is unlikely. The
London Plan also identifies education as a strategic need that could be met by the reuse of
redundant employment sites.
35 Although purpose-built student housing is excluded from the London Plan definition
of affordable housing, the plan acknowledges that its provision adds to the overall supply of
housing in London and could significantly ease the pressure on the existing supply of
market, low-cost rented and affordable housing sectors. In practice, therefore, it is
unnecessary to impose an affordable housing obligation on a development comprising
student and key worker housing only. The latter would provide affordable accommodation
for qualifying key workers, such as lecturers, or nursing staff that may have trained in the
teaching quarters of the development, are subsequently employed within the locality and are
facing difficulty obtaining alternative housing accommodation.
36 In terms of residential density, the latest revisions represent a reduction from 951
habitable rooms per hectare (hrpha) to 797 hrpha. This figure is still above the London Plan
guide of 450-700 hrpha for an urban site within 10 minutes walking distance of a town
centre and a public transport accessibility level (PTAL) of 3-4. In this respect, the
development is consistent with the London Plan objective to make the most efficient use of
urban brownfield land in locations well served by public transportation.
37 The applicant has indicated that a registered social landlord would manage the
residential elements of the scheme. This would include the day to day functioning of the
student accommodation and the tenure of the key worker housing, following the nomination
of occupiers by Thames Valley University and its potential partners (e.g. NHS, Ambulance
and Fire Service).
The mix of uses
38 With its mix of academic space, student halls of residence, key worker housing and
retail space, the use of the site for higher educational purposes offers a wider variety of uses
than the office developments for which there are extant planning permissions.
39 Though the loss of some strategic employment land is regrettable, the proposed mix
of uses would produce some distinct planning advantages. Most significantly, it would
secure a high-density development on a site with reasonably good public transport
accessibility, thereby reversing the long-term uncertainty surrounding the site. It would
contribute to the improvement of skills and employment opportunities for local people,
employers within the strategic A4/M4 employment corridor and Londoners in general,
thereby enhancing London’s ‘world city’ role as a centre of learning. In terms of
sustainability, the proximity of substantial residential accommodation and an on-site retail
facility to the new academic building would reduce the demand for travel to a level below
that which could be expected from the permitted office developments.
Urban design and architectural quality
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40 In terms of urban design the key changes are a significant reduction in the scale and
massing of the buildings, an enhanced provision of amenity space, increased permeability
through the site and an improved relationship between the proposed buildings and those
surrounding the site.
41 The academic block has been redesigned to form an additional landmark at this
strategic gateway into London and the focal point of the proposed development. To reduce
the scale and massing of the original proposals, the elevations of its ‘stepped’ high-rise blocks
ranging from 12 to 18 storeys (the highest exceeding 50m) would be broken up and replaced
by distinctly separate blocks of 12 to 17 storeys high.
42 A distinguishing new feature is the creation of two vertical spaces on the northwest-
facing elevation adjacent to the school and on the southeast-facing elevation facing the
elevated motorway. One of these is a 10m-wide separation between two 12-storey blocks of
student accommodation, whilst the other separates the academic block from the student
accommodation. Together, they allow visual penetration through the buildings and retain
some daylight penetration to the adjacent school playground.
43 Additionally, the revised layout improves pedestrian access across the site,
particularly between the key worker blocks, the student accommodation and the academic
block. A linear route would be available from the Boston Manor Road entrance through the
atrium of the academic block, to the central area surrounded by student accommodation and
across the site to Windmill Road in the east, thereby facilitating easy access to the bus-stops,
underground and surface railway stations within the locality.
44 At the core of the development, will be an enlarged communal amenity area formed
within the courtyard of the student accommodation and on the roof deck of the proposed
common room. This should provide a pleasant and lively setting to the halls residence.
45 In terms of improving the relationship between the new buildings and those
surrounding the site, the student accommodation blocks adjacent to the north-western
boundary and the key worker block nearest to the M4 motorway have been set further in
from the site boundaries. The former would be less imposing on the primary school whilst
the latter allows St John’s Church to dominate the street scene at the corner of Boston Park
Road and the primary school access road. For similar reasons, the siting of the academic
block has been revised to increase its distance from and enhance the setting of the listed
building fronting Boston Manor Road.
Sustainable design and construction
46 The revised submission is supported by a Sustainability Report, which includes a
statement of Berkeley First’s intentions on the use of sustainable materials, together with
energy and water conservation during the construction and operational phases of the
47 In particular, the developer proposes energy efficient building techniques based on a
lightweight construction system that leaves voids in the walls, which can then be filled with
large volumes of insulation material. This in turn allows wall thickness to be kept slim and
the cavity clear to avoid damp conditions. Low energy bulbs and light fittings would be
installed throughout the development and controlled within the rooms by the users. All
communal areas, except emergency light, would be placed on timers to be set by the building
management, whilst all external lamps would be controlled by sensors. In addition, the
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developer is investigating the use of photovoltaic panels to form part of the roofing
membrane. The panels are said to be capable of generating up to 1000 watts per 25 sq. m.,
which could offer levels of low voltage lighting for the corridors and stairwells of the
48 In terms of water management, it is envisaged that the size and nature of the
development would generate large volumes of surface water into an overloaded local waste
and surface drainage system. Consequently, the developer is investigating the introduction
of special ‘Formpave’ block paving used on other sites, which allows most surface water to be
filtered directly into the ground, thereby reducing the impact on the existing system. Low
dual-flush toilet cisterns would also be installed throughout the development. The use of
‘grey water’ for toilet flushing has been explored but found not to be feasible, partly because
the volume needed by campus residents would require the use of vast underground tanks
and pumping systems to cover prolonged dry periods, and partly because the risk of cross
contamination with the potable mains system would outweigh the benefits of water
conservation. It is however proposed to install smaller tanks to collect rainwater from the
down-pipes for use in landscape management (e.g. watering the grass and shrubs), vehicle
washing and general maintenance.
49 The Sustainability Report states that this would be the second site on which Berkeley
First will undergo a BREEAM/EcoHomes assessment. The latter is a thorough examination
of the design, construction and customer needs fulfilment administered by the Building
Research Establishment and include criteria such as the use of A-rated kitchen appliances,
timber from sustainable sources, low energy bulbs and light fittings, low dual toilet cisterns
and proximity to public transport. The developer expects to achieve a ‘Very Good’ rating
from this assessment.
50 The revised plans respond to the Mayor’s earlier concern over the expediency of
siting residential units in areas that are subject to the highest category of noise exposure. To
this effect, the heights of student residential block D and key worker block A, closest to the
motorway, have been reduced to five and four storeys respectively. The buildings would also
be sited to provide a minimum clear distance of 40 metres away from the elevated motorway.
This would ensure that neither of the blocks are sited within noise category NEC D zone of
PPG 24 (Noise), wherein the national guidance is that planning permission should normally
not be granted for residential accommodation.
51 All the remaining flats would be within noise categories NEC B and C, wherein the
guidance allows residential development, subject to the imposition planning conditions to
secure an adequate level of noise mitigation within the development. To address this issue,
the applicant has submitted a noise mitigation report with the revised application. The
report includes proposals to provide an adequate level of noise protection to occupiers of the
new residential units.
52 The report on the original scheme identified a number of shortcomings in the air
quality assessment provided in the Environmental Statement. These have not been
substantively addressed as part of the revised submission. The supporting planning
statement refers to some recent appeal decisions that suggest development should not be
prevented in areas of poor air quality. The statement makes sweeping references to on-going
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improvements in local air quality due to Council initiatives and modern technology,
concluding that the development will not be adversely affected by poor air quality.
53 The issues raised in the previous report would need to be addressed a lot more
thoroughly, in order to fulfil the objectives of the London Plan and the Mayor’s Air Quality
54 The current revisions provide that 28 of the student rooms will be accessible to
wheelchair users. Disabled car parking spaces are located close to the level access of main
entrances to the buildings and lifts are provided for disabled users.
Comments of Transport for London
55 The applicant has submitted a Supplementary Transport Assessment (TA) to
accompany the revised proposals, which considers in more detail the impact of the
development on bus capacity and the local road network. TfL has reviewed the
Supplementary TA in light of the comments it made on 14 April 2004, regarding the impact
of the proposals on bus network capacity and the justification for S106 contributions and, in
the light of the increased car parking provision, the impact of vehicle trip generation on the
operation of the Boston Manor Road/Great West Road junction.
56 TfL is satisfied that the proposals will not result in an adverse impact on the
Transport for London Road Network despite the increase in car parking and that the
developer’s contribution of £300,000 towards bus service enhancements will adequately
mitigate any impact on the local bus network.
57 TfL also welcomes the increase in cycle parking spaces to 230. However, it requires
provision to be made for the student accommodation and the key worker flats in accordance
with the London Cycle Network Design Manual recommendations of 1 space per 2 students
and 1 space per flat respectively. Cycle parking and locker/shower facilities should also be
made available for staff/students visiting the education block.
58 TfL understands the heads of terms of a S106 agreement being negotiated with
Hounslow Council includes contributions to public transport, consultation and extension of a
controlled parking zone, pedestrian/cycle, environmental and air quality improvements. TfL
expects to work closely with Hounslow Council in developing the relevant transport
elements of the S106 agreement.
Comments of the London Development Agency
59 The LDA supports the provision of key worker and student accommodation in
principle and the proposal is particularly welcome as it combines this housing with new
academic facilities. However the site is within a SEL, where the Agency would normally be
seeking the retention the site in an employment use.
60 If Hounslow Council resolves to grant planning permission for the revised proposals,
it should satisfy itself that the loss of this site does not leave a shortfall of employment land
in relation to demand (which in West London is very high); that the cumulative effects of
alternative development on employment sites in this area would be acceptable; and that this
site in particular is less suited to employment uses than others. The Agency would wish to
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consider this evidence in the event that Hounslow Council is minded to grant planning
permission and the case is referred back to the Mayor.
Local planning authority’s position
61 Local planning officers propose to report the revised application to Hounslow
Council’s Sustainable Development Committee on 27 July 2004. Whilst the officers’ response
to the revisions have generally been positive, it is not certain at this stage what their
recommendation will be.
62 Under the arrangements set out in article 3 of the Town and Country Planning
(Mayor of London) Order 2000 the Mayor has an opportunity to make representations to
Hounslow Council at this stage. If the Council subsequently resolves to grant planning
permission, it must allow the Mayor an opportunity to decide whether to direct it to refuse
planning permission. There is no obligation at this present stage for the Mayor to indicate
his intentions regarding a possible direction, and no such decision should be inferred from
the Mayor’s comments unless specifically stated.
63 There are no financial considerations at this stage.
64 Whilst the original application sought to maximise the density of development on an
under-used urban brownfield site, this was done at the expense of the amenity of potential
occupiers and neighbouring residents, including the siting of residential accommodation in
locations subject to unacceptably high levels of noise.
65 The revised proposals optimise the scale of development whilst remaining at the
higher end of the London Plan density matrix. Despite the reduction in scale, the scheme
retains its potential to deliver some of London’s strategic planning priorities, most notably
the provision of high-density student accommodation and key-worker housing in a locality
with good public transport links and a significant contribution to London’s role as a ‘world
class’ centre of learning.
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for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email firstname.lastname@example.org
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email email@example.com
David Blankson-Hemans, Senior Strategic Planner (case officer)
020 7983 4268 email firstname.lastname@example.org
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