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London Borough of Hounslow Sustainability Appraisal of the

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									London Borough of Hounslow


Sustainability Appraisal of the
Employment Development Plan Document
Submission version




                                 July 2007
Table of Contents
        Table of Contents.............................................................................................2
        1.0   Summary and outcomes .......................................................................3
        1.1       Non-technical Summary ................................................................................. 3
        1.2       Statement on the likely significant effects of the development plan ............... 5
        1.3       Statement on the difference the process has made to date........................... 6
        1.4       How to comment on the report ....................................................................... 7
        2.0      Appraisal Methodology..........................................................................8
        2.1      Approach adopted to the Sustainability Appraisal.......................................... 8
        2.2      When the SA was carried out......................................................................... 9
        2.3      Who carried out the Sustainability Appraisal Scoping Report? ...................... 9
        2.4      Who was consulted on the scoping report, when and how? ........................ 10
        2.5      Difficulties encountered in compiling information or carrying out the
                 Assessment................................................................................................... 10
        3.0      Background to the Assessment...........................................................12
        3.1       Purpose Of The SA And The SA Report ...................................................... 12
        3.2       Plan Objectives and Outline of Contents...................................................... 12
        3.3       Compliance with the SEA Directive And Regulations .................................. 13
        4.0      Sustainability objectives, baseline and context ...................................16
        4.1       Links to other strategies, plans and programmes and sustainability
                 objectives ...................................................................................................... 16
        4.2       Description of the social, environmental and economic baseline
                 characteristics and the predicated future baseline ........................................ 24
        4.3       Main social, environmental and economic issues and problems identified .. 53
        4.4       Limitations of the Information and assumptions made ................................. 70
        4.5       The SA framework, including objectives, indicators and targets (Source: SA
                 Scoping Report September 2005)................................................................. 72
        5.0      Plan issues and options ......................................................................82
        5.1       Main strategic options considered and how they were identified ................. 82
        5.2       Comparison of the social, environmental and economic effects ofthe
                 options........................................................................................................... 84
        5.3       How social, economic and environmental effects were considered in
                 choosing the preferred options...................................................................... 85
        5.4       Options considered in choosing the plan objectives and preferred options ..
                 ...................................................................................................................... 97
        6 Plan Policies .........................................................................................131
        6.1 Significant social, environmental and economic effects of the preferred
            options ..............................................................................................131
        6.2.     How social, environmental and economic problems were considered in
                 developing the policies and proposals and proposed mitigation measures ...
                 .................................................................................................................... 137
        6.3       Uncertainties and risks ............................................................................... 144
        7.0      Implementation..................................................................................146
        7.1       Links to other tiers of plans and programmes and the project level (EIA,
                 design guidance etc) ................................................................................... 146
        7.2.     Proposals for monitoring ............................................................................. 148
        8.0      Appendices .......................................................................................152




                                                                                                                                       2
1.0     Summary and outcomes
1.1     Non-technical Summary

1.1.1   Within this Sustainability Appraisal (SA) Report, the preferred options, consulted on in
        January 2006 and draft policies in the Employment Development Plan Document (DPD) have
        been assessed for their effects on the environment, community and economy.

1.1.2   This report incorporates the SA scoping report (September 2005) (section 4.0) undertaken to
        establish a framework of objectives and indicators (section 4.5) for assessing the impacts of
        the development plan. This includes a baseline of data (section 4.2), which provides a picture
        of the “current situation” and can enable an assessment of change to be made as a result of
        the Employment DPD.

1.1.3   The options consulted on in June 2005 were appraised for their impacts on sustainability
        objectives and this assessment is included as Appendix 5 to this report (also refer to section
        5.2). Sections 5.3 (Refer to table which shows the progression from Issues through to DPD on
        pages 84 – 94) and 5.5 set out how the options informed the preferred options and how the
        initial sustainability appraisal of options influenced the decision-making process.

1.1.4   At the next stage of preferred options in January 2006, a sustainability appraisal report was
        prepared. This included an assessment of the development plan’s objectives (refer to section
        5.4) and preferred options (refer to section 6.1) for their impacts on sustainability objectives.
        In the appraisal of preferred options, alternatives were also considered and appraised for their
        impacts on sustainability objectives. This included an option of continuing to use the Unitary
        Development Plan (status quo) and a do nothing option of relying solely on national and
        regional guidance. This assessment is incorporated into this report (refer to section 6.1 and
        Appendix 6).

1.1.5   In preparation of this Sustainability appraisal of the objectives and policies in the development
        plan, an assessment has been made of the change in approach between preferred options
        and the development plan submitted. Appendix 4 as well as section 5.3 (pages 84 – 94) sets
        out the progression from preferred options to policies in the submission version of the
        development plan and it is the conclusion that the policies are only a refinement of preferred
        option(s) including more detailed policy wording. This report therefore does not contain an
        appraisal of the objectives and policies in the submission development plan.

1.1.6   In reading the appraisal of the preferred options in Appendix 6, notes are included to explain
        which objectives and policies in the DPD, one or more preferred options has informed.
        The significant effects from this appraisal are summarised together with the identification of
        cumulative and synergistic effects in section 6.1. Section 6.2 then sets out how the significant
        effects have been considered in preparation of the submission version of the development
        plan and what measures if any are required to mitigate the significant effects of the plan.

1.1.7   Section 7.2 presents a framework for monitoring the effects of the development plan on
        sustainability objectives. The indicators and targets have been developed specifically for
        monitoring the impacts of the development plan.

        Summary of findings from the SA Report

1.1.8   The key issues arising in preparation of the development plan include:

        •   The current designation of key employment locations (offices in out of centre locations)
            and the objective for these sites
        •   The need to identify strategic and locally significant industrial sites to provide sufficient
            capacity to accommodate demand
        •   The need for development to be appropriately located and for high trip generating uses to
            be directed to the most accessible locations


                                                                                                        3
         •   The appropriate management of existing supply including vacant sites/buildings and
             directing demand to the right locations
         •   The scope to provide for small and medium sized businesses
         •   The location of hotels including those serving the airport
         •   Recognition that there are sites where employment is not likely or are not in an
             appropriate location

1.1.9    The Sustainability appraisal has enabled the Council to identify effects on sustainability
         objectives arising from the options and preferred options that are summarised as follows:

         •   economic benefits of protecting the existing supply of industrial land to accommodate
             demand
         •   negative environmental impacts on noise and air quality of industrial and commercial
             development
         •   negative consequences of development and transport on climate change
         •   any additional effects on the environment of protecting existing strategic offices in
             unsustainable locations
         •   positive contribution that strategic office locations make to the local and regional economy
         •   negative effects on the environment of allowing further development at strategic office
             locations and recognition that public transport accessibility improvements are unlikely
         •   potentially unsustainable use of resources as a result of new development
         •   negative impacts on the environment of car based travel due in part to low levels of public
             transport accessibility

1.1.10   The significant effects arising (refer to section 6.1 of the report) from the preferred options
         have been addressed in preparation of the submission version of the development plan and
         measures to mitigate impacts considered where appropriate. The following summarises how
         the positive and negative effects of the development plan have been addressed:

         •   directing offices to sustainable locations where reliance on the car is reduced, the use of
             sustainable modes of transport is encouraged and therefore impacts of car use are
             minimised
         •   safeguarding offices in strategic locations (including Bedfont Lakes and on the Great
             West Road) to ensure the benefits of local employment are retained whilst not allowing
             further development in unsustainable locations. Through not allowing more office
             development in out of centre locations, further negative environmental effects of offices in
             these locations is avoided
         •   designating strategic and locally significant industrial sites for protection thus ensuring
             any new development is of a similar nature to existing uses. Any impacts are therefore
             likely to be neutral i.e. there is not expected to be any significant effects arising as the
             designation to protect uses does not result in change to the use of land.
         •   protecting locations where their appears to be no impact on neighbouring uses
         •   allowing the release of industrial land where there are negative impacts on the amenity of
             the surrounding area
         •   ensuring the impacts of new development are considered in the development control
             process and any effects avoided or mitigated through the implementation of policies in the
             UDP and emerging development plan documents (incl. the Core Strategy).
         •   developing guidance on planning obligations and air quality to ensure an effective
             process for the implementation of measures to address the effects of new development
         •   the implementation of other plans and strategies including the Local Implementation Plan
             which support wider economic, social and environmental targets

1.1.11   The SA process of identifying the social, economic, and environmental effects of the different
         options and preferred options and comparing the effects of preferred options with the effects
         of alternatives has enabled a better understanding of issues and greater consideration to
         sustainability in preparation of the development plan.



                                                                                                           4
1.2     Statement on the likely significant effects of the development plan

1.2.1   This section sets out what the Employment Development Plan Document will achieve and its
        effect in economic, environmental and social terms. Also refer to Section 6.1 of this report that
        sets out the significant effects from the appraisal of preferred options that has informed the
        submission version of the DPD.

1.2.2   Through the objectives in the plan (and policies to implement the objectives) of ensuring
        development is appropriately located; seeking to minimise the impacts of development;
        promoting diversity; and improving employment opportunities for residents, the plan
        incorporates wider sustainability objectives.

1.2.3   To maintain and enhance Hounslow’s employment role and promote a range of jobs (SA
        objectives 21 and 22) requires a sufficient land supply to accommodate employment. This can
        be achieved through the protection of sites that are strategically and locally significant for a
        range of uses including offices and industrial sectors. Furthermore, the protection of industrial
        sites, suitable for accommodating uses not requiring a high quality environment, maintains a
        supply of land to accommodate demand from such uses, therefore avoiding their location in
        areas where there are negative impacts on the surrounding environment and communities
        (SA Objectives 5, 9, 15, 16 being of most relevance).

1.2.4   The plan continues to protect strategically important offices in less sustainable locations
        (Great West Road, Bedfont Lakes) for the economic benefits arising (SA objectives 21 and
        22). However, the submission version of the Employment Development Plan Document takes
        a different approach from the current Unitary Development Plan in not allowing further office
        development in unsustainable locations. This avoids negative environmental impacts that
        arise from reliance on travel by car to work including noise, emissions to air and contributions
        to climate change (SA objectives 5, 15 and 16). Through directing high trip generating uses to
        sustainable locations, accessibility to employment is enhanced, particularly for those without
        access to a car, therefore supporting SA objectives 6 and 23.

1.2.5   In seeking to achieve an appropriate balance in supply and demand, there may be capacity
        for the release of sites to other uses. Through ensuring any release is managed, sufficient
        capacity can be maintained to support economic growth and jobs (SA objectives 20 and 21).
        Where is not demand, a change of use from a industrial/ commercial use is acceptable and
        can regenerate a site consistent with SA objective 13. Where there are adverse effects of an
        industrial use on the surrounding area, a change of use is also acceptable, therefore
        minimising impacts on SA objectives 5, 9, 15, 16.




                                                                                                       5
1.3     Statement on the difference the process has made to date
1.3.1   The Sustainability appraisal of the Employment Development Plan Document has resulted in
        more weight being given to issues not previously incorporated into the plan making process.
        The key changes are as follow:

        •   Identification of effects not previously considered in the plan making process, particularly
            environmental and social impacts e.g. climate change, which have not been given as
            much weight in the past.

        •   Through greater recognition of effects arising from the preferred options, awareness of
            impacts on implementation is enhanced. As a result, there is greater accountability for
            plan-makers to ensure the submission version of the development plan document
            sustainable, and that this is demonstrated on paper.

        •   In identification of Key Office Locations at Bedfont Lakes and on the Great West Road,
            the SA process has enabled consideration of the effects on sustainability objectives.
            Through realising the potential negative effects of offices in these locations and the
            significance of the effects, it has been recognised that these sites will not be made more
            accessible in the plan period, which has resulted in the approach to further development
            being tightened relative to existing UDP policy.

            The option of protecting offices at Bedfont Lakes and on the Great West Road has been
            carried forward into the submission version of the development plan document through
            careful consideration of the effects and what benefits the companies in these locations
            provide relative to the environmental costs.

        •   Greater recognition of the need to strike an appropriate balance between demand and the
            supply of land. Sites have been identified for protection to ensure there is a reservoir of
            industrial capacity to meet demand with the majority of release occurring on other sites
            subject to criteria.

        •   Consideration of factors wider than demand and supply in developing criteria for the
            protection of sites.




                                                                                                         6
1.4     How to comment on the report
1.4.1   Comments are invited on the Sustainability Appraisal (SA) as part of consultation on the
        Employment Development Plan Document (DPD), which has been informed by the SA. The
        consultation period is from 20th July until the 30th August 2007

1.4.2   Responses on the Sustainability Appraisal must be made in writing either by email
        ldf@hounslow.gov.uk, fax 020 8583 5233 or post to Strategic Planning Policy, London
        Borough of Hounslow, Civic Centre, Lampton Road, Hounslow, TW3 4DN by Thursday 30th
        August 2007. Responses must be received between the 20th of July and 30th August 2007.

1.4.3   The SA is available to download or complete online at
        www.hounslow.gov.uk/employmentplanconsultation or a paper copy can be requested from
        Strategic Planning Policy on 020 8583 5202 or ldf@hounslow.gov.uk.

1.4.4   Paper copies of the SA are also available at Borough Planning Reception, London Borough of
        Hounslow, Civic Centre, Lampton Road, Hounslow, TW3 4DN between the hours of 9am -
        5pm Monday to Thursday and 9am - 4.45pm on Fridays, and at the Borough’s libraries.

1.4.6   If you require additional information, have any questions, or require additional copies of the
        SA, please contact Strategic Planning Policy on 020 8583 5202 or ldf@hounslow.gov.uk.

1.4.7   Responses to the Employment Development Plan Document will be made public and a
        summary of the consultation findings will be made available on the Council’s website.

1.4.8   Please specify your contact details if you would like to be notified of the publication of the
        recommendations of the Inspector appointed to carry out an examination or the adoption of
        the Employment DPD or both.




                                                                                                         7
2.0     Appraisal Methodology
2.1     Approach adopted to the Sustainability Appraisal
2.1.1   The approach follows government guidance contained in‘ Sustainability Appraisal of Regional
        Spatial Strategies and Local Development Frameworks’ (November 2005). The process is
        summarised below.

        DPD Stage 1: Pre production - Evidence Gathering
        SA stages and tasks
        Stage A: Setting the context and objectives, establishing the baseline and deciding on
        the scope
        A1: Identifying other relevant policies, plans and programmes, and sustainability objectives.
        A2: Collecting baseline information.
        A3: Identifying sustainability issues and problems.
        A4: Developing the SA framework.
        A5: Consulting on the scope of the SA.
        DPD Stage 2: Production
        SA stages and tasks
        Stage B: Developing and refining options and assessing effects
        B1: Testing the DPD objectives against the SA framework.
        B2: Developing the DPD options.
        B3: Predicting the effects of the DPD.
        B4: Evaluating the effects of the DPD.
        B5: Considering ways of mitigating adverse effects and maximising beneficial effects.
        B6: Proposing measures to monitor the significant effects of implementing the DPDs.
        Stage C: Preparing the Sustainability Appraisal Report
        C1: Preparing the SA Report.
        Stage D: Consulting on the preferred options of the DPD and SA Report
        D1: Public participation on the preferred options of the DPD and the SA Report.
        D2(i): Appraising significant changes
        DPD Stage 3: Examination
        D2(ii): Appraising significant changes resulting from representations.
        SA stages and tasks
        D3: Making decisions and providing information.
        Stage E: Monitoring the significant effects of implementing the DPD
        E1: Finalising aims and methods for monitoring.
        E2: Responding to adverse effects.

2.1.2   Reference has also been made to the ODPM document ‘A Practical Guide to the Strategic
        Environmental Assessment Directive’ (September 2005).




                                                                                                    8
2.2     When the SA was carried out
2.2.1   The Sustainability Appraisal has been produced alongside the production of the Employment
        DPD. There have been three main stages of consultation that have informed the
        Employment Development Plan Document and this report.

2.2.2   The London Borough of Hounslow Sustainability Appraisal Scoping Report (September
        2005) was produced following the suggested format in the then draft government guidance.
        It equates to the Stage A tasks detailed above. Through an assessment of existing plans
        and proposals, collecting baseline data and identifying sustainability issues specific to
        Hounslow the document arrives at a set 23 objectives designed to promote the creation of
        sustainable communities. The objectives are grouped into the three categories of social,
        environmental and economic. These objectives are used in the later stages of the SA
        process to compare the potential impacts of different policy options. Following formal
        consultation (detailed below) the document was amended and finally adopted by Executive in
        September 2005 to be used in the production of the Council’s Development Plan Documents.

2.2.3   To accompany the initial consultation on the Employment Options the Council made available
        a background paper and a document entitled Sustainability Appraisal Assessment of
        Options (June 2005) (Appendix 5). Whilst not formally consulted on, the document was
        intended to help inform the community about the possible impacts of the options put before
        them. Each option was assessed against the 23 sustainability objectives and a narrative
        provided where the potential impacts of adopting such a policy stance were considered to be
        either uncertain or negative.

2.2.4   Following options consultation, responses on the options together with the sustainability
        appraisal and national, regional guidance informed the preferred options. At the preferred
        options consultation stage, the Sustainability Appraisal report of the Preferred Options
        (January 2006) was also consulted on. Each preferred option was assessed against the 23
        objectives from the SA Scoping Report (September 2005) for their significant effects from
        which mitigation measures were identified to address these. Indicators to monitor the effects
        of policies on sustainability outcomes were also proposed in the SA report.

        This document, the Sustainability Appraisal of the Employment Development Plan Document
        (submission version) incorporates the findings of the SA report of preferred options and
        presents changes to:
            o address issues raised in representations on the Sustainability Appraisal report of the
                Preferred Options(January 2006)
            o meet requirements in the guidance that had not previously been included in the
                Sustainability Appraisal
            o reflect changes between preferred options and the submission version of the DPD
            o ensure it is up to date and reads as the SA report of the submission version of the
                DPD rather than the preferred options

2.3     Who carried out the Sustainability Appraisal Scoping Report?
2.3.1   The first stage of the SA process was carried out in part through the employment of an officer
        with a qualification and experience in environmental science. This was for a temporary
        period of 6 months. During the production of the Scoping Report and especially the
        collecting of baseline data support was given by many officers within a variety of departments
        within the Council including the Environmental Strategy team who are responsible for SEA at
        a corporate level.

2.3.2   The initial options appraisal assessments were also carried out primarily by the temporary
        sustainability officer with support from other members of the Strategic Planning Policy Team.
        Officers within the Strategic Planning Team also completed the Sustainability appraisal of the
        preferred options (January 2006) and this document, the Sustainability appraisal of the
        Employment DPD (July 2007).


                                                                                                        9
2.4     Who was consulted on the scoping report, when and how?
2.4.1   As required by the strategic environmental assessment (SEA) Directive, the Scoping Report
        was referred to the four Consultation Bodies with environmental responsibilities. The
        guidance also states that it is also desirable for other bodies with social and economic
        responsibilities to be consulted, as the Council considers appropriate.

        List of Consultation Bodies for the Scoping Report
         The four SEA consultation bodies:
         Countryside Agency
         English Heritage
         English Nature
         Environment Agency

         Additional bodies:

         Adjoining Local Planning Authorities – London Boroughs of Ealing, Hammersmith and
         Fulham, Hillingdon and Richmond. Spelthorne Borough Council and Surrey County
         Council.
         Other West London Local Planning Authorities – London Boroughs of Brent and Harrow
         Government Office for London – GOL
         Greater London Authority – GLA
         West London Business
         Thames Water

         London Borough of Hounslow – internal circulation to relevant Departments, including
         Housing, Health, Economic Development, etc

2.4.2   The consultation period of 5 weeks ran from 31 May – 6 July 2005. Responses to the
        consultation were broadly supportive of the report but some minor amendments were
        suggested. An amended report was agreed by Executive in September. A summary
        schedule of representations received and the Councils responses is contained in Appendix
        1a.

2.5     Difficulties encountered in compiling information or carrying out the
        Assessment
2.5.1   The initial problem in carrying out the assessment (of options) was the fact that the
        government guidance relating to appraisal of LDF’s was still only in draft form. As a result
        additional guidance was provided removing the need for an initial sustainability report and
        further clarification provided via an interim advice note on frequently asked questions.

2.5.2   In terms of providing baseline data this was made more challenging through the absence of
        any corporate monitoring system. This therefore necessitates relying on the good will of a
        large number of officers throughout the council to provide relevant time series data with useful
        comparative data. This in itself results in difficulties associated with differing priorities and
        difficulties in responding to others deadlines.

2.5.3   Without a corporate monitoring system, information needs to be compiled from a variety of
        sources which is more time consuming

2.5.4   In preparation of the existing baseline, there was also a need to consider which data was
        used where there were different sources for the same indicator. An example is data on
        unemployment, and the different indicators used to measure unemployment.

2.5.5   The final difficulty relates to the scale of the task. With the benefit of hindsight it would have
        been sensible to have created fewer options at the first consultation stage of the process.

                                                                                                        10
The number of options provided together with a large number of sustainable objectives has
resulted in a significant amount of work that could perhaps have been reduced through
having a sharper focus at the outset.




                                                                                            11
3.0     Background to the Assessment
3.1     Purpose Of The SA And The SA Report
3.1.1   The purpose of the SA is to ensure that sustainable development objectives are integrated
        into the formulation of policy and that such considerations inform decisions taken on which
        options should be promoted in local development documents.

3.1.2   The SA report brings together previous work undertaken including the SA scoping report
        (September 2005), the assessment of options (June 2005) and sustainability of the preferred
        options (January 2006) in the preparation of the Employment DPD. This report demonstrates
        that the social environmental and economic objectives are reflected in the Employment
        Development Plan Document submitted by the Council.

3.1.3   This SA report accompanies the Submission Development Plan Document and is subject to a
        period of formal consultation.

3.2     Plan Objectives and Outline of Contents
3.2.1   Four new objectives are proposed to replace those in the Employment Chapter of the Unitary
        Development Plan, Adopted December 2003. These objectives are consistent with other
        objectives of the existing Unitary Development Plan, Adopted December 2003 (refer to
        Soundness Self Assessment Test 6) and reflect new national and regional guidance (refer to
        section 5.4.1).

3.2.2   The Council will work in partnership with stakeholders to achieve the following four objectives:

        1 To maintain and enhance Hounslow’s employment role in both a strategic and local context,
        promote diversity in business, a range of employment sectors and size of businesses

        2. To provide capacity to accommodate future employment growth, whilst aiming to achieve
        an appropriate balance in supply and demand for employment land.

        3. To ensure that development is appropriately located and negative impacts of existing and
        new development on the environment, economy and community are minimised.

        4. To improve equality of opportunity for residents in the Borough through employment and
        training; and ensuring developments are accessible to all.

3.2.3   The Employment DPD will replace the existing employment objectives, policies, designations
        and proposal sites in the Unitary Development Plan Adopted December 2003. The policies
        being replaced are:

        Objective IMP.4
        Policy IMP.4.1           Primary locations for economic development
        Policy IMP.4.2           The Great West Road
        Policy IMP.4.3           Bedfont Lakes
        Policy IMP.4.4           Chiswick Business Park

        Objective E.1
        Policy E.1.1             Location of new employment development
        Policy E.1.2             Locations for business (B1) use
        Policy E.1.3             Location of general industry (B2) and storage and distribution
                                 (B8) uses
        Policy E.1.4             Change of land use to class B on sites not in Employment Areas,
                                 Town Centre or Designated Areas
        Policy E.1.5             Development involving loss of or changes in employment uses

        Objective E.2

                                                                                                      12
        Policy E.2.1            Environmental criteria
        Policy E.2.2            Mixed Uses
        Policy E.2.3            Improvement of employment sites
        Policy E.2.4            Improvement of employment premises

        Objective E.3
        Policy E.3.1            Disabled access

        Objective E.4
        Policy E.4.1            Local residents
        Policy E.4.2            Childcare facilities

        Objective E.5
        Policy E.5.1            Visitor accommodation
        Policy E.5.2            Conference and exhibition facilities
        Policy E.5.3            Visitor attractions
        Policy E.5.4            Open-air tourism and short stay camping and caravan sites

3.2.4   The Employment DPD will include:

        i.      Objectives for planning the future use of employment land in the borough
        ii.     Policies for managing the protection and release of employment sites in the borough,
                including industrial sites and offices and directing new development to appropriate
                locations
        iii.    Designations for Strategic Employment Locations and Locally Significant Industrial
                Sites
        iv.     Designations for Key Existing Office Locations and Proposed Office Locations

3.2.5   The Sustainability Appraisal provides justification for the objectives and policies in the DPD,
        and assesses the effects of the preferred options against social, economic and environmental
        criteria.

3.3     Compliance with the SEA Directive And Regulations
3.3.1   The following table sets out the requirements of the SEA Directive in table form as provided in
        the Practical Guide to the Strategic Environmental Assessment Directive. The right hand
        column indicates the stage where these requirements are met within the Sustainability
        Appraisal report.

        Requirements                                                            Where covered in
                                                                                Guide
                                                                                (stage/appendix)

        Preparation of an environmental report in which the likely
        significant effects on the environment of implementing the plan or
        programme, and reasonable alternative staking into account the
        objectives and geographical scope of the plan or programme, are
        identified, described and evaluated. The information to be given is
        (Art. 5 and Annex I):
        a) An outline of the contents, main objectives of the plan or           Chapter 3
        programme, and relationship with other relevant plans and               Chapter 4
        programmes;
        b) The relevant aspects of the current state of the environment and     Chapter 4
        the likely evolution thereof without implementation of the plan or      Appendix 2
        programme;
        c) The environmental characteristics of areas likely to be              Chapter 4
        significantly affected;
        d) Any existing environmental problems which are relevant to the        Chapter 4
        plan or
                                                                                                    13
programme including, in particular, those relating to any areas of a
particular environmental importance, such as areas designated
pursuant to Directives 79/409/EEC (protection of wild birds) and
92/43/EEC(Habitats Directory);
e) The environmental protection objectives, established at                Chapter 4
international, Community or national level, which are relevant to the
plan or programme and the way those objectives and any
environmental considerations have been taken into account during
its preparation;
f) The likely significant effects on the environment, including on        Appendix 6
issues such as biodiversity, population, human health, fauna, flora,
soil, water, air, climatic factors, material assets, cultural heritage
including architectural and archaeological heritage, landscape and
the interrelationship between the above factors. (Footnote: These
effects should include secondary, cumulative, synergistic, short,
medium and long-term permanent and temporary, positive and
negative effects);
g) The measures envisaged to prevent, reduce and as fully as              Chapter 6
possible offset any significant adverse effects on the environment of
implementing the plan or programme;
h) An outline of the reasons for selecting the alternatives dealt with,   Chapters 5 & 6
and a description of how the assessment was undertaken including          Chapter 2
any difficulties (such as technical deficiencies or lack of know-how)
encountered in compiling the required information;
i) a description of measures envisaged concerning monitoring in           Chapter 7
accordance with Article 10;
j) a non-technical summary of the information provided under the          Chapter 1
above headings.
The report shall include the information that may reasonably be
required taking into account current knowledge and methods of
assessment, the contents and level of detail in the plan or
programme, its stage in the decision-making process and the extent
to which certain matters are more appropriately assessed at
different levels in that process to avoid duplication of the
assessment (Art. 5.2).
Consultation
• authorities with environmental responsibility, when deciding on         Chapter 2
     the scope and level of detail of the information to be included in
     the environmental report (Art. 5.4).
• authorities with environmental responsibility and the public shall      Chapter 1
     be given an early and effective opportunity within appropriate
     time frames to express their opinion on the draft plan or
     programme and the accompanying environmental report before
     the adoption of the plan or programme (Art. 6.1, 6.2).
• other EU Member States, where the implementation of the plan            Not Applicable
     or programme is likely to have significant effects on the
     environment of that country (Art. 7).
Taking the environmental report and the results of the
consultations into account in decision-making (Art. 8).
     Provision of information on the decision:                            Chapter 1
When the plan or programme is adopted, the public and any
countries consulted shall be informed and the following made
available to those so informed:
• the plan or programme as adopted;
• a statement summarising how environmental considerations
     have been integrated into the plan or programme and how the
     environmental report pursuant to Article 5, the opinions
     expressed pursuant to Article 6 and the results of consultations

                                                                                           14
    entered into pursuant to Article 7 have been taken into account
    in accordance with Article 8, and the reasons for choosing the
    plan or programme as adopted, in the light of the other
    reasonable alternatives dealt with; and
• the measures decided concerning monitoring (Art. 9 and 10).
Monitoring of the significant environmental effects of the plan’s or    Chapter 7
programme’s implementation (Art. 10).
                                                                        1
Quality assurance: environmental reports should be of a sufficient
standard to meet the requirements of the SEA Directive (Art. 12).




1
 The process of consulting on the Sustainability Appraisal provides an opportunity for scrutiny
of the document. Review by external agencies including SEA consultees will ensure the
document is sound and of a sufficient standard.
                                                                                            15
4.0   Sustainability objectives, baseline and context
4.1   Links to other strategies, plans and programmes and sustainability
      objectives

                             Relevant Policies, Plans and Programmes
      International Context
      The Johannesburg Declaration on Sustainable Development (2002)
      European Spatial Development Perspective (1999)
      European Directives, including the Birds (79/409/EEC), Habitats (92/43/EEC), Air Quality
      (1996/62/EC), First Air Quality Daughter (99/30/EC), Water Framework (2000/60/EC), Second
      Air Quality Daughter (2000/69/EC), Third Air Quality Daughter (2002/3/EC), Environmental
      Noise (2002/49/EC) and Waste Framework - Landfill Directive (99/31/EC)
      European Programmes, such as Objective 1 and Objective 2, Interreg (1999)
      Aarhus Convention (1998)
      The Convention on Biological Diversity - Rio de Janeiro (1992)
      Kyoto Agreement (1997)
      The Water Framework Directive (2002)
      EU Sixth Environmental Action Plan
      National Context
      UK Sustainable Development Strategy – Securing the Future (2005)
      Working with the grain of nature: A Biodiversity Strategy for England (2002)
      Urban White Paper (2000)
      The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (2000)
      The Future of Air Transport – Aviation White Paper (2003)
      The Tidal Thames Habitat Action Plan (2002)
      UK Climate Change Programme (2000)
      Planning Policy Statement 1: Delivering Sustainable Development (2005)
      Planning Policy Statement 3: Housing (2006)
      Planning Policy Statement 6: Planning for Town Centres (2005)
      Planning Policy Statement 9: Biodiversity and geological conservation (2005)
      Planning Policy Statement 10 Planning for sustainable waste management (2005)
      Planning Policy Statement 11: Regional Spatial Strategies (2004)
      Planning Policy Statement 12: Local Development Frameworks (2004)
      Planning Policy Statement 22: Renewable Energy (2004)
      Planning Policy Statement 23: Planning and Pollution Control (2004)
      Planning Policy Statement 25: Development and Flood Risk (2006)
      Planning Policy Guidance 2: Green belts (2001)
      Planning Policy Guidance 4: Industrial, commercial development and small firms (2001)
      Planning Policy Guidance 5: Simplified planning zones (1992)
      Planning Policy Guidance 8: Telecommunications (2001)
      Planning Policy Guidance 13: Transport (2002)
      Planning Policy Guidance 15: Planning and the historic environment (2002)
      Planning Policy Guidance 16: Archaeology and planning (2001)
      Planning Policy Guidance 17: Planning for open space, sport and recreation (2002)
      Planning Policy Guidance 19: Outdoor advertisement control (1992)
      Planning Policy Guidance 24: Planning and noise (2001)
      Minerals Planning Guidance various (1998)
      Regional context
      A Sustainable Development Framework for London (2003)
      The London Plan - Spatial Development Strategy for Greater London (2004)
      Draft London Plan Alterations (2005)
      The Mayor’s Transport Strategy (2001)
      The Mayor’s Economic Development Strategy – Sustaining Success (2005)
      The Mayor’s Cultural Strategy (2004)
      The Mayor’s Ambient Noise Strategy – ‘Sounder City’ (2004)

                                                                                            16
        The Mayor's Energy Strategy – ‘Green Light to Clean Power’ (2004)
        The Mayor’s Air Quality Strategy – ‘Cleaning London’s Air’ (2002)
        The Mayor’s Biodiversity Strategy – ‘Connecting with London’s Nature’ (2002)
        The Mayor's Municipal Waste Management Strategy – ‘Rethinking Rubbish in London’ (2003)
        The Mayor’s Housing Supplementary Planning Guidance (2005)
        The Mayor’s Accessible London Supplementary Planning Guidance (2004)
        The Mayor’s Draft Supplementary Planning Guidance on Industrial Capacity (2003)
        The Mayor’s Sub Regional Development Framework (West London) (2003)
        The Mayor’s Review of Industrial and Warehousing Land Demand in West London (2004)
        The Mayor’s Office Policy Review (2004)
        The Mayor’s London Industrial Land Release Benchmarks (2007)
        The GLA’s Economic Interim borough level employment projections to 2016 (2005)
        West London Economic Development Strategy (2004)
        West London Economic Development Strategy Implementation Plan (2005)
        Local context
        Hounslow State of the Environment Report (April 2006)
        Executive Business Plan 2005/06 to 2007/08
        Corporate Equality and Opportunity & Community Cohesion Plan 2005 -2008
        Black and Ethnic Minority Housing Strategy 2005 –2007
        LBH Aviation Policy (February 2006)
        Homeless Strategy 2003-2008
        Hounslow’s Local Area Agreement 2006-2009
        Hounslow’s Ecological Footprint 2005
        Hounslow Community Plan 2007 - 2010
        London Borough of Hounslow Unitary Development Plan (adopted December 2003)
        Community Cohesion in Hounslow – Meeting the Challenge (2003)
        Hounslow Local Biodiversity Action Plan (2003 – 2008)
        London Borough of Hounslow Crime Reduction Strategy 2002-2005
        London Borough of Hounslow Community Safety Strategy 2005-2008
        Housing Investment Programme 2003-2006
        Bringing Success to the Voluntary Sector – Hounslow Council’s Voluntary Sector Strategy
        2003-2006
        Cultural Strategy for Hounslow 2001-2005
        London Borough of Hounslow Waste Management Strategy (2003)
        London Borough of Hounslow Equal Opportunities & Diversity Policy (2003)
        London Borough of Hounslow Sport and Active Recreation Strategy 2005-2010
        Hounslow NHS Primary Care Trust Health Delivery Plan 2005/6 – 2007/8
        Hounslow Air Quality Action Plan (2005)
        London Borough of Hounslow and Partners BAA Heathrow and Green Corridor West Area
        Study (2005)
        Borough Spending Plan 2006/07
        The Brentford Regeneration Framework (2005)

4.1.1   The list of plans considered is in Table 1 above. A review of the policies, plans and
        programmes listed above is available upon request. No list of plans, policies or programmes,
        can be definitive and the list will be reviewed during the SA process. The London Borough of
        Hounslow will consider other PPPs if they become relevant and will record them.

4.1.2   In identifying the proposed spatial vision, objectives and policies for the Employment
        Development Plan Document the Council has taken account of national and regional
        guidance, deliverability, and local opinion.

4.1.3   This section sets out the general context for the proposed vision, spatial
        objectives and policies of the Employment Development Plan Document (DPD). The
        proposed vision and objectives are underpinned by the principles of sustainable development.



                                                                                                 17
18
         National Policy

4.1.4    The Government sets out national policy in Planning Policy Guidance Notes
         (PPGs) which are currently being replaced by Planning Policy Statements (PPSs). The
         Government also produces Circulars and Best Practice Guides in order to provide advice to
         local planning authorities, to encourage a consistent approach to planning across the country.
         For more information please refer to the Department for Communities and Local Government
         website at www.communities.gov.uk

         Regional Policy

4.1.5    Regional planning policy for London is set out in the Mayor’s Spatial Development Strategy
         for London - The London Plan (published February 2004). The London Plan provides the
         regional spatial framework within which Local Development Documents of the Local
         Development Framework (LDF) will be prepared.

4.1.6    Early alterations to the London Plan on housing targets, waste and minerals were published
         in December 2006 and now form part of the London Plan. Further alterations to the London
         Plan, consulted on from September to December 20006 are subject to an Examination in
         Public and subject to the recommendations of the EIP will form part of the Development Plan
         for the Borough upon adoption.

4.1.7    The London Plan forms part of the statutory development plan alongside the Development
         Plan Documents of the LDF. For more information please refer to the Greater London
         Authority website at www.london.gov.uk

         Spatial Development Strategy for Greater London-The London Plan

4.1.8    The Mayor’s London Plan states that the greatest challenge faced by the plan is:

                 ‘to accommodate significant growth in ways that respect and improve London’s
                 diverse heritage while delivering the Mayor’s vision for an exemplary, sustainable
                 world city. This will involve the sensitive intensification of development in locations
                 that are, or will be, well served by public transport.’

4.1.9    Those elements of the Mayor’s overall spatial strategy for development that have a specific
         relevance to the Employment Development Plan Document are listed below:

4.1.10   All proposals will be considered against the sustainability criteria in Policy 2A.1. The criteria
         include optimising the use of previously developed land and the potential of each site,
         ensuring development occurs in the most accessible locations and takes account of the
         capacity of local infrastructure and essential services. The physical constraints of a site and
         the potential impact on environmental and cultural assets will also be assessed.

4.1.11   Policy 2A.2 (Opportunity Areas) requires the production of a sustainable development
         programme for the Heathrow/Feltham/Bedfont Lakes Opportunity Area. The programme
         must have regard to estimates for employment set out in the sub-regional tables and
         maximise access by public transport. Opportunity Areas have been identified on the basis
         that they are capable of accommodating substantial new jobs or there potential should be
         maximised.

4.1.12   The lack of cohesion in this very broadly defined opportunity area brings into question
         whether there are any benefits associated with its definition. This is being discussed with the
         GLA.

4.1.13   The strategic importance of town centres in accommodating economic growth is identified in
         Policy 2A.5 (Town Centres) and Policy 2A.6 (Spatial strategy for the suburbs), which states
         that key commercial activity and services in the suburbs should be focused in key
         metropolitan, major, district and local town centres.

                                                                                                           19
4.1.14   Policies 2A.7 and 3B.5 (Strategic Employment Locations) requires the identification of
         strategic employment locations (SELs).

4.1.15   There are also thematic policies in the London plan that will have particular spatial impacts:

         Living in London (Chapter 3, Part A)
4.1.16   Policy 3A.2 (Borough housing targets) identifies the need for new sources of land for housing
         including the potential for changes of use of surplus industrial/ employment land to residential.
         Working in London (Chapter 3, Part B)
4.1.17   Policy 3B.1 (Developing London’s economy) states that policies must provide a range of
         premises of different types, sizes and costs to meet the needs of different sectors of the
         economy and firms of different types and sizes.

4.1.18   Policy 3B.2 (Office demand and supply) requires that the amount and flexibility of the current
         office stock should be increased through the development of brownfield sites and the
         renovation and renewal of existing stock.

4.1.19   Policy 3B.5 (Strategic Employment Locations) requires boroughs to identify SELs and to
         develop local policies for employments sites outside SELs.

4.1.20   Policy 3B.6 (Supporting innovation) states that boroughs should ensure an adequate supply
         of environmentally attractive, high quality and affordable premises, ‘incubator units’ and sites
         for synergy between business and research and academic institutions.

4.1.21   Policy 3B.11 (Environmental industries) requires local policies to identify and safeguard land
         and premises in appropriate locations including river- and rail-based locations, to secure the
         capacity for appropriate environmental industries and facilities for the recycling and
         reprocessing of waste.

         Connecting London (Chapter 3, Part C)
4.1.22   Policy 3C.1 (Integrating transport and development) identifies the need to support high trip
         generating uses such as employment only at locations with both high levels of public transport
         accessibility.

         West London Sub-Regional Development Framework, May 2006

4.1.23   The Sub Regional Development Framework (SRDF) covers the West London sub-region,
         which is made up of the six boroughs of Brent, Ealing, Hammersmith and Fulham, Harrow,
         Hillingdon and Hounslow. Its purpose, in line with PPS 12 and in the spirit of PPS 11, is to
         provide guidance on the implementation of policies in the London Plan in order to help deliver
         a sustainable and prosperous future for the sub-region.

4.1.24   The SRDF sets out about 100 proposed actions that either give a direct steer on the sub-
         regional implementation of the strategic policies in the London Plan, or provide guidance and
         a checklist of matters that need to be developed in an integrated way at the local level. The
         proposed actions of relevance to employment include:
         Proposed Action(s) 1B

         (i) In partnership with the LDA, boroughs are asked to facilitate the implementation
         of the Mayor’s Economic Development Strategy through the West London Sub-
         Regional Economic Development Strategy and Implementation Plan (SREDIP) 12.
         (ii) The Mayor will work with LDA, boroughs and other stakeholders to encourage
         the market to provide and enhance viable, affordable provision for SMEs in
         appropriate locations, and, through the SREDIP, to meet their specific needs for
         business support and training.

                                                                                                       20
         (iii) The Mayor will continue to analyse the London wide office market. Boroughs
         and other stakeholders are encouraged to supplement this through sub-regional
         and local office market analysis.

         (iv) Through LDFs, boroughs and other partners are encouraged to promote the
         consolidation and re-positioning of the sub-regional office market in
         appropriate, viable locations and achieve wider planning objectives including
         town centre renewal and increased housing provision.

         Proposed Action(s) 2D

         (i) When implementing London Plan Policy 2A.7, Boroughs are asked to take into
         account the indicative boundaries of SELs in Annex 2 in defining them in LDFs
         and to identify Locally Significant Industrial Sites in light of local and strategic
         industrial demand assessments and London Plan Policy 3B.5.

         (ii) In producing and reviewing the Sub-regional Economic Development
         Implementation Plan for West London, the LDA and West London Partnership
         should consider measures to improve the quality of retained industrial locations
         in order to stimulate business development and employment.

         West London Economic Development Strategy (December 2004)

4.1.25   The West London Economic Development Strategy (WLEDS) puts forward an economic
         vision of the sub-region to complement the spatial policies and to inform the development of
         Local Development Frameworks. The objectives of the WLEDS of particular relevance to the
         Employment Development Plan Document are to:
         • Ensure that there is sufficient development land of the right quality to meet demand.
         • Promote, mange and enhance the quality of existing stock of key strategic employment
              locations and improve transport to these locations.
         • Support the rejuvenation of town centres as centres of employment.
4.1.26   There is an Implementation Plan for the WLEDS, published in September 2005.

         Local Policy

4.1.27   Currently the Hounslow Unitary Development plan 2003 is the adopted Development Plan for
         the area. However the Planning and Compulsory Purchase Act 2004 requires existing
         Development Plans to be replaced by Development Plan Documents. Hounslow’s Local
         Development Scheme sets out the timetable and work programme for the review of the UDP.
         The employment chapter of the current UDP and Brentford Area Action Plan have been
         prioritised for review. For more information please refer to the London Borough of Hounslow
         website at www.hounslow.gov.uk

4.1.28   The Employment DPD should be based on a clear vision for the future of the Borough’s
         employment land and should take account of other policies and strategies affecting the
         London Borough of Hounslow.

         The Council’s current Unitary Development Plan (UDP) 2003

4.1.29   The Council’s UDP was adopted in December 2003. The general principles, which form the
         basis for all plan policies and proposals, are listed below.

         •   Sustainability, accessibility, opportunity and equity
         •   Concentrating development in town centres and regeneration areas
         •   Re-use and renewal

                                                                                                  21
         •   Encouraging economic success
         •   Environmental enhancement
         •   Reducing waste and pollution
         •   Working in partnership

         Hounslow Plan 2006 - 2010

4.1.30   The Hounslow Plan in delivering the policy framework for the Executive over the period to
         2010 sets ten priorities under three broad policy themes of Organisational delivery, Quality of
         Life and Looking to the future.

4.1.31   Under ‘Quality of life’, the Council seeks
         • to safeguard and enhance the environment including working for high quality
            development
         • improve standards in schools. Ensuring a good education can provide greater
            opportunities later in life. Providing for learning and skills development early can provide a
            ‘ladder of opportunity’ and allows people to reach their full potential. The commitment to
            improving knowledge and skills is therefore central to the Council.

4.1.32   In ‘Looking to the Future’, the Hounslow Plan has priorities of
         • delivering the existing Community Plan Objectives, commitment to key local issues and
              positive engagement with the community including businesses
         • leading in delivery of the new Community Plan
         • developing a vision for the physical development of the borough, which this Development
              Plan Document contributes to

         Hounslow Community Plan 2007 – 2010

4.1.33   At a local level, the Community Plan (2007 – 2010) prepared by the Local Strategic
         Partnership (LSP) has an overarching theme of ‘A growing community’, which provides a
         framework for supporting the delivery of services and activities.

4.1.34   In achieving the overarching theme of ‘A growing community’, the key objectives are
             • To ensure spatial plans for Hounslow achieve sustainable development of the
                 borough by balancing economic and social growth needs with the protection and
                 enhancement of the environment
             • To ensure that the new developments contribute to meeting current and future needs
                 but complement the surrounding area
             • To ensure new housing provision is supported by amongst other uses and
                 infrastructure, business areas to build sustainable communities
             • To ensure the full and active involvement of all of the community in our development
                 plans for the borough and in deciding on individual proposals

4.1.35   There are 6 themes with objectives below each, the most relevant theme for the Employment
         DPD being -

                   ‘An Economically Active and Skilled Community’ will ensure Hounslow prospers
                   from economic growth and that residents have the right skills to be actively
                   involved.’

4.1.36   A number of challenges are identified as facing the local economy including
             • Easy access to low skilled jobs makes it harder to persuade young people to stay in
               education and training long enough to gain higher-level skills.
             • Affordable business premises on flexible terms suitable for start-up are harder to find.
             • Uncertainty about airport expansion plans and the premium airport activity places on
               industrial land inhibit business growth in more sustainable sectors


                                                                                                       22
            •   Traffic congestion slows down the local economy and causes significant amounts of
                pollution.

4.1.37   To address these, the key objectives to achieving an ‘economically active and skilled
         community’ are
             • To complete the regeneration of Hounslow Town Centre and Brentford
             • Increase skills attainment particularly at “NVQ level 3” by encouraging more young
                people into further education and apprenticeships and reducing the number of 16-18
                year olds ”Not in Employment, Education or Training” (NEET)
             • Increase the number of borough residents in paid work
             • Support local business growth and development, promoting the borough to attract
                investment and development

4.1.38   One of the means for determining whether these objectives has been achieved, particularly
         the last of the four is through the Employment DPD. This reflects the local development
         framework being the spatial expression of the Community Plan.




                                                                                                 23
4.2       Description of the social, environmental and economic baseline
          characteristics and the predicated future baseline

4.2.1     Population

4.2.1.1   SA Objective(s)
          1. To maintain and/or improve the health of the population of the borough
          4. To improve opportunities or developing community cohesion through increasing
          understanding and learning between our many communities

4.2.1.2   Indicators
          •   Resident Population
          •   Age and Gender Distribution
          •   Population Projections
          •   Ethnicity and Religion
          •   Population Density
          •   Refugee Population and Profile

          Current Baseline

4.2.1.3   In the twenty years between 1982 and 2002 the population of Hounslow grew by 7.1 per cent,
          compared with an increase of 8.7 per cent for London region as a whole. The total resident
          population of Hounslow at the time of the 2001 census was 212,341 of which 49% were male
          and 51% female. Mid-2003 population estimates predicted an increase to 212,900 residents.

4.2.1.4   The population pyramids of age range and gender show that Hounslow has a very similar
          population profile to the rest of London. The majority of the population are aged between 20
          and 55 years old. Hounslow and London both have a younger population profile than the UK
          as a whole, with a higher percentage of the population within the 20-39 year old age group
          and a lower percentage in the 50-84 year old age groups.

          Figure 4.1: Population Pyramids for Hounslow and London
                Hounslow Population Pyramid                  London Population Pyramid




          Source: Office for National Statistics – Census 2001            Source: Office for National
                 Statistics – Census 2001

4.2.1.5   The population density of Hounslow averages 37.9 people per hectare, compared to the
          London average of 45.6 people per hectare. Hounslow is ranked 25th out of 33 London
          boroughs for population density. The low population density of Hounslow in comparison to
          most London boroughs reflects Hounslow’s geographical location in outer London and the
          large areas of green belt and metropolitan open land. The most densely populated wards in

                                                                                                    24
           the borough are Hounslow Central, Hounslow West and Heston Central with over 60
           residents per hectare. The most sparsely populated ward in the borough is Osterley and
           Spring Grove with only 16.5 people per hectare.

4.2.1.6    Hounslow has a diverse community with 35% (74,587) of residents from minority ethnic
           communities. This proportion of non-white ethnic minority residents is higher than both the
           Outer London average of 25% and the London average of 29%. The largest community is
           from the Indian sub-continent and the largest Indian and Pakistani communities are in Heston
           and Cranford, and Central Hounslow. There are also estimated to be between 7,100 – 8,200
           (3.3% - 3.9% of the population) refugees in Hounslow as well as a relatively small travelling
           community.

           Future Baseline

4.2.1.7    Figure 4.2 shows that between 2003 and 2028 there is predicted to be a 5% (10,000 people)
           increase in the population of Hounslow (It should be noted that population projections do not
           comprehensively take into account population increase resulting from all development). The
           population increase for the borough is significantly lower than the projected increases for
           London as a whole (13%) and NW London (25%).

4.2.1.8    The age profile of the population will also change with an 11% decrease in the size of the 15-
           24 age group over the next 25 years. This contrasts with the projected increase by 2028 of
           this age group in NW London (4%) and the rest of London (2%).
4.2.1.9    The fastest growing ethnic population in the borough is the Black African community, although
           the White and Indian communities will continue to be the two largest ethnic groups. In line
           with broader population trends, the ethnic population of Hounslow is also an ageing one. In
           2006, over one quarter of the ethnic population (26%) will be over 45. An ageing population
           profile will have significant implications for the provision of education, health and welfare
           services in the borough.
           Figure 4.2: 2003-based Population Projections in Hounslow to 2028
                                    224                                                    223.1

                                    222
                                                                                  219.9
                                    220
           Population (thousands)




                                    218
                                                                          216.5
                                    216

                                    214                           213.4
                                          212.9
                                                  212.4
                                                          211.9
                                    212

                                    210

                                    208

                                    206
                                          2003    2004    2008    2013    2018    2023      2028
           Source: 2003-based population projections, ONS
4.2.1.10   The density of the borough’s population will increase as the density of developments in
           locations with good access to public transport increases in accordance with the London Plan
           and UDP.




                                                                                                       25
4.2.2      Health

4.2.2.1    SA Objective(s)
           1. To maintain and/or improve the health of the population in the borough

4.2.2.2    Indicators
           • Standardised Mortality Rates (SMR’s) for all ages and for deaths before 75 years of age
           • Direct Standardised Death Rate (DSDR) for all ages and for deaths before 75 years of
               age from circulatory disease, CHD and cancer
           • Life expectancy
           • Percentage of people who describe their health as good

           Current Baseline

4.2.2.3    Health is an important issue in the Borough, with a number of Community Plan targets,
           Strategies and Plans addressing health issues and ensuring people have the opportunity to
           maintain and improve their health. Health is linked to factors such as housing quality, lifestyle
           and environmental issues, such as pollution, which can be the cause of health inequalities.

4.2.2.4    Health issues in the Borough are measured by a range of indicators. A Standard Mortality
           Rate is a measure if how more or less likely a person living in the Borough is to die compared
           to the standard population, in this case England. The SMR is a ratio of the actual number of
           deaths in the Borough to the number expected if the Borough had the same age specific
           mortality rates as England, multiplied by 100. An SMR of 100 indicates that the Borough has
           average mortality, lower than 100 indicates lower than average mortality.

4.2.2.5    Overall mortality, measured by the Standardised Mortality Rate (SMR) for all ages is 108,
           significantly higher than for Outer London, London and England. The average SMR for deaths
           before 75 in the Borough is 110, higher than the London average of 103 (Source: London
           Health Observatory).

4.2.2.6    The average life expectancy in the Borough for both males (75.2) and females (79.8) is
           slightly lower than for London (75.7 and 80.6) and England (76 and 80.6) (Source: London
           Health Observatory). ,

4.2.2.7    Despite these figures, the proportion of people stating their health as generally ‘good’ (71%) is
           higher than regional and national figures. In Hounslow 14.9% of the population is reported to
           have limiting long-term illness in comparison to the average for England and Wales of 18.2%.

           Future Baseline

4.2.2.8    Demands on health care services resulting from new development and proposals in
           the development plan will need to be monitored for their effects on the health of the
           population. A Health Impact Assessment of recent developments in Brentford is
           currently being undertaken to scope the potential health impacts of development in the
           Brentford area.

4.2.2.9    Through involvement of the Primary Care Trust in negotiating planning obligations,
           and application of the Healthy Urban Development Unit model to proposals for
           development, the negative impacts of further growth on health infrastructure can be
           mitigated through planning obligations, where applicable.

4.2.2.10   Furthermore, the implementation of health strategies and plans for the future planning of
           health can ensure there are services available, including adequate health provision to meet
           the needs of the community.




                                                                                                         26
4.2.3     Crime

4.2.3.1   SA Objective(s)
          2.    To reduce crime and the fear of crime

4.2.3.2   Indicators
          • Recorded Crimes per 1,000 population
          • Domestic Burglaries per 1,000 households
          • Violent offences committed per 1,000 population
          • Fear of Crime
          Current Baseline

4.2.3.3   The levels of recorded crime in the borough are at a six-year low (at 131 crimes per 1,000
          population) and are below the London average (of 144 crimes per 1,000 population). They are
          above the average for England and Wales (at 108 crimes per 1,000 population), which
          reflects the fact that London has the highest crime rate in the UK.

4.2.3.4   Hounslow had the sixth highest crime rate in 2004/5 amongst London borough’s considered
          most similar (Barnet, Brent, Croydon, Ealing, Enfield, Greenwich, Haringey, Hillingdon,
          Lewisham, Merton, Sutton and Waltham Forest). The average crime rate for all the ‘most
          similar’ boroughs was 121 crimes per 1,000 people compared with Hounslow’s figure of 131
          crimes in 2004/5.

4.2.3.5   Statistics from the Metropolitan Police Service (MPS) show that in the 12 months to
          November 2005 the burglary rate was 13.8 crimes per 1,000 compared with 14.8% for
          London as a whole. The crime rate for violence against the person was 28.9 per 1,000, and
          for recorded violent crime, 29.8 per 1,000.

4.2.3.6   The results of Hounslow’s Community Safety Partnership survey show that in the borough as
          a whole in 2004, 80% of residents felt very/fairly safe outside during the day compared to the
          London average of 82%. Only 36% felt very/fairly safe outside during the night, which is
          again lower than the rest of London average of 47%.

          Future Baseline

4.2.3.7   Overall levels of recorded crime in the borough have fallen in the last six years, and this may
          have contributed to in a reduction in people’s fear of crime during the day. However, surveys
          by Hounslow’s Community Safety Partnership have identified that tackling anti-social
          behaviour, and crime and disorder, are consistently high priorities for residents. Support for
          young people has been identified as a particular priority as they are considered to be the most
          vulnerable to negative influences and their needs should be addressed in plans for future
          population growth. Levels of recorded crime are highest in the borough’s four town centres of
          Chiswick, Feltham, Brentford and Hounslow and the major neighbourhood centres such as
          Hounslow West. Improvements to the design and safety of these areas must be addressed in
          plans for redevelopment or expansion.




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4.2.4     Housing and households

4.2.4.1   SA Objective(s)
          3. To ensure that everyone has the opportunity to live in a decent, sustainably constructed
          and affordable home.
          9. To improve the quality of where people live
          13. To promote regeneration that makes use of existing assets

4.2.4.2   Indicators
          • BVPI 184a - the proportion of local authority homes, which were non-decent at the start of
              each financial year.
          • BVPI 106 - the percentage of new homes built on previously developed land.
          • Annual provision for additional homes target (1997-2016) set in the London Plan, of 470
              completions per year
          • Affordable housing completion figures
          • Homelessness and temporary accommodation
          • Overcrowding figures including average household size and number of rooms per
              household
          • Proportion of residents ‘very satisfied’ or ‘fairly satisfied’ with their neighbourhood as a
              place to live

          Current Baseline

4.2.4.3   The Housing Investment Programme Report, published on 1 April 2004, shows that the total
          number of dwellings in the Borough was 89,169, an increase of 1,609 dwellings since
          2001/02. There were 9,762 unfit dwellings at 1st April 2004, with 79% of those being in the
          private sector. The Council is working to improve the quality of unfit private sector dwellings
          through government grants made available to local authorities. At the start of the year
          2002/03, 71% of local authority homes were non-decent, and by 1 April 2003; this figure had
          decreased by 7.3% (BV 184a). The proportion of vacant dwellings in the Borough represents
          2% of the housing stock and has decreased since 2001/02.

4.2.4.4   The number of homeless households in priority need and in temporary accommodation in
          2004 was 1,328, down from 1,478 the year before, which is an overall decrease of 10%, and
          the lowest it has been for four years. Of the 1,328 homeless households, 86% contained
          dependent children or a pregnant woman, which is the highest it has been over the last 4
          years. Hounslow did not reach its target for average length of stay in Bed and Breakfast and
          Hostel Accommodation, but is closer to it than in previous years.

4.2.4.5   The proportion of owner-occupier households is higher in the borough than for London as a
          whole (61% compared to 57%) but lower than the average for Outer London boroughs (68%)
          and England and Wales (69%). There are a greater proportion of households renting both
          from the Council and privately than for Outer London (18.2%) and England and Wales
          (19.2%).

4.2.4.6   The average household size in the Borough is 2.51 greater than the London wide average of
          2.35 persons per household. The average number of rooms per household in the Borough is
          4.73, lower than the averages for Outer London (4.99) and England and Wales (5.34).

4.2.4.7   Hounslow has a similar proportion of single parent households with dependent children
          (11.7%) to Outer London (11.6%) and London (12.7%), but a higher proportion compared to
          the national average. There are fewer pensioners living alone, and fewer households living
          without central heating than in London and England.

4.2.4.8   In 2004/05, 570 new homes were completed in 2004/05, which is significantly above the
          target of 470 set out in the London Plan. 35% of these new homes were affordable, below the
          50% Borough wide target set in local and regional policy.



                                                                                                        28
4.2.4.9    The proportion of new homes built on previously developed land in Hounslow was 74% for
           2004/05, down from 83% in 2003/2004 (recorded by BV106). This falls short of the Borough
           target and is well below the London average of 98% but is above the national average of
           70%.

4.2.4.10   According to the Residents Panel Survey, 17% of residents were very satisfied and 43%
           satisfied with the neighbourhood as a place to live (June 2006 Residents Panel Survey) The
           residents panel survey will continue to be used as a baseline source for reporting on this
           indicator which includes this question on an annual basis.

           Future baseline

4.2.4.11   Housing projections show a high rate of housing development in the borough with 1,015 new
           dwellings per year over the next four years. From 2009-2014 annual projected housing
           development will be 493 per year, which will continue to meet the London Plan target.




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4.2.5     Social Inclusiveness and Accessibility

4.2.5.1   SA Objective(s)
          4. To improve opportunities for developing community cohesion through increasing
          understanding and learning between our many communities
          6. To ensure fair and equal access to services (health care, education, employment,
          shopping, transport), culture, leisure and recreation for all residents
          7. To reduce discrimination and promote equality of opportunity and fair treatment for all of
          our communities
          23. To improve accessibility for all sections of the community to jobs, education, skills training
          and life long learning

4.2.5.2   Indicators
          •   Percentage of local people who feel that their local area is a place where people from
              different backgrounds and communities can live together harmoniously
          • Voluntary activity
          • Percentage of local authority buildings open to the public in which all public areas are
              suitable for and accessible for disabled people
          • Percentage of total length of footpaths and other rights of way, which were easy to use by
              members of the public
          • Indices of Multiple Deprivation
          • Proportion of the population who live in wards that rank within the most deprived 10% in
              the country
          • Amount of new residential development within 30 minutes public transport time of areas
              of employment

          Current Baseline

4.2.5.3   Hounslow is one of the most culturally diverse areas of London with over 35% of the
          population from minority ethnic groups. A Hounslow’s Residents’ Panel survey in 2004 shows
          that it is a cohesive community with a majority (84%) of respondents saying that their local
          area was a place where people from different backgrounds got on well together. The
          borough’s cultural diversity highlights the importance of community and voluntary groups in
          supporting their own communities and fostering a sense of cohesion with others. There are
          currently estimated to be over 800 community and voluntary groups in the borough. This is
          equivalent to 4 community and voluntary groups for every 1,000 people in the borough
          compared to the national average of 3 groups per 1,000 people (Source: Quality of Life
          Counts Indicator, Defra 2004).

4.2.5.4   Accessibility for disabled people in the borough is good. Approximately 43% of Council
          buildings open to the public were suitable and accessible to disabled people in 2004/5 which
          is greater the than the London average of 28.7% and is equal to the UK average of 43.8%.
          The quality of footpaths in the borough is high with 87.5% of the total length of footpaths and
          other rights of way easy to use by members of the public.

4.2.5.5   The Indices of Multiple Deprivation 2004 (IMD 2004) combine information on income,
          employment, education, health, skills and training, barriers to housing and services, and crime
          to provide an overall measure of deprivation at the local level. Map 1 in Appendix 2 shows
          that in the 2004 rank of Indices of Multiple Deprivation (IMD), the most deprived areas in the
          borough were in the wards of Bedfont, Brentford, Hanworth, Heston West and Syon. The
          2004 IMD also shows that 3 areas in Hounslow are in the top 10% most deprived areas in
          England. These are in the wards of Feltham West, Hanworth and Isleworth and equates to
          15.7% of people residing in the borough. Of those sectors of the community in receipt of
          income support, the majority are single females aged between 25 and 49.

4.2.5.6   Refer to Annual Monitoring Report for baseline on the amount of new residential development
          within 30 minutes public transport time of areas of employment.

                                                                                                         30
31
          Future Baseline

4.2.5.6   The work of community groups within the borough should be encouraged and monitored
          because of the important role they play in community relations, and the access they can
          provide to hard to reach groups.

4.2.5.7   The proportion of public buildings that are accessible to all members of the community will
          continue to increase with the implementation of the Disability Discrimination Act regulations
          2003. This will ensure that any new public buildings in the Borough are accessible to people
          with disabilities or impaired mobility. The percentage of pedestrian crossings with facilities for
          the disabled should be maintained at 100%.

4.2.5.8   Deprivation is a notable and persistent issue in certain parts of the borough. The issues of
          poverty and social exclusion faced by different communities in these areas, including
          affordability of housing and access to essential services, should be addressed in plans for
          future regeneration and growth.




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4.2.6     Noise

4.2.6.1   SA Objective(s)
          5. To reduce as far as practicable noise from all sources

4.2.6.2   Indicators
          • Noise levels from road traffic
          • Noise levels from air traffic – LEQ contours
          • Method of travel to work (refer to section 4.2.7 for baseline data)

          Current Baseline

4.2.6.3   Noise is a problem for many residents in Hounslow, with noise generated from flights in and
          out of Heathrow airport (there were approximately 320,000 flights in 2003 over the borough)
          as well as road traffic being a major contributor. Aircraft noise is monitored at two points in the
          borough.

4.2.6.4   The EU Noise Directorate (2002/49/EC) requires member states to map noise from road, rail
          and air transport, which Defra are currently working to produce. The London road traffic noise
          map is currently available online (provided by Defra). See www.noisemapping.org

          Future Baseline

4.2.6.5   Noise is addressed in the Community Plan target to produce supplementary planning
          guidance (now known as a supplementary planning document under the Local Development
          Framework) on noise. This document will be produced in April 2007. A third aircraft noise
          monitoring station will be set up in Cranford in early 2006

4.2.6.6   The development of Terminal 5 at Heathrow, and possibility of a third runway at Heathrow
          could lead to increased noise nuisance for Hounslow’s residents. The Government’s Aviation
          White Paper outlines measures to be taken to combat negative impacts of a third runway,
          including airport operators offering noise insulation to   schools and hospitals in affected
          areas. The Council will continue to seek improvements to the       existing environment and
          will endeavour to ensure that any          airport development proposals do not prejudice any
          future or potential improvement in the environmental quality of the Borough.

4.2.6.7   The effects of noise from roads and other sources will also be taken into account in the
          development process.




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4.2.7     Transport

4.2.7.1   SA Objective(s)
          6.    To ensure fair and equal access to services (health care, education, employment,
                shopping, transport) culture, leisure and recreation for all residents.
          10.   To minimise the need to travel, increase the use of sustainable transport modes
                (walking, cycling and public transport) and reduce reliance on the car
          23.   To improve accessibility for all sections of the community to jobs education, skills
                training and life long learning.

4.2.7.2   Indicators
          •   Public Transport Accessibility Scores (PTAL)
          •   Mode share for work and education trips
          •   Car ownership
          •   Traffic Flows
          •   Density of Development
          •   Method of travel to work
          •   Amount of new residential development within 30 minutes public transport time of areas
              of employment
          • Overall reduction in distance travelled to work
          Current Baseline

4.2.7.3   Public transport in the borough is provided by the London Underground (Piccadilly and District
          Lines), the North London, Hounslow Loop and Waterloo to Reading overground rail lines, and
          numerous bus services which primarily serve to link communities within town centres and
          major employment areas. There are also areas that are very poorly served by public
          transport particularly in the west of the borough and in other out of centre locations (see Map
          2 in Appendix 2). Hounslow’s proximity to Heathrow Airport has also created a role for the
          borough as a gateway to the capital for many visitors. The major roads within the borough
          include the M4 and M3, and a number of Primary and Secondary roads – the A4, A312, A315,
          A30, A316, A205 and A406 (North and South Circular Roads) cut through the borough linking
          Hounslow with other Metropolitan centres and London with the south and west of the country.

4.2.7.4   Transport accessibility varies significantly across the borough. Access to public transport is
          measured using Public Transport Accessibility Level (PTAL) scores. Map 2 (Appendix 2)
          shows that the majority of the borough has below average to very poor PTAL scores apart
          from Central Hounslow and areas around Feltham, Hounslow West, Hounslow Central,
          Hounslow East, Gunnersbury, Turnham Green and Stamford Brook stations that show above
          average to very good PTAL scores.

4.2.7.5   Hounslow has relatively high car ownership levels in comparison to the rest of London. At the
          time of the 2001 Census, 71.4% of households in Hounslow owned a car compared to the
          London average of 62.5%. The current mode share for trips to work in the borough show that
          30% of Hounslow residents use public transport to travel to work, which is a lower proportion
          than Outer London (36%) and London (42%). The percentage of people travelling to work by
          car in Hounslow is relatively high at 54%. In comparison to Outer London (45%) and London
          (36%). Hounslow is ranked 7th highest out of 33 boroughs in terms of the proportion of people
          who travel to work by car (32 London boroughs and the City of London). Traffic flows in the
          borough have also been increasing recent years. In terms of distance travelled to work by
          Hounslow’s residents, 24.6% travel more than 10km to work, 23.6% travel 5 -10 km and 39%
          travel less than 5km.

4.2.7.6   In 2001 the average trip of all trips made in Hounslow was 5.56km, in comparison to averages
          for Greater London and Central London of 5.46km and 4.47km respectively (these are
          estimates based on the 2001 London Area Transport Survey).


                                                                                                       34
4.2.7.7    The proportion of Hounslow residents using public transport to travel to education is 28%.
           Use of the bus (21%) and travelling as a car passenger (28%) for education trips has
           increased significantly in recent years, and the percentage of trips made by walking (37%)
           has significantly declined.

4.2.7.8    Refer to Annual Monitoring Report for baseline on the amount of new residential development
           within 30 minutes public transport time of areas of employment.

           Future Baseline

4.2.7.9    The accessibility of the borough should continue to be monitored and improved where
           possible. With no major planned improvements to the provision of public transport in the
           borough, poor public transport accessibility could have a negative impact on the sustainability
           of future growth in Hounslow and the accessibility of essential services.

4.2.7.10   The location of Hounslow in Outer London, the large numbers of residents that work outside
           the borough (Heathrow airport or areas beyond outer London) and poor levels of public
           transport accessibility are factors contributing to traffic congestion, air pollution, and noise
           pollution levels, but this will need to be addressed at a more strategic level.

4.2.7.11   Traffic flows should continue to be monitored and measures considered reversing the current
           increases in the borough’s traffic levels. The potential for increasing the density of
           development in the most accessible areas of the borough should also be promoted.




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4.2.8     Air

4.2.8.1   SA Objective(s)
          16. To improve air quality in the borough
          Targets set by EU and National Air Quality Strategy

4.2.8.2   Indicators
          • Nitrogen dioxide (NOx) levels
          • Particulate matter (PM10) levels
          • Method of travel to work (refer to section 4.2.7 for baseline data)

          Current Baseline

4.2.8.3   Air pollution is an identified problem in the borough, and the Council is committed to
          implementing an air quality action plan. Poor air quality can be damaging to human health
          and contributes to health inequalities, as well as impacting on biodiversity.

4.2.8.4   The majority of air pollution comes from busy or congested roads including the M4, A4 and
          A30, in part related to the borough’s location next to the world’s busiest international airport
          and as a western gateway into London. In the west of the borough pollution directly from
          Heathrow Airport is significant.

4.2.8.5   Targets for air quality are set by the EU and the National Air Quality Strategy (NAQS).
          Nitrogen dioxide levels in the borough are high and exceed the objective set by the NAQS.
          Road traffic is the dominant source of nitrogen dioxide, with airport activities contributing to
          around a quarter of nitrogen dioxide levels in the west of the borough.

4.2.8.6   Council policy aims to reduce the level of specific pollutants and in particular those associated
          with road traffic. In response to this and in line with Council policy to reduce the level of
          specific air pollutants, 3 Air Quality Management Areas (AQMA) are designated in the
          Borough. An AQMA is an area where one or more of the air quality objectives are not
          expected to be met unless action is taken to improve air quality.

4.2.8.7   Carbon monoxide, sulphur monoxide and ozone levels in the borough do not exceed EU
          targets. Existing policies are seen to be sufficient and the levels of these pollutants are not
          considered a priority for local air quality management in Hounslow.

          Future Baseline

4.2.8.8   Nitrogen dioxide (NO2) levels over large areas of the borough are predicted to exceed the
          national air quality (NAQS) objective for 2005 of 40μg/m³. As with all predictive data, there is
          some uncertainty but it is unlikely the air quality objective for 2005 will be met. The Council
          will continue to monitor trends in NO2 levels and within the AQMAs.

4.2.8.9   It is also likely that following the recommendations of Hounslow’s Air Quality Management
          Plan (May 2005) that the whole of the borough will soon be designated an AQMA.




                                                                                                             36
4.2.9     Water

4.2.9.1   SA Objective(s)
          11. To ensure the quantitative and qualitative conservation of resources (soil,
          mineral aggregates, water, energy)
          15. To reduce negative contributions to climate change
          18. To promote high quality urban design and the use of sustainable building materials where
          appropriate

4.2.9.2   Indicators
          • Percentage of main rivers and canals with good or fair biological and chemical water
              quality
          • Development taking place within the 1 in 100 year flood plain
          • The number of large developments incorporating Sustainable Drainage Systems (SuDS)
          • Number of planning permissions for B class uses granted contrary to the advice of the
              Environment Agency (EA) on either floor defence grounds or water quality

          Current Baseline

4.2.9.3   The major water bodies within the borough are the River Thames, River Crane, Whitton
          Brook, River Brent, Longford River, Duke of Northumberland’s River and Grand Union Canal.
          They are key elements of the Borough’s environment and make a significant contribution to
          the landscape, ecology and local amenity of the area.

4.2.9.4   The Environment Agency’s river quality assessments show that the biological (17%) and
          chemical (13%) quality of a low proportion of monitoring points in the Borough’s water bodies
          is good.

4.2.9.5   The Environment Agency’s flood zone maps have determined that there are parts of the
          borough that are in flood zone 2 and 3 (as determined by the Environment Agency). These
          areas are: along the length of the River Crane in the west of the borough in the Cranford and
          Feltham areas, along parts of the River Brent and Grand Union Canal in the east of the
          borough in the Brentford area, and along the length of the Thames in the east of the borough
          covering extensive areas of Isleworth, Syon, Brentford and Chiswick.

4.2.9.6   Refer to Annual Monitoring Report for number of planning permissions granted contrary to the
          advice of the Environment Agency (EA) on either floor defence grounds or water quality

          Future Baseline

4.2.9.7   The Council will continue to liaise with the Environment Agency to encourage cleanliness of
          all waterways, and aim to reduce pollution of the Thames, its tributaries and other waterways.
          In seeking to achieve this, the quality of the Borough’s waterways will be monitored and
          improvements sought in biological and chemical quality.

4.2.9.8   Developments taking place within the Environment Agency’s Flood Zone 3 will be monitored.
          Land within these areas has a 1% (1 in 100) or greater chance of being flooded by a
          waterway each year.

4.2.9.9   The Council will also monitor the number of large development incorporating Sustainable
          urban Drainage Systems (SuDS). SuDS mimic the natural drainage of a site to minimise the
          impact of urban development on the flooding and pollution of waterways.




                                                                                                     37
4.2.10     Soil and minerals

4.2.10.1   SA Objective(s)
           11. To ensure the quantitative and qualitative conservation of resources (soil, mineral
           aggregates, water, energy)

4.2.10.2   Indicators
           • HA of contaminated land
           • Production of primary land won aggregates and secondary/recycled aggregates

           Current Baseline

4.2.10.3   The geology of the borough is dominated by an extensive spread of sand and gravel up to 8
           metres in thickness, which occur as “terraces” on the valley sides. These terraces were laid
           down by the Thames and rest on London Clay, which forms the “bedrock” beneath the
           borough. Hounslow’s sand and gravel, including a deposit of sandy loam known as
           ‘brickearth’ (used in brick-making), have been extensively worked, particularly in the west of
           the borough. These sand and gravel extraction sites have subsequently become landfill sites,
           and have been monitored by the Council since the early 1990s. All publicly owned landfills
           have had monitoring boreholes installed.

4.2.10.4   Hounslow has a history of industrial land use, including factories, gas works, landfill sites and
           military land. These uses have the potential to leave contamination, which may pose risks to
           human health, water supplies, natural habitats and property. Since April 2000 Council’s have
           had a statutory duty to identify and clean up contaminated areas. Hounslow’s Contaminated
           Land Strategy was published in June 2001. In accordance with the strategy the Council’s
           Land Quality Team is actively investigating areas of potential contamination across the
           borough, giving priority to the most sensitive land uses. This work involves the assessment of
           existing information and, in some cases, physical sampling of sites. Currently there are no
           legally determined contaminated land sites in the borough. All sites that are determined
           Contaminated Land in the future will appear on a public register.

           Future baseline

4.2.10.5   Ongoing work as part of the Contaminated Land Strategy may reveal sites that need to be
           cleaned up and this work will be carried out in accordance with the strategy. Assessments of
           contamination are made in the evaluation for potential new developments on sites known to
           have previously been in industrial use.




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4.2.11     Waste

4.2.11.1   SA Objective(s)
           17.   To minimise the production of waste

4.2.11.2   Indicators
           • Amount of waste collected by type
           • Percentage of waste recycled
           • Percentage of waste composted
           • Amount of waste disposed in landfill
           Current Baseline

4.2.11.3   The total amount of municipal waste collected in 2004/05 amounted to 96,617 tonnes. Figure
           4.3 provides a summary of the composition of municipal waste (as defined by the types
           listed).

                          Figure 4.3: Summary of municipal waste collected by type


                        Municipal waste by type             Amount of waste           % of total

                        Collected household waste                 60717                  63%
                           Collected trade waste                  11,165                 12%
                           Street cleaning waste                  6,491                   7%
                       Council office/services waste                74                    0%
                         Collected recycled waste                 15,154                 16%
                               Green waste                        3,016                   3%
                                 Total                        96,617                    100%
                   Source: Land Quality team, London Borough of Hounslow

4.2.11.4   The proportion of household waste that is being recycled is steadily increasing, rising from
           14.4% in 2003/4 to 14.6% in 2004/05. However the percentage of waste recycled in 2004/05
           was lower than the borough’s target of 17.8%. The percentage of household waste sent for
           composting in 2004/05 was 2.8%. This proportion was again lower than the target of 3.5%,
           but up from 1.5% achieved in 2003/04.

4.2.11.5   Recycling facilities provided to all Hounslow residents include a weekly green garden waste
           collection service and a kerbside collection of recyclables. Residents also have access to a
           number of recycling bank sites and one active re-use and recycling centre.

4.2.11.6   The remaining 81.9% of waste is sent to the Waste Disposal Authority, West London Waste
           Authority for disposal outside of London. This is higher than the London average of 71% as
           none of the waste generated in Hounslow is currently treated in Hounslow.

           Future Baseline

4.2.11.7   Information on the amount of waste collected and the proportion of waste sent for recycling
           and composting in the borough will continue to be monitored on an annual basis. Although
           Hounslow has failed to meet its targets for the last two years, significant infrastructure
           investment has also allowed the recycling facilities at Council’s Reuse and Recycling Centre
           to expand the range of materials recycled and the capacity for existing materials. Hounslow’s
           targets for waste recycling and composting will increase to 21% by 2005/06 and 23% by
           2006/07.



                                                                                                      39
4.2.11.8   The Borough’s strategic approach is to concentrate on waste minimisation rather than       just
           recycling and composting. The continuing rises in Landfill tax, should also act as         an
           incentive for Hounslow to improve its performance on recycling and composting. The Council
           is currently examining the most appropriate way to deal with waste by     working with the
           other constituent Boroughs of the West London Waste Disposal Authorities on a Joint
           Municipal Waste Management Strategy.

4.2.11.9   When agreement has been reached, the Council will bring forward a revision to this Local
           Development Scheme detailing the scope and timetable for the joint document.




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4.2.12      Biodiversity, fauna and flora

4.2.12.1    SA Objective(s)
            12. To maintain and enhance existing biodiversity (areas of nature conservation interest,
            wildlife and habitats)

4.2.12.2    Indicators
            • Percentage of SSSIs in good condition
            • Area of LNR per 1,000 head of population
            • Achievement of Biodiversity Action Plan targets
            • Amount of land developed in any given year within areas designated for nature
                conservation

            Current Baseline

4.2.12.3    Biodiversity is a key test of sustainability. The health of habitats and living things that
            surround a community all affect people’s health and the general wellbeing of the community.
            There are many significant sites for nature conservation in and around the Borough, many of
            which support rare and important species of wildlife.

4.2.12.4    Hounslow has 33 nature conservation sites covering 749 hectares, managed either wholly or
            partly for nature conservation. This includes sites of international, regional, metropolitan and
            local importance.

4.2.12.5    Kempton Nature Reserve provides the habitat for a variety of bird species of national and
            international interest and is part of the South West London Waterbodies Special Protection
            Area (SPA). It is also a Ramsar site, which are sites formally designated as Wetlands of
            International Importance by the Secretary of State and a Site of Special Scientific Interest
            (SSSI). There is another SSSI in the Borough at Syon Park.

4.2.12.6    English Nature monitor the condition of SSSI’s and have determined that 92% of the area
            designated as SSSI’s is in “favourable” or “recovering” condition (February 2005). Favourable
            means the SSSI land that is being adequately conserved and is meeting its 'conservation
            objectives', although there is scope for the enhancement of the sites. Recovering sites are not
            yet fully conserved but all the necessary management measures are in place, and provided
            that the recovery work is sustained, the SSSI will reach favourable condition in time.

4.2.12.7    Local Nature Reserves (LNR) are sites that have been identified as areas of high value to
            nature conservation. An LNR is managed for the purposes of preserving flora and fauna, or
            geological or physiographical characteristics. English Nature suggests they can be used as
            an indicator for sustainability and that a target of 1 hectare of LNR per 1,000 head of
            population is realistic. The Borough currently has a figure of 1 hectare of LNR per 1,370
            people. This figure falls short of this target, however as a borough located in Greater London,
            this is an encouraging result and shows that conserving natural areas is of importance to the
            Council and it’s residents.

4.2.12.8    Hounslow’s Biodiversity Action Plan (HBAP) was adopted in 2003 and contains details of
            prioritised actions for protecting, conserving and enhancing wildlife and habitats in the
            borough. It incorporates Habitat Action Plans, Species Action Plans and identifies Flagship
            Species (special animals and plants that will generate interest among the public). The HBAP
            includes action plans for the borough’s different habitats and species.

4.2.12.9    Refer to Annual Monitoring Report for amount of land developed in any given year within
            areas designated for nature conservation.

            Future baseline

4.2.12.10   The Borough is proposing to:


                                                                                                           41
            •   Develop a baseline ‘State of Environment’ Report, Strategic Environmental Assessment
                and develop protocols for inclusion in Council policies
            •   Continue work with the Hounslow Local Biodiversity Partnership to complete targets and
                actions in the Local Biodiversity Action Plan 2005/06
            •   Re-evaluate the Council’s Local Agenda 21 process for incorporating guidance from the
                National Sustainable Development Strategy
            •   Implement the Air Quality Action Plan

4.2.12.11   Through implementation of policies in the Unitary Development Plan, there will be no loss in
            areas and population of biodiversity importance, or the loss of sites designated for their
            international, national, regional, and/or local significance.




                                                                                                       42
4.2.13     Cultural, heritage and landscape

4.2.13.1   SA Objective(s)
           19. To conserve and enhance the quality and character of the Borough’s landscape and
           townscape including the historic environment

4.2.13.2   Indicators
           • Number of listed buildings, scheduled ancient monuments and conservation areas
           • Buildings of Grade I and II* at risk
           • Scheduled ancient monuments at risk

           Current Baseline

4.2.13.3   The Borough has twenty-six designated conservation areas, for which Conservation Area
           Statements are being produced. There are 887 listed buildings in the borough (August 2005),
           of which are 60 of Grade I, 35 of Grade II* and 792 of Grade II status. English Heritage
           publishes a register of listed buildings at risk (BAR) lost through disrepair, vacancy or both.
           This list includes one Grade I, five Grade II* and fifteen Grade II buildings in the borough.
           English Heritage has a target to remove 23% of these buildings from their register.

4.2.13.4    Three of Hounslow’s historic houses and grounds, Osterley House, Chiswick House and
           Gunnersbury, are on English Heritage’s Register of Parks and Gardens of Special Historic
           Interest. As well as statutorily listed buildings, Hounslow has a list of 120 Buildings of Local
           Townscape Character, of which 11 have been added to the statutory list.

4.2.13.5   The borough has 12 Archaeological Priority Areas stretching across the borough and
           encompassing a variety of historic environments. There are five Scheduled Ancient
           Monuments in the Borough, detailed below,
              • Romano-British site, 910 metres west of East Bedfont Parish Church
              • Double ditched enclosure beside A30 road, 460 metres west of East Bedfont Parish
                  Church
              • Kempton Park Pumping Station, Hanworth
              • Pair of late 18th Century garden features at Tudor Court, Hanworth
              • Chiswick House, Chiswick

           Future Baseline

4.2.13.6   The Council will continue to conserve and enhance the cultural heritage and landscape of the
           borough. It will encourage, improvements to buildings on English Heritage’s register of listed
           buildings at risk.




                                                                                                              43
4.2.14     Open Spaces, Leisure and Activities

4.2.14.1   SA Objective(s)
           6. To ensure fair and equal access to services (health care, education, employment,
           shopping, transport), culture, leisure and recreation for all residents.
           13. To promote regeneration that makes use of existing assets
           14. To maintain and improve the quantity and quality of publicly accessible open spaces.

4.2.14.2   Indicators
           • Participation in cultural, leisure and recreation activities
           • Percentage of population in areas of open space deficiency
           • Amount of publicly accessible open space land including greenways and allotments
           • Proportion of the population within 400m of parks and open spaces
           • Completed development on brownfield/ greenfield sites
           • Amount of land developed in any given year within areas designated as green belt,
               metropolitan open land and local open space

           Current Baseline

4.2.14.3   Hounslow has around 2,810 hectares of open space, which include 74 public parks and
           recreation grounds. As a proportion of the Borough’s area, this is more than any other London
           borough. Please see Appendix 3 for a schedule of parks and open spaces in Hounslow.

4.2.14.4   Easy access to parks and open spaces improves resident’s quality of life and provides
           essential opportunities for informal recreation. A Residents’ Panel Survey conducted at the
           end of 2004 sought the Panels’ opinions on the use of parks and open spaces.
           Panel members identified over 80 different parks and open spaces in the borough that
           they used. Other key findings from the survey are as follows:

               •   61% used at least one park or open space in the borough, 43% used at least two and
                   25% at least three,
               •   Close to 50% said that they visit a park/open space at least once a week, of which
                   28% visited a park more than once a week and 17% about once a week.
               •   5% said that they visit a park/open space once a year or less, and
               •   69% use the open spaces they specified for fresh air, 47% to take children to play,
                   46% for casual games/walking/jogging/cycling and 40% for nature/wildlife.

4.2.14.5   There are eight sports and recreation facilities in Hounslow including two major leisure
           centres in Feltham and Brentford and local pools in Chiswick, Isleworth and Heston. Bedfont
           and some parts of Feltham currently suffer from a shortage of public recreations facilities.
           The number of visits to sports centres per 1,000 population (all activities) in 2004/05 was
           5,866 per 1,000 population, which was above the Council’s target of 5,723.

4.2.14.6   A survey of the Hounslow’s Residents Panel in November 2004 showed that just over half of
           the panel’s members take part in a sporting activity at least once week, using swimming pools
           (21%), private health clubs (16%) and leisure centres (14%). Reasons for not participating
           regularly in sport include lack of time (49%), cost (36%), quality/range of local facilities (24%)
           and lack of public transport provision (10%).

4.2.14.7   In terms of cultural facilities, there are currently 11 libraries in the borough, which received
           8,282 visits per 1,000 population during 2004/05 (BV117). The number of visits per 1,000
           population was below the Council’s target of 8,500. Information collected on museum visits
           and usage in the borough shows that in 2004/5 there were 123 visits to/usage (including
           emails and telephone enquiries) of museums per 1,000 population (BV170a). Approximately
           107 of these visits were in person (BV170b).

4.2.14.8   Refer to Annual Monitoring Report for baseline data on

                                                                                                          44
            o   completed development on brownfield/greenfield sites. Paragraph 4.2.4.9 presents a
                baseline for housing development on brownfield/green field sites
            o   amount of land designated as green belt, metropolitan open land and local open space
                (baseline)

            Future Baseline

4.2.14.9    The use of libraries, museums and sports facilities is monitored annually. The Council will
            continue to encourage the use of all its leisure and cultural facilities, and has set targets to
            increase the use and approval ratings of facilities. This will contribute to improving the quality
            of life for all residents.

4.2.14.10   The Council needs to identify the percentage of population in areas of open space deficiency
            and the proportion of the population within 400m of parks and open spaces to determine
            whether green spaces within the borough are accessible to all. This will form part of an open
            space study, as a background document to the emerging Local Development Framework.




                                                                                                           45
4.2.15     Climatic Factors

4.2.15.1   SA Objective(s)
           15. To reduce negative contributions to climate change

4.2.15.2   Indicators
           • Standard Assessment Procedure (SAP) rating for local authority owned buildings
           • Development taking place within the 1 in 100 year flood plain.
           • Carbon dioxide emissions produced by transport
           • Total new capacity of renewable energy technology installed as part of completed
               development

           Current Baseline
4.2.15.3   The UK Government’s aim, based on international agreements and targets, to reduce
           greenhouse gas emissions as fundamental to limiting climate change is carried through to the
           local level in Hounslow’s Community Plan. The plan sets a target to reduce Hounslow’s
           carbon dioxide (CO2) emissions from energy use by 20% below the 1990 levels by the year
           2010.

4.2.15.4   Buildings are by far the biggest cause of CO2 emissions in the UK and therefore it is essential
           that new and existing buildings are as energy efficient as possible. The Standard Assessment
           Procedure (SAP) is the Government's recommended system for energy rating of dwellings.
           Hounslow’s average SAP rating for local authority owned dwellings is 64 out of 120. This
           figure is above Hounslow’s set target of 54 and the Borough’s performance is in the top 25%
           for London.

4.2.15.5   The biggest source of CO2 emissions in the borough is road transport. Figure 4.4 shows a
           steady increase in carbon dioxide emissions from road transport since 2002.

           Figure 4.4: Projected emissions of CO2 from Road Transport in Hounslow

                                             Hounslow Projected Road Transport CO2 Emissions
                                             London Atmospheric Emission Inventory 2002 - GLA

                                       370
              Thousand tonnes of CO2




                                       360
                                       350
                                       340
                                       330
                                       320
                                       310
                                         2002   2003   2004   2005   2006    2007   2008   2009   2010
                                                                     years



4.2.15.6   Refer to Annual Monitoring Report for Total new capacity of renewable energy technology
           installed as part of completed development.

           Future Baseline

4.2.15.7   The West London Heatstreets initiative targets low income and vulnerable households in
           order to improve energy efficiency in their homes. A target of 1,000 homes improved per year
           is set for 2004/05 and 2005/06.

                                                                                                         46
4.2.15.8   The graph above shows that the increase in carbon dioxide emission levels from road
           transport will gradually level off. However, the impact of road traffic and associated
           greenhouse gas emissions generated from the opening of Heathrow’s Terminal 5 will need to
           be considered in future projections.




                                                                                                  47
4.2.16     Employment

4.2.16.1   SA Objective(s)

           20. To provide opportunities and benefits to the local economy especially in town
           centres, whilst having regard to the wider environment
           21. To maintain and attract new economic development that provides a range of jobs in
           appropriate locations
           22. To maintain and enhance the importance of Hounslow as an employment centre in both
           the West London and London wide context
           23. To improve accessibility for all sections of the community to jobs, education, skills training
           and life long learning

4.2.16.2   Indicators
           • Employment figures
           • Unemployment figures
           • Average weekly earnings
           • Percentage change in the total number of VAT registered businesses in the area and the
               number of new businesses forming
           • Percentage of jobs within target sectors
           • Percentage of residents commuting into and out of the borough
           • Commercial floorspace take up or percentage of vacant floor space
           • Local Pattern of industrial and office rents
           • Employment land supply by use class
           • Losses in employment land
           • Change in employment within the ‘Financial and Business services’ and ‘Hotels and
               catering’ sector in lower layer Super Output Areas that include town centres (to be
               monitored in future through AMR)
           • Change in the number employed in the borough by industry (to be monitored by number
               rather than percentage in future)
           •   Change in number of employee jobs
           •   Overall reduction in distance travelled to work (Refer to section 4.2.7 for baseline)

           Current Baseline

4.2.16.3   Hounslow has a population of 212,300 of which 66.9% are of working age (aged 16-64)
           (midyear population estimates, 2004, Nomis). 75.6% of the working age population are
           economically active (Annual Population Survey Apr 2004 – Mar 2005, Nomis). There is a net
           increase in Hounslow’s daytime population of 3.4%. This includes 27.5% of Hounslow
           residents who work and live in the borough, and 34% who are not economically active. The
           remaining 38.4% of residents work outside the borough.
4.2.16.4   The unemployment rate in the borough is low at 3.1% and is less than London (3.5%)
           (ONS/Nomis November 2005).
4.2.16.5   The average hourly pay for full-time employees living in Hounslow is £12.10. This is lower
           than the London average of £13.30 but higher than the UK average of £10.60, which reflects
           the higher cost of living within the capital.
4.2.16.6   Of those residents in employment, 16.7% were in managerial and senior official occupations,
           and 31.4% in professional and associate professional occupations. 11.7% were in
           administrative and secretarial occupations and 8.9% in skilled trade occupations. 6.3% were
           in processing occupations and 9.1% in elementary occupations. Compared with figures for
           Great Britain, a higher proportion of the Borough’s working population are employed in
           managerial and senior official, professional and associate professional occupations. However,
           it is less than the proportion working in these occupations in London. A smaller proportion of

                                                                                                          48
            the Borough’s working population are employed in process, plant and machine operatives or
            in elementary occupations compared to Great Britain, but it is higher than figures for London
            (Annual Population Survey Apr 2004 – Mar 2005, Nomis).
4.2.16.7    In 2003 (Annual Business Inquiry employee analysis), 90.4% of residents in employment
            worked in the service industries. The largest service sector employers were the distribution,
            hotel and restaurant sectors (25.1%) followed by finance, IT and business services (24.5%),
            public administration, education and health (17.9%), and transport and communications
            (14.3%). The dominance of the distribution and hotel sectors reflects the influence of
            Heathrow airport on employment opportunities in the borough. The remaining employment
            sectors are manufacturing (5.6%), construction (3.7%) and tourism-related industries (5.5%)
            (Figures include some double counting for employees who work in more than one sector).

4.2.16.8    The business structure of the borough shows that the overwhelming majority (99%) of
            workplaces are SMEs, of which 85% employ between 1 and 10 people (8,120 workplaces in
            2005). Since 2003, there has been a 5% increase in the number of workplaces of between 1
            – 10 employees (small businesses) or 392 workplaces. Whilst there has been a decrease of
            37 (4%) in the number of workplaces between 11 – 199 employees (medium sized
            businesses) (Annual Business Inquiry 2005), the overall number of small and medium sized
            enterprises (1 – 199 employees) has increased by 4% due to the increase in workplaces of 1
            – 10 employees (small businesses).

4.2.16.9    The GLA’s Industrial and Warehouse Land study (2004) shows that Hounslow has 18.8% of
            the total built industrial/warehousing floorspace in the West London sub- region. The
            Hounslow Employment Land Study (HELS) shows that the largest proportion of employment
            floorspace in the borough is used for warehousing (44.6%) with manufacturing floorspace
            making up 19.7%. In 2003, the vacancy rate for industrial and warehousing floorspace in
            Hounslow was low at 4.3% compared to the West London average of 6.2%, and London
            average of 8.2%. The HELS in 2004 had seen an increase in vacant industrial and
            warehousing to 10.5% of total floorspace.

4.2.16.10   The areas of the borough with the highest rateable values for industrial/warehouse floorspace
            are Heston Central (£94 sq m for warehouse floorspace), Cranford (£82 sq m for warehouse
            floorspace), followed by Bedfont (£81 sq m for factory floorspace), and Feltham North,
            Feltham West (both £78 sq m for warehouse floorspace). The high rental values reflect their
            close proximity and accessibility to Heathrow Airport, which has created a demand for uses
            such as freight handling and storage, distribution and airline catering.

4.2.16.11   The HELS shows that office floorspace is the second most important employment land use in
            the borough at 30.6%. The vacancy rate according to the HELS in 2004 was 10.3%. In terms
            of demand by sector, the highest demand for offices in Hounslow has been from the
            pharmaceutical, marketing and media sectors. The highest rateable values for office
            floorspace are in Bedfont (£230 sq m), Brentford (£217 sq m) and Turnham Green (£202 sq
            m) reflecting the location of prestigious office developments at Bedfont Lakes, Chiswick Park
            and the Great West Road.

4.2.16.12   In terms of floorspace, the HELS indicates that the business parks of Bedfont Lakes, Chiswick
            Park and offices on the Great West Road have a significantly higher supply of office space
            compared to the town centres. This reflects the markets of business parks providing for larger
            companies requiring purpose built space, and town centres which serve a more localised role.
            The HELS indicated that there was a particularly weak office market in the town centres in
            2004 (the exception being Chiswick) and that demand could be accommodated in these
            locations, particularly for smaller companies.

4.2.16.13   The Business Parks at Chiswick, Bedfont Lakes and offices on the Great West Road provide
            approximately 375,000 sq m of floorspace. On the Great West Road, there is a marked
            difference in offices with modern, head quarter buildings providing for international companies
            such as GSK, and other buildings which have been vacant for a period of time and under
            pressure for other uses including housing.


                                                                                                        49
4.2.16.14   In 2004/05, there was 8,334 sq m of floorspace in B1, B2 or B8 use approved for a change of
            use to residential. Of this, 2,281 sq m was B1; 3,506 sq m B2; and 2,547 sq m B8. The
            majority of floorspace lost to residential was in Isleworth and Brentford (5,621 sq m) but did
            not include any floorspace on the Great West Road.

4.2.16.15   If the change in B1, B2 and B8 floorspace based on permissions approved in 2004/05 is
            considered, there was a net increase in B1 floorspace of 37,907 sq m, which largely
            comprised Buildings 4 and 5 at Chiswick Business Park. There was a net loss of B2
            floorspace of 7,039 sq m, and net gain in B8 floorspace of 326 sq m. Note, assumptions have
            been made on a site-specific basis in calculating floorspace for permissions granted for
            flexible B use. Furthermore, the loss of B1-B8 floorspace may not result in a loss of
            employment, where a change of use is to a Sui Generis use, for example.

4.2.16.16   The Borough’s location adjacent to Heathrow and as the gateway to London has contributed
            to the development of a number of hotels in recent years. A number of hotels have been built
            close to the airport because of their function in serving the airport. This trend will continue with
            the increasing visitor numbers to London and Olympics in 2012.

            Future Baseline

4.2.16.17   The 2005 interim borough level employment projections predict that there will be an 11% rise
            in the borough’s employment levels between 2002 and 2016 from 137,000 to 152,000. This is
            revised from a GLA study of demand and supply in 2002, projecting an increase of 14.1%.
            The interim projections have not been disaggregated so for the purpose of considering the
            forecast growth by employment types, the latter is used.

4.2.16.18   Much of the projected increase in employment is in financial and business services, 37% for
            Hounslow compared with 32% for West London and 33% for London. Whilst, there is
            projected to be a decline in industrial employment, Hounslow is projected to lose 4.2% of jobs
            compared with the London average of 11.4%. This reflects the continuing strong demand for
            industrial and warehousing units close to Heathrow.

4.2.16.19   The HELS assessment of employment land and buildings shows that there is five years
            supply of vacant industrial and commercial land in the borough at current take up levels for
            employment uses. This reflects the GLA’s survey of industrial and warehousing land demand
            (2004), which found the pressure of demand for industrial land in the Borough to be high.
4.2.16.20   There are a number of unimplemented permissions for employment floorspace in the
            Borough, implementation of which would significantly increase the amount of floorspace
            available. However, the implementation of these would see a significant increase in B1 space
            and loss of both B2 and B8 floorspace. Although not all the office floorspace will be built out, it
            does demonstrate the restructuring of the market, reflecting a downturn in manufacturing, and
            growing service sectors.
4.2.16.21   There are potential structural problems for employment in the borough because of its
            relatively low industrial diversity and the current dominance of airport-related service sector
            industries. The borough will need to attract inward investment and promote business
            development to diversify its economic base.




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4.2.17     Education Participation and Skills

4.2.17.1   SA Objective(s)
           8. To improve the education and skills of the population overall

4.2.17.2   Indicators
           • Percentage of young people in higher education
           • Participation in adult education
           • Proportion of population with poor literacy and numeracy skills
           • Percentage of population with qualifications of Level 1 or lower
           • Percentage of population qualified to Level 4 (degree level)
           • Percentage of disaffected young people not in education, employment or training
           • Percentage of students achieving 5 or more A*-C GCSEs
           • Number of people aged 16 – 19 placed on apprenticeship programmes and retained for
               the first year of their course (if the course is less than one year) (To be monitored through
               Local Area Agreement – baseline not available)

           Current Baseline

4.2.17.3   Statistics from the Basic Skills Agency in 2001 showed that 23.6% of the population of
           Hounslow had poor literacy skills. These are the 2nd highest figures in the London West LSC
           areas. Amongst the wards particularly affected are Cranford (33%) and Hanworth (30%).
           The figures for poor numeracy skills follow a similar pattern.

4.2.17.4   The overall qualification levels of Hounslow’s working age population are generally lower than
           the London average. In particular the proportion of Hounslow residents with Level 4
           equivalent qualifications (NVQ4 and above e.g. HND, degree or higher degree) is 24.7%,
           approximately 6% lower than the rest of London average of 30.8%. The proportion of the
           population with Level 1 qualifications (NVQ1 and above e.g. fewer than 5 GCSEs at grades
           A-C, foundation GNVQ or equivalent) is 65.6%, also lower than the London average of
           69.7%. However, a lower proportion of the working age population have no qualifications
           (10.7%) relative to London (13.9%) and Great Britain (15.1%).

4.2.17.5   There are currently 60 primary schools, 14 secondary schools and 5 special schools in
           Hounslow. The total school population (2005 rolls) is 35,858. This is made up of 2,084
           nursery school pupils, 16,780 primary school pupils and 16,606 secondary school pupils and
           388 special school pupils. The 2005 Local Authority Pupil Ethnicity Survey showed that the
           largest ethnicity group in the Borough’s schools is White British, with 38% recorded among
           pupils who provided ethnicity details. Indian, Pakistani and Black African pupils are the next
           largest groups with 20%, 8% and 7% respectively.

4.2.17.6   In 2004/5 the percentage of pupils in schools maintained by the local authority achieving five
           or more GCSEs at grades A*-C or equivalent was 52.4%. This is lower than the national
           average of 53.7%, but approximately 6% higher than the 2000 figure for Hounslow of 46.5%.

4.2.17.7   Hounslow has one further education institution (West Thames College) and 12 adult
           education institutions. The London West Learning and Skills Council (LWLSC) provides
           funding for further education provision in the borough. The LWLSC Needs Assessment 2004
           identified 4,446 learners in further education and adult education institutions in the borough in
           2002/3. In 2004/5 the number of enrolments on adult education courses per 1,000 population
           was 82.6. At the time of the 2001 census 3.6% (7,610) of people living in Hounslow were in
           higher education. Of this total, 3,035 (39.8%) were non-mature students.

4.2.17.8   The Hounslow Community Plan raises concerns about the growing number of disaffected
           young people (16-18 year olds) not in education, employment or training) in the borough. In
           December 2004, 372 (6.18%) of 16-18 year olds were not in education, employment or


                                                                                                         51
            training (Source: Crime and Drugs Audit 2004 London Borough of Hounslow, Hounslow
            Community Safety Partnership).

            Future Baseline

4.2.17.9    The overall number of learners on further education courses and the number of enrolments
            per 1,000 population will be monitored by LWLSC and the Council. There has been a slight
            decrease in the number of people enrolled onto further education courses over the last two
            years, but this reflects the long-term strategy of LWLSC of providing longer courses at higher
            levels. Thames Valley University have also been granted planning permission for the
            construction of a new campus within the borough. The campus will include 12,029 square
            metres of education floorspace and 849 student study rooms. Once complete, this
            development will significantly increase the student population of the borough and provide new
            opportunities for residents to access higher education courses.

4.2.17.10   The percentage of pupils achieving grades A*-C is increasing although it continues to be
            lower than the national average. The adult population of Hounslow has been shown to be
            relatively low skilled, and poor educational attainment amongst school leavers could
            exacerbate the current skills shortage. There is concern that not enough residents have the
            skills and qualifications to compete for better paid and more secure jobs in the borough.
            Furthermore, if residents cannot meet the skill requirements of employers in the borough, an
            increasing number of people from outside the borough will be appointed to fill vacancies. This
            may increase levels of unemployment and deprivation amongst residents and increase
            congestion as people are forced to travel longer distances to their place of work.




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4.3   Main social, environmental and economic issues and problems identified

      Topic         Sustainability   Supporting Evidence and Potential Significant Impacts                                          Source                    Related SA
                    Issues                                                                                                                                    Objective
      Social
      Population    Large working    Majority (68%) of the population is of working age 16-65.                                      Census 2001, Office       20, 21, 22
                    age population   Potential significant impacts:                                                                 for National Statistics
                                          Increase in the attractiveness of the area for inward investment by new companies         (ONS) (review of
                                          Increase in local job opportunities would reduce the need for local residents to travel   baseline information)
                                          long distances to work
                    Growing          From 2003 to 2028 there is an overall increase in the projected population of Hounslow         ONS - 2003-based          3, 6, 10, 11,
                    population       just over 10,000 people (approximately 5% of the current population). The projected            population projections    15, 16, 17
                                     population increases do not take account of new residential developments in progress and       (review of baseline
                                     in the pipeline                                                                                information)
                                     Potential significant impacts:
                                        Increase in housing development
                                        Increase in social infrastructure requirements and services
                                        Increase in waste production and need for waste management facilities
                                        Possibly decrease in air quality
                                        Possibly more travel by car leading to traffic congestion
      Population    Aging            The 45-64 age group is expected to increase by 11,300 (20%) between 2003 and 2028.             ONS - 2003-based          1, 6
      projections   population       The 65-74 age group is expected to increase by 4,800 (27%) between 2008 and 2028.              population projections
                                     The 75+ age group is expected to increase by 3,500 (25%) between 2008 and 2028.                (review of baseline
                                                                                                                                    information)
                                     Potential significant impacts:
                                        Increase in health services for the older age groups
                                        Increase in demand for residential accommodation for the elderly
                    Decrease in      The under 15-age group is expected to decrease by 3,200 (9%) between 2003 and 2013.            ONS - 2003-based          6
                    under 15         However after these dates there are increases projected for this age group to 2028 of 900      population projections
                    population       people.                                                                                        (review of baseline
                                                                                                                                    information)
                                     Potential significant impacts:
                                         Change in demand for childcare facilities
                                         Change in infrastructure requirements


                                                                                                                                                              53
Topic         Sustainability   Supporting Evidence and Potential Significant Impacts                                   Source                   Related SA
              Issues                                                                                                                            Objective
                                   Change in demand for school places
                                   Change in demand for leisure facilities for this age group
              Significant      The 15-24 age group is expected to decrease by 3,400 (11%) between 2003 to 2028.        ONS - 2003-based         6
              decrease in      Potential significant impacts:                                                          population projections
              15-24                                                                                                    (review of baseline
                                   Change in demand for social infrastructure
              population                                                                                               information)
                                   Possible change in demand for post secondary/further education and training
                                   Change in need for student accommodation
Ethnicity &   Ethnic mix       According to the 2001 census, there were 74,587 people (35%) living in LB of Hounslow   Census 2001, ONS         3, 4, 6, 7, 23
Religion                       from minority ethnic communities, the largest group representing 17% is Indian. The     (review of baseline
                               borough has a higher number of non-white ethnic minority residents (35%) compared to    information)
                               outer London (25%) and London (29%), and significantly higher than England (9%).
                               Within Hounslow, the Central Hounslow (53%) and Heston and Cranford areas (63%)
                               have the largest of non-white residents compared to others.
                               Potential significant impacts:
                                   Increase in the need to raise awareness of the benefits of community cohesion
                                   Increase in cultural requirements (community facilities e.g. places of worship)
                                   Different demands on education requirements
                                   Possibly differences in jobs and types of employment
                                   Possibly differences in housing need requirements
                                   Possibly differences in transport requirements relating to culture
                                   Possibly differences in shopping facilities and buying habit requirements
              Religion         The Census 2001 found 52% of residents said they were Christian, but there were         Census 2001, ONS         4, 6, 7, 23
                               significant proportions of the population who were Muslim (9%), Sikh (9%) and Hindu     (review of baseline
                               (8%).                                                                                   information)
                               Potential significant impacts:
                                   Increase in the need to raise awareness of the benefits of community cohesion
                                   Increase in cultural requirements (e.g. places of worship)
                                   Increase in diversity of schools that have religious affiliation
                                   Address any differences in education needs
                                   Possibly differences in transport requirements relating to culture
              Ethnic           The Asian population is primarily located in the Central Hounslow (30%) and Heston &    Census 2001, ONS         3, 4, 6, 7, 23
              concentration    Cranford (37%) areas, the African and Caribbean population in the located in Heston &   (review of baseline

                                                                                                                                                54
Topic         Sustainability   Supporting Evidence and Potential Significant Impacts                                        Source                   Related SA
              Issues                                                                                                                                 Objective
              in certain       Cranford (5%) and Isleworth & Brentford (5%) areas.                                          information)
              wards            Potential significant impacts:
                                   Decrease in community cohesion
                                   Increase in social infrastructure requirements
                                   Possibly differences in housing need requirements
                                   Possibly an impact on schools in the areas
Ethnic        Projected        The number of minority ethnic elders (aged 65 years or more) in Hounslow is expected to      ONS - 1991-based         1, 3, 4, 6
population    increase in      increase from 3,877 in 2001 to 4,991 in 2006 – an increase of 29%.                           population projections
projections   ethnic elders                                                                                                 (review of baseline
                               Potential significant impacts:
                                                                                                                            information)
                                   Increase in opportunities for enhanced community leadership
                                   Possibly differences in housing need requirements and use of housing stock
                                   Possibly differences in health services requirements
Refugee       Large number     In Hounslow there are estimated to be between 7,100 – 8,200 refugees (3.3% - 3.9% of         Research in 2001         1, 3, 4, 6, 7,
population    of refugees      the population). Hounslow’s refugee population is increasing and there are refugee           undertaken by            23
                               families and single individuals throughout the borough, with concentrations in central       Michael Bell
                               Hounslow, Isleworth and Feltham.                                                             Associates and MORI
                                                                                                                            for Renewal (review
                               Potential significant impacts:
                                                                                                                            of baseline
                                   Potential difficulties in accessing services due to language differences
                                                                                                                            information)
                                   Potential for economic exclusion because of difficulties in understanding legal issues
                                   and business support services.
                                   Increase in social infrastructure requirements
                                   Possible difference in the demand for health service provision
                                   Increase in housing requirements
                                   Increase in education and training needs
                                   Increase in different education requirements
Languages     Diversity of     The LB Hounslow community speaks over 120 languages. A 2003 survey showed that               Hounslow Community       4, 6, 8
              languages        Hounslow’s pupils speak a rich diversity of languages with an estimated 133 different        Plan 2004 - 2007,
              spoken           languages spoken. The highest percentage is English (53%), then Punjabi (12%), Urdu          London West
                               (6%) and Gujarati (3%).                                                                      Learning and Skills
                                                                                                                            Council, (review of
                               Potential significant impacts:
                                                                                                                            policies, plans and
                               Potential significant impacts:
                                                                                                                            programmes (PPPs)
                                   Difficulties in understanding/engagement and access to services due to language

                                                                                                                                                     55
Topic          Sustainability   Supporting Evidence and Potential Significant Impacts                                     Source                  Related SA
               Issues                                                                                                                             Objective
                                    differences                                                                           and baseline
                                    Increase in the need to raise awareness of the benefits of community cohesion         information)
                                    Potential social exclusion
Human Health   High mortality   The Standardised Mortality Rates (SMRs) over 100 represent a higher death rate than       London Health           1, 6
               rate for all     England and Wales, and below 100 represent a lower death rate. Hounslow’s overall         Observatory, October
               ages             mortality rate (SMR= 107) for all ages, 1998-2002 is significantly higher than Outer      2004 (review of
                                London (SMR= 97), London (SMR= 100) and England (SMR= 100). Also the death rate           baseline information)
                                from all circulatory disease is significantly higher in the borough than Outer London,
                                London and England.
                                Potential significant impacts:
                                    Increase in need for enhanced targeted health education
                                    Increase in targeted health services
               Decrease in      Female life expectancy in LB Hounslow is 79.8 years, and has decreased from 80.0 years    London Health           1, 6
               female life      in 1999-2001 - a –0.2% decrease, whereas positive increases in life expectancy were       Observatory, October
               expectancy       seen in London and England.                                                               2004 (review of
                                Potential significant impacts:                                                            baseline information)
                                    Increase in need for enhanced targeted health education
                                    Increase in targeted health services
               High             Deaths before 75 years of age overall are significantly higher in Hounslow. Hounslow’s    London Health           1, 6
               premature        overall premature mortality rate (SMR= 111) is significantly higher than Outer London     Observatory, October
               mortality rate   (SMR= 96), and higher than London (SMR= 104) and England (SMR = 100). The death           2004 (review of
                                rate from all circulatory disease is significantly higher than Outer London, London and   baseline information)
                                England.
                                Potential significant impacts:
                                    Increase in need for enhanced targeted health education
                                    Increase in targeted health services
Crime          High overall     Total crime per 1,000 in comparison to those boroughs considered ‘most similar’ to        Crime and Drug Audit    1, 2, 4, 9, 18,
               crime            Hounslow. Hounslow had one of the higher crime rates; the average crime rate was 121      2004 (review of PPPs    20
                                crimes per 1,000 people compared with Hounslow’s figure of 131 crimes.                    and baseline
                                Potential significant impacts:                                                            information)
                                    Decrease in community cohesion
                                    Decrease in viability of businesses e.g. Town Centres

                                                                                                                                                  56
Topic        Sustainability    Supporting Evidence and Potential Significant Impacts                                       Source                 Related SA
             Issues                                                                                                                               Objective
                                    Increase in use of design to reduce crime
                                    Possibly an effect on health of residents
             High violent      The 18% increase in violent crime offences from 2001/02 to 2002/03, was a significant       Crime and Drug Audit   2, 4, 9, 20
             crime rate        rise. However, 2004/05 showed a 3% decrease in violent crime offences from the              2004 (review of PPPs
                               previous year.                                                                              and baseline
                               Potential significant impacts:                                                              information)
                                    Decrease in community cohesion
                                    Possibly a negative effect on economic well being e.g. Town Centres
             Fear of crime     The results of Hounslow’s Community Safety Partnership survey show that in the borough      Hounslow Community     1, 2, 4, 9, 20
                               as a whole, 80% of residents felt very/fairly safe outside during the day compared to the   Plan 2004 - 2007,
                               London average of 82%.

                               Potential significant impacts:
                                    Decrease in community cohesion
                                    Decrease in quality of life
                                    Possibly a negative effect on economic well being e.g. Town Centres
                                    Possibly an effect on the health of residents
Housing &    Homelessness      Homelessness is a significant problem in the borough. At the end of March 2004 there        Housing Strategy –     1, 3, 6, 7
Households                     were 1328 homeless households in LB Hounslow of this amount 1145 homeless                   Housing Investment
                               households contained dependent children or a pregnant woman, and 116 homeless               Programme 2003-
                               households were in bed and breakfast accommodation. Hounslow has not met its targets        2006 (review of
                               for the average length of stay in bed and breakfast or hostel accommodation of homeless     PPPs)
                               households.
                               Potential significant impacts:
                                    Increase in housing stock requirements
                                    Increase in social services requirements
                                    Increase in health services and possibly differences in requirements
             Significant new   In 2004/05, 570 new homes were completed in 2004/05, which is significantly above the       The London Plan -      1, 3, 4, 6, 7,
             house building    target of 470 set out in the London Plan. Housing projections show a high rate of housing   Spatial Development    9, 11, 13, 14,
                               development in the borough with 1,015 new dwellings per year over the next four years.      Strategy for Greater   16, 17, 18,
                               From 2009-2014 annual projected housing development will be 493 per year, which will        London (2004)          19, 20
                               continue to meet the London Plan target.                                                    (review of PPPs)
                               Potential significant impacts:


                                                                                                                                                  57
Topic   Sustainability   Supporting Evidence and Potential Significant Impacts                                     Source                Related SA
        Issues                                                                                                                           Objective
                            Increase in the need to raise awareness of the benefits of community cohesion
                            Increase in need for housing mix
                            Increase in social and environmental infrastructure requirements and services
                            Increase in health services and possibly differences in requirements
                            Increase in use of design, quality and materials for new build
                            An additional demand for local goods, as well as leisure, cultural and entertainment
                            facilities
                            Possibly increase potential for provision of a local labour force with new skills
        Need for an                                                                                                Housing Strategy –    1, 3, 4, 6, 7,
        increase in      Hounslow has a significant level of need for affordable housing. In 2004/05, 35% of new   Housing Investment    9, 18
        affordable       homes were affordable, below the 50% Borough wide target set in local and regional        Programme 2003-
        housing          policy.                                                                                   2006 (review of
                         Potential significant impacts:                                                            PPPs)
                             Increase in the need to raise awareness of the benefits of community cohesion
                             Increase in housing stock requirements
                             Increase in social services requirements
                             Increase in health services and possibly differences in requirements
                             Increase in use of design, quality and materials for new build
        Households       Hounslow contains 31.8% of households with dependent children. This is slightly higher    Census 2001, ONS      3, 6
        containing       than comparators – Outer London (31.1%), London (29.0%) and England & Wales               (review of baseline
        dependent        (29.5%).                                                                                  information)
        children         Potential significant impacts:
                             Increase in housing requirements
                             Increase in need for housing mix
                             Increase in social services requirements
        Housing tenure   17.2% of households rent from the Council, 6% from Housing Association or Registered      Census 2001, ONS      3, 4
                         Social Landlord (RSL) and 60% of households are owner occupied. A higher proportion of    (review of baseline
                         homes are rented from the Council compared with Outer London (11.6%), London (17.1%)      information)
                         and England & Wales (13.2%).
                         Potential significant impacts:
                             Increase in the need to raise awareness of the benefits of community cohesion
                             Increase in housing requirements
                             Increase in need for housing mix


                                                                                                                                         58
Topic             Sustainability   Supporting Evidence and Potential Significant Impacts                                         Source                  Related SA
                  Issues                                                                                                                                 Objective
                  Overcrowding     Overcrowding of homes in Hounslow is a concern. There were 1-2 rooms too few for              Census 2001, ONS        3, 6, 18
                                   16.2% of households. This is significantly greater than Outer London (12.4%) and              (review of baseline
                                   England & Wales (6.9%), and is close to that of London (17.3%).                               information)
                                   Hounslow also had a larger average household size of 2.51 than Outer London, London
                                   and England & Wales and had a greater percentage of 3 or more people living in
                                   households in comparison to London and England and Wales. However in comparison to
                                   household size and the number of people living in households, Hounslow had a lower than
                                   average number of rooms per household of 4.73, in comparison to Outer London (4.99),
                                   London (4.68) and England & Wales (5.34). This is likely to explain the extent of
                                   overcrowding.
                                   Potential significant impacts:
                                       Increase in housing requirements, needs
                                       Increase in need for housing mix
                                       Increase in use of design, quality and materials for new build or extensions
                                       Increase in social services requirements
Social            Social           Community Cohesion is a significant challenge and this priority is critical for Hounslow as   Meeting the             3, 4, 6, 7, 9,
Inclusiveness &   exclusion        a borough. Hounslow is a Community of communities, but it is only when we have sincere        Challenge, Hounslow     23
Accessibility                      commitment to Community Cohesion that we can resolve problems and reflect the social,         Community Plan 2004
                                   cultural and religious needs of all our communities in Hounslow. Community Cohesion           - 2007, Executive
                                   goes beyond the concept of race equality and social inclusion. It is about the celebration    Business Plan (review
                                   of diversity and a common sense of belonging for all communities. It lies at the heart of a   of PPPs)
                                   safe and strong community.
                                   Potential significant impacts:
                                        Increase in the need to raise awareness of the benefits of community cohesion
                                        Increase in social exclusion
                                        Increase in anti-social behaviour
                                        Decrease in understanding/engagement due to language differences
                                        Potential increase in need for community and cultural facilities
                  Areas of         There are notable and persistent areas of deprivation in the wards of Bedfont, Brentford,     Indices of Multiple     1, 3, 4, 6, 7,
                  Deprivation      Hanworth, Heston West and Syon. The Indices of Deprivation 2004 shows areas of                Deprivation 2004        8, 9, 23
                                   deprivation within many of the wards in the borough and 3 areas in Hounslow are in the        (review of baseline
                                   top 10% most deprived areas in England. These are located in Feltham West, Hanworth           information)


                                                                                                                                                         59
Topic           Sustainability    Supporting Evidence and Potential Significant Impacts                                       Source                   Related SA
                Issues                                                                                                                                 Objective
                                  and Isleworth.
                                  Potential significant impacts:
                                      Decrease in community cohesion
                                      Increase in housing requirements, needs
                                      Increase in social services requirements
                                      Increase in different education requirements
                                      Increase in health services and possibly differences in requirements
                                      Possibly a need for local employment opportunities
                                      Possibly a need for targeted training
                School            The following ethnic groups have the highest school exclusion rates – travellers of Irish   Hounslow Primary         4, 6, 7, 8, 23
                exclusion rates   heritage, mixed heritage: white and black Caribbean; black and black British: Caribbean;    Care Trust, 2004,
                for ethnic        and any other black.                                                                        Annual Public Health
                groups            Potential significant impacts:                                                              Report 2004, pp.10-
                                      Decrease in community cohesion                                                          12 (review of baseline
                                      Decrease in career/employment choices                                                   information)
                                      Increase in different education requirements
Noise           Noise levels      Road traffic congestion and flights in and out of Heathrow airport contribute to the        Draft SEA of Local       1, 5, 10, 15,
                                  significant levels of noise experienced in the borough.                                     Implementation Plan      16
                                  Potential significant impacts:                                                              (review of baseline
                                      Decrease in health                                                                      information)
                                      Decrease in air quality
                                      Increase in the number of sensitive sites
Environmental
Transport       The car is the    The car is the main mode used to travel to work and this is expected to continue. The         London Area              1, 5, 10,
                main mode of      percentage of people travelling to work by car in Hounslow is 54%. This percentage is         Transport Survey         15, 16
                travel to work    significantly higher in comparison to Outer London 45% and London 36%. Hounslow is            2001 & Census 2001
                                  ranked 7 out of 33 (32 London boroughs and the City of London).                               (review of baseline
                                  Potential significant impacts:                                                                information)
                                      Decrease in health
                                      Decrease in air quality
                                      Increase in noise
                                      Increase in traffic congestion
                                      Increase in emissions

                                                                                                                                                       60
Topic   Sustainability      Supporting Evidence and Potential Significant Impacts                                           Source                    Related SA
        Issues                                                                                                                                        Objective
        Walking has         The proportion of Hounslow residents using public transport to travel to education was 28%        London Area               1, 5, 10,
        decreased           in 2001. Use of the bus (21%) and travelling as a car passenger (28%) for education trips         Transport Survey          15, 16
        significantly for   had increased significantly between 1991 and 2001. The percentage of trips made by                1991 & 2001 (review
        education trips     walking (37%) had significantly declined from 50% in 1991.                                        of baseline
                            Potential significant impacts:                                                                    information)
                                 Decrease in health
                                 Decrease in air quality
                                 Increase in noise
                                 Increase in emissions
        Average trip        In 2001 the average trip length or distance of trips made in Hounslow was 5.56km, while the       London Area               10
        length              averages for Greater London and Central London were 5.46km and 4.47km respectively                Transport Survey
                            (these are estimates based on the 2001 London Area Transport Survey). The majority of             2001 (review of
                            trips made in Hounslow were between 0 and 1km in length. Short trip distances make it             baseline information)
                            feasible for Hounslow residents to walk, cycle or use the bus for their journeys. Mixed use
                            developments in the Borough may increase the potential for local residents to use more
                            sustainable methods of transport
                            Potential significant impacts:
                                Increase in modal split towards more sustainable transport modes
        Increasing          Traffic flows are increasing and are expected to rise further. This is the trend for Outer        Department for            1, 5, 10,
        traffic flows       London where traffic flows have also been increasing, whereas the trend for Inner London          Transport’s National      15, 16
                            shows traffic flows have been decreasing. Mixed-use developments may increase the                 Road Traffic Survey
                            potential for residents to use more sustainable methods of transport. However, traffics flows     1993-2002 (review of
                            are largely affected by the Borough’s location adjacent to the main strategic road link           baseline information)
                            between central London and Heathrow airport. Local initiatives alone cannot significantly
                            address the increase in traffic volumes.
                            Potential significant impacts:
                                Decrease in health
                                Decrease in air quality
                                Increase in noise
                                Increase in traffic congestion
                                Increase in emissions
        High level of       A considerable number of households (46%) in the borough have one car and this is                 Census 2001, ONS          1, 5, 10,

                                                                                                                                                      61
Topic   Sustainability     Supporting Evidence and Potential Significant Impacts                                         Source                     Related SA
        Issues                                                                                                                                      Objective
        car ownership      expected to rise further. Hounslow also has a slightly higher number of households with one     (review of baseline        11, 15, 16
                           car in comparison to Outer London (45%), London (43%) and England and Wales (44%).              information)
                           Potential significant impacts:
                                Decrease in health
                                Decrease in air quality
                                Increase in noise
                                Increase in emissions
        Poor public        Access to public transport is measured using Public Transport Accessibility Levels (PTAL)       Transport for London       5, 6, 10,
        transport          scores. The majority of the borough has below average to very poor PTAL scores apart from                                  11, 15, 16,
        accessibility      Central Hounslow and areas around Feltham, Hounslow West, Hounslow Central, Hounslow                                       23
        levels             East, Gunnersbury, Turnham Green and Stamford Brook stations that show above average
                           to very good PTAL scores.
                           Potential significant impacts:
                                Difficulties in accessing services
                                Increase in noise
                                Increase in emissions
                                Increase in traffic congestion
Air     Poor air quality   It has been agreed by the Council’s Executive to declare a borough-wide Air Quality             Draft Air Quality          1, 10, 11,
                           Management Area, as pollutant levels are likely to exceed maximum allowable levels in           Action Plan (review of     15, 16, 18,
                           2005.                                                                                           baseline information)      19
                           Significant impacts:
                                Decrease in health
                                Decrease in air quality
                                Increase in emissions
                                Increase in damage to buildings
                                Possibly increase in use of design, quality and materials
Water   Areas of risk of   The Environment Agency’s flood risk assessment has determined that there are parts of the      Environment Agency         3, 9, 11,
        flooding           borough that are in flood warning areas (as determined by the Environment Agency). These       online maps from           12, 18, 19
                           areas are:                                                                                     website (review of
                                along the length of the River Crane in the west of the borough in the Cranford and        baseline information)
                                Feltham areas,
                                along parts of the River Brent and Grand Union Canal in the east of the borough in the
                                Brentford area, and


                                                                                                                                                    62
Topic           Sustainability   Supporting Evidence and Potential Significant Impacts                                          Source                    Related SA
                Issues                                                                                                                                    Objective
                                      along the length of the Thames in the east of the borough covering extensive areas of
                                      Isleworth, Syon, Brentford and Chiswick.
                                 These areas are identified on the Flood Zone Maps produced by the Environment Agency.
                                 Potential significant impacts:
                                      Decrease in water quality
                                      Increase the risk of damage to housing
                                      Increase the risk of damage to transport & infrastructure
                                      Increase the risk of damage to the historic environment
                                      Possibly negative effects on biodiversity, fauna & flora
                                      Possibly increase in use of design, quality and materials
Waste           Recycling and    In Hounslow for 2003/2004, 14.2% of waste was recycled and 1.5% of waste composted.             Best Value                11, 13, 17
                composting       The amount of waste recycling has shown a slight increase between 2002/2003 and                 Performance
                                 2003/2004. However, Hounslow did not meet its target for 2003/2004 of 14.5% of waste            Indicator (BVPI)
                                 recycled and 3% of waste composted.                                                             information (review of
                                 Potential significant impacts:                                                                  baseline information)
                                      Increase in the amount of waste sent to landfill
                                      Increase in land take for waste facilities an estimated 40ha sub-regionally
Biodiversity,   Condition of     Need to show improvement in condition of SSSIs to meet governments PSA target. The              English Nature            9, 12
Fauna & Flora   Sites of         government’s public service agreement (PSA) target on SSSIs is to have 95% in favourable        (review of baseline
                Special          or recovering condition by 2010. Hounslow’s current situation is that 92% of the 42 hectares    information)
                Scientific       designated as SSSIs currently have this this status.
                Interest         Potential significant impacts:
                (SSSIs)               Decrease in biodiversity, fauna & flora
                Amount of        English Nature suggests that they can be used as an indicator for sustainability and that a     (review of baseline       1, 6, 12, 14
                Local Nature     target of 1 hectare of LNR per 1,000 head of population is realistic. Hounslow currently has    information)
                Reserve (LNR)    a figure of 1 hectare of LNR per 1,370 head of population. This figure falls short of this
                                 target.
                                 Potential significant impacts:
                                    Decrease in total area of open space
                                    Decrease in access to open space for recreation
                                    Decrease in health
                                    Decrease in biodiversity, fauna & flora
                Significant      There is a need to protect the seven nature conservation areas identified within and around

                                                                                                                                                          63
Topic          Sustainability    Supporting Evidence and Potential Significant Impacts                                           Source                   Related SA
               Issues                                                                                                                                     Objective
               sites of nature   the BAAP area
               conservation
               within the        Potential significant impacts:
               BAAP area             Decrease in total area of open space
                                     Decrease in access to open space for recreation
                                     Decrease in health
                                     Decrease in biodiversity, flora and fauna
Cultural       Listed            The boroughs collate and English Heritage publishes a register of listed buildings at risk       English Heritage BAR     9, 13, 19
Heritage &     buildings at      (BAR) of loss through disrepair, vacancy or both. The 2005 register includes six buildings in    Register (review of
Landscape      risk              the Borough one Grade I, and five Grade II* “buildings”.                                         baseline information)
                                 Potential significant impacts:
                                     Decrease in cultural heritage & landscape in the borough
Open Spaces,   Use of arts and   The results from BVPI information for museum visits and usage in the borough show that in        BVPI information         6, 20
Leisure and    culture           both cases visits and usage has increased, however visitation and usage targets were not         (review of baseline
Activities     facilities        met in 2003/04 and the targets set for achievement in 2005/06 and 2006/07 may be too             information)
                                 ambitious at the current rate of increase.
                                 Potential significant impacts:
                                     Decrease in access to culture
                                     Decrease in tourism - opportunities & benefits to local economy
               Areas of Open     There are a number of areas with the Borough that do not have convenient access to public        Borough Planning         6, 9, 12, 14
               Space             open space (i.e. more than 400 metres from the nearest park or open space)                       Office
               Deficiency
                                 Potential significant impacts
                                     Decrease in total area of open space
                                     Decrease in access to open space for recreation
                                     Decrease in health
                                     Decrease in biodiversity, flora and fauna
Climatic       Increase in       The main source of carbon dioxide is from combustion of fossil fuels i.e. through electricity    London Atmospheric       15
Factors        carbon dioxide    generation and vehicle emissions. Transport has been the fastest growing source of carbon        Emissions Inventory
               emissions         dioxide in the UK because of the increases in road traffic and although vehicles have            (2002) (review of
                                 become more fuel efficient, there has been an increase in the number of vehicles on the road     baseline information)
                                 and this is expected to increase. Buildings are also the biggest cause of carbon dioxide
                                 emissions in the UK.


                                                                                                                                                          64
Topic         Sustainability   Supporting Evidence and Potential Significant Impacts                                              Source                 Related SA
              Issues                                                                                                                                     Objective
                               Hounslow’s emissions for carbon dioxide from road transport are projected to increase.
                               Potential significant impacts:
                                   Increase in climatic change
                                   Increase in emissions
Economic
Economic      Town centre      Major developments are set to increase the vitality and viability of three of the key town          Community Plan        6, 9, 11, 18,
Development   redevelopment    centres of Brentford, Feltham and Hounslow.                                                         (review of PPPs)      19, 20, 21,
                               Potential significant impacts:                                                                                            22, 23
                                   Increase in use of design, quality and materials
                                   Increase in access to services
                                   Increase in local economy
                                   Increase in employment opportunities
                                   Possibly decrease in distance needed to travel
Employment    Types of         Thousands of Hounslow’s residents are employed in Gateway industries such as transport,             Census 2001, ONS      10, 20
              employment       aviation, accommodation, catering, and high tech companies. Logistics and freight                   (review of baseline
              and reliance     movement are key components in this sector, with DHL and airline subsidiaries amongst the           information)
              on the Airport   local leading players. Heathrow airport is another significant employer.
              economy
                               Potential significant impacts:
                                    Decrease in local economy
                                    Possibly differences in travel to work patterns
              Achieving an     There are vacant office/industrial sites e.g. Great West Road, in the Borough which have           Hounslow               6, 20, 21, 22,
              appropriate      been subject to pressure for alternative uses. From evidence on demand and supply in the           Employment Land        23
              balance in       Hounslow Employment Land Study 2004, there is currently 5 years of employment land to              Study
              Land supply      meet current demand. Given the limited supply and study by the GLA into industrial
                               capacity, the Borough should take a restrictive approach to the release of employment
                               sites. It is important that strategically and locally important industrial/warehousing sites and
                               offices are protected to maintain an appropriate balance.

                               Potential significant impacts:
                                   Maintain employment opportunities
                                   Increase in local economy
                                   Possibly decrease in distance needed to travel Possible decrease distance need to


                                                                                                                                                         65
Topic   Sustainability   Supporting Evidence and Potential Significant Impacts                                         Source                Related SA
        Issues                                                                                                                               Objective
                              travel to work
        Location of      The high level of vacancy in town centres and location of offices in less accessible          Hounslow              6, 20, 21, 22,
        high trip        locations suggests that there is a need for the net release of office floorspace. Some        Employment Land       23
        generating       offices have a strategic or local function and should be protected, whilst offices in other   Study
        uses (offices)   areas may be released subject to criteria to direct high trip generating uses to more
        in appropriate   accessible locations
        locations
                         Potential significant impacts:
                             Increased use of public transport
                             Decrease in emissions to air, noise and contributions to climate change
        Visitor          A number of hotels have been completed in the Borough in recent years contributing to         London Development    20,21,22,23
        accommodatio     Hounslow’s role as a gateway to London, and reflecting the influence of Heathrow. A           Database
        n                number of hotels have been given planning permission in close proximity to Heathrow (in
                         out of centre locations) raising the issue of whether it is appropriate to allow more hotel
                         development in out of centre locations serving the airport
                         Potential significant impacts:
                         • Increase in employment opportunities
                         • Contributions to local economy
                         • Increase in economic growth
                         • Possible increase in distance need to travel to work where hotels are located close to
                             the airport
                         • Increased emissions to air, noise and contributions to climate change
        Service-led      90.4% of residents in employment worked in the service industries. The largest service        Census 2001, ONS      21, 22, 23
        economy          sector employers were the distribution, hotel and restaurant sectors (25.1%) followed by      (review of baseline
                         finance, IT and business services (24.5%), public administration, education and health        information)
                         (17.9%), and transport and communications (14.3%). The dominance of the distribution
                         and hotel sectors reflects the influence of Heathrow airport on employment opportunities in
                         the borough. The remaining employment sectors are manufacturing (5.6%), construction
                         (3.7%) and tourism-related industries (5.5%) (Figures include some double counting for
                         employees who work in more than one sector).
                         Potential significant impacts:
                             Change in local economic diversity
        Business         The business structure of the borough shows that the overwhelming majority (99%) of           ABI inquiry 2005      20, 21, 22, 23

                                                                                                                                             66
Topic             Sustainability   Supporting Evidence and Potential Significant Impacts                                          Source                   Related SA
                  Issues                                                                                                                                   Objective
                  structure        workplaces are SMEs, of which 85% employ between 1 and 10 people (8,120 workplaces
                                   in 2005). Since 2003, there has been a 5% increase in the number of workplaces of
                                   between 1 – 10 employees (small businesses) or 392 workplaces. Whilst there has been a
                                   decrease of 37 (4%) in the number of workplaces between 11 – 199 employees (medium
                                   sized businesses) (Annual Business Inquiry 2005), the overall number of small and
                                   medium sized enterprises (1 – 199 employees) has increased by 4% due to the increase in
                                   workplaces of 1 – 10 employees (small businesses).
                                   Potential significant impacts:
                                        Change in local economic diversity
                  Low pay          The average hourly pay for full-time employees living in Hounslow is £12.10. This is lower     West London              1, 3, 4, 6, 7,
                                   than the London average of £13.30 but higher than the UK average of £10.60, which              Learning and Skills      8, 20, 21, 22,
                                   reflects the higher cost of living within the capital.                                         Council, 2002,           23
                                   Potential significant impacts:                                                                 Hounslow: Annual
                                        Decrease in access to services                                                            Business Inquiry
                                        Decrease in community cohesion                                                            (review of baseline
                                        Increase in social services                                                               information)
                                        Increase in health services
                                        Increase in housing requirements, needs
                                        Increase in education and training need
                  Unemployment     The unemployment rate in the borough is low at 2.4% (working age claimants actively            West London              1, 3, 4, 6, 7, 8
                                   seeking work of at least 40 hours a week; claimant count with rates and proportions,           Learning and Skills      21, 22, 23
                                   December 2005), and is less than London (3.4%) (December 2005).                                Council, 2002,
                                   Potential significant impacts:                                                                 Hounslow: Annual
                                        Decrease in access to services                                                            Business Inquiry
                                        Decrease in economic growth                                                               (review of baseline
                                        Decrease in community cohesion                                                            information)
                                        Increase in social services
                                        Increase in health services
                                        Increase in housing requirements, needs
                                        Increase in education and training need
Education         Ethnic profile   The total school population (2005 rolls) is 35,858. The 2005 Local Authority Pupil Ethnicity   Pupil Ethnicity Survey   4, 6, 7, 8, 23
Participation &   of school        Survey showed that the largest ethnicity group in the Borough’s schools is White British,      2003/04 (review of
Skills            pupils           with 38% recorded among pupils who provided ethnicity details. Indian, Pakistani and           baseline information)


                                                                                                                                                           67
Topic   Sustainability    Supporting Evidence and Potential Significant Impacts                                        Source                 Related SA
        Issues                                                                                                                                Objective
                          Black African pupils are the next largest groups with 20%, 8% and 7% respectively.


                          Potential significant impacts:
                              Decrease in understanding/engagement due to language differences
                              Decrease in community cohesion
                              Increase in different education requirements
                              Increase in diversity of schools that have religious affiliation
                              Increase in cultural requirements and facilities
                              Possibly differences in school educational achievements
        Performance in    Hounslow school results show an improvement in all ages in recent years. However             Department for         4, 6, 8, 20,
        schools           further improvement is needed to meet the national average. In 2004/5 the percentage of      Education and Skills   21, 22, 23
                          pupils in schools maintained by the local authority achieving five or more GCSEs at grades   Performance tables
                          A*-C or equivalent was 52.4%. This is lower than the national average of 53.7%.              (review of baseline
                          Potential significant impacts:                                                               information)
                               Decrease in economic growth
                               Decrease in community cohesion
                               Decrease in career/employment choices
                               Increase in different education requirements
        Literacy and      Statistics from the Basic Skills Agency in 2001 showed that 23.6% of the population of       West London            8, 20, 21, 22,
        numeracy skills   Hounslow had poor literacy skills. These are the 2nd highest figures in the London West      Learning and Skills    23
                          LSC areas. Amongst the wards particularly affected are Cranford (33%) and Hanworth           Council, 2002,
                          (30%). The figures for poor numeracy skills follow a similar pattern.                        Hounslow: Annual
                          Potential significant impacts:                                                               Business Inquiry
                               Decrease in economic growth                                                             (review of baseline
                               Decrease in career/employment choices                                                   information)
                               Increase in education and training need
        Disaffected       There is much concern in the borough about disaffected young people not in education,        (review of baseline    2, 3, 6, 8, 20,
        young people      employment or training. In December 2004, 372 or 6.18% of these young people were not        information)           21, 22, 23
        not in            in education, employment or training. In 2003, it had been 7%.
        education,
                          Potential significant impacts:
        employment or
                              Decrease in economic growth
        training
                              Decrease in career/employment choices

                                                                                                                                              68
Topic   Sustainability    Supporting Evidence and Potential Significant Impacts                                           Source                Related SA
        Issues                                                                                                                                  Objective
                              Decrease in access to services
                              Increase in social services
                              Increase in housing requirements, needs
                              Increase in education and training need
                              Possibly an increase in anti-social behaviour
        Adults with low   The borough also has a considerable number of adult residents with low-level                    West London           3, 6, 8, 20,
        level             qualifications of level 1 or lower. The 4 wards in the whole of the London West area (123       Learning and Skills   21, 22, 23
        qualifications    wards) with the highest proportion of adults with low-level qualifications are in Hounslow, -   Council, 2002,
                          Hanworth (56.2%), Feltham West (54.6%), Feltham North (54.3%)and Bedfont (53.4%).               Hounslow: Annual
                          The average figure for London is 36.7%.                                                         Business Inquiry
                                                                                                                          (review of baseline
                          Potential significant impacts:
                                                                                                                          information)
                              Decrease in economic growth
                              Decrease in community cohesion
                              Decrease in career/employment choices
                              Decrease in access to services
                              Increase in housing requirements, needs
                              Increase in adult education need
        Population        The overall qualification levels of Hounslow’s working age population are generally lower       Census 2001, ONS      8, 20, 21, 22,
        qualified to      than the London average. In particular the proportion of Hounslow residents with Level 4        (review of baseline   23
        degree level      equivalent qualifications (NVQ4 and above e.g. HND, degree or higher degree) is 24.7%,          information)
                          approximately 6% lower than the rest of London average of 30.8%.
                          Potential significant impacts:
                              Decrease in economic growth
                              Decrease in career/employment choices
                              Increase in further education need




                                                                                                                                                69
4.4     Limitations of the Information and assumptions made
4.4.1   In preparation of the Sustainability Appraisal Scoping Report, Adopted in September 2005,
        the existing and future social, economic and environmental baseline including indicators and
        targets were collated from a range of sources including other departments within the Council,
        and external agencies.

        Limitations

4.4.2   A limitation in collating information has been the absence of a corporate monitoring system.
        Information has generally been available for indicators. However, there are a large number of
        objectives and indicators relevant to the work of different sections of the Council, Local
        Strategic Partnership and other external agencies, which do not have related targets.

4.4.3   This is due in some instances to the lack of monitoring information available as well as
        difficulties in monitoring change, particularly for environmental objectives where the change in
        quality of an area is not measurable.

4.4.4   A further limitation is the baseline from primary or secondary sources in that the data may
        have a degree of error due to how figures were calculated or the source of the information.
        For example, population projections whilst providing an indication of the future population do
        not include all development in the pipeline (unimplemented planning permissions).

        Assumptions

4.4.5   In producing this Sustainability Appraisal and in considering the potential social,
        environmental and economic effects of the policy options a number of assumptions have
        been made. The key assumptions are listed below.

        •   That broadly speaking there will be no major change to existing national or regional
            planning policy guidance. This takes in the major approaches to developing sustainable
            communities, reducing the need to travel, focusing high trip generating development in
            locations accessible by public transport, accommodating growth whilst protecting the
            green belt and MOL etc.
        •   Notwithstanding the point made above, there is an assumption made that the importance
            given to the issue of climate change is likely to increase. This is acknowledged in terms
            of emphasis rather than assumptions about future policy initiatives.
        •   It is assumed that there will be no significant advances in reducing pollutants from fuel.
        •   Heathrow will continue to increase in terms of passenger numbers. The locational
            advantages for business of being close to Heathrow will continue. There will be no
            significant advances in quieter aircraft.
        •   There will be no significant new transport infrastructure in the Borough.
        •   There is scope for improved service frequency and better links to transport hubs and
            stations
        •   Many people will still rely on using private cars for transport although uses of sustainable
            modes will steadily increase.
        •   There will continue to be pressure for residential development on existing employment
            land.
        •   Existing town centres will continue to be the main location for retail and leisure floorspace.
        •   The development industry will increasingly embrace mixed-use development.
        •   The need for affordable housing will continue or increase especially in terms of larger
            units.
        •   The health of the economy and unemployment levels will be maintained.
        •   The Borough will continue to be an ethnically diverse community and Community
            cohesion will remain a key priority for the Council.
        •   There is an increasing need to deal with our own waste.
        •   Listed buildings, areas of townscape character, and other historic assets will continue to
            be protected

                                                                                                      70
        •   Development will e resisted in the green belt and metropolitan open land
        •   Open space will be protected

4.4.6   Assumptions made in preparation of the DPD and the flexibility of policies to deal with change
        is addressed in the Council’s Soundness Self Assessment (Soundness test 9 – The DPD is
        reasonably flexible to enable it to deal with changing circumstances).




                                                                                                   71
4.5   The SA framework, including objectives, indicators and targets (Source: SA Scoping Report September 2005)
      Refer to Section 7.2 for proposals to monitor the significant effects arising from the DPD.

      Sustainability Appraisal Objectives, Indicators and targets
      SA Objective                           Indicators                                Targets

      Social
      1 To maintain and/or improve the             Death rate - Standardised               By 2010 to reduce inequalities in health outcomes by 10 per cent as
      health of the population in the              Mortality Rates (SMR’s) for all         measured by infant mortality and life expectancy at birth (National
      borough                                      ages and for deaths before 75           PSA target Health Inequalities)
                                                   years of age
                                                   Direct Standardised Death Rate
                                                   (DSDR) for all ages and for
                                                   deaths before 75 years of age
                                                   from circulatory disease, CHD
                                                   and cancer
                                                   Life expectancy
                                                   % of people who describe their
                                                   health as good
      2 To reduce crime and the fear of            Recorded crimes per 1,000           By 2007/08, Hounslow Community Safety partnership aims to
      crime                                        population                              achieve a 20% reduction in recorded crime
                                                   Domestic burglaries per 1,000           reduce the fear of crime in all areas of the borough and among
                                                   households                              vulnerable groups;
                                                   Violent offences committed per          increase the confidence in the Criminal Justice System by bringing
                                                   1,000 population                        more offenders to justice;
                                                   Fear of crime                           make sure young people at risk of offending do not enter the Criminal
                                                                                           Justice System;
                                                                                           prevent re-offending by making perpetrators
                                                                                           address their offending behaviour.
                                                                                       Community Safety Strategy (2005 – 2008)
      3 To ensure that everyone has the            Homelessness and temporary              Max. 3 people sleeping rough on a single night within the Borough for
      opportunity to live in a decent,             accommodation                           each year to 2007/09 (BV202)
      sustainably constructed and                  Housing completion figures              % of non-decent Local Authority homes to be reduced to 0 by end of
      affordable home.                             Affordable housing completion           2005/06
                                                   figures                                 Complete a minimum of 470 new residential units per year of which
                                                   Overcrowding figures including          an overall target of 50% is sought to be affordable to 2016
                                                   average household size and


                                                                                                                                                                   72
                                          number of rooms per household
4 To improve opportunities for            Percentage of people who feel        Target not available
developing community cohesion             that their local area is a place
through increasing understanding          where people from different
and learning between our many             backgrounds and communities
communities                               can live together harmoniously
                                          Voluntary activity
5 To reduce as far as practicable         Noise levels from road traffic       0% of LA homes are non-decent by end of 2005/06. This includes
noise from all sources                    Noise levels from air traffic –      adequate noise insulation against external noise (where external
                                          LEQ contours                         noise is a problem).
                                          Method of travel to work             Reduction in travel to work by private car

6 To ensure fair and equal access to      Residents/households defined         Place 400 people from disadvantaged groups into sustainable
services (health care, education,         as within a distance of 500m         employment by April 2006 (Community Plan)
employment, shopping, transport),         (15 minutes walk) of key local       By 2007/08, 55% of authority buildings are open to the public in which
culture, leisure and recreation for all   services                             all public areas are suitable for and accessible to disabled people
residents                                 Households without a car             (BV156)
                                          Percentage of total length of        No net loss of social and community facilities including existing
                                          footpaths and other rights of        religious meeting places (Policies C.1.1, C.1.3, and C.6.1 of UDP)
                                          way, which were easy to use by       Each year until 2007, 90% total length of footpaths and other rights of
                                          members of the public                way should be easy to use by members of the public (BV178)
                                          Percentage of local authority        All new residential development within 30 minutes public transport
                                          buildings open to the public in      time of areas of employment
                                          which all public areas are
                                          suitable for and accessible to
                                          disabled people
                                          PTAL scores
                                          Participation in cultural, leisure
                                          and recreation activities
                                          Percentage of population in
                                          areas of open space deficiency
                                          Amount of new residential
                                          development within 30 minutes
                                          public transport time of areas of
                                          employment




                                                                                                                                                         73
7 To reduce discrimination and          Indices of Multiple Deprivation      The Local Government Equality Standard to increase by one point
promote equality of opportunity and     Proportion of population who         each year, to a target of 4 by 2007 (BV 2a)
fair treatment for all of our           live in wards that rank within the   74% Race Equality Scheme criteria to be met by 2007, in order to
communities                             most deprived 10% in the             promote Race Equality (BV 2b)
                                        country                              The borough should continue to follow the CREs code of practice for
                                                                             rented housing and good practice standards for social landlords on
                                                                             tackling harassment (BV 164)
                                                                             By 2007, no more than 190 racial incidents to be recorded by the
                                                                             authority per 100,000 population per year (BV 174)
8 To improve the education and skills   Percentage of young people in        56% of 15 year olds in LEA schools to achieve 5+ GCSEs Grades A*-
of the population overall               higher education                     C by 2007 (BV 38)
                                        Participation in adult education     Ratio of the percentage of 19 year old former care leavers who were
                                        Proportion of population with        engaged in employment, education or training to the percentage of all
                                        poor literacy and numeracy           19 year olds in the population who were engaged in employment,
                                        skills                               education or training to reach 0.77 by 2007 (BV 161)
                                        Percentage of population with        Increasing number of people aged 16 – 19 placed on apprenticeship
                                        qualifications of Level 1 or lower   programmes and retained for the first year of their course thereafter
                                        (no)                                     2006/07 150
                                        Percentage of population                 2007/08 300
                                        qualified to Level 4 (degree             2008/09 450
                                        level)
                                        Percentage of disaffected
                                        young people not in education,
                                        employment or training
                                        Percentage of Students
                                        Achieving 5 or more A*-C
                                        GCSEs
                                        Number of people aged 16 – 19
                                        placed on apprenticeship
                                        programmes and retained for
                                        the first year of their course (if
                                        the course is less than one
                                        year)
9 To improve the quality of where       Percentage of residents who          Increase in the proportion of residents ‘very satisfied’ or ‘fairly
people live                             are satisfied with their             satisfied’ with their neighbourhood as a place to live
                                        neighbourhood as a place to
                                        live

                                                                                                                                                     74
Environmental
10 To minimise the need to travel,      Mode of travel to work            Increase in travel by sustainable modes of transport (including
increase the use of sustainable         Average trip length/distance of   Underground, metro, light rail or tram; Train; Bus, minibus or coach;
transport modes (walking, cycling       trips                             Bicycle; On foot)
and public transport) and reduce        Car ownership                     No permissions granted which exceed parking standards
reliance on the car                     Traffic flows                     Green travel plan provided for all schemes providing employment for
                                        Density of development            100 or more.
11 To ensure the quantitative and       Contaminated land                 BV106. 85% new homes to be built on previously developed land by
qualitative conservation of resources   Loss of greenfield land           2007, rising from 80% in 2006
(soil, mineral aggregates, water,       Percentage of main rivers and     No planning permissions granted contrary to the advice of the EA
energy)                                 canals with good or fair
                                        biological and chemical water
                                        quality
                                        Developments incorporating
                                        renewable energy.
                                        Number of planning
                                        permissions for B class uses
                                        granted contrary to the advice
                                        of the Environment Agency
                                        (EA) on either floor defence
                                        grounds or water quality
12 To maintain and enhance existing     Percentage of SSSIs in good       English Nature target of at least 1 hectare of Local Nature Reserve per
biodiversity (areas of nature           condition                         1,000 head of population.
conservation interest, wildlife and     Achievement of Biodiversity       No development within SSSIs (Policy ENV-N.2.1, UDP)
habitats)                               Action Plan targets               Biodiversity Action Plan targets to be achieved by 2008
                                        Area of LNR per 1,000 head of     No net loss in areas designated for nature conservation
                                        population
                                        Net loss in the number or area
                                        of Sites of Importance for
                                        Nature Conservation (SINCS)
                                        Amount of land developed in
                                        any given year within areas
                                        designated as nature
                                        conservation
13 To promote regeneration that         Vacancy levels of commercial      100 private sector vacant dwellings to be returned into occupation or
makes use of existing assets            properties                        demolished as a direct result of action by the local authority, per year
                                        Completed on brownfield sites     until 2007 (BV 64)

                                                                                                                                                     75
                                                                       85% new homes to be built on previously developed land by 2007,
                                                                       rising from 80% in 2006 (BV 106)
                                                                       100% of all completed B class development on brownfield sites
14 To maintain and improve the        Amount of publicly accessible    No development on the greenbelt (Policy ENV-N.1.2, UDP),
quantity and quality of publicly      open space land including        metropolitan open land (Policy ENV-N.1.11, UDP) or land open space
accessible open spaces                greenways and allotments         (Policy ENV-N.1.2, UDP) incl. playing fields, private open space, or
                                      Proportion of the population     allotments and leisure gardens
                                      within 400m of parks and open    No net loss in areas designated for green belt, metropolitan open land
                                      spaces                           and local open space
                                      Amount of land developed in
                                      any given year within areas
                                      designated as green belt,
                                      metropolitan open land and
                                      local open space
15 To reduce negative contributions   SAP rating for local authority   Energy Efficiency: The average Standard Assessment Procedure
to climate change                     owned buildings                  (SAP) rating of local authority owned dwellings (not new
                                      Development taking place         developments) to reach 66 per year until 2007 (BV 63)
                                      within the 1 in 100 year flood   Community Plan target to reduce Hounslow’s carbon dioxide (CO2)
                                      plain.                           emissions from energy use to 20% below the 1990 levels by the year
                                      Carbon dioxide emissions         2010
                                      produced by transport            Planning permission granted in floodplains contrary to Environment
                                      Total new capacity of            Agency advice
                                      renewable energy technology      Increase in capacity of renewable energy technology installed as part
                                      installed as part of completed   of completed development
                                      development
16 To improve air quality in the      NOx levels                       Aim to reduce NO levels in the borough to meet the standard of
borough                               PM10 levels                      40mg/m3 set in National Air Quality Strategy (Air Quality Action Plan)
                                      Method of travel to work         PM10 target set by EU, of no more than 35 days per year with
                                                                       particulate matter levels greater than 50μg/m³.
                                                                       Reduction in travel to work by private car
17 To minimise the production of      Amount of waste collected by     Number of kilograms of household waste collected per head
waste                                 type                             population to reduce to 400kg by 2007 (BV 84)
                                      Percentage of waste recycled     Percentage of the total tonnage of household waste which has been
                                      Percentage of waste              recycled to reach 24% by 2007 (BV 82A)
                                      composted                        Percentage of the total tonnage of household waste which has been
                                      Amount of waste disposed of in   sent for composting or for anaerobic digestion to reach 4.7% by 2007
                                      landfill                         (BV82b)


                                                                                                                                                76
18 To promote high quality urban       Design award scheme               To achieve an average SAP rating for local authority owned dwellings
design and the use of sustainable      Percentage of new build and       of 66 annually until 2007 (BV 63)
building materials where appropriate   retrofit homes meeting
                                       EcoHomes “very good” or
                                       “excellent” standard
                                       The number of large
                                       developments incorporating
                                       SuDS
19 To conserve and enhance the         Number of listed buildings,       No loss of conservation areas (Policy ENV-B.2.1, UDP)
quality and character of the           scheduled ancient monuments       No loss of listed buildings and buildings of local townscape character
Borough’s landscape and townscape      and conservation areas            (Policies ENV-B.2.4 and ENV-B.2.6 of UDP)
including the historic environment     Buildings of grade I and II* at   No loss of scheduled ancient monuments (Policy ENV-B.3.1, UDP)
                                       risk
                                       Scheduled ancient monuments
                                       at risk
Economic
20 To provide opportunities and        New industrial and commercial     Increase in employment within ‘Financial and Business services’ and
benefits to the local economy          floorspace approved and           ‘Hotels and catering’ sector in lower layer Super Output Areas that
especially in town centres, whilst     completed, including proportion   include town centres
having regard to the wider             of high trip generating uses in
environment                            town centres
                                       Percentage change in the total
                                       number of VAT registered
                                       businesses in the area or
                                       number of new businesses
                                       forming
                                       Employment figures
                                       Unemployment figures
                                       Change in employment within
                                       the ‘Financial and Business
                                       services’ and ‘Hotels and
                                       catering’ sector in lower layer
                                       Super Output Areas that
                                       include town centres
21 To maintain and attract new         New industrial and commercial     GLA draft Industrial Capacity Study benchmark that West London can
economic development that provides     floorspace approved and           accommodate the loss of 41 ha of industrial land between 2001 and
a range of jobs in appropriate         completed                         2016, equating to 7ha for Hounslow (if divided equally between 6
locations                              Losses in employment land to      boroughs).

                                                                                                                                                  77
                                           other uses                          Growth in employment in at least 5 industries
                                           Percentage of jobs within target
                                           sectors
                                           Percentage of residents
                                           commuting into and out of LBH
                                           Commercial floor space take up
                                           or percentage of vacant floor
                                           space
                                           Percentage of vacant retail floor
                                           space
                                           Change in the number
                                           employed in the borough by
                                           industry
22 To maintain and enhance the             New industrial and commercial       Growth in employment in the Borough
importance of Hounslow as an               floorspace approved and
employment centre in both the West         completed
London and London-wide context             Employment Land Supply by
                                           type
                                           Change in number of employee
                                           jobs
23 To improve accessibility for all        Percentage of work trips            Ratio of the percentage of 19 year old former care leavers who were
sections of the community to jobs,         undertaken by means other           engaged in employment, education or training to the percentage of all
education, skills training and life long   than the car                        19 year olds in the population who were engaged in employment,
learning                                   Average weekly earnings             education or training to reach 0.77 by 2007 (BV 161)
                                           Level of unemployment               Place 400 people from disadvantaged groups into sustainable
                                           New industrial and                  employment by April 2006 (Community Plan)
                                           commercial floorspace               Overall reduction in distance travelled to work
                                           approved and completed,
                                           including proportion of high
                                           trip generating uses in town
                                           centres
                                           Average distance travelled to
                                           work




                                                                                                                                                       78
Testing the Internal compatibility of the Sustainability Objectives

                 SA Objectives
                                      1                                             Key:
                                 1        2
                                 2    +       3
                                                                                    +          Positive impact
                                                                                    -          Negative impact
                  Social         3    +   +       4
                                                                                    0          No relationship between objectives
                                 4    +   +   +       5                             ?          Impact but not known
                                 5    +   0   +   0       6
                                 6    +   +   +   +   +       7
                                 7    +   +   +   +   0   +       8
                                 8    +   +   +   +   +   +   +       9
                                 9    +   +   +   +   +   +   +   0       10
                                 10   +   +   0   +   +   +   +   0   +        11
                                 11   0   0   ?   0   +   0   0   0   +   +         12
                                 12   0   0   ?   0   +   0   0   0   +   ?    +         13
                                 13   +   +   +   +   -   +   +   +   +   +    +    +           14
              Environmental      14   +   +   ?   +   0   +   +   0   +   -    +    +      +         15
                                 15   +   0   ?   0   +   ?   ?   0   +   +    +    +      +     +        16
                                 16   +   0   ?   0   +   ?   +   0   +   +    ?    +      ?     +   +         17
                                 17   0   0   +   0   0   0   0   0   +   0    +    0      ?     0   +    +         18
                                 18   +   +   +   0   +   +   +   0   +   +    +    0      +     0   +    +    +         19
                                 19   0   0   ?   0   +   ?   0   0   +   +    ?    ?      +     +   ?    +    0    +         20
                                 20   +   +   +   +   ?   +   ?   +   +   +    +    0      +     +   +    ?    ?    +    +         21
                                 21   +   +   ?   0   +   +   +   +   +   +    +    0      +     +   +    ?    -    +    +    +         22
              Economic           22   0   +   ?   +   -   ?   ?   +   ?   ?    -    ?      +     ?   ?    -    -    +    ?    ?    +         23
                                 23   +   +   +   +   ?   +   +   +   +   +    +    0      +     0   0    0    0    0    0    +    +    +




                                                                                                                                                  79
Social                                     Environmental                            Economic
1 To maintain and/or improve the           10 To minimise the need to travel,       20 To provide opportunities and
health of the population in the borough    increase the use of sustainable          benefits to the local economy
                                           transport modes (walking, cycling and    especially in town centres, whilst
                                           public transport) and reduce reliance    having regard to the wider environment
                                           on the car
2 To reduce crime and the fear of          11 To ensure the quantitative and        21 To maintain and attract new
crime                                      qualitative conservation of resources    economic development that provides a
                                           (soil, mineral aggregates, water,        range of jobs in appropriate locations
                                           energy)
3 To ensure that everyone has the          12 To maintain and enhance existing      22 To maintain and enhance the
opportunity to live in a decent,           biodiversity (areas of nature            importance of Hounslow as an
sustainably constructed and affordable     conservation interest, wildlife and      employment centre in both the West
home.                                      habitats)                                London and London-wide context
4 To improve opportunities for             13 To promote regeneration that          23 To improve accessibility for all
developing community cohesion              makes use of existing assets             sections of the community to jobs,
through increasing understanding and                                                education, skills training and life long
learning between our many                                                           learning
communities
5 To reduce as far as practicable noise    14 To maintain and improve the
from all sources                           quantity and quality of publicly
                                           accessible open spaces
6 To ensure fair and equal access to       15 To reduce negative contributions to
services (health care, education,          climate change
employment, shopping, transport),
culture, leisure and recreation for all
residents
7 To reduce discrimination and             16 To improve air quality in the
promote equality of opportunity and fair   borough
treatment for all of our communities
8 To improve the education and skills      17 To minimise the production of waste
of the population overall
9 To improve the quality of where          18 To promote high quality urban
people live                                design and the use of sustainable
                                           building materials where appropriate
                                           19 To conserve and enhance the


                                                                                                                               80
quality and character of the Borough’s
landscape and townscape including the
historic environment




                                         81
5.0     Plan issues and options
5.1     Main strategic options considered and how they were identified
5.1.1   The Employment DPD options emerged from the following

        1. Consultation on employment related issues (August 2004)

5.1.2   The Council identified 10 potential ‘key issues’ in the form of questions that the employment
        options may need to address. These were presented to consultees who were asked to
        prioritise each question with a score between 1 and 4 (1 being the highest priority and 4 the
        lowest). The consultation sought to ensure that the community agreed with the issues
        identified or to identify issues that were missing.

5.1.3   The issues identified in the questionnaire included the following:

                •   amount of employment land required and which sites should be protected
                •   need for improving skills, job opportunities in the borough
                •   the location and accessibility to employment for residents
                •   the impacts on the environment of business and the need for mitigating effects
                •   the role of tourism in the borough including locations for hotel acccommodation
                •   the role of Heathrow in the local economy
                •   sites and premises which may be appropriate for alternative uses

5.1.4   Sixty-four questionnaires were received. More than fifty percent of respondents considered
        that all but one of the issues identified had a priority of 1 or 2. The one issue that more than
        fifty percent of respondents gave a 3 or 4 priority to was

                Hotels / Tourism – Is there sufficient visitor accommodation in the Borough? If not,
                where are the most appropriate locations for new hotel development?

5.1.5   Between fifty and sixty nine percent of respondents considered that the remaining issues had
        a priority of 1 (high) or 2. The Council has sought to address the ten issues in the options that
        followed. How the issues informed the options is presented in section 5.3 - table on pages 84
        - 94.

        2. New guidance

5.1.6   The amendment to Planning Policy Guidance 3 ‘Supporting the delivery of housing’ (New
        paragraph 42 (a) of PPG3) in January 2005 placed the onus on the Local Authority to
        demonstrate the need for retaining land allocated for industrial or commercial uses and
        redundant land or buildings in industrial or commercial use. The Council therefore needed to
        review the land currently allocated for employment and from which options were presented on
        the supply of industrial land and offices (Topics 3 and 6 of Options consultation
        questionnaire).

5.1.7   Planning Policy Statement 6 (March 2005) in making reference to hotels as a town centre use
        (unlike PPG6) necessitated the review the UDP policy on visitor accommodation.

        3. General conformity with the London Plan

5.1.8   The London Plan adopted in February 2004 requires ‘Boroughs to identify Strategic
        Employment Locations in UDP and develop local policies for employment sites outside SELs’
        (Policies 2A.7 and 3B.5). The Draft SPG on Industrial Capacity (September 2003) provides
        further guidance on the implementation of the SEL framework proposed by the Mayor.
        Paragraph 6.6 states that boroughs should designate on UDP Proposals Maps those sites of
        particular local importance, which they wish to protect for industrial users.

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5.1.9    The Employment DPD provides the first opportunity for the Council to formally identify
         Strategic Employment Locations and Locally Significant Industrial Sites. It was therefore
         necessary to present options on the sites that should be designated.

         4. Implementation of policies

5.1.10   From the application of employment objectives and policies to proposals for new
         development, the release and protection of employment land, there was a number of issues
         arising in the implementation of policies for example,

                 •   the need to differentiate between offices and light industrial uses in policy terms
                 •   determining whether reuse for employment is unlikely
                 •   definition of high trip generating uses and employment generating uses
                 •   demand for hotel development in the vicinity of Heathrow

         5. Community Plan (2004 - 2007)

5.1.11   In promoting and developing the social, economic and environmental well-being of our
         communities, the Community Plan (2004 – 2007) sought to help residents get the most from
         local employment opportunities. As a means for delivering objectives in the Community Plan
         through spatial planning, there was a need to consider options on the employment
         opportunities that should be provided and Hounslow’s employment role.

         6. Market pressure for change

5.1.12   The Hounslow Employment Land Study 2004 provided evidence that there was a high level of
         office vacancies in town centres. Vacant office buildings in out of centre locations were also
         indicative of an over-supply of office floorspace in the Borough. Options were presented in
         consultation that sought to determine whether there was ‘market’ consensus on the issue
         (Question 3: Supply of offices).

5.1.13   Given there was a supply-demand imbalance and the need to review the existing stock in light
         of the update to PPG3, options were presented on where new demand should be directed,
         where offices should be ‘released’ to other uses and locations where existing offices should
         be protected. Whilst government guidance supports a town centre led approach, there was a
         need to consider other options for the location of new office development and intensification
         of existing offices given the historic role of out of centre locations including the Great West
         Road and Bedfont Lakes.

5.1.14   In terms of industrial demand, the Hounslow Employment Land Study 2004 supported the
         need for limited net release of industrial land. There was however a need to draw opinion
         from the market on the issue and consider whether there was sufficient demand to
         accommodate current and future growth (in the plan period). Options were also presented on
         how the Council manage the supply of industrial land to and the public’s views on the future
         role of existing industrial estates/ sites.

5.1.15   As referred to under ‘New guidance’ above, hotels are specifically referred to in PPS6.
         However, there has been increasing demand for the development of hotels close to
         Heathrow. Whilst there was no evidence to support an option of allowing hotels in an out of
         centre location, the Council sought to understand views of the community on whether sites/
         an area should be allocated for hotels.




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5.2     Comparison of the social, environmental and economic effects of the
        options
5.2.1   The options consulted on in June 2005 were appraised against 23 sustainability Appraisal
        objectives developed in the Sustainability Appraisal Scoping Report 2005.
        The appraisal of the options is presented in Appendix 5 and undertaken on a four-point scale
        from possible conflict to positive compatibility. Where potential sustainability issues arise
        these are discussed in more detail in supporting tables.

5.2.2   Through undertaking the appraisal of options, the Council has been able to consider the
        impacts of different options and this has assisted in the preparation of the preferred options.
        Section 5.42 to 5.4.16 outlines the reasons some options were taken forward and others were
        not including consideration of the positive/ negative impacts of options in achieving
        sustainability objectives.




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5.3     How social, economic and environmental effects were considered in
        choosing the preferred options
5.3.1   The following table explains how the Council developed options from which developed
        preferred options and which led to the submission version of the Employment Development
        Plan Document. It also outlines the impacts on sustainability objectives of the options and
        preferred options considered in the preparation of the document and how these were
        addressed.

5.3.2   The progression from preferred options to objectives and policies in the DPD is also provided
        in Appendix 4 to the SA report. The appraisal shows that the objectives and policies in the
        DPD are a refinement of the preferred options including more detailed policy wording or
        refined criteria. For these reasons, a further Sustainability Appraisal (SA) has not been carried
        out in addition to the work in the Employment Development Plan Sustainability Appraisal
        report (January 2006) with the exception of the vision, which did not form part of the preferred
        options consultation document.




                                                                                                     85
Issues                      Options                     Findings of the initial      Preferred options         Findings of the              Submission DPD
                                                        sustainability appraisal                               Sustainability appraisal
                                                                                                               for preferred options
Issue of whether there is   Options on whether          Need to improve quality      Pref option 3 sought      The more efficient use of    Objective 2, Policy E1
the right amount of land    there is a sufficient       of existing offices          balance in supply/        land has positive effects    seek to provide capacity
                            supply of offices (Q3)      requires less use of         demand through more       in terms of resource use     to accommodate growth
                                                        resources relative to new    efficient use of land     and regeneration of          through the protection of
                                                        development and                                        existing sites for more      sites whilst allowing
                                                        therefore less negative                                appropriate uses.            managed release
                                                        effects. However,                                      Through seeking an
                                                        increase in supply may                                 appropriate balance in
                                                        be inefficient use of land                             supply/ demand there
                                                        and development has                                    are also positive
                                                        negative effects on                                    economic effects and
                                                        resource use.                                          potential for other uses,
                                                                                                               thus allowing for
                                                                                                               improvements in
                                                                                                               accessibility to services.
Issue of whether there is   Options on whether          Whilst the release of        Pref option 6 sought an   Retaining capacity to        Objective 2, Policy E1
the right amount of land    there is a sufficient       industrial land could        appropriate’ balance in   accommodate demand           seek to provide capacity
                            supply of industrial land   have negative effects        supply/ demand with       and restricting release is   to accommodate growth
                            (Q6)                        against economic             restricted release        beneficial to the            Sites are protected to
                                                        objectives, an increase                                economy and ensures          maintain capacity whilst
                                                        in supply has negative                                 the effective use of land.   allowing managed
                                                        environmental effects                                  This is positive in terms    release
                                                        from the use of                                        of resource use and
                                                        resources                                              through ensuring supply
                                                                                                               is in appropriate
                                                                                                               locations, there can be
                                                                                                               wider benefits from
                                                                                                               sustainable travel for
                                                                                                               example.

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Issues                Options                      Findings of the initial      Preferred options          Findings of the                Submission DPD
                                                   sustainability appraisal                                Sustainability appraisal
                                                                                                           for preferred options
Issue of what sites   Options on where offices     Options to protect offices   Pref option 5d sought to   Through protecting             Policy E1 seeks to
should be protected   (Q5d) should be              in locations not             protect sustainable        offices in unsustainable       protect sites of strategic
                      protected                    accessible by                locations including        locations, the preferred       and local significance
                                                   sustainable modes of         strategic important        option is continuing to        Policy EP2
                                                   transport has negative       locations on Great West    allow travel by private        Town centres, Great
                                                   environmental effects        Road, at Bedfont Lakes     vehicle and the                West Road, Bedfont
                                                   whilst protecting offices    and Chiswick Park          associated effects on air      Lakes (requiring longer
                                                   in town centres/ edge of                                quality, noise and             period of marketing than
                                                   centre locations has                                    climate change.                for other locations)
                                                   positive or no impact                                   However, there are             Policy EP3 Chiswick
                                                   against SA objectives                                   positive effects of            Park
                                                                                                           employment for local
                                                                                                           communities and on the
                                                                                                           local economy. Through
                                                                                                           not allowing further
                                                                                                           development in
                                                                                                           unsustainable locations
                                                                                                           the Council is seeking to
                                                                                                           minimise any further
                                                                                                           increase in negative
                                                                                                           environmental effects
Issue of what sites   Options on which             Option to protect            SEL boundaries defined     Criteria for determining       Policies EP6 and EP7
should be protected   industrial sites should be   strategic and locally        (3 SELs) and 37 estates    sites as locally significant   seek to protect SELs and
                      designated (Q.8a)            significant sites has        defined as LSISs (Q.8a)    is based on site               LSIS as designated on
                                                   positive effects against                                characteristics, the           the submission map
                                                   economic objectives and                                 environment,
                                                   whilst the mechanism of                                 accessibility and
                                                   designating a site does                                 location. The criteria
                                                   not change the existing                                 which are primarily
                                                   environment, their                                      employment based result
                                                   location requires                                       in negative impacts on


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Issues                    Options                    Findings of the initial     Preferred options            Findings of the               Submission DPD
                                                     sustainability appraisal                                 Sustainability appraisal
                                                                                                              for preferred options
                                                     movement by private                                      air quality, climate
                                                     vehicles which may                                       change and potentially
                                                     impact on the                                            noise. This reflects the
                                                     environment                                              inherent conflict between
                                                                                                              economic and
                                                                                                              environmental
                                                                                                              objectives. However
                                                                                                              criteria include ‘potential
                                                                                                              for movement of freight/
                                                                                                              people by sustainable
                                                                                                              modes’, ‘accessibility by
                                                                                                              sustainable modes’ and
                                                                                                              ensuring no detrimental
                                                                                                              impacts on noise
                                                                                                              sensitive uses thus
                                                                                                              seeking to avoid the
                                                                                                              inclusion of sites as LSIS
                                                                                                              that may have negative
                                                                                                              effects.
Issue of what                                        In the appraisal of         Objective 1 and Pref         Providing diversity has       Objective 1 and Policy
characteristics defines   Through differentiating    options, both offices and   option 2 sought to           positive effects in           E4 seek to encourage a
different sectors, the    between offices and        industrial uses have        encourage diversity in       improving the range of        range of business
premises required and     industrial land in the     positive effects in         the size of businesses,      opportunities for             activities to avoid over-
benefits from sector      options paper, the         benefiting the local        sectors/ industries and      employment/ training          reliance on any one
                          Council sought to define   economy, whilst having      employment uses.             and as a consequent,          sector, thus promoting
                          the types of premises      negative effects against                                 enhancing Hounslow’s          diversity in the local
                          necessary to               environmental criteria      In the preferred options,    role as an employment         economy.
                          accommodate different      subject to location. This   the Council differentiated   centre.
                          sectors                    reflects the inherent       between industrial land                                    The differentiation
                                                     conflict between            and offices to reflect the   Through providing for a       between offices and
                          Whilst there was not a     achieving economic and      different requirements of    diversity of sectors,         industrial capacity has


                                                                                                                                                             88
Issues                    Options                     Findings of the initial       Preferred options           Findings of the             Submission DPD
                                                      sustainability appraisal                                  Sustainability appraisal
                                                                                                                for preferred options
                          specific option on the      environmental                 different sectors e.g.      industries and uses there   continued through to the
                          sectors that should be      objectives.                   logistics v financial       are potentially negative    submission version.
                          encouraged, options                                       services                    effects against
                          were presented (Q2) on      Options related to                                        environmental criteria as
                          the levels at which         Hounslow’s role -                                         a result of development
                          different businesses        whether Hounslow                                          and the operation of
                          operate (international/     should promote itself as                                  uses. However, this can
                          strategic/ local).          a local, strategic or                                     be mitigated through
                                                      international business                                    appropriate development
                                                      location relates to the                                   and on-site management
                                                      types of sectors that may                                 of the effects
                                                      locate in the Borough
                                                      e.g. airport related
                                                      sectors are likely to be
                                                      international businesses.

                                                      Encouraging strategic
                                                      and international
                                                      business may have
                                                      economic benefits but
                                                      cause harm to
                                                      environmental objectives
                                                      through travel and
                                                      development.
Issue of how Hounslow     The options (Q2)            Given the nature of the       Objective 4 sought to       Seeking equality of         Objective 4 and Policy
moves up the earnings     considered whether          options, effects that arise   improve equality of         opportunity is consistent   E3 seek to improve
ladder, whether           there was a need for a      may be positive or            opportunity for residents   with social,                equality of opportunity
development can help      greater number and          negative against a            to employment and           environmental and           for residents to training
local people gain the     diverse range of job        number of SA objectives.      training                    economic objectives. In     and employment thus
necessary skills and if   opportunities, which also   The option to encourage                                   having access to            enhancing their
employers can be          relate to the ability for   a greater range of jobs                                   employment                  prospects in the

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Issues                    Options                     Findings of the initial       Preferred options             Findings of the              Submission DPD
                                                      sustainability appraisal                                    Sustainability appraisal
                                                                                                                  for preferred options
encouraged to employ      people to gain              contributes to increased                                    opportunities locally,       Borough. This can
local people              employment and develop      development and                                             there is not a need for      contribute to more
                          skills.                     resource use (negative                                      unsustainable journeys       sustainable travel
                                                      effects arising as a result                                 to work outside the          patterns the intent of
                                                      e.g. climate change).                                       Borough; there is            Policy E3.
                                                      Whilst supporting the                                       potentially a better
                                                      existing number of jobs                                     quality of life in having
                                                      has generally positive or                                   employment and benefits
                                                      no impact, there is                                         to the local economy.
                                                      guidance to support
                                                      growth at a London level.
Issue of where offices    Options on location for     Options to direct new         Pref options 5a and 5b        New development              Policies E2 and EP1
are located. Also what    development of offices      offices to locations not      sought to direct offices to   potentially has negative     direct new office
transport improvements    (Q5a, 5b)                   accessible by                 town centres, Chiswick        effects against              development to town
are required to promote                               sustainable modes of          Park and subject to           environmental objectives     centres and Chiswick
local economy                                         transport has negative        being more sustainable,       through resource use.        Park with only limited
                                                      environmental effects         the Great West Road           Through being in             office development
                                                      whilst the development        and Bedfont lakes             sustainable locations,       outside these locations
                                                      of offices in town                                          there are positive effects
                                                      centres/ edge of centre                                     in terms of encouraging
                                                      locations has generally                                     travel by means other
                                                      positive impacts against                                    than private vehicle and
                                                      SA objectives,                                              to the local economy
                                                      particularly access to                                      through providing
                                                      services, minimising use                                    employment.
                                                      of the car.
                          Options on the delivery     Further development and       Preferred option 7 and        Through directing            Policies E2 and EP5
                          of industrial land (Q7)     the designation of            8B sought to direct new       development to existing      direct new development
                          incl. intensification of    industrial sites has          industrial development to     employment sites there       to existing industrial
                          existing sites and/or the   positive impacts against      existing industrial sites.    are positive effects incl.   locations
                          designation of new areas    economic objectives                                         the regeneration of


                                                                                                                                                                90
Issues                     Options               Findings of the initial      Preferred options          Findings of the              Submission DPD
                                                 sustainability appraisal                                Sustainability appraisal
                                                                                                         for preferred options
                           for industrial uses   whilst there are potential                              existing brownfield sites
                                                 negative effects in terms                               and limiting the use of
                                                 of noise, air quality and                               resources through not
                                                 climate change arising                                  encouraging the
                                                 from the use of                                         development of new
                                                 resources and                                           sites. Development for
                                                 movement of goods/                                      employment uses in
                                                 travel                                                  itself will generate waste
                                                                                                         and have negative
                                                                                                         impacts against
                                                                                                         environmental objectives
                                                                                                         whilst having economic
                                                                                                         benefits
Issue of how                                     The initial SA of options    Objective 3 sought to      There are potentially        Objective 3 seeks to
environmental impacts of                         presented an overview of     ensure development is      negative effects of this     ensure the impacts of
employment are                                   the environmental            appropriately located      objective against            development are
mitigated                                        impacts arising from         and negative impacts are   economic objectives          minimised in part
                                                 options                      minimised                  reflecting the underlying    through being
                                                                                                         conflict. For example,       appropriately located
                                                                                                         development that has
                                                                                                         negative effects on the
                                                                                                         environment may
                                                                                                         provide jobs and in not
                                                                                                         allowing the
                                                                                                         development there is the
                                                                                                         opportunity cost.
                                                                                                         Through the inclusion of
                                                                                                         the objective,
                                                                                                         environmental issues
                                                                                                         can be dealt with in
                                                                                                         assessment of new


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Issues                        Options                    Findings of the initial        Preferred options           Findings of the              Submission DPD
                                                         sustainability appraisal                                   Sustainability appraisal
                                                                                                                    for preferred options
                                                                                                                    development
Issue of whether there is     Options on the             The options on locations       Pref option 9a sought to    Directing hotels to          Policy E10 directs visitor
sufficient supply of hotels   appropriate number and     for new hotels generally       direct hotels to town       locations close to the       accommodation and
and location for new          location of hotels (Q9a)   have positive economic         centres, and also on A4     airport potentially          conference facilities to
hotels                                                   effects.                       close to Heathrow where     encourages travel by         town centres
                                                         There are potentially          serving airport, there is   private vehicle and air
                                                         negative impacts against       good public transport       travel, contributing to
                                                         environmental and social       links and a demonstrated    negative effects on
                                                         objectives from directing      need                        climate change and air
                                                         hotels to the area                                         quality.
                                                         adjacent to Heathrow
                                                         encouraging travel                                         New hotel development
                                                         (access, travel by private                                 can provide employment
                                                         vehicle, air quality, noise,                               thus benefiting the local
                                                         climate change                                             economy but also
                                                         associated with travel).                                   requires resource use
                                                         Directing hotels to
                                                         locations accessible by a
                                                         choice of modes resulted
                                                         in generally positive
                                                         impacts against social
                                                         and environmental
                                                         objectives (equality of
                                                         opportunity, access).
Issue of how                  Option presented on        Negative effects               Pref option 2 sought to     Providing for diversity in   Objective 1 and Policy
environmental and             whether Hounslow takes     potentially arise from         encourage diversity in      industry has positive        E4 seek to encourage a
economic effects of           advantage of location      Hounslow taking                industries (thus not        effects in improving the     range of business
Heathrow are balanced         adjacent to Heathrow       advantage of Heathrow          relying on Heathrow).       range of opportunities for   activities to avoid over-
                              (Q2 – Option 1).           without regard to              Objective 3 also sought     employment/ training         reliance on any one
                                                         environmental effects.         to ensure impacts of new    and as a consequence,        sector (e.g. airport
                                                         An option for Hounslow         development are             enhancing Hounslow’s         related uses) thus


                                                                                                                                                                  92
Issues                       Options                     Findings of the initial     Preferred options          Findings of the               Submission DPD
                                                         sustainability appraisal                               Sustainability appraisal
                                                                                                                for preferred options
                                                         to encourage multi-         minimised including        role as an employment         promoting diversity in the
                                                         national companies (Q2)     effect of encouraging      centre.                       local economy.
                                                         reflects the inherent       airport uses.
                                                         conflict between                                       Whilst positive economic
                                                         economic and                                           effects arise from            Also recognition of
                                                         environmental, social                                  encouraging Heathrow’s        economic benefits
                                                         effects.                                               development, an over          through objective in DPD
                                                                                                                reliance on the airport for   to provide capacity to
                                                         A combined approach of                                 employment can cause          accommodate growth
                                                         encouraging local                                      harm to the local             incl. demand from
                                                         business whilst also                                   economy if there is a         Heathrow
                                                         positioning Hounslow as                                downturn in the aviation
                                                         a strategic employment                                 industry.
                                                         area raises potentially
                                                         negative effects against                               Across all industries
                                                         social and environmental                               there are negative
                                                         objectives subject to                                  environmental effects but
                                                         other factors. However,                                more so from those
                                                         both options bring                                     which require movement
                                                         positive economic                                      of people/ freight by air.
                                                         effects.                                               It is therefore important
                                                                                                                to encourage other
                                                                                                                sectors to develop and
                                                                                                                support local as much as
                                                                                                                international business
Issue of whether there       Options presented on        The release of offices to   Pref option 5c sought to   The release of office         Policies E1 together with
are sites no longer viable   locations for the release   other uses potentially      retain offices and key     floorspace not needed         EP2, EP4 allow for the
and with potential for       of offices (Q5c)            has negative impacts on     office locations with a    can allow for the             managed release of
other types of dev.                                      access to employment        restrictive approach to    regeneration of sites and     office floorspace subject
                                                         and the quality of where    release.                   contribute to the             to criteria
                                                         people live whilst having   The release of offices     conservation of

                                                                                                                                                               93
Issues                       Options                      Findings of the initial        Preferred options            Findings of the              Submission DPD
                                                          sustainability appraisal                                    Sustainability appraisal
                                                                                                                      for preferred options
                                                          positive impacts on the        outside these locations      resources through reuse
                                                          environment subject to         will be subject to           of buildings.
                                                          the proposed use.              assessment of demand/
                                                          Releasing offices in out       alternative supply           If offices outside town
                                                          of centre locations has                                     centres are released to
                                                          potentially positive                                        alternative uses, it can
                                                          effects through directing                                   redirect demand to more
                                                          demand to more                                              sustainable locations
                                                          sustainable locations                                       that has environmental,
                                                                                                                      economic and social
                                                                                                                      benefits including more
                                                                                                                      accessible opportunities
                                                                                                                      for employment and less
                                                                                                                      need for car use.
Issue of whether there       Option presented on the      This option had positive       Pref option 7 sought to      The release of industrial    Policies E1, EP6 – EP8
are sites no longer viable   release of industrial land   outcomes against all           allow release of             land can allow for the       are relevant to the
and with potential for       in locations that do not     sustainability criteria with   industrial land subject to   regeneration of land         change of use from
other types of dev.          have good                    the exception of               assessment of demand/        where it is no longer        Industrial, warehousing
                             characteristics (Q7          economic objectives.           alternative supply or        needed or bring about a      & related uses taking a
                             Option 3)                    The loss of land for           where there are negative     better quality of life for   restrictive approach to
                                                          industrial uses potentially    effects of an existing use   the surrounding              release based on
                                                          results in the loss of         due to a site’s              community where there        strategic and local level
                                                          employment subject to          characteristics              are negative effects from    assessments
                                                          the proposed use                                            the existing industrial
                                                                                                                      use.



                                                                                                                      Environmental benefits
                                                                                                                      may also arise where
                                                                                                                      there is a change of use

                                                                                                                                                                    94
Issues                    Options                   Findings of the initial     Preferred options         Findings of the               Submission DPD
                                                    sustainability appraisal                              Sustainability appraisal
                                                                                                          for preferred options
                                                                                                          due to the existing
                                                                                                          industrial use having
                                                                                                          negative effects


What mix of uses should   Options presented on      Of a range of scenarios     Pref option 9b sought a   The pref option can           Policy EP2 for CoU from
be prioritized            what mix of uses is       on what mix of uses is      mix of uses on            improve access to             offices allows a mix of
                          appropriate (Q9b)         appropriate on              employment sites whilst   services and                  uses where the
                                                    employment sites, there     ensuring retention of     employment subject to         equivalent no. of jobs are
                                                    was generally positive      jobs/ employment          the mix of uses               provided.
                                                    effects particularly in     floorspace                accommodated on sites.
                                                    terms of travel where                                 It can also minimise the
                                                    there is a mix of housing                             need to travel and            In taking a restrictive
                                                    and employment. This                                  conserve resources            approach to the release
                                                    option also had negative                              through accommodating         of industrial, policies EP6
                                                    effects against the                                   development on                and EP7 only allow uses
                                                    economic objective of                                 previously developed          that do not undermine
                                                    maintaining/ enhancing                                sites.                        the primary function of
                                                    economic dev. The other                                                             the sites and meet other
                                                    issue that arose from a                                                             criteria. Subject to
                                                    mix of uses was the                                                                 meeting the criteria,
                                                    impacts of waste                                                                    there is scope for a mix
                                                    generated.                                                                          of uses
                          Options on Hounslow’s     This generally has no       Objectives 1 in the       Through providing             Policy EP9 reflects
                          employment role (Q2)      impact against most         preferred options         opportunities for diversity   Objective 1 of promoting
                          give consideration to     sustainability objectives   promotes diversity in     in the size of space          diversity in the size of
                          whether the Borough       although there is           business size.            available for businesses,     businesses through the
                          should prioritise local   potential for negative                                there is greater              retention, protection and
                          business ahead of         effects against economic                              opportunity for new           provision of units for
                          strategic and             objectives where                                      business and existing         SMEs.
                          international business.   opportunities are not                                 business growth. This

                                                                                                                                                         95
Issues   Options                   Findings of the initial     Preferred options   Findings of the             Submission DPD
                                   sustainability appraisal                        Sustainability appraisal
                                                                                   for preferred options
         Local business is         encouraged for                                  can benefit the local
         dominated by SMEs and     international or national                       economy. Through there
         therefore the options     businesses to also locate                       being a greater diversity
         relate to the size of     in the Borough.                                 in business, there are
         business as much as the                                                   potentially greater
         level (international,                                                     opportunities for local
         national, local)                                                          employment, which has
                                                                                   social benefits.
                                                                                   The development of
                                                                                   business and new
                                                                                   companies (SMEs) can
                                                                                   have negative
                                                                                   environmental effects.




                                                                                                                           96
5.4        Options considered in choosing the plan objectives and preferred
           options

5.4.1      Objectives

5.4.1.1    The following section explains how the Plan Objectives have been formulated. In considering
           the impacts of objectives against the 23 sustainability objectives (SA Scoping Report 2005)
           regard should also be had to the table titled ‘Testing the Compatibility between new plan
           objectives and SA objectives Sustainability Objectives’ on pages 100 - 101.

5.4.1.2    The objectives consulted on in the preferred options document (January 2006) developed
           from the options (June 2005) and the need to incorporate sustainability objectives within the
           DPD itself.

           Objective A. Hounslow’s Employment Role and function

5.4.1.3    An objective on the role and function Hounslow performs as an employment centre developed
           from the options under “Topic 2” of the Options paper consulted on in June 2005. Relevant
           options are listed below:

           Topic 21 Hounslow’s Employment Role
           Option 1: Position Hounslow as an area that promotes international trade
           Option 2: Hounslow should have a primarily strategic employment role in relation to Greater
           London and the wider area
           Option 3: Priority should be given to encouraging the development of local business
           Option 4: Hounslow should encourage the local business community whilst positioning itself
           as a strategic employment area
           1. Referred to as “2. Hounslow’s Employment role” in the Employment Options paper.

5.4.1.4    An appraisal of the effects arising from each of these options against sustainability objectives
           was provided at the stage of options consultation in June 2005 (refer to appendix 5). A
           detailed assessment including key issues arising from each of the options, and summary of
           responses from public consultation on options is presented in section 5.4.4.

5.4.1.5    The SA assessment demonstrated that the preferred ‘option’ is for Hounslow to function as an
           employment centre at both a strategic and local level, which encourages diversity in the type
           and size of businesses.

5.4.1.6    In terms of jobs/employment uses and industries (‘Employment’) -
           Should diversity be encouraged as a general principle?
                                                    or is a specialised role appropriate for the Borough

5.4.1.7    Diversity in job provision was considered under Topic 1 (Employment Opportunities) of the
           options consultation paper. Options were presented on whether the current range of jobs is
           appropriate or there is a need for a greater range of jobs, providing a variety of opportunities.
           The key issues arising from each of the options and summary of responses from public
           consultation on options is presented in section 5.4.3

5.4.1.8    In terms of the policy context, the West London Economic Development Strategy (WLEDS)
           encourages a diversity of land uses as part of the overall vision for West London’s economy.

5.4.1.9    Heathrow is a key economic driver to attracting development to the Borough and as a result,
           there is increased risk in times of recession associated with the Aviation industry.
           Encouraging diversification can therefore ensure the extent of Heathrow’s impact does not
           begin to dominate the local economy in an unhealthy way.

5.4.1.10   The objective to encourage economic diversity is consistent with sustainability objectives of
           providing benefits to the local economy (Objective 20), potentially attracting economic

                                                                                                          97
           development that provides a range of jobs (Objective 21); and enhancing equality of access
           to jobs (Objective 6).

5.4.1.11   Setting an objective of encouraging the Borough to have a specialist role rather than
           encouraging diversity has potential negative effects on equality of access to jobs and
           provision of a range of jobs. It is also inconsistent with regional and local objectives as
           outlined above.

5.4.1.12   The preferred objective is therefore:

                   To maintain and enhance Hounslow’s employment role in both a strategic and local
                   context, through promoting diversity in employment uses, industries, business size
                   and scale.
5.4.1.13   Appendix 4 outlines the progression from preferred options to the submission version of the
           DPD. The Submission DPD carries forward this objective with minor amendments as follows:

                   To maintain and enhance Hounslow’s employment role in both a strategic and
                   local context, promote diversity in business, a range of employment sectors
                   and size of businesses

5.4.1.14   This ‘preferred objective’ is tested for compatibility with the SA objectives on page 100. In the
           testing of compatibility, negative effects of the plan objective arise against environmental
           objectives (climate change, air quality and waste). This reflects the inherent conflict between
           environmental and economic objectives as described in the London Borough of Hounslow
           Sustainability Appraisal Scoping Report. To address this, paragraph 1.8 of the DPD states
           that the development plan should be read in conjunction with other development plans. In this
           way, economic and environmental impacts can be balanced accordingly. Furthermore,
           objective 3 of the Employment DPD seeks to ensure the impacts of development on the
           environment, economy and community are minimised, which regard should be had to in
           interpreting other objectives and policies in the DPD.

           Objective B. Supply of employment land

5.4.1.15   Options forming the basis for an objective on the appropriate level of employment land in the
           Borough were consulted on in June 2005 as part of the Options paper.

5.4.1.16   Topics 3 and 6 provided options to consultees on whether there is an appropriate supply of
           offices and industrial land in the Borough. A detailed assessment including key issues arising
           from each of the options, and summary of responses from public consultation on options is
           presented in sections 5.4.5 (Topic 3 of the options consultation paper) and 5.4.11 (Topic 6 of
           the options consultation paper).

5.4.1.17   Also influential in developing an objective on appropriate supply of employment land is
           whether an increased provision of jobs/ growth in employment is sought. These are options
           considered in the options consultation paper and which are repeated in the table below. Also
           refer to section 5.4.3 for a detailed assessment including key issues arising from each of the
           options, and summary of responses from public consultation on options.

           Topic 12 Employment opportunities
           Option 1: Employment opportunities should be improved in the Borough through the provision
           of more jobs
           Option 2: The current level of employment (number of jobs) in the borough is acceptable and
           should remain the same in the future with a similar number of jobs.
           2. Referred to as “1. Employment Opportunities” in the Employment Options paper.

5.4.1.18   Whilst the aim to facilitate an increased number of jobs cannot be achieved through just the
           availability of land, it is seen as appropriate to consider as part of developing a more spatial


                                                                                                          98
           objective, which the Council could facilitate in partnership with other organisations and
           business.

5.4.1.19   The responses from the options consultation, detailed assessment of the options against
           sustainability objectives, and consideration of national and regional guidance (see section
           5.4.3) has enabled a ‘preferred option’ to be developed from the options discussed above,
           which forms an objective to the plan. In developing this objective, it has been seen as
           important to ensure a robust approach to managing supply of offices and industrial land, and
           ensure the plan can respond to a changing environment thus remaining relevant.

5.4.1.20   The preferred objective is therefore:

                   To provide capacity to accommodate future employment growth, whilst aiming
                   to achieve an appropriate balance in supply and demand for employment land.

5.4.1.21   Appendix 4 outlines the progression from preferred options to Submission version of the DPD.
           The Submission DPD carries forward this objective without changes.

           Objective C. Location and effects

5.4.1.22   As part of the options consultation in preparation of the Employment DPD, options were
           presented on the appropriate location for development of offices and industrial uses through
           intensification/expansion, allocation of new sites, and protection of existing sites (Topics 5
           (refer to sections 5.4.7 to 5.4.10 of this report), 7 (refer to section 5.4.12 of this report) and 8
           (refer to section 5.4.13 of this report).

5.4.1.23   The separation of options by land use (Topics 3 – 5 concern the future planning of offices,
           and Topics 6 to 8d concern industrial and warehousing land) reflects the different locational
           demands of the 2 distinctive types of employment land as well as national and regional
           guidance in where these uses should be directed.

5.4.1.24   Underlying the need to locate offices and industrial uses in appropriate locations is the wider
           objective of sustainable development. PPS1 states that sustainable development should be
           integrated into development plans, with consideration to “the interrelationship between social
           inclusion, protecting and enhancing the environment, the prudent use of natural resources
           and economic development”.

5.4.1.25   In seeking to achieve sustainable development, it is seen as appropriate to include an
           objective that demonstrates an integrated approach to the wider economy, environment and
           community. This comes out in the assessment of compatibility of plan objectives against
           sustainability objectives.

5.4.1.26   In developing an objective, the status quo in the current Unitary Development Plan (Adopted
           December 2003) has been considered. Objective E.1 of the UDP seeks to “encourage
           economic development which leads to more effective use of land and is compatible with the
           Council’s environmental objectives”. Objective E.2 of the UDP also incorporates the aims of
           sustainable development:

                   “To ensure and promote developments which are suitably located in terms of the
                   adjoining uses, road network and transport facilities, characteristics of the area, and
                   to promote environmental improvements to existing employment sites”.

5.4.1.27   Both objectives incorporate the aim of environmental and economic sustainability but do not
           consider the social objectives.

5.4.1.28   The second objective of the UDP, E.2 also includes reference to the need for development to
           be appropriately located. Whilst it is important to direct industrial uses to locations close to the
           strategic road network to avoid congestion on local roads in accordance in PPG4, it may be


                                                                                                             99
           appropriate for development requiring good access to locate in other locations where there is
           access by water and/or rail.

5.4.1.29   Furthermore, there is the aim in Objective E.2 of the UDP to ensure uses that require good
           access are located close to transport facilities. There are parts of the Borough where public
           transport accessibility levels are low, and there is still dependence on the car. Therefore, it
           may not be possible for developments to be ‘suitably located’ relative to the road network and
           public transport facilities.

5.4.1.30   Given the issues above and the requirements in transport objectives and policies of the UDP
           for proposals to be accessible by sustainable modes including water and rail, it is seen as
           appropriate for the objective to be flexible whilst ensuring impacts of development in a specific
           location are minimised.

5.4.1.31   Whilst other options could be considered for an objective, it is considered that such
           alternatives would be the antithesis of sustainability, and therefore have not been considered
           further.

5.4.1.32   The preferred objective is therefore:

                   To ensure that development is appropriately located and negative impacts of
                   existing and new development on the environment, economy and community
                   are minimised.

5.4.1.33   Appendix 4 outlines the progression from preferred options to Submission version of the DPD.
           The Submission DPD carries forward this objective without changes

           Objective D: Equality

5.4.1.34   An integral part to national, regional and local planning, is equality of opportunity. PPS1
           identifies the importance of meeting the needs of all people in existing and future
           communities, promoting personal well-being, social cohesion and inclusion and creating equal
           opportunity for all citizens. At a regional level, the GLA has a statutory duty to promote
           equality of opportunity in London, which is reflected in the London Plan.

5.4.1.35   At a local level, the Council has adopted an Equal Opportunities and Diversity Policy, which
           supports the Community Plan and has a key objective of “improving equality of access to
           service delivery and employment and training”.

5.4.1.36   The Statement of Community Involvement has been assessed for its likely impact on diversity
           and equality of opportunity, with all subsequent documents, forming part of the Local
           Development Framework, being produced in accordance with these standards.

5.4.1.37   Furthermore, the Sustainability Appraisal Scoping Report, adopted by the Council in
           September 2005 identifies the following sustainability objectives with specific reference to
           equality, which plans are assessed against:

                   (6) To ensure fair and equal access to services (health care, education, employment,
                   shopping, transport), culture, leisure and recreation for all residents

                   (7) To reduce discrimination and promote equality of opportunity and fair treatment for
                   all of our communities

                   (23) To improve accessibility for all sections of the community to jobs, education,
                   skills training and life long learning

5.4.1.38   To ensure equality of access is incorporated into future policies relating to employment land,
           an objective to improve equality is important. In developing an objective for the proposed
           Employment DPD, the status quo in the current UDP has been considered.

                                                                                                          100
5.4.1.39   Objectives E.3 and E.4 of the UDP both seek to ensure equality of access to jobs and new
           development. Given the underlying theme of equality in both these objectives, integration into
           a single objective is seen as appropriate, and consistent with the aim set out in PPS12 of a
           clear and succinct approach to the format of Local Development Documents.

5.4.1.40   The presentation of alternatives to enhancing equality of access could be considered further
           in formulating an objective but it would not be consistent with wider aims at a national,
           regional and local level.

5.4.1.41   The preferred objective is therefore:

                   To improve equality of opportunity for residents of the Borough through
                   employment and training; and ensuring developments are accessible to all.

           Appendix 4 outlines the progression from preferred options to Submission version of the DPD.
           The Submission DPD carries forward this objective without changes

           Objective D: Role of tourism in the Borough

5.4.1.42   The London Plan seeks to enhance London’s tourism industry and create “integrated and
           sustainable new products and destinations” in greater London, ensuring benefits for town
           centres and the suburbs. This is reflected in the Sub Regional Development Framework
           (WLSRDF) May 2006, which seeks promotion of West London as a tourism destination and
           requirement for improved leisure, culture and tourism provision.

5.4.1.43   The West London Tourism Strategy (WLTS) aims to support tourism growth through
           proposals for action. With London winning the right to host the Olympics in 2012, capturing
           the benefits of tourism; promoting Hounslow through the provision of venues and facilities;
           and realising the implications, on infrastructure for example, is seen as important.
5.4.1.44   There is a demonstrated need for hotel accommodation as stated in the London Plan,
           WLSRDF and WLTS, further emphasising the approach of promoting tourism in the Borough.

5.4.1.45   Tourism has a significant role in providing employment within the Borough, which is linked to
           the gateway function Hounslow serves in its location east of Heathrow, good transport links,
           and already strong tourism sector in West London. In terms of employment by sector, the
           highest proportion of Hounslow’s residents are employed in retail distribution, hotels and
           restaurants (25.2%). With growth industries including air transport, hotels and restaurants,
           there is seen to be a need for the Borough to capture the benefits of tourism.

5.4.1.46   Given the role of tourism in the local economy the existing UDP objective was carried forward
           into the preferred options.

5.4.1.47   However, in retrospect, an objective to encourage tourism does not need to be included in the
           submission version of the DPD as it mirrors strategic guidance (London Plan) and there are
           not considered to be local circumstances for a different approach.

5.4.1.48   Whilst the DPD has a policy to direct visitor accommodation and conference facilities to
           appropriate locations, Policy EP10 is a means for implementing Objective 3 in the DPD of
           ensuring that development is appropriately located. Thus there is not a means for delivering
           the objective and it has been excluded from the submission document.




                                                                                                     101
Testing the Compatibility between new plan objectives and SA objectives Sustainability Objectives

SA Objectives




                                   Objective 1

                                                 Objective 2

                                                               Objective 3

                                                                             Objective 4

                                                                                           Objective 5

                                                                                                         Objective 6

                                                                                                                       Objective 7

                                                                                                                                     Objective 8

                                                                                                                                                   Objective 9

                                                                                                                                                                 Objective 10

                                                                                                                                                                                Objective 11

                                                                                                                                                                                               Objective 12

                                                                                                                                                                                                              Objective 13

                                                                                                                                                                                                                             Objective 14

                                                                                                                                                                                                                                            Objective 15

                                                                                                                                                                                                                                                           Objective 16

                                                                                                                                                                                                                                                                          Objective 17

                                                                                                                                                                                                                                                                                         Objective 18

                                                                                                                                                                                                                                                                                                        Objective 19

                                                                                                                                                                                                                                                                                                                       Objective 20

                                                                                                                                                                                                                                                                                                                                      Objective 21

                                                                                                                                                                                                                                                                                                                                                     Objective 22

                                                                                                                                                                                                                                                                                                                                                                     Objective 23
Employment Objectives

1. To maintain and enhance
Hounslow’s employment role in
both a strategic and local
context, through promoting           +            O              ?             +             ?           ++              +             +             +             ?              ?              ?              ?              ?                -              -              -           O              O             ++             ++             ++              ++
diversity in employment uses,
industries, business size and
scale
2. To provide capacity to
accommodate future
employment growth, whilst
aiming to achieve an                 +            O              +            O              ?             +             +             +             +             ?              +              ?            ++               +              +              ?               ?            O               ?            ++             ++             ++              ++
appropriate balance in supply
and demand for employment
land
3. To ensure that development
is appropriately located and
negative impacts of existing
                                     +            O             O             O              +           ++              +             +           ++              +              +            ++             ++             ++             ++               +              +            ++             ++             ++             ++             ++              ++
and new development on the
environment, economy and
community are minimised
4. To improve equality of
opportunity for residents of the
Borough through employment
                                   ++             O              +           ++             O            ++            ++            ++            O               +             O              O             ++              O               +             O              O              O              O             ++             ++             ++              ++
and training; and ensuring
developments are accessible to
all.

                                                                                                                                                                                                                                                                                                                                                                    102
5. To encourage employment
opportunities and other benefits
to the local economy through
the development of Hounslow’s
                                      O   O   O   +   ?   +   +   O   +   ?   O   ?   +   +   ?   ?   -   O   ++   ++   ++   ++    ++
visitor attractions, hotel,
conference and exhibition
facilities, whilst having regard to
the wider environment

KEY
                 Impact
++                very positive
+                 Positive
O                 No impact
-                 Negative
--                Very negative
?                 Uncertain effect




                                                                                                                                  103
5.4.2     Options considered in choosing the preferred options

5.4.2.1   The following section includes a detailed assessment of the options considered and how the
          consultation responses to the options consultation, sustainability appraisal of the options2 and
          national, regional guidance informed the preferred options, and subsequently the Objectives
          and policies in the Employment DPD.

5.4.2.2   Reflecting on the options stage in line with the guidance, only those options that were
          reasonable and had some merit were put forward for comment as part of the options
          consultation paper (June 2005). Whilst there were a small number of exceptions that were in
          part inconsistent with national and regional guidance, it was seen as appropriate to include
          them as options to ensure consultees had the opportunity to comment on alternatives.

5.4.2.3   A table is presented by “topic” of the options consulted on in June 2005 including a summary
          of the consultation response and findings from the sustainability appraisal for each option.

5.4.2.4   Following this key issues have been identified, which outlines the reasons for taking forward
          an option as a preferred option or otherwise rejecting it including references where relevant to
          national and regional guidance, findings from the sustainability appraisal and responses to the
          consultation. Mitigation measures are also put forward where an option had negative effects
          against sustainability objectives (as identified in the “Employment Development Plan
          Sustainability Appraisal Assessment of Options” (June 2005) – refer to Appendix 5.




          2
            As part of the first stage of consultation on options (June 2005), a Sustainability Appraisal of
          the options was undertaken. The “Employment Development Plan Sustainability Appraisal
          Assessment of Options” (June 2005) appraised the sustainability of each individual option
          against the objectives developed in the Sustainability Appraisal Scoping Report (September 2005).
          This can be found in Appendix 5 of the DPD.
                                                                                                       104
5.4.3     Topic 1 Employment Opportunities

          Option                                  Reason for inclusion / rejection of option

          1 Provision of more jobs                This option received general support from
                                                  respondents, and negative impacts arising against
                                                  environmental criteria can be overcome through jobs
                                                  being appropriately located. This option forms the
                                                  basis for a preferred option.
          2 The current number of jobs is         This option was not sought by a high proportion of
          acceptable and should remain the        respondents. Whilst providing the same number of
          same in the future                      jobs has little or no negative impacts, it is not an
                                                  approach sought as it is inconsistent with the
                                                  Council’s objective of securing jobs through
                                                  development.
          3 A greater range of jobs in new        This option received general support and subject to
          areas should be provided                the location of jobs, this option can overcome any
                                                  potential negative impacts, particularly in terms of
                                                  equality of access.
                                                  The greater the range of employment opportunities
                                                  the more robust the local economy will be in
                                                  responding to a changing economy. On this basis, the
                                                  option forms the basis for a preferred option.
          4 The current range of jobs is          Whilst providing the same range of jobs has little or
          acceptable and should remain the        no negative impacts in the appraisal against
          same in the future                      Sustainability objectives, it is not an approach sought
                                                  as it is inconsistent with the regional and local
                                                  objectives of achieving economic diversity. The option
                                                  was not supported in consultation and will not be
                                                  taken forward as a preferred option.

          Key issues and mitigation:

5.4.3.1   The 2005 interim borough level employment projections (GLA) predict that there will be an
          11% rise in the borough’s employment levels between 2002 and 2016 from 137,000 to
          152,000.

5.4.3.2   The London Plan sets policies to accommodate this growth, and does not wish to reverse this
          change. Furthermore, the Council objective to secure jobs through development (Community
          Plan) emphasises a preferred policy direction to encourage the provision of more jobs (Option
          1). Development required to facilitate employment may have adverse effects on the use of
          resources, inconsistent with SA objective 11. This can be minimised through efficient use of
          land and making use of existing resources including previously development land. Other
          effects may arise against environmental objectives as a result of development e.g. noise. This
          can be minimised through ensuring development is accessible by public transport whilst
          meeting the locational demands of business.

5.4.3.3   Celebrating diversity is a key objective for the Council (Community Plan 2004), and in an
          economic context at both a regional and local level, new business can contribute to the
          diversity of the economy. A range of employment is supported reflecting the current range in
          jobs, and opportunities should be encouraged to support new economic development
          consistent with sustainability objectives.

5.4.3.4   There is the need to encourage diversification and ensure that the extent of Heathrow’s
          impact does not begin to dominate the local economy in an unhealthy way. Providing for a
          greater number and range of jobs may have the benefit to support local employment and
          enhance equality of access to jobs, but this is subject to factors such as the type of jobs and
          skill level required. This can be mitigated through enhancing learning opportunities e.g. S106


                                                                                                     105
          funding for training, which can be beneficial in terms of other sustainability criteria (Objective
          8 of improving education and skills of the population).

5.4.3.5   There is currently a net increase in Hounslow’s daytime population of 3.4% (aged between 16
          and 75). However, 58% of Hounslow working residents commute to work outside the
          Borough (60% of Borough workers live outside the Borough). Providing for an increased
          number and range of jobs may encourage more opportunities for Hounslow residents to work
          locally, but the reverse may occur and more people may commute into the Borough for work.
          Through ensuring the Borough’s residents have access to learning opportunities including
          education and training, there is an increased chance of residents having the skills required to
          meet labour demands.

5.4.3.6   Whilst the aim to facilitate an increased number and range of jobs cannot be achieved
          through just land availability, it is seen as appropriate to consider as part of developing a
          more spatial objective, which the Council could facilitate in partnership with other
          organisations and business (refer to paragraphs 5.1.1 to 5.1.12).
          Options 3 and 1 are therefore seen to form part of a preferred option.




                                                                                                          106
5.4.4     Topic 2 Hounslow’s Employment role

          Option                                   Reason for inclusion / rejection of option

          1 Position Hounslow as an area that      The effects of this option may be negative in terms of
          promotes international trade             social and environmental criteria, subject to
                                                   contributions that international companies make to
                                                   the local area. Also potential adverse effects subject
                                                   to international companies providing job opportunities
                                                   for residents of the Borough or to the local economy.
                                                   To ensure potential negative effects are mitigated, the
                                                   Council can work with partners to promote graduate
                                                   employment programmes/ sponsorship/ training of
                                                   local people to enhance work prospects.
                                                    This option received a reasonable level of support,
                                                   and if it can be delivered in a sustainable form, will be
                                                   considered as part of a wider approach.
          2 Hounslow should have a primarily       This option received some support. The potential
          strategic employment role in relation    negative effects on the local community and economy
          to Greater London and the wider          with a focus on a regional role for the borough could
          area                                     be overcome through a wider policy approach and
                                                   consideration of the contribution that national and
                                                   regional companies can make at a local level.
          3 Priority should be given to            The response to this option was split. Any negative
          encouraging the development of           impacts relate to the loss of international and regional
          local business                           business on the local economy and employment
                                                   opportunities for the Borough’s residents. This could
                                                   be overcome through a combination of the options for
                                                   the employment role Hounslow serves.
          4 Hounslow should encourage the          A combination of the above was the preferred option
          local business community whilst          from respondents and subject to mitigating potential
          positioning itself as a strategic        environmental effects will form the basis for policy.
          employment area

          Key issues and mitigation:

5.4.4.1   Hounslow performs a strategic function with areas identified in the London Plan as strategic
          employment locations for industrial capacity, and other locations identified as key locations for
          offices. Warehousing, particularly in the west is strategically important, serving both Heathrow
          and domestic markets. The sustainability objective of maintaining and enhancing the
          importance of Hounslow in a West London and London wide context emphasises the
          international and domestic role Hounslow serves, and options 1 and 2 are therefore seen to
          be relevant.

5.4.4.2   Small and medium sized enterprises (SMEs) dominate the business structure in Hounslow
          and West London, and with evidence of unfulfilled demand for small, affordable workspaces,
          there is a need to support local business. The London Plan seeks the provision of a variety of
          type, size and cost of premises to meet the needs of different sectors, and firms of different
          types and sizes. In addition the ‘Statement of Intent’ for first review of the London Plan
          proposes to strengthen the approach to small and medium enterprises and those businesses
          owned and operated by women, black, Asian and ethnic minorities.

5.4.4.3   Furthermore, the West London Economic Development Strategy seeks to sustain the
          contribution of SMEs. This necessitates a wider approach in the role that Hounslow should
          have as an employment centre.

5.4.4.4   Option 4 brings together the role of strategic and local business, reflecting options 1 to 3.
          Ensuring a suitable balance of employment uses to meet demand will address potential


                                                                                                          107
          secondary effects including the potential loss of opportunity in not providing for international,
          regional or local businesses.

5.4.4.5   The different options for the employment role Hounslow serves may have
          secondary/cumulative effects. Through recognising that Hounslow has an employment role,
          the Council is promoting the continuing and future use of land for employment. This does not
          help in reducing negative contributions to climate change or improving air quality, subject to
          business operations and travel associated with business.

5.4.4.6   Environmental effects may arise from any of the options. The difference in impact between
          the options is subject to other factors including the size, scale, accessibility, and location of
          business. This demonstrates the importance of promoting environmental improvements to
          existing sites and ensuring proposals include measures to address effects arising from the
          processes involved.

5.4.4.7   By ensuring that businesses are accessible by public transport and promote travel to work by
          sustainable modes e.g. green travel plan, effects on climate change and air quality can be
          minimised

5.4.4.8   Whilst effects can be avoided, remedied or mitigated, businesses will have locational
          demands and other economic objectives, thus any industrial/commercial development or
          related travel (e.g. logistics) supporting Hounslow’s employment role may have positive
          effects on economic outcomes, but negative effects on environmental objectives, such as air
          quality, use of resources, and climate change. This demonstrates the inherent conflict
          between environmental, social and economic objectives as described in the London Borough
          of Hounslow Sustainability Appraisal Scoping Report (Available upon request). Companies
          are incorporating environmental objectives into their plans with greater recognition of their
          effects on the environment. Whilst supporting regional and local businesses, it is important to
          ensure development is sustainable and promote increased environmental and social
          responsibility. The Council can do this by continuing to raise environmental issues through
          mechanisms such as its Sustainability checklist.

5.4.4.9   Following an overall assessment of the options and their effects, option 4 is the preferred
          approach from responses received to the consultation and in achieving sustainable
          objectives, where practicable.




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5.4.5     Topic 3 Supply of Offices

          Option                                 Reason for inclusion / rejection of option

          1 Need for increase in office space    This option received general support from
                                                 consultation. There are potential negative effects
                                                 against environmental criteria, which could be
                                                 overcome subject to where new office space is
                                                 provided. However, a net increase in office space
                                                 may not be efficient or have benefits for the local
                                                 economy where there is not demand and existing
                                                 under utilised offices are available. This is not
                                                 appropriate to take forward as an option given current
                                                 demand.
          2 Current level of office space is     Respondents did not support this option. If the
          sufficient for the plan period         existing supply of offices is retained rather than being
                                                 more efficiently provided, there are potential negative
                                                 impacts against economic objectives. Whilst it is
                                                 important to ensure there is sufficient supply to
                                                 accommodate demand, consolidation and the more
                                                 efficient use of land/buildings is appropriate given
                                                 current demand.
          3 There is too much office space and   The response to this option was split. Negative
          some should be released                impacts arise through the loss of employment space
                                                 that may be taken up in the future. However, negative
                                                 impacts arise through retaining existing vacant
                                                 offices, including the inefficient use of land, which
                                                 may have secondary impacts of directing other uses
                                                 to inappropriate locations. To ensure the efficient use
                                                 of land, and reflecting the objective of a balanced
                                                 approach to the supply and demand of employment
                                                 land, this option will be taken forward in development
                                                 of policy.
          4 There is a need to improve the       This was the preferred option from respondents and
          quality of existing offices through    was considered to be the most sustainable approach,
          renewal                                the only negative effect being in improving access to
                                                 jobs. This will form a part of the preferred option.

          Key issues and mitigation:

5.4.5.1   There is considered to be sufficient capacity to accommodate anticipated growth in jobs to
          2016 (WLSRDF), accentuated with interim employment projections (May 2005) to 2016
          showing an increase of 15,000 jobs in Hounslow compared with a projected 21,000 jobs in a
          technical report to the London Plan (2002).

5.4.5.2   Much of the employment growth is expected to be in office-based employment (Draft
          WLSRDF), which could be accommodated through the take-up of space in town centres;
          implementation of permissions including Chiswick Business Park; and use of existing vacant
          and underused stock (Hounslow Employment Land Study 2004). The London Plan (2004)
          recognises that the suburban office market has been losing its attraction as a strategic
          location for office based activity and this is reflected in high vacancy levels and older
          premises within the town centres (Hounslow Employment Land Study 2004).

5.4.5.3   Whether it is appropriate to promote an increase in supply, maintain existing capacity, or
          release offices to allow a reduction is subject to demand. To ensure a robust approach to
          managing supply, and to respond to a changing economy, it is appropriate for an objective to
          seek a balance in supply and demand, whilst encouraging the more efficient use of land.



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5.4.5.4   To enable the more efficient use of land, renewal of existing stock is appropriate (option 4)
          reflecting the London Plan. This option was the most beneficial in achieving sustainable
          outcomes and was the most supported option in consultation. An assessment of effects
          against sustainability objectives at the options stage showed that option 4 has positive
          outcomes, particularly in terms of conserving resources and promoting regeneration through
          reuse rather than new development; improving air quality and reducing negative contributions
          to climate change assuming renewal is sustainable in construction and design; and
          economically in encouraging efficient land use.

5.4.5.5   The effects against sustainability objectives of seeking a balance in supply and demand are
          subject to how this is achieved, which is given more consideration in the following sections.




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5.4.6     Topic 4 Delivery of Offices

          Option                                   Reason for inclusion / rejection of option

          1 Existing office sites should be        This was most favoured by the community.
          intensified/expanded                     Intensification requires additional resources
                                                   (inconsistent with SA objective 11), and does not
                                                   reduce the contributions to climate change (SA
                                                   objective 15). Through energy efficient and
                                                   sustainable design, these effects could be minimised.
                                                   Subject to the locations where
                                                   intensification/expansion is encouraged, there may
                                                   also be negative effects on air quality, and noise due
                                                   to potential travel, and no improvement in terms of
                                                   access to jobs for all. Through ensuring further
                                                   development is in locations with good levels of public
                                                   transport accessibility, these effects could be
                                                   overcome. The option therefore forms part of a wider
                                                   policy approach.
          2 New sites should be allocated for      The responses to this option were evenly split.
          offices                                  Given the lack of current surplus of office space in the
                                                   borough, it is not considered appropriate to designate
                                                   new sites for offices. However, this option is
                                                   considered further in terms of whether proposals for
                                                   office development are appropriate on new sites (not
                                                   previously in employment use). The negative
                                                   environmental effects of this option could be
                                                   overcome through the appropriate location of new
                                                   offices but there is also the inherent loss of
                                                   opportunity for other land uses on sites where offices
                                                   are built. Subject to location and a demonstrated
                                                   need for additional office space, this option will form
                                                   the basis for a preferred option.
          3 Sites currently used for offices       This was generally supported in consultation. In
          should be released for other uses        environmental terms, this may be acceptable in
                                                   unsustainable locations, but the release of offices to
                                                   other uses has negative impacts in the loss of
                                                   opportunity for future employment use. This is
                                                   assuming there is increased demand for office space
                                                   in the future. Given the current supply of offices, this
                                                   option will form part of a wider policy approach.
          4 Existing offices should be             The protection of existing offices did not have
          protected                                significant effects against sustainability objectives.
                                                   There was a small margin of support from responses
                                                   to the consultation. It is beneficial to protect offices
                                                   where they provide benefits to the local economy and
                                                   enhance Hounslow’s role as an employment centre,
                                                   consistent with sustainability objectives. It is seen as
                                                   appropriate to take forward as part of a preferred
                                                   option, given the importance of key locations to the
                                                   economy.

          Key issues and mitigation:

5.4.6.1   Ensuring an adequate supply of offices to accommodate demand can be achieved through a
          combination of options. The London Plan seeks the renewal of existing offices and provision
          of additional space whilst maximising the intensity of development. This is reflected in Option
          1, which was favoured by respondents and for which environmental effects can be addressed
          by ensuring intensification/ expansion is only in sustainable locations. Intensification has the

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          potential to increase resource use but through efficient and sustainable design, this can be
          minimised.

5.4.6.2   As described in the table above, it is not considered appropriate to designate new sites for
          offices (option 2) given current demand. Whilst there is sufficient capacity to accommodate
          projected jobs, new development may be appropriate as part of a flexible approach. Along the
          lines of a ‘plan, monitor, and manage’ approach identified in the London Plan, the market
          could construct new offices in some locations and lose it in others, enhancing the quality and
          flexibility of offices available.

5.4.6.3   The development of new sites may result in negative effects where there is a need for
          alternative uses, and existing vacant or underused offices. Through ensuring that proposals
          demonstrate need, this could be avoided. Environmental effects including air and noise
          pollution can arise as a result of traffic but this is subject to the location of new development.
          Assumptions can be made that offices will be located in sustainable locations, but this is
          addressed in the topics that follow. New offices may also provide benefits to the economy by
          attracting new economic development, maintaining Hounslow’s employment role, and
          ensuring access to jobs within the Borough.

5.4.6.4   The effects of releasing office space (option 3) may be acceptable where it enhances a site
          through bringing it back into use, and there is sufficient supply elsewhere to accommodate
          demand for office space. Release of office supply can be beneficial in providing land for other
          uses, particularly where there is a need, such as affordable housing (SA objective 3). The
          release of offices can also result in reduced energy use subject to the proposed alternative
          use being more energy efficient.

5.4.6.5   The retention of vacant office stock (opposite of option 3) can result in the inefficient use of
          land. This may have secondary impacts of not conserving resources or promoting
          regeneration (SA Objectives 11 & 13) as a result of directing other uses elsewhere, and
          placing pressure on greenfield sites, rather than the recycling and reuse of vacant buildings.
          Furthermore, the inefficient use of space does not provide benefits to the local economy due
          to under utilisation of resources, therefore not maximising growth. Thus, the option to allow
          release in some locations (option 3) is appropriate as part of a preferred option subject to
          criteria.

5.4.6.6   The Mayor has identified key locations, which serve or have the potential to serve a need.
          Given the strategic importance of sites such as Chiswick Business Park, it is considered
          appropriate to protect some ‘key office locations’. Whilst the protection of offices in ‘key
          locations’ may result in diminished opportunities for other uses, offices can serve a benefit to
          the local economy and enhance Hounslow’s role as an employment centre. By protecting only
          those sites where there is demand and which have strategic/local importance, other sites
          which are not needed can be released to other uses e.g. affordable housing (positive in terms
          of Objective 3).

5.4.6.7   The protection of offices has potential secondary effects as securing strategically or locally
          important sites for continuing employment use encourages economic development, which can
          enhance people’s quality of life through providing job opportunities. The effects of protection
          are considered in more detail under topic 5d (paragraphs 5.10.1 to 5.10.8).

5.4.6.8   In accordance with a plan, monitor, manage approach, a combination of all four options is the
          preferred approach allowing for intensification to encourage more efficient use of space, new
          development providing enhanced quality and flexibility in sustainable locations, release in
          achieving balance in supply and demand, and protection of sites that have a strategic role
          including town centres.




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          5. Location of offices
5.4.7     Topic 5a Intensification of offices

          Option                                  Reason for inclusion / rejection of option

          1 No intensification of offices         This option was not supported and would not
                                                  enhance Hounslow’s employment role. Furthermore,
                                                  it does not encourage the efficient use of space, and
                                                  is inconsistent with national and regional guidance.
          2 Offices in town centres should be     This option was generally supported. The negative
          intensified                             effects of intensification in town centres would arise
                                                  with any of the following options, incl. resource use
                                                  which may contribute to climate change. The benefit
                                                  of intensification in town centres is the most beneficial
                                                  in sustainability terms (consistent with reducing
                                                  dependency on the car and promoting equality of
                                                  access) as it is the most accessible location by public
                                                  transport. It is therefore the preferred approach.
          3 Offices in edge of town centre        This option does not contribute to improving
          locations should be intensified         accessibility, as it is not the most accessible location
                                                  by public transport. Responses to this option were
                                                  split. The option will not be taken forward ahead of
                                                  directing development to town centres.
          4 Office space should be intensified    This option was the preferred choice in responses to
          in business parks                       the consultation. The negative impacts of this option
                                                  can be overcome through only allowing further
                                                  development in business parks, which are accessible
                                                  by public transport. This will be taken forward as part
                                                  of a preferred option where business parks are
                                                  sustainably located.
          5 Offices should be intensified on      The feedback to this option was negative. Negative
          main road corridors (excl. roads in     effects of this option against sustainability objectives
          town centres, edge of centre            are subject to location and accessibility by public
          locations, or business parks on main    transport. This option will not be taken forward due to
          road corridors)                         the need to direct offices to locations with high public
                                                  transport accessibility (on the assumption that road
                                                  corridors do not have good public transport
                                                  accessibility and no transport improvements are
                                                  proposed e.g. Great West Road).
          6 Offices should be intensified in      This option was not supported and had negative
          inaccessible locations                  impacts on sustainable outcomes incl. equality of
                                                  access, and not encouraging sustainable transport.
                                                  This option is rejected on this basis.

          Key issues and mitigation:

5.4.7.1   PPS6 applies the sequential approach to site selection with offices directed to town centres.
          This is reiterated in the London Plan, which also identifies key locations for offices including
          local town centres reflecting option 2. Benefits from employment in a location with good public
          transport include providing for equality of access, minimising the need to travel by car, and
          minimising the potential environmental effects of travel. For these reasons, as well as the
          favourable response from consultation, option 2 is the preferred option.

5.4.7.2   The Mayor also identifies mid urban Business Parks (Chiswick), business parks out of urban
          areas (Bedfont Lakes) and existing linear development (Great West Road) as key locations
          subject to being made more sustainable. This reflects options 4 and 5. The clustering of
          businesses can contribute to a more robust economy through concentration of economic
          activity and where growth can be accommodated through intensification. Whilst Chiswick
          Business Park is considered to be accessible by sustainable means, minimising the need to

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          travel by car, the other locations are not. Until substantial improvements are made to Bedfont
          Lakes and the key locations on the Great West Road, intensification in these locations is not
          seen to be consistent with sustainability objectives of ensuring equality of access to
          employment, and providing benefits to the local economy in town centres.

5.4.7.3   Secondary effects may also arise from the intensification/expansion of offices in
          unsustainable locations (option 6) for example, through encouraging travel by car, negative
          effects on noise and air quality arise, which can be detrimental to people’s health and quality
          of life. These effects could be mitigated through public transport improvements, from planning
          obligations, and promoting green travel initiatives to encourage employees to use sustainable
          modes of transport. However, improvements to public transport accessibility are not realistic
          in the short to medium term, thus option 6 is rejected.




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5.4.8     Topic 5b New sites

          Option                                    Reason for inclusion / rejection of option

          1 No new sites allocated for offices      There was a split in responses to this option.
                                                    Whilst not designating new sites for offices potentially
                                                    results in the loss of employment opportunities, it may
                                                    prove to be inefficient where there is no demand.
          2 New sites allocated in town centres     This option received general support. There is the
                                                    inherent loss of opportunity for other land uses but
                                                    this option will provide the direction for a preferred
                                                    option given the benefits of directing new office
                                                    development to town centres. These include
                                                    promoting equality of access, use of public transport
                                                    and reducing the potential environmental effects
                                                    arising from travel).
          3 New space allocated for expansion       This was the preferred option from responses. The
          of existing business parks                potential negative impacts of this option can be
                                                    overcome through only allowing expansion in
                                                    business parks, which have good public transport
                                                    accessibility and are sustainable. This will be taken
                                                    forward subject to a restrictive approach.
          4 New sites should be allocated on        The responses to this option were evenly split, and
          main road corridors                       negative effects on sustainability outcomes are
                                                    generally subject to location and accessibility. The
                                                    option will not be taken forward due to the need to
                                                    direct offices to locations with good public transport
                                                    accessibility.
          5 New sites should be allocated in        This option was not supported and had negative
          inaccessible locations                    impacts on sustainable outcomes incl. equality of
                                                    access, and not encouraging use of sustainable
                                                    modes of transport. This option is rejected on the
                                                    basis that even with public transport improvements,
                                                    development would not be sustainable through not
                                                    being in close vicinity of other services.

          Key issues and mitigation:

5.4.8.1   As stated under topic 4 (paragraph 5.6.1 to 5.6.9), the designation of new sites (not previously
          in employment) is not considered appropriate given current demand. However, a preferred
          option will be taken forward to enable new office development to be directed to appropriate
          locations.

5.4.8.2   PPS6 as identified under topic 5a (paragraphs 5.7.1 to 5.7.4) directs offices to town centres,
          which is reflected in regional and sub-regional guidance. New development in town centres
          (option 2) is a preferred option on this basis and because of the favourable response and
          benefits from employment in a highly accessible location by public transport.

5.4.8.3   The Mayor also identifies mid urban Business Parks (Chiswick), business parks out of urban
          areas (Bedfont Lakes) and existing linear development (Great West Road) as key locations
          subject to being made more sustainable. This reflects options 4 and 5. Whilst Chiswick
          Business Park is considered to be a sustainable location, minimising the need to travel by car,
          the other locations are not. Until substantial improvements are made to Bedfont Lakes and
          the key locations on the Great West Road, new development in these locations is not seen to
          be consistent with sustainability objectives, particularly improving public transport accessibility
          to employment (Objective 10), and providing benefits to town centres (Objective 20).




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5.4.9     Topic 5c Release of office sites to other uses

          Option                                   Reason for inclusion / rejection of option

          1 No release of offices for other uses   The community rejected this option although there
                                                   was not a large response. Release of offices may be
                                                   appropriate where there is a not a demonstrated need
                                                   to retain office floorspace, the location is inaccessible
                                                   by public transport or there are adverse effects on the
                                                   surrounding area. Offices in other locations may also
                                                   be released subject to criteria, thus this option is not
                                                   see as appropriate to take forward.
          2 Offices should be released in town     This option was favoured although there was not a
          centre locations                         large response. The negative impacts of this option
                                                   include the loss of potential opportunity for
                                                   employment and in a location with relatively good
                                                   accessibility, which would be in conflict with the SA
                                                   objective of minimising the need to travel. As a
                                                   general presumption, this option is not taken forward.
          3 Offices should be released in edge     This option was favoured although again there was
          of town centre locations                 not a large response. The negative impacts of this
                                                   option include the loss of potential opportunity for
                                                   employment and in a location with relatively good
                                                   accessibility, which would be in conflict with the SA
                                                   objective of minimising the need to travel. A general
                                                   presumption of release in edge of centre locations will
                                                   not be taken forward given edge of centre locations
                                                   are sequentially the second most accessible location.
          4 Offices should be released in          This option was favoured in public consultation
          business parks                           although there were few responses. The negative
                                                   impacts arising are subject to demand for office
                                                   space in business parks, and their location/
                                                   accessibility by public transport. This option is not
                                                   favoured by the Council given the benefits of strategic
                                                   business parks in achieving economic objectives,
                                                   namely maintaining economic development and
                                                   enhancing Hounslow’s employment role. Whilst this is
                                                   contrary to the public response, there were few
                                                   responses, and it is not economically sustainable to
                                                   allow the general release of offices in business parks.
          5 Offices should be released on main     This option was favoured although there was not a
          road corridors                           large response. The effect on economic objectives is
                                                   dependent on need for retaining office space and
                                                   their location/ accessibility. Given the individual
                                                   characteristics of each location, this option is not
                                                   favoured as a general presumption.
          6 Offices in inaccessible locations      This option was the preferred option in consultation.
          should be released                       Any impact is generally positive subject to there not
                                                   being a need, and will be a consideration in
                                                   developing policies.

          Key issues and mitigation:

5.4.9.1   Through consolidation and intensification, there may be capacity to accommodate release of
          office space in achieving sustainable outcomes.

5.4.9.2   The loss of office space does not contribute to maintaining and attracting economic
          development but may provide other benefits to the local area through the more efficient use of
          existing office sites, directing demand for offices to sustainable locations. The release of

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          offices in town centres is not considered appropriate in improving accessibility to jobs and
          attracting new economic development to town centres. Whilst the release of offices in town
          centres is not taken forward as a preferred option, mixed use may be appropriate where it
          retains employment jobs and/or floorspace or where there is no demand or suitable
          alternative supply exists.

5.4.9.3   The identification of Chiswick Business Park, Bedfont Lakes and the Great West Road as key
          locations for offices serving a strategic function is a key consideration in a general
          presumption against the release of offices in business parks. The release of strategically
          important offices has a negative impact in achieving economic objectives, namely maintaining
          economic development and enhancing Hounslow’s employment role. Further justification for
          not allowing release of offices in ‘key office locations’ is addressed from paragraphs 5.10.1 to
          5.10.8.

5.4.9.4   Whilst a general presumption against the loss of offices in edge of centre locations and on
          main road corridors is not favoured, release may be appropriate subject to criteria including
          demand and alternative supply. Whilst there is the loss of employment opportunities, the
          release of offices in locations outside of town centres may provide benefits by directing
          demand to locations more accessible by public transport (town centres). This can have
          benefits in achieving sustainability objectives of improving accessibility to jobs, minimising the
          need to travel, which can contribute to the conservation of resources through reduced levels
          of energy use.

5.4.9.5   Existing offices in inaccessible locations excluding strategically important sites at Bedfont
          Lakes and on the Great West Road, are inherently unsustainable, and should therefore be
          released unless there is a need for it to continue in office use in the short and medium term.
          Whilst public transport improvements could mitigate potential effects, this not realistic in the
          short to medium term.




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5.4.10     Topic 5d Protection of offices

           Option                                   Reason for inclusion / rejection of option

           1 No protection of offices               The responses to this option were split. This option
                                                    may have a negative impact on sustainability
                                                    objectives through the loss of employment
                                                    opportunities although this is dependent on the
                                                    proposed use. Whilst not protecting office sites does
                                                    not result in the loss of an employment use, it
                                                    increases the likelihood. Given the benefits to the
                                                    economy of protecting sites, this option is rejected.
           2 Offices in town centres should be      This was the most favoured option (with option 4)
           protected                                from the consultation, and can facilitate jobs that are
                                                    accessible by public transport, and can promote
                                                    equality of opportunity. The option therefore forms the
                                                    basis for a preferred option.
           3 Offices in edge of town centre         There was a general split in views for this option
           locations should be protected            although there was a low response rate. The
                                                    difference in effects of protecting offices in edge of
                                                    centre locations as opposed to town centre locations
                                                    is marginal. As it is not the most accessible location
                                                    by public transport, a different level of protection may
                                                    be appropriate.
           4 Business parks should be               Any negative effects of this option are subject to the
           protected.                               location and accessibility of business parks. Along
                                                    with town centres, this was also the most favoured
                                                    location for protection of offices from the consultation.
                                                    This option will influence the policy direction taken
                                                    given the benefits of strategic business parks in
                                                    achieving economic objectives, namely maintaining
                                                    economic development and enhancing Hounslow’s
                                                    employment role.
           5 Offices on main road corridors         This option was not supported although there was a
           should be protected                      low response. The impact is dependent on public
                                                    transport accessibility levels. Given the individual
                                                    characteristics of each location, this option is not
                                                    favoured as a general assumption.
           6 Offices in inaccessible locations      This option was not supported by respondents, and
           should be protected                      due to the negative impacts on sustainable outcomes
                                                    incl. equality of access and not encouraging use of
                                                    sustainable modes of transport, this option is
                                                    rejected.

           Key issues and mitigation:

5.4.10.1   The preferred location for protection of offices is town centres with national guidance directing
           offices to town centre locations. This is supported by the London Plan, which identifies town
           centres as a key location for offices serving a strategic and/or local need. Option 2 has
           positive outcomes for the environment through reducing reliance on the car, and economy
           through maintaining economic development in an appropriate location.

5.4.10.2   The London Plan also identifies Chiswick Business Park, Bedfont Lakes and the Great West
           Road as key locations for offices, which are encompassed by options 4 and 5. These
           locations are strategically important and provide modern office accommodation in age and
           quality, and high quality urban design.

5.4.10.3   Furthermore, the occupiers in these locations have a strong presence visually and
           economically in West London, supporting the economic objective in the SA of enhancing

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           Hounslow’s role in a West London and London context. The presence of large firms has had
           a secondary effect of attracting other firms to the borough through benefits of business
           concentration and proximity to the supply chain.

5.4.10.4   Whilst public transport accessibility to Bedfont Lakes and office locations along parts of the
           Great West Road is relatively poor, past standards permitted high levels of car parking
           provision, contributing to good access between Heathrow and Central London. Whilst it is
           inconsistent with the SA objective of reducing reliance on the car, these strategically
           important sites make a significant contribution to the office supply in West London. They have
           a positive effect on local communities in providing employment opportunities, but also
           indirectly in supporting local services, which meet the needs of employees working in
           Chiswick Park, Bedfont Lakes and the Great West Road.

5.4.10.5   Protection of offices in these locations provides for large companies requiring a significant
           amount of office floorspace. The scale of offices is such that they could not be accommodated
           within the Borough’s town centres, due to capacity and the town centre’s role and function
           within the hierarchy, considerations identified in national and regional guidance. The offices in
           Chiswick Business Park, Bedfont Lakes and on the Great West Road do not relate to the role
           and function the town centres serve, with Hounslow being the only Metropolitan centre.

5.4.10.6   The identified key office locations have also facilitated growth industries, including the media
           and creative industries, exemplified at Chiswick Business Park, which has had high quality
           modern space to accommodate growth, and been receptive to the industry. These factors
           necessitate the protection of the key locations identified in addition to offices in town centres.

5.4.10.7   It is considered appropriate to protect offices outside town centres (edge of centre and on
           main road corridors) where serving a need, and subject to being a sustainable location
           accessible by public transport. This approach is not appropriate for inaccessible locations
           where it is not sustainable to protect offices. The release of relatively inaccessible offices will
           potentially further reduce overall supply and increase the need to require marketing evidence
           as a test for the potential loss of preferably located offices.




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5.4.11     Topic 6 Supply of industrial land

           Option                                   Reason for inclusion / rejection of option

           1 Need for an increase in the supply     The responses to this option were split. There are
           of industrial land                       potential negative effects against environmental
                                                    criteria subject to the location and accessibility of new
                                                    sites. The provision of new land for industrial uses
                                                    may make reuse or intensification of existing land
                                                    less likely but where there is a need, may have
                                                    economic benefits. From research undertaken at a
                                                    regional (GLA) and local level (Hounslow
                                                    Employment Land Study), there is not a need for
                                                    increases in the overall supply of industrial land at the
                                                    current time.
           2 Current supply of industrial land is   The responses to this option were split. In achieving
           sufficient for the plan period           good economic outcomes incl. maintaining economic
                                                    development, this option is favoured. Whilst retaining
                                                    vacant industrial land does not help improve the
                                                    quality of where people live, there is evidence to
                                                    demonstrate that vacancies will not continue in the
                                                    long term. Evidence in the Employment Land Study
                                                    demonstrates that there is a need to retain and
                                                    protect a large proportion of the industrial land in the
                                                    borough for the plan period, therefore this option
                                                    forms the basis for policy.
           3 Some industrial land should be         The responses to this option were also split. The loss
           released for other uses                  of industrial land would have a negative impact on
                                                    economic outcomes particularly in maintaining and
                                                    enhancing Hounslow’s employment role and
                                                    attracting new economic development given current
                                                    demand and supply. This option will be given
                                                    consideration in development of policy but a
                                                    restrictive approach will be taken to the release of
                                                    industrial land, in accordance with studies of
                                                    employment land at a regional and local level.
           4 Need for renewal of industrial sites   This option received this most support, although there
                                                    was not a large response. Renewal of existing sites
                                                    has little or no negative effects subject to the
                                                    redevelopment of sites being sustainable. This option
                                                    will form the basis for policy direction given the
                                                    positive effects particularly in attracting new economic
                                                    development, and improving the quality of where
                                                    people live.

           Key issues and mitigation:

5.4.11.1   The Hounslow Employment Land Study (2004) indicates that whilst there is a reduction in
           projections for employment growth (jobs) to 2016, there is demand for industrial and
           warehousing land. The decline in industrial demand is made up for by increased demand for
           warehousing and distribution space. The pressure on industrial land in the borough is
           reflected in the amount of vacant land available, representing 5 years supply.

5.4.11.2   Whilst there is currently 5 years supply, an increase in the supply of industrial land is not
           appropriate (option 1). This may change with an increase in employment growth. However,
           option 1 may result in the inefficient use of land where it remains vacant for a long period.
           Consistent with the sustainability objective of promoting regeneration and making use of
           existing supply, option 1 is not appropriate until evidence demonstrates that there is a need
           for more industrial land across the borough. There may be a need for additional land/space to

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           accommodate businesses with a specific need e.g. small-managed workspaces, but the
           overall supply is considered sufficient from evidence in the Employment Land Study 2004.

5.4.11.3   Maintaining the existing supply of industrial land (option 2) can encourage the conservation of
           resources and regeneration of existing vacant land/buildings. A small level of vacancy as
           exists is essential to enabling the economy to function efficiently, and maintaining existing
           office supply is therefore beneficial against economic objectives.

5.4.11.4   Through efficient use of land and higher density development in appropriate locations, access
           to jobs can be improved as well as potentially reducing the need for land, therefore providing
           the opportunity for other uses (beneficial against Objective 3). Productivity gains achieved
           through investment in new technologies will also contribute to efficient use of land.

5.4.11.5   By maintaining the existing supply of industrial land (Option 3), the reuse of derelict land is
           more likely than if industrial land capacity is increased. Reuse of land can also have
           secondary effects of potentially reducing the fear of crime by creating an active environment
           and also improve the quality of where people live.

5.4.11.6   The Mayor’s London Industrial Land Release Benchmarks (2007) and review of supply and
           demand in the Hounslow Employment land study and GLA study ‘Industrial and Warehousing
           land demand in London’ suggest that a restrictive approach should be taken to the release of
           industrial land to other uses. Release of industrial land can have negative implications in
           reducing job opportunities and access to jobs. These effects can be minimised by ensuring
           there is sufficient supply to accommodate demand.

5.4.11.7   Any more than marginal release would affect the demand and supply balance from evidence
           at a local and regional level, thus a general presumption for allowing release is not
           appropriate and a restrictive approach will be taken to any loss. Release may only be
           appropriate where there is not a need for the retention of industrial and warehousing land and
           there are negative impacts on the site’s surroundings. Effects of retaining industrial uses in
           inappropriate locations may arise including harm to resident’s quality of life, noise and air
           pollution, which is inconsistent with objectives 5, 15,16 and 19. Mitigation may include a
           reactive response by the Council through enforcement, ensuring new development is
           sustainable, and promoting improvements to existing sites e.g. screening.

5.4.11.8   In accordance with the ‘plan, monitor, and manage’ approach in the Mayor’s Draft SPG on
           industrial capacity, option 4 is seen as forming an integral part of a preferred option in
           ensuring industrial sites remain competitive for different types of occupiers. The benefits in
           sustainability terms are primarily in terms of attracting new economic development and
           therefore jobs, but also in potentially improving the quality of where people live through more
           efficient and sustainable use of land. Renewal of industrial sites is consistent with promoting
           regeneration and conserving resources that may otherwise be lost through new development.




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5.4.12     Topic 7 Delivery of industrial land

           Option                                    Reason for inclusion / rejection of option

           1 Existing industrial land, which has     This option received a favourable response.
           good site characteristics should be       Intensification of industrial uses may potentially result
           intensified/expanded.                     in negative environmental effects and reduce the
                                                     quality of where people live. However, this could be
                                                     overcome through appropriate mitigation e.g.
                                                     screening, ensuring sustainable construction, and
                                                     promotion of measures to improve practices.
                                                     Intensification may also be beneficial in providing for
                                                     the efficient use of land, potentially freeing up land for
                                                     other uses. This option is therefore seen to form the
                                                     basis for the preferred option.
           2 New areas should be designated          This option had support but this was marginal relative
           for industrial use where the site(s)      to those who disagreed. The provision of new areas
           have good characteristics.                for industrial use will have negative effects on
                                                     environmental objectives, which may be overcome
                                                     through ensuring the site is separated from sensitive
                                                     uses and has good accessibility. However, there is
                                                     the potential loss of opportunities for other land uses,
                                                     and it may make the redevelopment of vacant
                                                     industrial sites less attractive. This option will inform
                                                     policies for new development, but it is not considered
                                                     appropriate to designate new sites.
           3 Some industrial land should be          This was the preferred response from the
           released for other uses, where site(s)    consultation. The loss of employment on industrial
           do not have good characteristics.         land may have a negative effect on economic
                                                     outcomes, but this can be overcome by ensuring
                                                     there is sufficient supply to accommodate demand.
                                                     Release may be appropriate where there are
                                                     negative effects on the environment, particularly the
                                                     quality of where people live, thus the option
                                                     contributes to the preferred option.
           4 Existing industrial estates that have   This option received a favourable response. The
           strategic importance at a London          effects on sustainability outcomes are generally
           level and/or at a local level should be   positive particularly in terms of maintaining/
           protected.                                enhancing Hounslow’s employment role in a West
                                                     London and London wide context. This option will
                                                     also form basis for a preferred option.

           Key issues and mitigation:

5.4.12.1   Option 1 of intensification/expansion on existing industrial sites is consistent with the objective
           in the London Plan and Draft SPG (Industrial Capacity) of encouraging sustainable use of
           industrial land by fostering more dense development. In retaining sites for industrial use,
           criteria identified in the Draft SPG include the potential of a site for in-situ expansion of
           existing industrial businesses.

5.4.12.2   Intensification may be beneficial in providing more jobs on a site and/or result in the more
           efficient use of land, potentially reducing the need for additional land where there is demand.
           The more productive use of land can potentially free up land for other uses incl. housing,
           improving physical access to jobs and other services, and contributing to equality of access.
           Development through intensification can also have negative impacts, including resource use
           resulting in increased noise and air pollution, in turn contributing to climate change. Through
           efficient and sustainable design, this can be minimised.



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5.4.12.3   The Council is seeking to achieve the right balance between demand and supply in
           accordance with regional guidance. There is currently sufficient capacity to meet demand at a
           macro level and therefore development on new sites (not previously in employment use) may
           only be appropriate where it meets a need, enhances the quality of provision and maintains/
           enhances lower cost capacity. The development of new sites may result in negative effects
           where there is a need for alternative uses and existing vacant or underused stock. Balancing
           the needs of different uses can ensure sustainability outcomes and minimise potential effects.

5.4.12.4   As identified above, environmental effects may also arise from development. Subject to
           location, development incl. expansion can impact on biodiversity (whether it is a brownfield or
           greenfield site), open space and/or the Borough’s townscapes and landscapes but this could
           be avoided when specific proposals are considered.

5.4.12.5   As stated under topic 6 (paragraphs 5.11.1 to 5.11.9), a restrictive approach is preferred to
           the release of industrial land to other uses. Negative impacts on the environment and/or
           community of an existing industrial use may mean release is appropriate. However, measures
           can address these impacts including separation, improvements to existing practices, and
           reactive action by the Council (enforcement). Whilst there maybe negative impacts on the
           economy of releasing industrial land to other uses, this can be addressed through mixed use
           for example. Other effects of release are considered under topic 6 (paragraphs 5.11.1 to
           5.11.9).

5.4.12.6   The London Plan identifies Strategic Employment Locations and the Borough can designate
           locally significant industrial sites for protection and to sustain industrial capacity. Furthermore,
           this approach enhances the importance of Hounslow as an employment centre and attracts
           new economic development. Supporting the existing use of industrial land and retention of
           capacity for further development will have positive effects on economic outcomes, and
           negative effects on environmental objectives, including air quality, use of resources, and
           climate change. However, this reflects the inherent conflict between SA objectives identified
           earlier.




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           8. Location of industrial land
5.4.13     Topic 8a Identification of Strategic Employment Locations (SELs) and criteria based
           approach for identifying Locally Significant Industrial Sites (LSISs)

5.4.13.1   Planning Policy Statement 12 states that identification of sites for allocation, including
           Strategic Employment Locations and Locally Significant Industrial Sites, should be based on a
           robust and credible assessment of sites. The following section together with the document
           Background paper to Employment Development Plan Document (January 2006, updated July
           2007) provides the evidence to support the identification of strategic and locally significant
           industrial sites.

           Strategic Employment Locations (identified as Strategic Industrial Locations in the
           submission version of the Employment DPD)

5.4.13.2   The basis for designating Strategic Employment Locations (SELs) is in the London Plan,
           which identifies the general locations of SELs. The SEL framework is designed to reflect the
           needs of business in terms of

               o   Clustering
               o   Capacity
               o   Environment
               o   Accessibility
               o   Cost requirements

5.4.13.3   The London Plan identifies SELs, including Industrial Business Parks (IBP) and Preferred
           Industrial Locations (PILs), in Hounslow as listed below (refer to Annex 2 of the London Plan).
           Policies 2A.7 and 3B.5 state that Boroughs should identify SELs in UDPs therefore
           establishing their ‘identity’ and the boundaries of the SELs

                   North Feltham Trading Estate (PIL)
                   Brentford (part), including Transport Avenue Industrial Area, Commerce Road (PIL)
                   Great West Road (IBP)

5.4.13.4   As a part of the Options consultation paper (June 2005), Question 8a provided the public with
           the opportunity to identify the estates they thought should be part of a SEL. The estates listed
           as ‘options’ included those estates identified by the Mayor as well as estates within the ‘close
           proximity of those estates identified by the Mayor. Information was provided on each industrial
           estate in a Background paper to supplement the options consulted on in June 2005. This
           included the following information (subject to the location and characteristics of each site)

               o   Name of estate
               o   The uses on the estate
               o   Function that the estate served
               o   Location in relation to strategic highway network
               o   Accessibility to public transport
               o   Location relative to town centre
               o   Proximity to airport
               o   Distance from noise sensitive uses incl. residential
               o   Area of industrial activity/ size

5.4.13.5   The technical nature of the issues, and difficulties of encapsulating all information into the
           consultation documents contributed to a low response to the question of which estates should
           be included within an SEL. Whilst the responses to the consultation can inform the appraisal
           of sites, limited weight has been given due to the low response.




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5.4.13.6    Specific reference has been made in the London Plan to industrial estates in describing SELs
            (Refer to Annex 2) therefore recognising their strategic importance and giving weight to their
            identification as preferred sites.

5.4.13.7    The Great West Road Industrial Business Park is an SEL more difficult to define relative to
            the Brentford and North Feltham SELs as there is no reference to specific estates in the
            London Plan. To assist in establishing the boundaries of the SELs, the Mayor’s Draft SPG on
            Industrial capacity provides guidance on the uses appropriate within SELs. Therefore, the
            boundaries of strategic employment locations have been defined to reflect the current use of
            sites and drawn to exclude where appropriate any uses not compatible with the designations
            as Preferred Industrial Locations or Industrial Business Park.

            Locally Significant Industrial Sites

5.4.13.8    The London Plan states that Boroughs should identify industrial sites outside of the SEL
            framework that they wish to protect for locally significant industrial uses. These sites will be
            afforded the same protection as the SELs. To ensure that land protected as locally significant
            is used efficiently it must be demonstrated that there is demand. The Mayor’s SPG on
            Industrial Capacity 2003 proposes categories that Boroughs are assigned to as an indication
            of borough level industrial demand and the broad policy response to this. The most up to date
            research in the Hounslow Employment Land Study (2004) and London Industrial Land
            Release Benchmarks (2007) recommends a restrictive approach to the release of land.

5.4.13.9    As a part of the Options consultation paper (June 2005), Question 8a provided the public with
            the opportunity to identify the estates they thought were locally significant. This included any
            group of units in industrial and/or commercial activity and which were assessed as part of the
            Hounslow Employment Land Study 2004. These employment sites included industrial estates,
            warehousing and logistics parks, and business parks.

5.4.13.10   Information was provided on each industrial estate in a Background paper to supplement the
            options consulted on in June 2005. This included the following information (subject to the
            location and characteristics of each site)

                o   Name of estate
                o   The uses on the estate
                o   Function that the estate served
                o   Location in relation to strategic highway network
                o   Accessibility to public transport
                o   Location relative to town centre
                o   Proximity to airport
                o   Distance from noise sensitive uses incl. residential
                o   Area of industrial activity/ size

5.4.13.11   The initial stage in identifying estates that were locally significant was the collation of baseline
            information on each site to enable an assessment. This included information from the
                 o Hounslow Employment Land Study 2004
                 o Industrial Estates Database 2004
                 o Site visits
                 o Information available on the internet

5.4.13.12   Following the collection of baseline information and an understanding of the data available,
            criteria were developed to appraise industrial estates for their local significance. This was
            based on factors set out in paragraphs 6.13 to 6.15 of the Mayor’s Draft SPG on industrial
            capacity.

5.4.13.13   The criteria fits’ into 5 categories Site characteristics, Clustering, Environment,
            Accessibility/ Location and Need and was appraised for its impacts on sustainability
            objectives as part of the Employment Development Plan Sustainability Appraisal Report 2006
            (refer to Appendix 5 under Question 8a for an assessment of the criteria against the 23 SA

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            objectives and commentary on the negative (-) or potentially negative effects (?) arising).
            Section 6.2.2 of this SA report sets out how the effects arising from the criteria have been
            addressed in the Development Plan Document and any mitigation where appropriate.

5.4.13.14   The document Background paper to Employment Development Plan Document outlines the
            process in defining Locally Significant Industrial Sites as part of the preferred options
            including the appraisal of sites to determine whether they are locally significant. This was
            subsequently updated in preparation of the submission version of the DPD.

            Key Existing Office Locations and Proposed Office Locations

5.4.13.15   The basis for defining Key Existing Office Locations is set out in Background paper to
            Employment Development Plan Document. Policy EP2, which the designation of Key Existing
            Office Locations reflects, has been subject to a sustainability appraisal at the preferred
            options stage (refer to SA of preferred options 5c, 5d and 9b in Appendix 6). As the preferred
            options have been subject to a SA, it is not considered appropriate to appraise the designated
            sites, which illustrate the intent of Policy EP2

5.4.13.16   Despite the name, ‘Proposed Office Locations’ are not proposal sites/site allocations. The
            purpose of identifying ‘Proposed Office Locations’ is to illustrate the intent of Policy EP1 of the
            DPD that directs proposals for new office development to town centres and Chiswick Park in
            the first instance. Preferred options 5A and 5B (from which Policy EP1 of the DPD has
            developed) have been subject to a sustainability appraisal and it is not therefore appropriate
            to appraise the designated sites to which the policy relates.




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5.4.14     Topic 8b Intensification/expansion of sites

           Option                                    Reason for inclusion / rejection of option

           1 Intensification/expansion should be     This was the preferred option from respondents.
           on SELs                                   Intensification of industrial uses may potentially result
                                                     in negative environmental effects and reduce the
                                                     quality of where people live.
                                                     However, criteria identifying sites as SELs takes into
                                                     account the surrounding uses and distance to
                                                     residential uses. Furthermore, any potential effects
                                                     could be overcome through appropriate mitigation
                                                     e.g. screening, and sustainable development. This is
                                                     seen as forming the basis for a preferred option.
           2 Intensification/expansion should be     This option was supported although less responded
           on LSISs                                  compared to option 1.
                                                     Intensification of industrial uses may potentially result
                                                     in negative environmental effects and reduce the
                                                     quality of where people live.
                                                     However, criteria for allocation of sites as LSISs takes
                                                     into account the surrounding uses and vicinity of
                                                     residential. Furthermore, any potential effects could
                                                     be overcome through appropriate mitigation e.g.
                                                     screening, and sustainable development. This is seen
                                                     as forming the basis for a preferred option.
           3 Intensification/expansion should be     This option was rejected although there was a higher
           in other locations                        proportion that did not respond compared to options 1
                                                     and 2. As above, there could potentially be negative
                                                     effects on environmental outcomes. Whilst, other
                                                     sites are not allocated as strategically or locally
                                                     significant, they may still function successfully and
                                                     serve a need. This is also seen as forming the basis
                                                     for a preferred option.

           Key issues and mitigation:

5.4.14.1   The preferred approach is for intensification/expansion on all industrial sites regardless of
           their strategic and/or local role. It is not seen as appropriate to restrict development to
           strategic and locally significant industrial sites given the economic contribution that small-
           scale industrial sites make.

5.4.14.2   The effects of intensification and expansion identified under topic 7 (paragraphs 5.12.1 to
           5.12.7) arise regardless of the level of protection given to a site. The location of a site may
           have specific impacts. However, it would be inappropriate to rule out intensification/expansion
           on more isolated sites outside the SEL framework if the site characteristics and the proposed
           development were acceptable in terms of sustainability impacts.




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           9. Other uses
5.4.15     Topic 9a Hotels

           Option                                   Reason for inclusion / rejection of option

           1 Sites should be allocated where        Respondents generally supported this option.
           their location is accessible by a        Resource use potentially results in negative effects in
           choice of modes of transport             achieving environmental objectives due to
                                                    construction and operations of a hotel (incl. energy
                                                    use, potential emissions). How these effects have
                                                    been considered in the DPD are covered in Section
                                                    6.2. The option is favourable in providing benefit to
                                                    the town centres and providing access to
                                                    employment, and is seen to form the basis for policy.
           2 An area adjacent to Heathrow           This option was also supported. There are potential
           airport should be designated for hotel   negative effects on environmental objectives incl.
           uses                                     impacts on residential amenity, and hotels close to
                                                    Heathrow with low levels of public transport
                                                    accessibility can encourage use of the car. However,
                                                    the function airport hotels generally serve and vicinity
                                                    to Heathrow may minimise the distance to travel.
                                                    Furthermore, linkages with Heathrow by public
                                                    transport may make this a sustainable location. It is
                                                    therefore considered to form part of the preferred
                                                    option.
           3 Inappropriate to allocate sites for    Whilst this was the preferred option from responses, it
           hotel use                                is not seen as appropriate to allow the market to
                                                    direct the location of hotels given the potential
                                                    negative effects on environmental and economic
                                                    objectives. Otherwise, there is potential for hotels to
                                                    be located in inaccessible locations.
           4 There is not the capacity for          This option was rejected, and is not seen to provide
           additional hotels                        opportunities for access to services including
                                                    employment or maintaining/attracting economic
                                                    development. Furthermore, there is research to
                                                    demonstrate a need for additional hotel rooms across
                                                    Greater London. For these reasons it is not taken
                                                    forward.

           Key issues and mitigation:

5.4.15.1   PPS6 applies the sequential approach to site selection including hotels, which are identified
           as a town centre use. The benefits in achieving sustainable outcomes are positive in reducing
           reliance on the car, improving access to employment opportunities, and contributing to the
           regeneration of town centres. Furthermore, directing visitor accommodation to town centres is
           consistent with SA objectives of regenerating town centres and promoting equality of access.
           The London Plan supports the development of hotels in town centres where small-scale
           provision can be accommodated. On this basis as well as the favourable response from
           consultation and benefits from employment in a location with good public transport
           accessibility, this is the preferred option.

5.4.15.2   The Mayor identifies a strategically important cluster of hotels and related development
           around Heathrow where further development for visitor accommodation is encouraged. The
           function visitor accommodation serves for people who are visiting Heathrow itself provides
           reason to allow hotel development. Although it is an out of centre location, accessibility to
           Heathrow is good and there is a need for airport hotels. Subject to ensuring town centres
           locations are considered first, it is appropriate to direct airport hotels to the area along the
           Bath Road close to the airport. However, the designation of a specific area is not proposed as


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           each proposal will be assessed on its circumstances, incl. the level of accessibility by public
           transport and need for the particular type of accommodation.

5.4.15.3   Given the demonstrated need for hotels identified in the Mayor’s Tourism Strategy and
           potential loss of economic opportunities including access to services, option 4 is rejected.

5.4.15.4   It is important in achieving sustainable outcomes that hotels are directed to appropriate
           locations in accordance with national and regional guidance. Options 1 and 2 will therefore be
           taken forward.




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5.4.16.    Topic 9b Mixed uses

           Option                                  Reason for inclusion / rejection of option

           1 A mix of uses including housing       This option was generally supported. The adverse
           should be encouraged on                 effects of this option on economic objectives (loss of
           employment sites                        potential employment opportunities) are dependent
                                                   on the balance of uses, but there is also the potential
                                                   effect on quality of life/ environment from
                                                   industrial/commercial operations. However, there is
                                                   the assumption that mixed use will not be appropriate
                                                   where employment uses do not require a high quality
                                                   environment unless it can be demonstrated that
                                                   housing would not compromise the other uses on the
                                                   site. This option will inform a preferred option but will
                                                   be restricted by criteria.
           2 A mix of uses may be appropriate      This option was also supported. Effects of the option
           on some employment sites whilst         on economic objectives are dependent on the
           ensuring that employment remains        balance of uses (potential loss of employment
           the predominant use, and provided it    opportunities. This option will form a part of a
           does not affect operation of existing   preferred option with further consideration to criteria,
           businesses                              in addition to the assumption within the option that
                                                   other uses are acceptable if they do not affect the
                                                   operation of existing businesses.
           3 A mix of uses on employment sites     The views on this option were generally split. Whilst
           is not appropriate, and sites should    there are the positive effects of this option in
           be used primarily for B1, B2 and/or     providing benefits to the local economy through
           B8 uses.                                protection for industrial/ commercial uses, it does not
                                                   necessarily improve accessibility to jobs and services
                                                   (as is assumed with mixed use) or attract new types
                                                   of business. This option is not taken forward as part
                                                   of the preferred option as it is also inconsistent with
                                                   national and regional guidance.
           4 Employment sites should               This was the preferred option from consultation. The
           accommodate uses, which generate        option has potential negative effects in terms of noise,
           employment and not be restricted to     air quality, and waste that arise from
           B1, B2 and/or B8 use, whilst            industrial/commercial development. How these
           maintaining sufficient land to meet     effects are addressed is covered in section 6.2. The
           demand for these uses.                  option may be beneficial in maintaining economic
                                                   development through a diversity of uses/jobs but this
                                                   is subject to capacity and attracting other employment
                                                   uses outside of B1, B2, and B8. The option is taken
                                                   forward to support achieving the objective of
                                                   economic diversity.

           Key issues and mitigation:

5.4.16.1   Guidance at a regional and local level encourages mixed-use development in achieving
           sustainable objectives. This can be beneficial in achieving economic growth through
           intensification and the efficient use of land. As a general principle, mixed use on employment
           sites may be appropriate where it does not compromise the offer of sites for a range of uses
           including industrial.

5.4.16.2   Given the balance between employment land demand and supply, a restrictive approach is
           appropriate to ensure the objective of providing sufficient employment land for growth.

5.4.16.3   Options 1,2 and 4 are all to be taken forward with the balance of uses subject to other factors
           including employment demand and supply including the number of jobs and/or floorspace, the
           types of uses, accessibility, and effects on sustainability objectives.

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6       Plan Policies
6.1     Significant social, environmental and economic effects of the preferred
        options
6.1.1   Please refer to Appendix 6, which provides an appraisal of each preferred option against the
        23 sustainability objectives (Environmental, Social and Economic). As outlined below, the
        submission version of the DPD objectives and policies have developed from the preferred
        options. To assist, the draft objectives and policies that each preferred option has informed
        have been identified before each table in Appendix 6.

6.1.2   The appraisal of effects is compared with the effects of a “status quo” option of retaining
        existing policies in the Unitary Development Plan December 2003 and a “Do nothing” option
        of relying on national and regional guidance.

6.1.3   The effect is identified using the following levels:


                         ++                Major Positive
                         +                 Minor Positive
                         0                 No impact
                         -                 Minor Negative
                         --                Major Negative
                         ?                 Uncertain


6.1.4   In addition, the effects of the preferred options, ‘status quo’ and ‘Do nothing’ have been
        assessed for their significance with consideration to the probability, geographical scale,
        duration and timing of the effects arising. These factors have been assessed to determine the
        overall significance of the effect arising from the options against each sustainability objective.

6.1.5   The overall significance has been defined using the following levels:


                         H                 High
                         MH                Medium High
                         M                 Medium
                         LM                Low Medium
                         L                 Low
                         NS                No significance


6.1.6   In line with ‘Task D2(i): Appraising significant changes’ of DCLG guidance Sustainability
        Appraisal of Regional Spatial Strategies and Local Development Plan Documents the need to
        re-appraise submission draft policies for impact on sustainability has been considered.

6.1.7   Where a draft policy is a refinement of one of the preferred options including more detailed
        policy wording or a refinement of the criteria, a further Sustainability Appraisal (SA) has not
        been carried out in addition to the work in the Employment Development Plan Sustainability
        Appraisal report (January 2006). An assessment (refer to Appendix 4) has established that
        all submission draft policies and objectives are a refinement of Preferred Options and
        therefore do not incorporate significant change.

6.1.8   However, a vision has been formulated at the submission stage and was therefore not subject
        to the SA undertaken at the Preferred Options stage. There is hence a requirement to
        appraise the draft vision contained in the Submission Employment DPD for impacts on
        sustainability.



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132
6.1.9   The following tables summarise the significant effects arising from the assessment of the
        preferred options against the 23 sustainability objectives. These have been identified from the
        assessment in Appendix 6 on the basis that a significant effect is rated as high or medium
        high in terms of ‘overall significance’

                                                         Social
        Positive                                             Negative
        By providing opportunities for diversity, the        Development facilitating/as a result of
        needs of different individuals and                   employment growth can result in increased noise
        businesses/groups can be provided for                subject to the type of development. The
        (Preferred options 2, 9b).                           difference in noise levels is subject to size,
                                                             scale, accessibility and location (Preferred
                                                             options 1, 2, 3, 5d, 8b, 9a).
        Directing employment use to sustainable
        locations and the efficient use of land can
        contribute to enhancing access to employment
        opportunities, and consequently other services
        (Preferred options 3, 4, 5a, 5b, 5c, 5d).

        Release of employment land creates
        opportunities for of uses including affordable
        housing (Preferred option 5d)

        Through promoting Hounslow as an employment
        centre for a range of business, skills and
        educational opportunities can be improved
        through employment or programmes established
        by companies (Preferred option 2).

        The quality of people’s environment can be
        enhanced through the provision of employment
        close to where they live. This can be achieved
        through accommodating different sized
        businesses (Preferred option 2).

        Release of some land could lead to a reduction
        in noise in areas adjacent to the site and
        concentrate noisier employment uses on
        appropriate sites (Preferred option 6, 7)

                                                    Environmental
        Positive                                           Negative
        The delivery of industrial and commercial          Additional resources are required in providing for
        developments in locations accessible by            employment growth through construction,
        sustainable modes of transport can reduce the      operation and travel (Preferred options 1, 2, 3, 4,
        need to travel by car (Preferred options 3, 4, 5a, 5a, 5b, 5c, 5d, 6, 7, 8b, 9a).
        5b, 5c, 5d, 6, 7, 9a, 9b)
        Efficient use of space can provide opportunities   New development facilitating/as a result of
        for alternative uses and encourage                 employment growth contributes to reduced air
        redevelopment of previously developed land and quality and greenhouse gas emissions through
        buildings for other uses (Preferred options 3, 4,  construction, operations and travel (Preferred
        5a, 5b, 5c, 6, 7, 8b, 9b)                          options 1, 2, 3, 4, 5a, 5b, 5d, 6, 7, 8b, 9a).
                                                           However, employment development is
                                                           considered to have a minimal impact on the
                                                           highway network. Please refer to para 5.5 of the
                                                           Brentford Area Action Plan Draft Transport Study
                                                           (2007) for detailed impacts of employment

                                                                                                  133
                                                                development.
         New developments presents opportunities to             Growth resulting in/as a consequence of
         secure funding for improvements to existing            development increases the amount of waste
         open space (Preferred options 4, 5a, 5b).              produced (Preferred options 1, 2, 5a, 5b, 5c, 7,
                                                                8b, 9a).


                                                         Economic
         Positive                                              Negative
         The appropriate amount of employment land in
         accessible locations will ensure the provision of
         the optimum number of job opportunities and in
         the most sustainable locations (PO 3, 4, 5b, 6,
         7, 9b)
         A criteria-based approach to the selection of
         industrial sites for protection will allow industrial
         development in the most appropriate locations
         (PO 8b).
         Through facilitating a role for Hounslow as a
         strategic local centre, greater benefits can be
         achieved for the local economy, with
         employment and investment encouraged in
         town centres (PO 2, 5a, 5b, 5c, 5d, 6, 7, 9a).
         An appropriate balance of supply and demand
         will ensure an efficient economy and labour
         market, enhancing Hounslow’s employment
         role (PO 3, 5c, 6, 7)
         Attracting strategic and local businesses to the
         Borough through the provision of quality and
         flexible space can enhance accessibility to jobs,
         education and training. Increased employment
         opportunities may be available in range of
         industries of different sizes (PO 2, 4, 5a, 5b, 5c,
         6, 7, 9a, 9b).

         Assessment of cumulative effects (incl. secondary effects)

6.1.10   There are a number of secondary effects that have been identified in the appraisal of options
         and preferred options, for example the development of high trip generating uses e.g. offices,
         hotels in locations not accessible by a choice of modes of transport contributes to increased
         use of private vehicles. The effects of increased vehicle use include emissions (car fumes),
         which can contribute to climate change. These have been identified as effects in the
         sustainability appraisal report but may be secondary rather than primary effects.

6.1.11   In terms of cumulative effects, the last section identifies the significant effects arising from
         each preferred option within the DPD. The following table seeks to summarise effects that
         may arise from a combination of policies in the DPD. How negative effects have been
         addressed in the DPD including mitigation is addressed in section 6.2 of this report.




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Assessment of effects of DPD and potential cumulative effects arising

Policy                                                    Potential cumulative effect
E1 Maintaining Employment capacity                        Maintaining employment capacity through the protection and managed release of sites together with
                                                          seeking to retain business in the borough (Policy E3) can enhance access to employment (SA
                                                          objective 6) and therefore contribute to more sustainable patterns of travel (SA objective 10) within the
                                                          context of growth in the resident working population.
E2 Locations for Employment                               Directing high trip generating uses to sustainable locations can reduce car use (SA objective 10), which
                                                          in combination with Policy E1 that seeks to maintain capacity in these locations can ensure they
                                                          continue to be the foci for employment and other services (SA objective 20).
                                                          Policy E2 in combination with policy E1 also enables strategic and locally significant industrial sites to
                                                          develop and support employment, thus benefiting the local economy (SA objectives 21, 22).
E3 Local employment opportunities                         Policy E3 that seeks to enhance and retain business in the Borough in combination with Policy E1 of
                                                          sustaining capacity to accommodate employment can strengthen Hounslow’s employment role (SA
                                                          objectives 22/23).
E4 Diversity in employment                                Encouraging a range of business activities together with sustaining employment capacity (Policy E1)
                                                          can enhance Hounslow’s importance as an employment centre and improve accessibility to jobs/
                                                          training (SA objectives 6, 23)
EP1 Location of new office-based employment               Directing new office development together with hotels and visitor accommodation (Policy EP10) to town
                                                          centres can enhance their role as the foci for services and employment (SA objective 20). In
                                                          combination, these policies together with a more flexible approach to release in out of centre locations
                                                          (policy EP4) can encourage more sustainable travel (SA objective 10) and also provide better access
                                                          to services, particularly for those who depend on public transport (SA objective 6).
                                                          The development of new office floorspace can however increase resource use (SA objective 11) and
                                                          the production of waste (SA objective 17). This policy together with policies EP5, EP9 and EP10 and
                                                          proposals in the Brentford Area Action Plan results in greater requirements. Secondary effects of
                                                          resource use and waste include noise (SA objective 5) and pollutants (SA objective 16) which can
                                                          harm quality of life (SA objective 9) and contribute to climate change (SA objective 15)
EP2 Change of use from offices in Town Centres and Key    In combination with policies EP4 and EP8, the managed release of land from employment use can
Existing Office Locations on the Great West Road and at   regenerate sites and bring them back into use (SA objective 13). Furthermore, the reuse of land for
Bedfont Lakes                                             alternative uses can conserve resources (SA objective 11), which can ensure areas of open space and
                                                          biodiversity are maintained (SA objectives 12, 14).
EP3 Chiswick Business Park                                In combination with policy EP1 which directs new development to Chiswick Park together with town
                                                          centres, the role of Chiswick Park as an office location can be strengthened contributing to Hounslow’s
                                                          role as an employment centre (SA objective 21, 22).


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EP4 Change of use from offices (Outside town centres and Key   In combination with policies EP2 and EP8, the managed release of land from employment use can
Existing Office Locations)                                     regenerate sites and bring them back into use (SA objective 13). Furthermore, the reuse of land for
                                                               alternative uses can conserve resources (SA objective 11), which can ensure areas of open space and
                                                               biodiversity are maintained (SA objectives 12, 14). Through having a more flexible approach to the
                                                               release of land/ buildings in out of centre locations, this policy together with policies EP1, EP2 and
                                                               EP10 can enhance town centres (SA objective 20), potentially encouraging more sustainable travel (SA
                                                               objective 10) and improving access to services (SA Objectives 6, 23).
EP5 Location of new industrial/ warehousing and related uses   Directing new development to existing industrial sites can enhance their function and contribute to
                                                               Hounslow’s role as an employment centre (SA objectives 21, 22). However, as referred to above, new
                                                               development can contribute to increased resource use and waste which together with policies EP1,
                                                               EP9 and EP10 can be more significant. Secondary effects of resource use and waste include noise
                                                               (SA objective 5) and pollutants (SA objective 16) which can harm quality of life (SA objective 9) and
                                                               contribute to climate change (SA objective 15)
EP6 Preferred Industrial Locations and Locally Significant     The protection of industrial sites (EP6, 7) together with policies EP2 and EP3 that seek to maintain
Industrial Sites                                               office supply in sustainable locations, contributes to positive effects against SA objectives 20, 22
EP7 Industrial Business Park (Great West Road)                 The protection of industrial sites (EP6, 7) together with policies EP2 and EP3 that seek to maintain
                                                               office supply in sustainable locations, contributes to positive effects against SA objectives 20, 22
EP8 Other Industrial land (outside Strategic and Locally       In combination with policies EP2 and EP4, the managed release of land from employment use can
Significant Industrial Sites)                                  regenerate sites and bring them back into use (SA objective 13). Furthermore, the reuse of land for
                                                               alternative uses can conserve resources (SA objective 11), which can ensure areas of open space and
                                                               biodiversity are maintained (SA objectives 12, 14).
EP9 Small and Medium Sized Enterprise                          The development of small and medium sized enterprise in combination with policies EP1, EP5 and
                                                               EP10 contributes to resource use and increased waste
EP10 Location of Visitor accommodation and conference          The development of visitor accommodation and conference facilities in combination with policies EP1,
facilities                                                     EP5 and EP9 contributes to resource use and increased waste. In directing high trip generating uses to
                                                               town centres together with offices, the role of town centres as focii for services and emplyment can be
                                                               enhanced consistent with SA objective 20.




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6.2.      How social, environmental and economic problems were considered in
          developing the policies and proposals and proposed mitigation
          measures

6.2.1.1   Whilst all efforts have been made to ensure that preferred options result in positive impacts
          against the 23 sustainability objectives, inevitably there are some aspects of preferred options
          that result in negative impacts. These are clearly identified by a minus sign in the tables
          included in Appendix 6.

6.2.1.2   The following summarises the significant impacts arising from the appraisal of each
          preferred option against the 23 sustainability objectives, which encapsulates the problems or
          issues. Following the identification of significant effects from the preferred options, a section
          titled Mitigation explains how effects have been considered in the writing of policies including
          any mitigation where appropriate.

          Effect
          Development facilitating/as a result of employment growth can result in increased
          noise subject to the type of development. The effect of noise levels is subject to size,
          scale, accessibility and location (Preferred options 1, 2, 3, 5d, 8b, 9a).
          SA objective 5 To reduce as far as practicable noise from all sources
          Mitigation
6.2.1.3   In the Submission version of the DPD, locational policy EP5 (Location of new industrial/
          warehousing and related uses) seeks to direct development to existing industrial locations
          subject to being compatible with uses surrounding the proposal. With regard to new sites for
          industrial development, criteria under Policy EP5 has specific regard to “compatibility with
          uses in the area surrounding the proposal and potential impacts on those uses”.

6.2.1.4   In terms of other uses, proposals for office floorspace directed to locations under policies EP1
          (Location of new office-based employment) and EP10 (Location of visitor accommodation and
          conference facilities) and where there are a choice of modes of transport, therefore not
          encouraging use of private vehicle for journeys to/ from work, which can generate noise.
          Whilst Policy EP2 seeks to retain offices in ‘Key Existing Office Locations’ on the Great West
          Road and at Bedfont Lakes’, there is no additional development allowed in these
          unsustainable locations under Policy EP1 (unless limited in scale).
6.2.1.5   Objective 3 is also relevant and to be considered in ensuring proposals for development do
          not contribute to increased noise.
          _____________________________________________________________________
          Effect
          Additional resources are required in providing for employment growth through
          construction, operation and travel (Preferred options 1, 2, 3, 4, 5a, 5b, 5c, 5d, 6, 7, 8b,
          9a).
          SA objective 11 To ensure the quantitative and qualitative conservation of resources (soil,
          mineral aggregates, water, energy)
          Mitigation
6.2.1.6   This can be minimised through the efficient use of previously developed land, reuse of
          existing buildings and recycling of materials. Policy IMP.1.2 The reuse and recycling of urban
          land and buildings in the UDP encourages the re-use and recycling of existing vacant
          buildings; maximum use of previously developed land and development and redevelopment
          at higher densities. The Council is awaiting the direction of the Secretary of State to save this
          policy beyond September 2007. The Council will look to replace this policy as part of its Core
          Strategy/ Generic Development control (DC) policies given the principles of minimising
          resource use are generic to all types of development and not just employment.
                                                                                                      137
6.2.1.7    Through directing new development to appropriate locations, resource use can also be
           minimised. Policy EP1 (Location of new office-based employment) directs new development
           to locations accessible by a choice of modes of transport, thus seeking to minimise resource
           use rather than encouraging the use of private vehicles.

6.2.1.8    Furthermore, Policy EP5 in directing new development to existing industrial sites including
           designated locations seeks to encourage the reuse and the more efficient use of existing
           industrial sites. The intent of this policy in directing new development to existing sites is to
           utilise brownfield land before allowing new development on sites not currently in employment
           use. As with all policies in the DPD, this policy is to be read in conjunction with the London
           Plan, UDP and other DPD policies including Policy IMP.1.2 of the current development plan.

6.2.1.9    In preparation of the core strategy and waste development plan document, policies relating to
           resource use will be developed to replace existing UDP policies. Those UDP policies
           proposed to be saved are listed below:

           ENV-P.1.3 Surface water run off
           ENV-P.2.1 Waste Management
           ENV-P.2.4 Recycling facilities in new developments
           ENV-P.2.5 Energy and resource efficiency
           ENV-P.2.6 Renewable energy

6.2.1.10   Whilst it is not appropriate to address these in the Employment DPD they will be applied
           together with the Employment DPD in appraisal of planning applications.
           _____________________________________________________________________
           Effect
           New development facilitating/as a result of employment growth contributes to reduced
           air quality and greenhouse gas emissions through construction, operations and travel
           (Preferred options 1, 2, 3, 4, 5a, 5b, 5d, 6, 7, 8b, 9a)
           SA objective 15 To reduce negative contributions to climate change
           SA objective 16 To improve air quality in the borough
           Mitigation
6.2.1.11   In the Submission version of the DPD, EP5 (Location of new industrial/ warehousing and
           related uses) provides criteria for the development on new industrial sites. This includes
           “access by sustainable modes of transport” which can discourage use of private vehicles and
           contribute to a reduced level of emissions than might otherwise be the case.

6.2.1.12   Under policies EP1 (Location of new office-based employment) and EP10 (Location of visitor
           accommodation and conference facilities) proposals for new floorspace are directed to
           locations where there are a choice of modes of transport, therefore not encouraging use of
           private vehicle for journeys to/ from work. Whilst Policy EP2 seeks to retain offices in ‘Key
           Existing Office Locations’ on the Great West Road and at Bedfont Lakes’, there is no
           additional development allowed in these unsustainable locations under Policy EP1 (unless
           limited in scale) therefore not contributing to increased car use.
6.2.1.13   Objective 3 is also relevant and to be considered in ensuring proposals for development do
           not contribute to increased emissions

6.2.1.14   Also relevant in mitigating emissions is the designation of exiting industrial sites adjacent to
           rail corridors and waterways for industrial/ warehousing use under Policy EP6 thus ensuring
           they are safeguarded for their capacity to accommodate the movement of goods by rail/
           water. This can contribute to a reduced level of emissions than might otherwise be the case
           with road transport.

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6.2.1.15   In preparation of the core strategy and waste development plan document, policies seeking to
           reduce emissions will be developed to replace existing UDP policies. Those UDP policies of
           particular relevance, which are proposed to be saved are listed below:
           ENV-P.1.6 Air Pollution
           ENV-P.2.5 Energy and resource efficiency
           ENV-P.2.6 Renewable energy

6.2.1.16   As part of the Local Development Framework, a supplementary planning document on air
           quality is also being prepared that will require appropriate mitigation measures in assessing
           proposals for new development.

6.2.1.17   Whilst it is not appropriate to address these in the Employment DPD they will be applied
           together with the Employment DPD in appraisal of planning applications.
           _____________________________________________________________________
           Effect Growth resulting in/as a consequence of development increases the amount of
           waste produced (Preferred options 1, 2, 5a, 5b, 5c, 7, 8b, 9a).

           SA objective 17 To minimise the production of waste
           Mitigation
6.2.1.18   The development and operation of industrial and commercial uses produces waste, which can
           be minimised through the reuse and recycling of materials.

6.2.1.19   With the development of waste management facilities, the reuse and recycling of waste
           materials can be provided for. Whilst the Council is preparing a Joint Waste development plan
           document to allocate sites for waste management, the Employment DPD seeks to provide
           capacity to accommodate employment growth (Objective 2; spatial policy E1), which
           encompasses waste. As stated in supporting text to Policy EP5 there is “strong demand for
           waste (facilities)” (para. 14.14) and as an industrial use, the provision of waste management
           facilities is consistent with the designation of preferred industrial locations and locally
           significant industrial sites (refer to policy EP6).

6.2.1.20   As with all new development, employment uses generate waste. Objective 3 of the DPD
           seeks to minimise the effects of new development and together with policies in the DPD for
           new development (Locational policies EP1, EP5 EP9, EP10) is to be read in conjunction with
           UDP and other DPD policies including
           ENV-P.2.1 Waste Management
           ENV-P.2.4 Recycling facilities in new developments

6.2.1.21   In preparation of the waste development plan document, policies relating to waste
           management will be developed to replace existing UDP policies. Whilst it is not appropriate to
           address these in the Employment DPD they will be applied together with the Employment
           DPD in appraisal of planning applications.
           _____________________________________________________________________




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6.2.2     Effects arising from the sustainability appraisal of criteria used in identifying
          Locally Significant Industrial Sites
6.2.2.1   At the preferred options stage in preparation of the Employment Development Plan
          Document, criteria used for identifying Locally Significant Industrial Sites were assessed for
          their impacts against sustainability objectives (including in Appendix 5 under Question 8a).
          Negative effects or potentially negative effects arise against objectives 5, 6, 9, 10, 11, 15, 16
          17, and 23.

6.2.2.2   The following section presents the SA objective that negative or potentially negative effects
          arise against, and the criteria this relates to. Following this a section titled Mitigation explains
          how effects have been considered in the writing of policies including any mitigation where
          appropriate.

6.2.2.3   Note, SA objectives 10 – 19 are primarily environmental and there is an inherent conflict
          arising with the criteria used for assessing LSISs. Given the appraisal is to determine those
          sites that are significant for industry, there is an economic focus. On their own each criterion
          therefore have a negative or potentially negative impact (? Symbol used in the appraisal)
          against social and environmental objectives.
          __________________________________________________________________________

          SA Objective 5            To reduce as far as practicable noise from all sources.
          Criteria 5                There is potential for in situ expansion
          Criteria 9                There is potential for the transportation of goods by rail and/or water

          Mitigation

6.2.2.4   Noise arising from development and operation of uses on industrial estates can be mitigated
          through acoustic measures at the planning application stage and assessed against policies in
          the development plan as appropriate (outside scope of Employment DPD).
          Following review, the noise arising from the movement of goods by rail and/or water is
          considered more sustainable than transportation by road as may otherwise occur. Therefore,
          the overall impact of noise is potentially reduced.
          __________________________________________________________________________


          SA Objective 6            To ensure fair and equal access to services (health care,
                                    education, employment, shopping, transport) culture, leisure
                                    and recreation for all residents.
          Criteria 2                The site performs a strategic/significant function
          Criteria 8                Well located in relation to the strategic highway network

          Mitigation

6.2.2.5   The location of industrial estates close to the strategic road network may not be consistent
          with the criteria of being easily accessible by public transport to enable fair and equal access
          to employment. Whilst this conflict arises, there is not a need for uses with a low employment
          density to be in highly sustainable locations and to reduce the distance of journeys to the
          supply chain, it is a higher priority for industrial and warehousing uses to be in locations close
          to the strategic road network.
          Whilst protecting sites serving a strategic function may limit opportunities for local business,
          there is also a criterion in assessment of sites as to whether an estate contributes to local
          employment objectives. Through the designation of sites that support small and local
          business opportunities, diversity can be encouraged (objective 1 of the DPD).
          __________________________________________________________________________




                                                                                                          140
           SA Objective 9            To improve the quality of where people live.
           Criteria 2                The site performs a strategic/significant function
           Criteria 3                Contributes to local employment objectives and local economic
                                     diversity (e.g. size of units, cost, etc)
           Criteria 6                Is part of a larger cluster of employment activity

           Mitigation

6.2.2.6    There are potentially negative effects on quality of life. Firstly, where sites are protected that
           could be put to better use to improve the quality of the environment and secondly the limited
           employment opportunities in areas without LSISs that could be enhanced.

           1. Whether a site is appropriate for an alternative land use and improves the quality of the
           surrounding environment is outside the scope of the DPD. However, other criterion seeks to
           ensure that estates are identified as LSISs only where there is short term and/or long-term
           demand and there are not adverse impacts on the surrounding area.

           2. Whilst sites may not be identified as LSISs in some areas, the DPD seeks to retain
           employment sites and manage release subject to evidence there is no demand on a site.
           Therefore, there is a presumption to support employment opportunities in all areas across the
           borough.
           __________________________________________________________________________

           SA Objective 10           To minimise the need to travel, increase the use of sustainable
                                     transport modes (walking, cycling and public transport) and
                                     reduce the reliance on the car.
           Criteria 3                Contributes to local employment objectives and local economic
                                     diversity (e.g. size of units, cost, etc)
           Criteria 6                Is part of a larger cluster of employment activity
           Criteria 8                Well located in relation to the strategic highway network

6.2.2.7    The location of industrial estates close to the strategic road network or in other locations that
           support local employment opportunities may not be consistent with the criteria of encouraging
           the use of sustainable modes of transport. Whilst this conflict arises, there is not a need for
           uses with a low employment density to be in highly sustainable locations and to reduce the
           distance of journeys to the supply chain, it is a higher priority for industrial and warehousing
           uses to be in locations close to the strategic road network.

6.2.2.8    Whilst a cluster of estates may not be in a location that encourages the use of sustainable
           transport, the distance of journeys is minimised where businesses support each other e.g.
           one business is located close to another in the same supply chain.
           __________________________________________________________________________

           SA Objective 11           To ensure the conservation of resources (soil, mineral
                                     aggregates, water, energy).
           Criteria 1                Existing uses are appropriate for the site
           Criteria 5                There is potential for in situ expansion
           Criteria 6                Is part of a larger cluster of employment activity
           Criteria 8                Well located in relation to the strategic highway network

6.2.2.9    Whilst industrial uses and the intensification/ further development of existing sites require
           resources, the more efficient use of land through in-situ expansion can conserve resources in
           contrast to the development of land not previously in industrial use. Criteria (for identifying
           LSIS) on the potential for in-situ expansion on a site and ability to take advantage of existing
           infrastructure support this. Policies in the UDP (but outside the scope of the Employment
           DPD) promote and encourage the efficient use of resources in new development.

6.2.2.10   Whilst protecting sites close to the strategic road network may also encourage resource use
           through the transfer of goods by road, journeys are potentially reduced if located closer to the

                                                                                                          141
           supply chain e.g. Heathrow. Furthermore, there is also criterion in assessing site as to
           whether there is the potential for freight movements by rail and/or water.
           __________________________________________________________________________

           SA Objective 15           To reduce contributions to climate change.
           Criteria 1               Existing uses are appropriate for the site
           Criteria 4               Is well located to take advantage of existing infrastructure
           Criteria 5               There is potential for in situ expansion
           Criteria 6               Is part of a larger cluster of employment activity
           Criteria 8               Well located in relation to the strategic highway network
           Criteria 12              Demonstrable short-term demand for industrial development and/or
                                    strategic long-term demand

6.2.2.11   In mitigating emissions, criteria to encourage the more sustainable movement of freight is
           also considered in appraisal of LSISs (refer to Appendix 5 under question 8A). However,
           measures to reduce contributions to climate change from development are outside the scope
           of the DPD. In preparation of the core strategy and waste development plan document,
           policies seeking to reduce emissions will be developed to replace existing UDP policies.
           __________________________________________________________________________

           SA Objective 16          To improve air quality in the Borough.
           Criteria 1               Existing uses are appropriate for the site
           Criteria 4               Is well located to take advantage of existing infrastructure
           Criteria 5               There is potential for in situ expansion
           Criteria 6               Is part of a larger cluster of employment activity
           Criteria 8               Well located in relation to the strategic highway network
           Criteria 12              Demonstrable short-term demand for industrial development and/or
                                    strategic long-term demand

6.2.2.12   In mitigating emissions, criteria to encourage the more sustainable movement of freight is
           also considered in appraisal of LSISs (refer to Appendix 5 under question 8A) However,
           measures to reduce emissions to air from development are outside the scope of the DPD. In
           preparation of the core strategy, waste development plan document and air quality SPD,
           policies and guidance seeking to reduce emissions will be developed to replace existing UDP
           policies.
           __________________________________________________________________________

           SA Objective 17          To minimise the production of waste
           Criteria 1               Existing uses are appropriate for the site
           Criteria 5               There is potential for in situ expansion
           Criteria 12              Demonstrable short-term demand for industrial development and/or
                                    strategic long-term demand

6.2.2.13   Whilst industrial uses and the intensification/ further development of existing sites contributes
           to the production of waste, the identification of LSIS provides capacity for accommodate the
           need for waste management facilities in the future. Furthermore, policies in the development
           plan (UDP and London Plan) seek to minimise waste and this will be reviewed as part of the
           joint waste DPD.
           __________________________________________________________________________

           SA Objective 23          To improve accessibility for all sections of the community to
                                    jobs, education, skills training and life long learning.
           Criteria 8               Well located in relation to the strategic highway network

6.2.2.14   The location of industrial estates close to the strategic road network may not be consistent
           with the criteria of being easily accessible by public transport to enable accessibility for all
           sections of the community to jobs, skills training and life long learning. Whilst this conflict
           arises, there is not a need for uses with a low employment density to be in highly sustainable


                                                                                                        142
locations and to reduce the distance of journeys to the supply chain, it is a higher priority for
industrial and warehousing uses to be in locations close to the strategic road network.
__________________________________________________________________________




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6.3     Uncertainties and risks
6.3.1   Uncertainties and risks exist in the process of preparing the Sustainability Appraisal (SA),
        which are presented below. Some of the uncertainties and risks relate to the assumptions
        identified in the appraisal of options and preferred options (section 4.4).

        i) Process and how it has influenced the preferred options

6.3.2   In preparation of the SA, officers have determined the key issues, and the effects of options
        and preferred options. There is the risk that officers may make their own assumptions about
        the possible effects arising from a particular option/ preferred option. Through peer review
        and ongoing discussions about the assumptions made (section 4.4), there has a consistent
        approach based on information available from within the Council, and consultation previously
        undertaken (section 2.4). The SA process has not been scientific process and the
        consultation on the SA report is seen as adding value in allowing ‘experts’ and interested
        stakeholders to review the effects identified.

6.3.3   Furthermore, the SA report does not provide the definitive answer to determine the preferred
        options. This is supported in the guidance, which states –

                “It is not the role of the SA to determine the option(s) to be chosen as the basis for
                the preferred options and the draft plan. This is the role of those who have to decide
                which strategy is appropriate. The role of the SA is to assist with the identification of
                the appropriate options, by highlighting the sustainability implications of each, and by
                putting forward recommendations for improvement”.

6.3.4   Whilst the plan objectives and preferred options have been informed by the SA rather than
        being an outcome of the SA, there is the potential risk that measures proposed to address
        significant effects arising from preferred options restricts the implementation of wider
        objectives at a local, regional and national level in other strategies and plans.

6.3.5   There is a need to ensure general consistency with national and regional guidance, which
        may have effects on the economy, society and environment. At the next stage, mitigation
        measures will be refined to minimise significant effects.

        ii) Uncertainty in assumptions and effects

6.3.6   There is the risk that with change, assumptions may also change. For example, an
        assumption made is that there will be continuing pressure for residential development on
        employment land. The impact of reduced need for additional housing would affect
        assumptions made and affect how the plan is interpreted. This reflects the need for plans to
        be flexible to change, in the case of the Employment Development Plan, adapting to changes
        in the market.

6.3.7   There are instances where the effect has been described as “unknown”. This indicates that
        positive and negative impacts may arise from the options/preferred options but there is not a
        definitive answer, or there is an effect but it is difficult to determine. Further information may
        become available, including analysis through consultation, which can improve the prediction
        and evaluation of effects.

        iii) Baseline information on which SA is based

6.3.8   The data collected has been used to determine key issues as well as forming the baseline for
        identification of effects. There is the risk that the information collected is not from the most
        appropriate source and/or other more reliable sources of information become available in
        time. This can make the assessment of effects through comparison of data over a time series
        difficult, particularly if the methodology differs, or if the boundaries of an area on which data is
        based changes.


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6.3.9    There are also uncertainties in that data may not be available at a local level to determine the
         effects of policies, due to the nature and scale of effect. Consultation on the SA Scoping
         Report raised issues that have been addressed, and through preparation of the Sustainability
         Appraisal Report existing baseline has been reviewed and updated or amended to reflect
         changes or new sources of information.

6.3.10   Baseline information for environmental indicators was more easily available than social and
         economic baseline data, reflecting emphasis in the past on environmental impacts as a part of
         sustainability appraisals previously completed for the UDP.
         Whilst it has been the aim to achieve a balance between economic, social and environmental
         objectives, available baseline information, different elements making up each (Social,
         Environmental, and Economic), and existing guidance has resulted in more environmental
         (10) and social (9) objectives than Economic (4).

6.3.11   Collaboration with internal departments and external agencies has assisted in collection of
         data across all topics covered by the SA but there is always the potential for errors/omissions
         in the information presented. The collection of baseline data will continue to be collected over
         time in order to fill in existing gaps and expand on the baseline situation.

         iv) Objectives of the SA and Development Plan Document

6.3.12   There is the risk due to political change or other external factors that the Council’s vision may
         change, but the decision to save the existing UDP objectives was agreed by the Council’s
         Executive in recognition that the existing objectives were consistent with wider aims of the
         Borough.

6.3.13   In developing the SA objectives, a review of objectives at a national and regional level was
         completed, from which new objectives were developed incorporating recognition of local
         issues in the Community Plan. By ensuring that the SA objectives are in conformity with local
         and regional plans and strategies, the risk of inconsistency in preparation of the Core Strategy
         is reduced.

6.3.14   There was no attempt to weight the objectives given the uncertainties of such an approach.
         Scoring can be too simplistic in analysing the effects of different options, and despite the use
         of symbols e.g. +, the prediction of effects and their significance is qualitative. The decision to
         undertake a qualitative exercise was based on the information and resources available to
         complete this.

6.3.15   There has been the risk that the work required to assess the effects of options and preferred
         options is greater with 23 objectives. Whilst the process can be exhaustive, it is seen as
         providing outcomes founded on a robust and in-depth analysis of the impacts.

6.3.16   Other risks and uncertainties may arise as the Sustainability appraisal process develops in
         preparation of the Development Plan Document.




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7.0     Implementation
7.1     Links to other tiers of plans and programmes and the project level (EIA,
        design guidance etc)
7.1.1   Whilst an objective of the Employment DPD is to minimise impacts, this can only be achieved
        through recognition and implementation of other plans and strategies. The SA identifies the
        environmental, social and economic effects of the preferred options, and to monitor the
        effects arising from implementation of the plan and mitigation of these effects requires
        consideration of the plans, strategies and instruments identified as follows.

7.1.2   The Town and Country Planning (Environmental Assessment) (England and Wales)
        Regulations 1999 requires an Environmental Impact Assessment to be undertaken for
        developments included within Schedules I and II, and can ensure that at a project level,
        measures are implemented to mitigate potential impacts against sustainability objectives.

7.1.3   The Council is proposing to prepare Supplementary Planning Documents on air quality and
        noise. The noise and Air Quality SPDs will provide guidance supplementary to policies in
        assessing proposals for development.
        The Noise SPD will include noise level standards, and measures to mitigate noise from noise
        producing developments with specific guidance for industrial and commercial developments.
        Reference will also be made to requirements in Building Regulations (Part E – Sound
        Insulation 2006) and relevant British Standards in the Noise SPD to ensure adequate noise
        insulation and noise producing sources are within the levels prescribed.

7.1.4   The Air Quality SPD will provide guidance for planners and developers in considering air
        quality and the impact of development in the planning process.
        Through the Council’s Air Quality Action Plan (2005), measures will be introduced to
        improve air quality. A recommendation of the Management Plan is for the whole Borough to
        be declared an Air Quality Management Areas (AQMA), which means one or more of the air
        quality objectives are not going to be met unless action is taken.

7.1.5   Ensuring compliance with Environmental Pollution legislation through monitoring and
        enforcement can also ensure the effects of development are minimised. This would be
        subject to resources and the ability to enforce requirements. Whilst, abatement notices served
        on individuals/businesses are reactive, they can contribute to future compliance.

7.1.6   In minimising the production of waste (SA objective 17), the West London Joint Municipal
        Waste Strategy will be implemented to provide the framework for proposals to deal with
        waste, improving performance in recycling and composting. Development for industrial and/or
        commercial uses will need to demonstrate that waste arising from construction, operations will
        be minimised and that sustainable waste management practices are adopted in accordance
        with the existing Mayor’s Municipal Waste Management Strategy (2003) and Hounslow
        Waste Management Strategy (2003).

7.1.7   Through measures including promoting good design and energy efficiency in developments,
        impacts of the preferred options can be minimised including resource use and contributions to
        climate change. Through promoting planning advice including the ‘Sustainable Construction
        Guide’ (London Borough of Hounslow, 2003), ‘Adapting to Climate change: a checklist for
        development’ (London Climate Change Partnership 2005), and the ‘Renewable Energy
        Toolkit’ (London Renewables, 2004), the Council can encourage more sustainable
        development.

7.1.8   To ensure proposals for development do not have negative effects on biodiversity, the
        Council and developers should consider recommendations of Design for Biodiversity
        (London Development Agency, 2004), and the Hounslow Local Biodiversity Action Plan
        (2003). The HLBAP is important to implementation of biodiversity objectives at a local level,
        and through providing information on habitats and species, can increase awareness and


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         ensure development does not impact on nature conservation areas, and biodiversity on other
         greenfield and brownfield sites.

7.1.9    The Hounslow Draft Local Implementation Plan (2004) contains policies and targets for
         improving transport in the Borough, and together with the Borough Spending Plan can
         improve accessibility, consistent with objectives 6, 10, and 23.
         However, as identified earlier in the SA Report some parts of the Borough have poor levels of
         public transport accessibility. Through the Mayor’s Transport Strategy (2001, 2004 update)
         and Transport for London’s Statement of Intent, proposals for improvements to transport
         infrastructure can be realised. Without proposals and funding at a strategic level only local
         measures, such as bus improvements, can be taken forward and implemented. To achieve
         Sustainability objectives of reducing reliance on the car and promoting sustainable modes of
         transport is therefore dependent on other strategies.

7.1.10   The targets in the Local Area Agreement, which brings together targets of the Council and
         its partners are fundamental to achieving sustainability objectives and bring together targets
         from a range of different plans and strategies. Each of the 4 blocks making up the LAA
         contributes to social, economic and environmental objectives. The blocks are:
         • Children and Young People
         • Healthier communities and older people
         • Safer and stronger communities
         • Economic development and enterprise

7.1.11   The Council in partnership with the Hounslow Primary Care Trust can work to achieving the
         targets in the Hounslow NHS Primary Care Trust Health Delivery Plan 2005/06 – 2007/-8.
         Through assessing the impact of development and application of the Healthy Urban
         Development Unit model to proposals, the negative impacts of further growth on health
         infrastructure can be mitigated.

7.1.12   The proposed SPD on Planning obligations, which will provide guidance on how Hounslow
         will apply its policy on planning obligations, can ensure an effective process for
         implementation of measures related to affordable housing (3), transport (10), health (1),
         education (8, 23) and open space (14), which contributes to achieving Sustainable objectives
         (in brackets). Planning obligations can also secure funding for improvements to nature
         conservation areas, biodiversity (12), air quality and noise monitoring (5, 16).

         Background documents to LDF

7.1.13   A key background document to the Employment Development Plan Document is the
         Hounslow Employment Land Study 2004. It has provided information to assess industrial and
         commercial sites in developing preferred options for protection of strategically and locally
         significant sites. The Study will need to be updated in the future to monitor the effectiveness
         of policies; for example in determining whether there is an appropriate balance in supply and
         demand; and in identifying potential effects arising e.g. potential impact of new development
         on other businesses/ community.




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7.2.    Proposals for monitoring
7.2.1   The Draft Employment DPD includes indicators for monitoring the implementation of policies,
        which will enable an assessment of whether the policies are being delivered successfully.

7.2.2   The significant effects of the DPD against sustainability indicators also needs to be monitored
        to ensure the objectives and policies in the plan are not to the detriment of social, economic
        and environmental objectives. This section proposes indicators to monitor the impacts of the
        DPD on sustainability.

7.2.3   Whilst the Draft SA report published for consultation at the preferred options stage contained
        draft indicators for each preferred option, a review of these indicators has since been
        undertaken. The review of monitoring has considered

            •   whether the proposed ‘significant effects’ indicators are the most appropriate for
                measuring the impacts of the DPD on sustainability
            •   the availability of information and reliable data to monitor the impacts of the DPD
            •   whether the effects monitored can be attributed to individual policies and whether
                there is a need to look wider at the plan’s impacts
            •   the detail of existing indicators in the submission version of the DPD and whether
                they are too specific
            •   whether an indicator proposed in the draft SA is monitoring the implementation of the
                policy rather than the significant effects of the policy
            •   the resources available for monitoring

7.2.4   The proposed indicators for monitoring the effects of the plan against sustainability objectives
        are presented in the following and replace the previous indicators proposed in the Draft SA.
        The indicators will be reported in the Annual Monitoring Report.




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      Sustainability Objective              Significant Effects Indicator         Significant Effects Target          Relevant objectives and            Source
                                                                                                                      policies in Development
                                                                                                                            Plan Document
5. To reduce as far as practicable        Method of travel to work                Reduction in travel to work        Objective 3, 4; Spatial        Neighbourhood
noise from all sources.                                                           by private car                     policies E1, E2, E3;           Statistics /
                                                                                                                     Locational policies EP1,       Residents panel
                                                                                                                     EP2, EP3, EP4, EP5, EP10       survey
6. To ensure fair and equal access to     Amount of new residential               All new residential                Objectives 1, 2, 3, 4;         London
services (health care, education,         development within 30 minutes           development within 30              Spatial policies E1, E2, E3;   Development
employment, shopping, transport)          public transport time of areas of       minutes public transport           Locational policies EP1 –      Database
culture, leisure and recreation for all   employment3                             time of areas of                   EP7, EP10.
residents.                                (Also relevant to Objective 23)         employment
8. To improve the education and           Number of people aged 16 – 19           2006/07 150                        Objective 4; Spatial policy    LAA/ Economic
skills of the population overall          placed on apprenticeship                2007/08 300                        E3                             Development unit
                                          programmes and retained for the         2008/09 450
                                          first year of their course (if the      Increasing number of
                                          course is less than one year)           people aged 16 – 19 placed
                                                                                  on apprenticeship
                                                                                  programmes and retained
                                                                                  for the first year of their
                                                                                  course thereafter
9. To improve the quality of where        Proportion of residents ‘very           Increase in the proportion         Objective 3; Spatial policy    Residents Panel
people live.                              satisfied’ or ‘fairly satisfied’ with   of residents ‘very satisfied’      E2; EP1 – EP10                 Survey/ BVPI
                                          their neighbourhood as a place to       or ‘fairly satisfied’ with their
                                          live                                    neighbourhood as a place
                                                                                  to live




3
 With new development for employment uses in the Borough, there is potentially improved access from new residential developments to ‘employment areas’
as defined in guidance on Local Development Framework Core Output Indicators. The Employment DPD and saved housing policies seek to ensure new
development is accessible by public transport and saved housing policy H.3.5 (Release of Employment uses to residential) includes criterion that proposed
development is well located in relation to other employment opportunities.

                                                                                                                                                                  149
10. To minimise the need to travel,      Method of travel to work            Increase in travel by          Objectives 3, 4; Spatial       Neighbourhood
increase the use of sustainable                                              sustainable modes of           policies E1, E2, E3;           Statistics /
transport modes (walking, cycling                                            transport (including           Locational policies EP1,       Residents panel
and public transport) and reduce the                                         Underground, metro, light      EP2, EP3, EP4, EP5, EP10       survey
reliance on the car                                                          rail or tram; Train; Bus,
                                                                             minibus or coach; Bicycle;
                                                                             On foot)
11. To ensure the conservation of        Number of planning permissions      No planning permissions        Objective 3; Spatial policy    EA
resources (soil, mineral aggregates,     for B class uses granted contrary   granted contrary to the        E2; Locational policies EP1,
water, energy).                          to the advice of the Environment    advice of the EA               EP5, EP9, EP10.
                                         Agency (EA) on either floor
                                         defence grounds or water quality
12. To maintain and enhance              Amount of land developed for B      No net loss in areas           Objectives 2, 3; Spatial       London
existing biodiversity (areas of nature   class uses on areas designated      designated for nature          policies E1, E2; Locational    Development
conservation interest, wildlife and      as nature conservation              conservation                   policies EP1, EP5, EP9,        Database
habitats).                                                                                                  EP10.
13. To promote regeneration that         Completed B class development       100% of all completed          Objectives 2, 3; Spatial       London
makes use of existing assets             on brownfield sites                 development on brownfield      policies E1, E2; Locational    Development
                                                                             sites                          policies EP1, EP5, EP9,        Database
                                                                                                            EP10
14. To maintain and improve the          Amount of land developed for B      No net loss in areas           Objectives 2, 3; Spatial       London
quality of publicly accessible open      class uses on areas designated      designated for green belt,     policies E1, E2; Locational    Development
spaces.                                  as green belt, metropolitan open    metropolitan open land and     policies EP1, EP5, EP9,        Database
                                         land and local open space           local open space               EP10.
15. To reduce contributions to           Total new capacity of renewable     Increase in capacity of        Objectives 1 – 4; Spatial      London
climate change                           energy technology installed as      renewable energy               policies E1 – E4, Locational   Development
                                         part of completed employment (B     technology installed as part   policies EP1 – EP10            Database
                                         use class) development (part of     of completed employment
                                         Core Output Indicator 9)            development
16. To improve air quality in the        Method of travel to work            Reduction in travel to work    Objective 3, 4; Spatial        Neighbourhood
Borough.                                                                     by private car                 policies E1, E2, E3;           Statistics /
                                                                                                            Locational policies EP1,       Residents panel
                                                                                                            EP2, EP3, EP4, EP5, EP10       survey
17. To minimise the production of        Amount of trade waste collected     Reduction in amount of         Objectives 2, 3; Spatial       LB Hounslow
waste.                                   (tonnes)                            trade waste collected per      policies E1, E2; Locational    Recycling team


                                                                                                                                                         150
                                                                                 year                           policies EP1, EP5, EP9,
                                                                                                                EP10.
20. To provide opportunities and           Change in employment within the       Increase in employment         Objectives 1, 2, 3, 4;          Neighbourhood
benefits to the local economy              ‘Financial and Business services’     within ‘Financial and          Spatial policies E1, E2, E3;    Statistics
especially in town centres, whilst         and ‘Hotels and catering’ sector in   Business services’ and         Locational policies EP1,
having regard to the wider                 lower layer Super Output Areas        ‘Hotels and catering’ sector   EP2, EP10.
environment.                               that include town centres 1           in lower layer Super Output
                                                                                 Areas that include town
                                                                                 centres
21. To maintain and attract new            Change in the number employed         Growth in employment in at     Objectives 1, 2, 4; Spatial     Neighbourhood
economic development that provides         in the borough by industry            least 5 industries             policies E1, E3, E4.            Statistics
a range of jobs in appropriate
locations

22. To maintain and enhance the            Change in number of employee          Growth in employment in        Objectives 1, 2, 4; Spatial     ABI Employee
importance of Hounslow as an               jobs                                  the Borough                    policies E1, E3; Locational     analysis
employment centre in both the West                                                                              policies EP2 - EP4, EP6 –
London and London-wide context.                                                                                 EP9.
23. To improve accessibility for all       Average distance travelled to         Overall reduction in           Objectives 1,2, 3, 4; Spatial   Neighbourhood
sections of the community to jobs,         work                                  distance travelled to work     policies E1, E2, E3;            Statistics
education, skills training and life long   (also relevant to SA Objective 6)                                    Locational policies EP1 –
learning                                                                                                        EP7, EP10.




1
 Town Centres: Brentford: Hounslow 003E, Hounslow 006D; Chiswick: Hounslow 001B, Hounslow 002E, Hounslow 002B; Feltham: Hounslow 025A,
Hounslow 024E; Hounslow: Hounslow 18B, Hounslow 15A, Hounslow 12C, Hounslow 17C, Hounslow 18A

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8.0   Appendices
      Appendix 1a Schedule of Council’s response to representations on the SA Scoping Report
      2005

      Appendix 1b Schedule of Council’s response to representations on the Employment
      Development Plan Sustainability Appraisal Report January 2006

      Appendix 2 Baseline maps of the London Borough of Hounslow showing
             - Overall Index of Multiple Deprivation
             - Public Transport Accessibility Levels

      Appendix 3 Schedule of Parks and Open Spaces in Hounslow

      Appendix 4 ‘From Preferred Options to Submission version of the DPD’ – Table of how
      Objectives and policies in the Employment DPD have developed from preferred options

      Appendix 5 Employment Development Plan Sustainability Appraisal Assessment of Options

      Appendix 6 Detailed appraisal of preferred options and Do Nothing, Status Quo options
      against SA objectives




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