The Society is very concerned about the threat of tower blocks springing up all over the Borough. These blocks will completely change the character of Ealing as we know it. Now is your chance to comment on 3 major planning applications which are still open for comments, before it is too late. We have already sent in our objections which you can read below. Click on the names of the developments to link through to the planning applications to the Council where you may leave your comments.
Ealing Civic Society objects to this application which represents unacceptable overdevelopment, encroachment on Metropolitan Open Land and an approach entirely unsympathetic to the surrounding neighbourhood. Our detailed comments follow.
Height, Scale and Massing
The buildings, in particular Blocks A – D, are excessively tall and overbearing in both the context of the surrounding development and the surrounding Metropolitan Open Land. The design and finishes of all blocks are uninspired and in particular blocks A and B, which will provide the affordable housing units, have all the appearance of just the sort of Local Authority high-rise blocks that are now recognised as a failure of the 60s/70s and are being torn down. We would refer to the redevelopment of the South Acton Estate which embraces lower-rise and more attractive architecture.
Taken from the Planning Statement, the proposed densities are 1,081 habitable rooms per hectare (hr/ha) and 422 units per hectare (u/ha). These are over double the maximum figures quoted in the current London Plan density matrix, which for an urban setting (as assessed by the developer) with a PTAL rating of 2-3 are 200-450 hr/ha and 45-170 u/ha. We consider that the local area is essentially suburban in nature rather than urban, where lower densities of 150-250 hr/ha and 35-95 u/ha apply, making the proposals over 4 times the maxima. These proposals are significant overdevelopment by either measure.
The development proposes 599 residential apartments (comprising 33 x studio, 263 x 1 bed; 266 x 2 bed; and 37 x 3 bed units). We consider the proposed proportion of approximately 50% one-bed and studio flats to be over-provision and the proportion of 3-bed family sized units at just 6% to be below the expected 15%.
Proposed private amenity space is insufficient. For example, the balconies for the 1b2p flats are just 3m2 which is below the London Plan Housing SPG standard of 5m2 and we do not consider that this is compensated for by some semi-private or shared amenity space.
The proposed development includes increased car parking (194 spaces to 343, an increase of 149). These provide provision for residential parking at approximately one space per four units, to which we have in principle no objection other than the impact on the area of this large increase in population and associated car movements. It appears that there is a proposed reduction in parking available for the expanded leisure centre. Given that the catchment area for this facility will be wide, and the potential usage increased from the present, we would argue for further leisure centre user parking to avoid parking problems on neighbouring residential streets.
Metropolitan Open Land
This is a major departure application in terms of Metropolitan Open Land. The arguments in the planning statement obfuscate the loss of 13.2 ha of MOL. The developers claim a loss of less than 80m2 due to the majority of the site being previously developed land but also fail entirely to cross-reference the parallel application for development of a new BMX track on nearby currently undeveloped MOL which of course adds to the loss. Notwithstanding the previous use of MOL for the existing leisure centre and its unobtrusive surface car park, these new proposals are for an entirely different and more intensive and intrusive development.
The London Plan (7.17) states that “Appropriate development should be limited to small scale structures to support outdoor open space uses and minimise any adverse impact on the openness of MOL.”
The developers recognise that the leisure centre, residential component and retail component represent inappropriate development but argue that Very Special Circumstances (VSC) exist. The Planning Statement makes three arguments: that they are improving green links, re-providing and improving the leisure centre and providing housing.
We argue strongly that the VSC are not made out. The arguments put forward are not VSC in the context of MOL in that they do not, in and of themselves, necessitate the development going ahead and the loss of MOL land. If this land does need to be redeveloped, the MOL de-designation should be considered though the plan making process and not through a planning application that does not reach the high bar set by the need for VSC. This correct process was noted and applied in the case of de-designation of the southern portion of the former Barclays Bank sports ground off Hanger Lane in order to accommodate the new Ada Lovelace school.
Finally, the Council’s conclusion in the Screening Opinion that this development does not require an EIA is surprising. Not only is the development of a size that will have a significant impact on both infrastructure and traffic in the area, it encroaches on MOL and also has an adverse effect on the designated Site of Importance for Nature Conservation which also covers the site.
Overall it is Ealing Civic Society’s contention that the policy departures that would be required by this application are so significant as to necessitate a refusal.
Ealing Civic Society objects to this application. The proposals do not conform to a number of principles in EAL12 – West Ealing Crossrail Station Adopted Development Sites DPD, which states amongst other matters:
- The height and massing of development on this site should both respond to the adjacent Crossrail station and to the bulk of the buildings featured at this intersection
- Its bulk, scale and design should be sympathetic to the adjacent residential area, seek to enhance the setting of the locally listed sorting office and seek to complement rather than compete with the appearance of the new Crossrail station.
- Development should be designed to include features reflecting the prominent corner location of the site and respond to the ensemble of corner buildings that characterise the crossroads
- Due to the proximity of the railway line, a convincing case would need to be presented that proposals for residential accommodation would have a satisfactory level of amenity.
- Any residential use on the site must be designed to adequately shield residents from the noise and vibrations coming from the adjacent railway through proper insulation and ventilation.
- Residential development must provide adequate levels of communal and private garden space for residents; any balconies fronting the railway must achieve acceptable quality and usability standards particularly with regards to noise and air quality, and the provision of accessible roof space or terraces incorporating biodiversity features will be expected in flatted schemes.
- Residential units should be dual aspect (north facing single aspect units are not acceptable).
- Development must enhance the public realm on the approach from the Uxbridge Road to the Crossrail station, reflecting the standards set by the improvements made along the Avenue and establishing continuity with any public realm provided as part of Crossrail.
We object most strongly to the height, bulk and massing of the proposed 20-storey tower block, over 50% higher than any other building in the locality, which would have an overbearing and overshadowing impact on its surrounding area. This would have a particularly overwhelming effect on the low-rise Victorian terraced housing to the north and west of the site as well as being completely out of keeping with the architecture of the area. The height of the building cannot be considered to respond to the scale or appearance of the buildings on the other ‘corners’ of the crossroads and the setting of the locally listed sorting office would be harmed by such a large development rather than enhanced.
The submitted planning statement compares the density of the proposed development at 2,780 hr/ha with guideline metrics for central areas of 650-1,100 hr/ha. At nearly three times the maximum figures quoted, this proposal is clearly overdevelopment. However, in both the Ealing Plan and by observation of the surrounding area, this location is actually suburban and the relevant metrics are thus 200-350 hr/ha, highlighting the even more excessive overdevelopment proposed at eight times the maxima.
The Development Sites DPD very clearly states that residential units should be dual aspect and that north facing single aspect units are unacceptable. The proposals include single aspect units on most if not all floors including several that are north facing. The proposed single aspect north-facing apartments would suffer from low light levels and the south-facing apartments from increasing solar gain due to climate change; all would be difficult to ventilate adequately.
The planned private amenity spaces of balconies and so-called “winter gardens” are minimal and the shared space offers little additional space for the residents including families. We are particularly concerned about the suggested use of artificial grass and consider that this should be replaced with a green and permeable alternative, with additional planting provided. It should be noted that nearby open space is at a premium and all such areas are already oversubscribed by residents of the area.
The ground level open space also requires additional green planting, particularly as the pavement is planned to be widened. We are also concerned that the small open space in between the tower block and the station would be unpleasant to occupy due to the likely wind turbulence at the base of the tower block.
On the question of affordability, we note that the planned 144 residential units would be 100% affordable, with a 35%/65% London Living Rent/Shared Ownership split. While this clearly meets Ealing Council’s local affordable housing policy of 50% affordable units, this policy also states that affordable housing should be provided at a 60%/40% split of social or affordable rented accommodation to intermediate provision. It is not clear whether this latter requirement would be in practice be met.
Finally, the planned tower would extend upwards to such an extent that it would be clearly visible from the St Stephen’s Conservation Area to the north east, which would be an unacceptable incursion into the skyline.
For all these reasons, we consider that the application should be refused.
Ealing Civic Society objects to this application. We are extremely disappointed that no adjustments appear to have been made in response to our, and others’, comments on the exhibition plans. This scheme has a number of positives that will improve the area but these benefits are entirely undermined by the inappropriate scale of the residential blocks. We maintain our view that this scheme must respect more the height of its surroundings, in particular, the Grade II listed Acton Town Station and the adjacent Victorian sub-station. As we’ve responded previously, no block should be taller than those opposite it on Bollo Lane or on adjacent sites.
The block adjacent to the station and sub-station buildings should be reduced in height and its design made more sympathetic to the adjacent listed building: we find the featureless northern and southern flank walls of this block particularly unattractive and overbearing. We have particular concerns about the planned southernmost block of 25 storeys, which would far exceed the height of any of the surrounding buildings, including those in Chiswick Business Park. This block is likely to be visible from points within the Bedford Park Conservation Area, which would be unacceptable. The height of this block should not exceed that of existing developments.
Although proposals for the Victorian sub-station building do not form part of the full permission application, we are concerned to note that it appears from material submitted that it is intended to build several storeys above this building; such interference with the Victorian architecture would be unacceptable and should be reconsidered before submission of detailed proposals for this element.