Recent planning applications

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Every month our Environment Committee goes through the major planning applications submitted to Ealing Council. We send in an objection if we consider a proposed development to be unsuitable in view of its scale, density, aesthetic qualities or impact on the local environment.  We have been kept very busy over the past months with a large number of submissions including many for significant overdevelopments.  Extended consultation periods due to the pandemic mean that applications remain undetermined for a long time. We do wonder why some decisions cannot be made more promptly.

Here is a selection of our responses to the Council over the last few months:

Brentham Club, 38A Meadvale Road, W5 1NP – 201743FULConstruction of two storey, with habitable loft space, detached dwelling house

The application remains undetermined.

Ealing Civic Society supports the principle of enabling development to provide funds for necessary works to the Grade II listed Brentham Club. However, the proposed development involves building on Metropolitan Open Land, which normally we would not support.  At present, from the evidence available to us, the case for such loss of MOL has not been sufficiently made, neither have details of the works to be done to the club and other supportive evidence that the development would provide the funding to facilitate that work been provided. We would support this application provided we can be satisfied that the construction of the dwelling house would be an enabling development. Before making its decision on this application, we urge the Council to insist upon the assurances it needs, as set out by Historic England, for the economic case for this development.  If the application is then granted, completion of the works to the club should be secured by condition.  In addition, we would encourage the Council to respond to any comments from the Brentham Garden Estate Conservation Area Panel about the design of the planned development, given its proximity to neighbouring heritage assets, in particular, the Grade II listed Brentham Club.

 

Longfield Playing Fields, Stockdove Way, UB6 8TJ – 201541FUL – Construction of a BMX cycle track with 4 x 15m lighting masts; installation of a single storey structure for equipment storage/welfare facilities; associated hard surface, picnic area, bike racks, compost toilet, soft landscaping and vehicle parking

We considered this application in parallel with the one below for the Gurnell Leisure Centre site.  They are separate applications but related although the Council does not draw this to the attention of those wishing to comment.  The application has attracted nearly 400 comments, of which many are in support of the facility.  Most of these however ignore the planning reasons why the chosen site is unsuitable; the positive aspects of such a facility are not in doubt, but it must be in the right place!  The application remains undetermined.

Ealing Civic Society objects to this application because we consider the proposed construction of a BMX cycle track would be inappropriate development of the Metropolitan Open Land of Longfield Playing Fields, which are part of the recently designated Greenford to Gurnell Greenway.  The current site of the BMX cycle track has already required encroachment upon MOL and its planned relocation would require further MOL development on the hitherto undeveloped meadowland, without equivalent restitution of the previous site, now proposed to be subsumed as part of the Gurnell Pool redevelopment.  This, in our view, would be unacceptable.

In addition, the proposed new site for the cycle track is much less appropriate than its current site because the track would impact negatively on housing immediately to its north and be significantly less convenient for residents of the Gurnell Grove Estate who benefit from the current location.  Stockdove Way would also become even more congested than it currently is due to the access route it provides to Perivale Park Athletics Track.

This application should be refused and a more suitable, brownfield, site identified elsewhere, with this area incorporated into the Greenway landscape as originally promised.

 

Gurnell Leisure Centre, Ruislip Road East, W13 0AL – 201695FUL – Demolition of all existing buildings and erection of replacement leisure centre (Use Class D2), facilitating affordable and market housing residential development (Use Class C3) in 6 blocks, flexible retail floorspace (Use Classes A1 – A3), plant room and energy centre, leisure centre coach parking, basement residential and leisure centre cycle and car parking, refuse/recycling storage, new servicing, vehicular and pedestrian accesses and associated highway works, new and replacement play space, public realm and public open space, landscaping and associated ground works to existing public open space

Strong campaigning has resulted in over 1600 objections to this application.  The application remains undetermined.

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.

Density

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.

Unit mix

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%.

Amenity space

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.

Car parking

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.

EIA

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.

Conclusion

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.

 

 TfL Landholdings At Bollo Lane Acton Ealing Bounded By The Railway Lines To The West Acton Town Station To The North Bollo Lane To The East And The Bollo Lane Level Crossing To The South. W3 8QU – 201379OUT – Hybrid planning application for comprehensive phased redevelopment of the site comprising:

Full planning permission for demolition of existing buildings and structures (Phases 1 to 2) to provide up to 550sqm (GIA) of Business Use Class B1a/b/c floorspace, up to 125sqm (GIA) of flexible commercial Use Classes A1 / A2 / A3 / A4 / A5, up to 200 new affordable and market dwellings in a block up to 25 storeys, replacement Train Crew Accommodation (TCA) building, new footway to Bollo Lane, relocated bus stop, new pedestrian crossing, new open and amenity space and associated public realm works.

Outline planning permission (Phases 3 to 4) for demolition of existing buildings and structures to provide up to 1,800sqm (GIA) of Business Use Class B1a/b/c floorspace, up to 175sqm (GIA) of flexible commercial Use Classes A1 / A2 / A3 / A4 / A5, up to 700 new affordable and market dwellings (up to 61,940sqm(GIA)) in 8 Blocks of between 8 storeys and 18 storeys, new open and amenity space, vehicle and cycle parking, rear service road, alterations to vehicular accesses and associated public realm works. Appearance to be a ‘reserved’ matter.

This application has attracted over 600 objections and remains undetermined.

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.

 

22 Somerset Road, W13 9PB – 201967FUL – Construction of a three storey building , with basement level and habitable loft space, to accommodate 9 self-contained flats (following demolition of existing dwelling house) and provision of associated amenity spaces, parking spaces, cycle storage and refuse storage facilities

This and the related application for the next door site have each attracted over 100 objections and remain undetermined.

This objection should be considered in conjunction with our objection to application reference 201966 to be determined simultaneously.

Extent of Development. Ealing Civic Society objects to this application on grounds of overdevelopment. It is proposed to build a block of 9 flats for a total of 33 residents on the site of a single family house typically accommodating 4 or 5. This represents a massive increase in occupancy at odds with the character of the area. The footprint of the accommodation on the site is more than doubled and the proposed building extends excessively to the rear, beyond the rear of both its neighbour Trend Court and the proposed (and itself too large) new property at number 24. The density of the proposed development is also excessive. In the planning statement, the applicants acknowledge that the location is suburban yet then go on to claim that it should be assessed as urban as it is close to the Uxbridge Road. The location is definitely suburban in character and density must be considered in this context.  The 9 units on this .063 hectare site yield a density of 142 DPH and while we accept that this falls within the URBAN guideline of 45-185 DPH, it well exceeds the range for a SUBURBAN site of 45-90 DPH.

Living Conditions. The development includes a proposed basement of two units, one being the single family sized 3-bed unit. Flats located entirely at basement level provide sub-optimal living conditions and are particularly unsuitable for families. In this case, the basements add nothing to the design of the buildings and seem only to be included to maximise the number of units offered on the site, contributing to the overdevelopment. Should planners be minded to grant the application, as a minimum, the basement should be omitted.

Overlooking. Balconies are proposed to the rear of the development at 1st, 2nd and 3rd floors. Although an obscure glazed panel is proposed to the side towards number 24, these will still allow unacceptable overlooking to the rear amenity area of Trend Court and, tangentially, to the rear garden of 2A Rathgar Avenue.

 

 24 Somerset Road, W13 9PB – 201966FUL – Construction of a three storey building , with basement level and habitable loft space, to accommodate 9 self-contained flats (following demolition of existing dwelling house) and provision of associated amenity spaces, parking spaces, cycle storage and refuse storage facilities.

See above.

This objection should be considered in conjunction with our objection to application reference 201967 to be determined simultaneously.

Extent of Development. Ealing Civic Society objects to this application on grounds of overdevelopment. It is proposed to build a block of 9 flats with a total of 26 residents on the site of a single family house typically accommodating 4 or 5. This represents a massive increase in occupancy at odds with the character of the area. The footprint of the accommodation on the site is significantly increased and now appears to cover more than 50% of the plot and to extend at the rear beyond the rear of its neighbour number 26. The density of the proposed development is also excessive. In the planning statement, the applicants acknowledge that the location is suburban yet then go on to claim that it should be assessed as urban as it is close to the Uxbridge Road. The location is definitely suburban in character and density must be considered in this context.  The 9 units on this .04 hectare site yield a density of 225 DPH, significantly in excess of even the URBAN guideline of 45-185 DPH; and more than double the range for a SUBURBAN site of 45-90 DPH.

Living Conditions. The development includes a proposed basement of two units, one being the single family sized 3-bed unit. Flats located entirely at basement level provide sub-optimal living conditions and are particularly unsuitable for families. In this case, the basements add nothing to the design of the buildings and seem only to be included to maximise the number of units offered on the site, contributing to the overdevelopment. Should planners be minded to grant the application, as a minimum, the basement should be omitted.

Overlooking. Balconies are proposed to the rear of the development at 1st, 2nd and 3rd floors. Although an obscure glazed panel is proposed to the side towards number 22, these will still allow unacceptable overlooking to the rear garden of number 26 and also to the rear garden of 2A Rathgar Avenue.

 

64 Clovelly Road, W5 5HE – 202205FUL – Conversion of existing building into 6 self-contained flats; excavation to provide a basement level; single storey rear extension; single storey, part two storey, side extension including a creation of terrace/balcony to the first floor rear elevation (following demolition of existing side annexe and garage); Conversion of loft space into habitable room; rear roof extension, and installation of three roof lights to front roof slopes and creation of two terraces/balconies to the roof level rear elevation.

This application attracted 50 objections and has been withdrawn (suggesting that the Council may have advised it would not be approved); we await a revised submission.

Ealing Civic Society objects to this proposal on grounds of overdevelopment and unacceptable design.

While we could support the removal of the poor quality 1950s/60s side extension to the property, any replacement extension should be of a scale and design in keeping with the host property and subservient to it; this is neither. The proposals significantly extend the building envelope in all directions and do not, as claimed, lie within it. The floor area of the building is to be increased by over 200% to accommodate 28 residents rather than the 9/10 at present. The proposed 6 units would deliver a density of 120 units per hectare. In the submitted planning statement, it is suggested that the guideline density applicable to the location is 45-170 u/ha. This is an amalgamation of figures for flats of various sizes including single person units which are irrelevant here, and in an URBAN area. This area is SUBURBAN  and for the size of units proposed the correct guideline density is 40-80 u/ha. Planners should not accept the figures quoted by the developers but assess this proposal against these correct figures, and note that the maximum Is exceeded by 50%.

In terms of design, while elements of the front elevation attempt to replicate features of the host property and neighbours, the roof treatment is incongruous. The design of the southern side extension, which would be highly visible from Lammas Park, is not in keeping with that of neighbouring properties and appears excessively bulky. Similarly, the rear extensions, all with balconies/terraces extend considerably further into the plot than any neighbouring properties, present an overbearing appearance when viewed from the park. Plot coverage is also too great, apparently taking up over 50% of the area and bringing the building line too close to the two park boundaries.

Finally, we have concerns about two aspects insufficiently addressed from the planners’ pre-application comments. It was suggested that the three-bed family unit would be better situated on the ground floor. Although we note that this unit has now been given amenity space in the form of a terrace, such provision remains non-ideal for a family and relocation to the ground floor would be more suitable. It is noted that this area is prone to ground water flooding and it is clear that this is an unsuitable location for a basement. Omission of the basement was recommended but this advice has not been followed. Basement accommodation in any case offers far from ideal living conditions and should not be accepted.

In summary, this unsuitable application should be refused and revised proposals developed.

 

51-56 Manor Road and 53-55 Drayton Green Road, W13 0LJ – 202231FUL – Construction of a building with a basement level, part double-height ground floor with part mezzanine floor and 18 and 12 floors above with roof plant and communal roof garden to accommodate two flexible-use units at ground floor (A1/A2/A3/D1 or D2 use classes) and 144 residential units (100% affordable) on the upper floors (mezzanine to 18th floor) with associated cycle and bin stores, substation, private and communal amenity space and alterations to the highway (following demolition of existing buildings on site)

This application generated a very visible and successful campaign in opposition and attracted an unprecedented over 2300 objections.  It was referred to a planning committee for approval with planners’ recommendation to grant permission.  In a rare example of not following officers’ recommendations, the committee narrowly voted to refuse the application.

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.

 

70 Hanger Lane, W5 2JH – 202253FUL – Construction of a part two, part three, part four and part five-storey building with two basement levels comprising 48 self-contained residential units and provision of associated communal areas (co-living space) ,1 disabled parking space and 1 delivery bay accessed off Hanger Lane (Use Class Sui Generis) (Following demolition of existing buildings)

In addition to the Society’s objection, this application has attracted objections from several local conservation area panels as well as local residents.  The application remains undetermined.

Ealing Civic Society objects strongly to this application.  First and fundamentally, we contest that the development qualifies as sui generis use class.  It is our overall contention that due to the facilities and layout of the units and the provision of an on-site affordable housing contribution, this development should be treated as a C3 residential use and should therefore meet the policy requirements for residential uses in the Local Plan in respect of such things as unit sizes, density and amenity space provision.

There is a key requirement in Draft London Plan Policy H16 that in order to qualify as a sui-generis use class, co-living spaces must be of ‘adequate size and demonstrably not Use Class C3’.  Since the units are shown with living space, cooking facilities and bathrooms there is nothing to differentiate them from standard residential accommodation which means the units fall under the C3 use class.  Except in this case their size is generally below half the London Plan minimum for a studio unit, which is clearly totally unacceptable. Previously permitted co-living developments in the Borough are typified by more communal space and fewer facilities within the actual units, which differentiates them from C3 uses.

Furthermore, the Draft London Plan Policy H16 makes clear (A:9) that such development should provide a financial contribution in lieu of on site affordable housing. The explanatory notes state at para 4.16.7 that this is because this form of accommodation ‘does not meet minimum housing space standards and is not considered suitable as a form of affordable housing itself’. If affordable housing is proposed on site the units fall far below the London Plan space standards.

Secondly, we object most strongly to the proposal to construct such a significant development on Metropolitan Open Land (MOL).  We consider the planned increase of the existing building footprint by a factor of 2 and of built volume on the site by a factor of 8 to be completely unacceptable. The justification that is given in the recently uploaded Planning Statement is that the development falls into the exception to inappropriate development in Paragraph 145(g) of the NPPF (2019). In our view this exception is not made out as the development clearly causes substantial harm to the openness of Metropolitan Open Land by virtue of the increased volume of the on-site development.  Furthermore, no evidence has been presented to suggest Very Special Circumstances (VSC) apply to this development and in our view no VSC exist.

With respect to the proposed living conditions, we consider that this location next to the North Circular Road would be subject not only to traffic noise as acknowledged by the applicant, but also to vibration from heavy lorries using the road and to air-borne pollution.  No attempt appears to have been made by the applicant to address these issues and we cannot accept the applicant’s assertion that pollution would not impact negatively on future residents. Under the Mayor’s ULEZ proposals the North and South Circular Roads will be excluded from the more restrictive inner zone requirements from Autumn 2021 suggesting that more polluting traffic will be diverted onto this road by the time any development is built.

We object to the inclusion of residential units in the basement which we consider would not offer acceptable living conditions for future occupiers.  The very limited amenity space (45m2) proposed at the rear is inadequate even were a sui generis use approved and should be enhanced with additional landscaping to both front and rear.  Furthermore, one disabled car parking space would be insufficient for such a development and, should the application proceed, a legal agreement should be entered into that it should be car-free with leases to include a clause that residents may not park cars in neighbouring residential streets.

Finally, no impact assessment has been included in the application in relation to the Hanger Hill (Haymills Estate) Conservation Area, which lies immediately opposite the site on the east side of Hanger Lane.

 

Fern Bank, 2A Golden Manor, W7 3EE – 202794NMA – Application for a Non-Material Amendment in (S96a) seeking to allow lightwells to the side of dwelling on both sides in relation to planning permission reference 200106VAR dated 19/06/2020 for ‘Application for a Minor Material Amendment (S73a) to vary condition 2 (Approved Plans) of planning permission ref: 193811VAR dated 11/11/2019 for: Minor material amendment (S.73) to vary conditions no.2 (Approved Plans), no.3 (Parking Spaces), no.4 (Refuse Storage), no.5 (Cycle Storage) and no.8(Scheme of Landscaping) pursuant to planning permission reference 185210VAR dated 04/01/2019 for’ Application for Minor Material Amendment (S.73 Application) for the variation of Condition 2 (Approved Drawings), Condition 3 (Car Parking), Condition 4 (Refuse) and Condition 5 (Cycle storage) of Planning Permission ref: 172082VAR, granted on appeal Ref: APP/A5270/W/17/3191628 dated 25/04/2018, for ‘Application for Minor Material Amendment (S73)/Variation of condition 2 (approved drawings) of planning permission ref. PP/2014/6371, granted on appeal ref. APP/A5270/W/16/3162325 dated 31/01/2017 for Replacement of a two storey, with habitable loft, detached dwelling house with associated access, refuse storage, cycle storage and landscaping including formation of hard standing; basement with rear and front light’. Amendment includes the addition of two lightwells to the side’

This application is the latest in a series of amendments to an originally granted permission which together result in an unacceptable development.  We note that although technically allowed, this approach is a deliberate manipulation of the planning system.  The application remains undetermined.

Ealing Civic Society objects to this application.  We maintain our strong objection to the applicant’s approach of making a number of retrospective variation applications following unapproved incremental development of this site.  The Council should not endorse this abuse of planning regulations which contravenes its own requirements and process for non-material amendment applications as described at https://www.ealing.gov.uk/info/201161/planning_permission/649/applying_for_planning_permission/4

 

178 Church Road, W7 3BP – 201141FUL – Construction of a two storey building, with habitable loft space, to include 6 self-contained flats and construction of a single storey building, with habitable loft space, to include 2 self-contained flats (8 flats total); Provision associated communal garden area, parking, landscaping, refuse storage. (following demolition of existing building)

We submitted a further objection following revisions by the applicant and the provision of a ‘heritage statement’ in July 2020.  The application remains undetermined.

General

We have studied this addendum with interest since the authors have now acknowledged the merits of the house and accepted its provenance (which was provided by the Society). However the document remains full of contradictions and ill-informed assertions that suggest the authors lack any understanding of both the history and significance of the building and the character of the area in which it sits.

The authors acknowledge that the Society has uncovered a significant amount of information about the history of the building and its possible link with Hanwell Methodist Church, all of which was absent in the original Historical Statement.  This, despite its title and remarkable length, appeared to contain no statement of the history of the building at all.  We are pleased that this now at least admits that both the exterior and interior have “architectural value”.

The authors have also taken on board that the building combines Arts & Crafts features with more forward-looking interwar elements, which gives it a particular significance and rarity. However, they then attempt to undermine the value of the building by suggesting, completely incorrectly, that it is composed of two different structures.  This is pure fantasy and, needless to say, no evidence is adduced for this assertion and inspection of the plans [and building records] confirm it is baseless.

Having accepted that the building is an important “transition” from one style to another, the report then tries to claim it is in fact a hybrid and as a result somehow becomes worthless (“detracts from its significance and makes it unworthy of conserving” – page 2 para 6).  Aside from the absurdity that re-badging the house as a hybrid would strip it of its inherent significance, something that is a transition cannot, by definition, be a hybrid, which is a fusion of two pre-existing typologies.  It cannot be both transitioning to a new, as yet unestablished style, and also a hybrid of that style.  No, the building is a transitional pre-cursor, a remarkably early one, and as such doubly important and this is confirmed by the Victorian Society, who have referred to it recently as ‘irreplaceable’.

The report then describes it as an “anomaly of styles”.  Not only is this meaningless, an anomaly is an outlier from a single group, if we assume the author is attempting to say that it is a mix of styles, this is merely further acknowledgement of its transitional nature and a restatement of its significance.

The addendum then continues with further meaningless statements such as the following:

‘Whilst it’s (sic) independent design may contribute to the diverse character of the area, the hybrid style is not contiguous (sic) with the majority of buildings in the Conservation Area which are clearly from one period or another… Essentially it is the mix found in the form, style and quality of the current building that gives it an “ad hoc” character. This has the overall effect of diluting its appearance and allowing it to be read clearly as an Edwardian building”‘ … [para 7 page 2]

The author then attempts to challenge the status of the independent analysis of the character of the conservation area carried out in [2004] which specifically highlighted the positive contribution that the building makes to the Conservation Area.  Not only were no grounds given for this, we can also confirm that this analysis was very recently revisited by another independent consultant assessing the character of the conservation area on behalf of Ealing Council and the evaluation remains unchanged.

Design direction

The addendum goes on to try to justify the design of the proposed replacement building, which “makes more detailed references in its scale, massing and materiality to the Edwardian period and it takes its inspiration from the more picturesque nature of the Arts & Crafts idiom.” (page 3 para 8).

Despite these claims, the resulting design is in fact a clumsy Victorian pastiche that is deeply anachronistic and bears no relation to its neighbours or the local character of the Conservation Area.  Any references to the Arts and Crafts are so oblique as to be indiscernible.

The absurdity of this position is summed up in the totally bizarre assertion that the design of the proposed replacement building is more successful than the existing property because it “refers to the Traditional style in terms of its design, scale, massing and detailing”.  This is then contrasted with the “weakness” of the existing building on account of the “synthesis of the interwar form and the Arts & Crafts style” it demonstrates.  This succeeds in being simultaneously meaningless, incoherent and self-contradictory.

Public benefit to justify the harm of losing a unique Arts & Crafts house…

The report attempts to argue against the presumption in favour of preserving a positive contributor to the character of the conservation area by suggesting – again without any evidence – that its setting, in particular in relation to the rear, had in some way changed since the creation of the Conservation Area.  This, like so much else, is simply untrue, the changes to the rear of 180-190 Church Road all took place between the 1930s and the 1960s, decades before the Conservation Area appraisal of 2008 which identified no. 178 as a positive contributor.

Again without any evidence, the addendum also tries to suggest that “No 178’s earlier role as a former detached building has been modified through later additions and its status as a building from one architectural period has been compromised by stylistic touches from the 1930s” (page 4 para 3). As noted above, all the evidence is that the house is almost completely unaltered from when it was built in this form and there is no evidence for any subsequent additions or extensions.

With mounting incoherence, the addendum then goes on in a vain attempt to justify the design of the proposed replacement building by indicating that the “front elevation will allow for the other positive buildings in the context of number 178 to continue to be appreciated and encourages them to be placed within the wider spectrum of the local area… As the scale is in keeping with adjacent buildings it would not cause harm to the wider CA and would at least preserve the character and appearance of the … CA”.  Even if this had any meaning, it would be self-contradictory and baseless.

This is followed by the even more preposterous claim that “the loss of a hybrid building that provides an unusual contribution to the CA and its replacement with a whole building that refers to one architectural movement should be seen as an overall improvement .” (page 4 para 7).

Setting aside the fact that it is not a ‘hybrid’ building, this is simply a case of calling night as day.  It goes without saying that the loss of a contributor to the Conservation Area cannot be an improvement.  When the building to be lost is an irreplaceable missing link of great originality and the proposed replacement is a clumsy, poorly detailed and stylistically inappropriate pastiche then it truly is a case of trying to defend the indefensible.

 

Rear of Brent & Glebe Court, Church Road, W7 3BZ – 202873FUL – Construction of a three storey building comprising six flats (one x 1 bed, four x 2 bed and 1 x 3 bed); associated cycle/car parking and refuse storage and amenity areas (following demolition of existing garages)

It is of note that it has been suggested by local residents that the applicant has proposed building over part of the graveyard of the adjacent listed St Mary’s church, which must surely be unacceptable.  This application remains undetermined.

Ealing Civic Society objects to this application on the grounds of overdevelopment, inappropriate design and materials, failure to preserve or enhance the Conservation Area, inadequate amenity space and inadequate parking provision.  Further detail is provided in our emailed objection, but the major issues relate to overdevelopment, inappropriate design and materials and thus negative impact on the Conservation Area and grade II* listed St Mary’s Church.

Overdevelopment.  The proposed 6 flats on the site would have greater density and occupancy than the previously proposed three family houses advised by the Council at pre-application stage to be overdevelopment.  If there is to be any development on this site, three family houses of appropriate design would be a preferable alternative that would also better meet housing need.

Design and materials.  The contemporary design and in particular the crown roof and fenestration are incongruous in this location and the proposed red brick, roof tiles and aluminium window frames would be unsympathetic to neighbouring buildings.

We urge planners to refuse this inappropriate application.

 

10 and 12 Perryn Road, W3 7LR – 201805FUL – Demolition of existing buildings and construction of a part two and part three storey building including excavation for basement level to accommodate 8no. self-contained flats; provision of 3no. car parking spaces within forecourt; provision of refuse and bicycle store and associated landscaping

This developer’s application proposing demolition of two Victorian houses in a conservation area has attracted significant local objections.  The application remains undetermined.

Ealing Civic Society objects to this application.  We object in principle to the demolition of Victorian buildings within a conservation area.  In this instance, the planned demolition would not conserve or enhance the character and appearance of the Acton Park Conservation Area or the character and setting of the nearby Grade II* listed buildings, the Goldsmiths Almshouses.  We refute the view of the applicant that the existing buildings do not contribute to the Conservation Area.  The original features retained in these existing buildings, such as lintels and chimneys, are important to the streetscape of Perryn Road.  In addition, the “low quality alterations” mentioned in the Design and Access Statement predominantly refer to the modern extensions primarily to the rear of the buildings, not visible from the street.  Finally, we object to the proposed replacement buildings which would not be in keeping, and actually clash, with their neighbours – further to the detriment of the character and appearance of the Conservation Area.

Land At Rear of 7 Montpelier Road, W5 2QP – 202902FULConstruction of a single storey dwelling house with habitable basement level and provision of associated amenity space cycle storage and refuse storage facilities.

This application remains undetermined.

Ealing Civic Society objects to this application.  ECS objects in principle to back land development due to its propensity to provide poor quality homes in terms of design, access and siting.  The development in question is no different and for this reason alone, the application should be refused.  In design terms it provides a blank wall along its southern facade whereas the windows that are provided on the northern facades look directly on to a blank fence and brick wall respectively.  Access to the unit via a narrow walkway is poor, particularly for emergency services.  Finally, the siting of the property is inappropriate in planning terms.  The public comments demonstrate that neighbouring residents are vociferously opposed to the development due to the impact it will have on their amenity.

 

56-58 Stanley Gardens, W3 7SZ – 203193FUL – Demolition of the existing building and redevelopment of the site by construction of a part 5, part 7, part 8 and part 10 storey mixed use building for residential use (Use Class C3) comprising 76 units (44 x one bedroom; 26 x two bedroom and 6 x three bedroom) and commercial uses (Use Class B1(a)) comprising 969m2; together with ancillary parking space for 10 cars, cycle and bin stores, plant rooms and landscaped communal court at first floor level and landscaped communal roof terraces.

This application remains undetermined.

Ealing Civic Society objects to this application.  The proposals would result in considerable overdevelopment.  The density of the proposed development would be excessive and, at 10 storeys, the building is far too high.  We note that in pre-application discussions, planners advised the applicant that a maximum of 7 storeys should be considered and for this reason alone, the proposals would be unacceptable.  In addition, we object to the plan for 44 one bedroom units with just 6 three bedroom units, when Ealing borough is chronically short of 3-bedroom family units.

We also consider that a residential building within this locally significant industrial area would be inappropriate.  Residents would not have sufficient access to local amenities.  We note that this view is reflected in Ealing’s local planning policy.  Even if the Council were to accept deviation from the Local Plan, we would maintain that a residential building on this site would be incongruous.

Land Adjacent To 1-11 Shalimar Gardens, W3 9JG – 203061FUL – Construction three-storey residential building incorporating roofspace and basement level accommodation comprising five self-contained residential units (1 x 3 bed; 1x 2 bed; 3 x 1 bed); and provision of cycle and refuse/recycling storage; and private amenity space

This application remains undetermined.

Ealing Civic Society objects to this application.  We object most strongly to the design of the proposed building.  The residential properties immediately next to this site are of considerable architectural quality.  Consequently, their design should be suitably reflected in that of any adjacent scheme, which is not the case here.  As it stands, the design of the planned building is extremely poor.  The building would always read as a weak, unconvincing pastiche of its neighbours.  Specifically, the Dutch gable proposed in this application would be better centred on the building.  Given the grandeur of the neighbouring properties, the proposed roof windows would benefit from being of conservation style despite the site not being located in a conservation area.  Furthermore, we object to the design of the rear of the proposed building which appears to have an industrial aesthetic which would be completely out of keeping within a residential setting.  Finally, we consider that the planned building would be far too close to its neighbours in Horn Lane and have a very negative impact on their outlook, particularly the proposed blank eastern wall.

 

Arden Road Car Park, Corner of Arden Road & Uxbridge Road, W13 8RP – 203717FUL – Construction of a part 8 storey, part 6 storey and part 4 storey building comprising 29 residential units (Use Class C3) and a commercial unit (Use Class E) at ground floor, along with refuse storage, cycle parking storage, plant rooms, communal roof terrace on the fourth floor and associated private amenity space; provision of 9 car parking spaces; and associated alterations to the public realm along Arden Road and Uxbridge Road. (Regulation 3 Application by London Borough of Ealing)

This application is one of 6 submitted by the Council proposing residential development on sites deemed suitable for repurposing.  We submitted comments to the earlier public consultation on these proposals, which were largely ignored and were thus resubmitted in response to the planning application.  This unpopular application has received nearly 90 objections ; the application remains undetermined.

Ealing Civic Society object to this application.  We are extremely disappointed that the applicant does not appear to have taken into account our comments to the pre-application community consultation.  We maintain our objections as follows:

We consider that the proposed development would be out of keeping with the surrounding area by reason of its height and massing.  Firstly, the planned footprint does not respect the boulevard nature of the Uxbridge Road corridor – the new building would be set far too close to the road and should be set back to reflect the building line of the neighbouring church.  No consideration has been made to preserve views of the important heritage asset of the locally listed Fire Station.  The proposed building would also be much too high and over bulky in relation to its immediate neighbours – two and three storey houses.  Rather than offering an opportunity to enhance the community garden to the north of the site as suggested in the proposals, the construction of a 7/8 storey building would block all sunlight from the garden making it unsustainable as a growing space and unattractive as a ‘green oasis’.  In addition, the planned materials would be unsympathetic to those used elsewhere this vicinity.

Furthermore, we have concerns about the planned mix of accommodation.  There is already an over-supply of one- and two-bedroom flats in Ealing.  Any development on this site should provide much needed three-bedroom family units.

 

Maitland Yard & Dean Gardens Car Parks, South Of Pioneer Court, Leeland Mansions & The Lodge, Dean Gardens, Leeland Terrace, W13 9AW – 203719FUL – Construction of a 4 storey building, a 6 storey building and an 8 storey building, with lower ground floors, comprising 53 residential units in total (Use Class C3) and a commercial unit along Uxbridge Road (Use Class E), along with refuse storage, cycle parking storage and plant rooms; and associated alterations to the site access and public realm comprising landscaping, car parking and public amenity spaces to Maitland Yard and along Leeland Terrace. (Following demolition of existing building). (Regulation 3 Application by London Borough of Ealing)

This application is also one of 6 submitted by the Council proposing residential development on sites deemed suitable for repurposing.  We submitted comments to the earlier public consultation on these proposals, which were largely ignored and were thus resubmitted in response to the planning application.  The application remains undetermined.

Ealing Civic Society object to this application.  We are extremely disappointed that the Council did not appear to have taken into account our comments to the pre-application community consultation.  We maintain our objections as follows:

We consider that the proposed development would be out of keeping with the surrounding area.  The planned design is unimaginative and characterless and would not reflect the local vernacular.  The proposals represent overdevelopment and in particular, the proposed blocks would be far too high and the materials do not appear to complement the red brick of the neighbouring buildings.

In addition, we have concerns about the planned mix of accommodation.  There is already an over-supply of one- and two-bedroom flats in Ealing.  Any development on this site should comprise a predominance of much needed three-bedroom family units.

Finally, we consider that all the existing mature street trees on the boundary of the car park should be retained and well-managed.  Past neglect should not be a reason for their removal.

Land to Rear of 29 Corfton Road, W5 2HP – 203547FULConversion of an existing single storey building with basement storage into single family dwellinghouse; incorporating basement extension with two front lightwells; part single storey front extension; and provision of associated cycle storage, refuse storage and amenity space

The application remains undetermined.

Ealing Civic Society objects to this application.  We reject the applicant’s assertion that, because planning permission has already been granted for development on this site, permission should be granted for this application.  Instead, the Council must give full consideration to this new application.

Ealing Civic Society objects in principle to backland development due to its propensity to provide poor quality homes in terms of design, access and siting.  This proposed incremental development is no different and, for this reason alone, the application should be refused, as indeed we consider the previous application should have been.  To compound this, in our view, the building design in this latest proposal is of lower quality than the consented scheme.  The site is situated within the Ealing Cricket Ground Conservation Area, and we do not consider that the proposed design would preserve or enhance the area. If, however, the Council is minded to approve the application the flat roof addition should be altered to have a pitched roof and the fenestration should be of a more traditional design so as to be more in keeping with the character of the conservation area.

 

Perceval House, 14-16 Uxbridge Road, W5 2HL – 203275FULR3Demolition of existing buildings and phased redevelopment of the site to provide a mixed-use development comprising residential, office, civic/community uses and flexible non-residential floor space, below ground ancillary space (plant, car and cycle parking space, etc.), replacement and relocation of the existing sub-station, associated enabling landscape and public realm works and provision of new pedestrian and vehicle access. (Regulation 3 Application by London Borough of Ealing)

This application for redevelopment of the Council’s Perceval House site has now attracted over 750 objections along with concerns that the Council as landowner and planning authority is conflicted.  The application remains undetermined.

Ealing Civic Society objects to a number of aspects of this proposed development, which in summary we consider would cause substantial and unacceptable harm to the Ealing Town Centre Conservation Area, its residential neighbours and many heritage assets, is of inadequate design quality and does not adhere to aspects of planning policy.

Impact of tall building on heritage assets & distant views

The mass and height in particular of the 26 storey rear block would in our view cause substantial harm to heritage assets neighbouring the development site, namely:

  • Grade II listed Ealing Town Hall, particularly on the setting of the Town Hall when viewed towards the north-west from New Broadway;
  • Grade II* listed Christ the Saviour Church when looking towards the west from Ealing Broadway;
  • General views to the north-west from within the Ealing Town Centre conservation area; and
  • Locally listed former Ealing Fire Station, Longfield Avenue immediately opposite the site.

The impact can be clearly seen from the various visual impact assessments which accompany the application, in particular Views 3 & 4. Also, and arguably more damagingly, the block would intrude negatively in distant views looking north (View 9) from the Grade II* listed bridge in Walpole Park designed by Sir John Soane c 1800.

Although we note that Historic England takes the view that the harm to heritage assets would amount to less than substantial in policy terms, we would respectfully suggest that they underestimate this harm and we consider it to likely to be substantial in practice . We do not believe that this substantial harm could ever be outweighed by any alleged public benefits deriving from the scheme (policies 194 and 196 of the NPPF refer). We also agree with Historic England that the degree of harm would be exacerbated by the proposed appearance of the building, in particular the  prominent vertical red stripe on the East elevation which would serve to increase the presence and dominance of this building in view 3 in the context of Christ the Saviour Church. At the very least, the height of the building should be reduced in order to reduce its dominance in the landscape.

Design elements: cantilevered front block; alignment of Uxbridge Road frontage

We consider the design of the proposed cantilevered front block, together with the large area of glazing, to be unsympathetic and out of keeping with that of the Gothic style Grade II listed Ealing Town Hall immediately opposite to the East. We would wish the cantilevered element to be omitted which would have the benefit of removing the proposed arcaded area with its unattractive open space which is likely to be uninviting and windblown in anything other than very clement weather.

Furthermore, the frontage of the front block as proposed would be bought forward of the existing building line of Perceval House which would not be consistent with the “office corridor” concept set out in the Local Plan (policy 2.5(e)) and the Central Ealing Neighbourhood plan (policy HBE2). Both policies envisage an “increase in the number of street trees, other planting and active ground floor frontages” and the proposed development would thwart this ambition.

Conflict of interest

We understand from discussions with the developer that the overall quantum of development, in particular the height of the tallest block, has been driven entirely by the degree of development required in order to deliver the extent of affordable housing sought by the Council and its ambition to provide Council offices and associated facilities including the relocated Central Library and Customer Service Centre at no cost to the Council taxpayer. Since the Council, acting in its capacity as the local Planning Authority, will be determining the planning application and at the same time has a financial interest in the outcome it will be facing a conflict of interest. For this reason we consider that the final decision should be taken out of the Council’s hands and taken by the Secretary of State.