78a Silver Crescent
W4 5SE

22 May 2002
Planning reference: 00248/BX/P1
00248/586 -596/P1 00248/BY/P1

Mr Ian Draper
Planning Officer
The Civic Centre
Lampton Road
Middx TW3 4DN

Dear Mr Draper,
Chiswick West development - reconsultation

I refer to your letter of 7 May to the Society concerning the resubmitted planning application for 391-409 Chiswick High Road and land adjoining, 568-596 Chiswick High Road and land adjoining and land adjacent to Gunnersbury Station (01.10.2001. amended 05.04.2002.).

The Society has examined the revised plans and wish to register our objections to them.

These plans propose a 28 storey building adjacent to the existing BSI and a six storey building rising to nine storeys opposite. This would require the demolition of three residential units of housing, a public house and existing office block (Singapore Airlines) on one site; and a detached house and row of retail shops with flats above them.

Both buildings would be considerably higher than the existing buildings and would effectively tower above other properties, particularly residential units in the area.

In addition, these developments are in conflict with the UDP in that:

1. The nature of the development is not comparable with the existing area in terms of size, scale and design. The UDP states that any development needs to respect the proportions of existing buildings. This is not the case with these developments. The development of a tall building, such as Chiswick West, as well as the proposed office development at 391 - 409, clearly conflicts with the Council's UDP.
2. It also does not accord with the Council's policy in terms of the adverse impact it will have on the adjoining residential areas and open spaces.
3. The 28 storey tower and the 6 to 9 storey office development opposite will cast a significant shadow over much of Silver Crescent and Thorney Hedge Road. This will invade the privacy of those whole reside in these roads; as well as properties to the East and South of the Tower block development. The UDP makes it clear that any development needs to ensure that adequate daylight and sunlight reaches adjoining properties, and minimise any detrimental impact on them. It should also enhance the townscape of the surrounding area (see env.B/)002 & 003). This is not the case with this development.
4. For the Council to fail to recognise the intrusive nature of this development on those who live in the area, might place it - as a public body - in conflict with Article 8 of the Human Rights Act 1998, which provides for individuals to have a right to privacy.
5. The UDP also require the design of developments to enhance the safety and security in the environment. The Society would like to point out that both the local authority and police have a general duty under section 17 of the Crime and Disorder Act 1998 to ensure that in discharging their other duties they contribute to reducing crime and disorder in the area. To approve the construction of a 28 storey tower block on the flight path site to Heathrow and close to both a public transport station and the Chiswick Flyover would create a major security risk and provide a potential target for terrorists. As such they would both be failing in their duty under the Act if they were to approve a development of this nature.
6. The tower block would be visible from the conservation areas close to the site, as well as the Gunnersbury Triangle Nature Reserve; and would have an adverse impact on both these areas.
7. The Council's policy is to oppose the redevelopment of arts, cultural and entertainment facilities unless it includes the provision for replacement facilities on site (see C6.1 of UDP). The development proposes the demolition of the John Bull public house without any proposal to replace it on site.
8. The UDP envisages that Chiswick Business Park would be the area for office development in this part of the Borough. This Park is still under construction, yet is not fully let. There are other vacant office properties close by, which remain vacant. Indeed in recent years a number of office buildings have been changed over to residential use. Therefore, there is already a surfeit of office development on this part of the Chiswick High Road. So more is not needed and would not accord with the principles of sustainable and mixed development.
9. The degree of affordable and key worker housing proposed is only 69 units, which is considerably less than those required in the Borough's own Housing Strategy, or that shown in the UDP.
10. The amount of parking proposed is completely inadequate for some 226 units of accommodation, together with the parking generated by a further 700 jobs connected with the office development, the staff required to service the residential units, leisure facilities, restaurants and retail units. This would mean that parking would spill over into adjacent residential streets, which are already so heavily congested that it is often impossible for residents to find parking spaces near their homes.
11. The additional traffic flow that would be created as a result of the development would add to the untenable volume of traffic on Chiswick High Road This road will already become increasingly congested anyway once the Chiswick Business Park becomes fully developed. To add further to it would be detrimental to the area.
12. Furthermore, the additional traffic on Chiswick High Road would impede the flow of bus transport.
13. Although the developer proposed some developments to improve the access to Gunnersbury Station, these have not been agreed to by Railtrack or the train operating companies. In any event, they would not improve the flow of rail transport to station and would add to the heavy amount of passenger traffic that station experiences at peak travel times.
14. The UDP (IMP/005) makes it clear that any economic development in this part of the Borough should be accommodated within Chiswick Business Park "providing that public transport can be improved". This development fails both these tests.
15. The UDP also states that its policy is to retain and reintroduce the residential use of upper floor of business properties fronting Chiswick High Road. The Council also expressed its concern at the continuous pressure for additional A3 premises. This proposed development clearly conflicts with both these policies.
16. The environmental Impact Analysis submitted by Clifton Cape only mentions the immediate site and not the surrounding areas. In addition, the wind analysis makes no reference to the Venturi effect that will be created by having two high-rise building in close proximity to each other i.e. the Chiswick West Tower and the existing BSI building. The exiting wind effect caused by the BSI building is already considerable and will be further adversely affected by the construction of the Chiswick West building.
17. There are insufficient details provided of the proposed development of Gunnersbury Station on which to arrive at any clear conclusions.
18. The proposed development offers nothing of benefit for the local community. There is already a lack of community facilities and areas for young people to play in the area. The provision of 226 residential units, without contributing to the communities` facilities is a further weakness in the proposed application.

As a general observation, the developer invited the West Chiswick and Gunnersbury Society to provide it with its proposals for the development of these sites. These were provided on 4 February, a copy of which was sent to the Council's Development Control Officer. The Architect subsequently responded to say that it would take the views of the Society into account. It is obvious from the nature of these revised plans that virtually all of what the Society proposed has been ignored.

Yours sincerely,

T.M. Thorn

Revised Plans for Chiswick West Submitted

West Chiswick and Gunnersbury Society's Letter Objecting to Wing House Development

Chiswick on the March

West Chiswick and Gunnersbury Society

Comments on the new plans

New Application to Demolish John Bull

Residents Group Writes to Architects

Minutes of Meeting of Local residents

Opposition Grows to Chiswick West

Full Text of Letter of Objection from Peter Eversden

Sample Letter of Objection from local resident

Spokesman for Developer Urges Residents to View Plans Before Deciding

Comment on this issue on the Chiswick Discussion Forum

Transport Plans for Chiswick Business Park

Your local Council Representatives

Contact details for your MP