Full Text of Letter Objecting to Development by Peter Eversden of the Chiswick Protection Group

31st October 2001

Mr Ian Draper,
Environmental Services,
LB Hounslow, Civic Centre,
Lampton Road,
Hounslow TW3 4DN

Dear Mr Draper,

'Chiswick West' planning application 00248/BX/P1

This federation of resident, amenity and civic societies in Chiswick objects strongly to the proposed tall building in this development. Our members and many residents in the vicinity of the site are appalled that a colossal structure could be contemplated. The location is a sensitive one, with conservation areas to its north and south. It is surrounded by residential houses and any tall building would adversely affect the setting of those homes, of the Royal and public parks, of the locally listed buildings and of the protected views from and across the Blue Ribbon Network of the Thames and its local waterways. The proposed tower block is not in accordance with LB Hounslow's UDP policies.

The regeneration of the area would be most welcome but it cannot accommodate a building 70% taller than the BSI office block, which itself would probably not be allowed if proposed now. The development would remove a parade of shops and a popular public house yet offers inadequate replacements. Even where a few retail units are proposed they are marked as 'Retail/A3'. The kind of retail that the people in over 300 new living units will require is A1 shops, not A3 café/restaurant places, of which Chiswick has almost fifty now.

The site is alongside a station, which is a location given positive guidance by the GLA for additional homes. However, that station cannot accommodate more trains per hour due to track bottlenecks on both the North London Line and the District Line. These restrictions are acknowledged in the planning application. There are no projects or proposals in the London Mayor's published Transport Strategy to address these problems in the next twelve years. Gunnersbury station will have to cope with an extra 7,000 passengers in peak hours due to other developments in the area which have planning permission. The additional impact of 'Chiswick West' has to be considered against that transport situation.

The developer proposes

offices in two buildings - a block of 65 affordable/social housing units - 142 residential units within a tower block - a hotel within the tower - a health club in the tower - a 'community' facility building - a limited amount of retail - a medical centre with key worker housing

The percentage of accommodation for affordable purposes, as defined by the GLA, is not achieved.

Parking for visitors and the disabled seems to be inadequate. There is a key dependency on the agreement of other organisations to the availability of 'Site 3' for essential station improvements.

Specific objections to the proposed development are as follows.

UDP ENV1.1 requires that a development is compatible with, and seeks to enhance, the character of the area in terms of size, scale, materials and design. Also to avoid any sunlight being prevented from reaching adjacent properties. The 30 storey block plus its plant and lift machinery levels on top fails to conform to these policies. It would introduce the same problems that led to the withdrawal of the 'Pinnacle' proposal nearby which attracted objections from neighbouring Councils, English Heritage, CPRE (London) and the Royal Parks Agency.

The Schatunowski Brooks report states that "The new office development will affect the daylighting to the adjacent and opposite premises in Silver Crescent whilst the new residential block on the south side of the tower will affect the whole of the eastern elevations of Reubans Court." The analysis of shadows by that consultant for 10am in March/September shows that the BSI block affects the first six properties in Silver Crescent. The proposed tower, 70% taller, affects many additional properties including more in Thorney Hedge Road as well. In December the proposed tower would shadow all of the houses in both roads through the late morning period. The applicant's own evidence shows the effect would be unacceptable.

The Council's policies (in IMP.4.2) require that any proposal for a new building should take into account LPAC's Guidance on high buildings and the effect on adjoining residential areas, parks and gardens, strategic and Thames views and Metropolitan Open Land. The height and position of the proposed building would result in it spoiling local views and it would be oppressive to nearby residents.

UDP IMP4.4 covers the scale, design and mass of a proposed scheme and its effect upon the local area. The 'Chiswick West' tower block does not meet the policy objectives.

UDP ENV1.2 requires the protection of Conservation Areas. The proposed tower block would be visible as a blot on the landscape and skyline from all eight conservation areas in this part of the borough and others nearby in the borough of Ealing. The areas of Strand on the Green and Gunnersbury Park Estate would be affected particularly. The latter has just been granted Article 4(2) status by LB Hounslow which requires that its setting and appearance should not be changed. The Council has recently approved the designation of Grove Park, to the south east of the site, as a conservation area and locally listed many buildings there. However, the applicant states that there are no listed buildings in the area. There are also conservation areas at Acton Green and Bedford Park.

The response from English Heritage to this proposal is very relevant. They state that they consider the existing BSI building to be "an anomalous presence in the predominantly low-rise part of the Borough, and its highly damaging impact on the surrounding area and in distant views of this part of the Borough." With regard to the proposed tower they report that "other, lower forms of development merited fuller exploration." This organisation agrees with those opinions.

UDP ENV B.1.3 and ENV1.6 reinforce that local views are intended to be protected by the Council's development plan. The tall building would not conform to those policies because it is on a small site, is not related to the surrounding area, would adversely affect the amenities of surrounding sites and would mar the skyline from many open spaces. It would be visible in views for which the three local authorities in the area have UDP entries to protect on a mutual basis.

The required plot ratios for new buildings, as specified in the UDP, would not be met.

UDP ENV4.11, ENV N.1.16, ENV N1 seek to protect the views from historic parks and gardens. The proposal for the tower block does not respect those policies.

The Clifton Cape report that accompanies the planning application states that "in terms of the strategic locality, it is accepted that there would be some adverse effects." These effects have not been minimised by the architect before this application was made.

The office block on Site 2 fails to conform to several of the policies above. Although it has a curved roof profile that leads to a lower side of the building where it is alongside the Chiswick Park offices, it fails to relate to those and to other offices along the north side of Chiswick High Road. That is contrary to UDP ENV B.1.1 which would require it to relate to its siting. The block is probably two storeys too high for its location. If it was lower, the adverse impact described above on nearby homes would be reduced.

The Housing Strategy of LB Hounslow, as presented at the Chiswick Area Committee last month, and the UDP H.4.1 policy for affordable housing are not met by this proposal. The GLA sustainable development guidelines specify that at least half of the development should be of that type. In addition the percentages of each type of that housing should be as outlined in the document 'Towards the London Plan' in terms of its rent/part purchase and subsidised percentages. Those are 35% social rented and 15% intermediate and key worker. The height of the tower block should be reduced and these percentages then achieved in the final total configuration. There should be affordable housing in whatever the tower block is revised to be, to meet the GLA mixed development principles.

UDP T1 requires that sustainable development should reduce the need to travel and UDP T4 relates to the reduction in the use of the private car. This development would introduce over 230 parking spaces and it is important that the facilities that its inhabitants need are within easy walking distance. That would require a supermarket on the ground floor of the proposed tower block and related retail and service facilities on the floor above. Part of the ground floor of all other proposed buildings, including the office block on Site 2, should have retail facilities to meet all standard requirements. A whole parade of shops from 534 to 546 Chiswick High Road was replaced recently by new housing and a parade of shops is lost in this proposal. The amount of retail in the development should be increased. This will meet the Council's Shopping policies in its UDP and the retail aspects of PPG6.

Conditions should be applied in the case of any eventual planning approval to ensure that the A1 units are available in an on-going basis at affordable rents, related to other out of town centre locations. Change of use from A1 to A3 should be discouraged in whatever way that the Council can achieve.

PPG13 requires that local authorities should revise parking standards to allow for significant lower levels of off-street parking. The developer is proposing a number of car parking spaces that appears to be within the Council's standards but LB Hounslow should consider if recent GLA planning principles should not reduce that further for the residential duplex apartments. This would allow for some key worker and social housing parking, instead of the surprising figure of zero, as proposed in the application.

Facilities for parking by disabled persons will need attention.

The car provision for patients visiting the doctor and dentist consultation rooms is below the Council's standards. This should be reconsidered. There must be adequate provision also for vehicles used by medical staff for their off-site visits and trips.

UDP T2 requires that car traffic and the demand for road space should be reduced. This would necessitate that residents in the 'Chiswick West' development are not allowed to purchase parking permits for the West Chiswick Controlled Parking Zone (CPZ). This has been done in the case of a development in Putney and details of that have been provided to John Evans of LB Hounslow.

This development of over 300 homes (plus the hotel, which is badly needed) would lead to a high level of demand by residents' visitors for Pay & Display facilities in nearby residential streets. The parking predictions indicate that the spaces underneath the office block on Site 2 are full by 11am. This does not allow much flexibility for business visitors. This visitor and business commuter parking demand must not be provisioned by a reduction in the amount of kerb space in the nearby CPZ streets for existing residents. Any such effects would make this development unsustainable.

The demand for road space is of concern with regard to vehicle movements into and out of the sites and the potential conflict with traffic entering and leaving the Chiswick Business Park. The flow of traffic heading east on Chiswick High Road could be restricted by the right turn into Site 1. The queue of eastbound vehicles waiting to enter the Chiswick Business Park in the mornings could further delay other traffic if the slip road allowed for them is of insufficient length. The main entrance to the office building is at the same point, attracting inevitable short wait delivery and collection vehicles. The policies of UDP T5 apply.

The local road network is wrongly reported in the application by Buchanan in their transport assessment. The road into Chiswick Park does not provide access for all traffic to Bollo Lane. That was prevented by a condition in the approval for the development by Stanhope plc.

The applicant's report by Buchanan stresses the importance of gaining approval for building over the tracks of the District and North London lines to provide the necessary rebuilding of the station and its new entrance, ticket hall and accessibility facilities.

If sufficient area over the tracks is allowed for development it may also be possible to increase the footprint of the affordable housing and increase the number of such units.

The wind effect analysis in the application papers warns that there will be strong down winds caused by the height and shape of the proposed tower. The consultants recommend a horizontal canopy running around the sides of the tower at an appropriate level to deflect the winds. Even then it is implied that there will be turbulence in the open space between the buildings. There is a further recommendation that the microclimate around the base of the tower needs to be tested with a scale model in a suitable wind tunnel facility. No doubt these considerations have to be applied to the tall buildings in the industrial areas of the Golden Mile. However it is of concern that such risks are inherent in this design of a tower block above the platforms of an open station and near to private housing and gardens. The necessary modifications with canopies and ledges on the profile of the main building could result in an unacceptable design.

There is no assessment yet of the effect of the proposed tower block on television, radio and cellphone reception. Responses by CABE, Royal Parks Agency, The Civic Trust, West London River Group, CPRE (London) and by those responsible for the recently issued Thames Strategy, Kew to Chelsea, are not included in the application. All these should be made available for public scrutiny before the application is considered by any Council committee.

LB Hounslow should specify in its report on this application the facilities required for the 'Community Facility' and the impact of this proposed development on local school places, resources and facilities. There should also be an assessment of the availability of play space, leisure and sports facilities in the area to meet the needs of up to seven hundred adults and children in this new 'Chiswick West' site.

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

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