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CHISWICK WEST - NEW DEVELOPMENT BY GUNNERSBURY
STATION
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
Your
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