Conservative Councillor Mark Reen writes:
Dear Mr. Mayor,
For years, the Oaks development has been an eyesore and a dislocation at the heart of the central Acton community. As Winston Churchill famously said: “First we shape our buildings, and then they shape us.” The scheme passed to you requires a fundamental re-assessment in my view, if not outright rejection.
However, we should first of all acknowledge the difficulty of the site as it currently is – with a significant level drop north to south, a large area of hard standing to the northern boundary with Churchfield Road and a site area that directly abuts a Conservation Area on all sides, including the site of an ancient burial ground that serves as a local park. The existing Oaks development, too, is poor and would not be missed.
The challenges of the site escalate when the range of stakeholders who have an interest in any development are considered – the developer empowered to get the maximum utility, the conservation interests, the council looking for a regeneration of the whole area (and having produced a development plan to that effect) and, lastly, local residents who have definite community views on any proposal and for whom the current open nature of the site will result in a significant change for them whatever the nature of the development being brought forward would be.
In my view, the central tenet of the processes behind the London Plan –; which is that communities engaged with the development process and supportive of it are more likely to produce good development - and, as importantly, are more likely to allow development to deliver a great community – has been lost.
Listed in no particular order are the following major concerns over the development agreed at Planning Committee:
The nature of the development and its appropriateness for its location; the impact on the Conservation Area; the density of the scheme itself; the relationship of the scheme to the Council's own stated development strategy; and, finally, the level and form of the affordable housing provision.
So, in order: The development is in a form that turns its back on the street scene – a development more akin for a high high-rise estate such as South Acton or a location in central London. London Plan guidance Policy 3.5 is clear; the development must “respect the existing character and urban grain of a place and build on its positive elements”. The scheme proposed, which is high -rise, which through its internal nature and through its relationship to Churchfield Road effectively turns its back on the centre of Acton – the garden space, the balconies and the built form all face inward and away from the street, a total disregard of the Victorian street pattern that prevails in the rest of Central central Acton.
The officers in Ealing worked hard to objectify the impact on the Conservation Area – but in my view (and it has to be a subjective process) the harm to the views and street scene of the Conservation Area have to be significant: if you live in Berrymead Gardens, the view will now be completely filled with the high high-rise portion on the eastern edge of the development. If you take the view across the burial ground, the view will now - even with the set set-back nature of the scheme at its highest – be a 9 -storey block of flats. In my view, this has to be contrary to the ambition of Policies 7.1, 7.4, 7.8 and 7.9 of the London Plan.
The London Plan Housing SPG is explicit in its ideas surrounding the density of development. For mixed-use schemes such as this, the worked example and the guidance text itself shows how to calculate the density of the proposal. In plot ratio terms, the scheme is dense; but measuring by hr/ha and units/ha, using the guidance methodology, shows the scheme to be delivering (according to my calculations and based on the Design and Access Statement supplied) a density of 976 hr/ha and 334 u/ha with a plot ratio of 4.85. Based on an urban site with the PTAL of 4-6 (Acton Town Centre), this shows The Oaks to be over 30% higher in density than the maximum provided for in the guidance. This is a CAZ scheme in an urban Outer London setting.
In this context, the London Plan is quite clear: “Unless additional significant reasons justify exceeding the top of the appropriate range can be demonstrated rigorously they [developments] should normally be refused.”. How much over the top of the guidance does a scheme have to be to be refused in this context – particularly when the weakness of the scheme in other respects is taken into account?
Finally, the abandonment of the 50% affordable housing target to a provision of 22% requires either a good reason or a financial offset – neither which, in my view, were provided for in the officer's report and therefore contrary to the London Mayor's ambition for affordable housing.
There are additional controversial elements for this scheme: Why has the Council put aside its own development strategy and eschewed a comprehensive scheme? Why has the council not used its site assembly powers under CPO to create a proper link between Churchfield Road and the High Street? Where is the capital receipt for the council's own land-holding (in the form of the Churchfield Road car park)? And, finally, why has Waitrose been advertised when, as we all know, the nature of the occupant of the retail scheme is irrelevant in planning terms?
So in summary – the development is wrong in context, harmful in its impact on the Conservation Area, delivers a small level of affordable housing, ignores the council's own development plan document and does so at a density that would be harmful to the residents of central Acton.
It is monolithic, un- neighbourly and ignores the heritage assets and built form of its environment.
I have no doubt that those Labour councillors who voted for The Oaks knew full well that this scheme was a shell of what could be possible for Acton. As I said at Planning Committee – the council can do better, the developer can do better and Acton deserves better.
I hope that you can see fit to review this scheme before Acton is harmed for a generation.
Cllr Mark Reen
Shadow Portfolio Holder for Finance
Member of Ealing Planning Committee
London Borough of Ealing
25th October 2013