Dominion Housing Group meeting on October 9
Dominion Housing Group, Metropolis Planning and Design
LLP has recently submitted a planning application to Ealing Council
for the redevelopment of part of the Oaks car park and relocation of
the art screens.
To see the proposed scheme, which would change the face of Churchfield Road completely, and to discuss it with
Dominion and their Architects there will be an open evening from 6 to
8pm on Monday 9 October, at St Mary's Church Hall.
This scheme has already been the subject of much discussion on the Actonw3.com Forum. Local Council Vlod Barchuk raised objections to the 5-story buildings for 11 reasons:
Over-development, loss of light to neighbouring properties, impact on existing retail businesses, inappropriate design, failure to take account of Acton Town Centre conservation area, failure to address parking problems that will be created by the development, impact on local schools, refuse and recycling collection, loss of green space,
loss of public art, inadequate public consultation.
His objections are listed in detail below:
" 1. Over-development. The proposed development will have the equivalent of 751 habitable rooms per hectare (hr/h). The Council’s Unitary Development Plan states that in high density sites up to 300 hr/h is permissible, with up to a maximum of 700 hr/h on certain sites (as defined in the London Plan). This development exceeds all guidelines on density and should be rejected on this ground alone.
2. Loss of light and privacy. Policy 4B.9 of the London Plan states: "all large scale buildings...should be of the highest quality design and in particular: be sensitive to their impact on microclimates in terms of...sun, reflection and overshadowing" and "pay particular attention, in residential environments, to privacy, amenity and overshadowing".
In respect of light levels, I refer to the planning report for Daniels Department Store, 96-122 Uxbridge Road, West Ealing W13: “Any reduction below this level [Vertical Skylight Component of 27%] should be kept to a minimum but where this value cannot be achieved a reduction of up to 20% of the former VSC value would not be noticeable and would not therefore be considered material. If the VSC with the new development in place, is both less than 27% and less than 0.8 times its former value, then occupants of the existing building will notice the reduction in the amount of skylight.” The daylight report in support of this application states that both of these VSC threshold tests will be failed in all affected properties in Hooper’s Mews and Churchfield Rd; residents will therefore notice a significant and unacceptable reduction in light levels to their properties.
The daylight and skylight report submitted with this application claims that Average Daylight Factor (ADF) ‘provides a more comprehensive understanding of diffused daylight within neighbouring properties.’ No evidence is provided to support this judgment. In fact the Building Research Establishment guidance on measuring daylight impact of developments does not list ADF as a method for measuring daylight loss in existing buildings (CIBSE guidance suggests ADF as a suitable measure for light levels in new developments). One serious drawback with ADF is that it does not quantify the reduction in daylight levels arising from new developments.
The ADF figures provided in the report are somewhat tendentious as its authors admit they could not access properties to make proper measurements and thus calculate ADF values accurately. The figures provided ignore the kitchen on Hooper’s Mews (referred to in the report), for which ADF would have to be at least 2%; the highest estimate quoted for ADF in Hooper’s Mews is 1.79%. It should be noted that an ADF of less than 2% indicates that natural day-lighting would not be effective in illuminating the environment and artificial lighting would be operational for the majority of the day; this is a very low standard for any property to meet.
The development will create properties that will look directly into bedroom windows on Hooper’s Mews and Churchfield Rd. Such intrusion of privacy would not be tolerated in a residential area.
3. Impact on existing retail space. It is proposed to add retail space of 1,077 m2 as part of the development. However, the area already suffers a lack of demand for retail; on Wednesday 19th September, I observed four, possibly five unused shop sites on Acton High St and six on Churchfield Rd. The creation of this retail space will either see displacement of existing retail from neighbouring streets or result in significant empty spaces within the development. Neither situation will be to the benefit of the area.
4. Inappropriate design. The proposal is tremendously intrusive onto the Churchfield Rd streetscape. At 5 storey level it is over 17 metres high and at 4 storey level it is about 14 metres. By contract, the property on the south side of Churchfield Rd and to the west of the proposed development is some 10 metres high and Derwentwater Mansions (on the north side of Churchfield Rd) are about 13.5 metres high at the top of the gables (measurements taken using the scaled A3 elevations submitted). By offering no break in the line along the top of the development, the design is dull, unimaginative and intrusive; it will dominate the sky line in a way other buildings in the area do not (and this leads onto the next reason for objection).
5. Failure to take account of Acton Town Centre conservation area. The proposed development site is bordered on three sides by a conservation area. The appraisal report for the conservation area states “an important part of the character of Acton town centre is the group value of its buildings and the way these buildings relate to each other. Many of the buildings have considerable architectural quality in their own right. This applies not only to those buildings listed as being of architectural or historic importance, but to a number of others which are strategically located in key positions and which make an important contribution to the area’s special character, including locally listed buildings and other buildings in Market Place, Churchfield Rd….” The proposed development takes no account of the neighbouring conservation area, dominating its surroundings in a way that no other building or group of buildings does and, architecturally, providing not even a nod to its Victorian surroundings.
6. Failure to address parking problems that will be created by the development. The proposal includes no parking spaces for residents of the development, except for 7 disabled parking spaces. No consideration is given to where residents of this development will park their cars, a particularly pertinent matter as the surrounding streets are part of a Controlled Parking Zone.
It will be argued that the developer will enter into a section 106 agreement that will prevent residents from being able to apply for a CPZ permit, hence no increase in car numbers in surrounding streets. This is a totally inadequate measure. Firstly, it ignores the fact that residents of the development may park cars outside the CPZ and move them inside at the weekends and evenings, when the CPZ does not apply. It also ignores the pressure on street car parking that will be created outside CPZ hours by visitors to the development. It also does not take account of the special features of Hooper’s Mews. This street, whilst adjoining the development site, does not appear to be part of the Acton Central CPZ; there are no signs in the road indicating parking restrictions and when I spoke to a resident I was told that no one had CPZ permits in the street (I suspect Hooper’s Mews may be an unadopted road, hence this situation). There is space is Hooper’s Mews for about 6 cars to park on road not marked by double yellow lines. Pressure on these spaces will be enormous if a development is put up next door with upto 72 households looking for car parking spaces.
It is claimed in the submission that the development will reduce pressure on parking due to the removal of the existing car park. This ignores the fact that the car park is being sold by the Council because it is surplus to requirements; when I visited the car park on Wednesday 19th there were 15 cars in the Churchfield Rd car park (including mine) and about 30 empty spaces in the neighbouring Oaks shopping centre car park. The development will increase vehicle movements in Churchfield Rd, due to cars owned by residents in the new development, visitors to development occupants and any retail traffic (should the latter emerge – see point 3 above).
7. Impact on schools. Local primary schools are already close to or at capacity. The nearest primary schools are Derwentwater Primary School (3 form entry – capacity therefore 630 - plus 50 place nursery) and St Vincents RC Primary School (2 form entry – capacity 420 pupils, no nursery). As a governor I know that Derwentwater is effectively at full capacity. An OFSTED report of May 2006 noted the school roll at St Vincent’s was 414, 6 short of the normal capacity of a 2 form entry primary school. A development of this size will bring more children into the area and it is particularly important that younger children should not have to travel significant distances to school. An assessment of the capacity of local school to deal with increased demand is therefore required – it is not immediately apparent that there is any capacity available.
8. Refuse and recycling collection. It is not clear from the proposal where refuse will be stored and how they will be disposed of. I receive regular complaints about refuse sacks being left on Churchfield Rd, allegedly by residents of properties above shops. It will need to be demonstrated very clearly what provisions will be made both for effective refuse disposal and provision to encourage recycling. It should be noted that the Council will be conducting a consultation this autumn on possible changes to collection of refuse and recycling materials; the design of the development must be able to meet the requirements of hard bins (should they be introduced) and recycling of food waste, cardboard and plastics.
9. Loss of green space. The development would involve removal of an area of grass, some 22 x 11 ft sq. bordering Churchfield Rd and adjacent to the boundary of St Mary’s cemetery. Whilst arguably of no great significance or merit in itself, this area provides some relief from the expanse of tarmac of the adjoining car parks. It should be noted that there is very little public green space in the area north of Acton High St, east of Horn Lane and west of Acton Central station, therefore any loss should be a matter of concern. The development will also result in the removal of all trees and shrubs adjoining and surrounding the existing car park. That a development can label itself ‘The Oaks’ yet not provide a single blade of grass will raise many a hollow laugh.
10. Loss of public art. The Acton Town Centre Strategy set as one of its environmental objectives, the development of a public art project at the rear of Oaks shopping centre. This is in place but will be removed by the proposed development and nothing in the plans indicates any intention to replace it.
11. Inadequate public consultation. This proposal will have a significant impact on the whole Acton area north of the High St. Yet there has been no public exposure of the proposal in the area. I’m sure planning officers will point to statute and regulation, yet it is difficult to believe that a proposal of similar magnitude in other parts of the borough, say central Ealing, would attract so little publicity or be allowed to proceed without fuller public consultation.
In considering this application it will be necessary to properly define the nature of the site. The UDP does not categorise this site, though it is acknowledged as a development site. It has potential retail and business uses, but the area surrounding it is predominantly residential. It therefore shares some, though not all, of the characteristics of a backland site that may be used for infill development; this is particularly pertinent as the development will predominantly face residential properties (Churchfield Rd and Hooper’s Mews). The UDP sets strict standards for infill developments including density, privacy for existing residents and sensitivity to its surroundings, all of which this proposal fails by a large margin.
In summary, there are numerous good reasons – critical, major and minor – for rejecting this application."
If you would like a chance to discuss this with the developers, or to raise any issues or voice your opposition to the plans - the meeting on Monday will be a good opportunity.
October 5, 2006