DICKENS YARD

Sustainability Appraisal

The analysis that follows is formed from comparing the recommendations set out in the Councils’ 2004 Site Brief for Dickens Yard with what is actually described in the current Planning Application. The Site Brief may be viewed in full.

The 2004 site brief envisaged that development of this Council owned site should be a flagship for sustainability. New dwellings would be built to `best practice' EcoHomes standard as well as meeting Lifetime Homes standards and other development would be at leading edge of sustainable technologies.  At least 10% of the development's predicted energy consumption would be generated on-site via renewable sources.  Best practice would reduce water consumption and provide a sustainable urban drainage system and waste recycling would be maximised.

The sustainability assessment that accompanies this planning application demonstrates that these objectives which SEC strongly supports have not featured at all strongly in the design of this development.  The assessment seems to have been prepared at the end of the design process so that the issues it addresses read as an afterthought to the design. There is no independent BREEAM assessment and no reference to the Government’s Code for Sustainable Homes.  Perhaps as a consequence of these omissions the assessment’s findings appear devoid of rigour and to carry all the conviction of a tick box exercise.

With the growing consensus of the need to respond to the challenges of Climate change the current proposals are very disappointing in their failure to pursue the 2004 objectives.  The supplement to PPS1 sets out the Government’s key objectives for delivering sustainable development. It is disappointing then that the planning authority has not, as the PPS1 supplement recommends, made use of the Design and Access Statement to obtain from applicants information to show how their proposed development will contribute to these Objectives. 

In our view, some of the most critical areas in which the proposals fail the sustainability test:

1.         Sustainable Building

This development is a major opportunity to secure the highest viable resource and energy efficiency but it is not being taken. We highlight some of the most serious issues below:

·       Attention to energy conservation appears to have been minimal.  Most of the flats are single aspect. Although this has the advantage of a presenting a relatively small external surface area, it means that north facing flats will never be warmed by the rays of the sun and south facing ones will be baked in summer. Best practice says flats should be multi-aspect to get a better balance of sunlight and be able to create a through draught by opening opposite windows.

·       Almost all the non habitable rooms – the bathrooms and kitchens - in the 698 residential units lack windows. This means that their lights will always have to be used in these.

·       Contrary to the site brief, there is no provision for rain water collection or any system to use grey water in toilets, etc

·       Contrary to the site brief, there is no provision for renewable energy generation.  Solar power is effectively dismissed because the roof space is taken up with private roof terraces.  A less intensive design with fewer roof terraces would permit some roof space to be carry photovoltaic or solar thermal panels. An opportunity for using ground source heat pumps is identified but dismissed on the grounds of higher capital costs.

·       The energy audit suggests that some of the heat and power will be provided by a bio-mass boiler but there is minimal detail and there is no explanation as to the source of the bio-mass. We are pleased to see there will be a gas fired CHP system which is an efficient arrangement.

2.         Waste facilities and recycling

The Dickens Yard site currently provides important and well used community recycling facilities that are not shown as being retained once construction commences. Some of the recycling facilities now provided, e.g. those for drinks cartons, are unique in the area and the local community will lose access to them.

The proposals show that residential waste will be managed in just 3 categories. These are already insufficient to cope will existing recycling arrangements while in future waste will need to be sorted more carefully for recycling.

3.         Parking

If implemented the proposals will continue to cause an over dependence on motor vehicles so that the opportunity to manage travel demand in more sustainable ways will  be missed.  The proposed 583 parking spaces are far more than envisaged in the site brief, or by the UDP. The provision of such a large number of spaces contravenes the parking standards in the London Plan for town centre sites with Ealing’s level of public transport accessibility. It also contravenes PPG13: Transport which seeks to reduce the need for travel by car, and to promote access to services by public transport, walking and cycling.

The proposed number of parking spaces is excessive both for the residential component of the scheme (300) and the number of public spaces for shoppers.  It will generate a large number of new car trips into Ealing Town Centre which is already heavily congested, particularly at peak times.  No town centre plan provides for this increase and no explanation or justification is provided for it.

4.         Access

Access into the site both by foot and by car is also not designed to maximise opportunities for sustainable development.

The existing pedestrian access from the north west past Springbridge Road Car Park is of very poor quality and no proposals are made to improve it.  Pedestrians or cyclists will be discouraged from using this short-cut on their way to Ealing Broadway station and the rest of the Town Centre.

Shoppers travelling from the north will be able to access the new car park only after rat-running through residential streets north of the railway line.  Not only is this arrangement contrary to UDP Policy, but it will also further reduce the air quality in these residential areas which London monitoring show is already below acceptable standards.

5.         Green Travel Plan and car club

UDP policy requires a Green Travel Plan for residential Developments with more than 25 units. Section 11 of the Transport Assessment sets out the applicant’s framework for preparing such a plan but it is almost devoid of specifics about the future content of that plan while the management arrangements for its preparation provide no opportunities for any public inputs. For these reasons we do not think that the proposals submitted are acceptable. 

We are particularly concerned that the focus of the GTP will be on residential uses for the new development.  Given the current use of the site as a staff car park for LBE employees, the plan needs also to consider journey to work alternatives for Council staff, and what effect these will have on the public transport network which already operates at or near capacity during peak hours.

While there are a number of references to plans for one, it is also disappointing to find no provision within the Transport Assessment for a car club.  Such a facility is in danger of being overlooked once implementation commences. Furthermore, as it has not featured in the original scheme design we have strong concerns that it would prove incapable of operating in a way that best meets either the needs of the residents or the wider objectives of sustainability.

Conclusion

The 2004 site brief correctly required that the redevelopment of this highly strategic site in the Council’s own back yard should be a flagship for best practice in sustainability.  The site brief carried an important message in signalling the Borough’s determination to lead in responding to the challenges of climate change.  And with the Council setting an example it could be envisaged that developers of other major sites in Ealing would follow them. 

It has therefore been extremely disappointing to see that this application disregards so many of these principles.  Our concern does not rest with this application alone. If the development of this major Council-owned site proceeds in its present form, it will set a precedent for unsustainable development throughout Ealing. Other developers will be encouraged to think that they can take a similar approach. We believe that the Planning Authority must use the Dickens Yard development to show all prospective developers in the Borough that sustainability principles must form a the a centrepiece of their plans.