London Borough of Ealing

LDF Consultation October 2009

Response of Save Ealing Centre

1 The Documents

1.1 This is a hugely important exercise that will shape the future of our Borough. Once it has been adopted the LDF will set out land use policies that take us up to 2026. Recent events eg the Arcadia public inquiry have shown how significant these policies are when considering developments of a Borough-shaping scale. It is important therefore that the strategy and supporting documents are given the consideration that they merit and it is for this reason that SEC has prepared the following comments which we hope will be considered.

1.2 SEC has sought to keep abreast of the LDF process for example by attending Scrutiny Panel meetings. Despite its attempts to become engaged with the process SEC has grown confused about the way the policies in the current set of papers on which we are being consulted have emerged. They bear very little resemblance to the policies that officers tabled and members discussed in depth at the Scrutiny meetings which we have attended.

1.3 As far as SEC can see, the current documents that we are now being consulted on were drawn up by officers who are not accountable to the public. None of these documents to our knowledge has been considered or approved by any of our elected representatives – either those who sit on the Scrutiny Panel or the Cabinet.

1.4 The sheer quantity of documents on which the public is being consulted is also a concern. With little explanation as to the significance of each document and how it is supposed to fit into the overall exercise it is extremely difficult to understand what the key points are.

1.5 It has taken some of the most persistent members of SEC a lot of time and many discussions with the Planning Policy team to clarify the situation. Our discussions have helped us understand the proposals better, but they have left us concerned that we are being asked to comment now on matters that really ought to be considered once the key strategy questions are have been determined. This applies in particular to the questions about development management policies and to infrastructure planning.

1.6 If the implications of this problem are not recognised, key issues that the public has an interest in and a right to comment on will be taken without consideration of the things that should be considered. This is likely to produce a strategy that cannot be implemented or one that would cause serious harm to the Ealing environment and its community.

1.7 It is important, then to note that SEC’s comments in this response primarily involve the 2026 Development Proposals Initial Proposals Paper. The approach and purpose of this document is particularly challenging. It does not fit easily with the guidance Government has given to LDF preparation and there is not a lot of explanation in the introductory comments. Our understanding is that the document is an attempt to update the UDP and to give it the same structure as the London Plan, but we are unclear about the implications, status and purpose of the maps in the Appendix or how they are to be taken forward.

1.8 Given the little time available to us we have therefore not been able to get to grips with the Development Management Document to the extent that we can make detailed comments on it. Our general comment is that we believe that the Policies in the UDP are now generally understood, and do not merit large scale relaxation for instance through the dismissive comments about the ‘protect the past’ option.

1.9 SEC is also disappointed that there are apparently no plans to prepare the Area Action Plans that are designed to ensure areas which it seems are destined to undergo significant change are planned properly. Such documents are provided for in PPS12 (‘Area action plans should be used when there is a need to provide the planning framework for areas where significant change or conservation is needed’) and SEC believes that the Strategy should consider them or explain why not. We have said on many previous occasions that in our view such plans are required both for Ealing Town Centre, and for West Ealing and Green Man Lane.

2 The Consultation – process

2.1 Information about the consultation has been disappointingly been scant. Government guidance about the need for frontloaded community engagement and the Council’s own Statement of Community Involvement are not reflected at all in the present exercise. Many people have not received any notice that it is taking place at all, and the leaflets that have been delivered to some addresses are uninformative about what the consultation is about and what will be its huge significance for the future of the Borough. We contrast this with the publicity given in the past with previous planning exercises, such as in the case of Ealing Town Centre public consultation exercise back in 2002. And when the first Borough Plan was prepared in 1982 a 16 page booklet was distributed to everyone in the Borough summarising in clear layman’s language the main features of the plan.

2.2 The documents and what they mean are very complicated and just about impossible for the public to understand. For example, the title of the key Strategy document is misleading – why not just call it ‘LDF Core Strategy: Initial Proposals’? The overall effect of the way the documents have been produced will be to deny the public its only chance to make any meaningful input into an exercise that will determine the future of their Borough. This is likely to be an issue that SEC will continue to press.

2.3 SEC has also been disappointed at the way that our responses in past consultations have so often been ignored despite the many hours of effort that that have gone into drafting them. We point for example to our responses to the previous rounds of consultation on the LDF, and to our own Vision for Ealing which we launched in the Town Hall at a full public meeting – none of which appear to be reflected in Background Paper 5 which purports to provide a ‘community consultations and evidence base Audit trail’. We hope that things will be different this time, but are rather sceptical that they will. The trouble is that eventually people will give up bothering as they will feel they are just wasting their time, and this will create a rather dangerous gulf between the Council as governors and we the governed.

3 The Consultation timetable and response questionnaire

3.1 There have been innumerable changes to the LDF timetable which are not reflected in the Local Development Strategy. This has created much confusion for everyone. SEC proposes that the Planning Policy website needs to have an up to date route map listing the documents, where they have reached in the process and where they have still to go. The absence of such information is a serious barrier to local engagement with the process.

3.2 Given the complexity of the documents we have sought to describe above, SEC thinks the 6 week consultation period is just not adequate. The 6 week period is certainly outside the spirit, if not the letter of the Council’s SCI. Ealing has generously allowed longer periods for major large scale planning applications and while these are sometimes difficult their impacts are never as far-reaching or extreme as those that would result from the proposals now being consulted on.

3.3 SEC also has strong reservations about the response questionnaires to this consultation. Because they look so similar it was only quite late on in the exercise that we found there were in fact two such forms – one for the strategy and one for the Development Management document. We fear that many people will not have noticed this either and so will not answer as fully as they are expected to. The two forms are long and complicated and in many cases they relate poorly to the policies about which we are being consulted on. For instance, although the Strategy remarks on the prominence that is being given to tall buildings there is no obvious place on the questionnaires that they can comment on the proposals. The boxes too on the questionnaire are also not user friendly. Some questions relate to multi-part strategies where respondents may want to tick the Support and Oppose boxes for different parts of the strategy – how are they supposed to do that?

3.4 It is for these reasons that SEC has decided not to use the questionnaire to respond to the consultation and to submit these notes instead as the easiest way to express our views on the issues that we think are the most important. We trust than in replying this way we shall not be deemed to be submitting positive responses to all the questions on the questionnaire.

4. The Evidence Base

4.1 The Government has made it clear that a robust and credible shared evidence base is a central feature of the LDF system. PPS12 describes how an evidence base is required to justify the effects that core strategies can have on social and impacts, helping access to housing, jobs, accessible local services and open space. It also says that the evidence base must provide evidence of the views of the local community and that the choices made byuthe plan are backed up by the facts. Unfortunately, as far as SEC can ascertain no such evidence base has been compiled in Ealing. Instead there is a great deal of confusion about what evidence if any the proposals in the strategy have been based on. We cite two serious areas in this section as examples of how this matters.

4.2 First, we believe it apparent that the strategy has been prepared on the basis of an analysis of the sites identified by officers in the Council who have undertaken a desk top study to propose how many homes can be physically crammed onto each site, without any regard for national, regional or local planning policy. These exercises have not been made available for public comment, and they have not been presented as part of the strategy papers. In short, they seem not to comply with SHLAA guidance and they cannot be construed as constituting the robust evidence the Government requires.

4.3 Second, Chapter 2 refers to the proposals in the Tibbalds Report as helping to guide development in the Town Centre over the Plan period. SEC has long raised its concerns about the status of the Tibbalds study and the way it has been used. The terms of reference for the study have never been made public, but it is understood that the consultants were told not to consider the key Arcadia and Dickens Yard sites. It would therefore be wrong to use the study to suggest that any advice Tibbalds has to offer pertains to those sites. The public consultation sessions that Tibbalds engaged in have never been published or commented on by the Council. In addition, LBE’s website and its submissions to the Arcadia Inquiry distance the Council from Tibblads’ findings in a way that raises concerns that there would be selectivity in the application of the report to suit individual agendas. In short the report does not meet the robust criteria Government guidance requires.

5. The Proposed Strategy

5.1 The Executive Summary fails quite seriously to highlight the key points in the Strategy. It is a motherhood and apple pie statement that conveys none of the reality of what is proposed in the rest of the document and. In our view it should be completely revised to explain clearly how (in SEC’s view) the Borough is planning to build around 1000 new homes every year and that almost all of them will be in the densest part of the borough. This will involve replacing much of the existing building stock with high rise developments.

5.2 Beyond the Executive Summary, the proposed Vision for 2026 is not an attractive one. It conjures up the prospect that much of what is known and cherished in Ealing, Acton and Southhall town centres will be demolished in the all-consuming drive to provide new homes and that municipal housing areas will be redeveloped at far higher densities than they are now.

5.3 While the Vision Statement in Chapter 1 carries some assertions that it would be otherwise, the vision effectively begins and ends with the construction of new homes that will swell the borough’s population. It all reads rather like a piece of 1960s Soviet style propaganda . The vision is worryingly vague in its consideration of how those new residents will live, work and play, or where their children will go to school or where their health centres would be located. It is quite silent about how those people – or indeed the ones who live here now - are to move between these places as people are usually inclined to do.

5.4 A major element that is lacking from the vision relates to transport provision in the future. On previous rounds of consultation, and during the planning of the now abandoned West London Tram, many members of the community raised concerns about the inadequacy of orbital, north- south links around Ealing and beyond. Residents who live in the north of the Borough and work in the south have a serious journey to work problem. Journey times can be so long as to be a deterrence for some jobseekers for whom a commute into Central London is a better prospect . For many it is easier to get to a major attraction at Wembley, just a short distance outside the Borough by going via Central London. If anything, the situation seems to be getting worse with reduced frequencies on orbital bus routes like the E2 and failure to take opportunities to improve the service on the Greenford Overground Line. But none of this is reflected anywhere in the 2026 Strategy. Given the assurances that were made when the West London Tram was abandoned t is very surprising that the Vision’s only transport related consideration involves the provision of more car parking spaces. Unfortunately there is no consideration of the implications of this strategy for congestion on the road network, atmospheric quality or environmental sustainability.

5.5 Also missing is any appraisal of other land use requirements in the Borough that would assist in the appraisal of alternative the single strategy offered to us of concentrating new housing along the Uxbridge Road. In particular there is no published analysis of the amount of employment floorspace that Ealing needs to retain, nor what kind of floorspace that should be – whether for offices, industry or warehousing – or where it can be best located. Lacking such analysis, SEC can do no more than register its concern that too many sites in the Borough away from the Uxbridge Road corridor have been overlooked as potential housing sites.

5.6 SEC is particularly concerned that the strategy appears to be overwhelmingly driven by the need for new housing. Of course additional new homes are required in Ealing, but the Strategy does not attempt to justify why there must be so many. While both PPS3 and the London Plan are insistent on the need for new homes in the country as a whole and in London in particular, both are careful to insist that this should be provided in a proper planned way with concern for the support of the community, and for the context and for the location of the new housing. Little evidence is discernible that there has been such consideration given to the location of new housing in Ealing at the densities that the draft strategy appears to contemplate.

5.7 The background papers for the Strategy purport to provide the justification for the need for so many new homes. These papers are not at all easy to follow, but examination of them suggests they have been quite hurriedly put together with little of the rigour that the Government envisages in its guidance for example in doing Strategic Housing Land Availability or Housing Market Assessments. Amongst other things, strategic market assessments need to look at the sub-regional situation, the breakdown between natural growth and in-migration, and the reasons why incomers have decided to locate in Ealing. Strategic Housing Land Assessments must consider policy restrictions such as designations or existing planning policies but there is no evidence available that encourages us to think this has been done in Ealing.

5.8 Instead, examination of the Background Papers 1 and 3 on population and housing suggests there may be some serious inconsistencies and omissions in the analysis and these in turn raise questions about the reliability of the assumptions that underpin this key part of the Strategy. We cite a few of the examples below:

· Inconsistencies in the figures: Background Paper 1: Population and Household Projections says (page 19) that in 2026 the anticipated number of households will be 140,500 and the population will be 342,100. In contrast Background Paper 3: Housing says (page 6) that the in 2025 there will be 143,900 households and a population of 350,400.

· Apparent Errors in the figures: Background Paper 1 (page 19) says that the 2026 total of 140,500 households represents a growth of 6.6% and the population of 342,100 represents a growth of 13.4%. The tables on page 14 don’t support these figures. It looks as if the percentage growth figures have been transposed between households and population.

· Inadequacies in the analysis: Background Paper 1 appears primarily concerned to raise the ONS population estimates in order to increase council revenues. Households and population projections for 2026 only appear in Section 6 apparently as simple straight line projections of past trends. These projections demand some sensitivity testing, particularly at a time when the economy has stalled and the numbers of migrants from Eastern Europe has slowed rapidly. Besides, although it describes some of the issues of mapping between households and residential units, Background Paper 1 does not forecast the number of residential units required. What assumptions are used to move from the population forecasts to the LDF measures of new housing and physical residential units?

5.9 What is needed but has not been made available, are forecasts that link the growth of population, household formation and new residential units. Some of the issues that arise from the inadequacy of the analysis include:

· A population growth forecast of around 1.6 extra people in the borough per new home built, compared with Background Paper 3 (page 7) saying the current housing stock under provides for larger housing units (3 and 4 bedrooms).

· An apparent increase in households and population in recent years that probably (no historical figures are given) outstrips the building of new homes. This may be because many homes in Ealing are under occupied. What scope exists for reducing this?

· The opportunities for having multiple households per home without being a licensed HMO. The focus in Background Paper 1 (page 8) is clearly on HMOs that need licensing. However, even the old (pre-April 2009) regulations allowed an owner occupier to take in 3 separate lodgers (giving 4 households) without a licence. The current regulations set higher limits. Also, the use of electoral services data will only be a partial help in assessing the situation. People in shared homes won’t show up if they are not citizens of the EU or the Commonwealth.

· The lack of consideration of initiatives that could encourage people to move to accommodation more suitable for their needs, e.g. older people into flats or sheltered housing.

5.10 In short, while page 6 of Background Paper 1 criticises the way that ONS population figures assume past trends will continue, the rest of the paper simply assumes past trends will continue. What is needed is a consideration of alternative scenarios, involving the performance of the London economy and like different levels of movement of people into and out of Ealing.

5.11 SEC suspects that it is a result of this unsatisfactory level of analysis that has led to such startlingly high figures of new housing need in the Borough. This certainly appears to be the case when Ealing is compared with other Boroughs in this part of London:

5.12 It is also important to know why it is that so many more new homes are required in Ealing than in a neighbouring Borough with quite similar geographical and demographic characteristics such as Hounslow. Both Boroughs occupy intermediate locations between inner and outer London and while both are of almost identical size, Ealing’s population is half as large again as Hounslow’s. It is very difficult to understand what reason there could be for Ealing’s target number of new homes to be more than twice that of Hounslow according to the London Plan. Can this difference be explained by the fact that Hounslow’s planners are planning with more care for the quality of the outcomes than Ealing’s?

6. The Spatial Approach

6.1 If the total number of new homes that are to be provided is not well explained, nor is the strategy for locating them. As the most intensively developed part of the borough there is very little space along the Uxbridge Road corridor on which to locate both the new homes that are being planned and the social infrastructure Ealing needs to support them. The existing scale of residential development along the corridor is high density low rise and this suits the needs of Ealing’s residential population. It is very concerning that no consideration has been paid to the implications of changing this scale by trying to cram large numbers of high rise buildings onto every site which falls vacant on it.

6.2 The density of the corridor means there is little prospect for providing new family housing that the strategy says is a priority in the Borough – instead it is likely that there will be more one and two bed units which have already been provided in good quantities.

6.3 If as many new homes are needed in Ealing as is claimed, it may just be that such locating them along the A4020 is the only one feasible. But SEC will argue very strongly that before such drastic change is wreaked in an area in which hundreds of thousands of people live very happily other options need to be properly identified and tested for their feasibility. Guidance on the preparation of LDF is very clear about the need to identify and consult on options before a single strategy is selected. This process has simply not happened in Ealing. SEC has in the past proposed alternative potential strategic locations to consider for major new residential development but these have not been reflected in any of the papers in this consultation.

6.4 Other vital spatial questions are not addressed at all by the strategy. A particular spatial concern in Ealing is the inadequacy of north-south orbital public transport networks. In SEC’s view residential investments in places away from the Uxbridge Road Corridor would help attract investment in new public transport services where they are sorely lacking at present. In contrast, concentrating all the development along the A4020 will reinforce the existing transport network and peripheral areas will find themselves increasingly dependent on the private car.

7. Tall Buildings

7.1 SEC is particularly concerned about the proposals relating to Tall Buildings which we consider to be ill-thought through. They seemed to appear from out of the blue and were not discussed at any meetings of the LDF Scrutiny Panel.

7.2 The Government and the Mayor of London recognise that Tall buildings are sensitive matters that need to be planned carefully. CABE and English Heritage have published some useful guidance on planning for them. It is disappointing that none of this guidance – nor even its existence – is reflected in the consultation document. Much more work on this policy is required if it is to feature in the 2026 strategy.

7.3 We do note that the Strategy recognises that more work is required in this area and we think this will be an important priority. What exactly is being countenanced by the strategy’s support for high buildings? – are we talking about buildings 6 storeys high or 60? Given the debate that has arisen recently in regard to the Arcadia development this has become an important priority.

7.4 Concern about the vagueness of the wording about acceptable locations for tall buildings. It appears in the strategy document that they would be acceptable just about anywhere. What exactly are the sensitive locations that the strategy would steer tall buildings away from? To what extent would these include the impact on Conservation Areas and Listed buildings?

8. Town Centres

8.1 Disappointingly, there is no consideration in any of the documents of the future of the Borough’s town centres, even though each one of them has struggled for one reason or another over many years to compete in a dynamically changing world. The LDF is an opportunity to reappraise what purpose these centres now serve to the local community and to the local economy and how they can change to meet the realities of the new millennium?

8.2 SEC is especially disappointed to see no reference in any of the consultation documents to its own ‘Vision for Ealing’ which we published at the beginning of this year and launched at a full meeting in the Victoria Hall. The meeting was attended by Councillors of all parties who welcomed our contribution to the debate about the development in the Borough. Where then do the kind of values that SEC promoted fit with the Vision that Ealing is now consulting on? How will the LDF accommodate them?

8.3 We believe that the Development Strategy is the right place to consider what Ealing’s regional and sub-regional role will be in the future, and whether it accords with its present designation as a metropolitan centre. As we have argued on many occasions this designation dates back to a very different era in the 1960s when Ealing played a considerably more significant role in west London life. Recent retail developments and Ealing’s tightly constrained location away from the major strategic road network mean that it is no longer appropriate to consider Ealing in the same retail league as say Croydon, Kingston or Harrow. By many measures Ealing occupies a lower position on the retail hierarchy than centres like Richmond, Wimbledon and Hammersmith which the London Plan designates as Major Town Centres.

8.4 We sense that only way that Ealing has retained its metropolitan centre designation is because Ealing Town Centre and West Ealing are grouped together as a single centre. There is little reason why this should be the case and continuing to do so harms them both. It means that neither will be able to achieve the long term potential that they both have in serving as the focal points for their local communities. Ealing Town Centre of course has other roles that it should be playing, particularly as a centre for arts, culture and leisure activities serving the Borough and beyond.

9. Conservation and the Built Environment

9.1 SEC is concerned that the consultation documents are very thin on the status and the role of the Borough’s Conservation Areas and its built environment heritage generally. These are attributes of the Borough that are of great importance to its residents; it is what has led many of us over the years to choose to establish ourselves here. The Planning Authority also has a statutory duty to protect and enhance Conservation Areas and listed buildings. The thrust of the consultation strategy and the absence of any clear policies affirming the importance of Ealing’s Heritage creates serious concerns that Plan’s intention is to erode Ealing’s heritage.

9.2 We note that item (e) of Proposal 1.1 – Spatial Vision for Ealing 2026 says that there will be ‘care for the borough’s historic character and ensure excellence in design.’ But this seems to us vague and aspirational. It is hard to discern any reflection of this part of the vision in any of the provisions in the rest of the document. Our concerns have been heightened through discovering how unimportant it was to the Council in the evidence it presented to the recent Arcadia public inquiry. Government legislation places a duty on Local Planning Authorities to protect and enhance the historic environment and we are keen to know what policies Ealing proposes in this regard.

9.3 One of the reasons why this matters so much is because the low priority which seems to be given to heritage issues when large developments are under consideration is not reflected in the tight controls placed on individual homeowners who want to make minor changes to their own properties. What is required is a consistent approach to design for all developments.

10. Sustainability and the Green Environment

10.1 Finally, SEC would like to suggest that the strategy should give some more thought to what Ealing can do through its land use policies to address the threats of climate change. Some areas that might be discussed include:

• the role of more sustainable transport including improvements to the public transport network,
• opportunities for reducing the need to travel through more sensitive land use
• planning the relationships between land use policies and public transport – for example by considering the merits of locating major trip generators such as employment and leisure uses in high accessibility areas as against housing and
• the sustainability implications of redevelopment of buildings as opposed to refurbishment.

Will French

Save Ealing’s Centre

16 October 2009