LDF Consultation October 2009
Response of Save Ealing Centre
1 The Documents
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
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.
has taken some of the most persistent members of
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.
is important, then to note that
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.
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.
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
3 The Consultation timetable and response questionnaire
have been innumerable changes to the LDF timetable which are not reflected in
the Local Development Strategy. This has created much confusion for everyone.
the complexity of the documents we have sought to describe above,
is for these reasons that
4. The Evidence Base
Government has made it clear that a robust and credible shared evidence base is
a central feature of the LDF system.
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.
Chapter 2 refers to the proposals in the Tibbalds
Report as helping to guide development in the Town Centre over the Plan period.
5. The Proposed Strategy
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
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.
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
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
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.
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.
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
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
6. The Spatial Approach
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
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.
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
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
7. Tall Buildings
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.
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
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?
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
sense that only way that Ealing has retained its metropolitan centre
designation is because Ealing Town Centre and
9. Conservation and the Built Environment
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
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
Save Ealing’s Centre