Statement of Representations on the 2026 Development Strategy with Officer's Recommendations

DEVELOPMENT STRATEGY 2026:

INITIAL PROPOSALS,

PUBLISHED: SEPTEMBER 2009

STATEMENT OF

REPRESENTATIONS

SECOND EDITION: th PUBLISHED APRIL 16 2010

2 1. INTRODUCTION

a) Overview

1.1 The 2026 Development Strategy sets out the spatial vision and proposals for the future development of the borough. Ealing Council recently undertook a six- week period of formal consultation on some initial proposals. This took place between September 4th and 16th October 2009. This consultation provided businesses, community/voluntary groups, residents and statutory organisations with another opportunity to make representations on the content of the Development Strategy.

1.2 These initial proposals were informed by comments received during the earlier two rounds of consultation (Issues and Options for Spatial Planning, Feb- Mar 2006) and New Issues and Options for Planning Your Borough, Sept-Oct 2007.

1.3 This report has been prepared in response to Regulation 25 of the Town and Country (Local Development)(England)(Amendment) Regulations 2008. This sets out a requirement for public participation in the preparation of a development plan document. More specifically, clause (5) states that: “In preparing the DPD, the local planning authority must take into account any representations made to them…”

1.4 This report provides a concise and informative analysis of the representations received and a summary of the key issues. Appendix 1 lists each of the respondents by category and Appendix 2 contains a more detailed synopsis of the individual representations. 619 representations were received from 60 respondents and the council is very grateful to everybody who took the time and made the effort in sending in comments. b) Format and Structure of the Report

1.5 This report is divided into three parts:

• Statistical Analysis – which provides a breakdown of the representations, setting out the overall number of respondents and the number of comments received from various sectors and individuals. • Summary of Issues – which provides a summary of the key issues raised by the respondents. • Next Steps – which explains the next stages in the process of preparing proposals for formal notification and then submission to government.

1.6 It also contains a lengthy appendix that sets out a detailed synopsis of the individual representations together with responses by officers.

3 2. STATISTICAL ANALYSIS

2. STATISTICAL ANALYSIS

2.1 619 representations were received from 60 respondents. Representations were submitted by businesses, community/voluntary groups, residents and statutory organisations. a) Respondents

2.2 The following table and pie-chart states the numbers of respondents broken down by type:

Respondent Type Amount Residents 20 Community/Voluntary Groups 15 Statutory Bodies 10 Business Organisations 15 Total 60

Percentage of Respondents by Type

25% 17% Residents

Community/Voluntary Groups Statutory Bodies

Business Organisations 25% 33%

4 b) Representations

2.3 The following table and pie-chart states the numbers of representations broken down by type of respondent:

No. of Respondent Type Representations Residents 220

Community/Voluntary Groups 231 Statutory Bodies 94

Business 74 Total 619

Percentage of Representations by Respondent Type

Residents

12% Community/Voluntary 36% Groups 15% Statutory Bodies

Business Organisations

37%

2.4 The table on the following page provides a breakdown of representations relating to the key spatial policies, respondent type, and number of responses:

5 Community/ Reference Initial Proposal Title Residents Voluntary Business Statutory Total groups Bodies 1.1 Spatial Vision for Ealing 2026 36 13 8 8 52 1.1 (a) Homes and & Jobs 2 5 2 3 12 1.1 (b) Development Corridors 11 2 5 1 19 1.1 (c) North South Links 2 1 0 0 3 1.1 (d) Suburban Communities 1 1 0 0 2 1.1 (e) Historic Character 1 2 0 0 3 1.1 (f) Green Spaces and Corridors 2 1 0 0 3 1.1 (g) Infrastructure 0 0 0 4 4 1.2 Delivery of the Vision for Ealing 2026 253717 1.2 (a) Housing 3 3 1 1 8 1.2 (b) Waste Management 1 1 0 0 2 1.2 (c) Tall Buildings 9 10 4 1 24 1.2 (d) Flood Risk Management 1 1 1 0 3 1.2 (e) Infrastructure Delivery 1 2 0 1 4 1.2 (f) Car Parking 2 2 1 3 8 Realising the Potential of the 2.1 Uxbridge Road/Crossrail corridor 766322 2.1 (a) Housing Projections 2 3 0 0 5 2.1 (b) Business Floor-space 1 1 0 0 2 2.1 (c) Improve Transport Services 1 1 0 0 2 2.1 (d) Sensitive Development Management 10001 2.1 (e) Southall TC Boundary 1 1 0 0 2 2.1 (f) Consolidate TC Boundaries 1 0 0 0 1

3.1 Realising the Potential of the A40 Corridor and Park Royal 435012 4.4 North - South Links 5 5 2 2 14 5.1 Protect and Enhance the Metropolitan Green Belt 6 4 0 1 11 Protecting and Enhancing 5.2 Ealing's Green and Open Spaces 4 4 2 2 12 5.3 Green Corridors 4 4 1 0 9 5.4 Natural Environment 4 5 2 0 11 5.5 Parks and Outdoor Recreation 8 5 1 1 15 5.6 Burial Land 6 5 0 1 12 6 Physical, Social & Green Infrastructure 15 19 3 24 61 Total 144 115 47 63 369

6 2.5 The following graph provides a further breakdown of the sources of the various representations relating to Initial Proposal 1.1 – Spatial Vision for Ealing 2026:

IP 1.1 - Spatial Vision

20 18 Statutory Bodies 16 14 12 Number of Business 10 Representations 8 6 Community/ 4 Voluntary 2 groups 0 Residents 1.1 1.1 1.1 1.1 1.1 1.1 1.1 (a) (b) (c) (d) (e) (f) (g) Policy

2.6 The following graph provides a further breakdown of the sources of the various representations relating to Initial Proposal 1.2 – Delivery of the Vision:

IP 1.2 - Delivery of the Vision

25 Statutory Bodies 20

15 Business Number of Representations 10 Community/ 5 Voluntary groups Residents 0 1.2 (a) 1.2 (b) 1.2 (c) 1.2 (d) 1.2 (e) 1.2 (f) Policy

7 2.7 The following table and bar graph breaks down representations by those referring to the specific places within identified Chapters 2, 3 and 4 of the 2026 Development Strategy. These relate to different parts of either of the two development corridors (including town centres) or specific regeneration sites in the residential hinterlands.

Community/ Location Residents Voluntary Business Statutory Total groups Bodies Acton Town Centre 9 4 0 2 15 South Acton 6 5 0 0 11 Acton Main Line station 4 2 0 3 9 Ealing Town Centre 10 14 1 1 26 Green Man Lane Estate 5 7 0 0 12 Hanwell Town Centre 10 4 1 1 16 Southall Town Centre 7 7 3 3 20 Havelock Area 4 3 1 1 9 Greenford Town Centre 4 3 0 0 7 Greenford Station 4 3 2 0 9 Greenford Green 3 2 2 0 7 Greenford Depot 3 3 1 0 7 Total 69 57 11 11 148

Specific Area Based Representations

30 25 Statutory Bodies 20 15 10 Business 5 0 Community/ Voluntary e n e e e e n o on tr tr ot ti tate ntr ea ntr ee p groups entr en ation r Act ta Cen k Ar t C h s Ce c Ce d De Residents n C n n o n d S rd G r wn ut ine w ne Es w l r o o e fo nfo So L Tow av Tow in l ll To enfo een ee n T a an La a H rd e r to ing T wel fo G Gr M n n Gr Ac Eal uth e ton M e reen Ha So Ac G Gr

8 3. SUMMARY OF KEY ISSUES

3. SUMMARY OF KEY ISSUES

3.1 The 619 representations commented on a wide variety of issues. For ease of use, this summary of key issues has been provided to provide a broad overview.

3.2 However, officers will take into consideration every comment in a review of the 2026 Development Strategy before preparing a revised version of the plan for the formal notification and submission stage.

a) General Process Issues

3.3 A number of representations stated concerns regarding the perceived lack of consultation and engagement with residents and community/voluntary organisations undertaken in preparing the 2026 Development Strategy.

3.4 There were also a number of comments that suggested a bias towards the treatment of comments from the private sector/development industry.

3.5 Specific comments were raised regarding the following aspects of the consultation process:

• Public/community/voluntary organisation involvement – a number of representations indicate concern at the relatively low level of resident and local groups/organisations that had either made formal representations or attended any of the public consultation events.

• Length and Timing of the Consultation – a number of representations regarded the six-week formal consultation to be insufficient but nobody suggested that the timing of the consultation during the Autumn was inappropriate.

• Publicity – a number of representations indicated that the different types of media used to publicise the formal consultation period to be inadequate and that insufficient notice of public meetings had been provided.

• Website – a number of representations found the council’s web-pages devoted to the public consultation difficult to navigate and once found expressed concerns at the accessibility of information and the difficulties of using the on-line software application to submit formal comments by electronic means.

• Feedback – a number of representations were highly critical of the length of time that had elapsed between this and the previous round of formal

9 public and stakeholder consultation and the failure to provide either a formal written report or response to comments that were made.

• Accessibility – a number of representations viewed the format and structure of the Development Strategy to be difficult to fully comprehend citing difficulties in cross-referencing information particularly in relation to the adopted UDP and Consolidated London Plan. Some respondents also viewed the response form to be difficult to understand and complete and at least one complained about the failure to provide copies of the consultation documents in community languages. b) Specific Policy Issues

3.6 Specific comments were raised regarding the following policy issues:

Location of Development

Representations from the majority of residents and residents groups objected to the proposals to focus future development along the Uxbridge Road and A40 Corridors. However the majority of statutory bodies and business groups supported these same proposals. Concerns were expressed that these two corridors are already congested and that existing infrastructure is already overstretched.

Other representations supported the proposals to focus future development in town centres where existing and enhanced transport links and other necessary infrastructure can be easily accessed.

It was also suggested that new development should not be restricted to specific town centres, but should be encouraged in sustainable locations with good access to public transport.

Housing and Employment Targets

There was a mixed response to the level of new homes and employment space proposed. Many representations felt that the proposed level of additional homes to be provided by 2026 was excessive, particularly when compared to surrounding boroughs of a similar size.

It was also felt that there was an over reliance on the Gasworks site in Southall in terms of meeting the overall housing targets and that an even distribution of housing units throughout the borough is required.

10 Town Centres

A significant amount of support was provided for the regeneration of the town centres in the borough. A high level of attention to urban design and conservation was seen as important for ensuring that future regeneration proposals are successful. A number of representations were concerned about the impact of the Arcadia and Dicken’s Yard proposals on Ealing town centre. Similarly, concerns were expressed in relation to the impact of the Gasworks site in Southall town centre.

Concern was expressed at the level of congestion in many of the town centres and that existing infrastructure and services are at capacity. The need to upgrade and enhance existing infrastructure facilities before any new development proposals commence was also seen as critical.

Tall Buildings

The majority of residents and residents groups opposed the concept of tall buildings. Representations also sought clarification as to what constitutes the height of a tall building, along with more detailed guidance as to appropriate locations and acceptable circumstances where a tall building would be appropriate. Concerns were raised that existing infrastructure is already at capacity and would not sustain new pressures that tall buildings would bring. It was suggested that tall buildings needed to respect the scale and character of the historic environment and conservation areas.

Support was also provided for the concept of tall buildings, provided that more information is made available with regard to acceptable heights and provided that they are well designed and situated in sustainable locations with good access to public transport.

Transport and Linkages

Support was expressed for improvements to north-south public transport services linking the Uxbridge Road and the A40 Corridor. Concern was expressed at the inadequacy of the exiting orbital and north-south links within and surrounding Ealing. The reduction in frequency of certain bus routes was also highlighted as a challenge, particularly for commuters.

Improvements to transport infrastructure and services across the borough was seen as critical in order to sustain and support the development targets outlined in the strategy.

11 Infrastructure

Concern was expressed that existing infrastructure was already at capacity and could not sustain the levels of development proposed.

It was suggested that where new developments are reliant on necessary infrastructure, this infrastructure should be phased in line with construction. It was also suggested that funding sources, including, developer contributions should be secured to ensure the delivery of this infrastructure.

The preparation of a clear evidence based infrastructure delivery plan was seen as critical, particularly for the first five years of the plan period. It was also stated that that this plan needed to outline the infrastructure priorities which that would be necessary for delivering the main elements of the strategy.

Open Space and Green Areas

The proposals to protect and enhance green areas, corridors and open spaces were widely supported, with some representations viewing their protection as vital.

A number of comments referred to the inadequate private open space provisions of new developments, which results in increased pressures on public open spaces.

Some representations suggested that existing green areas be utilized for local food production.

Climate Change and Sustainability

It was suggested that further detail and reference was required in relation to current relevant sustainability issues, particularly climate change mitigation and adaption, future energy demand, and the challenges posed by peak oil. Some representations proposed setting a local target for reducing carbon emissions.

Comments also suggested that existing green areas should be utilized for local food production, as this would be a sustainable means of meeting future food demand within the borough and surrounding areas.

The need for existing and new buildings to reduce energy use was also identified as an issue. It was suggested that an increased emphasis on the provision and utilization of on site renewable energy sources was required.

12 4. NEXT STEPS?

4.1 Following completion of this review a further revised iteration of the Development Strategy 2026 will be produced containing proposals that the council intends to submit to government. This will then be the subject of formal notification for public and stakeholder consultation in Autumn 2010.

4.2. Subject to the further consideration of any duly made representations the council plan to submit this development plan document to government for formal examination in January 2011 and adopt it by the end of 2011.

5. APPENDICIES

APPENDIX 1: LIST OF RESPONDENTS

RESPONDENTS

Residents:

• Denis Hawkins • Sarah Stanley • Siobhan Martin • J K Gill • Janet Smith • Collin Emmins • John Murray • Susan New • Gerald T Moran • George Peach • Gary Chamberlain • Carrie Sharman • Peter L Flatau • Eric Leach • M Collins • Christine Eborall • Katharine Brooks • Michael Simmons • Martin Gorst • J Hughes

Community/Voluntary Organisations

• Ealing In Transition • Havelock Residents Steering Group • Ealing Civic Society • Central Ealing Residents Association - Jullian Edmonds • Central Ealing Residents Association - F S Price • Wildberry Nature Reserve Community Association • Save Ealing's Centre

14 • Hillingdon Motorist Forum • Walpole Residents Association • Kingsdown Residents Association • West Ealing Neighbours • Ealing Friends of the Earth • Hanwell Village Green Association • Ealing Fields Residents' Association • The Charity of William Hobbayne

Businesses

• Royal Mail • Hovedean Properties • BlackRock UK Property Fund • National Grid Properties • Segro Plc • Thomas Wrenn Homes Ltd • GSK • Ealing Shopping Centre Limited Partnership • Britel Fund Trustees • Dooba Investments VI Ltd • Hallmark Property Group • Twyford Abbey Properties • Outdoor Advertising Association • Esa Planning - Paul Woods • Metropolis Planning and Design LLP

Statutory

• Greater London Authority (GLA) • Thames Water • EON - Central Networks • The West London Mental Health National Health Service Trust • Government Office for London • Transport For London - Philip Clarke • Transport For London (included in GLA submission) • Metropolitan Police Authority • Highways Agency • Her Majesty's Court Service

15 APPENDIX 2: REPRESENTATIONS RECEIVED AND OFFICER’S RESPONSES

Chapter 1: Vision for Ealing 2026

Initial Proposal 1.1 – Spatial Vision for Ealing 2026

Name Organisation Policy Reference Government Office for London Statutory 1.1 Nature of Comment: Support with conditions

The emerging strategy identifies what will be built and broadly where, in some cases providing a good level of (written) spatial detail on where development is encouraged. However, as you develop your evidence base, the Core Strategy will need to include more detail on when development will come forward, and who will deliver this. The spatial portrait and vision set out in the document is broadly appropriate in scale and detail, particularly if supported by a site allocations DPD. However, it would be helpful if the maps outlining broad locations of change were clearer and more detailed, for example the Southern Gateway area.

Infrastructure and Delivery: At this stage of plan preparation we accept that much evidence is yet to be finalised and this detail will be included in the Infrastructure Delivery Plan (including identifying infrastructure needs, costs, funding sources, phasing of delivery and responsibilities for delivery). However, as Chapter 6 (Ensuring Sustainable Delivery) develops, later versions of this document will need to build upon the existing narrative. This will include outlining infrastructure priorities (as opposed to aspirations) for delivering the critical elements of the Strategy, and setting out the key headlines of costs and funding sources for any critical infrastructure (whether funded or aspirational). Response: Support welcomed.

The spatial portrait and vision will be supported by a Development Sites Document, which will set out specific policies for the development of key sites, areas and locations in the borough. It will outline in greater detail the suitability of individual sites for facilitating different uses and densities, based on their individual merits. This includes any proposals for land and buildings on significant sites that are likely to be subject to development proposals during the plan period i.e. 2011-2026. These allocations are intended to assist in delivering the priorities and objectives of the Development Strategy 2026. Detailed maps for each site will be provided in tandem with this document.

Along with this, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: Accept conditionally.

Further detail to be provided in the Development Sites Document and the Infrastructure Delivery Plan.

16 Name Organisation Policy Reference Her Majesty's Court Service Statutory 1.1 Nature of Comment: Support

We support the general thrust of the Spatial Vision, which at point G on page 11 supports the provision of community facilities and services in the Borough where and when they are needed. It is noted under Initial Proposal 6.2 (p.52) that Social and Community Infrastructure includes courts.

Similarly, we support the courts inclusion as community infrastructure that reflects their importance in developing sustainable communities. For both grounds of support we request that a reference to HMCS is brought forward into formal policy.

Furthermore, in the introduction to Chapter 6 (p.50) we note that the Council will be developing an 'Infrastructure Delivery Plan', we request that HMCS is invited to take part in the formulation of both the 'Infrastructure Delivery Strategy' and 'Infrastructure Delivery Schedule' that will form the overall Plan. Response: Support welcomed.

The importance of HMCS as a key provider of community and social infrastructure is recognised. However we believe that there is sufficient reference to the role of the courts as a key part of community and social infrastructure in the document. As a statutory consultee, Her Majesty’s Court Service will be consulted as part of the Infrastructure Delivery Strategy Plan. Outcome: No Change.

Name Organisation Policy Reference Metropolitan Police Authority Statutory 1.1 Nature of Comment: Support with conditions

By 2026 Ealing will have enhanced existing and created new successful places and communities that have the necessary physical, social, community and green infrastructure and services. The MPA's supports this statement and are keen for its retention within the emerging development strategy.

Chapter 1 - Within this opening paragraph, bullet point 2 states that one of the Borough's visions is to make Ealing one of the safest places in London. This vision complements the MPA's objective of delivering a safer London. The MPA support this statement and are keen for its retention within the emerging Development Strategy.

Sub-section (g) seeks to ensure community facilities are provided where and when they are needed. The MPA consider the description of community facilities as set out at section 6.2 of the development strategy is referred to at this point. Response: Noted.

The general reference to community facilities will be expanded to refer to ‘social’ and community facilities, however it is not deemed necessary to expand on the types of social communities at this point, as these are outlined in greater detail in a dedicated section in Initial Proposal 6.2. Outcome: Accept conditionally. Amendment to text of 1.1 (g).

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation General Nature of Comment: Comment

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. Response: Noted

In addition to this strategy, recent national and regional planning policies require local authorities to take a strategic approach to planning sustainable energy measures. In particular Planning Policy Statement PPS1a for Climate Change calls for Development Plan Documents to expect that a proportion of the energy supply for all buildings to be delivered by decentralised and renewable or low carbon technologies. Ealing Council has fully committed to produce a robust evidence base that will assess the viability of energy efficiency measures and low carbon sources in both residential and non-residential sector. The evidence base will adopt the energy hierarchy as in the Mayor’s London Plan which gives priority to the improvement of the energy efficiency measures first, then to develop and promote decentralised energy network(s) and finally encourage the use of renewable energy sources.

In addition to this, the Council has also fully committed to exploring the scope for the development of decentralised energy network(s) in the borough. The Council is working closely with the Greater London Authority (GLA) and London Development Agency (LDA) in order to identify the most cost- effective options for developing low carbon heat networks within the borough. Driver for identifying district heating opportunities is the Mayor's target for 25% of London's energy supply to come from decentralised sources by 2025.

Higher Code Levels (minimum of level 4) are also being sought for major residential schemes, subject to feasibility. Similarly a rating of BREEAM ‘Excellent’ has also been sought for major non- residential developments in Ealing. In addition proposals will also be expected (relative to their scale) to make provision for, contribute to or connect to existing or proposed DE networks (heating & cooking).

Name Organisation Policy Reference Greater London Authority Statutory General Nature of Comment: Comment

All development proposals should be encouraging the development of district heating networks, not just Ealing TC, in order to be in accordance with policy 5.5 of the Draft replacement London Plan.

Response: Accepted.

Text will be amended to incorporate the necessary changes in order to conform with the Draft replacement London Plan. Outcome: Accepted. Amend text.

Name Organisation Policy Reference Ealing Fields Residents' Association Community/Voluntary Organisation 1.1 Nature of Comment: Comment

Reduction in Bus Frequencies - The frequency of bus services is a key factor in their use. We therefore ask that every effort is made to reverse the recent cut in the frequency of the orbital E2 bus service by between 25% and 33%, and also to ensure that no other service is reduced in this way.

We understand that TfL is under an obligation to consult the Council on all changes in frequency and therefore suggest that an unambiguous response is made by the Council to all future proposals to reduce the frequency of bus services.

There seems little point in the planning framework adopting an anti-car and pro-bus stance, if TfL can unilaterally withdraw bus services.

Response: Noted.

The delivery of bus services is outside of the remit of Ealing Council. Transport for London is responsible for the delivery of such elements of public infrastructure. Ealing Council is consulted when there are proposed changes to the frequencies of routes, however Transport for London are not under any obligation to comply with our views. Outcome: No Change.

Name Organisation Policy Reference Transport for London Statutory General Nature of Comment: Comment

The broad spatial approach taken within the Development Strategy is supported. However, it is also important to ensure that strategic planning policies are appropriately developed, including those relating to housing, design, sustainability and transport. The document does acknowledge that these policies need to be progressed, and further discussions are strongly encouraged as the document evolves. Throughout the document more reference needs to be made to TfL as an infrastructure owner and transport provider.

19 Response: Support welcomed.

The revised Strategy and supporting DPD’s, SPD’s and Infrastructure Delivery Plan will contained on the topics outlined above. A clearer reference to TFL as an infrastructure owner and provider will also be included in amendments to be made. Outcome: No change. Further detail to be provided in the supporting DPD’s and SPD’s and amendment to text.

Name Organisation Policy Reference Walpole Residents Association Community/Voluntary Organisation General Nature of Comment: Comment

The lack of considered options - In our opinion there have never been any options offered for informed debate and assessment with the community and other stakeholders. The whole process has started from given solutions - in particular the development of the "Uxbridge Road Corridor" and the "Metropolitan Centre" - rather than building up from base facts and needs. Ealing Centre's Designation - The strategy assumes that Ealing is a Metropolitan Town Centre. We consider this to be an outdated concept that reflects 1960's thinking that is no longer appropriate to our situation. Ealing is split into two areas (Centre and West) joined only by an office corridor. This is clearly not one entity but two and therefore Ealing is not one coherent Metropolitan Centre. Disappointingly, WRA finds this Development Strategy to be woefully incomplete and not fit for purpose. We have drawn this conclusion based on attendance at your meetings and careful study of the documents. I should add that some of us on the WRA Committee have considerable professional experience of developing strategies. Response: Not accepted

In the Issues and Options stage of the LDF consultation process, alternative options to the current strategy were identified. However at the time it was accepted that the protection and enhancement of residential hinterlands was a priority, as was the protection and enhancement of our green and open spaces. These locations also possess low public transport accessibility levels (PTALs) as identified in the London Plan and are therefore not suitable for high density development. As a result it was considered that the concentration of future development in areas with high PTALs and close to the necessary transport and other infrastructure was the most acceptable option.

In relation to the Ealing Metropolitan Centre this designation is set out in the London Plan and following a review to inform its replacement the Mayor of London has determined that the metropolitan status be maintained. This view is also reinforced by the council’s own retail needs assessment prepared in 2006 and an update due to be published shortly. We do not accept that the designation is either inappropriate or “out-dated”.

We do not accept that the document is not fit for purpose. It is acknowledged that there are amendments to be made, however the current proposals have emerged from a series of reports and studies that have formed the evidence base for our proposals. With regard to residential development quantums, the Strategic Housing Market Assessment (SHMA) provides an overview of housing need and demand and the findings are linked to regional and sub-regional targets. In addition to this, the Council has worked with the GLA to produce its London-wide Strategic Housing Land Availability Assessment (SHLAA). The figures generated through the SHLAA process in terms of deliverable and developable sites will also inform the revised housing targets outlined in the revised London Plan. It is Ealing Councils obligation to conform to these targets.

20 With regard to commercial development quantums, we are also currently in the process of undertaking an Employment Land Review study. This will analyse the role and function of existing employment sites within the context of the emerging development strategy and will identify new sites that would be suitable for additional employment uses within the borough. This document will be used in tandem with the Development Sites policy document to identify the location of proposed housing, employment and other uses and will support the overall strategy and vision.

Along with this, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential social, transport, green community and other necessary infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation 1.1 Nature of Comment: Object

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 e.g. 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.

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. 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.

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.

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.

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.

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. 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. 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. 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. Response: Noted.

The purpose of the vision is to set out in broad terms, how and where we see Ealing developing in the period up to 2026. The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development Sites Document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document.

22 London-wide Strategic Housing Land Availability Assessment (SHLAA). The figures generated through the SHLAA process in terms of deliverable and developable sites will also inform the revised housing targets outlined in the revised London Plan. It is Ealing Councils obligation to conform to these targets.

With regard to commercial development quantums, we are also currently in the process of undertaking an Employment Land Review study. This will analyse the role and function of existing employment sites within the context of the emerging development strategy and will identify new sites that would be suitable for additional employment uses within the borough. This document will be used in tandem with the Development Sites policy document to identify the location of proposed housing, employment and other uses and will support the overall strategy and vision.

The concern regarding the inadequacy of the North-South orbital links is recognised as an important issue to address and the inclusion of Initial Proposal 4.4 in the Development Strategy supports this.

Along with this, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential social, transport, green community and other necessary infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change.

Name Organisation Policy Reference National Grid Properties Holdings Business 1.1

Nature of Comment: Support Initial Proposals - We note that the first bullet point of the Executive Summary of the Development Strategy is that the housing stock within the Borough will have grown to accommodate projected growth in population through new developments in town centres, remodelling of housing space and “the redevelopment of Southall Gas Works”. In addition, 97% of the major residential development will fall within the Uxbridge Road/Crossrail and A40/Park Royal Corridors, of which the Southall Gas Works forms an important part. Clearly, these are valid aspirations for the Borough, and in principle, National Grid Properties support Southall Gas Works role in the vision, which is to harness opportunities for growth and development and to promote improvement in appropriate locations. Response: Support welcomed. Outcome: No change.

23 Name Organisation Policy Reference SEGRO Business 1.1 Nature of Comment: Support with conditions

Background - SEGRO plc, (previously Brixton plc) have been engaging with the Authority for some time in relation to their land interests at Rockware Avenue, Greenford Green. Through this process, SEGRO have responded to the Council’s invitation to identify future potential opportunities in relation to their own land and how this could contribute to the Authority’s regeneration aspirations for the wider Greenford Green area. For simplicity, we do not repeat that information here, although Officers are aware of the background material provided to-date. The following comments on the consultation development strategy therefore reflect and support the ongoing process and address SEGRO’s Greenford Green interests. We would welcome, indeed encourage the opportunity to discuss these comments and the wider Greenford Green framework over the coming months.

We note that the Development Strategy [DS] sets out the broad locations for growth and although it is not site-specific, it does not contain references to the Rockware Avenue location under the Greenford Station/Greenford Green area policies.

We consider that the broad emphasis appears to be positive in terms of the land being within an identified growth area, but clarity is requested in terms of the net contributions to growth area targets that will be made by the Greenford Green area and individual sites. In this context, whilst we appreciate that detail will evolve through subsequent site allocation and potential SPD, we feel that in order to be sound, the Development Strategy should respond to the specific comments below, which broadly address:

• Support of the broad growth areas strategy – with the recommendation that in terms of the overall distribution of development and associated delivery timeframes, opportunities outside of the Crossrail corridor [which has potential risk of delays] should be considered to provide a more robust opportunity to meet overall targets.

• Support for the focus on regenerating Greenford Green and enhancing the public transport capacity of the station and its linkages – with caveats such that this support depends very much on the detail to emerge within the area/site specific framework – with the need for development targets to be realistic and deliverable.

• The suggestion that there should be a clearer reference to mixed uses and in particular to the residential opportunity of the area, including Segro land near to the station, local services and the high environmental opportunity of the canal.

• The need for clarity in respect of how the Council envisages that it will manage the approach to different employment land designations, for example, how Segro’s land at Rockware Avenue, which is not designated as strategic, will be treated in respect of GLA guidelines on flexibility compared to other nearby strategic sites.

Summary on the Development Strategy - We consider that the document is drafted in a generally assertive manner, with the identification of broad corridors where growth will be accommodated and other areas that will be subject to enhancement and/or protection. Although generic targets for growth areas are identified, we would welcome clarity in further stages in respect of the manner in which individual sites and/or locations will contribute to these targets and the necessary infrastructure implications. This will provide necessary clarity to the assertion that the overall growth strategy is one of ‘providing the right amount of growth in the right places’.

24 Response: Support welcomed.

As indicated in the spatial vision, the primary locations for future development will be along the A40/Park Royal and Uxbridge Road/Crossrail corridors. While other areas (or hinterlands) outside of these two corridors may facilitate development at a lesser scale, it is not considered that this will be overly significant in terms of meeting the overall targets set out in the strategy. An exception is made for the business hinterland at Greenford Green.

In relation to Greenford Green, the emerging policy will be further reviewed in the light of an updated Employment Land Review and following further discussions with the GLA. The council acknowledges the significance of this site and recognises this at Initial Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Sites Allocations DPD. The guidance within this SPD is intended to be complimentary to the current LDF. For avoidance of doubt, the geographical boundaries of the site are defined as the site area is bounded by the central line to the south, Oldfield Lane North to the West and North, and Greenford Road to the east.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

Name Organisation Policy Reference Ealing Transition Steering Group Community/Voluntary Organisation 1.1 Nature of Comment: Comment

Climate Change and Peak Oil as a Planning Paradigm - Following the passing of the Climate Change Bill, the ambition to reduce greenhouse gas emissions by 80% by 2050 is now the law of the land. Despite the prominence given to a small number of climate change deniers, the science of global warming is now beyond doubt. Data provided by oil industry geologists and economists indicates that globally we are approaching or indeed have probably reached the point of Peak Oil, the point of the maximum possible extraction rate of oil. This does not mean oil will run out, rather that supplies will increasingly reduce whilst demand increases. The result will be significant price instability and inexorable increases in the costs of energy. We have seen the beginnings of this with the oil price spike last year when oil reached $140 per barrel, and earlier during the 2000 UK tanker drivers’ strike, which paralysed the country in days and left us on the brink of serious food shortages. All other forms of fossil fuel will be affected by this rise, as oil costs form a significant element in their production and use and demand for them will further increase. Our economy depends on highly industrialized, energy-dependent processes for producing our food and manufactured goods, and on the worldwide transport systems to deliver these. All these systems are hugely dependent on energy inputs, primarily oil. Oil is uniquely flexible as a fuel particularly for transport and as a feedstock for pesticides and plastics and much, much more. The significance of this growing cost of oil will be enormous. It will profoundly affect our economy, our patterns of employment, our access to transport, the cost of domestic energy for heating and not least, our food security. When oil costs increase, it will impact heavily and immediately on our community. We need to plan now in order to create local resilience to be able to cope with the coming dramatic changes. The realities are spelt out not only by Oil Industry Experts and

25 Economists (see appendix) but by the House of Commons All Party Group on Peak Oil & Climate Change (www.appgopo.org.ukT)

Consequences for the LDF - We believe that there is much of value in the document but that it fails to acknowledge the major strategic issues of our day - climate change and peak oil - as elaborated. By 2026 Peak Oil and Climate Change will impact every area of activity in the borough, from housing to food, transport and employment. Elements of the plan such as flood defence, a 100% waste/recycling policy and a ‘centralised energy facility’ seem to acknowledge these strategic realities, however without any substantial supporting detail, nor the preceding strategic justification for these initiatives. The LDF appears to assume that energy costs / supplies will remain broadly the same as they are now. The paradigms elaborated above call into question the sense of embarking on significant energy intensive projects such as building very tall buildings in central Ealing, irrespective of whether or not these are believed to be ‘right’ for the borough. Future energy scarcity rather suggests a period of consolidation of the existing building stock. We also note that the assumptions that underpin the report appear to date back to before the recession. The LDF’s narrow focus on population growth in the borough over the last ten years may well be a function of the housing boom, and may well go into reverse as migrant workers return home. In the medium term, renewed emphasis on small-scale farming will result in a migration away from the cities. It is not clear what the projected 109,000 new jobs forecast by the LDF will comprise. Finally, the LDF does not explore the implications of a national target for carbon emissions. Harrogate, by way of an example, has set itself the target of reducing emissions by 40% by 2020.

Specific Considerations - 3. Employment - The LDF can help shape a future for Ealing by helping create a much more self-reliant and localised economy. Local food production and local trade could create many new employment opportunities. The high cost of fossil energy will eventually make it cheaper to undertake many jobs manually and provide opportunity for meaningful work and craftsmanship. Repairing, maintaining, re-using and re-cycling manufactured goods will again become necessary and a source of employment. Reskilling will again be crucial in enabling these opportunities to convert to employment. Retailing is likely to undergo radical change. The LDF should ensure that future planning does not lock Ealing into an outmoded economic model and ensures that plans for retail are congruent with a more localised, lower energy, role. The LDF plans should enable the development of locally-based retail linked more explicitly to local producers to ensure viability in a low energy future.

The LDF Vision - Corporate / consultancy textbooks define the role of a vision, whether that is an organisational or a brand vision, as being to: 1. Bring focus and clarity to the desired future of the business (and what makes it distinctive) 2. Inspire people to work towards that future 3. Guide people in their decision-making as they reach for this future. With this in mind, our concern is that the LDF does not spell out a compelling ‘vision’ of the kind of life we might want to be living in 2026. There is no predictive element regarding the shape of the world in 2026, the impact of new technologies etc, despite the wide availability of such reports (see e.g. Henley Centre). All of this makes it difficult for those reading the report to imagine a future Ealing. Making the borough ‘an attractive place to live and work at the heart of west London’ merely articulates present realities. The London Plan’s rallying cry - ‘lean, clean, green’- whilst not a vision as such, is certainly a catchy articulation of intent, and one which will motivate and inspire. Based on feedback from our members, there is no doubt that the length and complexity of the LDF is deterring people from engaging with it meaningfully.

A Vision - A ‘Vision’ for Ealing might look as follows (the numbers are for illustrative purposes only but are in the logic of similar reports which address the implications of the Government’s 2050 climate targets). To set the standard as the premier urban space in the UK (the Green Queen of the Suburbs?) by 2026, by - Leading the way in Energy Descent planning, including a reduction in carbon emissions of (e.g. – as per Harrogate) 40% by 2020. - Producing (e.g.) 50% of our own fruit and vegetables. - Producing (e.g. as per the London plan) 25% of our own energy and reducing our energy consumption by 50 % by retro-fitting existing buildings. - Reducing car usage by 50 %, encouraging car clubs, making 30% of the borough’s streets car free, introducing

26 dedicated arterial cycling routes, improving public transport. - Creating 33,000 green-collar jobs (say, 30% of the 109,000 new jobs forecast by the LDF). - Creating a sense of community, and building the skills and resilience to deal with future challenges

Steps to Get Us There - A series of practical first steps might look as follows; - A local audit / census, with the dual aim of assessing the borough’s housing stock for energy conservation measures and gaining more accurate population data to enable better planning. An audit of the borough’s green space including public and private land, with the aim of assessing how much of this could be turned over to food production. Setting up an energy task force to assess the possible contribution Ealing could make to its own energy provision in line with the London Plan. Consideration of e.g. methane production from sewage, CHP, solar etc. A programme of planting fruit and nut trees such as that carried out already by Manchester. Facilitating and encouraging new ‘green collar’ jobs. Possibly Ealing council could act as a broker / facilitator for residents who want to prepare their homes for a low-energy future. Developing a sustainability taskforce comprising representatives of all parties and local community groups. Putting in place a genuine consultative framework and encouraging community involvement in all of the above.

Summary and Conclusion - The LDF is a fantastic opportunity to offer a vision, rather than a justification for present developments, based on ‘business- as-usual’ assumptions. In this respect, we believe that the role of Planning has never been more important than it is now. Ealing Transition will be initiating projects within the community to address the issues we have discussed above in forthcoming months. It goes without saying that to see the above acknowledged in the Local Development Framework would give a major boost to our efforts, and we would be very happy to work with yourselves to take these ideas forward.

Response: Noted.

27 & cooking).

The evidence base assessment will help us to determine the targets for carbon dioxide emissions reduction and therefore our policies. While all the current policies target major developments, the assessment will also examine what is achievable in smaller scale developments. Outcome: Accepted in part conditionally. Suitable amendments informed by the evidence base work will be included in the Development Strategy including clearer reference to targets.

Name Organisation Policy Reference Greater London Authority Statutory 1.1 Nature of Comment: Support with conditions

The broad spatial approach is supported. It is important that strategic planning policies are appropriately developed. The Spatial Vision and the Document as a whole, does not place sufficient emphasis on climate change mitigation and adaption.

Response: Noted.

28 Name Organisation Policy Reference Susan New Resident 1.1 Nature of Comment: Comment

A Vision for Ealing 2026 and the future London Plan - Given that the LDF is being revised at the same time as the London Plan I feel the council should have included in the documentation some of the London Plan revisions that are being considered. There are differing views within the GLA...'a third group arguing for lower densities, particularly in outer London. There was general agreement that if we hare to see higher density development, it is essential that these are well designed, respect the character of the locations in which they are planned and are supported with the infrastructure needed.' (Mayor's response to consultation on Planning for a Better London)

Initial Proposal 1.1 - Town Centres - There should be a planning policy in place in regard to vacant flats above shops before any development takes place. There should also be a policy with regard to which part of the population can be housed in town centres. There is also an emphasis on how excellent the transport links are but it is never mentioned how overcrowded and unreliable the transport system is. Parts of Ealing and Acton are conservation areas and therefore not suitable for high-density development or tall buildings. Re: Municipal Housing -The Council should employ a visionary consultant who can reinvent the housing estates so that they are integrated into the general fabric of an area so that they are no longer separate from the rest of the community and there should be no high rise buildings built for families.

Response: Noted.

The Initial Proposals for Development Strategy 2026 was prepared and made available to the public prior to the formal publication of the draft Replacement London Plan (RLP) although the council was able to anticipate many of the proposals that came forward. Ealing’s LDF development plan documents must be prepared so as to be conformity with the RLP and the preparation of final proposals for the Development Strategy will take this into account. The timetable for adoption of the RLP and Development Strategy is proceeding in tandem and any future changes will be considered and taken into account.

Many of the other issues raised are more suitably covered in the Development Management policy document and are not matters dealt with in great detail in the Development Strategy.

Specifically, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026.

In respect of the council’s estates regeneration programme, the council is promoting a major investment and regeneration programme to transform many of its homes, estates, town centres and neighbourhoods. It aims to provide residents with the best possible homes and housing services that will match the standards that they have told us they want. These ambitious plans seek to transform parts of the borough that need significant investment, care and attention as well as boost the economic, social prosperity and quality of life for our residents. Outcome: No change.

Name Organisation Policy Reference Carrie Sharman Resident 1.1 Nature of Comment: Object

Initial Proposal 1.1 - I feel that the vision does not represent a future where we have cut carbon emissions by 80% by 2050 as we are legally obliged to do. I feel the plan assumes that energy supply will remain constant whereas people within the oil industry itself have reported that global

29 oil supply has reached it's peak and we can expect it to decline by 3% per year from this point onward. Response: Noted.

It is recognised that during the lifetime of the plan and beyond, efforts to mitigate the climate change impacts and reduce the borough’s reliance on fossil fuels will pose the key challenges.The Climate Change Strategy 2008-2011 for Ealing is currently in place and aims to reduce the borough’s carbon dioxide emissions by 10% by 2010/2011 from a 2005 baseline while the current and Draft Replacement London Plans provide the policy context for the borough’s emission reduction policies. I think the priorities ought to be - planning for life with less energy (fossil fuels) - consolidating current building stock + improving insulation, reducing need for energy. - Looking at converting usable land for localised food production, roof gardens and improving knowlege of permaculture over next 10-20 years as oil declines.

Name Organisation Policy Reference JK Gill Resident 1.1 Nature of Comment: Object

Page 6 of the background paper 3 - Housing states that 90% of all housing requirements in the borough will be met through turnover of existing stock - does this mean that if existing stock is utilized then there will be a requirement for just 10% new builds? Affordable housing shortages also need to be tackled.

Monitoring is essential to ensuring high quality design.

30 It is outlined that there is potential for increasing housing density in existing estates, however many of these estates have high enough densities already. Response: Noted.

In relation to affordable housing, the Strategic Housing Market and Needs Assessment 2009 says “Determining what this means for the future requirements for types of dwelling is complex. The requirement for the expected future growth in households can only be estimated in terms of the size of new dwellings. Providing a better balanced housing stock should have been the key criteria for the authority to be able to provide sustainable developments and communities” (Page 16, Para. 1.9.1-1.9.2). The report goes on to identify a shortfall of 2,560 net units in the affordable sector per annum against an overall current London Plan housing supply target of 915 net units pa.

In relation to monitoring, the Council produces an Annual Monitoring Report each year, which outlines the extent to which the policies set out in our local development, plans are being achieved. Included in this is the extent to which design objectives have been achieved.

With regard to increasing housing densities in existing estates, the Development Sites document will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, having taken into account the potential impacts of future development on the site and surrounding area. The estates regeneration programme will also be included as part of this analysis, where tall buildings will be considered on their merits according to function, character and quality of urban design. Guidance on the criteria to be used when determining planning applications will be contained in the Development Management policy document. Outcome: Accepted conditionally. Add reference to monitoring and review.

Initial Proposal 1.1 (a)

Name Organisation Policy Reference Transport for London Statutory 1.1 (a) Nature of Comment: Support

Initial Proposal 1.1 - Spatial Vision for Ealing 2026 - Sets out the housing targets for the Borough. TfL supports the Borough’s proposed designation of six sites which are considered appropriate for residential development (sites 1, 2, 3, 4, 11 and 12 on the attached map). In accordance with PPS3 and the London Plan, TfL considers that in some circumstances mixed use may be appropriate for these sites. The sites are situated along the A40 Corridor between North Acton and East Acton. Their designation for residential development (including potentially some mixed use) aligns with the principle of TfL’s future aspirations for residential development which would be supported by transport infrastructure. Designation of these sites is in accordance with the London Plan (including consultation on the new London Plan). The sites will make a significant contribution towards maximising opportunities for housing development in the borough and are consistent with other policy objectives in the emerging LDF. TfL would welcome the opportunity to promote a further 7 sites along the A40 for residential and mixed use development. TfL would welcome the opportunity to discuss delivery of the sites with the Borough. Response: Noted.

Further details regarding individual sites are to be provided as part of the forthcoming Development Sites document. The Council will endeavour to continue to work with TfL and local residents in exploring how best to deliver a Green Corridor in this area. Outcome: No change. Further details are to be provided as part of the Development Sites Document.

31 Name Organisation Policy Reference Royal Mail Business 1.1 (a) Nature of Comment: Support with conditions

In this Chapter we note that the arrival of five proposed Crossrail stations in Ealing will be a substantial addition to Ealing’s transport infrastructure. In addition they will not only underpin physical, economic and social change in this corridor, but will also fundamentally alter the overall demand for new development and the spatial distribution of development in proximity to each Crossrail station. This Chapter also details the Councils initial proposals for the regeneration of a number of areas in the Borough, including Acton, Ealing, Southall and Hanwell. Additionally, Maps 3, 4 and 5 of this Document identify potential locations for future employment and housing sites within these towns/areas. We understand that the Council has not yet identified the exact locations for allocated employment and housing sites and that this will be provided in the emerging Site Allocations Development Plan Document. Royal Mail supports the broad spatial objectives of the initial proposals for the regeneration of these town centres/areas. However, in light of the Council’s forecasted rise in the Borough’s population from 323,600 to 354,100 between 2011 to 2026 (Background Report – Population and Household Projections page 14) we submit that the Council should take into consideration the increased demands and pressures this will place on Royal Mail’s operations in the Borough when developing the detailed policies for the town centres/areas. Response: Support welcomed.

More detail will be provided in the Infrastructure Delivery Plan. This will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: Accept conditionally. Further detail to be provided in the Development Sites Document and the Infrastructure Delivery Plan.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.1 (a) Nature of Comment: Object

A large number of sites are identified for housing without space for infrastructure for the total of 14,115 proposed dwellings, much needed leisure facilities, community facilities or expansion of school places for children of existing residents. This target for homes must be reduced to accommodate on appropriate sites, land for such essential uses avoiding gridlock on roads and inappropriate impacts on street scenes and the historical environment; yet providing for a good residential environment. Response: Not accepted. As the draft plan acknowledges the council is preparing an Infrastructure Delivery Plan. This will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change. Further detail to be provided in the Development Sites Document and the Infrastructure Delivery Plan.

Name Organisation Policy Reference Kingsdown Residents Association Community/Voluntary Organisation 1.1 (a) Nature of Comment: Object

We do not agree that 14,000 new homes should be built by 2026 in the borough, over 90% to be in a one mile wide “corridor” half a mile either side of Uxbridge Road from Acton to Southall. (KRA

32 area is in this corridor) • The targets for new homes in Ealing far exceed those in neighbouring boroughs. Why is this? • This programme proposes a “densification” of our neighbourhood that could virtually destroy its assets. • We have been told that 75% of the development sites have already been selected and are within the planning process now, yet these sites are not revealed to us. This is quite wrong. The Council is putting developers first. • We do not agree that the most built-up parts of the borough should receive this huge number of homes. • We would suggest a smaller number (e.g. 7,000) that should be spread throughout the borough.

Response: Not accepted.

The purpose of the vision is to set out in broad terms, how and where we see Ealing developing in the period up to 2026. The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development Sites policy document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document.

With regard to residential development quantums, the Strategic Housing Market Assessment (SHMA) provides an overview of housing need and demand and the findings are linked to regional and sub-regional targets. In addition to this, the Council has worked with the GLA to produce its London-wide Strategic Housing Land Availability Assessment (SHLAA). The figures generated through the SHLAA process in terms of deliverable and developable sites will also inform the revised housing targets outlined in the revised London Plan. It is Ealing Councils obligation to conform to these targets. Proposed targets are slightly lower than those set currently and taken as a whole are close to the London wide average. A lower development quantum would not be adequate to meet housing need in the borough.

Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents Community/Voluntary Association Organisation 1.1 (a) Nature of Comment: Object

Initial Proposal 1.1 Spatial Vision for Ealing - EFRA does not support the spatial vision set out in the consultation document. Our concerns include: • The very large quantum of additional housing units, which is significantly greater than that proposed by surrounding boroughs. • The construction of these additional housing units in locations, including town centres, which are already overcrowded and lack adequate social (including medical and educational) and community facilities. • The over reliance on already overloaded east – west radial: road, rail and underground transport routes. The rail and underground overcrowding is documented in figures 6.5 to 6.8 in the GLA Evidence Base supporting the October 2009 consultation draft of the London Plan. • The over reliance on Crossrail. This will run on existing tracks which are already operating to capacity in

33 peak periods. Crossrail will therefore displace existing rail services within the Borough, rather than generate significant additional capacity. • The poor level of north-south and orbital public transport within the Borough, which means that residents of the new developments may need to resort to private transport if their place of work cannot be reached by the east-west public transport routes.• The high levels of road congestion and pollution in Ealing’s town centres.• The dependence on the Public Transport Accessibility Level (PTAL) assumption in the Strategic Housing Land Availability Assessment (SHLAA) that there will be an increase in bus frequency, while locally the Council has accepted a reduction of between a 25% and 33% on key routes such as the E2. • The absence of supporting analysis setting out the employment and commuting patterns of the residents of the proposed developments. We share the concerns expressed by the Council’s of Director Housing, and approved by the Council’s Cabinet at their meeting on 4th December 2007, that Ealing town centre is not an appropriate location for family housing due to the lack of suitable amenities. While this opinion was expressed in terms of affordable housing, we believe that it is equally applicable to full market price housing. We would also suggest that these concerns should apply to all high density housing developments whether they are located in Ealing town centre or elsewhere along the Uxbridge Road/Crossrail Corridor. Response: Not accepted.

34 necessary infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Specifically, in relation to Crossrail, this will have a transformational effect and is critical to the delivery and viability of the development quantums identified for the Uxbridge Road corridor.

In relation to family housing, in 2009 the council carried out a new Strategic Housing Market Assessment to form the evidence base for the LDF and a new Housing Strategy. The key objectives of the study are to enable the Council to understand the nature and level of housing demand and need within the borough and to provide a robust and credible assessment of the local housing market with which to inform its policies and strategies. Data is fed into the Department of Communities and Local Government Needs Assessment model and showed an annual shortfall of affordable housing totalling over 2,500 units. Further analysis on a geographical basis concluded that a high level of demand for affordable housing fell in the Ealing area, particularly for 2 and 3 bed units. A copy of the Housing Strategy including evidence from the SHMA can be found on the council’s website. Outcome: No change.

Name Organisation Policy Reference The West London Mental Health Statutory 1.1 (a) Nature of Comment: Support

The Trust also generally supports the provision for additional homes (1.1 (a)) in the borough due to the need arising from the projected increase in population in Ealing over the period. The Trust has previously converted some of the older redundant hospital accommodation at St Bernard’s to residential use as part of its plans to upgrade its clinical facilities at that time. In reviewing the need to further improve its clinical facilities the hospital may identify further such opportunities to re-use land or buildings for residential use which in turn may assist the Council in meeting its housing targets in some way. Response: Support welcomed.

The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development Sites Document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document. The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It is essential therefore that there is on-going and continuing dialogue with the Trust to ensure any detailed plans are properly accounted for, where relevant and appropriate. Outcome: No change.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation 1.1 (a) Nature of Comment: Object

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

35 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? 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. 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. 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: 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?

Response: Noted.

In relation to the population growth forecast of around 1.6 extra people in the borough per new home built and figures showing demand for larger housing units, the council’s best estimates show that there will be an average of 1.6 people for every new home. The total number of people living in households across the borough are divided by the number of households to reach the average of 1.6. But household size varies considerably across the borough. For example, the ONS 2001 census shows that Southall Green and Southall Broadway wards have the highest overcrowding rates in London. Whilst the average household size is 1.6, there is high need for single occupancy homes and for homes which can accommodate large households in Ealing borough. More detailed information on this and the treatment of vacant homes is provided in Ealing Council's 2009 Strategic Housing Market Assessment.

In relation to HMOs, the council is working toward a more precise number of households and households living in various shared accommodations in the borough. Electoral services data will as suggested be helpful in achieving a better picture on this, and known datasets that could help are also partial. Matching administrative datasets such as the council tax list, and the GP register would improve the error margin on knowledge of Ealing population and household size and distribution and make future projections for development need more precise. Some households types will be less easy to capture on these administrative records: those living in shared accommodation who don't have a GP, for example, will not be included. Knowledge of the number of households would help public funding to obtain the right funding for the local population size. It will also help us to communicate with more residents, and provide the basis for projecting the demand for various household types and sizes in the future so is an important issue for many reasons.

In relation to demographic projections, the council are working toward a more accurate knowledge of the borough population. Our current model is certainly an improvement on that based on ONS population estimates. Our next step is to triangulate administrative data to get an even more robust evidence base. Ealing Council's special household projections use the ONS/GLA model for projecting type and number of household, but deviate in exchanging ONS mid year population estimates for number of local records of the households paying council tax between 2001 and 2010. Ealing Council considers that our own council tax records to be a more accurate reflection on the number of households; these show the population is higher than the ONS/ GLA population estimates based on the 2001 census.

It is possible that LB Hounslow is basing its housing need trajectory on the ONS population estimates rather than administrative records. The council does aspire to scenario based population estimates, and will commence work to achieve this once we have a more accurate current household/population estimate. Ealing borough has a relatively high density. Whilst being typical in its geographical size, Ealing has the third highest population size of the 32 boroughs. It is correct to say that the 2001 census showed Ealing borough to have some 50% more residents than LB Hounslow. Outcome: No change at this stage. However, this will be reviewed in the light of the demographic study to be commissioned by the council.

Name Organisation Policy Reference Britel Fund Trustees Business 1.1 (a) Nature of Comment: Support with conditions

We support the Spatial Vision for Ealing up to 2026 for the level of additional residential and employment proposed. It should be recognised however that there are continuing vacancies in the proposed development areas, in particular within some of the Major Employment Locations e.g. Perivale Industrial Estate. In light of this, the spatial vision should recognise that some rationalisation of existing industrial areas, where vacancy rates are prevalent, including the potential to provide a mixture of alternative uses including residential should be considered. It is also considered that the location of some of the industrial/business areas, particularly Perivale Industrial Estate, share boundaries with residential development as this would define the industrial/business park boundary and enhance the residential amenity of the area. The loss of employment and floorspace where sufficient evidence exists to support such a loss should be allowed. Flexibility to allow the provision of modern floorspace should also be considered. Also, policies should recognise the need for a range of business units within existing and proposed business/industrial areas, therefore providing maximum flexibility and marketability of units/parks, especially given the current economic climate.

37 Response: Support welcomed. The general policy presumption set in both the London Plan and Ealing’s LDF supports this approach and where exceptions are made a case will be made. An updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan. Outcome: Accept conditionally. The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA.

Name Organisation Policy Reference Greater London Authority Statutory 1.1 (a) Nature of Comment: Object

The overall housing and employment targets need to be fully justified and supported by relevant evidenced based data, and in relation to housing, seek to exceed the updated targets in table 3.1 of the draft replacement London Plan. When establishing levels of affordable housing, reference to the need to ensure deliverability in the current market should be used cautiously as the Core Strategy is a 15-year Plan. Response: Noted. With regard to residential development quantums, the Strategic Housing Market Assessment (SHMA) provides an overview of housing need and demand and the findings are linked to regional and sub-regional targets. In addition to this, the Council has worked with the GLA to produce its London-wide Strategic Housing Land Availability Assessment (SHLAA). The figures generated through the SHLAA process in terms of deliverable and developable sites will also inform the revised housing targets outlined in the revised Replacement London Plan. The council is in the process of commissioning studies to further assess the viability of its affordable housing proposals. In addition, an updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan. Outcome: Accept conditionally.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 1.1 (a) Nature of Comment: Comment

The population in Central Ealing will be increased by the developments shortly to be built however I cannot comment on the other areas of the borough.

Response: Noted. The council is commissioning a further study on demographic change both to inform service planning generally and the preparation of an Infrastructure Delivery Plan.

Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 1.1 (a) Nature of Comment: Object

Initial Proposal 1.1 - No to 14,115 new homes. No to 1.1 million sqm Employment space. No to 85% of homes Uxbridge Road/Crossrail corridor. Response: Not accepted. The purpose of the vision is to set out in broad terms, how and where we see Ealing developing in the period up to 2026. The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development

38 Sites policy document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document.

Name Organisation Policy Reference JK Gill Resident 1.1 (a) Nature of Comment: Object

I object to the 14,115 and the 1.1m square metres of employment floorspace to be created. Planning for homes, transport and health is meaningless unless detailed knowledge has been obtained as to who exactly is a resident and working in the whole of London. The footnote stating see 'table 2' on appendix 2 is inaccurate as there is no table two present.

Response: Noted.

39 be used in tandem with the Development Sites policy document to identify the location of proposed housing, employment and other uses and will support the overall strategy and vision.

The footnote is wrong and refers to a table included in an earlier iteration of the plan. Apologies. Outcome: No change.

Initial Proposal 1.1 (b)

Name Organisation Policy Reference Highways Agency Statutory 1.1 (b) Nature of Comment: Support

The HA supports the citing of major developments in town centres and near public transport hubs such as the Crossrail corridor. These locations are better served by public transport links and therefore benefit from an enhanced level of accessibility. Locating developments in these areas is likely to minimise the impact of increased trips on the SRN and assist in maintaining an enhanced level of accessibility in line with the principles of PPG13, and therefore helps the Development Strategy to meet PPS12 soundness requirement that it is consistent with national policy. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.1 (b) Nature of Comment: Object

Uxbridge Rd / Crossrail corridor as a place to concentrate new housing. Acton /Ealing/ Hanwell /Southall are places in their own right not part of some high rise commuting belt. Their character including Conservation Areas, open space, community facilities and access to public transport should influence any new development. These towns should not have uniform corridor policies imposed.

Bullet 2 - The A40 corridor is equally meaningless, Greenford Town Centre lies well to the south of both trunk road and central line. Employment areas are identified north of the A40. The existing urban structure within the 2 corridors would suffer destruction to replace by high densities. Strong pressures for redevelopment would result in building schools on green space. This is unacceptable especially as redevelopment for high buildings uses much energy in replacing the buildings. Response: Noted.

It is important to realise that the concept of the development corridors is not intended to convey any administrative boundary but are intended to provide some broad unifying spatial elements. They are diagrammatic and not meant to be taken literally. A great deal of work has been doe in respect of the specific characteristics of the communities across the borough but if this were to added to the text of the strategy it would destroy the document’s brevity and focus. However, it is broadly accepted that the maps can be a little difficult to understand and that do not communicate change especially well. Outcome: Accept conditionally. We will explore further the possibility of including brief and geographically specific commentaries and maps for each of the major communities in the borough.

Name Organisation Policy Reference Twyford Abbey Properties Business 1.1 (b) Nature of Comment: Support with conditions

Initial Proposal 1.1 Spatial Vision for Ealing - Twyford Abbey Properties (TAP) propose the

40 identification of the Twyford Abbey Site in MAP 2. "Housing & Employment Sites in Ealing & The Development Corridors" as potential housing sites with capacity of 200+ units. Response: Noted. This is still under consideration, and further details regarding the Twyford Abbey site will be provided as part of the Initial Proposals into the Development Sites document, due in Autumn this year. Outcome: No change. Further details are to be provided within the Development Sites policy document and initial proposals will be published in Autumn 2010.

Name Organisation Policy Reference SEGRO Business 1.1 (b) Nature of Comment: Support with conditions

Support of the broad growth areas strategy – with the recommendation that in terms of the overall distribution of development and associated delivery timeframes, opportunities outside of the Crossrail corridor [which has potential risk of delays] should be considered to provide a more robust opportunity to meet overall targets

The need for clarity in respect of how the Council envisages that it will manage the approach to different employment land designations, for example, how Segro’s land at Rockware Avenue, which is not designated as strategic, will be treated in respect of GLA guidelines on flexibility compared to other nearby strategic sites. Response: Support welcomed.

For avoidance of doubt, the geographical boundaries of the site are defined as the site area is bounded by the central line to the south, Oldfield Lane North to the West and North, and Greenford Road to the east.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

41 Name Organisation Policy Reference West Ealing Neighbours Community/Voluntary Organisation 1.1 (b) Nature of Comment: Comment

1.1 Spatial Vision for Ealing - We do not see any evidence of the investigation of alternative strategies to that of concentrating new home building along the Uxbridge Road/Crossrail corridor. It appears as a fait accompli. Improving north-south public transport is important and WEN has proposed a new bus route from Tesco in Perivale to West Middlesex Hospital in its recent report about the Lido Junction. Response: Noted.

Support is welcomed for the promotion of better North-South orbital links in the borough and Initial Proposal 4.4 in the Development Strategy supports this. With regard to the proposed new bus route, the council's Crossrail Scrutiny Panel has recommended that consideration be given to bus links to the redeveloped West Ealing station, including the possibility of diverting services, and a focus on additional north-south services and links to South Ealing, Northfields, North Ealing and Perivale. The suggestion by WEN to extend north-south bus services further south to West Middlesex Hospital is noted and can be included in discussions with TfL London Buses as part of on-going discussions to meet gaps in the bus network. Outcome: No change. The proposal on a new bus route will be considered as part of the on-going review of bus services.

Name Organisation Policy Reference Dooba Investments VI Ltd Business 1.1 (b) Nature of Comment: Support

Our client is supportive of a general strategy of promoting the focus of new employment development in centrally located locations such as Town Centres and near stations and transport corridors in the two development corridors. The redevelopment of Exchange Plaza (Uxbridge Road, Ealing) will help meet such an approach. Response: Support welcomed.

The council is preparing a Development Sites policy document and any specific proposals for the Exchange Plaza should be included, where appropriate, and further discussions would be welcomed. Outcome: No change.

Name Organisation Policy Reference Hallmark Property Group Business 1.1 (b) Nature of Comment: Support

My client is supportive of proposals to concentrate new residential and commercial development within the A40 Corridor. However policy should not seek to restrict new development solely to the Greenford town centre, North Acton Station or Park Royal area. It is considered that policy should encourage new development in sustainable locations with good access to public transport. While my client is generally supportive of proposals to maintain the borough's green spaces and green

42 corridors, it is considered that policy should acknowledge the role that new development can make in enhancing these areas. National planning policy (PPS9 - Biodiversity and Geological Conservation) recognizes this, places the enphasise much more on the need to "conserve or enhance", rather than simply "protect". It is considered that policy should be amended to reflect national policy on this issue. Response: Support welcomed.

See also Chapter 5 of the Development Strategy which deals with the Protection and Enhancement of Ealing’s Green and Open Spaces. It is acknowledged that new development can have the potential to enhance such areas; detailed policies for assessing the impact of new development on their surroundings will however be set out in the Development Management document, and specific planning applications will also be assessed against these policies. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 1.1 (b) Nature of Comment: Object

Development Strategy Document - Initial Proposals Consultation Questionnaire - Executive Summary - Background Paper 1 'The Council's ability to plan services, development and regeneration is seriously jeopardised by poor knowledge of basic demographic information' Given that the council does not seem to know exactly how many people live in the borough and what sort of housing is needed it seems ridiculous to plan any development until you have this essential information. At a recent transport meeting we were told that the Uxbridge Road is the busiest road in Europe. If this were so it would seem foolhardy to have 97% of residential development along the busiest and most polluted area of the borough. It is also assumed that Crossrail will bring business into the area whereas in fact the most likely scenario, given the route of Crossrail and the two major developments proposed in the centre of Ealing, will be that the borough will just become a dormitory suburb. This is also likely to happen given the number of offices that are either being pulled down for residential use or converted for residential use. Given that the current infrastructure is already groaning under Ealing's current population, the development strategy is sadly lacking in infrastructure improvements that can sustain an increased population. Response: Not accepted.

Uxbridge Road has some of the highest public transport accessibility levels (PTAL) in the borough (see Map 12) and this will increase in the coming years, for example when Crossrail is completed (see Appendix 3). The Council’s proposals are to promote sustainable development by maximising development potential along main corridors with good access to public transport. The proposed significant investment in public transport and promotion of alternatives to the car for regular journeys will reduce the impact of travel demands from increased population. In addition, each development proposal is assessed on its own merits and appropriate mitigation is secured through legal agreements to ensure that the transport impact of each development can be accommodated within the existing road network. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 1.1 (b) Nature of Comment: Object

There is a wholly excessive focus on additional housing and commercial space along the Uxbridge Rd corridor; All aspects of infrastructure already overstretched; Detailed study work with infrastructure providers should have preceded the strategy; High land costs equals excessively dense housing schemes - few opportunities for family housing/ no proportionate provision of associated public and garden and amenity space; Developers preferences for easiest and quickest profit opportunities should be rejected and a commercially led agenda scrapped in favour of a

43 Borough wide holistic plan Response: Not accepted.

Name Organisation Policy Reference JK Gill Resident 1.1 (b) Nature of Comment: Comment

There appears to be no strong need for the proposed development on the Gasworks site in Southall or on the Arcadia site in Ealing Broadway. Areas on the A40 are already congested and I would have concerns that the concentration of development along this route would lead to more congestion. Response:

The proposed locations for concentrating the new homes and business space have some of the highest public transport accessibility levels (PTAL) in the borough (see Map 12) and this will increase in the coming years, for example when Crossrail is completed (see Appendix 3). The Council’s proposals are to promote sustainable development by maximising development potential along main corridors and within areas with good access to public transport. The proposed significant investment in public transport and promotion of alternatives to the car for regular journeys will reduce the impact of travel demands from increased population. In addition, each development proposal is assessed on its own merits and appropriate mitigation is secured through legal agreements to ensure that the transport impact of each development can be accommodated within the existing road network. Outcome: No change.

Initial Proposal 1.1 (c)

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation 1.1 (c) Nature of Comment: Comment

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

44 congestion on the road network, atmospheric quality or environmental sustainability. Response: Noted.

Uxbridge Road has some of the highest public transport accessibility levels (PTAL) in the borough (see Map 12) and this will increase in the coming years, for example when Crossrail is completed (see Appendix 3). The Council’s proposals are to promote sustainable development by maximising development potential along main corridors with good access to public transport. The proposed significant investment in public transport, including improvements to north-south links, (see Map 8) and promotion of alternatives to the car for regular journeys will reduce the impact of travel demands from increased population. The Council’s transport strategy identifies unmet north- south bus links and is working with TfL London Buses to expand the network. In addition, each development proposal is assessed on its own merits and appropriate mitigation is secured through legal agreements to ensure that the transport impact of each development can be accommodated within the existing road network. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 1.1 (c) Nature of Comment: Comment

The north-South public transport system should be in place and the West London Orbital link should not be included because, if approved, it will not be in existence until after 2026. The Victorians, the Edwardians and even the Romans built the transport infrastructure first and then development grew up around it. Ealing Council does the opposite, hoping that somehow the transport system will improve without actually being pro-active in making it happen. For instance, no effort has been made in improving Ealing Broadway station despite the fact that in 2004 there were over 13 million entries and exits and in 2008, 17 million. What would Ealing Council have done if Crossrail had not been approved? Response: Noted.

In addition to Crossrail, improvements at and around Ealing Broadway station will be developed and delivered as part of the redevelopment of Ealing town centre. In addition, in the shorter term, the Council can use other funding streams to finance improvements in the transport network before major projects and redevelopment takes place. This shorter term work includes working with TfL London Buses to achieve improvements to the bus network. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 1.1 (c) Nature of Comment: Support

1.1 (c) The improvement of transport links across the borough are welcomed, especially between the A40 and the Uxbridge Road corridor, however knowledge of how people are travelling across London is required before anything is built. Response: Support welcomed. Support welcomed. Travel data is available via the annual residents survey and from TfL’s annual travel surveys. Outcome: No change.

Initial Proposal 1.1 (d)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.1 (d) Nature of Comment: Comment

Suburban character should be protected wherever there is attractive and useful housing not just confined to areas defined as 1-12. Response: Noted.

Name Organisation Policy Reference JK Gill Resident 1.1 (d) Nature of Comment: Support with conditions

The UDP could be updated by meeting additional criteria on distances between windows and neighbouring dwellings and other building standards such as room sizes. Response: Noted.

This is an issue that will be dealt with the Development Management policy document. Outcome: No change.

Initial Proposal 1.1 (e)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.1 (e) Nature of Comment: Comment

Conservation areas are ignored. Historic environment is an inadequate description for areas of architectural importance. Also it is unacceptable that there is no reference to sustainable buildings of high design quality in the Vision. Response: Noted. These are issues that will be dealt with in more detail in the Development Management policy document but it makes sense to ensure that commitments to high quality design are set out clearly in the Development Strategy and this will be further reviewed. Outcome: Accepted conditionally.

Name Organisation Policy Reference JK Gill Resident 1.1 (e) Nature of Comment: Support with conditions

This is supported but the document does not state how it will be achieved Response: Support welcomed.

More detail will be provided in the Development Sites and Management policy documents. Outcome: No change.

46 Initial Proposal 1.1 (f)

Name Organisation Policy Reference Walpole Residents Association Community/Voluntary Organisation 1.1 (f) Nature of Comment: Comment

Conservation Areas and Green Open Spaces - Ealing Centre is uniquely defined by a number of conservation areas and green open spaces. The purpose of the conservation areas is to preserve our architectural heritage rather than trample over it with modern faceless blocks of apartments, offices or shops. Similarly, too much development near our green spaces will result in their deterioration and an irreversible decline in Ealing's distinctive nature. This does not appear to have been considered in the strategy. Response: Not accepted. More detailed policies/criteria will be provided in the Development Sites and Management policy documents and will supplement policies containing in the London Plan and its replacement. Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 1.1 (f) Nature of Comment: Support

The current Arcadia site development overshadows Haven Green. Is this to continue with similar tall buildings? 1.1 g. - There is a lack of infrastructure in both "Dickens Yard" and "Arcadia" sites. Bodes badly for future development. Response: Noted.

In relation to the Arcadia development, this is not now proceeding in its current form following the intervention of the Secretary of State.

In relation to infrastructure, an Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential social, transport, green community and other necessary infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 1.1 (f) Nature of Comment: Support with conditions

A London wide policy is required to protect public green spaces from being developed on. Higher standards required for children’s play areas. Schools should be forced to cease selling their playing fields. Response: Noted. Policies in respect of the green and open spaces are to be found in Chapter 5 of the Initial Proposals and more detailed policies/criteria will complement the London Plan (and its replacement) and will be set out, where appropriate, in the Development Management policy document. This will be informed by work that has recently been commissioned in respect of an open space strategy. Outcome: No change.

47 Initial Proposal 1.1 (g)

Name Organisation Policy Reference Highways Agency Statutory 1.1 (g) Nature of Comment: Support with conditions

The HA would not generally support development located in non-accessible locations unless infrastructure improvements necessary to support development are identified and funding sources, including developer contributions are secured. Where new developments are reliant on proposed infrastructure, it is critical that this is phased in line with occupation. This will ensure that developments have sustainable transport access from the outset. It is suggested on page 11 that further proposals will be needed to enhance north-south movement to facilitate regeneration. The actual proposals required should be outlined in the Strategy. Response: Support welcomed.

Name Organisation Policy Reference Government Office for London Statutory 1.1 (g) Nature of Comment: Support with conditions

Further detail to be provided in the Development Sites Document and the Infrastructure Delivery Plan.

Name Organisation Policy Reference Metropolitan Police Authority Statutory 1.1 (g) Nature of Comment: Support with conditions

Sub-section (g) seeks to ensure community facilities are privided where and when they are needed. The MPA consider the description of community facilities as set out at section 6.2 of the development strategy is referred to at this point. Response: Noted. Outcome: Accepted. Either amend or provide appropriate cross-references.

Name Organisation Policy Reference The West London Mental Health Statutory 1.1 (g) Nature of Comment: Support with conditions

Chapter 1: Vision for Ealing 2026 - The Trust supports the overall spatial vision for Ealing 2026 as set out in Initial Proposals 1.1 and 1.2. In particular, the Trust welcomes the identification of the need ‘to ensure that community facilities… are provided in the borough where and when needed’ (1.1 (g)). Health care facilities are very important community facilities. We support recognition in this way of the fact that mental health needs must be provided for in the future. These needs will arise from the existing population and expected population increases in the borough and further afield over the area which St Barnard’s serves. This would carry forward the general approach of the adopted UDP (Policy 8.8) AND London Plan (Policy 3A.21). It is important to note that the Trust considers that meeting the mental health needs of the West London community and the role of St Bernard’s hospital is of strategic significance such that it merits full attention in this document. Response: Support welcomed.

Initial Proposal 1.2 – Delivery of the Vision for Ealing 2026

Name Organisation Policy Reference Royal Mail Business 1.2 Nature of Comment: Support

Summary - Notwithstanding the support expressed above for the broad spatial objectives of the Development Strategy and Development Management Policies, it is essential that the Council recognises the importance of Royal Mail’s operations. As previously stated, should any of Royal Mail’s sites and/or sites surrounding Royal Mail be redeveloped, it would be vital that the operations should be appropriately re-provided/relocated and that any new uses surrounding their sites be designed and managed so that they are both cognisant and sensitive of and to Royal

49 Mail’s operations. Royal Mail has advised that they would welcome the opportunity to meet with the Council to discuss the emerging plans for the town centres/areas so as to assist the Council with the production of their emerging Site Specific Allocations Development Plan Document and, as well as, the Infrastructure Delivery Plans. We would therefore be grateful if you could acknowledge receipt of our representations and advise as to the next stages for the above documents and when the Site Specific Allocations Development Plan Documents are due for public consultation. Response: Support for broad spatial objectives welcomed.

The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development Sites Document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document. The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It is essential therefore that there is on-going and continuing dialogue with the Royal Mail to ensure any detailed plans are properly accounted for, where relevant and appropriate. Otherwise, the Royal Mail’s concerns regarding relocation are noted, however any plans to re-provide or relocate existing premises will be assessed on the individual merits of that application, having regard to relevant statutory plans, policies and objectives. Outcome: No Change.

Name Organisation Policy Reference Government Office for London Statutory 1.2 Nature of Comment: Support with conditions

Where there is a lack of evidence that infrastructure provision is achievable, or where development has critical new-infrastructure dependencies for delivery, the Core Strategy should include contingency plans, for example alternative means of achieving an acceptable PTAL rating. A clear evidenced based infrastructure strategy will be especially important for the first 5 years of the plan period, which should be the most certain period of the plan. On Map 8 (Approved and Proposed Improvements to Transport in Ealing), it would be helpful to differentiate between approved (funded) and aspirational (unfunded) public transport improvements in the Borough.

Housing growth appears to be a central plank of your strategy. Therefore it may be helpful to include a summary housing policy setting out overall housing numbers, broken down by phase and locality where possible. It is currently unclear whether the Borough has a reliance on windfall sites. Should this be the case you need to include robust evidence and follow guidance in PPS3 para 59, SHLAA Practice Guidance and advice in PINS’ Local Development Frameworks ‘Learning from Experience’ document (September 2009).

We could not see any mention of Gypsies and Travellers. This will need to be dealt with in forthcoming versions, and should be evidence based.

Monitoring mechanisms should be included in the Regulation 27 publication version of the Strategy. This is most usefully set out in a single table in the annex.

Response: Support for the broad spatial objectives welcomed.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This will ensure that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. In the event that required critical infrastructure will not be available for proposed developments, alternative methods of addressing this will be investigated

50 and outlined in the Infrastructure Delivery Plan and will also be monitored on an annual basis in the Annual Monitoring Report (AMR).

In relation to Map 8, this will be amended to differentiate between the approved and proposed transport improvements in the borough.

In relation to residential development quantums, more detailed information will be provided either directly in the Development Strategy or in supporting documentation. In the interests of brevity and clarity we do not intend to have separate thematic policies but accept that targets should be clearly set out.

In relation to gypsies and travellers, reference is made at Initial proposal 3.8 (b) with regard the existing traveller’s site at Bashley Road, Park Royal. This is complemented by Initial Proposal 3 in the Development Management Issues and Options policy document which also refers to facilitating improvements to the above site. However, it is accepted that the treatment of any targets set out in the London Plan needs to be set out more clearly and further discussion with the GLA is anticipated.

Finally, the published version of the Strategy shall include details of monitoring mechanisms as appropriate. Outcome: Accepted conditionally.

Name Organisation Policy Reference Metropolitan Police Authority Statutory 1.2 Nature of Comment: Comment

National Policy The MPA are mindful that PPS1 states that Councils should prepare development plans which promote inclusive, healthy, safe and crime free communities. Conclusion - Mindful of the draft consultation documents and overarching planning policy, the MPA would like to reiterate their main policing concerns which should be implemented within this document, including: I. Overarching Policy Support For Policing; II. Support for policing facilities to be located on surplus industrial/employment sites and in town, neighbourhood and local centres; and III. Policing facilities are adequately provided in response to growth and large-scale developments. Response: Noted.

The role of the police in providing healthy, safe and crime free communities is acknowledged, and the police are included as being a key element of Social and Community infrastructure in Initial Proposal 6.2 of the Development Strategy. The spatial portrait and vision will be supported by a number of separate planning documents, such as the Development Sites policy document and the Infrastructure Delivery Plan and these will ensure the delivery of the vision. The Development Sites Document will set out in greater detail the suitability of individual sites for facilitating different uses and heights, based on individual merits. More detailed maps for each site will be provided in tandem with this document. The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It is essential therefore that there is on-going and continuing dialogue with the Royal Mail to ensure any detailed plans are properly accounted for, where relevant and appropriate. Otherwise, the Metropolitan Police’s concerns regarding new facilities are noted, however any plans to re-provide or relocate existing premises will be assessed on the individual merits of that application, having regard to relevant statutory plans, policies and objectives. Outcome: No Change.

51 Initial Proposal 1.2 (a)

Name Organisation Policy Reference Government Office for London Statutory 1.2 (a) Nature of Comment: Support with conditions

To comply with PPS3 para 29 you should include a specific Ealing affordable housing policy (which is viability tested), with a tenure breakdown of affordable housing. You may also wish to make reference to whereabouts of SHMA and SHLAA, cross reference to housing trajectory, and include family housing policy if this is an identified problem in the area. Response: Noted.

Amend affordable housing policy. Further detail to be provided in the Affordable Housing SPD, the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.2 (a) Nature of Comment: Object

Affordable housing increases the cost of open market housing so that it is important that any policy changes are fair and not open to fraud. Response: Noted.

An Affordable Housing SPD is currently being prepared. This will build on the existing work that has been carried out to date and will contain a breakdown of the provision of affordable housing during the plan period. In addition, a draft SPD on Legal agreements etc is also in the pipeline and will be amended once the council has prepared an Infrastructure Delivery Plan and considered its position in relation to the Community Infrastructure Levy. Both shoulkd provide the necessary levels of transparency. Outcome: No change.

Further detail to be provided in the Affordable Housing SPD, the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 1.2 (a) Nature of Comment: Object

Initial Proposal 1.2 Delivery of the Vision for Ealing 2026 - The consultation document refers in Initial Proposal 1.2 (a) on page 13 to a forthcoming review by the Council of its ‘Affordable Housing Supplementary Planning Document’. Affordable housing will be an integral element of the proposed developments. It is therefore unfortunate that this review wasn’t undertaken and completed before the start of this consultation. In these circumstances it is difficult to see how members of the public can comment meaningfully on the Affordable Housing aspects of the Development Strategy. Nor is it clear what future consultation opportunities there will be for the public to comment on this key subject.

52 Response: Noted. There will be further opportunity to comment on the draft policy contained within the Development Strategy when final proposals are published in Autumn 2010. As mentioned, an Affordable Housing SPD is currently being prepared. This will build on the existing work that has been carried out to date and will contain a breakdown of the provision of affordable housing during the plan period. There will be an opportunity for the public to comment on the draft SPD in Spring 2012. Outcome: No change. Further detail to be provided in the Affordable Housing SPD, the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Hovedean Properties Business 1.2 (a) Nature of Comment: Support Affordable Housing - We support the statement on affordable housing where a balance of density and tenure mix for new schemes across the borough is envisaged. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 1.2 (a) Nature of Comment: Object

Housing provisions cannot be estimated if the existing population base is not known. Reducing the provisions of affordable housing does not make sense. It appears that Ealing has to build twice the amount of houses than Hammersmith, Fulham or Hounslow, which does not make sense given that Ealing is a 'cluster borough' with the aforementioned areas. Response: Not accepted. A considerable amount of work has been carried out in order to establish a sound evidence base for the proposals and objectives outlined in the Development Strategy. With regard to residential development quantums, the Strategic Housing Market Assessment (SHMA) provides an overview of housing need and demand and the findings are linked to regional and sub-regional targets. Population projections were based on work carried out by the GLA with substantial input from the council. In addition to this, the Council has worked with the GLA to produce its London-wide Strategic Housing Land Availability Assessment (SHLAA). The figures generated through the SHLAA process in terms of deliverable and developable sites will also inform the revised housing targets outlined in the revised Replacement London Plan. The intention to reduce the overall level of affordable housing is a reflection of what is realistically deliverable in the short term, given the overall reduction in housing completions currently being experienced. The council is currently in the process of commissioning studies to further assess the viability of its affordable housing proposals. Outcome: No change. Further detail to be provided in the Affordable Housing SPD, the Development Sites Document and the emerging Development Management Document.

Initial Proposal 1.2 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.2 (b) Nature of Comment: Comment

Meaning is unclear. How can waste be disposed of within the 6 boroughs.

53 Response: Noted Waste from the 6 boroughs is currently being disposed of externally. It is the intention of the 6 West London Boroughs to accommodate all their waste within the boundaries of the 6 boroughs by 2020. A joint Waste DPD is currently being prepared will set out policies for dealing with waste, taking into account strategy agreed with West London Boroughs. Consultation on the Draft is expected to take place in Autumn 2010. Outcome: No change. Further detail to be provided in the West London Waste DPD.

Name Organisation Policy Reference JK Gill Resident 1.2 (b) Nature of Comment: Support with conditions

In order to ensure that there is a significant reduction in waste that can be recycled, each area should be responsible for their own natural waste collection and disposal. I would personally support any plan that reduces landfill waste Response: Noted. A joint Waste DPD is currently being prepared and will set out policies for dealing with waste, taking into account strategy agreed with West London Boroughs. Consultation on the Draft is expected to take place in Autumn 2010.

Outcome: No change. Further detail to be provided in the West London Waste DPD.

Initial Proposal 1.2 (c)

Name Organisation Policy Reference Martin Gorst Resident 1.2 (c) Nature of Comment: Object I am concerned about the possibility of high-rise buildings, as these would spoil the character of Ealing. I also do not believe that concentrating future development along the Uxbridge Corridor is a good idea. The idea of concentrating large amounts of residential housing close to stations will lead to high rise developments that will result in sun-less, wind blasted streets, and in the case of Uxbridge Road is likely to lead to a Ghetto corridor. I would advocate spreading the housing along the borough in the form of low-rise developments. Response: Noted. The role of the Development Strategy is to set out, in broad terms, how and where Ealing will develop in the period up to 2026. The Development Sites Document is a supporting document to the strategy and its purpose is to set out in greater detail the suitability of individual sites for high- rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. In this regard, they will be assessed against Policy 7.7 of the Draft Replacement London Plan. Outcome: No change. Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Government Office for London Statutory 1.2 (c) Nature of Comment: Comment

Climate change, flood risk and tall building issues which are currently all mentioned in the ‘Vision’ section of the document should all be addressed in spatially specific policies. For example, with regard to tall buildings, we recommend that you identify appropriate broad locations for tall buildings, and pro-actively produce evidence to support these policies. Response: Noted.

The role of the Development Strategy is to set out, in broad terms, how and where Ealing will develop in the period up to 2026. The Development Sites Document is a supporting document to the strategy and its purpose is to set out in greater detail the suitability of individual sites for high- rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. In this regard, they will be assessed against Policy 7.7 of the Draft Replacement London Plan. Comments in relation to climate change and flood risk are noted. Outcome: Accepted.

Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.2 (c) Nature of Comment: Comment

Tall buildings may be appropriate for City Centres where offices are grouped together for business contacts and prestige purposes. Acton and Ealing town centres are conservation areas where the scale of the historic environment should be respected. Landmark buildings do not need to be tall. Towers do not provide satisfactory flats for families as shown by the problems of S Acton, Gurnell, Green Man Lane etc estates. Areas for tall buildings should be defined as suggested by EH/CABE and UDP policy used. Response: Noted.

The role of the Development Strategy is to set out, in broad terms, how and where Ealing will develop in the period up to 2026. The Development Sites Document is a supporting document that will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. It is accepted that Landmark buildings do not need to be tall. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. Design objectives for future development will be outlined in the Development Management document. Future design will ensure that the well being of residents is paramount, resulting in an enhanced quality of life for all. Outcome: No change.

Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Kingsdown Residents Association Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

We do not agree that there should be a policy that existing Council Housing Estates are remodelled to vastly increase the number of homes. This involves selling sites to developers/Housing Associations. Two sites are already in the process of sale. We presume we can expect to see other Council Estates sold off and buildings growing taller, housing denser and existing tenants of affordable housing destined to live in flats only. We are unhappy at this “secret” sale of Borough assets. This is taking place with no proper public discussion. Once sold, there can be no future Council role whatever need may arise. If other less built up areas were selected for the affordable housing there could be proper family homes, including houses with gardens, for some tenants to rent. Response: Not accepted.

The council’s estates regeneration programme, the council is promoting a major investment and regeneration programme to transform many of its homes, estates, town centres and neighbourhoods. It aims to provide residents with the best possible homes and housing services that will match the standards that they have told us they want. These ambitious plans seek to transform parts of the borough that need significant investment, care and attention as well as boost the economic, social prosperity and quality of life for our residents. The Development Sites Document is a supporting document to the Development Strategy that will set out in greater detail the suitability of individual sites for development and redevelopment, including high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, having taken into account the potential impacts of future development on the site and surrounding area. Estates Regeneration Areas will also be included as part of this analysis and the Local Planning Authority will have a specific role when assessing tall buildings and other forms of redevelopment according to function, character, quality of urban design and impact on the site and its surroundings. Outcome: No change. Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Kingsdown Residents Association Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

No “landmark tall buildings” - We are very unhappy about this. Without a proper definition of what constitutes either the height of a “tall building” or “the right circumstances” for its location, it would appear that the Council wishes us to give it “carte blanche” to do whatever it likes. We therefore can only say that we want no tall buildings in any circumstances. Response: Noted.

The role of the Development Strategy is to set out, in broad terms, how and where Ealing will develop in the period up to 2026. The Development Sites Document is a supporting document that will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. Outcome: No change. Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Twyford Abbey Properties Business 1.2 (c) Nature of Comment: Support with Conditions

We welcome that Tall Building are acceptable as landmark buildings on the right circumstances. Although Tall Buildings will be directed towards parts of the Town Centres, other locations or individual sites should also be considered for Tall Building based on their own merits according to function, character and quality of urban design. Response: Support welcomed. The Development Sites Document, which will support the Development Strategy, will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. Outcome: No change. Further detail to be provided in the Development Sites Document and the emerging Development Management document.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

Tall Buildings - It was stated at the public meeting(s) that the Council had decided to include exceptionally the special subject of Tall Buildings in this consultation. We are therefore disappointed and surprised to find that the Council has failed to include a specific question on this subject in the consultation questionnaire. This omission may mean that a number of respondents may fail to comment on this key subject. Initial Proposal 1.2 (c ) on page 13 opens with the statement, “Tall buildings are acceptable as landmark building in the right circumstances.” This is a far more permissive and pro tall buildings stance than that agreed by the councillors at the 22nd April 2009 meeting of the LDF Scrutiny Panel, which is minuted as, “Panel agreed that there should be a borough wide policy on tall buildings. The Panel felt that tall buildings should only be situated in appropriate locations where there were other such buildings. However the Panel was also anxious to avoid an over concentration of tall buildings in any one area and was particularly anxious to avoid a further proliferation of tall buildings on Council housing estates with all their attendant problems. Dick Johns agreed to prepare a draft statement on tall buildings for inclusion in the development strategy document and to circulate this for Panel Members’ comments.” EFRA regrets the construction of tall buildings in what is essentially a low rise suburban borough. If the construction of tall buildings is to be considered, we believe that the views expressed by the councillors on the LDF Scrutiny Panel represent a far more acceptable policy than that proposed in the consultation document. We also wish to place on record that we have been unable to locate the draft statement on tall buildings mentioned in the above minutes.

57 Response: Noted.

Tall Buildings were included under Initial Proposal 1.2 (c), and received a substantial number of representations. The draft statement that is referred to above was prepared by officers but as it was not considered by Cabinet members it was unavailable for circulation to the LDF scrutiny panel prior to the publication of the draft Strategy Document.

The Development Sites Document, as a supporting document to the Development Strategy, will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area. Design and other objectives for future development will be outlined in the Development Management document.

Outcome: No change. Further detail to be provided in the Development Sites Document and the emerging Development Management Document.

Name Organisation Policy Reference Dooba Investments VI Ltd Business 1.2 (c) Nature of Comment: Support

Initial Proposal 1.2 - Delivery of the Vision for Ealing 2026 - Tall 'Landmark' Buildings in appropriate central locations, such as at Exchange Plaza, present the opportunity for a positive impact on the environment and could act as an inspiration for future high quality development. Response: Noted. Outcome: No change. Further detail on Landmark Buildings to be provided in the Development Sites Document and the Development Management Document.

Name Organisation Policy Reference West Ealing Neighbours Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

1.2 Delivery of the Vision for Ealing - There is no definition of a tall building. There must be a definition of a tall building before any judgement can be made about its acceptability. It is difficult to comment in detail on some of the proposals as the infrastructure documents are crucial and these have yet to be published. The principle of balancing the needs of car users with the desire to encourage walking, cycling and electric cars is sound but far too often these are fine words with little or no action to bring about a proper balance – as at the Lido Junction. Response: Noted.

The Development Sites Document will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

58 Outcome: No change.

Further detail to be provided in the Development Sites Document and the Development Management document.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

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. 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. 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. 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? Response: Not accepted

We do not accept that the Tall Buildings proposals appeared ‘out of the blue’, as they were discussed at a number of LDF scrutiny panel meetings.

Outcome: No change.

Further detail to be provided in the Development Sites Document and the Development Management document.

Name Organisation Policy Reference Walpole Residents' Association Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

Tall Buildings - This is a particularly special and sensitive subject in Ealing, especially in the light of our conservation areas and open spaces. The strategy does make particular mention - however the phraseology is ill-defined and gives no strategic guidance on two simple points: - What is a "tall building" - for example is it defined as a building greater than six storeys? - Is it appropriate to have tall buildings in or adjoining a conservation area? The current strategy needs to be clear on these points or it a valueless.

59 Response: Noted.

Outcome: No change. Further detail to come in the Development Sites Document and the Development Management document.

Name Organisation Policy Reference Hovedean Properties Business 1.2 (c) Nature of Comment: Support

In relation to Tall Buildings, we support the Tall Building Strategy to include land within site S2 from Map DM 2. The opportunity lands to the south of the Southall Railway station should provide for high-density accommodation that will assist in the regeneration of areas further to the southeast. The new link across Grade Lane is supported, as are the housing opportunity sites to the south of Southall Rail station and an enlarged TC boundary in accordance with Map DM2, Southall. The inclusion of the site known as the Middlesex Business Centre within the S2 area, which supersedes the UDP designation, is also supported.

Response: Support welcomed. Outcome: No Change.

Name Organisation Policy Reference Hallmark Property Group Business 1.2 (c) Nature of Comment: Support with Conditions

Initial Proposal 1.2 - Delivery of the Vision for Ealing 2026 - My client is supportive of policy which encourages the location of tall buildings in sustainable locations with good access to public transport. It is however respectfully suggested any references to specific locations where tall buildings might be acceptable in principle (Hanger Lane, Park Royal, etc) be deleted, and replaced by policy setting out criteria by which proposals for tall buildings 'borough-wide' can be judged against. Response: Support welcomed.

In the absence of a Development Sites document during the consultation process, it was considered appropriate to identify broad locations for tall buildings. The Development Sites document is currently being progressed and as part of this, the appropriateness of identifying individual locations for tall buildings will be reviewed. Along with this, the Development Sites Document will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

Outcome: No change.

Further detail to come in the Development Sites Document and the Development Management document.

Name Organisation Policy Reference Michael Simmons Resident 1.2 (c) Nature of Comment: Comment

Initial Proposal 1.2 Delivery of the Vision - The consensus on tall buildings is that they should be in clusters. What are the "Proposed Improvement to Transport Links" in map 4 - This is totally unclear. The maps in the document are very unclear as they have few points of reference. Response: Noted.

The Development Sites Document is a supporting document to the Development Strategy that will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

The proposed improvements to transport links on map 4 were for indicative purposes. These are currently being reviewed and future maps will provide greater detail on proposed transport improvements. Outcome: No change.

Further detail to be provided in the Development Sites Document and Proposals Maps.

Name Organisation Policy Reference Susan New Resident 1.2 (c) Nature of Comment: Comment

In the London Plan Review it states 'tall buildings will continue to have a place in London, but will be sited where the existing context, and boroughs, can support them'. Context is the key word and the council should have a separate planning committee, as in other boroughs, to consider such developments. So far tall buildings have been sited where the context has not been considered. Response: Noted.

Further detail to be provided in the Development Sites Document.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Association Organisation 1.2 (c) Nature of Comment: Object

We do not need any more high-rise blocks on the Uxbridge Road. Already people are suffering from mental disorders from living in such places (women in particular - children are not allowed out).

61 Response: Noted.

Increased heights and densities are justified by future population and housing projections. Design objectives for future development, including tall buildings, will be outlined in the Development Management document. Future design will ensure that the well being of residents is paramount, resulting in an enhanced quality of life for all.

Further detail to be provided in the Development Management and Development Sites Documents.

Name Organisation Policy Reference Katharine Brooks Resident 1.2 (c) Nature of Comment: Object

The phrase 'landmark high-rise' bothers me and I would like to see a commitment to nothing over 15 floors being approved. Response: Noted.

Further detail to be provided in the Development Sites Document.

Name Organisation Policy Reference Mrs J. Hughes Resident 1.2 (c) Nature of Comment: Object

I oppose the concept of "Building Landmark Tall Buildings" in Ealing, particularly in the Town Centre, to invite an influx of perhaps 28,000 people to occupy 14,000 new homes in Ealing. "High Rise" will simply destroy our Garden Suburb, and we haven't the space for the facilities need to support such a change - Health centres and Doctors, Schools, Fire Stations - Nor are there Jobs available within reach to support these people. "Sky-scrapers" have already failed in London in that they have separated people and destroyed community spirit, many have been pulled down. What is needed is low rise, close, communal living with proper support on the old village concept, so people can be human and not just numbers.

62 Response: Noted.

Name Organisation Policy Reference Peter L Flatau Resident 1.2 (c) Nature of Comment: Object

Tall buildings again see comment 1.1 g. above these two tall buildings sites do not fall in with your requirements of 1.2c is this how you intend to continue? The current Arcadia site development, overshadows Haven Green. Is this to continue with similar tall buildings? Response: Noted.

Name Organisation Policy Reference Eric Leach Resident 1.2 (c) Nature of Comment: Object

What are 'Tall Buildings' 3 storeys = maybe OK. 9-26 storeys = NO. No to tall residential tower blocks. In built up areas with already inadequate (and no upgrade) social and community facilities. No data on the latter. Response: Noted.

The Development Sites and Management policy documents will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

63 Outcome: No change.

Further detail to be provided in the Development Sites and Management policy documents and the Infrastructure Delivery Plan.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 1.2 (c) Nature of Comment: Object

It is wrong to attribute 'landmark' status/benefits to tall buildings - many designs/forms can be landmark buildings. The reference to 'tall' is vague and therefore meaningless. Strategy needs to relate tall to specific settings/context. 'Tall' should certainly not be an option wherever either a Conservation Area setting or views into or from neighbouring CA's would be compromised, or if it would impact on the setting of a statutory or locally listed building. 'Tall' and/or high density development should only be considered in tandem with additional transport and social infrastructure and amenity space - not put further pressure on existing infrastructure. Response: Noted.

It is accepted that Landmark Buildings do not necessarily need to be tall. The Development Sites Document, which supports the Development Strategy, will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

Further detail to be provided in the Development Sites Document and the Infrastructure Delivery Plan.

Name Organisation Policy Reference JK Gill Resident 1.2 (c) Nature of Comment: Support with conditions

Tall buildings need to be proportionate and have impacts that need to be addressed. Advice needs to be taken from other cities where tall buildings are standard Response: Noted.

The Development Sites Document, which supports the Development Strategy, will set out in greater detail the suitability of individual sites for high-rise buildings. This will identify appropriate uses and heights that are suitable for each site, based on individual merits. Tall buildings will be assessed according to function, character and quality of urban design and taking into account the potential development impacts on both the site and surrounding area.

Outcome: No change. Further detail to be provided in the Development Sites Document.

64 Initial Proposal 1.2 (d)

Name Organisation Policy Reference Ealing Civic Society Resident 1.2 (d) Nature of Comment: Support with conditions

New development should not be located in areas of high flood risk. Response: Support welcomed.

All new development shall be subject to a sequential test, which will seek to redirect new development to areas of least risk. Outcome: No change.

Name Organisation Policy Reference Britel Fund Trustees Business 1.2 (d) Nature of Comment: Object

In respect of flood risk, we consider that development which is not identified within a flood risk area, or an area prone to flooding, should not be required to be the subject of the sequential test. Response: Noted.

All new development shall be subject to a sequential test, which will seek to redirect new development to areas of least risk. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 1.2 (d) Nature of Comment: Support

I support the logic in not building in flood plains. Response: Support welcomed. Outcome: No change.

Initial Proposal 1.2 (e)

Name Organisation Policy Reference Metropolitan Police Authority Statutory 1.2 (e) Nature of Comment: Support with conditions

This section highlights the 'Delivery of the Vision for Ealing 2026' and point (e) supports the appropriate provision of social, physical and green infrastructure in the right locations and at the right time to support the level of housing and employment growth proposed for delivery in Ealing. This will be delivered through the Infrastructure Requirements and Delivery Plan.

This statement is consistent with London Plan policy 3A.18 which emphasises the need for social infrastructure and community facilities to be included within DPDs. Policing facilities are recognised as Social Infrastructure within the London Plan.

The MPA support this statement and note that the Infrastructure Requirements and Delivery Plan document is currently being prepared by the LPA and will be out for consultation towards the end of 2009, at which stage the MPA will make more detailed comments.

65 Response: Noted. Outcome: No change.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.2 (e) Nature of Comment: Object

Provision of the infrastructure at the right time and place is welcome but cost is not adequately taken into account with pressure for high residential developments. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It will include details on the delivery, cost and phasing of the infrastructure necessary to achieve the objectives set out in the Strategy. Outcome: No change.

Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference Kingsdown Residents Association Community/Voluntary Organisation 1.2 (e) Nature of Comment: Support

No building before Infrastructure. We are told that a plan is to be published in 2010 on how utilities, education, health, leisure and other essential services can be delivered in these already densely developed areas. The infrastructure plan should come first or alongside the two proposal plans. Schools, health and hospital facilities are already very overstretched. Sites must be identified and plans made for such provision first. Where in Central or West Ealing can new schools be built, especially if all available space is crammed with new flats? Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It will include details on the delivery, cost and phasing of the infrastructure necessary to achieve the objectives set out in the Strategy.

The Sites Development Document will also set out specific policies for the development of key sites, areas and locations in the borough. It will outline in greater detail the suitability of individual sites for facilitating different uses and densities, including schools, based on their individual merits. This includes any proposals for land and buildings on significant sites that are likely to be subject to development proposals during the plan period i.e. 2011-2026. These allocations are intended to assist in delivering the priorities and objectives of the Development Strategy 2026. Detailed maps for each site will be provided in tandem with this document. Outcome: No change.

Further detail to be provided in the Infrastructure Delivery Plan and Development Sites document.

Name Organisation Policy Reference Susan New Resident 1.2 (e) Nature of Comment: Object

Basically what seems to be currently happening is, because development is developer led rather than council led, public green spaces are having to supply the amenity space lacking in developments, for example Dean Gardens is the only green space near numerous large developments that lack amenity space and if all the residents who occupy or will occupy these buildings stood in the park you would not be able to see the grass. Social infrastructure in Ealing is already inadequate. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure, including social and green infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. It will include details on the delivery, cost and phasing of the infrastructure necessary to achieve the objectives set out in the Strategy. All future development will be required to provide adequate levels of open space and where there is a reliance on existing green infrastructure there will be a requirement to contribute to the upgrading and enhancement this existing infrastructure. Outcome: No change.

Further detail to be provided in the Infrastructure Delivery Plan and the Development Sites Document.

Initial Proposal 1.2 (f)

Name Organisation Policy Reference Highways Agency Statutory 1.2 (f) Nature of Comment: Support with conditions

Section f’ of initial proposal 1.2 suggests that the requirement for parking in the borough will be within the maximum provision allowable in outer West London. The HA would recommend that consideration be given to reduce maximum parking standards in areas with good access to public transport. This would be consistent with the recommendations of PPG13, paragraph 49, and therefore meets PPS12 soundness requirement. Critical to the development of the Development Strategy will be the completion of a transport evidence base. In our response to the Issues and Options document, we requested that an evaluation of the transport impacts be undertaken. The evaluation will help you to identify appropriate levels of mitigation to minimise the potential for impacts on the SRN, hence demonstrate that the Strategy is set on a robust and credible evidence base as required by PPS12. I have attached an advice note outlining a suggested methodology for such an assessment. Response: Noted.

It is anticipated that further work will be required to refine policies on all aspects of car parking and this will need to take into account emerging policies in the Replacement London Plan and which also take account of, for example, PTALs, the network capacity, travel planning and parking needs in individual localities. This review will be completed by Summer 2010 and final proposals will be subject to further consultation in Autumn 2010.AITING COMMENTS FROM TRANSPORT PLG? Outcome: Accepted conditionally.

Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 1.2 (f) Nature of Comment: Comment

Car parking must be reviewed because street parking causes congestion and pavement damage. Response: Noted.

Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 1.2 (f) Nature of Comment: Object

Car Parking - It was also stated that at the public meeting(s) the Council had exceptionally decided to include the subject of car parking in the Development Strategy, rather than consult on it at a later stage in the LDF process. This appears to relate to the level of car parking provision which will be permitted at or associated with the proposed additional 9,000 plus housing units. It is unfortunate that the consultation documents only set out the new proposals and fails to include a comparison as to how they compare to the provisions of the existing Unitary Development Plan (UDP). In these circumstances it is difficult to provide a meaningful response and we reserve the right to comment at a later date. Response: Noted.

Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

Name Organisation Policy Reference Britel Fund Trustees Business 1.2 (f) Nature of Comment: Support with conditions

Generally supportive, however the provision of underground car-parking will not be feasible in every development proposal. The policy should allow greater scope for parking requirements, on a case by case basis as opposed to a blanket policy restriction.

68 Response: Noted.

Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

Name Organisation Policy Reference Susan New Resident 1.2 (f) Nature of Comment: Object

Given that numerous developments have been and are being built without car parking provision in a borough not noted for its low car use the council has to invest far more time in improving the transport infrastructure and just asking developers to provide green travel plans is risible. Car clubs have to sited next to low car housing projects not a few roads away. Response: Noted.

Support for improvement in public transport and transport infrastructure is welcomed and Initial Proposal 4.4sets out the council’s proposals. I relation to low car housing developments, it is preferable to locate car club as close to the development as is feasible. More detail on low car housing and car clubs will be provided in the Development Management policy document. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 1.2 (f) Nature of Comment: Support with conditions

1.2 (f) Development proposals need to have regard to the safety and ease of movement of cyclists and pedestrians by: ensuring ensuring separate footpaths and cycle ways; cyclists and pedestrians have safe and easy crossing facilities; secure cycle parking is provide. I would also support areas in the borough being subjected to environmentally friendly motor vehicles and improved footpaths and cycle ways together with charging points in all car parks in appropriate locations in all of the borough neighbourhoods. Response: Noted.

Detailed policies relating to cycling etc will be included in the Development Management policy document. In line with the emerging Replacement London Plan provision will be made in the future for car charging points and the car parking standards will be reviewed in the light of this requirement. Outcome: Accepted conditionally. Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

Name Organisation Policy Reference Transport for London Statutory 1.2 (f)

69 Nature of Comment: Support with conditions

TfL has some concerns with the way the Development Strategy (initial proposal 1.2 and appendix 4) addresses car parking although the approach based on maximum parking standards is welcomed. The suggested standards should be in line with those in the adopted London Plan and should also take account Table 6.1 of the draft replacement London Plan. While most of the standards are consistent, there is a slight discrepancy relating to smaller food stores. The requirement for electric car charging points, as mentioned in the Development Management document needs to be included in the car parking standards tables. The draft replacement Plan states that 20% of all residential spaces must be for electric vehicles (or one point per five car parking spaces), with an additional 20% passive provision. For commercial development the target is 20%, with a further 10% passive provision, and for retail 10%, with a further 10% passive provision. The concept of car clubs is supported by TfL, but the Council needs to ensure that these are not used in conjunction with high car parking levels, as the document seems to suggest, but instead they should be used along side restrained car parking provision to encourage sustainable travel. This will ensure compliance with London Plan policies 3C.23, 3C.24 and Policy 6.13 of the draft replacement Plan.The Development Strategy must include minimum cycle parking standards. These should be in line with Table 6.2 of the draft replacement London Plan, or higher where local circumstances allow. The commitment to cycling improvements is welcomed. However, the proposed cycle superhighway, which will link Park Royal to Hyde Park Corner, should be referenced. The potential for cycle docking stations to allow for future expansion of the Mayor’s London cycle hire scheme should also be considered within the Development Strategy. These will ensure the document complies with London Plan Policy 3C.22 and Policy 6.9 of the draft replacement Plan.

The Development Strategy must include minimum cycle parking standards. These should be in line with Table 6.2 of the draft replacement London Plan, or higher where local circumstances allow. The commitment to cycling improvements is welcomed. However, the proposed cycle superhighway, which will link Park Royal to Hyde Park Corner, should be referenced. The potential for cycle docking stations to allow for future expansion of the Mayor’s London cycle hire scheme should also be considered within the Development Strategy. These will ensure the document complies with London Plan Policy 3C.22 and Policy 6.9 of the draft replacement Plan. Response: Noted.

Pending the outcome of the review, appropriate amendments will be incorporated into the Development Strategy and the Development Management policy document.

70 Chapter 2: Uxbridge Road/Crossrail Corridor

Name Organisation Policy Reference Trustees of Blackrock Property Group Business 2 Nature of Comment: Support Support is offered for the intention to concentrate development within the Uxbridge Road/Crossrail Corridor, and it is believed that Hanwell Town can play an important role in achieving the outlined growth targets. Response: Support welcomed. Outcome: No change required.

Name Organisation Policy Reference Hovedean Properties Business 2 Nature of Comment: Support

The proposed addition of a Crossrail at Southall is supported. It is believed that the opportunity sites near the Rail Station are suitable for taller Landmark buildings. These will be required as the overall demand and distribution of new development will be altered due to substantial pressure for physical, economic and social change in the Southall area. Response: Support welcomed. Outcome: No change required.

Initial Proposal 2.1

Name Organisation Policy Reference Royal Mail Business 2.1 Nature of Comment: Support

Chapter 2: Development in the Uxbridge Road/Crossrail Corridor - In this Chapter we note that the arrival of five proposed Crossrail stations in Ealing will be a substantial addition to Ealing’s transport infrastructure. In addition they will not only underpin physical, economic and social change in this corridor, but will also fundamentally alter the overall demand for new development and the spatial distribution of development in proximity to each Crossrail station. This Chapter also details the Councils initial proposals for the regeneration of a number of areas in the Borough, including Acton, Ealing, Southall and Hanwell. Additionally, Maps 3, 4 and 5 of this Document identify potential locations for future employment and housing sites within these towns/areas. We understand that the Council has not yet identified the exact locations for allocated employment and housing sites and that this will be provided in the emerging Site Allocations Development Plan Document. Royal Mail supports the broad spatial objectives of the initial proposals for the regeneration of these town centres/areas. However, in light of the Council’s forecasted rise in the Borough’s population from 323,600 to 354,100 between 2011 to 2026 (Background Report – Population and Household Projections page 14) we submit that the Council should take into consideration the increased demands and pressures this will place on Royal Mail’s operations in the Borough when developing the detailed policies for the town centres/areas. Response: Support welcomed.

Royal Mail will be contacted as part of the Infrastructure Development Plan process. The Development Sites policy document will make provision for this type of development. Outcome: Accepted conditionally. Include Royal Mail as part of IDP engagement.

Name Organisation Policy Reference Government Office for London Statutory 2.1 Nature of Comment: Support with conditions

Retail: We recommend that the floor-space targets for each town centre are set out in a retail summary table, as well as within town centre policies, with reference to the evidence base. A clear sequential town centre policy is also required. (See PPS6 paragraphs 2.15 – 2.18) Response: Noted.

A clearer reference will be made to the retail hierarchy in the text of the Development Strategy. The Retail Needs Study will help to inform floorspace targets for individual centres. Outcome: Accepted. Feed in outputs of RNS and clarify retail hierarchy in the final text.

Name Organisation Policy Reference Hillingdon Motorist Forum Community/Voluntary Organisation 2.1 Nature of Comment: Support with conditions

Chapter 2 Developments in the Uxbridge Rd / Cross rail Corridor. Town Centre shopping facilities are mentioned. Provision of adequate parking is necessary if they are to match the ease of access and convenience of out of town shopping centres and supermarkets. Response: Not accepted.

The character and attractions of town centre shopping are different from edge-of-town retail. However, the current proposal is also to carry over existing standards to new development. Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 2.1 Nature of Comment: Object/comment

Initial Proposal 2.1 Realising the potential of the Uxbridge Road/Crossrail Corridor - We have considerable reservations about the proposal to build a further 9,364 housing units along the already densely developed Uxbridge Road/Crossrail Corridor. This road and rail corridor is already experiencing considerable pressures. These include: • shortage of community medical facilities, • shortage of educational facilities, • high levels of road congestion, • inadequate north-south orbital bus routes, • peak hour congestion on the main line rail services, according to the GLA. The consultation document states on page 50 that an ‘Infrastructure Delivery Plan’ will be prepared and states that this, “will set out the infrastructure required to support existing and new development.” It is unfortunate and regrettable that public consultation on the Development Strategy has taken place without this key input. The concentration of development along the Crossrail Corridor is predicated on the assumption that the residents of the 9,000 plus additional housing units will commute to and from work via Crossrail and the main line railway network. Such a fundamental assumption needs to be supported by detailed evidence and analysis. This evidence base appears to be missing from the consultation documents. The concept of an Uxbridge Road/Crossrail Corridor appears reminiscent of the ‘ribbon development’ of the 1930’s. The width of the proposed corridor extends into and encroaches on the adjoining residential districts and communities. The discrete nature of these communities should be reinforced and enhanced by the strategic planning process, rather than subsumed into a continuous development corridor over a mile wide.

Travel patterns of New Residents and their Children - More information needs to be obtained and shared on the probable travel patterns of the 9,000 plus additional housing units to be located along the Uxbridge Road/Crossrail Corridor. It is unlikely that they all will use the east-west rail and bus links. A significant proportion can be expected to use the north-south orbital routes and add to

72 the congestion referred to in the consultation documents.

In addition to these new residents commuting to and from their place of work, a significant number of additional journeys can be expected if educational provision is located in the residential hinterlands rather than within or alongside the new residential developments in the Uxbridge Road/Crossrail Corridor. Response: Noted.

Infrastructure development will be considerably assisted by new development in the Borough and the shape and form of necessary new provision will be informed by the Infrastructure Delivery Plan which is now in progress. Without the enabling factor of new development it is unlikely that improvements to existing infrastructure will be possible.

The analogy of ribbon development is misplaced as the identified corridors for growth are located in the centre of an urban area. These corridors constitute the core of the Borough and serve their own populations as well as those of the residential hinterlands. As in any settlement, these core areas will see the greatest change and development and will yield the highest densities. Monitoring will review the targets, if infrastructure delivery doesn’t meet the delivery plans then these will be revised.

Transport in London, as in any large urban area functions on a network principle, so no assumption about the travel habits of incoming residents is made. Access to London’s integrated transport system allows modal change and journeys on a wide variety of routes. The development of CrossRail will only increase transport provision and choice. Locating development in the most accessible areas of the Borough, judged by PTAL rating, is the most sustainable option for growth.

The corridors are indicative and do not reflect political or administrative boundaries. They are not blanket areas for demolition and redevelopment but search areas which will guide development. The Development Strategy will include descriptions of each community and its relationship to the corridor. Outcome: No change.

Name Organisation Policy Reference SEGRO Business 2.1 Nature of Comment: Support with conditions

The Uxbridge Road / CrossRail Corridor - We note that it is proposed that this area will accommodate circa 9,350 residential units [85% of the Borough’s overall target], but only 450,000 sq.ft of class B space [42% of target]. We question whether it is robust to rely upon one area to provide such a significant proportion of overall growth area targets and are concerned that there should not be an over-reliance on this area alone for the majority of the Borough’s housing, as there are, for example, risks associated with the delivery and timing of Crossrail, which could delay site delivery and undermine housing trajectories. We would also suggest a more balanced provision of housing to employment between this area and the A40 corridor, see below. Response: The development corridors constitute the core of the borough and serve their own populations as well as those of the residential hinterlands. As in any settlement, these core areas will see the greatest change and development and will yield the highest densities. Monitoring will review the targets, if infrastructure delivery doesn’t meet the delivery plans then these will be revised.

Access to London’s integrated transport system allows modal change and journeys on a wide variety of routes. The development of Crossrail will only increase transport provision and choice. Locating development in the most accessible areas of the borough, judged by PTAL rating, is the most sustainable option for growth. Outcome: No change.

Name Organisation Policy Reference National Grid Property Holdings Business 2.1 Nature of Comment: Support

Initial Proposals 2.1 - NGP support the proposal to realise the potential of the Uxbridge Road/Crossrail Corridor, which includes Southall and the Southall Gas Works site, for development. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Greater London Authority Statutory 2.1 Nature of Comment: Support with conditions

The areas affected by Crossrail, including the Uxbridge Road/Crossrail corridor, Acton Mainline Station Area, and Ealing Town Centre should include a requirement for relevant proposals to contribute towards crossrail. Response: Support welcomed.

The Council’s IDP will help establish priorities for planning obligations across the borough. The draft SPD on Legal Agreements will be progressed to adoption in June 2012.The Local Planning Authority will consider whether to adopt CIL alongside s106 in due course. Outcome: Accepted. Include reference in footnote. Further detail to be provided in the Infrastructure Delivery Plan and SPD on Legal Agreements.

Name Organisation Policy Reference Hovedean Properties Business 2.1 Nature of Comment: Support with conditions

We recommend the inclusion of the land known as the Middlesex Business Centre to be included within the new TC boundary as a mixed business and residential area. We believe that the development opportunity sites immediately near Southall Rail Station can be developed to include a similar brand offer as 'neighbourhood shopping centre' with cultural amenity provisions connecting the town centre with the East-West canal link, new shops and community offers that link towards the Havelock Estate. Response: This site will be included in the Employment Land Review, along with all other major employment sites. Town Centre boundaries are designed to consolidate retail functions, there is no need to include retail or employment areas within town centres to facilitate these uses. Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 2.1 Nature of Comment: Object

Initial Proposal 2.1 Realising the potential - This Initial proposal sets out the vision and deliverables for the Uxbridge Road/Crossrail Corridor. Additional development at South Ealing/Northfields and at Ealing Broadway is wholly unreasonable without additional tube capacity. There should be provision for enhanced tube capacity as part of this proposal. Response: Noted.

Proposals are intended to compliment the development proposals of TfL. The CrossRail

74 programme, which has already commenced construction, will add significant capacity to the East- West routes in London. No proposals for major development at South Ealing/Northfields are made in the DS. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 2.1 Nature of Comment: Object

Initial Proposal 2.1 - See Executive Summary plus (d) The Tibbalds report outlined distinctive quarters for Ealing and it would suggest that the only part of the corridor in the metropolitan area that would be suitable for tall buildings would be the Office Quarter yet the council has approved developments that go against these proposals and will lead to conservation areas within the corridor losing their existing character. (f) The Council commissioned various Conservation appraisals and before any development takes place the improvements suggested in the documents should be acted upon. This is a quote from the Hanwell Clock Tower document but applies to all town centre conservation areas- 'The overall condition of most fabric in the CA is sound, but shabby. A visitor from elsewhere would have difficulty in appreciating that this is designated as an historic area where preservation should be paramount, in most cases however, regular maintenance, retention or reinstatement of original features, one-off gentle cleaning of brickwork, removal of redundant, excessive, lurid or internally illuminated signage and encouraging higher quality shop fronts will bring about substantial enhancement and ensure the preservation of the area's character for the future'. This was written in 2007 and all that has happened is that the inevitable hanging baskets have appeared and the pavements are being redone. Nothing has happened to the fabric of the buildings or the shop fronts. There needs to be a stronger planning policy in place for conservation areas. Response: Noted.

The corridors are indicative and do not reflect political or administrative boundaries. They are not blanket areas for demolition and redevelopment but search areas that will guide development. The preamble to the Development Strategy will include descriptions of each community and its relationship to the corridor. Regeneration is one of the driving forces behind the Development Strategy. It is difficult to see improvements to existing areas occurring, especially of the sensitive and expensive nature required by historic buildings, without the catalyst provided by new development. Outcome: No change.

Name Organisation Policy Reference Katharine Brooks Resident 2.1 Nature of Comment: Support

I support Crossrail and the need to increase Housing supply, but feel that 14,000 new homes is too high given the current population density. Response: Support welcomed.

The development proposals and their infrastructure requirements are informed by the Strategic Housing Needs Assessment and the forthcoming Infrastructure Delivery Plan. Both outputs of the Development Strategy will be monitored and subject to modification and adaptation in the event that their objectives are not realised. Outcome: No change.

75 Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 2.1 Nature of Comment: Comment

The population in Central Ealing will be increased by the developments shortly to be built however I cannot comment on the other areas of the borough. Response: Noted. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.1 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 2.1 Nature of Comment: Object

Crossrail may never happen. Uxbridge Road is already overused and congested. Response: Not Accepted.

The Government and the Mayor of London are both given strongly committed to Crossrail. We believe it will have a transformational effect and the viability of development quantums proposed would be undermined if this project did not proceed. The council’s Infrastructure Delivery Plan will examine contingencies and risks in the event the project is delayed/shelved. The development corridors constitute the core of the Borough and serve their own populations as well as those of the residential hinterlands. As in any settlement, these development corridors will see the greatest change and development and will yield the highest densities. Monitoring will review the targets, if infrastructure delivery doesn’t meet the delivery plans then these will be revised. Access to London’s integrated transport system allows modal change and journeys on a wide variety of routes. The development of Crossrail will increase transport provision and choice. Locating development in the most accessible areas of the Borough, judged by PTAL rating, is the most sustainable option for growth. Outcome: No change.

Name Organisation Policy Reference Carrie Sharman Resident 2.1 Nature of Comment: Object

Initial Proposal 2.1 - I will not comment further as my concerns largely affect the entire set of assumptions on which all the smaller plans reside. I believe the plans need to fundamentally re- examine the world context of the future you are building in Ealing. Response: Noted.

Name Organisation Policy Reference Peter L Flatau Resident 2.1 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Siobhan Martin Resident 2.1 Nature of Comment: Comment

Given that the A40 within Ealing’s boundaries goes out as far as Northolt, then why isn’t there any proposed development incorporated along the length of this road, and was this influenced by the Park Royal Partnership and the expansion of the Industrial area? Response: Noted. Park Royal is an industrial and business site of region-wide importance and serves more than just Ealing Borough’s economic needs. There are also significant issues of accessibility and viability which limit the development potential of this corridor. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 2.1 Nature of Comment: Object

This is obviously a developer led rather than a holistic approach; Worsens over-intensive east/west pressures; marginalises other locations suited to lower cost/less dense/more family friendly housing; Drains yet more vitality from other town centres; threat to many conservation areas and heritage assets; No incentive for TFL/transport operators to remedy deficiencies in north-south provision. Response: Not accepted.

A holistic approach requires precisely the assessment of constraints and opportunities that informs the approach taken by the Development Strategy. The identified corridors constitute the core of the Borough and serve their own populations as well as those of the residential hinterlands. These hinterlands are residential environments that extend out to the edges of the Borough, in many places to Green Belt or Metropolitan Open Land.

As in any settlement, the development corridors will see the greatest change and development and will yield the highest densities. Monitoring will review the targets, if infrastructure delivery doesn’t meet the delivery plans then these will be revised. Both the green space and the residential hinterlands are areas with more constraints to development than the more rapidly changing urban core. Locating development in the most accessible areas of the borough, judged by PTAL rating, is the most sustainable option for growth.

The development corridors are indicative and do not reflect political or administrative boundaries. They are not blanket areas for demolition and redevelopment but search areas that will guide development. The Development Strategy will include descriptions of each community and its relationship to the corridor. Outcome: No change.

77 Name Organisation Policy Reference Transport for London Statutory 2.1 Nature of Comment: Support with conditions

References to ‘new’ Crossrail stations should be amended to refer to the ‘refurbishment of four stations’ in order to avoid confusion within the document. Although it will be served by Crossrail, as far as TfL is aware there are no improvements planned at Hanwell Station Response: Support welcomed. Outcome: Accepted. Amend text as suggested.

Initial Proposal 2.1 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.1 (a) Nature of Comment: Object

The area identified covers protected open space, conservation areas and even those with poor public transport accessibility as having potential for development. We object strongly because the points made in a) and b) form an overwhelming pressure to ignore d). Response: Not accepted. The development corridors are indicative and do not reflect political or administrative boundaries. They are not blanket areas for demolition and redevelopment but search areas that will guide development. The Development Strategy will include descriptions of each community and its relationship to the corridor. Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 2.1 (a) Nature of Comment: Object

We share the concerns expressed by the Council’s of Director Housing, and approved by the Council’s Cabinet at their meeting on 4th December 2007, that Ealing town centre is not an appropriate location for family housing due to the lack of suitable amenities. While this opinion was expressed in terms of affordable housing, we believe that it is equally applicable to full market price housing. We would also suggest that these concerns should apply to all high density housing developments whether they are located in Ealing town centre or elsewhere along the Uxbridge Road/Crossrail Corridor Response: Not accepted.

In 2009 the council carried out a new Strategic Housing Market Assessment to form the evidence base for the LDF and a new Housing Strategy. The key objectives of the study are to enable the Council to understand the nature and level of housing demand and need within the borough and to provide a robust and credible assessment of the local housing market with which to inform its policies and strategies. Data is fed into the Department of Communities and Local Government Needs Assessment model and showed an annual shortfall of affordable housing totalling over 2,500 units. Further analysis on a geographical basis concluded that a high level of demand for affordable housing fell in the Ealing area, particularly for 2 and 3 bed units. A copy of the Housing Strategy including evidence from the Strategic Housing Market Assessment can be found on the council’s website. Outcome: No Change.

78 Name Organisation Policy Reference West Ealing Neighbours Community/Voluntary Organisation 2.1 (a) Nature of Comment: Object

2.1 Realising the potential of the Uxbridge Road/Crossrail Corridor - Building 85% of the additional borough’s net total increase in housing along this corridor seems excessive and we reiterate our earlier point about there being no evidence of any alternative strategy. Again, without any detail on the proposed improvements to local infrastructure we cannot see how such an increase can be successfully accommodated. Again, we read many fine words but past experience leads us to be highly sceptical that adequate provision will be made in terms of sustainable facilities and resources for local residents whether for leisure activities, school provision or healthcare. Response: Not accepted.

Locating development in the most accessible areas of the borough, judged by PTAL rating, is the most sustainable option for growth. These development corridors serve their own populations as well as those of the residential hinterlands. As in any settlement, these core areas will see the greatest change and development and will yield the highest densities. Monitoring will review the targets, if infrastructure delivery doesn’t meet the delivery plans then these will be revised. Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 2.1 (a) Nature of Comment: Object

No further comment. Response: Noted.

This respondent’s concerns are addressed elsewhere, where they are put more explicitly. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.1 (a) Nature of Comment: Object

2.1 (a) It is not possible set a housing target when there is no accurate information on London's population. Also, housing need can be met from utilizing existing stock Response: Not accepted.

The development proposals are informed by the Strategic Housing Needs Assessment. There is no evidence that there is adequate surplus in the existing housing stock to serve any significant increase in demand and abundant reason to believe that there is already a significant shortfall in supply locally as there is both nationally and across the Region. Outcome: No change.

Initial Proposal 2.1 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.1 (b) Nature of Comment: Object

79 Response: Not accepted.

Regeneration is one of the driving forces behind the Development Strategy. It is difficult to see improvements to existing areas occurring, especially of the sensitive and expensive nature required by historic buildings, without the catalyst provided by new development. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.1 (b) Nature of Comment: Object

2.1 (b) There is existing floorspace available in the Mall. There is also space available in the western international market and in the Hayes/Southall border and probably all around London Response: Not accepted.

Evidence from the Retail Needs Assessment does not find sufficient floor space available in current build to meet the demand projected over the plan period. Outcome: No change.

Initial Proposal 2.1 (c)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.1 (c) Nature of Comment: Support with conditions

Crossrail is supported but not if it causes the termination of Greenford trains at West Ealing. If buses are increased along the Uxbridge Rd. congestion will delay traffic so that vehicle movement becomes is too slow. Housing schemes should be delayed until crossrail is completed. Response: Support welcomed.

The council supports the building of a new railway track between West Ealing and Ealing Broadway however acknowledges that it is unlikely to be affordable during the plan period. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.1 (c) Nature of Comment: Support

2.1 (c) Improvements to bus services need to be agreed by all political parties in the GLA and improvements to bus designs are also required. Response: Noted.

Outcome: No change.

Initial Proposal 2.1 (d)

Name Organisation Policy Reference JK Gill Resident 2.1 (d) Nature of Comment: Support

2.1 (d) A laudible aim, but difficult to achieve given the opposition present in relation to Dicken's Yard and the Gasworks site in Southall Response: Support welcomed. Outcome: No change.

Initial Proposal 2.1 (e)

Name Organisation Policy Reference Ealing Transition Steering Group Community/Voluntary Organisation 2.1 (e) Nature of Comment: Comment

Specific Considerations - 5. Waste - Currently food waste from the borough is transported to a site in Bedford to be anaerobically digested. Whilst the councils/West London Waste Authorities decision to adopt this technology should be commended, the transportation of a valuable renewable energy feedstock out of the borough should be viewed as a short-term strategy. The adoption of micro scale anaerobic digesters to generate electricity on both new and existing housing developments should be considered as a longer term aim. world in 2026, the impact of new technologies etc, despite the wide availability of such reports (see e.g. Henley Centre). All of this makes it difficult for those reading the report to imagine a future Ealing. Making the borough ‘an attractive place to live and work at the heart of west London’ merely articulates present realities. The London Plan’s rallying cry - ‘lean, clean, green’- whilst not a vision as such, is certainly a catchy articulation of intent, and one which will motivate and inspire. Based on feedback from our members, there is no doubt that the length and complexity of the LDF is deterring people from engaging with it meaningfully. Response: Noted.

Regional policy is to move to full self-sufficiency in waste treatment. Ealing is following this approach with the production of a joint waste DPD with the other West London Boroughs, so this change in current practice is already in hand.

Outcome: No change. Further information to be provided in the West London Waste Plan DPD.

Name Organisation Policy Reference JK Gill Resident 2.1 (e) Nature of Comment: Object

2.1 (e) I object to this on a number of grounds, as per my official objection dated 30 December 2009 and 15 July 2009 Response: Noted.

This respondent’s concerns are addressed elsewhere, where they are put more explicitly. Outcome: No change.

81 Initial Proposal 2.1 (f)

Name Organisation Policy Reference Trustees of the Blackrock Property Fund Community/Voluntary Organisation 2.1 (f) Nature of Comment: Object/Support

We believe that the Council that the proposal to reconfigure the boundaries of Southall Town Centre should be extended to other Town Centres along the corridor where appropriate, such as Hanwell. Therefore we object to the preference to reaffirm the existing boundaries of Hanwell Town Centre.

We support the vitality and future sustainability of each town centre Response: Not accepted.

Initial proposal 2.7 proposes measures to enhance and consolidate Hanwell town centre. This will be informed by an update of the retail Needs study due to published shortly. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.1 (f) Nature of Comment: Object

2.1 (f) There is a big emphasis on shopping at local town centres, however it is questionable how much money people can actually spend in the middle of a recession. Response: Noted.

The approach focuses on share of spend rather than just increasing the level of spend overall. It should also be borne in mind that the plan period extends to 2026 and any outlook must cover the medium/long-term not just the short-term. Outcome: No change.

Initial Proposal 2.2

Name Organisation Policy Reference Greater London Authority Statutory 2.2 Nature of Comment: Support with conditions

Acton Town Centre: The regeneration of the TC is supported. Further consideration should be given to the proposed approach to office uses within the TC, particularly as part of a wider residential or mixed-use development. Response: Support welcomed.

A mix of uses, including office uses, will be encouraged as part of any future development/redevelopment in Acton town centre. This will be informed by an Employment Land Review which is currently being undertaken. This will analyse the role and function of existing employment sites within the context of the emerging development strategy and will identify new sites that would be suitable for additional employment uses within the borough. This document will be used in tandem with the Development Sites policy document to identify the location of proposed housing, employment and other uses and will support the overall strategy and vision. Outcome: No Change.

82 Name Organisation Policy Reference Michael Simmons Resident 2.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 2.2 Nature of Comment: Object

Initial Proposal 2.2 - Please see executive summary - Re: Town Centres- There should be a planning policy in place in regard to vacant flats above shops before any development takes place. There should also be a policy with regard to which part of the population can be housed in town centres. There is also an emphasis on how excellent the transport links are but it is never mentioned how overcrowded and unreliable the transport is. Parts of Ealing and Acton are conservation areas and therefore not suitable for high-density development or tall buildings. Plus, having looked at the development framework for Acton the Council needs to look at empty premises above shops, conservation issues and other pressing social issues before creating a more fundamental development plan. Acton is a good example where the council has chosen not to invest in the upkeep of buildings so that they fall into such a state of disrepair that they are no longer viable. Response: Noted.

Realising underutilised assets is a key element of the development strategy, however it must be understood that some of these, such as unused accommodation above shops may not be achievable without wider regeneration of neighbouring uses. The broader development strategy is therefore fundamental to achieving even these smaller changes. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 2.2 Nature of Comment: Comment

There needs to be a non - vehicle area larger than as proposed Response: Not accepted.

The proposed level of provision is deemed adequate. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

83 Name Organisation Policy Reference Peter L Flatau Resident 2.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 2.2 Nature of Comment: Support

'Natural Surveillance' public realm needed through to South Acton Estate. Reassess retail floorspace in relation to Westfield. Response: Support welcomed.

The Retail Needs Assessment will provide robust evidence of the quantity of retail space needed in the Borough over the plan period. Principles of ‘Secured by Design’ are required by the regional spatial strategy and will therefore be the subject of all planning decisions. Outcome: No change.

Initial Proposal 2.2 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.2 (a) Nature of Comment: Object

Initial Proposal 2.2 (Regenerate Acton town centre) a) and b) are objected to because the wording is so general it is impossible to tell what will happen to existing town hall, swimming pool or other buildings that make an important contribution to the conservation area. These important municipal buildings should be retained largely in community use. Response: Noted.

The Development Sites policy document, which will set out specific policies for the development of key sites, areas and locations in the borough. It will outline in greater detail the suitability of individual sites for facilitating different uses and densities, based on individual merits. This includes any proposals for land and buildings on significant sites that are likely to be subject to development proposals during the plan period i.e. 2011-2025. These allocations are intended to assist in delivering the priorities and objectives of the 2026 Development Strategy. More detailed maps for each site will be provided in tandem with this document. Outcome: No change.

Further detail to be provided in the Development Sites policy document.

Name Organisation Policy Reference JK Gill Resident 2.2 (a) Nature of Comment: Object

2.2 (a) If the council is proposing to develop existing buildings I would not object, however I would object if it is proposed to build new floor space and new buildings

84 Response: Not accepted.

Development will use old and new buildings as is most appropriate in individual cases. It is unrealistic and would be counter-productive to expect no new building to occur in Acton Town Centre over the plan period. Outcome: No change.

Initial Proposal 2.2 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.2 (b) Nature of Comment: Object

Further detail to be provided in the Development Sites policy document.

Name Organisation Policy Reference JK Gill Resident 2.2 (b) Nature of Comment: Object

2.2 (b) There is no explanation as to how this calculation has been arrived at. Response: Not accepted.

Footnote 17 explains that this is the identified potential from ‘large’ sites (those which yield 10 or more units). A breakdown is provided in Background Paper 3: Housing. Outcome: No change.

Initial Proposal 2.2 (c)

Name Organisation Policy Reference JK Gill Resident 2.2 (c) Nature of Comment: Support

No further comment. Response: Support welcomed.. Outcome: No change.

85 Initial Proposal 2.2 (d)

Name Organisation Policy Reference Government Office for London Statutory 2.2 (d) Nature of Comment: Support with conditions

You will need to establish and make clear whether this infrastructure is critical to achieving the objectives for that location, and how this infrastructure will be delivered. Information should be provided on the need, cost, funding sources, phasing and who will deliver specific infrastructure, particularly for the earlier phases of the Core Strategy. Response: Support welcomed.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development, up to 2026. Detail will also be provided on the need, costs, funding sources and phasing that will be necessary for the delivery of the proposed items of infrastructure. Outcome: Accepted conditionally. Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference JK Gill Resident 2.2 (d) Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Initial Proposal 2.2 (e)

Name Organisation Policy Reference JK Gill Resident 2.2 (e) Nature of Comment: Support with conditions

2.2 (e) There is no mention of how this will be achieved but in general terms it seems acceptable. Response: Support welcomed. Outcome: No change.

Initial Proposal 2.3

Name Organisation Policy Reference Michael Simmons Resident 2.3 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

86 Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.3 Nature of Comment: Object

Initial Proposal 2.3 (Regenerate South Acton) The need to increase the number of housing units is resulting in a most unattractive redevelopment. The open space deficiency should be rectified by a range of play and leisure facilities some of which could be in Gunnersbury Park which is the nearest metropolitan park. Safe access to this park should be improved. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed (including Open Space and playspace) to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. The Council’s Open Space Strategy is also currently being produced and will inform the IDP. Outcome: Accepted conditionally. Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference Susan New Resident 2.3 Nature of Comment: Object

Initial Proposal 2.3 - See initial proposal 1.1 'The council should employ a visionary consultant who can reinvent the housing estates so that they are integrated into the general fabric of an area so that they are no longer separate from the rest of the community and there should be no high rise buildings built for families'. Response: Noted. The council is promoting a major investment and regeneration programme to transform many of its homes, estates, town centres and neighbourhoods. It aims to provide residents with the best possible homes and housing services that will match the standards that they have told us they want. These ambitious plans seek to transform parts of the borough that need significant investment, care and attention as well as boost the economic, social prosperity and quality of life for our residents. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 2.3 Nature of Comment: Object

More of a Community Action plan is required to regenerate this area Response: Noted. CAPs are an essential tool in urban regeneration, however, the enabling potential offered by new development makes this an equally necessary device for regeneration where both development interest and opportunity are present. CAPs are a community-lead initiative and it is not for the Council to initiate these or set their agenda. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.3 Nature of Comment: Support No further comment. Response: Support welcomed. Outcome: No change necessary.

Name Organisation Policy Reference Peter L Flatau Resident 2.3 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 2.3 Nature of Comment: Object

Initial Proposal 2.3 - This large area needs new social and community infrastructure to support the new homes. No hint of infrastructure. Currently 2,000 residents occupying 62 acres. Less new homes and more social and community infrastructure required. Response: Not accepted.

Infrastructure development will be considerably assisted by new development in the Borough and the shape and form of necessary new provision will be informed by the Infrastructure Delivery Plan that is in preparation. It should also be borne in mind that without the enabling factor of new development it is unlikely that improvements to existing infrastructure will be possible. Outcome: No change. Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference JK Gill Resident 2.3 Nature of Comment: Comment

2.3 The document does not state how this will be achieved Response: Noted.

As with other objectives contained within the Development Strategy, regeneration in South Action will be realised by harnessing the potential of new commercial sector development and implementing social facilities through public spending programmes. Outcome: No change.

Initial Proposal 2.4

Name Organisation Policy Reference Government Office for London Statutory 2.4 Nature of Comment: Support with conditions

88 workplaces and other forms of development, up to 2026. Detail will also be provided on the need, costs, funding sources and phasing that will be necessary for the delivery of the proposed items of infrastructure. Outcome: Accepted conditionally. Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference Michael Simmons Resident 2.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 2.4 Nature of Comment: Comment

This needs to be based on carbon neutral, sustainable building - not more of the same. Response: Noted.

Carbon neutrality for residential development is to become the national standard by 2016 and will therefore likely constitute the majority of new development that occurs during this plan period. Non-residential uses are also expected to reach carbon neutrality during the plan period, notionally in 2019 although this has yet to be confirmed, and is sufficiently far in the future that this timetable may yet be realigned. However, there is yet to be any substantive guidance from central government on a timetable to make transport carbon neutral, and the direction taken by the UK Low Carbon Transition Plan and the National Carbon Budget seems to indicate that the technological base in this sector is not yet sufficiently advanced to allow complete elimination of emissions from this sector. Instead, its emissions are budgeted to be off-set by reductions in other sectors. It is not within the Council’s legal powers or technological knowledge to vary significantly from this approach. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 2.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

89 Name Organisation Policy Reference Community/Voluntary Central Ealing Residents Association Organisation 2.4 Nature of Comment: Support

Rationalise freight yard area to realise additional public open space/green corridor opportunities. Also a temporary site base to service Crossrail construction elsewhere along the route needs to be identified. Response: Support welcomed.

The significance of rail routes as biodiversity corridors is well established. Variation in the size and from of rail infrastructure is at the discretion of Network Rail, as are arrangements for the construction of Crossrail. Outcome: No change.

Name Organisation Policy Reference Transport for London Statutory 2.4 Nature of Comment: Support

The status of some schemes within the Development Strategy should be clarified. TfL requests all references to ‘fastbus’ are removed and replaced with more appropriate wording such as ‘aspiration for a high frequency bus route between Ealing and Wembley via Park Royal, with bus priority measures introduced along the route where appropriate’. Response: Support welcomed. Outcome: Accepted. Amend text as suggested.

Name Organisation Policy Reference JK Gill Resident 2.4 Nature of Comment: Support

Any improvements must be in tandem with the crossrail proposals Response: Support welcomed.

It should be noted that all transport in London is co-ordinated by TfL and the council will continue to press for improvement s in public transport, see Initial proposal 4.4. Outcome: No change.

Initial Proposal 2.4 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.4 (a) Nature of Comment: Support with conditions

Renewal of the station is supported but there is no room for a bus interchange. Response: Noted.

Further studies will be need to be undertaken to identify and develop a bus/train interchange near Acton Main Line station. The amount of space for an interchange need not be large and, subject to

90 the study, could be accommodated on the highway close to the station. Relatively small scale interchange improvements, such as shelters, passenger information and pedestrian crossings etc, that are well located and well designed can provide significant benefits for public transport users, and the Council will exploit all reasonable opportunities to achieve better interchanges in parallel with bus network improvements. Outcome: No change.

Initial Proposal 2.4 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.4 (b) Nature of Comment: Object

This is too vague. What mixed uses are proposed? Retail would detract from Acton Town Centre and the grouping of high rise residential buildings in this area would result an increase in residents living in a noisy, polluted and visually unattractive environment. Response: Noted.

Mixed use suggests housing, retail and employment uses. The point of this mix is to serve need generated by new development and improve the quality of the environment. No typology is inherently unsuitable for residential buildings, their success is dependent on the quality of design and construction. Outcome: No change.

Initial Proposal 2.4 (c)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.4 (c) Nature of Comment: Object

This depot is a real eyesore creating dust and noise pollution. Local residents would like to see it relocated in a Major Employment Area. Significant amenity improvements are needed if it is to be retained including the replacement of advert hoardings by trees. Response: Noted.

However, it is beyond the remit of this review. Outcome: No change.

Initial Proposal 2.5

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.5 Nature of Comment: Object

We object to the use of the Tibbalds report (which is not adopted policy) to guide and inform the development of the town centre. These functions should be based on survey, consultation and not on retail targets to justify Metropolitan Centre Status. Response: Not accepted.

The Development Strategy is based on evidence as well as consultation. The Tibbalds report is

91 valid evidence and is necessary to inform the development of policy. A supplementary planning documents is also to be prepared for the town centre. Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 2.5 Nature of Comment: Object/Support with conditions

Initial Proposal 2.5 Regenerate Ealing town centre - We share the aspiration to regenerate Ealing town centre and believe that this would best be achieved by close attention to urban design and in particular the enhancement of the Victorian and Edwardian historic buildings and frontages that contribute to its character and appearance. We suggest that there is much to be learnt from the examples of recent town centre regeneration in nearby Richmond and Uxbridge. In the case of Richmond the Quinlan Terry development has blended well into the historic town centre, while at Uxbridge the historic high street frontage has been retained as the exterior of the new Chimes shopping centre. The Council’s town planning consultants have identified that the predominant height of buildings in the town centre is between four and six stories high. This makes a major contribution to the character of the existing town centre. We therefore suggest that any redevelopment in the town centre should reflect current building heights and that tall buildings, whether residential or commercial, should be avoided other than alongside those which currently exist in the stretch of the Uxbridge Road referred to as the ‘Office Corridor’. We are unconvinced by the concept of one or more landmark buildings at the heart of Ealing town centre, for example at or near the station. There seems little point in having a landmark if road congestion and poor orbital links, both of which are acknowledged in the consultation documents, means that one cannot approach such a landmark. In such circumstances the landmark would only serve as the warning of a location which visitors should avoid. The analogy of the Eddystone lighthouse comes to mind.

Transport Interchange - The construction of a fully integrated undercover transport interchange with a bus station, taxi rank and drop-off area located directly above the platforms at Ealing Broadway Station would represent a major benefit to residents of the surrounding area and users of the town centre. This improvement should also contribute to an increase in town centre footfall and therefore the economic viability of businesses and cultural facilities. We therefore ask that the next edition of the draft Development Strategy places more emphasis on the need to construct a comprehensive transport interchange.

Culture - Cultural uses should be an integral element of the regeneration strategy for Ealing Town Centre. Richmond has two professional theatres, the larger one on the Green and the Orange Tree. Developers have recently donated the 1,000 seat Rose theatre to Kingston.

Richmond has three cinemas, two of which are multi screen and all of which are accessible to nearby parking and a wide choice of restaurants. Uxbridge included a multi-screen cinema as part of the Chimes shopping centre and located it next to a 1,500 capacity car park.

Cultural uses provide a major opportunity for regeneration and should figure more prominently in the Development Strategy.

Town Centre Status - There is an inconsistency between the draft Development Strategy and the information presented to the LDF Scrutiny Panel over the status of Ealing in the hierarchy of Greater London town centres.

Page 25 of the consultation document states, “The purpose of promoting improvements at Ealing Town Centre is to enhance that centre’s role as one of London’s top ten ‘metropolitan centres’.

This statement presupposes that Ealing town centre continues to meet criteria which are intended

92 to embrace the largest town centres in Greater London such as Croydon and Kingston.

Published GLA data indicates that Ealing is materially smaller than all of the other ten Metropolitan town centres in Greater London. This is after including West Ealing and the Uxbridge Road ‘Office Quarter’ within the boundaries of Ealing town centre.

The same GLA statistics show that Ealing is materially smaller than a number of the town centres which make up the next tier down in the London planning hierarchy. This lower tier is referred to as ‘Major’ town centres and includes the following locations which are larger than Ealing: Kings Road East, Kensington High Street, Lewisham, Bexleyheath, Wimbledon and Walthamstow. Richmond is only marginally smaller than the combined Ealing Broadway, Office Quarter and West Ealing definition of Ealing town centre.

Concerns have been raised in a number of Council documents and reports that Ealing may no longer operate as an integrated Metropolitan town centre.

Most recently Shared Intelligence, the Council’s latest planning consultants and whose work is referred to on page 7 of the consultation document, have said that there is a need to: “Review assumptions about Ealing’s position in London’s retail hierarchy in the light of the opening of Westfield Shopping Centre. Further work is required to establish the case and the preferred approach.” Recommendation 5.13. Retail is a key ingredient in the determination of a town centre’s ranking in the London planning hierarchy.

An officer report to the 25th March 2009 meeting of the LDF Scrutiny Panel identified that the Council needed to urgently update its retail needs and capacity assessment.

Shared Intelligence endorsed this need and stated in their report: “Review the evidence base for retail, commercial and residential demand across the Borough and assess how overall demand may be distributed across the Borough’s localities.” Recommendation 5.12

Background paper 5 to this consultation acknowledges that these urgent updates and reviews had not been completed prior to the preparation of the consultation proposals, documents and questionnaire. On page 10 the Background paper refers to the Borough’s evidence base and states, “In Preparation: Updated retail needs assessment (jointly with LB Hammersmith & Fulham; LB Hounslow).”

In these circumstances, we suggest that the assumption that Ealing town centre should continue to be classified as a metropolitan town centre is premature, and should be the subject of further consultation once up-to-date detailed supporting information has been produced and made available for review by members of the public. Response: Not accepted.

Ealing Town Centre occupies a strategically important point in West London and serves a far greater population than that of Ealing Broadway ward. The changed character of the built environment is a function of the changed role of the centre. The limited service provision in Ealing Town Centre relative to other Metropolitan Centres that the respondent identifies is exactly the problem that the Development Strategy is designed to address. It is unsustainable for the centre to continue to underprovide for so much of its hinterland and to offset the needs of the population outside of central Ealing to other centres in London. Evidence is in need of update because of its age, however, the more up-to-date evidence currently in preparation continues to show significant unmet need in the Borough.

Transport for London, which would provide necessary funding for any improvements at Ealing Broadway Station, considers that there is no business case for a comprehensive transport interchange. Improvements would be made even more difficult without contributory funding from

93 new development. Outcome: No change.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation 2.5 Nature of Comment: Comment

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 Tibbalds’ 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. Response: Not accepted.

The Tibbalds report is valid evidence and is necessary to inform the development of policy. A further review is being prepared together with a supplementary planning document for the town centre. Outcome: No change.

Name Organisation Policy Reference Dooba Investments VI Ltd Business 2.5 Nature of Comment: Comment

Our client agrees that the regeneration of Ealing Town Centre is a positive policy approach and that the development of 21,000 sq.m retail and 100,000 sq.m of replacement and new office space in the areas identified (including the office quarter along Uxbridge Road) should be promoted albeit that this should not be seen as a ceiling to further development. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 2.5 Nature of Comment: Object

Initial Proposal 2.5 Regenerate Ealing town centre - Redevelopment yes; but no additional housing without an increase in the tube service especially at peak times. Response: The metrics on which TfL services are determined are based on existing demand. Additional services will be difficult to attract without additional demand. In addition, contributions from development will greatly assist the improvement of station and ancillary facilities. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 2.5 Nature of Comment: Object Initial Proposal 2.5 - (a) I am vehemently opposed to the current developments at Dickens Yard and Arcadia. They are developer led not council led and are inappropriate for Ealing Town Centre.

94 There could be up to 2500 extra people living in the centre of Ealing without any social infrastructure, health and community facilities. If the council has a development framework it has to keep updating it as various factors change. In 2004 the BBC was one of the main businesses in Ealing. Westfield has been built. A different vision from just flats and shops was needed and the council should have worked with the developers to create a different visions for Ealing. It could have been done. (b) If an area is an office quarter you then should not allow hotels to be built in it. If the area is part of the cultural quarter, buildings should be for cultural purposes. At the moment the council lets anything be built. (c) I feel this paragraph has been written to justify the major developments already passed and certainly does not address an urban design policy. Trees and hanging baskets do not make a boulevard. The council never does anything interesting with the pavements. The Edwardians, as well as having beautiful shopfronts, had interesting tiling either in the doorways or along the front of the facade. And what about the shopfront guidance leaflet in conservation areas? (d) Ealing does not need a bus interchange; it needs a 21st Centrury transport interchange to accommodate the current population. (e) What new health centre and what cultural facilities? The new health centre is yet to materialize. Ealing Town centre supposed to be a part of a metropolitan centre but Richmond, which isn't, boasts 3 cinemas, 2 theatres, arts centres and sports facilities. The Town Hall cannot possibly hold all the facilities needed for a thriving metropolitan centre as well maintaining what currently happens in the building. All the current cultural activities in Ealing are run on a voluntary basis except for the barely open Pitshanger Manor and Gallery and the odd few days in the summer given over to culture. (f) I don't quite know where the number of six and a half thousand jobs comes from but given that the two new developments are mainly retail and restaurants the people who work in these developments will have some of the lowest wages in the country. Response: Not accepted. Employment figures are subject to current update in the form of the Employment Land Review, and growth is anticipated to be across a variety of sectors not just retail. The infrastructure delivery plan will also outline all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 2.5 Nature of Comment: Object

The population in Central Ealing will be increased by the developments shortly to be built however I cannot comment on the other areas of the borough. Response: Noted.

Population increase is projected to occur across the region and it is unrealistic to believe that Ealing can be excluded from this. It is preferable to plan for this change constructively. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 2.5 Nature of Comment: Object

No vision and no idea of user friendly approaches. Where's the green feel Response: Not accepted.

The Development Strategy only sets out the broad view of development. Complimentary and subsidiary DPDs/SPDs will develop this. Sustainable development has as much to do with the strategic location of development in relationship to other uses and within the borough as a whole as

95 it does with specific ‘green’ initiatives. Most of these lower level sustainability requirements appear as Development Management requirements that will apply to all development in the borough rather than being area specific. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.5 Nature of Comment: Support

Please could we have a bus direct from Northolt Park to the centre of Ealing? Revenue is lost to Ealing as it is easier to shop in Harrow and even Uxbridge as we have no direct links with Ealing Town Centre. Response: Noted.

The suggestion to extend north-south bus services from Northolt Park to Ealing town centre is noted and can be included in discussions with TfL London Buses as part of on-going discussions to meet gaps in the bus network. Outcome: No change. The proposal on a new bus route will be considered as part of the on-going review of bus services.

Name Organisation Policy Reference Peter L Flatau Resident 2.5 Nature of Comment: Object

1. I live in Ealing, 2.5 a. "Dickens Yard" and "Arcadia" are unsatisfactory in many ways, hence opposition for inquiry. It is doubtful if serious retail development will succeed. 2.5 c. Building heights have been exceeded already. 2.5 d. The most important requirement is a proven interchange at Ealing Broadway Station train/tube/xrail/bus/taxi/car/cycles and foot. Hammersmith is the example to follow. 2.5 e. When do you intend to advise "Questions" members of your proposals? Ealing Broadway "High quality retail destination" too late I suspect, too many adjacent developments. Response: Not accepted.

As the policy states its intention to encourage ‘varied building heights’ there are no specific heights to exceed. Evidence from the Retail Needs Assessment does not find sufficient floor space available in current build to meet the demand projected over the plan period. It is therefore necessary for new provision to be made in the borough. Transport for London, which would provide necessary funding for any improvements at Ealing Broadway Station, considers that there is no business case for a comprehensive transport interchange. Improvements would be made even more difficult without contributory funding from new development. Finally, It is unclear what the respondent is referring to in relation to 2.5 (e). Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 2.5 Nature of Comment: Object

No explicit commitment to building and integrated transport hub Dickens Yard and Arcadia will destroy Ealing Town Centre. 1,265 new flats with lots of the 57 new shops unoccupied. The silly Ealing Metropolitan Centre needs to be dumped. Ealing Broadway is turning into a value retail destination - and this will continue tibbalds tells us nothing we don't already know. Response: Not accepted.

Transport for London, which would provide necessary funding for any improvements at Ealing

96 Broadway Station, considers that there is no business case for a comprehensive transport interchange. Improvements would be made even more difficult without contributory funding from new development. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 2.5 Nature of Comment: Object

Tibbalds proposals - not publicly consulted. Evident post-hoc rationale especially regarding Dickens Yard or Arcadia Sites and should therefore not assume a significant role in this strategy. The Metropolitan Centre designation mis-informs the realities of both the present and future nature of both Ealing or West Ealing town centres. The definitions on P.25 are subjective - at best, aspirational - at worst misleading. Response: Not accepted.

The report from Tibbalds is evidence from a professional planning practice. Evidence informs the Development Strategy proposals which are then consulted on themselves.

Name Organisation Policy Reference Transport for London Statutory 2.5 Nature of Comment: Support with conditions

References to ‘new’ Crossrail stations should be amended to refer to the ‘refurbishment of four stations’ in order to avoid confusion within the document. Although it will be served by Crossrail, as far as TfL is aware there are no improvements planned at Hanwell Station. Response: Noted. Outcome: Accepted. Amend as suggested.

Initial Proposal 2.5 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.5 (a) Nature of Comment: Object

Large amounts of new retail space are unlikely to be successful because the designs do not provide a shopping environment that can compete with either Brent Cross or Westfield in Hammersmith. Also there is an increase in mail order and internet shopping. The Ealing Broadway centre is a locally listed building and recent changes allowed (despite conservation area panel comments) have detracted from its appearance. We are very concerned about the influence of this policy. It should be deleted. Office floorspace is objected to because the text does not state how much of 100,000 Sq.m is expansion. The impact of office blocks on adjoining residential areas is a problem so that a large increase could have an unacceptable impact.

97 Response: Not accepted.

Ealing Town Centre occupies a strategically important point in West London and serves a far greater population than that of Ealing Broadway ward. The changed character of the built environment is a function of the changed role of the centre. The limited service provision in Ealing Town Centre relative to other Metropolitan Centres that the respondent identifies is exactly the problem that the DS is designed to address. It is unsustainable for the centre to continue to underprovide for so much of its hinterland and to offset the needs of the population outside of central Ealing to other centres in London. As Brent Cross and Westfield are themselves the product of new development it is difficult to see why an environment of equal or greater quality is not possible in Ealing through a similar catalyst of new development. The precise quantum of employment floorspace will be determined by the Employment Land Review currently underway, however, there are no indications that requirements have changed so radically that no increase will be required. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.5 (a) Nature of Comment: Object

2.5 (a) No information has been given as to how it will be funded, and people in general can only spend so much money in the middle of a recession Response: Not accepted.

The Development Strategy addresses a longer timeframe than the next few years of recession. Ealing Town Centre occupies a strategically important point in West London and serves a far greater population than that of Ealing Broadway ward. The changed character of the built environment is a function of the changed role of the centre. The limited service provision in Ealing Town Centre relative to other Metropolitan Centres that the respondent identifies is exactly the problem that the DS is designed to address. It is unsustainable for the centre to continue to underprovide for so much of its hinterland and to offset the needs of the population outside of central Ealing to other centres in London. Outcome: No change.

Initial Proposal 2.5 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.5 (b) Nature of Comment: Object

Meaningless text which could be used to justify any thing, must be deleted. Response: Not accepted. The purpose of the Development Strategy is to set the general direction of development in the service of the broader spatial strategy. Greater detail will be provided in subsidiary SPDs, particularly the Ealing Town Centre SPD. Outcome: No change. Further detail and clarity to be provided with the preparation of the Ealing Town Centre SPD.

Name Organisation Policy Reference JK Gill Resident 2.5 (b) Nature of Comment: Object

2.5 (b) All the quarters of the town centre should have different uses

98 Response: Not accepted. Mixed uses are the healthiest and most practical form for urban areas, however, the policy is designed to build on the variety and historical richness already present in Ealing Town Centre. Outcome: No change. Further detail and clarity to be provided with the preparation of the Ealing Town Centre SPD.

Initial Proposal 2.5 (c)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.5 (c) Nature of Comment: Object

We object to high buildings justified on the basis that they are landmark buildings and provide town squares. Please delete reference to gateways. Town centres do not need this concept. Uses gradually build up from residential to those typical of town centres and if these are redeveloped new gateway developments will have a strong impact on adjoining residential areas. Boulevard along the Uxbridge Rd should have trees on property frontages. Response: Not accepted.

Tall buildings offer the opportunity to accommodate development in the most sustainable locations, as determined by their accessibility. If these are to be constructed then it is important that they be of an appropriately high quality to fit their locations. The strategy therefore sees a justification for tall buildings provided that they are of sufficient quality to be landmarks. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.5 (c) Nature of Comment: Support with conditions

2.5 (c) I agree that historic buildings and frontages should be enhanced. However I have reservations about the height of buildings and landmark buildings do not necessarily have to be tall. The proposed boulevard will have to be well maintained. Response: Landmark buildings do not need to be tall, however, the strategy sees a justification for tall buildings provided that they are of sufficient quality to be landmarks. Outcome: No change.

Initial Proposal 2.5 (d)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 2.5 (d) Nature of Comment: Support with conditions

Ealing Broadway is supported if Haven Green is freed from its current bus station cycle park and taxi rank role. Villiers House should be demolished to make space. Opportunity at West Ealing is lost. Response:

In addition to Crossrail proposals, improvements at and around Ealing Broadway station will be developed and delivered as part of the redevelopment of Ealing town centre. In addition, the Council can use other funding streams to finance improvements in the transport network along with major redevelopment projects. Development of these transport projects will include working with TfL London Buses to achieve improvements to the bus network and bus/train interchange, designing better taxi rank, cyclist and pedestrian facilities, and creating a better urban realm. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.5 (d) Nature of Comment: Support with conditions

It is accepted that landmark buildings do not need to be tall, however, the strategy sees a justification for tall buildings provided that they are of sufficient quality to be landmarks. Outcome: No change.

Initial Proposal 2.5 (e)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.5 (e) Nature of Comment: Support with conditions

Welcomed provided they are a requirement of specific sites. Response: Support welcomed.

Facilities will be related to specific areas and demands by the IDP. Outcome: No change.

Further information to be provided in the Development Sites Document and Infrastructure Delivery Plan.

Name Organisation Policy Reference JK Gill Resident 2.5 (e) Nature of Comment: Comment

2.5 (e) With respect to the health centre, Mattock have a health centre that can be refurbished. There is no detail given on the 'centralised energy facility. There is no detail given as to what improvements will be made to the theatre or the town hall Response: Noted.

The Development Strategy is not intended to give detail on this level. Exact location will be provided by the Sites DPD and subsidiary DPDs. The type of provision will be established by the Infrastructure Development Plan. Outcome: No change.

Further information to be provided in the Development Sites policy document and the Infrastructure Delivery Plan.

Initial Proposal 2.5 (f)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.5 (f)

100 Nature of Comment: Object

Object to estimate of potential dwellings (flats not houses) with concerns about gross business floor space. Response: Not accepted.

Residential and commercial quantums have been informed by a series of major studies that form essential components of the LDF evidence base. In respect of housing these include both the Strategic Housing Market Assessment (conducted at both local, sub-regional and London wide levels) that examined housing need and capacity and the Strategic Housing Land Availability Assessment (coordinated and led by the GLA) which examined housing supply. Further work has been commissioned in relation to the viability of affordable housing and will be published in due course. In respect of commercial development, an updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.5 (e) Nature of Comment: Comment

2.5 (f) The figures quoted are now supported in any way and appear to have been picked randomly. Response: Not accepted.

Initial Proposal 2.6

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.6 Nature of Comment: Support with conditions

Initial Proposal 2.6 (Regenerate the Green Man Lane estate) Improvement has been subject to consultation with residents and a planning application is expected in January 2010. We are concerned that redevelopment is not going to help the regeneration of West Ealing. The loss of two public car parking will make further difficulties for access to the West Ealing Shopping Centre for residents living North of the Uxbridge Rd.(ie no right turn into Uxbridge Rd at Drayton Green Rd. and no left turn at Eccleston Rd) No improvements are proposed yet. There is little Public Open Space despite an open space deficiency and the private amenity space will be overshadowed by 8 storey buildings. The units and family housing are being increased but no school expansion is provided . If more class rooms are needed they will use the playground and this will impact on small area of POS.

101 Response: Noted.

The Singapore Road multi-storey car park has operated with reduced capacity for a number of years and the Singapore Road surface car park has facilitated the majority of parking requirements for this part of the town centre following the closure of the upper storeys of the multi-storey car park. As part of the proposed redevelopment of the estate, dual-use parking for the public will be provided within the re-aligned Singapore Road. In total, there would be 75 spaces provided for the public (shoppers, etc) to use on the periphery roads to the development. There will also be at least two on-street 'car club' bays and cars, which would be for use by residents of the estate and the wider area.

In relation to planned improvements to the wider road network within West Ealing, Transport Services are currently examining traffic flows along Felix, Endsleigh and Alexandria Roads. Improvements to traffic flows along these roads, as well as improvements to the Lido junction and north-south corridor between West Ealing and Northfields, are planned independently of the regeneration proposals for the Green Man Estate. Transport improvements in West Ealing will be funded through the Transport for London (TfL) Local Implementation Plan and specific schemes developed through this programme will be subject to public consultation during their detailed development and prior to any approved implementation.

The provision of amenity space and children's play space within the estate would be primarily for the future residents of the estate. There is no requirement to further constrain the proposals for housing on this site by providing Public Open Space, however in response to current residents aspirations, the amenity space within the central perimeter block would be open for use by the public during daylight hours and a children's playground to the rear of the cafe would also be open for children visiting this facility. The shadow diagrams indicate that the gardens within the centre of the perimeter blocks will have decent levels of sunlight and direct daylight.

The children living in the development will attend school's within their catchment area, which includes St John's school. Education Services have reviewed the proposals and have identified that monetary contributions are required in order to increase capacity within the catchment area. Contributions would be secured under a S106 agreement. Such contributions would be commensurate to the increase in child yield as a result of the proposals. Contributions will be sought on a phased basis in relation to the tenure and size of units provided within each phase. Education Services may find that St John's School requires further classroom capacity and this may be achieved through any number of design options, however any proposals would be subject to the submission of a planning application. The existing play area within the school grounds is not Public Open Space, as designated within the Ealing UDP, however would need to be safeguarded for play opportunities in accordance with the relevant policies within the Ealing UDP. Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents' Association Community/Voluntary Orgs 2.6 (EFRA) Nature of Comment: Support with conditions

Initial Proposal 2.6 Regenerate the Green Man Lane estate - This redevelopment provides an opportunity for the wider regeneration of West Ealing.

We suggest that the replacement housing should be planned so that it is linked to and integrated with the West Ealing retail locations, both those on the Uxbridge Road and Waitrose.

Consideration should also be given as to how facilities including schools, pre-schools, doctor’s surgeries and community centres can be included in the development for the benefit of its residents.

102

The densification associated with the proposed increase in housing units on the site is potentially concerning and means that particular care must be taken to ensure that immediately accessible open air recreational areas are provided for all residents. This need will be particularly important for families with young children, many of whom are likely to be located in flats rather than houses with gardens. Response: Noted.

The Development Sites policy document, which will support the Development Strategy will set out specific policies for the development of key sites, areas and locations in the borough, including the Green Man Lane Estate. It will outline in greater detail the suitability of individual sites for facilitating different uses and densities, based on their individual merits. This includes any proposals for land and buildings on significant sites that are likely to be subject to development proposals during the plan period i.e. 2011-2026. These allocations are intended to assist in delivering the priorities and objectives of the Development Strategy 2026. Outcome: No Change.

Name Organisation Policy Reference Michael Simmons Resident 2.6 Nature of Comment: Support

Initial Proposal 2.6 Regenerate the Green Man Lane Estate Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Orgs 2.6 Assoc Nature of Comment: Object

Overdeveloped already. Response: Not accepted.

Name Organisation Policy Reference M Collins Resident 2.6

Nature of Comment: Support Response: Support welcomed. Outcome: No change.

103

Name Organisation Policy Reference Peter L Flatau Resident 2.6 Nature of Comment: Support Response: Support welcomed. Outcome: No change necessary.

Name Organisation Policy Reference Eric Leach Resident 2.6 Nature of Comment: Object

Initial Proposal 2.6 - 738 new homes with no social and community infrastructure planned; no extending/re-purposing/replacing of St John's School, no improvement re traffic congestion to the north; no health care, and no law and order. Response: Not accepted.

The Development Strategy is not intended to give detail on this level. Exact location will be provided by the Development Sites policy document and subsidiary DPDs. The type of provision will be established by the Infrastructure Development Plan. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Orgs 2.6 Nature of Comment: Comment

Will do little for West Ealing Broadway, a declining and unsatisfactory centre. Notable Art Deco buildings, some on prominent corner sites, should provide a framework for design led regeneration. Response: Not accepted.

Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.6 Nature of Comment: Comment

Just because there are problems with the design does not mean the building has to be demolished and it may be more cost effective to ascertain if these buildings can be adapted Response: Noted.

Initial Proposal 2.7

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.7

104 Nature of Comment: Object

Initial Proposal 2.7 (Enhance and consolidate Hanwell town centre)e) provision 45 homes and 8000 sq m of business FS. Is not adequately explained. They are not explained in Housing paper 3. Response: Noted.

Name Organisation Policy Reference Ealing Fields Residents' Association Community/Voluntary Orgs 2.7 (EFRA) Nature of Comment: Support

Initial Proposal 2.7 Enhance and consolidate Hanwell town centre - We endorse the stated aspiration in the consultation document that the Development Strategy will endorse the: “Enhancement of the historic buildings and frontages that contributes to the character and appearance of the town centre.”

We trust that this will be achieved without an increase in the current building heights and suggest that this expectation be included in the revised draft. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Trustess of the Blackrock Property Fund Business 2.7 Nature of Comment: Support/Object

Intitial Proposal 2.7 which seeks to consolidate the town centre to meet the retail needs of the Hanwell district is supported, however it is felt that this will be difficult to achieve given the proposed retail floorspace in competing centres nearby e.g. Initial Proposal 2.5 (a) which outlines proposed retail floorspace levels in Ealing. Again, the extension of existing centre boundaries is considered key - sites which offer better retail potential would become available, with better opportunities for higher densities to be achieved. Paragraphs 2.5 - 2.6 from PPS6 is quoted to support this. It is felt that our clients land, which can accommodate town centre uses under the current Class A1 designation, together with land immediately adjacent to the town centre has a role to play in delivering proposed growth in the area. The town centre boundary should therefore be revised to allow this. Please advise us of the future stages of the LDF. Response: Noted.

Town Centre boundaries are designed to consolidate retail functions, they will be reviewed and extended where necessary to facilitate these uses.

105 Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 2.7 Nature of Comment: Support

Initial Proposal 2.7 Enhance/consolidate Hanwell town centre Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 2.7 Nature of Comment: Support

Initial Proposal 2.7 - But to quote an earlier comment - The Council commissioned various Conservation appraisals and before any development takes place the improvements suggested in the documents should be acted upon. This is a quote from the Hanwell Clock Tower document but applies to all town centre conservation areas - ' The overall condition of most fabric in the CA is sound, but shabby. A visitor from elsewhere would have difficulty in appreciating that this is designated as an historic area where preservation should be paramount, in most cases however, regular maintenance, retention or reinstatement of original features, one-off gentle cleaning of brickwork, removal of redundant, excessive, lurid or internally illuminated signage and encouraging higher quality shopfronts will bring about substantial enhancement and ensure the preservation of the area's character for the future'. This was written in 2007 and all that has happened is that the inevitable hanging baskets have appeared and the pavements are being redone. Nothing has happened to the fabric of the buildings or the shopfronts. There needs to be a stronger planning policy in place for conservation areas. Hanwell library should be restored to its former glory and more use made of upper rooms. Heath Lodge should be regenerated Response: Noted.

More detail will be provided in the Development Sites and Management policy documents together with supplementary planning documents on Shop Front Design and Conservation Areas and Listed Buildings which are all currently being prepared. These are intended to support the implementation of the objectives outlined in the Development Strategy Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Orgs 2.7 Assoc Nature of Comment: Object

Not really addressing the problems, need a town centre Response: Noted. Policy will be further reviewed in the light of an update of the retail needs assessment and it is planned to consolidate the town centre. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.7 Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

106

Name Organisation Policy Reference Peter L Flatau Resident 2.7 Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 2.7 Nature of Comment: Object

Initial Proposal 2.7 - Changes proposed are cosmetic. Ironically as Hanwell is to be a crossrail station the plans are inconsistent with the overall strategy. I.e Where are the residential tower blocks?! Response: Not accepted.

The development corridors are indicative and do not reflect political or administrative boundaries. They are not blanket areas for demolition and redevelopment but search areas which will guide development. The Development Strategy will include descriptions of each community and its relationship to the corridor. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Orgs 2.7 Nature of Comment: Support

Design led planning and shopfront manifesto would deliver a big impact in a compact area. Response: Although the DS intends to preserve the historically valuable environment of the conservation area it will not do so to the exclusion of any new development. It is intended that good design of new development will enhance the area too. Outcome: No change.

Name Organisation Policy Reference Transport for London Statutory 2.7 Nature of Comment: Support with conditions

Furthermore, references to ‘new’ Crossrail stations should be amended to refer to the ‘refurbishment of four stations’ in order to avoid confusion within the document. Although it will be served by Crossrail, as far as TfL is aware there are no improvements planned at Hanwell Station. Response: Noted. Outcome: Accepted.

Amend text accordingly.

107 Initial Proposal 2.7 (a)

Name Organisation Policy Reference JK Gill Resident 2.7 (a) Nature of Comment: Support with conditions

Support, as long as funding is in place Response: Support welcomed. Outcome: No change.

Initial Proposal 2.7 (b)

Name Organisation Policy Reference JK Gill Resident 2.7 (b) Nature of Comment: Comment

It will be difficult to increase retail needs when major shopping centres exist in other town centres, given the amount of money people have available to spend in the current climate Response: Noted.

Notwithstanding the existence of shopping centres in other town centres, a high standard of local retail provision remains essential for the local population. The consolidation of the town centre will assist in supporting this. Outcome: No change.

Initial Proposal 2.7 (c)

Name Organisation Policy Reference JK Gill Resident 2.7 (c) Nature of Comment: Support

Any improvements must be in tandem with the crossrail proposals Response: Noted. Outcome: No change.

Initial Proposal 2.7 (d)

Name Organisation Policy Reference JK Gill Resident 2.7 (d) Nature of Comment: Support

The detail on how this is to be achieved has not been included in the document Response: The DS is not intended to give detail on this level. Exact improvements subsidiary DPDs and the Infrastructure Delivery Plan. Outcome: No change.

108 Initial Proposal 2.8

Name Organisation Policy Reference National Grid Properties Holdings Business 2.8 Nature of Comment: Support

As you will be aware, National Grid Properties (NGP) own Southall Gas Works which is currently identified as a major regeneration area in both the London Plan and the Ealing Plan. An application for outline planning permission has been submitted for the redevelopment of the site comprising a mixed use development and this is currently under discussion with officers of the Council and of the GLA. Whilst there are matters under discussion with regard to some details of the appliction proposals, it is understood that the general principle and scale of development proposed is acceptable. The planning application and supporting documents, including the Environmental Statement, demonstrate the 'capacity' of the site in terms of accomodating retail, residential, leisure and employment development, together with associated physical and social infrastructure. The representations submitted on behalf of NGP are, primarily focussed on issues relating specifically to the Southall Gas Works site. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference National Grid Properties Holdings Business 2.8 Nature of Comment: Object

Initial Proposals 2.8 - NPG support the proposals for major changes to Southall Town Centre – taking advantage of the redevelopment of the station as a Crossrail station, and the opportunities provided by the development of Southall Gas Works site to the west of the existing centre. However, NGP strongly object to the statement that the Southall Gas Works site could provide “up to 2,618 new homes”. An illustrative masterplan, which has been supported in principle by CABE, has been worked up with officers of Ealing Council and the GLA and this demonstrates that up to 3,750 dwellings could be accommodated on the site. The various documents submitted in support of the application demonstrate that this level of development could be satisfactorily accommodated on the site. Response: Noted.

It is accepted that the planning application for the Southall Gas Works Site was for 3,750 units, however the total number of units in the proposal were to be developed on a phased basis up to 2031. As our Plan period extends to 2026 only, the total number of units as per the planning application were not outlined in the Draft Strategy. Our current housing trajectory is also being revised in order to include the most up to date housing figures. Outcome: Accepted.

Amendment to text to distinguish between the total number of proposed units in the planning application and the actual number to be achieved by 2026.

Name Organisation Policy Reference Greater London Authority Statutory 2.8 Nature of Comment: Support with conditions

Southall: Reference should be made to the designation of Southall as an Opportunity Area within the draft Replacement London Plan, and the 4,000 minimum new homes and 2,000 indicative employment capacity that is identified. The strategic policy direction provided within Annex 1 should be reflected in the Core Strategy. In addition, reference to the Southall Gas Works site should reflect the planning application which includes 3,750 residential units.

109 Response: Noted.

Amendments will be made to the text in order to conform with the draft Replacement London Plan. It is accepted that the planning application for the Southall Gas Works Site was for 3,750 units, however the total number of units in the proposal were to be developed on a phased basis up to 2031. As our Plan period extends to 2026 only, the total number of units as per the planning application were not outlined in the Draft Strategy. Our current housing trajectory is also being revised in order to include the most up to date housing figures. Outcome: Accepted.

Amendment to text to conform with the draft Replacement London Plan and in to distinguish between the total number of proposed units in the planning application and the actual number to be achieved by 2026.

Name Organisation Policy Reference Hovedean Properties Business 2.8 Nature of Comment: Support/Object

We support the inclusion of the site known as the Middlesex Business Centre within the S2 area designated as mixed business and residential area. We also support the references to the Broadway, South Road and the Green as an 'Asian Gateway'. The regeneration of southall station and environment is welcomed, however a stronger view is needed towards larger station facilities which is more appropriate for the density of development proposed in surrounding areas. Additional facilities should be considered at the Eastern end of the rail platforms at the location of the pedestrian bridge - currently closed. This would act as a regeneration catalyst for regeneration of the land known as the Middlesex Business Centre. We believe that the configuration of proposals in Southall close to the LB Hillingdon boundary may have a negative impact on neighbouring town centres. We have a concern over the impact which may arise from the 'prejudice' given towards the Southall Gas Works Site as concentration on this site may affect the supply of new housing in the area. We support the housing needs figures expressed but believe the figures should not be achieved by concentrating mainly on the Southall Gasworks site, but other opportunity sites such as land at the Middlesex Business Centre. Response: Support welcomed.

The scope of necessary infrastructure will be established through the Infrastructure Delivery Plan. Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 2.8 Nature of Comment: Support

Initial Proposal 2.8 Regenerate Southall town centre Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Orgs 2.8 Assoc Nature of Comment: Comment

Southall needs total redesigning, with all cars removed from area. Response: Noted.

110 While complete elimination of all car traffic is probably unrealistic, the Development Strategy envisages more effective techniques for managing this traffic and encouraging modal shift to public transport. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.8 Nature of Comment: Support Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 2.8 Nature of Comment: Support

Initial Proposal 2.8 - Is the idea that major development at Southall Gas Works site and Ealing Broadway compete with each other? You would have more mileage with a top rate Indian/Asian market after Bombay or Durban. A serious idea not meant to be racial, it could become famous. Response: Noted.

It is not envisaged that Ealing and Southall will be in competition, rather that improved facilities are put at the disposal of currently under served communities. Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 2.8 Nature of Comment: Object

Initial Proposal 2.8 - Southall residents have convinced me that the housing estate to be built on the Gas Works Site will lead to the destruction of Southall Centre. It will lead to traffic gridlock. Much, much more infrastructure needs to be added. Response: Not accepted.

The scope of necessary infrastructure will be established through the Infrastructure Development Plan. Outcome: No change.

Name Organisation Policy Reference Transport for London Statutory 2.8 Nature of Comment: Support with conditions

References to ‘new’ Crossrail stations should be amended to refer to the ‘refurbishment of four stations’ in order to avoid confusion within the document. Although it will be served by Crossrail, as far as TfL is aware there are no improvements planned at Hanwell Station. Response: Noted. Outcome: Accepted. Amend wording as suggested.

111 Initial Proposal 2.8 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (a) Nature of Comment: Object

Initial Proposal 2.8 (Regenerate Southall town centre) a)While supporting regeneration of Southall we object to the layout proposed for the gas works site. There is not enough open space proposed and the impact of the gas holders, a huge landmark, is not taken into account. If the Town centre boundary is extended into the gas works site, land on the east side which is suitable for public open space would be incorporated in the town centre envelope.

The two separate centres are likely to have different characters, the new one with the characteristics of a retail park with large units and adequate parking, the other with its existing town centre shops, restaurants and businesses. There is little point in trying to join them up artificially. b) We object to the reference to ‘Gateway” because this implies tall buildings in an area of severe traffic congestion. Space and buildings are needed for cultural facilities c) Proposals are fully supported but the current application for the eastern access to the gas works site is unacceptable and southern access is inadequately provided for. d) Community facilities (hub) should be located on the gas works site e)&f) Total housing too much. Response: Not accepted.

The layout of the Southall Gas Works proposals is a matter for the current planning application not the Development Strategy. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.8 (a) Nature of Comment: Object

2.8 (a) A formal objection has already been submitted in relation to this Response: Noted

This respondent’s concerns are addressed elsewhere, where they are put more explicitly. Outcome: No change.

Initial Proposal 2.8 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (b) Nature of Comment: Object

We object to the reference to ‘Gateway” because this implies tall buildings in an area of severe traffic congestion. Space and buildings are needed for cultural facilities. Response: Noted. The use of the phrase in this instance is not intended to convey this outcome. Outcome: No change.

112 Initial Proposal 2.8 (c)

Name Organisation Policy Reference Government Office for London Statutory 2.8 (c) Nature of Comment: Support with conditions

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (c) Nature of Comment: Comment

Proposals are fully supported but the current application for the eastern access to the gas works site is unacceptable and southern access is inadequately provided for. Response: Not Accepted.

The layout of the Southall proposals is a matter for the current planning application not the Development Strategy Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.8 (c) Nature of Comment: Support

2.8 (c) Any improvements must be in tandem with the crossrail proposals Response: Support welcomed.

It should be borne in mind that all transport in London is co-ordinated by TfL. Outcome: No change.

Initial Proposal 2.8 (d)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (d) Nature of Comment: Comment

Community facilities (hub) should be located on the gas works site Response: Noted. The layout of the Southall Gas Works proposals is a matter for the current planning application not the Development Strategy. Outcome: No change.

113

Name Organisation Policy Reference JK Gill Resident 2.8 (d) Nature of Comment: Object

2.8 (d) A new community hub is not necessary (I am assuming it will be located on the gasworks site). Response: Noted.

The scope of necessary infrastructure will be established through the Infrastructure Development Plan. The increase in population envisaged indicates a need for the facilities described. Outcome: No change.

Initial Proposal 2.8 (e)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (e) Nature of Comment: Object

Total housing too much. Response: Not accepted

Name Organisation Policy Reference JK Gill Resident 2.8 (e) Nature of Comment: Object

2.8 (e) I object to the 2618 new homes to be provided on the gasworks site Response: Not accepted.

Initial Proposal 2.8 (f)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.8 (f) Nature of Comment: Object

114 Total housing too much. Response: Not accepted.

Name Organisation Policy Reference JK Gill Resident 2.8 (f) Nature of Comment: Object

2.8 (f) The proposed figures in relation to homes, business space and jobs and are not justified. There is existing business space located near the gasworks site Response: Not accepted.

Initial Proposal 2.9

Name Organisation Policy Reference Havelock Estate Residents Steering Community/Voluntary Orgs 2.9 Group Nature of Comment: Comment

The residents Steering Group welcomes the promotion of the regeneration of their estate. They wish however, further consideration of the level of additional housing provision and the designation of open space within the site. As the site is outlined for redevelopment in the draft Development Strategy 2026, we seek that the Havelock Estate, the extent of which is outlined in the accompanying site plan, is designated within the emerging LDF proposals map.

We believe that a higher level of housing can be can be provided on the site than is currently proposed. The site could reasonably be described as being within a central location. This is because it is within 800m walking distance of Southall Town centre. This is described as a Major Town Centre within the London Plan. It should also be noted that the site is located on a main arterial route and is located within close proximity to Southall Overground Station.

Whilst currently at a PTAL of 1-3, we believe that it is reasonable to assume that the relevant

115 indicative density in the London Plan should, as a starting point permit development up to 650 hrh for the whole site given that it meets the criteria of being within 800m of a major town centre and is located adjacent to a main vehicular route. We further believe that there is the potential to maximise development opportunities further as part of a major regeneration scheme. This is because there are clear opportunities to alter existing road connections and improve public transport connections through the redevelopment proposals, thus enhancing bus provision and improving opportunities to use alternative modes other than the car. We understand that Southall station is also proposed to be serviced by the Crossrail network which will provide rail services from Maidenhead to Abbey Wood and Shenfield.

Such improvements would increase the PTAL levels to 4-6 category where there would be a clear justification to provide densities within the 650-1100 hrh band and therefore has clear potential to increase the level of development through transport connections and good design to maximise the housing and other opportunities. In relation to Open Space, we request similar flexibility as has been shown towards the proposed designation of Site S7 (Glade Lane Site) in the Development Management Policies DPD, which promotes the re-location and re-provision of open space as part of redevelopment proposals. An arbitrary 10 metre buffer adjacent to the canal and 5 metre buffer adjacent to other open spaces is also not necessarily the most flexible or imaginative approach which could limit regeneration in other areas. Response:

The detailed proposals for the redevelopment of Havelock are not yet available and will be dealt with in due course as a planning application. The density of the development will nee to relate to transport capacity and any departure from the density matrix in the Consolidated London Plan would need to be justified. Improved transport links will also form part of any development proposals. In relation to any landscaped buffer between the development and the green corridor this is likely to be at least 5m and it should be noted that the policy in the existing UDP only relates to Metropolitan Open Land. Outcome: No change.

Name Organisation Policy Reference Greater London Authority Statutory 2.9 Nature of Comment: Support with conditions

Havelock Area: Any proposals to amend Metropolitan Open Land and Strategic Industrial Location designations need to be discussed in detail with GLA Officers. Proposals to MOL need to ensure no net loss where changes are proposed - these should result in improvements in the quality of space protected. Proposed amendments to SIL must be as a result of a detailed and up to date land review. Further information is required before this can be deemed acceptable. Response: Noted

The GLA will be involved in any proposals to amend MOL or SIL designations. The reconfiguration of open space, employment land, special opportunity site and residential space in this area is designed to improve its function and usability. Although the exact arrangement of this space is still to be finalised, it is intended that there would be no net loss of open space. Furthermore, given the ecologically value of the canal, a buffer would be formed between any built development and the canal edge. Outcome: Accepted.

We will engage with the GLA regarding any proposed changes to MOL or SIL designations. Further details regarding the arrangement of this space are to be published as part of the initial proposals for the Development Management policy document due in Autumn 2010.

116

Name Organisation Policy Reference Hovedean Properties Business 2.9 Nature of Comment: Support

We support the regeneration strategy for the Havelock Estate. We also support the proposed land swap between Glade Lane and the Havelock Estate to create a green corridor between the Southall Rail Station, through the Middlesex Business Centre, land next to the Hortus Cemetery towards Havelock Road. We support the new residential canal development in new opportunity land. We also support the view towards regeneration of the Middlesex Business Centre. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 2.9 Nature of Comment: Support

Initial Proposal 2.9 Regenerate the Havelock area - This initial proposal sets out the vision and deliverables for Southall town centre Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Orgs 2.9 Assoc Nature of Comment: Object

Overdeveloped already. No quality of life. Response: Not accepted.

The proposals seek to improve the existing estate by increasing accessibility and connectivity to the surrounding areas. Outcome: No change.

Name Organisation Policy Reference M Collins Resident 2.9 Nature of Comment: Support Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 2.9 Nature of Comment: Support Response: Support welcomed. Outcome: No change.

117 Initial Proposal 2.9 (a)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.9 (a) Nature of Comment: Object

The Havelock estate was badly designed with poor access to a station. Providing more buses is no justification for major density increase to accommodate 193 extra dwellings. No basis is provided. Response: Not accepted.

Improved public transport accessibility will not rely on the provision of more buses as the sole means through which accessibility will be improved. Enhanced access will also be provided through the increased provision of walking and cycling routes which will link the estate to the surrounding areas. Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 2.9 (a) Nature of Comment: Object

2.9 (a) - Regenerate the Havelock Area - I object to that and do not know how it will create 193 additional new home. Response: Not accepted.

The additional dwellings will result from the more efficient use of the space and the improved design and layout. Outcome: No change.

Initial Proposal 2.9 (b)

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Orgs 2.9 (b) Nature of Comment: Object

Object to building on MOL. The space between the canal and railway has already been intruded upon by housing. But Glade Lane Canalside Park is established as an attractive area with developing nature conservation value The canalside is a green corridor and nature conservation site where development is excluded by existing policies and proposed strategies. This is an area of district park deficiency with no proposal to relieve this. Any other land available should be added to the total green space not used as an excuse to build on high amenity land near the canal. Residential moorings along the towpath are likely to be vandalised. They should be located on the other side of the canal in an area that is not deficient in nature conservation sites. Response: Noted. The reconfiguration of open space, employment land, special opportunity site and residential space in this area is designed to improve its function and usability. Although the exact arrangement of this space is still to be finalised, it is intended that there would be no net loss of open space. Furthermore, given the ecologically value of the canal, a buffer would be formed between any built development and the canal edge. Outcome: No change. Further details regarding the arrangement of this space are to be published as part of the initial proposals for the Development Management Document due in September this year.

118 Initial Proposal 2.9 (c)

Name Organisation Policy Reference JK Gill Resident 2.9 (c) Nature of Comment: Support

2.9 (c) Regenerate the Middlesex Business Centre & environs. Detail is not given although I would support the aim, in general. I do question why it is stated that the Havelock area is beyond the catchment for the railway station. It is approximately 100 yards away. Perhaps improvements to the Havelock Estate can be financed through European Community monies; as well the Highfields development in Feltham in the mid 1990s. Response: Noted. Outcome: No change.

119 Chapter 3: Development in the A40 Corridor and Park Royal

Initial Proposal 3.1

Name Organisation Policy Reference

Hillingdon Motorist Forum Community/Voluntary Organisation 3.1 Nature of Comment: Support with conditions

This and other chapters refer to additional homes being constructed in various locations in Ealing. There needs to be road improvements to handle the additional traffic that will be generated by these developments. It is important that the number of accesses to a development are maximised to avoid all the traffic being funnelled into one area which will result in unnecessary congestion. The proposal for the Greenford to the A40 freight link is most welcome. Response: Support welcomed.

The impact of this development will be carefully assessed and appropriate mitigation will be secured through legal agreements to ensure that any proposals can be accommodated within the highway network.

Outcome: No change.

Name Organisation Policy Reference

Twyford Abbey Properties Business 3.1 Nature of Comment: Support

TAP welcome the development of additional homes within the A40 corridor (Twyford Abbey fall within the A40 Corridor). Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference SEGRO Business 3.1 Nature of Comment: Support with conditions

The A40 / Park Royal Corridor - There is a greater emphasis upon employment protection and provision in this broad growth area, with only 1,350 residential units [12% of target] proposed, but some 360,000 sq.ft of class B space [33% of target]. It is suggested that there should be a protection of strategic employment land and an enhancement of Park Royal, although we note that there is an acknowledgement that commercial uses generate traffic issues in residential areas and that some may require fresh assessment. We support the principle of reviewing existing employment areas, their impact and their alternative opportunities, but would reiterate that in respect of strategic employment land, there is a clear priority within London Plan policy / SPG for other land to be considered for release first and recommend that this should be reflected in the overall DS. We consider that the sites likely to be identified for potential mixed-use development within this overall growth area will be capable of delivering significantly greater than the 1,350 units suggested, but should be capable of doing so without detriment to other policies, amenity or infrastructure and thus the overall housing delivery targets should be reviewed to ensure that appropriate opportunities for regeneration are not stifled in the future.

120 Response: Support welcomed.

The policy context in respect of SIL, particularly in the context of the emerging RLP is acknowledged. An updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan. Outcome: Accept conditionally.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA.

Name Organisation Policy Reference

Britel Fund Trustees Business 3.1 Nature of Comment: Support with conditions Recognition that where residential and business uses interlink, flexibility for redevelopment to either residential or business uses to provide defined boundaries for independent or mixed uses should be considered. Response: Support welcomed.

An updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan. Outcome: Accept conditionally.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA.

Name Organisation Policy Reference

Hallmark Property Group Business 3.1 Nature of Comment: Support with conditions

My client is generally supportive of proposals that to regenerate this part borough. However, it is respectfully suggested that policy should be amended so that a range of different uses (not just restricted to residential or employment based uses) be considered in this location. Response: Support welcomed.

Name Organisation Policy Reference

Michael Simmons Business 3.1 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

121

Name Organisation Policy Reference Hanwell Village Green Community Association Community/Voluntary Group 3.1 Nature of Comment: Support with conditions

Development in this area could be positive but pollution levels already exceed EU standards - this needs to be addressed Response: Noted.

The LDF will seek to ensure that the location and design of development takes account of pollution control objectives, including those objectives of the Air Quality Action Plan. Any development which hinders the achievement of these objectives will be resisted. Similarly any development which contributes to the achievement of these objects, including for example, low car development to reduce air pollution, the use of mitigation measures etc will be promoted. The Development Management DPD will contain policies for the management of future development in the area in terms of emissions. With regard to individual development sites identified within this area, these will be the subject of a Sustainability Appraisal (SA). The SA process has sought to direct vulnerable uses, away from areas of poor air quality in the borough. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.1 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 3.1 Nature of Comment: Support.

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Eric Leach Resident 3.1 Nature of Comment: Object.

Park Royal could be completely repurposed as a new, complete, mixed community - housing offices, shops, new transport hubs, culture, sport, healthcare, education, law and order, hotels, community centres, meeting rooms, conference centre and tourist centre.

122 Response: Not accepted.

The emphasis in the plan is on the protection of the core industrial land asset of Park Royal and supporting the modernisation of the business park and the development of its supporting infrastructure and amenities. It is acknowledged that there is limited scope for release of employment land at the periphery for housing development where this clearly supports the wider strategy of strengthening the employment location. It should be noted that the Southern Gateway to Park Royal is already a mixed use development area (see Initial Proposal 3.4) and there are also specific proposals for the Park Royal neighbourhood centre (junction of Park Royal Road and Coronation Road), the travellers’ site at Bashley Road and (in Chapter 5) the Metropolitan Open Land at Twyford Avenue. Outcome: No change.

Name Organisation Policy Reference

Central Ealing Residents Association Community/Voluntary Group 3.1 Nature of Comment: Object

Additional commercial floorspace will generate yet more road congestion. No fast north/south bus e.g. fastbus, to alleviate private car usage. Poor air quality not addressed. Response: Noted.

In relation to the transport issues, the council will secure funding from developers (via planning related legal agreements) towards road improvements from new development. The Council’s Transport Strategy sets out bus network improvements that are being sought via negotiations with London Buses. The concern regarding the inadequacy of the north-south orbital links is recognised as an important issue to address and inclusion of Initial proposal 4.4 in the Development Strategy supports this. The council continues to lobby and push for these improvements including better north-south bus links.

In relation to air quality, the LDF will seek to ensure that the location and design of development takes account of pollution control objectives, including those objectives of the Air Quality Action Plan. Any development that hinders the achievement of these objectives will be resisted. Similarly any development that contributes to the achievement of these objects, including for example, low car development to reduce air pollution, the use of mitigation measures etc, will be promoted. The Development Management DPD will contain policies for the management of future development in the area in terms of emissions. With regard to individual development sites identified within this area, these will be the subject of a Sustainability Appraisal (SA). The SA process has sought to direct vulnerable uses, away from areas of poor air quality in the borough. Outcome: Accept conditionally.

Amendments to be made in the light of the emerging IDP.

Initial Proposal 3.1 (a)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Group 3.1 (a) Nature of Comment: Object

We cannot support these figures as we do not know how they are justified.

123 Response: Not accepted. Residential and commercial quantums have been informed by a series of major studies that form essential components of the LDF evidence base. In respect of housing these include both the Strategic Housing Market Assessment (conducted at both local, sub- regional and London wide levels) that examined housing need and capacity and the Strategic Housing Land Availability Assessment (coordinated and led by the GLA) which examined housing supply. Further work has been commissioned in relation to the viability of affordable housing and will be published in due course. In respect of commercial development, an updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan.

Outcome: No change.

Initial Proposal 3.2

Name Organisation Policy Reference

Highways Agency Statutory 3.2 Nature of Comment: Object

Consideration should be given to minimise potential increases in Heavy Goods Vehicle (HGV) movements. We would therefore support and encourage the promotion of rail and water related transport to minimise the use of the local and national highway network for the movement of goods across the borough. One of the key transport challenges should therefore be, where possible, the maximisation of sustainable transport improvements (particularly at Park Royal) and non-road based freight movement. Whilst desirable, the reality in a lot of cases is that transporting goods by rail/water is not feasible due to the costs associated with providing access to the sites by these modes. If rail/water transport is not feasible, the impact of transporting all waste by HGV should be taken into account. Response: Noted.

Where non-road based freight transport is not feasible, developers’ transport assessments will be required to demonstrate mitigation of adverse impacts. The council continues to work with and support the work of West London Freight Quality Partnership to improve the movement of freight and mitigate adverse impacts on other road users.

Outcome: No change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Group 3.2 Nature of Comment: Support with conditions

a) Any support is based on replacement of corridor by something more meaningful and improvement of accesses which impact on residential property. b) This needs more explanation in particular how the aspiration could be achieved. Direct access from A40 to each estate needs improvement as well Response: Support welcomed

Outcome: No change.

124

Name Organisation Policy Reference

GSK Community/Voluntary Group 3.2 Nature of Comment: Support with conditions

Although the consultation draft replacement London Plan, October 2009 at Policy 2.17 identifies the need to protect SIL'S it also recognises that non-employment uses within SIL'S maybe acceptable where it follows a strategically co-ordinated process of consolidation taking into account assessment of industrial land demand and supply which takes place through the borough DPD. As indicated below we believe that LBE should consider this process in light of initial proposal 4.2 which indicates that the GSK Greenford site is appropriate for mixed use development. Response: Noted. The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA. Specifically in respect of the Greenford Green site, the council acknowledges the significance of this site and recognises this at Initial Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Development Sites policy document. The guidance within this SPD is intended to be complimentary to the current LDF. Outcome: Accept conditionally.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

Name Organisation Policy Reference

Britel Fund Trustees Business 3.2 Nature of Comment: Object

While we support the intentions of the policy overall, the policy should allow greater flexibility for the provision of alternative uses where better defined surroundings in terms of use would result. In addition, greater flexibilty for alternative uses should be incorporated into the policies. Response: Not accepted.

The general policy presumption set in both the London Plan and Ealing’s LDF supports this approach and where exceptions are made a case will be made. An updated and revised Employment Land Review is being commissioned and this will enable the council to fine tune its policies in relation to employment sites and enable a final determination to be made with regard overall commercial quantums identified in the plan.

Outcome: No change at this stage.

The emerging policy will however be further reviewed in the light of ELR and following further discussions with the GLA.

125

Name Organisation Policy Reference

Michael Simmons Resident 3.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 3.2 Nature of Comment: Comment

Development at what cost to humans and wildlife? Response: Objection is unclear.

The development of this corridor can be compatible with other objectives including those seeking to protect and enhance the natural environment, and addressing climate change. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.2 Nature of Comment: Comment

We need land to be safeguarded for employment in view of the increasing population. Response: Noted.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA.

Name Organisation Policy Reference

Peter L Flatau Resident 3.2 Nature of Comment: Support

No further comment.

126 Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

JK Gill Resident 3.2 Nature of Comment: Comment

I think that this proposal needs to be considered as part of the London Plan. Input needs to be had from the local population as to how much traffic congestion/disruption this proposal will entail or ameliorate. Response: Noted.

The planning process for new development includes public consultation and developers’ transport assessments will be required to demonstrate mitigation of adverse impacts. The Council continues to work with and support the work of West London Freight Quality Partnership to improve the movement of freight and mitigate adverse impacts on other road users.

Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 3.2 Nature of Comment: Support

Further emphasis needed i.e. more housing. Response: Noted. Outcome: No change.

Initial Proposal 3.3

Name Organisation Policy Reference

Michael Simmons Resident 3.3 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.3 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

127

Name Organisation Policy Reference

Peter L Flatau Resident 3.3 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Association Community/Voluntary Organisation 3.3 Nature of Comment: Comment

Needs to be greened. Response: Noted.

An Open Space Strategy is currently being prepared for the borough which will explore and set out opportunities for enhancing existing open space, including improving access to this space, and establishing new green space. Innovative measures, such as green roofs/walls etc will also be promoted within the Park Royal area, and appropriate policies/standards will be established in the Development Management DPD for this purpose. Outcome: Accept conditionally.

The Open Space Strategy will explore opportunities for greening this area. The findings of which will inform the emerging LDF documents, including the Development Management DPD.

Name Organisation Policy Reference

Transport for London Statutory 3.3 Nature of Comment: Support with conditions

There are a large number of references in the documents to proposed transport improvements where the status is uncertain, in particular north south-links listed in initial proposal 4.4 and identified on map 8 in the Development Strategy and potential interchanges in initial proposal 3.3. It will be important that in the text, on accompanying maps, and in the proposed Infrastructure Plan that the current status, level of commitment and funding, lead agencies and timescales are clearly and consistently identified and are related to the proposed Development Strategy. Many of the proposed improvements are not currently programmed and are future aspirations which should be clearly identified as such to avoid confusion. This would ensure compliance with adopted London Plan Policy 3C.1 and 3C.2, and should take account of the indicative list of transport schemes in Table 6.3 of the draft replacement Plan. Response: Support welcomed.

The council is currently preparing a detailed Infrastructure Delivery Plan (IDP) and key components will be summarised in and inform any submission proposals. A clear distinction will be made between projects that are programmed and which remain aspirational to ensure the Development Strategy proceeds on a realistic basis.

128 Outcome: Accept.

Amendments to be made in the light of the emerging IDP.

Name Organisation Policy Reference

JK Gill Resident 3.3 Nature of Comment: Comment

The appropriate transport infrastructure needs to be in place before there is development of a site said to house 2000 businesses Response: Not accepted. The residential quantum referred to is inflated and it is unclear whether or not the respondent is specifically referring to the Park Royal area. It is acknowledged however that improvements to both traffic movement and public transport are essential. Outcome: No change.

Initial Proposal 3.3 (a)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.3 (a) Nature of Comment: Comment

Is all this space needed? If any more land is to be used for residential development it should be provided with adequate community facilities. Response: Not accepted.

Outcome: No change.

Name Organisation Policy Reference

Highways Agency Statutory 3.3 (a) Nature of Comment: Support

129 Response: Support welcomed.

Where non-road based freight transport is not feasible, developers’ transport assessments will be required to demonstrate mitigation of adverse impacts. The Council continues to work with and support the work of West London Freight Quality Partnership to improve the movement of freight and mitigate adverse impacts on other road users. Outcome: No change.

Initial Proposal 3.3 (b)

Name Organisation Policy Reference

Government Office for London Statutory 3.3 (b) Nature of Comment: Support with conditions

The council is currently preparing a detailed Infrastructure Delivery Plan (IDP) and key components will be summarised in and inform any submission proposals. Outcome: Accept.

Amendments to be made in the light of the emerging IDP.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.3 (b) Nature of Comment: Support

Strongly supported but is unlikely to happen according to Guiness Site Developers. Response: Support welcomed.

Notwithstanding the Guiness site development situation, the Council wishes to continue to promote this policy in conjunction with other stakeholders and developers.

Outcome: No change.

Initial Proposal 3.4

Name Organisation Policy Reference

Michael Simmons Resident 3.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

130

Name Organisation Policy Reference Hanwell Village Green Community Association Community/Voluntary Organisation 3.4 Nature of Comment: Support

Access needs improving. Response: Support welcomed.

The plan envisages the redevelopment of North Acton Station and creation of a bus interchange to improve accessibility. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 3.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Eric Leach Resident 3.4 Nature of Comment: Object

Not suitable for new homes. Response: Not accepted.

Southern Gateway is already a mixed-use development area that includes high density housing. Outcome: No change.

Name Organisation Policy Reference

Transport for London Statutory 3.4 Nature of Comment: Support with conditions

131 Response: Support welcomed.

Name Organisation Policy Reference

Paul Woods Resident 3.4 Nature of Comment: Comment

Paragraph c) refers to 975 residential units in the Gateway. Please can you confirm that these are additional units to the completed developments within the Gateway site? In addition, reference is made to the figure deriving from the Background Paper No.3 Housing. However, this only quotes a figure of 325 units being delivered in the first five years. Am I therefore right in thinking that the 975 figure noted in Initial Proposal 3.4 sets out the envisaged provision up to 2026? Response: Noted.

This figure does indeed to refer to the net gain in residential units and covers the whole plan period. Outcome: No change.

Initial Proposal 3.4 (a)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.4 (a) Nature of Comment: Support

This Is essential for any development. Response: Support welcomed. Outcome: No change.

Initial Proposal 3.4 (b)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.4 (b) Nature of Comment: Object

We object to the detail proposed because we do not know where and what density this will be.

132 Response: Noted.

More detailed information will be provided in the Development Sites policy document.

Outcome: No change.

Initial Proposal 3.4 (c)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.4 (c) Nature of Comment: Object

We object to the detail proposed because we do not know where and what density this will be. Response: Noted.

More detailed information will be provided in the Development Sites policy document.

Outcome: No change.

Initial Proposal 3.4 (d)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.4 (d) Nature of Comment: Object

This extends an area of high-rise buildings over the railway. Response: Support welcomed.

Outcome: No change.

Initial Proposal 3.4 (e)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.4 (e) Nature of Comment: Support with conditions

The idea is supported but where will these parks be? Green space should be maximized with tree planting to help improve air quality.

133 Response: Support welcomed.

The Southern Gateway Position Statement already identifies options for the provision of new open space within the site itself. In addition, work has recently commenced on producing a new open space strategy for the borough. This strategy, will explore opportunities for new provision in the area to address deficiency, and measures to improve access to existing sites in the surrounding area. Tree planting and other landscaping measures will be seen as a central component of any enhancement strategy.

Outcome: No change.

Initial Proposal 3.5

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.5 Nature of Comment: Support with conditions

Making an attractive town centre would be welcome but where will a new bus interchange be located? Object to 121 additional homes because it is not clear where they will go. Symbols seem to represent housing that is completed. Response: Support welcomed.

With regards to improvements in public transport services and provision for in Greenford Town Centre, the council is currently preparing a detailed Infrastructure Delivery Plan (IDP) and key components will be summarised in and inform any submission proposals. A clear distinction will be made between projects that are programmed and which remain aspirational to ensure the Development Strategy proceeds on a realistic basis.

Amendments will be made in the light of the emerging IDP regarding the possibility of improvements to bus operation and passenger facilities and it is expected that these would be located broadly in its current location.

With respect to the proposed residential quantum more detailed information will be provided in the Development Sites policy document.

Outcome: Accept conditionally.

Name Organisation Policy Reference

Michael Simmons Resident 3.5 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Hanwell Village Green Association Resident 3.5

134 Nature of Comment: Object

Where are the cycle lanes? There is a wide pavement - traffic congestion and poor shops. These are not improved by proposals Response: Noted.

Greenford Broadway currently has average cycle accessibility. Cycle infrastructure improvements will come from small-scale interventions that would be developed at detailed design stages, and will include items such as permeability measures (e.g. off-road routes through green spaces and cycle exemptions from road closures and one-ways), combined with reductions in traffic speeds on the main roads, and some cycle lanes to allow queueing motor vehicles to be passed. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.5 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 3.5 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 3.5 Nature of Comment: Object

Minimal increase in residential accommodation will hamper retail improvements. No likelihood of expansion of public transport - modal shift away from public transport is wishful thinking Response: Not accepted.

In relation to housing issue, it is unclear whether the respondent is arguing for a higher or lower residential quantum?

In relation to the transport issue, the initial proposal seeks improvements to public transport facilities, including the bus terminus, interchange and passenger facilities. The Council’s Transport Strategy includes proposals to improve the bus network in the area, providing better accessibility for people without access to a private car.

Outcome: No change.

Name Organisation Policy Reference

135 JK Gill Resident 3.5 Nature of Comment: Comment

If Greenford is to be improved who will be shopping at Park Royal; the Westway Shopping centre and White City. Response: Not accepted.

The council has commissioned a Joint Retail Needs Study Update which will be published shortly. This will provide a detailed assessment of retail needs and capacity. Outcome: No change.

Initial Proposal 3.6

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.6 Nature of Comment: Object/Support

Object to high density development on the station. This is on an embankment which is not a suitable place to build high rise development which would detract from the natural landmark of Horsenden Hill. Improved public transport links are supported. What is the point of a mixed use area to the north of the station? It is shown as a special opportunity site on the UDP proposal map but site 80 in the text is recorded for Employment uses which should continue. Storage seems an ideal use to continue because of easy access to the A40. Object to Westway Cross expansion. The original permission was contrary to planning policies pressured by ideas of regeneration of the MEL. Its catchment area is restricted by open space and access depends on cars. Large retail centres, leisure and community uses should be promoted in existing town centres not on industrial land, otherwise the town centres will lack facilities Response: Noted.

With regard to Greenford Station this is a key nodal point within the development corridor and the proposals takes forward proposals in the extant development plan.

With regards to Greenford Green, the emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA. The council acknowledges the significance of this site and recognises this at Initial Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Sites Allocations DPD. The guidance within this SPD is intended to be complimentary to the current LDF.

With regards to Westway Cross, this is designated as a neighbourhood shopping centre and this initial proposal seeks to promote better public transport links to this centre and help promote more sustainable shopping patterns rather than significantly expand the shopping centre itself. It is accepted that retail uses are best promoted in existing town centre locations.

Outcome: No change.

136

Name Organisation Policy Reference

Michael Simmons Resident 3.6 Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

SEGRO Business 3.6 Nature of Comment: Support with conditions

We consider that there is a broadly positive area specific framework in terms of the principle of redeveloping /regenerating the area, but consider that further clarity is required in terms of boundaries and targets. In this respect we understand that a draft area framework is being considered, and welcome early dialogue with key stakeholders including SEGRO.

The draft wording reflects to some extent, the historical UDP designation rather than reviewing the site in the context of future priorities and opportunities. In summary our comments on Proposal 3.6 are: • We support the identification of SEGRO’s Rockware site as a specific opportunity within the growth area, • We welcome the opportunity to identify site specific opportunities through the wider LDF process. • We recommend that a cautious approach be adopted to the amount of office space that can be provided and highlight that land south of the canal is not strategically protected employment land and should remain so, • The DS should note that the sites closer to the station are highly accessible and are sequential preferable in terms of growth, density and land-use mix when compared to sites to the north of the canal, including SIL. • We support the identification of residential and other uses as appropriate for delivering the wider regeneration of the area. Recommend early engagement with stakeholders to investigate capacity and delivery opportunities. As per our comments below, we consider that clarity should be provided as to the boundary between the area covered by proposal 3.6 and that addressed under residential hinterlands 4.2 below.

137 Response: Support welcomed.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA. The council acknowledges the significance of this site and recognises this at Initial Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Sites Allocations DPD. The guidance within this SPD is intended to be complimentary to the current LDF. For avoidance of doubt, the geographical boundaries of the site are defined as the site area is bounded by the central line to the south, Oldfield Lane North to the West and North, and Greenford Road to the east. Finally, we welcome further opportunities for early engagement with relevant stakeholders to discuss emerging policy and proposals for this site. Outcome: Accept conditionally.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

Name Organisation Policy Reference

Hanwell Village Green Association Resident 3.6 Nature of Comment: Object

Poor access - lack of infrastructure - overdevelopment of a poor kind. Response: Not accepted. Greenford Station is a key nodal point in the development corridor and the initial proposal sets out the need for providing good public transport, cycling and pedestrian links to/from the regeneration area to the north and to Westway Cross. It also takes forward policies in Ealing’s existing UDP. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.6 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 3.6

138 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 3.6 Nature of Comment: Support

Significant residential population increase needed to improve public transport within the area and new links to Crossrail, e.g. at West Ealing Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

JK Gill Resident 3.6 Nature of Comment: Comment

Not enough demand for 2 shopping centres Response: Not accepted.

This reference is unclear but is assumed to me Greenford Town Centre and Westway Cross neighbourhood shopping centre. The council has commissioned a Joint Retail Needs Study Update which will be published shortly. This will provide a detailed assessment of retail needs and capacity. Outcome: No change.

Initial Proposal 3.7

Name Organisation Policy Reference

Michael Simmons Resident 3.7 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Hanwell Village Green Association Resident 3.7 Nature of Comment: Comment

Needs pedestrianising, greening, carbon neutral development.

139 Response: Noted.

Further details will be provided in the publication draft of the Development Strategy. The Development Management DPD will also set targets securing sustainable design and construction for future development proposals, informed by ongoing evidence base work around energy matters. Outcome: Accepted conditionally. Further details will be provided as part of the Development Management DPD

Name Organisation Policy Reference

M Collins Resident 3.7 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 3.7 Nature of Comment: Support No further comment. Response: Support welcomed. Outcome: No change. Name Organisation Policy Reference

JK Gill Resident 3.7 Nature of Comment: Comment

Every town centre is to be given state of the art shopping centres but there is no evidence of demand for these. Response: Not accepted.

The council has commissioned a Joint Retail Needs Study Update which will be published shortly. This will provide a detailed assessment of retail needs and capacity. Outcome: No change.

Initial Proposal 3.7 (a)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.7 (a) Nature of Comment: Support/Object

We support retail in 4 neighbourhood shopping centres and facilitating walking and cycling. But we have concerns about what you mean by ‘other appropriate development’. Empty shops or blank shop windows make neighbourhood shopping centre unattractive places to shop so that knowing what appropriate development is will encourage such uses.

140 Response: Support welcomed.

In addition to retail shops other appropriate development in such neighbourhood centres would aim to help meet the day-to-day needs of the local population. Examples would include community uses, banks and other services. Outcome: No change.

Initial Proposal 3.7 (b)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.7 (b) Nature of Comment: Support

We support enhancing area around ASDA. Response: Support welcomed. Outcome: No change.

Initial Proposal 3.7 (c)

Name Organisation Policy Reference

Hillingdon Motorist Forum Community/Voluntary Organisation 3.7 (c) Nature of Comment: Support

This proposal is also welcome, could this be an opportunity for co-operation between Ealing and Hillingdon as the area forms part of the border between the two Boroughs. Response: Support welcomed.

Officers from Ealing and neighbouring boroughs meet on a regular basis and seek to cooperate on cross boundary development opportunities wherever possible. Outcome: No change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.7 (c) Nature of Comment: Support with conditions

Support extending Northolt Village boundary but much is a conservation area and the character is important to residents Response: Noted Outcome: No change.

Initial Proposal 3.8

Name Organisation Policy Reference

Ealing Fields Residents Association Community/Voluntary Organisation 3.8

141 Nature of Comment: Support with conditions

We share the aspiration on page 35 of the consultation document to protect the character of suburban neighbourhoods.

However, we have concerns that the sheer scale of the number of additional housing units proposed for the Uxbridge Road/Crossrail Corridor is likely to impact adversely on the adjoining suburban neighbourhoods.

Particular concerns include the provision and location of educational and medical facilities. Very few of these are located along the proposed corridor. Most are located within the surrounding residential neighbourhoods and are already operating at capacity. The need to accommodate additional pupils and patients from the proposed new housing units is likely to place even greater pressures on already oversubscribed facilities.

The consultation documents do not appear to address this concern in any detail and we can only assume that further analysis is being undertaken and will be reported in the awaited Infrastructure Requirements Plan and the Infrastructure Investment Framework.

We look forward to a fresh round of consultation and the opportunity to comment once these key documents are available.

We note that both documents were identified as urgent priorities in the officer report to the 25th March 2009 meeting of the LDF Scrutiny Panel, and at that time it was indicated that they would be available by September 2009.

It is perhaps unfortunate that consultation has taken place without these key inputs. Response: Support welcomed.

The respondent rightly acknowledges that an infrastructure delivery plan (IDP) has been commissioned and will provide some answers as to the detail. This is due to be published shortly. Officers had hoped to commission this study earlier but such studies are expensive and require considerable inputs from a wide range of agencies both internal and external to the council. Postponement of the consultation was not considered appropriate as there had already been a two year delay since the previous round of consultation. There will be another round of consultation in Autumn 2010 and there will be scope and opportunity to formally comment on the IDP at that stage.

Outcome: No change.

Name Organisation Policy Reference

Twyford Abbey Properties Business 3.8 Nature of Comment: Support with conditions

(TAP) agree the protection of residential character whilst providing further residential development, largely at identified sites, such as the Twyford Abbey site E106 which was identified at the "New Issues and Options on strategy and sites" consulted in September 2007. TAP proposes the development of Twyford Abbey Site E106 for: "Residential Development on a refurbished Abbey and setting; creation of new public open space, restoring heritage land and extending the site for nature conservation. New Park for the residents and workers of west Twyford and Park Royal".

142 Response: Noted.

This is still under consideration, and further details regarding the Twyford Abbey site will be provided as part of the Initial Proposals into the Development Sites document, due in Autumn this year. Outcome: No change. Further details are to be provided within the Development Sites policy document and initial proposals will be published in Autumn 2010.

Name Organisation Policy Reference

Britel Fund Trustees Business 3.8 Nature of Comment: Support with conditions

Policy should recognise that existing residential neighbourhoods are in close proximity and bounded by industrial areas and as such, proposals to provide defined boundaries by progressing residential developments on these sites should be supported. Response: Noted.

Outcome: No change at this stage.

Name Organisation Policy Reference

Greater London Authority Statutory 3.8 Nature of Comment: Support

Development proposals should appropriately reflect the Park Royal Opportunity Area Planning Framework. Response: Noted.

Outcome: Accepted. Add footnote.

Name Organisation Policy Reference

Michael Simmons Resident 3.8 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

M Collins Resident 3.8 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

143 Hanwell Village Green Association Resident 3.8 Nature of Comment: Object

They need servicing, greening, carbon neutral development. Where is the Sustainable Development "Planning Policy Statement 1: Delivering Sustainable Development 2005"? Response: Noted.

The objection is unclear. The need to address climate change is seen as being central to the Development Strategy. It is accepted however, that given the spatial structure of the strategy, the document presented at Initial proposals may appear to be fairly silent on this matter. It is agreed therefore that the publication draft of the Strategy should be more explicit in how it seeks to contribute to the objectives of tackling and adapting to climate change, and will be drafted accordingly. For example it is intended that the Strategy will set the overall direction in this respect, and also identify spatially opportunities for decentralised energy networks within the borough. In addition, the Development Management will set standards for sustainable design and construction measures, including carbon emission saving targets for new developments. Evidence base work around energy is currently being prepared which will inform the drafting of the above documents. Outcome: Accepted conditionally. The Development Strategy will be revised to provide a stronger emphasis on achieving climate change objectives. Further details will also be provided as part of the Development Management Strategy.

Name Organisation Policy Reference

Peter L Flatau Resident 3.8 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Eric Leach Resident 3.8 Nature of Comment: Comment.

Most of it too vague and aspirational. Response: Noted. Outcome: No change.

Name Organisation Policy Reference

JK Gill Resident 3.8 Nature of Comment: Comment

The proposal for additional sites for gypsies and travellers and associated infrastructure and facilities - I would question the need for further residential development. Response: Noted.

Outcome: No change.

144

Initial Proposal 3.8 (a)

Name Organisation Policy Reference

Transport for London Statutory 3.8 (a) Nature of Comment: Comment

Residential Neighbourhoods - Promotes residential development at a number of sites along the A40 Corridor. TfL supports the Borough’s proposed designation of six sites which are considered appropriate for residential development (sites 1, 2, 3, 4, 11 and 12 on the attached map). In accordance with PPS3 and the London Plan, TfL considers that in some circumstances mixed use may be appropriate for these sites. The sites are situated along the A40 Corridor between North Acton and East Acton. Their designation for residential development (including potentially some mixed use) aligns with the principle of TfL’s future aspirations for residential development which would be supported by transport infrastructure. Designation of these sites is in accordance with the London Plan (including consultation on the new London Plan). The sites will make a significant contribution towards maximising opportunities for housing development in the borough and are consistent with other policy objectives in the emerging LDF. TfL would welcome the opportunity to promote a further 7 sites along the A40 for residential and mixed use development. TfL would welcome the opportunity to discuss delivery of the sites further with the Borough. Response: Noted.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.8 (a) Nature of Comment: Objection

To protect suburban character high-rise should be excluded. Response: Noted.

The locations referred to in Initial Proposals 1.2 (b) do not include those residential neighbourhoods of the wider A40 Corridor identified in this policy.

Outcome: No change. Initial Proposal 3.8 (b)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 3.8 (b) Nature of Comment: Support

Support improvement of travellers’ site at Bashley Rd. Response: Support welcomed.

Outcome: No change.

145

146 Chapter 4: Enhancing Residential Hinterlands and North – South Links

Initial Proposal 4.1

Name Organisation Policy Reference Hillingdon Motorist Forum Community/Voluntary Organisation 4.1 Nature of Comment: Comment

Again the mention of more homes being constructed, as previously stated public transport cannot provide all the necessary additional transport capacity. Public transport cannot match the flexibility and convenience of private vehicle. Response: Noted. The impact of this development will be carefully assessed and appropriate mitigation will be secured through legal agreements to ensure that any proposals can be accommodated within the highway network. Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 4.1 Nature of Comment: Object

Initial Proposal 4.1 Enhance residential hinterlands - The concept of residential hinterlands in which the objective is to use the local planning framework to protect the character of suburban neighbourhoods is commendable. There are, however, major concerns over the way in which this aspiration has been set out in the consultation document. The map on page 37 of the consultation document indicates potential flaws in the concept of Residential Hinterlands. As drawn, it suggests that the Uxbridge Road/Crossrail Planning Corridor, will stretch as far south down Northfield Avenue as the entrance to Lammas Park and as far south down St Mary’s Road as the lych-gate entrance to St Mary’s church. We suggest that the concept of residential hinterlands will only make sense in planning terms, and is only likely to secure resident acceptance, if it reflects the circumstances on the ground. In practical terms, the proposed northern boundary of ‘Hinterland 10’ (Boston Manor, Northfield, South Ealing) should be moved northwards to the line of the following the residential roads: Leeland Terrace, Seaford Road, Mattock Lane and Grange Road. All the roads to the south of this line are broadly homogenous in their residential use and the nature of their built environment, most of which dates from the early 20th century. Furthermore, these residential areas focus on and share neighbourhood shopping locations such as Northfield Avenue and St Mary’s/South Ealing Road. They are also broadly co-terminus with catchment areas for primary schools, doctors’ surgeries and places of worship. We therefore think it would be mistaken to perpetuate the draft definition in the consultation documents of defining the southern portion of these integrated areas as ‘Hinterlands’, while including their northern portion within the ‘Uxbridge Road/Crossrail Planning Corridor’. Response: Noted. It is important to realise that the concept of the development corridors is not intended to convey any administrative boundary but are intended to provide some broad unifying spatial elements. They are diagrammatic and not meant to be taken literally. A great deal of work has been done in respect of the specific characteristics of the communities across the borough but if this were to added to the text of the strategy it would destroy the document’s brevity and focus. However, it is broadly accepted that the maps can be a little difficult to understand and that do not communicate change especially well. Outcome: Accept conditionally. We will explore further the possibility of including brief and geographically specific commentaries and maps for each of the major communities in the borough.

147 Name Organisation Policy Reference GSK Business 4.1 Nature of Comment: Comment

Initial proposal 4.1 - Enhance residential hinterlands - It is noted that GSK Greenford Site is located within a defined 'Regeneration Hinterland' - Greenford Green. This location is supported as part of the process identify in the initial proposal 4.2 to encourage regeneration through appropriate employment/mixed use development. Response: Noted.

Outcome: No change.

Name Organisation Policy Reference SEGRO Community/Voluntary Organisation 4.1 Nature of Comment: Support with conditions

Chapter 4 – Residential Hinterlands - We note that the DS assumes a more cautious approach in the residential hinterlands outside the growth areas, for example, suggesting that only 3% of the Borough’s housing targets would be met in these areas – although it does suggest that 25% [275,000sq.ft] of new employment floorspace will be provided here. Whilst we acknowledge that maps are at this stage indicative, we would request clarity in terms of the boundaries around Greenford Green in respect of the transition between the A40 growth area and the residential hinterland [area 12]. We consider that there are clear locational characteristics north and south of the canal that allow this differentiation to be made, that is, that south of the canal can be considered to be within the growth area and north of it, the residential hinterland. Subject to the Council’s position on the locational / growth area characteristics of the Greenford Green area, it may be necessary to address the need for greater flexibility in terms of the capacity of these areas to accommodate residential growth, as 3% of overall housing targets does not offer significant flexibility. There is no plan to accompany the following site specific reference, although Butler’s Wharf appears to overlap with the reference to land included within Proposals 3.6 above. Response: Support welcomed.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

148

Name Organisation Policy Reference West Ealing Neighbours Business 4.1 Nature of Comment: Support

We support any plans to enhance the Northfield Avenue shopping area and believe our proposal for a new north-south bus route would contribute to this enhancement. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Michael Simmons Resident 4.1 Nature of Comment: Object

This proposal focuses on the vision and deliverables for the borough's residential hinterlands. There should be no increase in housing without an increase in the Piccadilly line tube service. Response: Not accepted. he residential quantums identified in this chapter are relatively modest. There are also many committed transport improvements that will address some of the challenges identified in this plan. As well as Crossrail this includes a 24% increase in capacity on the Piccadilly Line by 2016. Outcome: No change.

Name Organisation Policy Reference Susan New Resident 4.1 Nature of Comment: Comment

I can only make a general comment using my own neighbourhood, Northfields, as an example. However I think it applies to many other areas. Given that the borough is currently festooned with Shop Local banners I would like to point out that in 1981 I could do virtually all my shopping locally. We had 2 banks, gone, 2 post offices, gone, 3 butchers, 2 remain and a variety of other shops that have now disappeared. We now have a proliferation of fast food outlets and restaurants. Many councils have tried to bring back post offices and in the consultation re The London Plan it mentions temporary use of buildings for arts and the cumulative impact and saturation of a night- time economy. I would suggest that, as in planning applications, neighbourhoods were informed of licence applications by post and not just licence applications being posted on doors and windows. Residents associations should be informed of all change of use applications and license applications. More grants should be made available to independent shops and supermarkets and large businesses should not be allowed frontages and signage out of keeping with the architectural characteristics of the area. Response: Noted.

Regarding consultation on planning applications a facility exists for residents associations to receive the planning weekly list notifying them of applications received by the council. Information is also readily available on the council’s web-site.

Regarding licensing matters Regarding licensing matters, the method and procedure for advertising and consulting on premises licenses is specified in law, and as such there is no legal requirement to undertake a direct consultation. The Council will in the coming months be consulting on a revised Licensing Policy Statement and this will provide an opportunity for businesses and residents to inform the licensing policy for 2011-14. As part of this process we will note this comment and explore how this idea may be incorporated into procedure.

149 Regarding the council’s shop front improvement scheme, businesses may be eligible to apply for a grant of up to 90% of the costs to improve their shopfront. The grants are available to independent businesses within the town centres of Acton, Central Ealing, West Ealing, Hanwell and Southall. Detailed criteria regarding shop fronts etc will be contained within the Development Management policy document and the council is also planning to produce a supplementary planning document on shop front design. This SPD will set out guidelines that seek to improve the image and environment of town centres in the borough, provide the necessary information relating to the policy, processes and permissions needed in the installation or alteration of shop fronts, promote distinctiveness whilst respecting and enhancing conservation area status (where appropriate) and set out the design and architectural principles which need to be considered in relation to shop front design. The guidance will offer practical advice to applicants and developers in preparing and submitting planning applications and is intended to provide a “tool-kit” for development management officers when assessing planning applications. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 4.1 Nature of Comment: Comment

North/South transport is good, however the following needs to be addressed: Cycling and walking; Environmental Buildings; Carbon Neutral buildings and development; Biodiversity. Response: Noted.

Initial Proposal 4.1 already promotes walking and cycling. The need to address climate change is seen as being central to the Development Strategy. It is accepted however, that given the spatial structure of the strategy, the document presented at Initial proposals may appear to be fairly silent on this matter. It is agreed therefore that the publication draft of the Strategy should be more explicit in how it seeks to contribute to the objectives of tackling and adapting to climate change, and will be drafted accordingly. For example it is intended that the Strategy will set the overall direction in this respect, and also identify spatially opportunities for decentralised energy networks within the borough. In addition, the Development Management DPD will set policy targets/standards for sustainable design and construction measures, including carbon emission saving targets for new developments. Evidence base work around energy is currently being prepared which will inform the drafting of the above documents. The Development Management DPD identifies substantial additions to the network of nature conservation sites in the borough. Outcome: Accepted.

The Development Strategy will be revised to provide a stronger emphasis on achieving climate change objectives. Further details will also be provided as part of the Development Management Strategy.

Name Organisation Policy Reference M Collins Resident 4.1

Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

150 Name Organisation Policy Reference Peter L Flatau Resident 4.1 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Eric Leach Resident 4.1 Nature of Comment: Object

A rag bag of proposals for a rag bag of areas (apparently West Ealing does not exist according to map and text). Response: Noted. A great deal of work has been done in respect of the specific characteristics of the communities across the borough but if this were to added to the text of the strategy it would destroy the document’s brevity and focus. However, it is broadly accepted that the maps can be a little difficult to understand and that do not communicate change especially well. Outcome: Accept conditionally. We will explore further the possibility of including brief and geographically specific commentaries and maps for each of the major communities in the borough.

Name Organisation Policy Reference JK Gill Resident 4.1

Nature of Comment: Object

I do not agree with the additional building of new homes. Response: Not accepted.

Residential quantums have been informed by a series of major studies that form essential components of the LDF evidence base. In respect of housing these include both the Strategic Housing Market Assessment (conducted at both local, sub-regional and London wide levels) that examined housing need and capacity and the Strategic Housing Land Availability Assessment (coordinated and led by the GLA) which examined housing supply. Further work has been commissioned in relation to the viability of affordable housing and will be published in due course. Outcome: No change.

Initial Proposal 4.1 (a)

Name Organisation Policy Reference Ealing Civic Society Resident 4.1 (a) Nature of Comment: Object

This cannot be supported due to lack of information. Response: Not accepted. Residential quantums have been informed by a series of major studies that form essential components of the LDF evidence base. In respect of housing these include both the Strategic Housing Market Assessment (conducted at both local, sub-regional and London wide levels) that examined housing need and capacity and the Strategic Housing Land Availability Assessment (coordinated and led by the GLA) which examined housing supply. Further work has been commissioned in relation to the viability of affordable housing and will be published in due course. Outcome: No change.

151

Initial Proposal 4.1 (b)

Name Organisation Policy Reference Ealing Civic Society Resident 4.1 (b) Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No Change.

Initial Proposal 4.1 (c)

Name Organisation Policy Reference Ealing Civic Society Resident 4.1 (c) Nature of Comment: Objection

This should not be confined to the areas 1-12. Separate policies for these areas cannot be supported as their access to public transport and character does not differ from much of the so alled corridors. Response: Noted. It is important to provide a full range of local facilities within these neighbourhoods to minimise the need to travel. Outcome: No change.

Initial Proposal 4.1 (d)

Name Organisation Policy Reference Ealing Civic Society Resident 4.1 (d) Nature of Comment: Objection

This should not be confined to the areas 1-12. Separate policies for these areas cannot be supported as their access to public transport and character does not differ from much of the so called corridors. Response: Noted. Movement is generally constrained to/from these hinterland neighbourhoods and the plan seeks to promote improved north-south links across the borough and enhance links with town centres. Equally important is the provision of a full range of local facilities within these neighbourhoods to minimise the need to travel. Outcome: No change.

Initial Proposal 4.2

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 4.2 Nature of Comment: Objection

We have commented on Butlers Wharf/site 80 and Westway Cross Shopping Centre under 3.6. The retail/leisure floorspace of the latter is already adequate to support employment area provided there is flexibility in uses.

152 Response: Noted.

Name Organisation Policy Reference GSK Business 4.2 Nature of Comment: Support

Initial proposal 4.2 - Regenerate Greenford Green and renew employment sites - GSK supports appropriate employment/mixed uses on the GSK Greenford Site as part of regenerating Greenford Green and notes that the development sites document will in due course deal with specific uses and delivery. It is important that your council ensures that the evidence base supports this approach so that it is consistent with the London Plan and the SIL designation. Response: Support welcomed.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA. The council acknowledges the significance of this site and recognises this at Initial Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Sites Allocations DPD. The guidance within this SPD is intended to be complimentary to the current LDF. Outcome: Accept conditionally. The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

Name Organisation Policy Reference SEGRO Business 4.2 Nature of Comment: Support with conditions

This proposal highlights the Greenford Green industrial area, and also refers to smaller employment sites throughout the hinterland area. Delivery of the regeneration proposals for Greenford Green will be facilitated by the forthcoming Development Sites document. The Development Management policy document will provide more detail on the proposals for suburban neighbourhoods. A statutory Proposals Map will accompany these documents in due course. Infrastructure improvement will be facilitated by the infrastructure planning process. As per previous comments, we recommend that clarity be sought, as to the respective growth area boundaries and the manner in which it will differentiate between strategic and non-strategic employment land. Response: Support welcomed.

The emerging policy will be further reviewed in the light of ELR and following further discussions with the GLA. The council acknowledges the significance of this site and recognises this at Initial

153 Proposal 4.2. The council will also produce a supplementary planning document to guide development and sets out Ealing Council’s vision for the area and its expectations in regard to land uses, the form and layout of the area, design principles, and guidance regarding planning obligations and the phasing of development. It main role is as a planning policy document will be to add more detail than is found in the LDF DPDs (Local Development Framework Development Plan Documents) including the Development Strategy 2026 and the Sites Allocations DPD. The guidance within this SPD is intended to be complimentary to the current LDF. Outcome: Accept conditionally.

The emerging policy will be further reviewed in the light of ELR, following further discussions with the GLA and the emerging draft of the Greenford Green SPD.

Name Organisation Policy Reference Michael Simmons Resident 4.2

Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 4.2 Nature of Comment: Object

North/South transport is good, however the following needs to be addressed: Cycling and walking; Environmental Buildings; Carbon Neutral buildings and development; Biodiversity Response: Noted.

Initial Proposal 4.1 already promotes walking and cycling within the Hinterlands. The need to address climate change is seen as being central to the Development Strategy. It is accepted however, that given the spatial structure of the Strategy, the document presented at Initial proposals may appear to be fairly silent on this matter. It is agreed therefore that the publication draft of the Strategy should be more explicit in how it seeks to contribute to the objectives of tackling and adapting to climate change, and will be drafted accordingly. For example it is intended that the Strategy will set the overall direction in this respect, and also identify spatially opportunities for decentralised energy networks within the borough. In addition, the Development Management DPD will set policy targets/standards for sustainable design and construction measures, including carbon emission saving targets for new developments. Evidence base work around energy is currently being prepared which will inform the drafting of the above documents. The Development Management DPD identifies substantial additions to the network of nature conservation sites in the borough. Outcome: Accepted.

The Development Strategy will be revised to provide a stronger emphasis on achieving climate change objectives. Further details will also be provided as part of the Development Management Strategy.

154 Name Organisation Policy Reference M Collins Resident 4.2 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 4.2 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Initial Proposal 4.3

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 4.3 Nature of Comment: Object

The Greenford depot already impacts on the Brent River Park and adjoining high school in an unacceptable manner. The uses should be transferred to an industrial area in the long term. Response: Not accepted.

As an existing waste facility the London Plan (policy 4A.24) requires the Council in its LDF documents to safeguard such facilities for waste management purposes, and where appropriate maximise their use. A separate waste development plan document is currently being prepared with neighbouring West London Waste Authority boroughs. This plan aims to identify and safeguard sufficient sites for waste management facilities in the borough, and the potential of Greenford Depot is currently being considered as part of this exercise. Further details of the waste plan will be published in Autumn 2010. It is agreed however that any potential future proposals for this site would need to be assessed in terms of their impact on and compatibility with neighbouring uses. It is intended that the waste plan will also contain policy criteria to ensure that developers consider and mitigate the impacts of their development on the environment, the community and the appearance of the local area. Outcome: No change.

Name Organisation Policy Reference GSK Business 4.3

Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

155 Name Organisation Policy Reference Michael Simmons Resident 4.3

Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference M Collins Resident 4.3 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Association Community/Voluntary Organisation 4.3 Nature of Comment: Object

North/South transport is good, however the following needs to be addressed: Cycling and walking; Environmental Buildings; Carbon Neutral buildings and development; Biodiversity. Response: Noted.

Initial Proposal 4.1 already promotes walking and cycling within the Hinterlands. The need to address climate change is seen as being central to the Development Strategy. It is accepted however, that given the spatial structure of the Strategy, the document presented at Initial proposals may appear to be fairly silent on this matter. It is agreed therefore that the publication draft of the Strategy should be more explicit in how it seeks to contribute to the objectives of tackling and adapting to climate change, and will be drafted accordingly. For example it is intended that the Strategy will set the overall direction in this respect, and also identify spatially opportunities for decentralised energy networks within the borough. In addition, the Development Management DPD will set policy targets/standards for sustainable design and construction measures, including carbon emission saving targets for new developments. Evidence base work around energy is currently being prepared which will inform the drafting of the above documents. Outcome: Accepted. The Development Strategy will be revised to provide a stronger emphasis on achieving climate change objectives. Further details will also be provided as part of the Development Management Strategy.

Name Organisation Policy Reference Peter L Flatau Resident 4.3 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

156

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 4.3 Nature of Comment: Support

Vital to retain and expand the recycling resource. The thinking is too vague and generalised. Response: Noted.

Full details of the council’s plans for the management of waste will be dealt with in a separate West London Waste Plan. It will also form part of Ealing’s LDF. The plan aims to identify and safeguard sufficient sites for waste management facilities in the borough. This site will also be included in the Development Sites policy document and this will also examine any scope for further development of this site. Outcome: No change.

Initial Proposal 4.4

Name Organisation Policy Reference Michael Simmons Resident 4.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 4.4 Nature of Comment: Support with conditions/Object

New West London orbital underground through Ealing Broadway is unlikely to be funded. Greenford station to West Ealing would be a loss of public transport access. Service should continue to Ealing Broadway if necessary by building a 5th track. Extension of rail services from Greenford to Northolt then Ruislip along Central Line. We support improved interchange with Chiltern Line. Response: Support welcomed.

Amendments to be made in the light of the emerging IDP. The council supports the building of a new railway track between West Ealing and Ealing Broadway however acknowledges that it is unlikely to be affordable during the plan period.

157 Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 4.4 Nature of Comment: Support

We endorse the following statements on page 40 of the consultation document: “Congestion on orbital (north-south) routes is a feature of Ealing rush hours. . . . These problems disproportionately affect residents of Ealing’s residential hinterlands, particularly since these residents are disproportionately dependent on cars for movement from home to work and other destinations. Clearly, these factors . . . conspire to make it more difficult to achieve sustainable communities in these hinterland locations.” “Studies have indicated that in general, in West London, public transport journey’s originating and ending at points located away from the established radial public transport routes take up to five times as long as car journeys. The improvement of orbital public transport links between interchanges on the radial routes is vital as a means of facilitating the improved sustainability of these hinterland communities” “More generally, improved bus services on north-south routes are necessary, as are improved public transport interchange facilities where these intersect with radial routes.” Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference GSK Business 4.4 Nature of Comment: Support

GSK supports the West London Orbital proposal in order to improve North/South accessibility. If implemented these proposals will have significant benefits for businesses and employees in West London. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference West Ealing Neighbours Community/Voluntary Organisation 4.4 Nature of Comment: Support with conditions

The impact of Crossrail is likely to be significant for West Ealing. We urge the Council to do all in its power to ensure a good transport hub/interchange is built into plans for the new ticket office, whether it is in Manor Road or a nearby location. Whilst we recognise that Crossrail itself has a key role to play here, so too does the Council. We hope, for example, that Crossrail, Ealing Council and TfL will work together to design in from the outset a proper bus pull-in whether in front of the station or at Waitrose (as originally planned for the Waitrose site). Response: Noted.

The council has been in regular dialogue with Crossrail, Transport for London and Network Rail in relation to the design, layout and function of the planned Crossrail stations in the Borough. The detailed design process for West Ealing Station will be commencing in the next 12 months and the Council will continue to ensure that the design meets the needs of all future users. Outcome: No change.

158 Name Organisation Policy Reference National Grid Property Holdings Business 4.4 Nature of Comment: Support

In principle, NGP support proposals to promote the north-south transport links. In particular, NGP support the proposals for the Southall bridge widening. In support of the Development Strategy vision, the Southall bridge widening is part of the proposals for the redevelopment of the Southall Gas Works site. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Susan New Resident 4.4 Nature of Comment: Support

Initial Proposal 4.4 - But I think the West London Orbital should not be included as it will not be built within the time frame of the framework and therefore cannot be used for justification for the influence it might or might not have in the future. Response: Support welcomed. The council is currently preparing a detailed Infrastructure Delivery Plan (IDP) and key components will be summarised in and inform any submission proposals. A clear distinction will be made between projects that are programmed and which remain aspirational to ensure the Development Strategy proceeds on a realistic basis. Outcome: Accept conditionally. Amendments to be made in the light of the emerging IDP.

Name Organisation Policy Reference M Collins Resident 4.4 Nature of Comment: Support

We also need to enhance links from NW to SE i.e. Ealing Town Centre. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Peter L Flatau Resident 4.4 Nature of Comment: Support

"New West London Orbital Line" NWLOL - passing through Ealing Broadway Station. (EBS). When EBS is re-developed it is essential that provision is made to accommodate this additional service. EBS is presently over stretch at peak times. This "NWLOL" + Crossrail will further crowd EBS bus terminal. All the above further re-inforce the requirement for a proper multi-transport interchange at EBS. Response: Noted.

The New West London Orbital Line was developed as a concept by Capita Symonds for West London Business. Whilst Ealing Council supports proposals for improving north-south connections in the Borough, the scheme has no funding or current status. Detail as to what would need to be provided to accommodate this at Ealing Broadway has not been sufficiently developed and there are no plans at present to accommodate this scheme. Ealing Council is leading on developing a

159 study looking at the best option for a long-term multi-modal interchange at Ealing Broadway.

Outcome: No change. The council is currently preparing a detailed Infrastructure Delivery Plan (IDP) and key components will be summarised in and inform any submission proposals. A clear distinction will be made between projects that are programmed and which remain aspirational to ensure the Development Strategy proceeds on a realistic basis.

Name Organisation Policy Reference Eric Leach Resident 4.4 Nature of Comment: Support

Improvements needed N/S through West Ealing: + LIDO Junction improvements + bus Perivale to West Middlesex Hospital. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 4.4 Nature of Comment: Support

Too much hope attached to big capital projects, notably Rail - beyond LBE's control. Population expansion in the hinterland area vital to encourage new north-south bus provision. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference JK Gill Resident 4.4 Nature of Comment: Support

Any improvements must be in tandem with the Crossrail proposals. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Transport for London Statutory 4.4 Nature of Comment: Support

160 that the current status, level of commitment and funding, lead agencies and timescales are clearly and consistently identified and are related to the proposed Development Strategy. Many of the proposed improvements are not currently programmed and are future aspirations which should be clearly identified as such to avoid confusion. This would ensure compliance with adopted London Plan Policy 3C.1 and 3C.2, and should take account of the indicative list of transport schemes in Table 6.3 of the draft replacement Plan. Response: Support welcomed.

Amendments to be made in the light of the emerging IDP.

161 Chapter 5: Protecting and Enhancing Ealing’s Green and Open Spaces

Initial Proposal 5.0

Name Organisation Policy Reference Wildberry Nature Reserve Community Community/Voluntary Organisation 5.1 Nature of Comment: Support

The Community Association supports the proposal to designate and manage the Wildberry Nature Reserve (near Boston Manor tube station alongside Wildberry Close ((off Cawdor Crescent)) between Boston Parade and the Gardens of Clitherow Avenue) as a Site of Interest for Nature Conservation. Response: Noted. Outcome: No change. Sites designated for their nature conservation value will be listed within the Development Management Document and mapped on the Proposals Map.

Initial Proposal 5.1

Name Organisation Policy Reference Ealing Civic Society Community/Voluntary Organisation 5.1 Nature of Comment: Object

Object to building on MOL. The space between the canal and railway has already been intruded upon by housing. But Glade Lane Canal side Park is established as an attractive area with developing nature conservation value The canal side is a green corridor and nature conservation site where development is excluded by existing policies and proposed strategies. This is an area of district park deficiency with no proposal to relieve this. Any other land available should be added to the total green space not used as an excuse to build on high amenity land near the canal. Residential moorings along the towpath are likely to be vandalised. They should be located on the other side of the canal in an area that is not deficient in nature conservation sites. Response: Noted. The reconfiguration of open space, employment land, special opportunity site and residential space in this area is designed to improve its function and usability. Although the exact arrangement of this space is still to be finalised, it is intended that there would be no net loss of open space. Furthermore, given the ecologically value of the canal, a buffer would be formed between any built development and the canal edge. Outcome: No change. Further details regarding the arrangement of this space are to be published as part of the initial proposals for the Development Management Document due in September this year.

Name Organisation Policy Reference

GSK Business 5.1 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No Change.

162

Name Organisation Policy Reference Ealing Fields Residents' Association Community/Voluntary (EFRA) Organisation 5.1 Nature of Comment: Support

Initial Proposal 5.1 Protect and enhance Metropolitan Green Belt - The protection and enhancement of existing open space will be even more important than it already is if a significant number of additional housing units are to be built in the Borough.

It is vital that every resident and family member has immediate and direct access to open air and superviseable space.

It is not acceptable to: • rely on distant parks, recreation grounds or play areas to provide these facilities, or • have to cross busy roads to reach them.

Where construction takes the form of flats, it is essential that each development includes open air play and recreation areas.

The planning guidelines should include provisions to ensure that developers comply with this requirement. Response: Noted.

The Council are currently preparing an open space strategy for the borough which will seek to ensure the right provision of open space in the borough relative to population growth. This strategy will inform the Development Strategy, Development Management DPD and the Infrastructure Delivery Plan. It is intended that provision standards required as part of new developments for children’s play space, garden space and amenity space will be set out in the Development Management DPD. Outcome: No change.

Further details regarding provision standards will be provided as part of the Development Management DPD.

Name Organisation Policy Reference

Martin Gorst Resident 5.1 Nature of Comment: Support

I am concerned about the proposals to convert part of Gunnersbury Park into housing and feel it is very important not to concrete over any more green space. Response: Noted.

Gunnersbury Park is located within the LB of Hounslow and is therefore not covered in Ealing’s LDF documents. It is noted though that the park is jointly managed by the LB’s of Ealing and Hounslow. The Council will endeavour to engage with Hounslow and other neighbouring boroughs in the development of their own LDF documents, particularly where cross boundary issues may arise.

Outcome: No Change.

163 Name Organisation Policy Reference

Michael Simmons Resident 5.1 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Greater London Authority Statutory 5.1 Nature of Comment: Support with conditions

An audit of existing open space and an assessment of local open space needs should be undertaken in accordance with policies 2.18, 3D.12 and 7.8 of the draft replacement London Plan. 7.8 refers to addressing local deficiencies. Response: Noted.

An Open Space Strategy is currently being prepared for the borough, which will supersede the existing Parks Strategy published in 2003. This new strategy will be prepared in accordance with the requirements of PPG 17, and the Mayor’s/Cabe’s guidance on producing open space strategies. Both an audit of existing open space and an assessment of open space needs are presently being undertaken as part of this exercise. The audit is expected to be completed by early summer. Outcome: Accept.

The findings of the open space strategy will inform the LDF.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 5.1 Nature of Comment: Support with conditions

It is vital to protect Metropolitan green belts

Response: Noted. Outcome: No change.

The forthcoming Proposals Map will define areas designated as Green Belt. The Open Space Strategy will review the status of existing Green belt in the borough.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 5.1 Nature of Comment: Support with conditions

This needs to be increased and protected. At the moment it is being built on slowly e.g. Brent River Park. Southall back garden developments - no enforcement action.

164 Response: Noted.

There is a policy presumption against built development within Green Belt, which is defined in national policy (PPG 2), and regional guidance (London Plan). The status of existing Green Belt and MOL will be tested as part of the Open Space Strategy currently being prepared for the borough, to ensure that such land currently satisfies the tests for inclusion. Outcome: No Change.

Name Organisation Policy Reference

M Collins Resident 5.1 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 5.1 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Eric Leach Resident 5.1 Nature of Comment: Object

Initial Proposal 5.1 - 1. Don't want all this new housing in Ealing. 2. I don't want residential tower blocks in built-up areas. 3. If we must have 1. These homes will have to built on green and open spaces next to Police Stations, Hospitals, and Schools on Green and Open Spaces

Response: Noted. There is a policy presumption against built development on open space unless it directly supports its open space function. If the borough is to accommodate further growth, the need for open space as a central component of this built environment will inevitably grow. Accordingly, in this context, established open space will become an evermore valuable resource. The need to protect existing sites, and identify new sites for protection from irreversible development is therefore central to the Strategy. It is accepted however, that in some rare cases, built development may be deemed acceptable, either because exceptional circumstances exist to justify this development, or because a site no longer satisfies the tests for inclusion as open space. The later of the two scenarios will be identified through the open space strategy. It should be noted that this is seen as being very much an exception to the rule, and where such exceptions exist, these will already be identified through the LDF. Outcome: No change.

165

Name Organisation Policy Reference

JK Gill Resident 5.1 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Initial Proposal 5.1 (a)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.1 (a) Nature of Comment: Comment

Down Barns- Reference to West London Shooting Range omitted which is main land use rather than agriculture Response: Noted. Outcome: Accepted. The policy in the publication draft of the Development Strategy will be amended to include reference to the West London Shooting Range.

Initial Proposal 5.1 (b)

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.1 (b) Nature of Comment: Object

Object to loss of green belt by building a school where the A40 crosses Oldfield lane. Northolt and Greenford Countryside Park needs toilets and an Environmental Centre. Medlar Fields is part of the Country Park linking Northala Field to Rectory Park. Response: Noted. Objection noted in respect of proposed new school on Green Belt. The need for a new secondary school in this part of the borough is critical. No other viable alternative sites have been identified which are not also designated as open space. Moreover, whilst there would be some net loss of open space, the proposal will also seek to enhance this open space and improve its accessibility.

The need for additional facilities at Northolt and Greenford Countryside Park is noted. This will be logged and considered further as part of the Open Space Strategy for the borough. Outcome: No Change.

166 Initial Proposal 5.2

Name Organisation Policy Reference

Government Office for London Statutory 5.2 Nature of Comment: Comment

Following the experience of LB Sutton, should you be seeking to de-designating MOL boundaries, we recommend that you ensure you have solid evidence to back up special circumstances for this policy approach and discuss it with GLA beforehand. Response: Noted.

It is proposed to review Green Belt and MOL boundaries as part of the Open Space Strategy. Outcome: Accept conditionally.

Review to be undertaken in tandem with open space strategy.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.2 (a-e) Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No Change.

Name Organisation Policy Reference Ealing Fields Residents’ Association Community/Voluntary Organisation 5.2 (a-e) Nature of Comment: Support

Initial Proposal 5.2 Protect and enhance Metropolitan Open Land - The protection and enhancement of existing open space will be even more important than it already is if a significant number of additional housing units are to be built in the Borough.

It is vital that every resident and family member has immediate and direct access to open air and superviseable space.

It is not acceptable to: • rely on distant parks, recreation grounds or play areas to provide these facilities, or • have to cross busy roads to reach them.

Where construction takes the form of flats, it is essential that each development includes open air play and recreation areas.

The planning guidelines should include provisions to ensure that developers comply with this requirement.

167 Response: Noted.

The Council is currently preparing an open space strategy which will seek to ensure the right provision of open space in the borough relative to population growth. This strategy will inform the Development Strategy, Development Management DPD and the Infrastructure Delivery Plan. It is intended that provision standards for children’s play space, garden space and amenity space will be set out in the Development Management DPD.

Outcome: No change.

Further details regarding provision standards will be provided as part of the Development Management DPD.

Name Organisation Policy Reference

West Ealing Neighbours Community/Voluntary Organisation 5.2 Nature of Comment: Support with conditions

5.2 Protect and Enhance Metropolitan Open Land - We are interested in the possible open space use of the two Hanwell cemeteries whilst ensuring their prime use if fully respected and protected. Response: Noted.

Both the Westminster and Kensington & Chelsea cemeteries are designated as Metropolitan Open land. There are currently no proposals to change their status. Only appropriate ancillary development, which directly supports the open space function of these sites will be permitted. Outcome: No Change.

Name Organisation Policy Reference

Twyford Abbey Properties Business 5.2 Nature of Comment: Object

Initial Proposal 5.2 - Protect and enhance the Metropolitan Open Land - TAP object to the designation of the Twyford Abbey Site as Metropolitan Open Land (MOL). It is considered that the site is inappropriately designed as MOL given its enclosure on three sides by existing residential development and with the North Circular forming an effective boundary and visual screen on its northern side. The site is private land which is not currently open to public and the openness of the site serves no strategic function. The Twyford Abbey site should be removed from the designiation of MOL Response: Noted.

The site is considered to satisfy the tests for inclusion as MOL as set out in London Plan policy 3D.10. In particular it is considered to contribute to the physical structure of London by being clearly distinguishable from the built-up area. Moreover, the site contains features or landscape (gardens) of historic value at a metropolitan level. This will be reviewed further however as part of the Open Space Strategy. The council are particularly keen to open up public access to this site. Outcome: No change.

However, the MOL status of this site is to be reviewed further as part of the emerging open space strategy.

168 Name Organisation Policy Reference

Greater London Authority Statutory 5.2 Nature of Comment: Support with conditions

The strongest protection should be afforded to Green Belt and Metropolitan Open Land and any proposed amendments to these boundaries should be discussed with GLA Officers. In accordance with Policy 7.22 of the Draft Replacement London Plan, existing allotments within the borough need to be protected, and potential open spaces that could be used for community gardening need to be identified. This should be included within Map 9, as well as reflected in the main policy text..2 Protect and Enhance Metropolitan Open Land - We are interested in the possible open space use of the two Hanwell cemeteries whilst ensuring their prime use if fully respected and protected. Response: Noted.

Work has recently commenced on preparing a new Open Space Strategy for the borough which will review the status of Green Belt and MOL land. In undertaking this work we will seek to engage with the GLA. It is envisaged that those areas designated as Green Belt and MOL will remain largely unchanged in the emerging LDF documents. Both Council run and privately managed allotments are designated and protected as Community Open Space with the borough.

Outcome: Accept conditionally.

The findings of the Open Space Strategy will inform the emerging LDF documents. Sites designated and protected as Community Open Space will be listed in the Development Management DPD and mapped on the Proposals Map.

Name Organisation Policy Reference

Michael Simmons Resident 5.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Hallmark Property Group Business 5.2 Nature of Comment: Support Initial Proposal 5.2 - Protect and enhance Metropolitan Open Land - My client is generally supportive of proposals to enhance Metropolitan Open Land. Policy should however acknowledge the important role that new development can make in enhancing the quality and improving access to these areas. National planning policy (PPS9 - Biodiversity and Geological Conservation) recognizes this, and places the emphasise much more on the need to "conseve or enhance", rather than simply "protect". It is considered that policy should be amended to reflect national policy on this issue.

169 Response: Not accepted.

Only ancillary development which is directly related to the open space use of the site will be permitted on land designated as MOL. Whilst the Council clearly supports the enhancement of existing open space, in most instances this can be achieved without any loss of space to development. The Open Space Strategy will explore options/actions for enhancing existing open space in the borough. This will also be reflected through the Infrastructure Delivery Plan. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Association Community/Voluntary Organisation 5.2 Nature of Comment: Comment

More areas must be designated as Metropolitan Open Land Response: Noted.

The Open Space Strategy will review the network of MOL in the borough, and will explore whether other sites not currently designated as MOL also satisfy the tests for inclusion as MOL. Outcome: Accept conditionally.

The findings of the open space strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

M Collins Resident 5.2 Nature of Comment: Support

No further comment.

Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 5.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 5.2 Nature of Comment: Support with conditions

Proposals should specifically include protection and enhancement of two intensively used open spaces - Haven Green and Dean Gardens

170 Response: Not accepted.

Haven Green and Dean Gardens are not presently designated as MOL as they are not felt to satisfy the tests for inclusion as such as defined in London Plan policy 3D.10. Both sites are however protected as Public Open Space. Outcome: No Change. Retention of both sites as Public Open Space.

Name Organisation Policy Reference

JK Gill Resident 5.2 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.2 (a) Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No Change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.2 (f) Nature of Comment: Object

BRP – Object to the intensive recreation area proposed adjacent to Gurnell Pool. The retention of uncluttered flood plain in narrow sections like this is essential for the safe dispersal of flood water.

Norwood Green is objected to because a school has been allowed on the Norwood Hall MOL Response: Noted

Outcome: No Change.

Initial Proposal 5.3

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.3 (a-d)

171 Nature of Comment: Support

No further comment. Response: Support welcomed

Outcome: No Change.

Name Organisation Policy Reference Havelock Estate Residents Steering Group Community/Voluntary Organisation 5.3 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Ealing Fields Residents’ Association Community/Voluntary Organisation 5.3 Nature of Comment: Support

Initial Proposal 5.3 Protect and enhance Green Corridors - Green corridors provide an irreplaceable resource for both wildlife and residents. Every effort should be made to protect and extend them, especially against a background of proposed high density developments.

Towpath land alongside the River Brent and the canals represents a major recreational asset and should be protected by planning controls which recognise the green nature of these routes.

The proposal to incorporate planting and buffer landscaping for cycle paths and footpaths where these follow the road network is welcomed.

The planning guidelines should include provisions to ensure that developers comply with these requirements. Response: Support welcomed.

Noted that whilst the canal is currently designated as Green Corridor, the towpath of the River Brent is not. The inclusion of the River Brent (and path) as Green Corridor will be considered as part of the Open Space Strategy. Further details regarding buffer zones etc are to be provided within the Development Management DPD. Outcome: Accept conditionally. The findings of the open space strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

172 West Ealing Neighbours Community/Voluntary Organisation 5.3 Nature of Comment: Comment

5.3 Protect and Enhance Green Corridors - There is no mention here of the importance of back gardens as green corridors. We believe back gardens are vital for a healthy environment and community and should be specifically mentioned in this context. There is also no mention of allotments and their role as not just green corridors but also as vital habitats for wildlife. Response: Noted.

The value of back gardens as green space is recognised. It is proposed that the Development Management DPD will include policies to also protect informal open space, including back gardens, in addition to those formally designated. It is not proposed however that rear gardens be designated as Green Corridor, as they don’t lend themselves to being designated as Green Corridors in the same way as rail, road and waterway corridors. Moreover, permitted development rights which exist for residential properties are likely to override Green Corridor objectives. Policies for the protection and enhancement of allotments will be covered in the Development Management DPD. It should be noted that allotments are currently designated as Community Open Space, and it is proposed that this is taken forward into the LDF.

Outcome: No Change.

Name Organisation Policy Reference

Hallmark Property Group Business 5.3 Nature of Comment: Support

Initial Proposal 5.3 - Protect and enhance Green Corridors - My client is generally supportive of proposals to maintain and improve the borough's green spaces and green corridors. Policy should however acknowledge the important role that new development can make in enhancing the quality and improving access to these areas. National planning policy (PPS9 - Biodiversity and Geological Conservation) recognizes this, and places the emphasis much more on the need to "conserve or enhance", rather than simply "protect". It is considered that policy should be amended to reflect national policy on this issue. Response: Noted.

Only ancillary development which is directly related to the open space use of the site will be permitted on land designated as Green Corridor. Whilst the Council also supports the enhancement of existing open space, in most instances this can be achieved without losing some of this space to development.

Outcome: No change.

Name Organisation Policy Reference

Michael Simmons Resident 5.3 Nature of Comment: Support

No further comment.

173 Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 5.3 Nature of Comment: Support

Enhancement is the most important as this is very limited and protection at the present time is sadly lacking.

Response: Noted.

An Open Space Strategy is currently being prepared for the borough. It is intended that this strategy will comprise an action plan, outlining investment priorities for open space in the borough. Enhancement could be in the form of improved facilities within existing green space or through improved access to open space (both physically and in terms of access rights).

Outcome: No change. The findings of the open space strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

M Collins Resident 5.3 Nature of Comment: Support

Initial Proposal 5.3 - Our borough needs to ensure that even smaller pockets and rail corridor enhanced as green corridors. We have to restore the balance between overcrowding-back garden developments and green space for the health of all residents and balance of wildlife etc. Response: Noted. Outcome: No Change.

Name Organisation Policy Reference

Peter L Flatau Resident 5.3 Nature of Comment: Support

Name Organisation Policy Reference

JK Gill Resident 5.3

174 Nature of Comment: Support

No further comment. Response: Support Welcomed. Outcome: No Change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.3 (c) Nature of Comment: Comment

Road and rail green corridors have an important function in helping to reduce pollution and noise for adjoining development and enhancing amenity. Yet the A40 Green Corridor is becoming littered with advert hoardings. A definite policy backed up by effective environment, is needed to reverse this trend. Response: Noted.

This will be covered in the Development Management DPD. Outcome: No Change.

Initial Proposal 5.4

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.4 Nature of Comment: Comment

What is the difference between a Site of Metropolitan Importance and a Site of Regional Importance for Geodiversity? Response: Noted.

‘Sites of Metropolitan Importance’ (or SMI for short) are defined because of their biodiversity significance (in terms of flora/fauna) at a regional level. Sites designated as being of ‘Regional Importance for Geodiversity’ recognise their geological value. In the case of Horsenden Hill, this site is designated both for its ecological and geological importance. Both are defined in the London Plan, and reflected through the LDF. Outcome: Accept. Further information regarding both designations will be provided in the supporting text to the policy in future iterations of the plan.

Name Organisation Policy Reference

Ealing Fields Residents Association Community/Voluntary Organisation 5.4 Nature of Comment: Support

No further comment Response: Support welcomed.

175 Outcome: No change.

Name Organisation Policy Reference

Twyford Abbey Properties Business 5.4 Nature of Comment: Support with conditions

Initial Proposal 5.4 - Protect the natural environment - biodiversity and geodiversity - We do not disagree with this designation but consider that there would be scope for some redevelopment within the site without harming its nature conservation importance. Large parts of the site will remain free from development allowing further protection and promotion of nature conservation. Response: Support noted.

It is not generally considered appropriate to allow built development on land designated as being of nature conservation value, and for this reason a general policy presumption against built development within such sites exists. The 2006 review of nature conservation sites undertaken in the borough, recommends the continued inclusion of this site as a SINC. Specific development proposals will be considered on their individual merits.

Outcome: No change.

Name Organisation Policy Reference

Hallmark Property Group Business 5.4 Nature of Comment: Support with conditions

Initial Proposal 5.4 - Protect the natural environment - biodiversity and geodiversity - My client is generally supportive of proposals to conserve and enhance the network of nature conservation sites in the borough. Policy should however acknowledge the positive contribution new development can have on these sensitive sites, particularly in terms of the the management of these areas. It is considered that policy should be amended to reflect national policy (PPS9) on this issue. Response: Noted.

It is not generally considered appropriate to allow built development on land designated as being of nature conservation value, and for this reason a general policy presumption against built development exists. The 2006 review of nature conservation sites undertaken in the borough, recommends the continued inclusion of this site as a SINC. Specific development proposals will be considered on their individual merits. Outcome: No Change.

Name Organisation Policy Reference

Ealing Transition Steering Group Community/Voluntary Organisation 5.4

176 Nature of Comment: Comment

Specific Considerations - 2. Food Security - We believe that the LDF should undertake to explore local food growing capacity, either in respect of the Borough’s own needs or in partnership with neighbouring West London and London-fringe authorities. Land and related local transport links should be identified, where intensive fossil-fuel-free horticulture and agriculture can ensure food supplies for this community. The strategy might also explore enabling the development of Community Supported Agriculture (CSA) where producers and consumers are partners in ensuring secure local food needs. (Achieving this is far from unrealistic. Cuba suffered a 70% loss of oil supplies almost overnight in the 1990s when its key supplier, the Soviet Union collapsed. Cuba responded by creating localised intensive organic market gardens many run by local communities. Havana, a far from ‘green’ city, now grows over 80% of its fruit & vegetables within the city limits and Cuba is now a major exporter of organic fertilizers). Strategic food security planning will need to include not just land use and transport planning, but also re-skilling and re- educating the workforce and the community to undertake the new local jobs in food production, distribution and processing. The LDF needs to plan for the infrastructure needs for this re-skilling combined with integrating skills development within the local education system. Preservation of existing open space and growing space, whether public or privately owned, should now become a priority. Specifically there should be no loss of open space in Gunnersbury Park to housing and commercial development. The practice of paving over gardens should be stopped for environmental and food security reasons through planning regulation. Planning requirements should also be considered whereby new developments should be required not only to produce energy on site but also grow a proportion of their food, harvest rainwater etc. Response: Noted.

The Council are keen to ensure that proper provision of allotment space is provided for in the borough. An analysis of supply and demand, both existing and future, is currently being undertaken as part of the Open Space Strategy. The Development Management DPD will comprise policies which promote the use of green roofs/walls and other innovative measures for increasing green space. In developing policies in the Development Management Development Plan Document, we will also explore opportunities for setting standards to secure space for food growing as part of new development proposals. Potentially this could be conditioned as part of landscaping details. The practice of paving over front gardens is outside of the remit of Planning Policy and is controlled at a national level through the General Permitted Development Order.

Outcome: Accepted conditionally. The findings of the open space strategy will inform the emerging LDF documents, and in particular the Development Management DPD and Infrastructure Delivery Plan. In developing policies in the Development Management DPD the Council will explore opportunities for setting standards for securing space for food growing as part of new development proposals.

Name Organisation Policy Reference

Michael Simmons Resident 5.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

177 Community/Voluntary Central Ealing Residents Association Organisation 5.4 Nature of Comment: Support

Absolutely essential. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference Hanwell Village Green Community Community/Voluntary Association Organisation 5.4 Nature of Comment: Support

This needs to increase. More trees on the street; green areas in housing, car parking and employment areas; green routes (very poor approach considering the critical stage we are at) Response: Noted.

Further details however will be provided as part of the emerging Development Management DPD. It is intended that this document will set standards in terms of the provision of green space as part of new development, and set criteria for the protection of existing space of value. Outcome: No Change, with respect of the Strategy document, although further details will be provided in the Development Management DPD.

Name Organisation Policy Reference

M Collins Resident 5.4 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 5.4 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

178 JK Gill Resident 5.4 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Initial Proposal 5.5

Name Organisation Policy Reference

Thomas Wrenn Homes Ltd Business 5.5 Nature of Comment: Comment

Initial Proposal 5.5 (Promote parks, sports, outdoor recreation and travel) Consider the last sentence of Initial Proposal 5.5 to be over-prescriptive, particularly in respect of Community Open Space. Alternative uses may be appropriate dependent on location, site characteristics and specific local needs (perhaps with a caveat that any alternative development should be compatible with objectives of the Core Strategy). This, and the prospect of resources being available to ensure that specific sites are able to meet Community Open Space objectives, should be considered in the proposed updating of the Council’s Parks and Open Space Strategy (referred to on page 48). Response: Not accepted.

There is a general presumption against built development on Community Open Space, unless it directly relates to the open space function of the site. Whilst the Council are keen to promote improved access to such space, in most instances this should be achievable without losing any of this space to development. Both the Open Space Strategy and the Infrastructure Delivery Plan will review opportunities/actions for enhancing existing community open space. Outcome: No Change.

Name Organisation Policy Reference

Ealing Fields Residents Association Community/Voluntary Groups 5.5

179 Nature of Comment: Object

The protection and enhancement of existing open space will be even more important than it already is if a significant number of additional housing units are to be built in the Borough.

It is vital that every resident and family member has immediate and direct access to open air and superviseable space.

It is not acceptable to: • rely on distant parks, recreation grounds or play areas to provide these facilities, or • have to cross busy roads to reach them.

Where construction takes the form of flats, it is essential that each development includes open air play and recreation areas.

The planning guidelines should include provisions to ensure that developers comply with this requirement. Response: Noted.

The Council are currently preparing an open space strategy which will seek to ensure the right provision of open space is made in the borough relative to population growth. This strategy will inform the Development Strategy, Development Management DPD and the Infrastructure Delivery Plan. It is intended that provision standards for children’s play space, garden space and amenity space will be set out in the Development Management DPD. Outcome: No change.

Further details regarding provision standards will be provided as part of the Development Management DPD.

Name Organisation Policy Reference

West Ealing Neighbours Community/Voluntary Organisation 5.5 Nature of Comment: Object

There is a general presumption against built development on Community Open Space, unless it directly relates to the open space function of the site. Whilst the Council are keen to promote improved access to such space, in most instances this should be achievable without accepting any loss of this space to development. Both the Open Space Strategy and the Infrastructure Delivery Plan will review opportunities/actions for enhancing existing community open space. Outcome: No Change.

Name Organisation Policy Reference

180 Greater London Authority Statutory 5.5 Nature of Comment: Support with conditions

Reference to the need to provide play facilities for children, improving existing as well as requiring new facilities should be included. Response: Accepted. he Mayor’s SPG on child play space already establishes provision standards for play space required to be provided as part of new development – in effect 10 sq. m. per child. It is proposed that this standard be taken forward into the Development Management DPD. In addition provision standards for parks, active recreation and garden/amenity space will also be provided. Outcome: No change. Further details to be provided within the Development Management DPD.

Name Organisation Policy Reference

Michael Simmons Resident 5.5 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Susan New Resident 5.5 Nature of Comment: Support

I support all these proposals but the council seems to be doing its utmost to put pressure on Ealing's open spaces by having developments that do not have their own open spaces. Response: Support welcomed.

It is proposed that the Development Management DPD will comprise provision standards for parks, active recreation, child play space, garden and amenity space, which will be applied for individual development proposals.

Outcome: No change. Further details to be provided in the Development Management DPD.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 5.5 Nature of Comment: Support

Sports facilities can be positive or negative for parks, peoples use and biodiversity. This needs to be very carefully executed.

181 Response: Noted.

It is proposed that the Development Management DPD will set out criteria for the assessment of appropriate uses in open areas, including the intensification of open space. This is intended to ensure that proposed changes will not compromise an already informal open space function of a site. Outcome: No change. Further details will be provided in the Development Management DPD.

Name Organisation Policy Reference

M Collins Resident 5.5 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 5.5 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference Community/Voluntary Central Ealing Residents Association Organisation 5.5 Nature of Comment: Support

Walking, play and other recreation should be clearly identified as top of the hierarchy. Expansion of cycling provision only where it would not compromise the enjoyment or safety of these activities - but welcome where these activities can be fully met Response: Noted.

It is proposed that the Development Management DPD will include policies to control the intensification of open space, even where these proposals directly support an open space function. The informal value of open space is recognised, and policies will continue to protect this function. Outcome: No change. Further details are to be provided in the Development Management DPD.

182

Initial Proposal 5.5 (a)

Name Organisation Policy Reference

JK Gill Resident 5.5 (a) Nature of Comment: Support with conditions

The statement that 'where a particular open space is no longer required, the land will be utilized for an alternative open space rather than buildings will need to be checked for its legality, as the original conveyance documents may have restrictions in place to prevent this Response: Noted.

This would need to be considered on an individual basis. The Council’s intention however is to ensure that open space is not lost to irreversible development, and where demand for other appropriate open space uses exist, the space would be put to such use. Outcome: No change.

Initial Proposal 5.5 (b)

Name Organisation Policy Reference

JK Gill Resident 5.5 (b) Nature of Comment: Support with conditions

As I object to the overall gasworks proposal I also object to the provision of open space on the site Response: Noted. Outcome: No change.

Initial Proposal 5.5 (c)

Name Organisation Policy Reference Community/Voluntary Ealing Civic Society Organistaion 5.5 (c) Nature of Comment: Object

Object to a sports hub at Gurnell Pool and satellite sites should not be located in the floodplain.

The areas identified as deficient in parks seem to have omissions and some areas that are not shown as deficient on Maps in UDP Vol2.

Local Park deficiency-Areas omited include Castlebar hill/Haven Green area; Elthorne and Hanwell; very little of Southfield is deficient.

183 Response: Noted.

It is generally accepted that built development will not be located within the floodplain, in line with PPS 25. PPS 25 defines uses in terms of their vulnerability to flooding, and based on this vulnerability identifies which uses would or wouldn’t be appropriate within the flood zones. Development sites identified in the forthcoming Development Sites DPD will be the subject of sequential test as part of the Sustainability Appraisal process in accordance with the requirements of PPS 25. The sequential test will be used to locate new developments to the least risky areas relative to their vulnerability. Based on this approach, certain less vulnerable uses such as outdoor sports facilities may be an appropriate in areas at risk of flooding.

Areas of deficiency in terms of access to open space are to be reviewed and remapped as part of the new open space strategy. In addition to mapping deficiency in terms of access to Public Open Space, the new strategy will also map deficiency for other types of open space too. Outcome: No change. However, the findings of the open space strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

JK Gill Resident 5.5 (c) Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

Initial Proposal 5.5 (d)

Name Organisation Policy Reference

JK Gill Resident 5.5 (d) Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

Initial Proposal 5.6

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 5.6 Nature of Comment: Support

Reuse of existing sites would provide finance for improved care of cemeteries. Green burials and attractive places for internment of ashes should be available within the borough. They need not look like traditional burial grounds but could be planted with trees. Some burial customs may not be provided for in each part of the borough but liaison with adjoining boroughs could supplement provision.

184 Response: Noted.

The provision of burial space in the borough is currently being reviewed as part of the Open Space Strategy for the borough. This will seek to ensure that provision is adequate over the life of the plan. In the first instance this will look to maximise existing sites, and then consider the need for additional space. The contribution of green burials will be considered as part of this. London Plan policy 3D.19 requires local authorities in preparing their DPD’s to ensure that adequate provision is made for the boroughs needs, including in particular the needs of certain religious or cultural groups for whom burial is the only option. Provision should also be based on the principle of proximity to local communities, however in developing this strategy, we will endeavour to liase with neighbouring authorities to see what scope there is to meet needs at a sub regional level. Outcome: No change. However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

Ealing Fields Residents Association Community/Voluntary Organisation 5.6 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Michael Simmons Resident 5.6 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

National Grid Property Holdings Business 5.6 Nature of Comment: Comment

With regard to the provision of additional burial land, it is considered that it is appropriate to take a broader view as to the capacity of the existing cemeteries within a sub region rather than just purely within one Borough. As such, the fact that Hounslow has reserves for 150 years should mean that this could serve the wider area and that it is not, therefore, necessary for specific additional provision to be made within Ealing Borough.

185 Response: Noted.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

Susan New Resident 5.6 Nature of Comment: Comment

If land can be used for burials in Hounslow what about the other swathes of empty land that can be used in Hounslow for housing. Response: Noted.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 5.6 Nature of Comment: Object

There are far too many cemeteries in Ealing, most of which were occupied in the 19th century by people who could not find, or afford, space in Kensington, Chelsea and Fulham - plus some from other areas. Preserve the best Victorian Monuments and those of great people and (subject to current laws of course) persuade the Christian Churches and those of other religions to agree.

186 Response: Noted.

Outcome: No change.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 5.6 Nature of Comment: Support

This needs to have a larger green burial area. Response: Noted.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

M Collins Resident 5.6 Nature of Comment: Object

Space is a premium, burial land already in existence should have greater attention - but I am doubtful that we should be using more land for burial land

187 Response: Noted.

Outcome: No change.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

Peter L Flatau Resident 5.6 Nature of Comment: Comment

Discourage burials of bodies, but allow ashes. Allow re-use. Response: Noted.

Outcome: No change. However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

Eric Leach Resident 5.6 Nature of Comment: Object

I'm going to be cremated and ashes scattered - I suggest everyone else does the same.

188 Response: Noted.

Outcome: No change.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

Name Organisation Policy Reference

JK Gill Resident 5.6 Nature of Comment: Object

They may be legally obliged to do this based on the original documents when the land for burials came under public ownership Response: Noted.

This would need to considered on an individual basis. Outcome: No Change.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 5.6 Nature of Comment: Object

This is not Sustainable Development. Response: Noted.

Outcome: No change.

However, the findings of the Open Space Strategy will inform the emerging LDF documents.

189

Chapter 6: Sustainable Delivery

Name Organisation Policy Reference

Metropolitan Police Authority Statutory 6 Nature of Comment: Support

Planning Obligations and Legal Agreements - This section states that Section 106 agreements can be used to not only support the provision of community facilities, but also their maintenance or improvement. It also highlights the possible use of a Community Infrastructure Levy (CIL) for the provision of identified community infrastructure requirements. In order to reflect CIL Guidance published by the Communities and Local Government Department, it is prudent to emphasise the necessity for securing planning obligations under Section 106 (Town and Country Planning Act 1990) to run parallel with the CIL. Section 64 of the CIL guidance states that planning obligations sought through Section 106 will complement CIL, and notes in some cases planning obligations may be the only suitable tool to secure site specific benefits in particular. For example, whilst CIL will rely upon future forecasting of infrastructure requirements, policing requirements are generally influenced by geographic location, demographics, accessibility and the economy; all of which are factors outside of the MPA's control. The MPA's requirements are therefore difficult to forecast. Accordingly, the MPA support the reference within the emerging Development Strategy to both planning obligations being secured through the traditional Section 106 route and the use of the CIL, where appropriate. Response: Noted.

The draft SPD on Legal Agreements will be progressed to adoption in June 2012.The Local Planning Authority will consider whether to adopt CIL alongside s106 in due course.

Outcome: No change. Further information to be provided in the Legal Agreements SPD.

Name Organisation Policy Reference

Greater London Authority Statutory 6 Nature of Comment: Support with conditions

This chapter should be developed in discussions with GLA officers to ensure that the policies within Chapter 4 of the London Plan and Chapter 5 of the draft replacement Plan in relation to climate change are appropriately reflected in local policies. This is largely overlooked in the existing document.

The Council should develop the priorities for planning obligations, taking into account the strategic priorities set out in Policy 8.2 of the draft replacement London Plan, and 6A.4 and 6A.5 of the London Plan. Response: Noted.

The Council’s IDP will also help establish priorities for planning obligations across the borough.

Outcome: Accepted. Further information to be provided in the Infrastructure Delivery Plan.

190 Name Organisation Policy Reference

Greater London Authority Statutory 6 Nature of Comment: Support with conditions

Response: Noted.

The Council’s IDP will also help establish priorities for planning obligations across the borough.

Outcome: Accepted. Further information to be provided in the Infrastructure Delivery Plan.

Initial Proposal 6.1

Name Organisation Policy Reference

Highways Agency Statutory 6.1 Nature of Comment: Comment

We are pleased to note the intention to produce and maintain an ‘infrastructure requirements and delivery plan’. Background Paper 4 provides rough details of what it will contain and we note that you have identified ‘physical transport’ as one of the key features. Paragraphs 4.8 - 4.12 of the revised PPS12 highlight the need for an infrastructure plan as part of a robust and credible evidence base. This plan should outline what infrastructure is needed (i.e. soft measures such as public transport, cycle lanes and, as a last resort, highway improvements) to enable the delivery of LDF development. The infrastructure plan should not only establish the infrastructure required but also detail the associated costs, sources of funding, timescales for delivery and gaps in funding. In terms of infrastructure contributions, the HA would need to be satisfied that the infrastructure plan will set out clear and robust policies for acquiring funds. This will ensure that infrastructure required to mitigate impact of development is deliverable. The level of contribution will be dependent on the likely mitigation measures required, which should be identified through the transport evidence base. In order to complete a successful infrastructure plan in advance of the Development Strategy Submission document, it is considered that timely, effective and conclusive discussions with the HA will be essential, as outlined in paragraphs 4.27 - 4.29 of the revised PPS12. The HA recognises that although new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment. It is therefore important that an appropriate assessment of infrastructure requirements is performed for the above ‘Initial Proposal’ development sites. Furthermore, the occupation of such developments should be phased in line with the provision of necessary transport infrastructure. This will help the Development Strategy meets PPS12 requirement that a sound DPD should be ‘justified’ and ‘effective’ and hence be deliverable.

Response: Noted.

The IDP will include detail of infrastructure costs, funding sources, timescale for delivery and gaps in funding. Outcome: Accepted conditionally. Further information to be provided in the Infrastructure Delivery Plan.

191

Name Organisation Policy Reference

Thames Water Statutory 6.1 Nature of Comment: Support with conditions

We welcome the acknowledgement that infrastructure planning is an integral to investment and delivery of land and buildings. We also welcome reference to the Council providing appropriate infrastructure in the right locations and at the right time to support levels of wider development. The proposal to identify and promote improvement of utility development, particularly in respect of water use, sewerage infrastructure and sustainable urban drainage is welcome. We do however still consider there should be a specific policy on water and sewage infrastructure. LDF planning policies, as stated in PPS12 should consider the impact development would have on essential infrastructure; furthermore it is critical to have planning policy support within the document for new utility infrastructure. Without planning policy support for new utility infrastructure, new utility infrastructure can be delayed through the planning system, and the wider principles of sustainability are compromised as development is brought forward without the appropriate infrastructure in place. A suggested policy for the Core Strategy is detailed below:- “Water and sewage infrastructure - Planning permission will only be granted for developments which increase the demand for off-site service infrastructure where: sufficient capacity already exists or extra capacity can be provided in time to serve the development which will ensure that the environment and the amenities of local residents are not adversely affected. When there is a capacity problem and improvements in off-site infrastructure are not programmed, planning permission will only be granted where the developer funds appropriate improvements which will be completed prior to occupation of the development.” The development or expansion of water supply or waste water facilities will normally be permitted, either where needed to serve existing or proposed development in accordance with the provisions of the Development Plan, or in the interests of long term water supply and waste water management, provided that the need for such facilities outweighs any adverse land use or environmental impact that any such adverse impact is minimised.” It is considered that the above suggested policy accords with the guidance referred to above in PPS12 and the London Plan. Response: Support welcomed.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development, up to 2026. More specific policies relating to the capacity of water /sewage infrastructure will either be included in the Replacement London Plan policies and/or the Development Management policy document. Outcome: Accepted conditionally.

Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 6.1 Nature of Comment: Support

Transport, Utilities, Public Realm, Historic legacy are supported

Response: Support welcomed. Outcome: No change.

192

Name Organisation Policy Reference

Metropolitan Police Authority Statutory 6.1 Nature of Comment: Support with conditions

Circular 05/05 paragraph B9 advises developers may be expected to pay for or contribute to the cost of all, or that part of additional infrastructure provision which would not have been necessary but for their development.

Initial Proposal 6.1 - This section refers to Physical Infrastructure. The third bullet point within this section refers to the 'Public Realm'. The MPA suggests that this should include reference to 'Secured by Design' principles in line with the Metropolitan Police's 'Secured by Design' accreditation. Response: Noted. Outcome: Accepted.

Name Organisation Policy Reference

Hillingdon Motorist Forum Community/Voluntary Organisation 6.1 Nature of Comment: Support

It is correct to state that the transport infrastructure will require upgrading but this should include improvements and enhancements of the road network. Planning Obligations and Legal Agreements: It is right that the developer should contribute to any infrastructure upgrades that are required as a result of the development, of course these costs will be passed on to the purchasers of the properties. The planning of any development should maximise the number of access point to the development. This will spread the additional traffic generated by the residents of the development. Response: Support welcomed.

Contributions from developers will be sought where there are infrastructure requirements arising from the development which are not provided as part of the application, cannot be met on site or accommodated within existing provision. Access requirements will be the subject of policies within the Development Management document and determined on a case by case basis dependant on the circumstances of each individual planning application. Outcome: No change. Further information to be provided in the Infrastructure Delivery Plan and the Development Management policy document.

Name Organisation Policy Reference

West Ealing Neighbours Community/Voluntary Organisation 6.1 Nature of Comment: Comment

6.1 Physical Infrastructure - We have already mentioned a new north-south bus route. Our Lido Junction report also includes proposals for improving local cycle routes. Response: Noted. Required transport improvements will be set out in the Infrastructure Delivery Plan. Outcome: Accepted conditionally. Further information to be provided in the Infrastructure Delivery Plan.

193 Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 6.1 Nature of Comment: Comment

Initial Proposal 6.1 Physical infrastructure - Considerable pressures are already being experienced on the existing physical infrastructure. This is especially apparent in the case of transport. The high levels of road congestion on the orbital north-south road links is acknowledged in the consultation document. A direct consequence of this congestion is the displacement of through traffic onto residential side streets. With main and distributor roads at near capacity, any increase in traffic volumes can be expected to increase disproportionately the volume of movements through, and impact on, residential side streets. Background papers published by the GLA in support of the latest consultation draft of the London Plan confirm that the east-west rail and underground routes are already suffering from rush hour overcrowding. The proposal to add 9,000 plus housing units along the Uxbridge Road/Crossrail Corridor will add to these transport pressures. Assuming an average occupancy of two per unit this can be expected to generate a minimum 18,000 additional peak period movements. While some of these movements will be radial, a large number will add to the pressures on the orbital road network. This will be especially true in the case of parents/carers with children commuting to schools, virtually all of which are located outside the development corridor and some distance from the proposed new housing units. The consultation document states that the Council will produce an Infrastructure Delivery Plan. No date is indicated for the production of this plan or any public consultation which may follow that publication. The LDF Scrutiny Panel was advised at its 25th March 2009 meeting that there was an urgent requirement to prepare an ‘Infrastructure Requirements Plan’ and an ‘Infrastructure Investment Framework’. The councillors on the panel were advised that these documents were due to be produced by September 2009. These documents have yet to be published. Given the volume of additional housing proposed in the draft Development Strategy it is essential that the associated potential infrastructure pressures are identified, quantified and a range of scenarios that model them are prepared and shared with the public. In the absence of this essential information it is not possible to comment meaningfully on the proposals. This consultation on the draft Development Strategy should therefore be regarded as premature.

Shopmobility - Access to town centres, neighbourhood shops and all public spaces is a major issue for those with mobility requirements. It is difficult to find any mention of this need in the consultation documents. We ask that specific references are included in the next draft of the Development Strategy and that this includes the requirement that all town centre developments must conform to an integrated and comprehensive Shopmobility scheme for that town centre. We wish to draw councillors and officers to the excellent Shopmobility scheme in Uxbridge which is located to the new Chimes shopping centre and services the whole town centre. We strongly recommend a fact finding visit so that the key elements of this integrated scheme can be indentified, documented and incorporated in Ealing’s Development Strategy. Response: Noted.

In relation to the Infrastructure Delivery Plan, this is currently being produced and will be published for consultation alongside the Development Strategy in Autumn 2010.

In relation to shopmobility, detailed criteria will be set out in the London Plan and/or the Development Management policy document as well as Accessible Ealing SPD to ensure appropriate accessibility standards are met in new developments. Contributions towards the shopmobility scheme will also be sought through s106 legal agreements where relevant. Outcome: No change.

Further information will be provided in the Infrastructure Delivery Plan, Development Management policy document and Accessible Ealing SPD.

194

Name Organisation Policy Reference

Ealing Transition Steering Group Community/Voluntary Organisation 6.1 Nature of Comment: Comment

Specific Considerations - 1. Energy/Housing - As far as energy is concerned, we feel that two major areas are notably absent from the LDF. The first of these is a policy on existing housing stock and the need identified in the London Plan to reduce energy use in existing buildings. Whilst new national planning laws for new buildings are already being reflected positively in e.g. proposals for the Green Man Estate, the vast majority of Ealing’s housing stock comprises draughty Victorian / Edwardian properties. The second is an explicit plan regarding decentralised and renewable energy provision, also identified in the London Plan.

Specific Considerations - 4. Transport - With high oil costs, we will be far more reliant on public transport as car use becomes increasingly unaffordable. Transport links need to be sufficiently comprehensive to enable the move away from car use and ownership. The use of bicycles should be encouraged according to continental models.

Towards a New Strategic Framework - We believe that any plan for Ealing in 2026 should acknowledge that by 2026 energy will be more scarce, and more expensive. Further, it should acknowledge that a major programme of carbon reduction is likely to be in place by this point. The strategic questions that any report facing up to life in 2026 should be addressing are as follows. How will Ealing meet its energy needs in 2026? - How can Ealing make dramatic reductions to its carbon footprint in line with government targets, in particular in respect of housing and transport? - How will Ealing ensure it has access to healthy, nutritious, seasonal food in 2026 without incurring a significant carbon footprint? What proportion of its own food could Ealing produce? - How will Ealing house and provide employment for its population in 2026? - What kinds of local infrastructure, public spaces etc need to be in place to cope with the realities of life in 2026? Response: Noted.

In relation to the final point in Para 3, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development, up to 2026. Outcome: No change.

Further information will be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 6.1 Nature of Comment: Comment

The infrastructure is sadly lacking.

Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development, up to 2026. Outcome: No change. Further information to be provided in the Infrastructure Delivery Plan.

195

Name Organisation Policy Reference

Susan New Resident 6.1 Nature of Comment: Support

Initial Proposal 6.1 - Transport. - The reliability and the accessibility of all transport needs to be improved. The Council needs to work more closely with London Transport re the types of buses used on different routes, the countdown system, inadequate bus shelters and state of the art interchanges. In many other cities in England the buses are far more accessible to the disabled, elderly and for people with buggies. Unless the public transport system is dramatically improved people will continue to rely on cars. Utilities - I doubt whether or not the sewage system and water supply currently in place will be able to cope with the amount of development proposed, and so far I have only seen one housing association development with solar panels. Public Realm - There needs to be a much more imaginative and though through approach to the public realm. Not just hanging baskets and the odd tree. Heritage Legacy - Conservation appraisal and management documents are already in place but the council seems to be determined to ignore them. Response: Support welcomed.

Further information to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Hovedean Properties Business 6.1 Nature of Comment: Support

Transport - we support deliver mechanisms that promote the north-south links within the borough, specifically proposals to widen the rail crossing at South Road, proposals for a rail crossing at Merrick Road and the proposals to link between Glade lane to Park Avenue. These rail crossings shall deliver sustainable access through the Borough.

Utilities - We support improvements to utility infrastructure that support increases in development. However we suggest that delivery of renewable energy supply be considered on a district basis and that site by site energy supply be restricted solely to major developments which can incorporate measures of a sustainable critical mass. This approach may be facilitated through an integrated approach between existing developed landowners and proposed developments and be advocated within partnerships such as ESco's and separated out from community infrastructure contributions or planning obligations from development as part of a joint partnership approach (possibly incorporating Low Carbon Communities Fund).

Public Realm - We support coherent public realm improvements and for the branding of identifiable areas of particular interest as promoted within Initial proposal 2.8.

Response: Support welcomed.

The need, delivery and phasing of infrastructure, including transport and utilities/energy will be set out in the Infrastructure Delivery Plan. Outcome: No change.

196

Name Organisation Policy Reference

Michael Simmons Resident 6.1 Nature of Comment: Support

No further comment. Response: Support welcomed.

Outcome: No Change.

Name Organisation Policy Reference

M Collins Resident 6.1 Nature of Comment: Support

No further comment

Response: Support welcomed.

Outcome: No change.

Name Organisation Policy Reference

Peter L Flatau Resident 6.1 Nature of Comment: Comment

Initial Proposal 6.1 - Historic legacy - This requires careful of building heights. Which does not seem to have been properly considered in the current "Dickens Yard" (DY) and Arcadia (A) sites.

Response: Noted

The Development Sites policy document that will support the Development Strategy, will set out specific policies for the development of key sites, areas and locations in the borough. It will outline in greater detail the suitability of individual sites for facilitating different uses and densities, based on individual merits.

Outcome: No change. Further detail to be provided in the Development Sites policy document.

Name Organisation Policy Reference

Eric Leach Resident 6.1 Nature of Comment: Object

Initial Proposal 6.1 - Apart from 'Children's Centres' there is no data in here.

197 Response: Noted.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

George Peach Resident 6.1 Nature of Comment: Comment

Pavement congestion and pedestrian circulation impedement in Northolt is a problem and this is likely to get worse in central areas unless major developments are properly enforced. There is a virtual disregard for water surface run off and poor levels of water flow.

Response: Noted.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 6.1 Nature of Comment: Object

Green Transport Plans should be required for both the construction and occupancy phases for any 'large' scheme. North - South transport links under-provision will continue without substantial additional demand from more residents to be located in hinterland areas. Pressures and constraints on utilities should have been closely examined before proposals for large scale development were included in the Strategy. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where infrastructure will be required and delivered over the Plan period. Outcome: Accepted conditionally.

Further detail to be provided in the Infrastructure Delivery Plan.

198 Name Organisation Policy Reference

Transport for London Statutory 6.1 Nature of Comment: Support with conditions

TfL supports proposals to improve the walking environment and the public realm. Contributions to help encourage walking by improving signage in line with the Legible London principles should be considered as part of applicant contributions. TfL is also willing to support the Council with public realm schemes and will try and assist with seeking applicant contributions to deliver the Council’s aspirations. Furthermore, to promote walking in the borough, the document should refer to, promote, and aim to complete, the Strategic Walk Network, which goes through Ealing in the form of the Capital Ring walking route. TfL suggests that in order to ensure that all existing pedestrian infrastructure is suitable for its proposed use, the Development Strategy should promote the use of pedestrian audits for strategic applications. These measures will ensure compliance with London Plan Policy 3C.21 and Policy 6.10 of the draft replacement London Plan. Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

JK Gill Resident 6.1 Nature of Comment: Support

There is a lack of detail as to how this will be achieved Response: Noted. The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where infrastructure will be required and delivered over the Plan period. Outcome: Accepted conditionally. Further detail to be provided in the Infrastructure Delivery Plan.

Initial Proposal 6.2

Name Organisation Policy Reference

Her Majesty’s Court Service Statutory 6.2 Nature of Comment: Support

HMCS plays a key role in the delivery of safe and secure neighbourhoods and communities, alongside other delivery partners, such as, the Metropolitan Police. It is our experience that whilst schools and health care services are typically addressed as part of community and infrastructure needs, the role that the courts play in the community is often overlooked. We support the general thrust of the Spatial Vision, which at point G on page 11 supports the provision of community facilities and services in the Borough where and when they are needed. It is noted under Initial Proposal 6.2 (p.52) that Social and Community Infrastructure includes courts. Similarly, we support the courts inclusion as community infrastructure that reflects their importance in developing sustainable communities. For both grounds of support we request that a reference to HMCS is brought forward into formal policy. Furthermore, in the introduction to Chapter 6 (p.50) we note that the Council will be developing an 'Infrastructure Delivery Plan', we request that HMCS is invited to take part in the formulation of both the 'Infrastructure Delivery Strategy' and 'Infrastructure Delivery Schedule' that will form the overall Plan.

199 Response: Noted.

All infrastructure providers should be engaged in the production of the Infrastructure Delivery Plan. HMCS will be contacted to discuss their specific plans and requirements that will form part of the IDP. Outcome: Accepted conditionally.

Contact will be made as part of the production of the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Michael Simmons Resident 6.2 Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 6.2 Nature of Comment: Object

Initial Proposal 6.2 (Social and community infrastructure)We are very concerned that new schools are being permitted /planned in Green belt or MOL. Increasing capacity of existing schools should not deprive existing pupils of much needed playground space and games areas. Transporting pupils to distance playing fields reduces games time and increases transport cost which is not sustainable.

Schools should be provided where they are needed, Long journeys by bus eat into pupils’ homework and recreation time and places an extra burden on Transport for London.

Built leisure uses should be provided in town centres. There is not endless finance to improve transport for either schools or leisure facilities Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure (including education and leisure) needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will seek to demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. Outcome: Accepted conditionally.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Metropolitan Police Authority Statutory 6.2

200 Nature of Comment: Comment

I write on behalf of our client the Metropolitan Police Authority (MPA) with regard to the above documents. The MPA provide a vital community service to the Borough of Ealing and policing is recognised within the 2008 London Plan as being an integral part of social infrastructure. Acknowledging this strategic policy context, the MPA have a number of representations concerning the Council's Development Strategy Initial Proposals: Issues and Options report and the Development Management Policy Document: Issues and Options.

Policy 3B.4 of the London Plan (Industrial locations) highlights the potential for surplus industrial land to help meet the strategic and local need for other uses such as social infrastructure. Also Circular 05/05 paragraph B9 advises developers may be expected to pay for or contribute to the cost of all, or that part of additional infrastructure provision which would not have been necessary but for their development.

Strategic Policy At the strategic level, paragraph 3.99 of the London Plan (Consolidated with Alterations since 2004) states ‘initiatives relating to policing and community safety and crime reduction are seen as increasingly important in improving the quality of life of many Londoners’.

Policy 3A.17 Addressing the needs of London’s diverse population states that the diverse populations needs should be met through the general and specific policies relating to the provision of social infrastructure including ‘policing facilities’. This policy has been altered from its original form in the 2004 version of the plan to recognise that the provision of police facilities is defined as an element of social infrastructure.

This is also reflected in Policy 3A.18 which states: ‘Policies in DPDs should assess the need for social infrastructure and community facilities in their area, and ensure that they are capable of being met wherever possible. These needs include primary healthcare facilities, children’s play and recreation facilities, services for young people, older people and disabled people, as well as libraries, sports and leisure facilities, open space, schools, nurseries and other childcare provision, training facilities, fire and policing facilities, community halls, meeting rooms, places of worship, public toilets, facilities for cyclists, convenience shops, banking facilities and post offices (also see Chapter 3D). Policy 3A.18 further notes that development plan policies should seek to ensure that appropriate facilities are provided and that the net loss of such facilities must be resisted.

Policy 3A.26 also highlights the importance of ‘ensuring communities benefit from development including through Section 106 agreements’ and improving safety and security.

The London Plan (Consolidated with Alterations since 2004) defines policing as a material consideration when assessing the impact of significant development upon policing and when formulating relevant development plan policy. It is therefore appropriate to ensure that the needs of the MPA are reflected within forthcoming Development Strategy and Development Management Policies document.

The need for additional policing facilities are highlighted in the Metropolitan Police Authority's AMP (copy attached) for the London Borough of Ealing and gives a summary of police requirements in the Borough. The MPA suggest that an additional bullet point is included within this section which reads: - • Police- Ensure adequate policing facilities are provided where appropriate to mitigate the impact of proposed borough growth upon policing. The MPS' Asset Management Plan (or revision thereof) will be used as guidance of the Borough based policing requirements for Ealing Borough.

Initial Proposal 6.2- Social Infrastructure - This section identifies the police as a community service and identifies a number of requirements to specific services. Chapters 2-4 highlight significant regeneration and growth with Ealing. In order for the Development Strategy to comply with Policy 3A.18 of the London Plan which seeks to ensure appropriate social infrastructure and community facilities are provided, it is recommended that an additional criterion is added, to ensure the successful delivery of the MPA's AMP.

201 Response: Noted

The Infrastructure Delivery Plan will identify all items of infrastructure (including police, ambulance and fire services) needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period, and where possible state how delivery of certain services may change over time. Outcome: Accepted conditionally.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

West Ealing Neighbours Community/Voluntary Organisation 6.2 Nature of Comment: Comment

Need to see the detailed Infrastructure plans. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. It will be consulted upon alongside the next version of the Development Strategy document Autumn 2010. Outcome: Accepted conditionally.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Greater London Authority Statutory 6.2 Nature of Comment: Support with conditions

The requirements for health infrastructure should be included Response: Noted.

A detailed section on health will be included in the Infrastructure Plan, including reference to the PCT estates strategy.

Outcome: Accepted. Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

M Collins Resident 6.2 Nature of Comment: Support

No further comment. Response: Support welcomed. Outcome: No change.

202 Name Organisation Policy Reference Ealing Fields Residents Associaiton Community/Voluntary Organisation 6.2 Nature of Comment: Comment

Initial Proposal 6.2 Social and community infrastructure - Considerable pressures are already being experienced on the existing infrastructure. In the context of Social and Community Infrastructure this is especially apparent in the case of educational and community medical facilities.

There has been extensive coverage in the local media of the shortage of primary school places and of the proposals by the Council to cram additional classrooms onto existing school sites in order to meet this shortfall in capacity.

Major pressures have also been reported with community medical provision, with the new residents of existing housing units experiencing difficulty in being added to GP lists.

The proposal to add 9,000 plus housing units along the Uxbridge Road/Crossrail Corridor will add to these pressures. This will be especially true in the case of school provision. Few schools are located within this development corridor, which means that most of the children resident in the new developments will have to be educated at the already oversubscribed schools located in the adjoining residential hinterlands.

The consultation document states that the Council will produce an Infrastructure Delivery Plan. No date is indicated for the production of this plan or any public consultation which may follow that publication.

The LDF Scrutiny Panel was advised at its 25th March 2009 meeting that there was an urgent requirement to prepare an ‘Infrastructure Requirements Plan’ and an ‘Infrastructure Investment Framework’. The councillors on the panel were advised that these documents were due to be produced by September 2009. These documents have yet to be published.

Given the volume of additional housing proposed in the draft Development Strategy it is essential that the associated potential infrastructure pressures are identified, quantified and a range of scenarios that model them are prepared and shared with the public.

In the absence of this essential information it is not possible to comment meaningfully on the proposals. This consultation on the draft Development Strategy should therefore be regarded as premature. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. It will be consulted upon alongside the next version of the Development Strategy document Autumn 2010. Outcome: Accepted conditionally.

Further detail to be provided in the Infrastructure Delivery Plan.

203 Name Organisation Policy Reference

The West London Mental Health Trust Statutory 6.2 Nature of Comment: Support with conditions

Ensuring Sustainable Delivery - The Trust considers that mental health services should be explicitly identified within the social and community infrastructure as outlined in the first paragraph of Initial Proposal 6.2. Further recognition should also be given to this in the form of more detailed text as per the bullets dealing with other uses. This could relate to health care generally or mental health care specifically. This would also reinforce the text already contained within the Leisure bullet point which recognises the link between the leisure and health agenda. This proposal should recognise that there is a requirement for new and improved mental health care provision within the Borough up to 2026. It should then specifically identify the role of St Bernard’s Hospital in meeting these needs through improvements to its existing estate rather than seeking development in alternative locations. This would accord with Table 8F of the UDP which seeks to safeguard suitable sites. It is of paramount importance that the Development Strategy provides the policy context which allows St Bernard’s to plan its future investment on this site. It is also important to emphasise that the Trust is also major employer and the Development Strategy has an important role in reinforcing St Bernard’s role in this regard through the changes proposed above. The Trust objects to the fact that St Bernard’s Hospital is not identified in Map 10 as a community facility. As stated above the Council should note that the Trust’s services are entirely independent of those provided at Ealing Hospital on the adjacent site and this needs to be recognised by an amendment to that plan. Response: Noted.

Map will be amended. All infrastructure providers should be engaged in producing the Infrastructure Delivery Plan. The Trust will be contacted in order that their plans are adequately reflected in the document. Outcome: Accepted. The map will be amended to incorporate changes and contact will be made as part of the production of the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Susan New Resident 6.2 Nature of Comment: Comment

Initial Proposal 6.2 - Education - The council needs to work out exactly how many school places are needed in the future since it has got the figures so completely wrong in the past. Given that the council sold off one of the borough's main assets that could be used, and was used, for local infrastructure I doubt if there is much land left to improve health, sport and leisure. Central Middlesex and Hammersmith Hospital should not be included on the Community Facilities map as they are not in the borough and Clayponds Hospital only caters for the elderly. We only have one hospital catering for over 300,000 people. Response: Not accepted. The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. Detailed sections on Education and Health will be included. Adjacent borough’s infrastructure is included on the mapping as our borough’s residents inevitably use facilities across borough boundaries, (eg schools, leisure facilities and hospitals), as do other borough’s residents use those situated within Ealing borough. Outcome: No change. Further detail to be provided in the Infrastructure Delivery Plan.

204

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 6.2 Nature of Comment: Comment

This is also lacking. Response: Noted.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. Outcome: No change.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Peter L Flatau Resident 6.2 Nature of Comment: Comment

See 6.1 above very little consideration seems to have been given to these matters in the DY and A current proposals. More attention to such items will be required in the future. Response: Noted

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. Outcome: No change.

Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 6.2 Nature of Comment: Support

Notable that the Council's own land has failed to provide and social or community infrastructure in the case of Dickens Yard site. This proposal needs to be rigourously tested Response: Support welcomed.

This is a comment made in relation to a specific planning application. However, the Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period.

Outcome: No Change.

205 Name Organisation Policy Reference

JK Gill Resident 6.2 Nature of Comment: Comment

The proposed social infrastructure will be reliant on suitably qualified people to support it. Response: Noted.

Outcome: No Change.

Initial Proposal 6.3

Name Organisation Policy Reference

Ealing Civic Society Community/Voluntary Organisation 6.3 Nature of Comment: Support

More ways of improving open space should be promoted through volunteers, fund raising events, diverting sponsorship finance to less ephemeral projects than annuals on roundabouts.

The lack of Infrastructure plan makes commenting at this stage difficult.

Priorities for sustainable development do not seem to be included adequately in the consultation. Examination of sustainability appraisals shows a range of permissions with poor scores. CHP fueled by biofuels seems to be the peak of sustainability provision. More detailed policy is needed

Planning obligations and legal agreements seem too confidential. We would like to know what section 106 money is to be spent on. Response: Support welcomed.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. The IDP will also help establish priorities for seeking and spending 106 monies. Details of s106 spend are regularly reported to the Cabinet.

Outcome: No change. Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Michael Simmons Resident 6.3 Nature of Comment: Support

No further comment Response: Support welcomed.

Outcome: No change.

206 Name Organisation Policy Reference Ealing Fields Residents Association Community/Voluntary Organisation 6.3 Nature of Comment: Support

The protection and enhancement of existing open space will be even more important than it already is if a significant number of additional housing units are to be built in the Borough. It is vital that every resident and family member has immediate and direct access to open air and superviseable space. It is not acceptable to: • rely on distant parks, recreation grounds or play areas to provide these facilities, or • have to cross a busy roads to reach them.

Where construction takes the form of flats, it is essential that each development includes open air play and recreation areas. The planning guidelines should include provisions to ensure that developers comply with this requirement. Response: Support welcomed.

The Infrastructure Delivery Plan will identify all items of infrastructure needed (including Open Space and playspace) to ensure the sustainable delivery of the growth targets contained in the Development Strategy 2026. It will demonstrate what, how, when and where such infrastructure will be required and delivered over the Plan period. The Council’s Open Space Strategy is also currently being produced and will inform the IDP. Outcome: No change. Further detail to be provided in the Infrastructure Delivery Plan.

Name Organisation Policy Reference

Hanwell Village Green Association Community/Voluntary Organisation 6.3 Nature of Comment: Support

For great developments the following are necessary: Trees in all situations; grass (not astro-turf); green routes, wind and solar micro generation; ponds and wetlands even in shopping and industrial areas; cycle and walking to be made a priority and safe Response: Noted.

As well as using London Plan policies, the Council will include relevant policies in the Development Strategy and Development Management documents to help achieve successful and sustainable developments.

Outcome: No change. Further detail to be provided in the Development Strategy and Development Management policy documents.

Name Organisation Policy Reference

M Collins Resident 6.3 Nature of Comment: Support

No further comment Response: Support welcomed. Outcome: No change.

207 Name Organisation Policy Reference

Peter L Flatau Resident 6.3 Nature of Comment: Comment

Open Spaces - care must also be taken so that existing Open Spaces are not degraded by development. E.g. The Arcadia site which will overshadow Haven Green and some adjacent housing. Response: Noted.

As well as using London Plan policies, the Council will include relevant policies in the Development Strategy and Development Management document to help achieve successful and sustainable developments. Outcome: No change.

Further detail to be provided in the Development Strategy, Development Sites and Development Management policy documents.

Name Organisation Policy Reference Central Ealing Residents Association Community/Voluntary Organisation 6.3 Nature of Comment: Comment

Small spaces and opportunities to increase planting should sit alongside the larger proposals. Temporary gardens/allotments on vacant land (e.g. prior to construction starting) should be encouraged. Response: Noted.

Further detail to be provided in the Development Strategy, Development Sites and Development Management policy documents.

208 General Comments

Name Organisation Policy Reference Ealing Fields Residents Association Community Voluntary Organisation General Nature of Comment: Comment

Engagement with Residents - We are disappointed with the Council’s engagement with residents in respect of this consultation. Our concerns include: • inadequate feedback following the 2007 LDF consultation, • failure to use adequately the large number of resident contact details held by the Council to write and/or email those residents who have previously commented on UDP, LDF or Planning matters, • failure to circularise long established residents’ and community associations with information about the consultation, including either summary or comprehensive consultation documents and response forms, • Extremely poor and last minute advance publicity for the programme of public meetings.The quality of engagement must have a major bearing on the effectiveness of the consultation with ordinary residents and we do question that it has been adequate in this instance.

Conduct of LDF Public Meetings - We appreciate the efforts the Planning Policy team went to in arranging a programme of public meetings at relatively short notice. We do, however, have a number of concerns over the way in which these meetings were conducted. Our concerns include the following: • Lack of clarity in explaining the components of, and stages in, the preparation of the LDF and its consultation ‘journey’. There is an excellent overview of the process in the 8 page summary document circulated by Merton Council to the 800 plus organisations and individuals on that Council’s LDF contact list. We suggest that Ealing embraces this example at future meetings and in future publications. • Failure to introduce and describe to the members of the public the consultation documents, reports and response forms which had been prepared by Council officers. Probably virtually all those who had attended the Ealing meeting left without being aware that there were two lead documents, supported by five background papers. They also left the meeting confused as to the existence of the two 20 page consultation forms the Council wished respondents to complete. We understand that officers have been subject to substantial budgetary pressures in respect of printing LDF documentation. However, we fail to see how a meaningful and effective LDF consultation can take place if the key documents are not presented to the consultees. • The structure of the Ealing public meeting did not follow that of the two consultation documents and their respective response forms. Members of the public were asked to join thematic discussion groups and to ‘brainstorm’ their opinions on generic issues. While this approach revealed a consistency of concerns between the discussion groups, it failed to adequately address the detailed proposals and options set out in the LDF documents and questionnaires. It therefore failed to assist members of the public in their subsequent completion of the Council’s two 20 page consultation questionnaires.

LDF Scrutiny Panel - An LDF Scrutiny Panel has been meeting regularly for over a year since July 2008. Successive meetings of the Panel reviewed the draft of a more comprehensive Development Strategy document. The version on which the Council is now consulting bears little resemblance to the earlier draft. We are disappointed that only a very early and incomplete draft of the current version of the Development Strategy document was shared with the LDF Scrutiny Panel at its April 2009 meeting. This was the last meeting of the Panel prior to the start of the public consultation. Drafts of this questionnaire were not shared with the LDF Scrutiny Panel. We feel that a review of the draft documents and questionnaire by the LDF Scrutiny Panel would have identified and help resolve many of the concerns raised in this response and by other members of the public.

209 Response: Noted.

It is acknowledged that feedback following the 2007 round of LDF consultation was inadequate and it is hoped that the feedback generated following this latest round of consultation will meet with greater approval. A full review of the council’s engagement plan is planned before the next round of consultation that will take place in Autumn 2010 and this will include better and more creative use of publicity including the council’s own magazine “Around Ealing”. It is acknowledged that planning public meetings and events is always difficult as it is not always possible to keep all sections of the audience happy. The format adopted at the public meetings was discussed and agreed at the Planning and Community Working Group and that includes a number of prominent community representatives. Membership is open and active participation is encouraged and will be further promoted through the web pages and e-bulletin. Some significant improvements have already taken place including the establishment of regular e-bulletin to everyone on the LDF mailing list to keep people informed as to progress, events and activities and a revamp of the planning policy pages of the council’s web-site due to launched shortly. It is acknowledged that budgetary pressures have prevented free circulation of consultation documents to a wider audience although copies for inspection were available at public libraries and the council’s customer services centre and could be downloaded from the council’s web-site. Regarding the role of the LDF Scrutiny Panel, it is important to recognise that this panel is not a decision making body and has an advisory role and feeds through comments through the council’s scrutiny arrangements. Outcome: No change. These comments will inform a review of the engagement plan before the next round of consultation in Autumn 2010.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation General/Intro Comment Nature of Comment: Support with conditions

Outcome: No change.

Name Organisation Policy Reference Walpole Residents Association Community Voluntary Organisation General Nature of Comment: Support with conditions

The Consultation Process and Audit Trail - There is no obvious consideration of past input that stakeholders such as WRA have made. We have found that Background Paper 5 to the Development Strategy Report is impenetrable and buries the past community consultation and input rather than showing how views have been considered. The structure of this "audit trail" document is based around solutions rather that, as is claimed, options or themes. Response: Noted. It is hoped that the feedback being provided in this report will help address this concern and will be approach adopted in future. Outcome: No change. These comments will inform a review of the engagement plan before the next round of consultation in Autumn 2010.

210

Name Organisation Policy Reference Susan New Resident General Nature of Comment: Comment

Public Consultation - Unfortunately I was only able to attend the consultation meeting at Ealing Town Hall and judging from that experience I would not say that in anyway a public consultation had taken place. We were only given the briefest of summaries accompanied by the vaguest of maps that I have ever seen. We were then expected to trudge to Perceval House of the local library to see full documents plus supplementary documents. Given that this is supposed to be a Vision for Ealing 2026 and will affect every resident in Ealing and their future quality of life I think everyone should have been given more time and information before the consultation deadline date was imposed. Response: Noted.

Active consideration is being given to the proposal to extend the consultation period beyond the six-week statutory period. Outcome: No change.

These comments will inform a review of the engagement plan before the next round of consultation in Autumn 2010.

Name Organisation Policy Reference Janet Smith Resident General Nature of Comment: Object

Having failed to reach you by telephone hence my letter. My letter informing me of the Ealing LDF consultation meeting on Wednesday 9 September was not delivered until 8 September - having been posted on 4th prior to the weekend. I notice the 1 September is the date in preparation of the letter. If the Council are really serious about consultation periods with local people then plans must be made further ahead than 24hrs. I hope your department will be able to give more notice of any other pending consultations for the Ealing area. Response: Noted.

full review of the council’s engagement plan is planned before the next round of consultation that will take place in Autumn 2010 and this will include better and more creative use of publicity including the council’s own magazine “Around Ealing”. Some significant improvements have already taken place including the establishment of regular e-bulletin to everyone on the LDF mailing list to keep people informed as to progress, events and activities and a revamp of the planning policy pages of the council’s web-site due to launched shortly. Outcome: No change.

These comments will inform a review of the engagement plan before the next round of consultation in Autumn 2010.

211 Name Organisation Policy Reference Christine Eborall Resident General Nature of Comment: Object

I would like to object to the proposed treatment of front gardens.

Response: Not accepted.

It is unclear what exactly the respondent is objecting to in relation to the treatment of front gardens. Outcome: No change.

Name Organisation Policy Reference Save Ealing Centre Community/Voluntary Organisation Executive Summary Nature of Comment: Object

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. Response: Not accepted

The purpose of the executive summary is to provide a broad summary, based on the most important themes, of what is contained in the Strategy. As it is a summary, it cannot include all of the detail of the document. Outcome: No change.

Name Organisation Policy Reference Walpole Residents Association Community/Voluntary Organisation Executive Summary Nature of Comment: Object

The Executive Summary of the Strategy - The current document is preceded by a "summary" - however, it is not a summary of the strategy, but rather a series of disconnected statements. It should be rewritten or re-titled. Response: Not accepted

Outcome: No change.

212 Maps

Name Organisation Policy Reference Greater London Authority Statutory Maps Nature of Comment: Comment

The development proposal maps for each core area of the borough are supported but these should be developed further and better linked to the development proposals for each area.

Response: Noted.

A Proposals Map DPD, which specifies sites, areas, and other locations identified in the Development Strategy, Development Sites and Development Management DPDs will be prepared and published in Spring 2012. This will build on the existing maps provided to date and provide greater level of clarity and detail. Outcome: Accepted.

Further detail to be provided in the Proposals Map DPD.

Name Organisation Policy Reference Michael Simmons Resident Maps Nature of Comment: Object

The maps are very poor and in some regards invalidate this consultation. The document fails to address enhancements to the District, Central and Picadilly line tube services without which development at Ealing Broadway is not viable and in the South Ealing wholly unacceptable. Response: Not accepted.

The maps provided are indicative only and their purpose was not to include the finer detail which will be provided in a Proposals Map DPD. The Proposals Map DPD, which specifies sites, areas, and other locations identified in the Development Strategy, Development Sites and Development Management DPDs will be prepared and published in Spring 2012. This will build on the existing maps provided to date and provide greater level of clarity and detail.

The Infrastructure Delivery Plan will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure is provided alongside new homes, workplaces and other forms of development up to 2026. Included in this will be the relevant necessary enhancements to tube services, as deemed appropriate in order to assist in achieving the objectives set out in the Strategy.

Outcome: No change.

Further detail to be provided in the Proposals Map DPD and the Infrastructure Delivery Plan.

213 Appendices

Name Organisation Policy Reference Transport for London Statutory Appendix 3 Nature of Comment: Support with conditions

The target of 26% increase in transport capacity post 2011 will need to be fulfilled through infrastructure planning. To help assist this process the Council should ensure early consultation with TfL and engage in pre-application discussion on large and strategic planning applications.

When considering the impact of development proposals on the transport network and proposed mitigation measures, both transport assessments and travel plans are likely to be required. For applications that are referred to the Mayor these should be prepared in accordance with TfL best practice guidance.

TfL supports the need for a clear framework for S106 contributions for public transport. This should reflect the priorities set out in the draft replacement London Plan 2009. TfL would wish to be consulted on SPD9 at an early stage in its preparation. This should reflect the priorities set out in the The London Plan: consultation draft replacement (October 2009) policy 8.2 and London Plan policies 6A.5 and 6A.6.

As stated earlier in this response, although Ealing lies outside the Central Activities Zone, Crossrail contributions should be sought in appropriate circumstances. Response: Support welcomed.

Transport for London will be consulted on any future large or strategic planning applications and on SPD 9. The Infrastructure Delivery Plan, which is currently being prepared will identify all items of infrastructure needed to ensure the delivery of the growth targets contained in the Development Strategy 2026. This ensures that an appropriate supply of essential infrastructure, including the necessary transport infrastructure, is provided alongside new homes, workplaces and other forms of development up to 2026. Outcome: No change.

214