Statement of Consultation
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Appendix A Old Oak and Park Royal Development Corporation Local Heritage Listings Statement of Consultation October 2019 1. Introduction OPDC consulted the proposed Local Heritage Listings from 8 February and 22 March 2018. Twenty-seven consultation responses were received providing two-hundred and twenty-seven individual comments. This document presents all comments provided on the proposed Local Heritage Listings as part of the consultation, as well as OPDC officers response to these comments. Where a change is proposed in response to specific comments, this is noted in the officer response. This statement should be read alongside the Assessment of Nominations to the Local Heritage Listings. Page 2 2. Comments and Responses Com ment Respondent Comment OPDC Officer Response ref 1 West Twyford 1. Some building entries are in a very poor physical condition and in Noted. Residents' need of extensive work to make them presentable in a 21st century Association industrial estate. 2 West Twyford 2. No suggestions are made as to possible alternative uses - which may Noted. This is beyond the scope of a Local Heritage Listing. Residents' / would be acceptable to the owners and planners - and fit into the Association Master Plan. 3 West Twyford 3. I assume the list will be published in and shown in the Master Plan. Noted. The Local Heritage Listings will be published separately to the Residents' Old Oak North Development Framework Principles. Association 4 West Twyford 4. How enforceable are the listings as they are not National Planning Noted. Heritage assets that are locally listed or identified as Residents' Listings Grade 1 or 2 - which are enforceable by Planning Authorities. buildings of interest do not benefit from statutory protection from Association Commercial owners of existing properties may be surprised to find out demolition. However, identification will inform OPDC's planning their building is on a new local Heritage listing. decisions when considering development proposals. OPDC's Local Plan, the London Plan and national policy will be used to manage these assets. 5 West Twyford 5. It is interesting that the Perfume factory is on the list as two Change proposed. Since the Local Heritage Listings consultation was Residents' developers are currently working on schemes for this site and one has undertaken the Perfume Factory has been demolished and will be Association been submitted for Planning. ( I know it has been rejected by ealing removed from the Local Heritage Listings document. Planners but the developer has spent a lot of time and money). 6 West Twyford 6. Some of the buildings listed in Evelyn Road, Ealing NW10 are related No change proposed. These buildings are located within Park Royal Residents' to food production. They are smelly, unsightly, and adjacent to Strategic Industrial Location (SIL). Local Plan policy P1 requires that Association residential areas and they back onto the Grand Union Canal. Not what industrial uses are protected. However, should the site be developed you want next to residential areas or on a canal side / cycle route in a for industrial uses, policy EU4 will be implemented which requires future tourist area. (It should also be noted that Brent's proposed development to deliver a positive contribution to air quality. housing corridor along the North side of the Grand Union Canal from Alperton to Stonebridge is earmarked for future housing and will look onto these premises.) Page 3 7 West Twyford 7. Why is only half the length of the Grand Union Canal (within OPDC), Noted. The designation shown on the map reflects the existing Residents' shown as a Conservation Area? designations of two separate conservation areas by LB Association Hammersmith & Fulham and LB Ealing. OPDC will be progressing the designation of a new conservation area for the whole of the Grand Union Canal within the OPDC area in due course. 8 West Twyford 8. Publicly Accessible Open Space is not divided into public and private Noted. Local Plan Policy D2 provides guidance to deliver public Residents' ownership. As an example the open spaces shown in the First Central access to privately owned public realm. Association Development is Privately owned and access has been limited since the first OPCD plans were published. 9 West Twyford 9. Cemeteries are open spaces but not recreational spaces. There is a Noted. Residents' big difference in the use of a park and a cemetery. Association 10 West Twyford 10. Why are no Accessible Open Spaces on the Local Heritage Listings? No change proposed. The Local Heritage Listings designations reflect Residents' All parks should be listed as they are integral to the communities they the historic significance of assets following a comprehensive Association serve. Two I am particularly interested in are the Harold Wesley Park assessment. The protection of existing open spaces is detailed in next to the Wesley housing estate and the Bodium Field Park on the Policy EU1 of OPDC's Local Plan. NW corner of First Central Development. With the exception of Wormwood Scrubs these are the only two good sized parks where a child can kick a ball any distance. There are no future football pitches proposed in the OPDC development area. 11 Ealing Council General comment:We have no objections in principle to the objectives Noted. of the document. The document is set out clearly and in a methodical manner and incorporates good graphical information. 12 Ealing Council Comment on listings criteria: Noted. The development of two designations was recommended 1. The criteria that is set out is generally quite standard in nature. The within OPDC's Heritage Strategy. Section 1.2 of the Local Heritage only thing we would question is the fact that you are distinguishing Listings sets out the role of the Local List in accordance with Historic between two sets of designation: one is the more traditional ‘local list’ England's guidance. Section 1.3 of the Local Heritage Listings but the other refers to less important assets of ‘heritage interest’. document identifies that Buildings of Local Heritage Interest have Whilst this approach is not new, it is not something specifically lesser heritage interest but are part of the Old Oak and Park Royal advocated by Heritage England’s Advice Note (no. 7). We are not sure story. OPDC considers that this two tier approach provides what added value this secondary designation brings and, if anything, additional clarification to stakeholders on the heritage significance could confuse matters in terms of what weight/value to apportion to to inform development proposals. assets in this category as part of the planning process. This will to some extent depend on any supporting policy that is adopted is in relation to this, but we note that this is not something that you are consulting on Page 4 at the moment. 13 Ealing Council Comment on listings criteria: No change proposed. The Local Heritage Listings identify where an 2. The selection of assets for a local list is often done as part of, or existing conservation area and it's setting relate to the listing. On the linked to, a conservation area appraisal. No new conservation areas are establishment of OPDC on 1 April 2015, the responsibilities for proposed, but it is worth reiterating that the selection of locally conservation areas within Old Oak and Park Royal became important assets should have full regard to the existing conservation responsibility of OPDC. OPDC will be undertaking a review of existing areas in the area- notably Old Oak and the Canalside (north-western) conservation areas it has inherited from the boroughs in due course. Conservation Areas. Ealing is in the process of carrying out a strategic review of all 29 of its conservation areas. This will include Old Oak and Canalside over coming months. 14 Ealing Council Comment on proposed heritage list: No change proposed. This is set out in summary of draft Local 1. We note that the descriptions provided with assets (including within Heritage Listings on page 85 and onwards within the Local Heritage the separate appendix) lack detail in some cases. It would be useful to Listings document. have more detailed descriptions setting out more clearly how the selection of the assets relate to the specific selection criteria. 15 Ealing Council 2. L37- Former Railway Institute – proposed for local list. Our CA Noted. Appraisal identifies this as a key building of local interest based on its architectural form and social function/history. As such there is no objection in principle to the proposed local listing. 16 Ealing Council 3. L38- Fisherman's Arms PH- proposed for local list. Again our CA Noted. Appraisal proposed adding this to ‘buildings of local merit’. As such there is no objection in principle to the proposed local listing. Page 5 17 Ealing Council 4. B15- Railway Cottages- proposed to add all the cottages within the No change proposed. The Local Heritage Listings identify where an conservation area to list of Local Heritage Interest. Our CA appraisal existing conservation area and it's setting relate to the listing. On the specifically only mentions 22-49 Old Oak Lane as being locally listed at establishment of OPDC on 1 April 2015, the responsibilities for that time (2008). These are currently identified as ‘Positive conservation areas within Old Oak and Park Royal became Contributors’ to the CA. In terms of the remaining cottages, our own CA responsibility of OPDC. OPDC will be undertaking a review of existing appraisal states that it would be difficult to separate any of these in conservation areas it has inherited from the boroughs in due course. terms of value. However in terms of whether they should all be included on the list of Heritage Interest, we would like to reserve judgement on this until we have carried out our own strategic review of the area.