Matter 2- Vision and Objectives (Chapter 1) Will French BSc, MCD, MBA, MRTPI, Representor Ref 174 This Submission relates to Representation Number 395, 397, 707, 710, 711 1. Are the Vision and Strategic Objectives soundly based and appropriate for this Borough, consistent with national policies, reflecting community views and locally distinctive, and do they provide a sound basis for the overall spatial strategy and strategic policies in the Core Strategy? Response. This question raises many similar concerns as those raised in Matter 1, Our response is much the same as our response then, and the Inspector is referred to it. In addition the Key Map (Map 2) has been prepared to provide a diagrammatic interpretation of the strategy as it applies in the Borough overall. Two points need to be made in relation to it: • The two development corridors are depicted using an extremely broad brush. Almost the entire borough is included in the two corridors but some locations are excluded even though they have very good access to public transport (South Acton, and Greenford) or to the A4/M4 corridor (South Ealing and Norwood). These areas are at least as accessible as some of the locations within the two development corridors which the final paragraph on page 12 suggests provide the criteria for channelling development into them. • On the other hand, the corridors that Map 2 identifies are extremely important in understanding the Borough’s underlying geography – the way that it works economically and socially. It highlights Ealing’s very strong east-west corridors and the weakness of its north-south linkages. This becomes even more apparent if the A4/M4 corridor to the south is considered which, while outside the Borough, is very important to it. I described this underlying spatial structure right at the start of the plan preparation process, Annex 1) and I continue to suggest it as a far more useful underpinning for the Spatial Vision than that presented the Strategy now proposed. 2. Is the Spatial Vision (policy 1.1) soundly based, effective and deliverable, appropriate for the Borough, supported by robust and credible evidence, and consistent with national policy? Response. Again, many of our concerns have been previously described and the Inspector is referred to our response to Matter 1. Other matters specifically related are these: • Policy 1.1 has one big idea which is expressed in (b) – to concentrate new development primarily along the Uxbridge Road but also along the A40. The other elements of this Policy ie (a) and (c) to (k) are not spatial policies at all – November 2011. Ealing LDF Examination: Matter 2- Vision and Objectives 1 they relate instead to the kind of aspirations which are set out in the Sustainable community strategy or to the sort of Issues that preparation of the Strategy should have explored spatial solutions to. • Of particular concern is Policy 1.1(c) – the commitment to protecting industrial and warehousing uses in the Borough. As I commented more fully in my response to the study by Roger Tym and partners on employment land use there is no justification for protecting warehousing in a Borough like Ealing which is already intensively developed and congested. By its nature, warehousing is low value adding and employs few people. It is also heavily traffic generating. The proper locations for such distribution uses should be in locations that have easier access to the national transport network ie around the M25. Much of the warehousing land in Ealing is Park Royal where it is under-utilised and could be released for higher value and more intensive purposes – including for instance the sort of major residential use proposed by Sir peter Hall. • Policy 1.1(h) also needs to be considered. This policy is worthless in the way that it is written, because unlike, for instance Policies 1.1(a) and (b) it is entirely unspecific in its wording such so that in practice it will carry very little weight. Adding insult to injury the reference to the Development Management DPD - a document that is at a far earlier stage of its preparation than the Strategy and even when approved will carry les weight than this Core Strategy document. 3. Is a vision based on transport improvements proposed in the two corridors deliverable if the schemes do not materialise and are the proposed improvements to transport capacity and quality east-west and north-south deliverable? and 4. For the transport strategy to be justified should there be specific reference to the Mayor’s London Transport Strategy. Response. The Borough is very strongly structured around its excellent east-west transport linkages which, sooner or later are now destined to be improved through the opening of Crossrail. The timing of Crossrail may be uncertain but the scheme is now sufficiently well advanced for it to be reasonably certain it will be delivered. Far less certain are any improvements to strengthening north-south or orbital routes which must now be deemed as the Borough’s priority in terms of its transport planning. Achieving significant improvements will depend very largely on the Mayor and TfL, but the need for such routes and the importance to its (and West London’s) economic growth should be stated much more clearly than the Strategy does. This will help the Borough to make its case in discussions with regional bodies like the Mayor and TfL and with neighbouring authorities. And it will help add weight to initiatives being taken for new orbital routes such as by the West London Orbital scheme (Annex 2) and the Brent Cross Rail Proposals (Annex 3). It is unduly restrictive and quite unnecessary to restrict the policy (top of P9) to enhance north-south movements to the facilitation of regeneration. The benefits of improved connectivity in the West London sub-region promise many benefits beyond the rather woolly principles associated with regeneration. Some of these are described in Annex 3. November 2011. Ealing LDF Examination: Matter 2- Vision and Objectives 2 5. The introduction to policy 1.2 refers to including some agencies; to be effective all relevant agencies should be noted. Response. We agree with the Inspector, but suggest in addition that the Ealing Community, its residents and interest groups should also be mentioned in line with the Government’s localism agenda and its promotion of the Big Society. We say this not to score a point, but because it will better reflect the role of the Council and its planners as coordinators, and enablers of all those who live and work in the Borough whose enterprise and initiative can contribute more fully to the way it develops. 6. Does policy 1.2(b) accord with emerging National Policy, if not, is the policy justified? Response. As we pointed out in our response to the 2010 study into Employment and Land Use by Roger Tym and commissioned by the Council, commercial uses are of critical importance to the continuing role of Ealing Town centre as a major centre in West London. There has been a steady decline in office and other B1 uses over recent years which is impacting on business in Ealing. The aims behind Policy 1.2(b) could therefore be better served were there a stronger commitment here as well as in other sections of the Strategy to the role of Ealing town centre as a commercial centre and the heart of civic activities in the Borough. 7. Is the supporting paragraph to policy 1.2(b) ‘short term protection’ in the proposed changes implying that an alternative use is a sentence rather than an opportunity? Response. During the past 10 year explosion in house prices important small employment sites that played an essential role in the local economy and servicing the local community have been appropriated for housing. The wider costs to Ealing in terms of a loss of start-up premises, longer journeys by small traders and the loss to the community of small workshops has never been cost out. Policy 1.2(b) should include a provision that further loss of such units will normally be protected against. 8. Policy 1.2(f) provides for tall buildings in specific town centres, what is the justification for such development and how will the area for such buildings be controlled? There is no definition of what constitutes a tall building effectively. Response. No justification is given in the Plan for locating tall buildings in town centres, and as the policy is stated it will be very hard for the development management team to control them. The wording of 1.2(f) is so loose as to be useless because it can be interpreted in just about anyway anyone chooses. The contrast with the existing UDP policy on high buildings is much clearer – where Table 4B states that ‘buildings or structures which exceed 20m or 65ft in height or which are significantly higher than their surroundings will ... not generally be acceptable on sites ... within Conservation Areas.’ The Council has offered no explanation for departing from this approach. As the last November 2011. Ealing LDF Examination: Matter 2- Vision and Objectives 3 sentence on p23 affirms, the London Plan confirms that ‘it is important to acknowledge that higher density housing does not automatically equate to high-rise development. The fudging of the policy on tall buildings in the Strategy is extremely worrying and is likely to have a major bearing on the deliverability of the strategic plan. The plan is dependent on the assumption that new homes will be provided in places like central Ealing in tall buildings. This was implicitly acknowledged in the July 2010 Officers’ report to Cabinet on the Strategy which overturned the LDF Specialist Scrutiny Panel’s desire to ‘avoid an over-concentration of tall buildings in any one area’.