PLANNING  

Some of the Applications Reviewed/Commented on:-

Park Road Cemetery Chapels (Grade ll Listed) :  Change of Use to “Community Use”, for vulnerable adults to meet and undertake craft and engineering projects.  In progress.

Land Adjacent to 36 Kendall Road : to build one 4 bed family home on three floors.  Officers recommend refusal as would harm neighbours’ living conditions and be of poor standard.

Bolder Academy, 1 Macfarlane Lane : demolition of club house/ car park to construct part 2-4 storey secondary school, multi-use games area : approved by planning committee despite acknowledged concerns over inadequate access/transport provision.

37-71 Wynne Court, Hartland Road : conversion of 38 sheltered flats into 18 units general housing comprising 15 social rental flats and 3 shared ownership. TIS objected to loss of needed sheltered homes; over-development with no amenity space and unacceptable waste and recycling provision.  Planning Committee approved 

37 South Street : Prior Approval request for change of use from Betting Shop to two residential units.  Refused as Prior Approval is not applicable within a Conservation Area.

4 The Pavement, South Street : erection of single storey rear extension to create a flat/rear and roof extensions to existing flat.  Refused as excessive scale, inadequate internal space/poor outlook.

33 South Street : new application to change use of bin store to retail unit with glazed shop front. TIS has objected over poor access to re-located bin store and lack of information on application in regard to the proposed retail unit.  In progress.

Ashby House, Swan Street : window alterations, erection of roof extension, creation of terrace and extension of balcony : approved.

George Public House, 114 Twickenham Road (Grade ll Listed) new owners are fund raising with intent it should become a "community centre, for youth work, education and prayer facilities".  No Change of Use or Planning Application has yet been made.

THE ISLEWORTH SOCIETY SUBMISSIONS DECEMBER 2017

TO LONDON BOROUGH OF HOUNSLOW’S LOCAL PLAN REVIEW 2017 CONSULTATION 

LOCAL PLAN REVIEW AMENDMENTS TO VOLs 1 and 2 OF LOCAL PLAN 2015

CONSULTATION OCTOBE 2017

The Isleworth Society objects to, and requests removal of, the proposal to allocate Park Road Allotment Gardens, Isleworth, for residential development for 170 units for the following reasons:-

·      Incorrect “justification” is cited intimating the land is surplus to the Council’s requirements; the Council’s latest Allotment Strategy does not substantiate this claim and acknowledges a high percentage of use of the plots available; the Northumberland Estate, owners of the land, hold a list of prospective allotment holders.  GB8 of the Council’s approved Local Plan states “We will encourage continued use of allotments”. 

·      The proposal is contrary to the Context and Character study for the area, namely, to reflect the setting of the place including natural and human history, its identifiable forms of settlement, its buildings and its spaces, its ecology, archaeology, location and need to foster active lifestyles.  The land has not previously been built upon and has been available as allotments for over 100 years.

·      The site is governed by Asset of Community Value status.  Among her findings during a First Tier Tribunal following the Northumberland Estate’s appeal over grant of ACV, when the status was upheld, Judge Findlay stated “I am satisfied the allotment land not only provides recreation and food for its direct users but also community benefits of green space and concomitant benefits to air quality and visual amenity”.

·      The site is designated as Open Space 

·      The proposal is contrary to the approved Local Plan 2015 Spatial Strategy statement “Isleworth derives much of its special character from its relationship with the River Thames”.   The site contributes to a green corridor from the Thames, is within the flood plain and prone to flooding.

·      The proposal is contrary to the approved Local Plan 2015 statement that “the grouping of All Saints’ churchyard, Park Road Allotments and Park Road cemetery provides an historic Open Space with a woodland of mature trees, shrubs, hedges, allotment spaces and, due to the limited footfall, a much-valued wildlife haven”.

·      It is contrary to the approved Local Plan 2015 Spatial Strategy statement for Isleworth that “There is little room for new development and this is reflected in the planning approach which focuses on safeguarding and promoting the established character”.

·      The site has a poor PTaL rating

·      The proposal will be the equivalent to implanting a new village within an existing small village enclave to double its size. 

GREAT WEST CORRIDOR LOCAL PLAN REVIEW                                                  

PREFERRED OPTION CONSULTATION DOCUMENT OCTOBER 2017

 

1.     OPTIMISING HOUSING GROWTH.

POC Para 2.17 “residential conversion of office buildings through utilising permitted development rights is a threat to the commercial activity in the area”.   The Local Plan should include a statement that applications for sites with low PTaL ratings at the time of submission should be refused; the reasoning is that consent for further office buildings prior to substantial improvements in public transport will lead subsequently to conversion of commercial sites to residential.

POC Para 2,16 states “any significant employment growth is dependent on significant improvements to public transport to access the area”.  Development should be dependent on significantly improved access and this should be rail based and not solely bus.  It is an improbable conclusion that people wishing to live close to their workplace would lead them to desire to live so close to major roads, not least because many applications are for studio/1/2 bedroom flats rather than family accommodation.   Sites close to the North and South Circular Roads, the A4/M3 corridor are unsuitable for residential development.

2.     PROMOTING HIGH QUALITY URBAN DESGN AND CONSERVING HERITAGE

POC paras 2.27-2.29 fail to recognise that the scale and setting of existing art deco buildings are as important as their decorative features; new buildings should not be permitted to affect their settings. In addition, more protection should be afforded to maintaining views to the Art Deco Gillette Building with its clock tower (para 2.2 refers) recognised in the document as a landmark building forming the western entry to the Golden Mile. Views to the tower should be specifically protected from all angles but particularly from the south and south-west where high rise developments are proposed. Figures 4.1 and 4.4 should illustrate this as a significant view. Further there needs to be a distinction between Heritage and ‘landmark’ buildings to emphasise this point and we suggest that para h) is amended to refer to Heritage and ‘landmark’ buildings and that the Gillette Tower is included with the buildings in (i) on p53

(POC) para 2.30 recognises that modern tall buildings can adversely affect vistas from Kew Gardens but fails to acknowledge the harm to views from Kew and Syon Park both Grade l heritage sites.  No policy is acceptable that promotes tall buildings which can harm views from listed buildings or Conservation Areas.

3.     ADDRESSING CHALLENGES

POC para 2.31 fails to provide remedies for the challenges outlined.  The A4/M4 is the major west radial to Heathrow, and the west, further development will inevitably result in more vehicles.   

4.     TRANSPORT AND CONNECTIVITY.

What is required is a comprehensive programme for transport improvement to include inter alia a cycle superhighway for the A4, a total re-build of Gunnersbury Station with substantially improved access, increased local bus services and a two way link to Cross Rail.  It is imperative new developments are not approved prior to PTaL improvements.

5.     THE SPATIAL VISION.

Recognition needs to be given to the fact industrial estates, while of great importance to the area, are incompatible with residential development. A policy comment is essential to ensure achievement of objections on pages 38/39.

6.     SPATIAL POLICIES: HOUSING.

(POC) Para 4.7 states that the “Great West Corridor has been identified as a potential “Opportunity Area (OA) or an “Intensification Area”.   The area is not currently included as an Opportunity Area in London, nor an Intensification Area.  It does not have the capacity required for this if heritage assets are to be respected or homes provided that do not depend on artificial ventilation or accord with densities that pay attention to PTaLs.

(POC) Para 4.9 refers to the need for affordable housing.  Too many past permissions been permitted omitting affordable housing citing exceptional circumstances.    It is understood that Hounslow’s target is in the region of 10,500 new homes but is it has not been demonstrated that the Great West Corridor has the capacity to provide 45% of this housing over the plan period.  No estimate has been given of additional school population or how this will be met.

7.     ALTERNATIVE APPOACH

(POC) Page 48 indicates an alternative approach if “the game-changing infrastructure” is not operating within the plan period and will be determined by “The Transport Impact Assessment”.  This document has not been made available which makes the alternative approach pure conjecture.

8.     EMPLOYMENT GROWTH

There are no proposals in (POC) paras 4.22/25 (pages 50/55) to show how these objectives could be met if the “game changing infrastructure” is not operational before 2030.

9.     DESIGN AND HERITAGE

A specific policy is needed to ensure that any development which crosses the existing skyline seen from Kew Gardens and Syon and to and from the River Thames should normally be refused.

(POC) Para 4.49.  Much of Brentford is in an “Open Space Deficiency Area”. New public open spaces need to be factored in to meet the standards set in the London Plan.

10.  ENVIRONMENTAL QUALITY AND OPEN SPACE

(POC) Paras 4,53/55 outline pollution and noise problems.   Specific policies should be included to reduce traffic speeds, introduce traffic controlled pedestrian crossings, ensure schools are not built on open spaces, support completion of the Thames Path.

11.  TRANSPORT AND CONNECTIVITY

Evaluation of how much additional development can be accommodated is not possible until the Transport Impact Assessment is provided. Although the document does suggest an incremental approach to achieving the necessary growth linked to this it needs to be made clear that this must be related to achievable delivery dates for any new or updated transport infrastructure. These must be as a pre-requisite, be step free and able to cope with increasing levels of demand including at weekends.

12.  PLACES POLICIES

The approach outlined on POC pages 81 – 84 is unrealistic.  Buses need lay-bys to prevent congestion at each stop, cycle routes need protection from traffic turning off the road and crossing a six lane highway is perilous for pedestrians.  It is essential buildings are set back to make provision for these aspects, in addition to room for trees, signal controlled crossings, service access, etc.

13.  EDUCATION AND INFRASTRUCTURE.

Requirements for schools need to be realistically demonstrated, also facilities that will be provided in a way that supports residents close to their homes 

14.   CONCLUSION: 

The draft document does not demonstrate that there is sufficient capacity to achieve the objectives of its Vision for 4,800 new homes and attendant facilities and to maximise employment space while preserving and respecting the historic heritage.  

WEST OF BOROUGH LOCAL PLAN REVIEW OCTOBER 2017

1.    The key proposal to remove green belt protection from over 100 hectares of Open Space with the downstream purpose of large scale development linked to Heathrow Expansion, is contrary to both Government and GLA policy in addition to that of the Council.

 

2.    It is significantly flawed, reaches erroneous conclusions, is different from the 2013 policy with no justifiable reasons given for reviewing the green belt.  The assessments ignore the function of supporting Feltham and Ashford.  There is no evidence that derelict and other urban land has been assessed.

 

3.     The proposal conflicts with those of the Mayor of London’s Green Belt Land.   The draft London Plan includes guidelines for increasing green infrastructure; a framework to help boroughs and developers determine how much should be required in new developments and makes it clear green infrastructure must not be an “add-on”, thus the West of the Borough Plan fails to have due regard to the Mayor of London’s draft London Plan.