CHRAG met with Rachel Victor-Sampson, Chiswick Town Centre Manager. Rachel explained that she covers Brentford and Isleworth as well as Chiswick. Her team at the Council is principally involved with Regeneration and Inward Investment, headed up by Ian Rae.

We had a wide-ranging agenda which included:

• Supporting small businesses and traders on CHR (& adjoining streets)
• Maintaining the character & context of Chiswick, in line with the Local Plan, Character & Context study, new conservation area status, etc
• Carrying out a comprehensive appraisal of CHR. Can we bid for money to fund CHRAG or a consortium of local interested to commission/prepare such an appraisal?
• What we can do to ensure highest-possible quality of any new building or refurbishment of existing buildings.
• Our concerns about over-dense/over-high new developments (eg. Empire House).
• Improve short-term parking for shoppers and encourage LBH/TfL to consider introduction of shuttle bus services, cycle lanes, etc to encourage local shopping and support of local businesses/traders.
• In line with LBH commitment to community engagement, improve dissemination of information about planning applications and developments by using all means of communication, including IT-based but also notices at Town Hall, Library, Post Office, street notice boards.
• Telephone boxes (we have supported a planning application to turn a couple of boxes into coffee kiosks)

After some discussion about the Manager’s realistic ability to deal with many of our concerns, the following emerged :

1. Public realm
Defending the public realm. We made clear that we were concerned about infringements on the public realm. For instance, we explained our concerns about a possible offer from developers to re-imagine the market stalls (in front of Sainsburys), as part of their S106 payment. Not only should substantial S106 supply amenities such as schools and doctors’ surgeries, but also we did not want to encourage any risk that public realm could become privatised.

2. Design surgeries
We felt that more discussion about developments in Chiswick before planning applications would be useful.

3. Transport issues
One of our members had in the past drawn up a list of possible parking areas that could be effectively used by the public on the weekend (eg. behind the Town Hall, ex-BSI building, etc. Rachel would look into the matter.

4. Communication
The noticeboard at the Town Hall was neglected, and could be used to better effect.

5. Chiswick Market
There was discussion about the possibility of creating a Saturday Chiswick Market in the car park outside the police station, which used to be the site of the old Chiswick Market. It was felt this could provide a central point for Chiswick, which was felt to be lacking, eg. for a Christmas tree. CHRAG would explore further.

6. Destination Chiswick / ShopChiswick
Destination Chiswick, with the support of MP Mary Macleod and Rachel, is aiming to raise money via Spacehive to create a Chiswick website and maps. ShopChiswick links small businesses in the area.

Chiswick High Road Action Group (CHRAG) is an amorphous group comprising local residents and business people. It is committed to supporting good sustainable development of the Chiswick High Road Area.

CHRAG has published its response to this major development

Download Full Objection

Make your own objection – DEADLINE EXTENDED

Sustainable Development?

The development site with its excellent transport links is suitable for uses consistent with Hounslow’s Local Plan including office, hotel / conference, community / institutional and open space.

Such uses would represent socially and environmentally sustainable development, as well as being financially sustainable.

What is proposed is adding purely residential units.  This removes the opportunity for other uses of a large part of central Chiswick forever and endangers its sustainability.

CHRAG is determined that the opportunities afforded by this site should be exploited to benefit sustainable growth for the future of those who live and work in, and those who visit, Chiswick. The development makes no contribution to the future sustainable development of Chiswick.

Lend Lease’s vision of the future of Chiswick. Essex Place (behind Chiswick High Road, next to Sainsbury’s). No new mixed-use buildings – just residential buildings aimed at the high-end executive market. No affordable housing.

The Plans

Lend Lease have planning permission for the conversion of Empire House to residential under permitted development, something over which the local planning authority had no control. This permission applied to the floor plate of Empire House itself. Lend Lease now proposes to extend this block both upwards and outwards, and in addition seeks permission for new residential developments on other areas of the site.

This includes a 7 and 8 storey block on a car park that has not been subject to a previous planning application, and a 5 storey block on a car park that does have existing permission for residential development.

“The proposed development is wholly out of keeping with this part of Chiswick.”

The proposal provides residential units at the expense of local amenity and is ultimately a block to sustainable development of this part of Chiswick.

Affordable Housing?

Affordable Housing gives the opportunity for someone with an average income to be able to afford to buy. Developers are required to allocate a proportion of affordable housing within a given housing development. This ensures a healthy mix of new residence.

Despite clear requests Lend Lease has refused to provide any information about Affordable Housing and their contribution to infrastructure amenity. CHRAG believes this reflects an approach focused on maximising profit at the expense of any other considerations.

The presentations given at the exhibitions and on the developer’s website obscured important aspects of the development. The increased height and width of Empire House and the bulk and extent of the additional tower blocks was hidden. Pictures were used that obscured the nature and mass of the development.

A rudimentary online survey conducted by CHRAG shows results that are diametrically opposed to Lend Lease’s assertions of public opinion.

View survey results here

Design

Lend Lease image of Empire House Tower from behind the bushes

Lend Lease states their overall design objective to be as;

“Comprehensive redevelopment of the site for residential led mixed use development […] and improvement to the public realm and creation of on and off street car parking.”

In fact the proposals only public realm offer is to create a narrower road with greater traffic load, increase the total car requirement in the area while creating no additional car parking space.

Lend Lease sketch of their new enlarged tower. Balconies barely visible, and proposed Essex Place missing from the picture.

The existing tower block, Empire House, is described by Hounslow Council in the Turnham Green Conservation Area Planning Statement as being of “obtrusive height”.

The current application seeks to raise the height and to project balconies, which will further increase the appearance of bulk, whichever direction it is viewed from.  Drawings are not completely clear but it appears that there may be recessed balconies in the south facade, overlooking Turnham Green, and projecting balconies on the west and east elevations.

The image Lend Lease refused to show us. A composite 2D representation with Empire House superimposed on a developer’s drawing of the Essex Place development.

Whilst it is possible to draw projecting balconies to imply they have minimal visual impact, the reality will be that this already bulked-up mass of tower block, will appear to be even fatter.

There is no justification in permitting this obtrusive tower to grow bigger again.

The main entrance proposed into the enlarged Empire Tower from CHR, is a three-storey tall “portico” with a recessed glass and sheet aluminium wall surface behind.

The Design Statement’s assertion that this emulates the grandeur of the original theatre would be laughable if it were not meant seriously.

The original theatre was extrovertly ornate and decorative Frank Matcham Baroque, with a 3-bay central section of the frontage being a two storey “triumphal” arch opening over the ground floor marquee.

Any more than a moment’s thought will demonstrate there is no comparison between the new Empire tower entrance and the Edwardian theatre, contrary to Lend Lease’s promise in their planning application

“Grounding” the tower, as referred to in the D&A Statement, by dropping eleven storeys of the cliff-face of the building straight down to pavement level, is no way to reduce the detrimental effect of its bulk on the skyline or as a backdrop to Turnham Green church or to the Conservation Area.

The Acton Lane block faces across the road to Chiswick Park station. The station building is Grade 2 Listed (= Heritage Asset) and one of a group of important inter-war Deco stations by Charles Holden. Other recent mundane developments which have been permitted nearby should be no excuse for yet another. Planning authorities have a duty to protect the area around Listed Buildings from inappropriate developments which damage or detract from that building or its setting.

Irrespective of arguments about whether the development should be permitted at all, the totally unsympathetic architecture of the buildings proposed should be rejected.

The entrance to the road serves a further 21 flats in Acton Lane and bifurcates to provide access to Sainsbury’s car park and delivery yard. The traffic on this road will be heavy – the child and his dog playing in the middle of the road are a fiction of the architects’ imagination and a misleading visual by the developers.

The high buildings on either side of Essex Place (13 storeys on one side, 7 and 8 on the other) will make it more like a dark windy canyon.

“Promoting pedestrian use of Essex Place through the creation of shared space” simply means putting down some kind of friendly paving. This in no way reduces the amount of traffic.

“Providing opportunity for external integrated play space, seating and general amenity” has actually resulted in no space designated for play; there is one bench shown in the images, and that fronts directly onto the roadway.

The beautifully-drawn planting in the images will have to be very mean to allow for the delivery access. The front entrances from the houses and flats open almost directly onto the roadway with a small amount of tightly controlled planting to protect the first steps out of the houses.

The proposed design of this building should be rejected in favour of a building of architectural merit in conformity with local policy.
Overall the proposed development fails to improve the public realm and, if allowed, would represent a significant degradation of the public realm and a blow to sustainable development of this part of the Chiswick area of Hounslow.

In addition to the formal responses to Hounslow about the Local Plan Consultation sent by CHRAG (read these in full here), the group has today lodged a complaint about the consultation process itself as follows:

Further to the representations made by the Chiswick High Road Action Group on the Local Plan Submission Draft, attention is drawn to a seriously misleading error in the Local Plan Consultation Statement.

We understand this does not relate to the Local Plan itself, however feel that this point should nevertheless be made as an addendum to our responses sent earlier today 29/4/2014.

The error is in the ‘Summary of Comments per policy area for the Local Plan Policy Options 2015-2030’ in section 5 that begins on page 15.  The first, and arguably the most important, of the policies is “Key Challenges”.  According to the bar chart produced on page 15 as Table 4.3 and the pie-chart on the same page 59% of respondents disagreed with the key challenges for the borough.  Yet the text of the document reads, at 5.1:  “Respondents were asked whether they agreed with the key challenges for the borough, Majority (59%) responded they were in support [my emphasis] of the key challenges the Local Plan identified for the borough. . . . . ”

This is surely a totally unacceptable, dangerous and key error that demonstrates an unsatisfactory, flawed and careless approach to consultation.  Furthermore the Consultation Statement fails adequately to deal with the level of disagreement as to the Key Challenges (even if 35%, but surely if 59%) and to demonstrate that proper account has been taken of the representations made.

It is to be noted that next policy area, Spatial Strategy, had the second highest level of disagreement and although that is accurately recorded in the narrative, the ‘How these issues were taken into account’ section is very weak and falls short of the satisfactory explanation required.

These are serious errors in the interpretation of key consultation data upon which readers are expected to provide responses, and calls into question the legal compliance of the consultation process.

The Chiswick High Road Action Group (CHRAG) has formally responded to Hounslow’s final call for comments on the proposed Local Plan. CHRAG’s response focuses on the Chiswick High Road area.

CHRAG has requested to be present at the oral part of the examination for the following reason:

“We wish to bring the attention of the Inspector to the risks we perceive of Chiswick being subject to over-development in an eagerness to attract big business and large-scale developments, rather than encouraging small and independent traders, retailers and businesses, consistent with the special character and context of Chiswick as a small town centre.”

CHRAG’s representation comprises four responses, the full text of which are presented below.

Overall Language and Presentation

CHRAG believes that the Local Plan document in its entirety uses impenetrable terminology.  Its language is in many places vague and ambiguous.

There are sentences that are incomplete and difficult to follow, and difficult to relate to the National Planning Policy Framework and The London Plan. These are failures that have effectively excluded ordinary residents and groups from being able to engage properly in the consultation process.

Proposed change

CHRAG formally requests that the local authority provide a 2 page executive summary in plain English which will facilitate engagement by the local populace.

There are too many examples of incomplete sentences and poor grammar to list here, however CHRAG formally requests that the proposed submission is re-worded where such mistakes have been made.

No Concrete Guidance for Planners

The wording of the Chiswick section provides no concrete guidance as to how the apparent desired outcomes will be achieved. For example;

1)      How can “modest levels of growth” deliver housing and jobs? How will LBH secure improved public transport provision (2.38 para 5)?

2)      How are planners expected to be guided by the expressed desire for “in a sensitive, thoughtful, yet contemporary manner”? This wording provides no concrete policy guidance for planners or developers.

3)      The map on page 35 has no legend to explain the colours, shading, numbers, and arrows. CHRAG as representatives of the interests of Chiswick High Road Residents, users, and business people cannot comment on the soundness of the map, the legal compliance of this section, and how the map might affect the lives of people living and working in the area.

4)      Para 2.38, point 2. We have concerns about the proposal to “connect the growth of the Golden Mile” to Chiswick Business Park, and we do not think this is sufficiently explained. What does “connect the growth of the Golden Mile” mean in development terms?

5)      While the plan purports to protect the established character of 3 to 4 storey mixed-use buildings and promote sensitive infill (2.38 point 3), it nevertheless encourages redevelopment of major sites such as 500 Chiswick High Road in point 1 of this section in such a way that contradicts the aforementioned aim. For example, in the case of 500 Chiswick High Road, planning has been approved for a 7 storey building where previously there was a 2 storey building with a tall tower on one corner, not to mention the loss of a Victorian residential property as part of this scheme. Regardless of one’s view about this scheme, this is an example of inherent contradiction within the Local Plan.

Proposed change

Provide concrete guidance as to how the apparent desired outcomes will be achieved:

1)      The plan needs to explain how the investment will help to deliver the quoted infrastructure improvements given that LBH has no authority over TfL or the Highways Authority deliverables

2)      Instead of vague sentiments, such as “sensitive, thoughtful, yet contemporary manner”, use objective language, for example;

“Respecting the current low-rise and historic character of Chiswick”,

and provide specific examples of what this entails referring to architectural features and proportions, building materials, use of space, etc.

3)      The map on page 35 needs to be explained, be annotated with its own legend / key, or provide a reference to another part of the document where this is explained.

4)      The Local Plan must explicitly provide that, in the course of any development, the individual characters of conservation areas are retained, such as those of Thorny Hedge Road and Silver Crescent.

5)      The Local Plan must be more explicit in its commitment to ensuring that the character and context of Chiswick Town Centre is retained, and that tall buildings are avoided in accordance with the Character and Context Study for Chiswick which illustrates on page 9 the whole of Chiswick’s unsuitability for tall buildings.

Empire House Area

Development of Empire House area as hotel, office and “larger floor plate” retail accommodation (page 235) suggests an intensity of use inconsistent with the stated goal to “support the diverse mix of local independent shops and businesses” (page 34, 2.38 point 3).

CHRAG welcomes development suitable for hotels, offices, and retail, however the reference to “larger floor plate” retail accommodation is not appropriate given the proposed goals in page 34.

Proposed change

Remove the reference to “larger floor plate” retail accommodation which would certainly not directly attract local independent retailers according to the Local Plan’s stated objectives.

Replace this with wording that secures the Local Plan’s stated objectives, rather than undermines it.

Furthermore CHRAG request that the Local Plan explicitly stipulates space for community recreation activities, as well as pedestrian access and enjoyment.

At the very least this site should support the council’s stated commitment to support independent business.

Relation to the Character and Context Study

Page 9 of the Character and Context Study for Chiswick shows that almost the entire area of Chiswick has low suitability for tall buildings. In area E of the Character and Context Study for Chiswick, the Empire Building is described as ‘an incongruous 1960s office tower overlooking Turnham Green Common’ and the 19 storey Chiswick Tower is described as ‘hiding Gunnersbury Station beneath.’

We also criticise the Local Plan for the suggestion that the Golden Mile should be extended and linked to Chiswick Business Park.

Proposed change

The Local Plan, on page 235, should emphasise the fact that the Empire House site falls in an area which is not suitable for tall buildings. Development of the very large site identified on page 235 must be consistent with the special character and context of Chiswick in general and the Turnham Green Conservation Area in particular.

The Local Plan should also demonstrate an understanding that areas regarded as unsuitable for tall buildings are equally sensitive to tall buildings being erected in adjacent areas.

In the section on Connectivity (10), a stronger case must be made for negotiation and cooperation with TfL and Network Rail to bring about significant improvements to Gunnersbury Station. This must also include improved access especially for the disabled and greater visibility from the main road.

Hounslow have published their “Policy Options for the Local Plan” document.

Download this document here.

This document sets out the first stage in developing a new plan for Hounslow that sets out the borough’s future development over the coming 15 years.

• The Policy Options and accompanying interim Sustainability Appraisal Report are published for public consultation for a six week period from 14th June to 26th July 2013.
• Chiswick High Road Action Group is currently considering its position on various aspects of this document, however it recognises that a response will be required as much of the document will affect the character of the High Road and surrounding residential areas.

Chiswick High Road Action Group sends in objection to Brentford Football Club’s planning application.

This proposal (Planning No 00703/A/P11) is for a new 20,000 seat football stadium, up to 910 high rise residential units, 160 room hotel, ancillary offices etc on land adjacent to the North/South Circular Road at Lionel Road, Chiswick/Brentford, TW8 9QR

In summary, our objections are:

• The scale, height and massing of the 9 high rise residential towers of up to 17 storeys impacts negatively on the surrounding areas and overshadows Chiswick
• The increase in proposed population with no provision for additional social facilities or outside space is unacceptable
• The architecture is inappropriate and characterless with no sense of local pride or civic identity
• The traffic impact of the proposed scheme is enormous and entirely negative, both on roads and on public transport
• The impact on local residential areas and the riverside, both of which are integral to the character and context of our area, are substantial and negative

In short, we worry that this is not really a stadium with enabling development, it is actually a development with enabling stadium which provides the veneer of community benefit to a very substantial building programme which may well damage the very communities and areas it claims to be supporting.