According to the Town and Country Planning Act 1990 National Planning Policy Framework must be taken into account in making planning decisions.

The current planning application for a 32-storey skyscraper at Chiswick Roundabout (dubbed The Chiswick Curve) is unsustainable. It lacks provision for infrastructure, it utterly fails to support “strong, vibrant and healthy communities” by providing suitable housing – by no stretch of the imagination could living on the Chiswick Roundabout be described as healthy – and it has no “accessible local services that reflect the community’s needs and support its health, social and cultural well-being”. Finally it makes no contribution “to protecting and enhancing our natural, built and historic environment”. For all these reasons the application is unsustainable, thereby infringing para 7 of the NPPF.

Paragraph 32 of the NPPF states that “Plans and decisions should take account of whether safe and suitable access to the site can be achieved for all people”. Access to this site is very difficult for motorised traffic, and most residents will not have car parking space, nor should they be encouraged to use their cars. All other access is via foot or cycle only by crossing at least 4 lanes of fast moving traffic, through a highly polluted roundabout at the junction of the North Circular and several main roads, and beneath the four lanes of the A4. It is ludicrous to suggest that this is a suitable site.

The nearest tube station is Gunnersbury, where local residents are already asked to avoid travelling during rush hours as the station is overcrowded to the point of unsafety.

Development can, according to para 32 of the NPPF “be prevented or refused on transport grounds where residual cumulative impacts of development are severe.” This is such a case, both on its own, and even more so when taken in conjunction with the Brentford Football Stadium and its associated 900+ flats.

Paragraph 35 of the NPPF requires “access to high quality public transport facilities; create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians.” This development contravenes this requirement.

Paragraph 38 states that, especially within large developments, such as this one “key facilities such as primary schools . . . . and should be located within walking distance of most properties.” This application contravenes this requirement. A child living in this proposed property would not only have a very long distance to walk to the nearest school, but would be doing so across many lanes of crowded traffic, in a highly polluted atmosphere. While these flats are not aimed at families with children, by the laws of nature, they will inevitably arrive.

Click on image to see relative heights in closer detail

Paragraph 58 states that developments should aim to “establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit; respond to local character and history, and reflect the identity of local surroundings and materials.” There is nothing in the Local Plan’s analysis of character and history that in any way presents a 32 storey glass skyscraper as appropriate. Far from responding to local character and history, this development would dominate the surrounding conservation areas, and indeed establish its own sense of place in conflict with its surroundings, which would be irrevocably altered by the dominance of this building.

Paragraph 61 states that a new development “should address the connections between people and places and the integration of new development into the natural, built and historic environment.” The developer’s claims that the colouring will reflect the river reflections only serves to demonstrate how the building will overshadow the area, not just in the immediate vicinity but from as far away as the river (in contradiction to the Thames Strategy – Kew to Chelsea), Kew Gardens (UNESCO world heritage site) and indeed for some ten miles around. This is relevant, even before one adds into consideration the 25 metre advertising screens that will shine out from the building in several directions.

Paragraph 66 requires applicants to take account of the views of the local community. While pre-application discussions have been held with the planning department of Hounslow Council, these do not reflect the views of the local community, which have been very hostile. A PR exercise carried out by Starbones in Brentford cannot be considered representative. The hostility shown by all Chiswick councillors, and all local Chiswick societies, along with representatives from Kew, Ealing and Brentford reflects a more accurate view of local opinion.

Paragraph 67 says that “Poorly placed advertisements can have a negative impact on appearance of built and natural environment.” The enormous advertising screens on this building will do just that.

Paragraph 109 says that planners should “prevent both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution.” This building will be situated in one of the most heavily air polluted sites in London, possibly in Europe. All along the A4 in Hounslow is subject to disastrously high levels of air pollution. The offices at the level of the A4 will have the highest levels, while the penthouses will be less polluted. The architects say that all windows will be sealed shut and “fresh” air drawn in from the roof. Meanwhile government health policies encourage fresh air activity. Sealing the new residents and workers of this building into a hermetic pod because of the toxicity of the surrounding air is no way to live or work.

Paragraphs 128 and 129 state that local heritage assets should be considered. Kew Gardens, Gunnersbury Park, Strand on the Green, Kew Bridge are just a few of the heritage assets that will be adversely affected.

Paragraph 154 states that new development should be “plan led” with the Local Plan offering clear guidance. The Local Plan for Hounslow was only adopted a few months ago, and there is a clear prescription against high rise buildings.

This development also infringes key elements of the London Plan of March 2015.

The level of habitation is too dense – for instance para 3.30 notes that where public transport is limited, densities should be lower. It infringes the requirement for children’s play space (“ensure that all children and young people have safe access to good quality, well designed, secure and stimulating play and informal recreation provision, incorporating trees and greenery wherever possible”, Policy 3.6). According to Policy 3.16 “Boroughs should ensure that adequate social infrastructure provision is made to support new developments” – not only is there no consideration, eg for enough schools for these new residents, but eventual schools risk having to be built on open space (thereby contravening policy 7.17). We have already seen this narrowly averted with the recently defeated proposals to build a new school on Brentford Rec. No schools, no open space in this development.

Policy 7.4 of the London Plan, part A requires that “Development should have regard to the form, function, and structure of an area, place or street and the scale, mass and orientation of surrounding buildings. It should improve an area’s visual or physical connection with natural features.” It would be ludicrous to suggest that this was the case with the Chiswick Curve.

7.4, part B c states that development “is human in scale, ensuring buildings create a positive relationship with street level activity and people feel comfortable with their surroundings.” Any attempt to claim that a building of 32 storeys that bulges out from its tiny footprint to lean over a surrounding roundabout and dual carriageway, while shining out large adverts for miles around, would be ludicrous. Claims by the developer that the public realm at ground level will be enhanced should be treated with great scepticism. The footprint of what will be left after the 3-fold towers are built on this small site is negligible, so there is very little public realm left; what little there will be is virtually under the motorway, at the foot of these huge towers, and isolated on a tiny island with two-lane traffic all around.

Policy 7.7 states that tall buildings should “generally be limited to sites . . . . that have good access to public transport, only be considered in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building, have ground floor activities that provide a positive relationship to the surrounding streets, incorporate publicly accessible areas on the upper floors where appropriate, should not affect their surroundings adversely in terms of microclimate, wind turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference,  should not affect their surroundings adversely in terms of microclimate, wind turbulence, overshadowing, noise, reflected glare, aviation, navigation and telecommunication interference, and should not impact on local or strategic views adversely.” It is hard to see where the Chiswick Curve would not impact on nearly all of these. For instance it will overshadow the entire area around it, it will give off great reflected glare not only from its own glass surfaces but also from its huge advertising screens, it will impact on local views over Gunnersbury and the river, let alone from Chiswick and Brentford.

Policy 7.10 requires that “Development should not cause adverse impacts on World Heritage Sites or their settings”. Kew Gardens will be adversely impacted.

Policy 7.14 requires that “Development proposals should minimise increased exposure to existing poor air quality”. All residents and workers at the Chiswick Curve will experience increased exposure – not only by living or working there, and certainly by trying to arrive or leave from the site. Surrounding areas will be affected by the increased traffic and congestion caused by this development at what is already a very congested junction.

Historic England has also recently (December 2015) issued guidance on tall buildings which should be taken into consideration. “Tall buildings can significantly affect the image, character and identity of towns… One of the principal failings in the design of certain tall buildings was a lack of understanding of the nature of the area around them.” They ”can also seriously harm the qualities that people value about a place.”

There are no similar tall buildings in the area – the Chiswick Curve would be some 20 storeys higher than anything in the area.

Conclusion

The Chiswick Curve development infringes many aspects of the National Policy Planning Framework, the London Plan and Historic England’s Tall Building Advice and should therefore be rejected.

The challenge brought by local resident Simon Kverndal QC against the Lend Lease development of Empire House and Essex place was adjourned until September in the High Court today.

Local residents donated a total of £20,035 towards legal fees for the case. Following a short hearing, the judge decided that as it was a complex case involving “substantive planning issues” it needed more than the time allocated.

The next hearing will be in September 2015.

Mr Kverndal and his supporters were seeking permission for a judicial review of Hounslow Council’s granting of planning permission to the development. The claim is that the decision was unlawful because of the failure of Officers to properly consult and their failure to take into account and apply important local planning policies.

The development consists of 72 residential units, including affordable homes, in Essex Place and Acton Lane. The Empire House tower block is currently being refurbished from office to residential, on sale as The Opus Collection, with new retail frontage of seven units planned below.

The Judicial Review application being taken by Simon Kverndal QC, is supported by local lawyers and four residents’ groups, challenging the legality of the planning decision.

The residents groups supporting the challenge include all four neighbouring groups: Friends of Turnham Green, Chiswick High Road Action Group, West Chiswick and Gunnersbury Society and Acton Green Residents’ Association.

The challenge is based on the following:

– Height of buildings – Local policies are against tall buildings in this area and there is a long standing aspiration to get rid of Empire House.

– Employment – The local plan site designation for this site provided for mainly continued employment uses such as offices or hotel space.

– Heritage – The proposed development will cause irreparable harm to the Turnham Green Conservation area.

– Housing – The development seeks to get round Hounslow’s policies on affordable housing by claiming the right to develop Empire House with no affordable housing contribution and the remainder of the site with only a fraction of the 41% affordable housing target. The result is just 11% affordable housing. All this is based on claims as to viability of the project based on calculations that have not been disclosed.

– Consultation – Officers recommended approval of this development despite strong opposition from the overwhelming majority of respondents to consultation. There were comprehensive objections from residents, residents’ groups and Sainsbury’s who own the adjoining superstore and car park together with British Land. These were ignored. In a final blow, the Council refused to allow time to examine and respond to a substantial amount of important documentation put in at the last minute, well after the consultation period was over.

Chiswick High Road Action Group will be part of a team representing the views of the vast majority of local residents and speaking up against the Empire House site development at Hounslow’s Planning Committee meeting tomorrow evening.

Four residents’ groups have published a joint statement in response to the Planning Officer’s Report (full text below).

Members of the public are welcome to attend the meeting.

• The meeting is due to take place in Committee Rooms 1 & 2, Civic Centre,
  Lampton Road, Hounslow on Thursday, 29 January 2015 at 7:30pm
• Download meeting agenda here
• Download Hounslow’s report pack here
• Download the 4 residents’ groups Joint Statement (full text below)
• Download the 4 residents’ groups planning objections here:
  • AGRA Objection
  • CHRAG Objection
  • FoTG Objection
  • WCGS Objection

Joint Statement from the following resident and amenity groups

Acton Green Residents Association (AGRA)
Chiswick High Road Action Group (CHRAG)
Friends of Turnham Green (FOTG)
West Chiswick and Gunnersbury Society (WCGS)

1. Having studied the Planning Officer’s Report and taking note of Council Leader, Steve Curran’s, recent statement that “The Council is committed to preserving our rich heritage” (in relation to establishing a new Conservation Area in Chiswick) the above Groups jointly request that the Committee refuse the application for this development.

2. It is widely accepted that Empire House is out of place in this location – it is a towering and oppressive presence – an unwelcome intrusion on the heritage surroundings of Chiswick Town Centre. We had high hopes that any development in this locality would seek to lessen this building’s negative impact in accordance with the borough’s planning policy (both existing UDP and the emerging Local Plan).

3. Never did we imagine that anything could be worse than the existing building. However, in contrast to the conclusion reached in the Planning Officer’s Report, we strongly believe that, overall, the proposed scheme would do more harm than good.

• The reclad Empire House itself will be even more prominent and “in your face” with its protruding balconies, white stone cladding, increased height and massive, atrium-style entrance.
• The new build on the Essex Place and Acton Lane sites would compound the harm to the surroundings.
  • The Essex Place 7-8 storey buildings would be visible from all directions and would rise obtrusively above and behind the shops on the Chiswick High Road, damaging the otherwise harmonious skyline by adding asymmetrically to the “intrusion” of Empire House itself – adding insult to injury.
  • The Acton Lane site is at an important and prominent location between the High Road and Chiswick Park Station – a gateway to the borough from the neighbouring borough of Ealing. The proposed building is higher than nearby buildings, cramped on its plot, providing no communal amenity space, very limited opportunity for landscaping and no positive contribution to the public realm.

4. The proposals for public realm improvements to Essex Place are presented as representing a major public benefit of the scheme. We believe that the amount of development proposed undermines the scheme’s ability to achieve any real benefits. Essex Place is a narrow and cramped cul-de-sac and must continue to provide essential access to Sainsbury’s shoppers’ car park and delivery yard and the rear service areas of businesses on the CHR and Acton Lane. This traffic will be augmented by that associated with the new development (access to parking, drop-offs, deliveries and servicing).

5. Section 5 of the Report fails to indicate the nature and depth of the objections to the scheme. The 163 objections received (5.2) included detailed, reasoned comments submitted by the four resident/amenity groups named above. The Report refers to a “petition” against the proposal (no figure given); we are not aware of such a petition but CHRAG summarised the 450 results it received to its on-line survey within the comments it submitted. The summary of comments given in the table (5.3) is so abbreviated that we fear that Members of the Planning Committee will be unable to appreciate the significance and weight of these objections.

6. The following comments focus on the Planning Issues discussed in Section 7 of the Report.

7. Chiswick Town Centre: Justification for residential use The emerging Local Plan forecasts for housing (7.5) are for the whole of Chiswick, not just for the town centre. Unlike other town centres in the borough, Chiswick already has a good amount of residential; provision of significantly more is likely to upset the healthy balance of retail/commercial and residential uses rather than “enhance the vitality and viability” (7.9). As recognised in the Report Chiswick is already successful (7.12) and meets the Mayoral SPG aspiration of “a high quality, inclusive and liveable place” (7.10). The proposed development of the three linked sites squanders the opportunity to make significant improvements to the townscape (7.13). The proposed scheme is highly unsympathetic.

8. Even if the developer’s arguments for loss of office use held weight, despite the high demand in Chiswick indicated in the Report (7.18- 7.19), this does not mean that it is necessary to depart entirely from the employment use designated in the site allocation of the emerging Local Plan.

9. We question what evidence there is that the impact of office provision in the Chiswick Business Park is to lower the demand for this town centre location. Furthermore in light of the successful conversion of office space to the Moran Hotel (7.20) and of the absence of any information concerning the viability of hotel use, we question how the Report can conclude (7.31) that the case is made to deviate from the proposed site allocation, which includes hotel.

10. The developer’s prior approval (7.26) for conversion of Empire House to residential use (62 flats) deserves little, if any, weight in the context of the current application. Since no external alteration is permitted for such a PA conversion, it is an unattractive proposition, especially given the state of the external facades described in the developer’s Marketing Report recently published for the application:

“The facades are dated and degrading. Wintech Façade Engineering Consultancy … concluded that ‘given the current condition it should be considered for replacement, in its entirety, to produce a more efficient and modern façade.’ From a re-letting perspective the current dated appearance is going to be a negative factor for any prospective tenant.”

Note also that other former office buildings on the Chiswick High Road (7.20) are not in the Town Centre and other than the Moran Hotel (see above) are not conversions. 500 Chiswick High Road is to be demolished and replaced with a mixed-use residential and office development.

11. Lapsed permission for 12 residential units in a 3- to 4-storey building on the Acton Lane site (7.65) does not justify the proposal for 21 units in a 5-storey building. The height and density of the new 6- to 8- storey residential block on Essex Place (7.66) is quite unsuitable for this highly compromised site. The 8-storey element would tower uncomfortably above the adjacent 3-storey town houses, the “family dwellings” beside the Sainsbury delivery yard, whose only private amenity space will be their rooftop gardens.

12. Design and Impact on the Area; Residential The Report provides a synopsis of the planning policies relevant to this aspect (7.39 – 7.56). Paragraph 7.57 then asks the question “do the alterations and additions to it [Empire House], as well as the other associated buildings of the scheme preserve or enhance the conservation area and meet the design quality espoused in the NPPF.” We strongly contest the assessment in the Report (7.57- 7.66) which maintains that they do.

13. We believe that the scheme is not in accordance with policies in the NPPF, London Plan and the UDP and emerging Local Plan. It fails to respond appropriately to the “identity of a place/sense of place” (7.42 and 7.45) or to reinforce local distinctiveness (7.43), local character (7.44). We believe that the Spatial Strategy for Chiswick and the Context and Character policies (CC 1 – 4) of the emerging Local Plan should be given great weight, especially CC3 and CC4.

14. Empire House is within the Turnham Green Conservation Area and the other two sites are adjoining (7.46- 7.56); to the north is the Acton Green Conservation Area. Chiswick High Road is long and the heights of buildings along the high road further west towards Gunnersbury station (approx 700 metres away) and of those in the Chiswick Business Park are not relevant (7.55) to this application within the Town Centre/Turnham Green Conservation Area. The buildings in the borough of Ealing to which reference is made have no impact on the streetscape of the Chiswick High Road or the area to the north of the High Road. Since Hounslow Council objected strongly to the height of Chiswick Point (off Bollo Lane), it hardly represents a character which Hounslow should seek to extend.

15. As stated above (point 3) we believe that, as now proposed, this scheme neither adequately respects nor appropriately responds to the established character of the area, especially the Turnham Green Conservation Area in which it stands.

• How can adding height to a 1960s building acknowledged to be far too tall for its location (an 11-storey intrusion in a high street of 3- to 4-storey, mixed use buildings) be considered acceptable? Any changes to Empire House should make it less dominating not more. We strongly dispute the contention that the proposed design for Empire House has taken cues from the former Empire Theatre that stood on this site (7.59); as shown in the photo in the Report, the theatre was a distinctive, 4-storey building topped by a cupola and with a central arched feature above the entrance.

• If balconies are necessary (7.61) to mitigate for the serious lack of amenity space throughout the scheme, they should be provided within the envelope of the building in order to avoid adding bulk to this building.

• Essex Place and Acton Lane  (see point 3 above).

16. The proposals for Public realm improvements to Essex Place are presented as representing a major public benefit of the scheme. The service vehicle access will continue to be via Essex Place (7.70) and will additionally include that for the 116 residential units in Empire House and Essex Place. The concept of introducing “shared space” in this confined cul-de-sac (7.69) is seriously flawed. The attractive scenes shown in the artist’s impressions give an entirely false sense of space and safety; they omit any traffic (in transit or parked). Furthermore the enhanced public realm proposals only relate to the section of Essex Place between Sainsbury’s delivery entrance and the eastern end of the development. Omitting the key western section from the junction with Acton Lane – the entrance to Essex Place – will seriously undermine any scheme.

17. The serious under-provision of private and communal amenity and children’s play space (7.81 – 7.84) is a major negative aspect of the scheme. The report suggests that these shortfalls are acceptable because of the proximity of Gunnersbury Nature Reserve, Turnham Green and Acton Green and Chiswick Common. The residential density of central Chiswick is such that there is already considerable pressure on these open spaces – pressure which cannot be relieved by a financial contribution. The Gunnersbury Triangle is a small and vulnerable nature reserve not a playground.

There is a play ground on Acton Green in LB Ealing but the town-centre open space of Turnham Green serves other functions. While these include informal play and sports, there is no formal play equipment.

18. 18. We note with concern (1) the low number of 16 Affordable Housing units (7.89) to be provided at Acton Lane site – only 22% even after discounting the PD units in Empire House (target 41%) and (2) the absence of any social rent properties (target 60% of Affordable).

19. In conclusion, we consider that the scheme, as currently proposed, will have a significant negative impact on the townscape and street-scene and/or harm the open space of Turnham Green and will offer very little in terms of real public benefit. We therefore request the Committee to refuse the application.

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.

Chiswick High Road Action Group carried out a survey to discover the true reactions of local residents to the proposed redevelopment of Empire House, Acton Lane, and Essex Place after developer Lend Lease claimed that their “consultation” had shown overwhelming support for their development. For more information about this development click here.

CHRAG received over 450 responses between 6th October and 6th November 2014 and the results are presented below.

Summary of findings

• 83% believe that this development should either be permitted only with improved amenities or should be rejected outright
• 86% wish the height of Empire House tower to be lower or remain the same height. Only 14% welcome an increase in height.
• 83% believe Empire House should have recessed balconies or none at all
• 56% believe that Essex Place should be developed, but only into mixed-use / residential buildings of 3-4 storeys, whilst 30% would prefer this area to be used only as public amenity space. Only 14% support the Lend Lease proposal for two 7 and 8 storey blocks
• An overwhelming 94% think the amount of affordable housing should be made public
• Although 27% agree that more housing is needed in Chiswick, 67% are not happy with this particular scheme

Comments received

“Affordable housing should be included throughout the scheme, not simply in one area of the proposed development. The decision to re clad the 1960s tower block monstrosity was wise. The proposed design is not.”

“Not in keeping with context of Chiswick. Poor design quality. I welcome good development, but […] this scheme looks particularly unsympathetic, crude in design and looks to aim only for maximum return for developer with minimum investment for the development’s locality”

“Totally contrary to Conservation Area principles”

“Empire House is already out of keeping with the High Road therefore increasing the height is unacceptable”

“The current proposal lacks creativity and is a mere attempt to stack high as much profit as possible without a care for the community.”

“Key point is height – I do not want the village atmosphere around Turnham Green and Chiswick generally to be compromised by tall tower blocks. This plan for this proposed development need to have the height of its buildings dramatically reduced and its proportion made to match and harmonise with surrounding structures and architectural proportions.”

“Turnham Green is a beautiful open space in an area of high density population and developments like this would threaten the integrity of this space for future generations”

“The nearest of the proposed adjacent buildings so artistically shrouded by trees is too high. The appearance of the shop fronts too uniform. The charm of the High Road is its diversity”

“proposed buildings too high, Chiswick is not a high rise area – three floors high max, not enough parking for more cars and public transport struggling to cope as it is”

“Happy for the development, but its not in keeping with the rest of the area. Lower height would be preferred […] and therefore am not happy with the scheme as it currently stands”

“I think the increase in massing of the development is inappropriate in this location.”

“Any new development in Chiswick should be in style with the existing architecture and mistakes from the 60s should not be perpetuated and repeated.”

“This area would be ideal for mixed-use, including affordable housing (affordable sensu stricto). This would be best achieved by rejecting this development, taking down Empire House (already an eyesore), or at least lowering it to the level of already extant buildings, so that a new development (not necessarily by this contractor) would fit harmoniously with its surroundings. The current proposal is an eyesore.”

“Absolutely need planning for affordable homes, for investment in public space. Heights should not be increased”

“Chiswick is not a high rise town and the plans are not in keeping with the area”

“Strongly object to new blocks above 3 or 4 storey, to any increase in height of existing tower (which should not have been allowed in first place) and to any external balconies in existing tower. Do want to see shops at base redeveloped and would not mind considerate conversion of office block to residential to support this though would want that block vastly reduced in height.”

“These proposals are, to me, yet another encroachment on the character of London. Victorian buildings are now being destroyed apace in the centre, to be replaced by tower blocks that could be anywhere on the planet […] These latest proposals simply enshrine that original bad decision and make it worse by adding yet more out-of-place blocks. The proposals are simply an extension to the suburbs of the over-development of London with second-rate buildings already apparent elsewhere. It is very easy to change the character of places like Chiswick for the worse, but it can never be changed back. So, yes to more human-scale affordable housing in keeping with Chiswick’s character; no to more tower blocks.”

“No high rise please. All development should be kept aligned to the rest of Chiswick”

“The existing tower is totally out of character with the rest of the street scene and should never have been approved. Making it even more intrusive would be a travesty. Two wrongs do not make a right.”

“Happy for existing tower block to be converted from office space into residential but do NOT want the height or width increased. Do not want the new residential buildings to be any taller than the existing tower block. There should be added medical, school, and affordable housing included in the scene”

Sample data

Responses received over 1 month

What do locals want for Essex Place?

11th October 2014

Do you know about the proposed new 13 storey tower block development overlooking Turnham Green?

New apartments – adding two penthouse storeys atop existing tower

7 and 8 storey blocks overlooking Turnham Green – rest of Chiswick High Road is 3 to 4 storeys

Corner of Acton Lane near Chiswick Park Tube

CHRAG is currently working on its formal response to the Empire House / Essex Place development, which includes 137 new dwellings in the centre of Chiswick, which it believes is overly intensive and lacking in adequate amenity space and facilities.

In the meantime, if you feel the same way as CHRAG (i.e. not impressed!) then you can do two things.

1. Take the survey to learn more and give your views:
   Take our 5 minute survey
2. More importantly, send your personal objection to the Council. Here’s how:Make an objection

If you want to do even more, CHRAG would love your help. See below for more information.

More information

• Deadline for objections to Hounslow Council: 25th October 2014

• To view the planning application submitted to Hounslow, click here, accept the Hounslow T&Cs then search for application with planning number 00248/408-430/P1.

• If you feel that dredging-through hundreds of pages of tedium to get the important facts (buried deep!) is too much, we don’t blame you. Take a look at the aspects that matter to us as local residents – click here

• To view marketing information about this development by Lend Lease, the Australian investment firm who are proposing the scheme, click here

What else can I do?

• We have leaflets – we need to get them out PLEASE help us distribute them. Get in touch. Email info@chiswickactiongroup.org.uk

• To download a leaflet click here

• Copy / paste this web link and send to your contacts – it’s our survey! https://www.surveymonkey.com/s/PBQWFBN

• Speak to other locals, shopkeepers, etc. and rally the troops. You can always give them a link to this website to find out more: www.chiswickactiongroup.org.uk

• Ask your friends to sign-up to our mailing list. We will be emailing again with details of our objection, and a further prompt to make your own. Please bandy this link around to your contacts too: http://www.chiswickactiongroup.org.uk/get-involved/

June 2014

Rather than writing a formal response at this stage, CHRAG would like to express a series of “likes and dislikes” about the plans shown in Lend Lease’s public consultation which took place this week:

Below are minutes from CHRAG’s meeting with Lend Lease about the current plans for Empire House, Chiswick High Road.

Thanks to Paul Dimoldenberg for putting these together.

Minutes

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.