Ealing Council, like all other councils, has to produce a local plan. The plan lays out how the Council would like to see the borough developing over the next 15 years. This plan is now at the very last stage before it goes for approval, or not, by a government inspector.
West Ealing Neighbours, along with many other local residents groups and umbrella organisations in the borough, is working on its response to the plan. Putting together a response is quite a daubnting task. The plan itself is over 500 pages long plus supporting information on top.
The deadline to respond is 6pm on 10th April. As we complete our response we will put our documents up on our website for you to read. You are welcome to take any elements of our responses to use in your own. The first three of these documents are at the bottom of this page. They cover planned tall builsings in central West Ealing, no plans for a publically accessible police station and serious questions over the supply of electricity to the planned developments.
As a starting point, here is the link to the local plan on the Council’s website.
There is also an interesting article on the Ealing Today website about Friends of the Earth’s view that needing to build 43,000 new homes to accommodate the planned growth in population mean that it is impossible for the Council to meet its target Net Zero target.
Chapter 4 is the most relevant section of the plan to look at as it includes the information about the development plans for the 43,000 new homes across the ‘seven towns’ of Ealing borough. West Ealing is included in the Ealing Town Plan and Development Sites. Below are some initial thoughts and comments on this section:
Chapter 4 general points
20-minute neighbourhoods, to the detriment of “place making”
4.2.17 says “Across Ealing town its smaller centres and local parades (i.e. Northfields, The Avenue and Pitshanger Lane) are not meeting their full potential. These smaller centres are often comprised of single storey buildings that provide opportunity for mix-use intensification of retail, commercial, and residential uses that would support Ealing’s priority to reimagine local centres as a network of 20-minute neighbourhoods.”
They seem to assume that single-storey buildings are incompatible with 20-minute neighbourhoods. In fact most of us can easily get to almost everything we need on a typical day with less than ten minutes of walking – and so can most other West Ealing residents. We don’t need taller buildings in order to have a 20-minute neighbourhood.
Many key businesses on Northfield Avenue have a second storey above them providing income that makes the property sustainable. These two-storey buildings are part of, or harmonise with, the Victorian feel which makes this area so attractive that the council proposes declaring it a Conservation Area.
Thus why do we have “new community infrastructure that would encourage these areas to act as social hubs”. They are social hubs already, and partly because of their low-rise charm.
In 4.2.49 (page 167) there are sweet words about “low rise premises in South Ealing and Northfields centres which offer a particular opportunity for sensitive intensification above existing commercial premises”. But what is their idea of “low rise”?
Electricity supply
4.2.29 includes Table E1 which predicts improvements to the electricity supply at a date “TBC”. This doesn’t give much confidence about the proposed near-term intensification of housing and high-tech businesses. It conflicts with 4.2.56 which says “infrastructure is expected to be delivered in earlier phases of development”.
Police station
Table E1 also says the Police station will be refurbished at a date “TBC”. Having said that central Ealing is the thriving hub of the borough, the plan seems not to care that this thriving hub has no police station that anyone can use.
West Ealing station area
Policy E2 on page 160 makes it clear that growth around West Ealing station is to be “optimised” to bring more people into the borough. Why should this be the aim, since they’re already saying we have too many people looking for housing here?
Ealing Character Study
4.2.56 says that all development proposals “must respond to relevant contextual design guidance provided in Part 2 of the Ealing Character Study”. Part 2 can be found here:
https://www.ealing.gov.uk/download/downloads/id/17176/part_2_-_typologies_and_scope_for_growth.pdf
It has 118 pages. One interesting statement, on page 14, says “retained historic fabric [of buildings] provides a human scale and fine grain of unit size”. This was written specifically about town centres like Ealing and West Ealing. So this is useful for seeking to avoid the destruction of historic building scales.
Further information for our future use: on page 17 regarding neighbourhood centres, “create a consistent datum and roofline in plots where buildings are lower, such as Northfields single storey buildings”. In other words, don’t put tall buildings there.
On page 49 it says “height should not be a precursor for the location of other tall buildings; careful consideration of clusters, the sensitivity of context and setting needs to be considered”. In other words, the presence of one skyscraper doesn’t justify another.
Overall, the recommendations of this study form a recipe for sensitive development, and we may want to refer to it when proposals are put forward.
Housing Design Guidance
4.2.56 says that “development proposals must comply with latest design guidance provided by … the council’s Housing Design Guidance” which can be found here:
https://www.ealing.gov.uk/download/downloads/id/17171/housing_design_guidance_november_2022.pdf
This includes design guidance for tall buildings. It does say (page 10) that the surrounding area and heritage must be considered:
Consider the local architecture and building typologies and the local pattern of built form. How can new development respond to this in terms of building line, scale and massing?
Submision 1 – Sainsbury’s site and other tall buildings planned for central West Ealing
3. To which part of the Local Plan does this representation relate?
Paragraph: Chapter 4, pages 192-193
Policy: E2 Ealing Metropolitan Town Centre, paragraph G.
Policies Map: Site 11EA (Sainsbury’s and Library, West Ealing)
4. Do you consider the Local Plan is: (please tick)
4.(1) Legally compliant
4.(2) Sound NO
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.
Chapter 4 says on page 192 “design analysis indicates a maximum height of 16 storeys”. But I see no design analysis in the Local Plan or its supporting documents which would support that assertion. On the contrary, the “Tall buildings strategy, main report” gives guidance for West Ealing overall on page 28, with prospective tall building heights being 7-13 storeys.
The “Tall buildings strategy appendix – Guidance for study sites” includes on page 49 a map more specific to this site’s area, clearly showing that no building taller than 13 storeys is desirable.
In addition, a maximum height of 13 storeys for this site was proposed at the Regulation 18 stage of consultation. I have found no explanation for the increase between stages 18 and 19.
If the council’s aim was to add a certain number of new homes in the area, the new increase to this site’s target height was not necessary, because sites 12EA and 14EA will inevitably produce significantly more homes than envisioned for them in the Local Plan. (See further Part B representations below.) The sum of new homes across sites 11EA, 12EA and 14EA will be enough to meet the council’s aims even when the 11EA target is reduced back to 13 storeys where it stood at Regulation 18.
If I may refer again to the “Tall buildings strategy, main report”, it says on page 6: Examples of inappropriately tall buildings include developments that … exceed the upper limit of the guidance set out for an appropriate location for tall buildings. The proposed 16-storey replacement for West Ealing Sainsbury’s would thus be inappropriately tall, by the council’s own definition.
NPPF paragraph 31 says the preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned.
Ealing’s Local Plan does not conform to the NPPF, because no relevant evidence has been shown for increasing the height of site 11EA beyond 13 storeys.
6. Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.
Chapter 4, pages 192-193 should be changed to set a maximum height of 13 storeys. Any other references to the height of 11EA should be changed accordingly.
I would also suggest that the Design Principles on page 193 state that car parking will be required for the supermarket and community facilities.
7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?
| No, I do not wish to participate in hearing session(s) | X | Yes, I wish to participate in hearing session(s) |
8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:
Very few people feel that they have understood the 516-page Local Plan and all its related documents. The Council has in effect stifled objections by structuring the plan in this unnecessarily cumbersome way. Therefore those few of us who have spent hours reading the plan must be prepared to speak on behalf of our neighbours.
Part B (Please use a separate sheet for each representation).
3. To which part of the Local Plan does this representation relate?
Paragraph: Chapter 4, pages 194-195
Policy: E2 Ealing Metropolitan Town Centre, paragraph G.
Policies Map: Site 12EA (Chignell Place, West Ealing)
4. Do you consider the Local Plan is: (please tick)
4.(1) Legally compliant
4.(2) Sound NO
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.
The plan for site 12EA is not deliverable, since Ealing Council has already approved application 215125FUL for an 8-storey development on this site.
The draft Local Plan calls for a maximum of 4 storeys, and specifically states that the site “is not in principle suitable for a tall building”. But these words and these aims have no meaning, following the council’s approval of the 8-storey development.
6. Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.
The appearance of site 12EA in the Local Plan is misleading, because the council has already given away control, and it is now undeliverable. I leave it to the Inspector to decide whether there is sufficient merit to keep it in the Local Plan at all.
7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?
| No, I do not wish to participate in hearing session(s) | X | Yes, I wish to participate in hearing session(s) |
8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:
Very few people feel that they have understood the 516-page Local Plan and all its related documents. The Council has in effect stifled objections by structuring the plan in this unnecessarily cumbersome way. Therefore those few of us who have spent hours reading the plan must be prepared to speak on behalf of our neighbours.
Part B (Please use a separate sheet for each representation).
3. To which part of the Local Plan does this representation relate?
Paragraph: Chapter 4, pages 198-199
Policy: E2 Ealing Metropolitan Town Centre, paragraph G.
Policies Map: Site 14EA (Western Gateway, West Ealing)
4. Do you consider the Local Plan is: (please tick)
4.(1) Legally compliant
4.(2) Sound NO
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.
The plan for site 14EA is not deliverable, since Ealing Council has already approved application 225080FUL for a 9-storey development on this site.
The draft Local Plan calls for a maximum of 6 storeys. But this has no meaning, following the council’s approval of the 9-storey development.
It seems likely that the council will also approve application 235015FUL making the 9-storey building wider.
6. Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.
The appearance of site 14EA in the Local Plan is misleading, because the council has already given away control, and it is now undeliverable. I leave it to the Inspector to decide whether there is sufficient merit to keep it in the Local Plan at all.
Submission 2 – lack of infrastructure to support planned new homes including no new police station open to the public
3. To which part of the Local Plan does this representation relate?
Paragraph: Chapter 4, pages 154-155, 159, 169, IDP Part Two section 3.9
Policy: E1 Ealing Spatial Strategy, paragraph P
Policies Map: Site 06EA (49-69 Uxbridge Road, pages 182-183 of Chapter 4)
4. Do you consider the Local Plan is: (please tick)
4.(1) Legally compliant
4.(2) Sound NO
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.
The Local Plan is not consistent with national policy.
I quote from the NPPF:
(paragraph 8a) an overarching economic objective is coordinating the provision of infrastructure
(paragraph 11a) all plans should promote a sustainable pattern of development that seeks to … align growth and infrastructure
(paragraph 86c) planning policies should seek to address potential barriers to investment, such as inadequate infrastructure
An item of infrastructure that every large community needs is a police station where the public can go to seek help or, for example, to leave goods which appear to have been stolen. Central/West Ealing, a town of 91,149 people, has been without such a police station for several years.
The Local Plan does not address this in a timely way. In Chapter 4 page 159, Table E1, the refurbishment of Ealing Police Station has a target date “TBC”. The table at the end of the Infrastructure Delivery Plan, Part Two also says “TBC”. Chapter 4 site selection 06EA sets a target for completion of 2038.
This is not soon enough. New housing developments adding tens of thousands more people should not go forward until there is water, electricity, transport … and a fully functional police station.
The Infrastructure Delivery Plan, Part Two: Infrastructure Delivery Schedule, page 20 does not give one further hope: In terms of planned service provision, the Metropolitan Police Service identified the ‘Strongest Ever Neighbourhood Policing’ initiative, which would see investment by the Metropolitan Police in more local police officers and police community support officers (PCSOs) in the neighbourhood. There is nothing concrete in this statement. It is not a plan nor a schedule. It’s what is commonly called “waffle”.
6. Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.
The 06EA site plan on pages 182-183 should be changed to specify a timeframe for delivery within 5 years. Corresponding changes should be made to Table E1 on page 159 and to the table at the end of the Infrastructure Delivery Plan, Part Two. The 06EA site plan should make it clear that the new police station will have a public-facing desk, open all hours every day.
The Inspector may wish to review other site allocations to ensure that housing builds do not outrace infrastructure preparations.
7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?
| No, I do not wish to participate in hearing session(s) | X | Yes, I wish to participate in hearing session(s) |
8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:
Very few people feel that they have understood the 516-page Local Plan and all its related documents. The Council has in effect stifled objections by structuring the plan in this unnecessarily cumbersome way. Therefore those few of us who have spent hours reading the plan must be prepared to speak on behalf of our neighbours.
Submission 3 – significant questions over electricity newtwork capacity for planned new homes
3. To which part of the Local Plan does this representation relate?
Paragraph: Infrastructure Delivery Plan, Part Two: Infrastructure Delivery Schedule
Policy: E1 Ealing Spatial Strategy, paragraph P
Policies Map:
4. Do you consider the Local Plan is: (please tick)
4.(1) Legally compliant
4.(2) Sound NO
5. Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.
The Local Plan is not consistent with national policy.
I quote from the NPPF:
(paragraph 8a) an overarching economic objective is coordinating the provision of infrastructure
(paragraph 11a) all plans should promote a sustainable pattern of development that seeks to … align growth and infrastructure
(paragraph 86c) planning policies should seek to address potential barriers to investment, such as inadequate infrastructure
The electricity supply in the West Ealing area is already overburdened. There have been power cuts – such as that of 19 January 2024 caused by a major fire at the ageing Dean Gardens substation in early 2024. This substation is just one of many ageing substations that need replacing.
The Local Plan does not address what is already a critical issue. Please consult the table at the end of the Infrastructure Delivery Plan, Part Two: Infrastructure Delivery Schedule. Near the beginning of this table are five “Electricity Supply” projects. All five are marked “Critical”. Four of them have a delivery period of “TBC”, including both of the projects earmarked for Ealing.
With the current situation liable to cause further outages and fires, and the impending creation of hundreds of new homes, it is simply not good planning to leave electricity supply projects for a date TBC. This is not a plan that conforms to the NPPF.
6. Please set out the modification(s) you consider necessary to make the Local Plan legally compliant and sound, in respect of any legal compliance or soundness matters you have identified at 5 above.
Establish target dates in the immediate future for all Electricity Supply projects in the IDP final table. Make corresponding changes to Chapter 4, Ealing Town Plan, Table E1, page 159.
Furthermore, the plan should include a statement, agreed between the council and the relevant electricity providers, guaranteeing that sufficient electrical supply will be available for all site allocations in the Ealing Town Plan.
7. If your representation is seeking a modification to the plan, do you consider it necessary to participate in examination hearing session(s)?
| No, I do not wish to participate in hearing session(s) | X | Yes, I wish to participate in hearing session(s) |
8. If you wish to participate in the hearing session(s), please outline why you consider this to be necessary:
Very few people feel that they have understood the 516-page Local Plan and all its related documents. The Council has in effect stifled objections by structuring the plan in this unnecessarily cumbersome way. Therefore those few of us who have spent hours reading the plan must be prepared to speak on behalf of our neighbours.