As explained in a previous post, the Planning Inspector dealing with the examination of the OPDC Draft Local Plan agreed to hold four further public hearing sessions on 11th and 12th January.

At a hearing on the 11th January 2022 OONF had some success in persuading the Inspector (Paul Clark) that OPDC need to be more upfront and specific about ‘suitable locations’ and ‘appropriate heights’ of tall buildings, in a final version of its ‘Post Submission Modified Draft Local Plan’.

We have been making the point for five years that the current draft refers frequently to ‘varying building heights’.  The document includes maps with large areas deemed as ‘appropriate’ for tall buildings.

On each of the three successive versions of the Draft Plan we have asked for more honesty from OPDC, in the form of the housing density figures assumed for each ‘site allocation’ and the likely implications for building heights.

In a Local Plan which sets site allocations with specific housing numbers, it is not rocket science to forecast the building typologies and heights likely to result, within a range.  These heights might be ‘mansion blocks’ of 10-14 storeys up to towers of 40 storeys and more, depending on how many housing units are to be fitted into the site.

OPDC planning officers have always remained very coy on this subject.  Vague answers have been given at public meetings.   We pointed out to the Planning Inspector that the maps and text in the ‘Place’ sections of the Draft Local Plan are similary vague.

Nowhere in the many hundred pages of Draft Local Plan documents is there any acknowledgement of a specific building height above 12 storeys.  Yet local people know very well that buildings of 20-30 storeys have been granted planning consent at ‘Oaklands Rise’ and along Scrubs Lane.  And that LB Ealing has approved towers of 50 storeys plus at North Acton, on applications ‘delegated’ by OPDC.

Now there is a new policy D9 on Tall Buildings included in the 2021 London Plan.  This applies to all new local plans being prepared by Boroughs, the OPDC and the London Legacy Development Corporation (LLDC).

At the hearing on January 11th, the Planning Inspector accepted our case that more honesty and transparency is needed in the final ‘modifications’ of the OPDC Local Plan.  He has told OPDC officers to come up with further amendments which will identify ‘suitable locations’ and ‘appropriate heights’ for tall buildings, in text and on maps.  These changes are needed  for the adopted Plan to ‘generally conform’ with the London Plan and to be deemed ‘sound’ in this respect.

We have yet to see how OPDC responds to this new requirement for more modifications to be made.  There has been silence on the subject from OPDC, since the conclusion of the public hearing.

Imperial College proposal for One Portal Way, North Acton

This application was submitted by Imperial in November 2021.  OPDC say it will not be put to the OPDC Planning Committee until mid 2022.  The ‘end date’ published by OPDC for responses to public consultation was 8th January, but OONF and GUA were given an extended deadline of 28th January.  OPDC are anyway legally required to take account of all representations up until the application is decided.

The OPDC Planning Committee considered an initial report on the proposals at it meeting on 20th January.  It appears that the Imperial team and their architects have made (or will be making) a presentation to the OPDC ‘Planning Advisory Panel’ anytime now.

We have asked about this ‘Advisory Panel’ and whether the public will be allowed to view or attend such a session.  If not, this seems a one-sided opportunity for a developer.

The proposed development involves 7 buildings.  Full planning consent is sought for the first two, including a 56 storey residential tower.  Outline consent is sought for a second phase, including two further buildings of up to 50 storeys.

OONF has submitted a detailed objection One Portal Way objection No.1  We will be submitting a further objection, including serious concerns on fire safety, in early February.

Our campaign website on this development is at  http://imperialfolly.org.uk/ and gives more background.   This includes a set of 12 reasons for objecting to the proposals, drawn up with our colleagues at Ealing Matters.  The CGI below is what the ‘North Acton Cluster will be like if this and other consented schemes are built.

We have been corresponding with Imperial College on why a university with a global reputation for work climate change should be pursuing a speculative development with buildings of 50 storeys plus.  This building typology is known to be both energy intensive and with high levels of embedded carbon at the construction stage.

The College claim that this massive project (which has nil academic or university related content) is an ‘investment’ by the College Endowment. See more at http://imperialfolly.org.uk/?page_id=25.

If you have not already submitted comments on the application, it would be great if you could send an email to planningapplications@opdc.london.gov.uk.  You need to give your name and address (which will be redacted when your representation is published online) plus the reference number 21/0181/OUTOPDC

Pocket Living application at Atlas Wharf, Old Oak Lane  

A less extreme example, but one with unwelcome building heights for residents of the Old Oak Conservation Area (island triangle/TITRA/railway cottages) is an application from developers Pocket Living.  This is for a scheme of 436 housing units at ‘Atlas Wharf’.  This is the site behind the Collective building and beside the Grand Union Canal, off Old Oak Lane.

The development involves three buildings ranging from 9 to 29 storeys. This application has a reference number 21/0214/FUMOPDC and a ‘publicity end date’ of 8th February.  OONF will be submitting an objection, on the basis that the OPDC Draft Local Plan is not yet adopted and this application is premature.

The site is not designated for housing in the 2012 Ealing Core Strategy.  The Draft OPDC Local Plan refers to building heights of generally, 6 to 8 storeys fronting the Grand Union Canal.   The CGI image below is from the Planning Statement submitted with the application.

OPDC may delay a decision on this application in the hope that their Draft Local Plan will be supported by the Inspector and can be adopted shortly.  But the examination of this draft plan is not yet over (see separate post).

If you feel that 29 storeys is not the same outcome as 6-8 storeys, comments on this application can be sent to planningapplications@opdc.london.gov.uk with your name and address and reference 21/0214/FUMOPDC.   The development offers housing units aimed at ‘mid-income’ renters and has plus points (if the ground floor spaces can be ‘activated’ with the type of users that Pocket Living hopes to attract).

This area of Atlas Road/Channel Gate is where we had hoped to extend the boundary of the Old Oak Neighbourhood Forum.  But our ‘designation application’ was refused by OPDC in November 2021.   Had we succeeded, we would have had a chance to negotiate with Pocket Living (and their co-applicants the current landowners) on a scheme with a lower density and more modest building heights.

Other parts of London are seeing good quality developments that the Forum would support.  The land values at Channel Gate/Atlas Road have in the past been at levels for industrial land, rather than residential so could have supported lower densities.

The gap between industrial and residential values will have narrowed since OPDC chose to allocate these sites (potentially) for 3,200 new homes.   But has the public gained any benefit from this change in planning designation?

These proposals are once again proving to be ‘developer led’ rather than ‘plan led’ as aspired to in the National Planning Policy Framework.  This is a repeat of the Scrubs Lane scenario in the east of the OPDC area.  So far this has not gone well from anyone’s perspective – developer or local community.  Developers overpaid for sites in the expectation of Cargiant’s ‘Old Oak Park’ scheme next door, for which plans were abandoned in 2018.

Planning Inspector Paul Clark originally decided that he did not need to hold further public hearings, as part of his ‘examination’ of OPDC’s Draft Local Plan.

The previous round of hearings ended in July 2019.  The Inspector subsequently issued in September 2019 his ‘interim findings’.  These rejected as unviable OPDC’s proposals for compulsory purchase of the 46 acres of  Cargiant land as the first major stage of regeneration at Old Oak.

We are now in 2022, and the examination continues.  The Draft Plan remains that submitted by OPDC in October 2018 – as ‘modified’ by a series of new site allocations and a shift to a new strategy for the ‘Western Lands’ in East and North Acton.

We have long argued that these changes to OPDC’s proposals are more than ‘modifications’.  They rely on a very different spatial solution for Old Oak.  We think this solution makes little sense as a new part of London.

We welcome the fact the Planning Inspector has proved willing to change his mind, and to agree to further examination hearings on 11th and 12th January.  These will be held online.  We will publicise the link as soon as we are given it.

The January 11th examination hearings will look at two important questions:

1. The session at 10 am on Tuesday 11th January will hear evidence on PTAL levels at Old Oak.  PTAL is the measure of levels of Public Transport Accessibility which have long been used in London to assess the suitability of locations for high density housing.

The nearer to good public transport (on a range of 0-6) the more appropriate a site for high density living.   We think that the final version of the OPDC Local Plan has gone backwards in this respect,as compared with the 2018 version.  Our draft evidence for this session as at this link OONF and StQW on PTAL for Jan 11th V4

2.  The session at 2pm on Tuesday 11th June will consider whether the final version of the OPDFC Local Plan ‘generally conforms’ with the 2021 Policy D9 in the London Plan.  This policy was varied and strengthened by the intervention of Secretary of State Robert Jenrick in December 2020.

We will be seeking to persuade the Inspector that the Local Plan has avoided specifying locations for tall buildings, and makes no mention of the likelihood of buildings over 12 storeys.  Given that OPDC are currently considering an application at North Acton with one building at 56 storeys and two more at ‘up to 50’ this reality on the ground does not square with the content of the Local Plan.  Our draft evidence on this point can be downloaded here StQW and OONF rep on D9.V4

Our OONF/GUA meeting on January 4th at 6.30pm will discuss and finalise these to submissions to the Planning Inspector.  Any comments welcome at oonforum@gmail.com