See here:
Planning application to Ealing Council: 195284FUL
For a 22 storey tower block between Stanley Road, Greenock Road and the South Acton allotments.

On 12th February 2020:
Objections: 441   Supporting: 5

Planned 22-storey block towering over Ravenswood Court's ten storeys
Extremely dramatic and adverse visual impact over a very large area of South Acton.

This, the developer's own graphic representation!
Tower block causing serious loss of sunlight to neighbours including allotments 



Ealing Council Planning 195284FUL comments

Planning application has been made to Ealing Council for a 22 storey tower block between Stanley Road W3, Greenock Road, W3 and the South Acton allotment site 

210 apartments, for rent only, inside an industrial estate, with no residential infrastructure. 

More than twice as high as the neighbouring apartment block, on a site of only 0.15 hectares. 

A massive building, vastly out of proportion with all surrounding structures, and an eyesore for residents in the area far and wide. Severe wind tunnel effect between buildings. 

Inadequate road access for construction and service vehicles. 

Construction work would create massive noise, dust, traffic and disturbance in the surrounding area. 

The tower block would over-shadow the award-winning South Acton allotment site, and seriously damage the productive potential of the plots. 

The developer is a private equity company, Henley Investments, which would sell the building when the flats are rented. This is NOT a Council development. 

See two sections below:

1. How to compose a letter of objection

2.Arguments against the proposal

1. How to compose a letter of objection

The key is to understand that, when members of the Planning Committee of Ealing Council consider a planning application, they assess how it conforms with a major Council objective (in this case to create new residential housing in Ealing), and with the policies and standards of the Council, and of London as a whole, on such things as proximity to other buildings, loss of light, loss of privacy and overlooking, conflict with local or London plans etc. The Henley Investments plan obviously meets the overall objective of Ealing Council, so the objections of local residents must focus on policies and standards, which are breached or ignored in development plan.

The most effective objections start with a short statement of the Council’s policy or standard on e.g. loss of light, followed by a statement of how this planning application fails to meet this policy or standard. Finding out what the relevant policies and standards are is a long and tedious job. Fortunately, our friend in Acton Gardens has done this hard work for us. The result is available in full through the link HERE, and is summarised in the next section.

The letter of objection can list every matter of any substance on which policies or standards exist, together with explanations of how and where the planning application fails to meet them. Photographs can be used in letters of objection, just as they are in the planning application.

Straightforward statements, that, for example, the building is too high, or transport links are poor, will have greater impact if they are backed up with detail about policies that are being breached, or standards that are not being met.

Remember finally, to give your name and address and email contact details when you start your response; and send your comments in before the deadline of Wednesday February 12th. Comments received after that date are likely to be ignored.

The Ealing Council system allows only 5000 characters to be used in each comment, but there is no prohibition on an individual sending in two separate comments. It is best if objectors express their views in their own language, but anyone is welcome to re-use facts and arguments provided in the next section.

2. Arguments against the development proposal

1. Sustainable Residential Quality (SRQ), or Over-development

The Mayor of London’s guideline on SRQ levels states:“The London Plan uses PTAL (Public Transport Access Level) as one of the key factors in determining the density of housing that is desired in different parts of London. This is based on the idea that areas with good public transport service are more suitable for intense development.” Further, Policy 3.4, in Optimising Housing Potential (Mayor of London) states: “…relevant density range shown in Table 3.2. Development Proposals which compromise this policy should be resisted.”

The eastern end of Stanley Road has a PTAL score of 1b (0 is the lowest and 6 the highest) because of its poor connectivity to town centre locations. The hectare that contains Ravenswood Court and Welbeck Court falls in the range of 2.7 to 3.0 habitable rooms/unit. Combined with the PTAL score of 1b, Table 3.2 quoted above shows that the immediate area should have a SRQ density of 50-95 units/hectare. The SRQ density of that area now is 54 units per hectare, derived from the two existing apartment blocks. The Henley building would fall within the same hectare and would raise the SRQ density to 264 units/hectare, or 178% above the recommended level.

Packing 210 flats into the tiny 0.15 hectares of the Henley building therefore constitutes gross over-development by the standards of the Mayor of London’s policy on optimising housing potential, and breaches that policy.

2. Local and District Park Deficiency

Ealing Council’s Development Strategy 2026 acknowledges that South Action is particularly short of public open spaces: “In quantity terms, as a proportion of public open space per head of population, Ealing Broadway and South Acton Wards are particularly deficient.”

The Henley building provides no public open spaces apart from two tiny roof gardens. It cannot contribute to Ealing and Acton Garden’s vision of a sustainable neighbourhood. Bringing even more residents into an already heavily populated area will increase pressure on the few public open spaces in South Acton, and have a detrimental effect on an area already lacking in open spaces.

3. Daylight, Sunlight and Acton Garden’s Design

Ealing and Acton PPL has adopted a strategy in relation to Acton Gardens that emphasises the need for transport, open spaces, amenities and well-built and well-lit housing. A key target is to disallow single aspect north facing developments. All one bed flats in the Henley building would be single aspect north facing units, in which living spaces would require constant lighting. This is in complete contradiction to Ealing’s existing and approved standard for Acton Garden.

Ealing’s Policy 7b “Design Amenity” in the draft Development Management document, stated that developers must ensure good levels of daylight and sunlight for residents. That has been achieved in the existing apartment blocks, which currently ensure adequate light and privacy.

The Henley building will severely impact single aspect one-bed flats in the existing Stanley Road blocks. The Vertical Sky Component (VSC) measure in some flats in Ravenswood Court will fall from c. 27% to almost zero, if the Henley building is constructed. This is a consequence of the height of the proposed building, its proximity to Ravenswood and Welbeck Court and the very small footprint of the Henley building, which means that it cannot be built at an angle or set back in any way. Loss of sunlight on neighbouring buildings is therefore another reason for rejecting the application.

4. Privacy, Proximity and Ventilation

Development policies and guidelines relating to loss of privacy require minimum distances of 18 to 21 metres between buildings. The proposed distance between the Henley building and Ravenswood and +Welbeck Courts is 16.6 metres. Henley claims that the gap will be 18m. Measurements from Google satellite maps indicate that this is wrong. One-bed flats in both existing blocks, would lose all privacy. The Henley building would have direct, unobstructed view into the whole bedroom of these flats from a distance below the recommended limit.

Heavy curtains or blinds would be necessary to maintain privacy by day and to cut out light pollution at night.

Ventilation in the Ravenswood and Welbeck apartments would also be severely impaired because they rely on the ability to open all windows facing onto Stanley Road in the summer months, without blinds or curtains in the way.

5. Height and Visual Impact

Henley states that the main block’s height of 22 storeys “… appears in keeping with the context and emerging urban grain of the area”. This is pretentious nonsense. The surrounding area consists of ten storey apartment blocks, two storey light industrial buildings and an award-winning allotment site at ground level.

The nearby 100 Bollo Lane building has only 13 storeys and is much further away from other residential buildings (about 40 metres, compared to less than 18m in the case of the Henley building).

The Henley building is completely out of scale and out of proportion with the Acton Garden estate, and contradicts Ealing’s strategy on the Acton Garden development, where building are smaller and lower as they get nearer to the Chiswick border to the East.

The visual impact of the Henley building will be far greater, especially in the area to the North and to the East of the Railway line, than is indicated in the planning application. The local views including the proposed building have been taken from angles that deliberately exclude the new building: by directing the camera away from the building, the impression is given that it cannot be seen.

The application document does admit that “the Scheme Proposal is considered, overall, to have an adverse effect on this representative view.” The visual impact from all houses along Weston Road and roads to the East will be very severe and intrusive, but no views have been shown from those locations.

The visual impact from the South Acton allotment site (which is scarcely mentioned anywhere in the planning application) will be extremely dramatic and adverse.

The building is claimed  to “improve the townscape situation of the view and overall it will have a neutral effect”. How a tower block improves the townscape is not explained. In the view from the Bollo Lane level crossing, it is claimed to “The Acton Gardens proposals can be glimpsed in the background of the view”. This is clearly misleading; the building would be seen very distinctly, rather than “glimpsed”. The analysis of the local visual impact in the Townscape and Visual Impact appraisal cynically understates the impact of the building, by choosing views that exclude the building, by showing views with trees in full leaf, rather than autumn or winter views, and by excluding views from residential houses or flats. Occupants of these homes will be exposed to the view of the building for much longer than pedestrians on roads or in parks.

6. Locally Significant Industrial Sites

Ealing’s ‘Development Strategy 2026’ document (p.15) describes the protection and management of Light Industrial Areas. The South Acton PPL Planning Report (2018) stated that “To the south-west is an industrial area designated as a Locally Significant Industrial Site”. Chapter 7 of the Mayor of London’s ‘Policy on Lifetime Neighbourhoods’ states that “the design of new buildings and the spaces they create should help reinforce or enhance the character, legibility, permeability, and accessibility of the neighbourhood”.

The proposed design directly conflicts with these policies. It will lead to the gradual erosion of the fabric of the area of which the Industrial Estate is a vital component. A high rise residential development will conflict with the objective of reinforcing and enhancing the South Acton Industrial Estate, a Locally Significant Industrial Site. Many of the businesses have stated that the development will lead to the end of their tenure at this location. If the Henley building proceeds, other will follow. The closure or migration of these businesses would be a major loss to local employment and to the fabric, make-up and socio-economic landscape pf the area.

7. Wind Tunnel Effect

Henley Investments has presented only an interim report on the wind conditions around the proposed building. The consultant responsible for report was instructed “to conduct a desk-based assessment of the proposed Stanley Road development”. It is clear from the consultant’s report that no investigations were carried out on the site.

There is already a very strong wind tunnel effect, at the end of Stanley Road, when the wind is from the west or north-west. This effect is particularly severe beside the entrance to Ravenswood Court and at the entrance to the allotment site. It is created by the existing buildings. It will be much worse if there is a second building on the other side of Stanley Road. The report takes no account of the situation of people working on the allotments or walking along Stanley Road to the entrances to Ravenswood and Welbeck Court. They are now often exposed to very strong winds, to the point when walking is very difficult and physical work is very uncomfortable.

The application document predicts “exceedances of the strong wind threshold to the north-west and south east of the Site which are to be quantified as part of further wind tunnel testing” and conditions at the end of Stanley Road that are “up to two categories windier than desired”.

The assessment of wind conditions is clearly inadequate, and the developer’s report itself speaks of the need for“further wind tunnel testing”. This must include numerous site visits, to check on conditions on windy days.

Further study is also required on the wind effects on the balconies of flats in Ravenswood and Welbeck Court facing onto Stanley Road. The current report considers the likely effect only on balconies on the proposed new building. Planning permission cannot be given while this issue remains outstanding.

8. Impact on allotments

The Henley building will cause a serious loss of sunlight on much of the South Acton West allotment site.  The BRE standard for sunlight on open spaces (two hours per day over half the site at the equinox) will be exceeded by the proposed building, but allotments need much more sunlight than that for cultivation of vegetables and fruit, especially during the growing season, from March to October, and during the midday and afternoon periods, when the sun is hottest.  Early morning sun and low level sun is not sufficient.

The building therefore conflicts with Ealing’s Adopted 2004 Plan for the Environment / DCLG Direction 2007. Ch. 3: section 3.6: "The Council is committed to safeguarding sites for allotments"; support for allotments was also a Labour Party manifesto commitment, presumably supported by Labour councillors on Ealing Council. 

The South Acton allotment site is in high demand and has been turning away applicants at the rate of two per week or more since May 2017, because the existing waiting list will take at least ten years to clear. The South Acton site was voted the best small allotment site in Ealing in September 2019. The allotment site is a valuable local amenity, owned by Ealing Council and rented to plotholders. It contributes to nature conservation, as well as to the local ecology, which will therefore be damaged.

To all local residents:

Please feel free to select anything that you wish from the above list, when making your objections to the planning application.