Friday 25 March 2022
You can watch the proceedings of this day on Hounslow Council’s YouTube channel https://www.youtube.com/c/LBHounslow
The second of the days of roundtable discussions started with a consideration of housing needs and mix. David Pavett, for OWGRA, argued that housing mix and needs were closely interrelated. He accepted that there were increased demands, and said that we agreed that the target for affordable homes had been met, however the Tesco/Homebase applications did not satisfy the well-documented need for larger family homes. He used LB Hounslow’s analysis showing that 57% and 43% of homes in the social and private sectors respectively should be 3-bed or larger.
OWGRA’s argument was based on four points:
LBH suffers from serious overcrowding,
LBH’s assessment showed that 50% of new homes should be 3+ bedrooms,
The Local Plan sets a strategic target for larger family homes of 30%,
Large scale developments need to comply with these targets.
Only 14% is proposed for Homebase and circa 19% for Tesco, resulting in a large shortfall.
Mr Smith, for LBH, said that the detailed requirements in the Local Plan should be regarded as a starting point for discussions to arrive at the final mix. There was a need for 3+ beds, but also other sizes, and there could be more 1-2 beds if the development was (1) in a town centre or (2) near to a station and good public transport!
The Inspector herself then referred to our concerns regarding poor public transport! Mr Smith replied that it was ‘either or’. David replied that neither condition was satisfied, and that the claims about a post COVID demand for smaller homes lacked any detail.
Mr Booth QC, for LBH, reiterated the argument that Local Plan policies were just a starting point for a discussion with developers. David said that its targets for homes were strategic and while not applying exactly to every development should do so overall and should certainly apply to very large developments such as Tesco/Homebase. He said that the claims of the applicant and LB Hounslow were a long way from meeting these targets.
Mr Roberts, for the applicant, said the housing mix of the proposed developments aimed at the ‘optimisation of the sites’. The QC, for the applicant, also spoke of ‘optimisation’. This blogger was left in no doubt as to what was being ‘optimised’ and for whom!
The subsequent sessions considered the impact of the developments under various headings.
Mr Roberts, for the developer, stated that the developments had been fully assessed against Building Research Establishment (BRE) standards and that despite some adverse effects the overall outcome was satisfactory bearing in mind the need to ‘optimise the sites’. A small number of adjacent properties would fall outside the minimum daylight reduction targets. Barbara Stryjak, for OWGRA, pointed out, as a lay person, that the number of properties in Northumberland Gardens, Syon Lane and Oaklands Avenue which would suffer moderate or major adverse effects was a cause of concern. She referred to a statement by an OWGRA member on the opening day of the inquiry. Mr Roberts insisted that there is good light for the majority, and that is just how BRE guidelines are implemented. Mr Warren QC, for the applicant, agreed and said that BRE is not the final test, but requires that experts come to a balanced judgement. Barbara responded that many residents will be affected, staring at a wall of tower blocks, and asked further detailed questions about individual properties. Mr Roberts argued that many problems resulted from existing conditions, such as overhang, etc.
Noise and Disturbance
Lis Guest, for OWGRA, spelt out the noise issues at Gillette Corner from traffic and planes. Residents either had to keep their windows closed or open them to noise and poor air quality. She expressed concern about noise and pollution during the proposed lengthy construction period. Mr Smith stated that LBH understood noise etc. concerns and would seek to minimise disruption. Lis noted that tower blocks require deep excavations which will be damaging to the environment. Mr Smith confirmed that there would be a construction/ environmental management plan for delivery/ construction vehicles.
Outlook for Existing Residents
The Inspector asked for clarification of the cross-section drawings showing angles of view from existing properties. These appeared to show differing angles. Mr Roberts and Mr Smith sought to clarify the issues, by stating that properties with a head on view of a tower block might have a view of the sky to one side or another! The Inspector noted that to the rear of 47 Oaklands Avenue the nearest new building appeared to be only 15 metres away (rather than the 18m minimum), and from the end of their 10m garden, only 5m away. This would appear to be uncontested.
Living Conditions for Future Residents
Barbara referred to the discussion about single-aspect properties (SAP) from the previous week, and the view of the LBH Design Review Panel that the number of SAPs was unacceptable. Mr Roberts stated that the constraining factors on both sites made the number of SAPs inevitable, but that design of the units minimised adverse effects and was acceptable. Barbara said that they had rejected the advice of the Design Review Panel. Mr Roberts replied that they had taken a balanced approach.
Overheating and Ventilation
Mohsen Zikri, for OWGRA, reaffirmed our concerns about SAPs. He noted that the London Plan policies pointed to ventilation problems in SAPs and said that they should be avoided where possible. Where unavoidable they should be adequately ventilated. He pointed out that the applicant’s energy statement discussed mitigation measures (reflectors, fans etc.), but made no commitments. Many bedrooms failed overheating/ventilation standards, with the recommendation that windows should be open during the day and closed at night! Mr Roberts claimed that design measures would be included, and when all is considered, the outcome would be satisfactory. The proposals were based on a planning judgement by energy consultants and was not a policy matter. Mohsen disagreed, saying that it was not good enough to rely on mechanical ventilation, which needed maintenance and consumed energy. Mr Roberts stated that mechanical ventilation was only part of the package, and that everything could be solved by design or passive and mechanical ventilation.
Amenity and Green Space
Barbara referred to the planning statements which showed that for both sites the podium/public accessible space was lower than LBH policy. Mr Smith argued that the policy sets benchmarks but had no fixed minimum standards. High quality design would be set against the constraints of the sites. Mr Roberts noted the need to look at such spaces across both developments, including balcony space, which were compliant with the London Plan. These standards were not a minimum requirement, but a balanced approach was needed. He went on to refer to – yes, you’ve got it – ‘optimisation of the capacity of the site’! Barbara repeated that there was a shortfall, and said that very few open spaces were accessible within 15 minutes’ walk (with reference to the ‘15-neighbourhood’ where amenities should ideally be within a 15-minute walking distance).
Barbara noted further that the planning statements showed a shortfall in play areas. Mr Smith said that the shortfall on the Homebase site would be offset by a financial contribution for elsewhere. Barbara asked, as a lay person, how a financial contribution could compensate for a lack of play space and referred to the statement by an OWGRA member on the opening day of the inquiry.
Mohsen raised the issues of noise, glare, privacy/intrusion, who would have access to the amenity areas, and sustainability. He noted that the architect, Mr Patel, in the first week had promised to provide examples of developments with similar podium/community spaces that were not in a city centre. Mr Roberts stated that plane and road noise had been assessed, and the issue of disturbance had been addressed in the design. Mohsen was not convinced by the reference to ‘areas of tranquillity’, and that design would not answer the intrusion/privacy issue. Such podium and public landscapes will need constant maintenance. Mr Roberts confirmed that the podiums will be accessible to all and will be well managed and maintained at no extra costs to affordable tenancies. Mohsen concluded by stating that high quality comes at a cost and that the proposals would not be sustainable.
So ended day 6.
Thursday 24 March 2022
The day started with a discussion of recent letters claimed by the developer to be in support of the development. One of the alleged supporters contacted OWGRA to say that he wrote no such letter. The QC for the developer said there may have been a mistake made in compiling the information and undertook to look into the matter and to report his findings to the Inquiry.
John McNulty, for OWGRA, pointed out that the greater part of both sites had a low public transport rating (PTAL 2). In addition, he said that there is no planned funding for major public transport improvements like the West London Orbital and Southall Rail Link train routes. He argued that a PTAL rating of mainly 2 is below planning guideline requirements for such large developments which need to have good transport connections and be in or near to a town centre.
Mr Roberts, for the applicant, responded that residents could take the H91 bus to Osterley station. He accepted that completion of the developments may be contingent on new infrastructure but claimed that there would be adequate capacity to proceed with the planned mitigations e.g. an extra gate at the station.
John McNulty asked about the treatment of foul and surface water:
“The applicant is providing attenuation tanks to cope with the surface water so that discharge is released as and when authorised by Thames Water to ensure that their system is not overwhelmed. The question is 'Can the applicant clearly state how he will be dealing with foul discharge into Thames Water's sewers, particularly in view of the long-standing problems of the Mogden Lane treatment plant?' ”
On behalf of the developer (applicant) Mr Roberts replied:
“Thames Water were … consulted on both surface and foul water and they had no objection. They proposed conditions for how this be dealt with. These relate to conditions requiring development and infrastructure phasing plans which consider the delivery of infrastructure improvements against the increase in pressure associated with the development. So this is how it will be agreed with Thames Water in the course of discharging those conditions.”
The Inspector asked about provisions in planning obligations. She wanted more detail on the contributions to the Brentford Health Centre. She also asked about costs and their shortfall.
Barbara Stryjak said that the proper location for a new GP surgery should be on the Homebase site because of transport links and parking. A new GP surgery is needed in the area to replace those that have closed over the years and to cope with the increase in population in the area.
Mr Roberts for the developer argued that there was sufficient GP capacity in the area and that the Homebase development would have negligible impact. Barbara responded with detail about the current problems with GP surgeries which she said are already overstretched.
The Inspector said that the development could not be expected to resolve existing problems but only those created by the development. The discussion ended with no commitment to providing a new surgery.
The shortage of primary places in the area was recognised but the case for the developer was that a new school would be provided in Layton Road, Brentford. Barbara pointed out that this would involve a 20 minute walk along a highly polluted road. The reply was that new capacity at Layton Road would relieve pressure on places generally so that the developments' residents could use their local school.
Mr Ward opened for the developer on trip generation. A TfL model had been used as the basis for the calculations.
Dominic West, for OWGRA, said that TfL had commented that some sweeping assumptions had been used in the traffic assessment. A detailed series of exchanges then followed ranging over such things as whether the proposed solutions were interim or permanent and the problem of exiting the new Tesco site onto Syon Lane. Dominic asked if the impact of rugby at Twickenham and football at Brentford had been included in the modelling. It turned out that they had not on the basis that this involved “occasional” events. Dominic responded that the events were regular and of increasing frequency.
Dominic opened on cycling saying the existing facilities on the Great West Road are poor and the proposed improvements minimal. In response it was claimed that improvements were being made for the Bolder Academy. The discussion then went into detail about bus routes, turning points, pedestrian routes, the location of bus stops and the lack of detailed drawings for these problems. Dominic had people speaking for the developer/LBH ranged against him but showed an impressive command of all the relevant materials. He showed that some of the claims made by the developer lacked evidence and that others were too vague. He said that OWGRA had not yet seen updated/new documents on transport and asked if there would be a chance to comment further at a later stage in the Inquiry. The Inspector agreed to this.
Mr Smith, for the Council, stated that the development plans were fully compliant with the climate change policies of the London Plan and of LB Hounslow and added that the Council's climate emergency Action Plan was aimed mainly at its own properties. Mohsen Zikri responded for OWGRA. He pointed out that the Action Plan has a section on commercial and residential properties and that the Plan's goal is to move to zero carbon building as soon as possible. He said that from 2025 new homes cannot be connected to the gas grid. A speaker for the applicant replied that the Action Plan does not change existing planning policy and the developments comply with current policy. Mr Sinclair for the developer said that the government had decided against banning gas boilers and gas connections to homes.
Mohsen wondered why triple glazing was being considered for the Tesco site but not for the Homebase site. He argued that triple glazing could make a big contribution to carbon reduction. He also said that plans for PV cells (solar panels) were inadequate, unclear and in conflict with other uses of roof space. A discussion on the use of the roof space for various purposes seemed to support Mohsen's point. Mr Sinclair, for the developer, said that the building requirements for the two sites were different and also that triple glazing costs would go down in time and would be more cost efficient by the time of building on the Tesco site.
Mohsen questioned paying into carbon offset funds rather than installing triple glazing. Mr Smith said that the offset payments were agreed with the GLA and LBH. Mohsen accepted that the developer was complying with policies but said that it could easily do better.
Lis Guest opened for OWGRA explaining our concerns about poor air quality at Gillette Corner and the Great West Corridor. She said that OWGRA had shown the alarming level of NO2 pollution in those points (up to 50% more than the EU/UK limits). She argued that, given this high background level of pollution, the intention from the start should have been to make the developments air-quality positive rather than air-quality neutral. The failure to do so, she said, led to conflicts with a number of policies on air pollution. She added that Breathe London measurements at Gillette Corner showed high levels of NO2 and PM2.5 particles. Finally, she said that adding filtration units to the developments to deal with pollution was unacceptable.
Mr Rusby, for the developer, responded by saying that their extrapolation of pollution data was “standard” and that anyway the nearest monitor was only 200m away along Syon Lane. He said that Breathe London data was not sufficiently accurate. He explained that air-positivity was a developing idea for which there was no current guidance. Mr Smith said that measured air quality levels were within official limits.
The Inspector asked about residual effects off site. Mr Roberts said that wind tunnel testing with a model had revealed problems, all of which, bar one, were dealt with by mitigation measures. The exception was a bus stop where the problem was comfort level rather than danger. Mohsen spoke about wind condition on the podiums and pointed to problems for which he believed the mitigation measures are not shown on the architect’s drawings. A debate ensued about whether the podiums were fully usable all year round. Mohsen argued that the developer's documentation made this seem doubtful. Mr Roberts for the developer rejected that interpretation and said that wind issues were adequately addressed.
Mohsen argued that the developer admitted that there would be a problem of glare from the Homebase development but proposes no solution. Mr Smith said that the transport authorities had been consulted and had raised no concerns.
Tuesday 22 March 2022
The 3 heritage days that could not go ahead on 21-23 March have provisionally been moved to 26-28 September, as that is the earliest time that everyone taking part in the inquiry is available.
The roundtable sessions are going ahead this Thursday, 24 March and Friday, 25 March, except for ‘Character and Appearance’ which will provisionally move to Thursday, 29 September and closing statements would be presented on Friday, 30 September.
You can watch this Thursday's and Friday’s proceedings from 9.30am on Hounslow Council’s YouTube channel https://www.youtube.com/c/LBHounslow