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.
Transport infrastructure
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.
Waste water
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.”
GP surgeries
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.
Schools
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.
Highway matters
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.
Healthy Streets
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.
Environmental impact
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.
Air quality
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.
Wind
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.
Glare
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.