Below is an extract from the planning application for the current development phase, adjacent to the Recreation Ground. This explains the mix of private, intermediate and social tenure. Only "secure" tenants from the next development phase will be offered flats in this phase.The section on "Design, Scale and Siting" is a classic piece of architectural planning greenwash. Worth noting the significant increase in density, cramming more people into smaller spaces. No doubt this pattern will be repeated in future phases, even though it is out of step with stated GLA regeneration policy. The trade-off is that unless the developer can turn a decent profit somehow, the regeneration wouldn't be happening. And that would be much worse. The risk is that, if private buyers aren't tempted by the delights of living in South Acton, the private sale flats will be bought by buy-to-let investors and then rented back to the council for occupation by HB tenants. And we'll be back to square one in a decade or so. It's a win-win for the developer either way...Mix of Housing, Viability and DensityAffordable Housing The proposal would provide 87 units / 269 habitable rooms in affordable tenure, which is equivalent to 55% of the total habitable rooms. The remaining 80 units / 218 habitable rooms would be private sale housing. Whilst the proposal would appear to meet the requirements of London Plan policies 3A.9 and 3A.10, which seek to maximise the provision of affordable housing in developments of more than 10 units; policy 3A.15 of the London Plan requires no net loss of affordable housing and this would not be achieved by this development. In this regard, the proposal would deliver 29 units less than the affordable accommodation previously provided in Kipling Tower and Bollo Court. Whilst it is relevant to consider the provision of affordable housing on individual sites, this development would form part of the on-going South Acton estate regeneration programme. The consolidation of the recently completed phase 2.1, phase 2.2 (under-construction) and this proposed development would ensure that there would be a net gain of affordable housing within the South Acton Estate. The GLA have accepted the proposal on a ‘wider estate renewal’ basis and consider that this proposal would aid the delivery of a wide range of housing types in the neighbourhood. A comparison of the pre-development and post-development housing provision for phases 2.1, 2.2 and the application site is provided below: Phase 2.1, Phase 2.2 and proposed Affordable Housing Pre-redevelopment (units) Delivered / Proposed (units) Net Gain / Loss (units)Phase 2.1 65 129 +64Phase 2.2 20 125 +105Bollo Court and Kipling Tower site 116 87 - 29TOTAL 201 341 +140Table 2: Phase 2.1 (P/2007/2310), Phase 2.2 (P/2008/4713) and proposed affordable housingPolicy 3A.9 of the London Plan requires that the split between the social rent and intermediate rent units is 70:30. The current application would provide 68 units in social rent and 19 intermediate rent, equating to a split of 78:22. The high proportion of social rent units is partly due to the requirement to accommodate existing residents to be decanted from the next anticipated phase of redevelopment of the estate. Again, it is considered relevant and appropriate to consider Phases 2.1 and 2.2 to gain a broader view of the regeneration proposals on the estate. Phase 2.1 provided 74 units in social rent and 55 units in intermediate rent and at the completion of phase 2.2 there would be 84 units in social rent and 41 units in intermediate rent. The consolidation of these two phases of development with the current proposal would provide a split between social rent and intermediate rent of 66:34. This would broadly comply with the recommendations of policy 3A.9 of the London Plan.Additionally, it is considered desirable to have a provision of private sale housing within the development in order to meet the needs of a wide variety of households in the local area, which is one of the key objectives of PPS 3 ‘Housing’ and policies of the development plan. Housing Mix The mix of accommodation in affordable tenure is comprised of:Unit size Number of Units (Social Rent) Number of Units (Intermediate) Overall % SPD 1 Affordable Housing %1-bed 21 7 32% 27%2-bed 29 10 45% 37%3-bed 10 2 14% 24%4-bed + 8 0 9% 12%Total 68 19 100% 100%The proposed mix of affordable units does not fully follow the general aspirational mix outlined within the Ealing SPD1 (Affordable Housing), which seeks a higher proportion of three and four bedroom dwellings and less one and two bedroom dwellings. However, this is not considered objectionable in this particular instance. SPD 1 must be read as a borough-wide, strategic document and clearly differences in need exist within the Borough. Applications must also be considered on their merits and against the various constraints imposed on them, which dictate their appropriateness for the type of varied dwelling mix achieved. In this case, the development would predominantly accommodate Council tenants who will be decanted from the next anticipated future development phases in the regeneration of the South Acton estate. To this end, the Council’s Housing Regeneration Service have worked with the applicant to ensure that the housing mix meets the specific local housing needs identified on the estate.The mix of private housing would incorporate 29 x 1-bedroom, 45 x 2-bedroom and 6 x 3-bedroom units. Combined with the mix of non-family and family sized accommodation in affordable tenure, it is considered that the proposal would provide a variety of housing to suit the widely differing social and economic needs of the Borough’s population. Density Policy 3A.3 of the Consolidated London Plan requires that development proposals achieve the maximum intensity of use compatible with local context, the principles of good design and with public transport capacity. Corresponding policy 3.4 of the draft replacement London Plan shifts the emphasis from achieving the ‘maximum intensity of use’ to ‘optimising housing potential’ and gives further prominence to the need to take account of local context. London Plan policy 3A.15 resists the loss of housing, including affordable housing without its planned replacement at existing or higher densities. Policies 3A.5 and 3A.10 focus on securing housing choice and the maximum reasonable amount of affordable housing which is financially viable. The application site previously accommodated 127 units / 383 habitable rooms (contained in Bollo Court and Kipling Tower) and the proposed development would contain 167 units / 487 habitable rooms. At a proposed density of 223 units / hectare and 649 habitable rooms / hectare, the proposal would exceed the recommendations within table 3A.2 of the London Plan for the density of development in an ‘urban’ setting with an average of 2.7 – 3.0 habitable rooms per unit and with a public transport accessibility level (PTAL) of 3 (moderate). The recommended density of development in such circumstances is between 70-170 units / hectare and 200-450 habitable rooms / hectare. The GLA have considered the application and advised “…for such high density development to be acceptable, the application would need to be exemplary in all other respects and provide a high-quality living environment”. In this case, it is considered that the proposal would provide high quality, generously proportioned, and environmentally sustainable housing in a mix of tenures that furthers the objectives of the regeneration aspirations for the estate. In relation to the requirement to consider development in its local context, the surrounding built environment is comprised of a starkly varied density and typology of housing. The homogenous character of the low-rise Victorian and Edwardian terraces to the north and east of the South Acton Recreation Ground are contrasted with the existing high-rise flatted buildings within the South Acton estate. The development currently under construction (Phase 2.2) immediately to the south of the application site varies in height between 6 to 8-storeys, whilst recently completed development (Phase 2.1A and 2.1B) further to the south and west of the application site varies between 3 and 10 storeys. Blackmore Tower on the west side of Palmerston Road is a 14-storey point block, whilst Bollo Court was 4-storeys and Kipling Tower was 12-storeys high. It was accepted as part of the South Acton estate Phase 2 masterplan that this site could accommodate a flatted development of predominantly 6-storeys with an element up to 13-storeys high. In such circumstances, it is considered that the proposed 3-9 storey perimeter building would not be out of context with the varied form of development within the local area. Furthermore, the site is located in a sustainable location in close proximity to Overground and Underground train services and TfL bus services and close to the Acton District Centre, which offers a wide range of retail, health and leisure services. On balance, it is considered that the development site could sustain development at the proposed density. Design, Scale and SitingPolicies within chapter 4 of the Ealing UDP are concerned with guiding the design quality of Ealing’s urban form. Good urban design is considered to be fundamental to the provision of an attractive, safe, accessible and sustainable Ealing, in which people want to live, work and spend leisure time. It is also considered to be a fundamental principle of urban renaissance, which aims to create well-designed cities that are more compact and connected. The Council’s policies under chapter 4 of the Ealing UDP aim to relate to the overall form of development, including the layout, integration of the building with the public realm, landscaping, accessibility and perception of safety. Good design is also central to the objectives of policies of the London Plan and specifically promoted within chapter 4B of the plan. Layout, scale and building form A general characteristic of the tower buildings in the existing estate is that they take no account of the pre-existing street lines and do not therefore interact with the street like traditional housing. Legibility is also poor in the existing estate and there are limited opportunities for natural surveillance. In contrast, the proposed perimeter block form frames surrounding streets with active building frontages to create a coherent street pattern with a clear distinction between public and private space The layout and massing of the proposed building is a specific response to the site's context and shape. The design proposes two L-shaped blocks of 6 to 8-storeys high, reaching 9-storeys in the north-west corner of Bollo Bridge Road and Palmerston Road, linked by two rows of 3-storey houses. Buildings enclose a central 1st floor courtyard deck with an undercroft car park below, helpfully hiding the main provision of car parking from public view. The building layout clearly takes priority over streets and car parking and minimises the area taken by highways. The design of the perimeter block building maximises street frontages, views of the park and morning / afternoon sunlight to the courtyard, whilst creating a variety of building scales, types and enclosures to enliven the streetscape. Houses would be positioned opposite the taller flat elements in order to address the site's narrowness. Building lines recede and project to address existing trees that the Council wished to see retained. The architectural form and contemporary language of the proposed buildings together with their carefully detailed fine grain facades, give the scheme its own specific identity and strong character. Elevations share a common theme but are expressed differently according to their height and the space they face. The stepped, strongly articulated form and bold use of colours on buildings are aspects of the scheme that relate particularly well to the earlier South Acton phases (2.1 and 2.2), which are considered the most relevant visual reference for this site. The changes in scale and architectural treatment of buildings are considered to aid navigation around the site. The larger stone, glass, boldly coloured north-eastern elevation of the development would be instantly recognisable on the streetscape and would help to signal the site's important intersection with Bollo Bridge Road and the South Acton Recreation Ground. In contrast, the south elevation facing the home zone is more subdued, emphasising the more intimate nature of this space. The east elevation, more articulated and predominantly brick, has a more domestic, solid feel and forms an elegant, robust edge that maximises views towards the park. The almost identical appearance of the west elevation is less successful in addressing the more local character of Palmerston Road and closer proximity to existing and future development. It fails to provide a more specific face of the development leading towards South Acton station, however visual interest is provided to this elevation through the provision of the smaller town houses, the retention of street trees and opportunities for more significant areas of landscaping at street level. The proposed undercroft car park is enclosed by residential frontages and does not interfere with the streetscene. Access to the car park from Palmerston Road is discreetly designed into the west building elevation. The provision of on-street parking bays are broken up by soft landscaping and their presence would be softened by linked front gardens to ground floor units with low, continuous, buffer planting enclosures. The footpaths around the site are free from barriers and edged by soft landscaping, making them pleasant routes for pedestrians.The proposed development would frame the adjoining streets, public open spaces and the internal courtyard with active building edges with frequent doors, windows and balconies, promoting natural and informal surveillance of these spaces. The position of core entrances to either side of the energy centre prevents this potentially becoming a dead frontage. The proposal has been designed according to Secure By Design principles. Subject to the submission of a materials sample board, the proposal is considered to represent a high-quality residential development that broadly accords with the Council’s design requirements under chapter 4 of the Ealing UDP.Quality of resulting residential accommodationPolicy 5.5 of Ealing’s UDP requires that residential development provide good living conditions for residents by ensuring that the accommodation provides an attractive outlook and sense of privacy; adequate indoor living space and garden space related to the accommodation; adequate sunlight and daylight; and play space for children. Policy 3A.5 of the London Plan and policy 5.3 of the Ealing UDP require that all new housing is built to Lifetime Homes Standards, and 10% are designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users. Layout The Council’s SPG 14 ‘Indoor Living Space’ sets the minimum indoor living space requirements for new development. The proposal would exceed the Council’s adopted requirements for all units across the different tenures and mix of accommodation. The proposed accommodation would be comprised of the following gross internal areas compared against the Council’s SPG 14 standards and the London Housing Design Guide (Interim Edition):Total Units 57 1 3 28 51 19 8 167 1b2p 1 bath 2b3p 1bath (rented) 2b3p 1bath (private) 2b4p 1bath (rented) 2b4p 2bath (private) 3b5p 2bath 4b7p House 2bath Proposed Gross Internal Area m2 50 61 61 72 72 94 120 SPG 14 requirement m2 44.5 56.6 56.6 66.8 66.8 78.9 97.5 London Housing Design Guide (Interim Edition) 50 61 61 70 70 86 123 The proposal would predominantly meet the minimum space standards set out in the London Housing Design Guide (Interim Edition), which exceed the Council’s adopted floorspace standards. The GLA specifically highlighted this in the Stage 1 Response and welcomed this aspect of the proposal. The layout of the development is such that each unit would be self-contained and ground floor units would have their own individual front door. Upper floor units would be accessible from one of the six entrance cores, which are segregated by tenure. It was considered necessary to limit the number of units accessible from each of the communal cores in order to overcome criticisms of high-density developments that often fail to prosper a sense of community due to high numbers of residents accessing the building from the same entrance. In such circumstances there is generally a need for CCTV and other enhanced security measures because residents have no sense of privacy, ownership or familiarity with the other residents sharing the entrance core. The Mayor’s Housing Design Guide (Interim Edition) recommends that the number of homes accessible per floor should be restricted to groups of 2-8. In the case of the proposed development, no more than 4 units would be accessible per floor within individual cores. The guide also suggests that the safe maximum dwellings per core should be restricted to 25 dwellings. Block 1 (social rent tenure) and block 6 (private sale tenure) would have entrance cores that serve 32 and 30 units respectively. However the other four building cores would not serve more than 25 dwellings. A condition has been included in the recommendation that requires that the development be carried out in accordance with the principles of Secured by Design, which would address the requirement for enhanced security within these entrance cores. Aspect Approximately three-quarters of the proposed housing would have a dual aspect outlook. Crucially, none of the single-aspect units would have a north-facing outlook. The upper floor units facing Bollo Bridge Road would all have a view over the central landscaped courtyard ensuring a pleasant and calm outlook. The ground floor units sited along the Bollo Bridge Road frontage would benefit from a dual-aspect (north and east or north and west) and would be setback between 2m-6m from the public footpath. The massing and layout of the building has been manipulated in order to maximise the views over the adjoining parkland to the east of the site. A limited number of units would have habitable room windows that do not fully meet the Council’s recommended 21m-separation distance. However, the minimum separation distance between habitable room windows within the development would be 19m and this is considered to be sufficient to ensure a reasonable level of privacy for the future occupiers of the proposed development. The internal layout of the building has been designed in such a way that the majority of principal living rooms within the northern and southern axis of the building face south. Those units within the northern block with a view to the south look over the communal courtyard, which is 73m in depth. The units within the southern block have an outlook over the landscaped home zone. It is considered that the outlook from the individual units within the development would provide a pleasant internal living environment for the future occupiers of the site.Daylight and Sunlight (within the development) An assessment of the daylight and sunlight distribution to individual dwellings within the development scheme was undertaken by an assessor using the BRE Guidance ‘Site Layout Planning for Daylight and Sunlight’. It is relevant to note that there are no minimum requirements in the Building Regulations for daylight or sunlight provision in new buildings and the daylight credits in the Code for Sustainable Homes are optional, not mandatory. However, Ealing UDP policy 5.5 (Residential Design) states that residential development should provide good living conditions for residents that ensure adequate sunlight and daylight, and as such the results of the sunlight and daylight assessment are of material consideration.The Code for Sustainable Homes (CfSH) recommends targets for the average daylight factor of at least 2% to be achieved in kitchens, and 1.5% for living rooms, dining rooms and studies. The flats that were tested for average daylight factor within the development included a typical recessed balcony flat, which makes up the majority of accommodation within the proposal. The findings of the assessment indicate that the ‘typical’ flat would achieve a 1.89% average daylight factor to the kitchen, marginally lower than the recommendations. However, a 2.45% average daylight factor to the living room would be achieved, which exceeds the recommendation. This would be increased to 2.53% if the partition between the kitchen and living room was removed, which is a viable option for the layout of individual units. This demonstrates that the CfSH targets for the average daylight factor in the typical flat within the development could be achieved and that the quality of daylight penetration would be acceptable. Shadow plot diagrams were also included within the Daylight and Sunlight Report and demonstrate that the varying height strategy along the eastern and western axis of the building would ensure that the majority of the internal courtyard (communal amenity space), balconies and roof terraces would receive excellent levels of direct sunlight during the summer periods. Only in mid-winter, when the sun is extremely low, does the communal courtyard remain in shadow for the morning and afternoon periods, with some sunlight penetration at midday. The gardens, balconies and roof terraces of individual units are orientated south, east or west and all have been found to receive some sunlight for part of the day for all days of the year. Consequently, it is considered that the proposed development would be of sufficient high quality with access to sunlight / daylight that broadly meets the aspirations of policy 5.5 of the Ealing UDP.Lifetime Homes and Wheelchair Standards The development has been designed to comply with the Lifetime Homes Standards, as required by Policy 3A.5 of the London Plan and policy 5.3 of the Ealing UDP. 10% of units have been designed to meet Wheelchair design standards. The rented units would be dedicated dwellings designed to Habinteg wheelchair standards and the intermediate-rent and private sale dwellings would be wheelchair adaptable, designed to the GLA Best Practice Guidance – Wheelchair Accessible Housing. The wheelchair housing would be provided across the different tenures of accommodation and lift access is provided to each floor of the building, with access being provided into the first floor communal courtyard for people in wheelchairs. The layout of the courtyard would be such that a perimeter circulation path and the soft landscaped areas would be accessible to all. Crime Prevention Policy 4.4 of the Ealing UDP requires that the layout and design of new development be based on the promotion of a safe and secure environment, including the maximum possible adoption of natural surveillance of public spaces. The design of the proposed development has been informed by the comments and scrutiny of the Metropolitan Police Crime Prevention Design Advisor and in accordance with the government publication ‘Secured By Design – New Homes 2010’. Additionally, the proposed affordable tenure accommodation has been designed to achieve Level 4 of the Code for Sustainable Homes (CfSH) and would therefore be required to incorporate appropriate physical security levels for items such as doors and windows. The design of the building incorporates large areas of glazing and private balconies overlooking the adjoining highways, the central communal courtyard and the South Acton Recreation Ground to the east. Combined with the provision of private front door access to ground floor units and houses, it is considered that the development would enhance opportunities for casual surveillance and activity along all four frontages of the proposed perimeter building. The ground floor units would have small garden enclosures for bin storage, however this would also act as a buffer between the unit and public realm.The proposed undercroft car park is hidden from casual surveillance and would consequently require enhanced security measures to restrict access. The segregation of refuse and recycling storage and cycle parking away from the car park would assist in limiting the number of residents who would have access to the undercroft. The entrance to the car park would incorporate a mechanical gate and access into this area would therefore be restricted. It is intended that CCTV entry systems would be located on all of the six communal entrances. The Crime Prevention Design Officer is satisfied with the proposed safety measures to be incorporated into the development; however a condition has been included in the recommendation relating to compliance with the Secured by Design principles. Future Management Although not a material planning consideration, the applicant has advised that the ongoing management and maintenance of the development would be by London and Quadrant Housing Association. The management would be across the social rent, intermediate rent and private sale units and would incorporate routine maintenance and cleaning of communal areas such as entrance cores and the landscaped areas. This would help to ensure that the development is managed in perpetuity.
Peter Millman ● 5108d