The PR company for Carlton Developments have been kind enough to invite me to meet the architects next Tuesday morning 29th May. If readers have any additional points to the ones below that they would like me to make please leave them on this thread or email me at david@dewhurst.netWith regard to Jorden Molna's statement that "tall buildings are the future" to me it is both terribly '60s and a legitimisation for "anything goes"I think there is a vicious circle between Defra objectives, Local Authority objectives and what the developers have therefore to play to which is against the real needs of both local residents and the potential incommers to the Alpha Laval site. My points are included at more length in my two formal submissions to Hounslow Planning which follow.. . . .Comments on Plans for the Alfa Laval Tower site Great West Road BrentfordRegrettably the period allowed for comments does not allow for democratic participation. The volume and detail in the plans took me two hours to get a moderate overview. If two people viewed the plans at once at best about 50 people a week could realistically look at them. If we suppose only 1000 people will be critically affected that would require 20 weeks (half as much if they got to the Civic Centre). Given that many people work five days a week the required period, with good scheduling, would be several times more.Most of the paperwork was originally generated on computer so it would be relatively easy to put it on-line.As a former lead Ofsted inspector I am used to getting to grips with crate-loads of paper- work but without several times two hours access I can not guarantee that all my points are spot on or that I have identified all the downsides.1/ Despite the necessary volume of the plans they are generally well presented although failure to include a sky-line profile for Challis Rd and Clements place – the most heavily overlooked area – is a glaring omission.2/ The inclusion of 39 three and four bedroom houses is very welcome. This accords with the general residential profile to the north, south and east. More would be desirable. The fact that they all can be “social rented affordable units” is impressive and shows the potential to create a humane environment.3/ The massing of the remaining 321 residential units (ignoring for now the 200 hotel and 200 serviced apartment rooms) is not, I think, humane. I understand that the BCC (Brentford Community Council) reckons it is not possible to meet the required government/ Local Authority maximum housing density “guidelines” without building up to 5 or 6 stories (maybe this just refers to the office frontage barrier along the M4 and the residential units would be a storey less, I am not quite sure).4/ We are already an above average crime area; lower quality over dense-housing will increase crime. Even before the completion of accommodation in the Great West Quarter, and other developments, infant schools are oversubscribed, elsewhere is tight, and local people who talk to me are dissatisfied with local school quality. I am not aware of plans for new school places and the infant “bulge” is set to move up the system.5/ It appears that the government, Local Authority and Carlton Developments are caught in a negative mesh of well-meaning, inappropriate, overdetailed targets with a lack of the joined up thinking which we all hopefully await. Most people want to live in low-rise housing with at least a minimal back garden. With a small minority of exceptions, anything less creates social stress. Targets may achieve “success criteria” for one department but their fulfilment in this case will create problems elsewhere in the system. The mesh of target constraints between institutions makes the whole system less amenable to democratic control by those for whose benefit the targets are theoretically created. (c.f. “Paradoxes of optimisation in public service management” Kybernetes 2006 vol.35 no1/2 pp25-29 by myself)6/ I understand that the government requires Hounslow to create 10,000 extra housing places, a suspiciously (arbitrary?) round number. Most people would suspect that the official statistics could already overlook 10,000 people in a Local Authority of our size. If we are all to be housed decently the government must modify its requirements and release “Green Belt”. The average back garden is more ecologically diverse and potentially a better CO2 sink than a field of subsidised agribusiness monoculture. Moreover determination to vest ownership of the land in a stunningly low percentage of the population is not the best guarantee of human welfare. In any case a very low (2% max. I read) proportion of the land would be converted if this policy were applied nationally.7/ My concerns about cramping and inappropriate targets apply also to the serviced apartments, hotel and office space. Carlton is obliged to include these to meet local employment provision targets for the site. They plausibly indicate that surveys show that Brentford is not a desirable location for new employers generally. The Great West Road is already lined with half empty office spaces. I do not think the new, better located, hotels around Brentford are optimally occupied. As an ex-4-night-a-week hotel user I would desperately avoid one alongside a motorway. Most regular travellers end up using B&Bs.In a short walk around the area you can easily find other decent empty employment sites.8/ These notions of the leading edge of employment development are obsolete. A better employment option would be the provision of garden offices and home offices (some maybe doubling a B&Bs at times?). This is also by far the most ecological transport option.9/ The other rationale for the hotel/office frontage is as a protective sound wall from the M4. Quite rightly the developers have identified the current noise level as unacceptable. We have faced this to the north since the late 60s. (I try to cope with double glazing, ear plugs and a duvet over the bedroom window.) However a barrier to the south will reflect the sound back to residents to the north, almost doubling it. The architects say that their consultants say this will not be a problem. No rationale or mechanism is given. This is implausible. An echo is an echo. Also without the empty Alpha Laval site more motorway pollution will also drift to the north. 10/ What is required before any further development is transparent sound barriers along both sides of the motorway. Switzerland can do it. I realise this poses interesting engineering issues with an overhead motorway. This is why the mechanics of it should start now, and the promised joined-up-thinking should include the highways authority.11/ However the most offensive aspect to people on my side of the motorway (the north) is the proposed twelve times increase of the frontage looking down on them compared to the old tower. I make it about 557 ft wide and 220 ft high, 256 ft with the wind turbines. No previous or oncoming local development has overfaced residents in this way. To allow this when there are strict (and appropriate) limits forbidding home extensions from overlooking neighbours would be absurd. I know there is a distinction on overlooking made depending on whether it is from a balcony or behind a window. To quote the professor of the Bartlett School of Architecture at UCL this is also “absurd.”12/ All the residents I met when I leafleted them last Sunday were bitterly opposed to this visual insult which will block our skies to the south. No development should obtrude above the motorway. The 30 metre advertisement hoardings which we have allowed so far are bad enough and create unacceptable night light pollution. No one believes that anyone would dare propose a development in this way for the residents of Chiswick Park.13/ I have picked up frustration from residents in central Hounslow at the relatively low new three and four storey developments hemming them in and blocking sight lines there. Conceivably this was a factor in the swing in voting behaviour. People already comment around Challis, Clements, Enfield, Eastbourne and Clayton about how they feel increasingly hemmed in with the student towers to the East and the threat of large blocks in the Great West Quarter. (Residents on Ealing Rd near the motorway also felt affronted by the coming and proposed changes.)14/ A final concern is the noise created by the proposed wind turbines on top of the development. That they will be quieter than conventional turbines is not reassuring, nor is the argument that it is a trifle in the existing noise profile. They will probably be at a different frequency and therefore quite discernable. Also the motorway does often become relatively quiet between 2.30 and 5am (pacé night flights) and the turbines would obtrude during the best hours of our sleep. The plans indicate that they will supply 0.26% of the ongoing energy needs of the development, rather an ecological figleaf. The best ecological option is not to build the office/hotel frontage at all. 15/ Most people locally face enough stress living their ordinary lives with some dignity. I myself have been unable to discharge my other responsibilities as well while responding to this application. All the people I talked when I delivered over 200 leaflets were affronted by this development, particularly the “wall of offices” aspect. Some were unbelieving at first, others shocked and offended but what shocked me most was the just-over-half who said, “You’re absolutely right but you’re wasting your time. They’ll never change it.” If you believe in real democracy and want other people to believe, you will. Dr David Dewhurst, 17 Challis Rd. TW8 9PP. . . .Further points on the Alpha Laval Site PlansDear Sue Bendle,Having gleaned another four hours to look at the plans I would like to make the following additional comments. I reiterate that this is not nearly long enough to digest the 8 inch pile of A4, A3 and A1 papers.The noise surveys and projections are at best meaningless and at worse misleading with respect to residents to the northNoise levels along York Parade were measured at a height of 1.8m., i.e. under the motorway. Sound will be bouncing back here already because of the barriers round the site. The point is to measure and predict the sound at bedroom level – approximately M4 level – of the residential properties to the north of the site. This the computer simulation fails to do. The calculation of an increase of only 0.43dB (P9 of Supporting Planning Statement Part 6) along York Parade is irrelevant to most of those who will be affected. The statement that the façade will be louvered rather than flat which will therefore help scatter the sound only means it will reach us from more different angles. Earlier in the Planning Application (Part 2?) a two day survey at one point above the motorway shows a noise level at a potential façade of LAeq 75-76dB, LAf max typically 77-90dB and the graph seems to show a spike of over100dB. They acknowledge that further away the drop is only 2-3 dB.Thus the conclusion of the paragraphs headed “Reflected Noise” P9 “..the increase in noise level at the properties opposite the site will not be significant” only applies to around 6 feet up along York Parade. I find this misleading.Analogous considerations appear to apply with the pollution calculations such as NO2 . Further the monitoring station is 290m to the south-west of the site and even there the annual average NO2 level is consistently exceeded. Obviously for those of us far closer the situation is worse. However the commercial façade would further screen the air monitoring station so ostensibly pollution would go down while in fact more drifted north.Habitation density arguments are implausible.In the initial site description the area of the site is given as 1.86 hectares (ha). However in the Supporting Planning Statement (Part 6) section 10.10 when the developers calculate hrha (habitable rooms per hectare) they base it on their description of the site as being “just over 2ha”. This gives an hrha of 495 against my calculation of 1063 ÷ 1.86 = 571.5 which is itself an underestimate as it does not factor out the land given to offices. (At one point “employment use” is given as 44%.)I assume they are correct (section 10.3) in saying that the Hounslow UDP policy H.4.2 states that residential density of new developments should not exceed 250 hrha. There follows a quote about special circumstances in which higher densities “will be considered”. The arguments that these conditions are met are implausible – It is not in a town centre. It is surrounded to north east and west by “residential character” dwellings. To say “there is no established residential character on the Great West Road” is vitiated by the fact that immediately to the west, after the New England pub there is a line of trees and vegetation sheltering the back gardens of houses that back on to the Great West Road. With respect to relaxations for “a high quality environment,” the environment is hardly high quality and the little courtyards compared to built area make it less so. With a projected 231 children and social, affordable housing most people would baulk at the description “predominantly non-family”. Obviously by squeezing in more single households or apartments you can get over 50% but this is hardly fair on the children. Paragraph 10.5 appears to argue that the Wallis House development will degrade the area so that a higher hrha density could be considered. If that can be considered it sends out a dismal or insulting message and should be rejected.Much of the employment aspirations are based on wishful thinkingHistorically the site has been industrial and I can empathise with Hounslow planners’ reluctance to entirely forgo an employment element. However decent housing is a bigger problem in London, and Hounslow, than gross employment. Much of the analysis of the Hounslow Office Market (in Part 5) strikes me as the developers diplomatically telling the Hounslow planners that such development is otiose. From a plethora of negative evidence, I am struck by the characterisation of the market as one of “unremitting gloom”. The estimate given for “displacement” i.e. jobs taken from elsewhere, by the offices is only 12%. I can’t see why it isn’t 100%.The displacement effect given for the Hotel and Serviced Apartments is put at 50%. Again for the Hotel, if it were effective, a figure approaching 100% seems more plausible. I feel less able to guess about the serviced apartments. I know that when my cousin comes to London on business he finds the time taken to travel in from Brentford makes it more efficient to pay to stay in a serviced apartment centrally, despite the atypical family ties which bring him to Brentford when the pace is slow.The estimates of one employee per two rooms seems high for the hotel and ridiculous for the serviced apartments. It would be fun to ask Travel Lodge and Staybridge to guarantee these levels.Around Section 11.5 of the employment analysis a table gives an estimated multiplier effect for the on site employment of 151 for the Office and 69 for the rest. I can not find the rationale for these exact numbers. I trust the negative impact of displacement has been factored out. I can not tell if the table is unclear or I just don’t understand it.I repeat the point of my previous submission that home and garden offices would provide more plausible, good quality, ecological employment.The alternative justification for the commercial frontage is as a sound shield. If south of the M4 will need it the north always has. Joined up thinking would involve the highways authority in putting up transparent sound screening along the M4 itself. An additional “environmental” sound shield could be created with a ramp of vegetation facing the A4/M4 consisting of gorse, holly, cupressus and leylandii. This would complement the line of trees and vegetation just along the A4 to the west. A genuinely sound absorbent artistic screen behind this would be feasible; or if permanent residents could put up with the conditions proposed for hotel residents and those in the serviced apartments they might prefer triple glazing. . . . .I have no time before the official closing date to complete a full critique. I note that in section 5, Townscape and Visual figure 5.4 of nearby high rise developments omits the new towers at the corner of Boston Manor Rd. and the A4. The attempt to imply “strong support” for a proposal created “in conjunction” with the community is strange. The Developer’s Response to Comments in Part 1, particularly in response to overshadowing to the north, include straight non-sequiturs.At best they find 41 people (85% of 48 respondents) to say that the plans are “generally progressing in the right direction”; I agree, but there is a long way to go. I do like the roof gardens. Dr David Dewhurst, 17 Challis Rd. TW8 9PP
David Dewhurst ● 6579d