Ealing’s Local Development Framework, 16th September 2009

Yesterday and today I spent five hours trying to make sense of the two main 60+ page documents. One of them – ‘Development Management’ – is completely impenetrable. I suspect even planning experts would have trouble trying to fully understand it all. Some examples of the planning guidelines and jargon you need to consult to even understand this document include:

Ealing’s UDP, PPG3, LTP, SPG 13, the Mayor’s SPG, CLP, PPS 25, land won aggregates, BREEAM Excellent rating, MOL/Heritage Land, SINC/SMI and the Code for Sustainable Homes.

Most of the 240,000 adults living in Ealing are lay people and not planning experts. It is just not possible to describe this document as fit for purpose for Public Consultation.

The other 60+ page document – ‘2006 Development Strategy’ is not much more penetrable. However Map 2 on page 12 just about sums up the Ealing Council ‘strategy’. It shows residential tower blocks all along the Uxbridge Road/Crossrail route from Southall in the west to Acton in the east.

We are in the fifth consecutive quarter of recession and the UK. With the UK’s budget deficit forecast to reach £175 billion this year and with our National Debt expected to rise to £1.4 trillion by 2014 it seems excessively foolhardy to be discussing any building development at all for the foreseeable future.

Ealing’s UDP (Unitary Development Plan) is the local planning guidance which Ealing’s LDF will eventually replace. The UDP was adopted in 2004. In the written evidence I submitted to National Government at the Arcadia Public Inquiry in June 2009, I lamented about the unrealistic nature of the UDP. With regards to the centre of Ealing, I pointed out:

‘10. Ealing’s 2004 UDP details six major development sites covering 32 acres in the Town Centre – whose preferred uses include the provision of social and community infrastructure including cinema, hotel, community units, education developments, and quality public space. None of these developments have even got foundations dug or a single brick laid. In five years, four of these sites have attracted no development plans at all. Just how valid is the UDP.’

In the three months since I wrote those words nothing has changed.

National Government’s ‘Soundness Guidance’ to Local Government (published by The Planning Inspectorate, August 2009: 2nd Edition) lays down a number of soundness tests for LDF Core Strategies. These tests include legal compliance, justification, effectiveness and consistency with national policies.

The key test posed for justification is:

‘Has the consultation process allowed for effective engagement of all interested parties?’
12 days into the ‘skimpy’ 42 day Public Consultation period I would have to say the Ealing Council’s effective engagement with its 240,000 adult residents has failed this test. However it will be interesting to see and hear what the worthy burghers of Greenford make of the LDF tonight. One even wonders how many of the 30,000 Greenford adults know about this meeting; have obtained and read the 232 pages of the September 2009 LDF eight document set; and actually turn up at the meeting?

Another test is:

‘Have the reasonable alternatives been considered and is there a clear audit trail showing how and why the preferred strategy/approach was arrived at?’

My initial assessment is that Ealing’s LDF effort is failing this test. Many, many indicators point to the fact that we are heading for decades of austerity and cuts in public spending. Peak Oil and climate change allied to our bankrupt economy are plain for all to see.

There’s little in the 232 pages about austere alternatives like repurposing existing, empty buildings; open and brown field land being re-purposed for food production; dealing with the possible truncation, delay or cancelling of Crossrail; dealing with the realities of ‘localisation’ taking over from failing globalisation; and the possibility of property developers going bust or not being able to raise the cash to build their tower blocks. .

The key test posed for effectiveness is:

(Is the LDF) ‘deliverable’?

Peak Oil – the point at which oil production globally reaches its highest point and thereafter declines – was reached in 2008. By 2015 shortages of oil and natural gas are widely expected to limit economic growth. The UK and Ealing are heavily dependent on oil. This LDF will consume enormous energy in building and running these tower blocks. This energy may not be available in the decades to come.

Very few people want ‘Landmark’ tall residential buildings. The opposition to Dickens Yard and Arcadia has been massive. 1,000s of local residents have opposed these ‘big’ developments over and over again for two years – and will surely continue to do so.

Another effectiveness test is: ‘Sound infrastructure delivery planning’:

I live in West Ealing. In February 2009 I responded to Ealing Council’s plans to expand Primary School places by researching the current and projected numbers of Primary age children in West Ealing and the current and planned State School capacities. Using the Council’s, ONS’s and the NHS’s figures I calculated that in 2014, 185 children of Reception Class age would not get places at Fielding, Drayton Green or Hathaway. No-one disputed these figures. We need to build another State Primary School in West Ealing. Where will it be built? When will it be built? The Ealing LDF 232 page, eight document set s contain no details at all. This is but one small example of a failure in ‘sound infrastructure delivery planning’.

Eric Leach
16th September, 2009

Ealing’s Local Development Framework, 14th September 2009

More reports are coming in about residents failing to obtain copies of the eight document 232 page Ealing LDF 2009 Core Strategy. A local West Ealing residents’ group Secretary read the statutory advertisement in the Ealing Gazette and drove over to Hanwell Library on Saturday morning just to look at the LDF documents. The lady in reception in the library had no knowledge whatsoever of the LDF documents and the resident left empty handed. She tried again today at Perceval House. She was allocated a ticket and sat and waited in the ‘Environment’ queue for an hour. At this point she got a little irritated and interrupted one of the Customer Service personnel. Eventually the resident was shown the 232 pages of LDF papers and told to go to a nearby room and study the documents. She said that didn’t work for her as she wanted to purchase a set of documents so she could review the 232 pages at home. The Customer Service lady telephoned Planning but got no answer, so our residents’ group Secretary left Perceval House empty handed – yet again.

Is this incompetence by Ealing Council or is this a planned process so that residents won’t get to read the LDF documents? Under the banner of ‘PLANNING AND COMPULSORY PURCHASE ACT 2004’ the statutory advertisement in the 4th September 2009 issue of the Ealing Gazette states ‘Copies can be obtained from the Council’s reception area…’ ‘There is a charge for some documents’. This statement is patently untrue and as such it suggests that Ealing Council is breaking the law.

It’s interesting to speculate that the Arcadia Planning Application (applying to just over 4 acres) period of Public Consultation was 90 days. However for the planning of 20+ square miles of Ealing borough – for half a generation – Ealing Council allocates just 42 days.

It will also be interesting to see what the residents of Greenford make of Ealing Council’s 2011 to 2026 spatial plans at a Greenford Area Meeting in Greenford Town Hall on Wednesday 16th September starting at 7:00pm. I wonder how many of the 40,000 Greenford residents know about the meeting; how many have read the eight LDF documents; and how many will turn up on the night? I’ll certainly attend and find out what residents think of the plans and the meeting itself.

Eric Leach
14th September, 2009

Diane’s view on the LDF meeting – 9th September 2009

Regarding the meeting on Wednesday I have similar views to David; I wasn’t going to walk away from the situation and thought I may as well make the best of my time there. Most of our session was spent explaining stuff to us which we then commented on. I thought our group was very reasonable and actually enjoyed working with them unlike other occasions when the people drove me insane with their silly suggestions and harping back to the old days (yawn) I do struggle with why we were not given copies of all these documents; I cannot print them at home due to the colour maps and the length of the documents so it means me either trying to read on my laptop which I don’t like doing or sneaking the printing in at work (not too difficult if I have the time)

Regarding Sarah’s idea of engaging this lot, I truly believe we have tried this approach and we have also had a successful meeting with our own yellow stickies (way before the councils!) with all the feedback going to the council. I just don’t think Brendan Walsh and Lucy Taylor are that interested in us anymore – not sure if it is a time thing or can’t be bothered. The more I think about it the more I think the consultation is a sham. I also think that 6 weeks is NO time at all to respond to a plan that will last for at least 15 years.

WEN Committee Member

Sarah’s view on the LDF Meeting – 9th September 2009

Like the others, because I hadn’t read the proposals prior to the meeting, I felt it could never be a meaningful consultation.

I certainly plan to read the proposals and give some feedback to the council, but was wondering how WEN go about commenting on proposals, i.e. do you all do it separately, or do you make a collective response?

Gill made the point last Saturday that it’s a shame WEN don’t have a much better working relationship with the council, and in the organisation of LDF consultations I can see how this has evolved. Would it be worth approaching the team from Wednesday night, to say as much and suggest a way of forging a better relationship might be to meet with WEN (once we’ve had a chance to look over things and formulate our ideas)?

I’m aware that this might seem a little naive of me, but the alternative is to continue very much in the spirit of a battle, whereas creating a better relationship with individuals may if nothing else enable us to find out exactly where and who exerts certain pressures, so that WEN could focus it’s energies more efficiently. The council evidently want all responses to follow Wednesday’s consultation using their response forms, however as it fell short of our needs and the council claim to be committed to working with the public, a meeting would enable them to either demonstrate their commitment or further prove they are merely ticking a bureaucratic box (which if this is their response would further feelings of animosity). If they really do want meaningful feedback we could get questions answered and make more meaningful comments, which would ultimately save them time and lead to a better quality of response. Just an idea…

WEN Committee member

Ealing’s Local Development Framework, 10th September 2009

To my astonishment I learn this morning that attendees at the first so-called Ealing LDF Public Consultation meeting last night were not given copies of the eight Ealing LDF September 2009 documents which I obtained on 8th September. When I walked out at 7:50pm last night I saw lots of cardboard boxes at the back of the room and one of the boxes contained document 2. (see below) in the Ealing LDF September 2009 document set.

The documents in the Ealing LDF September 2009 document set are:

1. 2026 Development Proposals: Development Strategy: Initial Proposals: September 2009. 1st September, 2009. (66 pages).
2.Developement Management: Policy Document: Issues and Options: Delivering EALING 2026: Development Strategy. 3rd September, 2009. (67 pages).
3. Backgound Paper 1: Population &Household Projections. Undated. (20 pages).
4. Backgound Paper 2: Ealing’s Economy. Undated. (9 pages).
5. Background Paper 3: Housing. Undated. (27 pages)
6. Background Paer 4. Infrastructure Planning & Delivery. Undated. (7 pages).
7. Background Paper 5. Community Consultations &Evidence Base Audit Trail. Undated. (15 pages).
8. COMMENT FORM: 4th September to 16th October 2009. (21 pages).

In order to participate in the public consultation you’ll need a legible copy of these documents. Printing out 232 pages of text and coloured maps from the Council’s web site, especially with a black and white printer, will be tedious. I recommend you go to Perceval House and search out Ian Weeks in Planning and acquire a document set from him.

The fact that the event organisers couldn’t be bothered to make up document sets for each of the attendees is extremely worrying. Wasn’t there time to do this? Possibly because the documents had only just arrived from the printers? Or perhaps staff had been instructed not to hand out the documents.

Sometimes I get the distinct impression that Ealing Council doesn’t want a rich, open debate with residents about Ealing’s future. Rather the Council wants to go through the absolute minimum of process so that it can convince the Government’s Planning Inspectorate in Bristol that it has ‘done’ public consultation.

Eric Leach
10th September, 2009

Ealing’s Local Development Framework, 9th September 2009

Ealing’s Local Development Framework (LDF) is a statutory planning requirement for the future of Ealing. Local Authorities all over the UK are at various stages of implementing their LDFs, which in Ealing’s case will replace its UDP as the planning ‘bible’ for Ealing in 2013 – for the years 2011 to 2026.

The most important LDF document is the local authority’s LDF Core Strategy. This document, when approved by the Government, will determine what will stay the same and what will change and where throughout the whole of Ealing over the nect 17 years.Ealing published – but didn’t publicise – its draft Core Strategy on its web site at the beginning of September 2009. Hard copies of the drafts were no doubt handed out to attendees as they left Ealing’s first of four LDF Core Public Consultation meetings held in Ealing Town Hall on 9th September 2009.

For a town of over 300,000 residents, whose five central Wards number around 75,000 residents, the turn out for this meeting was small – in fact much less than 100 people. However this is hardly surprising as Ealing Council carried out no significant or effective pre-meeting publicity. No information appeared on the Council’s web site home page; and a very small item was buried away in September’s, Ealing Council ‘Around Ealing ‘monthly magazine which plopped through my letterbox on 4th September. Residents’ groups and community groups received letters about the meeting less than one week before the meeting.

I attempted to obtain a copy of the LDF Core Strategy prior to the meeting so that I could make useful use of my time at the meeting. Ealing Council paid for an advertisement in the 4th September 2009 issue of the ‘Ealing Gazette’. The advertisement was entitled ‘Ealing’s Local Development Framework’. The text of the ad informed me that I could purchase copies of the Ealing LDF Core Strategy at Ealing Council’s Perceval House any weekday between 8:30am and 5:00pm.

On Tuesday 8th September I duly turned up at Perceval House at 8:30am only to find the building locked. Onlookers told me that the building never opened till 9:00am. Infuriated I went for a coffee and returned at 9:00am only to find over 20 people queuing being supervised by FOUR uniformed staff, who only allowed four people at a time into Reception. The Receptionist had never heard of the LDF and neither had Noreen the Customer Service operative in the internal Blue Zone in the Customer Services Centre. Noreen telephoned the Planning Department but no-one answered. Noreen did find a box of photocopied LDF documents which she said I could read but not take away. I left Noreen my card and told her I’d be back in 90 minutes. An hour later Ian Weeks of Planning called me on my mobile phone He said that the printed copies of the LDF Core Strategy were not available as they were still at the printers. I got annoyed at that point and pointed out that the advertisement said that the documents were available. He said he’d do some photocopying. At 10:45am I re-entered Perceval House, dug out Noreen who gave me photocopies of the LDF document. I offered to pay her for the documents bit she declined to accept payment.

Over the next 30 hours I studied the documents and drafted over 20 questions I wanted answers to at the 9th September Public Consultation meeting.

At 6:55pm on Wednesday 9th September I arrived at the LDF Public Consultation meeting in Ealing Town Hall. To my horror the room I found that the room was set up as a number of workshop round tables. Ealing Council Interim Planning Policy Manager Steve Barton delivered a quite short but competent overview of the LDF process. He explained that each of the residents would sit in a different LDF Workshop discussion. Richard Chilton, a local resident, raised a point about the scope of the issues and was told that there would be no ‘full audience’ questions – or answers. Will French, another local resident, told the assembled crowd that he wanted to take part in all the different workshops. Steve ruefully told him from the platform that he either joined one workshop or departed. I’m not sure what Will did but at that point I departed.

To ask residents to take part in round table workshop discussions on a 68 page Ealing LDF Core Strategy which they almost certainly have not seen or had chance to study is both stupid and a waste of rate payers’ time and money.

Of the 21 Ward Councillors in the five inner Ealing centre wards of Walpole, Elthorne, Ealing Common, Hanger Hill, and Ealing Broadway – I only saw three of them at the meeting. The Council Leader and the Council’s Chief Executive also did not attend. Aileen Jones the head of Planning was also a no-show. I think that tells us all how interested they all are about the future of Ealing.

There are three more of these meetings taking place around over the next three weeks in Greenford, Acton and Southall. I’ll attend all of them all and report on what happens at them.

I’ve studied the Government’s guidance on LDF Core Strategy Public Consultation and Ealing Council’s performance so far would not find favour with the Government’s Planning Inspectorate in Bristol.

Eric Leach,

9th September, 2009