A response to the Report to Chiswick Area Committee

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By the applicant, London & Bath and Galliard

The report to committee should be for information purposes only, to highlight issues about a scheme and it does not make a recommendation. It should provide a balanced description. However in this instance the applicant believes the report presents a particularly one sided view and does not provide a balanced assessment.

As such this note has been prepared to offer some general comments to redress the balance. To keep the note short not all points raised in the report have been taken up.

Description of area The report suggests that the site is situated in the middle of a leafy suburb. While it is acknowledged that there are wonderful residential and sensitive areas
further afield, the immediate environs of the site are highly mixed commercial and low quality, characterised by the buttress walls of the motorway, the B&Q car park and store, industrial buildings, car showrooms and carwash etc.

Furthermore it is clearly situated within the A4/M4 commercial corridor, which is
home to numerous major businesses including Glaxo, Worley Parsons, EMC and others. The report suggests that the Golden Mile was a feature of a bygone era only, and makes no mention of the Council’s objective to reinvigorate commercial activity within the area.

Height

At 52 metres the current proposal is shorter than the 59 metre tall proposal already approved by Hounslow for this site. Furthermore the upper section of the building, which would be most visible in any view of the building, tapers to a narrow point, whereas the consented scheme rises to its full 60 metres width.

By contrast, we are less than half the height of the Pinnacle proposal which at a height of 120 metres caused some concern years ago. We are also significantly shorter than the 85 metre tower Hounslow only recently approved for the Barratts redevelopment of the old Beechams estate.

Our nearest neighbour, Vantage West, is 50 metres tall (incorrectly stated at 40 metres in the report), and there are numerous buildings in the locality which are either taller or similar in height – Glaxo HQ (73m), Great West House (63m), Alfa Laval (49m), Wallis House (40m), the Haverfield Estate towers (65m), the Steam Museum chimney (50m), BSi tower (64m), 414 Chiswick High Road (41m), to name but a few.

Visual Impact

The report makes frequent reference to Kew Gardens and clearly infers that the
proposal will impact upon it.

The report neglects to mention that expert evidence has been submitted which establishes that the proposal cannot be seen from Kew Gardens, which is more than 1km away at its nearest point - it is thus completely unaffected.

All other references to visual impact in the report are exaggerated. The expert evidence provided, including visually verified images, establishes that the proposal will have negligible impact on Gunnersbury Park and the Thorney Hedge Road and Wellesley Road Conservation Areas. The proposal will have virtually no impact on Strand on the Green or Kew Bridge Conservation Areas.

The impression given by the report is that the scheme will have a visual impact over a wide area including several conservation areas. This is not the case.

Visually verified views have been submitted to support this statement. However this evidence has been ignored and misrepresented in the report.

Furthermore, at no time prior to or following the submission of the planning application, has the case officer requested any additional information on visual impact or for anything by way of further detail or clarification.

Planning History

The site has a history of tall and large office buildings being approved. The 59m
tall, 200,000 square foot Citadel scheme which was implemented in 2008, was a
revision of a similar scheme consented in 2002.

Even the 120m tall, 250,000 square foot Pinnacle scheme was approved by
Hounslow in 2000, although the application was withdrawn following its ‘call in’ by
the Secretary of State.

The report places an over-reliance upon the 41m tall proposal with screens
(refused under delegated powers and by any committee) that was then dismissed
on appeal in 2006. The primary reason for its dismissal was that the Inspector
considered the design of the building to be of insufficient quality.

In direct response to this criticism new architects were appointed. The architects
for the current proposal, MAKE Architects, are acknowledged to be a world
leading practice, headed up by Ken Shuttleworth who designed the Gherkin.
I would respectfully suggest that the number of modern buildings in the Borough,
designed by world leading architects, is quite small.

As regards the planning history of the advertisements on site, this too has been
distorted with the report.

There have been advertisements, including at motorway level, on this site for
decades - most have had consent at some time. Consent was granted on appeal
for high level advertisements in 2003 contrary to what is stated in the report
When, in 2008 and 2009, applications for motorway level towers were dismissed
on Appeal, it was not for any highway safety reason but because the Inspector
thought that the scaffold or pole type towers proposed were of poor quality, and
potentially harmful to visual amenity.

The quality of the design of the screens now proposed, and the supporting
structure (which comprises the building), is now so vastly different and superior,
it doesn’t bear comparison.

I would add that the nine screens on site today, including one LED screen (also
not referred to in the report), all have consent and that their overall display area
is similar to the total area of the screens now proposed.

LEDs and lighting

At the time of the submission of the ‘2006 proposal’ LED screens were novel, and
there were none being used for advertisements in the Borough or anywhere else
nearby.

Since then, LED screens have been approved on this site, on the Torch tower by
B&Q, at 1053 Great West Road and elsewhere in the Borough.

If one considers the numerous LED screens by the Hammersmith flyover and by
Holland Park roundabout, and elsewhere around London, it can be seen that LED
screens have become customary and accepted.

Early version LED screens such as those on the Torch, tend to be either on or off.
More modern screens include the facility to be dimmed at night and matched to
the prevailing ambient light conditions so that their degree of luminance is not
excessive.

In effect the LED screens will appear no brighter at any time of day than the
traditional backlit vinyl screens which are commonplace. At night they will be
dimmed. However, LEDs have the advantage that they can be individually set
into ‘cups’ and shielded, so that the ‘cone of vision’ can be limited to a much
tighter area than is the case with traditional backlit vinyl screens or with front
screens such as the shroud on the Alfa Laval tower.

All of this information was submitted as part of the application, but none of it has
been included in the report to committee.

Furthermore, the luminance of the screens would be covered by condition to
comply with standards in the UDP and the ILE Institute of Lighting Engineers
guidance.

Highway Safety

In the report there is an over-reliance upon the objection of the Highway Agency,
who for the last several years has always been represented by the same one
officer.

The HAg officer has submitted a standard ‘blanket’ objection to all advertisement
proposals alongside the elevated M4 motorway.

On two occasions his evidence has been dismissed by Inspectors, in connection
with the subject site, and on a third occasion in 2009 he withdraw his objection
on the opening day of the hearing.

On at least eight other occasions his evidence has been dismissed by Inspectors
on other advertisements alongside the elevated M4 (the Torch, the Foster tower,
1053 GWR and others). In virtually every instance where the appeal has been
considered at a hearing, rather than by way of written reps, the evidence of the HAg has been dismissed by Inspectors.

In 2009, in the case of the advertisements on the shroud on the Alfa Laval
building, which are similar in size but unlike the design of the current proposal,
LB Hounslow itself chose to ignore the objection of the Highway Agency.

In terms of highway safety, the subject site is in a far better position than most
other consented advertisements alongside the elevated M4. There is a long
stretch of straight roadway in either direction from the site, we are some distance
from any junction, and there is no conflict with any directional signage.

In March 2008, when considering motorway level advertisements on this site, the
Inspector concluded, “I therefore find that the proposals do not harm public
safety. There is no breach of saved policy T.4.4 on road safety or policy ENVB.
1.4 in this respect”

TfL (Transport for London) have carefully considered the application and have
raised no objection. We accept the conditions they have proposed.

Design

Whilst the design of the Citadel, and other previous proposals, was of high
quality, the design of the current proposal is altogether in a different and
exceptional league.

The current architects were charged with the objective of producing a landmark
design which would bear comparison with, if not outshine, landmarks across
London including all those now being built in east London in preparation for the
Olympics.

The design had to be memorable and worthy of its position alongside the most
important route into one world’s greatest capital cities.

The GLA have commented as part of their positive stage one response, “Whilst
this is an unusual development, it is an excellent response to the site context of a
roundabout and elevated urban motorway. It provides a unique landmark, worthy
of serving as a gateway to London”.

This view by the GLA accords with LB Hounslow’s policy BAAP2 which seeks high
quality and innovative designs at this gateway location, but it is also not referred
to in the report to committee.

Evidence was also submitted on the stimulus to the prestige of the locality and to
the local economy, but this was omitted from the report to committee.

We have received widespread support, including from the London Mayor and from
the West Chiswick and Gunnersbury Society, but this too was omitted from the
report to committee. No reference is made to the consultation exercise
undertaken that generally supported the proposals.

Conclusion

The report submitted to committee contains errors and omissions, and it gives a
highly selective and prejudicial view.

Any careful and objective analysis of the planning history of the site, and of the
extensive expertly-prepared material for the current application would reveal:

• The principle of a large scale landmark-style development has long been
established and supported by Hounslow.
• The proposal is smaller in height, size and volume, than a scheme which
Hounslow has already approved.
• Considerable design and technical expertise has been applied to controlling
light from the proposal, and it will meet guidance contained in the UDP
and the Institute for Lighting Engineers
• There is no evidence that adverts at this location would lead to concerns
regarding highway safety and Inspectors have accepted this at recent
appeals.
• The proposal is by world class architects and will provide an appropriate
London landmark at this gateway site.
• The proposal accords with LB Hounslow policies to promote urban
regeneration, high quality architecture and economic activity.
• The GLA has given its support and endorsed the landmark quality of the
architecture.

It is natural that a design which is so unusual would cause debate. However, the
overwhelming response has been that this is a remarkable and exciting example
of modern architecture, and that it is something that should be supported.

It is hoped that you will share this view, and see that it has the potential to attain
international recognition, and to reinforce Hounslow’s rightful status in a modern
and vibrant city, particularly at the time of the London Olympics.

January 18, 2010