This response is from the Churchfield Community Association (CCA), whose members include residents and businesses in Churchfield Road W3 and the surrounding area. The CCA aims to improve the lives of those who reside, work and/or shop in and around Churchfield Road and to enhance the economy and environment of this area in partnership with local statutory and voluntary organisations.
While the CCA does not think that the current use of The Oaks area is optimal and agrees that it is ripe for redevelopment, it believes that this redevelopment should be carefully and holistically done, in the interests of both the public and any commercial ventures that might establish themselves there. Any proposals should be proportionate and should enhance rather inhibit the development of Acton in general and Churchfield Road in particular as a thriving, mixed community of residents, retailers and businesses. We do not believe that this, revised, proposal from the
Acton Regeneration Company (ARC) does this and would urge the Planning
Committee to reject it on the following grounds.
According to the Development Plan Document EDS3, any plans for Acton 'should better integrate the town centre itself'. They should provide: a revitalised town centre, attractive and good quality public realm, improve accessibility, movement and linkages within Acton Town Centre … [There should be the] creation of better pedestrian north–south linkages between
Churchfield Road and the High Street.
In addition, in the recently (6 August 2013) updated EDS3, it says:
Development of the site must support the urban design objectives for the site as a whole, requiring a comprehensive masterplan that realises the full potential of the site. A piecemeal approach to development that does not contribute to delivery of a cohesive scheme for the site as a whole is not acceptable.
However, the ARC proposes to erect a massive 142-unit gated community above an underground supermarket and a multi-storey car park – on a site that is universally agreed to be at the heart of Acton. There may be an external amenity for future residents of this community, but it is private and built on top of the car park block.
The proposed public 'walkway' that the ARC insists is a route leading to the High
Street actually ends with a drop down into the proposed supermarket and an exit through the commercial arcade of shops. This walkway will be closed at night.

The main problem seems to be that this is a supermarket-led development, with the added difficulty of the ARC's insistence on putting the proposed supermarket underground with car parking on top. This severely limits any flexibility in design so that the site can be opened up to the public. It also makes the commercial success of the site rest on the viability of the supermarket – if this were to pull out, the site could quickly become derelict, as happened with the 'Precinct' on the same site in the 1970s and '80s. One of the main reasons why Acton, unlike Ealing, has not been negatively affected by the arrival of Westfield is the fact that it consists of mainly
SMEs. Surely a more varied retail offer than a supermarket would be economically more dependable and more in keeping with what already exists in Acton?
Other recent developments in the hearts of town centres (Regent Quarter at King's
Cross, Liverpool One on Merseyside, for instance) manage to combine residential and shopping/business areas without excluding the public from access to open spaces, squares and thoroughfares. The ARC's proposals, in contrast, are highly controlling of the local population’s access and amenity. It plans to erect a development in the middle of our community and then exclude us from it. This is unacceptable. The original specification required a through route and a development that would enhance the community. These proposals offer neither.
It is the CCA's opinion that ARC's proposals for this overwhelming construction and inadequate linking of Churchfield Road and the High Street will actually hinder any revitalisation that this sort of regeneration is intended to do, will reduce accessibility, movement and linkages between the two parts of Acton, will present an impenetrable barrier to the world outside the gated community and do not represent either a 'comprehensive masterplan' or a 'cohesive scheme for the site as a whole'.
Height, density and mass These aspects of the proposed building are totally out of context with the surrounding area. The nine-storey tower will dominate the townscape wholly – even taking into account the proposal to recess the top floors. It is out of proportion in an area where the tallest building is the spire of St Mary’s
Church.
The whole development is over-large for the space. The CCA had hoped that, if the
ARC were sold the council car park to use as part of the development, their plans would become less dense and massive and offer more community access. This remains our preference, but in fact, the ARC now propose greater density. Given that the developers own the existing Oaks shopping centre, the rest of the car park and the building currently occupied by a succession of failing gyms, we do not understand why a coherent plan, at a lower density for this critical site in the centre of Acton, cannot be facilitated.
The proposed tower, especially now it has been relocated back on Churchfield Road, would dominate not just the newly regenerated road itself but also the residences in
Newburgh and Derwentwater roads opposite. Those living in these homes, many of

whom are members of the CCA, are wholly opposed to the imposition of a tower that will dominate and overshadow their houses.
This tower and the mass of the development will also adversely affect the St Mary’s
Burial Ground – which will shrink into the shadow of a disproportionate block just next door.
We also understand that the ARC's proposals exceed the maximum allowable number of housing units per hectare, which is 260. The estimates that we have seen are either 311/hectare for the whole site or 480/hectare if only the residential part of the site is considered. These densities far exceed the allowable levels in the London
Plan. A previous proposal for this site was turned down partly because of its density, which was substantially less than the density of the present ARC plans.
Infrastructure
We do not believe that the infrastructure will be in place that will be able to cope with the finishing of this development.
• Traffic We are concerned about the increase in traffic if a major supermarket were to be located on the site. Both customers' cars and large delivery vehicles would have to access the site from the Horn Lane end of Churchfield Road. This junction is already heavily used by pedestrians – indeed, the council lowered the pavement level to increase footfall – so that there is a greater likelihood of traffic accidents, plus the fact that this corner is fairly sharp, making it quite difficult for large lorries to negotiate it safely. Will the developers be contributing (through
S106/CIL money) to transport improvements?
• Schools Acton's schools are full to overflowing at the moment and for the foreseeable future. The developers say that, by their reckoning, under 30 children will be living in The Oaks units. However, of the 142 residential units planned by the
ARC, 50 are 2-bedroom, 39 are 3-bedroom and 1 is 4-bedroom. If you assume
(which we think is reasonable) that one bedroom would be for the owner, it is likely that any others would or could be occupied by children. If these children occupied bedrooms on their own, that would result in a maximum of 131 children (50x1 +
39x2 + 3). The developers say that they are willing to contribute S106/CIL money, but where would this be spent? All the extra places have been filled – 'temporary' huts at Derwentwater School, the 'reactivating' of The Priory Centre into a school, etc. Even Toby Young was unable to find premises for his 'free school' in Acton.
• Water supply According to recent changes to the Development Plan Document
EDS3, Thames Water has identified a potential need to improve water supply capability and waste water services in relation to this site. The developers do not to appear to have produced a strategy to deal with this.
'Affordable' vs. 'social' housing The CCA welcomes the proposal to make some
22% of the residential units 100% shared ownership and so 'affordable'. However, with the availability of Home Buy and Help to Buy shared ownership, this is not a priority now. What Acton desperately needs are residences available at a social rent rather than to be bought at an 'affordable' price. One of the best things about Acton

is its mix – race, religion, ethnicity and economic status. Without building in social housing of some sort, we are in effect making the town impossible for any but the affluent to live here in the future.
The CCA does not think the developers have adequately addressed either the community’s concerns or those expressed in Ealing’s response to their plans in late
2012. The changes they have since made seem to be largely cosmetic and do not address the fundamental problems of this scheme.
The CCA notes that in the Addendum Design & Access Statement (pdf), at point 2.9, the developers say:
Three meetings have taken place with the CCA since the application was submitted to discuss the original proposals, together with revisions.
Comments that have been received from the CCA broadly follow those outlined in 2.4 (above) and have informed the revised design. The revised
Design and Access Statement outlines the changes to the scheme that have been presented and discussed with the CCA since the application was submitted.
The comments outlined in 2.4 were about the scale and massing, the tower, the screen that was once proposed to cover the building, the overshadowing and overlooking of existing properties, the relevance of the Churchfield Road elevation to the area and the impact of the proposal on the conservation area.
Nowhere does this statement mention anything about the CCA’s repeated criticism of the development as a massive gated community in the heart of Acton and our desire for a road or, at the least, a substantial path (open all hours) down to the High
Street – as was originally required in the Council’s own specification for the development.
This statement also fails to make it clear that, at every stage, the CCA has opposed the tower concept in its entirety and specifically when massed and ranged on
Churchfield Road itself where it is wholly out of proportion to the surrounding townscape.
The CCA feels that, in not mentioning any of our objections, the developers are seriously misrepresenting us and that their claim to have consulted the local community should therefore be treated with some scepticism.
We would urge the Planning Committee to reject this proposal and ask the developers to look at the site more holistically with a view to providing a development that will enhance rather than loom over our community. We would be more than happy to work closely with the ARC or any other developer to make this happen.

For CCA members
You can send your own objections to the council on this web page: http://www.pam.ealing.gov.uk/portal/servlets/PlanningComments?REFNO
=PP/2012/3154