Advice from English Heritage - 21 December 2007


Request for Pre-application Advice

Thank you for consulting us over the plans for the above site.   On the basis of the latest information about the proposals, received by us on 28 September 2007 and detailed below, I offer the following advice.


The site is currently fully developed, and the application therefore includes demolition of a number of unlisted buildings within the Ealing Town Centre conservation area. The site also borders the Haven Green Conservation area. The redevelopment proposals for this mixed-use & residential scheme include 6 buildings ranging in height from part 2 to part 40 stories, with the majority of the mid-rise between approx. 9 - 15 stories. The 40 storey tower is building F. The proposals include bridging over the railway tracks  

The site comprises a mixed group of buildings and structures, some of historic origin but none which are of special interest beyond their townscape quality.

A number of buildings would be considered as of townscape quality, and as making a positive contribution to the character or appearance of the Ealing town centre conservation area (although the adopted Conservation Area appraisal does not discuss individual buildings in detail.) Similarly, the historic plot-widths and traditional urban grain has historic merit, and usual conservation area practice would be to respect these delineations.

On balance it is understood that the redevelopment of this site would be critical to the regeneration of Ealing town centre, which would have a positive impact upon the wider area. With the above in mind, English Heritage would, in this instance, raise no objection to the conservation area consent for demolition, providing that an agreed scheme for the site were in place.

The proposed scheme under consideration raises serious concerns regarding the form, scale and style of development for this site.

In summary English Heritage strongly object to the proposal, and the impact upon the character or appearance of the conservation areas and the wider historic environment.

English Heritage Advice

The principle consideration is of the quantum of development proposed on site. This is obviously dominated by the 40 storey tower, but further concern regarding the mid-rise residential finger blocks that form the bulk of the scheme is expressed. The mid-rise blocks themselves are significantly taller than the established building heights of Ealing Town Centre, rising from 6 to an unprecedented15 stories. Both the tower and the mid-rise elements would be out of keeping with the established scale of Ealing town centre, and would earmark a significant change for the character of the conservation area, and the perception of Ealing as a suburban centre - therefore not only impacting upon the physical place, but also the sense of place.

The impacts will be further felt well beyond the immediate environs of the town centre, given the bulk and, particularly, the scale of the proposals. They will impact upon long views of surrounding listed buildings, conservation areas and public open spaces.

The Grade II* church and the Grade II town hall are established local landmarks; the distinctive tower and spire standing taller that the immediate environs and thereby establishing their civic presence. The qualities of these listed buildings and their local distinctiveness would be severely altered by the proposed scheme. 

It is considered that insufficient weight has been attached to the intrusive impact of the scheme upon the wider historic environment - the view of the garden front of Grade I listed Pitshanger Manor is in particular noted as a view that is not discussed within the submitted application, and conservation areas further afield are neither mapped nor discussed.

Policy Framework

There is no local policy regarding the siting of tall buildings within development plan documentation for the London Borough of Ealing. A plan-led approach is therefore not possible, and the assessment must be made in relation to CABE/EH guidance on tall buildings, July 2007, and the London Plan.

The CABE/EH guidance stresses the importance of the ‘relationship to context’ (4.1.1.) and the ‘effect on the historic context’ (4.1.2.)

It is considered that the proposed development fails to bear a close relationship with either the local context or the historic context. The design could be applied to any location, and the scale - not only of the large tower, but also of the mid-rise development - does not relate either to the established scale or character of the context. 

It is therefore considered that the ‘effect on the local environment’ (4.1.9.) would be detrimental.

Other criteria are successfully addressed; issues such as architectural quality and the benefits to urban design permeability have undoubtebly been well considered. However, EH maintain that the impact of this scheme would cause detriment to the established local and historic context of Ealing.

The London Plan

Any tall building applications will be assessed in line with policies including:

 -  4B.1 (Design principles for a compact city) which states that, amongst other criteria, applications should: “Respect local context, character and communities, and respect London’s Built Heritage.” It is considered that the proposed scheme fails to respect both the local context and the local built heritage, and therefore does not stand-up to these assessment criteria. Additionally:

 -  4B.7 (Respect local context and communities) and,

 -  4B.10 (London’s Built Heritage). It is considered that the proposed scheme is contrary to both of these policies.

In summary of policy consideration, concern is expressed regarding two principle concerns: the impact of the development upon the historic environment, and the lack of relationship to the established character, wherein it is considered that the scale of the development is significantly out of keeping with the established suburban character of Ealing.

Concern is also expressed regards the impact of these proposals upon Ealing in the longer term. CABE/EH guidance discusses (in section 4.1.1.) the virtue of clusters of tall buildings. The proposed development would materially change the character of Ealing, with mid-rise development and one significant tall building. This would have major impact upon the future of the area, setting an out-of-context precedent for similar scale development. Much importance is attached in the above quoted guidance, and in PPS1, to tall buildings being situated in the right location. Given the lack of precedent and the established suburban character, it is considered that this is the wrong location for a development of this scale.


The applicant is advised that EH recommend strong objection to this proposal on the grounds of its inappropriate scale, lack of contextual relation to the established character of the immediate area, its impact upon the wider historic environment, (particularly in relation to the setting of listed buildings and the character and appearance of conservation areas,) and the detrimental impact that would be imposed upon the established sense of place in Ealing.

The proposed development does not meet all of the criteria in the London Plan, or in CABE/EH guidance on tall buildings. As such, the local authority are advised to recommend refusal for planning permission, and refusal of conservation area consent for the demolition of buildings on the site in the absence of an appropriate scheme for redevelopment.