Our response to Ealing Council’s Reg 19 Local Plan Consultation
Brent River & Canal Society (BRCS) welcomes the opportunity to feed back on the Reg 19 draft of Ealing’s Local Plan and we submit the following comments together with our suggestions for improvements. BRCS is prepared to work with the Council to discuss and develop these modifications prior to the Inquiry so that an agreed version can be put before the Inspector. All comments and suggestions made below that are not resolved before the plan goes to the Inspector are to be taken as objections. BRCS is willing to be called upon by the Inspector during the examination stage of the process to provide evidence to support our objections.
Green and Blue Environment – National and Regional Policy
BRCS believes that the plan is fundamentally unsound because the reports within it are too heavily weighted towards housing and the built environment. Insufficient weight is given to Ealing’s green and blue environment and biodiversity and key reports that should underpin open spaces policies are incomplete or missing. Ealing has not produced or updated crucial strategies and plans that it has committed to or has a statutory duty to do, as detailed below.
Because of this missing or incomplete information, the plan fails the test of soundness in the following key areas:
It does not meet the requirements of National Planning Policy Framework 14 – Meeting the challenge of climate change, flooding and coastal change. In particular the Council has not met its obligations to consider the effects of its proposed changes to Green Belt (GB) and Metropolitan Open Land (MOL) boundaries with regard to directing development away from areas of higher flood risk and of not increasing the risk of flooding elsewhere.
It does not meet the requirements of National Planning Policy Framework 15 – Conserving and enhancing the natural environment. The Council has not met its obligations to consider the effects of proposed changes to GB and MOL boundaries with regard to protecting and enhancing valued landscapes and sites of biodiversity. Nor does the plan consider improving public access to, between and within these areas. It does not minimise impacts on or provide net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. There is no strategic approach to maintaining and enhancing networks of habitats and green infrastructure and no plan for enhancement at a catchment or landscape scale across boundaries with neighbouring Boroughs. The Council has not properly updated its identification and mapping of local wildlife-rich habitats and wider ecological networks, wildlife corridors and the stepping stones that connect them. Despite committing to do so in the 2022 Biodiversity Action Plan (BAP), the Council has not set up consultation with national and local partners to identify areas for habitat management, enhancement, restoration or creation.
It neglects both the London Mayor’s commitment to make more than half of London green by 2050 (London Plan 8.1.3) and the Government’s commitment to protect 30% of land for nature by 2030. The government intends to halt and reverse biodiversity loss and to become nature positive by 2030 and the Local Plan, which covers most of this time period, must be able to deliver this. BRCS in its response to the Reg 18 draft suggested expansion of the Nature Conservation Management Areas (NCMA’s) shown in Ealing’s 2004 Plan for the Environment which could include significant new areas of open spaces being designated as MOL. BRCS also proposed that the suggested Masterplans (now referred to as Development Sites) for the redevelopment of brownfield sites should require the restoration of at least 30% of the total ground area to natural green space. Such green space should be separated from any adjacent multi-storey buildings by the use of adequate buffer zones. The use of masterplans for Development Sites is an opportunity for a local departure from the minimum requirements of the London Plan for Urban Greening (G5) to achieve more and better greening on such sites than might be obtained under the London Plan alone. The Reg 19 draft proposes some greening in its Development Site plans but this is not quantified and may not even be on the same site. To be sound, the Local Plan needs to have a minimum metric for new green space for each Development Site.
Biodiversity and Climate Change
The Reg 19 draft does not take account of key planning issues stemming from Ealing’s Biodiversity Action Plans (2001 & 2022) delivery of which is fundamental to the Council’s statutory biodiversity duties and to fulfilling its Climate and Ecological Emergency Strategy (2021). In the 2022 BAP the Council committed to set up the Ealing Biodiversity Partnership to review the BAP each year and to promote actions within it. Ealing has yet to do so and has missed the first two annual reviews. The Reg 19 draft is unsound because the Council has consistently failed to consult with partners and to monitor or deliver its BAP policies or to integrate them into this Local Plan.
The 2022 BAP commits Ealing to produce an Ecological Networks Map but this has not been done. Ealing says that it will create an ecological network that operates more naturally and effectively needing more, bigger, better and joined-up sites. The Biodiversity Action plan (BAP) states ‘the Local Plan and council strategic documents will uphold the BAP vision, aims and Habitat and Species Action Plans through strengthened plan-making and decision-making policies and processes that require the protection, conservation and enhancement of biodiversity in Ealing’.
Since Ealing has yet to complete its Ecological Networks Map the Reg 19 draft fails the test of soundness in this regard. This map would inform in particular the designation of new MOL and the creation of new green corridors to extend and better connect existing sites. BRCS suggested such modifications in our Reg 18 response and we detail these in our submission on Nature Management Areas below.
The Ecological Networks Map is required to provide the foundation for the preparation of a Local Nature Recovery Strategy. Since Ealing has yet to complete its Local Nature Recovery Strategy (scheduled for 2025) the Reg 19 draft also fails the test of soundness in this regard.
SINC Review (overdue)
The Council has not carried out its long overdue review of Sites of Importance for Nature Conservation (SINC’s) as required by the London Plan (G6). The ‘Ealing Local Plan (Reg 19) Sites of Importance for Nature Conservation: Initial Report’ is not a SINC review and it is misleading to include it as if it is. The review process is laid down by the GLA and includes not just an evaluation of existing SINC’s but, amongst other things, the setting up of an expert panel and the consideration of any new sites which meet the SINC criteria. Ealing has not yet done this and is still one to two years away from finishing this process.
Since Ealing has yet to complete its SINC review the Reg 19 draft fails the test of soundness in this regard. It is known that some areas of GB or MOL proposed for de-designation already meet the criteria for SINC designation and would therefore be classified as such in the current review. Until this review is finalised, such de-designation proposals in the Reg 19 draft cannot be considered as based on sound evidence.
Green Space Strategy (overdue)
Ealing published its last Green Space Strategy in 2012. This was due for review in 2022/23 but this has not yet been done. Until this review is complete, de-designation proposals for open spaces in the Reg 19 draft cannot be considered as based on sound evidence.
Nature Management Areas
The Reg 19 draft does not identify any of the Borough’s Nature Conservation Management Areas as mapped in Ealing’s 2004 Plan for the Environment. All of these are still extant, and will necessarily form the basis of the Ecological Networks Map and Local Nature Recovery Strategy when these are prepared. In order to deliver national and local targets, the new Local Plan should map and protect all the existing NCMA’s and at the same time identify new ones and substantially extend and connect these areas. The term ‘Nature Management Areas’ (NMA’s) would be appropriate for these extended and new NCMA’s. BRCS suggested such modifications, see below, in our Reg 18 response. The Reg 19 draft cannot be considered sound unless it takes a proactive approach now by identifying and mapping areas to be set aside for nature management and recovery.
Ealing’s Regional Park
The Reg 19 draft refers to a proposed new Ealing Regional Park at SP2.2 but with no detail. In previous reviews of green spaces, the Brent River Park has been always been treated as a Regional Park. In it’s report ’A background to Ealing’s Parks and Open Spaces (Scrutiny Committee 1st July 2009) the BRP was described at 2.1.3 as ‘acting as a Regional Park’. Plans for the Regional Park are still at an early stage but the Council has indicated that it will include and link up at least two NCMA’s (the BRP and Horsenden Hill) into the RP.
Ealing’s proposed new RP is an opportunity significantly to raise the quality of open space provision in the Borough by improving connectivity between formerly isolated sites and setting higher standards for site management, staffing and infrastructure, particularly in improving public rights of way and access, signage and delivery of BAP targets through better site management and the creation of new green corridors. To be sound, the Local Plan needs to provide a coherent plan for what is to make up the RP and to include all six of the below suggested NMA’s in the RP.
Rights of Way Improvement Plan (overdue)
Ealing did not fulfil its statutory duty under S60 of the Countryside and Rights of Way Act 2000 to publish a Rights of Way Improvement Plan by November 2007 or to review that plan every 10 years. A network of public rights of way (of which Ealing has many) is key to accessing open spaces within the Borough, yet no consideration is given to such routes in the Reg 19 draft. Previous local plans mapped for example a network of proposed and existing footpaths within the Brent River Park, but these are not shown in this draft. Without a strategic approach based on evidence, the Reg 19 Plan is unsound because it has not properly considered public access to open space including in its proposed changes to GB and MOL boundaries. To be sound, a map showing all existing and proposed Rights of Way should be included in the Local Plan.
Requirement to manage, improve, protect and extend GB and MOL
A fundamental flaw of Ealing’s approach to the Reg 19 draft is that previous Local Plans (for example the 2004 Plan for the Environment Ch 3.1), the London Plan (1.2.6 & GG2.F, G1) and the Council’s Ecological & Emergency Strategy and Biodiversity Action Plans require the Council to manage, improve, protect and extend all MOL and Green Belt land within its custodianship, while these policies also require isolated sites to be connected into a network of green areas. Government has a wider target of setting aside 30% of the UK’s land area for biodiversity by 2030 and the London Mayor has committed to make more than half of London green by 2050. There is no part of the Reg 19 draft that attempts significantly to increase GB or MOL. Instead of seeking to improve, protect and extend GB and MOL the Reg 19 draft proposes deregistering underperforming sites. It is unsound in this regard as it does not carry through policies to manage, improve, protect and extend open spaces as is required by the London Plan (e.g. 8.2.2, 8.3.4, 8.4.3, 8.4.4) and its own local policies.
Enabling development
At 5.65 – 5.66 the Reg 19 draft proposes a local policy departure from the London Plan for enabling development. The draft and the Atlas of Change regards such enabling development in some circumstances as justifying a change in a site’s designation, for example by removing it from GB or MOL. The Reg 19 draft is unsound in this regard, as enabling development does not have to be carried out by releases of land from GB or MOL. It can and should be carried out by releases of Council land (as was done with for example Dickens Yard) that do not have open space designations. Development of green space is in direct conflict with the London Plan and with local strategies and policies.
Nature Management Areas
Ealing has not prepared an Ecological Networks Map or a Local Nature Recovery Strategy in time for the Reg 19 draft. In absence of these key strategies, to be sound, the Local Plan needs to bring forward proposals that do create an ecological network that will operate more naturally and effectively. This requires the inclusion of existing and potential new green sites into coherent designated Nature Management Areas and the creation of additional green corridors better to connect sites.
BRCS proposes 6 overarching NMA’s:
Brent River Park NMA
To include the existing NCMA and to extend it to include the MOL, SINC’s, Green Corridors and Parks at Osterley, Tentelow Lane, Norwood Green, Norwood Toplock and Glade Lane, Haslemere Wildlife Reserve, Blondin Park, Ravenor Park, Costons Allotments, railside land N of Greenford Halt, Ealing Central, Trailfinders, Gurnell Grove and Castlebar, Cuckoo Park and Littlejohn Field. Also to include the banks of the River Brent and the nature area at Manhatten Business Park to connect by footpath from the A40 at the Vanguard site into London Borough of Brent.
With the designation of green corridors to link in particular Ravenor Park to Stanhope PF and Southall Park along the Uxbridge Road to Dormers Wells.
Horsenden Hill NMA
To include the existing NCMA and to extend it to include Perivale Wood LNR with adjacent railside land, Paradise Field, Carr Road Nature Reserve with adjacent railside land, Grove Farm with Ealing Northern and Halsbury Road.
With the designation of a green corridor to link Grove Farm to Berkeley Fields.
Greenford & Northolt Park NMA
To include the two existing NCMA’s at Greenford & Northolt Countryside Park and to join and extend these to include the A40 corridor and all GB and MOL to the north with the Golf Range, Northolt Manor, Greenford Birch Wood and adjacent sports grounds, Litten LNR, the Grand Union Canal Green Corridor to the south with open land at Greenford Urban Village, Southall Cricket Club, King George’s Field, Durdans Park, Cranleigh Gardens and Spikes Bridge Park.
Yeading Valley Park NMA
To include the existing Lime Trees GC NCMA and to extend it to include all Green Belt land to the west including West London Shooting Grounds and Yeading Valley Park, south to Lime Trees Park, north to the BA Sports Ground, Islip Manor Fields, Lord Halsbury’s Memorial Field, the railside Green Corridor and Islip Manor Park and east along the A40 corridor and Northolt Academy.
North Circular Park NMA
To include the existing South Ealing Cemetery NCMA and to extend it by adding all open land along the A404, including Barons Pond and the Old Actonians Sports Ground, Popesfield, LRT railsides, Ealing Common, Hanger Lane and Woodland, Barclays Sports Ground and Pavilion, Hanger Hill Park, Fox Wood, Hanger Lane Gyratory and railside Green Corridor, former Guinness Mounds and Park Royal LRT railside land, Park Royal estate at Lakeside Drive and Twyford Abbey.
Acton Park NMA
To include the existing Acton Cemetery NCMA and to extend it to include the railside Green Corridors and the A40 corridor, North Acton Playing Fields, Great Western Allotments and adjacent schools sports areas, Twyford Avenue Sports Ground, Springfield, Acton Park and the MOL to the east including David Lloyd with the other sports grounds and allotments, Southfields Rec and the railside Green Corridor to Gunnersbury Triangle. In particular, masterplans for the redevelopment of industrial parks at Horn Lane and elsewhere should seek to connect open areas in Acton by the creation of new parks and green spaces.
Adopted Policies Map – Schedule of Proposed Changes
As noted above, Ealing has still to:
1) update its Green Space Strategy
2) publish its statutory Rights of Way Improvement Plan 3) carry out a review of and update its list of SINC’s
4) prepare an Ecological Networks Map
5) prepare a Local Nature Recovery Strategy
In light of these missing key strategies, any proposed removals of open space designations cannot be underpinned by proper evidence and are premature until such evidence can be taken into account. Additionally, in the reports it has presented, Ealing has not taken account of or given proper weight to the reasons such land was designated originally (in many cases the land usage is unchanged since designation) nor has it given regard to its obligations to manage, improve, protect and extend GB and MOL.
The Green Belt and Metropolitan Open Land Review report which is cited to support these removals does not adequately consider the benefits and justifications for MOL designation of sites. For example within the BRP, sites proposed for removal along Uxbridge Road (Map 9) in Southall are substantially in the same state as when the park was first created. Designation serves the purpose of maintaining the open nature of the park and views into it by limiting the type and height of structures even on Previously Developed Land (PDL). It can render available brownfield sites within NMA’s where future rewilding projects funded by BNG or CIL might realistically return land to open space usage, as for example was carried out at Fox Meadow, Hanwell (formerly an industrial site under concrete) and now a SINC approved for designation as part of a statutory Local Nature Reserve.
At Gurnell, within the BRP (Map 24), a substantial removal of MOL is proposed. Previous attempts to remove this area were refused by the London Mayor and there is little difference in the Council’s reasoning in the Reg 19 draft. The Council conducted a ‘Sounding Board’ process on its plans for Gurnell in which it consulted with many local groups including BRCS. All groups bar one signed a Minority Report after this process in which they disagreed with the Council’s proposals for a substantial housing development on the MOL and the removal without replacement of the largest visitor car park in the BRP. The Green Belt and Metropolitan Open Land Review does not mention the Minority Report or its content and refers erroneously to part of the site as PDL, even though it contains no built structures and is included in Ealing’s list of parks and open spaces, both precluding it from classification as PDL. Additionally, much of the site proposed for removal now meets the criteria for SINC designation and is likely to be reviewed as such in due course. MOL designation currently protects the flood plain of the River Brent at Gurnell and prevents existing housing at Peal Gardens from redevelopment with taller buildings that would overshadow meadowland to the north.
Also within the BRP, land (Map 25) is proposed for removal from MOL despite being identified in the initial RP consultation as part of the corridor connecting the Horsenden Hill and BRP NCMA’s. This is incompatible both with the Council’s policies to protect and connect green sites and its aspirations for a new RP.
At the boundary with London Borough of Brent (Map 26), the removal of a complete section of BRP MOL along the banks of the River Brent is proposed. This land forms part of a Borough Grade I SINC, is entirely within the flood plain and with its pollarded riverside willows provides an impressive landscape enhancement viewed either from the A40 Western Avenue or the railway. Removing this land from MOL is incompatible with the Council’s policies to take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure at a catchment or landscape scale across boundaries with neighbouring Boroughs.
For brevity, BRCS is outlining its reasoned objections only to a small sample of proposed removals, but to confirm, we object to all removals of GB and MOL designations in the Reg 19 draft as premature and unwarranted and we are willing to provide detail on a site by site basis to any removals that remain when the Local Plan goes to the Inspector.
Regarding additions to MOL, BRCS has no objections to any of the proposed additions. However we would comment that the addition of the River Brent and a section of the Grand Union Canal makes no sense and is unnecessary. All previous local plans include and map it as MOL. For example, in the 2004 Plan for the Environment, it is clearly shown as part of the BRP NCMA, which is therein defined as MOL.
The Green Belt and Metropolitan Open Land Review report (Appendix 3) initially suggested a number of additional open spaces for designation as MOL. These were: Islip Manor Park, Ravenor Park, Southall Park, Blondin Park, Twyford Avenue Sports Ground and North Acton Playing Fields. None of these additions has been carried through to the Reg 19 draft. BRCS objects to the omission of these sites, all of which would be justified in terms of Council and London Plan policies for extending MOL and all of which BRCS suggests should be included in our proposals for NMA’s.
Submitted by the Trustees of the Brent River & Canal Society on 10/04/2024 secretary@brentriverpark.org