Statement on the development of tall buildings in Ealing

Ealing’s adopted local plan defines tall buildings as: “those that are substantially taller than their neighbours and/or which significantly change the skyline.” (Development Management DPD, Policy 7.7 H, adopted December 2013).

Development proposals that include tall buildings are often controversial and rightly attract significant interest from within our local communities. Certainly, this is the case in Ealing and in many more boroughs across London.

The recent Manor Road appeal decision  (29 October 2021) is just one example of how a tall building proposal generated much concern and impassioned debate amongst our local communities, which ultimately had to play out in a highly technical and legal forum that was overseen by an independent inspector employed by the government.

For this reason, any proposal including a tall building must therefore always be considered as a significant form of development and must be subjected to thorough scrutiny. In instances where they are deemed an appropriate form of development, they must also achieve an exemplar standard of design. Although critical, design and appearance are not the only policy considerations for assessing a tall building, the site location, its setting and surrounding built context also play a key role in informing the decision making process, which can often be finely balanced. This is complicated further by the subjective nature of this process, where opinions can differ, and the Manor Road site is a case in point. Here, the government’s planning inspector disagreed with the council and the Mayor of London and decided to allow the developer’s appeal, stating the proposed 20 storey building “would not appear as an alien insertion into the townscape. It would be an indicator of the transition from buildings of lower size and height to the more intensive uses and buildings of greater height around the node or hub formed by the meeting of the roads, their crossing of the railway and the station.”

Despite our great disappointment on the Manor Road appeal outcome, we must also be realistic in recognising that tall buildings have been an integral part of the overall development story in London, particularly over the last few decades, and will continue to be so. Moreover, with our green belt, metropolitan open land (MOL) and parks afforded the greatest policy protection against development, land is a finite resource in the capital, and it is therefore prudent to consider all forms of development on brownfield land to optimise its use. Scale and density can therefore be influenced by the need to accommodate a range of land uses that are required by nationally imposed planning policies, most notably a compliant level of affordable housing. This gives a sense of how complex the task can be when assessing proposals for tall buildings and the multiple policies that must be carefully weighted.

Given the complexities and nuances of tall building assessment, the council maintains that policy on tall buildings must be robustly tested at the plan-making stage and the development of tall buildings must be plan-led. Our plan-led approach has been advocated by Ealing’s current Local Plan since its adoption in 2012/13.  Despite this, we cannot control the submission of speculative proposals for tall buildings that clearly contradict our plan-led approach. All local planning authorities have a legal obligation to consider any application on its merits, including the speculative applications. Helpfully, our grounds to resist speculative applications for tall buildings has been strengthened further with the adoption of the new London Plan 2021, which reinforces plan-led approach for the capital.

To support the positive planning of our borough and inform negotiations on individual planning applications we have commissioned an Ealing Character Study and Housing Design Guide, which contain very helpful generic design principles that will be applied to the consideration of tall buildings and future development in general. These include responding to character, context and identity, scrutinising the built form in terms of scale, massing, density, plot coverage, building heights and rooflines and ensuring that developments are well connected with their surroundings. For tall buildings, the visual impact on views, the integration with neighbourhoods, the effects on the microclimate and the sustainability of the buildings will also be of particular importance. These design principles will be used to assess planning applications as they come forward.

In summary, the council is reaffirming its commitment to a plan-led approach for tall building proposals, directing these to sites already identified in the development plan and to generally resist speculative applications for tall buildings on unidentified sites. This approach is in full accord with the current adopted planning framework and for the purposes of greater clarity we have drafted a Local Plan Policy Guidance (LPPG) note to remind all applicants of the policy context they should respectfully work within.