Response to the Planning Application for the Sports Hub

Planning and Listed Building Applications Reference Nos P/2015/4519 P/2015/4520

23 December 2015

Dear Ms Bassett

I am writing on behalf of the Friends of Gunnersbury Park & Museum to set out our response to these applications. We placed the planning documents from Hounslow Council’s website in a more accessible format on our own site, we issued a special Friends’ Newsletter, received a number of email comments from our members and held a meeting on site to discuss the impact of the proposals. There has been a very strong consensus in the views expressed.

We are fully committed to ensuring that Gunnersbury remains a park which supports sport, leisure and recreation for the citizens of both boroughs, and we are very pleased that so much work has been invested in helping to restore its capacity to do this. However the application is for more than restoration of the status quo. It is for a new building in Metropolitan Open Land which, amongst other things, will provide indoor sports for which parkland is not essential, and for rentable office space. At the same time, modern outdoor sport appears to require fencing, lighting, tarmac paths and substantial car parking, all of which elements have the capacity to diminish park users’ pleasure if they are not well planned.

We wish to comment specifically upon the following matters:
• the quality of the design and the proposed materials
• the relocation of the sports building
• the impact of fencing, artificial grass pitches and floodlighting on the open landscape
• cycle routes across the Park
• car parking and access to and from the Park
• the absence of promised proposals for free of charge fitness and sports equipment
• the impact upon the CIC’s ability to hold major events to generate income in future
• the lack of any provision for the preservation/use of the Model Farm of the early 1800s
• the timetable for this consultation

1. The quality of the design of the building

This does not match the expectations we are entitled to have of a new building in a Grade 2* Listed Park and Conservation Area. PPG7 points to the need to add to the overall quality of the area and reflect the identity of local surroundings and materials. We have several substantive objections to its appearance.

The first of these relates to the size, form and silhouette of the structure. Its very large solid rectangular facades are urban, even industrial, in form and style and do not transplant well into a complex planted landscape of open parkland.

The second objection concerns the materials proposed. Black painted wood planks are shown at its upper levels with the justification that historically timber-framed agricultural buildings were finished with black tar. The result is ugly and far too dominant; it is not appropriate for either sports buildings or similar important new buildings within a Listed park. The treatment of the ground floor with gabions and metal panels not only contradicts the claimed aesthetic of a barn but these are also inappropriate materials in such a sensitive site.

The recently-built toilets near the cafe show quite conclusively that gabions are wholly out of place in this historic landscape. The local vernacular left timber buildings untreated – see Harmondsworth or Headstone Manor (tarred black timber is more favoured in other areas of the country). The principal building material in this area has been brick – indeed there are records of the extraction of brickearth from this very field in the 18th and early 19th centuries. The metal panels are derived from modern office buildings. As the recently-published English Heritage book Played in London shows, sports buildings have made a huge and distinctive contribution to the built environment in London, and we deserve to have something which could take its place in that tradition.

In 2006 English Heritage objected to a proposed Butterfly House (Planning database reference no 00885/A/P11) on this site with the words “the proposed new building which is of utilitarian design and construction does not appear to offer any benefits to the Park or to the At Risk buildings”. We believe the same description applies to the design and construction of the new building.

2. The location of the proposed building

We are very concerned about the dominance of the building in its proposed location. The grass-land falls away below it and the black box of the substantial upper storey will be seen from many parts of the park, especially in winter. A very large building such as the one proposed would make a significant impact wherever it was sited in the Park as the selection of views provided indicates.

Promises of tree planting to conceal the building would surely apply to this design whatever the location but would not be necessary if the building were a pleasure to view. We are disappointed to note that the architects have not considered the visual impact from one of the most important viewpoints, namely that from the Temple steps; the prominence of the building will become more evident, especially if the proposed extension to the car park goes ahead.

When confronted with the Butterfly House proposal, English Heritage made exactly the same point: “the new building would be located on one of the highest parts of the Park and would be visible over a large area, The proposal would have a detrimental effect on the character and appearance of the Registered Park and of the Conservation Area and would detract from the setting of the Listed Buildings”. That proposal would have been 28ft high – the proposed sports hall will be approximately 37ft.

We do not believe that a sufficient case has been made for this location. The sports facilities were designed around the provision of changing rooms and services near the Model Farm. To move this provision to the new site requires many ancillary changes which have not been justified. In fact we are very disturbed by para 4.2 in The Planning Statement by Shire Consulting which describes the “recommendation” of one of the officers from the Planning Authority for the bowling green site, and also by para 6.24 in the same paper which states that the subject site was chosen by one of Hounslow Council’s Planning Officers because the impact of any building upon the “heritage” views in the Park was considered insignificant and the loss of trees would not be an issue. We clearly disagree with the Planning Officer about the building’s effect upon other, but equally important, views within the Park and believe the exemplar images offered in The Visual Impact Statement to be wholly inadequate.

3. Fencing, artificial grass pitches and floodlighting

The three fenced areas, two with floodlighting, will have a substantial impact upon the appearance and upon public enjoyment of the open field area. The tennis court fencing will be 3-metre (10ft) high green plastic-covered chain-link with 15 galvanised column lights each 8 metres (26ft) high. The artificial grass pitches will have 4.5 metre (15ft) high fencing with 9 galvanised column lights, all 13 metres (43ft) high. The Multi-Use Games Area (MUGA on the plans) will have 3-metre high green chain link fencing, but does not appear to be floodlit. (We do not yet know if the proposed golf course near to houses and back gardens will need to be netted for safety).

The fencing and flood-lighting will have a major visual impact on the park. One of Hounslow’s Planning Officers, Sean Doran, is quoted in support of siting the Sports Hall on the bowling green: the “location of the new sports hub is determined by two main factors; the benefit of using a part of the site that is previously developed and the fact that locating it here will not impact on the historic protected landscape setting, views within the setting to and from the listed mansions and other listed buildings/structures, and will not further remove any openness from the Metropolitan Open Land.”

However, the openness of the Metropolitan Open Land will be significantly diminished by the siting of the two artificial grass pitches and their 15ft fencing, 43ft floodlighting, and what looks like a new roadway which will be laid halfway across the field. This whole feature will divide the open land across its middle, and could hardly be more intrusive. The Visual Impact Statement presents several views of the fenced enclosures but none includes the floodlight columns, and the viewpoints chosen diminish the impact of the proposals. One of the great values of Gunnersbury is that its view to the west has a low horizon, no tall buildings and a full open sky which lifts the spirit. It is not a heritage view, but it is view which matters to many park users.

The experience for the typical visitor through the Pope’s Lane entrance will be rather unwelcoming. Once they have parked their car or bike, they will walk along the main path into the Park with a 37ft wall between them and the landscape, they will arrive at the children’s playground, and if they look or turn to the right they will be met with a high mesh fence around the artificial grass pitches.

4. Cycle routes within the Park

The Transport Assessment (para 4.3.5) states “As can be seen cycle routes are provided within Gunnersbury Park. Full off-street routes are available close to the perimeter of the Park, whilst there is also a cycle route provided on a north south axis across the centre of the Park.”

This statement on cycle routes is repeated throughout the supporting documents, but it is mistaken. Public consultations on this subject have always included the promise that no decisions have been made. The Park’s Bye-laws clearly state that cycling is forbidden; other than issuing this map nothing has been done to change this. Transport plans drawn up on the basis that there are fast routes through the park cannot be relied upon.

5. Increased car parking

As the Transport Report shows, Gunnersbury has good public transport links, with Kew Bridge, Gunnersbury and Acton Town Stations within walking distance, and bus routes along the A4 and Popes Lane. The PTAL assessment in 2006 was level 4. It is also clear that the presumption behind past development has been that it limits car parking provision to encourage people to use public transport. That presumption should be even stronger in the case of an urban park. We have found considerable unease not only about the scale of the proposed expansion of the parking area but also about the greater risk to pedestrians from increased traffic through the Pope’s Lane gate.

The consultation meetings were told that the sports funding bodies insisted that the new building and the car parking be close to each other. We have two comments about that. The first is that the funding bodies should not be influencing the design and planning process to this degree. The second is that since the old changing rooms were built in 1962 thousands of sports players have found it quite acceptable to walk between them and the existing car park. From the Park’s opening until 1962, sports players were changing and showering in the Stables and walking even further.

6. The absence of promised proposals for free of charge fitness and sports equipment

The Friends and the members of the Gunnersbury Park Joint Advisory Panel have repeatedly asked for and received assurances that there will be provision in the Park for exercise with some equipment provided for use by people of all ages without charge. This is to ensure that people with limited funds, or who prefer to exercise at their own pace rather than in team games, will be able to enjoy and benefit from Gunnersbury Park.

We have not been able to identify any such provision in the planning application documents, but we believe such features may also need consent in a Listed Park and would ask that these proposals are included as a matter of urgency.

We note in the Planning Statement (p.4.5) that the option of providing health and fitness facilities to bring in a revenue stream is being considered. If this is instead of open and free provision, it does not match the assurances given in public consultations.

7. The impact upon the potential for major events to generate income in future

More than a decade of the London Mela has demonstrated the potential for significant London or regional events using the substantial open area of the field. Apart from space, which is easily accessible by public transport, Gunnersbury has not been able to offer infrastructure such as power or water supplies on the field, which would have made such events more feasible and generated greater income. The potential for upgrading what could be offered to support events has been mentioned in passing in the past but this opportunity to provide a means of bringing new and wider audiences into Gunnersbury is being missed, even obstructed, by the current proposals.

We are disappointed to find that the concept behind the current proposals for sports pitches, with new changes in level, fenced sports pitches and “swales” with belts of planting to manage water drainage on the field, have been prepared with a fixed vision that the field is only intended for sports activities.

The creation of new forms of governance for the Gunnersbury estate, with both a Community Interest Company and a Development Trust, has begun to put into place the administrative infrastructure for the management of such major events. Though the Business Plan remains confidential, (despite promises that a version would be made public) we cannot believe that the long-term planning process has not included the expectation that such events would form part of future activity to support these two bodies. This may not be a planning issue but it is certainly a significant management issue for the long-term survival of the Gunnersbury Estate, and the granting of permission for these particular plans would be a major blow to the estate in the future.

8. The absence of plans for the preservation/use of the Model Farm of the early 1800s

The core of the Model Farm buildings have survived neglect, vandalism and fire damage. The visitor interpretation at Gunnersbury both in the Museum and across the landscape will be designed to help visitors make sense of the estate as a historic entity, through the layers of the past. Close to the Model Farm, for example, are the traces of ridge and furrow from mediaeval farming. It had been built for the estate before 1836, and its importance increased after the purchase of the Brentford Common Field in the early 1860s. As the Conservation Management Plan makes clear, “The Model Farm along with the Walled Garden to the north form the core of the functional service estate ensuring the Mansion House was supplied with food all year round and acted as a focus for estate management” (p.70). The casual division of the estate into the very precious historic core and the insignificant open land may be convenient as a description but is damaging as a concept. Without the Farm, the story of this estate is incomplete and it should not

just be allowed to collapse or be demolished without a careful evaluation of its potential and consideration of options for its future use. The planning presumption with this Park and with its historic buildings should be that all efforts should be invested in the adaptation and continuing use of its existing buildings as a greater priority over building new ones.

Other than the suggestion that a sports building near the Farm might damage a historic view, and that the proposed site is convenient for parking, we can find no evidence that site of the former changing rooms has been fully considered as the location for new sports facilities, despite having some clear advantages, in particular spreading activity further through the Park rather than concentrating it in an already congested zone, allowing a more sympathetic layout of the fenced pitches, and contributing to a feeling of safety all through the Park. A well-designed sports building might even be considered as an asset amongst the historic views. Far more damaging to the visitor’s experience of views and the experience of open space will be the new wall of tower blocks at the Brentford Stadium site, the Gunnersbury Roundabout site (32 stories) and the Capital Way Interchange site (22 stories) which we seem to be powerless to prevent.

9. The timetable for consultation

We feel the process of publishing this application has left the public at a great disadvantage in being able properly to respond. We have provided some of the detail in an appendix.

This is a major application for the largest new building proposed for Gunnersbury since the failed athletics stadium proposal in 1965. The process of informing the public and asking for comment has been very unsuccessful and we ask Hounslow’s Planning Committee to delay their decision and engage in a proper and meaningful public consultation on the actual proposals now in front of us.

James Wisdom, Chairman of the Friends of Gunnersbury Park,
020 8994 4231

Appendix on communication and consultation

The project team called a number of public meetings as the plans were being formulated, and published responses to what they called Frequently Asked Questions. However, at all stages of these meetings, the material we were shown was described as indicative, and much of it was changing. So it has only been possible to make comment once the final application has been made.

After a notice was published to us and local residents on 14th October, a local journalist wrote to us: “A planning application has been submitted for the redevelopment of Gunnersbury Park which envisages the nursery and bowls green going. There are no supporting documents with it – do you have any indication as to what is being planned?”

By 9th November, with nothing filed on Hounslow’s Planning Portal, we enquired of the project team about progress on and were told: “A full application has now been submitted following the original documents which went live in October 2015. Unfortunately as you’ve picked up on, there was a delay with documents being uploaded to Hounslow ‘s planning portal due to essential portal maintenance works, which has been noted our end. We are now working flat out to get the application documents available to view and finalising the consultation boundary. Once this has taken place there will be 21 days for residents to comment on the application.”

This was disappointing as we had been promised 28 days at one of the public meetings.

On 29th November the leaders of both councils issued a press release and conducted a photo call marking the beginning of the restoration work and announcing that the park was to get a sports hub.

An email reporting that the documents were available was sent from Ealing on 2nd December, with a url which did not work and reference numbers which returned nothing. By 4th December, 129 documents had been posted, divided between the two applications. After downloading and comparing, it emerged that 75 of these were time-wasting duplicates, and it is hard to imagine many members of the public having the time or will to work through the list.

Perhaps the planning information was not sent to either the traditional or the electronic newspapers, but only one ( has reported it. This was on 21st December, and was derived from the Friends’ Newsletter. Nothing has been reported on the new project website,