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The Ealing Parks Foundation welcomes the concept of an integrated Local Plan for the London Borough of Ealing.

 

We understand that the Consultation is Stage 3 of Stages 0 to 8 and that it has been extended for an additional two weeks beyond the statutory requirement of six weeks and we welcome this extension as more people become aware of the Local Plan. 

 

We also understand that there are a number of stages yet before the plan is adopted, the first being to take note of feedback and objections from residents in Ealing; to seek feedback from City Hall as to how this fits into the London Plan and to consult with adjoining Boroughs who may share Green Corridors/spaces etc. Our concerns around the Consultation focus on:

1. Methodology which appears to be an independent approach, 

2. Redesignation of Green Belt, MOL and other green spaces 

3. The absence of any meaningful activity with regards to climate change. 

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Local Plan Methodology

We are concerned that by Ealing Council taking a unilateral approach to the creation of a Local Plan with a self-developed methodology gives the lay person the impression there is a weakening in commitment to important green spaces.

 

Furthermore, the consultation process and supporting documentation is likely to prevent some from responding. This is even more likely for the vulnerable people who are unlikely to be able to represent their views, but equally to enjoy the calm tranquillity, health and wellbeing benefits that all green spaces offer. 

 

With over 500 pages and numerous appendices the documentation is daunting rather than informative. Similarly, the response options - of which there are many - make it hard for people to know how best to respond. The people who are unable to engage with this consultation - the socially and digitally excluded - are very unlikely to have their views considered.

 

Concerns about the methodology have been presented by other organisations. We provide more details below. 

 

Redesignation of Green Belt, MOL and other green spaces

As an independent charity whose objects include enhancing parks and green spaces, supporting their use by the community for health and wellbeing and protecting and enhancing wildlife, heritage and biodiversity we are particularly interested in the redesignation of green spaces, particularly those already designated Green Belt or Metropolitan Open Land (MOL).

 

We know the Council has a commitment to create ten new green spaces with the assurance that this plan results in a net gain of green spaces. While the notion is good, these should be appropriate green spaces, not a numeric target. 

 

We understand from the Strategic Planning Team (SPT) at Ealing Council who have created the Local Development Plan, along with input from the Council Leader, the Local Development Plan Advisory Committee of seven Councillors and other Council colleagues as required, that the proposed redesignation from Green Belt/MOL is intended to protect these green spaces from inappropriate development through challenges to the designation. 

 

From meeting with the SPT we understand, a number of Ealing’s green spaces have multiple designations already and the changes are intended to simplify and clarify areas that may be confusing, and that there is a wish by the Council to implement more local designations.

 

Our concerns around redesignations of existing Green Belt and MOLs arise from the level of protection afforded these areas if these are local designations that are effectively in the gift of whichever Council Cabinet is in situ at the time and that these may be subject to the demands for additional building or planning requests, rather than a nationally recognised designation that affords some protections and a wider appeal process.

 

Additionally, the Council historically has frequently been the organisation that has chosen to interpret the “subjective nature” - the STPs phrase - of the National Planning Policy Framework (NPPF) and London Plan to introduce plans that are to the benefit of the Council objectives, with these proposals then being approved or rejected by the Council’s Planning Department through delegated powers or the Council’s Planning Committee. Will these redesignated protections of Green Belt, MOL and other green spaces be part of policy that guides the Planning Department and Planning Committee and encourages them to dismiss precedents? 

 

It would be helpful if the various designations that the Council are considering replacing Green Belt and MOLs with could be made available in appropriate detail along with a clear understanding of their various protections.

 

As stated above, we appreciate that a key driver is to ensure consistency of approach across the Borough but this now opens the potential for different designations of the same land where it straddles Borough boundaries.

 

Rather than change the designations, a less controversial approach would be to enforce more rigorously the protections that Green Belt and MOL designation should provide. 

 

One argument is that the Green Belt and MOL designations will be replaced by new designations more appropriate to the circumstances and will provide the same level of protection against development as exists at present. In order to understand this, a full mapping of the old and proposed new designations is needed with a comprehensive assessment in each case of the applicable protections.

 

Putting the technical justification aside, the voluntary de-designation of Green Belt and MOL will be perceived as a lack of commitment towards the preservation of green spaces. This will have two wider effects:

 

1. Distracting significant resource and attention from the many positive and critical elements of the overall plan

2. Eroding the confidence of local residents causing them to be less willing to step forward as volunteers. Given the criticality of Active Citizenship to the delivery of many elements of the Local Plan, it is important that our volunteer networks are able to stand fully behind this plan, rather than risk being depleted.

 

We also have concerns about the high level of future housing requirements as part of the Tall Towers Strategy. We are led to believe that tall new builds have a greater carbon footprint than retrofitting energy efficiency measures to existing housing stock. In relation to parks and green spaces our concern is this building programme will overshadow and add pressure to dilute further any protections afforded by the proposed redesignations. Increased population will have an impact on green spaces, managing this impact is one of the core objects of Ealing Parks Foundation.

 

Strategic Objectives and Priorities - Tackling the Climate Crisis 

We strongly welcome tackling the climate crisis as one of the Council’s current three Strategic Objectives and Priorities (the others being Fighting Inequality and Creating Good Jobs and Growth). All three of these objectives are very important. 

 

We welcome mention of biodiversity, along with Net Zero, with several other initiatives including a reminder that “Ealing Council declared a climate emergency in April 2019, committing to treat the climate and ecological emergency as a crisis requiring immediate climate action.” (Local Plan. Para 2.25) 

 

The Local Plan’s 15-year shelf life extends to 2038, yet there is very little evidence to back up the Council’s claim that their “aim is to become carbon neutral as a borough and an organisation by 2030.” (Local Plan Para 2.25). This is a target that can only be met with the full and willing engagement and support of the 360,000 residents that live in Ealing.

 

As Ealing Parks Foundation, we take the view that the attitude towards and treatment of green spaces is a strong indication of how they are valued. 

 

It is difficult to see within the Local Plan any evidence of actions that would deliver carbon neutrality for Ealing by 2030, which is just six years after the proposed 2024 launch of the Local Plan. 

 

We would like to see Ealing embrace the importance of green spaces in all their forms being available free of charge, reflecting the varied importance of these spaces to the communities that use them. From a small patch of land in a housing estate to some of the large green spaces, they are all important to someone and indeed the local a wider community. 

 

It requires truly local and specialist knowledge to understand the breadth of the issues. EPF does not have this level of expertise. We have been contacted by many groups - national and local - that have expressed their concerns about the impact of the Local Plan on their green space. We list some of these below as we are concerned that the complicated nature of the Consultation, and the confusion around how to respond is likely to prevent many from engaging and submitting feedback. 

• The Campaign for the Protection of Rural England (London) has prepared a 13-page response detailing concerns about Ealing's bid to remove protections from parks - CPRE London. CPRE London’s response includes a detailed objection to the methodology. In its opinion, the current designations can and are justified within the NPPF and London Plan policies and therefore that what Ealing is doing is making an active choice to move away from protection of these green spaces. 

• Ealing Friends of the Earth have prepared a detailed response which looks at the impact of the Local Plan on nature, and connecting issues to the proposed Tall Building Strategy and the impact it will have on carbon emissions. 

• Ealing Transitions encourages comments on the Local Plan, adding the ETI response to Ealing Local Plan suggesting the core of the plan proposes “business as usual”, while also offering progressive and inclusive models such as ‘Doughnut Economics’ if Ealing Council is genuinely serious about reaching net zero by 2030.

• Ealing Wildlife Group, with over 5,000 members and a local leader in biodiversity initiatives, issued An EWG statement on the proposed future of Warren Farm - Ealing Wildlife Group, with Dr Sean McCormack BSc, founder and chair saying “I’m very disappointed that our leaders are pushing on with plans to destroy half of one our most biodiverse habitats in the borough, home to many rare species and the only site in Ealing where Skylarks can breed, a red listed bird of highest conservation concern. Having contributed to Ealing’s Biodiversity Action Plan (BAP) which vows to protect and enhance habitat for this rare bird it’s shocking to hear that it’s apparently either Skylarks or sports facilities for children. This is disingenuous and misleading.” Dr McCormack goes on to call the plans “ecocide” adding the plans are “stubborn, ignoring the overwhelming consensus of the local community and undermining democracy at worst, and ecologically illiterate at best.”

• Fields in Trust report Pitshanger Area Friends are concerned about the removal of MOL status in Fox Woods, a place protected in perpetuity by Queen Elizabeth II in June 2013, which is now used by 450 children for sporting activities at weekends.

• Ealing Allotments Partnership who state the redesignation is “cynical attempt to weaken or eliminate protection for important green spaces across the borough” concluding the Council should “honour the statement in its Climate and Ecological Emergency Strategy (January 2021), which states that existing allotments should be protected.”

• Friends’ groups have shared their disappointment and frustration in the methodology, use of outdated information in preparation of the Local Plan, while the document also manages to contradict their decision by highlighting the value and importance of green spaces to Ealing communities who both benefited from and volunteered in these green spaces during the pandemic. As stated above, the Local Plan has the potential to seriously impact the level of community and volunteer engagement with the level of disregard that local groups perceive to be happening.

 

If climate change and valuing our green spaces is one of the strategic priorities of the Local Plan, it would be reasonable to expect broadly supportive responses from these organisations. These organisations and many others are far from supportive. 

 

We would like to see Ealing Council genuinely engage with the climate crisis through the Local Plan, changing their perspective on decisions that appear poorly advised, and switching to adopt a policy that genuinely places reducing climate change at the heart of the decision. By doing so they will make progress on all three of the Strategic Objectives and Priorities which are tackling the climate crisis, fighting inequality and creating good jobs and growth.

 

As an overall comment the plan needs to more clearly highlight how it is a response to the climate crisis. In Section 5, for example, we would like to see the impact of development on local green spaces reflected more prominently and some clear assurances given that overall there will be no net loss of green space and that any substitutions will be equivalent in terms of access, amenity and biodiversity. 

 

We recognise that there must be a Local Plan, and we also recognise that it is unlikely that a Local Plan is going to be supported unanimously. The strategic objectives and priorities are important and we support them. However the detail of the Local Plan fails to deliver on the promise of those opening details. 

 

We urge Ealing Council to revisit the concerns we mention above, and those of other organisations with more specialist knowledge. We are very happy to engage in discussion around the green spaces that are cherished by so many in the London Borough of Ealing. 

 

As Ealing Parks Foundation we could not support the loss or degradation of any existing public green space across the borough of Ealing.