The cross-party campaign sent the following joint letter asking him to refuse the development. He can decide to refer it back to Barnet Council to make the decision, reject it or take over the planning application as the planning authority.
Dear Mr Mayor,
Ref: Application No. 13/0938. West Hendon Estate, NW9
We, the undersigned, have considered the above application and wish to confirm our objection on the following grounds:
This is an exceptional and most significant site located in a conservation area enjoyed and cherished by the people of Brent and Barnet and is of a remarkable value to Londoners and visitors as a whole. The site is rich in its heritage and unique given that it is a Site of Special Scientific Interest (SSSI); accommodating a Reservoir; unique ecological heritage and green un-spoilt environment with leisure and recreational facilities. The proposed development will see some four-fold increase in the current population. This proposal amounts to gross overdevelopment on this site and will destroy the heritage and value the site provides locally as well as strategically.
Scale of the Development
The scale of the development with 2,000 residential units, commercial and community facilities including a two form entry primary school is wholly inappropriate for this sensitive site. The built environment with tower blocks and the resultant bulk dominating the skyline will not be in keeping with the character of the area, will have a serious detrimental impact on local views and set a precedent destroying permanently the outstanding character and the natural beauty the area provides as well as jeopardising the maintenance of the Welsh Harp SSSI status into the future.
Conservation and Impact on Environmental Amenities
The applicant’s design and access statement refers to the Brent Reservoir SSSI, primarily notified for its wetland breeding birds, wintering water fowl and botanical interests. According to this document, studies undertaken for 2004 ES identified ‘the existing ecological value of the site to be low’. We challenge this statement as the conclusion in this document is not backed up by clear evidence and is in direct contradiction to the assessment of this site by many professional organisations and individuals. The influx of some 5,000+ residents together with the massive development itself within the 20M ‘No build zone’ would threaten the ecological amenity. The site is of London and National ecological importance and the development in question lacks adequate research and evidence to demonstrate that the scale and design of the development can sustain and enhance the quality of nature conservation aspects. We would like to draw attention to the specific environmental concerns raised by Brent Council Environmental Officers which ‘remain’ despite assurances from the developer:
It is considered that the edge of the Welsh Harp Reservoir, marshland and tree line will be affected as a result of the development for the following reasons:
· The new buildings are planned to be considerably closer to the water’s edge than the buildings of the existing development. This reduces further the belt of green-space between the development and the reservoir.
· The two new footbridges that are proposed across the Reservoir and SSSI (Site of Special Scientific Interest) to link to play-areas and park at West Hendon is likely to affect the reservoir by introducing infrastructure into the reservoir and disturbance by users.
· Apparent lack of improvements to enhance the natural environment of the reservoir – There is mention of ‘linear woodland’ but it is unclear where this will be provided as there is insufficient space between the development and the water’s edge to create woodland.
· The proposed felling of trees that contain features conducive for roosting by bats.
· Lighting: the impact of lighting on bats is likely to be a direct impact. (The Environment Statement: non-technical summary, suggests that lighting is likely to be an ‘indirect’ impact).
· Insufficient research into existing fauna and flora and underestimating its national and local importance.
· The applicant's report mentions wildlife but seems to play down its national and London wide importance. A GiGL search of the area has revealed that the reservoir supports the country’s largest breeding group of great crested grebe whilst in winter it supports nationally important numbers of waterfowl as well as over 40 nationally rare species. The applicant is advised to contact GiGL for accurate info.
We believe that whilst the above environmental concerns remain unaddressed by the developer that the proposals cannot legitimately be granted planning permission in their current form.
High Rise Blocks
The site is designated (Barnet’s Core Strategy: Tall Buildings policy CS5) as appropriate in some strategic locations for tall buildings of 8 – 20 storey but the proposed tower blocks of 29, 27 and 21 storey height are contrary to Barnet’s policies and will completely destroy the physical character of this site. Equally, the high-rise blocks fail to comply with the stringent policies set out in the London Plan. The London Plan policy 7.7 (Location and Design of Tall Buildings) requires tall buildings to be located in town centres and major zones of economic development and can be considered only ‘in areas whose character would not be affected adversely by the scale, mass or bulk of a tall or large building’. Section 7.7E of the London Plan also states “a matter for particular consideration is the setting of tall buildings on the edge of Metropolitan Open Land”. The applicant has not submitted the necessary information to do this, and therefore does not comply with the criteria for assessment set out in London Plan policy 7.7E
Provision of ‘Homes’: Barnet’s Core Strategy states (clause 9.2 for homes of
different sizes) that the majority of units are houses which account for 62% of the stock. ‘Design And Access Statement’ of the applicant claims “The mixture of typologies provides opportunities to accommodate people’s preferences for housing” but this is not backed up in the scheme offered in the application. In reality, the proposal is driven by a commercial scheme with no relevance to the preferences of Barnet’s residents. Woefully small provision of 20 ‘houses’ (only 1% of total) fails to provide an acceptable mix of residential accommodation to reflect the character of Barnet’s existing residential stock and preferences of residents to live in traditional homes and not flatted accommodation in towers as tall as 29 storey high.
Inadequate Affordable Housing: Provision of a meagre 25% Affordable Housing is market driven to maximise the return at the cost of much needed affordable socially rented housing. For a scheme of this scale a minimum of 35% stock of housing for socially rented housing is required and the deficiency is serious enough to demand refusal of the scheme.
Dearth of Family Size Housing: Barnet’s Core Strategy says 33% of all Barnet households contain children, the majority of these comprising an adult couple with children. Barnet’s specialist Housing Strategy sets out housing priorities and delivery by 2025 with overarching objective of ‘providing housing choices that meet the needs and aspirations of Barnet residents’. The Core Strategy further states ‘to improve choice we need to increase housing supply including family sized homes.’ ‘Our dwelling size priorities are for family accommodation across all tenures.’ (3 Bedrooms higher and 4 bed rm medium priority). The Mayor of London’s Housing Strategy for affordable housing (Policy 1.1C) specifies the requirement for more family-sized homes, with 42 per cent of social rented and, by 2011,16 per cent of intermediate homes having three bedrooms or more. A meagre provision of 20 houses (8 no. 3 bedroom houses and 12 number 4 bedroom houses) and 290 (14.5%) duplex apartments completely undermines Barnet’s Core Strategy, Specialist Housing Strategy and the Mayor’s Housing Strategy.
We do not believe that Barnet Council has demonstrated a robust assessment of the proposed community amenities such as the 2 form entry primary school, nursery and community centre in order to gauge the adequacy of these facilities to support the scale and size of the scheme. Significantly, the scheme contains no provision for a GP surgery or medical centre facilities for the new occupants. There already exists an acute shortage of medical facilities locally and the absence of this provision in the proposals is a serious omission which must be incorporated to provide adequate social infrastructure. There appears to be an overall lack of long-term vision for the plans, particularly from a health and safety and emergency perspective.
Transport, Parking and Congestion
Bus Priority Lanes & Cool Oak Lane
Serious concerns exist with regards to the acute traffic and congestion problems resulting from this massive development on the already busy A5, local road network and junctions. We disagree with the proposal of deleting sections of priority bus lanes on the A5 as part of the new proposal as this will remove the ‘multi – modal’ aspect agreed with TfL to provide non-car sustainable transport and the objectives agreed for A5. In addition, there are concerns about capacity of junctions, trip generation and increase in flow of traffic on the A5. The objectives for the A5 have been split into two groups, one set for the north, one set for the southern section. These are set down in the North London sub-regional transport plan 2012, and the objectives for the northern section (which this site adjoins) are –
- To encourage longer distance traffic to exit the A5 at appropriate points
- To minimise the impact of developments on the performance of the A5 corridor
- To further improve highway performance by tackling issues at identified delay hotspots
- To protect the status of local and district centres through environmental, public realm and active mode initiatives
- To encourage greater use of public transport from local neighbourhoods to facilities along the A5
- To accommodate longer distance freight and facilitate deliveries and servicing whilst minimising its impact on residents, congestion and air quality.
Assessments to accompany developments should illustrate how these objectives are being worked towards, or at least not acted against.
Furthermore, the adjacent Cool Oak Lane which cuts through the Welsh Harp itself is a narrow, winding and picturesque road which is simply not designed to cope with a four-fold increase in the local population.
Trip Generation Levels
The tables showing the levels of trip generation have been reviewed. Whilst the levels of junction saturation are stated, the developer does not illustrate the overall level of increase in flow on the A5 (current and future flows) as a result of the development. The junction looks to be very close to capacity already – the assessment states that where development traffic is factored up by 10% to provide a robust assessment, this makes little difference to the operation
of the junction, and that queue lengths only increase by a maximum of 2 pcus. This seems very low and Brent Council has asked that this figure be re-checked.
In conclusion, the application drives a coach and horses through all significant planning policy justifications. The applicant has given inadequate consideration to the local, London-wide and national significance of this unique site and the proposed development would seriously threaten the SSSI status of the Welsh Harp (The only SSSI in Brent or Barnet).
We believe that there are a great number of important factors which remain unaddressed by the developer and if approved, the decision would be tantamount to an act of vandalism.
We, as a cross party alliance in addition to the 800+ Brent Residents who have formally objected to this scheme, urge your good offices to refuse this development in light of the breadth and scale of the concerns outlined above.
Navin Shah AM
London Assembly Member for Brent & Harrow
Cllr Muhammed Butt
Leader of Brent Council
Cllr Roxanne Mashari
Labour Councillor for Welsh Harp Ward
Lead Member for Environment & Neighbourhoods
Cllr Alison Hopkins
Liberal Democrat Councillor for Dollis Hill Ward
Chair, Welsh Harp JCC
Cllr Suresh Kansagra
Leader of the Conservative Group
Chair, Brent Green Party
Chair, Brent Campaign against Climate Change
Cllr Javaid Ashraf
Liberal Democrat Councillor for Dollis Hill
Chair, Brent One Council Overview & Scrutiny Committee
Brent Friends of the Earth
Chair, Dors Close and Doreen Avenue
Former Conservative Councillor
Chair, Wood Close Neighbourhood Watch
Chair, Comber Close