Final appeal as London Mayor decides on West Hendon/Welsh Harp development

Today Boris Johnson will meet with GLA planners to decide what action to take on the Barnet Council-Barratt Homes West Hendon development on the banks of the Welsh Harp nature reserve and SSSI.

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:

Site Considerations

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

Residential Proposal

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.

Social Infrastructure

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.

Conclusion

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.

Yours sincerely,

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 Brent Council	Brian Orr Chair, Brent Green Party
Martin Francis Chair, Brent Campaign against Climate Change	Cllr Javaid Ashraf Liberal Democrat Councillor for Dollis Hill Chair, Brent One Council Overview & Scrutiny Committee
Viv Stein Transition Willesden Brent Friends of the Earth	Maurice Hearn Chair, Dors Close and Doreen Avenue Neighbourhood Watch Former Conservative Councillor
Roland Santos Chair, Wood Close Neighbourhood Watch	Alexander Melia Chair, Comber Close Residents Association

Welsh Harp JCC on why Mayor should reject West Hendon development

The letter below was sent to Boris Johnson today:

West Hendon Estate, Barnet (planning reference: H/01054/13)

I write as chair, and on behalf of, the Welsh Harp Joint Consultative Committee, which includes elected councillors from both Brent and Barnet and is a cross party body. Our charter is to consider and co-ordinate all the interests of recreation, leisure, maintenance and nature conservation together with the statutory requirements of the British Waterways Board and the Environment Agency at the Welsh Harp (Brent Reservoir) Our resulting objective is to protect the Welsh Harp Reservoir and surrounding open land as a unique environment for both recreation and wildlife conservation.

At our last meeting on the 24^th July 2013, the committee noted with considerable disappointment and concern that the London Borough of Barnet Planning and Environment Committee had granted planning permission to the redevelopment of the West Hendon Estate. It was agreed that we would write to you to express our objections to the scheme as it is currently proposed.

Our grounds for objection are based on the environmental impact of the scheme and are therefore in line with our remit.

SSSI endangerment

The Welsh Harp – also known as the Brent Reservoir – is a nature reserve and a Site of Special Scientific Interest (SSSI). As one of only approximately thirty-six SSSIs across London, the area is of considerable value not only locally but also London wide and nationally.  Both the London and Barnet Plans contain directives regarding the protection of SSSIs. This scheme clearly breaches those directives.

The proposed development will cause considerable disruption and therefore harm to the wildlife of the SSSI. This disruption will be caused by the process of construction, the size and scale of the development, the resulting increase in population density, together with light and noise pollution.

We have grave concerns that allowing such a scheme will create a precedent and endanger similar areas in the capital and beyond.

Risk to flora and fauna

We wish to  highlight that one of the proposed pedestrian bridges would span the wetland breeding grounds on the SSSI and it would be impossible for this to not negatively impact the birds nesting in the area, both during construction and afterwards when in use. Migratory birds using the area include Gadwalls and Widgeon and it is known that there is a colony of Daubenton Bats roosting in the area.

Some of the buildings will be 29 storeys in height. This will impact on the bird population, especially as they are a mere 20 metres from the water’s edge.  A particular issue is the effect this will have on wind currents which could cause birds to fly into buildings or become confused and be displaced. There has been no mention of this issue in the application for the scheme.

Inadequate assessments and safeguards

We consider that the wildlife assessments which have  been undertaken are  lacking, and are deeply concerned that the proposals for the scheme make no specific mention of the reservoir or of flora and fauna.

 The committee also noted the views of Natural England which were reported as advising that construction should not go ahead either in summer or winter due to the disruption that would be caused to birds. We are aware that Natural England has also supported the appointment of an SSSI Warden to monitor the impact of the scheme on the SSSI.  However, very little detail has been provided regarding the powers of this post and the funding provided is considered insufficient by the committee.

In summary, therefore, we believe that the scheme as currently designed presents a grave risk to the status and environment of one of the very few wild spaces left in London. As a city, we cannot afford to risk endangering and damaging this priceless and very special place.

We urge you to direct the Local Planning Authority to refuse the application or failing that to act as the Local Planning Authority yourself so that the application can be considered fully in the light of all the appropriate development plan policies.

Yours sincerely,

Councillor Alison Hopkins

Chair Welsh Harp Joint Consultative Committee

Liberal Democrat councillor for Dollis Hill (Brent)

Boris Johnson to decide on West Hendon development on Wednesday

Following Barnet Council's referral of the West Hendon Regeneration Planning Application to the London Mayor last Friday, Boris Johnson will be making his decision on Wednesday 7th July.

He can decide that Barnet Council should make the decision, reject the application or decide to act as the Planning Authority for the application.

Navin Shah AM for Brent and Harrow; Cllr Roxanne Mashari, Brent Council's lead member for environment and Martin Francis, Brent Green Party, met with GLA planners today to put the views of those opposed to the application.

They will be circulating a letter over the weekend to go to Boris Johnson and the planners which will summarise the case against the development and urging him to reject the planning application or failing that, to act as the planning authority. The aim is to get the letter signed by members of all the main political parties in Barnet and Brent as well as all those organisations opposed to the development.

If you do not receive the letter by 9pm on Sunday evening please email Martin Francis at mafran@globalnet.co.uk to request a copy.

Assessing the public health impact of the West Hendon development

Patrick Vernon writes:

I am supporting the campaign to stop Barnet Council approving the planning application with Barratts to build 2000 units at Welsh Harp. Although we recognise that as a result of successive government policy in preventing the expansion of Council led social housing this has now increased pressure for deals with developers in the private sector and Registered Social Landlords to meet regional and local targets for affordable home particularly for families.

However the submission made by Brent Council, local councillors, residents associations, conservation and environmental campaigners have put forward clear and strong grounds on the environmental and ecological consequences why this proposed development should not go ahead.

I also suggested at the public meeting on Saturday 4th of May there is another angle which the campaign can also peruse to potentially either delay or force the Council to reconsider the planning application by assessing the public health dimension of the development.

Under the Local Government Act 2000 local authorities have a power to promote wellbeing for the economic, social and environmental aspects of their local community. This is reflected in authorities in making an explicit statement on wellbeing, training councillors and officers to understand the wellbeing agenda with a clear community engagement plan.

The recent controversial Health and Social Care Act 2012 gives local authorities the responsibility for the public health function from the NHS, along with developing health strategies for the wellbeing of the local population and leadership of the Health and Well Being Board. Finally, The Localism Act 2011 gives a clear mandate for council to devolve power, support the development of Neighbourhood Forums/Parish Councils and be more transparent with the public regarding expenditure and decision making processes. These statutory powers give a clear obligation for all councils particularly Barnet to have plans and strategies to promote and enhance the wellbeing of the local community.

The only way that Barnet Council and especially their Planning Committee can make a proper assessment of the wellbeing of people in Barnet and Brent is to undertake what is known as a Health Impact Assessment (HIA).

HIA is used a lot in the UK and internationally on policy decisions and infrastructure projects in a variety of areas such as education, employment, transport, green space, housing, and finance and welfare impact on health. The HIA can identify potential or actual health impacts of polices and thus using the results this can to minimise any negative and maximise positive impacts or even defer a project.

Under the leadership of the former Mayor of London, Ken Livingstone used HIA to inform all major policies and regeneration projects in London such as the Olympics and the introduction of the Congestion Charge. When I worked for the NHS in Brent I lead two HIAs on Wembley Stadium redevelopment and Central Middlesex Hospital.

The key essence of a HIA is to promote the maximum health of the population. I believe that using the following principles and values we can determine the potential impact of the Welsh Harp development:

Democracy, emphasising the right of people to participate in a transparent process for the formulation, implementation and evaluation of policies that affect their life, both directly and through the elected political decision makers;
Equity, emphasising that HIA is not only interested in the aggregate impact of the assessed policy on the health of a population but also on the distribution of the impact within the population, in terms of gender, age, ethnic background and socio-economic status;
sustainable development, emphasizing that both short term and long term as well as more and less direct impacts are taken into consideration; and
Ethical use of evidence, emphasising that the use of quantitative and qualitative evidence that has to be rigorous, and based on different scientific data.

Over the last decade the health inequality gap is getting wider in North London. For instance if you drive along the A5 from Kilburn to Colindale life expectancy increases by about approximately 10 years. However West Hendon according to the recent Barnet Joint Strategic Needs Assessment (2011-2015) is an area of multiple deprivations with one of the lower rates of life expectancy for men and women in Barnet. That is why an HIA will be important for the Welsh Harp development.

It is difficult to speculate at this stage what would be the likely health impact but similar studies and research indicate the potential following impact that could apply to Welsh Harp:

• Increased sense of isolation and impact on mental wellbeing;
• Lack of sense of community and social capital;
• More road traffic accidents especially involving children;
• Limited support and intergenerational dialogue with young and older people;
• Greater pollution during the construction phase;
• Increased emission and noise levels;
• Increased health inequalities particularly respiratory diseases such as asthma and hay fever;
• Increased fuel poverty and limited financial inclusion;
• Increase wealth and income inequality with the creation of gated communities for more affluent residents;
• Community safety issues around perceived increased fear of crime and criminal damage during the construction phase.

I believed that Barnet Council in partnership with Brent Council should develop a joint approach with the Directors of Public Health as lead officers to undertake a detailed health impact assessment of Welsh Harp plans using the above principles and involving key stakeholders affected by the development.

I also urge Boris Johnson as Mayor who now has clear strategic powers and responsibilities for public health in London to be committed to ensure that his future plans for any major policy change or regeneration project use HIA. I hope he will put pressure on Barnet Council or use powers to ensure that he health and ecological impacts are carefully considered.

We must put people before profits if we want a safe, healthy and sustainable community in both Brent and Barnet. Let’s work together and Save Our Welsh Harp for future generations of local people in North London.