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
|
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