Dear
Mr Wyld,
Re:
Planning Application H /01054/13
On behalf of Transition Willesden, I am writing to object to this
planning application on the following grounds:
1. Impact on the Welsh Harp SSSI
The plans are sited on the North-Eastern boundary of the Welsh Harp
reservoir – an area which has been designated as an SSSI, and the
whole area is recognised as Metropolitan Open Land. This is the only
SSSI in the Boroughs of Brent and Barnet and is as such a valuable
and unique nature reserve in the London suburbs, which is much loved
and cherished by local residents and visitors from all over the
country, who come specially to view rare bird species. It is
primarily a place of peace and tranquillity, where wildlife of every
kind can be encouraged to thrive.
There are many
brown-filled and derelict and other sites all over Barnet and in
neighbouring Boroughs, which would be much more suitable for
development. These proposed luxury apartments at the edge of the
reservoir, right next to a nature reserve, would command a huge
asking price due to their prestigious location, but in allowing them
to be built there, the wildlife of the Welsh Harp would be destroyed.
(i) The Wildlife and Countryside Act outlines that all SSSIs should
be protected, and Local Authorities have a duty to protect them.
Natural England has reported favourably on the condition of the SSSI
at the Welsh Harp, which, in view of its situation within a built up
area, reflects well on the responsible Boroughs of Barnet and Brent
and the adjacent communities.
(ii) Barnet’s recent Local Plan contains Core Strategy 12,
enhancing and protecting Barnet’s Open Spaces, expressed formally
in Policy CS7. The proposed residential development in the new site
layout is much too close to the edge of the reservoir. This is the
area where a large number of the bird population nest, gather and
feed, and the presence of permanent dwellings and their accompanying
activities is likely to seriously disturb and deter bird life. There
is a danger that birds could fly into the proposed tall buildings.
This site is particularly important for bird populations as no less
than 72 species of birds were recorded by the Welsh Harp Conservation
Group as visiting/breeding in the reservoir during 2011.
(iii) We are sceptical of developers' claims that sufficient
protection would be included in such a large development. The
Sustainability Assessment accepts that there will be some adverse
effects by awarding only 2 out of 3 points to the proposed measures
for mitigation. We are concerned that measures listed such as bird
boxes, planting native trees etc. are token measures which make
nonsense of the national policy of preserving SSSIs as unspoilt sites
for wildlife. We suggest that an independent external organisation
such as Natural England should be asked to recommend the best
measures for the protection of the SSSI and the associated bird life
in particular, and assess whether any such measures would indeed
provide the protection required.
(iv)
Proposals to build two footbridges across the reservoir near to the
Silk stream in the north and to Cool Oak Lane require the same
considerations. Both will disturb the wildlife and though permission
has already been given it is important that the northern bridge
should be as far north as possible, that trees should not be cut down
in order to provide views and walkways, and that great care should
be taken during construction to minimise damage. There is concern for
example that these footbridges could lead to fly-tipping in the area,
which would be harmful to wildlife and pollute the reservoir. Again
Natural England should provide independent advice. The bridge should
be
a through way only, with no access possible to the wet woodland. The
impact of lighting on bats is likely to be a direct impact, whereas
the Environment Statement: non-technical summary, suggests that this
is likely only to be an ‘indirect’ impact. There should be
minimal lighting only to preserve the site as a dark site. We
are also concerned about the proposed felling of trees that contain
features conducive for roosting by bats.
(v) There is insufficient research into existing fauna and flora and
an underestimating of its national and local importance. The
applicant's report mentions wildlife but seems to play down its
national and London wide importance. A Greenspace Information for
Greater London (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.
(vi) We also wish to highlight the very recent report, the
Terrestrial Biodiversity Report by Natural England and others, on
large scale threats to biodiversity. This spells out that our flora
and fauna are increasingly more vulnerable due to climate change and
the destruction of habitat. The report states that,“the protected
area network, which includes Sites of Special Scientific Interest and
National Nature Reserves, will continue to have a valuable role in
conservation... and that climate change will interact with, and may
exacerbate, the impact of other continuing pressures on biodiversity,
such as land-use change and pollution.” We feel it is therefore
imperative to protect our SSSIs before all other considerations. As
the Welsh Harp is a particular site of importance for several birds
and other species, it must be protected at all costs. Damage to
these populations could mean the loss of the SSSI status altogether
and lasting damage to the area.
2. Excessive Height of Buildings
The proposal includes seeking full planning permission for 358 new
residential units in buildings ranging from 5 to 26 stories. This
raises a number of concerns.
(i) Under the new Barnet Local Plan Core Strategy policy CS5,
buildings of up to only 20 storeys are permitted. How then can 26
storey buildings be allowed? This goes against Barnet's own planning
guidelines.
(ii) The Core Strategy also includes the visual effect of high rise
buildings and states that “(planning) decisions will protect local
views from places within Barnet”, and “respect and enhance the
distinctive natural landscape of Barnet”. It surely cannot be
Barnet's intention to withhold such consideration from residents in
the neighbouring Borough of Brent, who will not be protected from
viewing these excessively tall tower blocks. There are many homes
whose main viewpoint is across the reservoir and the prospect of
several 26 storey buildings towering over an otherwise green horizon
is abhorrent.
(iii) The height of the blocks also goes against The
London Plan:
Section
7.7e “The impact of tall buildings proposed in sensitive
locations should be given particular consideration.”
Section
7.7d says tall buildings must not “affect their
surroundings adversely in terms of microclimate, wind turbulence,
overshadowing, noise, reflected glare, aviation,
navigation and telecommunication interference” and “should
not impact on local or strategic views adversely”.
Section
7.8e says “New
development should make provision for the protection of
archaeological resources, landscapes
and significant memorials.”
3. Transport and Air Quality
The Environmental Assessment includes an assessment of the effects of
both the buildings and the extra traffic on future air quality,
concluding that there will be a minor adverse effect . However this
based on the assumption that travel plans will be followed and low
emissions vehicles will be used. The following points should be
considered.
(i) The Core Strategy of the Local Plan promises “to take into
account the impact on air quality when assessing development
proposals.” The whole area is designated as an AQMA- Air Quality
Management Area – and Barnet has an excellent Action Plan designed
to reduce pollution from buildings and transport as well as
supporting an extension of the Low Emission Zone, which has been
unfortunately postponed by the Mayor of London.
(ii) The main pollutants of concern, nitrogen oxides, are lung
irritants and especially liable to harm children and those with chest
problems such as asthma.
All existing residents have been exposed for some time and any future
residents will be for the foreseeable future. It is claimed that
those living in the upper floors will experience better air quality.
However we are not aware of any research measuring air pollution at
different heights in high rise buildings. The measures proposed for
the reduction in emissions from the buildings can be relied on, but
no such reliance can be placed on the use of low emissions cars and
other vehicles, as that is a matter of individual choice.
Additionally it is difficult to reduce nitrogen oxides at the same
time as particle PM10 in diesel engines. This development is
therefore likely to aggravate the pollution significantly within the
area unless a low emission zone is introduced. Only a reduction in
the number of dwellings could reduce the pollution.
(iii). Levels of nitrogen oxide pollution in London along with other
cities in the UK is still way above the safe levels required under UK
and EU legislation. The UK will soon have to pay significant annual
fines to the EU until pollution levels are reduced. This may mean
more effective pollution control measures will have to be introduced
which could affect planning controls for new developments.
(iv) We are concerned
that transport implications have not been taken fully into
consideration. The additional traffic, noise, pollution and
disruption, both during construction and after construction would
have a permanent detrimental effect on the Welsh Harp, which could
never be reversed.
(v) The A5 is already congested, with little capacity to accommodate
additional traffic from 2,000 new homes. From this point of view
alone the amount of housing proposed at this site is excessive.
4. Affordable Housing and Impact on Local Community
We also question the level of provision of affordable housing in this
development. It is not clear how many of the 597 existing dwellings
that will be demolished are council owned. The proposals are for
2,000 new dwellings, of which only 680 will be affordable. This is
less than the 30% proposed in the Local Plan. However a proportion
of the demolished houses are already affordable. It is not clear
where residents will be rehoused in the short term, and moreover it
is unlikely that any of the new units proposed will be affordable to
them should they wish to move back to the area. We understand that
an excessively high service charge plus an obligation to supply
utilities through one company alone will be prohibitive for low
income families. Local people are therefore being priced out of the
area, with an impact on other areas of the Borough.
West Hendon Estate has been neglected for decades and must be
properly improved for the benefit and well being of those who live
there. That means good open space, proper community amenities and
proper housing, not high density tower blocks.
5. Impact on Infrastructure
We
agree with Brent Council's own strong objections that the size of the
development is excessive. There is insufficient infrastructure
planned such as GP surgeries, schools etc. for the amount of
dwellings planned. One primary school alone is not adequate to meet
the needs of a fourfold increase in the local population. The
plan makes no mention of any additional health services.
6. Health and Well-being
We believe that the Welsh Harp plays a vital role in the health and
well-being of local residents in both Brent and Barnet who benefit
from this green open space. Under the Local Government Act 2000,
Local Authorities have a power to promote well being for the
economic, social and environmental aspects of their local community.
This is reflected in authorities in making an explicit statement on
well-being, training councillors and officers to understand the
well-being agenda with a clear community engagement plan.
The recent 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 well-being of the local
population and leadership of the Health and Well Being Board.
Finally, the Localism Act 2011 gives a clear mandate for Councils 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 well-being of the
local community.
Barnet Council needs therefore to make a proper assessment of the
well being of people in both Barnet and Brent by undertaking a Health
Impact Assessment (HIA) to determine the potential impact of the
Welsh Harp development in this respect.
In conclusion, we believe the plans are excessive,
damaging and totally inappropriate for the area, and as such they
should be rejected.
Please acknowledge receipt of this
submission.
Yours sincerely ,
Viv Stein
Transition Willesden
Making
Willesden Green
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