Welsh Harp Conservation Group submission

May 1st 2013 Re: West Hendon Re-development. Planning Application H/01054/13 This letter has been written on behalf of the Welsh Harp Conservation Group. It is in response to the above Planning Application and lists our concerns, comments and objections.

Significance of Northern Reservoir/Refuge/Marsh and associated woodland The site was designated as a SSSI for a range of reasons. The citation covers specific waterfowl species, Great Crested Grebe, Shoveler, Pochard during the breeding season, also for assemblages of breeding waterbirds including both waterfowl and wetland songbirds such as Reed Warbler amongst others.

 Some notable water plants in the marshy margins are also covered. Several habitats are mentioned in the citation from open water and marsh to willow carr and wet woodland. The Northern reservoir is an important refuge used by wildfowl, especially when there is disturbance on the main reservoir from sailing. It functions this way throughout the year but especially during the autumn and winter months when the normal numbers of birds increase by several hundred displaced ducks and other wildfowl.

 The area most used by these birds is along the bank next to the estate. An important screen of trees currently separates the water from the estate. The marshy northern end of the water is also important for breeding wildfowl in the sheltered pools and channels, some such as Gadwall and Pochard of National importance. Finally at the northern end is a quiet area of wet woodland in which a number of shy woodland birds breed (owls, woodpeckers, warblers).

The area of the re-development abuts the whole of the edge of the waterway, marsh and woodland. The area is an important wetland ecosystem and there are associated communities of flora, fauna and insects. The fact that it is a SSSI should afford a high level of protection under wildlife legislation.

Proposed re-development- key features

The proposal involves a huge increase in the density of housing and exceeds the GLA recommended level for a site of this size increasing from 7-800 housing units to over 2000. A key feature of the proposal is the construction of a number of extremely high tower blocks, up to 29 stories in height; these are sited immediately adjacent to the water and the SSSI boundary. The excessive height of these towers seems more appropriate for a central banking district than a North London suburb. The development will have a major impact on the surrounding area and put a huge strain on local health, education and road infrastructure.

The plans also include two footbridges through the SSSI itself and a planned reduction of the tree screen to give views across the lake from West Hendon Broadway.

Impact on SSSI, Reservoir and Local Nature Reserve Height of blocks, proximity to SSSI and density of built footprint

The towers are far too high and much too close to the refuge.
· There will be a major increase in disturbance of the wildfowl refuge both during construction and when occupied, both due to the excessive height and density of the buildings and the tripling of the number of occupants
 · The towers are too close to the SSSI and the extreme height of the blocks will interfere with flight lines for birds trying to escape from sailing disturbance on the main reservoir. There could also be and increased risk of bird strikes made worse by the large area of glass at all levels of the building.
 · There will be a large increase in the amount of night-time light pollution in what is currently a dark site. External night-time lighting of the towers must be kept to a minimum. Brightly lit towers have been shown to have a detrimental effect on night flying and migrating birds which are killed in collisions with buildings (e.g. Canary Wharf). Certain bat species are especially averse to bright lights
· The ecological survey included a limited single season bat survey. This understated the importance of the site for bats. Previous surveys have recorded seven and possibly eight species present making the site of regional importance.
 · The two reservoirs have an important secondary function as a flood buffer. The huge increase in the local built footprint will increase the rate of run-off and have an adverse effect on the carrying capacity in times of heavy rain. Flood events seem to be on the increase at the site from my own observations over a period of 30 years. Screen of trees The screen of trees is vital for shielding the birds from disturbance and activity on the estate
 · The developers would like to remove tree screening to open up sight lines from West Hendon Broadway. This will make matters worse and increase disturbance. We can expect that this will have a major impact on roosting birds. The existing tree buffer hides all but the single 15 storey tower that currently exists. The tree screen needs to be effectively managed and maintained. New Footbridge Wet Woodlands This is potentially very damaging. The woodland is important as a buffer for the wildfowl breeding area and scarce breeding wildfowl such as Gadwall and Pochard will be disturbed in the pools and reed-beds at the end of the reservoir next to the woodland. It is also of LNR significance for shy woodland birds, owls, woodpeckers etc. This could be mitigated by.
 · Placing the bridge as far north as possible, as close to Halfords as the new envelope allows. The area designated is too broad.
 · By prevent access to the woodlands, it must be a throughway only · Limiting the use of lighting. There should be limited lighting of appropriate design, not left lit at night to preserve the woodlands as a dark site
. · It should be locked overnight and should be constructed to prevent fly-tipping into the river and the SSSI. New Footbridge Cool Oak Lane An appropriately sited footbridge would assist pedestrian safety
· Site important, it must be placed close to the bridge on the north side
· It should be freestanding to prevent damage to the Grade II Listed road bridge

Impact on Barnet and Local Community

Barnet has a duty to conserve and improve the SSSI Barnet has conflicting interests. It wants the estate improved and perhaps could gain financially but leases the lake margins and bank from the Canal and River Trust and has duties to the SSSI
 · The Application is a departure from LB Barnet Local Plan and Core Strategy in terms of Housing Density, Approach to the Open Space and the effect on the SSSI
· The proposal is also in conflict with the GLA London Plan
· LB Barnet has a duty under Wildlife Legislation to conserve and improve SSSI Previous development The extant approved application was originally with high blocks placed near the water.
 · The plans were altered and changed for conservation reasons. The towers were made lower and placed further back
 · The current application is for a more extreme design and should be amended for the same reasons. Local community and Landscape This development will put great strain on local infrastructure, facilities and roads
 · It is a huge density of housing in a suburban area of terraces and semi-detached houses. With the exception of one block set well back the existing estate is low-rise.
· Massive impact on local traffic and parking · Big impact on culturally diverse West Hendon
 · Huge looming presence over what is currently a peaceful lake and the ruin of a tranquil landscape Density of occupation Such a development of densely packed housing and people is out of place in suburban Barnet. · GLA recommended occupancy rate exceeds that specified in the London Plan
· There will be an unacceptable level of increased disturbance on the SSSI due to more visitors and the increase in people on the estate House Martins West Hendon Broadway is home to London’s largest remaining House Martin colony with up to 55 pairs breeding in recent years
· This colony will be damage severely by the demolition of the end two shops on the corner of Station Road to improve traffic flow

Summary This development will have a major and detrimental impact on the Reservoir SSSI, the Local Nature Reserve and the local community. It is inevitable that the SSSI will be adversely affected. In our role as the resident conservation group we consider the key concerns are
 · The tower blocks which should be reduced in height and placed back from the margins of the reservoir.
 · The planned occupancy level which needs to be greatly reduced to a level more appropriate to the area and the setting.
· The damaging northern footbridge which is of doubtful viability
 · The removal of vital screening trees to open up the view and disturb the wildfowl

The part of the development already completed shows the overbearing and inappropriate nature of the building design next to one of London’s most important sites for recreation and natural history. As you can see from the above there are a number of reservations held by the WHCG about the current scheme.

The London Borough of Barnet, The Canal and River Trust (ex British Waterways) owners (of the reservoir) and the developers have a legal duty under existing wildlife legislation to conserve and improve the SSSI and to prevent adverse impact from ‘Damaging Operations’. As the proposals stand it is impossible for them to achieve this aim and we can only expect deterioration in the standard of the SSSI.

We object to the application in its current form and call upon you to do the same and reject this proposal. Yours sincerely Roy Beddard (Chair Welsh Harp Conservation Group)