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 ,
Transition WillesdenMaking Willesden Green