London Borough of Brent’s Local Plan

Development Management Policies Development Plan Documents

Sustainability Appraisal Report Appendices to Part A: Sustainability Context

July 2015

Prepared for London Borough of Brent and Collingwood Environmental Planning

Collingwood Environmental Planning 1E, The Chandlery 50 Westminster Bridge Road London, SE1 7QY, UK

SA Report Contents

CONTENTS

(See separate volumes for the contents of the main SA Report)

APPENDICES

APPENDICES TO PART A: SUSTAINABILITY CONTEXT

Appendix 1: Scoping Report Consultees ...... 3

Appendix 2: Summary of Consultees Comments on Sustainability Appraisal Scoping Report ...... 7

Appendix 3: Review of Relevant Plans and Programmes ...... 23

Appendix 4: Baseline Data...... 47

Appendix 5: Sustainability Objectives, Criteria, Indicators and Targets ...... 99

Appendix 6: Significance Criteria ...... 109

APPENDICES TO PART B: APPRAISAL OF THE DEVELOPMENT POLICIES (included in separate volume)

Appendix 7: Initial Sustainability Appraisal Commentary and LB Brent Responses .. 115

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SA Report Abbreviations March 2014

ABBREVIATIONS

AMR Annual Monitoring Report LDF Local Development Framework AQMA Air Quality Management Area LDS Local Development Scheme BAP Biodiversity Action Plan LEA Local Education Authority BEA Borough Employment Area LES Local Employment Site BIW Businesses, Industry and Warehouses LGA Local Government Association BREEAM BRE (Building Research Establishment) LNR Local Nature Reserve LPA Environmental Assessment Method Local Planning Authority CEP Collingwood Environmental Planning LIP Local Implementation Plan CF Community Facilities MOL Metropolitan Open Land CMS Convention on Migratory Species NDC New Deal for Communities CO Carbon Monoxide NO Nitric Oxide CO2 Carbon Dioxide NO2 Nitrogen dioxide CP Core Policy NVQ National Vocational Qualifications CST Culture Sport and Tourism ODPM Office of the Deputy Prime Minister db Decibels OS Open Space DC Development Control ONS Office of National Statistics DCLG Department for Communities and Local PCT Primary Care Trust Government PM10 Particles measuring less than 10 microns DCMS Department for Culture Media and Sport PPG Planning Policy Guidance Defra Department for Environment Food and PPS Planning Policy Statement Rural Affairs PTAL Public Transport Accessibility Level DETR Department for Transport, Local Government and the Regions RSL Registered Social Landlords DfT Department for Transport SA Sustainability Appraisal DP Development Policy SAP Standard Assessment Procedure DPD Development Plan Document SCI Statement of Community Involvement DTI Department of Trade and Industry SD Sustainable development EA Environment Agency SD Sustainable design EEA Energy Action Area SEA Strategic Employment Area EEC European Economic Community SEA Strategic Environmental Assessment EC European Commission SFRA Strategic Flood Risk Assessment EIA Environmental Impact Assessment SINC Sites of Importance for Nature Conservation ENV Environment SOA Super Output Areas EU European Union SO Sulphur dioxide GPD Gross Domestic Product 2 SPD Supplementary Planning Document GIS Geographical Information System SPG Supplementary Planning Guidance GLA Greater London Authority SRDF Sub Regional Development Framework GOL Government Office for London SSSI Site of Special Scientific Interest GP General Practitioner SUDS Sustainable Urban Drainage GQA General Quality Assessment TC Town Centre H Housing TPO Tree Preservation Order HA Housing Association TRN Transport Ha Hectare UD Urban Design IEA Industrial Employment Area UDP Unitary Development Plan IMD Index of Multiple Deprivation UNFCCC United Nations Framework Convention on I & O Issues and Options Climate Change LA 21 Local Agenda 21 VAT Value Added Tax LBB London Borough of Brent LB WFD Water Framework Directive Brent London Borough of Brent WLWDA West London Waste Disposal Authority LBPN London Bus Priority Network (known as WestWaste) LCN+ London Cycle Network Plus ZED Zero Energy Development LDD Local Development Document

Brent’s Development Management DPD Appendices Preferred ii Options – SA Report (Appendices to Part A)

APPENDICES

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APPENDIX 1

SCOPING REPORT CONSULTEES

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Appendix 1

Sustainability Appraisal Scoping Report Consultees

The consultees formally consulted on this Scoping Report (including as part of the SEA determination process set out in Regulation 9) as required by the SEA Regulations were:

• Natural England (superseded Countryside Agency and English Nature)*

• English Heritage *

• Environment Agency*

Other consultees included internal departments within the Council and the following external organisations:

• Government Office for London

• Greater London Authority

• London Development Agency

• London Wildlife Trust

• Adjacent London Boroughs (Barnet, Camden, Ealing, Hammersmith & Fulham, Harrow, Kensington & Chelsea and Westminster)

• Partners for Brent (the Local Strategic Partnership)

• Brent Energy Network

Those that responded are marked with an asterisk. Details of these comments are included in Appendix 2.

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APPENDIX 2

SUMMARY OF CONSULTEES COMMENTS ON SUSTAINABILITY APPRAISAL SCOPING REPORT

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Appendix 2

Summary of Consultees Comments on Sustainability Appraisal Scoping Report

The following table summarises how the comments and issues raised by the formal consultation on the SA Scoping Report were addressed.

(Page and section numbers refer to the SA Scoping Report (June 2005) except where otherwise stated)

Comment Response / Changes to SA

Countryside Agency Baseline and maps: - EN5: Townscape and Landscape Quality. Use of map Map of areas of low townscape quality included commended. Recommended to update this map if in Part A of SA Report (Figure 23). Update necessary. requested from LBB but not available.

- Consider wider use / role of Landscape Character Comment passed on to the officers responsible Assessment in development of LDF, and particularly for preparing the LDF. monitoring. Refer to “Landscape Character Assessment: Guidance for England and Scotland” April 2002 (CAX84) and www.ccnetwork.org.uk

- Consider Volume 7 of the Countryside Character Information added to Baseline table (see (publication reference CA13). Contains character Appendix 5). information on areas in Greater London (in particular CCAs 81, 111-115 and 119

- Consider CA maps of open countryside and registered Not applicable common land – Areas 1 and 8. Due to be issued summer 2005, at www.openaccess.gov.uk

- Review annual State of the Countryside Reports and Information reviewed. related data at: www.countryside.gov.uk/evidenceandanalysis/state_o f_the_countryside_reports/index.asp and www.countryside.gov.uk/EvidenceandAnalysis/dataHu b/2004_dataarea/index.asp Key sustainability problems: Consider whether any further landscape/townscape No changes consider necessary. character issues / problems should be included Suggested modification to sustainability objective EN5: This has been amended as suggested (See Change to – “EN5: to maintain and enhance the character Table 8 in Part A) and quality of landscapes and townscapes” Consider whether there is any land in Brent designated as Not applicable conditionally exempt from capital taxes on grounds of outstanding scenic, scientific or historic interest? For up-to-date list go to: www.hmrc.gov.uk/heritage/lbsearch.htm Access and recreation: Not applicable Potential impacts on access land, public open land and rights of way should be fully considered. Particularly the Thames Path National Trail. Info at www.nationaltrails.gov.uk

Environment Agency Review of other policies and plans – include: Regional Blue Ribbon Policy: reviewed and - National Wildlife and Countryside Act, 1981 added to PPP list. - Countryside and Rights of Way Act, 2000 National legislation has not been included in - Salmon and Freshwater Fisheries Act 1975 review as at this level. - Regional Blue Ribbon Policy

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Comment Response / Changes to SA

P.24 section 4.31 Wildlife corridors mentioned in Section 3 (Para.

Note additional important wildlife corridor running down the 3.47) of SA Report River Brent

Section 4.26

Expressed extreme concern about lack of information on Flood risk map has now been included in section fluvial and surface water flood risk in this section. Urge 3 of Part A of main SA Report inclusion of information on: - Water quality. Important to include implications of the WFD reference has been added in section 3 of WFD. Part A

- Fluvial flood risk. Note that areas of Brent fall within fluvial flood plains of the following rivers: River Brent, Flood risk map included Wealdstone Brook, Wembley Brook, Mitchell Brook, Grand Union Canal, Kenton Brook and Silk Stream

- Refer to PPG25. In accordance with it, any The requirements of PPG25 have been development should be resisted which has the considered when undertaking the appraisal and potential to contribute to flood risk and have an will be more relevant to the appraisal of the Site adverse impact on river channel stability or damage Specific Allocations DPD wildlife habitats.

- Consider undertaking a Strategic Flood Risk Comment passed on to the officers responsible Assessment (SFRA) to zone development within the for preparing the LDF. SFRAs referred to in whole borough. Such an assessment should be draft DPD. undertaken in discussion with the EA.

- Recommendation that new development be kept As above outside of the 1 in 100 year floodplain taking into account climate change.

- Need to include reference to the inclusion of SUDS in References to SUDS included in SA report new developments. Also promote the use of water conservation techniques such as grey-water reuse / rainwater harvesting should be promoted as should the development of green roofs.

- Proximity of proposal to rivers and river corridors. This comment will be taken into account in the Section needs to make reference (currently absent) to appraisal of the Site Specific Allocations and the need to preserve the integrity of rivers and their Development Control Policies. associated corridors by providing an undeveloped buffer strip between proposed developments and the brink of watercourses. For fluvial main rivers this buffer strip should be 8 metres wide measured from bank top.

Key sustainability issues

Page 30 - Row 9: reference should be made to the need to Rows 9 and 11 of Table 7 (Part A): Key restore and enhance degraded habitats in the borough sustainability problems have been modified – e.g. rivers and driver corridors as a means of accordingly. satisfying the WFD which emphasises the need to enhance heavily modified water bodies. Examples such as the restoration of the River Brent at Tokyngton Park should be further promoted throughout the borough. - Row 12: Fluvial and Surface water flood risk should be Distinction has been made between surface and separated into separate rows. Reference must be river flooding in row 12 of Table 7: Key made to EA flood zone maps, and particularly at risk sustainability problems (Part A of main SA areas in the borough. Report) and flood risk areas map has been included (Figure 19)

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Comment Response / Changes to SA

Sust. Objectives and criteria

Page 33 - Water resources: Section must include the reduction Flooding from all sources is included under the of fluvial and surface water flood risk as prime Climate Change objective in Table 8: objectives. Preventing development in flood plains Sustainability objectives and criteria of Part A of and ensuring that surface waters are disposed of SA Report. sustainably will ensure that risk of flooding to additional people and property is reduced. - Biodiversity: Section should not only focus on This is sufficiently covered in the criteria under preserving existing sites of good quality but should Biodiversity (Table 8: Sustainability objectives also seek to enhance degraded sites within the and criteria of Part A of SA Report) borough – in line with the WFD. - Climate change: This section should also refer to PPG25 which asks that the impact of climate change Not considered relevant to objectives and be considered when undertaking FRAs. criteria, but considered elsewhere

Page 36 Section 7.6

Refer also to fluvial flood risk as well as surface water Text not repeated in SA Report, but comments flood risk. noted Page 82 Objective 10: Rather than create a new objective our appraisal - “The reduction of flood risk” should be a separate framework will be assessing all Spatial Strategy objective. policies against each sub-criteria, including flood - Row entitled “Flood risk areas” should refer to EA risk reduction. flood zone maps. - Last 3 rows of objective 10 should reference flood zone maps which provide information on people at risk of fluvial flooding, and refer to frequency of fluvial events. Page 86 Objective 12 Should seek to enhance degraded sites in borough as well Felt sufficiently reflected in criteria as preserving existing sites of good quality – in line with WFD

English Heritage Consider “Environmental Quality in Spatial Planning” June 2005 Documents reviewed and added if appropriate and “Heritage Counts: State of the Historic Environment” Ensure design issues are considered in the baseline – and develop monitoring indicators (qualitative as necessary). These documents should inform the update of the environmental baseline. Consider “Making Design Policy Work” – CABE, June 2005 As above – which provide guidance and good practice on the development of LDFs. Consider the following EH documents in the development As above of the baseline and options: - Transport and the Historic Environment - Streets for All - Regeneration and the Historic Environment - Local Strategic Partnerships and the Historic Environment

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Comment Response / Changes to SA Review of other policies, plans and programmes, should As above also include: National - Planning (listed buildings and conservation areas) act, 1990 - Ancient Monuments and Archaeological Areas Act, 1979 - The Historic Environment: A Force for Our Nature (DCMS 2001) Regional - The London Plan - Draft Sub-regional Development Framework – west London (June 2005) - Draft SPG on Sustainable Design and Construction (March 2005) Local - Conservation Area Appraisals - Cultural Strategy These have been included when information Baseline was available / relevant Consider the following statutory designations and their settings: - World Heritage Sites - Listed Buildings - Scheduled Ancient Monuments - Archaeological Priority Areas - Registered Historic Parks and Gardens - Registered Battlefields - Conservation areas Also consider: As above Other archaeological sites, locally listed buildings, parks, character of the wider landscape, historic landscapes and potential for as yet unrecorded archaeology. Wider historic environment should be considered in assessment of future trends. Suggested information sources: As above - Heritage Counts: www.heritagecounts.org.uk - Greater London Sites and Monuments Record - National Monuments Record Centre, Swindon - Magic www.magic.gov.uk - English Heritage annual Buildings at Risk Register - Local Authority conservation team for locally listed buildings - Local History / studies centres Suggested indicators: As above - Number of listed buildings under each grade - Number and % of listed buildings at risk - Number of scheduled ancient monuments - Number and % of archaeological sites at risk - Number of registered historic parks and gardens - Number of conservation areas - Number and % of Conservation Areas with appraisals - Impact of change on character and appearance of conservation areas - % or areas of historic buildings, sites and areas affected whether in adverse or beneficial way - Street / public realm audits, improvement works, de- cluttering works - % residents content with character and appearance of local area - Rate of loss of historic landscape features - Erosion of quality character and distinctiveness

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Comment Response / Changes to SA Key sustainability issues: No action, it has been accounted for Consider impact / pressure of development on areas not specifically protected, but which are considered to have historic value or make Suggested objectives: This is sufficiently covered by existing criteria - Preserve and enhance the character and appearance of archaeological sites, historic buildings, conservation areas, historic parks and gardens, and other culturally important features and areas, and their settings - Protect and enhance the character and appearance of townscape / landscape - Maintain and strengthen local distinctiveness and sense of place - Improve quality of the public realm, creating places that work well, are maintained and managed and are attractive to users Options: This has been covered by the appraisal Concern expressed that the issues and options for the historic environment are not clearly set out in report. Should be explicitly addressed given it is a key objective of the LDF. Closely involve Council conservation staff in the SA Noted process. Brent Planning and Policy team General: This is accounted for in report Entire report talks about an integrated SA / SEA approach at the beginning, but only seems to talk about SAs from then on. Review of other policies, plans and programmes should Added include: - EU Directive on energy performance of buildings 2002/91/EC 16, December 2002 Baseline: Indicator IDs are not included in final version of - Indicator IDs missing report

- References / sources need to be clearer. Revised in baseline summary and baseline table

- Sustainability objective 6 linked to air quality issue. Unclear (objective numbers changed?) Can more linkage or reference be made?

- Sustainability objective 10 - touches on potential flood Felt sufficiently covered in criteria risk – a potential consequence of climate change. Not enough linkage or reference to CC objective.

- Sustainability objective 20 – might be helpful to write Objective changed promote “ ‘sustainable’ regeneration” Agree, however the objectives are meant to - Sustainability objective 22 – links to travel & air quality highlight specific Sustainability issues. – links could be made more explicit Commentary will seek to bring out issues such as this one. Section Comments: - 4.1 – last word should be ‘affected’ not ‘effected’ Done

- 4.23 Links with various other indicators (to their This has been revised in section 3 of SA Report detriment). Could expand on the implications of traffic problems in damaging health, quality of life / sense of place / comfort (heavy traffic is unpleasant to have around) & biodiversity, reducing economic efficiency & potential detriment to regeneration opportunities.

- 4.26 & 4.27 need explicit reference to climate change As above which is likely to have a significant detrimental effect

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Comment Response / Changes to SA on flooding in the Borough. Also exacerbated by trends such as increased paving of frontages.

- 4.28 / 9 could make more specific reference to health As above implications of poor air quality & the fact that the NC rd is the most polluted A road in London. Key sustainability problems: 15. There should be some sort of reference to or separate This has been highlighted in Table 7 of SA problem regarding renewable energy installations. There report and mainstreamed into appraisal criteria are currently only four known installations in the Borough whose outputs are unknown. All efforts should be made to encourage and increase the number of renewable energy installations in the borough. Issues and options: Text not repeated in SA Report therefore no Consistency issues: need for change, but comments noted Sometimes ‘potential options’ is used & sometimes ‘options’ is used, which could give the impression that some options are more likely or preferred.

- 7.6 better to list as ‘noise’, ‘air quality’, ‘contaminated land’ in keeping with the rest.

- Energy efficiency needs to be explicitly stated and emphasised. Higher energy efficiency needs to be required in buildings; the Building Regulations are a minimum legal requirement and cannot require higher standards according to local circumstances as planning requirements potentially could.

- 7.7 Final paragraph could be slightly more clearly worded.

- 7.10 Location of out of centre superstores - should there not be consideration of whether such developments are needed at all?

- 7.11 1st para – should be ‘especially’ not ‘specially’

- 7.12 is it really viable to be looking into giving up areas of public space for burial sites?! Should we not perhaps be promoting more long-term sustainable options (e.g. cremation) as this is only going to be an ongoing & growing problem?

- 7.14 should read ‘ways of reducing’, not ‘ways for reducing’. Also, either commercial should be included, or just talk about maximising recycling (perhaps specifying ‘including construction’ so people don’t just think of domestic waste).

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APPENDIX 3

REVIEW OF RELEVANT PLANS AND PROGRAMMES

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Appendix 4

Review of Relevant Plans and Programmes

Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SAs International 1. Kyoto Protocol Aims to minimise the adverse affects of climate change by limiting The DPD should aim to reduce greenhouse The DPD needs to consider impact of new and reducing the emission of greenhouse gases. gas emissions. development on climate change and plans for its impact. 2. The Johannesburg Aims to build a humane, equitable and caring global society. Key The DPD will need to consider the The DPD will need to ensure that it Declaration on objectives include the sustainable use of resources, energy protection and management of natural encourages the aims set out in the sustainable Development efficiency and biodiversity and to promote more sustainable resources and biodiversity. Declaration. 2002 production and consumption patterns.

3. Bern Convention on the Aims to ensure conservation of wild flora and fauna species and The SA Framework should consider the The DPD must have regard for the Conservation of their habitats. Special attention is given to endangered and impact of development on pollution control conservation of vulnerable species and European Wildlife and vulnerable species, including endangered and vulnerable migratory and impact on wild flora and fauna habitats in the area. It should ensure that its Natural Habitats (1979). species specified in appendices. The Parties undertake to take all including habitats, particularly any policies are not in conflict with the protection appropriate measures to ensure the conservation of the habitats of endangered species and conservation of these species. the wild flora and fauna species. 4. Ramsar Convention on The Convention on Wetlands, signed in Ramsar, Iran, in 1971, is SA framework will need to consider the There are no RAMSAR sites within the Wetlands of International an intergovernmental treaty which provides the framework for impacts of development on natural London Borough of Brent. However, the core Importance (1971). national action and international co-operation for the conservation resources. practices and objectives of the Convention and wise use of wetlands and their resources. can be integrated into the DPD, including the water courses running through the area. European

5. European Spatial EU aim of achieving a balanced and sustainable development, in The Sustainability Appraisal Framework The DPD should achieve balanced and Development Perspective particular by strengthening economic and social cohesion should take a balanced approach to sustainable development in the context of 97/150/EC development. Brent and the region, and should provide fair opportunities for poorer and disadvantaged people. 6. European Directive on Aims to sustain populations of naturally occurring wild birds by The SA framework will need to consider the The DPD should support and sustain wild bird the Conservation of Wild sustaining areas of habitats to maintain populations at ecologically impacts of the AAP’s proposals on wild bird populations, their habitats, nests and eggs Birds 79/409/EEC and scientifically sound levels. This applies to birds, their eggs, populations and incorporate appropriate and development should not impact adversely nests and habitats. objectives/ indicators to maintain and on this by ensuring habitats are maintained improve habitats. and improved.

7. European Directive The Directive aims to reduce and prevent water pollution caused or The SA framework will need to incorporate The DPD should support the overall Nitrates 91/676/EEC induced by nitrates from agricultural sources. objectives concerning reducing pollution. objectives and requirements of the Directive.

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8. European Directive Aims to enhance waterways and wetlands, to ensure water is used SA to include objectives/ indicators for The DPD should support the overall Water Framework in a sustainable way, to reduce groundwater pollution, to lessen the improving water quality its use, the objectives and requirements of the Directive. 2000/60/EC effects of floods and droughts and to protect and restore aquatic ecological status of inland water bodies ecosystems. (biodiversity) and lessening the impacts of flooding.

9. European Directive Promotes the improvement of the energy performance of buildings The SA framework should include The DPD should support the overall Waste Framework within the community, taking into account outdoor climatic and local objectives/ indicators which consider objectives and requirements of the Directive. 75/442/EEC conditions, as well as indoor climate requirements and cost energy efficiency. effectiveness.

10. European Directive To monitor noise exposure, its effects and to implement measures The SA framework should consider any The DPD will have to reflect the outcomes as Assessment and to address noise pollution and to maintain environmental noise. adverse noise impacts. set out within Brent’s Noise Action Plan. Management of Environmental Noise 11. European2002/49/EC Directive Establishes mandatory standards for air quality The SA framework should consider any The DPD should consider the contribution that Ambient Air Quality and adverse impacts with regard to air pollution. spatial development may have on air pollution Management 1996/62/EC and try to minimise its impact where possible by promoting more sustainable transportation.

National 12. Securing the Future. The The Government’s highest level sustainable development While much of the national sustainable UK Government Sustainable strategy. strategy will beyond the scope of the DPD it remains important for it to reflect the new Development Strategy, Sets out a new purpose and principles for sustainable national strategic priorities and principles. March 2005 development and new shared priorities agreed across the UK, including the Devolved Administrations. The strategy contains: • A new integrated vision building on the 1999 strategy – with stronger international and societal dimensions • Five principles – with a more explicit focus on environmental limits • Four agreed priorities – sustainable consumption and production, climate change, natural resource protection and sustainable communities • A new indicator set, which is more outcome focused, with commitments to look at new indicators such as on wellbeing.

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13. Defra (July, 2004). Making DEFRA held a three month consultation on a new cross- The new strategy will require a holistic The DPD will need to not only reflect Space for Water: Government strategy for flood and coastal erosion risk approach to flood risk management, existing policy in PPS25, but also the Developing a new management during Autumn 2004. The Government's First incorporating the implications of climate evolving strategy. Government Strategy for Response to Making space for water has now been published change, better management of risk Flood and Coastal Erosion (March 2005). A summary of the consultation responses and an through flood risk assessments at all Risk Management in updated Regulatory Impact Assessment have also been levels. England. A Consultation produced. Exercise. And First The First Response sets out the strategic direction of travel on Response, DEFRA, March key issues. For those areas of complex policy that it cannot 2005 resolve, it sets out the programme of work required to achieve this. The Response also sets out the aim of the new strategy: To manage the risks from flooding and coastal erosion by employing an integrated portfolio of approaches which reflect both national and local priorities, so as: • to reduce the threat to people and their property; and • to deliver the greatest environmental, social and economic benefit, consistent with the Government's sustainable development principles. To secure efficient and reliable funding mechanisms that deliver the levels of investment required to achieve the vision of this strategy. 14. Communities Plan The Communities Plan establishes a long-term programme of It is important the DPDs do not conflict The DPDs should be aware of the (Sustainable Communities: action for delivering sustainable communities in England. with this national programme of action. elements of the Communities Plan and Building for the Future); follow the relevant principles. 2003. It aims to tackle housing supply issues in the South East; low demand in other parts of the country; and the quality of public spaces. It marks a step change in policies for delivering sustainable communities for all. The main elements are:

• Sustainable communities. • Step change in housing supply. • New growth areas. • Decent homes; including the need to bring council homes up to a decent standard. • Improvements to the local environment; particularly the public realm.

15. UK Climate Change The Climate Change Programme is designed to deliver the UK’s The draft Development Policies DPD can Programme, 2006 (Defra) Kyoto Protocol target of reducing emissions of the basket of six play a significant role in reducing CO2 greenhouse gases by 12.5 per cent below base year levels over emissions. The DPD should be aware of, the commitment period 2008-2012, and move the UK close to and contribute to meeting UK’s the domestic goal to reduce carbon dioxide emissions by 20 per commitment. cent below 1990 levels by 2010. It also aims to put the UK on a path to cutting carbon dioxide emissions by some 60 per cent by about 2050, with real progress by 2020. 16. Decent homes and decent The government has a target to ensure that, social homes meet DPDs should take these targets into communities, DCLG, 2006 minimum standards of decency, and that 70 per cent of account. vulnerable households in the private sector have decent homes.

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17. DCLG, Code for Sustainable This code aims to facilitate a step-change in design and DPD should take the Code for Homes: A step-change in construction of new homes for sustainability. It sets out new Sustainable Homes into account. sustainable home building national standards for buildings using a rating system. practice, 2006 Compliance with the Code is currently voluntary, but Government is considering making them mandatory. 18. DTI Energy white paper: The DPD should include measures to reduce This white paper sets out the Government’s international and meeting the energy energy consumption domestic energy strategy for long term energy challenges. challenge, 2007 It seeks to aid deliver four energy policy goals: - to put ourselves on a path to cutting CO2 emissions by some 60% by about 2050, with real progress by 2020; - to maintain the reliability of energy supplies; - to promote competitive markets in the UK and beyond; - to ensure that every home is adequately and affordably heated. It details the implementation measures of the Energy Review Report (2006) and those announced since. Some of the measures require further consultation. 19. English Heritage, This is a joint guidance document in achieving environmental Included are comprehensive checklists The DPD should take this guidance Countryside Agency, quality through spatial planning. to scope, proof and Local Plans. These are document into account English Nature and It updates previous documents produced by each organisation, intended to be comprehensive in terms of Environment Agency, and complements recent guidance produced by ODPM following what the four agencies would like to see Environmental quality in the publication of PPS11 (Regional Spatial Strategies) and included in plans and strategies. Spatial Planning, PPS12 (Local Development Frameworks). Incorporating the natural, built and historic environment, and rural issues in plans and strategies, 2005 Making Design Policy Work: This guidance sets out five fundamental factors for good local Good design should be integrated in the how to deliver good design design policies. It explains where different types of policy can fit draft Development Policies DPD through your local into the different local development plan documents, and development framework suggests key objectives for a range of design policies from CABE, June 2005 landscaping to architecture 20. Draft Climate Change Bill The Climate Change Bill is intended to provide a clear, credible The the draft Development Policies DPD (March, 2007) and long-term framework for tackling climate change. It aims to can contribute to the UK framework for reducing carbon dioxide emissions via the following four tackling climate change. Policies and elements: supporting text should reflect the goals and objectives of the Bill through reductions in • Setting targets in statute and carbon budgeting carbon dioxide emissions. • Establishing a Committee on Climate Change • Creating enabling powers • Reporting requirements

The elements of this Bill create a framework to achieve a more coherent approach to managing climate change in the UK via ambitious targets, powers to achieve them, a strengthened institutional framework and clear and regular accountability to Parliament.

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21. Climate Change and The principal Purpose of the Act is to enhance the UK’s The policies included in the draft Sustainable Energy Act contribution to combating climate change. Overall, it aims to Development Policies DPD can contribute (2006) increase energy efficiency and reduce green house gas to national energy and climate change emissions. related targets.

In accordance with the Act, local authorities will have to publish an energy measures report in exercising their functions and from time to time may have to publish revised energy measures reports. 22. DCLG, Planning white This white paper sets out our detailed proposals for reform of Decision making in the DPD should respond paper: Planning for a the planning system, including, improving the speed, to changes in the planning system made Sustainable Future, responsiveness, efficiency in land use planning. as a result of this white paper. Consultation 2007 It proposes reforms on decision making and further reforms to the Town and Country Planning system. 23. Waste Strategy for England, The waste strategy sets up the vision for sustainable waste The draft Development Policies DPD 2007 management in England, with the following key objectives: should take this white paper into account • decouple waste growth (in all sectors) from economic and include policies that help deliver the growth and put more emphasis on waste prevention and re- objectives of the waste strategy. use; • meet and exceed the Landfill Directive diversion targets for biodegradable municipal waste in 2010, 2013 and 2020; • increase diversion from landfill of non-municipal waste and secure better integration of treatment for municipal and non- municipal waste; • secure the investment in infrastructure needed to divert waste from landfill and for the management of hazardous waste; and • get the most environmental benefit from that investment, through increased recycling of resources and recovery of energy from residual waste using a mix of technologies.

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SAs National 24. The Localism Act 2011 Aims to further promote sustainable development, promotes The DPD should seek to reflect the The DPD needs to reflect the needs and community “right to buy”, provides further clarification on the sustainability objectives in the Act. representations of the local community, and Community Infrastructure Levy and promotes empowerment to should promote sustainable development. allow local community groups to produce neighbourhood plans.

25. Flood and Water Management Introduced in response to the floods of 2007, aims to overhaul the The DPD should consider flood risk and The DPD should support the aims of the Act 2010 management of water resources and infrastructure. Includes sustainable urban drainage. F&W Management Act to encourage the measures to encourage the uptake of SUDs. uptake of SUDs.

26. National Planning Policy The National Planning Policy Framework sets out national The DPD needs to consider how it can The DPD should consider the three Framework (2012) planning policy and provides general guidance on a wide range of contribute to the delivery of sustainable dimensions to sustainable development: planning matters. Of general importance is the introduction of a development through: economic, social and environmental. presumption in favour of sustainable development an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs;

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and support its health, social and cultural well-being; and

an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.

27. DCLG PPS10: Planning for Regional planning bodies and planning authorities should Mainly relevant for West London waste Sustainable Waste prepare and deliver planning strategies that:: DPD, but the draft Development Policies Management. • help deliver sustainable development through driving waste DPD should take this guidance into management up the waste hierarchy, addressing waste as a account where relevant resource and looking to disposal as the last option but one which must be adequately catered for; • enable sufficient and timely provision of waste management facilities to meet the needs of their communities; • help implement the national waste strategy, and supporting targets, and are consistent with obligations required under European legislation; • help secure the recovery or disposal of waste without endangering human health and without harming the environment and ensure waste is disposed of as near as possible to its place of production; • reflect the concerns and interests of local communities, the needs of waste collection authorities, waste disposal authorities and business and encourage competitiveness; • protect green belts but recognise the particular locational needs of some types of waste management and that the wider environmental and economic benefits of sustainable waste management are material considerations that should be given significant weight in determining whether proposals should be given planning permission; • ensure the layout and design of new development supports sustainable waste management.

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA Regional / London 28. The Mayor’s London Plan: The London Plan sets out strategic planning policies for The DPD should conform with the Spatial Development London. As such the London plan is the key planning document London Plan and should reflect its strategic Strategy for Greater London; for the capital. planning objectives. . 2014.

29. Draft Further Alterations to The London Plan sets out strategic planning policies for The DPD should be in conformity with the Mayor’s London Plan: London. As such the London plan is the key planning document the London Plan and should reflect its Spatial Development for the capital. strategic planning objectives. DPD should Strategy for Greater London; also take into account the proposed further 2006. alterations to the London Plan, especially the criteria based policies. 30. Planning for Equality and This SPG provides detailed guidance on how to implement the The DPD should take into account equality Diversity in London. The key London Plan policies relating to equality and diversity. It is issues at the earliest stage in the preparation London Plan (Spatial principally aimed at local authority planners responsible for of DPD. Development Strategy for producing DPDs and community strategies. Greater London) Draft Supplementary Planning The purpose of this SPG is to give more detailed guidance on Guidance, 2007 policies with equalities implications, to encourage developers and planners to consider equality issues at the earliest stages of applications and in the preparation of DPDs. Specifically in relation to Policy 3A.14 Addressing the Needs of London’s Diverse Population

It provides guidance on some of the tools available for addressing equality issues and how to take equalities issues into consideration.

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA 31. Providing for Children and This SPG provides guidance to London Boroughs on The DPD will have to respond to and Young People’s Play and providing for play and recreation needs of children and young reflect this guidance in providing for play Informal Recreation. The people (under the age of 18). It also provides guidance on the and recreational needs of children and London Plan (Spatial use of benchmark standards in the preparation of Play and young people. Development Strategy for Informal Recreation Strategies. Greater London) SPG, 2008 32. The Mayors Sustainable This SPG provides additional information to support the The DPD should reflect this guidance and Design and Construction: implementation of the Mayor’s London Plan (the Spatial use the criteria for sustainable design and The London Plan Development Strategy) and is applicable to all development construction as appropriate. The SA should Supplementary Planning types and associated spaces. use these as a benchmark to inform the Guidnace, 2013 appraisal of the Development policies in It provides guidance on implementing London Plan Policy 4B.6 particular. on sustainable design and construction. 33. Entec UK Sustainability This report sets out the results of the final iteration of the Contains a source of useful information Note as part of the SA. Appraisal of the London Sustainability Appraisal that was undertaken in on objectives, issues of importance etc. Plan, Final Report, April, November/December of 2003. 2004. 34. Sustainability Appraisal of This Sustainability Appraisal Report sets out the results of the Contains a source of useful information This is a key contextual document. Note the draft further alterations to Sustainability Appraisal, produced in full in September 2006, on objectives, issues of importance etc as part of the SA, including the findings of the London Plan (spatial and re-issued April 2007. the assessment of policies as well as development strategy for context. Greater London), Forum fore the Future and Ben Cave Associates, 2006, re- issued, 2007.

35. A Sustainable Development Sets out an overarching framework for sustainable development This is a key contextual document. The Framework for London. for the city. Framework consists of a vision; overall objective DPD and SA should reflect the vision and London Sustainable and framework objectives. These are under four themes: objectives of this high-level sustainability Development Commission; Taking responsibility; developing respect; getting results and document. June 2003. managing resources.

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA 36. The Mayor’s Transport The Transport Strategy supports the aims of the emerging Relevant targets include: This Strategy’s objectives, policies and Strategy Revision (2004) London Plan (the Mayor’s Spatial Development Strategy), in • Traffic volumes: Achieving zero proposals are integrated within the London and Transport Strategy promoting London’s economic and social development and growth in outer London town centres Plan (Spatial Development Strategy). LB Implementation Targets improving the environment. The Strategy will increase the • Modal shift (New target): TfL and Brent is required to produce a Business (2004). capacity, reliability, efficiency, quality and integration of boroughs are to maintain or increase Plan and LIPs to set out how they will London’s transport to provide the world class system the Capital the proportion of personal travel implement this Strategy which needs to be needs. The second document adds some targets and reflects made by means other than car reflected in the DPD. changes since the publication of the Mayor’s Strategy. • Walking (New target): TfL and boroughs to achieve an increase of at least 10% in journeys made on foot for person in London between 2001-2015 • Cycling (New target): TfL and boroughs to achieve an increase of at least 80% in cycling in London between 2001-2011 37. Sustaining Success: The Central aim is to ensure cross cutting sustainable development The DPD should consider the cross Mayor’s new Economic themes including health and equality of opportunity are built into cutting issues included in the strategy and Development Strategy. economic analyses and proposals. incorporate them within development principles. Key goals / investment themes: • Investment in infrastructure and places • Investment in people • Investment in knowledge and enterprise • Investment in marketing and promotion 38. Connecting with London’s The Biodiversity Strategy provides a strategic framework within The DPD should reflect the objectives Nature. The Mayor’s which the London Biodiversity Action Plans sit. Action plans will included in the BAP. The importance Biodiversity Action Plan. be among the principal means of implementing the Mayor’s placed on green space in Brent should be strategic agenda. explicitly addressed in DPD policy and site Objectives for biodiversity: allocations. The DPD should seek to promote the importance of nature / • Biodiversity for people – to ensure all Londoners have biodiversity. access to wildlife and natural green spaces. • Nature for its own sake – to conserve London’s plants and animals and their habitats. • Economic benefits – to ensure the economic benefits of natural green space and greening are fully realised. • Functional benefits – to ensure the city enjoys the functional benefits biodiversity can bring • Sustainable development – biodiversity conservation as an essential element of sustainable development

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA 39. Design for Biodiversity; 2003. Provides general guidance for developers on biodiversity. Potential for constrain / conflict between Where appropriate direct reference should London Development Describes drivers and processes and contains case studies of development proposals and habitat / be made to the planning guidance included Agency with English Nature; how nature conservation priorities have been achieved in biodiversity – which guidance seeks to in this guide. GLA and the London development. limit and mitigate against Biodiversity Partnership. 40. Sounder City: the Mayor’s Outlines proposals / strategy to tackle the ‘forgotten pollutant’ – The DPD should be Ambient Noise Strategy; Noise – and seeks to view it on a similar footing as townscape proactive in approach to managing ambient 2004. and landscape. Seeks to lead the way in developing new ways noise and reflect the issues and priorities of dealing with city noise; at a time when international pressure identified in this strategy. Noise should be is growing to take more action. considered as part of siting development. 41. Cleaning London’s Air; The The aim is to improve London’s air quality to the point where The DPD should be aware of and Mayor’s Air Quality Strategy; pollution no longer poses a significant risk to human health. contribute to the aims of the strategy. LB 2010. The Strategy sets out policies and proposals to move towards Brent is required to have regard to this Air this. Quality Strategy and should ensure that the DPD is in general conformity with it. As road traffic is main source of air pollution in London, consider the role of the DPD in changing transport patterns / modes / use; and in encouraging behaviour which will result in lower emissions.

Air quality should be considered as part of siting development. 42. Green Light to Clean Power. The Strategy sets out the Mayor’s proposals for change in the This strategy will be important to a number The Mayor’s Energy way energy is supplied and used within London over the next of topics throughout the DPD. Energy Strategy; 2011. ten years and beyond. Long-term vision is a sustainable energy efficiency in building and construction; and system in London by 2050 – with a key target of CO2 emissions the encouragement of renewables should be reductions of more than 60% relative to 2000 values. incorporated into the DPD principles and policies. 43. Towards Zero Carbon This report provides supportive information is targeted The DPD should heed the recommendations Development: supportive principally at borough officers, including planners. It includes made in this report. information for Boroughs, practical advice around how local authorities can use their London Energy Parnership, powers to encourage zero carbon developments. 2006 It also includes discusses current planning policy issues and the introduction of Local Development Frameworks.

44. Integrating renewable energy This toolkit will inform a SPG to the London Plan on renewable This toolkit should inform several policies into new developments: energy and parts of it are expected to be annexed to the SPG. in the DPD, for instance those on toolkit for planners, Sustainable Construction and Climate developers and consultants. Change, and be promoted to The Mayor’s London Energy developers as good practice. Strategy, 2004 45. London’s Wasted Sets out current and future waste situation in London; and This strategy should be reflected in the Resource, GLA, 2011 proposes a policy framework to achieve vision initially up to DPD, although the majority of policies on 2005/06 but with longer vision to 2020: “By 2020; municipal waste and spatial

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA waste should no longer compromise London’s future as a planning are proposed to be dealt with in a sustainable city.” West London Waste DPD.

46. Cultural Metropolis: The The Mayor’s Culture Strategy has four key objectives; This strategy does make reference to The DPD should reflect the importance Mayor’s Culture Strategy; 2010. supported by a number of detailed policies: Wembley which is a major site for of culture in its policies. The strategy • Excellence – to enhance London as a world-class city of development with a nationally important identifies that the Mayor wishes to culture cultural development. realise the potential of Wembley as a • Creativity – to promote creativity as central to the success of nationally and internationally significant London sports, leisure and business location. • Access – to ensure that all Londoners have access to The need for sites for the provision of culture in the city the necessary facilities should be • Value – to ensure that all London gets the best value out of considered in the Site Specific its cultural resources Allocations DPD. Underpinning each of these objectives is the principle of diversity. 47. London’s Warming – The This study aimed to provide an overview of the existing Provides advice to local authorities how Contains useful baseline information. Impacts of Climate Change information on the impacts of climate change on the they can address climate change issues on London, Technical environment and the economy and, to elucidate the social within their plans and strategies. Report, 2002. impacts of climate change largely based on existing reviews, research and monitoring studies within and outside of London. The study findings are discussed in context with existing policies and strategies for London. 48. London’s Framework for Contains a number of strategic objectives and priority actions. The strategic objectives and priorities for Contains useful information. Regional Employment and action may provide a useful source of Skills Action (FRESA), the further information when addressing London Skills Commission. employment issues. 49. The Mayor’s Accessible Gives advice on how to promote and achieve an inclusive Accessibility is a key issue for Brent. London: Achieving an environment in London. The SPG: Specific guidance and advice should be Inclusive Environment. SPG drawn upon in preparing the DPD and in • Provides detailed guidance on the policies contained in the April 2004. subsequent DPDs and SPDs which should London Plan regarding the promotion of an inclusive and make explicit reference to the SPG. accessible environment. • Provides LPAs with advice on how to implement these policies • Explains principles of inclusive design and how to apply them • Gives ideas to designers on technical advice and guidance • Gives disabled people and understanding of what to expect from planning in London

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA • Identifies national legislation and policy guidance relevant to an inclusive and accessible environment 50. Land for Industry and The objectives of this SPG are to supplement and to provide This SPG should be used as a key Transport SPG, GLA, 2014 detailed guidance as to how the broad policies of the DLP reference in addressing industrial capacity should manage industrial development capacity in the DPD. 51. The Mayor’s SPG on The purpose of this SPG is to give guidance on the application This SPG should be used as a key Housing 2012 and implementation of policies on affordable housing in the reference in defining the DPD affordable London Plan. It does not set out any new policies; objectives or housing policy / principles, along with the targets but is designed to help LPAs when reviewing UDPs; London Plan and its alterations. LDDs and planning applications. Conditions on sites for affordable housing will also need to reflect the SPG.

52. Adapting to Climate Change: Checklist and guidance for new developments to adapt to The checklist includes several issues for a checklist for development. climate change. The document is mainly aimed at developers new developments that are relevant to the Guidance on designing but it is expected to be useful for others including planners. DPD including flood risk locations, site developments in a changing layout, drainage, water, outdoor spaces climate, 2005 GLA and connectivity and should be promoted to developers in the DPD as good practice. 53. Securing London’s Water The Mayor’s Water Strategy has three key objectives; The Strategy should be reflected in the Future: The Mayor’s Water supported by a number of detailed policies: DPD which includes a hierarchy for water Strategy; 2011 • To secure a fair share of water for Londoners and London’s supply, water use, rainwater drainage, water-related environment through the best use of the wastewater disposal and flooding. The available water flooding hierarchy in particular should be • To minimise the release of wastewater into the clean water reflected in the site selection process. environment • To reduce the threat to people and their property from flooding and to mitigate its effects

54. Action Today to Protect The Action Plan is to sets out an agenda to cut London’s carbon The DPD can contribute to carbon Tomorrow. The Mayor’s dioxide emissions. It focuses on the priorities for action in dioxide emission reductions. The Action Climate Change Action Plan, London, in other words, those that deliver the most significant Plan should help guide CO2 reductions in 2007 CO2 savings at lowest cost (and in many cases with no net cost, Brent. since many actions bring energy savings). It details what

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Plan or programme title Relevance to the DPDs Comments, opportunities, synergies How the DPDs can respond / and constraints Implications for the SA 2 London can do to deliver substantial CO savings while boosting Emissions from traffic will be particularly London’s economy. relevant to Brent considering its relatively high traffic volumes. 55. London’s Urban Heat Island: This report is a summary of a technical study into London’s This report should provide useful A Summary for Decision Urban Heat Island (UHI) effect. It provides options on information on guiding the DPD to take Makers, Greater London managing the UHI effect. into account and manage the UHI effect Authroity 2006 in Brent. It is aimed at ‘decision makers’ - planners, architects, urban designers, developers and public health care professionals.

56. The London Plan, Sub- The West London Sub Regional Development Framework The document sets out 54 actions Regional Development (SRDF) covers 6 West-London boroughs including Brent. Its designed to achieve implementation of the Framework, West London, purpose is to provide guidance on the implementation of London Plan and to provide guidance and 2006 policies in the London Plan. a check-list of matters that need to be developed at the local level through Local Plans. 57. London View Management This SPG provides guidance on the policies regarding the No strategic views in Brent, but principles Framework, SPG, 2012 protection of strategic views contained in the London Plan. may be relevant.

58. Draft London Housing Strategy This strategy has been developed with the purpose of aligning This Strategy includes a series of targets SPG, GLA, 2013 the London Housing Strategy with the London Plan and to cover that should inform the DPD on ‘Meeting the same time span housing needs’. 59. T he Mayor’s Economic This strategy aims to support the development of London’s This strategy should inform several policies Development Strategy, 2010 economy and businesses within the context of fair and including those under ‘employment’ in the sustainable economic development. DPD.

60. Providing for Children This strategy aims to make London a more child friendly city This strategy should influence a number of and Young people’s Play policies included in DPD, as well as site and Informal Recreation, slection and conditions placed upon sites, GLA, 2008 as it deals with several relevant issues such as reducing child poverty, improving safety of public transport and open spaces, creating new places for play and making cycling and walking easier.

61. London Assembly, The Blue This document revisits the Blue Ribbon Network proposals in London Boroughs should assess The DPD should promote the principles Ribbon Network, The heart the London Plan to see how they can be implemented in order compliance with the Blue Ribbon set out in the Blue Ribbon Network of London 2006 to place the waterways of London at the heart of planning Network policies of proposed document in issues affecting development policies developments close to waterways close to the River Brent and other waterways such as the Grand Union Canal.

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough 62. LBB Core Strategy DPD; The Core Strategy DPD Preferred Options 2010 provides the spatial strategy and the key policies which sets the framework for the DPD. 63. Adjoining Borough See individual strategies and DPD as they emerge. Consider in relation to impact of policies on Strategies and DPD e.g. adjoining boroughs and the impact of their London Boroughs of Harrow, policies on Brent. Ealing, Barnet, Westminster, Kensington and Chelsea, and Hammersmith 64. LBB Regeneration Strategy The Action Plan sets a clear agenda for regeneration in Brent The DPD can play a major role for Brent 2010 – 2030. over the next two years tosupport the priorities of the Brent contributing towards regeneration for Regeneration Strategy 2010 - 2030. Brent. The strategic objectives of this plan should be incorporated. 65. LBB Council’s Corporate Brent’s Corporate Strategy 2006 - 2010 sets out Brent’s The values and issues within this strategy Strategy 2010 – 2014. priorities and ambitions for the next four years. The overall should be incorporated within the overall vision and priorities of the Borough are to secure the long-tem objectives of the DPD. prosperity, wellbeing and quality of life for all of Brent’s residents. The vision for Brent focuses on four main themes / headings:

• A great place • A borough of opportunity • One community • Civic leadership 66. LBB Community Plan 2003 The Community Strategy 2006 – 2010 aims ensure that Brent A key document. The DPD and SAs - 2008: A Plan for Brent (To be is / will be a prosperous and lively borough full of opportunity should consider and reflect where replaced by Brent Community and welcoming to all, a place that will thrive for generations to appropriate the priorities of local people for Strategy 2006 - 2010) come, whose future will be determined by local people the future of Brent included in this plan.

It is based around three main themes that Brent will be a:

• Great place; • A borough of opportunity • An inclusive Community 67. LBB Contaminated Land Part IIA of the Environmental Protection Act 1990 placed a The DPD should incorporate relevant

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough Inspection Strategy, adopted number of new powers and duties on Brent Council with regard aspects of this Strategy in seeking the 2001, updated January and to contaminated land. remediation and re-use of contaminated May 2007. land. The Contaminated Land Inspection Strategy encompasses the following main strategic areas:

• Effective implementation of Part IIA of the Act • Procedures for dealing with contaminated land enquiries or contaminative uses • Procedures for self regulation and discharge of the Council’ responsibilities as a owner and operator of contaminated sites or sites at risk

The Strategy was reviewed in 2005/06 and was updated in January and May 2007. The May update introduces a revised risk prioritisation and consequently a revised spread of priority sites for investigation. 68. LBB Air Quality Action Plan, The plan describes what can be done to deal with air quality in The DPD should take into account the 2012-2015. Brent. It includes both new measures identified during the measures included in this plan, particularly development of the plan as well as actions included in national in the AQMA, including in policies relating legislation and other plans including the Mayor of London’s. to the siting, density, type, location and design of development. The plan identifies measures to improve air quality across Brent and groups them into a series of categories:

• Promoting cleaner modes of transport • Traffic reduction and tackling through traffic • Promotion of cleaner fuel technology • Measures concerning local industries • Improving Eco-efficiency of current and future developments, including • properties owned or run by the Council • Actions to be taken corporately, regionally and in liaison with the Mayor 69. LBB Parks Strategy 2010 – This Strategy sets out a clear policy framework for Brent Parks Open spaces and parks are of particular 2015. over the next five years and links to the community strategy importance in Brent and large parts of the process. It also provides a structure to ensure that the wider borough have a deficiency of open space. Council’s priorities are achieved. Contains a number of This strategy should be referred to when objectives organised under three themes: addressing open space within the DPD. • Provision of parks • Funding • Maintenance 70. LBB Biodiversity Action A partnership of local groups and organisations co-ordinated by The DPD should reflect where Plan, 2007. appropriate the actions and priorities for

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough Brent Parks Service. species and habitats covered by the Lists 6 species and 30 habitats for which action plans have Biodiversity Action Plan; and be sensitive been prepared. Refer to action plan website for full list of to biodiversity issues generally. The SA should reflect the priorities in the Plan. species and habitats: http://www.ukbap.org.uk/lbap.aspx?id=394

This document is currently undergoing revision. 71. LBB Sport and Physical The following factors are identified as being particularly The DPD should incorporate where Activity Strategy 2010 – important in the strategy: appropriate the measures included in this 2015. strategy, especially those regarding the • Promoting the health benefits of an active lifestyle provision of sport facilities. • Increasing awareness of sports opportunities • Ensuring sports facilities are fit for purpose • Reducing barriers to participation and ensuring equity in sport • Supporting and developing local sports clubs • Increasing sports opportunities for young people 72. LBB Playing Pitch Strategy The Strategy guides the planning and provision of playing fields Open space for recreation can play an The DPD should reflect the need for and 2003-2008; May 2004. for the main team sports in Brent up to 2008 and follows sport important role in health; well-being and benefits of playing fields and account for England guidelines. Includes a detailed analysis of the current community spirit. future demand as appropriate / relevant. state of pitch supply and use. It also predicts future demand – to assess adequacy of current facilities and establishes an action plan for the period up to 2008. 73. LBB Draft Municipal Waste Discusses waste management in Brent in the context of The DPD should reflect these action Strategy – 2006. national (Waste Strategy 2000) and regional (Mayor’s Waste areas, and seek to avoid any potential Strategy for London) waste management strategic objectives conflict with them through its objectives as well as the 2002 WLWA waste strategy. and principles, although the majority of policies on waste and spatial planning are Brent’s Strategy Framework comprises 7 main areas of action for the period to 2006: proposed to be dealt with in a West London waste DPD. • Improve the performance of existing waste schemes • Extend the Green Box where appropriate • Provide a variant of the Green Box service to estates • Introduce the collection of organic waste for central composting • Establish a Waste Management Site incorporating Recycling Facilities including some bulk storage, Civic Amenity functions, and a base for future Waste Collection Operations. • Carry through procurement of services beyond 2007 • In its role as a WPA ensure that sufficient land resources are available by safeguarding existing waste sites and identifying new sites. In addition to waste covered by this strategy this process needs to take into account all other waste arising in Brent.

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough 74. LBB Local Implementation The production of this plan is a statutory requirement under the LIP includes proposals to improve The DPD should incorporate policies Plan (LIP) for Brent GLA Act. The Plan details the Borough's policies and strategies walking routes and crossings, encourage appropriate to spatial planning which support with regard to transportation matters. residents to walk more, improve access the priorities of the LIP which include safety and accessibility to local services, and security, reducing traffic congestion, identify suitable cycle parking sites and improved bus services, accessibility and local improvement of rail and underground area initiatives. The site sections process access, amongst others. should reflect the priorities in the LIP.

75. Nature Conservation in Several parts of the Borough have significant nature The Council's current nature The DPD should reflect the contents of Brent. London Ecology Unit conservation value, with many other areas offering great conservation policies in the UDP are the Ecology Handbook and the updated (2000). potential for further creation of wildlife habitats. The Council's based on information contained in the version and seek opportunities to conserve nature conservation policies in the UDP are based on Ecology Handbook. and enhance existing habitats as well as information contained in the Ecology Handbook No 31, 'A seek opportunities to create habitat and Nature Conservation Strategy for the London Borough of Brent'. reduce areas of deficiency. Sites of wildlife conservation value are classified by the London Ecology Unit (LEU) as sites of Metropolitan, Borough (Grade I and Grade II) or Local Nature Conservation Importance or sites which form a Wildlife Corridor. Nearly all sites were surveyed. This document is currently being updated. 76. London Borough of Brent Licensing Act 2003 transfers responsibility of issuing licensing Statement of Licensing for the sale and supply of alcohol and provision of Policy, 2005 entertainment and late night refreshments to Local Authorities. The four objectives of this statement are: Prevention of crime and disorder; prevention of public nuisance; public safety; and protection of children from harm 77. LBB Planning for Children The SOP is the starting point for the School It is important for the DPD to be aware of the and Families in Brent, 2012-2015 Organisation Committee (SOC) in considering statutory Plan’s findings and principles when proposals for changes to schools. developing policies which relate to or could Purpose of the SOP is to set out clearly how the Local Education affect schools / education. Authority (LEA) plans to meet its statutory responsibility to secure sufficient education provision within its area in order to promote higher standards of attainment.

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough 86. Brent SPGs and SPDs Each SPG/SPD will be relevant to different sections or policies Consider existing policy context provided within the DPD by SPGs/SPDs as drafting different SPG 01 Making a Planning sections or policies within the DPD. Application Consider need to update them / create SPDs from SPGs to reflect latest policy SPG 02 Commenting on a position and latest good practice. Planning Application

SPG 03 Forming an access onto a road

SPG 04 Design Statements

SPG 05 Altering and Extending your Home

SPG 07 Shop fronts and Shop Signs

SPG 08 Advertisements (other than shops)

SPG 10 Community Safety - building or refurbishing domestic or commercial properties

SPG 12 Access for disabled people: designing for accessibility

SPG 13 Layout standards for access roads

SPG 14 Childcare facilities

SPG 16 Special Standards for Hassop Road

SPG 17 Design Guide for New Development

SPG 18 Employment Development

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Plan or programme title Relevance to the DPD Comments, opportunities, synergies How DPD can respond / Implications for and constraints the SA Local / Borough SPG 19 Sustainable Design, Construction & Pollution Control

SPG 20 Buildings in Gardens within Conservation Areas

SPG 21 Affordable Housing 87. LBB Brent Sustainable The purposes of the guidance are: The DPD should include the policy context Design, Construction and • Provide guidance to developers, on ways of meeting for the guidance on sustainable design and Pollution Control, Policies BE12 and other policies in the Adopted UDP, construction included in the SPD and where Supplementary Design and aimed at securing more sustainable development in Brent; appropriate reflect current good practice Planning Guidance 19 (SPG • Encourage developers and building professionals to where it has subsequently evolved, including 19) consider sustainability from the earliest stages of the design that proposed by the Mayor’s SPG and process, and to go beyond minimum standards; London Plan alterations. • Raise awareness among local residents, businesses and other Council units, by highlighting the expectations and features of current best practice in sustainable design, construction and pollution control. 88. LBB Brent Cultural Strategy The strategy provides an overview of culture in Brent and The DPD should seek ways of 2006-2010 outlines a series of priorities for the area in the coming years. It contributing to achieving the objectives of also outlines Brent’s vision of culture as a key factor in ensuring this strategy. community cohesion in one of the most diverse boroughs in Europe. The term ‘Culture’ includes: Arts, creative activity, sports, libraries, museums, heritage, architecture/design of the public realm, children’s play, parks and other forms of recreation.

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APPENDIX 4

BASELINE DATA

Brent ‘s Development Management Appendices Policies Preferred Options - SA Report 47 (Appendices to Part A)

Appendix 5

Social baseline characteristics and trends

Sustainability Objective 1: To reduce poverty and social exclusion (S1)

Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, IMD, 2010 IMD 2010: Rank Rank IMD 2000 (rank of As a Borough and at the Index of Multiple of Av. of Av. average ward scores): aggregated ‘rank of Deprivation Brent is now ranked 35th most deprived Brent now ranks as the Score: Rank: average score’ level, Brent Local Authority in England (IMD 2010), 11th most deprived Brent: Rank of has a level of deprivation declining 18 places since the IMD 2007 borough in London. 57 38 average score: 68 (of comparable or lower than were published. 41 23 354, where 1 is most many neighbouring inner 5 IMD 2004: 13 10 deprived) London boroughs. Brent AMR 2005-06 11 6 17 12 Lewisham: 53 However income and Brent is ranked 58th out of 354 on the 23 13 Greenwich: 44 employment deprivation local authority national deprivation index. Lewisham: 4 2 Haringey: 20 are an issue at the Carlton, Stonebridge, St Raphaels, Greenwich: 5 1 Newham: 5 Borough level (shown by Roundwood and Harlesden wards are Haringey: 6 4 Southwark: 14 lower rank than average ranked in the 10% most deprived wards Newham: 99 94 Lambeth: 42 for these scales). nationally. Southwark: Tower Hamlets: 1 Lambeth: Hackney: 4 Equally the disparities Brent, IMD 2004: Tower Hamlets: Islington: 11 between different wards in Hackney: Ealing: 106 the Borough are dramatic. Average score: 25.95 (out of 100, where 1 Islington: 14 SOAs in Brent are in is the least deprived and 100 the most) Ealing: the top 10% most deprived Rank of average score: 81 (of 354*, in the UK. where 1 is most deprived) (rank of 354 local Rank of average rank: 62 authorities where 1 is Deprivation, exclusion and Rank of income scale: 22 most deprived) inequalities form a key Rank of employment scale: 39 sustainability issue for the Borough. *Local Authorities

Note: Rank / score is across each of the ‘domains’ (indicators): income, employment, health, education, housing and services, crime and living environment.

(English Indices of Deprivation 2004, Neighbourhood Renewal Unit, ODPM, 2004.)

There are 174 Super Output Areas 5 (SOAs) in Brent, and 14 of those are in The choice of deprivation ‘domains’ (income and employment) and comparator boroughs follows those used by Brent in its 2003 report ‘Brent Summary – Key Statistics, Information and Summary’, the top 10% most deprived in the country. Brent February 2003. These areas are located in the following wards: Stonebridge, Harlesden, Kensal Brent’s Development ManagementGreen, Willesden Policies Gre eDPDn and Kilburn. Appendices Preferred Options – SA Report (Appendices to Part A) 48 Appendix 5

Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments

Government Office for London (http://www.go- london.gov.uk/boroughinfo/borough.aspx? bid=4)

See Figure 3 in Section 3 of Part A.

Brent, Borough Profile (2010): Brent, Borough Profile (2010): Average household These data emphasise the Average household Approximately 16% of households in Brent Brent has the 17th highest house price in income of £21,552 is intra-borough disparities income have an average annual income of £15,000 London, but the 3rd lowest average household £6,000 less than which exist. or less. income. London average (Brent Housing Needs Disparity in social and Brent, average household income: London, 2006 Survey 2004) economic conditions is a £27,212 (AMR 2005-6) key sustainability issue. The average household earned income is Average household income is £21,752 in only two thirds of the London average (AMR Brent North and falls to £17,193 in Brent 2005-06) South giving them the respective rankings of 41st and 67th lowest in London’s 71 constituencies Brent’s average earned income is only 66% (Barclays Bank press release, of the London average of £41,759, the 08/12/2005, cited in AMR 2005-06). fourth lowest in London. And the Brent average salary of £27,402 is even lower than the national average of £28,941 (Office Brent, Employment Land Demand Study ofLo Nationalndon, 2001: Statistics, 2006, cited in AMR The percentage of Percentage (2013): In 2012 the unemployment rate in 20056.6%- 06). households with no households with no LB Brent was 10.9% (13,900), which is England and Wales, 2001: employed adults with employed adults with slightly above that of London (9.1%) and 4.9% dependent children is dependent children somewhat higher than that of Great Britain higher in Brent than either (8%). (Census 2001, accessed online at the London or England www.statistics.gov.uk) averages. Brent, Census 2001: 7.4% London 2004 Social and economic In 2004, workless households with disparity with other areas is (Census 2001, accessed online at dependent children comprised 25% of all a key sustainability issue. www.statistics.gov.uk) London’s households. This rate has remained constant since 1999. The rate rises to 35% in Inner London and drops to 19% in Outer London. The national average is 15%.

(London SD Commission report on London’s Quality of Life Indicators, 2005)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Health profile, 2012: London The target was to Although there is no Percentage of children Approximately 18,400 children live in reduce this by a available data on child living in poverty (after poverty. Data from DWP, 2004-2005 quarter from 1998/9 to poverty for Brent, the housing costs) 2004/5. surrogate measure (% of Brent, 2004-05 Percentages of children living on low children on benefits) shows incomes (below 60% median, or “in In Great Britain, child that four wards in Brent Data on child poverty are based on a poverty”) in 2004/5, net of housing costs. poverty fell by 16% have considerable levels of survey that does not allow breakdowns (from 33% to 27% of child poverty. below regional level. Great Britain: 27% children) However, the Joseph Rowntree Foundation has put together local data London: 41% In London, child using another measure – the percentage poverty rose by 4% of children living in families claiming out of The target was to reduce this by a quarter (from 39% to 41% of work benefits. This does not count all from 1998/9 to 2004/5. children) people who are poor, but is a good indicator of how bad poverty is in different In Great Britain, child poverty fell by 16% (Source: areas. (from 33% to 27% of children) http://www.jrf.org.uk/c hild- There are 4 wards in Brent where the In London, child poverty rose by 4% (from poverty/documents/Lo percentage of children on benefits is at 39% to 41% of children) ndon.doc) least twice the national average of 21%: Nationally, 21% of children are on families Stonebridge: 50.8% on benefits. Harlesden: 45.2% Kilburn: 43.9% Within London: Willesden Green: 42.7% There are 105 local wards where the (Source: http://www.jrf.org.uk/child- percentage of children on benefits is at least poverty/documents/London.doc) twice the national average

(Source: http://www.jrf.org.uk/child- poverty/documents/London.doc)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Percentage of Brent, 2011 UK 2004 UK Although percentage figure households suffering 9.8% residents suffer from fuel poverty. Defra estimate the numbers number of for UK is calculated using from fuel poverty households in fuel poverty in the UK as: Eradicating fuel data from different (Department of Energy and Climate 1996: 4.3 millions poverty by 2016 sources, and cannot Change) 2002: 1.4 millions = 5.7% therefore be deemed http://www.defra.gov accurate, it is likely to be Brent, 2000 (% for 2002 Calculated based on Census .uk/environment/ene within the correct order of Brent Energy Network’s spring 2000 2001 estimates that the number of UK rgy/fuelpov/pdf/fuelp magnitude. Domestic Energy Survey findings have households with residents was 24.5 ovstrat- led to an estimate of 18% of borough millions) 4thannualreport.pdf In 2000 the level of fuel residents suffering from fuel poverty. poverty was considerably above the national (Indicators for a sustainable Brent, (Defra Fuel poverty monitoring indicators, average. January 2001) 2004. http://www.dti.gov.uk/energy/consumers/fue l_poverty/monitoringindicators2004.pdf)

Sustainability Objective 2: To improve the health of the population (S2) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, Census 2011: England and Wales, 2001 Brent levels are Self assessment of Very good: 48% Good: 68.6% comparable with National. health over last 12 Good: 35% Fairly good: 22% months Fairly good: 12% Not good: 9.2% Bad health 4% Very bad health: 2% (Census 2001, accessed online at www.statistics.gov.uk) Brent, Census 2001: Good: 70% Fairly good: 21.3% Not good: 8.6%

(Census 2001, accessed online at www.statistics.gov.uk) Brent, 2002 High incidence and fear of Perception of factors Residents identifying factors as having crime is a key sustainability impacting on health bad effect on health or quality of life: issue. Crime: 32% Violent crime: 23% Road traffic: 20% Environmental pollution: 19% Drug problems (in area): 16% (Living in Brent 2002 a Representative View. A MORI study for Brent Borough Council.) Brent’s Development Management Policies DPD Appendices Preferred Options – SA Report (Appendices to Part A) 51 Appendix 5

Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Only site specific data within Brent was 2002: 1996: England - Participation in sport located. London: 44% London: 45% (excludes walking) 70% of England’s The Brent Playing Pitch Strategy identifies North East: 37% North East: 41% population to be that Brent has a below average level of North West: 41% North West: 47% reasonably active participation in football and a below Yorks and Humber: 41% Yorks and Humber: (30 minutes of minimum standard of outdoor playing East midlands: 42% 43% moderate exercise space as determined by the National West midlands: 39% East midlands: 44% five times a week) Playing Field Association Standards. East of England: 45% West midlands: 42% by 2020 South East England: 46% East of England: 51% The Strategy for Sport and Physical South West: 50% South East England: (http://www.shu.ac.uk Activity in Brent reports the profile of 50% /cgi- users as follows: (Sport England Research Briefing Note: South West: 46% bin/news_full.pl?id_n Participation in Sport 2002) um=PR561&db=04) Gender: The London Plan Male - 59% aims to increase Female - 41% overall participation rates by Age: an average of 1% per year, Under 16 yrs - 23% increase participation 16 – 34 yrs - 51% by under represented 35 – 59 yrs - 22% groups and Over 60 yrs - 4% provide structures to enable individuals to Ethnic background: reach their sporting potential. African-Caribbean - 36% White - 28% Asian - 30% Other - 6%

However, the ethnic profile of users varies significantly across each of the centres to reflect the ethnic make-up of the wards in which they are based and their catchment areas.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Number of sports Indoor sports: facilities by type Vale Farm Sports Centre – 25m pool and teaching pool, 5 badminton courts/sports hall, squash courts, dojo and meeting rooms.

Council owned: Charteris Sports Centre – 3 badminton courts, weight / fitness area. Bridge Park Community Leisure Centre – 5 badminton courts/sports hall, dance studio, fitness studio / weights room. Willesden Sports Centre – six lane 25m main pool plus teaching pool, four badminton court sports hall, fitness / weights area, dojo and multi purpose room, athletic s and five-a-side indoor football pitches.

Source: A Strategy for Sport and Physical Activity in Brent 6 Brent 2001 The net loss of 4.6ha Though no comparator Access to public open 40% of Brent’s domestic properties are in of open space during data has been identified a spaces open space deficiency areas: 2000-2006, compares figure of 40% is considered positively to the to be relatively high. These are residential areas more than 28.6ha net loss in the 400 metres from a public open space of previous six year Quality of access to open over 2 hectares. period. Since the spaces and parks is a key Revised Unitary sustainability issue. Source: AMR 2004-05 Development Plan 2001 came into effect, There are also disparities Spatial inequality affects access to public public open space has between north and south open spaces, with large areas such as generally been Brent. Fryent Country Park and the Welsh Harp successfully protected in the north of Brent while southern areas from alternative or have insufficient land for recreation and inappropriate uses sport (AMR 2005-06). (AMR 2005-06).

See Figure 6 in Section 3 (Part A) for areas of open space deficiency.

6 The substantial difference between this figure and the 2005 AMR figure is due to an allotment site (Ref.:00/0751) not being included in the original calculation.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, JSNA 2011 London, 2001: Brent, 1991: The London Cycling Relatively high use and Main mode of travel to At least 25% of Brent residents are Underground: 10% Underground: 25% Action Plan: dependence on public work believed to use public transport to Train: 7% Train: 4.5% 80% increase in transport, and particularly commute to work. A minimum of 2% of Bus: 18% Bus: 12.5% cycling levels in the underground. residents cycle or walk to work. Walk/cycle: 23% Walk: 9% Capital by 2010 and Car/taxi: 42% Car: 36% a 200% increase by Low car use is a positive Other: 6% 2020, compared to factor against most Brent, 2001: (Transport for London Statistics: cycling levels in sustainability criteria, Underground: 26% http://www.transportforlondon.gov.uk/tfl) 2000. however ensuring Train: 6% adequate access to public Bus: 13% (Brent Draft LIP of transport and ease of Walk: 6% the Mayor’s movement is a key Car: 34% Transport Strategy) sustainability issue. Other: 6%

(Brent Summary Key Statistics, February 2003)

Brent, JSNA (2011) Life expectancy for males is close to Health inequalities Life expectancy at birth in Brent for both English average and higher for women. men (78.8 years) and women (84years) is There are fewer deaths from smoking and higher than life expectancy in both London cancers. More infant deaths, more road and England. injuries. More people recorded with diabetes. Alcohol related hospital stays Male life expectancy increases by each below average. Children’s tooth decay more northward Bakerloo line station. Northwick common. Park male residents have 10 extra years compared with Harlesden. (Brent Primary Life expectancy significantly lower than the Care Trust, 2004 cited in AMR 2005-06) English average in two wards in the South.

‘Health Profile for Brent 2006’ : http://www.communityhealthprofiles.info/pro (comparison with England) files/00AE-HP.pdf

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2002/03 Brent 2000-2004 Targets from Brent Access to GP or Practices with appointment systems in Net increase of PCT (indicator primary care place to see a GP: 92.9% 1930m² floorspace in numbers from professional 1. Practices with an appointment to see health facilities 2000 – column 2): a primary care professional within 1 2004; 1. 100% working day: 57.1% Net decrease of 14, 2. 90% 2. Practices with an appointment to see 750m² hospital space 3. 90% a GP within 2 working days: 73.8% 2000 – 2004 4. 100% 3. Practices with an appointment system in place to see a primary Brent PCT online: care professional: 90.5% http://www.brenttpct.o 4. Practices participating in Primary rg/html/Publications_9 Care Access Survey: 53% 59.htm

Brent PCT online: http://www.brenttpct.org/html/Publications _959.htm

Figure 4 (Section 3, Part A) illustrates that in some areas of Brent there are a very large number of households served per GP.

Sustainability Objective 3: To improve the education and skills of the population (S3) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, JSNA (2011) England average, 2006 Brent Educational attainment at Secondary: Level 2, 5 or more GCSE grades A*-C Level 2: Level 2 / GCSE level are % Children obtaining Average for attainment at Key Stage 3 (including english and maths): 45.8% 2000: 48.4% comparable with national at least 5 GCSEs at English is 73%. For maths it is 2001: 45.6% averages. grades A* - C 75%.Standards remain high at Key http://www.dfes.gov.uk/performancetables 2002: 49.7% Stage 4, with Brent pupils surpassing the 2003: 50.7% national average for the proportion of 2004: 54.5% pupils achieving five good GCSEs 2005: 57.1% including English and mathematics – http://www.dfes.gov.u Brent is ranked 29th out of 150 LAs on k/rsgateway/LEAS/30 this measure. 4.shtml

Brent LEA average, 2006: England Level 2, 5 or more GCSE grades A*-C Level 2: (including english and maths): 48.9% 2001: 53.7% 2004: 53.7% 2005: 57.1%

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments http://www.dfes.gov.u k/performancetables Brent LEA average, 2005: England average, 2005 Brent: English2001 As above except in Primary: Key Stage English: 79% English: 79% 2000 - 74% Science where the average 2 performance (% Maths: 73% Maths: 76% 2001 - 74% for 2005 is lower than the achieving level 4+) Science: 82% Science: 87% 2002 - 74% national average and the 2003 - 77% 2002 Brent average. DfES: 2004 - 78% http://www.dfes.gov.uk/performancetables 2005 - 78% http://www.dfes.gov.uk/performancetables Brent: Maths 2000 - 72% 2001 - 72% 2002 -75% 2003 - 72% 2004 - 74% 2005 - 73%

Brent: Science

2000 - 83% 2001 - 86% 2002 - 84% 2003 - 84% 2004 - 83% 2005 - 79%

http://www.dfes.gov. uk/rsgateway/LEAS/ 304.shtml

England, 2002 English: 75% Maths: 73% Science: 86%

England, 2004 English: 78% Maths: 74% Science: 86%

England, 2005 English: 79% Maths: 75% Science: 86%

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments http://www.dfes.gov.u k/performancetables/

Brent, 1999-2000 London, 1999-2000 Brent The percentage taking part Enrolments on adult 38.5 72 1998-99: 42 in adult education is well education courses per 1997-98: 47 below London and national 1000 population (Nomis Labour Market Profile for Brent. National, 1999-2000 averages and has fallen in www.nomisweb.co.uk, accessed: April 61 London the Borough since 1997. 2005) 1998-99: 62 1997-98: 61 Educational attainment is a key sustainability issue. Brent 2005 (Jan-Dec) London, 2005 (Jan-Dec) Brent 2003-04 At higher NVQ levels (3 Education (NVQ NVQ4+: 28.3% NVQ4+: 33.3% NVQ4+: 26.0% and 4) Brent data is equivalent) NVQ3+: 44.4% NVQ3+: 46.7% NVQ3+: 37.4% comparable with London qualifications of NVQ2+: 55.8% NVQ2+: 59.9% NVQ2+: 48% and GB. working age residents NVQ1+: 61.6% NVQ1+: 70.4% NVQ1+: 56.5% Other: 27.3% Other: 16.4% Other: 27.3% However at lower NVQ No Qualifications: 14.3% levels and particularly 1, No Qualifications: 13.4% No Qualifications: attainment levels are Great Britain, 2005 (Jan-Dec) 16.2% relatively low. (Nomis Labour Market Profile for Brent. NVQ4+: 26.5% www.nomisweb.co.uk) NVQ3+: 44.4% London, 2003-04 The percentage of people NVQ2+: 62.9% NVQ4+: 30.8% with no qualifications is NVQ1+: 77.2% NVQ3+: 45% slightly lower than the See Figures 7 and 8 (Section 3, Part A). Other: 8.8% NVQ2+: 59% London and Great Britain No Qualifications: 14.3% NVQ1+: 69.7% averages. Other: 16.4% No Qualifications: Educational attainment is a 13.9% key sustainability issue.

Great Britain, 2003- 04 NVQ4+: 25.2% NVQ3+: 43.1% NVQ2+: 61.5% NVQ1+: 76% Other: 8.8% No Qualifications: 15.1%

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent is a net exporter of statutory school Forecast growth 2000-2005 and surplus / There is a forecast deficit Access to secondary age pupils: in March 2003, 3172 pupils: deficit of 11-16 places in 2005 – adjacent in adjacent borough’s schools. boroughs schools. The projected Secondary schools 4660 pupils living outside the authority Growth: Surplus / shortfall of school places is capacity attended Brent schools deficit of a key sustainability issue. 7832 Brent residents attended schools places: outside the borough. Barnet 5.2% -559 Camden 2.5% -163 Existing capacity: Westminster 8.1% -164 7.9% (5.9% when schools over capacity Kensington 9.9% -256 are taken into account) Hammersmith 6.9% +65 Ealing 9.2% -250 (Brent Schools Organisation Plan 2003- Harrow 2.2% +349 2008)

Brent Primary school Primary school capacity: 2626 capacity 11% capacity

(Brent Schools Organisation Plan 2003- 2008) No data identified. A map of library Access to libraries locations is available, but does not identify ease or otherwise of access and use.

Sustainability Objective 4: To provide everybody with the opportunity to live in a decent home (S4) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, Census 2011 Brent, 2001 If population increase Population Size and All people: 311,215 The 2001 Census trends continue this will Growth Males: 156,468 showed that the mean increased pressure Females: 154,747 population of Brent on existing facilities and increased for the first services such as schools, Brent, 2005 time in 50 years. health and transport. All people: 270,100 Increasing by 8.4% from Males: 135,600 a population of 243,025 Provision of and access to Females: 134,500 in 1991 to 263,466 in essential services and 2001. amenities is a key (Nomis Labour Market Profile for Brent. sustainability issue. www.nomisweb.co.uk) The Census 2001, a Profile for Brent

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2004 All people: 267,700 Males: 134,300 Females: 133,400

(Nomis Labour Market Profile for Brent. www.nomisweb.co.uk)

Brent, Census 2011 = 72 persons per Outer London Brent Population density: hectare. This is the highest in Outer = 35 persons per hectare = 55 people per hectare people per hectare London and the 14th highest in England Inner London in 1991 and Wales. = 78 persons per hectare. (AMR- 2005-06) (AMR- 2005-06) (AMR- 2005-06)

This may be a misleading indicator at ward level due to distribution of park-land / open space. Brent, Census 2011 London 2001 Brent, 1991 Comparable with London Age structure: 0 to 4: 7.2% 0 to 4: 6.67% 0 to 4: 6.8% averages. Brent has population by age 5 to 19: 17.7% 5 to 15: 13.53% 5 to 9: 6.5% slightly higher number in group 65+: 10.5% 16 to 19: 4.66% 10 to 14: 6.0% the 20-44 age group. 20 to 44: 42.72% 15 to 19: 6.0% Brent, 2001(%s) 45 to 64: 20% 20 to 24: 9.7% 0 to 4: 6.19% 65 and over: 12.43% 25 to 29: 10.9% 5 to 15: 13.61% 30 to 34: 8.5% 16 to 19: 5.07% The average age in England and Wales at 35 to 39: 6.9% 20 to 44: 43.96% the time of the 2001 census was 38.6 40 to 44: 6.3% 45 to 64: 19.69% 45 to 49: 5.5% 65 and over: 11.48% (Census 2001, accessed online at 50 to 54: 5.4% www.statistics.gov.uk) 55 to 59: 5.0% Brent’s average age at the time of the 60 to 64: 4.4% 2001 Census was 35.4 65 and over: 9.4%

(Census 2001, accessed online at www.statistics.gov.uk)

The ‘age pyramid’ of Brent has been included in Section 3, Part A (Figure 9).

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments London, 2001: Brent, 1991 Brents’ diversity represents Population by ethnic Brent, Census 2011 White: 71.15% White: 50.7% a cultural / community group White: 36% Mixed: 3.15% Mixed: NA asset. Asian/Asian British: 33% Asian/Asian British: 12.08% Asian/Asian British: Black/Black British: 19% Black/Black British: 10.92% 21.6% Chinese/other: 2.69% Black/Black British: Brent, 2001: 15.1% White: 45.27% Chinese/other: 3.8% Mixed: 3.72% (Census 2001, accessed online at Asian/Asian British: 27.73% www.statistics.gov.uk) Black/Black British: 19.86% Chinese/other: 3.41%

Based on the 2001 Census, 5,633 (2.1%) Brent residents have moved into the borough from outside the UK, this is the second highest figure out of all the Outer London Boroughs.

(Census 2001, accessed online at www.statistics.gov.uk)

See a graphical representation of these figures in Section 3, Part A (Figure 10).

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Brent, October - December 2006 Greater London, October - December Brent, October – In common with London Average house prices Detached: £602,125 2006 December 1996 averages, house prices in by type Semi: £365,335 Detached: £628,239 Brent are considerably Terraced: £336,764 Semi: £361,619 Detached: £161,315 higher than the England Flat: £226,823 Terraced: £331,450 Semi: £108,190 and Wales average. Flat: £275,267 Terraced: £89,209 All properties: £292,596 Flat: £58,731 The relative (to incomes) All properties: £323,511 cost of housing Is a major (Land Registry – All properties: £82,829 issue for the Borough and http://www.landreg.gov.uk/propertyprice/in England and Wales, March 2007 the lack of affordable teractive ) All properties: £178,423 Greater London, housing is a key October – December sustainability issue. (Land Registry – 1996 http://www.landreg.gov.uk/propertyprice/in Detached: £208,427 teractive ) Semi: £114,392 Terraced: £103,973 Flat: £90,023

All properties: £105,159

England and Wales, April- June 2006 All properties: 199,184

(Land Registry – http://www.landreg.gov. uk/propertyprice/interacti ve )

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2003: 6.02 England average: 4.11 As above Affordability of (Affordability differences by area for London average: 4.69 housing: working households buying their homes, Ratio of average 2003 update. Joseph Rowntree Lewisham: 4.81 house price to gross Foundation, 2003: Greenwich: 3.98 household income http://www.jrf.org.uk/knowledge/findings/h Haringey: 4.42 ousing/024.asp) Newham: 5.30 Southwark: 5.41 Brent 2005 Lambeth: 4.41 Between 1999-2004 household incomes Tower Hamlets: 4.87 rose by 8.5% whilst house prices have Hackney: 5.02 risen by 300% in the last decade. Islington: 5.28 Ealing: 5.34 (Brent Housing Strategy Statement 2005) In July 2003 the average house price in London was £241,818 – some 45% more than the national average and an increase of 9.4% over the previous year.

(London Key Facts, LGA 2004) Brent, Census 2011 Outer London 2001 Brent 1991 Borough levels of owner Housing stock by Owned: 44.39% Owner occupied: 68% Owner occupied: 57.7% occupation lower than tenure Social Rented: 24.11% Rented from Council: 11.6% Rented from Council: London averages. Private Rented: 30.09% Rented HA / RSL: 6.6% 17.6% However large disparity Living rent free: 1.41% Rented private: 11.3% Rented HA / RSL: 7.2% exists within borough: in Other: 2.5% Rented private: 17.5% certain wards social Brent 2001 Other rented: NA housing / renting is Owner occupied: 55.9% Greater London 2001 (All rented=42.3%) predominant form of Rented from Council: 10.6% Owner occupied: 56.6% tenure. Rented HA / RSL: 13.3% Rented from Council: 17.1% Rented private: 17.0% Rented HA / RSL: 9.1% Poor housing conditions, Other rented: 3.1% Rented private: 14.3% lack of affordable housing (All rented=44.1%) Other: 2.9% and overcrowding, particularly in southern (Census 2001, accessed online at (Census 2001, accessed online at wards is a key www.statistics.gov.uk) www.statistics.gov.uk) sustainability issue.

Within the priority neighbourhoods of South Kilburn, St Raphaels/Brentfield, Roundwood, Church End, Stonebridge and Harlesden under a third of residents own their own homes compared to a Borough average of around 55%.

(Brent Regeneration Strategy 2001-2021)

For maps showing tenure in the Borough see Figures 11, 12 and 13 in Section 3 of Brent’s Development ManagementPart A. Policies DPD Appendices Preferred Options – SA Report (Appendices to Part A) 62 Appendix 5

Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2001 Outer London 2001 - Housing / dwelling Detached: 6.53% Detached: 8.81% type Semi: 23.88% Semi: 28.24% Terrace: 16.93% Terrace: 29.27% Flat : 52.6% Flat : 33.55% Temporary: 0.05% Temporary: 0.11%

Greater London 2001 Brent 2001 Detached: 6.04% Detached: 6.47% Semi: 19.13% Semi: 27.6% Terrace: 25.93% Terrace: 18.87% Flat : 48.8% Flat : 46.85% Temporary: 0.11% Temporary: 0.12%

Note: ‘flat’ includes purpose built, converted and flats in commercial buildings.

(Census, accessed online at www.statistics.gov.uk) Brent 2011 Outer London 2001 Household sizes and Household Size: No of Average size: 2.8 Average size: 2.43 overcrowding levels are people living in Rooms / h-hold: 4.6 Rooms / h-hold: 4.99 higher than London property Bedrooms/ h-hold: 2.5 H-holds with occupancy ratio –1 or less: averages, and both H-holds with occupancy ratio –1 or less: 12.35% important issues. 29.64% Greater London 2001 Brent 2001 Average size: 2.35 Average size: 2.61 Rooms / h-hold: 4.68 Rooms / h-hold: 4.63 H-holds with occupancy ratio –1 or less: H-holds with occupancy ratio –1 or less: 17.32% 23.95% (Census 2001, accessed online at Note: an occupancy ratio of –1 implies www.statistics.gov.uk) there is one room too few and that there is overcrowding in the household. Brent has the third highest household size in England and Wales and second highest (Census 2001, accessed online at level of overcrowding in London, with over www.statistics.gov.uk) 23% of its households living in overcrowded accommodation. Figure 12 in Section 3 of Part A shows average household sizes by ward. (AMR 2005-06)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2001 Brent 1991 There has been a marked Household Single person head: 29% Single person head: fall in the number of composition Married person head: 29.2% 30.2% married person headed Single pensioner: 10.9% Married person head: households. All pensioner h-hold: 16.1% 48.9% Lone parents: 12.8% Single pensioner: 11.9% May be due to a number of H-holds dependent children: 33% All pensioner h-hold: demographic factors, 18.2% however changing (Census, accessed online at Lone parents: 5.8% household needs should www.statistics.gov.uk) H-holds dependent be accounted for in SA and children: 31.2% DPD.

Brent, 2001 Neighbouring Boroughs, 2001 Poor housing conditions, Condition of housing Local authority: 2.7% lack of affordable housing stock: Housing assoc: 3.8% Barnet: and overcrowding, Unfit dwellings by Private: 15% Local authority: 0.2% particularly in southern tenure Total: 12% Housing assoc: 0% wards. Private: 5.5% London Divided: Income inequality and Total: 4.8% poverty in the capital. GLA, November 2002. Camden: Local authority: 2.6% Brent, 2001 Housing assoc: 7.8% 15.9% of dwellings are classified as unfit Private: 17.3% for habitation whilst a further 19.1% are Total: 11.9% deemed to be in a very poor state of repair. Harrow: Local authority: 1.3% (Brent Regeneration Strategy 2001-2021) Housing assoc: 0% Private: 4.0% Total: 3.7%

Ealing: Local authority: 2.0% Housing assoc: 1.7% Private: 6.0% Total: 5.2%

London Divided: Income inequality and poverty in the capital. GLA, November 2002 Brent’s Development Management Policies DPD Appendices Preferred Options – SA Report (Appendices to Part A) 64 Appendix 5

Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 1997-2005 Brent 1997-2004 Current UDP target As above Additional home 1997-2016: provision, new home Completed housing and additional Completed housing and Provision of at least completions housing: additional housing: 13,510 additional (UDP Indicator) 4,817 new self-contained homes 4,087 new self-contained homes, including 1,565 new non self-contained homes homes 9,650 self contained 810 formerly vacant dwellings 1,558 new non self- dwellings Total: 7,192 contained homes 720 formerly vacant (AMR 2005-2006) dwellings Total: 6,365 (AMR 2004-2005) Brent 1997-2005 Brent 1997-2004 UDP Target: As above Affordable housing 2480 self-contained dwellings 2091 self-contained 4800 affordable provision 710 non- self contained homes dwellings home completions 3190 total additional homes 710 non- self contained 1997-2016 homes Total additional affordable homes 2005- 2876 total additional 06 = 551 homes

(AMR 2005-06) (AMR 2004-05)

It is estimated that there is a shortfall of Total additional affordable housing in the Borough of affordable homes 2004- 3,382 homes per year, which represents a 05 = 249 total of 16,910 dwellings to 2010. (Brent Housing Strategy Statement 2005) (AMR 2004-05)

Brent, 2006 Brent, 2004 As above Vacant homes At the end of 2005-06, Brent had a total of Housing Service c106,000 houses and flats (including indicated a total of 4,272 c4,000 homes) vacant. There were a empty homes in 2003, of variety of reasons for the vacancies, which 3,304 had been particularly legal problems and empty for longer than six refurbishment schemes. months.

(UDP Annual Monitoring Report 2004) Brent 2003-2004 fiscal year UDP Target: % of housing built on 2005-2006 fiscal year return: 97% return: 99.56% 95% 2000-2010 previously developed 2004-2005 fiscal year land return: 100% (UDP Indicator)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2003/04 Brent 2002/03 Homelessness Decisions: 2666 Decisions: 2524 Acceptances Acceptances: 933 Acceptances: 1085

(Brent Affordable Housing Development Brent 2000/02 Team, RSL Key Facts, April 2004) Decisions: 2539 Acceptances: 1263

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Sustainability Objective 5: To provide everybody with good quality surroundings (S5) Also refer to Objective 13: To maintain and enhance the quality of landscapes and townscapes Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2003 UDP Target: Levels of vacant floorspace % Vacant Floorspace (AMR 2012-13) Wembley: 8.5% National Average by have fallen in some wards in Primary Shopping Kilburn: 0% 2010 but risen in others. Frontages by town Cicklewood: 2.2% centre Kilburn -4.4% Burnt Oak: 13.6% Disparity within the Wembley 3.3% Willesden: 6.2% Borough is a key issue. Kingsbury: 1.3% Burnt Oak -32.1% Harlesden: 2.4% Sudbury: 11.7% Colindale -2.6% Wembley Park: 0% Cricklewood -10.3% Preston Road: 0% Queens Park: 9% Ealing Road 0.4% Neasden: 8.5% Harlesden -1.5% Colindale: 3.2% Ealing Road: 4.2% Kingsbury -3.0% Kenton: 11.1% Kensal Rise: 13.5% Neasden -0.8% Preston Road -2.8% (AMR 2004-05)

Wembley Park 4.4% Brent 1997 Wembley: 10.7% Willesden Green -3.6% Kilburn: 12.2%

Cicklewood: 5.1%

Burnt Oak: 6% Brent 2005 Willesden: 10.8% Wembley: 18.4% Kilburn: 1.4% Kingsbury: 15.6% Cicklewood: 12.2% Harlesden: 12.9% Sudbury: 11.7% Burnt Oak: 0.0% Willesden: 4.7% Wembley Park: 0% Kingsbury: 2.6% Preston Rd: 4.2% Harlesden: 7.3% Queens Park: 6.4% Sudbury: 6.5% Neasden: 10.6% Wembley Park: 8.7% Colindale: 0% Preston Road:3.60% Ealing Road: 4.2% Queens Park: 2.0% Kenton: 17.2% Neasden: 6.0% Kensal Rise: 16.8% Colindale: 3.2% Ealing Road: 7.9% Kenton: 27.2% Kensal Rise: 7.6%

(AMR 2005-06)

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Brent, 2003: UDP Target: District parks: 3 No net decrease Public parks / Open Local parks: 9 2000-2010 Spaces Small local parks: 44 Sports grounds: 11 Pocket parks / play areas: 25 Country Park and Nature Reserve: 2

(Brent Parks Strategy, 2004)

Noise nuisance Brent

Figure 14 in Section 3 of Part A shows noise complaints per hectare and housing density in Brent.

Sustainability Objective 6: To reduce crime and anti-social activity (S6) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2004 Brent’s Crime Fear of crime is a key Fear of crime 66% of residents feel threatened a ‘great Strategy aims to sustainability issue deal’ by crime in their area (Brent’s Crime reduce the figure (of Audit questionnaire, 2004, cited in AMR residents that feel 2005-06). threatened ‘a great deal’) to 50% by 2007 (AMR 2005- 06)

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Brent, Apr 2005- Mar 2006 England and Wales, Apr 2004- Mar 2005 Brent, 2000-2001 Other than sexual Levels of crime Rates per 1000 population Rates per 1000 population Rates per 1000 offences, all crime rates Violence against person: 30.9 Violence against person: 19.8 population are above the national Sexual offences: 1.2 Sexual offences: 1.2 Violence against average within Brent. Robbery: 8.8 Robbery: 1.8 person: 22.9 Violent crimes, robbery Burglary: 14.5 Burglary: 12.1 Sexual offences: 1.3 and burglary are Vehicle and other theft (includes theft Vehicle and other theft (includes theft from Robbery: 7.7 particularly high. from and of a vehicle): 42.5 and of a vehicle): 37.3 Burglary: 13.3 Theft of motor vehicle: The high incidence of (Crime Statistics for England and Wales (Crime Statistics for England and Wales 6.8 crime is a key sustainability www.crimestatistics.org.uk ) www.crimestatistics.org.uk ) Theft from motor issue. vehicle: 11.5 Figure 15 in Section 3 (Part A) compares levels of crime in Brent versus national (The 2001 Census, A averages. Figure 16 shows street crime Profile of Brent.) levels in the Borough. England and Wales, 2000-2001 Rates per 1000 population Violence against person: 11.4 Sexual offences: 0.7 Robbery: 1.8 Burglary: 7.6 Theft of motor vehicle: 6.4 Theft from motor vehicle: 11.9

(The 2001 Census, A Profile of Brent)

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Sustainability Objective 7: To encourage a sense of local community; identity and welfare (S7) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2002 London Brent, 2000 Comparable with London Percentage of Satisfied: 74% Satisfied: 72% averages. residents who are Dissatisfied: 17% In 2003, 71% of Londoners were very or Dissatisfied: 16% satisfied with their fairly satisfied with London as a place to neighbourhood as a (Living in Brent 2002 a Representative live, with 78% very or fairly satisfied with place to live View. A MORI study for Brent Borough their neighbourhood. The figures for 2002 Council.) were 69% and 80% respectively

(GLA Mori Poll: Annual London Survey, 2003). http://www.mori.com/polls/2003/gla- dec.shtml)

Brent, 2011-12 Brent 1994-1999 UDP Target: Net change in Overall net decrease No net loss 2000- 2 floorspace in D2 16,638 m² of new community floorspace of 920m 2010 community use was created in 2010-2012. 2000-2004 Brent, 2005-06 Overall net increase 2 of 24,710m 6190m2 of new community floor space was created in 2005-06. (UDP Annual Monitoring Report (AMR 2005-06) 2004)

4120m2 of new community floor space was created in 2004-05

(AMR 2004-5)

No data identified. London 2001 Percentage involved 39% Londoner’s participated in formal in volunteering over volunteering (at least once in the last 12 last 3 years months) identical to the England average.

(2001 Home Office Citizenship Survey ‘People, families and communities: active participation in communities’. Home Office Research Study 270. http://www.homeoffice.gov.uk/rds/pdfs2/hor s270.pdf)

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Sustainability Objective 8: To improve accessibility to key services especially for those most in need (S8) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Access to non-car transport Brent has two radial routes and one orbital route forming part of the 900 km London Cycle Network Plus (LCN+) that is due for completion in 2010.

The implementation of the London Bus Priority Network (LBPN) has resulted in major benefits in Brent particularly on the Edgware Road and Harrow Road corridors.

(Brent Draft LIP of the Mayor’s Transport Strategy)

See the following Maps in Section 3, Part A: Figure 5 showing cycle routes and cycle parking in Brent. Figure 17, public transport accessibility and the location of railways and underground. Figure 18 showing bus priority and cycle route network. No data identified. Provision of and access to Access to Services (% essential services and having difficulty with amenities is a key access) sustainability issue. Access to: Post office Food shop GP Primary school

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Net increase in Provision of and access to Number of childcare childcare facility essential services and places available per 450 childcare providers distributed floorspace 1994-2004; amenities is a key 1,000 population of (evenly) throughout the borough 3,890m² sustainability issue. children under 5 not in early education Net increase in childcare/nursery (Brent LEA) floorspace 2005-06: 1330 m2. Increase in (AMR 2005-06) childcare/nursery floorspace 2004-2005: 2 2100 m

(AMR 2004-5)

Identical to Open Space indicator and % Population living access map under Sustainability within 200m of open Objective 2. space Brent, 2003: Area of outdoor sports land for community Football: 0.21 use (hectares per 1000 Cricket: 0.06 population) Rugby: 0.009 Gaelic football: 0.023 Hockey: 0.015

Total: 0.33

Brent Playing Pitch Strategy 2003-2008, Brent Parks Service, May 2004.

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Environmental Baseline Characteristics and trends

Sustainability Objective 9: To reduce the effect of traffic on the environment (EN1) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2002 – 2005 For the first 2 years of the period 2001 to Brent 1997-2004 Brent Traffic flows barely Traffic reduction 2011 where Brent’s revised target of “a Between 1997 and UDP Target: increased in Brent in 2005- levels – traffic levels Estimated traffic flows for all motor noticeable reduction in traffic growth” should 2004 Brent has 10% reduction 1997- 06. The percentage per annum (UDP vehicles by Local Authority, 2002-2005 apply, there was a significant increase in the recorded an 80 million 2008 increase of traffic flows indicator) (million Km) rate of growth over the previous 3 years, Km, or 8.6%, increase between 2002-2003 to although this stabilised to zero growth from in traffic flow. “noticeable 2004-2005 has decreased 2002: 1005 million Km 2003-2004. In comparison, the overall reduction in within Brent 2003: 1013 million Km Greater London growth has remained (Annual Monitoring growth” target up to =0.8% change relatively low at a rate of only 3% from 1997 Report 2004-05) 2011 (AMR 2005-06) to 2004. (AMR, 2004-5) 2004: 1013 million Km The current trend is for 2005: 1017 million Km (AMR 2004-05) traffic levels to continue to =0.0% change grow with increasing car Brent‘s level of increase in traffic was below ownership and consequent (AMR 2005-06) that of Camden, Barnet and Westminster. decreasing average journey speeds (LBB, Draft (AMR 2005-06) LIP)

Noise nuisance and vibration from major road routes, poor air quality, ease of movement and pressure on biodiversity and habitats are all critical sustainability issues.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments See Sustainability Objective 22. London Transport modal split Use of public transport per head to grow faster than use of private vehicle.

50% increase in public transport capacity by 2021

(London Plan Annual Monitoring Report, 2006)

Noise disturbance and related maps are Noise nuisance and Road noise included below:. vibration from major road routes in the Borough is a London Noise Map key sustainability issue. http://www.noisemapping.org/frames/Map .asp provides overview maps of noise (road/postcode based search)

Shows that all major roads in the Borough are a source of severe localised noise pollution.

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Sustainability Objective 10: To improve water quality; conserve water resources and provide for sustainable sources of water supply (EN2) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments The River Brent (which is a main river) Water Framework Water quality and pollution runs through the borough, as well as Directive target of are key issues for the Chemical / biological several tributaries including the ‘good status’ for all watercourses running river water quality Wealdstone Brook, Mitchell Brook and the water bodies by through Brent. Wembley Brook. The borough is also 2015. crossed by the Grand Union Canal in the south.

Water quality is generally only ‘fair’ or ‘poor’ using the Environment Agency’s General Quality Assessment (GQA) classification and many watercourses suffer from pollution and sewerage misconnections.

Data is available from Environment Agency

http://www.environment- agency.gov.uk/maps/960669/?version=1& lang=_e

The River Brent has been divided into three stretches for the Water Framework Directive classification. All three are considered to be ‘at risk’ of not achieving the environmental standards of the WFD and have been provisionally classified as ‘heavily modified’ water bodies.

Data is available from the Environment Agency http://maps.environment- agency.gov.uk/wiyby/wiybyController?extr aClause=RIVER_NAME~'Brent'

Domestic water use No data identified. 165 litres per capita in London compared to 150 l/per capita (national average) and 120 litres in Copenhagen or Berlin.

Sustainability Appraisal of the London Plan (First Review) Scoping Report, January 2006

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Sustainability Objective 11: To improve air quality (EN3) Also refer to Objective 9: To reduce the effect of traffic on the environment (as driver for air pollution) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2004 Brent, 2003 Air quality in Brent exceeds Air quality monitoring CO: national standards on results (based on CO: Days moderate or occasions. This is the case results from the 5 1 Station above: O (1 station) of nitrogen dioxide (NO2) monitoring stations in Target achieved: NA Target achieved: YES and particulate matter up Brent Borough) NO2: NO2: to 10 micrometers in size 4 Station Days moderate or (PM10). In Brent, the Annual mean achieved: YES (1 station) / above: 1 (3 stations) primary source for these NA (2 stations) NO (1 station) Targets achieved: and other pollutants is road Ozone: YES (1 station) / NA traffic. Days moderate or above: 7 (1 station) (2 stations Target achieved: YES Ozone: (LBB Air Quality Action SO2: Days moderate or Plan 2005-2010) Days moderate or above: 0 (3 stations) above: 54 (1 station) Target achieved: NA (3 stations) Target achieved: NO PM10: PM10: Days moderate or above: 5-165 Days moderate or (4stations) above: 12-25 (3 Targets achieved: YES (2 stations), NO (2 stations) stations) Targets achieved: YES (1 station), NO (2 (Air Quality in London 2004, Kings stations) College London, Environmental Research SO2: Group, 2004) Days moderate or above: 1 (3 stations) PM10: 2005-2006 Target achieved: YES Annual mean Objective (of 40 μgm-3) (1 station), NA (2 exceeded at Brent 4 (roadside station) stations) and Brent 5 (residential station) Air Quality in London Incident-based Objective of 50 μgm-3, 2003, Preliminary measured as a daily mean (not to be Report, Kings College exceeded on more than 35 days London, per year) was exceeded on 180 days in Environmental 2005. Brent 4 also exceeded the Research Group objective.

During the first 6 months of 2006, Brent 5 exceeded the daily mean objective on 85 days as did Brent 4 (51 days).

(Air Quality In London 2005 and mid 2006 – Briefing, July 2006)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments

See also Figure 21 in Section 3 of Part A. Brent, 2003: 60 Other London, 2003: 2002: Number of days slightly Days when air quality N. Kensington: 59 above national urban is moderate or higher Regional Quality of Life 2003, Defra, 2004 Camden: 23 Brent: 24 average. (UK national SD Marylebone Rd: 104 indicator) Haringey: 19 N. Kensington: 16 Trend 2002 –2003 shows London A3: 33 Camden: 3 large increase, though this Bexley: 77 Marylebone Rd: 57 may be influenced by Eltham: 65 Haringey: 10 atmospheric and Hillingdon: 45 London A3: 1 meteorological factors. Bexley: 34 England urban: 51 Eltham: 24 Poor air quality, particularly Hillingdon: 11 along roads is a key Regional Quality of Life 2003, Defra, 2004 sustainability issue. England urban: 19

Brent, 2001 Poor air quality, particularly Air Quality along roads is a key Management Area/s The Council has approved that AQMAs sustainability issue. be declared in the following areas:

The entire area south of the North Circular Rd All road corridors to the north of the North Circular road: Bridgewater Road, Ealing Road, Harrrow Road, Watford Road, Kenton Road, Kingsbury Road, Edgware Road, Blackbird Hill, Forty Avenue, Forty Lane and East Lane.

(Indicators for a sustainable Brent, 2001)

See Figure 20 in Section 3 of Part A for Brent’s Air Quality Management Areas (AQMA) and Major Roads.

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Sustainability Objective 12: To conserve and enhance biodiversity (EN4) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2001 Significant areas of the Area (Hectares) of Borough are protected or Nature Conservation Sites of Special Scientific Interest: in need of protection for Importance in Brent 38 Ha nature conservation Borough grade 1 and Metropolitan Nature reasons. Conservation areas: 214 Ha The pressure on Borough grade 2 and Local Nature biodiversity and habitats Conservation areas: and lack of greenspace is 131 Ha a key sustainability issue. Wildlife Corridors: 215 Ha

(Indicators for a sustainable Brent, 2001)

Figure 22 in Section 3 of Part A shows areas of nature conservation importance in Brent. Figure 23 shows areas of nature conservation importance and access deficiency.

Brent, 2000: Brent Biodiversity As above Sites of Importance Sites of Metropolitan Importance: Action Plan for Nature 3 sites, 169 hectares Targets: Conservation (SINCs) Sites of borough importance: A: Maintain, and Grade I: 6 sites, 124 hectares improving the Grade II: 15 sites. 99 hectares wildlife status of Sites of local importance: Sites of Nature 17 sites, 44 hectares Conservation Importance in the Brent Biodiversity Action Plan, Brent Borough. Parks Services and Brent Environmental B: Reduce Areas of Services, 2001. Wildlife Deficiency in the Borough. Targets to be achieved through management of the Council’s own land; encouraging good practice by other land managers; and through planning policy

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments London, No net loss over the London Plan period

(London Plan Annual Monitoring Report 2006) Brent, 2000: As above Local Biodiversity Species: Action Plan Amphibians: Great Crested Newt Mammals: Pipistrelle Bat Local Species: Cardamine impaties, Hay meadow species, Meniola jurtina, Sanguisorba officinalis.

Habitats 6 Priority Habitats, 15 Local Habitats and 9 Broad Habitats are also identified under the Brent Biodiversity Action Plan.

Brent Biodiversity Action Plan, Brent Parks Services and Brent Environmental Services, 2001.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 307 Tree Preservation As above Tree coverage and According to the 1984-85 Wildlife Habitat Orders (TPOs). 9 new Tree Protection Survey, Brent ranks 22nd among 33 TPOs were made in Orders London Boroughs in terms of woodland the period April 2004 cover. to March 2005 which includes some 30 There were between 25,000 and 27,000 7individual trees and street trees surveyed in 1992. Since then, many trees in 180 trees have been lost each year groups and areas through vandalism, old age, disease, (AMR, 2004-5). driveway construction, subsidence claims and action by statutory bodies (utilities – gas, water, electricity, telecommunications etc). There has been no systematic tree replacement programme.

(Indicators for a sustainable Brent, 2001)

Brent, 2006 Tree protection orders: 300 trees are protected by Tree Preservation Orders (TPOs). Between April 2005 to March 2006, 7 new tree preservation orders were made which included some 100 trees.

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Sustainability Objective 13: To maintain and enhance the character and quality of landscapes and townscapes (EN5) Also refer to Objective 5: To provide everybody with good quality surroundings Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments A map of areas of low townscape quality UDP Target: There are significant areas Townscape has been included in Section 3 of Part A 10% decrease 2000- of the Borough deemed to considered to be of (Figure 24). 2010 be of low townscape low townscape quality quality, though these tend (UDP indicator) to be clustered in particular areas / wards.

The mixed quality of the built environment and need for improved architectural design quality is a key issue.

Brent, 2005-06 2004-5 Links to biodiversity and Percentage new 100% of housing greenspace issues / homes built on 97% of housing developments built on developments built on indicators. previously developed previously developed urban land (AMR, previously developed land 2005-06). urban land (AMR, 2004-5)

1992-1999: Between 1992-1999, approximately 60% of all housing developments were built on previously developed urban land in Brent.

Indicators for a sustainable Brent, January 2001

Vacant homes and vacant shopping Percentage vacant frontages contained under Objectives S4 properties and S5 above

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Countryside character Brent is part of the Countryside Character areas Area of Greater London (CCA 112), originally a gently terraced landform and now almost completely obscured by urban development.

(Volume 7 of the Countryside Character (publication reference CA13) no. 112)

Sustainability Objective 14: To conserve and where appropriate enhance the historic environment and cultural assets (EN6) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Given likely developments Number and condition Brent has 1 Grade I listed building and 6 in the Borough, there is a of listed buildings and Grade II* listed buildings. need to preserve and monuments enhance built heritage and (LB Brent Planning Services. Pers. the historic and Comm.) archaeological environment against the pressures of redevelopment. Figure 22 in Section 3 of Part A shows Conservation areas areas of nature conservation importance in Brent. Figure 23 shows areas of nature conservation importance and access deficiency.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2006 Brent, 1999 As above Listed buildings at English Heritage risk The English Heritage register of listed maintains a register of buildings that are at risk: statutory listed buildings that are 'at Old Oxgate Farm, Cricklewood (Grade II*) risk' through neglect Dollis Hill House, Gladstone Park (Grade and decay, or II) vulnerable to Cambridge Hall, Kilburn (Grade II) becoming so. Very St Andrews Church Yard (not listed, few buildings were on contains 6 listed monuments) this register in 1999, St Andrews Old Church, Kingsbury but it included the (Grade I) Grade I Old St 148 Slough Lane, Kingsbury (Grade II) Andrews Church, which has been (http://www.english- vulnerable to heritage.org.uk/server/show/nav.1424) vandalism, and the derelict Palace of Arts and Dollis Hill House. As a matter of urgency Brent is preparing action plans for the buildings.

Brent UDP, chapter 5 Built Environment No data identified. Loss or damage to scheduled ancient monuments and their settings Brent: Other London Boroughs: As above Number of 24 sites Lewisham: 54 archaeological sites of Greenwich: 68 interest Haringey: 13 Museum of London catalogue of London Newham: 32 archaeological sites. Southwark: 454 http://mol.nethostinguk.com/laarc/laarc_s Lambeth: 274 help2.html#geography [accessed Tower Hamlets: 228 September 2006] Hackney: 73 Islington: 146 Ealing: 35

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Sustainability Objective 15: To reduce contributions to climate change and reduce vulnerability to climate change (EN7) Refer also to Objective 9: To reduce the effect of traffic on the environment Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent: 24.9% Comparison authorities 1996-2005: Brent 1996-2002: Energy use and efficiency Overall improvement Lewisham: 19.2% 13.1% is a key sustainability issue in domestic energy Ninth progress report for 1996-2005, Greenwich: 20.5% and relates to issues of efficiency 1996-2003 Home Energy Conservation Act 1995 Haringey: 22.7% 1996-2003 climate change, fuel (Defra, 2006). Newham: 23.5% 15.9% poverty, income and Southwark: 17.3% health. Lambeth: 17.8% 1996-2004 Tower Hamlets: 8.2% 15.9% Hackney: 16.9% Islington: 23.1% Ealing: 11.6% 40 major applications have been UDP Target Number of evaluated through Brent’s Sustainability Net Increase developments meeting Checklist process. Of these, 36 have had ‘Good’ or ‘Very Good’ conditions and/or S106 terms requiring BREEAM / EcoHomes implementation of a range of measures Standard or and ‘Very Good/Excellent’ ratings to be incorporating achieved on the Building Research renewable energy Establishment (BRE) sustainability (UDP Indicator) assessments.

(AMR, 2004-05) No data identified. Domestic energy efficiency – SAP ratings and National Homes Energy Ratings Brent, 2003 UK, 2003 Brent, 2000 Domestic CO2 emissions Domestic CO2 Domestic CO2 emissions were estimated Brent Energy Network in Brent are similar to emissions at 661,000 tonnes of carbon dioxide Estimated domestic CO2emissions: 2.8 conducted a domestic those of Greater London during 2003, or an average of 2.5 tonnes tonnes per capita survey in 2000. They and the UK averages. a year per capita. calculated that the domestic energy There was a small (Defra (2005) Local and Regional CO2 Greater London, 2003 sector emitted about decrease in emissions Emission Estimates for 2003) 696,800 tonnes of since 2000. Estimated domestic CO2emissions: 2.6 carbon dioxide during tonnes per capita the year ending in March 2000, or an (Defra (2005) Local and Regional CO2 average of 7 tonnes a Emission Estimates for 2003) year per household.

(Indicators for a

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments sustainable Brent, January 2001) Brent, 2003 Greater London, 2003 London Total estimated per capita CO2 emissions from emissions in Brent in 2003 all sources Estimated CO2 emissions (tonnes): Estimated CO2 emissions (tonnes) per To reduce emissions were lower than the capita: 6.9 to 23% below 1990 Greater London average Industry and commercial: 578,000 (Defra (2005) Local and Regional CO2 levels by 2016 and that of several London Domestic: 661,000 Emission Estimates for 2003) boroughs. Road transport: 275,000 (London Plan Land use change: 0 Other London boroughs, 2003 Annual Monitoring Total: 1,514, 000 Report, 2006) Per capita: 5.7 Estimated CO2 emissions (tonnes) per capita (Defra (2005) Local and Regional CO2 Emission Estimates for 2003) Lewisham: 5.6 Greenwich: 5.8 Haringey: 5.5 Newham: 6.5 Southwark: 7.3 Lambeth: 5.7 Tower Hamlets: 11.2 Hackney: 4.4 Islington: 7.8 Ealing: 5.7

(Defra (2005) Local and Regional CO2 Emission Estimates for 2003) Brent, 2005-2006 Brent, 2004-2005 Brent % Energy from renewable resources There were three planning applications There are currently a 10% by 2016 which included renewable energy few small scale AMR 2004-05 generation. Two included solar panels renewable energy installation and the other was for 10 wind schemes in the turbines in the South Kilburn Borough. Regeneration area. (See Table 3, p. 18 (AMR, 2005-06) AMR 2004-05)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Specific localised flooding is an issue in London Flooding and flood risks Flood risk areas the Borough particular at times of particularly in relation to increased run-off. No net loss of the Welsh Harp Reservoir functional floodplain The Brent Council website identifies five and River Brent is a key problem areas / issues: Welsh Harp, sustainability issue. River Brent, Wealdstone Brook, surface (London Plan, water and water mains/melting Annual Monitoring snow/smaller water courses. Report, 2006)

(http://www.brent.gov.uk/services.nsf/0/ 3bbed5d8f558ab1080256e6a005627c7?O penDocument) Environment Agency produces flood risk Flooding and flood risks Flood risk zones maps. particularly in relation to the Welsh Harp Reservoir http://www.environment- and River Brent is a key agency.gov.uk/maps/960669/?version=1& sustainability issue. lang=_e

See Figure 19 for a map of flood risk zones in Brent. No data identified. Numbers of people and properties affected by fluvial flood events No data identified. Frequency of fluvial flood events No data identified. Development in the floodplain

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Sustainability Objective 16: To minimise the production of waste and use of non-renewable materials (EN8) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent Apr-Dec 2005 Brent 2002-2003: National Targets: Local pressures and Household waste Recycled (tonnes): Total household 2000 waste strategy: national / regional policy is collection and Kerbside collection: 5336 waste: 119,269 − Recover value from driving the need to manage composition Organic waste: 8716 tonnes 45% of municipal waste more effectively. Bring bank sites: 1786 Total non-household waste and to % waste: Civic amenity site: 1274 waste: 7,474 tonnes recycle 30% of The critical need to - recycled Recycling: 21% Total municipal waste: household minimise waste arisings - composted 126,743 tonnes waste by 2010 and deal with waste locally - land-filled Brent’s recycling rate Household recycled: − Enable 25% of and in a sustainable http://www.brent.gov.uk/waste 7,725 tonnes household waste manner is a key Municipal waste to be recycled or sustainability issue. recycling: 6.1% composted by 2005-6 www.capitalwastefact − Reduce landfill for s.com industrial and 2003-2004: commercial waste Recycled: 8,820 to 85% of 1998 tonnes (0.024 level by 2005 tonnes/household) Composted: 1,084 tonnes Tonnes not recycled: 105,693 (0.26 tonnes/household) Recycling: 8.6%

Brent Recycling Performance Data Chart: http://www.brent.gov.u k/waste

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2005-06 Greater London 2003/2004 Brent, 2000-2001 Statutory recycling As above Population with Households with kerbside recycling Total properties target 2007/08: 20% access to recycling collections: 76,000 Number of households: 3.1 million collected from: facilities = 74% have kerbside collection. Over 90 per cent of London households 102,737 http://www.capitalwastefacts.com have a recycling collection from home or Households with have suitable access to near entry facilities kerbside recycling (source: BVPI 91a 2005/06). collections: 72,781 = 71% have kerbside http://www.capitalwastefacts.com collection.

Brent Recycling Performance Data Chart: http://www.brent.gov.u k/waste Brent, 2004-5 West London Waste Authority, 2004-5 Municipal waste Waste generation arisings in West Summary of waste arisings: Waste generated per household: 1195 kg London increased up to 2001/2 and have Municipal waste: 131,000 tonnes of which decreased in the last household waste accounted for 117,000 four years. This tonnes. decrease reflects a decrease in civic Waste generated per household: 1121 kg amenity (CA) site and non-household waste (West London Waste Authority and arisings. However, Constituent Boroughs (2005) Draft Joint household waste Municipal Waste Management Strategy) generation is on the increase. It is thought unlikely that this decrease will continue in future, without targeted waste reduction and reuse programmes. Household waste constitutes 85% of all municipal waste.

(West London Waste Authority and Constituent Boroughs (2005) Draft Joint Municipal Waste Management Strategy) Consumption of No data identified aggregates per capita

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Sustainability Objective 17: To conserve and enhance land quality and soil resources (EN9) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent 2005 Net decrease (AMR Sites and Nature of Potentially a quarter of the land in Brent 2004-5) Contaminated Land could be contaminated due to historic industrial landuses.

A Contaminated Land Database has been compiled and includes 10, 300 sqkm of land with historical industrial uses, including in-filled land of which the origin is unknown, which may have generated the contamination of 1599 sites.

(AMR 2005-06)

Approximately 360 hectares of industrial land may be potentially contaminated

(http://www.brent.gov.uk/Services.nsf/0ef 29c57553ef690802568f00065fea4/51f6a0 a6ca2c7bb380256d660049a684!OpenDo cument)

Figure 26 shows areas of potentially contaminated land in Brent (Section 3, Part A). Brent 2005-2006 Brent 2000-2005 No net loss of open Loss of greenfield space land Net loss of 0.7ha of public open space to Net loss of 2.7 ha of (AMR 2004-5) development. open space to development (Total open space in Brent: 412 ha) (Total open space in There was an increase in the number of Brent: 412 ha) open space applications determined. However, net loss of public open space Brent 1993-1999 was marginal in comparison to previous rates of loss and new provision for sport Net loss of 38.5 ha and facilities was permitted. (AMR 2004-05) (AMR, 2005-06) Brent has seen a substantial improvement in the protection of public

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments open space, playing fields and allotments, since the mid 1990s (net loss of open space during 2000- 2006 was 4.6ha, compared to the 28.6ha net loss in the previous six years.

(AMR 2005-06)

No data identified. Stock / Area of Vacant and Brownfield Land Refer to indicator under Objective 4. UDP Target: % of housing built on 95% 2000-2010 previously developed land (UDP Indicator)

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Economic Baseline Characteristics and Trends

Sustainability Objective 18: To encourage sustainable economic growth (EC1) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2013 Brent, 2000 Development pressures Uses of land in are likely to increase employment use There is currently a total of Of a total of 437.4 in potential conflict between across the borough approximately 395ha of land currently in SEAs, BEAs and opposing land uses, active industrial use in Brent. Strategic LESs, 117 ha were in particularly between Industrial Land (SIL) accounts for around industrial, 128.9 in housing needs and the 75% of the borough’s total industrial land warehousing and 50.2 protection of employment portfolio, Locally Significant Industrial in retail use. land. Sites (LSIS) cover around 14% and the remainder is contained within Local Between 2000 and This is a key sustainability Employment Sites. There is 2006, there was a issue. approximately 277,00m2 of gross office decrease of 10.5%, B1a floorspace in Brent’s town centres, 7.8% and 12.5% of and a further 74,000m2 in predominantly land in industrial, industrial clusters. warehousing and retail use respectively (URS, Employment Land Demand Study, in SEAs, BEAs and 2013) LESs. Conversely, during the same Brent 2006 period there was an increase of land in There are a total of 432 ha of land residential use of accounted for in Brent’s Borough’s 12.9% in SEAs, BEAs Strategic Employments Areas (SEAs), and LESs. Borough Employment Areas (BEAs) and identified Local Employment Sites (LESs). URS (2006) LBB Of those 104.7 ha is in industrial, 118.9 in Employment Land warehousing and 43.9 ha is in office use. Demand Study

URS (2006) LBB Employment Land Demand Study.

The Employment Land Demand Study UDP Target: Vacant Employment (2013) found approximately 67,500 25% reduction by Land sqm of vacant office floorspace or 25% 2008 of total floorspace. There is approximately 16.2 ha of vacant industrial land.

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Sustainability Objective 19: To offer everybody the opportunity for rewarding and satisfying employment (EC2) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, various years London, various years The number, size and Number of The number of businesses per 1000 of The number of businesses per 1000 of the growth of business is Businesses, Business the population: 38.4 population: 47.4 below the London average. composition and Jobs From 1994-2004 there was a 16.6% 1994-2004 there was a 19.4% increase in These data may be increase in stock (VAT registrations and stock (VAT registrations and de- misleading however given de-registrations) registrations) for London large demographic divergence across the Average business size (2004 employees Average business size (2004 employees capital. per business): 8.9 per business): 10.7

(Economic and Social Bulletin for Brent May 2004. Policy and Research Unit) Brent, 2001 England and Wales, 2001 Data shows lower levels of Economic Activity of Employed: 56.9% Employed: 60.6% employment and higher population Unemployed: 5% Unemployed: 3.4% incidence of Economically active student: 3.6% Economically active student: 2.6% unemployment than in Economically inactive student: 8.3% Economically inactive student: 4.7% England and Wales. Retired: 9.6% Retired: 13.6% Looking after home/family: 6.8% Looking after home/family: 6.5% Unemployment and job Sick / disabled: 4.7% Sick / disabled: 5.5% opportunities for local Economically inactive: 5.1% Economically inactive: 3.1% people is a key sustainability issue. The 2001 Census, A Profile of Brent The 2001 Census, A Profile of Brent. London, October 2006 Brent May 2006 Data shows clear North – Change in claimant In 2012 the unemployment rate in LB Brent East: 4.5% South split within Borough. count unemployment Brent was 10.9% (13,900), which is Unemployment rate: 3.3% Brent North: 2.5% Unemployment rate is rate slightly above that of London (9.1%) and Male unemployment: 4.4% Brent South: 5.9% twice as high in the South somewhat higher than that of Great Female unemployment: 2.1% of Brent than the North. Britain (8%). (www.nomisweb.com) (AMR, 2005-06) Unemployment and job Brent, October, 2006 Unemployment rates opportunities for local In 2001/02, the unemployment rate for range from 9.1% people is a key Unemployment rate: 4.3% Black and Minority Ethnic (BME) groups in Harlesden to 2.7% sustainability issue. Male unemployment: 5.7% was 11.7%, compared to 5.1% for White in Queensbury Female unemployment: 2.7% groups, a ratio of 2.3. This means that BME (AMR 2004-5) groups are more than twice as likely to be Brent South: 14.6% (the second highest unemployed in London that White groups For the year to April unemployment rate at London the unemployment parliamentary constituency level) UK, June 2006 count increased by Brent North: 6.9% 2.6% 3.9% Brent East: 5.2% (Economic and Social ONS Labour Force Survey. Bulletin for Brent, Policy Figure 27 illustrates unemployment levels http://www.statistics.gov.uk and Research Unit, May by ward (Section 3, Part A). 2006)

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments

March 2004 Borough Count: 8213 Borough rate: 4.5%

Brent East: 4.6% Brent North: 2.7% Brent South: 6.1%

(Economic and Social Bulletin for Brent, Policy and Research Unit, May 2004) Brent, April 2007 London Brent, June 2006 Unemployment and job Long-term opportunities for local unemployment 25.1% of long-term unemployment 20.3% long-term unemployment (April, 21.7% of long-term people is a key (percentage of 2007) unemployment sustainability issue. unemployed who have Source: claimant count 19.5 long-term unemployment (June 2006) been out of work for (www.nomisweb.co.uk) Source: claimant count over one year) Great Britain (www.nomisweb.co.uk 16.7& (April, 2007) )

UK Brent is ranked as the 15.7% (June, 2006) 39th most employment deprived district in the Source: claimant count country (www.nomisweb.co.uk) (IMD 2004)

2001 The proportion of unemployed residents designated as long term unemployed (claiming benefits for more than 52 weeks) was over a third higher than the UK average. Brent was ranked as the 32nd most employment deprived district in the country and within the top 10% most deprived.

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments (Brent Regeneration Strategy 2001-2021) Brent, 2005 London, 2005 Brent, 2004 Full time / part time ratio Occupation of those Full time: 74% Full time: 74% Full time: 74% same as London. currently in Part time: 26% Part time: 26% Part time: 26% employment However greater share in Manufacturing: 11% Manufacturing: 5% Manufacturing: 10.7% manufacturing and Construction: 4.9% Construction: 3% Construction: 5% construction employment, Services: 84.1% Services: 91.7% Services: 84.2% and lower percentage in Tourism related: 5.3% Tourism related: 8.4% Tourism related: 5.5% services.

Nomis Brent Labour Market Profile London, 2004 Nomis Brent Labour (www.nomisweb.co.uk) Market Profile Full time: 73.7% (www.nomisweb.co.uk Part time: 26.3% )

Manufacturing: 5.5% Construction: 3% Services: 91.2% Tourism related: 8.5%

Brent, 2002 Unemployment and job Barriers to finding Not enough jobs: 15% opportunities for local work Need child care: 15% people is a key Not enough well paid jobs: 13% sustainability issue. Lack of skills / quals: 12% Few jobs suitable: 9% Don’t know: 40%

(Living in Brent 2002 a Representative View. A MORI study for Brent Borough Council.) No data identified. More than 25% of London’s children % People in Work-less live in a household where no one Households works, compared with 18% in the UK as a whole

Brent Regeneration Strategy 2001-2021

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Sustainability Objective 20: To reduce disparities in economic performance and promote regeneration (EC3) Also refer to Objective 1: To reduce poverty and social exclusion Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Refer to objective 1 and Figure 3 (Part A, Ratio of most to least section 3). deprived wards Data on these areas is included in the UDP Target: Area of land UDP Annual Monitoring Report 2004, 20Ha by 2010 redeveloped in however hard to represent in simple important (indicator) format. regeneration areas: Park Royal UDP suggested source: Wembley Planning database – acolaid (UDP indicator) Brent, 2006 Brent, 2000 UDP Target: The area of land occupied Vacant land and 25% reduction in by vacant premises and properties and derelict Vacant premises: 24.5 ha Vacant premises: 21.9 derelict land by 2008 vacant land has increased land Vacant land: 49.1 ha ha by 12% and 27% Vacant land: 38.8 ha respectively between 2000 (of a total of 432.2 ha of Employment and 2006. land) (of a total of 437.4 ha of Employment land) LBB Industrial Land Use Survey 2006 (cited in URS (2006) LBB Employment Brent Employment Land Demand Study) Land Survey Study 2001 (cited in URS (2006) LBB Employment Land Demand Study)

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Sustainability Objective 21: To encourage and accommodate both indigenous and inward investment (EC4) Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Brent, 2005 London, 2005: Brent, 2004 Borough showed a very Percentage change in VAT registrations: 1,085 (12.4%) VAT registrations: 11.8% VAT registrations: small rise in 2004. the total number of VAT de-registrations: 955 (10.9%) VAT de-registrations: 10.5% 1,150 (13.5%) However ensuring VAT registered VAT de-registrations: opportunities are suitable businesses in the area Percentage change in VAT registered Great Britain, 2005: VAT 1,140 (13.3%) and accessible to local business over year: 0.14% registrations: 9.7% VAT de- people remains a key registrations: 8.3% Percentage change in issue. (www.nomisweb.co.uk) VAT registered (www.nomisweb.co.uk) business over year: +0.009% London, 2004: VAT registrations: 12.4% Brent, 2003 VAT de-registrations: 11.4% VAT registrations: Percentage change in VAT registered 1,160 (13.7%) business over year: +0.98% VAT de-registrations: 1,060 (12.5%) England and Wales, 2004: VAT registrations: 10.1% Percentage change in VAT de-registrations: 9.4% VAT registered Percentage change in VAT registered business over year: business over year: +1.6% +0.94%

http://www.sbs.gov.uk/default.php?page=/a VAT registrations and nalytical/statistics/vatstats.php [accessed de-registrations: September, 2006] http://www.sbs.gov.uk /default.php?page=/a nalytical/statistics/vats tats.php [accessed September, 2006]

No data identified. New Business Surviving 3 Years Business start ups and closures No data identified. % Business Investment from Outside Borough

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Sustainability Objective 22: To encourage efficient patterns of movement in support of economic growth (EC5) Refer also to Objective 8: To improve accessibility to key services especially for those most in need, and Objective 9: To reduce the effect of traffic on the environment Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Poor transport Transport connectivity See the following Maps in Section 3, Part infrastructure and ease of / transport facilities A: movement particularly Figure 5 showing cycle routes and cycle given relatively low levels parking in Brent. of car ownership is a key Figure 17, public transport accessibility sustainability issue. and the location of railways and underground. Figure 18 showing bus priority and cycle route network.

See Figure 17 (Section 3, Part A). Access to public transport Brent, 2005-06 Brent, 2004-05 UDP Target: Low levels of car Proportion of retail / % approved applications at PTAL levels: % approved 90% in moderate to ownership mean that leisure floorspace Moderate: 51% applications at PTAL very good PTAL accessibility by public approved in areas of Good: 47% levels: Low: locations 2000- transport and/or foot / bike very good / good / Very good: 2% 16% Moderate: 2010. is very important. moderate public 59% transport accessibility 100% in moderate to very good PTAL Good: 17% locations Very good: 8%

PTAL – Public Transport Accessibility 84% in moderate to Level very good PTAL locations (AMR, 2005-06 (Planning Applications Database)) (AMR 2004-05 (Planning Applications Database))

2004 % approved applications at PTAL levels: Low: 24.5% Moderate: 23.4% Good: 25.9% Very good: 26.2% 75.5% in moderate to very good PTAL

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments locations

UDP Annual Monitoring Report, 2004

Brent, 2005-06 1994-2004 As above % new retail / leisure In town centre: 33.3% In town centre: 46% floorspace planning Adjoining town centre: 33.3% Adjoining town centre: permissions Out of town: 33.3% 21% in/adjoining town Out of town: 33% centres (AMR, 2005-06 (Brent Planning Applications Database)) (AMR, 2004-05 (Planning Applications Database)) Brent 2001 London 2001 Brent 1991 Relatively high use and Commuting by mode Means of travelling to work (question in Underground: 18.8% Underground: 25% dependence on public (mode of travel to Census) Train: 12.2% Train: 4.5% transport, and particularly work and school) Underground: 26% Bus: 11.1% Bus: 12.5% underground. Train: 7% Walk: 8.4% Walk: 9% Bus: 13% Car: 36% Car: 36% Low car use is a positive Walk: 7% Other: 4.9% Other: 6% factor against most Car: 34% sustainability criteria, Other: 6% National Statistics, Neighbourhood Statistics Note: these data do however ensuring (based on Census 2001). not sum to 100% as adequate access to public Note: these data do not sum to 100% as http://neighbourhood.statistics.gov.uk/Repor does not include transport and ease of does not include those who work mainly ts/eng/TableViewer/wdsview/download.asp those who work movement is a key from home. mainly from home. sustainability issue. London: The 2001 Census, A Profile of Brent. In 2001, 50% of London children walked to The 2001 Census, A school, 22% travelled by car and 20% Profile of Brent. caught the bus. Nationally, fewer children walk to school (48.5%) and more are driven to school by car (28.5%)

National Travel Survey, Department for Transport. http://www.dft.gov.uk/stellent/groups/dft_tra nsstats/documents/page/dft_transstats_028 347.hcsp

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Data Theme / Quantified Data, Scale, Map Comparators Trend Targets Issues and Indicator Reference Comments Greater London, various years Brent 2001-2018 Peak / Off peak traffic Average traffic speeds (mph) Average inbound speeds / flows Morning peak traffic flows on the 1983-90: 16.5 borough’s key roads 1990-97:15.7 between 8-9am are 2000-03: 15.0 predicted to increase by roughly 10% between now and National Travel Survey, Department for 2018. Transport. http://www.dft.gov.uk/stellent/groups/dft_tra (Indicators for a nsstats/documents/page/dft_transstats_028 sustainable Brent, 347.hcsp 2001)

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APPENDIX 5

SUSTAINABILITY OBJECTIVES, CRITERIA, INDICATORS AND TARGETS

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Sustainability Objectives, Criteria, Indicators and Targets

Sustainability Criteria Potential Indicators Targets Objectives Social Prosperity and • Will it reduce poverty and Population and demographics (age Social Inclusion social exclusion in those structure etc.) areas most affected? Index of Multiple Deprivation S1. To reduce • Will it improve Average household income poverty and social affordability of essential Percentage households with no employed exclusion services? adults with dependent children Percentage of children living in poverty (after housing costs) % Households Experiencing Fuel Poverty UK Eradicating fuel poverty by 2016 Health • Will it improve access to Self assessment of health over last 12 England high quality health months 70% target by 2020 S2. To improve the facilities? Participation in sport (excludes walking) health of the • Will it encourage healthy Number of sports facilities by type population lifestyles and provide Access to public open spaces opportunities for sport Main mode of travel to work London Cycling Action and recreation? Plan: • Will it reduce health 80% increase in cycling inequalities? levels in the Capital by • Will it reduce death 2010 and a 200% rates? increase by 2020, compared to cycling levels in 2000.

(Brent Draft LIP of the Mayor’s Transport Strategy) Access to GP/ Surveys of Access Targets from Brent PCT 1. Practices with an appointment to see a primary care professional within 1 1. 100% working day 2. 90% 2. Practices with an appointment to see 3. 90% a GP within 2 working days: 73.8% 4. 100% 3. Practices with an appointment system in place to see a primary care professional: 90.5% 4. Practices participating in Primary Care Access Survey: 53% No of GPs per 1000 population Education and • Will it improve Secondary: Skills qualifications and skills of % Children obtaining at least 5 GCSEs at the population? grades A* - C S3. To improve the • Will it improve access to Primary: education and skills high quality educational Key Stage 2 performance (% achieving of the population facilities? level 4+) • Will it help fill key skill Enrolments on adult education courses per gaps? 1000 population Education (NVQ equivalent) qualifications of working age residents Access to secondary schools. Secondary schools capacity Primary school capacity Access to libraries Housing • Will it increase access to Population density: people per hectare 50 dwellings per hectare good quality and (50 dph) 50 dph S4. To provide affordable housing? (minimum) (Section 7 on everybody with the • Will it encourage mixed Monitoring and opportunity to live in use and range of housing Implementation of the a decent home tenure? Development Policies • Will it reduce the number DPD). of unfit homes? House prices

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Sustainability Criteria Potential Indicators Targets Objectives • Will it reduce Affordability of housing: homelessness? Ratio of average house price to gross household income Household Size: No of people living in property Condition of housing stock: Unfit dwellings by tenure Additional home provision, new home Current UDP target completions 1997-2016: (UDP Indicator) Provision of at least 13,510 additional homes, including 9,650 self contained dwellings Affordable housing provision / completions UDP Target: 4800 affordable home completions 1997-2016

Section 7 on Monitoring and Implementation of the Development Policies DPD target: 4,575 affordable homes 2007/8 - 2016/17 Vacant homes % of housing built on UDP Target: previously developed land 95% 2000-2010

Section 7 on Monitoring and Implementation of the Development Policies DPD: 95% Homelessness Acceptances Number / percentage increase in housing development / completions Population density Quality of • Will it improve the surroundings satisfaction of people with % Vacant Floorspace in Primary Shopping UDP Target: their neighbourhoods as Frontages by ward National Average by S5. To provide places to live; 2010 everybody with encouraging ‘ownership’? % residents who are satisfied with their good quality • Will it improve residential surroundings amenity and sense of neighbourhoods as a place to live place? Surveys of perceptions • Will it reduce actual noise Public parks / Open Spaces UDP Target: levels? No net decrease 2000- • Will it reduce noise 2010 concerns? No net loss of open space to alternative uses. (Section 7 on Monitoring and Implementation of the Development Policies DPD) % population living within 200m of open Enhance and increase public open space space provision. Reduce area of open space deficiency. (Section 7 on Monitoring and Implementation of the Development Policies DPD) Area of outdoor sports land for community use Provision of new or improved children’s Net increase in number and quality of children’s play areas play areas. Reduce areas of deficiency. (Section 7 on Monitoring

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Sustainability Criteria Potential Indicators Targets Objectives and Implementation of the draft Development Policies DPD) Improvement of existing and provision for Enhance and increase public open space new or extended Public Open Space provision. Reduce area of open space deficiency (Section 7 on Monitoring and Implementation of the Development Policies DPD) Noise complaints To achieve no net increase in the number noise complaints (Section 7 on Monitoring and Implementation of the Development Policies DPD) Road / ambient noise mapping Crime Prevention • Will it reduce actual Fear of crime Brent’s Crime Strategy and & Community levels of crime? aims to reduce the figure Safety • Will it reduce the fear of (of residents that feel crime? threatened ‘a great deal’) S6. To reduce to 50% by 2007 (AMR crime and anti- 2004-5) social activity Level of crime Net reduction in criminal offences (AMR) Community • Will it encourage Percentage of residents who are satisfied Identity engagement in with their neighbourhood as a place to live community activities? Net change in floorspace in D2 community UDP Target: S7. To encourage a • Will it foster a sense of use No net loss 2000-2010 sense of pride in area? Net increase of leisure community; identity • Will it increase the ability facilities and welfare of people to influence (AMR) decisions? • Will it improve ethnic Provision of new or extended community Facilities to be accessible relations? facilities / Protection of existing community to those who need them • Will it encourage facilities (Section 7 on Monitoring communications between and Implementation of different communities in the Development Policies order to improve DPD) understanding of different Developer contributions towards new or Contributions towards needs and concerns? improved community facilities community facilities • Will it encourage people where a development to respect and value their results in additional contribution to society? pressure on, or shortage of, existing facilities (Section 7 on Monitoring and Implementation of the Development Policies DPD) Accessibility • Will it improve Number of childcare places available per accessibility to key local 1,000 population of children under 5 not in S8. To improve services? early education accessibility to key • Will it improve the level of Access to Services (% having difficulty with To ensure sustainable services especially investment in key access). Access to: Post office; Food communities, all new for those most in community services? shop; GP; Primary school residential developments need • Will it make access more should be within 30 affordable? minutes of public • Will it make access transport time of: a GP; easier for those without hospital, primary school, access to a car? areas of employment; and a major retail centre(s). (Section 7 on Monitoring and Implementation of the Development Policies DPD) Surveys of access / ease of access

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Sustainability Criteria Potential Indicators Targets Objectives Area of outdoor sports land for community use (hectares per 1000 population) % Population living within 200m of open space Access to non-car transport Environmental Traffic • Will it reduce traffic Traffic reduction levels – traffic levels per UDP Target: volumes? annum (UDP indicator) 10% reduction 1997- EN1. To reduce the • Will it increase the 2008 effect of traffic on proportion of journeys the environment using modes other than “noticeable reduction in the car? growth” target up to 2011 • Will it encourage walking (AMR, 2004-5) or cycling? Transport modal split London Use of public transport per head to grow faster than use of private vehicle.

50% increase in public transport capacity by 2021 (London Plan Annual Monitoring Report, 2006) Access to public transport PTAL score for new development Road noise Chemical / biological river water quality Water Framework Water Quality & • Will it improve the quality Resources of inland water? Directive target of ‘good • Will it reduce water status’ for all water EN2. To improve consumption? bodies by 2015. water quality; Flood risk areas London conserve water No net loss of functional resources and floodplain provide for (London Plan, Annual sustainable sources Monitoring Report, 2006) of water supply Frequency of fluvial flood events Number of planning permissions granted To achieve no which are contrary to Environment Agency permissions granted advice on water quality or flood risk contrary to EA advice on water quality or flood risk (Section 7 on Monitoring and Implementation of the Development Policies DPD) Domestic water consumption Sustainable water use in new development Net increase in number of applications implementing measures to reduce water demand (Section 7 on Monitoring and Implementation of the Development Policies DPD) Air Quality • Will it improve air quality? Air Quality Management Area/s • Will it help achieve the Air quality monitoring results (based on EN3. To improve air objectives of the Air results from the 5 monitoring stations in quality Quality Management Brent Borough) Plan? Days when air quality is moderate or higher National Air Quality • Will it reduce emissions (UK national SD indicator) Target achievement of key pollutants? throughout the borough. (Section 7 on Monitoring and Implementation of the Development Policies DPD) Biodiversity • Will it conserve and Tree coverage and Tree Protection Orders Net increase in tree enhance habitats of cover (Section 7 on

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Sustainability Criteria Potential Indicators Targets Objectives EN4. To conserve borough or local Monitoring and and enhance importance habitats and Implementation of the biodiversity create habitats in areas Development Policies of deficiency? DPD) • Will it conserve and Area (Hectares) of Nature Conservation No net loss of areas of enhance species Importance in Brent wildlife and nature diversity; and in particular conservation importance. avoid harm to protected (Section 7 on Monitoring species? and Implementation of • Will it maintain and the Development enhance sites designated Policies DPD) for their nature conservation interest? Enhance biodiversity and • Will it maintain and wildlife habitats of wildlife enhance woodland cover corridors. and management? (Section 7 on Monitoring • Will it encourage and Implementation of protection of and the Development increase number of Policies DPD) trees? Townscape considered to be of low UDP Target: townscape quality (UDP indicator) 10% decrease 2000- 2010 Percentage new homes built on previously developed land Loss of greenfield land

Sites of Importance for Nature Brent Biodiversity Conservation (SINCs) / Meeting Brent BAP Action Plan Targets: A: targets Maintain, and improving the wildlife status of Sites of Nature Conservation Importance in the Borough. B: Reduce Areas of Wildlife Deficiency in the Borough. Targets to be achieved through management of the Council’s own land; encouraging good practice by other land managers; and through planning policy

London,

No net loss over the London Plan period (London Plan Annual Monitoring Report 2006) Meeting Brent BAP targets % vacant properties Landscape & • Will it improve the Townscape landscape and ecological Number and condition of listed buildings quality and character of and monuments EN5. To maintain open spaces? Conservation areas Net improvements and enhance the • Will it enhance the quality (Section 7 on Monitoring character and of priority areas for and Implementation of quality of townscape and public the Development Policies landscapes and realm enhancements? DPD) townscapes • Will it minimise visual intrusion and protect Area of townscape considered to be of low views? quality • Will it decrease litter in urban areas and open spaces? Historic • Will it protect and Listed buildings at risk Environment & enhance Conservation Areas and other sites;

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Sustainability Criteria Potential Indicators Targets Objectives Cultural Assets features and areas of EN6. To conserve historical and cultural and where value? appropriate • Will it protect listed enhance the buildings? historic • Will it help preserve and environment and record archaeological cultural assets features? Climate Change • Will it reduce emissions Domestic energy efficiency – SAP ratings of greenhouse gases by and National Homes Energy Ratings EN7. To reduce reducing energy Number of developments meeting ‘Good’ or UDP Target contributions to consumption? ‘Very Good’ BREEAM / EcoHomes Net Increase climate change and • Will it lead to an Standard or incorporating renewable reduce vulnerability increased proportion of energy (UDP Indicator) to climate change energy needs being met Domestic CO2 emissions from renewable sources? CO2 emissions from all sources London • Will it reduce emissions of ozone depleting To reduce emissions to substances? 23% below 1990 levels • Will it minimise the risk of by 2016 flooding from rivers and (London Plan Annual watercourses to people Monitoring Report, 2006) and property? % Energy from renewable resources 10% by 2016 • Will it reduce the risk of AMR 2004-5 damage to property from Renewable energy installed by type To achieve a net storm events? (megawatts) increase in renewable energy installations and renewable energy generated. (Section 7 on Monitoring and Implementation of the Development Policies DPD) No. of major applications incorporating All major applications to onsite renewable energy generation achieve 20% or above, onsite renewable energy generation (Section 7 on Monitoring and Implementation of the Development Policies DPD) Household waste collection and National Targets: composition 2000 waste strategy: − Recover value from % waste: 45% of municipal waste - recycled and to recycle 30% of - composted household waste by - land-filled 2010 − Enable 25% of household waste to be recycled or composted by 2005-6 − Reduce landfill for industrial and commercial waste to 85% of 1998 level by 2005 Flood risk areas London No net loss of functional floodplain (London Plan, Annual Monitoring Report, 2006)

Development in the floodplain Population with access to recycling facilities Land and Soil • Will it minimise Sites and Nature of Contaminated Land Net decrease (AMR 2004-5)

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Sustainability Criteria Potential Indicators Targets Objectives EN9. To conserve development on % of housing built on previously developed UDP Target: and enhance land greenfield sites? land (UDP Indicator) 95% 2000-2010 quality and soil • Will it ensure that where Stock / Area of Vacant and Brownfield Land resources possible; new Loss of greenfield land development occurs on derelict; vacant and underused previously developed land and buildings? • Will it ensure land is remediated as appropriate? • Will it minimise the loss of soils to development? • Will it maintain and enhance soil quality? • Will it reduce the risk of subsidence? Economic Growth • Will it encourage new Number of Businesses, Business business start-ups and composition and Jobs EC1. To encourage opportunities for local Uses of land in employment use across the Net increase in the sustainable people? borough amount of floorspace economic growth • Will it improve business developed by type. development and enhance productivity? Net increase in the • Will it improve the amount of floorspace resilience of business developed by type in and the local economy? employment or • Will it promote growth in regeneration areas. key sectors? • Will it promote growth in Maintain integrity of key clusters? Strategic and Borough • Will it enhance the image employment area of the area as a business designations, subject to location? SSAs.

5% or less losses of employment land in employment/regeneration areas and local authority areas. (Section 7 on Monitoring and Implementation of the Development Policies DPD) Employment • Will it reduce short and Change in claimant count unemployment long-term local rate EC2. To offer unemployment? Long-term unemployment (percentage of everybody the • Will it provide job unemployed who have been out of work for opportunity for opportunities for those over one year) rewarding and most in need of % People in Work-less Households satisfying employment? employment • Will it help to reduce long hours worked? • Will it help to improve earnings? Regeneration • Will it promote Vacant land and properties and derelict UDP Target: regeneration; reducing land 25% reduction in derelict EC3. To reduce disparity with surrounding land by 2008 disparities in areas? Ratio of most to least deprived wards economic Area of land redeveloped in important UDP Target: performance and regeneration areas: 20Ha by 2010 promote Park Royal sustainable Wembley regeneration Investment • Will it encourage % Business Investment from Outside Borough

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Sustainability Criteria Potential Indicators Targets Objectives EC4. To encourage indigenous business? Percentage change in the total number of and accommodate • Will it encourage inward VAT registered businesses in the area both indigenous investment? New Business Surviving 3 Years and inward • Will it make land and Business start ups and closures investment property available for business development? Efficient • Will it reduce commuting? Proportion of retail / leisure floorspace UDP Target: 90% in Movement • Will it improve approved in areas of very good / good / moderate to very good accessibility to work by moderate public transport accessibility PTAL locations 2000- EC5. To encourage public transport; walking 2010. efficient patterns of and cycling? PTAL score for new developments Majority of new retail movement in • Will it reduce journey development to be support of times between key located in Wembley and economic growth employment areas and in locations with 'Good' key transport PTAL rating. (Section 7 interchanges? on Monitoring and • Will it facilitate efficiency Implementation of the in freight distribution? draft Development Policies DPD) % new retail / leisure floorspace planning No more than 35% of permissions in/adjoining town centres non- retail uses in District and Local centres’ Primary Frontage.

No more than 50% in centres with 10% or high vacancy level.

No more than 30% in Major Centres’ Primary Frontage.

(Section 7 on Monitoring and Implementation of the Development Policies DPD) Commuting by mode (mode of travel to work and school) Peak / Off peak traffic speeds / flows Transport connectivity / transport facilities Surveys of perceptions Access to public transport

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Appendix 6

APPENDIX 6

SIGNIFICANCE CRITERIA

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Appendix 6

Background and preamble

A set of ‘generic’ significance criteria was developed to provide guidance to help in scoring significance when completing the SA matrices, see overleaf. Perhaps more importantly the criteria provide a degree of transparency as to the reasoning behind allocating individual scores, such that anyone reading the SA Report should be able to understand the rationale underlying the score, even if they do not entirely agree with the score given.

It is important to recognise that the creation of pre-determined significance criteria is not a substitute for applying expert judgement:

• Completeness will never be possible, nor appropriate. Significance criteria are broad, and provide guidance to arriving at significance judgements rather than offer an accurate scale or series of thresholds. Such thresholds may be possible, but only in specific cases or projects and at small geographical scales, where, for example specific impacts and receptors can be both identified and understood. • Significance criteria will be case and location specific. Separate criteria will need to be developed in all SA and SEA examples.

• Expert judgement and local knowledge will remain a key and fundamental aspect of appraisal and significance scoring. Even when a scale or set of significance criteria have been developed, a series of judgements will still be required to decide the likely level of the effect(s) of a particular policy drawing on the evidence base available.

• Given this, differences of opinion and inconsistency remain possible. In particular the complexity surrounding predicting the effects of implementing a particular policy will remain even where significance criteria are introduced. Indirect, cumulative and long- term effects are still likely to lead to uncertainty, and different appraisers may still assign divergent scores in the same circumstances.

The generic significance criteria described here were developed further for each sustainability objective used in the completed SA of the Core Strategy Preferred Options to make them applicable to the Brent context, and can be provided on request.

The significance criteria developed for the SA of the Core Strategy DPD Preferred Options were also applicable to the SAs of the Development Policies and the Site Specific Allocation Preferred Options.

By way of illustration, the description of what would constitute a ‘major positive’ effect in the case of the sustainability objective S1 ‘To reduce poverty and social inclusion’ is as follows:

• The policy or option is likely to significantly reduce disparity and inequality within Borough, especially between the most deprived areas (Harlseden, Willesden, Kilburn

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Appendix 6

and Crickelwood) and those less deprived. In the long term it may lead to the alleviation of certain inequalities.

• It is likely to reduce significantly the number of households suffering from fuel poverty. The long-term effects are likely to lead to the eradication of fuel poverty in vulnerable households in the borough by 2010 and by 2016, as far as reasonably practical, for no person in England to be in fuel poverty (Fuel Poverty in England: The Government’s Plan for Action).

• Much improved access and affordability of essential services will be created.

• The policy or option is likely to create significant and suitable employment opportunities for local people.

• Sites: a major positive if all or most of the sites in or within easy access of most deprived wards; if providing a significant number of affordable homes;

Note that the criteria for a particular significance of effect category (major positive, minor positive, neutral etc) are not meant to be exhaustive. They are intended to provide guidance on the scores assigned during the appraisal, to ensure transparency and consistency of scoring. A score can be assigned without all the criteria within a significance of effect category being met – it would generally be assigned if one or more of the categories are met. They are not intended to be used as checklist, which suggests a level of accuracy in scoring which is simply not possible in the majority of cases.

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Appendix 6 March 2014

Generic significance criteria

7 Score Description General Comments Major An option, policy or group of sites?? very Major positive scores must be justified with Positive (++) likely to lead to a significant opportunity / description of the impacts likely to lead to a improvement, or a series of long-term major beneficial effect. improvements, leading to large-scale and permanent benefits to the sustainability Significant effects are those which either objective being appraised. impact a large amount on a specific receptor or group or potentially have smaller impact A major positive effect is also likely to have but on a particularly sensitive or important cumulative and indirect beneficial impact and receptor or group. / or improve conditions outside the specific policy or project area – will have positive Significance may also relate to existing transboundary effects. targets set locally, regionally or nationally, such as for waste management, air pollution, educational achievement etc.

Through reference to the baseline the likelihood, scale, time-frame and permanence of effects can be recorded. Minor An option, policy or project likely to lead to Minor positive scores should be justified with Positive (+) moderate improvement in both short and description of the impacts likely to lead to a long-term, leading to large scale temporary, beneficial effect. or medium scale permanent benefits to the objective being appraised. Commentary may be appropriate on how a minor-positive policy or option could be Even where beneficial effects are felt to be strengthened and / or any uncertainties and temporary, they should not be easily factors which have led to a minor as opposed reversible (to detriment of objective) in the to major positive effect being recorded. long-term.

A minor positive effect is likely to halt or reverse historic negative trends. Neutral (0) An option, policy or project which is unlikely Neutral scoring should only be used where it to have any beneficial or negative impact / is very likely that the effect will be neither effect on the objective being appraised in positive, nor negative. either the short, or long-term. Where positive and negative effects are likely This may include the continuation of a current to cancel each other out this should be trend – thus the condition of an issue may recorded as ‘mixed’ see below, rather than continue to decline / improve, however the neutral. appraiser’s judgement is that the policy is having no effect on the current trend. A neutral score is not the same as ‘uncertain’, where an appraiser is not sure if an effect is likely to be positive or negative, or ‘mixed’, where the appraiser feels that the effects are likely to be both positive and negative (see below for more detail). Minor An option, policy or project likely to lead to To be scored minor negative, effects should Negative (-) moderate damage / loss in both short and be considered able to be mitigated through long-term, leading to large-scale temporary, policy. or medium scale permanent negative impact on the objective. Commentary should be provided on how minor negative effects can be mitigated and / An option, policy or project which may also or reversed. have limited cumulative and indirect detrimental impact and / or limited degradation of conditions outside the specific policy or project area.

7 These comments should be reflected across the application of the criteria for each objective.

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Appendix 7

7 Score Description General Comments

A minor negative effect is likely to halt or reverse historic positive trends.

It is also likely that it will be possible to mitigate or reverse a minor negative effect through policy or project intervention. Major An option, policy or project likely to lead to Major negative scoring should be considered Negative significant or severe damage / loss, or a where effects are irreversible and difficult to series of long-term negative effects, leading mitigate. (--) to large-scale and permanent negative impacts on the sustainability objective being Significant effects are those which either appraised. impact a large amount on a specific receptor or group or potentially have smaller impact An option, policy or project which may also but on a particularly sensitive or important have significant cumulative and indirect receptor or group. detrimental impact and / or degrade conditions outside the specific policy or Where effects are uncertain, but there is project area – will have negative some probability of a significant negative transboundary effects. impact, a precautionary approach to scoring will be applied. An option, policy or project which is likely to threaten environmental thresholds / Major negative scores should be recorded capacities in areas already under threat. without taking into account potential for mitigation, since there is no guarantee that The detrimental effects of the option, policy or any mitigation measures (policies) will be project will be hard to reverse and are implemented or successful. In all cases unlikely to be easily mitigated through policy where major negative scores are assigned, or project intervention. policy improvement recommendations should be made. Any damage or detrimental effect in or to environmentally sensitive areas, issues or landscapes which are recognised and / or protected locally, regionally, nationally or internationally should be scored as a major negative. Mixed The effect is likely to be a combination of Such mixed and effects will be hard to (e.g. ++/-, +/- beneficial and detrimental effects, particularly predict, but could be significant in the long- where effects are considered on sub-issues, term, or when taken with other effects - etc.) areas or criteria. (cumulative).

For example a project may enhance the A mixed effect score may also be combined viability of certain protected species or with an uncertain score (?) where the relative habitats (such as native woodlands), but balance of effects, or the nature of the effects through this damage existing (non-native) remains uncertain. habitats which may themselves be important.

Uncertain The effect of a policy, project or option cannot This may be the case where a policy covers a (?) be, or is not, known or is too unpredictable to range of issues, or where the manner in assign a conclusive score. The appraiser is which a policy is implemented will have a not sure of the effect. material impact on the effects it will have.

Where the effect is genuinely uncertain an Equally it may be the case that there is uncertain score should be assigned rather insufficient evidence, information or expertise than attempt to give a positive, negative or to come to a satisfactory conclusion about neutral score. Uncertainty should be whether an effect is likely to be positive or acknowledged rather than attempt spurious negative. accuracy, which is likely to result in greater divergence amongst different appraisers. In these circumstances commentary should be provided as to how the policy may be improved / clarified to ensure a positive effect.

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SA Report Contents

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SA Report Abbreviations March 2014

ABBREVIATIONS

AMR Annual Monitoring Report LDF Local Development Framework AQMA Air Quality Management Area LDS Local Development Scheme BAP Biodiversity Action Plan LEA Local Education Authority BEA Borough Employment Area LES Local Employment Site BIW Businesses, Industry and Warehouses LGA Local Government Association BREEAM BRE (Building Research Establishment) LNR Local Nature Reserve LPA Environmental Assessment Method Local Planning Authority CEP Collingwood Environmental Planning LIP Local Implementation Plan CF Community Facilities MOL Metropolitan Open Land CMS Convention on Migratory Species NDC New Deal for Communities CO Carbon Monoxide NO Nitric Oxide CO2 Carbon Dioxide NO2 Nitrogen dioxide CP Core Policy NVQ National Vocational Qualifications CST Culture Sport and Tourism ODPM Office of the Deputy Prime Minister db Decibels OS Open Space DC Development Control ONS Office of National Statistics DCLG Department for Communities and Local PCT Primary Care Trust Government PM10 Particles measuring less than 10 microns DCMS Department for Culture Media and Sport PPG Planning Policy Guidance Defra Department for Environment Food and PPS Planning Policy Statement Rural Affairs PTAL Public Transport Accessibility Level DETR Department for Transport, Local Government and the Regions RSL Registered Social Landlords DfT Department for Transport SA Sustainability Appraisal DP Development Policy SAP Standard Assessment Procedure DPD Development Plan Document SCI Statement of Community Involvement DTI Department of Trade and Industry SD Sustainable development EA Environment Agency SD Sustainable design EEA Energy Action Area SEA Strategic Employment Area EEC European Economic Community SEA Strategic Environmental Assessment EC European Commission SFRA Strategic Flood Risk Assessment EIA Environmental Impact Assessment SINC Sites of Importance for Nature Conservation ENV Environment SOA Super Output Areas EU European Union SO Sulphur dioxide GPD Gross Domestic Product 2 SPD Supplementary Planning Document GIS Geographical Information System SPG Supplementary Planning Guidance GLA Greater London Authority SRDF Sub Regional Development Framework GOL Government Office for London SSSI Site of Special Scientific Interest GP General Practitioner SUDS Sustainable Urban Drainage GQA General Quality Assessment TC Town Centre H Housing TPO Tree Preservation Order HA Housing Association TRN Transport Ha Hectare UD Urban Design IEA Industrial Employment Area UDP Unitary Development Plan IMD Index of Multiple Deprivation UNFCCC United Nations Framework Convention on I & O Issues and Options Climate Change LA 21 Local Agenda 21 VAT Value Added Tax LBB London Borough of Brent LB WFD Water Framework Directive Brent London Borough of Brent WLWDA West London Waste Disposal Authority LBPN London Bus Priority Network (known as WestWaste) LCN+ London Cycle Network Plus ZED Zero Energy Development LDD Local Development Document

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Appendix 7 March 2014

APPENDIX 7

INITIAL SUSTAINABILITY APPRAISAL COMMENTARY AND LB BRENT RESPONSES

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Appendix 7 March 2014

Introduction

The tables which follow are recreated from the Initial Sustainability Appraisal Commentary prepared by Collingwood Environmental Planning based on a detailed review of the Development Control Policies – Preferred Options, March 2007 (as received 23/03/07 by email) and amended to reflect Development Policies – Preferred Options, May 2007 (as received 27/04/07 by email).

The tables also include (final column) the responses from LB Brent noting where the commentary and proposed changes were accepted, and if not the reason for this. Where comments have been accepted changes were made to the draft text which were included in the Development Policies DPD Preferred Options, June 1st May 2007.

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Overall and General Comments

Topic Suggested changes to the policy wording or supporting text as a result of the SA LBB Response General comments Consideration of The document includes boxes titled “Alternative options not included”. However, there are some Accepted. alternatives concerns that the justification of alternatives considered and rejected may not be sufficient within Further justification of alternative options some of the sections / for some policies. This relates to both SA requirements for the not selected to be provided as indicated consideration of alternatives and to meet the test of soundness of the DPD etc. against relevant sections below.

A few more specific comments are included on these boxes within the sections below, but the approach between sections in the draft Preferred Options is not always consistent and generally they would benefit from additional references back to the policy direction set by the Core Strategy policies or the London Plan (and that therefore various options have already been foreclosed by this higher level documents) which would provide the justification needed in some cases.

Some of the justifications on the alternatives not included just comment on that it is preferable to have a policy rather than not have one, which may well be correct but there are also potentially alternative polices / policy wording that could be used that it would be more useful to discuss.

Comments on alternatives not selected does not appear to be included for every policy and in amending the document between the March and May versions not all the policy references in the boxes have been updated.

Consider presenting several (ideally more than 2) for each policy (as presented fro DP OS8). This should include the business as usual (i.e. existing UDP policy).

Possible additional policy Some potential additional areas for additional policy are included within the sections below. areas Cross referencing of In some cases policies include cross-references to other policies which are relevant or related. policies We would recommend that the document is reviewed to ensure that they are consistent and also mutually supportive – for example UD3 Urban Structure: Space and Movement could be usefully cross-referenced to TRN2 and TRN4.

Policy “coding” Some policies do not have a reference number e.g. the policy on Sustainable Water – Demand and Efficiency and Wildlife Corridors. Adding these in will change the subsequent policy numbers.

Comments on the introduction DPD objectives Section 1 of the draft document includes a section on ‘Purpose of the Development Control Accepted. Additional information explaining Policies Preferred Options’ and ‘What are Development Control Policies?’. The later states that the purpose of the Development Policies “this Development Plan Document sets out the detailed policies which will be used primarily for document and its relationship with other Brent’s Development Management Policies DPD Preferred 117 Options – SA Report (Appendices to Part B) Appendix 8 March 2014

Topic Suggested changes to the policy wording or supporting text as a result of the SA LBB Response the determination of planning applications for development in the Borough. As with the Core DPDs to be included. Strategy, it is guided by sustainable development principles and must be subject to a sustainability appraisal” (para 1.4).

For the purposes of the SA process, which includes a task to “test the DPD objectives against the sustainability objectives”, and for the clarity of the document it is recommended that specific objectives for the Development Policies DPD are included to convey what the document is aiming to achieve (in addition to the more general LDF objectives in the Core Strategy Preferred Options). These could include, for example:

• To provide a framework and criteria for guiding the achievement of sustainable development in the Borough. • To provide the detailed interpretation of the spatial planning strategy set out in the Core Strategy. • To set out detailed policies for the determination of planning applications for development in the Borough.

Monitoring It would be useful to include some details on how the effectiveness of the implementation of the Accepted. A new section on plan will be monitored (via the AMR) and whether specific indicators will be required to achieve Implementation & Monitoring will be this (beyond those that are required / already monitored) etc included

Cross referencing to the It would be useful to explain the relationship between the Core Strategy and the Development Accepted. Additional cross referencing to Core Strategy Policies DPDs in the Introduction. It would also be useful to include cross referencing between be included where appropriate. Development policies and to the relevant overarching Core Strategy policy(ies) throughout the document.

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Policy Specific Comments

Promoting a Quality Environment

A Better Townscape – By Design

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? General / The chapter (promoting environmental quality) has a useful introduction to urban design, but it Accepted. Introduction would be useful to provide a summary of the purpose of the policies in this chapter overall and the link to the Core Strategy.

DP UD1 Urban Suggested clarifications and amendments to supporting text: Design Appraisal Para 1.6 (bullet 5) – whilst covered by this point (“…working, in partnership with the community”) it could be made clearer / emphasised that the community should be engaged with to ensure local needs and perspectives are incorporated into the design process.

Suggested clarifications and amendment to policy wording: First line refers to “urban design objectives”, however what follows is a list of other policies in the Accept – change word objectives document and not objectives. Consider amending wording to reflect this – e.g. state that proposals should be consistent with / meet the policy objectives set out in the following policies or amend wording so they are objectives (e.g. ensuring highest levels of townscape appropriate to local context and character are achieved as set out in policy DPUD2).

The policy numbers referred to do no match those in the May version of the document and need amending. The distinction between / definition of “major development proposals” and “smaller-scale proposals” To be added to glossary are not defined which could potentially lead to debate over which level of appraisal is required. Consider defining these – from a sustainability perspective this should ideally relate to the potential effects on the factors listed. Final sentence – cumulative effects of a number of “small-scale proposals” can still be significant. It Included in SPG/SPD? would be beneficial to make clear what would be expected in the “brief design statement” (in the supporting text?). This issue was raised in our appraisal of the Core Strategy policies: “Although the need to concentrate on significant developments is recognised, the cumulative effects of many smaller schemes can also be significant from a sustainability perspective. Some recognition of this fact and how to address design issues within smaller schemes should be dealt with in more detail in the forthcoming Development Control Policies DPD”

DP UD2 Townscape Suggested clarifications and amendment to supporting text: – Local Context and Para 1.10 – 2nd sentence: suggest that “development proposals on most sites” be amended to Accepted Character “development proposals on all sites”.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response?

Suggested clarifications and amendment to policy wording: ‘Good’ architecture difficult to define Point b) – although supporting text explicitly refers to “good architecture” and buildings which “surprise” – the policy text does not include any explicit reference to “architecture” which could be added to b)

DP UD3 Urban Suggested clarifications and amendment to supporting text: Structure Space and No comments. Movement Suggested clarifications and amendment to policy wording: Agreed This policy would benefit from cross referencing to the Transport policies relevant to walking, cycling and public transport. 2. Point i) – it would be useful to link to policy DC TRN7 as provisions of parking facilities will need Agreed to be appropriate. 2. Point iii) – minimising traffic conflicts is seen as positive. However it is important to ensure that Accepted- but appropriate for more “clear delineation of routes” does not mean that cycle and pedestrian routes become convoluted detailed guidance and indirect. Where pedestrian or cycle routes are indirect, over-long or complex cyclists and pedestrians are likely to take quickest route anyway – thus causing “traffic conflicts” even where specific, separate routes are provided (for example long spiralled foot/cycle bridges across roads in South Kilburn which are impractical as require walking two to three times the distance of simply crossing road – meaning that people breach barriers and walk directly across dangerous roads in spite of separate route provision).

2. Point iii) – Creating clear delineation should not result in street clutter and a detraction of local character. Agreed 2. Point iii) – it would be useful to link to policy DC TRN4 etc in relation to creating new / better cycling and walking routes.

DP UD4 Inclusive Suggested clarifications and amendment to supporting text: Design – Access For No comments. All Suggested clarifications and amendment to policy wording: Physical requirement for disabled people 1st Para – the supporting text (para 1.18) highlights the needs of other groups (the elderly, pregnant will generally meet the needs of other women and parents with young children and pushchairs) but the policy focuses on the “disabled groups people”. It would be beneficial if the needs of these groups could also be incorporated into this policy. DP UD5 Urban Suggested clarifications and amendment to supporting text: Clarity and Safety Para 1.25 – 1st sentence: suggest including reference to more specific spaces / places (shopping Accepted

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? areas, local parks, sport / play facilities) to explain what is meant by “the environment”.

Suggested clarifications and amendment to policy wording: No comments.

DP UD6 Tree Suggested clarifications and amendment to supporting text: Protection and Para 1.31 – This para could seek to support more strongly tree planting as part of development Agreed. Reference to need for tree Promotion proposals. Going beyond protection would have longer term sustainability benefits. planting on appropriate proposals to be added. Para 1.31 (or 1.37) – Reference could also be made to the need to use native species for new Not accepted. Although native species planting – which is preferable from a sustainability perspective as more likely to be in keeping with may often be preferred they are not existing trees / shrubs and provide suitable food / habitat for local wildlife. always appropriate, especially taking climate change into consideration. Suggested clarifications and amendment to policy wording: The focus of the policy is on tree protection, even though “and Promotion” has been added to the policy titles and (d) added regarding compensation since the March version. Incorporating Agreed as above. promotion of tree planting as part of this policy would be beneficial.

DP UD7 Public Suggested clarification in supporting text: Realm – Landscape Para 1.38 – it is not clear what is meant by “climate change dynamics”. Reference could also be Accepted- delete the word ‘dynamics’ Design and added regarding the need to facilitate adaptation of biodiversity under a changing climate. It is not clarification needed. Biodiversity clear what is meant by “Brent’s Design measures”.

Suggested clarifications and amendment to policy wording: Point b) – as well as “adequately”, landscaped frontages should be in keeping with the local character. Point c) – from a sustainability perspective it would be preferable that the emphasis was that all Policy already states that the expectation mature trees, shrubs and hedges should be retained except in exceptional circumstances. is that they will be retained , not Point d) – reference could also be made to appropriate species being those which are native. considered that only nature species are appropriate. Detail to be included in Point e) – is a little unclear what is meant by “integrally designed, structural landscaping on supplementary guidance. appropriate larger sites” The need to consider minimising water use as part of planting schemes and adapt to climate change would be beneficial. Bullet point before last para – sites may have habitats that are important in there own right even though they do not support specific protected or priority species. This bullet point should be worded to reflect this. Amendment to be made Bullet point before last para – It is not clear what “mitigate” means in this context (mitigate from what?). Reference to Bio-Diversity Action Plan to References to the Brent Biodiversity Action Plan has been deleted from here and elsewhere in the be included in section on enhancing

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? document compared with the March version of the document. Its there a reason for this as it is open space & biodiversity. assumed this provides useful context to what species and habitats are important locally and the actions that are needed locally?

DP UD8 Public Suggested clarifications and amendment to supporting text: Realm – Streetscape Para 1.43 – It is also important to resist crossovers etc as it increases urban run-off (as highlighted The formation of a crossover does not in in London Assembly’s Environment Committee report Crazy Paving: the environmental importance itself require planning permission where of London’s front gardens. This included a table of the number of applications for pavement permission is required the policy seeks crossovers to London Boroughs and for those boroughs that provided figures Brent had the most in to control the amount of hard most recent year report (2004)). It is recommended that this is given more prominence within landscaping policy.

Suggested clarifications and amendment to policy wording: 1st and 2nd para – consideration should be given to the environmental effects of street elements and furniture in terms of the materials used and their sources etc. This consideration should be referred to here. The factors listed a – e do not just raise issues which “detract from the local character” – they raise Not agreed. Criteria a & b are concerned a broader range of environmental issues (e.g. run-off and flood risk connected with c hard surfacing primarily with character. Detail relating to and front gardens) a provided by SPG. On c it is considered unreasonable to not allow any hard Point a) – ambiguity as to what may be deemed “excessive” infilling of space. Suggest expanding paving on development, especially as on this point to clarify. paving does not generally require Point c) –“half of a front garden area” could still represent a major loss of green space adjacent to permission, so is not included in policy. the street / open land. Any loss further should ideally be resisted.

Possible omission: signage. High-quality, clear signage can greatly improve permeability / access and ease of movement. This can be an integral part of / incorporated within street furniture and fittings. This is mentioned in the supporting text (para 1.39) however it is suggested this may merit inclusion within the policy text.

DP UD9 Public Suggested clarifications and amendment to supporting text: Realm – Lighting No comments. and Light Pollution Suggested clarifications and amendment to policy wording: No comments.

DP UD10 Suggested a clarifications and amendment to supporting text: Architectural Quality No comments.

Suggested clarifications and amendment to policy text:

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Point e) – suggest could include reference to pedestrians / passers-by, who may be as effected by a Not agreed. It is considered to be new building or extension to an existing one as those likely to use or visit it. especially important to respect the local Final sentence – from a sustainability perspective it is suggested that attention to these design / positive design and landscape where architectural considerations are just as important in areas of low townscape quality. this is of good quality. Can be dealt with Point e or f) - a reference could be added here to the need to consider climate change / hotter by cross referencing to policy SD1. average temperatures / urban heat island effect in design, use of materials, colour etc

DP UD11 Design-led Suggested clarifications and amendment to supporting text: Intensive and Mixed- No comments. use Design Suggested clarifications and amendment to policy text: No comments.

DP UD12 High Suggested clarifications and amendment to supporting text: Buildings No comments.

Suggested clarifications and amendment to policy text: 1st sentence – high building should only be appropriate where their visual and other impact can be Accepted- delete ‘most’ accommodated (rather than being “most” appropriate in these locations). Second sentence - Possible changing of wording from “Preferred locations” to “The only locations”. Not accepted- there may be other The supporting text seems to suggest that the Council will try to limit high buildings to these locations, depending upon assessment locations – so wording the policy thus could strengthen the Council’s position in this regard. of a proposal in terms of impact. This issue is addressed in SPG. Point a) – suggest inclusion of shadows / relationship to natural light and movement of the sun in Not accepted- as these issues are dealt the visual impact study. with in generic policy elsewhere, e.g. Point e) – this point could also refer to how high buildings need to consider waste disposal / SD1 & SD7. recycling issues and the need to adapt to climate change (increased temperatures etc) without increasing CO2 emissions etc. Point f) – “water channels” should also refer to groundwater flows is relevant. Not considered necessary as parking The policy could include or cross-refer to transport policies. Parking and localised traffic impacts may be a particularly important impact of such developments. and traffic impact are an important consideration in all development. Alternatives to Should refer to DP UD12 as well as DP UD 1-11. Agreed Policies DP UD1 – UD11 No specific policy alternatives have been recommended, although some justification is provided for The policies also flow from the core this. However, the “return to an earlier, single design policy” would appear not to be the only strategy i.e. policies SS1, SS9, UD1 & reasonable alternative available. UD2. This suite of policies provides the detail of how the core policies principles Some discrete policy alternatives can be imagined for Policy UD11 High Buildings, for example. It will be applied. could be limited to fewer areas or allow across the borough, or restricted further in height.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? If options are limited by the context provided by the London Plan or the Core Strategy, this should Agreed and will be added. be stated.

DP UD13 Priority Suggested clarifications and amendment to supporting text: Enhancement Areas Para 1.68 – it is unclear which “qualities” are being referred to in the 1st sentence. Agreed- to further clarify Para 1.69 – Gateways should include railway stations as well as road junctions. Agreed- and will also be reflected in a map to be included

Suggested clarifications and amendment to policy text: The intention of the policy is to treat General comment – the purpose and requirements of the policy are unclear from the limited details development within the gateways as a included. The sense of the policy also needs to be reviewed following the amendments from the priority in terms of enhancing the area. March version. This will be made clearer.

Alternatives to Should refer to DP UD13. Policies DC UD12 No specific policy alternatives have been recommended beyond dispensing with design area The only alternative is to not focus on policies. See General Comments above. key areas which is indicated, would not be in conformity with the London Plan. DP UD14 Building Suggested clarifications and amendment to supporting text: Services Equipment General comment – we would suggest including more comments promoting the use of passive solar The importance in reducing energy use design / passive heating and cooling systems and low energy cooling of buildings within the is accepted although it is considered that supporting text. This is important for reducing energy use / reducing greenhouse gas emissions, this is highlighted sufficiently by relevant and adaptation to climate change / reducing the urban heat island effect. policies SD1-7. This policy is primarily concerned with the visual /amenity Possible policy omission – there is no detailed policy obvious in the document seeking such passive impacts of equipment – detailed and design led approaches to cooling / heating and ventilation. Also is relevant as climate change guidance on how to achieve reduced response – adaptability and mitigation. energy demand as required by policy SD3, will be included in supplementary Suggested clarifications and amendment to policy text: guidance. First sentence – possible typographical error – should “conditional” read “conditioning”? Agreed. First sentence – suggest that this should include both “proposed buildings” and modifications / Agreed- delete word ‘proposed’ refurbishment to existing buildings. Not accepted Penultimate sentence – suggestion that the policy text is re-ordered so that this comes first. The “best” option in all cases seems likely to be encouraging design / architecture which negates the need for such equipment. Last sentence – these effects should be avoided as far as possible, with mitigation (as a last resort) Agreed. to an acceptable level where unavoidable.

DP UD15 Suggested clarifications and amendment to supporting text: Telecommunic- Para 1.75 – Is it likely that it would be acceptable to erect a mast in an SSSI? Depends upon the impact.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? ations Suggested clarifications and amendment to policy text: Final sentence – although the policy text is relatively strong as it stands (and perhaps goes as far as Considered strong enough for it to be it can legally?) it is suggested that schools and other sensitive sites should only be considered as a demonstrated that there are no last resort/exceptional circumstances. The text here could perhaps be strengthened to ensure this. alternative sites and that potential impact will be carefully assessed. DP UD16 Building- Suggested clarifications and amendment to supporting text: Mounted and General comment – can / should fly-posting and temporary advertising (such as estate agents This is an enforcement issue and does Freestanding boards etc.) be included in this policy? not need reference. Advertisements Suggested clarifications and amendment to policy text: Point b) – would it be possible to change “on or adjacent to” to “on, in, adjacent to as well as Considered that policy already goes into affecting” these areas as advertisements may be detrimental even if it is not on or adjavent to them? sufficient detail.

Alternatives to Should be DP UD 14 -16. Accepted- amendments to be made. policies UD13 - 15 Limited policy alternatives are discussed. See General Comments above.

DP UD17 Locally Suggested clarifications and amendment to supporting text: Listed Buildings No comments.

Suggested clarifications and amendment to policy text: Point d) – to ensure that long-term ‘gap-sites’ do not occur could a specific time-frame be put on the A condition would be applied to planning construction of replacements? consent.

DP UD18 Suggested clarifications and amendment to supporting text: Conversation Areas Para 1.95 / 1.96 – is there any plan to produce SPDs of Conservation Area Character Appraisals? Although character appraisals are being If so, they could be referred to here. produced it is not intended that these should be SPD. Suggested clarifications and amendment to policy text: No comments.

DP UD19 Areas of Suggested clarifications and amendment to supporting text: Distinctive No comments. N/A Residential Character Suggested clarifications and amendment to policy text: No comments.

DP UD20 Views and Suggested clarifications and amendment to supporting text: Landmarks No comments. N/A

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Suggested clarifications and amendment to policy text: No comments.

Alternatives to Should refer to policies DP UD 17-20 Agreed policies UD16-19 No specific policy alternatives have been included beyond simply having no conservation policies. Make reference to options foreclosed by Core Strategy and genuine alternatives to the policies. Agreed See General Comments above. Agreed 2nd para – 4 polices are included not 5.

Towards a Sustainable Brent, 2020

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Overall comments: The completion of the supporting text at the start of the section compared with the March version is welcomed. Referring back to the SA comments made during the appraisal of the Core Strategy, we would reiterate to reflect the London Plan alterations, the text could include reference to London targets Agreed. Reference to London targets to reduce carbon dioxide emissions e.g. “the council will seek to mitigate the effects of climate can be included. change locally to reduce carbon dioxide emissions by 25% by 2020 from 1990 baseline” (this is one of the figures in the London Plan alterations’ mitigating climate change policy – 4A.2ii, which is working towards 60% in 2050. The Borough could obviously have its own targets or use the target for a different year).

Updating the Brent Sustainable Design and Construction SPG 19 to an SPD, in line with the Agreed London SPG and London Plan alterations and other developments, will ensure that sustainable design and construction in the Borough is in line with the latest good practice. A specific reference to this could be added to this in the introductory text. It would be beneficial that the measures included in the London Plan (further alterations) policy on sustainable design and construction which are not be given much weight in the current document Consideration will be given to this. are reviewed and incorporated where possible (in this section or elsewhere as appropriate): • design new buildings for flexible uses throughout their lifetime • avoid creation of adverse local climate conditions • promoting the use of alternative fuels for transport (partly covered by ENV1?) • minimising overheating, heat island effects and solar gain in summer

DP SD1 Climate Suggested clarifications and amendment to supporting text: Change Mitigation Paras 1.178 – 1.181 and 1.188 – 1.190 – we welcome the inclusion of references to key Noted and Adaptation documents etc. Possible additional documents that could be referred to or could be used as a resource in drafting these sections include:

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? • Mayor’s Energy Strategy, 2004 http://www.london.gov.uk/mayor/strategies/energy/index.jsp • Planning response to climate change, ODPM, September 2004 • Towards zero carbon development: supportive information for Boroughs, July 2006 • Code for Sustainable Homes: a technical guide, March 2007 http://www.planningportal.gov.uk/uploads/code_for_sustainable_homes_techguide.pdf • Adapting to Climate change: a case study companion to the checklist for development, March 2007 http://www.london.gov.uk/climatechangepartnership/docs/adapting-climate-change-case- study-ver2.pdf

Para 1.190 – reference could also be added to this para to the GLA’s forthcoming Climate Change Adaptation Strategy.

Suggested clarifications and amendment to policy text: First sentence – it is unclear whether ‘major proposals’ have to be both or either 1,000m2/10 dwellings. Suggested that major proposals qualify if they are either of these rather than having to be both (or is this meant to be commercial and residential thresholds? If so would be clear to state this).

Bullet list – in terms of climate change mitigation and adaptation, a wider range of polices will be relevant that those in the SD or ENV sections. e.g. Adaptation of planting / landscaping to be Clarification will be made that it is water drought tolerant (e.g. UD7 and OS7?); reducing the need to travel (e.g. TRN2?); and either 1,000m² or for residential passive heating / cooling etc (UD10?), for example. development 10 units. Bullet list – reference numbering of policies needs to be reviewed as appears incorrect / note that the sustainable water policy is not numbered below Accepted- but will be made clear in Bullet list – why is ENV5 not included under environmental protection? It includes water supply supporting text. which is relevant here. Penultimate para, 1st sentence – DP ENV6 Flooding could also be referenced here, not just CP Agreed. Add cross reference ENV1. Given the susceptibility of the Borough to surface and sewer flooding, adaptation to increased flood risk from these sources may not be associated with traditional flood risk areas and the need to increase resilience to these forms of flooding should be reflected here. Last para, 1st sentence – the supporting text (para 1.180) specifies that levels 4-5 will be required, Agreed but this is not explicitly stated within the policy – reference to 4-6 could be added here (6, ‘zero carbon homes’, should not be restricted to the sites listed in para 1.187 but encouraged Agreed elsewhere especially within Wembley Energy Action Area and the Growth Areas). Agreed- minimum of level 4 to be added. ‘zero carbon homes’ are not restricted to these sites – as par 1.113 indicates these are initial designations

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Alternatives to Continuation of the current policy is one of the options available, but not the only one. Levels policy DP SD1 could be higher everywhere for example not just in the Wembley EAA and Housing Growth Areas. Agreed- alternative option of higher Justification based on the Alterations to the London Plan could be added etc. See general level will be included comments above.

DP SD2 Sustainable Suggested clarifications and amendment to supporting text: Householder Para 1.194 – this point about the significance of small developments to mitigation is important, but Agreed- sentence to be added to end Developments these smaller development also need to incorporate adaptation to climate change and it should of paragraph 1.120 accepting need for also be mentioned in this context. adaptation as well

Suggested clarifications and amendment to policy text: Policy SD2 contains requirements to submit / prepare checklists and statements. Whilst some It is necessary to minimise the level of criteria are included (minimum code level 2 and a min. of half the relevant measures etc), by detail within policy and provide more drafting this policy (and others) in this way with limited criteria / targets setting out explicitly what detailed criteria in supplementary is expected, significant reliance is being placed on the robustness of these checklists etc (for the guidance. This applies to guidance in final SA it would be useful to review these to come to a view on the implications on sustainability filling in a checklist. of this policy). Reference to specific targets/criteria in the policy would provide weight to negotiations with developers. Whilst it is understood that there could be advantages in not tying your hands within the policy itself with criteria, allowing the checklists and statements to be strengthened over time.

Alternatives to Another option, for example, would be not to distinguish between the major and small Agreed- this option will be included. policy DP SD2 developments and require them all to meet the standards set out in SD1. See general comments above.

DP SD3 Energy – Suggested clarifications and amendment to supporting text: Demand, Renewables Note Towards zero carbon development: supportive information for Boroughs (July 2006 – and Efficiency http://www.london.gov.uk/mayor/environment/energy/partnership-steering- group/LEP_towards_zero_carbon_developments.pdf) which suggests phasing requirements in major developments, and has an example policy from Kirklees council where “new council buildings incorporate a proportion of on-site renewable energy generation: at least 10% in 2005/6, Consideration will be given to rising by 5% each year, to at least 30% by 2010/11.” The current policy requires 20% straight reference in policy to seeking phased away, which is welcomed, but the accommodation of future increases could usefully be included. increases in the proportion of energy The above document, and the Mayor’s Energy Strategy also suggest that boroughs should derived from renewables over time require “energy demand assessments” for all major new developments – we would recommend and to requiring energy demand incorporating this in the policy. assessments.

Suggested clarifications and amendment to policy text: 2nd bullet – generating - See comments above re 1,000m2 / 10 dwellings. What is the percentage required for smaller sites? Would they have to comply with the 10% in the last para (as in policy

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? SD2)? Last para – examples of the circumstances which would be considered an exception could be added to the supporting text for clarity.

General - it is important to ensure that energy targets / aspirations are actually complied with / implemented post construction, especially where these targets are ongoing and progressive. If Consideration will be given as to how possible we would recommend that some formal requirement for ongoing energy performance policy will be mentioned. reporting / assessment is included in this policy and incorporated into AMR monitoring.

DP SD4 Sustainable Suggested amendments and clarifications to supporting text: Water – Demand and No comments.

Efficiency

Suggested amendments and clarifications to supporting text: Presumably this should be DP SD4? Points 1-3) - Whilst referred to in the draft strategy as a hierarchy, not all the ‘hierarchies’ operate Agreed- policy to be clarified. Although solely sequentially and it would useful to point out that all these approaches are likely to be specific targets will be extremely required (not if you do one you don’t need to do the others). difficult to monitor a reference to the General - By not including targets, just measures, this policy is potentially weakened and relies on need to have regard to the targets set enforcement through the Sustainability Statement etc. Reference to specific targets/criteria in the out in the Mayor’s draft water strategy policy would provide weight to negotiations with developers. 2007 will be added. Last para – add ‘and’ before ’Growth Areas’ as presumably this ‘particular regard’ should be for all

major developments in the Wembley EAA and Growth Areas? Note that Water matters: the Mayor’s consultation draft Water Strategy, 2007 (http://www.london.gov.uk/mayor/environment/water/index.jsp) includes (among others – these are selected for relevance) the following proposals (the targets from which could usefully be As indicated above reference will be incorporated into this or other policies): made to the need to have regard to the Proposal 3 The water use in new residential developments in London should never exceed 40m3 Mayor’s draft water strategy 2007. per bedspace per year. The Mayor’s Preferred Standards is 25 m3 per bedspace per year. Proposal 4 The Mayor will, and the Boroughs should, require major developments to supply a significant proportion of their water requirement from the site’s own resources. The Mayor will expect major developments over 30,000 m2 to supply a minimum of 50 per cent of their water requirement through on site reclamation, and developments over 15,000 m2 or 500 dwellings to meet 25 per cent of their water requirement in this way. Proposal 7 The Mayor will, and the Boroughs should, require new developments (larger than 1,000 m2 or more than 10 dwellings) to manage their surface water runoff so that there is a 50 per cent reduction in the volume and rate of surface water drainage when compared to that of the undeveloped site at peak times. Proposal 8 The Mayor will, and the Boroughs should, require new developments (larger than 3,000 m2 or more than 100 dwellings) to establish separate foul sewer and surface water drains

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? and not to discharge excess surface water into the combined sewer system. Proposal 16: Developers, in consultation with the relevant water company and sewerage undertaker, should demonstrate that there is an adequate water supply on and off site to serve the development, and that there is adequate capacity to dispose of the wastewater generated at the site. In some circumstances, it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of the existing water infrastructure.

DP SD5 Resource Suggested clarifications and amendments to supporting text: Efficiency – No Comments. sustainable Suggested clarifications and amendments to policy text: materials and Point a) – it is unclear how much weight is meant by ‘giving preference to’, does it mean all apart de/construction from exceptional circumstances for example – this could be clarified (e.g. by using a percentage) Point a-c) – does this really operate as a sequential hierarchy? No- wording will be amended Point c) – would it be possible to provide an increasing, date defined target – such as minimum accordingly 10% up until 2010, and 20% thereafter (to be reviewed) etc? Reference to specific targets/criteria Not accepted- it is not clear how a date in the policy would provide weight to negotiations with developers. defind target would work and how it could be monitored General comment –a useful source of information on sustainable construction and demolition can be found in: Planning policies for sustainable building, Guidance for Local Development Frameworks, LGA October 2006. http://www.pas.gov.uk/pas/aio/27775 (In particular, see p.8, p.11 and p.14 for policy examples from LDFs and p.18 onwards provides an outline of should be possible in policy).

DP SD6 Poor Air Quali General comment – a link is not made between this policy and DP ENV1. There would seem to Accepted – cross reference to be - Adaptation be potential overlaps between them. added to supporting text.

Suggested clarifications and amendments to supporting text: Section / policy title – the use of ‘adaptation’ in this context may be confusing and an incorrect Accepted- heading to be amended assumption made that it is principally to do with climate change (whilst the comment in para 1.215 is acknowledged). Accepted- policy is intended to deal Policy focus – it is unclear within the supporting text and the policy whether the focus is meant to with the impact of poor external air be internal air quality or internal and external air quality. The supporting text and the policy would quality on internal air quality for benefit from clarifying this. sensitive uses. This will be clarified.

Suggested amendments and clarification to policy text: More detail will be provided in revised General comment - More detail could be provided on the specific types of action and features SPD which developers will be expected to implement. Accept- need for consistency

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? nd st 2 para – replace ‘adjacent’ with ‘near’ as in the 1 para. Last para – whilst energy/CO2 is relevant the key source of poor air quality is likely to be traffic Not accepted- policy ENV1 deals with generation which is not addressed here. Requirements could be made to reduce the need to the impacts of new development on travel, reduce parking etc to compensate. external air quality.

DP SD7 Operational Suggested amendments and clarifications to supporting text: Waste Management Para 1.217 – to add to the urgency of this waste ‘message’ reference could be made to research Considered that the urgency of the by the Environment Agency, showing that at current rates of disposal to landfill, London only has waste message has been addressed landfill capacity for 4 years. Within the lifetime of the LDF dramatic changes will be required in sufficiently by both the document and the way the borough manages waste. http://www.environment- the core strategy. agency.gov.uk/subjects/waste/1031954/315439/1434288/1434300/?version=1&lang=_e Para 1.193 – Suggest changing “Government planning policy” to “Government Planning Policy Agreed- paragraph 1.444 will be Statement (PPS) 10: Sustainable Waste Management” and providing a link / full reference. amended. Para 1.220 and 1.221 – these 2 paragraphs appear incomplete. Paragraphs no longer included. Suggested amendments and clarification to policy text: General comment – it is recognised that waste is to be addressed through separate SPD etc however reference to specific targets/criteria in the policy would provide weight to negotiations Waste to be addressed through with developers. separated Joint Waste DPD for West London. Targets to be included in separate monitoring section. Alternatives to More specific details on potential options for each of the 5 policies covered here would be useful. Agreed- alternative options will be policy DP SD3-7 See general comments above. more fully expressed.

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Environmental Protection

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? DP ENV1: Air Quality Suggested amendments and clarifications to supporting text: Agreed. Additional text to be added Para 1.226 – it is recognised that the need to manage the air quality impacts of traffic is necessary, stating “ every effort will be made to however there may be some risk that the wording of the 1st sentence of this paragraph re ensure new development will not create development that “generates significant amounts of traffic” which could be taken to be acceptable so air pollution problems by generating long as they undertake an air quality assessment. Reference could be included to clarify that all significant amounts of traffic, and the effort will need to be made to ensure that new development does not create air pollution problems council will promote reducing the need to by significantly increasing traffic and that the need to travel and public transport, walking and cycling travel and sustainable transport modes should be promoted. such as public transport, walking and Para 1.226 – 3rd sentence: could an exemption be made to the requirement for energy generation cycling as promoted by Core policy CP projects to have an air quality assessment for wind and solar? “Any energy generation project” may TRN2 “Reducing the need to travel”. act as an (albeit minor) obstacle to appropriate renewables generation. Agreed.

Suggested amendments and clarifications to policy text: st The significant adverse impacts of a 1 sentence – information on what is likely to be considered a “significant adverse impacts” within development will vary from site to site, the supporting text would provide additional clarity. and it is used to allow flexibility. No st 1 bullet – policy SD6 refers to in or near AQMAs – could this also be used here (rather than just change within)? 2nd bullet - see comments above on traffic generation. Agreed 5th bullet – see comments above on renewable energy generation projects. See changes above

General comments: In Cleaning London’s Air, the Mayor’s Air Quality Strategy, 2002 (http://www.london.gov.uk/mayor/strategies/air_quality/index.jsp) a number of actions which boroughs can assist with were identified. Some of these which we would suggest could be included Will review the actions list in this in the supporting / policy text are: document again. Transport Low emission zones – excluding worst vehicles. Help expansion of alternative fuelling infrastructure Will add reference to this document and Buildings to the importance of energy efficiency Efficient new / improved efficiency of old buildings Lower construction pollution

DP ENV2: Noise & Suggested clarifications and amendment to supporting text: Vibration No comments.

Suggested clarifications and amendment to policy text: No comments.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response?

DP ENV3: Pollution Suggested clarifications and amendment to supporting text: and Amenity No comments.

Suggested clarifications and amendment to policy text: 1st para, Final sentence – “acceptable” impacts may be open to interpretation. We would suggest The word acceptable is used here as the reviewing the text in order that it is clearer what will be considered acceptable, or not. impacts will vary from site to site, and it is used to allow flexibility. No change. DP ENV4: Suggested clarifications and amendment to supporting text: Contaminated Land Para 1.232 – mention could be made as a caveat of the potential ecological value of brownfield land Agreed will add additional text. / previously development land (e.g. as a habitat for protected species) and the need for this to be assessed and taken into account / appropriately mitigated / compensation proposed.

Suggested clarifications and amendment to policy text: General – mention could be made of the approach to the remediation of contaminated land and the need to consider its environmental impact and the potential for biological treatment, or Agreed will add additional text. bioremediation, for example and approaches which may reduce the environmental impact of remediation (within the context of the regulatory regime, risk assessment and the protection of human health etc).

DP ENV5: Water Suggested clarifications and amendment to supporting text: Para 1.237, 1st sentence – the WFD was transposed into UK law via Regulations rather than just Agree will amend. becoming law itself. Para 1.239 – The WFD my change these requirements as part of the process of classifying water bodies and setting standards and in terms of achieving good ecological and good chemical status ..

General – reference could be made to the GLA’s draft Water Strategy and implications for the policies considered. st Para 1.242 – 1 sentence – the text could actively seek the removal of existing culverts and Agreed will cross reference accordingly. impounding as part of new development / redevelopment. This could also be included in the policy text. This is included in Open Space policy DP OS3 – so one suggestion is these policies are cross referenced here. Agreed. Para 1.242, 3rd para – it would be beneficial to add ‘at least’ before the reference to an 8m or 5m buffer so a wider buffer is encouraged – this is a minimum. General – no mention is made of climate change and the potential effect this mayhave on water quality through reduced flows etc.

Will add additional text to policy Suggested clarifications and amendment to policy text: st st (individually or cumulatively) as in policy 1 para, 1 sentence – although it is recognised that the individual effects of large developments is ENV6 flooding.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? likely to be significant, the cumulative effects of smaller developments / changes can also be significant (see para 1.244). The policy could perhaps go further than encourage and actually require all developments to consider the sustainable drainage. Agreed 1st para, 2nd sentence – suggest ‘appropriate’ is added before ‘sustainable drainage techniques’. nd st Agreed 2 para, 1 sentence – suggest add that the removal of existing culverts and impounding as part of new development / redevelopment is sought rather than just avoiding new culverting and impounding. Agreed 2nd para, 2nd sentence - suggest ‘at least’ is added before ‘8 metre’ and ‘5 metre’.

DP ENV7: Flooding Suggested clarifications and amendment to supporting text: Agreed General – section could be titled ‘Flood and Drainage’ as two separate but related issues. See GLA’s draft Water Strategy (and the forthcoming Climate Change Adaptation Strategy) – reference Add additional text stating that the SFRA could be made to the flooding and drainage hierarchies. will identify areas at risk from surface General – no refence is made to surface water or sewer flooding (or groundwater flooding) all of water, sewer or groundwater which are potentially important issues within Brent and should be considered as part of FRAs (not just fluvial flooding). flooding in addition to fluvial flooding. FRAs should consider all types of General – no mention is made of climate change and the need to incorporate planning for increased potential flooding. risk / the need for greater resilience (in the supporting text and the policy). General - while the financial impact of social costs may be very hard to calculate the social impacts The first sentence of the flooding policy are relatively well known. See for example: The impact of flooding on urban and rural communities, text justification mentions flood risk and Environment Agency and Defra, December 2005, http://publications.environment- its relationship with climate change. Will agency.gov.uk/pdf/SCHO1005BJTG-e-e.pdf add additional text to enhance the current wording to emphasise the Suggested amendments and clarifications to policy text: impacts on urban areas. 2nd para, last sentence – does not currently make sense.

DP ENV8: Energy Suggested clarifications and amendment to supporting text: Agreed – will amend to reflect this and Renewable Para 1.257 – It would be useful to explain the link to policy DP SD 3. comment. Energy Generation

Suggested clarifications and amendments to policy text: nd st Agreed. 2 para, 1 sentence – after ‘demonstrable need’ add reference to also the need to demonstrate no significant impacts on the environment (air quality, congestion etc) or people (noise, health etc) etc as in the bullet points above which should also apply in these circumstances (traffic generation could be issue with such energy generation projects depending on the fuel). Any new non renewable energy generation should not conflict with policies relating to climate change, air quality etc, nd nd 2 para, 2 sentence – The Mayor’s Energy Strategy also encourages boroughs to have “at least Agreed – this is also covered in one showcase renewables project”. This could be referred to in the context of the EAA with further sustainable development policies – which will be cross referenced here.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? details/guidance included in the supporting text.

Alternatives to ENV It would be useful to include reference to policy numbers. policies The alternatives presented are generally whether to have a policy or not. This is a somewhat Will amend alternatives with further extreme position (and is an unrealistic option in most cases). There are likely to be alternatives to options the content of each policy which should be explored and the selection of the preferred approach justified (which could include reference to the Core Strategy, London Plan or other requirements which restrict choices at this level). Alternatives can be imagined where much more stringent, binding targets are required for things like energy, air quality etc. and for those policies dictated by Government a further alternative could be to exceed these requirements / targets.

Enhancing Open Space and Biodiversity

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB response? Introduction Suggested clarifications and amendment to supporting text:

General comment – In the SA commentary on the Core Strategy policies we recommended that “in Agreed and will amend introduction planning new or enhanced areas of open space, consideration could be given to accessibility by public transport, walking and cycling and the need to involve local residents and businesses in the process.” Our suggestion was that this could be addressed in the Development Control policies. We welcome the inclusion of reference to public involvement and the importance of accessibility in policy OS7 (provision and enhancement Of open space and nature conservation), however, given its importance from a sustainability perspective, suggest that some reference could also be made to this in the introduction.

Para 1.258, final sentence - we suggest that the plan could also emphasise the need to enhancing existing and provide new open space wherever possible. Para 1.261, final sentence – the emphasis could also be to create new open space particularly in Agreed areas of deficiency. Agreed – additional text will be included - ‘to create new open space particularly in areas of deficiency, where feasible’.

DP OS1: Open Space Suggested clarifications and amendment to supporting text: and Outdoor No comments. Recreation Agreed – cross reference will be made to Suggested clarifications and amendments to policy text: relevant sustainable design policies

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB response? Point c) – reference to energy and water efficiency could also be added. (SD3 & SD4) Point d) – suggest delete reference to ‘natural’ (likely to be semi-natural at best) and add reference Agreed – will amend accordingly to ideally enhancing these areas not just avoiding negative effects. Agreed – will amend text to ‘the Point d) – is it likely that Natural England would accept even negligible impacts on SSSIs or the development will have no significant legislation (e.g. W&C Act 1981) would allow any effect on protected species? effect’ & cross reference to policies OS4/OS5/OS6

Agreed Point e) – would it be relevant to also include reference to creating and connecting to cycle routes / networks here?

Point f) – suggest rewording from “… proposals are avoided, reduced, or mitigated” to “… proposals Unnecessary wording – hierarchy can be are avoided. In exceptional cases where impacts are unavoidable, it may be acceptable for impacts clarified in supporting text to be reduced or mitigated to an acceptable / insignificant level”.

DP OS 2: Suggested clarifications and amendment to supporting text: Metropolitan Open No comments. Land (MOL)

Suggested clarifications and amendments to policy text: Point c) – reference to energy and water efficiency could also be added. See changes above Point d) – is it likely that Natural England would accept even negligible impacts on SSSIs or the legislation (e.g. W&C Act 1981) would allow any effect on protected species? See changes above Point d) – suggest delete reference to ‘natural’ (likely to be semi-natural at best) and add reference to ideally enhancing these areas not just avoiding negative effects. Point e) – suggest rewording from “… proposals are avoided, reduced, or mitigated” to “… See changes above proposals are avoided. In exceptional cases where impacts are unavoidable, it may be acceptable for impacts to be reduced or mitigated to an acceptable / insignificant level”. See changes above DC OS3 Green Suggested clarifications and amendment to supporting text: Chains and the Blue Para 1.278 – in para on the canal, reference to promoting river transport could be added. Agreed – will amend accordingly Ribbon Network Suggested clarifications and amendments to policy text: 2nd para – in the vicinity of or affecting could be a better way of describing the relationship of new Agreed – ‘Visible from’ should be development to the Blue Ribbon Network. maintained

3rd para – as above. See above

Point a) – would it be more correct to use the terms main rivers (the Brent Reservoir) and ordinary It is useful to define in the policy text watercourses? which watercourses are being referred to

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB response? Agreed – will amend text to include ‘and Point e) – suggestion that the policy could seek that development not only “not interfere” with where possible, seek to improve’ recreation potential etc. but actually seek to improve it. Agreed

Last para – should now be “f) and g)” not “e) and f)” as a) has been added.

DP OS4 Sites of Suggested clarifications and amendment to supporting text: Special Scientific No comments. Interest (SSSI)

Suggested clarifications and amendments to policy text: nd Agreed will amend accordingly although 2 sentence – development that is not on or adjacent to the SSSI could still adversely affect it. impacts of large scale development will Therefore suggest this is broadened to include “development on, adjacent to or potentially affecting be picked up by EIA the SSSI”.

nd 2 sentence - Is it likely that Natural England would accept even negligible impacts on SSSIs? Agreed – see above

DP OS5 Local Nature Suggested clarifications and amendment to supporting text: Reserves, Sites of Para 1.283 – reference here is to Welsh Harp reservoir, but Brent Reservoir is used in para 1.280. Agreed – amend text to ‘Brent Reservoir’ Important Nature To avoid confusion it is suggested that one or other name is used. Conservation and Wildlife Corridors Agreed – text will be amended Suggested clarifications and amendments to policy text: st accordingly 1 para – development that is not on or adjacent to a site could still adversely affect it. Therefore suggest this is broadened to include “development on, adjacent to or potentially affecting”. st 1 para – by referring to “development on” these sites it would appear that their loss / partial loss is An element of flexibility is maintained for acceptable despite the reference to “conserve and enhance the special interest features”. It is not conservation and habitat sensitive clear if this intentional or not (the reference to “highest priority” implies that the others are not development. dispensable). Whilst there is clearly a hierarchy of designations, there should be a presumption against any loss of any site (with perhaps a caveat of exceptional circumstances for the more local sites with a requirement for compensation etc). Point b) – under the legislation (e.g. W&C Act 1981) would “less harm” be acceptable for protected Agreed – amend text species? Agreed – additions can be made to point General – it would be beneficial to propose that development near or adjacent to these types of sites incorporates features / habitats within the development to complement them and extend / link c), design features are also covered in wildlife corridors etc. OS7

DP OS6 Species Suggested clarifications and amendment to supporting text: Protection No comments.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB response?

Suggested clarifications and amendments to policy text: This policy has been revised to reflect It is slightly unclear from the policy whether the reference to ‘protected species’ is just including these comments species protected under the law (e.g. W&C Act 1981) or is using a wider definition as alluded to in the supporting text (e.g. including UK, London and Brent BAP species etc). It is assumed given table 1.2 it is the later definition, but the policy would benefit from this being clarified. Given the weight or UK and European law, the approach of the policy to allowing adverse effects where it cannot be prevented may not be acceptable for some of the species included in the definition of ‘protected’ here where they are protected by law.

DP OS? Wildlife Suggested clarifications and amendment to supporting text: Corridors No comments.

Suggested clarifications and amendments to policy text: No policy number? Development that is not on or adjacent to a corridor could still adversely affect it. Therefore suggest this is broadened to include “development on, adjacent to or potentially affecting”. In the supporting text and ideally in the policy it would be useful to make reference here to climate Agreed – text will be amended change and the need to allow habitats etc to adapt to a changing climate (corridors may be accordingly particularly important in this regard). Note the BRANCH project http://www.branchproject.org/ which will be developing tools for planners http://www.branchproject.org/tools/ and see Natural England report Spatial Planning for Biodiversity in our Changing Climate http://www.branchproject.org.uk/available/reportsandpublications/ENRR677Spatialplanningforbiodiv ersityinourchangingclimate.pdf

DP OS7: Provision Suggested clarifications and amendment to supporting text: and Enhancement of No comments. Open Space and Nature Conservation Suggested clarifications and amendments to policy text: Agreed – text will be strengthened to Location and security – although the text does refer to spaces needing to be “accessible” – this incorporate accessible by means of could perhaps be strengthened by making explicit reference to the need to ensure open spaces are public transport, and walking and cycling accessible to local residents by non-car means, especially walking and cycling. in particular.

Alternatives to DP As policies linked directly to Core Strategy policy CPOS1 – it is felt that the comment on is OS1 – OS7 reasonable. However, some acknowledgement of the more detailed options policy by policy would be preferred.

DP OS8: Children’s Suggested clarifications and amendment to supporting text: Para 1.305 – given that the Brent Play Strategy has identified significant areas of deficiency could S106 monies are only for arising

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB response? Play Facilities the supporting text and ideally the policy make additional requirements of developments within deficiency not existing shortfall these areas to not only compensate for the additional demand their development will cause but also address some of the existing local shortfall?

Suggested clarifications and amendments to policy text: Agreed – will amend accordingly Location and security – although the text does refer to spaces needing to be “accessible” – this could perhaps be strengthened by making explicit reference to the need to ensure open spaces are accessible to local residents by non-car means, especially walking and cycling. General – in areas of poor air quality (e.g. the AQMA) and noise pollution, particular consideration / provisions may be needed in relation to exposure to pollution (of all types).

Alternatives to OS8 Three alternatives are outlined - this approach could be adopted as a useful approach for all the Agreed – alternatives options will be fully policies. Point c) is incomplete. discussed.

Meeting Housing Needs

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? General / The brief introduction is a very useful summary of the purpose of the policies in this chapter and the To be further considered Introduction link to the Core Strategy. This format could usefully be repeated for the other chapters and also amalgamated to form the over objectives of the Development Policies DPD as requested in the general comments on the introduction above.

Alternative options Boxes setting out the alternative options not considered are included under each policy which is To be further considered not considered welcomed and this format could usefully be repeated for the other chapters.

However, some of the comments provide present a limited view of the options available (options may be foreclosed by the London Plan or the Core Strategy for example but it would be useful for this to be explicitly stated – as in DP H14 for example) and/or presents extreme options (e.g. the comment for DP H2 which refers to the option of prioritising new housing on greenfield sites when a more realistic option could be a lower percentage of brownfield than 95% but still the majority). The Accepted in principle. current UDP policy position should also be referred to where relevant to provide the business as usual option.

Housing Provision – Sources of Supply DP H1 Resisting Suggested clarifications and amendment to supporting text: Loss of Housing No comments.

Suggested clarifications and amendment to policy text:

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? No comments (apart from the second a) should be c)). Agreed

DP H2 Housing on Suggested clarifications and amendment to supporting text: Accepted in principle Brownfield Sites Para 2.7, 3rd sentence – this contents of this sentence would benefit from further explanation. Care will be required in implementation of such a policy as there is potential conflict with other policies, especially ENV and OS policies, (e.g. brownfield sites may be of biodiversity or local Accepted in principle recreational value). The need to manage these potential conflicts could be referred to in the supporting text and the policy.

Suggested clarifications and amendment to policy text: Point d) – this should ideally be a presumption against development on any open space, not just open space which is deemed to be currently “of amenity value”. Some open space is ‘left over‘ from earlier development and is of no effective amenity value DP H3 Sub-Division Suggested clarifications and amendment to supporting text: of Houses; Flat No comments. Conversions Suggested clarifications and amendment to policy text: Although the need for more homes is acknowledged, care should be taken to protect the stock of The ‘conversion thresholds’ is family homes. This is noted in the supporting text (para 2.8), however we suggest this caveat might considered sufficient to protect existing be included within the policy itself. family housing

The SA baseline (see SA Report Part A Appendix 5) study showed that Brent had in 2001 an above average household size – in fact the third highest average size (at Local Authority level) in England Most conversions are of former Houses and Wales, and the second highest level of overcrowding in London. The critical shortage of family in Multiple Occupation rather than sized accommodation is also note in paragraph 2.32 under “A Balanced Housing Stock”. While current single family dwellings. And as Policy DP H9 addresses the need for new housing to provide family units (at 30%), this may partly residential conversions have accounted be offset if existing family size dwellings are sub-divided in significant numbers. for less than 10% of new housing completions in recent years in Brent, it is unlikely that “existing family size dwellings are sub-divided in significant numbers”. DP H4 Change of Suggested clarifications and amendment to supporting text: Use No comments.

Suggested clarifications and amendment to policy text: No comments.

Sustainable Housing Development General Suggested clarifications and amendment to supporting text: Para 2.11 – clarify distinction between adaptation and mitigation. Housing development should be Accepted in principle

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? adapted to (inevitable) anticipated climate change and be design to incorporate mitigate measures to avoid exacerbating further climate change.

DP H5 Scale of New Suggested clarifications and amendment to supporting text: Housing: the No comments. Locational Approach Suggested clarifications and amendment to policy text: 1st sentence – the policy could perhaps go further than just seeking to ensure that new housing development is “without detriment” to local amenities and townscape and explicitly seek for new Accepted in principle development to enhance and contribute to adjacent amenities and townscape.

DP H6 New Housing: Suggested clarifications and amendment to supporting text: External Design, No comments. Layout and Amenity Space Suggested clarifications and amendment to policy text: Additional point – designing housing to adapt to and mitigate climate change could be added as a Accepted in principle separate point cross referenced to policies DP SD 1-3 (in terms of adaptation, this could be in terms of ventilation and cooling for example)

DP H7 New Housing Suggested clarifications and amendment to supporting text: Development: No comments. Internal Layout and Amenity Suggested clarifications and amendment to policy text: 2nd para, 1st sentence – reference here could be added on lifetime homes (as well as working from Accepted in principle home) to provide flexible, accessible and adaptable housing (and references to it added to the supporting text).

DP H8 Very Large Suggested clarifications and amendment to supporting text: Housing Schemes, No comments. Including Major Estate Regeneration Suggested clarifications and amendment to policy text: Areas Point d) – reference could be made to “generation of on-site renewable energy”, rather than “use of Accepted in principle renewables”.

Additional point – it will be essential to involve the local community in schemes of this type and Accepted in principle therefore it is suggested that the following point is added: the employment of an exemplar approach to community engagement to ensure the views of the local community are incorporated into the design process, including the preparation and implementation of an appropriate community engagement plan.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? A Balanced Housing Stock DP H9 Dwelling Mix Suggested clarifications and amendment to supporting text: (Self-contained No comments. Housing) Suggested clarifications and amendment to policy text: See comments on DP H4 – it would seem useful to cross-reference the two policies. NB No comments have been made on H4 so clarification of intent is required DP H10 Sheltered Suggested clarifications and amendment to supporting text: Housing (Self- No comments. contained Accommodation Suggested clarifications and amendment to policy text: No comments.

DP H11 New Non Suggested clarifications and amendment to supporting text: Self-contained No comments. Accommodation Suggested clarifications and amendment to policy text: No comments.

DP H12 Housing Suggested clarifications and amendment to supporting text: Providing Care No comments.

Suggested clarifications and amendment to policy text: This policy deals with new care housing, but is there a need in the borough for this policy / another Definitely a need for a specific Housing policy to also cover the conversion of existing large residential / family properties into care housing – Providing Care Policy, which covers new whilst a) suggests that the redevelopment of these types of property to build new care homes etc on build as well as conversions. the site would not be acceptable, it may be preferable for them to be retained and converted to care housing rather than redeveloped for other housing (assuming it is perhaps a larger / older style Criteria a) is not a ‘presumption’ against property of some architectural / townscape interest). loss of existing family accom- modation. The balance between the need for Housing Providing Care and the loss of family accommodation will be assessed on a site/location specific basis. Experience has shown that Housing Providing Care is more likely to involve the loss of larger family accommodation than in conversions to flats, particularly where several adjoining large houses would be converted into a single establishment.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? DP H13 Sites for Suggested clarifications and amendment to supporting text: Nomadic Peoples No comments.

Suggested clarifications and amendment to policy text: Foul and surface water drainage is not Point c) – would “local services” include services such as schools, shops and health care and classified as a ‘local service’ but as a adequate means of foul and surface water drainage etc? If not, consideration should be given to basic Building Regulations requirement. specifying them. “Accessible to local services” if taken in the physical sense would not include Local services’ accessibility in the recognise the capacity or level of services available, which is also an important consideration. context of ‘capacity, as opposed to distance, is a Policy CP H1 requirement. Affordable Housing Provision DP H14 Requirement Suggested clarifications and amendment to supporting text: for Affordable No comments. Housing Suggested clarifications and amendment to policy text: No comments.

DP H15 Type of Suggested clarifications and amendment to supporting text: Affordable Housing No comments.

Suggested clarifications and amendment to policy text: No comments.

DP H16 Off-site Suggested clarifications and amendment to supporting text: Affordable Housing No comments. – ‘Provision in Lieu’ Suggested clarifications and amendment to policy text: No comments.

Connecting Places

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Assessing and Mitigation the Impact of Transport General / Introduction The chapter would benefit from a brief introduction to provide a summary of the purpose of the policies Accept- The policies in this chapter are in this chapter and the link to the Core Strategy. structured around the four Transport Core Policies in the LDF Core Strategy and are intended to aid the implementation of these strategic policies. The policies in

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? this chapter are intended to ensure: • Sustainable transport modes, • Free flow of traffic • Safety of the road network and public highway DP TRN1 Transport Suggested clarifications and amendment to supporting text: Accept, will remove 2nd sentence Assessment Para 3.1, 2nd sentence – presumably a Transport Assessment will be needed anyway in order to determine if the development will have a significant effect on either the local road network or public transport services (if this shows it will not have a significant effect, then the Travel Plan would become unnecessary). General – whilst it is appreciated that applications have to be considered on their merits, it would be useful to mention in the supporting text, and integrate into policy if possible, that the cumulate impact of Accept inclusion, however in application, small scale developments can combine to have a significant impact and where an individual small scale we would advise that the developer scheme is responsible to adversely affecting a transport system in a small way but which means a includes the cumulative impact of other threshold or level is reached it may mean the proposal is refused. proposed developments in the vicinity of the subject site in Transport Assessment. Suggested clarifications and amendment to policy text: No comments.

Alternatives to DP A reasonable summary of alternatives and justification of their rejection is provided – one additional Accept- include alternative TRN1 alternative that could be mentioned would be to limit the requirement for Transport Assessments and Travel Plans to only major developments in the policy (although this would not be the preferred approach in terms of sustainability).

Sustainable Modes of Transport DP TRN2 Public Suggested clarifications and amendment to supporting text: N/A Transport Integration Para 3.9 – not clear whether the reference to UD10 is correct?

Suggested clarifications and amendment to policy text: No comments. Possible amendment to policy text: No comments.

DP TRN3 Bus Suggested clarifications and amendment to supporting text: N/A Improvements / No comments. Connections Suggested clarifications and amendment to policy text:

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? No comments.

Alternatives to DC A reasonable summary of the justification for rejecting the alternatives is provided. N/A TRN2 and 3 DP TRN4 Cycling and Suggested clarifications and amendment to supporting text: Walking No comments. Environments Suggested clarifications and amendment to policy text: One possible addition could be to include text which seeks to promote a coherent network of walking Unnecessary, information already and cycling routes – that is routes which are consistent, connected and provide common sense routes. included in policy text.

Cycle routes and cycle lanes on roads should not end abruptly in unsafe or inconvenient locations, and special care should be taken at junctions and roundabouts. For example there has been criticism Accept inclusion, important to cyclists and (there are many examples from grass-routes and more mainstream organisations such as Sustrans) road safety. that currently cycle lanes in many part of the UK often ‘peter-out’ just before dangerous junctions.

Alternatives to DC A reasonable summary of the justification for rejecting the alternatives is provided. N/A TRN 4 Brent’s Road Network and Highway Design DP TRN5 Highway Suggested clarifications and amendment to supporting text: Design and Forming Para 3.16 and 3.17 – as they are linked by purpose, it may be worth cross-referencing DP UD8 Public Accept cross reference to UD8. an Access to a Road Realm – Streetscape (which in turn should cross-reference this policy).

Suggested clarifications and amendment to policy text: 3rd para - whist this policy is focussed on access to the highway via crossovers and DP UD8 is Accept- change to policy, this will require concerned partly with loss of front gardens to hard-standing, the issues are clearly related. In our joint working with the officer concerned. comments on DP UD8 we advocate that all loss of front gardens should be resisted (both in terms of streetscape but also drainage etc) and not “half of a front garden area”. In turn we would advocate a more restrictive policy on crossovers (which also raise safety issues for children on the pavement etc). However, the policy stance in the two policies needs to be consistent.

Alternatives to DC A reasonable summary of the justification for rejecting the alternatives is provided. N/A TRN 5 Freight DP TRN6 Freight Suggested clarifications and amendment to supporting text: N/A No comments.

Suggested clarifications and amendment to policy text: Ideally the amount of freight movement in the borough by road would fall – however it is understood Agreed but amendment is unnecessary that the council must plan for the management of freight based on the assumption that it is likely to rise.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response?

Alternatives to DC A reasonable summary of the justification for rejecting the alternatives is provided. N/A TRN 6 Parking in Brent DP TRN7 Parking: Suggested clarifications and amendment to supporting text: N/A Residential and Non- No comments. Residential Developments Suggested clarifications and amendment to policy text: No comments. Unnecessary, this is included in TRN4 Possible omission: Although parking for cycles is included in the Parking standards annex, this may also be a suitable location to include specific policy text on providing parking for bicycles. This should be conveniently located, secure, provide safe access to roads / cycle paths.

DP TRN8 Restrictions Suggested clarifications and amendment to supporting text: N/A of Off Street Parking No comments.

Suggested clarifications and amendment to policy text: No comments. N/A

General - the development policies and Connecting Places should consider the Local Implementation Agreed, these have been considered in Plan (LIP) and what spatial planning policies could do to further support its implementation. reference to Brent’s Road Danger Reduction Plan in the LIP. DP TRN9 Parking in Suggested clarifications and amendment to supporting text: N/A Town Centres No comments.

Suggested clarifications and amendment to policy text: N/A No comments.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. N/A TRN 7 - 9 Parking Standards Note: an appraisal of the Parking Standards has not been undertaken. N/A

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A Strong Local Economy

Business, Industry and Warehousing

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? General / The chapter has a very useful introduction that provides a summary of the purpose of the policies in Noted and accepted Introduction this chapter and the link to the Core Strategy.

No mention of Areas of intensification / Area of Regeneration / Opportunity Areas (apart from Park Royal Opportunity Area - para 4.22) from the London Plan and Sub Regional Development Frameworks generally in the draft DP Preferred Options – do any of these occur in Brent and should the plan include policies related to these if they occur?

DP BIW1 Suggested clarifications and amendment to supporting text: Regeneration of No comments. Local Employment Areas Suggested clarifications and amendment to policy text: Even small scale B8 uses may generate traffic. The policy text could explicitly state that such uses in LEAs will only be allowed where there is no significant impact on local amenity, local traffic, noise, Noted and accepted congestion etc.

DP BIW2 Facilities Suggested clarifications and amendment to supporting text: for Employees No comments.

Suggested clarifications and amendment to policy text: No comments.

DP BIW3 Work-live Suggested clarifications and amendment to supporting text: development No comments.

Suggested clarifications and amendment to policy text: No comments.

DP BIW4 Working at Suggested clarifications and amendment to supporting text: home No comments.

Suggested clarifications and amendment to policy text: No comments.

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response?

DP BIW5 Park Royal Suggested clarifications and amendment to supporting text: No comments.

Suggested clarifications and amendment to policy text: No comments.

Alternatives to DP The alternatives proposed are essentially the opposite of the draft preferred policies. As such there Noted and accepted BIW1-5 is clear justification in them not being preferred, but there are potentially more realistic alternatives that could be presented, including the business as usual options i.e. the current UDP policy.

Town Centres and Shopping

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? General / Para 4.25 -4.26 – it cannot be denied that shopping is a central part of most people’s lives. Disagree. This would form an Introduction However it is suggested that the CS / DC policies could propose a vision for town centres as a overarching vision to all boroughs’ town centre of social and cultural gathering, in which shopping is just one activity. Although it is centres. Certain local centres, especially recognised that some policies (TC4, TC7-10) do focus on some of these more cultural issues, these neighbourhood centres should not have opening paragraphs would seem also a good opportunity to present a vision of town centres as the same emphasis placed on them, in social and cultural centres. terms of their social and cultural role as the larger centres such as Wembley. DP TC1 Brent Retail Suggested clarifications and amendment to supporting text: Need Allocations No comments.

Suggested clarifications and amendment to policy text: The appraisal of the Core Strategy stated the importance of development at Wembley being Agree that impact needs to be assessed. complementary to existing local and independent retailers and other town-centre services: Policy will be amended to cross refer to “There may be some danger that a strong focus on a major retail centre at Wembley could damage assessment of impact in policy CP TC2. the viability of local centres and retailers, thus undermining regeneration efforts elsewhere. It is vital that development at Wembley is complementary and not conflicting with existing local services. Major retail development is likely to attract external investment to the Borough, but equally much of the economic benefit accruing will leave the Borough, as retailers of a scale suitable for a major location are likely to be national, or multinational companies. The regenerative and local benefits may thus be limited to some low-skill employment – and the positive economic (multiplier) effects for the Borough smaller than hoped”. We would recommend therefore that policy TC1 / the supporting text states that although the focus

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? of allocations will be as set out, it is important for the council to consider the impact on independent local services in all cases to ensure such impacts are minimised.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided TC1 DP TC2 Suggested clarifications and amendment to supporting text: Neighbourhood Para 4.32 – from a sustainability perspective it is important to ensure that neighbourhood centres Agree to amend wording as follow ‘It is Centres provide as many retail and other town centre amenities as possible – for all local residents. This important to retain the function of can play a strong role in regeneration, reducing travel need and supporting a genuinely local neighbourhood centres and parades to economy. We suggest therefore that although the needs of the “disabled and less mobile” are meet the day- to- day needs of the local clearly important, neighbourhood centres are valuable for the whole community. residents. They are valuable for the local community especially for disabled Suggested clarifications and amendment to policy text: people and the less mobile.’ No comments.

DP TC3 Other Suggested clarifications and amendment to supporting text: Shopping Parades No comments. and Units Suggested clarifications and amendment to policy text: No comments.

DP TC4 Car-Boot / Suggested clarifications and amendment to supporting text: Other Recycling From a sustainability perspective the text could be strengthened by adding to the “considerations” Agree. The policy will cross refer to the Sales something like: Connecting Places policy DP TRN1 - All efforts will be made by the organiser of such activities to encourage people to travel by foot, which requires development that is likely bicycle or public transport. This could, for example, include the provision of specific information on to have significant impact on the walking and cycle routes and public transport times with any promotional materials. transport network to submit a Transport Assessment. The amended policy - Sufficient safe access must be provided to the site for pedestrians and cyclists. Sufficient, secure wording will read as ‘Proposals for cycle parking space should also be provided. regular Car-boot/ other recycling sales Another aspect that does not appear to be covered is the frequency that sales will be held – will be assessed with regard to their although this would presumably be covered by permitted development rights? However, impact on overall impact. The development will be local residents etc will be significantly effected by the frequency e.g. whether they are occasional or subjected to a Transport Assessment regular events. (see policy DP TRN1) and will not be permitted unless…..’ Suggested clarifications and amendment to policy text: 1st para - additional point could be added related to the comments above on public transport, walking and cycling and frequency. It is considered that there is no evidence showing need to remove permitted

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? development rights relating to frequency of sales. Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. Comments could See response above. TC2-4 be added to refer to the current UDP policy position, the business as usual option, and why it is not the preferred policy (assuming it has changed from the UDP to the DPD).

DP TC5 Non-Retail Suggested clarifications and amendment to supporting text: Uses No comments.

Suggested clarifications and amendment to policy text: No comments.

DP TC6 Managing Suggested clarifications and amendment to supporting text: A3, A4 and A5 Uses No comments.

Suggested clarifications and amendment to policy text: Some town centres (anecdotally) appear to have considerable over-supply of fast-food takeaway Agree. Add new criteria to give stronger restaurants (A5). One possible additional consideration could be the actual need for a specific type environmental regards to A5 uses in of use (especially A5), based on existing similar uses in the vicinity. town centres. And possibly apply a percentage of A5 proportion in town centres shopping frontage.

DP TC7 Food and Suggested clarifications and amendment to supporting text: Drink (Café) No comments. Quarters Suggested clarifications and amendment to policy text: No comments.

DP TC8 Amusement Suggested clarifications and amendment to supporting text: Centres and Mini- No comments. cab Offices Suggested clarifications and amendment to policy text: No comments.

DP TC9 Offices and Suggested clarifications and amendment to supporting text: Residential Above No comments. Shops

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Suggested clarifications and amendment to policy text: Disagree. The use of ‘Long-term vacant’ Point 2 – what is considered to be “long-term vacant” could be clarified / specified to avoid any allows flexibility. This is to avoid units ambiguity in this policy. being left vacant purposively to fulfil the ‘vacant’ criteria for change of use above shops. DP TC 10 Existing Suggested clarifications and amendment to supporting text: and New Markets No comments.

Suggested clarifications and amendment to policy text: No comments.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. Comments could Agree. Add the following to the TC5-9 be added to refer to the current UDP policy position, the business as usual option, and why it is not Alternative statement ‘It is evident in the the preferred policy (assuming it has changed from the UDP to the DPD). Town Centre Policy Performance section in the AMR that the relevant UDP policy No mention of alternatives to DP TC10. has been under used because of the minimal level of change from residential above shops to commercial uses. However, it is also important in order to promote the diversity of town centre uses by allowing commercial uses above shops using long term vacant residential units. DP TC11 Design and Suggested clarifications and amendment to supporting text: Infrastructure No comments.

Suggested clarifications and amendment to policy text: No comments.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. TC11 DP TC12 Town Suggested clarifications and amendment to supporting text: Centre Management No comments. Initiatives Suggested clarifications and amendment to policy text: No comments.

DP TC13 Neasden – Suggested clarifications and amendment to supporting text: Development

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? Opportunities No comments.

Suggested clarifications and amendment to policy text: No comments.

DP TC 14 Brent’s Suggested clarifications and amendment to supporting text: Distinctive Multi- No comments. cultural centres Suggested clarifications and amendment to policy text: No comments.

DP TC15 Willesden Suggested clarifications and amendment to supporting text: Arts Quarter No comments.

Suggested clarifications and amendment to policy text: No comments.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. Comments could TC5-9 be added to refer to the current UDP policy position, the business as usual option, and why it is not the preferred policy (assuming it has changed from the UDP to the DPD) and reasonable alternatives to the polices as included.

Culture, Leisure and Tourism

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? DP CLT1 Culture Suggested clarifications and amendment to supporting text: Whilst this suggestion is good in theory, Leisure and Tourism Para 4.41 – encouraging facilities with a “community element” is welcomed. This text could be in practice it is unrealistic. Supporting uses strengthened further perhaps by recommending / seeking to ensure that local communities are text will be strengthened to include the involved in the planning, design, location and decisions over which types of facilities may be benefit of community involvement. provided in their area. Para 4.44 – We would recommend that any “major tourist generating activities” are only sought / Major developments are encouraged in provided in areas of excellent public transport (PTAL) and walking / cycling access – otherwise they Town Centres according to the can have significant impacts on local traffic problems, especially during large / popular events. This sequential approach. Our main Town comment also applies to point v) in the policy. centres already have very good public transport. This accords to criteria iii of Para 4.45 – this point regarding recruitment, training etc could be included as one of the criteria in the policy, which states the scale and

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Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? the policy. use of the facility is appropriate to its location. Major tourist activities could Suggested clarifications and amendment to policy text: also improve PTAL to some areas. See comments on the supporting text above. Accepted.

Not needed. DP CLT2 Protection Suggested clarifications and amendment to supporting text: of Brent’s Cultural No comments. Assets Suggested clarifications and amendment to policy text: Fixed. No comments (should be policy DP CLT2 not 1).

DP CLT3 Suggested clarifications and amendment to supporting text: Archaeological Sites No comments. and Monuments Suggested clarifications and amendment to policy text: (should be policy DP CLT3 not 2).

Is it the case that it will never be appropriate / necessary to consider archaeology / undertake It would be unrealistic for every archaeological investigations etc on sites outside Sites of Archaeological Importance or in development to carry out an Archaeological Priority Areas? Should the possibility that it will be appropriate to consider currently archaeological investigation. Areas of unknown archaeology for sites outside these areas be included in the policy? Archaeological Importance and Priority areas just flag this up. Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. Comments could CLT1-3 be added to refer to the current UDP policy position, the business as usual option, and why it is not Accepted the preferred policy (assuming it has changed from the UDP to the DPD).

No alternatives to DP CLT3 are provided.

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Enabling Community Facilities

Policy Suggested changes to the policy wording, or supporting text, as a result of the SA LBB Response? General / The chapter has a useful introduction but would benefit from a summary of the purpose of the Introduction policies in this chapter and the link to the Core Strategy.

Involving the local community and key stakeholders in planning for infrastructure is important and could be reflected more in the supporting text and policies.

DP CF1 New Suggested clarifications and amendment to supporting text: Community Facilities No comments. and Extensions to Existing Suggested clarifications and amendment to policy text: 1st para – needs could arise from the cumulative impact of several small developments and this Yes, agreed. should be reflected rather than just providing for major developments.

DP CF2 Protection of Suggested clarifications and amendment to supporting text: Existing Community No comments. Facilities Suggested clarifications and amendment to policy text: No, this is not the intent of the criteria. 2nd bullet – it would strengthen this policy from a sustainability perspective to state clearly that any Suitably relocated mainly means better relocation must also be to a location with equal or better ease of access / accessibility by public provision has been made elsewhere and transport, walking and cycling for the community it serves. it better serves the community. New facilities are to be located in accessible areas, covered by policy CF1. DP C3 Developer Suggested clarifications and amendment to supporting text: Provision and No comments. Contributions Towards Community Suggested clarifications and amendment to policy text: Facilities No comments.

Alternatives to DP A reasonable summary of the justification for rejecting the alternatives is provided. Comments could Agreed C1-3 be added to refer to the current UDP policy position, the business as usual option.

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Collingwood Environmental Planning