Site Allocations DPD Statement of Representations (Pre Submission)

1. Introduction

1.1 Consultation on the Site Allocations DPD Pre-Submission consultation document took place between 27th July and 7th September 2012. Consultation was undertaken in accordance with the Council’s Statement of Community Involvement and in line with regulations of the Town and Country Planning (Local Planning) (England) Regulations 2012. These regulations require the Council to produce a statement (the 'Consultation Statement') setting out the consultation undertaken on the Site Allocations DPD at the Pre-Submission stage, a summary of the main issues raised in response to that consultation, and to detail the Council’s response to comments made.

2. Summary of consultation undertaken on the Site Allocations DPD Pre-Submission consultation document

2.1 On 20th June 2012, Harrow’s Cabinet considered a report on the Site Allocations DPD (see http://www.harrow.gov.uk/www2/documents/g61243/Public%20reports%20pack,%20Wednesday%2020-Jun- 2012%2019.30,%20Cabinet.pdf?T=10). At that meeting Cabinet recommended the DPD be referred to Full Council for approval for consultation.

2.2 On 5th July 2012, Full Council endorsed the Site Allocations DPD Pre-Submission consultation document and resolved to publish the document for consultation for a period of six weeks and, following consultation, submission to the Secretary of State for independent examination in public (see http://www.harrow.gov.uk/www2/documents/g61086/Public%20reports%20pack,%20Thursday%2005-Jul-2012%2019.30,%20Council.pdf?T=10).

2.3 Formal notification of the Site Allocations DPD Pre-Submission publication was given on 27th July 2012, and representations were invited for a six week period ending 7th September 2012. Representations were also invited on the Sustainability Appraisal during this period.

2.4 A formal notice setting out the proposals matters and representations procedure was placed in the ‘Harrow Observer’ newspaper on both the 26th July and 2nd August 2012 (see Appendix A). In addition, on 23rd July 2012, a total of 1,048 notifications (see Appendix B) were sent by post or email to all contacts on the LDF database (see Appendix C), including all appropriate general consultation bodies. Enclosed with the letter was the Statement of the Representations Procedure (see Appendix D). Those emailed were also provided with the web link to the documents on the Council’s consultation portal and LDF web pages. All specific consultation bodies (see Appendix E) were also notified (see Appendix F) on 23rd July 2012. Unless otherwise requested by the consultation body, enclosed with the notification was a hard copy of the Site Allocations DPD Pre- Submission document, the Statement of the Representations Procedure, and the Sustainability Appraisal Report. In accordance with Regulation 21 of the Town and Country Planning (Local Planning) (England) Regulations 2012, a separate letter was also sent to the Mayor of London requesting his opinion on the conformity of the DPD with the London Plan 2011 (see Appendix G).

2.5 Hard copies of the Site Allocations DPD Pre-Submission consultation document, the Sustainability Appraisal Report, the Statement of the Representations Procedure and the response form (see Appendix H) were made available at the Harrow Civic Centre (Access Harrow) and all 1 public libraries across the Borough. Additional copies of the DPD Pre-Submission consultation document were also made available at these locations for short term loan. The documents were also made available to view and download from the LDF web pages of the Council’s website and via the Council’s consultation portal. The consultation portal has the added benefit of enabling respondents to submit their representations online as they review the document.

2.6 A week prior to the close of consultation a reminder e-mail and letter were sent out to those on the LDF consultation database to remind online consultees of the closing date for making their comments.

3. Duty to Cooperate

3.1 Section 110 of the Localism Act inserts section 33A into the Planning and Compulsory Purchase Act 2004. Section 33A imposes a duty on a local planning authority to co-operate with other local planning authorities, county councils and bodies or other persons as prescribed.

3,2 The other persons prescribed are those identified in regulation 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012. The bodies prescribed under section 33A(1)(c) are:

(a) the Environment Agency; (b) the Historic Buildings and Monuments Commission for England (known as English Heritage); (c) Natural England; (d) the Mayor of London; (e) the Civil Aviation Authority; (f) the Homes and Communities Agency; (g) each Primary Care Trust (h) the Office of Rail Regulation; (i) Transport for London; (j) each Integrated Transport Authority; (k) each highway authority and (l) the Marine Management Organisation.

3.3 The duty imposed to co-operate requires each person, including a local planning authority, to:

(a) engage constructively, actively and on an ongoing basis in any process by means of which activities within subsection (3) are undertaken, and (b) have regard to activities of the persons or bodies (above) so far as they are relevant to activities within subsection (3).

3.4 The relevant activities listed under subsection (3) comprises the preparation of development plan documents/local development documents, and activities which prepare the way for and which support the preparation of development plan documents, so far as relating to a strategic matter. 2

3.5 The Council has and continues to engage constructively with other local planning authorities and other public bodies on the preparation of the DPD, following the approach set out in the NPPF. The mechanisms for and evidence of cooperation and engagement is set out below.

Duty to Cooperate – Engagement Undertaken

Cross Boundary Consultee How we Cooperated Outcomes Neighbouring authorities (see Letters sent inviting representations on the DPD at both Details of representations received and the Council’s map 1) stages of preparation and responses received. actions as a result are detailed above (See Consultation Statement above) No major cross boundary issues identified.

West London Alliance (planning officers group from 6 Updates given by respective Borough’s on Local Plan West London Borough’s). progress and any cross boundary issues raised. Group memorandum of understanding. Memorandum of Understanding signed to give effect to cross boundary cooperation.

Meetings to progress the London – Luton growth corridor which will result in a joined up approach to managing London – Luton Corridor Forum and attracting growth in this area. No major cross boundary issues identified arising from this DPD.

Planning Officer meetings with Hertsmere Meetings last held in June / July 2012 and are scheduled for every quarter. Planning Officer Meetings with Three Rivers

Environment Agency Letters inviting representations on the DPD and Details of representations received and the Council’s responses received. actions as a result are detailed above. Issues raised (See Consultation Statement below) regarding policies dealing with flood risk and management, and river corridors (see above for details)

Meetings centred around the Level 1 and Level 2 SFRA Meetings at Council offices (5 in total) extents. Advice given on the wording of flooding policy and the use of SUDS.

Resolved to remove 3b designation from previously

3 developed sites.

EA provide flood mapping for the Borough. English heritage Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD)

Written communications between the Council and Advice on Heritage and Conservation policies given English heritage Heritage policies amended in light of specialist advice Draft copies of heritage policies sent before formal consultation Natural England Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD)

Written communications between the Council and Advice on biodiversity policies given Natural England

Civil Aviation Authority Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. No major issues (See Consultation Statements for each DPD) raised.

Greater London Authority Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD)

Officer from the GLA on secondment to the Local Plan Officer providing advice on policy development to ensure Team there are no conflicts with the strategic London Plan

Participation in the London wide SHLAA and SHMA GLA Housing Study meetings and work evidence base studies.

Discussions held and advice sent to ensure consistency Liason with specialist officers for policy development with the London Plan. regarding affordable housing and sustainability

London Wide Green Grid project Meetings and joint working undertaken to establish a Harrow Green Grid as part of the wider London Green Grid. 4

Primary Care Trust Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD)

Infrastructure Delivery meetings and correspondence Consulted on evidence base documents, and provided information to inform future service delivery Highways Agency (TFL) Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. (See Consultation Statements for each DPD)

Liason with TFL regarding transport study modelling and Agreed the methodology for modelling certain junctions, findings and the results of the findings of the study, using TFL data.

Infrastructure Delivery meetings and correspondence Consulted on evidence base documents, and provided information to inform future infrastructure provision Network Rail Letters inviting representations on all Development Plan Details of representations received and the Council’s Documents and responses received. actions as a result are detailed above. No major issues (See Consultation Statements for each DPD) raised.

4. Who responded and number of representations received

4.1 There were 45 representations received to the Site Allocations DPD Pre-Submission consultation. These came from statutory or neighbouring local planning authorities (6), developers and agents (9), amenity and interest groups (3), site owners (3), residents and individuals (21), local councillors (2) and a petition (53 signatories). Appendix I provides a full list of the respondents. In total, 115 individual comments were made that were considered and responded to by the Council (see Appendix J).

5. Summary of the main issues/comments raised to the Site Allocations DPD Pre-Submission consultation

5.1 Regulation 22(1)(c)(v) requires a summary of the main issues raised in representations made to the pre-submission DPD. Pursuant to this requirement, the following paragraphs set out the main issues raised in respect of each chapter of the pre-submission Site Allocations DPD.

General

5 5.2 Officers of the Greater London Authority (GLA) advised that the Mayor of London is content that the Pre-Submission DPD is in general conformity with the London Plan (2011). A number of specific representations were made by the GLA on matters of clarity and detail and these have been considered and wherever possible addressed as proposed minor modifications.

5.3 Thames Water advised that, due to limited information on the size of proposed development and complexities of sewerage networks, it is unable to determine infrastructure needs at this stage. The Council considers that Core Strategy Policy CS1 Z adequately deals with infrastructure matters to enable up-to-date requirements (and available capacity) to be assessed for each site and for all types of infrastructure, not just waste water. However, to assist those bringing sites forward, a minor modification to the Development Management Policies DPD is proposed to identify those sites where Thames Water has concerns.

5.4 As a general comment pertaining to all sites contained within the DPD, English Heritage sought modifications to annotate heritage assets on site maps, to summarise the significance of heritage assets affected and to highlight the opportunity for s.106 funding to enhance the historic environment. Relevant heritage assets (and their status e.g. grade I, grade II, etc) are identified in the text of the allocated sites, but in response to this representation some existing references are proposed to be clarified, and details of locally listed heritage assets added, as minor modifications to the DPD. However requirements for s.106 funding can be determined under the policies of other DPDs and so no modifications are proposed in this regard.

5.5 In addition, English Heritage wished the DPD to identify those sites that may be suitable for tall buildings and those that are not. No modifications are proposed by the Council in response to this, as sites outside of the Intensification Area have not been individually assessed for their suitability or unsuitability for tall buildings and the policies of the London Plan and of the Development Management Policies DPD provide an adequate framework for assessing ‘windfall’ tall building proposals.

Chapter 1: Introduction

5.6 In response to a request for clarification by the GLA additional text to the introductory chapter, to make reference to the role of the joint West London Waste DPD, is proposed as a minor modification to the DPD.

Chapter 2: Retail

5.7 Representations questioned the capacity of allocated sites and pipeline supply to deliver projected requirements for new retail floorspace, and raised issues with the deliverability of some of the retail-led development sites either because of flood risk, other site specific constraints, multiple ownerships or existing uses/development on the sites. In response it is proposed to amend the introductory text to this chapter, to correct and clarify the pipeline supply of floorspace, as a minor modification. A more detailed note on the floorspace projections and how the provisions of all three DPDs address identified need, is included at the end of this consultation statement. However it is not considered that the site specific planning constraints render the allocated sites as undeliverable for retail development.

6 5.8 The Environment Agency made representations against Site R3 on the basis that it falls within flood zone 3b. However in subsequent dialogue with the Agency it has been agreed that previously-developed sites within land identified on flood maps as functional floodplain can be treated as zone 3a.

5.9 One representation seeks to promote an out of town retail park for retail development. However the NPPF does not allow for the allocation of out of centre sites, and the Development Management Policies DPD already provides criteria for the consideration of out of centre development proposals.

5.10 Representations were received concerned with the identification of Site R4 for development. In response, and following dialogue with representatives from the site, it is proposed to relocate the allocation to chapter 8 of the document (with corresponding changes to the emphasis of the site’s allocation and the commentary) as a minor modification.

Chapter 3: Economic Development and Employment

5.11 The main issues made in respect of this chapter were on behalf of site owners seeking to modify allocations to allow wholly/mainly residential redevelopment. In each case the allocations give effect to provisions in the Core Strategy for employment led, mixed use redevelopment to contribute to economic diversification and the target to deliver 4,000 new jobs over the plan period. However the Council proposed a revision to the commentary of Site EM2, to allow for phased development, as a minor modification to the DPD.

5.12 One respondent raised concern about the loss of employment capacity. As noted above, the allocations in this chapter are for employment-led mixed use proposals to secure economic diversification and create new employment opportunities.

Chapter 4: Housing

5.13 Representations made by or on behalf of the owners of two allocations in this chapter indicated that the sites are not available for development. Consequently it is proposed to remove Sites H2 and H22 as a minor modification to the DPD. One sought the designation of the site for employment use, but there is no evidence included within Harrow’s Employment Land Study to support this.

5.14 Representations were received on a number of sites concerning the need to take account of the biodiversity value of adjoining land. As a result it is proposed to modify the commentary to Sites H13, H14 H16 and H21 to highlight the need for sensitive design and layout in relation to neighbouring designated nature conservation sites.

5.15 Detailed representations were made by a land owner in respect of the number of homes attributed to Sites H13 and H14. In both instances there are site specific issues (comprehensive development necessitating consideration of loss of office floorspace in respect of H13; and the relationship between the re-provision of car parking and the number of homes in respect of H14). For consistency with the rest of the document, the

7 housing capacity of sites is an indicative minimum based upon either a planning permission/advanced pre-application scheme, or otherwise based on the London Plan density matrix in accordance with the methodology set out in Appendix B of the DPD.

5.16 One respondent questioned the inclusion of Site H18, citing issues of congestion and loss of open space. However this site already has planning permission, these matters having been considered and found acceptable through the planning application process.

5.17 Loss of station car park at Sites H9, H14 and H21 was also raised in representations. However it is noted that the commentary for these sites already requires the redevelopment to make provision for adequate replacement station car parking as informed by evidence to be submitted with application proposals.

Chapter 5: Strategic Previously Developed Sites in the Green Belt

5.18 As with the housing chapter, representations were received about the biodiversity value of sites. Revisions to the commentary text of sites that already have planning permission, to require re-assessment of biodiversity impacts in the event of substantive changes to the approved schemes, are proposed as minor modifications to the DPD.

5.18 Site owners made representations regarding the details of their allocations. In response it is proposed to extend the site boundary of Site GB2 as a minor modification to the DPD, to reflect the current extent of ownership, but to maintain the indicative residential capacity of the site published in the DPD which reflects the approved scheme. It is also proposed to remove the indicative residential capacity of Site GB3, and to focus the allocation upon education and associated uses, as a minor modification to the DPD.

Chapter 6: Open Spaces

5.19 Representations were received casting doubt on the suitability and deliverability of Site MOS2 as a nature reserve. It is therefore proposed to omit this site as a minor modification to the DPD.

5.20 Some respondents questioned the need for additional publicly accessible natural/semi-natural open space sites in the Green Belt, and raised concerns about details such as the security of neighbouring property, the impact of public access upon biodiversity value and ownership issues. In response it is proposed to revise the commentary text, to highlight the need for an up to date assessment of sites’ biodiversity value and the implications of public access (and the possible need for a management plan), as minor modifications to the DPD. In addition and in response to ownership issues it is also proposed to modify the commentary text of Site MOS4, and to amend the boundary of Site MOS5, as a minor modification to the DPD.

5.21 Representations were received promoting additional minor open space designations. However these are not supported by the PPG 17 Study review of amenity greenspaces in the Borough.

8 Chapter 7: Biodiversity

5.22 There was only one representation made in connection with this chapter, supporting the protection of biodiversity.

Chapter 8: Other

5.23 Representations were concerned with the loss of (some) open space to development at Site G03. However the allocation reflects the planning history for the site and a consequent, recent planning permission where this issue was considered and resolved by making the remaining open space publicly accessible.

5.24 One representation raised concern about the destabilisation of existing community relations by the increased provision for Gypsies and Travellers at site G05. However the allocation is intended to meet the Borough’s need for additional pitches over the plan period and there is no evidence to substantiate the concern that the relationship between the settled and traveller communities in the area would be adversely affected.

5.25 Some respondents questioned the need to create a publicly accessible park at Site G06 and raised concerns over potential impacts such as parking, traffic, privacy, amenity and security. It is proposed to revise the commentary text, to allow greater flexibility over the typologies of open space and to highlight the need for a sensitive relationship between new development on the site and surrounding dwellings, as a minor modification to the DPD. Other impacts will be addressed through the planning application process. In response to a representation on behalf of the site owner it is also proposed to correct the indicative housing capacity of Site G06 as a minor modification.

5.26 One representation made reference to detailed heritage comments submitted as part of pre-application proposals for Site G06. However these are detailed matters to be resolved through the planning application process.

Sustainability Appraisal

5.27 One representation was received concerning the Sustainability Appraisal of the pre-submission DPD, seeking the mapping of heritage assets (and their significance) affecting each allocation. However this is not considered necessary; the Appraisal as published provides a robust basis for assessing the impact of the DPD on heritage assets.

Consequential Changes

5.28 It should be noted that the proposed minor modifications arising from the representations necessitaes consequential changes to some parts of the DPD, such as the summary tables at the end of Chapters 2 & 3 and the housing schedule at Appendix A of the DPD. Where these are necessary they are published in the table of proposed minor modifications to the DPD.

10 Appendix A – Notice placed in the ‘Harrow Observer’ newspaper on both the 26th July and 2nd August 2012

11 Appendix B – Notification Letter sent to all Consultees on the Council’s LDF Consultation Database

12 Appendix C – List of contact on the Council’s LDF Consultation Database

Moderation Dron & Wright Property Consultants London Waste Regulatory Authority Home Office London Fire & Emergency Planning Authority A2 Dominion Fields in Trust (FIT) London Green Belt Council London Wildlife Trust Nursing Services London Middx Archaeological Society Age Concern Harrow Metropolitan Public Gardens Association London Natural History Society C/o British Museum Planning Advisory Service (Natural History) Office of Government Commerce Edgware & Burnt Oak Chamber of Commerce Martineau UK Police Architectural Liaison Officers/Crime Farmers Union Commission for Architecture and the Build Prevention Design Advisors Environment(CABE) London Borough of Brent Forestry Commission East England Conservancy National Federation, Gypsy Liaison Group Department for Culture Media & Sport London Tourist Board Acton Housing Association Department for Education and Skills Hertfordshire County Council Home Group Harrow Health Authority Hertsmere Borough Council Catalyst Communities Housing Group Elstree and Borehamwood Town Council Westminster City Council West London YMCA Elstree District Green Belt Society Royal Mail Letters Planning & Legislation Unit Metropolitan Police Department for Environment, Food and Rural Affairs The Society for the Protection of Ancient Buildings Ealing Council Department of Constitutional Affairs Department for Business, Enterprise and Regulatory Reform (BERR) Barnet Council Department of Works and Pensions (DWP) The House Builders Federation Three Rivers District Council Department for Business, Enterprise & Regulatory Sport England Reform Harrow East Constituency Conservative Party London Borough of Camden Sport England (Greater London Region) Assembly Member for Brent & Harrow & LDF Panel Member Council for the Protection of Rural England(Harrow) Watford Borough Council Gareth Thomas MP for West Harrow Council for British Archaeology Watford Rural Parish Council Bob Blackman MP for East Harrow Mark Dowse (Crime Prevention) Health & Safety Executive Harrow Churches Housing Association Vodafone LTD Health Services Board Circle Anglia Transport for London Nature Conservancy Council Family Mosaic Housing Transport for London Strategy Group Network Rail Chiltern Hundreds Charitable Housing Association Ltd London Borough of Haringey Great Minster House Dimensions (UK) Limited London Borough of Hillingdon Group Property and Facilities Jewish Community Housing Association Brent & Harrow Chamber of Commerce Property Services Agency John Grooms Housing Association BAA Aerodrome Safeguarding Rail Freight Group Home Group Limited The Civic Trust Road Haulage Association Genesis Housing Group (PCHA Maintenance) 13 Civil Aviation Authority Safety Regulation Group Iceni Projects Pathmeads Housing Association Ltd London Borough of Hounslow GLA Biodiversity Group Strategy Directorate Genesis Housing Group London Councils London Underground Home Group (Regional Development Director) London Development Agency Harrow Hill Chamber of Commerce Dimensions (UK) Limited Harrow and Hillingdon Geological Society London Underground Limited Infrastructure Housing 21 Protection Shepherds Bush Housing Association Limited Drivers Jonas Warren House Estate Residents Association Paddington Churches Housing Association Ltd RPS Group Plc Worple Residents Association Paradigm Housing Association Pro Vision Plann & Design Augustine Area Residents and Tenants Association Housing Corporation DPDS Consulting Group Roxbourne Action Group (RAG) Chiltern Hundreds Housing Association (Paradigm Dalton Warner Davis Aylwards Estate Residents' Association Housing Group) Shepherds Bush Housing Association Limited Oxalis Planning Canning Road Residents Association Stanmore Christian Housing Association Limited Andrew Martin Associates Cannons Community Association Peabody Trust Barton Willmore Canons Park Estate Association The Abbeyfield Harrow Society Limited WS Planning Canons Park Residents Association The Guinness Trust PB Alexandra Avenue(Newton Farm) Tenant's Association Innisfree Housing Association Turley Associates Barrowdene Residents Association Sutherland Housing Association Limited GL Hearn Property Consultants Belmont Community Association Inquilab Housing Association Limited The London Planning Practice Arrowhead Parade Tenants & Residents Association Haig Homes Halcrow Group Bentley Priory Residents Association Anchor Trust Urban Initiatives Bentley Way Association Apna Ghar Housing Association Limited Brown Associates Blenheim Road Action Group Network Housing Group Strategic Leisure Brookshill Residents Association Origin Group Capita Symonds Afganstan Housing Association Home Builders Federation Knight, Kavanagh & Page Cherry Croft Residents Association CB Richard Ellis MWH Global Chichester Court Association Nathaniel Lichfield and Partners Gregory Gray Associates Claire Court, Elm Hatch, Cherry Croft Residents Association URS Corporation Ltd First Plan Claire Gardens Residents Association WYG Planning & Design Daniel Rinsler & Co Colman Court Residents Association Tribal Yurky Cross Architects Copley Residents Association Tym & Partners Jones Lang LaSalle Waxwell Close Association UK Planning Manager Wealdstone Residents Action Group CGMS Consulting Dandara Ltd Wemborough Residents Association DP9 Town Planning Consultants Saunders Architects LLP West Harrow Residents Association 14 MEPK Architects Savills Corbins Lane Residents Assoc. Metropolis PD Alsop Verrill Cottesmore Tenants & Residents Association Octavia Housing Colliers CRE Crown Sreet & West Sreet Area Residents Association Metropolitan Housing Trust Limited CB Richard Ellis Ltd Cullington Close Tenants Association Notting Hill Housing Trust Berkeley Homes Dalkeith Grove Residents Association Housing 21 Cluttons LLP Daneglen Court Residents Assoc Stadium Housing Association Limited DTZ East End Way Residents Association Servite Houses Elm Park Residents' Association Edgware Ratepayers Association LHA-ASRA Group Wilton Place Residents Association Elizabeth Gardens Tenants Association Veldene Way Residents Association Rayners Lane Tenants & Residents Association Roxbourn Action Group (RAG) Victoria Terrace Residents Association South Harrow & Roxeth Residents Association Kenton Forum Elmwood Area Residents' Association The Clonard Way Association Winton Gardens Residents Association Elstree Village Association The Cresent Residents Association Wolverton Road Tenants Association Gayton Residents Association South Hill Estates Residents Association Cambridge Road Residents Association Harrow Weald North Residents Association South Hill Residents Association Brockley Hill Residents Association Harrow Weald Tenants and Residents Association South Stanmore Tenants & Residents Association Aerodrome Householders Association Thurlby Close Residents Association Lodge Close Tenants Association Woodcroft Residents Association Tyrell Close Tenants Association Pinnerwood Park Estate Residents Association Woodlands Community Association Gleneagles Tenants Association Merryfield Court Residents Association Woodlands Owner Occupiers Golf Course Estate Association Pinner Road & The Gardens Residents Association Roxeth First & Middle School Atherton Place Tenants' Association Pinnerwood Park C.A. Residents Association Pinner & District Community Association South Hill Estates Harrow Ltd Manor Park Residents Association Raghuvanshi Chartiable Trust Herga Court Residents Association Letchford Terrace Residents Association Eastcote Conservation Panel Gordon Avenue Residents Association Laburnum Court Residents Association Post Office Property Holdings Hobart Place Residents Association Laing Estates Residents Association Stanmore Golf Club Grange Farm Residents Association Hardwick Close Flats Association Stanmore Society Greenhill Manor Residents Association Harrow Civic Residents Association St Anselm's RC Primary School Greenhill Residents Association Oak Lodge Close Residents Association Sheepcote Road Harrow Management Company Ltd Greville Court Residents Association Harrow Federation of Tenants & Residents Iraqi Community Association Associations Grove Tenants & Residents Association Pinner Green Council Tenants Association Jehovah's Witnesses Hardwick Court Maisonettes Association Pinner Hill Residents Association John Lyon School Jubilee Close & James Bedford CIose Residents Pinner Hill Tenants & Residents Association Roxeth Mead School Association Kenmore Park Tenants and Residents Association Nicola Close Residents Association Royal Association in Aid of Deaf People

15 Kenton Area Residents Association Orchard Court Residents Association Royal National Institute For The Deaf Honeybun Tenants Association South West Stanmore Community Association Kenton Lane Action Group Sonia Court Residents Association Princes Drive Resident Association Kerry Court Residents Greensward Properties Ltd Rowlands Avenue Residents Association Priory Drive Residents Association Grimsdyke Golf Club Roxborough Park Residents Association Sheridan Place Residents Association Stanmore Chamber of Trade Roxborough Residents Assoc. Northwick Manor Residents' Association Herts & Middx Wildlife Trust Roxborough Road Residents Association Nugents Park Res Association Tempsford Court Management Company Ltd Rusper Close Residents Association Mount Park Residents Association Wembley Rugby Club Queensbury Circle Tenants Association Harrow Hill Residents Association English Golf Union The Pinner Association Hatch End Association Harrow Heritage Trust The Pynnacles Close Residents Association The Waxwell Close Association St Mary's Church Sudbury Court Residents Association Hathaway Close Residents Association Harrow High Street Association Eastcote Village Residents Association Abchurch Residents Association Friends of Bentley Priory National Reserve Rama Court Residents Association Hazeldene Drive Tenants & Residents Association Harrow in Leaf Harrow Heritage Trust, Harrow Museum & Heritage Harrow Dental Centre Kenton Bridge Medical Centre Centre The London Playing Fields Society Abbey Dental Practice Kenton Clinic The National Trust West Middlesex Centre B Cohen Dental Practice Mollison Way Medical Centre The Ramblers Association - North West London Bridge Dental Practice Pinner View Medical Centre Group Harrow Natural History Society Bright Dental Practice Preston Road Surgery Harrow Nature Conservation Forum DentiCare Primary Care Medical Centre Harrow Partnership for Older People (P.O.P) Dr K A Nathan Dental Practice Roxbourne Medical Centre Friends of the Earth - Harrow & Brent Group Dr Tikam Dental Surgery Savita Medical Centre (1) Hatch End Cricket Club Family Dental Care Savita Medical Centre (2) Estates Bursar Harrow School G Bhuva & J Bhuva Dental Practice Shaftesbury Medical Centre Bursar, Harrow School Harrow View Dental Surgery St. Peter's Medical Centre Orley Farm School Harrow Weald Dental Practice Stanmore Medical Centre The Twentieth Century Society M Ali Dental Practice The Circle Practice The Victorian Society N Bahra Dental Practice The Elmcroft Surgery Harrow Association for Disability S Aurora Dental Practice The Enterprise Practice Harrow Association of Voluntary Service Village Surgery The Harrow Access Unit Harrow Athletics Club Preston Medical Centre The Medical Centre Dove Park Management Co Streatfield Surgery The Northwick Surgery West Harrow Action Committee GP Direct Medical Centre The Pinner Road Surgery Wealdstone Active Community Pinn Medical Centre Uxendon Crescent Surgery

16 Clementine Churchill Hospital Simpson House Medical Centre Wasu Medical Centre Harrow Healthy Living Centre Enderley Road Medical Centre Harrow Public Transport Users Association Hatch End Swimming Pool Elliot Hall Medical Centre Harrow Weald Common Conservators Whitmore Sports Centre Aspri Medical Centre Zain Medical Centre Christ Church Bacon Lane Surgery Alexandra Avenue Health & Social Care Centre Cygnet Hospital Clinic Blackwell House Surgery Belmont Health Centre Flash Musicals Chandos Surgery Brent & Harrow Consultation Centre Pinner Wood Children's Centre Charlton Medical Centre Honeypot Lane Centre Gange Children's Centre Civic Medical Centre Kenmore Clinic The Garden History Society Dr. Eddington & Partners (1) North Harrow Community Centre The Georgian Group Dr. Gould & Partners Pinner West End Lawn Tennis Club Harrow College (Harrow Weald Campus) Dr. Merali & Partners (1) Pinner Youth & Community Centre Stanmore Park Children's Centre Dukes Medical Centre Brady-Maccabi Youth & Community Centre Whitefriars Children's Centre Fryent Way Surgery Grant Road Youth & Community Centre Chando's Children's Centre Hatch End Medical Centre Henry Jackson Centre Grange Children's Centre Headstone Lane Medical Centre Lawn Tennis Association Kenmore Park Children's Centre Headstone Road Surgery Irish Traveller Movement in Britain D Barnett Dental Practice Honeypot Medical Centre Habinteg Housing Association Greater London Action on Disability Stimpsons Sean Simara Regard Mr David Cobb Mike Root Age Concern London Pegley D'Arcy Architecture Mr Julian Maw Centre for Accessible Environments John Phillips Harrow Agenda 21 Waste & Recycling Group Royal Institute of British Architects NVSM Ltd Harrow and Hillingdon Geological Society Commission for Architecture and the Built Environment Roger Hammond Eileen Kinnear Harrow Association of Disabled People Preston Bennett Holdings Ltd A J Ferryman & Associates JMU Access Partnerships Studio V Architects Anthony J Blyth JRF London Office Stephen Wax Associates Ltd ADA Architecture United Kingdom Institute for Inclusive Design W J McLeod Architect C & S Associates HoDiS J G Prideaux C H Mckenzie Litchurch Plaza Steene Associates (Architects) Ltd PSD Architects Shopmobility Stanmore Colllege David R Yeaman & Associates Disabled Foundation Racal Acoustics Ltd Donald Shearer Architects Harrow Crossroads Lloyds TSB D S Worthington Harrow Mencap The White Horse PH Eley & Associates Mind in Harrow Curry Popeck Solicitors G E Pottle & Co 17 Community Link Up Inclusion Project Allan Howard & Co Estate Agent Geoffrey T Dunnell Royal National Institute for Blind People Miss K Mehta Jackson Arch & Surveying Royal National Institute for the Deaf Mrs Dedhar H Patel People First Mr Jay Lukha J Driver Associates Disability Awareness in Action Mr Patel John Hazell National Centre for Independent Living Mr Lodhi James Rush Associates Headmaster, Harrow School Mr James Palmer Kenneth W Reed & Associates Our Lady & St Thomas of Canterbury Mr Harshan Naren Hathi Pinner Hill Golf Club Mr Sam Fongho Lawrence-Vacher Partnership Pinner Historical Society Mr A Ahiya Robin Bretherick Associates Northwood & Pinner Chamber of Trade G Lines Ms Pauline Barr Patel Architects Ltd Peterborough and St Margarets High School for Girls Apollonia Restaurant PCKO Architects Pinner Local History Society Mr Harsham Pearson Associates Pinner Local History Society Mr Mark Roche Pindoria Associates David Kann Associates Ms Cacey Abaraonye Richard Sneesby Architects Aubrey Technical Services Mr R Shah Mr P Varsani Mr M Solanki Mr Terry Glynn Satish Vekaria Mr A Modhwadia Nugents Park Residents Association S S & Partners Mr S Freeman Linda Robinson Survey Design (Harrow) Ltd RKA Architecture Roxborough Road Residents Association V J McAndrew Madhu Chippa Associates Bryan Cozens Nafis Architecture Mr J Benaim Merryfield Gardens Residents N M Architects Orchard Associates John Richards & Co Mr Ian Murphy KDB Building Designs Mr Cunliffe Gibbs Gillespie Estate Agent Jeremy Peter Associates LRHEquipment Hire Mr AbdulNoor JC Decaux UK Ltd Mr H Patel Mr B Nieto Dennis Granston Le Petit Pain Ms Jean Altman K Handa Mrs Jacqueline Farmer Mr Murray Gillett Macleod Partnership Mr Rashmin Sheth Mrs Tsang D Joyner R Raichura Paige & Petrook Estate Agent S Mistry Pharaoh Associates Ltd Mr G Trow Saloria Architects Mr Paul Bawden Mr Parekh Simpson McHugh Mr Kumar Mrs Walker Jeffrey Carr Mr Deva Mr Abood KDA Designs Mrs Jill Milbourne Mr Sanders Mr Gow Mr Yousif Mr Tom Johnstone 18 Home Plans Ms Michelle Haeems Mr Daniel Petran KCP Designs Mrs Mandy Hoellersberger Marchill Management Ltd John Evans Mr George Apedakih Mr Milan Vithlani Sureplan Mr H Khan Miss Wozniak J Loftus Mr John Fitzpatrick Ms Erika Swierczewski V Sisodia Mr and Mrs Siddiqi Mr Anat Anthony Byrne Associates Mr Shah Mr Patel Top Flight Loft Conversions Mr Goreeba Mr T Karuna S Vekaria Ms Anna Biszczanik Hair 2 Order A Frame Bhojani, Bhojani Properties Ltd Mr John Imade David Barnard Mr Damian Buckley I Muthucumarasamy Inthusekaran A Laight Mr Asury Ms Marli Suren B Dyer Mrs Trivedi Mr M Meke Sheeley & Associates Mr Mark Fernandes Team 2 Telecommunications Ltd Michael Hardman Mr M Selvaratnam Mr Sadiq Canopy Planning Services Miss Da Cruz Mr Gilani E Hannigan Mr Mohammed Hyder Mr D Burton Plans 4 U Mr P Allam Foxon Property P Wells Mr Kevin Conlon Mr Reidman Mr Sood Mr Shah Mr Dillon Thomas O'Brien Mr Morshed Talukdar Mr E Campbell Wyndham & Clarke Ms Orci Doctor A Savani Bovis Lend Lease Mr Oliver Reeves Doctor Samantha Perera Fairview New Home Ltd Mr Michael Moran Ms Mc Gleen Mr Suresh Varsani Mr SA Syed Mr Shemsi Maliqi Rouge Property Limited Mr Argarwal Mr Delroy Ettienne Mr S Pervez C/O Mr T Mahmood Mr R David Mrs Gohil The Castle PH Ms Lorraine Wyatt Ms Yvonne Afendakis Grimsdyke Hotel Mr Vishnukumar Miss M Lean Irene Wears P J Quilter Mr Z Hansraj V A Furby Mrs M Moladina Mr Raja Kingsfield Arms PH Mrs Gill Ms Grace Ellis Mr & Mrs Deller Mr Pandya Doctor Amin Raj Shah Lrh Equipment Hire Mr Noel Sheil Stephen Hassler MR Bharat Gorasia Mr Shah Mr Barry MR Imran Yousof Mr Singh 19 Richard Maylan Miss Wozniak Mrs Cirillo Mr Bhupat Patel Mr Gunasekera Mr Gary Marston Mr Kirit Dholakia Mrs B Murray Mrs Lilley Mr Samit Vadgama Mr R C Patel Mr Michael Foti Mr Rasite Mr Bernard Marimo Helen Stokes Mr Xioutas Mrs Patel Mrs S Narayan Mr B S Bhasin CCRE Touchstone Ltd Mr Depaie Desai Mr W Ali Ms Rena Patel Mr D Morgan MR Z Patel Mr M Patel Mrs K V Hirani Mrs Shah Mr Amory & Glass Mr Christopher Dixon Mr Kishore Tank Mr V Barot Mr and Mrs Patel Mr M Khan Mrs Patten Mrs M Patel Mr Manesh Ms Samia Mr P Mantle Mrs Vad Mr Anil Mavadia Mrs D Nagewadia Ms Patricia Simpson Mrs Winnie Potter Mrs R J Choudhry Mr Liu Mrs P Naring Mr David Michaelson Mr V Pansuria University of Westminster Mr Yaqub Mr A Patel Mr Peter Bennet Mr Wolf Ms Rena Khan Parkfield Estates Mr Fabrizio Pisu Dr A Savani Mr Dipack Patel Mrs Ram Pk Properties Estate Agent Mr Jaymesh Patel Mrs Patel Mr John Knight Mrs Rabbie Mr Dattani Miss Patricia Long Mr Ahmed MRs Naring Mr M Mccarrall Colin Dean Estate Agents Mr R Harrison Mr Oliver Abbey Mrs Changela MRs Neetal Khakhria Mrs Lipton Citywest Properties Ltd Mrs Bhudia Mr Akhtar In Residence Estates Mr Hussain Mr Andrew Lemar Mr K Patel Mr Vivek Marwaha Zoom the Loom Ltd Philip Shaw Estate Agent Mr Pedro Vas Miss Mepani Mr A Patel Hanover Shine Estate Agent Mr Ali Mr Hiren Hirani Mrs Hirani Mrs Shah AKA Mr C Karaiskos Mr G Vitarana Mrs Scantle Bury High Lawns Hostel Mr Ashwan Shah Ms Mitual Shah Mr Patel Mr Simon Bull Mr Sideras Ms Mullins Ms Hema Ganesh Mr Wright Miss Innis Davis, 20 Mr S Nathan Mrs Ahmed Mr Sanjay Patel Mrs Senanayake Mrs Anastasia Marshall Skippers Fish & Chips Ventra Management Ltd Mr V Sorocovich MPS Architects Mssr H Carolan Dr Vara Mr Lavin Vantage Property Services Hinton & Bloxham Estate Agent Mr Stephenson Mallon Rawlinson Gold Estate Agent Raka Properties & Lets Ltd Mr Pravin Bhudia Mr R Shah Mrs Liza Mrs Sandra Jenkins Mr J Meegama Mr Prajesh Soneji Mr P Nathan Mr C Patel Mr Shah Cumberland Hotel Mr N Shah Mrs Amanda Fogarty MR Pulford Mr Alpesh Patel The Rollands Phelps Tisser and Aromatherapist Mrs Deroy Cameron & Associates Mr R Dutt Mrs H Pereira PK Properties Estate Agent Mr Lanagan Ms Alison Wood Mrs Ved Mrs Garner David Conway & Co Estate Agent Mrs N Hindocha Ms J Sanagasegaran Mr Sandu & H Singh Mr Richards Mr Mohamed Ariff Mr R Jani Mr Jeff Panesar Mrs Elliot Mr Dar Mr M Haq Mr N Radia Bathrooms/Kitchens/Conservatories Mr Sidhu Mrs S Akhtar Mr Black Playfield Management MR Taylor D Shemie SPLA Castle Estates Mr A Kidwai Middlesex Properties Mr Sturrock MR Farhan Ebrahimjee Mr M Fazio Mr Mathew Hutchinson Camerons Jones Quainton Hall School Mr Bhupinder Singh Mr D Saran Mr Goodman MRs J Ahilan Mr A Maragh Mr A Hanefey Ms F Bajina Mr M Mockler Mr Kahn Anscombe & Ringland Est Agent Mr Bellank Mr Jonjan Kamal Mr NG Lakhani J B Webber Chemist Luigi Hairdresser Mr Campbell Mr B Patel Ms Lindsey Simpson, Mrs R Draycott Panstar Group Ltd Mr David Benson Stephen J Woodward Ltd Stephen J Woodward Ltd Mr D'Souza Mr G Trow Mr Hedvit Anderson Mr Arshad Minhas Burgoyne Johnston Evans Mrs Senanayake Dr P Sadrani Wilson Hawkins & Co Mr Mitesh Vekaria Mr Eric Lipede Mr N Patel Mr S Sharma Mrs McKenzie Mr Antonio Branca 21 Mr Jiten Soni Mr C Mohotti Mr Brijesh Mistry Doctor A Savani Mr Dalius Mr Sanjay Naran Mrs Uzma Awam Miss M Patel Mr Mohamed Agwah Mrs Nishma Palasuntheram Mr K Nava Mr Ramzan Farooqi Mr Mahmood Sheikh Mrs Trivedi Mr A Jaroudi Mr Brian Watson Mr MH Asaria Mrs Jacqueline Pepper Mr K Weerasinghe Mr N Johnstone Mr Patrick Curran Ms Vanisha Patel Miss F Khan Mrs Jacqueline Pepper Mr Vyas Mr A Balasusriya Mr Saleem Mr A Clifford Mr John Campbell Mr William Hunter Mrs Shelagh Kempster Mr P Lewis Mrs Q Chow Blue Ocean Property Consultant Miss Shah Mr Khan Mrs Roth Mrs Regunathan Mr Dene Burton Mr Kevin Conlon Mr Dattani Mr Deva Mr Ramchurn Mr Brian Lampard Mr B Desai Mr K Jabbari Mr Ralph Jean-Jacques Miss J Parker Mr McCormack Mr Rupesh Valji Mr R Carnegie Mrs Kettles Chase Macmillan Estate Agents Mr James Kearney Mr Rulamaalam Asokan Mrs O'Sullivan Mr A Ahmed Mr Alexis Mrs D Ahmed Mr G Puvanagopan Mr Raymond Mr Dene Burton Mr Patrick Curran

22 Appendix D – Statement of Representation Procedure

23 Appendix E – List of Specific Consultation Bodies

Greater London Authority English Heritage (London Region) The Coal Authority Environment Agency The Historic Buildings & Monuments Commission for England Natural England, London & South East Region Natural England, London & South East Region London Midland Harrow Primary Care Trust Defence Infrastructure Organsisation British Gas PLC Group EDF Energy Thames Water Utilities Ltd Thames Water Property Veolia Water Central Homes and Communities Agency - London Planning Inspectorate Communities and Local Government Entec on behalf of National Gird

24 Appendix F – Notification Letter sent to Specific Consultation Bodies

25 Appendix G – Letter to the Mayor of London

26 Appendix H – Response Form

28 Appendix J: Respondents to the Pre-Submission Site Allocations DPD Consultation

ID Respondent ID Respondent 1 Hertfordshire Borough Council 26 Pinner Association 2 Michael Weiser 27 Preston Bennett 3 Chris Rogers 28 Rita Slade 4 Jack Bye 29 RPS Planning & Development 5 Phil O’Dell 30 Environment Agency 6 Alan & Christine Piper 31 Scott Planning Associates 7 Arlene Laming 32 Shweta Kapoor Sharma, Aruna Kapoor, Surinder Kapoor and Munish Sharma 8 BNP Paribas 33 Susanah E. Greening, George H. Greening & Alice M. Greening 9 Catherine Kempt 34 Thames Water Utilities 10 CGMS 35 Drivas Jonas Deloitte 11 Chris Randall 36 Transport for London (Consents Team) 12 Gerald Eve LLP 37 Marion Garner-Patel 13 Mayor of London 38 Sandra-Lee Palmer 14 Hatch End Association 39 Mr. Nkansa-Dwamena 15 Herts & Middlesex Wildlife Trust 40 Mrs. Nkansa-Dwamena 16 John & Jean Davensac 41 English Heritage 17 Harrow College 42 Petition (53 signatories) 18 M. Chomistek & J. Floodgate 43 Mr. J. Welby 19 Mahendra C Patel, Michael J Donelly & Kiran C Patel 44 C. D. Noyce 20 GVA 45 Three Rivers District Council 21 Mr. & Mrs. Scott 22 Derek Biddle 23 Za Hida Agha 24 P. Giles 25 Janet Burgess

29 Appendix K: Responses to the Pre-Submission Site Allocations DPD Consultation – Respondent Order

Respondent 1: Hertsmere Borough Council

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 1 00 Hertsmere Chapt Yes Note that the Green Belt boundary is not proposed to N/A Yes Support for the protection and retention of the 1 Borough er 5 be altered between the north of the urban area in Green Belt is noted. No change. Council Harrow and our shared boundary. Hertsmere Borough Council supports the retention and protection of the Metropolitan Green Belt.

1 00 Hertsmere Chapt Yes There are three previously developed sites in the N/A Yes Noted. 2 Borough er 5 Green Belt identified that are close to the Borough No change. Council border. It is noted that Hertsmere Borough Council have been consulted previously on the relevant planning applications, and therefore have no additional comments in relation to these proposed allocations.

1 00 Hertsmere Site Yes Acknowledge the allocation of three pitches at N/A Yes Noted. 3 Borough G05 Watling Farm, in accordance with the Core Strategy No change. Council Watlin g Farm

Respondent 2: Michael Weiser

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2 00 Michael Site Not Though you very kindly assured me that his will not Not stated Not The inclusion of the site derives from 4 Weiser MOS5 stat affect The Santway personally, obviously I am very stat Harrow’s PPG 17 Study, which highlights an (Resident) The ed concerned and still would like to express my opinion ed existing and projected future shortfall in

30 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Santw on this matter, publicly accessible open space over the plan ay period and which identifies this and other Normally I would not have any objections to sites as ‘candidate’ sites for the provision of members of the public using any footpaths provided additional natural/semi-natural open space. including any forest land. The allocation recognises the need to There are various footpaths already situated in the address security when public access to the area which consists of two in Common Road, one site is realised. This and other necessary next to Glenhall Cottage, one opposite The Princess works would form part of a feasibility study Alexandra Home and one on the left before Hive prior to any planning application and Road approximately 600 yards before the Alpine associated consultation with neighbouring Restaurant traffic lights. residents.

There are two at the Clamp Hill end of Old Redding. In response to this representation, it is proposed to revise the commentary to the There is one situated just after the roundabout at the allocation to highlight the need for an bottom of Clamp hill (a nature trail). assessment of the site’s biodiversity value, environmental condition (including There is one situated almost opposite The Santway the ground surface) and the implications between Bentley Primary School and the Farm, plus of public access, as a minor modification. there is another footpath situated in Brookshill Close The assessment to inform how the site is and yet another 200 metres up Clamp Hill on the left managed including the hand side before the nursery. extent/management of public access.

There are two others in Brookshill which backs onto Clamp Hill nursery.

All these paths are very rarely used (for family exploring) mainly due to the lack of parking facilities and they are only used by handfuls of people on foot and usually at weekends only.

With regard to the forest land between the cemetery and The Santway, this area has always been faced off mainly due to the danger of the forest land being

31 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er very uneven, lots of ups and downs, pot holes and camouflaged trenches plus continuous falling trees and branches, plus the remains of Belgrano House.

This was pointed out to us by your local authority architects. At the time we were contemplating building our house. This encouraged us immensely at that time knowing that we will not going to be in the public view.

As far as health and safety is concerned, I certainly do not think this would have been a good idea to open to the public, especially when there are many safe areas which I have mentioned in the close proximity.

Apart from what I already mentioned, this forest land is now being occupied by an abundance of wildlife consisting of various foxes leers, monk jacks, badgers, hedge hogs and birds which my wife and various other neighbours encourage by feeding them on a regular basis. This would automatically disappear if they were to be interrupted or disturbed.

Finally the other main reason being that of security.

During the last 33 years that my wife and I have lived in The Santway we have had the disadvantage of suffering 6 robberies, 2 of which were aggravated burglaries, where armed men had entered our home, attacked and robbed us.

Because of what has happened in the past we have both become very security minded especially living in

32 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er this secluded area.

At this present time the general public are not at liberty to explore this area which allows us to feel less vulnerable and enjoy our home without inquisitive interruptions.

To conclude, I would certainly however be pleased to sign any necessary forms encouraging public footpaths in any other area with the exception of the area mentioned from the cemetery on Clamp hill to The Santway which has been our home for the last 32 years.

Respondent 3: Chris Rogers

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 3 00 Chris Site Not That this has planning permission granted for 189 Not stated Not The inclusion of the site reflects the fact of an 5 Rogers H18 stat homes (I assume flats but cannot find the application stat extant outline planning permission for 189 (Resident) Edgwa ed on the planning portal despite searching – please ed dwellings and the role of this site’s re provide the planning application reference number) is development in helping to deliver (through Town a concern; the area is already overpopulated and the s.106 funding already paid) The Hive football Footba adjacent road junction, by council officers’ own academy in Camrose Avenue/Whitchurch ll Club admission, poor and overcrowded. A parking CPZ is Lane. The site specific issues of loss of open already in place in Bacon Lane and a 20mph zone is space, flooding and highway impacts have being implemented as a direct result of the above. already were explored prior to the grant of outline planning permission. Documents That this application is intended despite the medium concerning the approved development on and high probability of flooding and it being an areas this site, and explaining its relationship with

33 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er of deficiency in access to nature conservation is Prince Edwards Playing Fields, have been bizarre, frankly. Your own policy states “Harrow's supplied to the respondent ifollowing the PPG 17 Open Space, Sport and Recreation Study making of this representation. (2010) found there to be existing and projected future No change. shortfalls in the availability of open space over the plan period, and in this context the Core Strategy establishes a presumption against any net loss of open space regardless of ownership and accessibility” – I’m thus unclear as to why development of this type is planned.

Finally, please explain how “The redevelopment of the site was approved by the Council as a means of realising a development plan objective to bring 7.25 hectares of open space at Prince Edward Playing Fields back into community use”, as I simply do not understand this.

Please could you clarify how the grant of planning permission allows completion of the Prince Edward scheme? The GLA First report seems to say that the works stalled when the contractor went bust. But presumably the costs of completion were budgeted for anyway, regardless of any delay caused by the need to find a new contractor, so why was an additional £750,000 needed?

In any event the justification appears dubious in part; I’m not aware how any borough can be said to have ‘too much’ playing field space, especially given recent events surrounding the Olympics. In any event the William Ellis Ground space has been reduced by a third due to Harrow’s grant of the Krishna Avanti school build.

34 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

The council seems to be having it both ways – justifying grant on the basis that leaving the site empty would cause harm, yet happy to grant an application that benefits no-one except the developer.

To place 190 homes and – staggeringly, given your own report on the level of public transport passing the site – 150 car spaces on one site, a site with a single small road that opens onto the A5 next to one of its busiest junctions, is staggering. The report says that Barnet LB has secured S106 funding to improve the junctions with roads on its side, yet Harrow appears to have had nothing to say about the junction with Camrose, whose appalling nature causes knock-on effects to Bacon Lane. Why?

I realise all of the above is too late, but you will surely realise that this entire application comes as a surprise to me – I have lived here since 1998 and have never been informed by leaflet drop about this application, which is a concern. 3 00 Chris H19 Not The removal of the existing industrial use is to be Not stated Not Support noted. The methodology for 6 Rogers Hill’s stat supported since the expansion of the site and its stat estimating the indicative housing capacity of Yard ed current activities are wholly incompatible with the ed the allocated sites is explained at Appendix B residential nature of Bacon Lane, again at officers’ of the DPD. own admission. I’m unclear how the figure of 28 units No change. has been arrived at however and would appreciate information on that.

Respondent 4: Jack Bye

35 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 4 00 Jack Bye H22 Not Your notice in Manor Road stating that 5 to 11 Manor Not stated Not The representation correctly points out that 7 (Resident) 5-11 stat Road is allocated for future development has caused stat the planning permission (allowed on appeal) Manor ed consternation among local residents. Although the ed for this site has now expired. Road proposal to demolish the houses and build flats was As no further interest in pursuing the approved on appeal in 2008 the stipulated three redevelopment of this site is apparent, it years for work to start is well past. is proposed to omit the site from the DPD as a minor modification. Please will you explain the basis on which the site is included in the LDF for redevelopment and why affected residents were not notified.

Respondent 5: Phil O’Dell

5 00 Phil O Dell Chapt Not The grass verges in Enderley Road should be Designate grass Not The verges were not identified as amenity 9 (Councillor) er 6 stat included in the green spaces listings verges in Enderley stat greenspace in the PPG 17 Study therefore ed Road as open space ed there is no evidential justification for (chapter 6) designating them as such. No change.

Respondent 6: Alan Piper

36 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 6 01 Alan Piper R4 Not As three of the Managing Trustees of North Harrow Amend the allocation Not The inclusion of the site responds to the 0 (for North North sou Methodist Church(NHMC) we wish to make to allow the existing Leg potential identified in the 2009 Retail Study Harrow Harro nd representation about the legal compliance and use as a church or al for redevelopment to meet additional retail Methodist w soundness of the Development Management Policies community facility to floorspace needs on an edge of centre site. Church) Metho Pre-Submission DPD in relation to the site of the continue. 1. The commentary to the allocation seeks dist church – Site R4 in the Site Allocations Document. Leg provision of a replacement place of worship/ Churc We are aware that a submission has already been al community uses as part of any h made on behalf of the church but we now have redevelopment, so there is no conflict with com further information that casts more doubt on the the broader objectives of the plan in this validity of the DPD and, as Charity Trustees with joint plian respect. and individual responsibility, we wish to make ce – additional points. Com Nevertheless, in response to further mun discussions with representatives of the 2. Soundness ity Church following the close of the pre- Invol submission consultation, it is proposed to “Justified” relocate this allocation from the retail vem chapter to the other chapter of the DPD The failure of Harrow Council in this respect to base ent and to revise both the site details and its proposal on robust and credible evidence is also a commentary to give greater emphasis to We breach of the “soundness” criterion of justification. the re-provision of the place of worship und /community facilities and the role of Harrow Council has not sought the participation of erst retail/residential development as an the Church Council nor asked whether the church and enabler to this end. It is proposed to make has any plan either to close or to develop the whole legal these changes as a minor modification to or any part of its premises. com the DPD. plian We have seen the Retail Study Review 2009 and ce note that the consultants then identified the site as inclu des having development potential. They did so however com with an express disclaimer of any analysis of plian development constraints or land ownership. Their ce evaluation that the site might become available in the with medium term (i.e. before 2015) was and is nonsense. the They noted “availability of premises unclear” and Stat eme 37 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er proposed retention of the existing use as an nt of alternative use. In the DPD Harrow Council has Com elevated this to a firm proposal for retail and/or mun ity residential use with “provision for a replacement Invol place of worship”. There is no evidence upon which vem the Council can have based this assumption. ent whic “Effective” h has The failure of the Council to seek any evidence that the the site may become available for development also obje affects the question of whether the DPD is ctive deliverable. Although we have been informed that s of the Council may have powers of compulsory refle cting purchase to implement its plan, we cannot believe the that it would seek to exercise such powers to close or view replace a viable place of worship and the proposal s, would therefore be non-deliverable. aspi ratio 3. Alternatives ns and We cannot say it is impossible that the site might one nee day become available, at least in part, for retail ds and/or residential development although we stress of the that the church currently plans only to increase the local numbers of people using the existing buildings as a com community centre and place of worship. We agree mun with the assessment of the consultants in ity 2009,however, that any plan should allow for the and continued existing use of the premises, and we say dra that the DPD and Site Allocation should include wing on provision for the use of the site to continue as a 38 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er church and community facility. their local kno wled ge. The Cou ncil’ s invol vem ent with NH MC was, so far as we kno w, limit ed to placi ng a notic e on a lam p- post on the

39 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er pav eme nt outsi de the chur ch. We kno w of no othe r notic e or requ est for infor mati on abo ut the chur ch or its plan s. Any enq uiry woul

40 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er d hav e disc over ed that the chur ch pre mise s are hom e to a thrivi ng com mun ity – not just a plac e of wors hip but a com mun ity cent

41 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er re use d by som e 750 peo ple eac h wee k atte ndin g Sco ut and Guid e grou ps and a vari ety of fitne ss and othe r clas ses rang

42 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ing from a pre- nata l sup port grou p to exer cise for the elde rly. It is use d by peo ple of all age s and man y diffe rent religi ons and soci al back

43 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er grou nds. The car park s are ofte n full. In 200 9 the chur ch com plet ed a £20 0,00 0 refur bish men t. To bas e and publi sh a dev elop men t

44 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er plan on an uns upp orte d assu mpti on that the chur ch is a failin g orga nisat ion who se pre mise s will be redu nda nt in the fore see able futur

45 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er e is unw arra nted and very dam agin g.

Respondent 7: Arlene Laming

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 7 01 Arlene G06 Not Following our telephone conversation this morning, I Open space should Not In view of the PPG 17 Study findings use as 1 Laming Kenton stat am writing with my concerns over the development of be allocated for stat a park would help to address local (Resident) Lane ed Kenton Lane Farm, Kenton Lane for Residential nature conservation ed quantitative deficiencies, but alternative types Farm Development and Public Open Space. or allotment use, but of open space (such as those suggested) not as a public park. which also have community access may be My family live at 35 Tenby Avenue, HA3 8RU and our appropriate. The broader concern about garden backs onto the open land of Kenton Lane security is recognised. Farm. We have lived here since 1983 and one of our main reasons for buying our property was the privacy In response to this representation it is and security that the privately owned open space therefore proposed to revise the afforded us. commentary to this site allocation, to provide greater flexibility over the open I understand from our conversation that the land is space typologies that may be secured not sustainable as a dairy farm and that some form of through the site’s redevelopment, and to change will happen. However, I am very anxious of draw attention to the need to ensure the the prospect of the land immediately backing my security of neighbouring residential property being turned into open park space. There property, as a minor modification.

46 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er are two parks very close to Tenby Avenue. The first is Centenary Park which has a sports club, many facilities including tennis courts and is well run and well managed. The second is closer - the park area which is accessible from Kingshill Drive and Hartford Avenue and which backs onto Priestmead School.

This park is lovely, during the daylight hours. At night-time it has become a haven for drunks and addicts; walk round the park in the morning and there is the unappealing spectacle of broken bottles, beer cans and needles to be found on the paths and in the bushes. Unfortunately, even though the park is locked at night, the cost of security is so prohibitive it has proved impossible to keep out those responsible. My two sons, now grown, would not stay near there once dusk fell and indeed both suffered at the hands of the hooligans and vandals who frequent the park at night. Neighbours' children don't play there and walk to Centenary Park instead. The police are too stretched to come out unless there is a serious crime there, but for the most part, the older children don't call them as by the time they would get to the park, those responsible have disappeared.

47 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er disruption to the wonderful, peaceful aspect of the neighbourhood. It is a pleasure to hear the children playing in the school (Priestmead is that close) but at the back of my house? Footballs being kicked at the fence or over the fence, kids wanting to retrieve their ball so climbing over.

If there has to be some development, there are surely some options which would still be of benefit. The prospect of a natural habitat, nature conservation area or allotments would still afford us some privacy and 'openness' and would be less likely to be a threat to anyone whose property backs onto the farm. It would not increase traffic to an already congested area and would work with the existing listed farmhouse buildings. I

I would implore you to look at alternatives to a public park.

Respondent 8: BNP Paribas

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 8 01 BNP H2 Not BACKGROUND Change site allocation Not However, as the site was not assessed as 2 Paribas 94-116 stat to employment land stat part of Harrow’s Employment Land Study, (for Travis Greenf ed Travis Perkins is one of the UK's leading builders’ and omit allocation for ed and as no site specific assessment has been Perkins ord merchants with more than 600 branches nationwide. residential. submitted with the representation, there is no Trading Co. Road The Company supplies more than 100,000 product evidence to demonstrate that designation of Ltd) lines to trade professionals including building the site as a new business use area (or materials, plumbing and heating, landscaping industrial & business use area) would secure

48 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er materials, timber and sheet materials, painting and feasible alternative employment uses or decorating, dry lining and insulation, tool and would be sustainable. equipment hire, doors and joinery, bathrooms and kitchens, and hand and power tools, together with a However, as it is apparent from this wide range of services including the trade-dedicated representation that current occupier has website, Trademate. Travis Perkins has been voted no interest in vacating the site, it is National Builders' Merchant of the Year seven times proposed to omit the site from the DPD as and has also been elected a Business Superbrand; a minor modification. the first company in the merchanting market and still the highest ranked merchant to be honoured.

Travis Perkins Greenford Road site is operational, situated on the eastern side of Greenford Road, in the sub-area of Harrow on the Hill and Sudbury Hill. To the north of the site Harrow Fencing Supplies (a builders yard) beyond which lies the Old Gaytonians Recreation Ground. Sudbury Hill Playing Fields are located to the east of the site and Harrow Cricket Club Ground can be found to the west and to the south is residential development. The site is approximately 0.4 hectares in size. We note that the Travis Perkins is not designated in Harrow Council’s adopted Proposals Map (February 2012).

We have undertaken a review of Harrow Council’s online planning history records available for the Greenford Road site and consider the following to be of particular relevance: ■ Planning permission was granted on 3 February 2010 for the “Change of Use of existing buildings yard (Sui Generis) to a builders merchant (Sui Generis) and the erection of 2 No. buildings for the display, sales and storage of building, timber and plumbing supplies, plant and tool hire, including outside display and storage and external alterations 49 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er including new fencing” (Application Ref: P/2312/09/HG/C).

We therefore consider the existing lawful use of the site to be a builder’s merchant (Sui Generis). Notwithstanding this, we consider the site to be more in line with a traditional employment use.

The Greenford Road site is identified as Site H2 for residential development in the draft Site Allocations DPD. Travis Perkins would like to remind the Council that the site is currently operational and Travis Perkins would like to maintain operational on the site as it would be difficult to find an alternate site in the vicinity. Travis Perkins only relocated to this property in 2009 after having lost its previous branch in Neptune Road, Harrow as a result of the redevelopment scheme there. Retention of this new branch is therefore important to retain its presence in the area.

On this basis, Travis Perkins object to the inclusion of their site within the Site Allocations DPD for residential development and request hat this site is included as protected employment and. This will ensure that Travis Perkins operations will not be prejudiced and can continue to operate from this location.

50 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er addition, we note that “Harrow is expected to meet and exceed housing targets for the next five years. It should also be noted that the Council’s Housing Trajectory forecasts an over-delivery of 400 units to 2025/26 and that the plan target will be met two years early in 2025/2026. In light of the information provided within the AMR and Employment Land Review (ELR), we are of the opinion that the Council should adopt a cautious approach to the release of employment land in preference to residential development, particularly given that the Council is set to exceed their overall target.

Industrial Use Further we also note that the ELR states “Local agents considered there to be strong locally generated demand in the Borough for smaller industrial/warehousing units up to around 500 m2 in size. “ Therefore, although marginally larger in size, we consider that our site could be deemed suitable for use as industrial/ warehousing site or storage facility.

Lastly, we note the Major’s Supplementary Planning Guidance ‘Industrial Capacity’ (adopted March 2008) and draft ‘Land for Industry and Transport Supplementary Planning Guidance’ (February 2012 ) seeks the limited transfer of industrial sites to other uses within Harrow (taking into account the projected demand from all types industrial activity and supply of capacity).

In light of the nature of the site, we are of the opinion that the Council should retain the site for continued

51 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er employment use.

POLICY CONSIDERATIONS

Our requests as detailed above accord with the Government’s National Planning Policy Framework (NPPF) (published March 2012) which “provides a presumption in favour of sustainable development” and from which we consider the following to be of particular relevance: ■ that plan-making should “positively seek opportunities to meet the development needs of their area… with sufficient flexibility to adapt [to] rapid change, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits” (Para 14); ■ that planning should “encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system. To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century” (Para 19 – 20); ■ that planning policy should “support existing business sectors, taking account of whether they are expanding or contracting... Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances” (Para 21); and

Further we note that, the NPPF state that local planning authorities should:

52 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

■ use their evidence base to assess: ■ “the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time as, or combined with, Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of previously allocated land” (Para 161).

We reserve the right to amend or supplement these representations at a later date if necessary.

Respondent 9: Catherine Kempt

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 9 01 Catherine H22 Not This development was approved for appeal on Not stated. Not The representation correctly points out that 3 Kempt stat 11/06/2008. The developer never went ahead with stat the planning permission (allowed on appeal) (Resident) 5-11 ed the project, because the company were not in a ed for this site has now expired. Manor position to proceed. In the text it states that these As no further interest in pursuing the Road properties have planning permission, but it is my redevelopment of this site is apparent, it understanding that the application period expired in is proposed to omit the site from the DPD 2011. as a minor modification.

53 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

As this site is residential property and I am the owner and occupier of the freehold property at 5 Manor Road, I would have appreciated the Council notifying me of the proposal to include my property into this DPD and not have to read it on a lamp post outside my house.

Respondent 10: CGMS

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 10 01 CGMS EM1 Not I write on behalf of our client, the Mayor’s Office It is recommended that Not The site is within the Northolt Road Business 4 (for stat for Policing and Crime/Metropolitan Police the police station site stat Use Area as shown on the Policies Map and Metropolitan Northo ed Service (MOPAC/MPS), with regard to the is removed from Site ed in the Core Strategy (Harrow on the Hill & Police lt Road Council’s consultation on the Site Allocations EM1: Northolt Sudbury Hill sub area map). Policy CS3G of Service) Busine Development Plan Document (DPD) – Pre Business Use Area the Core Strategy seeks provision for ss Use Submission version. The MOPAC/MPS provide and reallocated as a diversified employment opportunities through Area a vital community service and as such policing stand alone the redevelopment/conversion of premises is recognised within the adopted London Plan residential-led within the business use area. This and other (2011) as being an integral part of Social redevelopment site as provisions of the Core Strategy give effect to Infrastructure. The ability to ensure safe and per the May 2011 an objective to deliver 4,000 new jobs over secure communities throughout the Borough version of the draft the plan period. relies upon continued effective policing which, DPD. in turn, can be achieved through delivery of the It is noted that the complete removal of the MPS’ Estate Strategy. Therefore, given the site from the DPD is not sought. Although the strategic importance of borough policing, the 2011 consultation draft Site Allocations DPD following representations are made to the included the site in the housing chapter it emerging Site Allocations DPD. nevertheless sought a mixed use development for residential and non town Previous Representations centre economic uses (see ‘other proposed uses’ and commentary in the 2011

54 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er CgMs have previously made representations document). The now adopted Core Strategy on behalf of the MPS towards the Harrow & seeks employment-led, mixed use Wealdstone AAP Issues and Options document development throughout the Northolt Road in June 2011 and Preferred Options in business use area; to arbitrarily exclude this February 2012. Representations have also site would undermine this provision of the been submitted towards the Site Specific Core Strategy and would fail to increase the Allocations consultations in November 2010 pressure on other sites to deliver against the and June 2011 and the emerging Core Strategy Strategy’s job creation target for the plan in July 2008, December 2009, January 2010, period. May 2011, August 2011 and most recently in December 2011. The NPPF includes community uses in the definition of economic development. Relevant Planning Policy Therefore it is irrelevant that the police station is not a ‘B’ class use. The Council The provision of effective policing is of crucial would expect the redevelopment of the site to importance across London to ensure safe contribute to job creation as well as housing places to live are created as part of a objectives, and in this mixed-use area a sustainable community, consistent with mixed use development would not be planning policy. This policy background is set inappropriate. out in full in our letter of representation regarding the draft Core Strategy (2nd No change. December 2011).

Representations

Site EM1 Northolt Road Business Use Area (North and South), South Harrow

55 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er it is recommended that the police station site is removed from Site EM1: Northolt Business Use Area and reallocated as a stand alone residential-led redevelopment site as per the May 2011 version of the draft DPD.

The existing police station comprises a sui generis use in planning terms and, as defined within the London Plan and Core Strategy, policing is recognised as a community service. In line with the MOPAC/MPS’ Estate Strategy, the police station will only be released provided that the existing community service provision has been re-provided on sites elsewhere in the Borough or neighbouring areas. As such there would be no net loss in policing provision. Furthermore, as the police station does not comprise a Class ‘B’ use there is no planning policy requirement to provide replacement employment floorspace in this location.

The immediate vicinity is predominately residential in character with the surrounding area encompassing a variety of other land uses including residential, office, community and retail uses. The release of the Police Station site for a residential-led redevelopment would therefore be entirely appropriate in this location.

In terms of housing need, Core Strategy Policy CS1states that the Council will allocate sufficient previously developed land to deliver at least 6,050 net additional homes between 2009 and 2026. The redevelopment of this site for housing would therefore assist the Council in meeting this objective and would also be consistent with the objectives of the NPPF which states that:

56 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Whilst the Council can demonstrate a 5-year supply of housing to meet the Mayor’s target, this target represents a minimum and is appropriately assessed in parallel with London Plan Policy 3.4 which requires development plan preparation to optimise housing output.

Respondent 11: Chris Randall

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 11 01 Chris G06 Not The consultation has been very much under the Not stated Not Previous consultation relates to pre- 5 Randall stat radar. At the outset of this project all residents were stat application proposals put forward by the (Resident) Kenton ed personally contacted and given the opportunity to ed developer. Consistent with all other Lane view the planned proposal but since then there has development sites in the DPD, a site notice Farm been no contact whatsoever and it is purely by was used to publicise the DPD pre- chance that a resident happened to come across submission consultation. this. The communication has been woeful to say the least and in our view deliberately so to avoid any No evidence of a link between affordable opposition. We would like to make the following housing provision and property values has points against the development, which are shared been advanced. Nevertheless, property value with a number of my neighbours in Ivanhoe Drive. is not a planning consideration.

Further affordable housing in the area will have a Concern about disruption during the works is detrimental effect of the value of our properties. noted, but is a matter for control under the

57 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Environmental Health regime 9not planning It will be extremely disruptive for all residents during legislation). the building work In responding to this DPD, Thames Water Increase usage of drainage systems that are already Utilities have not sought to highlight any in serious need of maintenance. known problems associated with this site. Nevertheless, Core Strategy Policy CS1Z Significant blocking of light to our properties requires those proposing development to demonstrate adequate infrastructure Security concerns with the proximity of the housing capacity, and the Development Management Policies contain provisions relating to surface We do not need any more parks. Belmont/Kenton is water management. well served with parks. Indeed it would be better to concentrate on maintaining the existing parks with The site allocation does not propose or the use of wardens, rather than build another park. prescribe a specific design, and assessment We find it difficult to believe that any Belmont/Kenton of impact on neighbouring property would be residents have raised the issue of a lack of park a matter for consideration at pre-application/ facilities. planning application stages. Any planning application would be subject to public consultation with surrounding residents. However, in response to this representation it is proposed to amend paragraph 8.17, to highlight the need to achieve a sensitive relationship with surrounding dwellings, as a minor modification.

58 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er flexibility over the open space typologies that may be secured through the site’s redevelopment.

Respondent 12: Gerald Eve LLP

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 12 01 Gerald Eve GO3 Not We act for St George's Headstone Parochial Church Amend the allocation Not It is considered that scouting is in some 6 LLP stat Council who own this site and on whose behalf we to remove the scout stat significant part an open space use and (for St. St. ed are instructed to make representations in response to hut and its curtilage ed therefore the continued allocation of this part George’s Georg your Council's draft Site Allocations Pre-Submission from the open space of the site (together with the group’s HQ Headstone e’s DPD. designation and show building) as open space is justified and Parochial Playin designate instead for effective, consistent with the parallel example Council) g Field Our clients support the proposal to identify that part community use. of the tennis club and its pavilion building. of the site which is the subject of consented housing development separately from the open space The NPPF and the Development designation. Management Policies DPD provide safeguards for social/community facilities, However, we do not think that it is justified or such as the scout hut, but this does not effective to continue to include within that open space negate the conclusion that it is appropriate to designation the small area of land presently occupied include the premises as part of the open by the Headstone Scouts as their HQ (the 'Scout space designation. Hut') which comprises an area of land which is essentially a northern continuation of that strip of land No change. on the west site of the playing field that has been allocated for residential development. This area of land should be allocated for community uses and not for open space.

In following the logic of this conclusion, there is a distinction to be drawn between the Scout Hut and

59 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er the pavilion at the tennis club to the north of the site, which is there to support the open space use and ancillary to it.

Respondent 13: Mayor of London

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 01 Mayor of Gener Yes Having reviewed the allocations GLA officers are N/A Yes The finding of general conformity with the 7 London al (In content that the pre-submission document is in (In London Plan is noted. gen general conformity with the London Plan. gen No change. eral Nevertheless, detailed representations intended to eral conf clarify or improve detail within the document are conf ormi provided within Appendix 2 and must be taken into ormi ty account as part of these representations. ty with with the the Lon Lon don don Plan Plan ) ) 13 01 Mayor of 1.1 Yes The plan’s aim to promote the viability and vitality of N/A Yes Noted. 8 London (In town centres, along with ensuring effective use of (In No change. gen previously developed sites within the borough is gen eral strongly supported. eral conf conf ormi ormi ty ty with with the the Lon Lon don don 60 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Plan Plan ) ) 13 01 Mayor of Gener Yes The Council is advised that any site within close Amend commentary Yes In response to this representation it is 9 London al (In proximity to London Underground infrastructure for sites in close (In proposed to amend the commentary of gen (including sub-surface infrastructure) will require proximity to London gen sites R2, H9, H12, H13, H14, H21 and eral early consultation with TfL’s London Underground Underground eral MOS6, to highlight the need for conf Infrastructure Protection team. infrastructure to conf consultation with TfL, as a minor ormi highlight need for ormi modification. ty This particularly applies to sites at or adjacent to early consultation with ty with Rayners Lane, Canons Park and Stanmore London TfL’s infrastructure with the Underground stations. TfL would welcome a protection team. the Lon reference to this in the supporting commentary to Lon don relevant sites. don Plan Plan ) ) 13 02 Mayor of Gener Yes The Council may wish to use the supporting Amend commentary Yes Proposed Policy 53 of the Development 0 London al (In commentary to the site allocations to specify for sites in high PTAL (In Management Policies DPD sets out the gen instances where it would support proposals for car areas to support car gen circumstances for considering car-free eral free development, in areas of high public transport free development. eral proposals, including public transport capacity, conf accessibility. conf trip generation and the adequacy of ormi ormi surrounding parking controls. Therefore the ty ty appropriateness of car-free development with with should be a proposal-specific matter rather the the than a matter for the Site Allocations DPD. Lon Lon No change. don don Plan Plan ) ) 13 02 Mayor of 3.26 Yes The GLA supports the proposed removal of the N/A Yes Noted. 1 London (In northern area of the Honeypot Lane Strategic (In No change. gen Industrial Location (SIL) designation in order to gen eral rationalise, and redefine the SIL boundary, in eral conf response to the substantially completed mixed-use conf

61 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ormi development at this site. ormi ty ty with with the the Lon Lon don don Plan Plan ) ) 13 02 Mayor of GB1 Yes The allocation of the RAF Bentley Priory, Royal N/A Yes Noted. 2 London Bentle (In National Orthopaedic Hospital, Harrow Collage (In No change. y gen (Brookshill) and Wood Farm sites as strategic gen Priory eral previously developed sites in the Green Belt is eral GB2 conf supported, as is the Council’s intention that conf RNOH ormi development at these sites should deliver benefits to ormi , GB3 ty the Green Belt and improve public access and ty Harro with appreciation wherever possible. Policy 23 of the with w the Development Management Policies DPD will be the Colleg Lon applied, along with established strategic and national Lon e, GB4 don policy, to manage the sensitive redevelopment of don Wood Plan these sites. Plan Farm ) ) 13 02 Mayor of Chapt Yes The increased allocation of land for open space and N/A Yes Noted. 3 London ers 6 & (In biodiversity is supported in line with London Plan (In No change. 7 gen policies 7.18 and 7.19. gen eral eral conf conf ormi ormi ty ty with with the the Lon Lon don don Plan Plan ) ) 62 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 02 Mayor of Gener Yes Officers would welcome an acknowledgement within Amend the DPD to Yes In response to this representation it is 4 London al (In this DPD that Harrow's waste sites will be identified cross refer to the (In proposed to amend paragraph 1.4, to gen within the West London Waste Authority Waste Site allocating role of the gen ‘signpost’ the West London Waste DPD, eral DPD. West London Waste eral as a minor modification. conf DPD. conf ormi ormi ty ty with with the the Lon Lon don don Plan Plan ) )

Respondent 14: Hatch End Association

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 14 02 Hatch End Para Not Chapter 4 Housing: Page 73 - top of page – Change reference Not Paragraph 4.4 was included in the pre- 5 Association 4.4 stat reference should be “Chapter 8 “ not Chapter 9. after ‘Harrow Arts stat submission document for consultation ed Centre’ to chapter 8. ed purposes but will not be relevant to the final document. Therefore it is proposed to delete the whole of (including the part to which this representation relates) paragraph 4.4 as a minor modification.

Respondent 15: Herts & Middlesex Wildlife Trust

63 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H9 Not LEGALITY/SOUNDNESS Not stated. Not Site H9: The area allocated for development 6 Middlesex Land at stat For the above sites, the allocation may be stat excludes the (proposed revised boundary) Wildlife Rayner ed acceptable in principle. The legality or soundness of ed area of the adjacent site of importance for Trust s Lane the proposed use will depend on the detail of any nature conservation (SINC). SINCs are a Station proposals coming forward. The following comments regional designation and development therefore neither support or oppose the site adjacent to a SINC need not be harmful to its H13 allocations proposed, but are intended to draw conservation interest. Paragraph 4.24 Jubilee attention to nature conservation factors which may highlights the need for sensitive design and House, make the proposed allocation diverge from national layout. Policies 27 and 28 of the proposed Merrio policy or Core Strategy policies and objectives, or Development Management Policies DPD n make them less preferable sites. provide criteria for the protection and Avenu enhancement of biodiversity sites. e COMMENT No change. The above sites include areas which are designated H14 for their nature conservation interest as SINCs or Site H13: The area allocated for development Land at SSSIs, or otherwise are adjacent to sites having this is adjacent to but does not overlap the Stanm designation. neighbouring site of importance for nature ore conservation (SINC). SINCs are a regional Station The Council must consider what impacts may result designation and development adjacent to a on the SINCs or other designated sites from the SINC need not be harmful to its conservation H16 particular proposed site allocation. The Council interest. In response to this representation Gillian should consider whether any other sites are it is proposed to amend paragraph 4.33 to House available for this use/purpose, where any negative highlight the need for sensitive design impacts may be avoided or reduced. and layout, in relation to the neighbouring H21 designation, as a minor modification. Land at If any of these sites are allocated for future Policies 27 and 28 of the proposed Canon development or use in the Site Allocations DPD, it Development Management Policies DPD s Park must be ensured that the proposed use or provide criteria for the protection and Station development does not result in direct or indirect enhancement of biodiversity sites. long-term harm to the site, to its ecological integrity GB1 and role in the local ecological network. Site H14: The area allocated for development Bentley is adjacent to but does not overlap the Priory This should be achieved in the first instance and neighbouring site of importance for nature wherever possible through avoidance – such as conservation (SINC). SINCs are a regional GB2 locating built development away from the SINC site designation and development adjacent to a

64 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er RNOH and establishing, retaining and enhancing semi- SINC need not be harmful to its conservation natural buffer habitats. Secondly, where there is a interest. In response to this representation risk of impact, adequate and robust mitigation must it is proposed to amend paragraph 4.37 to be part of any development proposals. Any residual highlight the need for sensitive design impact must be ‘offset’ by compensatory measures – and layout, in relation to the neighbouring for instance, habitat creation on another part of the designation, as a minor modification. site; or funding or undertaking management and Policies 27 and 28 of the proposed enhancement work on the SINC or other nearby Development Management Policies DPD sites. Compensation and offsetting should never be provide criteria for the protection and seen as the first recourse, and should only be used enhancement of biodiversity sites. when preferred options of avoiding and mitigating adverse impacts have been exhausted. Site H16: The area allocated for development is adjacent to but does not overlap the If any of the above sites are allocated, the Council neighbouring site of importance for nature should also consider how development may conservation (SINC). SINCs are a regional enhance the local ecological network, through designation and development adjacent to a habitat creation, habitat improvement, and ongoing SINC need not be harmful to its conservation positive management. SINCs are an important interest. In response to this representation element of the ecological network, helping to create it is proposed to amend paragraph 4.42 to linkage between other, statutory sites such as highlight the need for sensitive design SSSIs. Opportunities to improve and strengthen the and layout, in relation to the neighbouring ecological network should be explored. For instance designation, as a minor modification. extending SINCs, managing SINC habitats better for Policies 27 and 28 of the proposed wildlife, creating buffer habitats and habitat corridors Development Management Policies DPD or patches between SINCs provide criteria for the protection and enhancement of biodiversity sites. CHANGE No specific changes suggested. Site H21: The area allocated for development is adjacent to but does not overlap the JUSTIFICATION neighbouring site of importance for nature Paragraph 109 of the National Planning Policy conservation (SINC). SINCs are a regional Framework (NPPF) sets out that the planning designation and development adjacent to a system should “contribute to and enhance the SINC need not be harmful to its conservation natural and local environment by… minimising interest. In response to this representation impacts on biodiversity and providing net gains in it is proposed to amend paragraph 4.58 to

65 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er biodiversity where possible… including by highlight the need for sensitive design establishing coherent ecological networks that are and layout, in relation to the neighbouring more resilient to current and future pressures.” designation, as a minor modification. Policies 27 and 28 of the proposed Paragraph 114 confirms that local planning Development Management Policies DPD authorities should ‘plan positively’ for the creation, provide criteria for the protection and protection, enhancement and management of enhancement of biodiversity sites. ecological networks and green infrastructure. Site GB1: The allocated site is adjacent to an Paragraph 117 states that, in order to minimise SSSI, a site of importance for nature impacts on biodiversity, planning policies should conservation (SINC) and a local nature inter alia: reserve. The redevelopment of the site has  plan for biodiversity at a landscape-scale; already been approved and this includes detailed assessment of biodiversity/nature  identify and map components of the local conservation impacts. Paragraph 5.3 ecological networks, including the hierarchy already refers to the need to safeguard of international, national and locally biodiversity. In response to this representation it is proposed to elaborate designated sites of importance for this paragraph, to highlight the need for biodiversity, wildlife corridors and stepping re-assessment in the event of substantive stones that connect them and areas changes or additions to the approved identified by local partnerships for habitat scheme, as a minor modification. Policies restoration and creation; 27 and 28 of the proposed Development Management Policies DPD provide criteria  promote the preservation, restoration and re- for the protection and enhancement of creation of priority habitats, ecological biodiversity sites, and paragraph 118 of the NPPF provides for proposals to be refused networks and the protection and recovery of where there would be an adverse effect on priority species populations, linked to an SSSI. national and local targets. Site GB2: The allocated site overlaps sites of Following Paragraph 165 of the NPPF, planning importance for nature conservation (SINC) policies and decisions should be based on up-to- and is also home to a species of local date information about the natural environment and biodiversity importance as identified in other characteristics of the area. The Framework Harrow’s Biodiversity Action Plan. The

66 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er directs that this should include an assessment of redevelopment of the site has already been existing and potential components of ecological approved and this includes detailed networks. assessment of biodiversity/ nature conservation impacts. Paragraph 5.7 When determining planning applications, paragraph already refers to the need to safeguard 118 of the NPPF states that local planning biodiversity. In response to this authorities should aim to conserve and enhance representation it is proposed to elaborate biodiversity by applying the principles listed in the this paragraph, to highlight the need for document, amongst which: re-assessment in the event of substantive  If significant harm resulting from a changes or additions to the approved development cannot be avoided (through scheme, as a minor modification. Policies locating on an alternative site with less 27 and 28 of the proposed Development harmful impacts), adequately mitigated, or, Management Policies DPD provide criteria as a last resort, compensated for, then for the protection and enhancement of planning permission should be refused; biodiversity sites.  Proposed development on land within or outside of a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be

67 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

Paragraph 176 states, “Where safeguards are necessary to make a particular development acceptable in planning terms (such as environmental mitigation or compensation), the development should not be approved if the measures required cannot be secured through appropriate conditions or agreements.”

NOTE: The government circular 06/2005 Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System, has been retained and remains as valid guidance for local planning authorities on decisions affecting protected species and designated nature conservation sites. 15 02 Herts & GB4 Yes LEGALITY/SOUNDNESS Not stated Yes In response to this representation it is 7 Middlesex The allocation is considered legal and sound in proposed to amend paragraph 5.16, to Wildlife Wood principle. ensure that any biodiversity impact from Trust Farm the residential development is avoided (or COMMENT mitigated where unavoidable), as a minor HMWT supports the extension of Stanmore Country modification. Park in principle, and its management as a nature reserve. The allocation site and surrounding areas are of notable value to wildlife. Pear Wood to the east is thought to be ancient, and has a diverse 68 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ground flora indicative of ancient origins. Pear Wood and Stanmore Country Park are designated as a SINC of metropolitan importance; the southern section of the site is designated also as a Local Nature Reserve. The majority of the site GB4 indicated on the map is SINC of borough grade II importance. By incorporating this area into the Country Park, ensuring positive conservation management is put in place across the site, and managing recreational use so that public enjoyment and learning from the site is maximised without detriment to its ecological interest, its ecological importance may increase.

If the Council consider that a residential development is indeed required to make the proposed extension financially viable, it must be ensured that the residential development of 10 houses is sited in an area where it will not cause any significant detriment to the ecological interest of the site and the significance of the nature conservation areas as a whole. It should be ensured that the ecological gain from this site allocation is significantly greater than the potential losses attributable to the residential development. Any potential direct or indirect negative impacts should be avoided as far as possible, mitigated through positive measures within the development area and through enhancement and management of the parts of the site that will be taken into the Country Park.

It must be ensured further that no detriment occurs to the metropolitan-grade SINC, including Pear Wood.

69 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er CHANGE No specific changes suggested.

JUSTIFICATION As per previous comment for H9, H13, H14, H16, H21, GB1 and GB2 15 02 Herts & MOS2 Not LEGALITY/SOUNDNESS Omit enabling Not In response to this representation which 8 Middlesex stat As this allocation is essentially ‘positive’, it is less of residential stat casts doubt on the value of allocating this Wildlife Land ed a concern in policy terms and there is less of a basis development potential ed site as a new nature reserve (confirmed Trust Rear of on which to judge its soundness than, for instance, from the proposed by the Council’s Biodiversity Officer), and 121- there would be with built development. However, it allocation and in the absence of evidence about the 255 is not clear that this particular site will contribute in consider the potential nature conservation value of the site, it is Pinner any measurable way to improving nature ecological value of the proposed to omit the site from the DPD as Road conservation in the area, why it is preferable for this site. a minor modification. It is also noted that allocation than other sites, or whether the site would a number of individual and groups of be ‘effective’ as a nature reserve (in terms of trees on the site are the subject of tree increasing local biodiversity and improving ecological preservation order protection. connectivity and function).

COMMENT HMWT has reservations about this site allocation. The site is put forward as a new Local Nature Reserve.

Firstly, the site is not currently designated as a SINC, so it is presumed that it has no particular ecological value that marks it out as a notable candidate for this use. It is not clear why this site has been identified for this use.

Secondly, the site is only 0.9 hectares. This is very small, and would constrain its potential value for nature and potential contribution to the local ecological network and its functioning.

70 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Finally, the Site Allocations document sates that the Council may consider allowing “enabling residential development” on the part of the site fronting the Gardens. This would reduce the size of the nature reserve further, and also introduce extra pressures on the nature reserve area, which would again reduce its attractiveness and usefulness for wildlife. Furthermore, it is difficult to see how a site of this small size will require ‘enabling’, as the costs of establishing and managing the site as a nature reserve will be relatively low.

Although we encourage Councils to seek opportunities to improve sites for biodiversity wherever possible and to create new nature reserves/nature conservation areas, it is important to remember that a site’s contribution to the local ecological network will depend on the site’s size and its quality. Setting aside small areas can contribute to the ecological network through creating links and ‘stepping stones’ between more important nature conservation sites; however, the Council should at the same time aim to allocate more substantial areas for this purpose, and also to make sure that existing habitat areas of quality (including SINCs and sites of SINC standard) are protected from development and managed appropriately to maintain and improve where possible their ecological interest.

CHANGE If this site is allocated as a nature reserve, no residential development should be allowed. If its funding is a concern, the Council should consider how developer contributions (eg. CIL) from other development in the vicinity could contribute to

71 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er addressing the deficiency of nature conservation sites in that area. Nature conservation sites are an important part of green infrastructure, which is a necessary and valuable infrastructure type for local communities.

If this allocation is going to be counted against delivering nature conservation objectives for Harrow, the Council should consider carefully how much this site will contribute in terms of improving ecological function. Allocating a piece of land on paper should not count towards nature conservation targets unless there is a measurable and real improvement for local wildlife.

JUSTIFICATION As per comment for H9, H13, H14, H16, H21, GB1 and GB2.

Respondent 16: John Davensac

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 16 02 John G06 Not I am away from home at present and would request Not stated Not The site allocation does not propose or 9 Davensac stat you list my name to oppose the Kenton lane farm stat prescribe a specific design, and assessment (Resident) Kenton ed development. ed of impact on neighbouring property would be Lane I have resided at 5 Tenby Avenue for 40 years and a matter for consideration at pre-application/ Farm have of course enjoyed the open space to the rear of planning application stages. my property. No change. The proposed development will cut out all sunlight from my garden with the position of the houses in However, in response to this

72 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er such close proximity. representation it is proposed to amend The value of my property will decrease with this paragraph 8.17, to highlight the need to terrible design. Would you please list my opposition achieve a sensitive relationship with to the petition which is being circulated. surrounding dwellings, as a minor modification.

Property value is not a planning consideration. No change.

Respondent 17: Harrow College

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 17 03 Harrow GB3 Not We would like to clarify that the commentary Not stated Not Following this representation officers met 0 College stat (relevant extract shown below) no longer reflects the stat with the Principal and Finance Director of the Harro ed primary plan for this site. This reflects a position from ed College on 21st September 2012. The w some years ago when the Learning and Skills College does not envisage releasing the site Colleg Council planned to make a very substantial grant for residential development during the current e available for redevelopment of the Lowlands Road plan period (2009-2026) but instead retaining site (the "One Harrow" project). This plan did not it in use as part of Harrow College, with come into fruition and no external funds were possible replacement of some of the existing invested in the site. It is highly unlikely that the buildings on the site in the event of an successor bodies to the LSC will have any significant improved financial outlook. As capital for investment in College infrastructure comprehensive redevelopment of the site is projects in this, or indeed the next, public sector unlikely during the plan period, the College spending round. Without a substantial injection of requests that the existing building to the north external capital, funds released from redevelopment of the complex be included within the ‘red of the Brookshill site alone would be insufficient (by a line’ development envelope of this Green Belt very considerable amount) to enable improvement of site. the Lowlands Road campus to the extent that it could provide additional facilities for activities conducted at In response to this representation it is

73 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er the Brookshill site. therefore proposed to revise the site details, to delete references to number of The College has therefore revised its property homes, and to replace under a new strategy to reflect this, and now intends redeveloping heading of ‘proposed allocation’ reference both sites on a modular basis to improve education to educational development and other facilities and opportunities for the Borough. This will uses associated with the College, as a be done in the full spirit of the Development minor modification. The commentary will Management Policies framework, with particular also be amended to reflect the revised focus on supporting employment and economic allocation. development; sustainability; community infrastructure and enhancing biodiversity.

Commentary 5.10 This site is a strategic, previously-developed site within the Green Belt because of the potential it provides to fund improved educational facilities on the more accessible Lowlands Road campus within Harrow town centre. 5.11 Harrow College is spread over two sites with the principal campus located in Lowlands Road, Harrow town centre. The consolidation of the College onto the Lowlands Road site would release land and buildings at the Harrow Weald campus for alternative use and redevelopment. Parts of the site (outlined in blue) are substantially open in character and should remain so; redevelopment will be confined to the red site boundary shown above and reproduced on the adopted Policies Map. The original college building on the site is of some local architectural and historic merit and every effort should be made to retain it. However the wider complex contains many later additions, the potential redevelopment of which could secure rationalisation of built form and enhance the site's contribution to Green Belt openness. 5.12 Open land to the north of the existing complex

74 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er of buildings could form an extension to Harrow Weald cemetery. The Council will seek the investigation of this possibility as part of any proposal for the development of the site, consistent with paragraph 10.11 of the Harrow Core Strategy (2012). 5.13 The housing capacity figure has been estimated using the London Plan sustainable residential quality density matrix, in accordance with the methodology set out at Appendix 2 but using the built footprint of the site (0.75 hectares) as the site area.

Respondent 18: M Chomistek & J Floodgate

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 18 03 M MOS4 Not We understand that that the area referred to as Glenthorne should Not The inclusion of the site continues an existing 1 Chomistek stat ‘Glenthorne’ has been recognised as a Conservation have restricted stat UDP allocation and is justified by an up to & J ed area as highlighted in UDP EP39 point 3.129. “A rich access. ed date PPG 17 Study, which highlights an Floodgate variety of flora and fauna are to be found at existing and projected future shortfall in (Residents) Glenthorne, including some uncommon species and publicly accessible open space over the plan valuable habitats. Access may need to be restricted period. to protect habitats and wildlife from undue No change. disturbance, thereby ensuring their continued survival, and that future generations are afforded the However, in response to this opportunity to enjoy them”. As a preliminary representation and upon the advice of the investigation has identified that Glenthorne has Council’s Biodiversity Officer, it is uncommon species and habitats we would strongly proposed to revise the allocation to ‘use suggest that a further review of this area should take in association with Bentley Priory’ and to place by specialist bodies for environmental amend the commentary to highlight the assessment. Also we believe that due to the need for an up-to-date assessment of the development of the Bentley Priory former RAF Base site’s biodiversity value, environmental there has been a significant loss of condition (including the trees) and the

75 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er woodland/vegetation and many species of wildlife implications of public access, as a minor have now moved into the Glenthorne area as it is modification. The assessment is to inform undisturbed. We strongly believe Glenthorne should how the site is managed as part of Bentley not be adjoined to Bentley Priory as we feel this Priory open space and the suitability/extent of would be detrimental to the flora and fauna and public access that may be appropriate. As valuable habitats and feel that such a proposal would with other major open space allocations, it is be against the ‘Sustainability Appraisal of envisaged that funding would principally Development Management, Site Allocations and derive from Community Infrastructure Levy Area Action Plan DPD Regulation 19’ points 4.64, revenue. 4.75, 4.77 and 4.79. We would like to understand better how the council proposes to protect the flora A small part of the site is leased by the and fauna which has existed there undisturbed for Council to the Metropolitan Police as a many years if the area is opened up to the public. wireless station. It is therefore proposed to revise the commentary, to make reference to the need to ensure the Also we would point out that the Glenthorne area is security of this facility, as a minor already deemed to be hazardous to the general modification. public (as identified in the UDP - revised July 2004 - part 2 section 17 PS 23). To highlight just some Detailed consideration of parking and access examples there are dangerous trees, barbed wire is arrangements a matter for any consequent littered around, broken bottles and plate glass, etc. It planning application to make the site publicly is our belief this would require a great investment of accessible. Investigation has revealed that a money and expense to ensure that the area is small area to the south of the site is the ‘cleaned up’ in order protect the health and safety of subject of an area-wide tree preservation all visitors. We also understand that currently the order but this need not affect the allocation. Bentley Priory Nature Reserve Management The obelisk referred to is not designated as a Committee works in partnership with the Harrow heritage asset, however the adjacent Nature Conservation Forum and the Committee are Glenthorne Lodge is a locally listed building intending to apply for a ‘Your Heritage Lottery Fund’ and the cast iron gates are referred to in the grant to undertake important habitat restoration work. listing (see response to English Heritage Therefore it is hard to understand how the Council is representation no. 102). able to fund opening up Glenthorne given the No change. expense that will be required to enable it be used by the public.

76 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

We would also highlight that in the Glenthorne area there are special architectural and historical monuments which should be reviewed - these being the gates at the entrance of Glenthorne Lodge and an obelisk, which can be found on local ordnance survey maps, within Glenthorne, sited near to the boundary of Bentley Priory. We would urge some thought to be given to this.

The current Bentley Priory Open space is 66 Hectares and in our opinion is currently under utilised by the local population. On a weekend day you can walk through the area and will see very few people, therefore we do not understand how releasing this additional space will enhance the population’s enjoyment. We believe that the monies would be better utilised by opening space in a more populated area so that more people will be able to enjoy it on ‘their doorstep’.

The parking of cars by individuals who currently utilise the open space is of concern, as often cars are parked on our front grass verge and block Common Road, which is a very busy ‘A’ road. We would suggest that an assessment of the impact of additional footfall should be carried out to ensure that traffic is not further hindered.

77 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Glenthorne area, therefore further investigation may be required to identify if any other trees require TPOs and a plan should be put into place to protect these trees for future generations. Furthermore to the south west of the Glenthorne site it appears that what is currently an area used by the Metropolitan Police seems to be included in DPD, this may need to be investigated in order to identify ownership.

As far as we can tell our property, Glenthorne Lodge, is the only house that may be directly affected by any changes to existing boundaries and fencing. We wish to state we are wholeheartedly against the proposal however we believe that if the proposal should go ahead a clear demarcation is necessary, and expect confirmation from the council regarding how this will look prior to any final decision, the type of barrier that will be erected, and, specifically where the boundary will lie. Our concern is that if this matter is not taken seriously we will have the general public walking through our garden.

We would reiterate that we believe that Glenthorne should have restricted access; permission should only be granted to conservationist and specialist groups in order to protect the habitats and wildlife from undue disturbance.

In summary we are completely against this proposal as stated in the above points, and feel that it is against point E.7 in the ‘Site Allocations Pre- Submission DPD’ document in that it is difficult to understand what ‘social, environmental, economic and resource use objectives of sustainability’ will be 78 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er achieved by opening up Glenthorne to the public.

We understand from Peter Barron, Planning Officer, that a decision was made not to formally/directly inform parties affected by this proposal and we would expect that in the future any decisions or communications regarding this proposal are communicated to us personally without delay.

We trust that our views will be taken into account when considering the future development of the Glenthorne site.

Respondent 19: Mahendra C Patel, Michael J Donelly & Kiran C Patel

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 19 03 Mahendra C G06 Not We are owners of properties at 306, 308 and 310 Not stated Not Detailed consideration of traffic impacts 2 Patel, stat Kenton Lane, and jointly wish to object to the stat would be a matter for consideration at pre- Michael J Kenton ed proposed development for residential development of ed application/planning application stage (a Donelly & Lane 35 houses and open space at Kenton Lane Farm high-level transport study underpins the Core Kiran C Farm Kenton lane. Strategy and the growth provided for in the Patel spatial strategy). (Residents) Our concerns are as follows: No change.

1. There is already considerable and congestion with The site allocation does not propose or parked cars along both sides of Kenton lane from prescribe a specific design, and assessment traders/customers and business man and the of impact on neighbouring property would be proposed development will make the situation worse a matter for consideration at pre-application/ and not better for the owners like ourselves, who are planning application stages. However, in pensioners, but also those with young families, as the response to this representation it is road in itself is a very busy road proposed to amend paragraph 8.17, to

79 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2. Such development can will take away light from highlight the need to achieve a sensitive our houses and also cause more pollution relationship with surrounding dwellings, 3. The open space that is being suggested we as a minor modification. understand is for a park, we cannot comprehend why you would require another open space when we have In response to this representation it is park high Park and Priestmead school park very also proposed to amend the commentary close by, and these parks themselves give rise to to this site allocation to provide greater Police having to man it on a regular basis. This will flexibility over the open space typologies also cause more noise and disturb our peace and that may be secured through the site’s quiet throughout the day and evenings redevelopment, and to draw attention to 4. We have to deal with drunken members of the the need to ensure the security of public on a number of occasions due to the local neighbouring residential property. pubs being close in proximity, and a park will naturally attract these types of people, especially at the weekend and on sunny days.

Please let us know when the public meetings are to be held to discuss this matter further.

Respondent 20: GVA

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 20 03 GVA EM2 Uns Introduction In order for the DPD Not 3 (for oun We respond to the above document on behalf of our to remain flexible, we stat Marylebone Rayne d client, Marylebone Property Investments Ltd in would suggest that ed Property rs relation to the site known as Imperial House, Imperial the Commentary Investment) Lane Drive, Harrow. A site location plan is attached to this within Paragraph 3.9 Offices letter. on page 54 states that ‘redevelopment may These representations are submitted following a be brought forward in meeting with planning officers on 9th August 2012, a phased manner’.

80 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er regarding future redevelopment options for the site (meeting ref. HA/2012/ENQ/00215). The site is currently let to Ladbrokes and is their headquarters We would therefore within the UK. request that the Site Details state that the Whilst Ladbrokes have recently renewed the lease provision of 150 units for an initial five years, the owner of the site is looking forms a minimum at future redevelopment as the existing building is target. becoming outdated and is in need of investment to remain attractive to office occupiers.

Our comments in relation to the Pre-Submission Site Allocations Development Plan Document (DPD) are provided in respect of the site at Imperial House. Representations have also be submitted under We would therefore separate cover in respect of the Development suggest that given the Management Policies Pre-Submission DPD (July scale of residential 2012). development proposed on the site Commentary and the flexibility Site EM2: Rayners Lane Offices, Imperial Drive, within the NPPF with Rayners Lane Policy EM2 is unsound because it is regard to the not effective and not consistent with national policy. protection of employment uses, it Phasing would be more Site EM2, ‘Rayners Lane Offices’, as identified in the appropriate to include Site Allocations document, comprises Imperial Site EM2 within Phasing House, Regent College and Talbot House to the west Chapter 4, Housing, of Imperial Drive. As such the site is currently in as a housing led In response to this representation it is multiple ownership and it is therefore likely that any scheme. proposed to amend paragraph 3.9, to redevelopment would come forward in phases. In allow phased development, as a minor order for the DPD to remain flexible, we would modification. suggest that the Commentary within Paragraph 3.9 on page 54 states that ‘redevelopment may be brought forward in a phased manner’.

81 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Minimum Housing Units We welcome the proposed allocation of Site EM2 for residential units, but would request that the quantum of units to be provided is consistent in both the Site Minimum Housing Units Details (page 53) and Commentary (page 54) for the site. The Site Details state that 150 homes are to be Paragraph B1 (page 251) of the DPD provided across Site EM2, whereas Paragraph 3.9 of confirms that the housing capacity attributed the Commentary states that this is a minimum figure to each site is indicative, not prescriptive and, in line with the Core Strategy. We would therefore in relation to sites within employment Chapter request that the Site Details state that the provision 3, paragraph 3.3 recognises that the of 150 units forms a minimum target. indicative housing capacities are modest. Therefore, for consistency with the format of Land Use the rest of the document, it is not proposed to Harrow’s adopted Core Strategy (February 2012) add minimum to the site details. states that within Rayners Lane District Centre No change. housing is to be provided as part of employment-led mixed use redevelopment of offices. Specifically, Paragraph 8.11 sets out that mixed-use Land Use redevelopment or conversion of redundant office buildings on Imperial Drive offers the opportunity to The findings of the GVA office report contribute to housing supply, whilst making provision submitted with this representation largely for appropriate economic uses to be supported. reflect those of Harrow’s Employment Land However, GVA’s Lease Consultancy Team has Study. Namely: commented on the future use of Imperial House (commentary appended to this letter) and considers  that Harrow’s office market is largely that redevelopment to an alternative use from localised in nature [and therefore employment would be the natural future of the site. requires smaller rather than larger Imperial House is coming to the end of its economic premises] and that that existing life as an office building and there is an anticipated provision (e.g. Talbot House) is of low level of future demand for 85,000 sq ft of office poor quality; and space within an area that is primarily residential with  that supply conditions are a secondary retail centre at Rayners Lane. suppressing rental levels [and Established office locations such as Harrow town therefore make speculative new centre, Uxbridge and commercial locations closer to office provision unviable].

82 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er London would provide more desirable employment opportunities, offering small to medium size suites at Harrow’s response to the Employment Land more affordable rents. In summary, we would Study, reflected in the Core Strategy, is to therefore consider it unlikely that the site would be seek economic diversification and renewal of brought forward as an employment led scheme. employment floorspace through mixed use redevelopment of sites such as that the Furthermore, the National Planning Policy subject of this representation. The allocation Framework (NPPF) adopted in March 2012, states recognises the role of residential as an that planning policies should avoid the long term enabler to this end. The indicative floorspace protection of sites allocated for employment use of 4,100m2 stated in the allocation (and for where there is no reasonable prospect of a site being the whole allocation including Talbot House) used for that purpose (Para 22). Applications for equates to 44,000 sq ft. and is therefore alternative uses of land or buildings are to be treated substantially less than the stated 85,000 sq on their merits having regard to market signals and ft. area of the existing Imperial House. the relative need for different land uses to support sustainable local communities. We would therefore Paragraph 19 of the NPPF places significant suggest that given the scale of residential weight on supporting economic growth development proposed on the site and the flexibility through the planning system, and paragraph within the NPPF with regard to the protection of 20 states that local planning authorities employment uses, it would be more appropriate to should plan proactively for business include Site EM2 within Chapter 4, Housing, as a development needs and to support an housing led scheme. economy fit for the 21st century. Harrow’s Core Strategy provides for spatial strategy for Continued Engagement in the Emerging Policy economic growth and diversification within Process the Borough, pursuant to a target to deliver We look forward to confirmation of receipt of these 4,000 new jobs over the plan period. The role representations at the earliest opportunity and would of the Rayners Lane offices in the delivery of welcome the opportunity to meet with officers to the strategy is written into the Core Strategy; discuss any part of our representations if necessary. office rejuvenation and employment generating uses are sought in Rayners Lane district centre as part of mixed use redevelopment. It should be noted that the ‘scale of residential development proposed’ is across the whole allocation, not just the Imperial House site, and that (as stated by

83 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er letter dated 22nd August 2012) the allocation is not prescriptive as to the amount or form of employment use to be delivered. The allocation emphasises the role of residential as an enabler. It has not been demonstrated that any mixed use development on this site would be unviable. The proposed allocation, which does not prescribe the nature and amount of employment uses to be delivered on the site, is considered to be both effective and consistent with national policy. No change.

Respondent 21: Mr. & Mrs. Scott

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 21 03 Mr. & Mrs. MOS5 Not Our property back onto Oak Lodge, and with only a None stated Not The allocation recognises the need to 4 Scott stat field behind for security if this plan goes ahead our stat address security when public access to the (Residents) The ed property would be very vulnerable. The only way to ed site is realized. This and other necessary Santw secure it would be to build a fence along the length of works would form part of a feasibility study ay our garden at great cost. prior to any planning application and associated consultation with neighbouring People are inquisitive and they would wonder what is residents. beyond the proposed pathways and blunder into our No change. properties, to which could lead to unsavoury characters checking out what is worth stealing, and in today’s climate that is a distinct possibility.

Respondent 22: Derek Biddle

84 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 22 03 Mr. Derek H22 Not Unsound – Justfied – Effective This site should be Not The representation correctly points out that 5 Biddle sou removed from the list. stat the planning permission (allowed on appeal) (Resident) 5-11 nd This site does not have Planning Permission. The statement ed for this site has now expired. Manor It may have done so when the Council started relating to this site is As no further interest in pursuing the Road preparing this document, but this expired in June factually incorrect. redevelopment of this site is apparent, it 2011 I - as the owner of is proposed to omit the site from the DPD one of the properties as a minor modification. (and I understand, the other owners) - have no interest in taking this forward.

Respondent 23: Za Hida Agha

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 23 03 Mr. Za Hida G06 Not Unsound – Justified Effective Consistent with Not stated Not Detailed consideration of traffic impacts 6 Agha sou National Policy stat would be a matter for consideration at pre- (Resident) Kenton nd ed application/planning application stage (a Lane a) traffic congestion b) added pressure on local high-level transport study underpins the Core Farm schools/ surgeries, which are already Strategy and the growth provided for in the oversubscribed. c) noise pollution in an spatial strategy). already congested area d) destroy green No change. area( open land ) The residential development would be liable We strongly oppose this planning as it will right to local Community Infrastructure Levy behind our house & could devalue our property charges (a high level infrastructure considerably. assessment underpins the Core Strategy and the growth provided for in the spatial strategy) to fund infrastructure improvements made necessary by this and other developments in the area.

85 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er No change.

Within the context of the surrounding residential suburb, the proposed residential allocation is unlikely to significantly increase noise pollution. No change.

The proposed allocation seeks to secure the future of (not destroy) the designated open space within the site.

Respondent 24: P. Giles

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 24 03 Mrs. P. MOS5 Not I am writing with regards to the notice of intent to turn Not stated Not The inclusion of the site derives from 7 Giles stat the woodland at the rear of my property into public stat Harrow’s PPG 17 Study, which highlights an (Resident) The ed natural woodland. ed existing and projected future shortfall in Santw publicly accessible open space over the plan ay Having looked at your plans for the development, period and which identifies this and other firstly I do not agree with the boundaries you have sites as ‘candidate’ sites for the provision of market out and secondly I am concerned and worried additional natural/semi-natural open space. that the public will be able to overlook my private property, which in this day and age seems that by The allocation recognises the need to allowing any Tom, Dick or Harry onto and around my address security when public access to the land as you can understand would make me very site is realised. This and other necessary vulnerable to trespass and even burglary of which I (e.g. public safety) works would form part of a have been a victim of twice already. feasibility study prior to any planning application and associated consultation with We have a lot of nature walks and natural woodland neighbouring residents. around the surrounding area, that does not affect the

86 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er residents privacy and vulnerability, and I feel sure In response to this representation it is that a few acres more would not add a lot more to proposed to amend the boundary of the peoples enjoyment, but would put more stress and proposed allocation, to properly reflect worry to the residents who live around the proposed the extent of the site within the Council’s site. ownership (but excluding land leased to third partied), as a minor modification. There is also a concern regarding the pond which is on my property, which would be construed as a great danger to children and pets from drowning in the pond and also stopped some from going in after their dog, who jumped in after some ducks. We also had to call the fire brigade twice after someone started a fire in the woods at the rear.

I do hope that your committee takes heed of this letter and comes to a sensible conclusion regarding this matter.

Respondent 25: Janet Burgess

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 25 03 Mrs Janet R4 Not Members of the Church Council of North Harrow The designated use Not The inclusion of the site responds to the 8 Burgess sou Methodist Church (as Managing Trustees) are very should be extended to stat potential identified in the 2009 Retail Study (for North North nd surprised and concerned that the site of their church, include, in addition ed for redevelopment to meet additional retail Harrow Harro church halls and car parks, including also the and as an alternative floorspace needs on an edge of centre site. Methodist w headquarters of 2nd Headstone Scouts, is to the retail and The commentary to the allocation seeks Church) Metho designated primarily for retail and residential use residential uses provision of a replacement place of worship/ dist (Site Allocation R4) without their knowledge or proposed, the community uses as part of any Churc approval. The Church Council has no current plans to continued primary use redevelopment, so there is no conflict with develop any part of the site which is, in addition to a and development of the broader objectives of the plan in this

87 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er h place of worship, a vital and vibrant community the site as a place of respect. centre in use every day by many community groups worship and facility for and will continue to be so. In consequence the community and Nevertheless, in response to further proposal is unlikely to be deliverable and this part of leisure activities. discussions with representatives of the the DPD is not "sound". Church following the close of the pre- submission consultation, it is proposed to The designated use should be extended to include, in relocate this allocation from the retail addition and as an alternative to the retail and chapter to the other chapter of the DPD residential uses proposed, the continued primary use and to revise both the site details and and development of the site as a place of worship commentary to give greater emphasis to and facility for community and leisure activities. the re-provision of the place of worship/community facilities and the role of retail/residential development as an enabler to this end. It is proposed to make these changes as a minor modification to the DPD.

Respondent 26: Pinner Association

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 26 03 Pinner R1 Not We refer to your Site Allocations DPD (paragraphs Change ‘Barter’s Not In response to this representation it is 9 Association stat 2.11 and 2.12 and associated plan and aerial Walk’ to ‘Bishop’s stat proposed to amend the site boundary to Land ed photograph) in which you have included a proposal to Walk’ ed exclude Beaumont Mews and to correct betwe designate an area between the High Street and Love paragraph 2.12 to refer to Bishop’s Walk en Lane in Pinner as being suitable for development. instead of Barter’s Walk as minor High modifications. Street We have the following observations on this proposal: Omit Beaumont Mews and from the allocation. The limitation of the site access is recognised Love Your text states the site includes Barters Walk. This and, to this end, paragraph 2.12 of the Lane is quite wrong. It should refer to Bishops Walk commentary already refers to the need to instead. Barters Walk is on the other side of the High ensure safe and effective vehicular access

88 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Street. Omit the entire from Love Lane. Additional text to amplify allocation unless this issue is proposed as part of the minor The site is shown as including the modern self- improved vehicular modifications to the DPD. Also, in contained residential development known as access to the site can response to this representation and for Beaumont Mews. We can see no justification for be achieved. consistency with the summary table at the including it within a potential new development site. end of chapter 2, it is proposed to reduce the potential retail foorspace of the site The present vehicular access for the proposed from 1,500m2 to 1,000m2 as a minor development site on to Love Lane is between No.1 modification. Love Lane and the end of Red Lion Parade and is very poor. Large delivery vehicles such as those which serve Marks & Spencer now have to make multi-point turns in an area which is already extremely congested with traffic and parked vehicles, often to the point of becoming jammed. Indeed jams also occur in this area without vehicles delivering to the site becoming involved because of the volume of traffic and both legal and illegal parking on both sides of Love Lane. Adding substantial retail development into this mix would be a recipe for even more traffic chaos.

The sight line to the right for a vehicle leaving the present access in forward gear is very poor and hazardous. This is because of the way No.1 Love Lane projects so far forward.

The present access point itself is also very close to the large roundabout in Bridge Street which also exacerbates the traffic problems in the area.

89 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er using the present access point. Within the constraints that the existing buildings fronting Love Lane impose it is hard to see where any improved access point could be sited. The High Street is a Conservation Area with Listed Buildings and therefore no vehicular access could be created from this side of the site.

For the above reasons we contend that this site is not one which is currently, or even prospectively, suitable for development as proposed.

Respondent 27: Preston Bennett

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 27 04 Preston G06 Yes The mixed use allocation to secure good quality and The existing Yes Support noted. 0 Bennett publicly accessible open space alongside residential farmhouse is broken (for David Kenton development is wholly appropriate for this site who’s into two existing In response to this representation, and Carol and Lane current open space designation is of no benefit to the dwellings (reducing following further discussion over a Brazier Farm public. Discussions have already been held between the net figure to 33). revised scheme with this contributor, it is Edwards) the land owner and the Council and the public proposed that the gross number of homes engaged on proposals in line with the proposed Given the current and be reduced to 34 and the net number of balance of uses and retention of the listed building. proposed use of the homes be reduced to 32, and that the The proposed allocation is therefore supported in its site it is requested commentary be amended to further current form, subject to the following brief comments. that the first sentence highlight the potential for open space of paragraph 8.18 be reconfiguration to achieve public access reworded to ‘parts of to this currently inaccessible open land, the site have potential as a minor modification. It is also value to the proposed to amend the site details to community as public correct the site area (to reflect the size of open space, to allow the entire site including the open space)

90 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er appropriate and to specify the area of the designated reconfiguration’. open space, and to amend the commentary to allow for the In paragraph 8.16 it reconfiguration of the open space, as should be highlighted additional minor modifications. that the current open space designation benefits from no current public access, being wholly private land.

Respondent 28: Rita Slade

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 28 04 Rita Slade G05 Not Many of my neighbours and myself are horrified to Not stated Not The allocation of this site for three additional 1 (Resident) stat hear that you intend to open up this site again to stat pitches responds to the additional pitch Watlin ed more Travellers ed requirement for the plan period (2009-2026) g Farm and are opposed to it. as set out in the Harrow Core Strategy. This Gypsy Although I have lived in Bushey or Aldenham all my approach reflects Government advice at and life I have no idea on the history of this site, because paragraph 8 of the publication Planning Travell it is miles away from your area of Harrow. policy for traveller sites (2012). There is no er Site As it is we already have two sites in Sandy Lane and evidence to demonstrate that the allocation Hilfield Lane, the Sandy Lane site is being extended will adversely affect the relationship between both are under Hertsmere B.C. care and the the settled and traveller communities in the travellers give us very little trouble. Both are only area, nor that there would be any increase in two/three miles away from crime as a result of the allocation. your site, further down the A.41. No change. Surely enough is enough? Hertsmere sites are managed by the other travellers

91 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er who live there, any trouble and those travellers have to go. Your site and I believe because it is so far from your care was a nightmare. There was one family there who broke in houses, stables, and my house, and both my neighbours were broken into which was them. Proven as it was their car but the police would not go into that area. Once they did, leaving the squad car outside on the A.41 only to return and find the car had no wheels on it! We do not want to go back to that. Thank You! It is very rural round here and we are vunerable. Last weekend it was the Barnet Fair and a lot of property went missing in this area. Travellers come from miles around to visit this Fair. Please don't do this to us. We already have our fair share of travellers in this small area. If you have to because of Government Policy - please give us an assurance that you will monitor the site and get rid of the trouble makers. I understand the existing Traveller on this site is very anxious about being invaded by more troublesome Travellers and going back to the troublesome past.

Respondent 29: RPS Planning & Development

92 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er t instructed by the Pearson Pension Property Fund Ltd (for Pearson (the Fund) to prepare representations to the London Pension Borough of Harrow Site Allocations Pre-Submission Property (DPD) consultation document, in respect of their land Fund) and property interests at Northolt Road Retail Park (the Retail Park), South Harrow, shown as the land within the blue line on the plan at Appendix 1.

1.2 The Retail Park lies just outside of the South Harrow District Centre and includes three units which have A1 consent including the sale of non-food comparison goods. The units are currently occupied by Dreams, Dunelm Mill and Staples.

representations promote the suitability of the Retail Park site for the provision of additional retail

floorspace and for the provision of convenience floorspace as replacement of the existing comparison

floorspace.

1.4 The following chapter provides details about Northolt Road Retail Park, and our comments in response to specific policies within the DPD consultation document are provided in Chapter 3 and are set out in the same format as the Council’s response forms.

1.5 RPS is willing to meet with Planning Officers from

93 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Harrow Council concerning the Fund’s interests at the Retail Park in contributing towards the Council’s requirements for additional retail floorspace (comparison or convenience) across the Borough.

NORTHOLT ROAD RETAIL PARK

Northolt Road Retail Park

2.1 The Retail Park which the Fund has interests in extends to approximately 6,782sqm of retail floorspace, and lies approximately 340m to the north- west of South Harrow District Centre, and close to the centres of Rayners Lane and Roxeth.

2.2 The Retail Park currently has planning permission for non-food open A1 retail use. Permission was granted on 27 June 2008 under application P/1628/08/VA, for the variation of condition 20 of application West/407/98/FUL and condition 2 of P/0286/08/CVA to allow the sale of non-food comparison retail goods in Units 1 and 2.

2.3 The Retail Park initially was two units but Unit 2 gained consent on the 20 March 2008 to subdivide

the retail unit to provide the current three units which are occupied by Staples, Dreams and Dunelm Mill.

2.4 The site is adjacent to an existing Waitrose

foodstore although this is not part of the site owned by the Fund and is not subject to these representations.

Suitability for Additional or Alternative Retail Suitability for Additional or Alternative Floorspace Retail Floorspace

94 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

2.5 The Retail Park is in a sustainable and highly The NPPF defines edge of centre sites (for accessible location in South Harrow with a Transport retail purposes) as those well connected and for London PTAL rating of 3. Accessibility to the site up to 300m from the primary shopping area is good with the Retail Park being situated off the and it is noted that the part of the Retail Park A312 Northolt Road, approximately 340m north-west to which this representation relates is furthest of South Harrow District Centre boundary, and 400m away from the town centre (would require from the Primary Shopping Frontage along Northolt pedestrians to walk across the extensive Road. surface car park). Therefore the site should be treated as ‘out of centre’. 2.6 There are a number of bus stops along Northolt Road and Shaftesbury Avenue, which run adjacent to the site, the closest being approximately 400m away. The site is also only approximately 400m from South Harrow tube station and the Piccadilly Line, and is approximately 2km from Northolt Park Railway Station to the south west and Harrow-on-the-Hill Railway Station to the north-east.

2.7 The Retail Park is an existing established retail location, due to the current retail uses and adjacent

foodstore, and should be recognised as an appropriate location for providing additional and

alternative comparison and convenience retail floorspace to meet the anticipated population and

expenditure increase within the plan period.

2.8 The Retail Park already has consent for non-food open A1 use, and therefore it is considered that the principle of retail sales on the site has already been established. The location of the site adjacent to the Waitrose foodstore demonstrates that the location is highly appropriate for the sale of convenience goods either in addition to or as an alternative to the sale of comparison goods.

95 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

2.9 Due to the units being in current retail use and having open A1 non-food consent, it is considered that the introduction of food sales on the site would not cause a significant impact in relation to traffic to and from the Retail Park, and would not be detrimental to other retail uses within the South Harrow District Centre, Harrow Town Centre or the Harrow and Wealdstone Intensification Area, where other retail development is proposed. Technical studies could be undertaken to demonstrate the impact of additional retail floorspace on the site. Any impact would be mitigated by the corresponding reduction in non-food sales.

PLANNING POLICY

National Planning Policy Framework National Planning Policy Framework

2.10 It needs to be borne in mind that National The NPPF continues the established Planning Policy Framework (NPPF), as did previous principle of ‘town centre first’. It is clear from guidance, includes retail development within the paragraph 23 that, if sufficient sites cannot be description of economic development. allocated within or at the edge of town

centres, then policies should be set to meet 2.11 As such retail development is a key part in needs in other accessible locations. i.e. out of

securing economic growth in order to create jobs and centre sites should not be allocated. See the prosperity. The Government is committed to ensuring retail note at the end of this schedule.

that the planning system does everything it can to support sustainable economic growth. Planning

should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.

96 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2.12 To help achieve economic growth, Local Planning Authorities should plan proactively to meet the development needs of business and support an economy which would include need for additional retail floorspace.

2.13 The NPPF encourages Local Planning Authorities to: set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth; and set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period.

2.14 In ensuring the vitality of town centres planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period. In drawing up Local Plans, Local Planning Authorities: should allocate a range of suitable sites to meet the

scale and type of retail development needed in town centres. It is important that needs for retail are met in

full and are not compromised by limited site availability;

undertake an assessment of the need to expand town centres to ensure a sufficient supply of suitable

sites; allocate appropriate edge of centre sites for main

town centre uses that are well connected to the town centre where suitable and viable town centre sites

are not available. If sufficient edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are

97 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er well connected to the town centre; and set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.

2.15 Local Plans should be aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where. Only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan.

2.16 Local Planning Authorities should set out the strategic priorities for the area in the Local Plan, provision of retail, leisure and other commercial development.

2.17 Crucially, Local Plans should: plan positively for the development and

infrastructure required in the area to meet the objectives, principles and policies of this Framework;

be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of

longer term requirements, and be kept up to date; be based on co-operation with neighbouring

authorities, public, voluntary and private sector organisations;

indicate broad locations for strategic development on a key diagram and land-use designations on a

proposals map; and allocate sites to promote development and flexible use of land, bringing forward new land where

98 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er necessary, and provide detail on form, scale, access and quantum of development where appropriate;

2.18 In respect of using a proportionate evidence base, NPPF states that each Local Planning Authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about It is considered that the economic, social and environmental the Retail Park is a characteristics and prospects of the area. Local suitable and planning authorities should ensure that their sustainable location assessment of and strategies for housing, for additional retail employment and other uses are integrated, and that sales including the they take full account of relevant market and sale of food, economic signals. compared with other identified sites within 2.19 Local Planning Authorities should have a clear the DPD understanding of business needs within the economic markets operating in and across their area.

2.20 Local Planning Authorities should use this evidence base to assess: the needs for land or floorspace for economic development, including both the quantitative and qualitative needs for all foreseeable types of economic activity over the plan period, including for retail and leisure development; the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time as, or combined with,

Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of

previously allocated land; the role and function of town centres and the

99 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er relationship between them, including any trends in the performance of centres; the capacity of existing centres to accommodate new town centre development;

2.21 The NPPF accepts out-of-centre sites as legitimate locations for retail use in the absence of suitable and available Town Centre or edge-of-centre sites.

Evidence Base Evidence Base

2.22 The 2009 Harrow Retail Study undertaken by It is observed following this Nathanial Lichfield and Partners (NLP), which representation that paragraph 2.4 (second updated a 2006 study, predicts that there will be a bullet) of the DPD erroneously attributes retail requirement of 38,912sqm net comparison and the new supermarket to Neptune Point 5,261sqm net convenience floorspace by 2025. We (already taken into account in the Retail have not critically analysed the Evidence Base and Study) and not to Harrow View. It is the following comments are based on its published therefore proposed to correct this text as findings. a minor modification.

2.23 As indicated in the Site Allocations Development The Retail Study is not out of date. It was published in the autumn of 2009 and was Plan Document, the additional requirement excludes the following approvals: used as part of the evidence base for the Core Strategy which was found sound in Extension of Tesco store, Station Road of 2,368sqm net comparison and 651sqm net 2011 and adopted early 2012. Paragraph 18.36 of the report recommends that the convenience floorspace; Neptune Point supermarket of 3440sqm gross Study should be updated in four to five years’ time, i.e. 2013-2014. For the purposes of the convenience and 560sqm gross comparison floorspace; and DPDs currently being prepared the existing Study is adequate, remains sufficiently up to 1,000sqm A1-A5 uses at Harrow View, Wealdstone. 2.24 It is evident that the balance for date and is relevant.

additional retail floorspace needs to be identified by the Council which should be included in the DMP document.

100 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

2.25 The 2009 study is out of date and it is considered that it does not sufficiently reflect the current retail needs of Harrow. Therefore, despite these proposed developments there is still a requirement of both convenience and comparison goods floorspace to be provided within the plan period. The Core Strategy target is for 6,050 homes 2.26 The Harrow Core Strategy 2012 indicates a over the plan period (2009-2026), and requirement of 3,250 new homes to be built between reconciliation of the difference between the 2009 and 2026. However, the ONS Household housing target and ONS household Projections to 2033 (CLG) predicts a population projections is explained at paragraph 4.12 of increase of 26,000 people for Harrow between 2008 the Core Strategy. It is not the role of the and 2028. examination into the Site Allocations DPD to re-open this issue. Meeting the Need Meeting the Need 2.27 The DPD proposes seven retail site allocations which would provide a total of approximately The retail note at the end of this schedule 8,500sqm retail floorspace within the plan period to sets out how the pipeline supply of retail 2026, which states at paragraph 2.5 that these will development and allocations in the Site include convenience and non-major comparison Allocations DPD and the AAP meets and

goods floorspace. These allocations in addition to the exceeds the projected need for additional recent approvals, detailed above, could provide convenience retail floorspace over the period

approximately 16,000sqm of retail floorspace. 2009-2025, and how the need for comparison retail floorspace will be met over the short to

2.28 Whilst it is acknowledged that some of the medium term (2009-2020) and the policy proposed requirement of 5,261sqm convenience provisions made in the event of longer term floorspace may be met through site allocations and need being realised (2020-2025). commitments, it is unclear whether this requirement will be fully met.

2.29 The Harrow and Wealdstone Area Action Plan proposes to allocate a number of sites to contribute

101 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er towards major comparison retail sales and additional convenience, clearly acknowledging that these sites are not suitable for major comparison floorspace. The NPPF requires that Local Planning Authorities ‘should allocate a range of suitable sites to meet the scale and type of retail development needed…’

2.30 Due to the vagueness of allocations in the Area Action Plan in respect of location, area, net floorspace, suitability, viability and mix of uses In response to this representation, to proposed, it is not considered that these sites, other provide greater clarity on how retail than the commitments, should be considered as development needs are to be met, it is contributing to the identified need, and should be proposed to revise the introductory text to regarded as windfall sites. Chapter 2 as a minor modification to the DPD. 2.31 It is unclear whether the Council could accommodate all of the required 44,173sqm on the The Council can demonstrate a sufficient proposed site allocations and existing commitments, supply of pipeline and allocated sites to meet and therefore additional sites should be considered in and exceed the projected need for addition to these to ensure that the Borough’s future convenience retail floorspace over the period retail needs are met. 2009-2025. The NPPF does not allow for the allocation of out of centre sites, but instead 2.32 It is considered that the Retail Park is a suitable states that any needs that cannot be met in-

and sustainable location for additional retail sales centre should be provided for through including the sale of food, compared with other policies. No change.

identified sites within the DPD.

SITE ALLOCATIONS Site Allocations

The DPD proposed seven retail allocations, six of R1: High Street/Love Lane, Pinner which are to be for mixed use development including retail, and one solely for retail use. Retail development is a less vulnerable use and therefore is not inappropriate on a Flood 2.34 It is recognised that a number of the sites Zone 3A site, and does not require exception identified in the DPD are currently in use as other testing (note however that it is proposed to

102 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er non retail land uses. omit the residential component of this allocation as a minor modification). 2.35 RPS consider sites R1, R2, R3 and R4 of the No change. proposed site allocations, which are allocated for retail development are unlikely to be redeveloped for R2: Units South of Rayners Lane Station retail uses within the early stages of the plan period and that the Retail Park site at South Harrow is a Harrow’s Retail Study rated the development more readily available location to accommodate prospects of this site as ‘good’ and as having additional or alternative retail floorspace. RPS, therefore, short-medium term availability. The requests that these production of a design which preserves or 2.36 Many of the sites are currently occupied which representations are enhances the conservation area need not be would undoubtedly delay the timeframe in which the taken into account in a significant impediment to retail retail floorspace would become available, and it is the preparation of the development. debateable as to whether this could be undertaken DPD, and that the No change. within the plan period. Council considers the suitability of this site R3: Harrow West Conservative Association 2.37 Sites R1 and R3 are within flood zones which for open A1 use to would require mitigation to be suitable for retail use. include the sale of Following discussions with the Environment Site R2 falls within a Conservation Area, thus the convenience goods Agency and subject to minor modifications to design of the retail proposal would need to be and to provide the Development Management Policies DPD sympathetic to the aesthetic quality of the area and additional retail it has been agreed that previously-developed as a result this could be a costly and time consuming floorspace to meet sites within Zone 3B may be treated as Zone exercise for a developer. It is also recognised that both the convenience 3A. Retail development is a less vulnerable Site R4 is also outside of the local District Centre as and comparison use and therefore is not inappropriate on a is the site at Northolt rd Retail Park. However, the needs of the Borough. Flood Zone 3A site, and does not require North Harrow Methodist Church that currently This could be exception testing. occupies the site would need to be replaced if the achieved within the No change. site was to be redeveloped; thus again complicating short term, within the the development process which will inevitably delay early stages of the R4: North Harrow Methodist Church the site in coming forward soon for retail plan period, making development. the site a more Harrow’s Retail Study rated the development appropriate location prospects of this site as ‘reasonable’ and as 2.38 Site R5 is proposed for 1,000sqm of retail uses than some of the having medium term availability. This site is in addition to housing, which is identified in the DPD other sites identified considered to be edge of centre (not out of as a possible single convenience store, several small centre) within the NPPF definitions. The

103 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er retail units or an extension to the existing Sainsbury’s within the DPD. development of a mixed-use scheme which store. The site is within the South Harrow District incorporates replacement community Centre and Primary Shopping Area. Sites R6 and R7 facilities need not be a significant impediment are also within District Centres and within 300m of to retail development. However, it should be Primary Shopping Areas. Site R6 is proposed for noted that in response to representations 1,000sqm for a large supermarket or retail from the site owner it is proposed to move warehouse. the allocation from the ‘retail’ chapter to the ‘other’ chapter of the DPD, and make the Site R7 is also proposed for a retail warehouse or provision of replacement place of worship/ foodstore. community facilities the focus of the allocation. 2.39 Site R5 is within close proximity of our client’s No change. site and as stated above it falls within the District centre and the primary Shopping Frontage, R5: Roxeth Library and Clinic nonetheless, a retail proposal at this location would require the redevelopment of site and the re-location Harrow’s retail study rated the development of the existing community uses upon the site, Public prospects of this site as ‘reasonable’ and as Library and Health Care Clinic. Such requirements having medium term availability. The can delay the development process, whereas the site development of a mixed-use scheme which at the Retail Park can accommodate additional retail incorporates replacement library and health floorspace in the short term, assisting the Borough in facilities need not be a significant impediment meeting the retail floorspace requirements specified to retail development. within the 2009 Retail Study and any additional No change. requirements that are likely to arise as a result of the increased population projections within the Borough. Suitability of locations R5 (South Harrow district centre), R6 (Kingsbury district centre) 2.40 RPS challenges the suitability of the location of & R7 (Stanmore district centre) sites R5, R6 and R7 sites for retail development, as they are located within existing District Centres. RPS These sites are ‘within town centre considers that the Retail Park is a more readily boundaries and are therefore sequentially available location to accommodate additional and more preferable to an out of centre retail park replacement retail sales of a convenience or for additional retail development. comparison nature. Furthermore, it is an established Notwithstanding availability, the NPPF does retail location, is easily accessible with minimal not allow for the allocation of out of centre constraints, is within walking distance to the South sites.

104 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Harrow Primary Shopping Area and District Centre, No change. and is adjacent to an existing foodstore.

2.41 The Retail Park is in an out of centre location within close proximity of the South Harrow District Centre and the Primary Shopping Frontage. Furthermore, it is adjacent to an additional retail store that is even close to these allocations. The site is an established retail location capable of accommodating additional retail convenience or comparison floorspace, and should therefore be considered to be a sequentially appropriate location to assist the Council in delivering the retail requirements of the Borough. The site would be able to provide this additional floorspace within the short-term and within the plan period.

2.42 Additional retail floorspace at this location or a relaxation of condition to allow a wider range of goods to be sold from the retail park, is in accordance with the requirements of the NPPF and would support economic growth, sustainable development and job creation.

2.43 A map showing the location of proposed site allocations R1-5 in relation to Northolt Road Retail Park is included at Appendix 2. Site R6 is located in Kingsbury and R7 in Stanmore, further from the Retail Park and so have not been included on the map.

2.44 The DPD also proposes to extend the South Harrow Primary Shopping Area to include part of the frontage along Northolt Road which is currently designated as Secondary Shopping Area to the

105 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er south. It is stated in the report that that this amendment is to provide consistency within the centre, as these frontages were reported in the 2009 RF01: South Harrow revised shopping Retail Study to accommodate key retailers. frontages

2.45 However, RPS considers that the District Centre The revisions to the shopping frontages in should be extended north to include the Northolt South Harrow are supported by Harrow’s Road Retail Park, as this is only 340m from the Retail Study. There is no evidence to support District Centre, and 400m from the Primary Shopping the extension of the district centre to the Area. However, due to the number of retail units Northolt Road Retail Park. It is the opinion of within the Retail Park, the site should be recognised the Council that such an extension would be as a significant shopping location within the area and a contrived rather than an obvious or natural included within the District Centre Allocation. extension of the town centre. No change. 2.46 The Retail Park is an established retail location with associated access/ egress and car parking, the site is a sustainable and highly accessible location; hence the site should be included within the District Shopping Centre designation and further retail floorspace for convenience or comparison goods sales should be supported at this location by the London Borough of Harrow.

2.47 Responses to the individual site allocations within the Pre-Submission consultation document are included in the following chapter.

CONCLUSIONS

2.48 The Retail Park is an established retail location with existing car park and access/egress arrangements that function well. Although by definition within the Development Management Policies document the site is in an out-of-centre location, RPS considers it to be a sustainable out-of-

106 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er centre location that is located within such close Conclusions proximity of an allocated centre. The NPPF does not permit the allocation of 2.49 RPS is of the view that the site is an appropriate out of centre sites and to do so would be at location that is suitable of accommodating odds with Harrow’s Core Strategy. The replacement or additional retail sales of either a relaxation of existing controls over retail sales comparison or convenience nature that would assist on the site should be pursued through the the Borough in meeting the requirements identified in planning application process (with the 2009 Retail Study, and any additional appropriate impact assessment) and not the requirements that will undoubtedly arise as a result of development plan process. the increased population that is anticipated within the No change. Borough.

2.50 Furthermore, additional retail sales at this location would comply with the requirements of the NPPF, supporting growth, economic development and job creation.

2.51 The 2009 Retail Study indicates a total requirement of 44,173sqm retail floorspace by 2025, which is a year short of the plan period. With current commitments and proposed site allocations it is unclear whether this provision can be made, and therefore additional sites need to be considered to ensure this retail requirement can be met.

2.52 A variation of condition to the existing planning permission for the Retail Park to allow the sale of convenience goods, or the reconfiguration of the site to enable an extension of the retail sales area could provide some much needed additional retail floorspace in the area in the short term.

2.53 RPS, therefore, requests that these representations are taken into account in the

107 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er preparation of the DPD, and that the Council considers the suitability of this site for open A1 use to include the sale of convenience goods and to provide additional retail floorspace to meet both the convenience and comparison needs of the Borough. This could be achieved within the short term, within the early stages of the plan period, making the site a more appropriate location than some of the other sites identified within the DPD. 29 04 RPS RF01 Not Not justified The District Centre Yes It is not accepted that the redesignation of 3 Planning & South sou should be extended to part of South Harrow’s district centre Developmen Harro nd include the Northolt frontages from secondary to primary frontage t w Paragraph 2.27 proposes the extension of the South Road Retail Park as it is unsound. The redesignation is justified by (for Pearson district Harrow Primary Shopping Area frontages to the is an established retail evidence and would be effective. Pension centre south along Northolt Road, replacing part of the area location with a range Property which is currently designated as a Secondary of occupiers, is easily Fund) Shopping Area. This is included within the South accessible just off It is not considered that the Site Allocations Harrow District Centre, which extends north of the Northolt Road, and is DPD is the appropriate vehicle for the railway line. only 340m from the consideration of a significant town centre District Centre, and extension; such a substantial change would 400m from the be more appropriately dealt with as part of a The reason given for the change of frontage to Primary review of the Core Strategy. Nevertheless, an Primary Shopping Area is that the 2009 Retail Study Shopping Area. initial assessment would indicate that the found that key national retailers are contained within distance of the site from the centre’s primary this centre. Therefore, the proposed designation and secondary retail frontages, and the amendment is to provide consistency within the physical barrier formed by the Piccadilly line, District Centre. Clearly this would not represent are such that it would not form a natural additional retail floorspace to meet the identified extension to the district centre’s retail need. function. No change. RPS considers that the District Centre should be extended north to include the Northolt Road Retail Park and Waitrose foodstore, as this is only 340m from the District Centre, and 400m from the Primary Shopping Area. Due to the number of retail units 108 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er within the Retail Park, the site should be recognised as a significant shopping location within the area and included within the District Centre. 29 04 RPS R2 Not Not justified RPS therefore Not It is not accepted that the site’s Conservation 4 Planning & Units sou recommends that the stat Area designation need be an impediment to Developmen south nd Site Allocation R2, South of Rayners Lane Station is Northolt Road Retail ed the appropriate redevelopment of this site. t or proposed for 500sqm retail floorspace in addition to Park is considered by The retail floorspace figure is based on the (for Pearson Rayne 15 homes, and is currently in retail use. The location the Council as an Retail Study, but it is acknowledged that the Pension rs of this allocation in relation to the Retail Park is alternative site for net gain would be modest. The Retail Study Property Lane shown at Appendix 2. additional retail indicates that the site could come forward in Fund) Station floorspace the short to medium term. Whilst RPS considers that this site could be (convenience/ appropriate for retail uses due to the current uses comparison) which This is an in-centre site (within the proposed and being within Rayners Lane District Centre, it is could be delivered in primary shopping area) and is therefore recognised that the site is within a Conservation Area the early stages of the sequentially more preferable to the Northolt which could be a constraint to further development of plan period. Road Retail Park, which is out of centre. It is the site. This would not be a net addition to meet not considered that the allocation of the needs for additional retail floorspace. Northolt Road Retail Park (an out of centre location) for additional retail floorspace is justified or consistent with national policy. No change. 29 04 RPS R3 Not Not justified RPS therefore Not This is an edge of centre site (within 300m of 5 Planning & Harro sou recommends that the stat the proposed primary shopping area) and is Developmen w nd Site R3 at Rayners Lane includes the Harrow West Northolt Road Retail ed therefore sequentially more preferable to the t West Conservative Association, Curves Fitness Centre and Park is considered by Northolt Road Retail Park, which is out of (for Pearson Conse Hallmark Cars, all which are currently occupied. The the Council as an centre. It is not considered that the allocation Pension rvative location of this allocation in relation to the Retail Park alternative site for of the Northolt Road Retail Park (an out of Property Associ is shown at Appendix 2. additional centre location) for additional retail floorspace Fund) ation convenience and is justified or consistent with national policy. RPS is aware that the site is surrounded by comparison retail residential properties and is identified in the draft uses including food It is not considered that the site’s flood risk consultation document as being edge-of-centre within sales because the status, nor the mitigation works that would be 300m of a Primary Shopping Area. The site is principle of retail use required, should be a serious impediment to proposed for 1000sqm of convenience retail uses. on the site is already the redevelopment of the site for retail use. 109 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er established due to the No change. However, RPS argues the suitability of the site for units already having additional retail floorspace, due to the site being A1 consent for the currently occupied by other uses, and mitigation that sale of non-food would be required due to the location being in Flood goods. The site is Zone 3A. As the units are currently occupied, and considered an ideal redevelopment would need to demonstrate that the location for additional location would be appropriate for retail use, it is convenience unclear how soon the site would become available floorspace, as the site for retail development. is not within a flood risk area and there are no constraints for the site to provide additional retail floorspace in the early stages of the plan period either through the variation of condition to allow a wider range of goods to be sold from the site, or by the reconfiguration of the site to allow additional floorspace.

29 04 RPS R5 Not Not justified RPS therefore Not The commentary to this allocation confirms 6 Planning & Roxeth sou recommends that the stat that replacement library and health facilities Developmen Library nd Site R5 is currently occupies by Roxeth Library and Northolt Road Retail ed would be sought but this need not be an t & the Health Clinic, and is proposed in the consultation Park is considered by impediment to the appropriate redevelopment (for Pearson Clinic document for 1,000sqm convenience retail the Council as a more of the site. The allocation is supported by the Pension floorspace and 34 new homes. The location of this appropriate Retail Study which recognises that its Property allocation in relation to the Retail Park is shown at alternative site for development prospects are medium term. Fund) Appendix 2. additional retail floorspace including This is in centre site (within the proposed 110 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Whilst the site is within the South Harrow District food sales, as the primary shopping area) and is therefore Centre and would form part of the Primary Shopping principle of retail on sequentially more preferable to the Northolt Area if this is extended, RPS argues the sites the site is already Road Retail Park, which is out of centre. It is suitability for retail uses due to the units being established due to the not considered that the allocation of the currently occupied by community uses. It is units already having Northolt Road Retail Park (an out of centre considered important to retain community uses to A1 consent for the location) for additional retail floorspace is support local communities. sale of non-food justified or consistent with national policy. goods. The site is No change. Therefore, it is expected that these facilities would considered an ideal need to be replaced if the site was redeveloped, for location for additional which the timeframe and viability of doing so is retail floorspace of a unclear. However, the relocation of these valuable convenience or community facilities is important as their loss would comparison nature. be detrimental to the local community and would The site is not within a question the sustainability of the sites redevelopment flood risk area and for retail uses. there are no constraints for the site to provide additional convenience/ comparison floorspace in the early stages of the plan Period.

Respondent 30: Environment Agency

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 04 Environmen R1 Sou We support this site allocation because it includes N/A Not Support noted. However, as the SFRA flood 7 t Agency nd consideration of flood risk in accordance with the stat maps indicate that a substantial extent of Land National Planning Policy Framework. ed the site is within Zone 3A it is proposed to

111 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er betwe delete the residential component of the en allocation, and make consequential High changes to the commentary, as a minor Street modification. and Love Lane

30 04 Environmen R3 Not All of site R3 falls within Flood Zone 3b. In line with Site R3 will need to Not Following further discussion with the 8 t Agency sou the National Planning Policy Framework only water be removed from the stat Environment Agency it has been agreed that Harro nd compatible or essential infrastructure is appropriate site allocations ed previously-developed sites within Zone 3B w within Flood Zone 3b. Retail and residential (both of may be treated as Zone 3A, subject to minor West which are suggested) are not appropriate. modifications to the Development Conse Management Policies DPD to justify this. On rvative this basis the redevelopment of the site for Associ retail use (less vulnerable) is appropriate on ation the site without the need to apply the exception test. No change. 30 04 Environmen EM1 Sou We support this site allocation because it includes N/A Not Noted. 9 t Agency nd consideration of flood risk in accordance with the stat Northo National Planning Policy Framework. We are also ed lt Road satisfied that river restoration is included. Busine ss Use Area 30 05 Environmen EM2 Sou We support this site allocation because it includes N/A Not Noted. 0 t Agency nd consideration of flood risk in accordance with the stat Rayne National Planning Policy Framework. ed rs Lane Offices

112 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environmen EM4 Sou We support this site allocation because it includes N/A Not Noted. 1 t Agency nd consideration of flood risk in accordance with the stat 47-49 National Planning Policy Framework. ed High Street, Edgwa re 30 05 Environmen H7 Sou We support this site allocation because it includes N/A Not Noted. 2 t Agency nd consideration of flood risk in accordance with the stat Forme National Planning Policy Framework. ed r Vaugh an Centre 30 05 Environmen H8 Sou We support this site allocation because it includes N/A Not Noted. 3 t Agency nd consideration of flood risk in accordance with the stat Forme National Planning Policy Framework. ed r Rayne rs Hotel 30 05 Environmen MOS6 Sou We support this site allocation because it includes N/A Not Noted. 4 t Agency nd consideration of flood risk in accordance with the stat Prince National Planning Policy Framework. ed Edwar d Playin g Fields 30 05 Environmen MOS7 Sou We support this allocation as it states development N/A Not Noted. 5 t Agency nd will not prejudice the role of this site as a flood stat Whitch storage area. ed

113 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er urch Playin g Fields (Para 6.17) 30 05 Environmen MOS7 Sou We support this site allocation because it includes N/A Not Noted. 6 t Agency nd consideration of flood risk in accordance with the stat Whitch National Planning Policy Framework. ed urch Playin g Fields (Para 6.18)

Respondent 31: Scott Planning Associates

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 31 05 Scott MOS2 Not Not justified or effective An ecological/habitat Yes In response to this representation which 7 Planning sou survey should be casts doubt on the value of allocating this Associates Land nd The proposal to designate this site as a nature carried out to site as a new nature reserve (confirmed (for Rear reserve appears to have been carried forward from ascertain whether the by the Council’s Biodiversity Officer), and Silveracre of 121- the Unitary Development Plan (2004) without any proposal can be in the absence of evidence about the Estates Ltd.) 255 research into its appropriateness and without any backed up by nature conservation value of the site, it is Pinner agreement from the site owners (delivery partners) or evidence. proposed to omit the site from the DPD as Road discussion with them. a minor modification. It is also noted that Discussions with the a number of individual and groups of Our client (Mr R Parmar of Silveracre Estates Ltd) is owners should be trees on the site are the subject of tree the freehold owner of the above site, and Scott entered into to preservation order protection. ascertain whether the 114 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Planning Associates has been instructed to review proposal is the Site Allocations DPD and submit representations deliverable. on their behalf as part of the Pre-Submission Consultation exercise. Deletion of the site as a Nature Reserve, if We write further to the representations t hat were appropriate. made (on the Representation Form) on 7 September2 012 about the above site and in regard to Policy MOS2. In a telephone conversation the same day Mr. Paterson kindly offered an extension of time (one week) during which further representations could be made. T his letter comprises t hose further representations.

Following further research into the proposed MOS2 designation and the planning history of the site, it still appears that the policy has simply 'evolved' without any robust assessment of the appropriateness of the site for use as a Local Nature Reserve. The site was not designated as a Site of Importance for Nature Conservation (S INC) or a Local Nature Reserve (LNR) in the Unitary Development Plan adopted in 1994, although it is understood that the site was identified as part of a Green Corridor in that plan. In January 1999 a planning application for the 'establishment of a wildlife reserve' on the site was submitted by the Pinner Road and The Gardens Residents Association.

Planning permission was granted in March 1999 but was never implemented and expired in March 2004. Then in July 2004 the replacement UDP identified the site as a proposed nature reserve (PS39).

Despite this, the site has never to our knowledge

115 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er been designated as a SINC for Metropolitan, Borough or Local Importance. nor are we aware that any comprehensive ecological survey has ever been undertaken to discover what features or species of nature conservation interest there may be on the site.

The London Wildlife Site Board published an Advice Note in June 2011 recommending a process for selecting and confirming SINCs in Greater London. The Note explains the roles and responsibilities of London Boroughs and states:

3. The Borough should secure the services of qualified ecologist to survey relevant land within the borough boundary, evaluate this land against the criteria set out in Appendix 1 of this document and provide a set of recommendations on which sites should be accorded S/NC status (and at which grade).

Appendix 1 outlines the policy, criteria and procedures for identifying nature conservation sites in London. In relation to Sites of Local Importance the policy makes it clear that only those sites that make a significant contribution to the ecology of an area should be identified (para. A1 .2.10).

The Department for Environment, Food and Rural Affairs (DEFRA) also published guidance in 2006 on the identification, evaluations, election and management of Local sites of nature conservation interest. The DEFRA guidance encourages the selection of sites on the basis of an assessment against specific criteria (set out in paragraph5 0), and also the early engagement of site owners so as to

116 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er discuss access to a site for a survey and the potential implications of designation an d to offer an opportunity for a site owner to raise any issues (paragraph 33). At the time of writing it is understood that there has been no engagement of the current owners in the process of designating the site as a Local Nature Reserve. This would have been particularly beneficial in view of the statement in the Site Allocations Pre-Submission DPD that:

'The Council may consider enabling residential development on the part of the site fronting The Gardens where this secures the delivery of the rest of the site as a publicly accessible Local Nature Reserve'.

We are aware that these concerns are partly shared by the Herts and Middlesex Wildlife Trust who have made independent representations querying the soundness of allocating this site as a Local Nature Reserve.

Finally, it would appear that there is some confusion as to the precise nature of the MOS2 policy in that it appears in the Open Space chapter of the DPD but not in the Biodiversity chapter, where new sites of nature conservation importance are identified.

Respondent 32: Shweta Kapoor Sharma, Aruna Kapoor, Surinder Kapoor and Munish Sharma

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

117 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 32 05 Shweta G06 Not I am writing regarding the proposal of Housing to be Not stated Not The proposed allocation seeks not only to 8 Kapoor stat built on Brazier stat retain the green open space but also to make Sharma, Kenton ed Dairy (Kenton West) also know as Kenton Lane ed it accessible to the community. It is also Aruna Lane Farm. proposed to retain the heritage buildings. Kapoor, Farm Surinder Writing on behalf and a voice for the residents in the The site allocation does not propose or Kapoor and area of Kenton prescribe a specific design, and assessment Munish Lane, Ivanhoe Drive and Tenby Avenue which all are of impact on neighbouring property would be Sharma affected if this a matter for consideration at pre-application/ (Residents) takes place. planning application stages.

I live on Tenby Avenue and there are many old age However, in response to this pensioners who cannot or not accessible to Internet representation it is proposed to amend and pc's . paragraph 8.17, to highlight the need to achieve a sensitive relationship with On their behalf and my family we totally reject these surrounding dwellings, as a minor plans! modification.

I understand a petition is going around but very last minute. I hope this email will be read as it would be a travesty to have flats and apartments built on that land which is one of the only green spaces left here apart from parks.

I have been living here since 1979 and my family. I was at school when Braziar dairy was the pride of our neighbourhood. We were very disappointed that it closed down and was taken over few years ago. As a child we had educational visits to the dairy as well from school. The Brazier family also lived on our road for many years before moving to the cottage there.

It is a part of our heritage and would be so sad to see a block of flats built. It would be an eyesore, noise pollution disturbances, dirt, block natural light.

118 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Surely somewhere more appropriate can be utilised in the area?

I am sure there are many local residents who also object to this plan. As a resident in this borough all my life I hope we have an opinion that counts and that our voice is heard.

I truly hope the right wise decision will be taken and the plans rejected.

Respondent 33: Susanah E. Greening, George H. Greening & Alice M. Greening

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 33 05 Susanah E. G06 Not My wife, our daughter, and I myself strongly object to Not stated Not Detailed consideration of traffic impacts 9 Greening, stat any such development as planned at Kenton Lane stat would be a matter for consideration at pre- George H. Kenton ed (the old J.H.Brazier Dairy site). We are sure that it ed application/planning application stage (a Greening, Lane would cause too much noise and traffic on a nice high-level transport study underpins the Core and Alice M. Farm quite and peaceful road, and all the local people Strategy and the growth provided for in the Greening would very much regret allowing the council or the spatial strategy). (Residents) government to pass this Planning Application. Within the context of the surrounding residential suburb, the proposed residential allocation is unlikely to significantly increase noise pollution.

No change.

Respondent 34: Thames Water Utilities Ltd. 119

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames Gener Not Not effective or consistent with national policy In light of the above Not The Core Strategy already includes Core 0 Water al sou comments, we stat Policy CS1 Z which requires proposals for Utilities Ltd. nd A key sustainability objective for the preparation of consider that the ed new development to demonstrate that the Local Development Framework/Local Plan should following section adequate capacity exists or can be secured be for new development to be co-ordinated with the should be added to both on and off site to serve the infrastructure it demands and to take into account the the DPD to ensure the development. Core Policy CS1 Z covers all capacity of existing infrastructure. Paragraph 156 of provision of adequate social and physical infrastructure applicable the new National Planning Policy Framework sewerage [and water to development including water supply and (NPPF), March 2012, states: supply] infrastructure sewerage infrastructure. The Council does to service not consider it necessary to repeat the “Local planning authorities should set out development to avoid requirements of this Core Policy again in the strategic policies for the area in the Local Plan. unacceptable impacts Site Allocations DPD, especially where the This should include strategic policies to on the environment effect would be to single out one type of deliver:……the provision of infrastructure for such as low water infrastructure requirement, potentially giving it water supply and wastewater….” pressure, sewage priority over all other infrastructure capacity flooding of residential considerations, such as transport, education, Paragraph 162 of the NPPF relates to infrastructure and commercial healthcare etc, which the Council considers and states: property and pollution should have equal weight. of land and “Local planning authorities should works with watercourses: In light of the representations made by this other authorities to: assess the quality and respondent to the Development Management capacity of infrastructure for water supply and “Water Supply & Policies DPD pre-submission consultation, it wastewater and its treatment…..take account of Sewerage is proposed to modify the reasoned the need for strategic infrastructure including Infrastructure justification to Policy 17 to draw attention to nationally significant infrastructure within their the allocated development sites where areas.” Developers will be Thames Water had raised concerns required to regarding waste water capacity and to demonstrate that highlight the need for the developer to Policy 5.14 of The London Plan, July 2011 is directly prepare a drainage strategy in liaison with relevant as it relates to Water Quality and there is adequate water supply, waste Thames Water, the purpose of which is to Wastewater Infrastructure and states: model the network capacity and ensure that, water capacity and if mitigation is required, this is undertaken surface water ahead of occupation of the development. drainage both on “Strategic The Council therefore considers that the and off the site to 120 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

A - The Mayor will work in partnership with serve the combination of Core Policy CS1 Z and the boroughs, appropriate agencies within development and paragraph 4.20 of the Development London and adjoining local authorities to: that it would not Management Policies DPD adequately addresses the respondent’s concerns. a) ensure that London has adequate and lead to problems for No change appropriate wastewater infrastructure to existing or new

meet the requirements placed upon it by users. In some population growth and climate change circumstances it may be necessary b) protect and improve water quality having for developers to regard to the Thames River Basin fund studies to Management Plan ascertain whether Planning Decisions the proposed development will B - Development proposals must ensure that lead to overloading adequate wastewater infrastructure capacity is available in tandem with development. of existing water Proposals that would benefit water quality, and/or waste water the delivery of the policies in this Plan and infrastructure. the Thames River Basin Management Plan Drainage on the site should be supported while those with must maintain adverse impacts should be refused. separation of foul and surface flows. C - Development proposals to upgrade London’s sewage (including sludge) Further information treatment capacity should be supported for Developers on provided they utilize best available water/sewerage techniques and energy capture. infrastructure can LDF preparation be found on Thames E - Within LDFs boroughs should identify Water’s website at: wastewater infrastructure requirements and http://www.thamesw relevant boroughs should in principle support ater.co.uk/cps/rde/x the Thames Tunnel.” chg/corp/hs.xsl/558. htm Policy 5.15 of the London Plan relates to water use Or contact can be and supplies and states: made with Thames 121 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Water Developer “Strategic Services A The Mayor will work in partnership with By post at: Thames appropriate agencies within London and Water Developer adjoining regional and local planning Services, Reading authorities to protect and conserve water Mailroom, Rose Kiln supplies and resources in order to secure Court, Rose Kiln London’s needs in a sustainable manner by: Lane, Reading RG2 a minimising use of mains water 0BY; b reaching cost-effective minimum leakage By telephone on: levels 0845 850 2777; c in conjunction with demand side measures, Or by email: promoting the provision of additional sustainable water resources in a timely and developer.services efficient manner, reducing the water supply @thameswater.co.u deficit and achieving security of supply in k” London d minimising the amount of energy consumed in water supply e promoting the use of rainwater harvesting and using dual potable and grey water recycling systems, where they are energy and cost-effective f maintaining and upgrading water supply infrastructure g ensuring the water supplied will not give rise to likely significant adverse effects to the environment, particularly designated sites of European importance for nature conservation.

Planning decisions B Development should minimise the use of mains water by: a incorporating water saving measures and

122 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er equipment b designing residential development so that mains water consumption would meet a target of 105 litres or less per head per day.

C New development for sustainable water supply infrastructure, which has been selected within water companies’ Water Resource Management Plans, will be supported.”

Sewerage Comments Due to limited information on the size of proposed developments and the complexities of sewerage networks, Thames Water are unable to clearly determine the infrastructure needs at this stage. Drainage areas do not fit neatly over local authority boundaries and therefore we also need to consider neighbouring boroughs proposed developments as well.

Sewage networks are complex and to determine the impact of development on them often requires detailed modelling to be undertaken which is normally funded by developers. When dealing with large networks that also drain neighbouring boroughs this is further complicated. The enclosed site specific comments have been provided following desktop assessments, but more detailed modelling is required to refine requirements. Thames Water would welcome the opportunity to work closer with Harrow and neighbouring councils to better understand phasing proposals and the potential impact on both

123 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

our water and waste networks

Strategic Comments Thames Water will need to investigate the impact of the proposed development sites on the existing waste water network. Even small infill development and brownfield redevelopment can have a significant impact on the infrastructure and, if necessary, developers would be required to fund impact studies and upgrading of the network.

It is essential that developers demonstrate that adequate capacity exists both on and off the site to serve the development and that it would not lead to problems for existing users. In some circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing water & sewerage infrastructure. Where there is a capacity problem and no improvements are programmed by the water company, then the developer needs to contact the water authority to agree what improvements are required and how they will be funded prior to any occupation of the development.

In very general terms it is quicker to deliver infrastructure on a small number of clearly defined large sites than it is in a large number of small sites, which may not be clearly defined.

It is vital infrastructure in place ahead of development if sewer flooding and low / no water pressure issues are to be avoided. It is also important not to under 124 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

estimate the time required to deliver necessary infrastructure, for example: -local network upgrades take around 18 months - Sewage Treatment & Water Treatment Works upgrades can take 3-5 years - New water resources & treatment works can take 8-10 years 34 06 Thames R4 Not Regarding Chapter 2 Retail Development. We would Not stated Not In light of the representations made by this 1 Water sou have capacity concerns regarding sites R4 and R7 if stat respondent to the Development Management Utilities Ltd. North nd the developments where to be considered for ed Policies DPD pre-submission consultation, it Harro housing. Developer would be required to fund is proposed to modify the reasoned w capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to Metho site upgrades. the allocated development sites where dist Thames Water had raised concerns Churc regarding waste water capacity and to h highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames R7 Not Regarding Chapter 2 Retail Development. We would Not stated Not In light of the representations made by this 2 Water sou have capacity concerns regarding sites R4 and R7 if stat respondent to the Development Management Utilities Ltd. Anmer nd the developments where to be considered for ed Policies DPD pre-submission consultation, it Lodge housing. Developer would be required to fund is proposed to modify the reasoned and capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to Stanm site upgrades. the allocated development sites where 125 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ore Thames Water had raised concerns Car regarding waste water capacity and to Park highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames EM1 Not Regarding Chapter 3 Employment. We would have Not stated Not In light of the representations made by this 3 Water sou capacity concerns regarding all sites EM1 - EM5 if stat respondent to the Development Management Utilities Ltd. Northo nd the developments where to be considered for ed Policies DPD pre-submission consultation, it lt Road housing. Developer would be required to fund is proposed to modify the reasoned Busine capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to ss Use site upgrades. the allocated development sites where Area Thames Water had raised concerns (north) regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

126 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames EM2 Not Regarding Chapter 3 Employment. We would have Not stated Not In light of the representations made by this 4 Water sou capacity concerns regarding all sites EM1 - EM5 if stat respondent to the Development Management Utilities Ltd. Northo nd the developments where to be considered for ed Policies DPD pre-submission consultation, it lt Road housing. Developer would be required to fund is proposed to modify the reasoned Busine capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to ss Use site upgrades. the allocated development sites where Area Thames Water had raised concerns (south) regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames EM3 Not Regarding Chapter 3 Employment. We would have Not stated Not In light of the representations made by this 5 Water sou capacity concerns regarding all sites EM1 - EM5 if stat respondent to the Development Management Utilities Ltd. Ballard nd the developments where to be considered for ed Policies DPD pre-submission consultation, it Mews housing. Developer would be required to fund is proposed to modify the reasoned capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to site upgrades. the allocated development sites where Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the 127 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames EM4 Not Regarding Chapter 3 Employment. We would have Not stated Not In light of the representations made by this 6 Water sou capacity concerns regarding all sites EM1 - EM5 if stat respondent to the Development Management Utilities Ltd. 47-49 nd the developments where to be considered for ed Policies DPD pre-submission consultation, it High housing. Developer would be required to fund is proposed to modify the reasoned Street, capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to Edgwa site upgrades. the allocated development sites where re Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames EM5 Not Regarding Chapter 3 Employment. We would have Not stated Not In light of the representations made by this 7 Water sou capacity concerns regarding all sites EM1 - EM5 if stat respondent to the Development Management Utilities Ltd. 57-59 nd the developments where to be considered for ed Policies DPD pre-submission consultation, it High housing. Developer would be required to fund is proposed to modify the reasoned Street, capacity surveys and possibly be required to fund off justification to Policy 17 to draw attention to Edgwa site upgrades. the allocated development sites where re Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to

128 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames GB1 Not Regarding Chapter 5 Strategic Previously Developed Not stated Not Thames Water had raised concerns 8 Water sou sites in the green belt - We would have capacity stat regarding waste water capacity and to Utilities Ltd. Bentle nd concerns if developments GB1 GB2 or GB3 where to ed highlight the need for the developer to y be considered for housing. Developer would be prepare a drainage strategy in liaison with Priory required to fund capacity surveys and possibly be Thames Water, the purpose of which is to required to fund off site upgrades. model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 06 Thames GB2 Not Regarding Chapter 5 Strategic Previously Developed Not stated Not Thames Water had raised concerns 9 Water sou sites in the green belt - We would have capacity stat regarding waste water capacity and to Utilities Ltd. RNOH nd concerns if developments GB1 GB2 or GB3 where to ed highlight the need for the developer to be considered for housing. Developer would be prepare a drainage strategy in liaison with required to fund capacity surveys and possibly be Thames Water, the purpose of which is to required to fund off site upgrades. model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the

129 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 07 Thames GB3 Not Regarding Chapter 5 Strategic Previously Developed Not stated Not In light of the representations made by this 0 Water sou sites in the green belt - We would have capacity stat respondent to the Development Management Utilities Ltd. Harro nd concerns if developments GB1 GB2 or GB3 where to ed Policies DPD pre-submission consultation, it w be considered for housing. Developer would be is proposed to modify the reasoned Colleg required to fund capacity surveys and possibly be justification to Policy 17 to draw attention to e required to fund off site upgrades. the allocated development sites where Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 34 07 Thames H1 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 1-5 nd Water capability in relation to this site. ed Sudbu ry Hill

34 07 Thames H24 Not On the information available to date we do not N/A Not Noted. 2 Water Sou envisage infrastructure concerns regarding Waste stat

130 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Utilities Ltd. 16-24 nd Water capability in relation to this site. ed Lowlan ds Road

34 07 Thames H20 Not On the information available to date we do not N/A Not Noted. 3 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 19 nd Water capability in relation to this site. ed Buckin gham Road

34 07 Thames H4 Not On the information available to date we do not N/A Not Noted. 4 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 205- nd Water capability in relation to this site. ed 209 Northo lt Road

34 07 Thames H22 Not On the information available to date we do not N/A Not Noted. 5 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 5-11 nd Water capability in relation to this site. ed Manor Road

34 07 Thames H18 Not We have concerns regarding Waste Water Services In this case we ask Not Thames Water had raised concerns 6 Water Sou in relation to this site. Specifically, the sewerage that the following stat regarding waste water capacity and to Utilities Ltd. Edgwa nd network capacity in this area is unlikely to be able to paragraph is included ed highlight the need for the developer to re support the demand anticipated from this in the Development prepare a drainage strategy in liaison with Town development. It will be necessary for us to undertake Plan. “Developers will Thames Water, the purpose of which is to Footba investigations into the impact of the development and be required to model the network capacity and ensure that, completion of this, on average, takes 12 weeks. It demonstrate that if mitigation is required, this is undertaken

131 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ll Club should be noted that in the event of an upgrade to there is adequate ahead of occupation of the development. our assets being required, up to three years lead in waste water capacity The Council therefore considers that the time will be necessary. both on and off the combination of Core Policy CS1 Z and site to serve the paragraph 4.20 of the Development development and that Management Policies DPD adequately it would not lead to addresses the respondent’s concerns. problems for existing No change or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing waste water infrastructure.”

34 07 Thames H23 Not On the information available to date we do not N/A Not Noted. 7 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Forme nd Water capability in relation to this site. ed r Tyneh olme Nurser y

34 07 Thames H13 Not On the information available to date we do not N/A Not Noted. 8 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Jubilee nd Water capability in relation to this site. ed House

132 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H3 Not On the information available to date we do not N/A Not Noted. 9 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 79-89 nd Water capability in relation to this site. ed Greenf ord road

34 08 Thames H14 Not We have concerns regarding Waste Water Services In this case we ask Not In light of the representations made by this 0 Water Sou in relation to this site. Specifically, the sewerage that the following stat respondent to the Development Management Utilities Ltd. Land nd network capacity in this area is unlikely to be able to paragraph is included ed Policies DPD pre-submission consultation, it at support the demand anticipated from this in the Development is proposed to modify the reasoned Stanm development. It will be necessary for us to undertake Plan. “Developers will justification to Policy 17 to draw attention to ore investigations into the impact of the development and be required to the allocated development sites where Station completion of this, on average, takes 12 weeks. It demonstrate that Thames Water had raised concerns should be noted that in the event of an upgrade to there is adequate regarding waste water capacity and to our assets being required, up to three years lead in waste water capacity highlight the need for the developer to time will be necessary. both on and off the prepare a drainage strategy in liaison with site to serve the Thames Water, the purpose of which is to development and that model the network capacity and ensure that, it would not lead to if mitigation is required, this is undertaken problems for existing ahead of occupation of the development. or new users. In some The Council therefore considers that the circumstances it may combination of Core Policy CS1 Z and be necessary for paragraph 4.20 of the Development developers to fund Management Policies DPD adequately studies to ascertain addresses the respondent’s concerns. whether the proposed No change development will lead to overloading of existing waste water infrastructure.”

34 08 Thames H8 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding Waste stat 133 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Utilities Ltd. Forme nd Water capability in relation to this site. ed r Rayne rs Hotel

34 08 Thames H10 Not On the information available to date we do not N/A Not Noted. 2 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. North nd Water capability in relation to this site. ed Harro w Library and Childre n’s Servic es

34 08 Thames H11 Not On the information available to date we do not N/A Not Noted. 3 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Enterp nd Water capability in relation to this site. ed rise House

34 08 Thames H12 Not On the information available to date we do not N/A Not Noted. 4 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Rear nd Water capability in relation to this site. ed of 57- 65 Bridge Street

134 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H19 Not On the information available to date we do not N/A Not Noted. 5 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Hill’s nd Water capability in relation to this site. ed Yard

34 08 Thames H2 Not On the information available to date we do not N/A Not Noted. 6 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 92-116 nd Water capability in relation to this site. ed Greenf ord Road

34 08 Thames H21 Not On the information available to date we do not N/A Not Noted. 7 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Land nd Water capability in relation to this site. ed at Canon s Park Station

34 08 Thames H5 Not On the information available to date we do not N/A Not Noted. 8 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. 1 & 1A nd Water capability in relation to this site. ed Silverd ale Close

34 08 Thames H9 Not On the information available to date we do not N/A Not Noted. 9 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Land nd Water capability in relation to this site. ed at Rayne

135 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er rs Lane Station

34 09 Thames H6 Not On the information available to date we do not N/A Not Noted. 0 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Forme nd Water capability in relation to this site. ed r Matrix P.H.

34 09 Thames H7 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding Waste stat Utilities Ltd. Forme nd Water capability in relation to this site. ed r Vaugh an Centre

Respondent 35: Drivers Jonas Deloitte

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

35 09 Drivers GB2 Not The current Not As explained at Appendix B of the document, 2 Jonas sou We write on behalf of our client, the Royal National Masterplan for the site stat where a site has planning permission for Deloitte RNOH nd Orthopaedic Hospital NHS Trust (the ‘Trust’) to make ed residential development (but has not started) (for Royal representations to the London Borough of Harrow seeks to deliver the site has been allocated in the DPD with National (“LBHarrow”) Local Development Framework (LDF) approximately 300 the corresponding number of homes. orthopaedic Site Allocations Development Plan Document Paragraph 5.7 of the commentary to the Hospital (SADPD) Pre-submission Consultation which ends allocation that the desirability of providing 136 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

NHS Trust) on 7th September 2012. residential dwellings. new hospital accommodation may constitute very special circumstances for enabling development that would otherwise be Accordingly, the Trust Representations have also been prepared on behalf inappropriate development in the Green Belt. of the Trust to the concurrent Development urges the Council to The number of homes cited in the allocation Management Policies DPD Proposed Submission amend Draft Site reflects the approved quantum of enabling Consultation and are submitted under separate Allocation GB2 to development to that end, but the need for any cover. reflect this uplift in increase in the number of homes (and These representations are made with specific consideration of the associated impact upon residential dwellings. reference to Draft Site GB2 ‘Royal National openness) should be formally demonstrated Orthopaedic Hospital, Brockley Hill, Stanmore, HA7 through the planning application process and Since the submission 4LP’. The Trust acknowledges that this stage of not pre-empted by the allocation. It Is not of the former planning consultation seeks to address ‘soundness’ and ‘legal considered that the site allocation, with an application for the compliance’. indicative number of homes, would be an RNOH site, the Trust impediment to a greater residential capacity if has purchased Site Location that is demonstrated to be necessary to additional land to the The RNOH site is located in the LB Harrow, deliver the objective of the replacement north of the site. It is hospital complex. approximately 14 miles North West of central London the intention of the No change. and 9 miles to the south of StAlbans. The immediate Trust to include this area is predominantly countryside and farmland, with area of land within the However, in response to this current proposals to existing residential and Stanmore centre located 1.3 representation it is proposed to amend deliver an important miles to the south. the site boundary, to reflect the up-to-date new public amenity extent of the hospital’s ownership, as a zone. minor modification. It is also proposed to The area is well serviced by major trunk roads with amend the site details to refer to hospital Junction 4 of the M1approximately 0.5 miles to the The site allocation development under ‘other proposed should therefore north and J21 of the M25 approximately 10 miles to uses’. include the site in its the north west of the site. Stanmore Underground entirety and we station is 1.3 miles to the south which provides links append an OS Map into central London on the Jubilee line. Elstree and (Appendix 1) setting Borehamwood Train Station, which provides direct out the extent of the Trust’s land services to St. Albans and Luton Airport to the north ownership, which now and London St. Pancras in 25 minutes, is two miles amounts to 137 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

to the north east. Site plans are included in Appendix approximately 43 hectares. 1 and 2.

Some parts of the site are densely wooded, whilst At present, draft site others are open with the present building stock allocation GB2 refers distributed over a large proportion of the eastern, to residential southern and western parts of the site. development only within the site details. Other than its Green Belt setting, the single most There are no ‘other uses proposed’ within important element of the site is its topography. There this section. The are very significant changes in the levels across the Trust suggests that site and although there are many local variations, the LBH also include general topography has a pronounced fall from south ‘hospital’ development within this section to north, amounting to as much as 20 metres from also. This will both the Wood Lane boundary to the northern edge reflect the abutting the adjacent farmland. redevelopment aspirations for both The open space within the site comprises open hospital and grassland, scrub, orchard, woodland, scattered trees residential development for the and agricultural fields. Trees within the site are site, and ensure subject to a Tree Preservation Order (“TPO”). Part of robustness for this the site lies within a Site of Nature Conservation site allocation. Importance (“SNCI”); a non-statutory designation for an area comprising flora and fauna of regional importance. Part of the site is designated as a Site of Metropolitan Importance

The main site access is from Brockley Hill with additional site access available via entrances on Wood Lane and Warren Lane. Most staff and 138 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

patients travel to the site by private motor vehicle. However Transport for London (‘TfL’) provide a bus service along Brockley Hill that links the hospital to Barnet & Chase Farm Hospitals NHS Trust, Elstree and Borehamwood main line station and Edgware underground station. The 615 Uno bus service has also been recently diverted to stop alongside the rear entrance of RNOH on Wood Lane, and serves Stanmore Station through to Hatfield.

Background The RNOH is the largest orthopaedic hospital in the UK, and is regarded as a leader in the field of orthopaedics both in the UK and world-wide. It provides a comprehensive range of neuro- musculoskeletal healthcare, ranging from acute spinal injuries to orthopaedic medicine and specialist rehabilitation for chronic back sufferers. The broad range of neuro-musculoskeletal services offered at RNOH is unique within the NHS.

However, the existing RNOH facilities no longer meet the current and future operational demands of service provision and patient care. In particular:

. 60% of the site’s current buildings are more than 60 years old;

. The buildings are not energy efficient and the site’s engineering infrastructure 139 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

is out-dated and in need of replacement;

. Car parks are located far from the buildings, which makes access to the hospital buildings difficult for patients;

. Many patient wards were originally designated for temporary war-time use only;

. The main ward areas have a steep slope, which makes transporting patients and equipment difficult; and

. The site layout is not ideal for patient care or staff efficiency as patients and staff frequently have to travel between buildings, often outdoors across uneven ground.

The RNOH site already benefits from an outline planning permission for the redevelopment of the site to provide a new hospital and residential development. This outline planning permission was originally granted in 2007 (reference: P/1704/05/COU) and was for the:

“Partial redevelopment to provide new hospital and associated facilities, housing (including staff), 140 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er revised road junction, car parking and open space.”

However, due to the RNOH Trust being unable to secure the necessary funding from Central Government to bring this development forward, the extant outline consent remained unimplemented and was due to expire on 15 January 2010.

Accordingly, under the planning procedures allowing the extension of the time limits for implementing existing outline planning permissions brought into force on 1st October 2009 (Town and Country Planning (General Development Procedure) (Amendment No.3) (England) Order 2009 (SI No. 2261)) an application to renew this planning permission was submitted in January 2010.

This application was subsequently granted planning permission on 4th June 2010 (ref. P/0083/10), thereby extending the life of the outline planning permission for a further five years (hereafter referred to as the “extant planning permission”).

However, a new outline planning permission is now being prepared as the extant planning permission for the RNOH site no longer secures the best outcome to the Trust.

On behalf of the Trust, and in light of the current

141 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

proposals for the site, we set out below comments on Draft Site Allocation GB2.

Draft Site Allocation GB2 As set out in Draft Site Allocation GB2, the RNOH site is a strategic, previously-developed site within the Green Belt because of the need to secure the modernisation of nationally significant health care facilities. The draft allocation continues to state that the desirability of providing new accommodation for the hospital is a significant consideration and may constitute ‘very special circumstances’ for some enabling development that would other be considered ‘inappropriate development’ in the Green Belt. The acknowledgement of the need for enabling residential development to secure the future operation of the RNOH from this site is supported by the Trust.

On behalf of the Trust, we set out below justification for concerns regarding soundness.

The Trust considers the draft site allocation to be ‘unsound’ as it provides insufficient flexibility for the future aspirations of the Trust to redevelop the site. This is due to the draft site allocation including an out-of-date assumption on the amount of residential dwellings that the site can accommodate. Site Allocation GB2 currently states that the site has the capacity to accommodate 127 dwellings. However, 142 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

this figure is based on the old outline planning application for the site.

Appendix B of the draft SADPD states at paragraph B1 that where pre-application proposals are available and considered reasonable, the relevant housing capacity figures will be used to inform the site allocation.

In light of paragraph B1, we highlight that the Trust has entered into a Planning Performance Agreement (PPA) with LBH in respect of the new development proposals for which the preparation of the planning application is on-going. The PPA acknowledges the shared desire of both the Trust and LBH to secure the future of the RNOH site, and has formed the basis for a series of focussed pre-application workshops that have been held over the past eight months between the Trust and LBH to discuss the redevelopment proposals for the site.

As a result of the focussed workshops, Planner Officers at LBH have contributed to the evolving Masterplan for the site, and we understand they are now broadly supportive of the redevelopment proposals for the site, which include the provision of a new hospital and residential development. The current Masterplan for the site seeks to deliver approximately 300 residential dwellings.

143 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Accordingly, the Trust urges the Council to amend Draft Site Allocation GB2 to reflect this uplift in residential dwellings.

Site Boundary Since the submission of the former planning application for the RNOH site, the Trust has purchased additional land to the north of the site. It is the intention of the Trust to include this area of land within the current proposals to deliver an important new public amenity zone. The site allocation should therefore include the site in its entirety and we append an OS Map(Appendix 1) setting out the extent of the Trust’s land ownership, which now amounts to approximately 43 hectares. Other Proposed Uses At present, draft site allocation GB2 refers to residential development only within the site details. There are no ‘other uses proposed’ within this section. The Trust suggests that LBH also include ‘hospital’ development within this section also. This will both reflect the redevelopment aspirations for both hospital and residential development for the site, and ensure robustness for this site allocation. Summary The Trust is grateful of the opportunity to make representations to this document and would like to be kept updated of future progress with the Harrow LDF.

Respondent 36: Transport for London (Consents Team)

144 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 36 09 Transport Gener Not This letter is submitted on behalf of Transport for N/A Not Noted. See the Council’s response to the 3 for London al stat London (TfL) Property Development in its capacity as stat sites identified in this representation below. (Consents ed the owner of land within the London Borough of ed Team) Harrow, part of which has been identified in the Pre Submission Version of the Site Allocations Development Plan Document (DPD) July- August 2012. Please note that this letter is not TfL‟s response as London‟s transport provider, nor does it represent an indication of the views of the Greater London Authority or of the London Mayor. A separate response dealing with TfL‟s overall operational and land use planning/transport policy matters will be provided by TfL‟s Borough Planning Team. As part of the London Borough of Harrow‟s Development Plan Documents Consultation, July 2012- September 2012, TfL Property has reviewed: Development Management Policies DPD (no comments); and Harrow and Wealdstone Area Action Plan (a separate response will be provided).

This Representation relates solely to proposals and policies set out in the Pre Submission Version of the Site Allocations DPD. TfL has a number of landholdings within the spatial scope of the Document. These are referenced as follows:

Proposal Site H9: Land at Rayners Lane Station, High Worple, Rayners Lane; Proposal Site H13: Jubilee House, Merrion Avenue, Stanmore; Proposal Site H14: Land at Stanmore Station, London Road, Stanmore; and 145 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Proposal Site H21: Land at Canons Park Station, Donnefield Avenue, Canons Park.

Overall, TfL Property supports the principles of the Document and welcomes the inclusion of the above sites, however would like to raise a number of points which are set out below. 36 09 Transport H13 Not TfL Property, in principle supports the inclusion of TfL To ensure the Not In response to this representation, it is 4 for London stat land within Proposal Site H13 (see land ownership Document is effective stat proposed to amplify the commentary of (Consents Jubilee ed plan overleaf). We have undertaken a Feasibility in terms of ed this allocation, to highlight the multiple Team) House Study which suggests a scheme comprising 18 units deliverability, we ownership of the site and, subject to can be delivered on TfL land, this excludes planning would suggest the Policy 41 of the Development consent of 35 units (Planning Reference: P/1220/07) following: Management Policies DPD, to seek a for Jubilee House which remains unimplemented. In a) Paragraph titled comprehensive redevelopment of the light of this, we would suggest a comprehensive ‘Other Uses entire allocated site, as a minor development approach should be considered for the Proposed’ to state ‘a modification. Under ‘other proposed uses’ site, a point which is not currently considered in the comprehensive make reference to a comprehensive Document. This will ensure any scheme brought development redevelopment scheme securing an forward is both viable and deliverable. scheme’. appropriate quantum of replacement b) Paragraph titled employment floorspace where this is ‘Number of Units’ to necessary to comply with Policy 41 of the state ‘minimum 35’. Development Management Policies DPD.

Paragraph B1 (page 251) of the DPD confirms that the housing capacity attributed to each site is indicative, not prescriptive. Therefore, for consistency with the format of the rest of the document, it is not proposed to add minimum to the site details. 36 09 Transport H14 Not Proposal Site H14 suggests that 44 residential units It is recommended Not In response to this representation, it is 5 for London Land stat will be delivered on the site in conjunction with an that the housing stat proposed to revise paragraph 4.35 of the (Consents at ed appropriate amount of station car parking. TfL capacity of 44 units is ed commentary, as a minor modification, to Team) Stanm Property supports ‘in principle’ the designation in revised to ensure a give greater clarity to the relationship ore particular the retention of some level of commuter scheme comprising between the amount of car parking to be

146 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Station parking however would advise that current housing residential units and re-provided and the number of residential capacity 44 units is undeliverable for the site. the retention of an units that will need to be accommodated appropriate provision in the delivery of this allocation, TfL produced a Feasibility Study which demonstrates of commuter parking recognising that the stated figure of 44 that a residential led scheme comprising 132 can be delivered on units is indicative and that a greater residential units and commuter car parking can be the site. This will also residential capacity may be acceptable, delivered on the site. The Council suggested through ensure that the subject to design and layout the supporting text in strategy but forward is considerations, to secure a feasible Proposal Site H14 that an ‘appropriate amount of the most appropriate scheme. station car parking’ will need to be retained, a point strategy for the site. which we support and have incorporated in the draft However, the representation implies a 25% Feasibility Study, details of which we are happy to We recommend the reduction in car parking capacity justified by share with you. The current commuter parking following: the feasibility study. As the starting point, the equates to 487 spaces. The Feasibility Study a) remove reference Council would expect the current level of car demonstrated that a significant amount of commuter to 44 units and parking to be re-provided; any reduction parking can be accommodated on the site, equating replace with would need to be justified by evidence of to a retention factor of approximately 85%. However, ‘approximately 100 demand sought in paragraph 4.35 of the this level of units’. commentary. commuter car parking can only be delivered through the construction of a decked structure. The cost associated with this structure is significant and can only be funded by the scheme. To deliver the Council’s aspiration of an appropriate level of commuter car parking and 44 units is unviable and thus undeliverable. 36 09 Transport H9 Not N/A Not Noted. TfL Property welcomes and supports the „principle‟ 6 for London Land stat of residential development of Site Proposals H9 and stat (Consents at ed H21. ed Team) Rayne rs Lane Station 36 09 Transport H21 Not N/A Not Noted. TfL Property welcomes and supports the „principle‟ 7 for London Land stat of residential development of Site Proposals H9 and stat 147 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er (Consents at ed H21. ed Team) Canon s Park Station

Respondent 37: Marion Garner-Patel

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 37 09 Mrs Marion G03 Not Not justified, consistent with national policy or Harrow is deficient in Not The allocation contained in the DPD reflects 8 Garner- sou positively prepared. open space. We refer legal the planning history for this site, following Patel St. nd to paras 5.33, 5.34 which there is an approved scheme for (Resident) Georg We refer to St. George’s Playing Field I Appeal & II and 5.35. There is a residential development to enable the e’s Appeal. Both Inspectors made decision on premise shortage of hockey remainder of the field to be restored as open Playin that the tennis courts were NOT part of open space. and junior football space that is accessible to the community. g Field Consideration and misunderstanding on how the pitches. The planning The allocation also amends the open space tennis and cricket clubs over 75 years old were permission will be designation to cover the full extent of the treated and evicted not taken into account. hopefully overturned tennis courts. by a judicial review. No change. We hope that the whole of St. George’s Playing Field will be reinstated as opens pace and once more open to the parishioners who bought it in 1923. Harrow is meeting housing targets. Why build on open space?

Reason for

148 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er attendance at oral examination: To explain the background, history and how the community of Headstone have fought hard to preserve the whole open space of St. George’s Headstone Playing Fields. All evidence is available on the town green documents application held by the Council and the two appeals.

Respondent 38: Sandra-Lee Palmer

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 38 09 Sandra-Lee G03 Not I should like to submit my combined comments Not stated Not Harrow’s Core Strategy, adopted February 9 Palmer stat regarding green open spaces in Harrow in this letter, stat 2012, provides a clear policy basis for the (Resident) St. ed which falls under Policy 25. ed protection of open space and for directing Georg new development to brownfield land. e’s In my opinion it Is absolutely vital that ALL existing However the decisions referred to, including Playin open spaces, parks, playing fields, sports grounds that of the subject site, pre-date the Core g Field and the like are fully protected from any Strategy but were made in the context of the development. Since the 1980s we have seen far too Harrow Unitary Development Plan (2004),

149 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er many green open spaces lost to medium and high the remaining saved provisions of which will density development projects to the detriment of the be superseded upon the adoption of the local residents, old and new. With an ever-increasing Development Management Policies DPD population and fewer properties with a reasonably (and the AAP in respect of the Intensification sized garden, we are in desperate need of open Area). In the case of Kodak the open space spaces where residents of all ages can go to benefit is to be re-provided (and increased) as well from individual and team sports and recreational as finding of improvements that will increase activities. Open spaces are places where residents the carrying capacity of existing sports can go, indeed should go, to bond with their facilities. neighbours. Youngsters should be encouraged to be active and providing sports grounds in a clean and The allocation contained in the DPD reflects safe environment is key to achieving this. the planning history for this site, made under previous development plan policies, but The primary concern of Harrow Council must be the following which there is nonetheless an residents who live and will live in the immediate approved scheme for residential vicinity, not the developers or religious groups from development to enable the remainder of the outside the area that wish to build on green open field to be restored as open space that is space rather than the many unused brownfield sites accessible to the community. in the borough, both small and large. In such cases No change. the sole beneficiaries are the applicants, because they always place their needs and profit targets before any possible advantage to the community.

Two controversial decisions to build on playing fields in Harrow are the Krishna-Avanti Primary School on the William Ellis Playing Field and 27 houses and flats on St George’s Playing Field. Residents fought very hard against developments on these green open spaces with full justification, but lost to the incorrect findings of the Planning Inspector. I hope that this consultation process is genuine and the Council will adopt a policy that fundamentally protects all open space in the borough, which is national and local planning policy.

150 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er It is essential that the policy should not depend on how or when publicly or privately owned open spaces are used, or if they have been used at all in the past few years, as it is well known that owners often deliberately prevent the use of open spaces in order to justify the sale of the land. The important factor to remember is that ALL open spaces are vital to the enlarged and diverse communities and hence they have an inherent value to the neighbourhood that cannot be underestimated or even ignored.

There is a notice outside St George’s Playing Field regarding the designation of the open space as part residential and part public open space. I believe that there is a genuine deficiency of open space, sport and recreation grounds in the area when the existing and future population is considered. The enclosed open land is suitable for both children and adult team activities. Hence the entire area of St George’s Playing Field should be designated public or private open space for sports or recreational activities only. Similarly, the Old Lyonians Sports ground, also in Pinner View, but a larger field, is ideal for children and team sports. Both grounds have been used for decades for this purpose and the numerous new flats in the area clearly demonstrate the continued need.

151 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Kodak. Why build on green open space and then expect people, especially young people, to use Headstone Manor that is oversubscribed after 4pm and at the weekends or to travel to the Roger Bannister sports ground that is some distance away? This is complete folly.

I trust Harrow Council will take my comments seriously and construct a comprehensive planning policy that protects ALL green open space for the present and future.

Respondent 39: Mrs. Nkansa-Dwamena

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 39 10 Mrs. G06 Not We, the owners of 43 Tenby Avenue, would like to Not stated Not The site allocation does not propose or 0 Nkansa- stat register formally our concerns about the planning stat prescribe a specific design, and assessment Dwamena Kenton ed application for the Brazier's Dairy site in Kenton ed of impact on neighbouring property would be (Resident) Lane Lane. included in the Council's Site Allocations a matter for consideration at pre-application/ Farm Development Plan Document. We wish our planning application stages. Any planning comments to be taken into consideration as part of application would be subject to public the Pre-Submission Consultation, which closes on consultation with surrounding residents. 7th September. However, in response to this representation it is proposed to amend Having read the DPD, we can see that it is paragraph 8.17, to highlight the need to thoughtfully and sensitively written to respect the achieve a sensitive relationship with heritage of the Brazier's Farm buildings. However, surrounding dwellings, as a minor we believe the document is deficient in some areas. modification.

Our concerns are as follows: Within the context of the surrounding

152 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er PRIVACY. The design of any new development residential suburb, the proposed residential should reflect the right to privacy of the properties allocation is unlikely to significantly increase that back onto the site. We would like explicit light, noise and dust pollution. reassurance that no new building will overlook our garden or other private gardens backing onto the The commentary to the allocation requires site. We ask that any development erected should the design and layout of development to respect our right to privacy by not overshadowing the enhance the setting of the listed buildings on garden or creating a loss of privacy by allowing new the site. residential properties to have a direct view into our garden and house. Detailed consideration of traffic impacts LIGHT POLLUTION. Similarly, given that our son's would be a matter for consideration at pre- bedroom is at the rear of our property, we ask that application/planning application stage (a any development of the site is designed to minimize high-level transport study underpins the Core light pollution. We would strongly oppose any plans Strategy and the growth provided for in the that directed electronic light towards our property - spatial strategy). either from external street lamps or internal residential lighting facing onto the rear of our Increased residential presence on the site property. may be expected to increase natural PRESERVING LOCAL HERITAGE. Our strong view, surveillance, and therefore security. Detailed which appears to have been reflected in the tone of consideration of crime prevention measures the DPD, is that the design and appearance of any can form part of the assessment of any new buildings should not undermine the historic subsequent planning application. character of the Brazier's farm buildings, which are of significance to the heritage of the local area. We ask that any new development is also in keeping with the style of the 1930s residential properties that surround it. SENSIBLE PLANNING AND DESIGN. The layout and density of the development should not be overly congested, and care should be taken to ensure that plans are sympathetic to the impact on the residents of the properties that back onto the site. For example, we would oppose any development that placed communal rubbish collection receptacles next to the boundaries of our property.

153 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er CRIME PREVENTION. The Kenton and Belmont area has been the target of burglaries in recent years. Our own house was broken into from the rear of the property last January. The Police who visited the scene suggested that the low visibility caused by garages combined with the shared driveways between properties may have contributed. We would hope that any development of the Brazier's Dairy site would incorporate the principles of Situational Crime Prevention so as not to inadvertently create more opportunities for criminals to access the properties of Tenby Avenue. TRAFFIC AND PARKING. Traffic and parking problems in the Belmont and Kenton area have increased in recent years. We welcome the decision not to cultivate the front of the farm buildings for parking but would hope that consideration has been given to ensuring that there is adequate parking for the residents and guests of any new development on the site. MINIMIZING OTHER INCONVENIENCES. We ask any new development does not create additional inconveniences for the residents of Tenby Avenue by, for example, causing excessive dust or noise outside of usual working hours, or by closing access to Kenton Lane or Tenby Avenue for significant periods of time. REGULAR UPDATES. We would ask that the residents of Tenby Avenue are updated in writing when key decisions are made relating to this development and when periods of engagement, such as consultations, are open. Many residents are elderly and not all have access to the internet.

Respondent 40: Mr. Nkansa-Dwamena 154

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 40 10 Mr. Nkansa- G06 Not We, the owners of 43 Tenby Avenue, would like to Not stated Not The site allocation does not propose or 1 Dwamena stat register formally our concerns about the planning stat prescribe a specific design, and assessment Kenton ed application for the Brazier's Dairy site in Kenton ed of impact on neighbouring property would be Lane Lane. included in the Council's Site Allocations a matter for consideration at pre-application/ Development Plan Document. We wish our planning application stages. Any planning comments to be taken into consideration as part of application would be subject to public the Pre-Submission Consultation, which closes on consultation with surrounding residents. 7th September. However, in response to this representation it is proposed to amend Having read the DPD, we can see that it is paragraph 8.17, to highlight the need to thoughtfully and sensitively written to respect the achieve a sensitive relationship with heritage of the Brazier's Farm buildings. However, surrounding dwellings, as a minor we believe the document is deficient in some areas. modification.

Our concerns are as follows: Within the context of the surrounding PRIVACY. The design of any new development residential suburb, the proposed residential should reflect the right to privacy of the properties allocation is unlikely to significantly increase that back onto the site. We would like explicit light, noise and dust pollution. reassurance that no new building will overlook our garden or other private gardens backing onto the The commentary to the allocation requires site. We ask that any development erected should the design and layout of development to respect our right to privacy by not overshadowing the enhance the setting of the listed buildings on garden or creating a loss of privacy by allowing new the site. residential properties to have a direct view into our garden and house. Detailed consideration of traffic impacts LIGHT POLLUTION. Similarly, given that our son's would be a matter for consideration at pre- bedroom is at the rear of our property, we ask that application/planning application stage (a any development of the site is designed to minimize high-level transport study underpins the Core light pollution. We would strongly oppose any plans Strategy and the growth provided for in the that directed electronic light towards our property - spatial strategy). either from external street lamps or internal residential lighting facing onto the rear of our Increased residential presence on the site property. may be expected to increase natural PRESERVING LOCAL HERITAGE. Our strong view, surveillance, and therefore security. Detailed

155 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er which appears to have been reflected in the tone of consideration of crime prevention measures the DPD, is that the design and appearance of any can form part of the assessment of any new buildings should not undermine the historic subsequent planning application. character of the Brazier's farm buildings, which are of significance to the heritage of the local area. We ask that any new development is also in keeping with the style of the 1930s residential properties that surround it. SENSIBLE PLANNING AND DESIGN. The layout and density of the development should not be overly congested, and care should be taken to ensure that plans are sympathetic to the impact on the residents of the properties that back onto the site. For example, we would oppose any development that placed communal rubbish collection receptacles next to the boundaries of our property. CRIME PREVENTION. The Kenton and Belmont area has been the target of burglaries in recent years. Our own house was broken into from the rear of the property last January. The Police who visited the scene suggested that the low visibility caused by garages combined with the shared driveways between properties may have contributed. We would hope that any development of the Brazier's Dairy site would incorporate the principles of Situational Crime Prevention so as not to inadvertently create more opportunities for criminals to access the properties of Tenby Avenue. TRAFFIC AND PARKING. Traffic and parking problems in the Belmont and Kenton area have increased in recent years. We welcome the decision not to cultivate the front of the farm buildings for parking but would hope that consideration has been given to ensuring that there is adequate parking for the residents and guests of any new development on

156 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er the site. MINIMIZING OTHER INCONVENIENCES. We ask any new development does not create additional inconveniences for the residents of Tenby Avenue by, for example, causing excessive dust or noise outside of usual working hours, or by closing access to Kenton Lane or Tenby Avenue for significant periods of time. REGULAR UPDATES. We would ask that the residents of Tenby Avenue are updated in writing when key decisions are made relating to this development and when periods of engagement, such as consultations, are open. Many residents are elderly and not all have access to the internet.

Respondent 41: English Heritage

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 41 10 English Gener Not We are encouraged by the referencing of heritage Not stated Not Consideration of locally listed buildings did 2 Heritage al stat assets that are associated with each site. Albeit, it is stat form part of the preparation of the Site ed not clear whether all relevant locally listed buildings ed Allocations DPD (see for example site H14: have been identified. For example they are not land at Stanmore station). It Is not necessary identified as a category under ‘Planning to cross-reference all other planning Designations’. documents in the Site Allocations DPD as these will form part of the planning framework However to aid understanding of the proximity of in their own right where relevant to the assets it would be useful to annotate each site map development of a site. Similarly requirements with the relevant heritage assets. In addition as a for s.106 funding can be determined under general point, we would encourage you, as part of relevant Development Management policies demonstrating a positive strategy for the at the time that development proposals on conservation of the historic environment (NPPF para allocated sites come forward. Development

157 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 126) that the significance of all relevant heritage Plan policy on tall buildings is adequately assets are summarised. For example if a site falls addressed in the London Plan, the Harrow & within or is adjacent to a conservation area, the Wealdstone Area Action Plan and the relevant headline details of the conservation area Development Management Policies DPD. It appraisal and management plan should be is not necessary to prescribe building heights expressed and applied to the site. This approach for sites allocated in the Site Allocations would help ensure that the significance of the DPD. conservation area is understood and used to inform how the site could be developed. However, in response to this representation the citation of heritage As previously expressed in our letter (dated 28th assets for each of the development sites June 2011) to the Draft version, we would also urge has been reviewed and the following you to highlight in the body of the text the opportunity clarifications/additions are proposed as a of using S106 funding to help enhance the historic minor modification to the DPD: environment, in particular where Heritage Assets are at Risk. Making this reference would help contribute R1: part within Pinner High Street towards the Council’s commitment to a positive Conservation Area; adjacent nos. 7, 9, 11 strategy for the conservation of the Borough’s historic and 25 grade II listed environment. R2: also opposite 462-472 (even) locally In addition we would reiterate our expectation that listed and former Ace Cinema grade II* greater clarity is given in the commentary on whether listed any of the sites identified are considered appropriate for tall buildings on not. In some cases building EM1: adjacent Royal British Legion Club heights have been provided, but others this locally listed information is missing. We would therefore encourage you for the purposes of consistency and EM2: adjacent Rayners Lane Public House clarity provide details of [sic] If so, then the scale, grade II listed form and height of development considered appropriate for the site should be clearly detailed, EM3: adjacent nos. 99/101 High Street and supported by robust thorough evidence, in line with telephone kiosks (on pavement) grade II CABE/EH Guidance on Tall Buildings (2007). This listed includes evidence of modelling and analysis of the site, its surroundings and impact upon heritage EM5: adjacent nos. 63, 65 & 67 grade II assets. listed

158 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

H15: adjacent Church St. William of York grade II listed

H17: opposite St. John the Evangelist & Old Stanmore Church both grade II* listed

GB2: Hospital lodge buildings and roadside wall/gates locally listed

G04: adjacent nos. 151-153, 161-163, Arts & Crafts Block and Henry Jones Gymnasium locally listed

MOS4: adjacent Glenthorne Lodge locally listed (listing refers also to cast iron entrance gates) 41 10 English G06 Not We would ask you to consider the comments we Not stated Not The letter referred to finds that the pre- 3 Heritage Kenton stat provided in response to a pre-application request for stat application proposals would harm the setting Lane ed advice for the residential development of Kenton ed of the listed buildings, by introducing a farm Farm. Our letter of response (dated 27th July 2011) suburban character to the site, and that the raised concerns related to the scale of development case for enabling development has not been proposed and its impact upon the grade II listed demonstrated. building, associated buildings and their settings. With The above comments relate to a specific, this in mind we welcome the reference made in the pre-application proposal. The support for the ‘commentary’ for the need for new developments to commentary included in the allocation, enhance the setting of the listed buildings. relating to the setting of the listed buildings, is noted. No change. 41 10 English Chapt Not In line with our previous comments it is not clear Not stated Not The basis for open space designations in 4 Heritage er 6 stat whether all of the open space designations have stat Chapter 6 is explained at paragraph 6.4 of ed been informed by the London Parks and Gardens ed the DPD, i.e. informed by Harrow’s PPG 17 Inventory of green spaces and parks. It would be Study (and not the Inventory referred to). useful to get clarity on this point.

159 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er However as the minor open space In addition the level of detail provided with regards to designations are included simply to update the heritage value of opens spaces is still variable, in the open spaces designation on the Policies the case of the Major Open Spaces. In the case of Map and do not contain specific proposals Minor Open Spaces the no details are provided. As (i.e. for new public access) it is not necessary raised before some of these open spaces are of to identify the heritage value of these sites. historic importance of contribute to the significance of No change. heritage assets. For example Site OS01: St Mary’s Church Yard, Harrow on the Hill, is covered by a number of heritage designations, such as the setting to the Church (grade I), include a number of listed structures (e.g. grave stone of Thomas Port – grade II, Lynch Gate - grade II), setting to other neighbouring listed buildings (e.g. Harrow School Speech Room – grade II*) and falls within the Harrow on the Hill Conservation Area. These are sensitivities which should be raised in the commentary for all of the Minor Open Spaces where relevant. 41 10 English MOS3 Not Planning Designation & Commentary – West Drive Not stated Not In response to this representation it is 5 Heritage stat conservation Area should be explicitly named and stat proposed to amend the planning Harro ed commentary given that the open space is an integral ed designations section and commentary of w part of the areas designation as a heritage assets. site MOS3 to identify the name of the Weald relevant conservation area. Park

41 10 English MOS4 Not Planning Designation & Commentary – For Not stated Not In response to this representation it is 6 Heritage stat completeness purposes, the grading of Bentley stat proposed to amend the planning Glenth ed Priory Historic park and garden should be stated ed designations and commentary section of orne (grade II), plus the commentary should recognise the site MOS4 to identify the grading of the value of this designation, in that this open space has adjacent Bentley Priory open space. historic interest which should be carefully managed. 41 10 English Sustai N/A In line with the above comments, providing further N/A N/A Noted. However it is not considered 7 Heritage nability detail with regards to the significance of heritage necessary to map the heritage assets in the

160 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Apprai assets that may be affected by each site allocation document to achieve this end. sal should help improve the scoring given. The extra understanding provided and illustration of each site map of where relevant heritage assets are would ensure the sustainability objective of conserving the historic environment is fully met.

Respondent 42: Petition (53 signatories)

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 42 10 Petition (53 G06 Not This is a petition against the development of Not stated Not Noted. 8 signatories) stat houses at Kenton Lane Farm, Kenton Lane, stat No change. Kenton ed Harrow HA3 8RT ed Lane Farm We, the undersigned, are concerned citizens who urge our leaders to act now to stop the planning and development of houses at the above site.

Respondent 43: Mr. J. Welby

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 43 10 Mr. J. Welby H14 Not A new point I would like to raise is the Local Not stated Not The commentary to the site allocation 9 (Resident) stat Development Plan, which has a date of reply of stat explains that the site is allocated for partial Land ed 7th September. There are issues which need ed redevelopment, with an appropriate amount at addressing. Stanmore and Canons Park of station car parking to be retained, Stanm Stations car parks which would be replaced by recognising its role for commuters and during

161 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ore housing. Wembley stadium events. It goes on to state Station that any planning application for the In respect of Stanmore the car park was full redevelopment of the site should be H21 during the Olympics and afterwards would be supported by evidence of car parking 50% to 75% full and if this scheme goes ahead demand, and how that demand will be met, Land with less car space there is nowhere else to by the re-provision of car parking on the site at park as the council put in place a CPZ to keep or elsewhere. Canon cars off the streets. People come from all over No change. s Park the country to park there as it is very costly in Station Wembley.

43 11 Mr. J. Welby H20 Not I spoke to Councillor Davine on Friday about a Not stated Not The relevant planning history section of this 0 (Resident) stat decision concerning Buckingham Road ex stat allocation notes the details of the recently 19 ed Council premises where a planning application ed refused application relating to this site. Buckin was turned down on the 12th July and she was No change. gham not consulted, This property is now scheduled Road for housing and community use.

43 11 Mr. J. Welby H19 Not The following premises are all scheduled for Not stated Not Harrow’s Employment Land Study identifies 1 (Resident) stat housing and are not suitable as it would cause stat an existing surplus of business and industrial Hill’s ed unemployment and demolition of existing ed use land in the Borough, and projects a Yard buildings: requirement to release 44,600m2 floorpsace  Bacon Lane, Edgware (employment over the period 2007-2026. As a site that is approx 50 people). not designated for business and industrial From what I have seen of the LDF Plan Harrow use, the release of the site for residential is taking over land for housing where there is accords with the Core Strategy sequential definite need on these sites and the prices approach for the managed release of surplus would exceed £200,000 each. premises. In view of the relationship of the site with surrounding residential property, and its poor location, the site is not considered suitable for mixed-use development to provide diversified employment opportunities.

The London Plan and Development 162 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Management Policies DPD provide the framework for securing affordable housing from development sites.

No change. 43 11 Mr. J. Welby EM4 Not The following premises are all scheduled for Not stated Not The site is allocated for employment-led, 2 (Resident) stat housing and are not suitable as it would cause stat mixed-use redevelopment to secure modern 47-49 ed unemployment and demolition of existing ed office or other business use/employment High buildings: generating floorspace. Street  High Street, Edgware (Safe Storage and VIP Lounge, VIP Lounge is a prty The London Plan and Development centre for weddings and conferences Management Policies DPD provide the on Sunday 27th August there was an framework for securing affordable housing Indian wedding with over 100 people from development sites. including an Indian drum band of 12. Generally it is used 7 days a week). No change. From what I have seen of the LDF Plan Harrow is taking over land for housing where there is definite need on these sites and the prices would exceed £200,000 each. 43 11 Mr. J. Welby EM3 Not The following premises are all scheduled for Not stated Not The site is allocated for employment-led, 3 (Resident) stat housing and are not suitable as it would cause stat mixed-use redevelopment to secure modern Ballard ed unemployment and demolition of existing ed office or other business use/employment Mews buildings: generating floorspace.  Ballards Mews, Edgware (offices and workshops employing over 50 people). The London Plan and Development From what I have seen of the LDF Plan Harrow Management Policies DPD provide the is taking over land for housing where there is framework for securing affordable housing definite need on these sites and the prices from development sites. would exceed £200,000 each. No change.

Respondent 44: C. D. Noyce

163

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 44 11 C. D. Noyce H9 Not I note the proposal for the Rayners Lane Not stated Not The commentary to the site allocation 4 (Councillor) stat Station car park to be allocated, as I stat explains that the site is allocated for partial Land ed understand it, for housing. ed redevelopment, with an appropriate amount at of station car parking to be retained, Rayne I would oppose such an allocation of a recognising its role for commuters and during rs previously allocated site because the loss of Wembley stadium events. It goes on to state Lane car parking which is already at a premium. Not that any planning application for the Station only do commuters use the car park Monday to redevelopment of the site should be Friday but it tends to be used all week as supported by evidence of car parking people utilize the car parking to make good the demand, and how that demand will be met, deficiencies in the area. by the re-provision of car parking on the site or elsewhere. In my considered opinion not only would the No change. car parking have to be replaced should any substantive planning application be made but there would be problem as the station car park is already the overfill parking capacity for the area.

Respondent 45: Three Rivers District Council

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 45 11 Three Gener Not Three Rivers has no comment to make on the N/A Not Noted. 5 Rivers al stat proposed submission document. stat District ed ed Council

164

165 Appendix L: Responses to the Pre-Submission Site Allocations DPD Consultation – Document Order

Whole document

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 01 Mayor of Gener Yes Having reviewed the allocations GLA officers N/A Yes The finding of general conformity with the 7 London al (In are content that the pre-submission document (In London Plan is noted. gen is in general conformity with the London Plan. gen No change. eral Nevertheless, detailed representations eral conf intended to clarify or improve detail within the conf ormi document are provided within Appendix 2 and ormi ty must be taken into account as part of these ty with representations. with the the Lon Lon don don Plan Plan ) ) 13 01 Mayor of Gener Yes The Council is advised that any site within Amend commentary for Yes In response to this representation it is 9 London al (In close proximity to London Underground sites in close proximity to (In proposed to amend the commentary of gen infrastructure (including sub-surface London Underground gen sites R2, H9, H12, H13, H14, H21 and eral infrastructure) will require early consultation infrastructure to highlight eral MOS6, to highlight the need for conf with TfL’s London Underground Infrastructure need for early consultation conf consultation with TfL, as a minor ormi Protection team. with TfL’s infrastructure ormi modification. ty protection team. ty See proposed minor modifications numbered with This particularly applies to sites at or adjacent with SA14, SA31, SA32, SA33, SA40 the to Rayners Lane, Canons Park and Stanmore the Lon London Underground stations. TfL would Lon don welcome a reference to this in the supporting don Plan commentary to relevant sites. Plan ) ) 13 02 Mayor of Gener Yes The Council may wish to use the supporting Amend commentary for Yes Proposed Policy 53 of the Development 0 London al (In commentary to the site allocations to specify sites in high PTAL areas to (In Management Policies DPD sets out the 166 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er gen instances where it would support proposals for support car free gen circumstances for considering car-free eral car free development, in areas of high public development. eral proposals, including public transport capacity, conf transport accessibility. conf trip generation and the adequacy of ormi ormi surrounding parking controls. Therefore the ty ty appropriateness of car-free development with with should be a proposal-specific matter rather the the than a matter for the Site Allocations DPD. Lon Lon No change. don don Plan Plan ) ) 34 06 Thames Gener Not Not effective or consistent with national policy In light of the above Not The Core Strategy already includes Core 0 Water al sou comments, we consider that stat Policy CS1 Z which requires proposals for Utilities Ltd. nd A key sustainability objective for the the following section should ed new development to demonstrate that preparation of the Local Development be added to the DPD to adequate capacity exists or can be secured Framework/Local Plan should be for new ensure the provision of both on and off site to serve the development to be co-ordinated with the adequate sewerage [and development. Core Policy CS1 Z covers all infrastructure it demands and to take into water supply] infrastructure social and physical infrastructure applicable account the capacity of existing infrastructure. to service development to to development including water supply and Paragraph 156 of the new National Planning avoid unacceptable impacts sewerage infrastructure. The Council does Policy Framework (NPPF), March 2012, states: on the environment such as not consider it necessary to repeat the low water pressure, sewage requirements of this Core Policy again in the “Local planning authorities should set out flooding of residential and Site Allocations DPD, especially where the strategic policies for the area in the Local commercial property and effect would be to single out one type of Plan. This should include strategic policies pollution of land and infrastructure requirement, potentially giving it to deliver:……the provision of watercourses: priority over all other infrastructure capacity infrastructure for water supply and considerations, such as transport, education, wastewater….” “Water Supply & healthcare etc, which the Council considers Sewerage Infrastructure should have equal weight. Paragraph 162 of the NPPF relates to infrastructure and states: Developers will be In light of the representations made by this respondent to the Development Management “Local planning authorities should works required to demonstrate Policies DPD pre-submission consultation, it with other authorities to: assess the quality that there is adequate water supply, waste water is proposed to modify the reasoned and capacity of infrastructure for water justification to Policy 17 to draw attention to 167 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

supply and wastewater and its capacity and surface the allocated development sites where treatment…..take account of the need for water drainage both on Thames Water had raised concerns strategic infrastructure including nationally and off the site to serve regarding waste water capacity and to significant infrastructure within their the development and that highlight the need for the developer to areas.” it would not lead to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to problems for existing or new users. In some model the network capacity and ensure that, Policy 5.14 of The London Plan, July 2011 is circumstances it may be if mitigation is required, this is undertaken directly relevant as it relates to Water Quality necessary for developers ahead of occupation of the development. The Council therefore considers that the and Wastewater Infrastructure and states: to fund studies to combination of Core Policy CS1 Z and ascertain whether the paragraph 4.20 of the Development proposed development “Strategic Management Policies DPD adequately will lead to overloading of addresses the respondent’s concerns. A - The Mayor will work in partnership existing water and/or No change with the boroughs, appropriate waste water agencies within London and adjoining infrastructure. Drainage local authorities to: on the site must maintain a) ensure that London has adequate separation of foul and and appropriate wastewater surface flows. infrastructure to meet the requirements placed upon it by population growth Further information for and climate change Developers on water/sewerage b) protect and improve water quality infrastructure can be having regard to the Thames River found on Thames Water’s Basin Management Plan website at: Planning Decisions http://www.thameswater.c o.uk/cps/rde/xchg/corp/hs. B - Development proposals must ensure that adequate wastewater xsl/558.htm infrastructure capacity is available in Or contact can be made tandem with development. Proposals with Thames Water that would benefit water quality, the Developer Services delivery of the policies in this Plan and By post at: Thames Water the Thames River Basin Management Developer Services, 168 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Plan should be supported while those Reading Mailroom, Rose with adverse impacts should be Kiln Court, Rose Kiln refused. Lane, Reading RG2 0BY; C - Development proposals to upgrade By telephone on: 0845 850 London’s sewage (including sludge) 2777; treatment capacity should be Or by email: supported provided they utilize best developer.services@tham available techniques and energy eswater.co.uk” capture. LDF preparation E - Within LDFs boroughs should identify wastewater infrastructure requirements and relevant boroughs should in principle support the Thames Tunnel.”

Policy 5.15 of the London Plan relates to water use and supplies and states:

“Strategic A The Mayor will work in partnership with appropriate agencies within London and adjoining regional and local planning authorities to protect and conserve water supplies and resources in order to secure London’s needs in a sustainable manner by: a minimising use of mains water b reaching cost-effective minimum leakage levels c in conjunction with demand side measures, promoting the provision of additional sustainable water resources in a timely and efficient manner,

169 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er reducing the water supply deficit and achieving security of supply in London d minimising the amount of energy consumed in water supply e promoting the use of rainwater harvesting and using dual potable and grey water recycling systems, where they are energy and cost-effective f maintaining and upgrading water supply infrastructure g ensuring the water supplied will not give rise to likely significant adverse effects to the environment, particularly designated sites of European importance for nature conservation.

Planning decisions B Development should minimise the use of mains water by: a incorporating water saving measures and equipment b designing residential development so that mains water consumption would meet a target of 105 litres or less per head per day.

C New development for sustainable water supply infrastructure, which has been selected within water companies’ Water Resource Management Plans, will be supported.”

Sewerage Comments Due to limited information on the size of

170 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

proposed developments and the complexities of sewerage networks, Thames Water are unable to clearly determine the infrastructure needs at this stage. Drainage areas do not fit neatly over local authority boundaries and therefore we also need to consider neighbouring boroughs proposed developments as well.

In very general terms it is quicker to deliver infrastructure on a small number of clearly defined large sites than it is in a large number of small sites, which may not be clearly defined.

It is vital infrastructure in place ahead of development if sewer flooding and low / no water pressure issues are to be avoided. It is also important not to under estimate the time required to deliver necessary infrastructure, for example: -local network upgrades take around 18 months - Sewage Treatment & Water Treatment Works upgrades can 172 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

take 3-5 years - New water resources & treatment works can take 8-10 years 36 09 Transport Gener Not This letter is submitted on behalf of Transport N/A Not Noted. See the Council’s response to the 3 for London al stat for London (TfL) Property Development in its stat sites identified in this representation below. (Consents ed capacity as the owner of land within the ed Team) London Borough of Harrow, part of which has been identified in the Pre Submission Version of the Site Allocations Development Plan Document (DPD) July- August 2012. Please note that this letter is not TfL‟s response as London‟s transport provider, nor does it represent an indication of the views of the Greater London Authority or of the London Mayor. A separate response dealing with TfL‟s overall operational and land use planning/transport policy matters will be provided by TfL‟s Borough Planning Team. As part of the London Borough of Harrow‟s Development Plan Documents Consultation, July 2012- September 2012, TfL Property has reviewed: Development Management Policies DPD (no comments); and Harrow and Wealdstone Area Action Plan (a separate response will be provided).

173 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Proposal Site H9: Land at Rayners Lane Station, High Worple, Rayners Lane; Proposal Site H13: Jubilee House, Merrion Avenue, Stanmore; Proposal Site H14: Land at Stanmore Station, London Road, Stanmore; and Proposal Site H21: Land at Canons Park Station, Donnefield Avenue, Canons Park.

Overall, TfL Property supports the principles of the Document and welcomes the inclusion of the above sites, however would like to raise a number of points which are set out below. 41 10 English Gener Not We are encouraged by the referencing of Not stated Not Consideration of locally listed buildings did 2 Heritage al stat heritage assets that are associated with each stat form part of the preparation of the Site ed site. Albeit, it is not clear whether all relevant ed Allocations DPD (see for example site H14: locally listed buildings have been identified. For land at Stanmore station). It Is not necessary example they are not identified as a category to cross-reference all other planning under ‘Planning Designations’. documents in the Site Allocations DPD as these will form part of the planning framework However to aid understanding of the proximity in their own right where relevant to the of assets it would be useful to annotate each development of a site. Similarly requirements site map with the relevant heritage assets. In for s.106 funding can be determined under addition as a general point, we would relevant Development Management policies encourage you, as part of demonstrating a at the time that development proposals on positive strategy for the conservation of the allocated sites come forward. Development historic environment (NPPF para 126) that the Plan policy on tall buildings is adequately significance of all relevant heritage assets are addressed in the London Plan, the Harrow & summarised. For example if a site falls within Wealdstone Area Action Plan and the or is adjacent to a conservation area, the Development Management Policies DPD. It relevant headline details of the conservation is not necessary to prescribe building heights area appraisal and management plan should for sites allocated in the Site Allocations be expressed and applied to the site. This DPD. approach would help ensure that the 174 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er significance of the conservation area is However, in response to this understood and used to inform how the site representation the citation of heritage could be developed. assets for each of the development sites has been reviewed and the following As previously expressed in our letter (dated clarifications/additions are proposed as a 28th June 2011) to the Draft version, we would minor modification to the DPD: also urge you to highlight in the body of the text the opportunity of using S106 funding to R1: part within Pinner High Street help enhance the historic environment, in Conservation Area; adjacent nos. 7, 9, 11 particular where Heritage Assets are at Risk. and 25 grade II listed Making this reference would help contribute towards the Council’s commitment to a positive R2: also opposite 462-472 (even) locally strategy for the conservation of the Borough’s listed and former Ace Cinema grade II* historic environment. listed

In addition we would reiterate our expectation EM1: adjacent Royal British Legion Club that greater clarity is given in the commentary locally listed on whether any of the sites identified are considered appropriate for tall buildings on not. EM2: adjacent Rayners Lane Public House In some cases building heights have been grade II listed provided, but others this information is missing. We would therefore encourage you for the EM3: adjacent nos. 99/101 High Street and purposes of consistency and clarity provide telephone kiosks (on pavement) grade II details of [sic] If so, then the scale, form and listed height of development considered appropriate for the site should be clearly detailed, EM5: adjacent nos. 63, 65 & 67 grade II supported by robust thorough evidence, in line listed with CABE/EH Guidance on Tall Buildings (2007). This includes evidence of modelling H15: adjacent Church St. William of York and analysis of the site, its surroundings and grade II listed impact upon heritage assets. H17: opposite St. John the Evangelist & Old Stanmore Church both grade II* listed

GB2: Hospital lodge buildings and

175 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er roadside wall/gates locally listed

G04: adjacent nos. 151-153, 161-163, Arts & Crafts Block and Henry Jones Gymnasium locally listed MOS4: adjacent Glenthorne Lodge locally listed (listing refers also to cast iron entrance gates) See proposed minor modifications numbered SA10, SA13, SA23, SA24, SA26, SA27, SA38, SA39, SA48, SA59, SA68 45 11 Three Gener Not Three Rivers has no comment to make on the N/A Not Noted. 5 Rivers al stat proposed submission document. stat District ed ed Council

Chapter 1: Introduction

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 01 Mayor of 1.1 Yes The plan’s aim to promote the viability and N/A Yes Noted. 8 London (In vitality of town centres, along with ensuring (In No change. gen effective use of previously developed sites gen eral within the borough is strongly supported. eral conf conf ormi ormi ty ty with with the the Lon Lon don don Plan Plan 176 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ) ) 13 02 Mayor of Gener Yes Officers would welcome an acknowledgement Amend the DPD to cross Yes In response to this representation it is 4 London al (In within this DPD that Harrow's waste sites will refer to the allocating role of (In proposed to amend paragraph 1.4, to gen be identified within the West London Waste the West London Waste gen ‘signpost’ the West London Waste DPD, eral Authority Waste Site DPD. DPD. eral as a minor modification. conf conf See proposed minor modification SA1 ormi ormi ty ty with with the the Lon Lon don don Plan Plan ) )

Chapter 2: Retail

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 29 04 RPS Gener Not INTRODUCTION Not 2 Planning & al stat stat Developmen ed 1.1 RPS Planning and Development (RPS) has ed t been instructed by the Pearson Pension (for Pearson Property Fund Ltd (the Fund) to prepare Pension representations to the London Borough of Property Harrow Site Allocations Pre-Submission (DPD) Fund) consultation document, in respect of their land and property interests at Northolt Road Retail Park (the Retail Park), South Harrow, shown as the land within the blue line on the plan at Appendix 1.

177 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 1.2 The Retail Park lies just outside of the South Harrow District Centre and includes three units which have A1 consent including the sale of non-food comparison goods. The units are currently occupied by Dreams, Dunelm Mill and Staples.

1.3 The Council is currently consulting on the draft DPD until the 7 September 2012, which runs alongside pre-submission consultations on the Harrow and Wealdstone Area Action Plan, and the Development Management and Policies Development Plan Document, to which separate representations have been made. These representations promote the suitability of the Retail Park site for the provision of additional retail floorspace and for the provision of convenience floorspace as replacement of the existing comparison floorspace.

1.4 The following chapter provides details about Northolt Road Retail Park, and our

comments in response to specific policies within the DPD consultation document are

provided in Chapter 3 and are set out in the same format as the Council’s response forms.

1.5 RPS is willing to meet with Planning Officers from Harrow Council concerning the Fund’s interests at the Retail Park in contributing towards the Council’s requirements for additional retail floorspace (comparison or convenience) across the Borough.

178 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

NORTHOLT ROAD RETAIL PARK

Northolt Road Retail Park

2.1 The Retail Park which the Fund has interests in extends to approximately 6,782sqm of retail floorspace, and lies approximately 340m to the north-west of South Harrow District Centre, and close to the centres of Rayners Lane and Roxeth.

2.3 The Retail Park initially was two units but Unit 2 gained consent on the 20 March 2008 to

subdivide the retail unit to provide the current three units which are occupied by Staples,

Dreams and Dunelm Mill.

2.4 The site is adjacent to an existing Waitrose foodstore although this is not part of the site

owned by the Fund and is not subject to these representations.

Suitability for Additional or Alternative Suitability for Additional or Alternative Retail Floorspace Retail Floorspace

179 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2.5 The Retail Park is in a sustainable and The NPPF defines edge of centre sites (for highly accessible location in South Harrow with retail purposes) as those well connected and a Transport for London PTAL rating of 3. up to 300m from the primary shopping area Accessibility to the site is good with the Retail and it is noted that the part of the Retail Park Park being situated off the A312 Northolt to which this representation relates is furthest Road, approximately 340m north-west of South away from the town centre (would require Harrow District Centre boundary, and 400m pedestrians to walk across the extensive from the Primary Shopping Frontage along surface car park). Therefore the site should Northolt Road. be treated as ‘out of centre’.

2.6 There are a number of bus stops along Northolt Road and Shaftesbury Avenue, which run adjacent to the site, the closest being approximately 400m away. The site is also only approximately 400m from South Harrow tube station and the Piccadilly Line, and is approximately 2km from Northolt Park Railway Station to the south west and Harrow-on-the- Hill Railway Station to the north-east.

2.7 The Retail Park is an existing established

retail location, due to the current retail uses and adjacent foodstore, and should be

recognised as an appropriate location for providing additional and alternative comparison

and convenience retail floorspace to meet the anticipated population and expenditure increase within the plan period.

180 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er highly appropriate for the sale of convenience goods either in addition to or as an alternative to the sale of comparison goods.

PLANNING POLICY

National Planning Policy Framework National Planning Policy Framework

2.10 It needs to be borne in mind that National The NPPF continues the established Planning Policy Framework (NPPF), as did principle of ‘town centre first’. It is clear from

previous guidance, includes retail development paragraph 23 that, if sufficient sites cannot be within the description of economic allocated within or at the edge of town

development. centres, then policies should be set to meet needs in other accessible locations. i.e. out of

2.11 As such retail development is a key part centre sites should not be allocated. See the in securing economic growth in order to create retail note at the end of this schedule. jobs and prosperity. The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should

181 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.

2.12 To help achieve economic growth, Local Planning Authorities should plan proactively to meet the development needs of business and support an economy which would include need for additional retail floorspace.

2.14 In ensuring the vitality of town centres planning policies should be positive, promote

competitive town centre environments and set out policies for the management and growth of

centres over the plan period. In drawing up Local Plans, Local Planning Authorities:

should allocate a range of suitable sites to meet the scale and type of retail development needed in town centres. It is important that

needs for retail are met in full and are not compromised by limited site availability;

undertake an assessment of the need to expand town centres to ensure a sufficient

182 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er supply of suitable sites; allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre where suitable and viable town centre sites are not available. If sufficient edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are well connected to the town centre; and set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.

included in the plan.

2.16 Local Planning Authorities should set out the strategic priorities for the area in the Local Plan, provision of retail, leisure and other

commercial development.

2.17 Crucially, Local Plans should: plan positively for the development and It is considered that the infrastructure required in the area to meet the Retail Park is a suitable and objectives, principles and policies of this sustainable location for Framework; additional retail sales be drawn up over an appropriate time scale, including the sale of food, 183 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er preferably a 15-year time horizon, take account compared with other of longer term requirements, and be kept up to identified sites within the date; DPD be based on co-operation with neighbouring authorities, public, voluntary and private sector organisations; indicate broad locations for strategic development on a key diagram and land-use designations on a proposals map; and allocate sites to promote development and flexible use of land, bringing forward new land where necessary, and provide detail on form, scale, access and quantum of development where appropriate;

2.18 In respect of using a proportionate evidence base, NPPF states that each Local Planning Authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing,

employment and other uses are integrated, and that they take full account of relevant

market and economic signals.

2.19 Local Planning Authorities should have a clear understanding of business needs within

the economic markets operating in and across their area.

2.20 Local Planning Authorities should use this evidence base to assess:

184 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

the needs for land or floorspace for economic development, including both the quantitative and qualitative needs for all foreseeable types of economic activity over the plan period, including for retail and leisure development; the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time as, or combined with, Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of previously allocated land; the role and function of town centres and the relationship between them, including any trends in the performance of centres; the capacity of existing centres to accommodate new town centre development;

2.21 The NPPF accepts out-of-centre sites as legitimate locations for retail use in the

absence of suitable and available Town Centre or edge-of-centre sites. Evidence Base

Evidence Base It is observed following this

2.22 The 2009 Harrow Retail Study undertaken representation that paragraph 2.4 (second bullet) of the DPD erroneously attributes by Nathanial Lichfield and Partners (NLP), which updated a 2006 study, predicts that the new supermarket to Neptune Point (already taken into account in the Retail there will be a retail requirement of 38,912sqm net comparison and 5,261sqm net Study) and not to Harrow View. It is therefore proposed to correct this text as convenience floorspace by 2025. We have not critically analysed the Evidence Base and the a minor modification. following comments are based on its published See proposed minor modification SA5

185 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er findings. The Retail Study is not out of date. It was 2.23 As indicated in the Site Allocations published in the autumn of 2009 and was Development Plan Document, the additional used as part of the evidence base for the requirement excludes the following approvals: Core Strategy which was found sound in Extension of Tesco store, Station Road of 2011 and adopted early 2012. Paragraph 2,368sqm net comparison and 651sqm net 18.36 of the report recommends that the convenience floorspace; Study should be updated in four to five years’ Neptune Point supermarket of 3440sqm time, i.e. 2013-2014. For the purposes of the gross convenience and 560sqm gross DPDs currently being prepared the existing comparison floorspace; and Study is adequate, remains sufficiently up to 1,000sqm A1-A5 uses at Harrow View, date and is relevant. Wealdstone. 2.24 It is evident that the balance for additional retail floorspace needs to be identified by the Council which should be included in the DMP document.

comparison goods floorspace to be provided within the plan period. The Core Strategy target is for 6,050 homes over the plan period (2009-2026), and

2.26 The Harrow Core Strategy 2012 indicates reconciliation of the difference between the housing target and ONS household a requirement of 3,250 new homes to be built between 2009 and 2026. However, the ONS projections is explained at paragraph 4.12 of the Core Strategy. It is not the role of the Household Projections to 2033 (CLG) predicts a population increase of 26,000 people for examination into the Site Allocations DPD to Harrow between 2008 and 2028. re-open this issue.

Meeting the Need Meeting the Need

2.27 The DPD proposes seven retail site The retail note at the end of this schedule

186 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er allocations which would provide a total of sets out how the pipeline supply of retail approximately 8,500sqm retail floorspace development and allocations in the Site within the plan period to 2026, which states at Allocations DPD and the AAP meets and paragraph 2.5 that these will include exceeds the projected need for additional convenience and non-major comparison goods convenience retail floorspace over the period floorspace. These allocations in addition to the 2009-2025, and how the need for comparison recent approvals, detailed above, could retail floorspace will be met over the short to provide approximately 16,000sqm of retail medium term (2009-2020) and the policy floorspace. provisions made in the event of longer term need being realised (2020-2025). 2.28 Whilst it is acknowledged that some of the proposed requirement of 5,261sqm convenience floorspace may be met through site allocations and commitments, it is unclear whether this requirement will be fully met.

2.29 The Harrow and Wealdstone Area Action Plan proposes to allocate a number of sites to contribute towards major comparison retail sales and additional convenience, clearly acknowledging that these sites are not suitable

for major comparison floorspace. The NPPF requires that Local Planning Authorities ‘should

allocate a range of suitable sites to meet the scale and type of retail development needed…’

2.30 Due to the vagueness of allocations in the RPS, therefore, requests Area Action Plan in respect of location, area, that these representations net floorspace, suitability, viability and mix of are taken into account in the uses proposed, it is not considered that these preparation of the DPD, and sites, other than the commitments, should be In response to this representation, to that the Council considers considered as contributing to the identified provide greater clarity on how retail the suitability of this site for need, and should be regarded as windfall sites. development needs are to be met, it is open A1 use to include the proposed to revise the introductory text to sale of convenience goods 2.31 It is unclear whether the Council could Chapter 2 as a minor modification to the and to provide additional 187 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er accommodate all of the required 44,173sqm on retail floorspace to meet DPD. the proposed site allocations and existing both the convenience and See proposed minor modifications SA5 & commitments, and therefore additional sites comparison needs of the SA6 should be considered in addition to these to Borough. This could be ensure that the Borough’s future retail needs achieved within the short The Council can demonstrate a sufficient are met. term, within the early stages supply of pipeline and allocated sites to meet of the plan period, making and exceed the projected need for 2.32 It is considered that the Retail Park is a the site a more appropriate convenience retail floorspace over the period suitable and sustainable location for additional location than some of the 2009-2025. The NPPF does not allow for the retail sales including the sale of food, other sites identified within allocation of out of centre sites, but instead compared with other identified sites within the the DPD. No change. states that any needs that cannot be met in- DPD. centre should be provided for through policies. No change. SITE ALLOCATIONS

The DPD proposed seven retail allocations, six Site Allocations of which are to be for mixed use development including retail, and one solely for retail use. R1: High Street/Love Lane, Pinner

2.34 It is recognised that a number of the sites Retail development is a less vulnerable use identified in the DPD are currently in use as and therefore is not inappropriate on a Flood other non retail land uses. Zone 3A site, and does not require exception testing (note however that it is proposed to 2.35 RPS consider sites R1, R2, R3 and R4 of omit the residential component of this the proposed site allocations, which are allocation as a minor modification). allocated for retail development are unlikely to No change. be redeveloped for retail uses within the early stages of the plan period and that the Retail R2: Units South of Rayners Lane Station Park site at South Harrow is a more readily available location to accommodate additional Harrow’s Retail Study rated the development or alternative retail floorspace. prospects of this site as ‘good’ and as having short-medium term availability. The 2.36 Many of the sites are currently occupied production of a design which preserves or which would undoubtedly delay the timeframe enhances the conservation area need not be in which the retail floorspace would become a significant impediment to retail

188 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er available, and it is debateable as to whether development. this could be undertaken within the plan period. No change.

2.37 Sites R1 and R3 are within flood zones R3: Harrow West Conservative Association which would require mitigation to be suitable for retail use. Site R2 falls within a Following discussions with the Environment Conservation Area, thus the design of the retail Agency and subject to minor modifications to proposal would need to be sympathetic to the the Development Management Policies DPD aesthetic quality of the area and as a result this it has been agreed that previously-developed could be a costly and time consuming exercise sites within Zone 3B may be treated as Zone for a developer. It is also recognised that Site 3A. Retail development is a less vulnerable R4 is also outside of the local District Centre use and therefore is not inappropriate on a as is the site at Northolt rd Retail Park. Flood Zone 3A site, and does not require However, the North Harrow Methodist Church exception testing. that currently occupies the site would need to No change. be replaced if the site was to be redeveloped; thus again complicating the development R4: North Harrow Methodist Church process which will inevitably delay the site in coming forward soon for retail development. Harrow’s Retail Study rated the development prospects of this site as ‘reasonable’ and as 2.38 Site R5 is proposed for 1,000sqm of retail having medium term availability. This site is uses in addition to housing, which is identified considered to be edge of centre (not out of in the DPD as a possible single convenience centre) within the NPPF definitions. The store, several small retail units or an extension development of a mixed-use scheme which to the existing Sainsbury’s store. The site is incorporates replacement community within the South Harrow District Centre and facilities need not be a significant impediment Primary Shopping Area. Sites R6 and R7 are to retail development. However, it should be also within District Centres and within 300m of noted that in response to representations Primary Shopping Areas. Site R6 is proposed from the site owner it is proposed to move for 1,000sqm for a large supermarket or retail the allocation from the ‘retail’ chapter to the warehouse. ‘other’ chapter of the DPD, and make the provision of replacement place of worship/ Site R7 is also proposed for a retail warehouse community facilities the focus of the or foodstore. allocation. No change.

189 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2.39 Site R5 is within close proximity of our client’s site and as stated above it falls within R5: Roxeth Library and Clinic the District centre and the primary Shopping Frontage, nonetheless, a retail proposal at this Harrow’s retail study rated the development location would require the redevelopment of prospects of this site as ‘reasonable’ and as site and the re-location of the existing having medium term availability. The community uses upon the site, Public Library development of a mixed-use scheme which and Health Care Clinic. Such requirements can incorporates replacement library and health delay the development process, whereas the facilities need not be a significant impediment site at the Retail Park can accommodate to retail development. additional retail floorspace in the short term, No change. assisting the Borough in meeting the retail floorspace requirements specified within the Suitability of locations R5 (South Harrow 2009 Retail Study and any additional district centre), R6 (Kingsbury district centre) requirements that are likely to arise as a result & R7 (Stanmore district centre) of the increased population projections within the These sites are ‘within town centre Borough. boundaries and are therefore sequentially more preferable to an out of centre retail park 2.40 RPS challenges the suitability of the for additional retail development. location of sites R5, R6 and R7 sites for retail Notwithstanding availability, the NPPF does development, as they are located within not allow for the allocation of out of centre existing District Centres. RPS considers that sites. the Retail Park is a more readily available No change. location to accommodate additional and replacement retail sales of a convenience or comparison nature. Furthermore, it is an established retail location, is easily accessible with minimal constraints, is within walking distance to the South Harrow Primary Shopping Area and District Centre, and is adjacent to an existing foodstore.

2.41 The Retail Park is in an out of centre location within close proximity of the South

190 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Harrow District Centre and the Primary Shopping Frontage. Furthermore, it is adjacent to an additional retail store that is even close to these allocations. The site is an established retail location capable of accommodating additional retail convenience or comparison floorspace, and should therefore be considered to be a sequentially appropriate location to assist the Council in delivering the retail requirements of the Borough. The site would be able to provide this additional floorspace within the short-term and within the plan period.

2.44 The DPD also proposes to extend the South Harrow Primary Shopping Area to include part of the frontage along Northolt Road which is currently designated as Secondary Shopping Area to the south. It is stated in the report that that this amendment is

191 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er to provide consistency within the centre, as these frontages were reported in the 2009 Retail Study to accommodate key retailers.

2.45 However, RPS considers that the District RF01: South Harrow revised shopping Centre should be extended north to include the frontages Northolt Road Retail Park, as this is only 340m from the District Centre, and 400m from the The revisions to the shopping frontages in Primary Shopping Area. However, due to the South Harrow are supported by Harrow’s number of retail units within the Retail Park, Retail Study. There is no evidence to support the site should be recognised as a significant the extension of the district centre to the shopping location within the area and included Northolt Road Retail Park. It is the opinion of within the District Centre Allocation. the Council that such an extension would be a contrived rather than an obvious or natural 2.46 The Retail Park is an established retail extension of the town centre. location with associated access/ egress and No change. car parking, the site is a sustainable and highly accessible location; hence the site should be included within the District Shopping Centre designation and further retail floorspace for convenience or comparison goods sales should be supported at this location by the London Borough of Harrow.

2.47 Responses to the individual site allocations within the Pre-Submission consultation document are included in the following chapter.

CONCLUSIONS

2.48 The Retail Park is an established retail location with existing car park and access/egress arrangements that function well. Although by definition within the Development

192 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Management Policies document the site is in an out-of-centre location, RPS considers it to be a sustainable out-of-centre location that is located within such close proximity of an allocated centre. Conclusions 2.49 RPS is of the view that the site is an appropriate location that is suitable of The NPPF does not permit the allocation of accommodating replacement or additional out of centre sites and to do so would be at retail sales of either a comparison or odds with Harrow’s Core Strategy. The convenience nature that would assist the relaxation of existing controls over retail sales Borough in meeting the requirements identified on the site should be pursued through the in the 2009 Retail Study, and any additional planning application process (with requirements that will undoubtedly arise as a appropriate impact assessment) and not the result of the increased population that is development plan process. anticipated within the Borough. No change.

2.50 Furthermore, additional retail sales at this location would comply with the requirements of the NPPF, supporting growth, economic development and job creation.

2.52 A variation of condition to the existing planning permission for the Retail Park to allow the sale of convenience goods, or the reconfiguration of the site to enable an

193 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er extension of the retail sales area could provide some much needed additional retail floorspace in the area in the short term.

2.53 RPS, therefore, requests that these representations are taken into account in the preparation of the DPD, and that the Council considers the suitability of this site for open A1 use to include the sale of convenience goods and to provide additional retail floorspace to meet both the convenience and comparison needs of the Borough. This could be achieved within the short term, within the early stages of the plan period, making the site a more appropriate location than some of the other sites identified within the DPD.

Site: R1 Land between High Street and Love Lane, Pinner

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 26 03 Pinner R1 Not We refer to your Site Allocations DPD Change ‘Barter’s Walk’ to Not In response to this representation it is 9 Association stat (paragraphs 2.11 and 2.12 and associated ‘Bishop’s Walk’ stat proposed to amend the site boundary to Land ed plan and aerial photograph) in which you have ed exclude Beaumont Mews and to correct betwe included a proposal to designate an area paragraph 2.12 to refer to Bishop’s Walk en between the High Street and Love Lane in instead of Barter’s Walk as minor High Pinner as being suitable for development. Omit Beaumont Mews from modifications. Street the allocation. See proposed minor modification SA12 and We have the following observations on this Love proposal: The limitation of the site access is recognised Lane and, to this end, paragraph 2.12 of the Your text states the site includes Barters Walk. Omit the entire allocation commentary already refers to the need to

194 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er This is quite wrong. It should refer to Bishops unless improved vehicular ensure safe and effective vehicular access Walk instead. Barters Walk is on the other access to the site can be from Love Lane. Additional text to amplify side of the High Street. achieved. this issue is proposed as part of the minor modifications to the DPD. Also, in The site is shown as including the modern self- response to this representation and for contained residential development known as consistency with the summary table at the Beaumont Mews. We can see no justification end of chapter 2, it is proposed to reduce for including it within a potential new the potential retail foorspace of the site development site. from 1,500m2 to 1,000m2 as a minor modification. The present vehicular access for the proposed See proposed minor modification SA9 development site on to Love Lane is between No.1 Love Lane and the end of Red Lion Parade and is very poor. Large delivery vehicles such as those which serve Marks & Spencer now have to make multi-point turns in an area which is already extremely congested with traffic and parked vehicles, often to the point of becoming jammed. Indeed jams also occur in this area without vehicles delivering to the site becoming involved because of the volume of traffic and both legal and illegal parking on both sides of Love Lane. Adding substantial retail development into this mix would be a recipe for even more traffic chaos.

The sight line to the right for a vehicle leaving the present access in forward gear is very poor and hazardous. This is because of the way No.1 Love Lane projects so far forward.

The present access point itself is also very close to the large roundabout in Bridge Street which also exacerbates the traffic problems in the area.

195 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Unless an improved vehicular access point can be obtained which eliminates or substantially reduces the hazards mentioned above we would not favour any scheme which would increase the traffic currently using the present access point. Within the constraints that the existing buildings fronting Love Lane impose it is hard to see where any improved access point could be sited. The High Street is a Conservation Area with Listed Buildings and therefore no vehicular access could be created from this side of the site.

For the above reasons we contend that this site is not one which is currently, or even prospectively, suitable for development as proposed. 30 04 Environment R1 Sou We support this site allocation because it N/A Not Support noted. However, as the SFRA flood 7 Agency nd includes consideration of flood risk in stat maps indicate that a substantial extent of Land accordance with the National Planning Policy ed the site is within Zone 3A it is proposed to betwe Framework. delete the residential component of the en allocation, and make consequential High changes to the commentary, as a minor Street modification. and See proposed minor modification SA9 Love Lane

Site: R2 Units south of Rayners Lane Station on Alexandra Avenue, Rayners Lane

196 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 29 04 RPS R2 Not Not justified RPS therefore recommends Not It is not accepted that the site’s Conservation 4 Planning & Units sou that the Northolt Road Retail stat Area designation need be an impediment to Developmen south nd Site Allocation R2, South of Rayners Lane Park is considered by the ed the appropriate redevelopment of this site. t or Station is proposed for 500sqm retail Council as an alternative The retail floorspace figure is based on the (for Pearson Rayne floorspace in addition to 15 homes, and is site for additional retail Retail Study, but it is acknowledged that the Pension rs currently in retail use. The location of this floorspace (convenience/ net gain would be modest. The Retail Study Property Lane allocation in relation to the Retail Park is comparison) which could be indicates that the site could come forward in Fund) Station shown at Appendix 2. delivered in the early stages the short to medium term. of the plan period. Whilst RPS considers that this site could be This is an in-centre site (within the proposed appropriate for retail uses due to the current primary shopping area) and is therefore uses and being within Rayners Lane District sequentially more preferable to the Northolt Centre, it is recognised that the site is within a Road Retail Park, which is out of centre. It is Conservation Area which could be a constraint not considered that the allocation of the to further development of the site. This would Northolt Road Retail Park (an out of centre not be a net addition to meet needs for location) for additional retail floorspace is additional retail floorspace. justified or consistent with national policy. No change.

Site: R3 Harrow West Conservative Association and Hallmark Cars, Village Way, Rayners Lane

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 29 04 RPS R3 Not Not justified RPS therefore recommends Not This is an edge of centre site (within 300m of 5 Planning & Harro sou that the Northolt Road Retail stat the proposed primary shopping area) and is Developmen w nd Site R3 at Rayners Lane includes the Harrow Park is considered by the ed therefore sequentially more preferable to the t West West Conservative Association, Curves Council as an alternative Northolt Road Retail Park, which is out of (for Pearson Conse Fitness Centre and Hallmark Cars, all which site for additional centre. It is not considered that the allocation Pension rvative are currently occupied. The location of this convenience and of the Northolt Road Retail Park (an out of Property Associ allocation in relation to the Retail Park is comparison retail uses centre location) for additional retail floorspace Fund) ation shown at Appendix 2. including food sales is justified or consistent with national policy. because the principle of

197 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er RPS is aware that the site is surrounded by retail use on the site is It is not considered that the site’s flood risk residential properties and is identified in the already established due to status, nor the mitigation works that would be draft consultation document as being edge-of- the units already having A1 required, should be a serious impediment to centre within 300m of a Primary Shopping consent for the sale of non- the redevelopment of the site for retail use. Area. The site is proposed for 1000sqm of food goods. The site is No change. convenience retail uses. considered an ideal location for additional convenience However, RPS argues the suitability of the site floorspace, as the site is not for additional retail floorspace, due to the site within a flood risk area and being currently occupied by other uses, and there are no constraints for mitigation that would be required due to the the site to provide additional location being in Flood Zone 3A. As the units retail floorspace in the early are currently occupied, and redevelopment stages of the plan period would need to demonstrate that the location either through the variation would be appropriate for retail use, it is unclear of condition to allow a wider how soon the site would become available for range of goods to be sold retail development. from the site, or by the reconfiguration of the site to allow additional floorspace.

30 04 Environment R3 Not All of site R3 falls within Flood Zone 3b. In line Site R3 will need to be Not Following further discussion with the 8 Agency sou with the National Planning Policy Framework removed from the site stat Environment Agency it has been agreed that Harro nd only water compatible or essential allocations ed previously-developed sites within Zone 3B w infrastructure is appropriate within Flood Zone may be treated as Zone 3A, subject to minor West 3b. Retail and residential (both of which are modifications to the Development Conse suggested) are not appropriate. Management Policies DPD to justify this. On rvative this basis the redevelopment of the site for Associ retail use (less vulnerable) is appropriate on ation the site without the need to apply the exception test. No change.

Site: R4 North Harrow Methodist Church, Pinner Road, North Harrow

198 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 6 01 Alan Piper R4 Not As three of the Managing Trustees of North Amend the allocation to Not The inclusion of the site responds to the 0 (for North North sou Harrow Methodist Church(NHMC) we wish to allow the existing use as a Leg potential identified in the 2009 Retail Study Harrow Harro nd make representation about the legal church or community facility al for redevelopment to meet additional retail Methodist w compliance and soundness of the to continue. floorspace needs on an edge of centre site. Church) Metho Development Management Policies Pre- 1. The commentary to the allocation seeks dist Submission DPD in relation to the site of the Leg provision of a replacement place of worship/ Churc church – Site R4 in the Site Allocations al community uses as part of any h Document. We are aware that a submission redevelopment, so there is no conflict with com has already been made on behalf of the church the broader objectives of the plan in this but we now have further information that casts plian respect. more doubt on the validity of the DPD and, as ce – Charity Trustees with joint and individual Com Nevertheless, in response to further responsibility, we wish to make additional mun discussions with representatives of the points. ity Church following the close of the pre- Invol submission consultation, it is proposed to 2. Soundness relocate this allocation from the retail vem chapter to the other chapter of the DPD “Justified” ent and to revise both the site details and commentary to give greater emphasis to The failure of Harrow Council in this respect to We the re-provision of the place of und base its proposal on robust and credible worship/community facilities and the role erst evidence is also a breach of the “soundness” of retail/residential development as an and enabler to this end. It is proposed to make criterion of justification. Harrow Council has legal these changes as a minor modification to not sought the participation of the Church com the DPD. Council nor asked whether the church has any plian See proposed minor modifications SA15, plan either to close or to develop the whole or ce SA16, SA18 & SA19 any part of its premises. inclu des We have seen the Retail Study Review 2009 com plian and note that the consultants then identified ce the site as having development potential. They with did so however with an express disclaimer of the any analysis of development constraints or Stat eme 199 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er land ownership. Their evaluation that the site nt of might become available in the medium term Com (i.e. before 2015) was and is nonsense. They mun ity noted “availability of premises unclear” and Invol proposed retention of the existing use as an vem alternative use. In the DPD Harrow Council ent has elevated this to a firm proposal for retail whic and/or residential use with “provision for a h replacement place of worship”. There is no has evidence upon which the Council can have the obje based this assumption. ctive s of “Effective” refle cting The failure of the Council to seek any evidence the that the site may become available for view development also affects the question of s, whether the DPD is deliverable. Although we aspi have been informed that the Council may have ratio powers of compulsory purchase to implement ns and its plan, we cannot believe that it would seek to nee exercise such powers to close or replace a ds viable place of worship and the proposal would of therefore be non-deliverable. the local 3. Alternatives com mun We cannot say it is impossible that the site ity might one day become available, at least in and part, for retail and/or residential development dra although we stress that the church currently wing on plans only to increase the numbers of people 200 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er using the existing buildings as a community their centre and place of worship. We agree with the local assessment of the consultants in kno wled 2009,however, that any plan should allow for ge. the continued existing use of the premises, and The we say that the DPD and Site Allocation should Cou include provision for the use of the site to ncil’ continue as a church and community facility. s invol vem ent with NH MC was, so far as we kno w, limit ed to placi ng a notic e on a lam p- post on the

201 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er pav eme nt outsi de the chur ch. We kno w of no othe r notic e or requ est for infor mati on abo ut the chur ch or its plan s. Any enq uiry woul

202 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er d hav e disc over ed that the chur ch pre mise s are hom e to a thrivi ng com mun ity – not just a plac e of wors hip but a com mun ity cent

203 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er re use d by som e 750 peo ple eac h wee k atte ndin g Sco ut and Guid e grou ps and a vari ety of fitne ss and othe r clas ses rang

204 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er ing from a pre- nata l sup port grou p to exer cise for the elde rly. It is use d by peo ple of all age s and man y diffe rent religi ons and soci al back

205 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er grou nds. The car park s are ofte n full. In 200 9 the chur ch com plet ed a £20 0,00 0 refur bish men t. To bas e and publi sh a dev elop men t

206 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er plan on an uns upp orte d assu mpti on that the chur ch is a failin g orga nisat ion who se pre mise s will be redu nda nt in the fore see able futur

207 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er e is unw arra nted and very dam agin g.

25 03 Mrs Janet R4 Not Members of the Church Council of North The designated use should Not The inclusion of the site responds to the 8 Burgess sou Harrow Methodist Church (as Managing be extended to include, in stat potential identified in the 2009 Retail Study (for North North nd Trustees) are very surprised and concerned addition and as an ed for redevelopment to meet additional retail Harrow Harro that the site of their church, church halls and alternative to the retail and floorspace needs on an edge of centre site. Methodist w car parks, including also the headquarters of residential uses proposed, The commentary to the allocation seeks Church) Metho 2nd Headstone Scouts, is designated primarily the continued primary use provision of a replacement place of worship/ dist for retail and residential use (Site Allocation and development of the site community uses as part of any Churc R4) without their knowledge or approval. The as a place of worship and redevelopment, so there is no conflict with h Church Council has no current plans to facility for community and the broader objectives of the plan in this develop any part of the site which is, in leisure activities. respect. addition to a place of worship, a vital and vibrant community centre in use every day by Nevertheless, in response to further many community groups and will continue to discussions with representatives of the be so. In consequence the proposal is unlikely Church following the close of the pre- to be deliverable and this part of the DPD is submission consultation, it is proposed to not "sound". relocate this allocation from the retail chapter to the other chapter of the DPD The designated use should be extended to and to revise both the site details and include, in addition and as an alternative to the commentary to give greater emphasis to retail and residential uses proposed, the the re-provision of the place of continued primary use and development of the worship/community facilities and the role site as a place of worship and facility for of retail/residential development as an community and leisure activities. enabler to this end. It is proposed to make these changes as a minor modification to the DPD. 208 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er See proposed minor modifications SA15, SA16, SA18 & SA19 34 06 Thames R4 Not Regarding Chapter 2 Retail Development. We Not stated Not In light of the representations made by this 1 Water sou would have capacity concerns regarding sites stat respondent to the Development Management Utilities Ltd. North nd R4 and R7 if the developments where to be ed Policies DPD pre-submission consultation, it Harro considered for housing. Developer would be is proposed to modify the reasoned w required to fund capacity surveys and possibly justification to Policy 17 to draw attention to Metho be required to fund off site upgrades. the allocated development sites where dist Thames Water had raised concerns Churc regarding waste water capacity and to h highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

Site: R5 Roxeth Library and Clinic, Northolt Road, South Harrow

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 29 04 RPS R5 Not Not justified RPS therefore recommends Not The commentary to this allocation confirms 6 Planning & Roxeth sou that the Northolt Road Retail stat that replacement library and health facilities Developmen Library nd Site R5 is currently occupies by Roxeth Library Park is considered by the ed would be sought but this need not be an t & and the Health Clinic, and is proposed in the Council as a more impediment to the appropriate redevelopment (for Pearson Clinic consultation document for 1,000sqm appropriate alternative site of the site. The allocation is supported by the 209 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Pension convenience retail floorspace and 34 new for additional retail Retail Study which recognises that its Property homes. The location of this allocation in floorspace including food development prospects are medium term. Fund) relation to the Retail Park is shown at sales, as the principle of Appendix 2. retail on the site is already This is in centre site (within the proposed established due to the units primary shopping area) and is therefore Whilst the site is within the South Harrow already having A1 consent sequentially more preferable to the Northolt District Centre and would form part of the for the sale of non-food Road Retail Park, which is out of centre. It is Primary Shopping Area if this is extended, goods. The site is not considered that the allocation of the RPS argues the sites suitability for retail uses considered an ideal location Northolt Road Retail Park (an out of centre due to the units being currently occupied by for additional retail location) for additional retail floorspace is community uses. It is considered important to floorspace of a convenience justified or consistent with national policy. retain community uses to support local or comparison nature. No change. communities. The site is not within a flood risk area and there are no Therefore, it is expected that these facilities constraints for the site to would need to be replaced if the site was provide additional redeveloped, for which the timeframe and convenience/ comparison viability of doing so is unclear. However, the floorspace in the early relocation of these valuable community stages of the plan Period. facilities is important as their loss would be detrimental to the local community and would question the sustainability of the sites redevelopment for retail uses.

Site: R6 Land at the junction of Kenton Road and Honeypot Lane, Kingsbury

NO REPS RECEIVED

Site: R7 Anmer Lodge and Stanmore Car Park, The Broadway, Stanmore

210 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames R7 Not Regarding Chapter 2 Retail Development. We Not stated Not In light of the representations made by this 2 Water sou would have capacity concerns regarding sites stat respondent to the Development Management Utilities Ltd. Anmer nd R4 and R7 if the developments where to be ed Policies DPD pre-submission consultation, it Lodge considered for housing. Developer would be is proposed to modify the reasoned and required to fund capacity surveys and possibly justification to Policy 17 to draw attention to Stanm be required to fund off site upgrades. the allocated development sites where ore Thames Water had raised concerns Car regarding waste water capacity and to Park highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

Summary of Retail-led Development Site Capacity

NO REPS RECEIVED

Primary Shopping Areas

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 29 04 RPS RF01 Not Not justified The District Centre should Yes It is not accepted that the redesignation of 3 Planning & South sou be extended to include the part of South Harrow’s district centre

211 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Developmen Harro nd Northolt Road Retail Park as frontages from secondary to primary frontage t w Paragraph 2.27 proposes the extension of the it is unsound. The redesignation is justified by (for Pearson district South Harrow Primary Shopping Area is an established retail evidence and would be effective. Pension centre frontages to the south along Northolt Road, location with a range of Property replacing part of the area which is currently occupiers, is easily Fund) designated as a Secondary Shopping Area. accessible just off It is not considered that the Site Allocations This is included within the South Harrow Northolt Road, and is only DPD is the appropriate vehicle for the District Centre, which extends north of the 340m from the District consideration of a significant town centre railway line. Centre, and 400m from the extension; such a substantial change would Primary be more appropriately dealt with as part of a Shopping Area. review of the Core Strategy. Nevertheless, an The reason given for the change of frontage to initial assessment would indicate that the Primary Shopping Area is that the 2009 Retail distance of the site from the centre’s primary Study found that key national retailers are and secondary retail frontages, and the contained within this centre. Therefore, the physical barrier formed by the Piccadilly line, proposed designation amendment is to provide are such that it would not form a natural consistency within the District Centre. Clearly extension to the district centre’s retail this would not represent additional retail function. floorspace to meet the identified need. No change.

RPS considers that the District Centre should be extended north to include the Northolt Road Retail Park and Waitrose foodstore, as this is only 340m from the District Centre, and 400m from the Primary Shopping Area. Due to the number of retail units within the Retail Park, the site should be recognised as a significant shopping location within the area and included within the District Centre.

Chapter 3: Economic Development and Employment

Site: EM1 Northolt Road Business Use Area (North and South), South Harrow

212 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 10 01 CGMS EM1 Not I write on behalf of our client, the Mayor’s It is recommended that the Not The site is within the Northolt Road Business 4 (for stat Office for Policing and police station site is removed stat Use Area as shown on the Policies Map and Metropolitan Northo ed Crime/Metropolitan Police Service from Site EM1: Northolt ed in the Core Strategy (Harrow on the Hill & Police lt Road (MOPAC/MPS), with regard to the Business Use Area and Sudbury Hill sub area map). Policy CS3G of Service) Busine Council’s consultation on the Site reallocated as a stand alone the Core Strategy seeks provision for ss Use Allocations Development Plan Document residential-led diversified employment opportunities through Area (DPD) – Pre Submission version. The redevelopment site as per the redevelopment/conversion of premises MOPAC/MPS provide a vital community the May 2011 version of the within the business use area. This and other service and as such policing is draft DPD. provisions of the Core Strategy give effect to recognised within the adopted London an objective to deliver 4,000 new jobs over Plan (2011) as being an integral part of the plan period. Social Infrastructure. The ability to ensure safe and secure communities It is noted that the complete removal of the throughout the Borough relies upon site from the DPD is not sought. Although the continued effective policing which, in 2011 consultation draft Site Allocations DPD turn, can be achieved through delivery of included the site in the housing chapter it the MPS’ Estate Strategy. Therefore, nevertheless sought a mixed use given the strategic importance of development for residential and non town borough policing, the following centre economic uses (see ‘other proposed representations are made to the uses’ and commentary in the 2011 emerging Site Allocations DPD. document). The now adopted Core Strategy seeks employment-led, mixed use Previous Representations development throughout the Northolt Road business use area; to arbitrarily exclude this CgMs have previously made site would undermine this provision of the representations on behalf of the MPS Core Strategy and would fail to increase the towards the Harrow & Wealdstone AAP pressure on other sites to deliver against the Issues and Options document in June Strategy’s job creation target for the plan 2011 and Preferred Options in February period. 2012. Representations have also been submitted towards the Site Specific The NPPF includes community uses in the Allocations consultations in November definition of economic development. 2010 and June 2011 and the emerging Therefore it is irrelevant that the police Core Strategy in July 2008, December station is not a ‘B’ class use. The Council 2009, January 2010, May 2011, August would expect the redevelopment of the site to

213 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2011 and most recently in December contribute to job creation as well as housing 2011. objectives, and in this mixed-use area a mixed use development would not be Relevant Planning Policy inappropriate. Policy CS1 Z of the Core Strategy states that the loss of community The provision of effective policing is of facilities will be resisted unless adequate crucial importance across London to arrangements are in place for their ensure safe places to live are created as replacement or the enhancement of other part of a sustainable community, existing facilities. consistent with planning policy. This policy background is set out in full in our No change. letter of representation regarding the draft Core Strategy (2nd December 2011).

Representations

Site EM1 Northolt Road Business Use Area (North and South), South Harrow

The MOPAC/MPS support the inclusion of Harrow Police Station within the draft Site Allocation DPD. Whilst the police station site is no longer identified as being surplus to requirements, the allocation would allow flexibility in allowing the MOPAC/MPS to implement their Estate Strategy should their future operational requirements in Harrow change. However, it is recommended that the police station site is removed from Site EM1: Northolt Business Use Area and reallocated as a stand alone residential-led redevelopment site as per the May 2011 version of the draft DPD.

The existing police station comprises a sui

214 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er generis use in planning terms and, as defined within the London Plan and Core Strategy, policing is recognised as a community service. In line with the MOPAC/MPS’ Estate Strategy, the police station will only be released provided that the existing community service provision has been re-provided on sites elsewhere in the Borough or neighbouring areas. As such there would be no net loss in policing provision. Furthermore, as the police station does not comprise a Class ‘B’ use there is no planning policy requirement to provide replacement employment floorspace in this location.

Whilst the Council can demonstrate a 5-year supply of housing to meet the Mayor’s target, this target represents a minimum and is

215 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er appropriately assessed in parallel with London Plan Policy 3.4 which requires development plan preparation to optimise housing output.

For the reasons outlined above, the MOPAC/MPS recommend that previous site allocation H3: Harrow Police Station is reinstated within the Site Allocations document as a residential-led redevelopment designation as per the May 2011 version of the DPD. 30 04 Environment EM1 Sou We support this site allocation because it N/A Not Noted. 9 Agency nd includes consideration of flood risk in stat Northo accordance with the National Planning Policy ed lt Road Framework. We are also satisfied that river Busine restoration is included. ss Use Area 34 06 Thames EM1 Not Regarding Chapter 3 Employment. We would Not stated Not In light of the representations made by this 3 Water sou have capacity concerns regarding all sites EM1 stat respondent to the Development Management Utilities Ltd. Northo nd - EM5 if the developments where to be ed Policies DPD pre-submission consultation, it lt Road considered for housing. Developer would be is proposed to modify the reasoned Busine required to fund capacity surveys and possibly justification to Policy 17 to draw attention to ss Use be required to fund off site upgrades. the allocated development sites where Area Thames Water had raised concerns (north) regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development

216 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Management Policies DPD adequately addresses the respondent’s concerns. No change

Site: EM2 Rayners Lane Offices, Imperial Drive, Rayners Lane

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 20 03 GVA EM2 Uns Introduction Not 3 (for oun We respond to the above document on behalf stat Marylebone Rayne d of our client, Marylebone Property Investments ed Property rs Ltd in relation to the site known as Imperial Investment) Lane House, Imperial Drive, Harrow. A site location Offices plan is attached to this letter.

These representations are submitted following a meeting with planning officers on 9th August 2012, regarding future redevelopment options for the site (meeting ref. HA/2012/ENQ/00215). The site is currently let to Ladbrokes and is their headquarters within the UK.

Whilst Ladbrokes have recently renewed the lease for an initial five years, the owner of the site is looking at future redevelopment as the existing building is becoming outdated and is in need of investment to remain attractive to office occupiers.

Our comments in relation to the Pre- Submission Site Allocations Development Plan Document (DPD) are provided in respect of the

217 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er site at Imperial House. Representations have also be submitted under separate cover in respect of the Development Management Policies Pre-Submission DPD (July 2012).

Commentary Site EM2: Rayners Lane Offices, Imperial Drive, Rayners Lane Policy EM2 is unsound because it is not effective and not consistent with national policy.

Phasing Phasing Site EM2, ‘Rayners Lane Offices’, as identified In order for the DPD to in the Site Allocations document, comprises remain flexible, we would In response to this representation it is Imperial House, Regent College and Talbot suggest that the proposed to amend paragraph 3.9, to House to the west of Imperial Drive. As such Commentary within allow phased development, as a minor the site is currently in multiple ownership and it Paragraph 3.9 on page 54 modification. is therefore likely that any redevelopment states that ‘redevelopment See proposed minor modification SA25 would come forward in phases. In order for the may be brought forward in a DPD to remain flexible, we would suggest that phased manner’. the Commentary within Paragraph 3.9 on page 54 states that ‘redevelopment may be brought forward in a phased manner’.

Minimum Housing Units Minimum Housing Units We welcome the proposed allocation of Site EM2 for residential units, but would request We would therefore request Paragraph B1 (page 251) of the DPD that the quantum of units to be provided is that the Site Details state confirms that the housing capacity attributed consistent in both the Site Details (page 53) that the provision of 150 to each site is indicative, not prescriptive and, and Commentary (page 54) for the site. The units forms a minimum in relation to sites within employment Chapter Site Details state that 150 homes are to be target. 3, paragraph 3.3 recognises that the provided across Site EM2, whereas Paragraph indicative housing capacities are modest. 3.9 of the Commentary states that this is a Therefore, for consistency with the format of minimum figure in line with the Core Strategy. the rest of the document, it is not proposed to We would therefore request that the Site add minimum to the site details.

218 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Details state that the provision of 150 units No change. forms a minimum target.

Land Use Land Use Harrow’s adopted Core Strategy (February We would therefore suggest 2012) states that within Rayners Lane District that given the scale of The findings of the GVA office report Centre housing is to be provided as part of residential development submitted with this representation largely employment-led mixed use redevelopment of proposed on the site and the reflect those of Harrow’s Employment Land offices. Specifically, Paragraph 8.11 sets out flexibility within the NPPF Study. Namely: that mixed-use redevelopment or conversion of with regard to the protection redundant office buildings on Imperial Drive of employment uses, it  that Harrow’s office market is largely offers the opportunity to contribute to housing would be more appropriate localised in nature [and therefore supply, whilst making provision for appropriate to include Site EM2 within requires smaller rather than larger economic uses to be supported. However, Chapter 4, Housing, as a premises] and that that existing GVA’s Lease Consultancy Team has housing led scheme. provision (e.g. Talbot House) is of commented on the future use of Imperial poor quality; and House (commentary appended to this letter)  that supply conditions are and considers that redevelopment to an suppressing rental levels [and alternative use from employment would be the therefore make speculative new natural future of the site. Imperial House is office provision unviable]. coming to the end of its economic life as an office building and there is an anticipated low Harrow’s response to the Employment Land level of future demand for 85,000 sq ft of office Study, reflected in the Core Strategy, is to space within an area that is primarily seek economic diversification and renewal of residential with a secondary retail centre at employment floorspace through mixed use Rayners Lane. Established office locations redevelopment of sites such as that the such as Harrow town centre, Uxbridge and subject of this representation. The allocation commercial locations closer to London would recognises the role of residential as an provide more desirable employment enabler to this end. The indicative floorspace opportunities, offering small to medium size of 4,100m2 stated in the allocation (and for suites at more affordable rents. In summary, the whole allocation including Talbot House) we would therefore consider it unlikely that the equates to 44,000 sq ft. and is therefore site would be brought forward as an substantially less than the stated 85,000 sq employment led scheme. ft. area of the existing Imperial House.

219 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Furthermore, the National Planning Policy Paragraph 19 of the NPPF places significant Framework (NPPF) adopted in March 2012, weight on supporting economic growth states that planning policies should avoid the through the planning system, and paragraph long term protection of sites allocated for 20 states that local planning authorities employment use where there is no reasonable should plan proactively for business prospect of a site being used for that purpose development needs and to support an (Para 22). Applications for alternative uses of economy fit for the 21st century. Harrow’s land or buildings are to be treated on their Core Strategy provides for spatial strategy for merits having regard to market signals and the economic growth and diversification within relative need for different land uses to support the Borough, pursuant to a target to deliver sustainable local communities. We would 4,000 new jobs over the plan period. The role therefore suggest that given the scale of of the Rayners Lane offices in the delivery of residential development proposed on the site the strategy is written into the Core Strategy; and the flexibility within the NPPF with regard office rejuvenation and employment to the protection of employment uses, it would generating uses are sought in Rayners Lane be more appropriate to include Site EM2 within district centre as part of mixed use Chapter 4, Housing, as a housing led scheme. redevelopment. It should be noted that the ‘scale of residential development proposed’ is Continued Engagement in the Emerging across the whole allocation, not just the Policy Process Imperial House site, and that (as stated by We look forward to confirmation of receipt of letter dated 22nd August 2012) the allocation these representations at the earliest is not prescriptive as to the amount or form of opportunity and would welcome the opportunity employment use to be delivered. The to meet with officers to discuss any part of our allocation emphasises the role of residential representations if necessary. as an enabler. It has not been demonstrated that any mixed use development on this site would be unviable. The proposed allocation, which does not prescribe the nature and amount of employment uses to be delivered on the site, is considered to be both effective and consistent with national policy. No change. 30 05 Environment EM2 Sou We support this site allocation because it N/A Not Noted. 0 Agency nd includes consideration of flood risk in stat Rayne accordance with the National Planning Policy ed 220 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er rs Framework. Lane Offices 34 06 Thames EM2 Not Regarding Chapter 3 Employment. We would Not stated Not In light of the representations made by this 4 Water sou have capacity concerns regarding all sites EM1 stat respondent to the Development Management Utilities Ltd. Northo nd - EM5 if the developments where to be ed Policies DPD pre-submission consultation, it lt Road considered for housing. Developer would be is proposed to modify the reasoned Busine required to fund capacity surveys and possibly justification to Policy 17 to draw attention to ss Use be required to fund off site upgrades. the allocated development sites where Area Thames Water had raised concerns (south) regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

Site: EM3 Ballard Mews Estate, Edgware

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames EM3 Not Regarding Chapter 3 Employment. We would Not stated Not In light of the representations made by this 5 Water sou have capacity concerns regarding all sites EM1 stat respondent to the Development Management Utilities Ltd. Ballard nd - EM5 if the developments where to be ed Policies DPD pre-submission consultation, it considered for housing. Developer would be is proposed to modify the reasoned 221 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Mews required to fund capacity surveys and possibly justification to Policy 17 to draw attention to be required to fund off site upgrades. the allocated development sites where Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 43 11 Mr. J. Welby EM3 Not The following premises are all scheduled for Not stated Not The site is allocated for employment-led, 3 (Resident) stat housing and are not suitable as it would cause stat mixed-use redevelopment to secure modern Ballard ed unemployment and demolition of existing ed office or other business use/employment Mews buildings: generating floorspace.  Ballards Mews, Edgware (offices and workshops employing over 50 people). The London Plan and Development From what I have seen of the LDF Plan Harrow Management Policies DPD provide the is taking over land for housing where there is framework for securing affordable housing definite need on these sites and the prices from development sites. would exceed £200,000 each. No change.

Site: EM4 47-49 High Street, Edgware, HA8 7DD

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

222 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environment EM4 Sou We support this site allocation because it N/A Not Noted. 1 Agency nd includes consideration of flood risk in stat 47-49 accordance with the National Planning Policy ed High Framework. Street, Edgwa re 34 06 Thames EM4 Not Regarding Chapter 3 Employment. We would Not stated Not In light of the representations made by this 6 Water sou have capacity concerns regarding all sites EM1 stat respondent to the Development Management Utilities Ltd. 47-49 nd - EM5 if the developments where to be ed Policies DPD pre-submission consultation, it High considered for housing. Developer would be is proposed to modify the reasoned Street, required to fund capacity surveys and possibly justification to Policy 17 to draw attention to Edgwa be required to fund off site upgrades. the allocated development sites where re Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change 43 11 Mr. J. Welby EM4 Not The following premises are all scheduled for Not stated Not The site is allocated for employment-led, 2 (Resident) stat housing and are not suitable as it would cause stat mixed-use redevelopment to secure modern 47-49 ed unemployment and demolition of existing ed office or other business use/employment High buildings: generating floorspace. Street,  High Street, Edgware (Safe Storage Edgwa and VIP Lounge, VIP Lounge is a prty The London Plan and Development centre for weddings and conferences Management Policies DPD provide the 223 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er re on Sunday 27th August there was an framework for securing affordable housing Indian wedding with over 100 people from development sites. including an Indian drum band of 12. Generally it is used 7 days a week). No change. From what I have seen of the LDF Plan Harrow is taking over land for housing where there is definite need on these sites and the prices would exceed £200,000 each.

Site: EM5 57-59 High Street, Edgware HA8 7DD

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames EM5 Not Regarding Chapter 3 Employment. We would Not stated Not In light of the representations made by this 7 Water sou have capacity concerns regarding all sites EM1 stat respondent to the Development Management Utilities Ltd. 57-59 nd - EM5 if the developments where to be ed Policies DPD pre-submission consultation, it High considered for housing. Developer would be is proposed to modify the reasoned Street, required to fund capacity surveys and possibly justification to Policy 17 to draw attention to Edgwa be required to fund off site upgrades. the allocated development sites where re Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns.

224 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er No change

Summary of Employment-Led Development Site Capacity

NO REPS RECEIVED

Employment and Industrial Use Areas

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 02 Mayor of 3.26 Yes The GLA supports the proposed removal of the N/A Yes Noted. 1 London (In northern area of the Honeypot Lane Strategic (In No change. gen Industrial Location (SIL) designation in order to gen eral rationalise, and redefine the SIL boundary, in eral conf response to the substantially completed mixed- conf ormi use development at this site. ormi ty ty with with the the Lon Lon don don Plan Plan ) )

Chapter 4: Housing

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

225 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 14 02 Hatch End Para Not Chapter 4 Housing: Page 73 - top of page – Change reference after Not Paragraph 4.4 was included in the pre- 5 Association 4.4 stat reference should be “Chapter 8 “ not Chapter ‘Harrow Arts Centre’ to stat submission document for consultation ed 9. chapter 8. ed purposes but will not be relevant to the final document. Therefore it is proposed to delete the whole of (including the part to which this representation relates) paragraph 4.4 as a minor modification. See proposed minor modification SA29

Site H1: 1-5 Sudbury Hill, Harrow HA1 3SB

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H1 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 1-5 nd Waste Water capability in relation to this site. ed Sudbu ry Hill

Site H2: 94-116 Greenford Road, Harrow HA1 3QL

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 8 01 BNP H2 Not BACKGROUND Change site allocation to Not However, as the site was not assessed as 2 Paribas 94-116 stat employment land and omit stat part of Harrow’s Employment Land Study, (for Travis Greenf ed Travis Perkins is one of the UK's leading allocation for residential. ed and as no site specific assessment has been Perkins ord builders’ merchants with more than 600 submitted with the representation, there is no Trading Co. Road branches nationwide. The Company supplies evidence to demonstrate that designation of

226 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Ltd) more than 100,000 product lines to trade the site as a new business use area (or professionals including building materials, industrial & business use area) would secure plumbing and heating, landscaping materials, feasible alternative employment uses or timber and sheet materials, painting and would be sustainable. decorating, dry lining and insulation, tool and equipment hire, doors and joinery, bathrooms However, as it is apparent from this and kitchens, and hand and power tools, representation that current occupier has together with a wide range of services no interest in vacating the site, it is including the trade-dedicated website, proposed to omit the site from the DPD as Trademate. Travis Perkins has been voted a minor modification. National Builders' Merchant of the Year seven See proposed minor modification SA29 times and has also been elected a Business Superbrand; the first company in the merchanting market and still the highest ranked merchant to be honoured.

We have undertaken a review of Harrow Council’s online planning history records available for the Greenford Road site and consider the following to be of particular

227 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er relevance: ■ Planning permission was granted on 3 February 2010 for the “Change of Use of existing buildings yard (Sui Generis) to a builders merchant (Sui Generis) and the erection of 2 No. buildings for the display, sales and storage of building, timber and plumbing supplies, plant and tool hire, including outside display and storage and external alterations including new fencing” (Application Ref: P/2312/09/HG/C).

We therefore consider the existing lawful use of the site to be a builder’s merchant (Sui Generis). Notwithstanding this, we consider the site to be more in line with a traditional employment use.

On this basis, Travis Perkins object to the inclusion of their site within the Site Allocations DPD for residential development and request 228 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er hat this site is included as protected employment and. This will ensure that Travis Perkins operations will not be prejudiced and can continue to operate from this location.

Existing Employment Land Further to our review of the Council’s Annual Monitoring Report 2010-2011 (AMR) and Employment Land Review (2010), we note the Council are broadly set to meet their 2026 target for all types of employment space within the borough. In addition, we note that “Harrow is expected to meet and exceed housing targets for the next five years. It should also be noted that the Council’s Housing Trajectory forecasts an over-delivery of 400 units to 2025/26 and that the plan target will be met two years early in 2025/2026. In light of the information provided within the AMR and Employment Land Review (ELR), we are of the opinion that the Council should adopt a cautious approach to the release of employment land in preference to residential development, particularly given that the Council is set to exceed their overall target.

229 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er warehousing site or storage facility.

In light of the nature of the site, we are of the opinion that the Council should retain the site for continued employment use.

POLICY CONSIDERATIONS

230 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er on the need to support economic growth through the planning system. To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century” (Para 19 – 20); ■ that planning policy should “support existing business sectors, taking account of whether they are expanding or contracting... Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances” (Para 21); and

Further we note that, the NPPF state that local planning authorities should: ■ use their evidence base to assess: ■ “the existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time as, or combined with, Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of previously allocated land” (Para 161).

CONCLUSION To reiterate, Travis Perkins seek to maintain operations on the Greenford Road site. We therefore object to proposed site allocation of this site for residential and request an employment land allocation for this site. 231 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

We reserve the right to amend or supplement these representations at a later date if necessary. 34 08 Thames H2 Not On the information available to date we do not N/A Not Noted. 6 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 92-116 nd Waste Water capability in relation to this site. ed Greenf ord Road

Site H3: 79-89 Greenford Road, Harrow HA1 3QF

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H3 Not On the information available to date we do not N/A Not Noted. 9 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 79-89 nd Waste Water capability in relation to this site. ed Greenf ord road

Site H4: 205-209 Northolt Road, South Harrow HA2 0NG

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

232 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H4 Not On the information available to date we do not N/A Not Noted. 4 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 205- nd Waste Water capability in relation to this site. ed 209 Northo lt Road

Site H5: 1 & 1A Silverdale Close, Northolt UB5 4BL

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H5 Not On the information available to date we do not N/A Not Noted. 8 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 1 & 1A nd Waste Water capability in relation to this site. ed Silverd ale Close

Site H6: Former Matrix Public House, 219 Alexandra Avenue, South Harrow HA2 9DL

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 09 Thames H6 Not On the information available to date we do not N/A Not Noted. 0 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Forme nd Waste Water capability in relation to this site. ed r Matrix

233 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er P.H.

Site H7: Former Vaughan Centre, Wilson Gardens, West Harrow HA1 4EA ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environment H7 Sou We support this site allocation because it N/A Not Noted. 2 Agency nd includes consideration of flood risk in stat Forme accordance with the National Planning Policy ed r Framework. Vaugh an Centre 34 09 Thames H7 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Forme nd Waste Water capability in relation to this site. ed r Vaugh an Centre

Site H8: Former Rayners Hotel, 23 Village Way East, Rayners Lane HA2 7LX

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environment H8 Sou We support this site allocation because it N/A Not Noted. 3 Agency nd includes consideration of flood risk in stat Forme accordance with the National Planning Policy ed 234 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er r Framework. Rayne rs Hotel 34 08 Thames H8 Not On the information available to date we do not N/A Not Noted. 1 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Forme nd Waste Water capability in relation to this site. ed r Rayne rs Hotel

Site H9: Land at Rayners Lane Station, High Worple, Rayners Lane HA5 5EG

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H9 Not LEGALITY/SOUNDNESS Not stated. Not Site H9: The area allocated for development 6 Middlesex Land stat For the above sites, the allocation may be stat excludes the (proposed revised boundary) Wildlife at ed acceptable in principle. The legality or ed area of the adjacent site of importance for Trust Rayne soundness of the proposed use will depend on nature conservation (SINC). SINCs are a rs the detail of any proposals coming forward. regional designation and development Lane The following comments therefore neither adjacent to a SINC need not be harmful to its Station support or oppose the site allocations conservation interest. Paragraph 4.24 proposed, but are intended to draw attention to highlights the need for sensitive design and nature conservation factors which may make layout. Policies 27 and 28 of the proposed the proposed allocation diverge from national Development Management Policies DPD policy or Core Strategy policies and objectives, provide criteria for the protection and or make them less preferable sites. enhancement of biodiversity sites. No change. COMMENT

235 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er The above sites include areas which are designated for their nature conservation interest as SINCs or SSSIs, or otherwise are adjacent to sites having this designation.

The Council must consider what impacts may result on the SINCs or other designated sites from the particular proposed site allocation. The Council should consider whether any other sites are available for this use/purpose, where any negative impacts may be avoided or reduced.

If any of these sites are allocated for future development or use in the Site Allocations DPD, it must be ensured that the proposed use or development does not result in direct or indirect long-term harm to the site, to its ecological integrity and role in the local ecological network.

This should be achieved in the first instance and wherever possible through avoidance – such as locating built development away from the SINC site and establishing, retaining and enhancing semi-natural buffer habitats. Secondly, where there is a risk of impact, adequate and robust mitigation must be part of any development proposals. Any residual impact must be ‘offset’ by compensatory measures – for instance, habitat creation on another part of the site; or funding or undertaking management and enhancement work on the SINC or other nearby sites. Compensation and offsetting should never be

236 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er seen as the first recourse, and should only be used when preferred options of avoiding and mitigating adverse impacts have been exhausted.

If any of the above sites are allocated, the Council should also consider how development may enhance the local ecological network, through habitat creation, habitat improvement, and ongoing positive management. SINCs are an important element of the ecological network, helping to create linkage between other, statutory sites such as SSSIs. Opportunities to improve and strengthen the ecological network should be explored. For instance extending SINCs, managing SINC habitats better for wildlife, creating buffer habitats and habitat corridors or patches between SINCs

CHANGE No specific changes suggested.

JUSTIFICATION Paragraph 109 of the National Planning Policy Framework (NPPF) sets out that the planning system should “contribute to and enhance the natural and local environment by… minimising impacts on biodiversity and providing net gains in biodiversity where possible… including by establishing coherent ecological networks that are more resilient to current and future pressures.”

Paragraph 114 confirms that local planning

237 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

 identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration and creation;

 promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets.

Following Paragraph 165 of the NPPF, planning policies and decisions should be based on up-to-date information about the natural environment and other characteristics of the area. The Framework directs that this should include an assessment of existing and

238 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er potential components of ecological networks.

When determining planning applications, paragraph 118 of the NPPF states that local planning authorities should aim to conserve and enhance biodiversity by applying the principles listed in the document, amongst which:  If significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;  Proposed development on land within or outside of a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be

239 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

240 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Rayne rs Lane Station

36 09 Transport H9 Not TfL Property welcomes and supports the N/A Not Noted. 6 for London Land stat stat „principle‟ of residential development of Site (Consents at ed Proposals H9 and H21. ed Team) Rayne rs Lane Station 44 11 C. D. Noyce H9 Not I note the proposal for the Rayners Lane Not stated Not The commentary to the site allocation 4 (Councillor) stat Station car park to be allocated, as I stat explains that the site is allocated for partial Land ed understand it, for housing. ed redevelopment, with an appropriate amount at of station car parking to be retained, Rayne I would oppose such an allocation of a recognising its role for commuters and during rs previously allocated site because the loss of Wembley stadium events. It goes on to state Lane car parking which is already at a premium. Not that any planning application for the Station only do commuters use the car park Monday to redevelopment of the site should be Friday but it tends to be used all week as supported by evidence of car parking people utilize the car parking to make good the demand, and how that demand will be met, deficiencies in the area. by the re-provision of car parking on the site or elsewhere. In my considered opinion not only would the No change. car parking have to be replaced should any substantive planning application be made but there would be problem as the station car park is already the overfill parking capacity for the area.

Site H10: North Harrow Library and Children’s Services, 429-433 Pinner Road, North Harrow HA1 4HN

241 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H10 Not On the information available to date we do not N/A Not Noted. 2 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. North nd Waste Water capability in relation to this site. ed Harro w Library and Childre n’s Servic es

Site H11: Enterprise House, 297 Pinner Road, North Harrow HA1 4HS

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H11 Not On the information available to date we do not N/A Not Noted. 3 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Enterp nd Waste Water capability in relation to this site. ed rise House

Site H12: Rear of 57-65 Bridge Street, Pinner HA5 3HZ

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

242 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H12 Not On the information available to date we do not N/A Not Noted. 4 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Rear nd Waste Water capability in relation to this site. ed of 57- 65 Bridge Street

Site H13: Jubilee House, Merrion Avenue, Stanmore HA7 4RS

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H13 Not LEGALITY/SOUNDNESS Not stated. Not Site H13: The area allocated for development 6 Middlesex Jubilee stat For the above sites, the allocation may be stat is adjacent to but does not overlap the Wildlife House, ed acceptable in principle. The legality or ed neighbouring site of importance for nature Trust Merrio soundness of the proposed use will depend on conservation (SINC). SINCs are a regional n the detail of any proposals coming forward. designation and development adjacent to a Avenu The following comments therefore neither SINC need not be harmful to its conservation e support or oppose the site allocations interest. In response to this representation proposed, but are intended to draw attention to it is proposed to amend paragraph 4.33 to nature conservation factors which may make highlight the need for sensitive design the proposed allocation diverge from national and layout, in relation to the neighbouring policy or Core Strategy policies and objectives, designation, as a minor modification. or make them less preferable sites. See proposed minor modification SA34 Policies 27 and 28 of the proposed COMMENT Development Management Policies DPD The above sites include areas which are provide criteria for the protection and designated for their nature conservation enhancement of biodiversity sites. interest as SINCs or SSSIs, or otherwise are adjacent to sites having this designation.

243 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er The Council must consider what impacts may result on the SINCs or other designated sites from the particular proposed site allocation. The Council should consider whether any other sites are available for this use/purpose, where any negative impacts may be avoided or reduced.

244 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er If any of the above sites are allocated, the Council should also consider how development may enhance the local ecological network, through habitat creation, habitat improvement, and ongoing positive management. SINCs are an important element of the ecological network, helping to create linkage between other, statutory sites such as SSSIs. Opportunities to improve and strengthen the ecological network should be explored. For instance extending SINCs, managing SINC habitats better for wildlife, creating buffer habitats and habitat corridors or patches between SINCs

CHANGE No specific changes suggested.

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

245 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

When determining planning applications, paragraph 118 of the NPPF states that local planning authorities should aim to conserve

246 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er and enhance biodiversity by applying the principles listed in the document, amongst which:  If significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;  Proposed development on land within or outside of a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused

247 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

36 09 Transport H13 Not TfL Property, in principle supports the inclusion To ensure the Document is Not In response to this representation, it is 4 for London stat of TfL land within Proposal Site H13 (see land effective in terms of stat proposed to amplify the commentary of (Consents Jubilee ed ownership plan overleaf). We have undertaken deliverability, we would ed this allocation, to highlight the multiple Team) a Feasibility Study which suggests a scheme suggest the following: ownership of the site and, subject to 248 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er House comprising 18 units can be delivered on TfL a) Paragraph titled ‘Other Policy 41 of the Development land, this excludes planning consent of 35 Uses Proposed’ to state ‘a Management Policies DPD, to seek a units (Planning Reference: P/1220/07) for comprehensive comprehensive redevelopment of the Jubilee House which remains unimplemented. development scheme’. entire allocated site, as a minor In light of this, we would suggest a b) Paragraph titled ‘Number modification. Under ‘other proposed uses’ comprehensive development approach should of Units’ to state ‘minimum make reference to a comprehensive be considered for the site, a point which is not 35’. redevelopment scheme securing an currently considered in the Document. This will appropriate quantum of replacement ensure any scheme brought forward is both employment floorspace where this is viable and deliverable. necessary to comply with Policy 41 of the Development Management Policies DPD. See proposed minor modifications numbered SA33 & SA34

Site H14: Land at Stanmore Station, London Road, Stanmore HA7 4PD

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H14 Not LEGALITY/SOUNDNESS Not stated. Not Site H14: The area allocated for development 6 Middlesex Land stat For the above sites, the allocation may be stat is adjacent to but does not overlap the Wildlife at ed acceptable in principle. The legality or ed neighbouring site of importance for nature Trust Stanm soundness of the proposed use will depend on conservation (SINC). SINCs are a regional ore the detail of any proposals coming forward. designation and development adjacent to a Station The following comments therefore neither SINC need not be harmful to its conservation support or oppose the site allocations interest. In response to this representation

249 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er proposed, but are intended to draw attention to it is proposed to amend paragraph 4.37 to nature conservation factors which may make highlight the need for sensitive design the proposed allocation diverge from national and layout, in relation to the neighbouring policy or Core Strategy policies and objectives, designation, as a minor modification. or make them less preferable sites. See proposed minor modification SA37 Policies 27 and 28 of the proposed COMMENT Development Management Policies DPD The above sites include areas which are provide criteria for the protection and designated for their nature conservation enhancement of biodiversity sites. interest as SINCs or SSSIs, or otherwise are adjacent to sites having this designation.

250 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er any development proposals. Any residual impact must be ‘offset’ by compensatory measures – for instance, habitat creation on another part of the site; or funding or undertaking management and enhancement work on the SINC or other nearby sites. Compensation and offsetting should never be seen as the first recourse, and should only be used when preferred options of avoiding and mitigating adverse impacts have been exhausted.

CHANGE No specific changes suggested.

JUSTIFICATION Paragraph 109 of the National Planning Policy Framework (NPPF) sets out that the planning system should “contribute to and enhance the natural and local environment by… minimising

251 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er impacts on biodiversity and providing net gains in biodiversity where possible… including by establishing coherent ecological networks that are more resilient to current and future pressures.”

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

 promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and

252 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er local targets.

253 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

254 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er authorities on decisions affecting protected species and designated nature conservation sites. 34 08 Thames H14 Not We have concerns regarding Waste Water In this case we ask that the Not In light of the representations made by this 0 Water Sou Services in relation to this site. Specifically, the following paragraph is stat respondent to the Development Management Utilities Ltd. Land nd sewerage network capacity in this area is included in the Development ed Policies DPD pre-submission consultation, it at unlikely to be able to support the demand Plan. “Developers will be is proposed to modify the reasoned Stanm anticipated from this development. It will be required to demonstrate that justification to Policy 17 to draw attention to ore necessary for us to undertake investigations there is adequate waste the allocated development sites where Station into the impact of the development and water capacity both on and Thames Water had raised concerns completion of this, on average, takes 12 off the site to serve the regarding waste water capacity and to weeks. It should be noted that in the event of development and that it highlight the need for the developer to an upgrade to our assets being required, up to would not lead to problems prepare a drainage strategy in liaison with three years lead in time will be necessary. for existing or new users. In Thames Water, the purpose of which is to some circumstances it may model the network capacity and ensure that, be necessary for developers if mitigation is required, this is undertaken to fund studies to ascertain ahead of occupation of the development. whether the proposed The Council therefore considers that the development will lead to combination of Core Policy CS1 Z and overloading of existing paragraph 4.20 of the Development waste water infrastructure.” Management Policies DPD adequately addresses the respondent’s concerns. No change 36 09 Transport H14 Not Proposal Site H14 suggests that 44 residential It is recommended that the Not In response to this representation, it is 5 for London Land stat units will be delivered on the site in conjunction housing capacity of 44 units stat proposed to revise paragraph 4.35 of the (Consents at ed with an appropriate amount of station car is revised to ensure a ed commentary, as a minor modification, to Team) Stanm parking. TfL Property supports ‘in principle’ the scheme comprising give greater clarity to the relationship ore designation in particular the retention of some residential units and the between the amount of car parking to be Station level of commuter parking however would retention of an appropriate re-provided and the number of residential advise that current housing capacity 44 units is provision of commuter units that will need to be accommodated undeliverable for the site. parking can be delivered on in the delivery of this allocation, the site. This will also recognising that the stated figure of 44 TfL produced a Feasibility Study which ensure that the strategy but units is indicative and that a greater demonstrates that a residential led scheme forward is the most residential capacity may be acceptable,

255 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er comprising 132 residential units and commuter appropriate strategy for the subject to design and layout car parking can be delivered on the site. The site. considerations, to secure a feasible Council suggested through the supporting text scheme. in Proposal Site H14 that an ‘appropriate We recommend the See proposed minor modification SA35 amount of station car parking’ will need to be following: retained, a point which we support and have a) remove reference to 44 However, the representation implies a 25% incorporated in the draft Feasibility Study, units and replace with reduction in car parking capacity justified by details of which we are happy to share with ‘approximately 100 units’. the feasibility study. As the starting point, the you. The current commuter parking equates to Council would expect the current level of car 487 spaces. The Feasibility Study parking to be re-provided; any reduction demonstrated that a significant amount of would need to be justified by evidence of commuter parking can be accommodated on demand sought in paragraph 4.35 of the the site, equating to a retention factor of commentary. approximately 85%. However, this level of commuter car parking can only be delivered through the construction of a decked structure. The cost associated with this structure is significant and can only be funded by the scheme. To deliver the Council’s aspiration of an appropriate level of commuter car parking and 44 units is unviable and thus undeliverable. 43 10 Mr. J. Welby H14 Not A new point I would like to raise is the Local Not stated Not The commentary to the site allocation 9 (Resident) stat Development Plan, which has a date of reply of stat explains that the site is allocated for partial Land ed 7th September. There are issues which need ed redevelopment, with an appropriate amount at addressing. Stanmore and Canons Park of station car parking to be retained, Stanm Stations car parks which would be replaced by recognising its role for commuters and during ore housing. Wembley stadium events. It goes on to state Station that any planning application for the In respect of Stanmore the car park was full redevelopment of the site should be during the Olympics and afterwards would be supported by evidence of car parking 50% to 75% full and if this scheme goes ahead demand, and how that demand will be met, with less car space there is nowhere else to by the re-provision of car parking on the site park as the council put in place a CPZ to keep or elsewhere. cars off the streets. People come from all over No change. 256 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er the country to park there as it is very costly in Wembley.

Site H15: Paxfold, Elizabeth Gardens, Stanmore HA7 4UG

NO REPS RECEIVED

Site H16: Gillian House, Elms Road, Harrow Weald HA3 6BU

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H16 Not LEGALITY/SOUNDNESS Not stated. Not Site H16: The area allocated for development 6 Middlesex Gillian stat For the above sites, the allocation may be stat is adjacent to but does not overlap the Wildlife House ed acceptable in principle. The legality or ed neighbouring site of importance for nature Trust soundness of the proposed use will depend on conservation (SINC). SINCs are a regional the detail of any proposals coming forward. designation and development adjacent to a The following comments therefore neither SINC need not be harmful to its conservation support or oppose the site allocations interest. In response to this representation proposed, but are intended to draw attention to it is proposed to amend paragraph 4.42 to nature conservation factors which may make highlight the need for sensitive design the proposed allocation diverge from national and layout, in relation to the neighbouring policy or Core Strategy policies and objectives, designation, as a minor modification. or make them less preferable sites. See proposed minor modification SA74

COMMENT Policies 27 and 28 of the proposed The above sites include areas which are Development Management Policies DPD designated for their nature conservation provide criteria for the protection and interest as SINCs or SSSIs, or otherwise are enhancement of biodiversity sites. adjacent to sites having this designation.

The Council must consider what impacts may

257 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er result on the SINCs or other designated sites from the particular proposed site allocation. The Council should consider whether any other sites are available for this use/purpose, where any negative impacts may be avoided or reduced.

If any of the above sites are allocated, the

258 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Council should also consider how development may enhance the local ecological network, through habitat creation, habitat improvement, and ongoing positive management. SINCs are an important element of the ecological network, helping to create linkage between other, statutory sites such as SSSIs. Opportunities to improve and strengthen the ecological network should be explored. For instance extending SINCs, managing SINC habitats better for wildlife, creating buffer habitats and habitat corridors or patches between SINCs

CHANGE No specific changes suggested.

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise

259 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

When determining planning applications, paragraph 118 of the NPPF states that local planning authorities should aim to conserve and enhance biodiversity by applying the

260 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er principles listed in the document, amongst which:  If significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;  Proposed development on land within or outside of a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or

261 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

Site H17: Wolstenholme, Rectory Lane, Stanmore HA7 4AQ

NO REPS RECEIVED

Site H18: Edgware Town Football Club, Burnt Oak Broadway, Edgware HA8 5AQ

262 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 3 00 Chris Site Not That this has planning permission granted for Not stated Not The inclusion of the site reflects the fact of an 5 Rogers H18 stat 189 homes (I assume flats but cannot find the stat extant outline planning permission for 189 (Resident) Edgwa ed application on the planning portal despite ed dwellings and the role of this site’s re searching – please provide the planning development in helping to deliver (through Town application reference number) is a concern; the s.106 funding already paid) The Hive football Footba area is already overpopulated and the adjacent academy in Camrose Avenue/Whitchurch ll Club road junction, by council officers’ own Lane. The site specific issues of loss of open admission, poor and overcrowded. A parking space, flooding and highway impacts have CPZ is already in place in Bacon Lane and a already were explored prior to the grant of 20mph zone is being implemented as a direct outline planning permission. Documents result of the above. concerning the approved development on this site, and explaining its relationship with That this application is intended despite the Prince Edwards Playing Fields, have been medium and high probability of flooding and it supplied to the respondent ifollowing the being an areas of deficiency in access to making of this representation. nature conservation is bizarre, frankly. Your No change. own policy states “Harrow's PPG 17 Open Space, Sport and Recreation Study (2010) found there to be existing and projected future shortfalls in the availability of open space over the plan period, and in this context the Core Strategy establishes a presumption against any net loss of open space regardless of ownership and accessibility” – I’m thus unclear as to why development of this type is planned.

263 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Please could you clarify how the grant of planning permission allows completion of the Prince Edward scheme? The GLA First report seems to say that the works stalled when the contractor went bust. But presumably the costs of completion were budgeted for anyway, regardless of any delay caused by the need to find a new contractor, so why was an additional £750,000 needed?

264 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er knock-on effects to Bacon Lane. Why?

I realise all of the above is too late, but you will surely realise that this entire application comes as a surprise to me – I have lived here since 1998 and have never been informed by leaflet drop about this application, which is a concern. 34 07 Thames H18 Not We have concerns regarding Waste Water In this case we ask that the Not Thames Water had raised concerns 6 Water Sou Services in relation to this site. Specifically, the following paragraph is stat regarding waste water capacity and to Utilities Ltd. Edgwa nd sewerage network capacity in this area is included in the Development ed highlight the need for the developer to re unlikely to be able to support the demand Plan. “Developers will be prepare a drainage strategy in liaison with Town anticipated from this development. It will be required to demonstrate that Thames Water, the purpose of which is to Footba necessary for us to undertake investigations there is adequate waste model the network capacity and ensure that, ll Club into the impact of the development and water capacity both on and if mitigation is required, this is undertaken completion of this, on average, takes 12 off the site to serve the ahead of occupation of the development. weeks. It should be noted that in the event of development and that it The Council therefore considers that the an upgrade to our assets being required, up to would not lead to problems combination of Core Policy CS1 Z and three years lead in time will be necessary. for existing or new users. In paragraph 4.20 of the Development some circumstances it may Management Policies DPD adequately be necessary for developers addresses the respondent’s concerns. to fund studies to ascertain No change whether the proposed development will lead to overloading of existing waste water infrastructure.”

Site H19: Hill’s Yard, Bacon Lane, Edgware HA8 5AR

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

265 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 3 00 Chris H19 Not The removal of the existing industrial use is to Not stated Not Support noted. The methodology for 6 Rogers Hill’s stat be supported since the expansion of the site stat estimating the indicative housing capacity of Yard ed and its current activities are wholly ed the allocated sites is explained at Appendix B incompatible with the residential nature of of the DPD. Bacon Lane, again at officers’ own admission. No change. I’m unclear how the figure of 28 units has been arrived at however and would appreciate information on that. 34 08 Thames H19 Not On the information available to date we do not N/A Not Noted. 5 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Hill’s nd Waste Water capability in relation to this site. ed Yard

The London Plan and Development Management Policies DPD provide the framework for securing affordable housing from development sites.

No change. 266

Site H20: 19 Buckingham Road, Edgware HA8 6LY

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H20 Not On the information available to date we do not N/A Not Noted. 3 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 19 nd Waste Water capability in relation to this site. ed Buckin gham Road

Site H21: Land at Canons Park Station, Donnefield Avenue, Canons Park HA8 6RN

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & H21 Not LEGALITY/SOUNDNESS Not stated. Not Site H21: The area allocated for development 6 Middlesex Land stat For the above sites, the allocation may be stat is adjacent to but does not overlap the Wildlife at ed acceptable in principle. The legality or ed neighbouring site of importance for nature Trust Canon soundness of the proposed use will depend on conservation (SINC). SINCs are a regional s Park the detail of any proposals coming forward. designation and development adjacent to a Station The following comments therefore neither SINC need not be harmful to its conservation support or oppose the site allocations interest. In response to this representation proposed, but are intended to draw attention to it is proposed to amend paragraph 4.58 to nature conservation factors which may make highlight the need for sensitive design 267 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er the proposed allocation diverge from national and layout, in relation to the neighbouring policy or Core Strategy policies and objectives, designation, as a minor modification. or make them less preferable sites. See proposed minor modification SA40 Policies 27 and 28 of the proposed COMMENT Development Management Policies DPD The above sites include areas which are provide criteria for the protection and designated for their nature conservation enhancement of biodiversity sites. interest as SINCs or SSSIs, or otherwise are adjacent to sites having this designation.

268 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er measures – for instance, habitat creation on another part of the site; or funding or undertaking management and enhancement work on the SINC or other nearby sites. Compensation and offsetting should never be seen as the first recourse, and should only be used when preferred options of avoiding and mitigating adverse impacts have been exhausted.

CHANGE No specific changes suggested.

269 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er establishing coherent ecological networks that are more resilient to current and future pressures.”

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

Following Paragraph 165 of the NPPF,

270 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er planning policies and decisions should be based on up-to-date information about the natural environment and other characteristics of the area. The Framework directs that this should include an assessment of existing and potential components of ecological networks.

271 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

272 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 08 Thames H21 Not On the information available to date we do not N/A Not Noted. 7 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Land nd Waste Water capability in relation to this site. ed at Canon s Park Station

36 09 Transport H21 Not TfL Property welcomes and supports the N/A Not Noted. 7 for London Land stat stat ‘principle’ of residential development of Site (Consents at ed Proposals H9 and H21. ed Team) Canon s Park Station 43 10 Mr. J. Welby H21 Not A new point I would like to raise is the Local Not stated Not The commentary to the site allocation 9 (Resident) stat Development Plan, which has a date of reply of stat explains that the site is allocated for partial Land ed 7th September. There are issues which need ed redevelopment, with an appropriate amount at addressing. Stanmore and Canons Park of station car parking to be retained, Canon Stations car parks which would be replaced by recognising its role for commuters and during s Park housing. Wembley stadium events. It goes on to state Station that any planning application for the In respect of Stanmore the car park was full redevelopment of the site should be during the Olympics and afterwards would be supported by evidence of car parking 50% to 75% full and if this scheme goes ahead demand, and how that demand will be met, with less car space there is nowhere else to by the re-provision of car parking on the site park as the council put in place a CPZ to keep or elsewhere. cars off the streets. People come from all over No change. the country to park there as it is very costly in Wembley.

Site H22: 5-11 Manor Road, Harrow HA1 2NZ

273 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 4 00 Jack Bye H22 Not Your notice in Manor Road stating that 5 to 11 Not stated Not The representation correctly points out that 7 (Resident) 5-11 stat Manor Road is allocated for future stat the planning permission (allowed on appeal) Manor ed development has caused consternation among ed for this site has now expired. Road local residents. Although the proposal to As no further interest in pursuing the demolish the houses and build flats was redevelopment of this site is apparent, it approved on appeal in 2008 the stipulated is proposed to omit the site from the DPD three years for work to start is well past. as a minor modification. See proposed minor modification SA41 Please will you explain the basis on which the site is included in the LDF for redevelopment and why affected residents were not notified. 9 01 Catherine H22 Not This development was approved for appeal on Not stated. Not The representation correctly points out that 3 Kempt stat 11/06/2008. The developer never went ahead stat the planning permission (allowed on appeal) (Resident) 5-11 ed with the project, because the company were ed for this site has now expired. Manor not in a position to proceed. In the text it states As no further interest in pursuing the Road that these properties have planning redevelopment of this site is apparent, it permission, but it is my understanding that the is proposed to omit the site from the DPD application period expired in 2011. as a minor modification. See proposed minor modification SA41 As this site is residential property and I am the owner and occupier of the freehold property at 5 Manor Road, I would have appreciated the Council notifying me of the proposal to include my property into this DPD and not have to read it on a lamp post outside my house. 22 03 Mr. Derek H22 Not Unsound – Justfied – Effective This site should be removed Not The representation correctly points out that 5 Biddle sou from the list. stat the planning permission (allowed on appeal) (Resident) 5-11 nd This site does not have Planning Permission. The statement relating to ed for this site has now expired. Manor It may have done so when the Council started this site is factually As no further interest in pursuing the Road preparing this document, but this expired in incorrect. redevelopment of this site is apparent, it June 2011 I - as the owner of one of is proposed to omit the site from the DPD the properties (and I as a minor modification. understand, the other See proposed minor modification SA41

274 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er owners) - have no interest in taking this forward. 34 07 Thames H22 Not On the information available to date we do not N/A Not Noted. 5 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 5-11 nd Waste Water capability in relation to this site. ed Manor Road

Site H23: Former Tyneholme Nursery, Headstone Drive, Wealdstone HA1 4UQ

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H23 Not On the information available to date we do not N/A Not Noted. 7 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. Forme nd Waste Water capability in relation to this site. ed r Tyneh olme Nurser y

Site H24: 16-24 Lowlands Road, Harrow HA1 3AT

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

275 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 07 Thames H24 Not On the information available to date we do not N/A Not Noted. 2 Water Sou envisage infrastructure concerns regarding stat Utilities Ltd. 16-24 nd Waste Water capability in relation to this site. ed Lowlan ds Road

Summary of Housing Site Development Capacity

NO REPS RECEIVED

Chapter 5: Strategic Previously Developed Sites in the Green Belt

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 1 00 Hertsmere Chapt Yes Note that the Green Belt boundary is not N/A Yes Support for the protection and retention of the 1 Borough er 5 proposed to be altered between the north of Green Belt is noted. No change. Council the urban area in Harrow and our shared boundary. Hertsmere Borough Council supports the retention and protection of the Metropolitan Green Belt.

1 00 Hertsmere Chapt Yes There are three previously developed sites in N/A Yes Noted. 2 Borough er 5 the Green Belt identified that are close to the No change. Council Borough border. It is noted that Hertsmere Borough Council have been consulted previously on the relevant planning applications, and therefore have no additional comments in relation to these proposed

276 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er allocations.

Site GB1: Former RAF Bentley Priory, The Common, Stanmore

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 02 Mayor of GB1 Yes The allocation of the RAF Bentley Priory, Royal N/A Yes Noted. 2 London Bentle (In National Orthopaedic Hospital, Harrow Collage (In No change. y gen (Brookshill) and Wood Farm sites as strategic gen Priory eral previously developed sites in the Green Belt is eral GB2 conf supported, as is the Council’s intention that conf RNOH ormi development at these sites should deliver ormi , GB3 ty benefits to the Green Belt and improve public ty Harro with access and appreciation wherever possible. with w the Policy 23 of the Development Management the Colleg Lon Policies DPD will be applied, along with Lon e, GB4 don established strategic and national policy, to don Wood Plan manage the sensitive redevelopment of these Plan Farm ) sites. )

15 02 Herts & GB1 Not LEGALITY/SOUNDNESS Not stated. Not Site GB1: The allocated site is adjacent to an 6 Middlesex Bentle stat For the above sites, the allocation may be stat SSSI, a site of importance for nature Wildlife y ed acceptable in principle. The legality or ed conservation (SINC) and a local nature Trust Priory soundness of the proposed use will depend on reserve. The redevelopment of the site has the detail of any proposals coming forward. already been approved and this includes The following comments therefore neither detailed assessment of biodiversity/nature support or oppose the site allocations conservation impacts. Paragraph 5.3 proposed, but are intended to draw attention to already refers to the need to safeguard nature conservation factors which may make biodiversity. In response to this the proposed allocation diverge from national representation it is proposed to elaborate

277 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er policy or Core Strategy policies and objectives, this paragraph, to highlight the need for or make them less preferable sites. re-assessment in the event of substantive changes or additions to the approved COMMENT scheme, as a minor modification. The above sites include areas which are See proposed minor modification SA44 designated for their nature conservation Policies 27 and 28 of the proposed interest as SINCs or SSSIs, or otherwise are Development Management Policies DPD adjacent to sites having this designation. provide criteria for the protection and enhancement of biodiversity sites, and The Council must consider what impacts may paragraph 118 of the NPPF provides for result on the SINCs or other designated sites proposals to be refused where there would from the particular proposed site allocation. be an adverse effect on an SSSI. The Council should consider whether any other sites are available for this use/purpose, where any negative impacts may be avoided or reduced.

278 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er another part of the site; or funding or undertaking management and enhancement work on the SINC or other nearby sites. Compensation and offsetting should never be seen as the first recourse, and should only be used when preferred options of avoiding and mitigating adverse impacts have been exhausted.

CHANGE No specific changes suggested.

279 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er are more resilient to current and future pressures.”

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

Following Paragraph 165 of the NPPF, planning policies and decisions should be

280 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er based on up-to-date information about the natural environment and other characteristics of the area. The Framework directs that this should include an assessment of existing and potential components of ecological networks.

281 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

282 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 34 06 Thames GB1 Not Regarding Chapter 5 Strategic Previously Not stated Not Thames Water had raised concerns 8 Water sou Developed sites in the green belt - We would stat regarding waste water capacity and to Utilities Ltd. Bentle nd have capacity concerns if developments GB1 ed highlight the need for the developer to y Piory GB2 or GB3 where to be considered for prepare a drainage strategy in liaison with housing. Developer would be required to fund Thames Water, the purpose of which is to capacity surveys and possibly be required to model the network capacity and ensure that, fund off site upgrades. if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

Site GB2: Royal National Orthopaedic Hospital, Brockley Hill, Stanmore HA7 4LP

283 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er sites.

15 02 Herts & GB2 Not LEGALITY/SOUNDNESS Not stated. Not Site GB2: The allocated site overlaps sites of 6 Middlesex RNOH stat For the above sites, the allocation may be stat importance for nature conservation (SINC) Wildlife ed acceptable in principle. The legality or ed and is also home to a species of local Trust soundness of the proposed use will depend on biodiversity importance as identified in the detail of any proposals coming forward. Harrow’s Biodiversity Action Plan. The The following comments therefore neither redevelopment of the site has already been support or oppose the site allocations approved and this includes detailed proposed, but are intended to draw attention to assessment of biodiversity/ nature nature conservation factors which may make conservation impacts. Paragraph 5.7 the proposed allocation diverge from national already refers to the need to safeguard policy or Core Strategy policies and objectives, biodiversity. In response to this or make them less preferable sites. representation it is proposed to elaborate this paragraph, to highlight the need for COMMENT re-assessment in the event of substantive The above sites include areas which are changes or additions to the approved designated for their nature conservation scheme, as a minor modification. interest as SINCs or SSSIs, or otherwise are See proposed minor modification SA49 adjacent to sites having this designation. Policies 27 and 28 of the proposed Development Management Policies DPD The Council must consider what impacts may provide criteria for the protection and result on the SINCs or other designated sites enhancement of biodiversity sites. from the particular proposed site allocation. The Council should consider whether any other sites are available for this use/purpose, where any negative impacts may be avoided or reduced.

285 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

CHANGE No specific changes suggested.

Paragraph 114 confirms that local planning authorities should ‘plan positively’ for the creation, protection, enhancement and management of ecological networks and green infrastructure.

Paragraph 117 states that, in order to minimise impacts on biodiversity, planning policies should inter alia:  plan for biodiversity at a landscape- scale;

286 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er for habitat restoration and creation;

287 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;  Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged;  Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits or, the development in that location clearly outweigh the loss.

288 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er measures required cannot be secured through appropriate conditions or agreements.”

NOTE: The government circular 06/2005 Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System, has been retained and remains as valid guidance for local planning authorities on decisions affecting protected species and designated nature conservation sites. 34 06 Thames GB2 Not Regarding Chapter 5 Strategic Previously Not stated Not Thames Water had raised concerns 9 Water sou Developed sites in the green belt - We would stat regarding waste water capacity and to Utilities Ltd. RNOH nd have capacity concerns if developments GB1 ed highlight the need for the developer to GB2 or GB3 where to be considered for prepare a drainage strategy in liaison with housing. Developer would be required to fund Thames Water, the purpose of which is to capacity surveys and possibly be required to model the network capacity and ensure that, fund off site upgrades. if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

35 09 Drivers GB2 Not The current Masterplan for Not As explained at Appendix B of the document, 2 Jonas sou stat where a site has planning permission for We write on behalf of our client, the Royal the site seeks to deliver Deloitte RNOH nd National Orthopaedic Hospital NHS Trust (the ed residential development (but has not started) (for Royal ‘Trust’) to make representations to the London approximately 300 the site has been allocated in the DPD with National Borough of Harrow (“LBHarrow”) Local residential dwellings. the corresponding number of homes. orthopaedic Development Framework (LDF) Site Paragraph 5.7 of the commentary to the Hospital Allocations Development Plan Document Accordingly, the Trust urges allocation that the desirability of providing NHS Trust) (SADPD) Pre-submission Consultation which the Council to amend Draft new hospital accommodation may constitute ends on 7th September 2012. very special circumstances for enabling 289 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Site Allocation GB2 to development that would otherwise be reflect this uplift in inappropriate development in the Green Belt. Representations have also been prepared on The number of homes cited in the allocation behalf of the Trust to the concurrent residential dwellings. reflects the approved quantum of enabling Development Management Policies DPD development to that end, but the need for any Proposed Submission Consultation and are Since the submission of the increase in the number of homes (and submitted under separate cover. former planning application consideration of the associated impact upon These representations are made with specific for the RNOH site, the Trust openness) should be formally demonstrated reference to Draft Site GB2 ‘Royal National has purchased additional through the planning application process and Orthopaedic Hospital, Brockley Hill, Stanmore, land to the north of the site. not pre-empted by the allocation. It Is not HA7 4LP’. The Trust acknowledges that this It is the intention of the Trust considered that the site allocation, with an stage of consultation seeks to address to include this area of land indicative number of homes, would be an ‘soundness’ and ‘legal compliance’. within the current proposals impediment to a greater residential capacity if to deliver an important new that is demonstrated to be necessary to Site Location public amenity zone. deliver the objective of the replacement

The RNOH site is located in the LB Harrow, hospital complex. The site allocation should No change. approximately 14 miles North West of central therefore include the site in London and 9 miles to the south of StAlbans. its entirety and we append However, in response to this The immediate area is predominantly an OS Map (Appendix 1) representation it is proposed to amend setting out the extent of the countryside and farmland, with existing the site boundary, to reflect the up-to-date Trust’s land ownership, residential and Stanmore centre located 1.3 extent of the hospital’s ownership, as a which now amounts to minor modification. It is also proposed to miles to the south. approximately 43 hectares. amend the site details to refer to hospital development under ‘other proposed The area is well serviced by major trunk roads uses’. with Junction 4 of the M1approximately 0.5 At present, draft site See proposed minor modification SA45 miles to the north and J21 of the M25 allocation GB2 refers to residential development only approximately 10 miles to the north west of the within the site details. There site. Stanmore Underground station is 1.3 are no ‘other uses proposed’ miles to the south which provides links into within this section. The central London on the Jubilee line. Elstree and Trust suggests that LBH Borehamwood Train Station, which provides also include ‘hospital’ development within this direct services to St. Albans and Luton Airport 290 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

to the north and London St. Pancras in 25 section also. This will both reflect the redevelopment minutes, is two miles to the north east. Site aspirations for both hospital plans are included in Appendix 1 and 2. and residential development for the site, and ensure Some parts of the site are densely wooded, robustness for this site whilst others are open with the present building allocation. stock distributed over a large proportion of the eastern, southern and western parts of the site.

Other than its Green Belt setting, the single

most important element of the site is its topography. There are very significant changes in the levels across the site and although there are many local variations, the general topography has a pronounced fall from south to north, amounting to as much as 20 metres from the Wood Lane boundary to the northern edge abutting the adjacent farmland.

The open space within the site comprises open grassland, scrub, orchard, woodland, scattered trees and agricultural fields. Trees within the site are subject to a Tree Preservation Order (“TPO”). Part of the site lies within a Site of Nature Conservation Importance (“SNCI”); a non-statutory designation for an area comprising flora and fauna of regional importance. Part of the site is designated as a Site of Metropolitan Importance

291 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

The main site access is from Brockley Hill with additional site access available via entrances on Wood Lane and Warren Lane. Most staff and patients travel to the site by private motor vehicle. However Transport for London (‘TfL’) provide a bus service along Brockley Hill that links the hospital to Barnet & Chase Farm Hospitals NHS Trust, Elstree and Borehamwood main line station and Edgware underground station. The 615 Uno bus service has also been recently diverted to stop alongside the rear entrance of RNOH on Wood Lane, and serves Stanmore Station through to Hatfield.

Background The RNOH is the largest orthopaedic hospital in the UK, and is regarded as a leader in the field of orthopaedics both in the UK and world- wide. It provides a comprehensive range of neuro-musculoskeletal healthcare, ranging from acute spinal injuries to orthopaedic medicine and specialist rehabilitation for chronic back sufferers. The broad range of neuro-musculoskeletal services offered at RNOH is unique within the NHS.

However, the existing RNOH facilities no longer meet the current and future operational

292 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

demands of service provision and patient care. In particular:

. 60% of the site’s current buildings are more than 60 years old;

. The buildings are not energy efficient and the site’s engineering infrastructure is out-dated and in need of replacement;

. Car parks are located far from the buildings, which makes access to the hospital buildings difficult for patients;

. Many patient wards were originally designated for temporary war-time use only;

. The main ward areas have a steep slope, which makes transporting patients and equipment difficult; and

. The site layout is not ideal for patient care or staff efficiency as patients and staff frequently have to travel between buildings, often

293 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

outdoors across uneven ground.

“Partial redevelopment to provide new hospital and associated facilities, housing (including staff), revised road junction, car parking and open space.”

294 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

(England) Order 2009 (SI No. 2261)) an application to renew this planning permission was submitted in January 2010.

However, a new outline planning permission is now being prepared as the extant planning permission for the RNOH site no longer secures the best outcome to the Trust.

On behalf of the Trust, and in light of the current proposals for the site, we set out below comments on Draft Site Allocation GB2.

Draft Site Allocation GB2 As set out in Draft Site Allocation GB2, the RNOH site is a strategic, previously-developed site within the Green Belt because of the need to secure the modernisation of nationally significant health care facilities. The draft allocation continues to state that the desirability of providing new accommodation for the hospital is a significant consideration and may constitute ‘very special 295 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

circumstances’ for some enabling development that would other be considered ‘inappropriate development’ in the Green Belt. The acknowledgement of the need for enabling residential development to secure the future operation of the RNOH from this site is supported by the Trust.

On behalf of the Trust, we set out below justification for concerns regarding soundness.

The Trust considers the draft site allocation to be ‘unsound’ as it provides insufficient flexibility for the future aspirations of the Trust to redevelop the site. This is due to the draft site allocation including an out-of-date assumption on the amount of residential dwellings that the site can accommodate. Site Allocation GB2 currently states that the site has the capacity to accommodate 127 dwellings. However, this figure is based on the old outline planning application for the site.

296 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

In light of paragraph B1, we highlight that the Trust has entered into a Planning Performance Agreement (PPA) with LBH in respect of the new development proposals for which the preparation of the planning application is ongoing. The PPA acknowledges the shared desire of both the Trust and LBH to secure the future of the RNOH site, and has formed the basis for a series of focussed pre-application workshops that have been held over the past eight months between the Trust and LBH to discuss the redevelopment proposals for the site.

Accordingly, the Trust urges the Council to amend Draft Site Allocation GB2 to reflect this uplift in residential dwellings.

Site Boundary Since the submission of the former planning 297 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er application for the RNOH site, the Trust has purchased additional land to the north of the site. It is the intention of the Trust to include this area of land within the current proposals to deliver an important new public amenity zone. The site allocation should therefore include the site in its entirety and we append an OS Map(Appendix 1) setting out the extent of the Trust’s land ownership, which now amounts to approximately 43 hectares. Other Proposed Uses At present, draft site allocation GB2 refers to residential development only within the site details. There are no ‘other uses proposed’ within this section. The Trust suggests that LBH also include ‘hospital’ development within this section also. This will both reflect the redevelopment aspirations for both hospital and residential development for the site, and ensure robustness for this site allocation. Summary The Trust is grateful of the opportunity to make representations to this document and would like to be kept updated of future progress with the Harrow LDF.

Site GB3: Harrow College, Brookshill, Harrow Weald HA3 6RR

298 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er y gen (Brookshill) and Wood Farm sites as strategic gen Priory eral previously developed sites in the Green Belt is eral GB2 conf supported, as is the Council’s intention that conf RNOH ormi development at these sites should deliver ormi , GB3 ty benefits to the Green Belt and improve public ty Harro with access and appreciation wherever possible. with w the Policy 23 of the Development Management the Colleg Lon Policies DPD will be applied, along with Lon e, GB4 don established strategic and national policy, to don Wood Plan manage the sensitive redevelopment of these Plan Farm ) sites. )

17 03 Harrow GB3 Not We would like to clarify that the commentary Not stated Not Following this representation officers met 0 College stat (relevant extract shown below) no longer stat with the Principal and Finance Director of the Harro ed reflects the primary plan for this site. This ed College on 21st September 2012. The w reflects a position from some years ago when College does not envisage releasing the site Colleg the Learning and Skills Council planned to for residential development during the current e make a very substantial grant available for plan period (2009-2026) but instead retaining redevelopment of the Lowlands Road site (the it in use as part of Harrow College, with "One Harrow" project). This plan did not come possible replacement of some of the existing into fruition and no external funds were buildings on the site in the event of an invested in the site. It is highly unlikely that the improved financial outlook. As successor bodies to the LSC will have any comprehensive redevelopment of the site is significant capital for investment in College unlikely during the plan period, the College infrastructure projects in this, or indeed the requests that the existing building to the north next, public sector spending round. Without a of the complex be included within the ‘red substantial injection of external capital, funds line’ development envelope of this Green Belt released from redevelopment of the Brookshill site. site alone would be insufficient (by a very considerable amount) to enable improvement In response to this representation it is of the Lowlands Road campus to the extent therefore proposed to revise the site that it could provide additional facilities for details, to delete references to number of activities conducted at the Brookshill site. homes, and to replace under a new heading of ‘proposed allocation’ reference The College has therefore revised its property to educational development and other 299 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er strategy to reflect this, and now intends uses associated with the College, as a redeveloping both sites on a modular basis to minor modification. The commentary will improve education facilities and opportunities also be amended to reflect the revised for the Borough. This will be done in the full allocation. spirit of the Development Management Policies See proposed minor modification SA50, framework, with particular focus on supporting SA51, SA52 & SA53 employment and economic development; sustainability; community infrastructure and enhancing biodiversity.

300 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Belt openness. 5.12 Open land to the north of the existing complex of buildings could form an extension to Harrow Weald cemetery. The Council will seek the investigation of this possibility as part of any proposal for the development of the site, consistent with paragraph 10.11 of the Harrow Core Strategy (2012). 5.13 The housing capacity figure has been estimated using the London Plan sustainable residential quality density matrix, in accordance with the methodology set out at Appendix 2 but using the built footprint of the site (0.75 hectares) as the site area. 34 07 Thames GB3 Not Regarding Chapter 5 Strategic Previously Not stated Not In light of the representations made by this 0 Water sou Developed sites in the green belt - We would stat respondent to the Development Management Utilities Ltd. Harro nd have capacity concerns if developments GB1 ed Policies DPD pre-submission consultation, it w GB2 or GB3 where to be considered for is proposed to modify the reasoned Colleg housing. Developer would be required to fund justification to Policy 17 to draw attention to e capacity surveys and possibly be required to the allocated development sites where fund off site upgrades. Thames Water had raised concerns regarding waste water capacity and to highlight the need for the developer to prepare a drainage strategy in liaison with Thames Water, the purpose of which is to model the network capacity and ensure that, if mitigation is required, this is undertaken ahead of occupation of the development. The Council therefore considers that the combination of Core Policy CS1 Z and paragraph 4.20 of the Development Management Policies DPD adequately addresses the respondent’s concerns. No change

301

Site GB4: Wood Farm, Wood Lane, Stanmore HA7 4LJ

15 02 Herts & GB4 Yes LEGALITY/SOUNDNESS Not stated Yes In response to this representation it is 7 Middlesex The allocation is considered legal and sound in proposed to amend paragraph 5.16, to Wildlife Wood principle. ensure that any biodiversity impact from Trust Farm the residential development is avoided (or COMMENT mitigated where unavoidable), as a minor HMWT supports the extension of Stanmore modification. Country Park in principle, and its management See proposed minor modification SA54 as a nature reserve. The allocation site and surrounding areas are of notable value to wildlife. Pear Wood to the east is thought to be ancient, and has a diverse ground flora indicative of ancient origins. Pear Wood and Stanmore Country Park are designated as a SINC of metropolitan importance; the southern section of the site is designated also as a Local Nature Reserve. The majority of the site GB4 indicated on the map is SINC of borough grade

302 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er II importance. By incorporating this area into the Country Park, ensuring positive conservation management is put in place across the site, and managing recreational use so that public enjoyment and learning from the site is maximised without detriment to its ecological interest, its ecological importance may increase.

It must be ensured further that no detriment occurs to the metropolitan-grade SINC, including Pear Wood.

CHANGE No specific changes suggested.

303 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er JUSTIFICATION As per previous comment for H9, H13, H14, H16, H21, GB1 and GB2

Summary of Previously-Developed Sites in the Green Belt Development Site Capacity

NO REPS RECEIVED

Chapter 6: Open Spaces

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 13 02 Mayor of Chapt Yes The increased allocation of land for open N/A Yes Noted. 3 London ers 6 & (In space and biodiversity is supported in line with (In No change. 7 gen London Plan policies 7.18 and 7.19. gen eral eral conf conf ormi ormi ty ty with with the the Lon Lon don don Plan Plan ) ) 41 10 English Chapt Not In line with our previous comments it is not Not stated Not The basis for open space designations in 4 Heritage er 6 stat clear whether all of the open space stat Chapter 6 is explained at paragraph 6.4 of ed designations have been informed by the ed the DPD, i.e. informed by Harrow’s PPG 17 London Parks and Gardens Inventory of green Study (and not the Inventory referred to). spaces and parks. It would be useful to get clarity on this point. However as the minor open space 304 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er designations are included simply to update In addition the level of detail provided with the open spaces designation on the Policies regards to the heritage value of opens spaces Map and do not contain specific proposals is still variable, in the case of the Major Open (i.e. for new public access) it is not necessary Spaces. In the case of Minor Open Spaces the to identify the heritage value of these sites. no details are provided. As raised before some No change. of these open spaces are of historic importance of contribute to the significance of heritage assets. For example Site OS01: St Mary’s Church Yard, Harrow on the Hill, is covered by a number of heritage designations, such as the setting to the Church (grade I), include a number of listed structures (e.g. grave stone of Thomas Port – grade II, Lynch Gate - grade II), setting to other neighbouring listed buildings (e.g. Harrow School Speech Room – grade II*) and falls within the Harrow on the Hill Conservation Area. These are sensitivities which should be raised in the commentary for all of the Minor Open Spaces where relevant.

Site MOS1: Land at Brigade Close, Harrow on the Hill

NO REPS RECEIVED

Site MOS2: Land Rear of 121-255 (odds) Pinner Road, West Harrow

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

305 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 15 02 Herts & MOS2 Not LEGALITY/SOUNDNESS Omit enabling residential Not In response to this representation which 8 Middlesex stat As this allocation is essentially ‘positive’, it is development potential from stat casts doubt on the value of allocating this Wildlife Land ed less of a concern in policy terms and there is the proposed allocation and ed site as a new nature reserve (confirmed Trust Rear less of a basis on which to judge its soundness consider the potential by the Council’s Biodiversity Officer), and of 121- than, for instance, there would be with built ecological value of the site. in the absence of evidence about the 255 development. However, it is not clear that this nature conservation value of the site, it is Pinner particular site will contribute in any measurable proposed to omit the site from the DPD as Road way to improving nature conservation in the a minor modification. It is also noted that area, why it is preferable for this allocation than a number of individual and groups of other sites, or whether the site would be trees on the site are the subject of tree ‘effective’ as a nature reserve (in terms of preservation order protection. increasing local biodiversity and improving See proposed minor modification SA57 ecological connectivity and function).

COMMENT HMWT has reservations about this site allocation. The site is put forward as a new Local Nature Reserve.

Secondly, the site is only 0.9 hectares. This is very small, and would constrain its potential value for nature and potential contribution to the local ecological network and its functioning.

Finally, the Site Allocations document sates that the Council may consider allowing “enabling residential development” on the part of the site fronting the Gardens. This would reduce the size of the nature reserve further,

306 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er and also introduce extra pressures on the nature reserve area, which would again reduce its attractiveness and usefulness for wildlife. Furthermore, it is difficult to see how a site of this small size will require ‘enabling’, as the costs of establishing and managing the site as a nature reserve will be relatively low.

307 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er conservation sites are an important part of green infrastructure, which is a necessary and valuable infrastructure type for local communities.

JUSTIFICATION As per comment for H9, H13, H14, H16, H21, GB1 and GB2. 31 05 Scott MOS2 Not Not justified or effective An ecological/habitat survey Yes In response to this representation which 7 Planning sou should be carried out to casts doubt on the value of allocating this Associates Land nd The proposal to designate this site as a nature ascertain whether the site as a new nature reserve (confirmed (for Rear reserve appears to have been carried forward proposal can be backed up by the Council’s Biodiversity Officer), and Silveracre of 121- from the Unitary Development Plan (2004) by evidence. in the absence of evidence about the Estates Ltd.) 255 without any research into its appropriateness nature conservation value of the site, it is Pinner and without any agreement from the site Discussions with the owners proposed to omit the site from the DPD as Road owners (delivery partners) or discussion with should be entered into to a minor modification. It is also noted that them. ascertain whether the a number of individual and groups of proposal is deliverable. trees on the site are the subject of tree Our client (Mr R Parmar of Silveracre Estates preservation order protection. Ltd) is the freehold owner of the above site, Deletion of the site as a See proposed modification SA57 and Scott Planning Associates has been Nature Reserve, if instructed to review the Site Allocations DPD appropriate. and submit representations on their behalf as part of the Pre-Submission Consultation exercise. 308 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

We write further to the representations t hat were made (on the Representation Form) on 7 September2 012 about the above site and in regard to Policy MOS2. In a telephone conversation the same day Mr. Paterson kindly offered an extension of time (one week) during which further representations could be made. T his letter comprises t hose further representations.

Planning permission was granted in March 1999 but was never implemented and expired in March 2004. Then in July 2004 the replacement UDP identified the site as a proposed nature reserve (PS39).

Despite this, the site has never to our

309 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er knowledge been designated as a SINC for Metropolitan, Borough or Local Importance. nor are we aware that any comprehensive ecological survey has ever been undertaken to discover what features or species of nature conservation interest there may be on the site.

310 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er guidance encourages the selection of sites on the basis of an assessment against specific criteria (set out in paragraph5 0), and also the early engagement of site owners so as to discuss access to a site for a survey and the potential implications of designation an d to offer an opportunity for a site owner to raise any issues (paragraph 33). At the time of writing it is understood that there has been no engagement of the current owners in the process of designating the site as a Local Nature Reserve. This would have been particularly beneficial in view of the statement in the Site Allocations Pre-Submission DPD that:

311 Site MOS3: Harrow Weald Park, Brookshill, Harrow Weald

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 41 10 English MOS3 Not Planning Designation & Commentary – West Not stated Not In response to this representation it is 5 Heritage stat Drive conservation Area should be explicitly stat proposed to amend the planning Harro ed named and commentary given that the open ed designations section and commentary of w space is an integral part of the areas site MOS3 to identify the name of the Weald designation as a heritage assets. relevant conservation area. Park See proposed modification SA58

Site MOS4: Glenthorne, Common Road, Stanmore

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 18 03 M MOS4 Not We understand that that the area referred to as Glenthorne should have Not The inclusion of the site continues an existing 1 Chomistek stat ‘Glenthorne’ has been recognised as a restricted access. stat UDP allocation and is justified by an up to & J ed Conservation area as highlighted in UDP EP39 ed date PPG 17 Study, which highlights an Floodgate point 3.129. “A rich variety of flora and fauna existing and projected future shortfall in (Residents) are to be found at Glenthorne, including some publicly accessible open space over the plan uncommon species and valuable habitats. period. Access may need to be restricted to protect No change. habitats and wildlife from undue disturbance, thereby ensuring their continued survival, and However, in response to this that future generations are afforded the representation and upon the advice of the opportunity to enjoy them”. As a preliminary Council’s Biodiversity Officer, it is investigation has identified that Glenthorne has proposed to revise the allocation to ‘use uncommon species and habitats we would in association with Bentley Priory’ and to strongly suggest that a further review of this amend the commentary to highlight the area should take place by specialist bodies for need for an up-to-date assessment of the environmental assessment. Also we believe site’s biodiversity value, environmental that due to the development of the Bentley condition (including the trees) and the Priory former RAF Base there has been a implications of public access, as a minor 312 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er significant loss of woodland/vegetation and modification. many species of wildlife have now moved into See proposed modification SA60 & SA63 the Glenthorne area as it is undisturbed. We strongly believe Glenthorne should not be The assessment is to inform how the site is adjoined to Bentley Priory as we feel this would managed as part of Bentley Priory open be detrimental to the flora and fauna and space and the suitability/extent of public valuable habitats and feel that such a proposal access that may be appropriate. As with would be against the ‘Sustainability Appraisal other major open space allocations, it is of Development Management, Site Allocations envisaged that funding would principally and Area Action Plan DPD Regulation 19’ derive from Community Infrastructure Levy points 4.64, 4.75, 4.77 and 4.79. We would revenue. like to understand better how the council proposes to protect the flora and fauna which A small part of the site is leased by the has existed there undisturbed for many years if Council to the Metropolitan Police as a the area is opened up to the public. wireless station. It is therefore proposed to revise the commentary, to make reference to the need to ensure the Also we would point out that the Glenthorne security of this facility, as a minor area is already deemed to be hazardous to the modification. general public (as identified in the UDP - See proposed modification SA63 revised July 2004 - part 2 section 17 PS 23). To highlight just some examples there are Detailed consideration of parking and access dangerous trees, barbed wire is littered arrangements a matter for any consequent around, broken bottles and plate glass, etc. It planning application to make the site publicly is our belief this would require a great accessible. Investigation has revealed that a investment of money and expense to ensure small area to the south of the site is the that the area is ‘cleaned up’ in order protect the subject of an area-wide tree preservation health and safety of all visitors. We also order but this need not affect the allocation. understand that currently the Bentley Priory The obelisk referred to is not designated as a Nature Reserve Management Committee heritage asset, however the adjacent works in partnership with the Harrow Nature Glenthorne Lodge is a locally listed building Conservation Forum and the Committee are and the cast iron gates are referred to in the intending to apply for a ‘Your Heritage Lottery listing (see response to English Heritage Fund’ grant to undertake important habitat representation no. 102). restoration work. Therefore it is hard to No change.

313 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er understand how the Council is able to fund opening up Glenthorne given the expense that will be required to enable it be used by the public.

314 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er not further hindered.

We are aware of at least one tree that has been numbered, (0444) which we believe to mean that it has a Tree Preservation Order (TPO). There are other trees of similar significance to this tree in the Glenthorne area, therefore further investigation may be required to identify if any other trees require TPOs and a plan should be put into place to protect these trees for future generations.

Furthermore to the south west of the Glenthorne site it appears that what is currently an area used by the Metropolitan Police seems to be included in DPD, this may need to be investigated in order to identify ownership.

We would reiterate that we believe that 315 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

Glenthorne should have restricted access; permission should only be granted to conservationist and specialist groups in order to protect the habitats and wildlife from undue disturbance.

In summary we are completely against this proposal as stated in the above points, and feel that it is against point E.7 in the ‘Site Allocations Pre-Submission DPD’ document in that it is difficult to understand what ‘social, environmental, economic and resource use objectives of sustainability’ will be achieved by opening up Glenthorne to the public.

We trust that our views will be taken into account when considering the future development of the Glenthorne site. 41 10 English MOS4 Not Planning Designation & Commentary – For Not stated Not In response to this representation it is 6 Heritage stat completeness purposes, the grading of Bentley stat proposed to amend the planning Glenth ed Priory Historic park and garden should be ed designations and commentary section of orne stated (grade II), plus the commentary should site MOS4 to identify the grading of the recognise the value of this designation, in that adjacent Bentley Priory open space. this open space has historic interest which See proposed modification SA63 should be carefully managed.

316 Site MOS5: The Santway, Clamp Hill, Stanmore

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 2 00 Michael Site Not Though you very kindly assured me that his Not stated Not The inclusion of the site derives from 4 Weiser MOS5 stat will not affect The Santway personally, stat Harrow’s PPG 17 Study, which highlights an (Resident) The ed obviously I am very concerned and still would ed existing and projected future shortfall in Santw like to express my opinion on this matter, publicly accessible open space over the plan ay period and which identifies this and other Normally I would not have any objections to sites as ‘candidate’ sites for the provision of members of the public using any footpaths additional natural/semi-natural open space. provided including any forest land. The allocation recognises the need to There are various footpaths already situated in address security when public access to the the area which consists of two in Common site is realised. This and other necessary Road, one next to Glenhall Cottage, one works would form part of a feasibility study opposite The Princess Alexandra Home and prior to any planning application and one on the left before Hive Road approximately associated consultation with neighbouring 600 yards before the Alpine Restaurant traffic residents. lights. In response to this representation, it is There are two at the Clamp Hill end of Old proposed to revise the commentary to the Redding. allocation to highlight the need for an assessment of the site’s biodiversity There is one situated just after the roundabout value, environmental condition (including at the bottom of Clamp hill (a nature trail). the ground surface) and the implications of public access, as a minor modification. There is one situated almost opposite The The assessment to inform how the site is Santway between Bentley Primary School and managed including the extent/ the Farm, plus there is another footpath management of public access. situated in Brookshill Close and yet another See proposed modification SA65 200 metres up Clamp Hill on the left hand side before the nursery.

There are two others in Brookshill which backs onto Clamp Hill nursery.

317 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er All these paths are very rarely used (for family exploring) mainly due to the lack of parking facilities and they are only used by handfuls of people on foot and usually at weekends only.

With regard to the forest land between the cemetery and The Santway, this area has always been faced off mainly due to the danger of the forest land being very uneven, lots of ups and downs, pot holes and camouflaged trenches plus continuous falling trees and branches, plus the remains of Belgrano House.

318 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er disturbed.

Finally the other main reason being that of security.

Because of what has happened in the past we have both become very security minded especially living in this secluded area.

At this present time the general public are not at liberty to explore this area which allows us to feel less vulnerable and enjoy our home without inquisitive interruptions.

21 03 Mr. & Mrs. MOS5 Not Our property back onto Oak Lodge, and with None stated Not The allocation recognises the need to 4 Scott stat only a field behind for security if this plan goes stat address security when public access to the (Residents) The ed ahead our property would be very vulnerable. ed site is realized. This and other necessary Santw The only way to secure it would be to build a works would form part of a feasibility study ay fence along the length of our garden at great prior to any planning application and associated consultation with neighbouring

319 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er cost. residents. No change. People are inquisitive and they would wonder what is beyond the proposed pathways and blunder into our properties, to which could lead to unsavoury characters checking out what is worth stealing, and in today’s climate that is a distinct possibility.

24 03 Mrs. P. MOS5 Not I am writing with regards to the notice of intent Not stated Not The inclusion of the site derives from 7 Giles stat to turn the woodland at the rear of my property stat Harrow’s PPG 17 Study, which highlights an (Resident) The ed into public natural woodland. ed existing and projected future shortfall in Santw publicly accessible open space over the plan ay Having looked at your plans for the period and which identifies this and other development, firstly I do not agree with the sites as ‘candidate’ sites for the provision of boundaries you have market out and secondly additional natural/semi-natural open space. I am concerned and worried that the public will be able to overlook my private property, which The allocation recognises the need to in this day and age seems that by allowing any address security when public access to the Tom, Dick or Harry onto and around my land site is realised. This and other necessary as you can understand would make me very (e.g. public safety) works would form part of a vulnerable to trespass and even burglary of feasibility study prior to any planning which I have been a victim of twice already. application and associated consultation with neighbouring residents. We have a lot of nature walks and natural woodland around the surrounding area, that In response to this representation it is does not affect the residents privacy and proposed to amend the boundary of the vulnerability, and I feel sure that a few acres proposed allocation, to properly reflect more would not add a lot more to peoples the extent of the site within the Council’s enjoyment, but would put more stress and ownership (but excluding land leased to worry to the residents who live around the third parties), as a minor modification. proposed site. See proposed modification SA64

There is also a concern regarding the pond

320 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er which is on my property, which would be construed as a great danger to children and pets from drowning in the pond and also stopped some from going in after their dog, who jumped in after some ducks. We also had to call the fire brigade twice after someone started a fire in the woods at the rear.

I do hope that your committee takes heed of this letter and comes to a sensible conclusion regarding this matter.

Site MOS6: Prince Edward Playing Fields, Whitchurch Lane/Camrose Avenue, Edgware

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environment MOS6 Sou We support this site allocation because it N/A Not Noted. 4 Agency nd includes consideration of flood risk in stat Prince accordance with the National Planning Policy ed Edwar Framework. d Playin g Fields

Site MOS7: Whitchurch Playing Fields, Wemborough Road, Belmont

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 321 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 30 05 Environment MOS7 Sou We support this allocation as it states N/A Not Noted. 5 Agency nd development will not prejudice the role of this stat Whitch site as a flood storage area. ed urch Playin g Fields (Para 6.17) 30 05 Environment MOS7 Sou We support this site allocation because it N/A Not Noted. 6 Agency nd includes consideration of flood risk in stat Whitch accordance with the National Planning Policy ed urch Framework. Playin g Fields (Para 6.18)

Minor Open Space Designations:

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 5 00 Phil O Dell Chapt Not The grass verges in Church Lane, Wealdstone, Designate grass verges in Not The verges were not identified as amenity 8 (Councillor) er 6 stat Harrow should be included in the green spaces Church Lane as open space stat greenspace in the PPG 17 Study therefore ed listings . (chapter 6) ed there is no evidential justification for designating them as such. No change. 5 00 Phil O Dell Chapt Not The grass verges in Enderley Road should be Designate grass verges in Not The verges were not identified as amenity 9 (Councillor) er 6 stat included in the green spaces listings Enderley Road as open stat greenspace in the PPG 17 Study therefore ed ed there is no evidential justification for 322 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er space (chapter 6) designating them as such. No change.

Chapter 7: Biodiversity

Chapter 8: Other

Site G01: Harrow School Estate, High Street, Harrow on the Hill

NO REPS RECEIVED

Site G02: Belmont Clinic, Kenton Lane, Belmont

NO REPS RECEIVED 323

Site G03: St. George’s Playing Filed, Pinner View, North Harrow

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 12 01 Gerald Eve GO3 Not We act for St George's Headstone Parochial Amend the allocation to Not It is considered that scouting is in some 6 LLP stat Church Council who own this site and on remove the scout hut and its stat significant part an open space use and (for St. St. ed whose behalf we are instructed to make curtilage from the open ed therefore the continued allocation of this part George’s Georg representations in response to your Council's space designation and show of the site (together with the group’s HQ Headstone e’s draft Site Allocations Pre-Submission DPD. designate instead for building) as open space is justified and Parochial Playin community use. effective, consistent with the parallel example Council) g Field Our clients support the proposal to identify that of the tennis club and its pavilion building. part of the site which is the subject of consented housing development separately The NPPF and the Development from the open space designation. Management Policies DPD provide safeguards for social/community facilities, However, we do not think that it is justified or such as the scout hut, but this does not effective to continue to include within that open negate the conclusion that it is appropriate to space designation the small area of land include the premises as part of the open presently occupied by the Headstone Scouts space designation. as their HQ (the 'Scout Hut') which comprises an area of land which is essentially a northern No change. continuation of that strip of land on the west site of the playing field that has been allocated for residential development. This area of land should be allocated for community uses and not for open space.

In following the logic of this conclusion, there is a distinction to be drawn between the Scout Hut and the pavilion at the tennis club to the north of the site, which is there to support the open space use and ancillary to it. 37 09 Mrs Marion G03 Not Not justified, consistent with national policy or Harrow is deficient in open Not The allocation contained in the DPD reflects 8 Garner- sou positively prepared. space. We refer to paras legal the planning history for this site, following Patel St. nd 5.33, 5.34 and 5.35. There which there is an approved scheme for

324 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er (Resident) Georg We refer to St. George’s Playing Field I Appeal is a shortage of hockey and residential development to enable the e’s & II Appeal. Both Inspectors made decision on junior football pitches. The remainder of the field to be restored as open Playin premise that the tennis courts were NOT part planning permission will be space that is accessible to the community. g Field of open space. Consideration and hopefully overturned by a The allocation also amends the open space misunderstanding on how the tennis and judicial review. We hope designation to cover the full extent of the cricket clubs over 75 years old were treated that the whole of St. tennis courts. and evicted not taken into account. George’s Playing Field will No change. be reinstated as opens pace and once more open to the parishioners who bought it in 1923. Harrow is meeting housing targets. Why build on open space?

Reason for attendance at oral examination: To explain the background, history and how the community of Headstone have fought hard to preserve the whole open space of St. George’s Headstone Playing Fields. All evidence is available on the town green documents application held by the Council and the two appeals.

38 09 Sandra-Lee G03 Not I should like to submit my combined comments Not stated Not Harrow’s Core Strategy, adopted February 9 Palmer stat regarding green open spaces in Harrow in this stat 2012, provides a clear policy basis for the (Resident) St. ed letter, which falls under Policy 25. ed protection of open space and for directing Georg new development to brownfield land. e’s In my opinion it Is absolutely vital that ALL However the decisions referred to, including Playin existing open spaces, parks, playing fields, that of the subject site, pre-date the Core sports grounds and the like are fully protected Strategy but were made in the context of the 325 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er g Field from any development. Since the 1980s we Harrow Unitary Development Plan (2004), have seen far too many green open spaces the remaining saved provisions of which will lost to medium and high density development be superseded upon the adoption of the projects to the detriment of the local residents, Development Management Policies DPD old and new. With an ever-increasing (and the AAP in respect of the Intensification population and fewer properties with a Area). In the case of Kodak the open space reasonably sized garden, we are in desperate is to be re-provided (and increased) as well need of open spaces where residents of all as finding of improvements that will increase ages can go to benefit from individual and the carrying capacity of existing sports team sports and recreational activities. Open facilities. spaces are places where residents can go, indeed should go, to bond with their The allocation contained in the DPD reflects neighbours. Youngsters should be encouraged the planning history for this site, made under to be active and providing sports grounds in a previous development plan policies, but clean and safe environment is key to achieving following which there is nonetheless an this. approved scheme for residential development to enable the remainder of the The primary concern of Harrow Council must field to be restored as open space that is be the residents who live and will live in the accessible to the community. immediate vicinity, not the developers or No change. religious groups from outside the area that wish to build on green open space rather than the many unused brownfield sites in the borough, both small and large. In such cases the sole beneficiaries are the applicants, because they always place their needs and profit targets before any possible advantage to the community.

326 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er with full justification, but lost to the incorrect findings of the Planning Inspector. I hope that this consultation process is genuine and the Council will adopt a policy that fundamentally protects all open space in the borough, which is national and local planning policy.

It is essential that the policy should not depend on how or when publicly or privately owned open spaces are used, or if they have been used at all in the past few years, as it is well known that owners often deliberately prevent the use of open spaces in order to justify the sale of the land. The important factor to remember is that ALL open spaces are vital to the enlarged and diverse communities and hence they have an inherent value to the neighbourhood that cannot be underestimated or even ignored.

327 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er decades for this purpose and the numerous new flats in the area clearly demonstrate the continued need.

Public parks such as Harrow Recreation Ground and Headstone Manor Recreation Ground serve the residents of Harrow, not only the local residents. The Kodak Development with almost 1,000 homes, potentially some 4,000 new residents of different ages and different needs, will certainly put enormous pressure on existing public open spaces. I am bitterly opposed to any development on the greenfield site at Kodak. Why build on green open space and then expect people, especially young people, to use Headstone Manor that is oversubscribed after 4pm and at the weekends or to travel to the Roger Bannister sports ground that is some distance away? This is complete folly.

I trust Harrow Council will take my comments seriously and construct a comprehensive planning policy that protects ALL green open space for the present and future.

Site G04: Harrow Arts Centre Car Park and Ancillary Buildings, Uxbridge Road, Hatch End

NO REPS RECEIVED

Site G05: Watling farm Gypsy and Traveller Site, Watling Farm Close, Stanmore

328 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 1 00 Hertsmere Site Yes Acknowledge the allocation of three pitches at N/A Yes Noted. 3 Borough G05 Watling Farm, in accordance with the Core No change. Council Watlin Strategy g Farm

28 04 Rita Slade G05 Not Many of my neighbours and myself are Not stated Not The allocation of this site for three additional 1 (Resident) stat horrified to hear that you intend to open up this stat pitches responds to the additional pitch Watlin ed site again to more Travellers ed requirement for the plan period (2009-2026) g Farm and are opposed to it. as set out in the Harrow Core Strategy. This Gypsy Although I have lived in Bushey or Aldenham approach reflects Government advice at and all my life I have no idea on the history of this paragraph 8 of the publication Planning Travell site, because it is miles away from your area of policy for traveller sites (2012). There is no er Site Harrow. evidence to demonstrate that the allocation As it is we already have two sites in Sandy will adversely affect the relationship between Lane and Hilfield Lane, the Sandy Lane site is the settled and traveller communities in the being extended both are under Hertsmere B.C. area, nor that there would be any increase in care and the travellers give us very little crime as a result of the allocation. trouble. Both are only two/three miles away No change. from your site, further down the A.41. Surely enough is enough? Hertsmere sites are managed by the other travellers who live there, any trouble and those travellers have to go. Your site and I believe because it is so far from your care was a nightmare. There was one family there who broke in houses, stables, and my house, and both my neighbours were broken into which was them. Proven as it was their car but the police would not go into that area. Once they did, leaving the squad car outside on the A.41 only to return and find the car had no wheels on it! We do not want to go back to that. Thank You! It is very rural round here and we are vunerable. 329 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Last weekend it was the Barnet Fair and a lot of property went missing in this area. Travellers come from miles around to visit this Fair. Please don't do this to us. We already have our fair share of travellers in this small area. If you have to because of Government Policy - please give us an assurance that you will monitor the site and get rid of the trouble makers. I understand the existing Traveller on this site is very anxious about being invaded by more troublesome Travellers and going back to the troublesome past.

Site G06: Kenton Lane Farm, Kenton Lane, Belmont

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 7 01 Arlene G06 Not Following our telephone conversation this Open space should be Not In view of the PPG 17 Study findings use as 1 Laming Kenton stat morning, I am writing with my concerns over allocated for nature stat a park would help to address local (Resident) Lane ed the development of Kenton Lane Farm, Kenton conservation or allotment ed quantitative deficiencies, but alternative types Farm Lane for Residential Development and Public use, but not as a public of open space (such as those suggested) Open Space. park. which also have community access may be appropriate. The broader concern about My family live at 35 Tenby Avenue, HA3 8RU security is recognised. and our garden backs onto the open land of Kenton Lane Farm. We have lived here since In response to this representation it is 1983 and one of our main reasons for buying therefore proposed to revise the our property was the privacy and security that commentary to this site allocation, to the privately owned open space afforded us. provide greater flexibility over the open

330 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er space typologies that may be secured I understand from our conversation that the through the site’s redevelopment, and to land is not sustainable as a dairy farm and that draw attention to the need to ensure the some form of change will happen. However, I security of neighbouring residential am very anxious of the prospect of the land property, as a minor modification. immediately backing my property being turned See proposed modification SA70 & SA71 into open park space. There are two parks very close to Tenby Avenue. The first is Centenary Park which has a sports club, many facilities including tennis courts and is well run and well managed. The second is closer - the park area which is accessible from Kingshill Drive and Hartford Avenue and which backs onto Priestmead School.

331 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er

The prospect of having this at the back of my garden, with all the associated issues of potential crime, is devastating. There would be nothing I could do to prevent anyone in the park having access to my garden and thus be a risk to my property. Even were I to have a fence high enough to stop direct access, the properties either side would still be open (the property at 37 Tenby Avenue is currently a rented property) so anyone could get over their fence to get into my garden. I also have a concern over the disruption to the wonderful, peaceful aspect of the neighbourhood. It is a pleasure to hear the children playing in the school (Priestmead is that close) but at the back of my house? Footballs being kicked at the fence or over the fence, kids wanting to retrieve their ball so climbing over.

I would implore you to look at alternatives to a public park. 11 01 Chris G06 Not The consultation has been very much under Not stated Not Previous consultation relates to pre- 5 Randall stat the radar. At the outset of this project all stat application proposals put forward by the 332 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er (Resident) Kenton ed residents were personally contacted and given ed developer. Consistent with all other Lane the opportunity to view the planned proposal development sites in the DPD, a site notice Farm but since then there has been no contact was used to publicise the DPD pre- whatsoever and it is purely by chance that a submission consultation. resident happened to come across this. The communication has been woeful to say the No evidence of a link between affordable least and in our view deliberately so to avoid housing provision and property values has any opposition. We would like to make the been advanced. Nevertheless, property value following points against the development, is not a planning consideration. which are shared with a number of my neighbours in Ivanhoe Drive. Concern about disruption during the works is noted, but is a matter for control under the Further affordable housing in the area will have Environmental Health regime 9not planning a detrimental effect of the value of our legislation). properties. In responding to this DPD, Thames Water It will be extremely disruptive for all residents Utilities have not sought to highlight any during the building work known problems associated with this site. Nevertheless, Core Strategy Policy CS1Z Increase usage of drainage systems that are requires those proposing development to already in serious need of maintenance. demonstrate adequate infrastructure capacity, and the Development Management Significant blocking of light to our properties Policies contain provisions relating to surface water management. Security concerns with the proximity of the housing The site allocation does not propose or prescribe a specific design, and assessment We do not need any more parks. of impact on neighbouring property would be Belmont/Kenton is well served with parks. a matter for consideration at pre-application/ Indeed it would be better to concentrate on planning application stages. Any planning maintaining the existing parks with the use of application would be subject to public wardens, rather than build another park. We consultation with surrounding residents. find it difficult to believe that any However, in response to this Belmont/Kenton residents have raised the representation it is proposed to amend issue of a lack of park facilities. paragraph 8.17, to highlight the need to

333 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er achieve a sensitive relationship with surrounding dwellings, as a minor modification. See proposed minor modification SA70

In view of the PPG 17 Study findings use as a park would help to address local quantitative deficiencies, but alternative types of open space which also have community access may be appropriate. In response to this representation it is therefore proposed to amend the commentary to this site allocation to provide greater flexibility over the open space typologies that may be secured through the site’s redevelopment. See proposed minor modification SA71 16 02 John G06 Not I am away from home at present and would Not stated Not The site allocation does not propose or 9 Davensac stat request you list my name to oppose the Kenton stat prescribe a specific design, and assessment (Resident) Kenton ed lane farm development. ed of impact on neighbouring property would be Lane I have resided at 5 Tenby Avenue for 40 years a matter for consideration at pre-application/ Farm and have of course enjoyed the open space to planning application stages. the rear of my property. No change. The proposed development will cut out all sunlight from my garden with the position of However, in response to this the houses in such close proximity. representation it is proposed to amend The value of my property will decrease with paragraph 8.17, to highlight the need to this terrible design. Would you please list my achieve a sensitive relationship with opposition to the petition which is being surrounding dwellings, as a minor circulated. modification. See proposed minor modification SA70

Property value is not a planning consideration. No change. 334 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 19 03 Mahendra C G06 Not We are owners of properties at 306, 308 and Not stated Not Detailed consideration of traffic impacts 2 Patel, stat 310 Kenton Lane, and jointly wish to object to stat would be a matter for consideration at pre- Michael J Kenton ed the proposed development for residential ed application/planning application stage (a Donelly & Lane development of 35 houses and open space at high-level transport study underpins the Core Kiran C Farm Kenton Lane Farm Kenton lane. Strategy and the growth provided for in the Patel spatial strategy). (Residents) Our concerns are as follows: No change.

1. There is already considerable and The site allocation does not propose or congestion with parked cars along both sides prescribe a specific design, and assessment of Kenton lane from traders/customers and of impact on neighbouring property would be business man and the proposed development a matter for consideration at pre-application/ will make the situation worse and not better for planning application stages. However, in the owners like ourselves, who are pensioners, response to this representation it is but also those with young families, as the road proposed to amend paragraph 8.17, to in itself is a very busy road highlight the need to achieve a sensitive 2. Such development can will take away light relationship with surrounding dwellings, from our houses and also cause more pollution as a minor modification. 3. The open space that is being suggested we See proposed minor modification SA70 understand is for a park, we cannot comprehend why you would require another In response to this representation it is open space when we have park high Park and also proposed to amend the commentary Priestmead school park very close by, and to this site allocation to provide greater these parks themselves give rise to Police flexibility over the open space typologies having to man it on a regular basis. This will that may be secured through the site’s also cause more noise and disturb our peace redevelopment, and to draw attention to and quiet throughout the day and evenings the need to ensure the security of 4. We have to deal with drunken members of neighbouring residential property. the public on a number of occasions due to the See proposed minor modification SA71 local pubs being close in proximity, and a park will naturally attract these types of people, especially at the weekend and on sunny days.

Please let us know when the public meetings are to be held to discuss this matter further.

335 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 23 03 Mr. Za Hida G06 Not Unsound – Justified Effective Consistent with Not stated Not Detailed consideration of traffic impacts 6 Agha sou National Policy stat would be a matter for consideration at pre- (Resident) Kenton nd ed application/planning application stage (a Lane b) traffic congestion b) added pressure high-level transport study underpins the Core Farm on local schools/ surgeries, which are Strategy and the growth provided for in the already oversubscribed. c) noise spatial strategy). pollution in an already congested area No change. d) destroy green area( open land ) The residential development would be liable We strongly oppose this planning as it will right to local Community Infrastructure Levy behind our house & could devalue our property charges (a high level infrastructure considerably. assessment underpins the Core Strategy and the growth provided for in the spatial strategy) to fund infrastructure improvements made necessary by this and other developments in the area. No change.

Within the context of the surrounding residential suburb, the proposed residential allocation is unlikely to significantly increase noise pollution. No change.

The proposed allocation seeks to secure the future of (not destroy) the designated open space within the site. 27 04 Preston G06 Yes The mixed use allocation to secure good The existing farmhouse is Yes Support noted. 0 Bennett quality and publicly accessible open space broken into two existing (for David Kenton alongside residential development is wholly dwellings (reducing the net In response to this representation, and Carol and Lane appropriate for this site who’s current open figure to 33). following further discussion over a Brazier Farm space designation is of no benefit to the public. revised scheme with this contributor, it is Edwards) Discussions have already been held between Given the current and proposed that the gross number of homes the land owner and the Council and the public proposed use of the site it is be reduced to 34 and the net number of engaged on proposals in line with the requested that the first homes be reduced to 32, and that the 336 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er proposed balance of uses and retention of the sentence of paragraph 8.18 commentary be amended to further listed building. The proposed allocation is be reworded to ‘parts of the highlight the potential for open space therefore supported in its current form, subject site have potential value to reconfiguration to achieve public access to the following brief comments. the community as public to this currently inaccessible open land, open space, to allow as a minor modification. It is also appropriate reconfiguration’. proposed to amend the site details to correct the site area (to reflect the size of In paragraph 8.16 it should the entire site including the open space) be highlighted that the and to specify the area of the designated current open space open space, and to amend the designation benefits from no commentary to allow for the current public access, being reconfiguration of the open space, as wholly private land. additional minor modifications. See proposed minor modifications SA69 & SA71 32 05 Shweta G06 Not I am writing regarding the proposal of Housing Not stated Not The proposed allocation seeks not only to 8 Kapoor stat to be built on Brazier stat retain the green open space but also to make Sharma, Kenton ed Dairy (Kenton West) also know as Kenton ed it accessible to the community. It is also Aruna Lane Lane Farm. proposed to retain the heritage buildings. Kapoor, Farm Surinder Writing on behalf and a voice for the residents The site allocation does not propose or Kapoor and in the area of Kenton prescribe a specific design, and assessment Munish Lane, Ivanhoe Drive and Tenby Avenue which of impact on neighbouring property would be Sharma all are affected if this a matter for consideration at pre-application/ (Residents) takes place. planning application stages.

I live on Tenby Avenue and there are many old However, in response to this age pensioners who cannot or not accessible representation it is proposed to amend to Internet and pc's . paragraph 8.17, to highlight the need to achieve a sensitive relationship with On their behalf and my family we totally reject surrounding dwellings, as a minor these plans! modification. See proposed minor modification SA70 I understand a petition is going around but very last minute. I hope this email will be read as it 337 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er would be a travesty to have flats and apartments built on that land which is one of the only green spaces left here apart from parks.

It is a part of our heritage and would be so sad to see a block of flats built. It would be an eyesore, noise pollution disturbances, dirt, block natural light.

Surely somewhere more appropriate can be utilised in the area?

I am sure there are many local residents who also object to this plan. As a resident in this borough all my life I hope we have an opinion that counts and that our voice is heard.

I truly hope the right wise decision will be taken and the plans rejected. 33 05 Susanah E. G06 Not My wife, our daughter, and I myself strongly Not stated Not Detailed consideration of traffic impacts 9 Greening, stat object to any such development as planned at stat would be a matter for consideration at pre- George H. Kenton ed Kenton Lane (the old J.H.Brazier Dairy site). ed application/planning application stage (a Greening, Lane We are sure that it would cause too much high-level transport study underpins the Core 338 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er and Alice M. Farm noise and traffic on a nice quite and peaceful Strategy and the growth provided for in the Greening road, and all the local people would very much spatial strategy). (Residents) regret allowing the council or the government to pass this Planning Application. Within the context of the surrounding residential suburb, the proposed residential allocation is unlikely to significantly increase noise pollution.

No change. 39 10 Mrs. G06 Not We, the owners of 43 Tenby Avenue, would Not stated Not The site allocation does not propose or 0 Nkansa- stat like to register formally our concerns about the stat prescribe a specific design, and assessment Dwamena Kenton ed planning application for the Brazier's Dairy site ed of impact on neighbouring property would be (Resident) Lane in Kenton Lane. included in the Council's Site a matter for consideration at pre-application/ Farm Allocations Development Plan Document. We planning application stages. Any planning wish our comments to be taken into application would be subject to public consideration as part of the Pre-Submission consultation with surrounding residents. Consultation, which closes on 7th September. However, in response to this representation it is proposed to amend Having read the DPD, we can see that it is paragraph 8.17, to highlight the need to thoughtfully and sensitively written to respect achieve a sensitive relationship with the heritage of the Brazier's Farm buildings. surrounding dwellings, as a minor However, we believe the document is deficient modification. in some areas. See proposed minor modification SA70

Our concerns are as follows: Within the context of the surrounding PRIVACY. The design of any new residential suburb, the proposed residential development should reflect the right to privacy allocation is unlikely to significantly increase of the properties that back onto the site. We light, noise and dust pollution. would like explicit reassurance that no new building will overlook our garden or other The commentary to the allocation requires private gardens backing onto the site. We ask the design and layout of development to that any development erected should respect enhance the setting of the listed buildings on our right to privacy by not overshadowing the the site. garden or creating a loss of privacy by allowing new residential properties to have a direct view Detailed consideration of traffic impacts 339 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er into our garden and house. would be a matter for consideration at pre- LIGHT POLLUTION. Similarly, given that our application/planning application stage (a son's bedroom is at the rear of our property, high-level transport study underpins the Core we ask that any development of the site is Strategy and the growth provided for in the designed to minimize light pollution. We would spatial strategy). strongly oppose any plans that directed electronic light towards our property - either Increased residential presence on the site from external street lamps or internal may be expected to increase natural residential lighting facing onto the rear of our surveillance, and therefore security. Detailed property. consideration of crime prevention measures PRESERVING LOCAL HERITAGE. Our strong can form part of the assessment of any view, which appears to have been reflected in subsequent planning application. the tone of the DPD, is that the design and appearance of any new buildings should not undermine the historic character of the Brazier's farm buildings, which are of significance to the heritage of the local area. We ask that any new development is also in keeping with the style of the 1930s residential properties that surround it. SENSIBLE PLANNING AND DESIGN. The layout and density of the development should not be overly congested, and care should be taken to ensure that plans are sympathetic to the impact on the residents of the properties that back onto the site. For example, we would oppose any development that placed communal rubbish collection receptacles next to the boundaries of our property. CRIME PREVENTION. The Kenton and Belmont area has been the target of burglaries in recent years. Our own house was broken into from the rear of the property last January. The Police who visited the scene suggested that the low visibility caused by garages

340 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er combined with the shared driveways between properties may have contributed. We would hope that any development of the Brazier's Dairy site would incorporate the principles of Situational Crime Prevention so as not to inadvertently create more opportunities for criminals to access the properties of Tenby Avenue. TRAFFIC AND PARKING. Traffic and parking problems in the Belmont and Kenton area have increased in recent years. We welcome the decision not to cultivate the front of the farm buildings for parking but would hope that consideration has been given to ensuring that there is adequate parking for the residents and guests of any new development on the site. MINIMIZING OTHER INCONVENIENCES. We ask any new development does not create additional inconveniences for the residents of Tenby Avenue by, for example, causing excessive dust or noise outside of usual working hours, or by closing access to Kenton Lane or Tenby Avenue for significant periods of time. REGULAR UPDATES. We would ask that the residents of Tenby Avenue are updated in writing when key decisions are made relating to this development and when periods of engagement, such as consultations, are open. Many residents are elderly and not all have access to the internet. 40 10 Mr. Nkansa- G06 Not We, the owners of 43 Tenby Avenue, would Not stated Not The site allocation does not propose or 1 Dwamena stat like to register formally our concerns about the stat prescribe a specific design, and assessment Kenton ed planning application for the Brazier's Dairy site ed of impact on neighbouring property would be in Kenton Lane. included in the Council's Site a matter for consideration at pre-application/ 341 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Lane Allocations Development Plan Document. We planning application stages. Any planning wish our comments to be taken into application would be subject to public consideration as part of the Pre-Submission consultation with surrounding residents. Consultation, which closes on 7th September. However, in response to this representation it is proposed to amend Having read the DPD, we can see that it is paragraph 8.17, to highlight the need to thoughtfully and sensitively written to respect achieve a sensitive relationship with the heritage of the Brazier's Farm buildings. surrounding dwellings, as a minor However, we believe the document is deficient modification. in some areas. See proposed minor modification SA70

342 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er appearance of any new buildings should not undermine the historic character of the Brazier's farm buildings, which are of significance to the heritage of the local area. We ask that any new development is also in keeping with the style of the 1930s residential properties that surround it. SENSIBLE PLANNING AND DESIGN. The layout and density of the development should not be overly congested, and care should be taken to ensure that plans are sympathetic to the impact on the residents of the properties that back onto the site. For example, we would oppose any development that placed communal rubbish collection receptacles next to the boundaries of our property. CRIME PREVENTION. The Kenton and Belmont area has been the target of burglaries in recent years. Our own house was broken into from the rear of the property last January. The Police who visited the scene suggested that the low visibility caused by garages combined with the shared driveways between properties may have contributed. We would hope that any development of the Brazier's Dairy site would incorporate the principles of Situational Crime Prevention so as not to inadvertently create more opportunities for criminals to access the properties of Tenby Avenue. TRAFFIC AND PARKING. Traffic and parking problems in the Belmont and Kenton area have increased in recent years. We welcome the decision not to cultivate the front of the farm buildings for parking but would hope that

343 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er consideration has been given to ensuring that there is adequate parking for the residents and guests of any new development on the site. MINIMIZING OTHER INCONVENIENCES. We ask any new development does not create additional inconveniences for the residents of Tenby Avenue by, for example, causing excessive dust or noise outside of usual working hours, or by closing access to Kenton Lane or Tenby Avenue for significant periods of time. REGULAR UPDATES. We would ask that the residents of Tenby Avenue are updated in writing when key decisions are made relating to this development and when periods of engagement, such as consultations, are open. Many residents are elderly and not all have access to the internet. 41 10 English G06 Not We would ask you to consider the comments Not stated Not The letter referred to finds that the pre- 3 Heritage Kenton stat we provided in response to a pre-application stat application proposals would harm the setting Lane ed request for advice for the residential ed of the listed buildings, by introducing a farm development of Kenton Farm. Our letter of suburban character to the site, and that the response (dated 27th July 2011) raised case for enabling development has not been concerns related to the scale of development demonstrated. proposed and its impact upon the grade II The above comments relate to a specific, listed building, associated buildings and their pre-application proposal. The support for the settings. With this in mind we welcome the commentary included in the allocation, reference made in the ‘commentary’ for the relating to the setting of the listed buildings, is need for new developments to enhance the noted. setting of the listed buildings. No change. 42 10 Petition (53 G06 Not This is a petition against the development of Not stated Not Noted. 8 signatories) stat houses at Kenton Lane Farm, Kenton Lane, stat No change. Kenton ed Harrow HA3 8RT ed Lane 344 ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er Farm We, the undersigned, are concerned citizens who urge our leaders to act now to stop the planning and development of houses at the above site.

Sustainability Appraisal

ID Re Site/ Responden Sou Leg p Chapt Reason Change Council’s Comments / Response t nd al No. er 41 10 English Sustai N/A In line with the above comments, providing N/A N/A Noted. However it is not considered 7 Heritage nability further detail with regards to the significance of necessary to map the heritage assets in the Apprai heritage assets that may be affected by each document to achieve this end. sal site allocation should help improve the scoring given. The extra understanding provided and illustration of each site map of where relevant heritage assets are would ensure the sustainability objective of conserving the historic environment is fully met.

345 Appendix M: Note on Retail Development

Planning for New Retail Floorspace – Policy Requirements

Paragraph 23 of the NPPF states that local planning authorities should:

 allocate a range of suitable sites to meet the scale and type of retail…development needed in town centres…;  allocate appropriate edge of centre sites for main town centre uses that are well connected to the town centre where suitable and viable town centre sites are not available. If suitable edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are well connected to the town centre; [and]  set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.

London Plan Policy 4.7 Retail and Town Centre Development states that boroughs should:

 identify future levels of retail and other commercial floorspace need in light of integrated strategic and local assessments  take a proactive partnership approach to identify capacity and bring forward development within or, where appropriate, on the edge of town centres  firmly resist inappropriate out of centre development  manage existing out of centre retail and leisure development in line with the sequential approach, seeking to reduce car dependency, improve public transport, cycling and walking access and promote more sustainable forms of development

Policy CS1L of Harrow’s Core Strategy supports proposals for convenience and non-major comparison retail within the Borough’s district and local centres. Proposals for major comparison retail development are directed to Harrow town centre’s primary shopping area. Paragraph 4.23 of the reasoned justification to the policy identifies the evidenced retail floorspace projections (see below) and goes on to caution: ‘…that long-term projections are subject to change and should therefore only be used as a broad guide’.

Planning for New Retail Floorspace – Evidence

The Harrow Retail Study (2009) projects a need for 38,912m2 comparison retail floorspace and 5,261m2 convenience floorspace over the period 2009 to 2025. The projection takes into account forecast expenditure growth within the catchment area of the study, the role of other forms of trading (such as internet shopping), the potential for increased sales density/reduced vacancy levels from existing retail floorspace, and the pipeline supply of new retail floorspace at the time of the study. The projection assumes that the Borough will maintain its market share of expenditure.

The Study disaggregates the floorspace projections into five yearly periods as follows:

2009-2015 2015-2020 2020-2025 2009-2025 Comparison 11,869m2 12,848m2 14,194m2 38,912m2 Convenience 3,366m2 1,017m2 882m2 5,261m2

The Study urges caution in the use and interpretation of the projections. In particular, paragraph 17.2 states that:

346  ‘The long term floorspace projections (up to 2020 and beyond) shown in Section 16.0 should be treated with caution and should only be used as a broad guide, particularly when translated into the development plan allocations or when used to guide development control decisions. Long term forecasts may be subject to change due to unforeseen circumstances. Projected surplus expenditure is primarily attributable to projected growth in spending per capita. If the growth in expenditure is lower than that forecast then the scope for additional space will reduce. Long term projections should be monitored and kept under-review. Recommendations on monitoring and updating projections are set out in Section 18.0’.

The need for caution in the use of the projections is repeated at paragraph 18.3, 18.5 and 18.35. At paragraph 18.36 it is recommended that the Retail Study be updated in 4-5 years’ time (i.e. 2013-2014).

Planning for New Retail Floorspace – Capacity of Consented Schemes and Site Allocations

The following table represents the ‘pipeline’ supply of new retail floorspace based on approvals following the completion of the Retail Study in 2009. It should be noted that the Neptune Point Morrisons store was included as a commitment in the formulation of the Retail Study projections, but that Bradstowe House was excluded (as a stalled development site).

The small units at Kodak and the Bradstowe House floorspace are attributed to comparison retailing as they are consented for A1-A5 uses.

Consented Schemes (post Retail Study) Site Comparison (m2) Convenience (m2) Kodak site 560 3,440 supermarket Kodak site 1,000 - small units (A1-A5) Tesco supermarket 2,368 651 extension Tesco 437 - small units (A1-A3) Bradstowe House 1,617 - retail Equitable House/Lyon House 5001 retail Totals: 6,482m2 4,091m2

The following table shows the potential retail floorspace of sites allocated in the Harrow & Wealdstone AAP. The floorspace of all sites is attributed to comparison retailing as they are allocated for A1-A5 uses.

AAP Allocations Site Comparison (m2) Convenience (m2) Wealdstone infills 1,000 - (site 5) Civic Centre small units 1,000 -

1 The approved scheme allows for 1,548m2 A1-A3 and D1 uses. Therefore a notional figure of 500m2 has been attributed to retail assuming that the remainder comes forward as D1 use.

347 (site 9) Greenhill Way car park 5,000 - (site 13) College Road west 3,000 - (site 16) Havelock Place 5,000 - (site 17) 51 College Road 5,000 - (site 18) Total: 20,000m2 -

The following table shows the potential retail floorspace of sites allocated in the Site Allocations DPD. For the purposes of this note and consistent with the Core Strategy, the floorspace of all sites with a capacity of 1,000m2 or less is attributed to comparison retailing, and those over 1,000m2 is attributed to convenience retailing. However, it should be noted that the sites with a capacity of 1,000m2 or less may also be suitable for convenience retailing development.

Site Allocations DPD Site Comparison (m2) Convenience (m2) Land between High Street 1,000 - and Love Lane (site R1) Units south of Rayners Lane 500 - Station (site R2) Harrow West conservative 1,000 - Association (site R3) Roxeth Library and Clinic 1,000 - (site R5) Land at junction Kenton Road 1,000 - /Honeypot Lane (site R6) Anmer Lodge and Stanmore - 2,000 Car Park (site R7) North Harrow Methodist - 2,000 Church (site G07) Totals: 4,500m2 4,000m2

The following table summarises the sum of pipeline and proposed allocated supply of comparison and convenience retail floorspace.

Totals Source Comparison (m2) Convenience (m2) Consented Schemes 6,482 4,091 Allocations 24,500 4,000 Totals: 30,982m2 8,091m2

Commentary

For the short/medium term period (2009-2020) the Retail Study floorspace projections amount to 24,717m2 comparison retail floorspace and 4,383m2 convenience retail floorspace. It can be seen from the tables above the consented schemes and allocations meet and exceed the projected need for comparison floorspace in the short-medium term, and that the projected need for convenience floorspace is almost entirely met by schemes that are already

348 consented. There are sufficient consented and allocated sites to meet and exceed the convenience floorspace projections for the entire period 2009-2025.

In view of the inherent uncertainty associated with the long term (2020-2025) projections, clearly highlighted in the Retail Study and reflected in the reasoned justification to Core Strategy Policy CS1, it is considered that short/medium term projections provide a reasonable planning basis for allocating sites in the Area Action Plan2 and Site Allocations DPD. In line with the Study’s recommendation, the floorspace projections will be reviewed in forthcoming years.

The implication of paragraph 23 of the NPPF is that out-of-centre sites should not be allocated, but that local planning authorities should set policies for meeting identified needs/considering proposals that cannot be accommodated on in-centre or edge of centre sites. Policy 46 of the Development Management Policies DPD sets out criteria for the consideration of new retail development in out of centre locations and therefore allows for any retail development associated with the higher (long range) comparison floorspace projections – in the event that they are sustained following a review of the Retail Study - to come forward during the plan period.

2 Which includes all of the consented developments.

349