Brent's Unitary Development Plan

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Brent’s Unitary Development Plan - 2004

Building A Better Borough Finding your way around the Unitary Development Plan

Title of Chapter Supporting Text - this explains the Policy Number existing situation of - all are listed on the the development issue first page of that in the policy which fol- Chapter lows.

It sets out Brent’s resulting approach to the issue, and it highlights the opportunities or problems proposals will need to address in order to meet the criteria in Cross the policy. References to other policies that Policy Title might apply- In the interactive Policy Text - online version, this sets out what clicking on them developments will will take you and won’t get plan- straight to that ning permission policy and, where appropriate, the criteria that have to be met Section for planning permis- Heading sion to be granted.

Development Title & Date of Plan Issues London Borough of Brent Unitary Development Plan 2004

Written Statement

Prepared in accordance with Section 13 of the Town and Country Planning Act 1990 as amended by Section 27 of the Planning and Compensation Act 1991 and the The Town and Country Planning (Development Plan) (England) Regulations 1999.

Maps within this document have been reproduced from Ordnance Survey mapping with the permission of the controller of Her Majesty’s Stationery Office © Crown Copyright. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. (Licence Number LA086 312)

Chris Walker Adopted Director of Planning 14th January 2004 © Brent Council 2004

Design, layout and text by Brent Planning Service

Maps by Brent GIS development.

An interactive online version of this UDP is available on the Council’s Website at: www.brent.gov.uk/planning.nsf

Printed on Conservation Grade paper

Final Cartography and printing by: ESR Cartography Ltd. Unit 10a Waldeck House Waldeck Road Maidenhead Berkshire SL6 8BR FOREWORD

Brent Council has adopted its Replacement Unitary Development Plan (UDP). The Plan provides planning guidance for the development and use of land. As such, it seeks to improve the environment of the Borough, promote the regeneration of areas in need of renewal in a sustainable way and promote access to new development for the whole community.

The UDP was adopted after several rounds of public consultation and a public inquiry which gave those with an interest in the future of Brent, an opportunity to have their say on the plan’s policies and proposals. Many residents, businesses and other interested parties have participated in drawing up the Plan which will have a central role in shaping the Borough over the coming years.

Parts of the Borough will be transformed over the next few years and it is important that there is clear planning guidance so that change is implemented in a way which brings environmental, economic and social benefits and is in the interests of local people. There is also much in Brent that is worthy of protection and conservation. The Plan provides the necessary guidance and controls to allow for the changes necessary to regenerate the run- down parts of the borough whilst protecting and enhancing the positive aspects of our environment.

(Cllr) Lesley Jones

Lead Member for the Environment and Planning

Brent Unitary Development Plan Table of Contents

Chapter Page 1. Introduction 1 Part I 2. Strategy 3 Part II 3. Built Environment 21 f Bren 4. Environmental Protection o t U63 gh n u it 5. Housing o 77a r r 6. Transport o 107 y B D

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8. Town Centres and Shopping d 167

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9. Tourism, Entertainment and the Arts 195p

10. Open Space and Recreation 201e n

l 0 a 2 n 11. Community Facilities - 221 12. Waste 233 Inset Plans 13. Park Royal 245 14. Wembley Regeneration Area 253 15. Site Specific Proposals 277 16. Glossary 287 17. Index 293 Maps Page

Map STR1 Location of Brent in London 17

Map STR2 Index of Local Deprivation 18

Map STR3 Strategic Diagram 19

Map BE1 Areas of Low Townscape or Public Realm Quality 59

Map BE2 Transport Corridors and Gateways 60

Map BE3 Conservation Areas and Article 4 Directions 61

Map BE4 Views, Landmarks and Viewpoints 62

Map H1 Major Estate Regeneration Areas 105

Map H2 Distribution of Supported Housing in Brent 106

Map TRN1 Public Transport Accessibility 146

Map TRN2 The London Bus Priority and Cycle Networks 147

Map TRN3 Brent's Road Network 148

Map EMP1 Unemployment in Brent 165

Map SH1 Shopping Provision in Brent 1999 193

Map SH2 Protected Shopping Frontages 194

Map OS1 Local Level Open Space and Open Space Deficiency 218

Map OS2 District Level Open Space and Open Space Deficiency 219

Map OS3 Areas of Nature Conservation Deficiency 220

Map WEM1 Long Distance Views of Wembley Stadium 274

Map WEM2 Short Distance and Internal Views of Wembley 275 Stadium

Proposals Map Key UDP area designations & Site specific proposals Back cover pocket INTRODUCTION 1INTRODUCTION

1.1 THE ROLE OF PLANNING of an area and, finally, gives everyone a reasonable level of certainty which can aid the making of property and investment deci- 1.1.1 Few things ever stay the same. Buildings that once met a need sions. become disused. New needs for houses, factories, offices and shops are found as people move in and out of areas, technology 1.2.3 The Council has reviewed the UDP adopted in 1996 and this ver- changes and the way we live alters. It is essential that we decide, sion replaces that plan. The replacement plan, however, had to as a community, the changes in the way we use land to reflect go through a number of stages before it could be finalised or these changing needs. 'adopted'. These stages are designed to take account of the views of those who might have an interest in the future planning 1.1.2 Planning permission is needed to prevent developments and new of the Borough such as local residents and businesses. uses which would be harmful to the public interest. Without planning control buildings which could unacceptably block light to 1.2.4 The replacement plan was adopted on 14th January 2004. The neighbours, create dangerous traffic conditions or be harmful in 'plan-led' system referred to above applies and Section 54A of the many other ways could be built. 1990 Planning Act requires planning applications to be determined in accordance with the Plan unless material considerations 1.1.3 Planning also has a more positive role: indicate otherwise. • It helps us achieve the kind of high quality environment we wish to see. • It helps see that the houses and places of work we need in the future are co-ordinated, are accessible and are built in the right places and in the right way. • It helps to see that resources are used efficiently on new transport investment and on regenerating run-down areas. • It helps us to preserve and enhance our most cherished built and natural heritage and it also helps ensure that the whole community has access to the facilities they need.

1.1.4 Planning is concerned with the management of this change for the good of the whole community. The law gives local Councils a duty to prepare a plan which set out how they would like this change to occur, and what can or cannot be built in particular areas (in Brent this is called a Unitary Development Plan (UDP)). It also makes Councils responsible for deciding whether or not particular proposals for change should be allowed.

1.2 PURPOSE OF THE PLAN Brent Planning Service is located at Brent House, 349 High Road Wembley

1.2.1 The Unitary Development Plan (UDP) is a legal document containing all the planning policies and standards which will be used to make decisions on planning applications - whether for major commercial developments or for small schemes such as house extensions. The Plan also indicates where the Council wishes positively to encourage new development in particular areas within the Borough or on individual sites.

1.2.2 In Britain a 'plan-led' system operates. This means that, unless there are good reasons not to, the plan should be followed in making decisions on planning applications. This helps avoid decisions being made in an arbitrary manner, gives the public the opportunity to shape the way decisions are made and the future

Brent Unitary Development Plan - 2004 1 INTRODUCTION

1.2.5 The legal framework for the preparation of the UDP is the Town and Country Planning Act 1990 (as amended by the Planning and 1.3 FORMAT OF THE PLAN Compensation Act 1991), and the Town and Country Planning (Unitary Development Plan) (England) Regulations 1999. Under 1.3.1 Under current planning legislation the UDP must contain a these every London Borough is required to prepare a Unitary Written Statement, presented in two parts, and a Proposals Map. Development Plan which is the statutory Development Plan for the whole of its area. The Plan has to address 'strategic' London- 1.3.2 Part I : This sets out the broad development and land use wide issues and contain detailed local policies. The original Brent strategy for the Borough, taking account of London-wide planning Unitary Development Plan was adopted on February 15th 1996. issues. It contains major land use policies and provides the The policies and proposals in the UDP are intended to last for framework for the more detailed policies and proposals in Part II. about 10 years from the date of adoption, although the Council is By law this section must contain policies on development, traffic required to keep the plan up to date and make formal modifica- management and environmental improvement. tions to the plan to take account of changing circumstances. 1.3.3 Part II : This contains the more detailed planning policies, 1.2.6 Brent's UDP has been produced within the context of national and with reasoned justification, under different chapter headings such regional planning policies as well as those for London as a whole, as shopping, housing, transport, open space, etc. There are the latter being set out principally in the Government's Strategic additional chapters on two areas in need of regeneration, which Guidance (RPG3) issued in 1996. It has also had regard to the are the subject of larger scale 'Inset' Plans. These Inset Plans Strategic Advice prepared by the London Planning Advisory look in greater depth at areas with complex planning issues and Committee (LPAC) - an organisation of London Boroughs which cover the Wembley Regeneration Area and Park Royal. In addi- advised on London planning issues, and proposals of adjoining tion there are parking and servicing standards and also proposals local authorities. The setting up of the Greater London Authority for specific sites which are set out in a Schedule of Site Specific in May 2000 means that the Mayor’s Spatial Development Proposals within the Plan. It is important to view the plan as a Strategy (the ‘London Plan’) has taken the place of these. whole - for example if land is allocated for a specific use then other policies generally promoting other uses will not apply. 1.2.7 The key stages in the plan preparation process are shown below. Following the initial 'deposit' of the plan there was a period for 1.3.4 The Proposals Map shows the areas covered by specific poli- objection. Then the Council responded to these objections and cies in the Plan such as Metropolitan Open Land, Conservation placed the plan on a 'revised deposit'. Following this, objections Areas, Primary Shopping Frontages and Strategic Employment were only permitted into the proposed alterations. This was the Areas, and proposals for specific sites. The Proposals Map also plan considered by an independent inspector who received writ- contains two Inset Maps to correspond with the Inset Plan areas. ten and/or verbal representations from objectors. The Inspector then prepared a report which the Council had a duty to consider 1.3.5 In addition to the statutory policies, proposals and parking and before the plan was adopted. In due course the whole review servicing standards set out in the Unitary Development Plan, the process will begin again. However, due to recent changes in the Council also issues additional planning guidance on matters such planning legislation, a new Local Development Framework (LDF) as the design of development and access for disabled people. will eventually replace the UDP. The LDF will go through a modi- Although not contained in the Plan, this guidance, called fied adoption process, which encourages more community Supplementary Planning Guidance, can be helpful for those mak- involvement. The Council’s planning website gives you more ing planning applications as it may be a material consideration in information about these changes at: www.brent.gov.uk/planning their determination.

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STRATEGY 2 STRATEGY

2.1 ABOUT BRENT 2.1.5 In much of the inner part of Brent, as in so many other areas of Inner London that are distant from London's major parks and 2.1.1 Brent covers an area of 4325 hectares - almost 17 square miles, open spaces, there is a deficiency of the green spaces that are between inner and outer North West London (see map STR1). It essential to the quality of life and to a pleasant urban environ- extends from Kenton and Kingsbury in the North to Harlesden, ment. Other Inner London characteristics can also be seen: Queens Park and Kilburn in the South. The North Circular Road industrial activities operating cheek by jowl with residential uses divides the less densely populated northern part of the Borough and the problems of the re-adjustment of town centres to shifting from the south. patterns of retailing and changing populations.

2.1.2 There are few London Boroughs as ethnically diverse as Brent. 2.1.6 The substantial development of the north of the Borough Among its population of 263,000, with black and minority ethnic occurred in the 1920's and 1930's with the expansion outwards of groups comprising 54.7% . Over 120 languages are spoken in London that accompanied the growth of rail and underground ser- the Borough. vices in the capital. That essentially suburban nature, with its characteristically lower densities, survives today. This part of the 2.1.3 The south of the Borough was substantially developed between Borough forms part of the large ring of areas of Inner London that 1890 and 1910, mainly with terraced houses for workers in indus- continues to house people working in Central London and, more try and services, but with some estates of larger houses around so today, elsewhere. As in much of suburban London, increased Kilburn. This area has been the focus of substantial change in demand for housing in the 1990s has brought pressures for rede- recent years: much housing renewal has been achieved both velopment at higher densities. through concerted public action and through piecemeal improvement in the private sector, often associated with conversions. 2.1.7 The fortunes of all parts of the Borough depend now, as much as Proximity of the inner part of the area to Central London has con- ever, on the prosperity of London as a whole. Other parts of tributed to these latter pressures. London provide the workplaces for a substantial proportion of Brent's residents. But Brent has its own contribution to make to 2.1.4 Parts of the Borough suffer from high levels of social and eco- London's economic well-being. In particular, it contains some 360 nomic disadvantage (see Map STR2). The extent of deprivation hectares (nearly 900 acres) of industrial estates many of which has long been officially recognised and Brent qualifies for a num- were originally developed during the expansion westwards of ber of European and National regeneration programmes. Brent London's manufacturing in the inter-war period. These estates contains four of the Government's Priority Community Areas eligi- have long been seen as a strategic resource providing relatively ble for regeneration funding: Harlesden, Willesden, Kilburn and rare opportunities in West London to house manufacturing activi- Cricklewood, the major focus of such areas in West London. ties, including both emerging new industries and those traditional industries, such as in the food and printing sectors, which continue to serve the London market from a base within the capital.

From Busy Urban Areas 2.1.8 The Borough is famous for being the home of Wembley Stadium - now being redeveloped as the new English National Stadium. Wembley is now a major focus for regeneration and will, when development is complete, attract major international sporting To Leafy Suburbs events.

2.1.9 The Borough is very diverse architecturally. Within Brent you will find well-planned leafy suburbs, dense 19th Century inner city housing, 1960s high rise residential and office blocks and two of London's largest industrial estates at Wembley and Park Royal.

2.1.10 The River Brent, after which the Borough takes its name, runs Brent is a Borough of Contrasts through the centre of the Borough (much of it now open as a riverside walk) roughly dividing the more inner urban South of the Borough from the more suburban North. Part of it flows through the Welsh Harp reservoir, important both for sailing and for its

Brent Unitary Development Plan - 2004 3 STRATEGY

wildlife. The Borough's largest open space is Fryent Country • Implementing the Local Agenda 21 Action Plan in collabora- Park which is a local nature reserve and retains its 17th Century tion with local people; hedgerow patterns. • Improving management of waste and the proportion of waste recycled; 2.1.11 The Borough has a large number of local and town centre shop- • Working to improve the quality of local public transport and ping areas, many of which have been in long term decline. The reduce congestion; two largest are Wembley and Kilburn (the latter shared with • Ensuring a diverse range of arts, leisure, sport and cultural Camden). activities are available to all sections of the community; • To make sure that older people, disabled people and those 2.1.12 The Borough has good communication links with the Piccadilly, with mental health problems are able to take a full and active Bakerloo, Jubilee and Metropolitan tube lines running through the part in the life of the community. Borough. The Borough also has rail links with the Chiltern Line, North London Line and the Euston Line passing through it. The 2.2.3 Regeneration and Priority Neighbourhoods:- North Circular Road is the Borough's major road link. • Reducing the gaps between Brent’s deprived communities and the rest of London and in particular to focus on the neigh- 2.3 BRENT’S COMMUNITY PLAN bourhoods of South Kilburn, St Raphael’s/Brentfield, Roundwood, Church End, Stonebridge and Harlesden; 2.2.1 The Community Plan, ‘A Plan for Brent 2003-2008’, drawn up by • Reducing unemployment levels across the Borough to below the Local Strategic Partnership (Partners for Brent), represents a the London average, concentrating efforts on those people combined statement of the needs and priorities of local people most in need; and identifies some of the policies that have been adopted by • Promoting a landmark development of regional and national local service providers, such as the Council, the police and the significance at Wembley, creating an identity for the Borough local health service, to meet these needs. and ensuring substantial local benefit; • Ensuring a consistently high quality of life for all residents of 2.2.2 The Community Plan identifies priority objectives under the fol- Brent – incorporating the provision of decent homes for all, lowing themes: high quality destinations and facilities, low levels of crime, • Health and social care healthy living and town centres which meet the needs of local • Environment and transport people; • Regeneration and employment • Making sure that older people, disabled people and those • Crime prevention and community safety with mental health problems are able to take a full and active • Education and lifelong learning part in the life of the community; • Taking positive preventative action in those areas most at risk Under each theme there is a description of how Partners for of falling into decline in the future. Brent is addressing the priority objectives 2.2.4 Tackling Crime and Promoting Community Safety;-

• By working with local communities, reduce the fear of crime 2.3 BRENT'S CORPORATE STRATEGY and support measures to improve residents’ personal safety.

2.3.1 ‘Building a Better Borough, the Corporate Strategy 2002-2006’ 2.2.6 There are also a number of other corporate strategy statements outlines Brent Council’s vision, values and key priorities over the which should be reflected and/or complemented by the planning four year period. It is the Council’s contract with the people of strategy in the UDP. The most significant of these are:- Brent setting out the main issues that will be addressed between 2004 and 2006. The UDP performs an important role in ensuring • Local Agenda 21 Action Plan - This contains a wide range of that many of the objectives of the corporate strategy are met. The initiatives to address environmental, economic and social key commitments in the strategy that are relevant to the UDP are issues. The implementation of the Council's planning policies set out below. in the UDP are important in ensuring that key elements of the Local Agenda Action Plan are implemented; 2.3.2 Promoting quality of life and the green agenda: • The Brent Primary Care Trust (PCT) Local Delivery Plan (LDP) ‘Investing for Health’ is the overarching three-year strategic plan for the organisation and its partners. It describes the PCT’s key priorities and identifies the resources that will need to be invested to enable this to be achieved. • The Brent Sports Strategy, aims to promote sporting activity in the Borough, thus making Brent a fitter and healthier place. • Brent Regeneration Strategy - This sets the direction of the Council's regeneration activity for the next 20 years. The vision is of a Brent fully integrated into the city – a single

Brent Unitary Development Plan - 2004 4 STRATEGY

urban Borough which makes a full and positive contribution to need to travel. It advocates the greater use of mixed use devel- the London economy. Brent’s communities will enjoy a high opment and increased importance to urban design matters. The quality of life and will be fully able to participate in society. At plan-led system is stressed as the most effective way of reconcil- the core of Brent will be a landmark international developing the demand for development and the needs of the environment at Wembley, providing a source of pride, identity, wealth ment. and aspiration for the Borough as a whole. • Brent Housing Strategy 2002 - 2007 - This includes the princi- 2.3.5 National advice on the role of development plans (PPG12), pal objectives of increasing the supply of affordable housing, December 1999, also emphasises the importance in the develop- improving the quality of the existing stock and linking housing ment process of statutory adopted plans such as a UDP. regeneration with other regeneration projects. ‘Planning decisions on proposals to build on land, or change its use, should not be arbitrary. They must be considered against clearly set out criteria. The statutory development plan provides the primary basis for this consideration. The development plan therefore, provides an essential framework for planning decisions (para 1.6).

2.3.6 PPG12 particularly stresses the importance of integrating land- use and transport planning. It requires development plans to include aims, objectives and targets on matters such as traffic reduction and development on previously used sites. It emphasises the importance of the plan-led system in providing infrastructure and the use of planning policies to secure planning obligations. The importance of land-use planning in promoting competitiveness and addressing issues of social exclusion is also 2.3 NATIONAL, REGIONAL AND LONDON highlighted. POLICY CONTEXT 2.3.7 PPG12 also sets out national advice in relation to the content of 2.3.1 In preparing policies and proposals for Brent's UDP, the Council is development plans. Such plans should include all policies and required to take account of national, regional and strategic proposals for the development and use of land, including propos- (Londonwide) planning guidance issued from time to time by the als relating to the development of the transport network as well as Government and the Greater London Authority (GLA). waste and minerals policies. Plans should have regard to the likely availability of resources, to the conservation of finite or non- 2.3.2 Underlying national planning policy is the UK Strategy for renewable resources, such as land and energy, and to the impli- Sustainable Development ‘A Better Quality of Life’. It defines sus- cations for public sector capital expenditure. Furthermore, tainable development as ‘ensuring a better quality of life for every- 'authorities should take account of the need to revitalise and one, now and for generations to come’. The revised strategy broaden the local economy, the need to stimulate employment emphasises the social aspects of sustainable development such opportunities, and the importance of encouraging industrial and as reducing social exclusion. Four major themes are empha- commercial development, particularly in the growing knowledge sised: driven sector’ (para 4.9) and plans 'should consider the relationship of planning policies and proposals to social needs and prob- • Social progress which recognises the needs of everyone; lems, including their likely impact on different groups in the popu- • Effective protection of the environment; lation such as ethnic minorities, religious groups, elderly and dis- • Prudent use of natural resources; & abled people, single parent families, students and disadvantaged • Maintenance of high and stable levels of economic growth and deprived people living in deprived areas.'(para 4.13) and employment. 2.3.8 The 1990 Town and Country Planning Act requires planning 2.3.3 It emphasises the role of planning in promoting regeneration, authorities, to have regard to environmental considerations in social inclusion and more sustainable patterns of development; preparing their general policies and proposals in UDP Part I's. especially through directing development to accessible locations. Government advice on the content of plans also refers to Government Circulars and Planning Policy Guidance Notes relat- 2.3.4 National planning policy is set out in Planning Policy Guidance ing to individual plan topics such as retailing and employment. Notes (PPGs) and Circulars. PPG1 sets out general planning This more detailed national policy advice is referred to in individu- policy and principles. It sets down the key themes of the govern- al topic chapters in Part II of this Plan. ments approach to planning and at the heart of these is sustainable development. It states "A key role of the planning system is 2.3.9 Government planning policy for the South East, which provides to enable the provision of homes and buildings, investment and the context for all development plans in the Region (including jobs in a way which is consistent with the principles of sustainable London at the time it was agreed), is encapsulated in a Planning development". (para. 1). It advocates locating development in Policy Guidance Note (RPG9) issued in March 2001. It aims to urban areas with good public transport accessibility to reduce the make urban areas the main focus for development, and green-

Brent Unitary Development Plan - 2004 5 STRATEGY

field development should only take place after all other alterna- infrastructure is particularly stressed. To this end the Stadium tives have been considered. Future development in London complex is highlighted as an area able to accommodate high vol- should support and develop London's role as a world business umes of spectators to major events. The stadium is also listed as and commercial centre and as a centre of international and a sporting site of national and international importance. national importance for retailing, tourism, education, heritage, culture and the arts. It is important to maintain London's attractive- 2.3.14 The objectives of the guidance overall are summarised as ness as a place to work and to avoid decentralisation of econom- follows: ic activity, skills and jobs from London. • Promote London as a world city; 2.3.10 The Secretary of State's regional guidance was issued as a • Maintain and enhance the competitiveness of business; response to advice from SERPLAN, which was the planning and • Encourage a pattern of land-use which reduces the need to transportation organisation representing all of London and the travel especially by car; South East region's local authorities before the GLA was estab- • Promote urban regeneration; lished. • Enhance the vitality, viability and character of town centres; • Maximise housing provision in London, consistent with main- 2.3.11 The Government's more specific planning policy for London as a taining environmental quality; whole is contained in 'Strategic Guidance for London Planning • Maintain and improve the natural and open environment; Authorities' (RPG3) issued in May 1996. The Guidance sets out a • Improve the quality and attractiveness of London's urban strategic framework for planning in London. Planning for the indi- environment; vidual diverse communities of London is the role of UDPs. UDPs • Facilitate the development of transport systems which are should give more attention to the strategic role of part I policies. safe and efficient; This will be replaced by the Mayor of London's Spatial • Seek to improve air quality, reduce pollution and encourage Development Strategy when this is adopted in 2004. recycling.

2.3.12 The importance of London as a world class city, contributing 2.3.15 The Mayor has published and consulted upon the draft Spatial around 15% of the UKs gross domestic product, is stressed. Development Strategy for London, known as the Draft London Boroughs should have regard to London's capital and world city Plan. This includes policies for the development and use of land status and make provision in plans for enhancing and supporting as well as all other policies affecting or affected by the distribution this role. of activities. It deals with matters of strategic importance to London and borough UDPs will have to be in general conformity 2.3.13 RPG3 highlights Wembley Park and Park Royal as lying within a with it, once it is adopted. In addition the Mayor has to be notified West London Regeneration corridor of fundamental regional and of applications of strategic importance and has the power to direct national importance. Development focused on public transport that applications be refused that boroughs are minded to

Brent Unitary Development Plan - 2004 6 STRATEGY

approve. An Examination in Public was held in early 2003 to 2.4.4 One of the most significant demographic changes in recent years examine issues that arose during consultation on the draft has been the increase in the numbers of very elderly (85+) peo- London Plan. ple. Together with other factors, such as later childbearing and a high divorce rate, this has resulted in a significant increase in sin- 2.3.16 National Guidance - especially that in PPG6 - promotes the gle person households (projected to be 80% of new households). regeneration of town centres - with more diverse mixed uses. It introduces a 'sequential approach’ whereby uses attracting large 2.4.5 To inform the preparation of the Plan, the Borough commissioned numbers of people are in the first instance directed towards town a housing needs and housing conditions survey undertaken in centres. More recently PPG3 has extended the principle, so that 1997. A further survey was undertaken in 2003 and this found brownfield sites are developed before greenfield sites. over 20,000 households living in statutorily unfit and overcrowded houses and that 90% of those who needed rehousing could not 2.3.17 Accordingly, the strategy of the Plan as a whole focuses new afford market housing. The Borough has the highest number in development on town centres and development nodes associat- temporary accommodation in West London. ed with public transport interchanges. The Borough supports, through West London Leadership, the Strategic Development Framework for West London which promotes Wembley as a key development node for leisure driven regeneration. The Strategic Development Framework aims to make West London into an international business centre. West London has key locational advantages with its links to the national road and rail networks, Heathrow airport and Central London. This means that it is able to attract investment that would not be attracted to elsewhere in London and in the South East. It aims to focus on nodes which offer similar locational advantages and where clusters of similar businesses operate. The attraction of international headquarters is seen as a priority, as are the retention, modernisation and ECONOMY AND EMPLOYMENT expansion of manufacturing activity and promoting it as a centre for information technology and media activities. Wembley is pro- 2.4.6 In employment terms the proportion of persons employed in man- moted as a key development node with the aim of repositioning ufacturing in the Borough has declined steadily since the war from the area as a '21st century centre of sports, media, tourism, retail almost 50% to only 11% in 1995. Alongside this has been growth and leisure activities'. Park Royal is promoted for manufacturing in the service sector. These broad economic changes have been opportunities, with the redevelopment of out-dated property and accompanied by substantial restructuring of the economy both creating advanced manufacturing inward investment sites as pri- organisationally and geographically. The number of small firms orities. has grown not only to provide new products and services but also because large companies and organisations have been subcon- tracting activities previously undertaken themselves. At the same 2.4 KEY TRENDS time, the shift of economic activities from metropolitan to non- metropolitan areas, that had its roots in the planned dispersal of 2.4.1 This section looks at some of the key trends affecting develop- the post-war decades, continues but is now a natural conse- ment in the Borough - and how these relate to the need for the quence of the growing congestion of metropolitan areas and its planning policies. It also summarises the key policy issues. associated costs.

POPULATION AND HOUSING 2.4.7 New firms have been moving in and occupying sites within industrial and business areas. These include smaller manufacturers, 2.4.2 The scale of household growth projected to occur will set severe especially in food processing, wholesale and production ware- challenges to planning in Brent. A more recent but equally signifi- housing and distribution forms, a cluster of computer related firms cant trend is a projected reversal in the decline in the Borough's in the Staples Corner area and a wide range of generally small population. The GLA estimates a 14% growth in Brent’s house- service sector firms. holds, from 101,500 households in 2001 to 112,000 in 2016 (SDS Technical Report 5). 2.4.8 All these changes have imposed a significant burden of adjustment on those parts of metropolitan areas previously dependent 2.4.3 The increasingly multi-cultural nature of the British population is for their economic vitality on the activities of large manufacturing especially reflected in Brent. According to the 2001 Census, concerns. Brent is no exception to this. Having been the tradi- 54.7% of Brent residents comprised black and other ethnic tional home of some major manufacturing companies, the 1980's minorities - the second highest proportion in London. saw significant losses in this sector. Since 1981,over 23,000 jobs have been lost in manufacturing in the Borough but an important manufacturing sector remains, notably in food and drinks industries, although these have declined as well in recent years with Heinz closing and Guinness announcing that they will no longer

Brent Unitary Development Plan - 2004 7 STRATEGY

be brewing in Park Royal. A large number of small firms have within the urban fabric. The Borough has areas of open space been established including many by African, Asian, Caribbean that are important to London as a whole: particularly the Welsh and Irish people. Unlike a number of other London boroughs and Harp and Fryent Country Park. particularly those in West London, Brent has failed to attract a sizeable share of the employment growth that has accompanied 2.4.12 In areas like Brent, the demand for built leisure, recreation and the emergence of London as an international financial capital. community facilities adds to the overall competition for land whilst the renewed interest in the use of open space for recreation and 2.4.9 Demographic trends, with large numbers of school-leavers enter- amenity purposes affects the balance between accommodating ing the labour market in the 1980's and the persistence of the dis- development pressures and enhancing the quality of life. A con- crimination that affects the job prospects of many people from tinuing trend - the disposal of sports grounds owned by compa- ethnic minority communities in the Borough, accentuated the nies and educational institutions - means that achieving this bal- impact of these changes on the level of unemployment in Brent, ance is particularly pertinent. with continuing effects for young people now in their late twenties and thirties. (The level of unemployment among 25-34 year old TRAFFIC AND TRANSPORT men in the Borough is higher than that for other age groups.) 2.4.13 Car ownership in Brent is low when compared with national levels; an average of 63% of households in 2001, with marked variations throughout the Borough. (Most trips made by Brent resi- RETAILING dents are within Brent or to other parts of outer north-west 2.4.10 Growing levels of car ownership and associated greater mobility London. Only 16% of all daily trips are made into Central London have facilitated the expansion of retail floorspace outside existing (source LATS 1991). The current focus of public transport infras- town centres. Together with increasing concentration of owner- tructure on radial trips into Central London does not address this ship in the retail food sector, this mobility has also encouraged the more scattered pattern of cross-suburban trips. development of large stores serving wide catchment areas: the pattern of convenience shopping is now dominated by the deci- 2.4.14 Increasing incomes allows substantial increased expenditure on sions of a few retailers and the location of a number of relatively travel. Car ownership nationally rose by more than 20%, and dispersed large stores. These trends have affected Brent in par- there was a general trend to travel further; be it for work, shopping ticular as relatively large sites on the North Circular Road became or recreation. The use of public transport declined in the mid- available in the 1980's. Major food stores have been developed eighties. This decline has reversed recently, and in London the on former industrial land in out-of-centre locations at Brent Park, rail system is now carrying record numbers of passengers. Colindale, Alperton and at Honeypot Lane. In addition, a million Freight transport by road increased to the extent that 96% of the square feet of non-food shopping floorspace, including a major expenditure on freight transport was on goods moved by road. As furniture store, is located outside Brent's town centres. Whilst investment in additional capacity was unable to keep pace with these developments have benefited car-borne shoppers, non car- increasing demand, congestion and delays have become com- owning households have suffered and Brent's town centres now mon on all forms of transport at peak times. perform a diminished role in retailing in the Borough and are in need of economic and environmental regeneration. 2.4.15 These trends have all had their impacts on Brent. Although the Borough has had a lower level of car ownership than nationally, there has been a significant growth in car usage in the Borough during the 1990s. In addition to traffic generated locally by residents and commerce, traffic passing through the Borough on radial routes to and from Central London and along the North Circular Road has increased. Increased traffic levels have reduced the environmental quality of residential areas and shopping centres in the Borough, have led to increased numbers of road accidents in the Borough, and have reduced the speed and reliability of bus services in London in general.

LEISURE 2.5 THE OVERALL STRATEGY

2.4.11 The 1990's saw increasing participation in leisure activities with 2.5.1 The overall aims of the Plan are :- demand for a wider range of leisure facilities involving the use of both buildings and open space. This has been accompanied by a • To improve the environment of the Borough; growing concern for 'green' issues which in metropolitan areas • To promote regeneration of areas in need of has found expression in pressure to improve the overall quality of • Renewal, ensuring that new development is sustain the built environment and to maintain and create 'green lungs' able; and • To encourage access to new development for the whole of the community.

Brent Unitary Development Plan - 2004 8 STRATEGY

The Key Diagram (map STR3), indicatively shows the main 2.5.6 Overall this will require a balanced pattern of land uses across the strategic policy designations. Borough and the achievement of mixed and balanced communities. A number of major sites in the Borough are classed as Major THE KEY OBJECTIVES OF THE PLAN Opportunity Sites. These each has specific policies to ensure comprehensive development. Each have the location, size and 2.5.2 The strategy has 10 key objectives, the part one policies are accessibility to be sites for major mixed-use development. arranged under these headings. The monitoring section (2.8) Planning briefs or development frameworks will be prepared for shows how the achievement of these objectives will be mea- each of these as supplementary planning guidance. sured:-

• Prioritising Locations and Land-Uses to Achieve Sustainable PRIORITISING LOCATIONS AND LAND-USES Development; TO ACHIEVE SUSTAINABLE DEVELOPMENT • Reducing the Need to Travel; • Protecting and Enhancing the Environment; 2.5.7 The built-up nature of much of the Borough means that land • Meeting Housing Needs; which is redundant in terms of its original purpose is • Meeting Employment Needs and Regenerating Industry and an important source of sites to accommodate Business; development that is required to meet the • Regenerating Areas Important to London as a Whole; needs of the Borough's population. • Supporting Town and Local Centres; There will never be enough land to meet • Promoting Tourism & the Arts; all of the development needs in West • Protecting Open Space and Promoting Sport; London therefore it is important that the • Meeting Community Needs; UDP sets out priorities in the use of land. • Treating Waste as a Resource. A number of areas are of strategic importance to London as a whole in terms of employ- 2.5.3 The regeneration of Brent is about creating lively, balanced com- ment (and are recognised as such in the Government's Strategic munities where people can live, work, shop, enjoy themselves Planning Guidance RPG3): the National Stadium Area and the and feel safe. Borough's main industrial estates including Park Royal which are designated as Strategic Employment Areas. These are the areas 2.5.4 The changes described in Brent's economy, as in many areas of best suited to long-term retention in industrial and related uses London, has been large areas of redundant or under used build- and appropriate for major development and redevelopment to suit ings, run down areas including town centres, with little or no the requirements of modern industry, in terms of accessibility to investment, unemployment, poverty, disadvantage, social exclu- the Strategic Road Network, size and suitability for inward invest- sion and crime. Regeneration seeks to address these problems ment. By directing industrial activities to these areas, the Council by a process of intervention - re-directing resources to arrest is able to ensure that industrial and related uses are accommo- decline, targeting disadvantage, promoting skills and education dated satisfactorily whilst protecting residential areas from the opportunities, increasing secure employment opportunities, environmental and traffic impact of their activities. Two other cat- encouraging a sense of well being within the business and local egories of employment area exist; Borough Employment Areas community, improving public transport, encouraging the provision and Local Employment Sites. This does not represent a 'hierar- of homes and securing sustainable improvements to the built and chy' of importance, rather a complementary network of sites serv- natural environment. ing different functions in the employment market.

2.5.5 The guiding principle of Brent's UDP is to meet this challenge so 2.5.8 Brent has one of the highest housing needs in London, and the that the Borough is a better place in which to live and work and Borough also places considerable importance on estate regener- that the benefits of new development and environmental improve- ation. The Council has therefore increased the priority given to ment are available to the whole community. The Council regards affordable housing, making it the main priority of the Plan. the quality of the environment and economic prosperity as inextri- cably linked. The preservation of existing jobs and the creation of 2.5.9 Alongside a prioritisation in terms of land use, the Plan contains a new opportunities depend on the attractiveness of the Borough prioritisation in terms of location. Government Policy (principally as a workplace and a residential environment. The quality of local PPG6) sets out the 'sequential approach'. This applies to devel- facilities - shopping, leisure and community - will also be deter- opments attracting significant numbers of people, where first con- mined by the extent to which the Borough can attract new regen- sideration should be given to sites in major town centres, followed erative investment. Similarly, the quality of life in Brent is influ- in turn by edge-of-major town centre sites, district and local cen- enced by the accessibility of workplaces and other facilities and tres and only then out-of-centre sites; where such facilities should the degree to which the whole community is able to share in the be grouped together and have good public transport accessibility. economic and social life of the Borough. It is also affected by the This test has now been applied throughout the Plan. levels of traffic generated by the different activities in the Borough and of through traffic. 2.5.10 In line with national policy the strategy prioritises the use of previously used urban land ('brownfield' sites) over 'greenfield' sites which in Brent include allotments, parks and playing fields. Any

Brent Unitary Development Plan - 2004 9 STRATEGY

development of these must be exceptional and justifiable in its own terms, e.g. a 'sports led' proposal to improve sports provision by developing a small part of a playing field, rather than development of open space to increase housing supply.

STR 1 Development for business, industry and warehousing uses will be protected and promoted in Strategic & Borough Employment Areas. Outside these areas, housing will be the priority alternative land-use, unless indicated otherwise in the Plan. Affordable housing will be a particular priority where it would help to achieve a mix and diversity of residential development in the 2.5.14 In order to improve the environment and reduce congestion a Borough. number of measures to restrain the use of the private car will be necessary. The amount of parking available at the end of a jour- STR 2 ney is one of the key means within the Plan of reducing car For development of retail uses, and other key town centre uses usage, as will be the introduction of on-street parking controls which attract a lot of people, first consideration will be given to (controlled parking zones). sites in Major Town Centres then sites on the edge of Major Town Centres followed by District Centres, and then sites on the 2.5.15 Brent's roads and rail lines form part of a wider network of trans- edge of District Centres, followed by local centres and, only then, port links in London. Strategic policies recognise the importance out-of-centre sites. to co-ordinate measures such as the London Bus Priority Network, the London Strategic Road Network and the London STR 3 Cycle Network. In the interests of achieving sustainable development (including protecting greenfield sites), development of previously devel- STR 5 oped urban land will be maximised (including from conversions A pattern of development which reduces the need to travel, and changes of use). especially by car, will be achieved through: (a) Locating major trip generating activity in areas most accessi- STR 4 ble to public transport, in particular at the transport inter- The Major Opportunity Sites, shown on the proposals map, will changes listed in part II of the Plan; be promoted for comprehensive development with a mix of land- (b) Giving priority to public transport, walking and cycling; uses and improvements to public transport, where appropriate. Regard should be had to any development framework or (c) Encouraging developments with a mix of uses in appropriate planning brief prepared for these sites. locations; (d) Increasing residential densities, particularly in walkable neighbourhoods (STR19); and REDUCING THE NEED TO TRAVEL (e) Securing significant public transport improvements. 2.5.11 Development that significantly attracts large number of people (such as shops, leisure uses and offices) should, where possible, STR 6 be located in places within short, and easily walked, distances of On-street parking controls and off-street parking standards will frequent public transport, so as to reduce the share of trips using be used to restrain traffic. the private car. Such developments will be restricted in scale STR 7 and/or development type elsewhere. The implementation of the London Bus Priority Network and the London Cycle Network will be a priority, including requiring its 2.5.12 Also, if development which significantly generate trips (such as provision as part of the development of appropriate sites. most housing) is located near to local facilities and work then the need to travel may be reduced (through mixed use developments STR 8 or otherwise). One of the key policy aims of the Plan is to promote Traffic management measures and planning powers will be used access by the whole community, and reducing the need to travel, to reduce traffic levels by: through promoting developments with a mix of land uses, can (a) Selectively reducing traffic congestion, especially to benefit help in this. The location of housing in relation to public transport buses and the emergency services; is also key in determining whether people use a car for work or (b) Restraining private car traffic, especially that entering leisure trips. Central London; and

2.5.13 Policies on the location of development must be supported by (c) Reducing the negative environmental effects of traffic: such policies which influence the means of transport. Sustainable as noise, vehicle emissions and accidents. means of transport such as walking, cycling and public transport are promoted in the strategy - so that the whole community can access new development.

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STR 9 context and character) urban structure (space and movement), GLA Roads and London Distributor Roads are designated as part urban clarity and safety, the public realm (landscape and of the London Road Network and the Council will ensure that streetscape), architectural quality and sustainability. detailed in development proposals and traffic management measures part II of the plan. should not conflict with their role of carrying essential through traffic, whilst discouraging through traffic on local roads. STR 15 Major development should enhancing the public realm, by creat- STR 10 ing or contributing to attractive and successful outdoor areas. Investment in and improvement to public transport facilities, and Comprehensive public realm enhancement strategies will be pre- links with national and international connections, will be sought pared for priority areas identified within the plan. for the proposed National Stadium and associated developments and in other major regeneration development proposals. STR 16 The particular characteristics of the Borough's Conservation Areas, Areas of Distinctive Residential Character, Listed Buildings PROTECTING AND ENHANCING THE ENVIRONMENT and Sites of Archeological Value will be conserved or enhanced. Particular attention will be paid to those features of importance 2.5.16 The quality of London's environment is critical to the maintenance to London's character such as the Grand Union Canal, the Welsh of its role as a World Class City. The Council is committed to Harp and Wembley. ensuring that new development contributes to preserving that which is environmentally pleasing in the Borough and improving STR 17 those parts of Brent which are less attractive. The design and Views and landmarks will be protected, in co-operation with location of new development must take into account the need to other London boroughs. conserve energy and the preservation of the wider environment. Wherever possible, schemes to upgrade the environment will be MEETING HOUSING NEEDS undertaken with the full involvement of the local community.

2.5.17 The key challenges of increased household growth and housing need are addressed in the strategy of the Plan. Two key targets are set out for additional housing (1997-2016). One for the total amount of housing , and the other for affordable housing. These targets were set following a detailed Boroughwide housing provision study examining just how much housing can be built in the Borough in this period. The Plan also contains a strategic policy for the Borough's Major Estates Regeneration Areas (MERAs), 20th century public housing estates suffering from severe structural and regeneration problems.

STR 11 2.5.18 Finally a strategic policy is included encouraging urban sites around 'walkable neighbourhoods' (a walkable neighbourhood is The quality and character of the Borough's built and natural that area within reasonable (600m) walking distance of a district environment will be protected and enhanced; and proposals or major town centre). Here, new housing can often do most to which would have a significant harmful impact on the environ- sustain the vitality of those centres and is where the need to trav- ment or amenities of the borough will be refused. el can be minimised. The strategy involves a 'design-led' STR 12 approach, appropriate to the character of the area, rather than Planning decisions should protect public health & safety. In par- one predetermined by density standards. ticular they should support the achievement of targets within the National Air Quality Strategy - especially those applying within air quality management areas.

STR 13 Environmentally sensitive forms of development will be sought, with reduced overall demand for energy and better integration with ecological and natural processes.

STR 14 New development will be expected to make a positive contribution to improving the quality of the urban environment in Brent by being designed with proper consideration of key urban design principles relating to: townscape (local

Brent Unitary Development Plan - 2004 11 STRATEGY

STR 18 to ensure that land in the Borough that has long been regarded as The following additional dwelling units shall be provided (includ- a strategic resource for new industrial development in London ing from conversions and changes of use), subject to the mainte- continues to be available for that purpose. nance of a quality environment: (a) the development of a minimum of 9,600 additional overall STR 23 dwelling completions between 1997 & 2016; and Strategic & Borough Employment Areas will be protected for industrial, business & warehouse use, for Brent and London as a (b) as part of the above the development of a minimum of 4,800 whole. additional affordable dwelling completions between 1997 & 2016. STR 24 The progress of housing completions and permissions and their The regeneration of Strategic & Borough Employment Areas to relationship to housing need will be closely monitored and meet the needs of industrial, business & warehouse users and adjustments to the housing provision levels will be proposed improve the environment will be encouraged. where necessary. STR 25 STR 19 Local Employment Sites will be protected for employment use New housing development should be located on sites which: unless the proposed development for alternative uses complies with detailed policies set down in the Plan. (a) Reduce the need for car travel; and (b) Give preference to the development of previously used urban STR 26 land; The development of business or technology parks will be encour- (c) Provide acceptable residential amenity for existing and pro- aged and promoted on suitable sites defined within the Plan. posed residents; and

(d) Provide for necessary physical and community infrastructure (e.g., community facilities, school places) arising from the development. Housing density will be determined by the acceptability of the design of a scheme complimenting the character of an area in which it stands. More intense residential development will be encouraged, particularly within walkable neighbourhoods (areas within easy (600m) walking distance of a district centre or major town centre) and where the design is of an appropriately higher quality.

STR 20 Where suitable and practical, housing development on sites capable of accommodating 15 or more units, or 0.5 hectares or REGENERATING AREAS IMPORTANT TO LONDON AS A over, should include the maximum reasonable proportion of WHOLE affordable housing consistent with the Plan’s affordable housing provision levels. 2.5.20 Two parts of the Borough are so important to London's economy that they have a concentration of proposals and special policies STR 21 applying to them. These form 'insets' to the proposals map and Major Estate Regeneration Areas, notably South Kilburn, will be inset plans in the text of the Plan itself. Park Royal is London's prioritised for comprehensive redevelopment or refurbishment as largest industrial estate. Park Royal Partnership is a business-led part of wider regeneration initiatives; including where appropri- regeneration partnership and has had great success in attracting ate linked off-site development. new investment into the area. The Wembley Regeneration Area comprises the area around the proposed National Stadium as STR 22 well as Wembley town centre. This regeneration must have two Housing will be permitted for those people with a need for sup- essential strategic components. Firstly the quality of environment ported housing in appropriate locations across the borough. created around the Stadium must be of sufficient quality to act as the 'flagship' for London's bids for international sporting events. Secondly to reduce the current unacceptable traffic impact on MEETING EMPLOYMENT NEEDS AND REGENERATING INDUSTRY AND BUSINESS local residents, especially if events are more frequent and new attractions are introduced, improved public transport links/ser- 2.5.19 The economic prosperity of the Borough and the availability of vices are necessary. jobs depends to a large extent on land being available to accommodate a wide range of business, industrial and warehousing developments, to meet the accommodation needs of both existing and new employers, and on employment areas being attractive places for employers and employees. The Council will seek

Brent Unitary Development Plan - 2004 12 STRATEGY

PROMOTING TOURISM & THE ARTS

2.5.22 Tourism and arts, culture and entertainment facilities are playing an increasingly prominent economic role. The stadium complex is the Borough's premier visitor attraction and there is considerable potential to widen this with the development of the English National Stadium and associated regeneration. The arts will play a central role in this in helping to create vital and interesting places. There is also a need to increase hotel provision as part of the Londonwide London Tourist Board strategy to relieve pres- STR 27 sure arising from the shortage of hotel rooms, especially in The development of the English National Stadium at Wembley is Central London. supported and the regeneration of the Wembley area as a regional sport, entertainment and leisure destination, involving STR 31 major improvements to the environment and infrastructure, is Existing arts, culture and entertainment facilities will be protect- encouraged and promoted. ed and new facilities will be promoted which comply with the locational requirements of the 'sequential approach' (Policy STR 28 STR2). The long term future role of the Park Royal estate as one of London's main industrial and business areas will be secured in STR 32 partnership with all relevant parties. New visitor and hotel facilities will be permitted as part of a strategy to expand tourism outside Central London, particularly to the National Stadium Policy Area, as long as such facilities do SUPPORTING TOWN & LOCAL CENTRES not conflict with residential amenity and comply with the locational requirements of the 'sequential approach' (Policy STR2). 2.5.21 The Town Centres identified in the Plan serve wide catchment areas. In particular, Kilburn and Wembley, together with a number of centres across London, have been identified by LPAC as major centres of significance to London as a whole. Town Centres are the main locations for shopping and other services, cultural and entertainment facilities and, because of their convenience and accessibility, will be maintained as such. This requires the control of major out-of-town-centre developments which threaten their vitality and viability. It is also important, especially for the less mobile, that accessible local shopping facilities should be available throughout the Borough.

STR 29 Development should sustain and enhance the vitality and viabili- ROTECTING PEN PACE ROMOTING PORT ty of the Borough's town and district centres. In particular, the P O S & P S role of Wembley and Kilburn as major centres within London will be supported. 2.5.23 The Council's policies are intended to preserve open spaces in the Borough, such as Metropolitan Open Land and Green STR 30 Chains, that are important to London as a whole as well as to pro- A widespread distribution of local shopping facilities and other tect smaller open spaces and to create new ones where deficien- local services will be maintained. cies exist. The Council will also protect those areas which have a nature conservation and wildlife value, including those whose significance extends beyond the Borough boundaries.

STR 33 Strategic open space, i.e. Metropolitan Open Land and Green Chains, will be protected from inappropriate development.

STR 34 In order to ensure the adequate provision of locally and strategically important sports facilities in North West London, development which leads to a loss of sports facilities will be refused, other than in those exceptional circumstances defined within the Plan where appropriate compensatory provision is secured.

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STR 35 of this are treating waste in the best way environmentally (the Improvements to the Borough's public open spaces and sports waste management hierarchy) and as close to its source as pos- facilities will be promoted, especially in those areas with a defi- sible (the proximity principle). ciency of quality facilities. STR 39 STR 36 In co-operation with other London boroughs and in support of Sites which have a nature conservation value will be the National Waste Strategy, a network of facilities for integrated protected and enhanced. The amenity value and needs of waste management and associated regeneration in West London wildlife should be taken into account in the design and manage- will be provided. ment of any development scheme.

MEETING COMMUNITY NEEDS

2.5.24 In order to meet the general need for community facilities and the 2.6 TOWARDS A BOROUGH OF particular needs arising from the increasingly multi-cultural nature SUSTAINABLE COMMUNITIES of the Borough's population, existing community facilities will be protected and new facilities will be encouraged. 2.6.1 Sustainable development implies that development which harms the quality of life will ultimately harm the economic development STR 37 on which this depends. Those that suffer the worst quality of life Accessible community facilities to meet the needs of the are those suffering from social exclusion from poverty, unemploy- Borough, including its workers and multi-cultural population will ment, low educational achievement etc. This is reflected in the be permitted, and the net loss of existing community facilities condition of much of the built environment. will be refused. 2.6.2 Building sustainable communities means planning for mixed and STR 38 balanced communities. It means development which is accessi- Major regeneration proposals should include proper provision for ble to and benefits the whole community and which promotes community facilities to meet the needs of that area. social inclusion. Reducing the need to travel, especially by the private car, and ensuring that residents have access to jobs within easy distance of their homes are central to achieving sustainable development. As well as influencing the pattern of development sustainable development must increasingly influence the forms of development, buildings which use recycled materials, use renewable energy and make minimum demands on resources and infrastructure.

2.6.3 The revised Plan as a whole has been designed to achieve a more sustainable Borough and each policy has been subject to an 'environmental appraisal'.

TREATING WASTE AS A RESOURCE 2.7 PUTTING THE PLAN INTO ACTION 2.5.25 London faces a crisis in terms of how to deal with its waste. It's available landfill space is running out. Brent supports the London 2.7.1 The Unitary Development Plan will only be a useful document, Pride Waste Action Plan which aims to treat waste as a resource. providing the certainty that is important to the local community Its strategy is 'recycling led' aiming to dramatically increase recy- and developers alike, if its policies are implemented, that is they cling in the capital. Brent's policies aim to implement this and to are put into practice. introduce sustainable waste management. Two key components

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2.7.2 The main way in which the Plan will be put into practice will be 11 Conservation. Rolling programme of providing design guides through development control decisions. For this reason it is and special controls in the Borough’s conservation areas, important that the Plan is frequently monitored and kept up to working closely with residents associations. date. The next section deals with this issue. In law good reasons 12 Enforcement. Proactive 'polluter pays' approach to enforce- are necessary to determine a planning application contrary to the ment including direct action. Plan. Brent's planning code of practice requires such reasons to be publicly given. 2.7.4 Brent is developing a Planning Obligations Strategy. This will help ensure that developments compensates for any harmful 2.7.3 Brent Council is not just waiting for these alone to implement the impact and, where appropriate, benefits the wider community, by Plan and is taking a series of more positive measures, including: ensuring that corporate objectives are secured. Planning obligations will be sought and secured strictly by the requirements of the 1 Estate Regeneration. Working in partnership with the housing law and national policy. The strategy prioritises infrastructure that department, local residents and others to help draw up regen- needs to be upgraded to support development. eration plans (more than just housing) for redeveloping Brent's run down post- war estates; 2.7.5 The implementation measures necessary to carry this out will be 2 Development Briefs. Providing planning briefs with urban published in an annual Brent UDP Action Plan, included as part of design frameworks for all major development sites; the Planning Service Annual report. 3 Town Centre Regeneration and Management. Assessing the health of each of Brent's town centres, working with local residents and traders with the aim of achieving a corporate approach to town centre management and town centre regeneration programmes for the two major town centres; 4 Industrial Regeneration and Inward Investment. Working with bodies such as West London Inward and Park Royal Partnership to provide potential inward investors with up to date site information. Proactive work to improve industrial areas such as compulsorily purchasing land. Environmental improvements on partnership with local businesses; 5 Integrated Transport. Work to implement the aims of the 2.8 KEEPING THE PLAN UP-TO-DATE Integrated Transport white Paper including partnerships with bus and rail operators, a Borough wide on-street parking 2.8.1 Monitoring the key planning and population changes in the strategy with planning powers used to bring it forward, provid- Borough is crucial in keeping the Plan up-to-date. ing a new tub-station/interchange at Park Royal and work to upgrade/provide interchange facilities for the three stations 2.8.2 A number of strategic policies contain key targets that need to be serving the National Stadium; met, including on housing completed, the proportion of housing 6 Housing Development. Working closely with housing associa- provided on previously developed land, and the level of traffic tions to increase affordable housing provision, and working reduction. Monitoring of these targets will be the main priority. jointly with them to identify and assess sites for the National Land Use Database which identifies brownfield sites; 2.8.3 Monitoring of certain criteria can act as Sustainability Indicators. 7 Open Space and Waterway Regeneration. Positive action to provide viable long term management plans for each of the "Sustainability Indicators are a tool by which: borough's major open spaces and sports facilities. Restoration programme for the River Brent and design and • To track progress development of local open spaces and other environmental • To measure it improvements; • To lead to the selection of active choices and changes in 8 Education and Community Facilities. Ensuring that all Brent practice facilitate a more sustainable form of development." pupils have the opportunity of a decent school place through (LGMB 1994) assessing the shortage of places and provide funding through planning obligations to meet the shortfall. Working with reli- 2.8.4 These indicators exist at national, regional and local levels. The gious organisations to ensure all major Brent religions have Government has published a series of headline indicators to worship space and opportunities for school premises; monitor progress on the national sustainable development 9 Area Consultative Forums. To give the local community a full strategy, including the proportion of housing built on previously voice in the planning and other local government priorities in developed land. The GLA also monitors environmental indica- an area; tors. Brent can make use of these for local purposes and many 10 Wembley/The National Stadium. Providing a positive plan- sustainability indicators will overlap with the key ning framework for this National project through a planning targets of the Plan. The sustainability appraisal of the Plan con- brief. Working with the land-owners in the area to ensure tains a series of indicators. A selection of these are highlighted as comprehensive regeneration of its surroundings;

Brent Unitary Development Plan - 2004 15 STRATEGY

‘headline’ indicators - bellwhether tests of progress. These are % new retail/leisure floorspace 90% 2000-2010 listed under the 10 key objectives of the Plan. The timescale and developed in/adjoining town centres level of many of the targets reflect national/Londonwide targets. Promoting Tourism and the Arts 2.8.5 The proposed headline indicators of the Plan are as follows: Hotel beds 50% increase Indicator by Objective Target 2000-2010

Prioritising Locations and Land-uses to achieve sustainable Protecting Open Space and Promoting Sport development Land in active sports pitch use No net decrease % of retail/leisure floorspace approved 90% 2000-2010 2000-2010 in areas of very good/good/moderate public transport accessibility Meeting Community Needs

Reducing the Need to Travel Net change in floorspace in D2 No net loss 2000- community use 2010 Traffic Reduction 10% 1997-2008 Treating Waste as a Resource Protecting and Enhancing the Environment Land lost to non-waste use in waste No net loss 2000- Days when air pollution is National Air Quality /management manufacturing areas 2010 moderate or high Strategy Targets

New Development attaining ‘Secured by Net Increase 2.8.6 The annual UDP Action Plan will publish the latest Borough Design’ standards monitoring information and the achievement of the Plan's key targets. The Borough constantly monitors planning permissions Reduction in areas of low townscape 10% 2000-2010 given and developments completed as part of the London quality Development Monitoring System. The Borough also monitors vacant previously developed land and buildings, and other pre- Meeting Housing Need viously land with development potential, as part of the National Land Use Database. The Borough also carries out regular sur- % of housing built on 95% 2000-2010 veys of shop uses and vacancies and periodic town centre previously developed land health checks (see Town Centres and Shopping Chapter), as well as studies of industrial land availability. Summaries of Number of dwelling completions 9,600 1997-2016 these will be included in the annual report. Overall assessment will be made for each of the 10 strategic objectives of the Plan Number of affordable dwelling completions 4,800 1997-2016 as to whether development permitted/completed is in line with, or contrary to, these objectives. Meeting Employment Needs and Regenerating Industry and Business 2.8.7 The publication of the Mayors new strategic plan for London will Land in employment use No net loss require an early review of this Plan. Work for this will be carried in Strategic and Borough Employment 2000-2010 out alongside the Greater London Authority’s work on this and will Areas be published as soon as possible after the Mayor's plan is published. Area of derelict land 25% reduction by 2008

Regenerating Areas of Importance to London as a Whole

Area of land redeveloped in 20Ha by 2010 Wembley and Park Royal

Supporting Town and Local Centres

Vacant Floorspace in Primary National Average Shopping Frontages by 2010

Brent Unitary Development Plan - 2004 16 STRATEGY

Brent Unitary Development Plan - 2004 17 STRATEGY

Brent Unitary Development Plan - 2004 18 STRATEGY

Brent Unitary Development Plan - 2004 19 STRATEGY

Brent Unitary Development Plan - 2004 20 Uni t tary en D r e B v f e o l o h p g

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Page BE16 OTHER PUBLIC REALM INITIATIVES 40

3.1 INTRODUCTION 22 3.9 OTHER STRUCTURES 40

3.2 BACKGROUND 22 BE17 BUILDING-SERVICES EQUIPMENT 40

3.3 STRATEGIC CONTEXT 23 BE18 SATELLITE DISHES 41

3.4 POLICY OBJECTIVES 25 BE19 OTHER FORMS OF TELECOMMUNICATIONS DEVELOPMENT 42 3.5 BOROUGH STRATEGY 25 BE20 ADVERTISEMENTS ON BUILDINGS 42

POLICIES & PROPOSALS BE21 ADVERTISEMENT HOARDINGS 43

3.6 DESIGN SUBMISSIONS 25 3.10 URBAN CONSERVATION 43

BE1 URBAN DESIGN STATEMENTS 26 BE22 PROTECTION OF STATUTORY LISTED BUILDINGS 44 3.7 URBAN DESIGN PRINCIPLES 27 BE23 SETTING OF LISTED BUILDINGS 44 BE2 TOWNSCAPE: LOCAL CONTEXT & CHARACTER 27 BE24 LOCALLY LISTED BUILDINGS 44

BE3 URBAN STRUCTURE: SPACE & MOVEMENT 28 BE25 DEVELOPMENT IN CONSERVATION AREAS 46 BE4 ACCESS FOR DISABLED PEOPLE 29 BE26 ALTERATIONS & EXTENSIONS TO BE5 URBAN CLARITY & SAFETY 30 BUILDINGS IN CONSERVATION AREAS 46

BE6 PUBLIC REALM: LANDSCAPE DESIGN 31 BE27 DEMOLITION & GAP SITES IN CONSERVATION AREAS 47 BE7 PUBLIC REALM: STREETSCAPE 32 BE28 OPEN SPACE IN CONSERVATION AREAS 47 BE8 LIGHTING & LIGHTPOLLUTION 33 BE29 AREAS OF DISTINCTIVE RESIDENTIAL BE9 ARCHITECTURAL QUALITY 34 CHARACTER 47

BE10 HIGH BUILDINGS 35 BE30 ENABLING DEVELOPMENT & HERITAGE ASSET CONSERVATION 48 BE11 INTENSIVE & MIXED-USE DEVELOPMENTS 36 BE31 SITES OF ARCHAEOLOGICAL INTEREST 48 BE12 ENVIRONMENTAL DESIGN PRINCIPLES 38 BE32 MONUMENTS AND EARTHWORKS 49 3.8 PRIORITY AREAS FOR TOWNSCAPE & PUBLIC REALM ENHANCEMENT 38 BE33 TREE PRESERVATION ORDERS 49

BE13 AREAS OF LOW TOWNSCAPE QUALITY 38 BE34 VIEWS & LANDMARKS 50

BE14 GRAND UNION CANAL CORRIDOR 39 APPENDIX BE1 SCHEDULE OF PROPERTIES IN CONSERVATION AREAS 50 BE15 TRANSPORT CORRIDORS & GATEWAYS 40

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APPENDIX BE2 SCHEDULE OF PROPERTIES IN GRAND 3.2 BACKGROUND UNION CANAL POLICY AREA 54 3.2.1 The built-environment is made up of many elements: buildings; APPENDIX BE3 SCHEDULE OF PROPERTIES IN transport infrastructure, streets; open land and the spaces around AREAS OF DISTINCTIVE RESIDENTIAL them; trees and other landscape features. It is the result of the CHARACTER 54 collective efforts of countless people; developers, architects, planners, engineers and builders, who conceive, fund, design, APPENDIX BE4 SCHEDULE OF LISTED BUILDINGS 55 plan, and construct our buildings, streets and public spaces. Collectively, these elements determine the character, appearance APPENDIX BE5 SITES OF ARCHAEOLOGICAL and quality of the local environment in which people live, work, IMPORTANCE AND ARCHAEOLOGICAL play and travel, often also providing urban habitats for wildlife. PRIORITY AREAS 57 3.2.2 The environment affects people in social, economic, psychologi- APPENDIX BE6 VIEWS AND VIEWPOINTS 58 cal as well as physical ways, and in recent times there has been much concern expressed about the alienating nature of the mod- MAP BE1 AREAS OF LOW TOWNSCAPE ern built environment, in addition to its production and mainte- QUALITY 59 nance - its wasteful use of energy and resources and detrimental impact on the eco-system. The quality of much modern building MAP BE2 TRANSPORT CORRIDORS AND is often seen as poor, using expensive, non-renewable materials, GATEWAYS 60 some of which adversely affect our health. Consequently, a 'good quality' environment is one that supports healthy lifestyles and MAP BE3 CONSERVATION AREAS AND encourages within us a feeling of well being, safety and confi- ARTICLE 4 DIRECTIONS 61 dence. Sustainability is thus an important dimension of urban design, which has emerged as one way of bringing architects, MAP BE4 VIEWS, LANDMARKS AND engineers and planners together with the community, to find more VIEWPOINTS 62 user-friendly solutions to poor environmental conditions.

3.2.3 Urban design has been defined in various ways, but is essentially the practice of shaping the complex interactions between urban 3.1 INTRODUCTION form and movement, between places and people, and between the built-environment and nature. It aims to influence the different 3.1.1 This chapter is concerned with the design quality of Brent's built aspects of the development process to deliver successful vil- environment and its setting. It relates to the overall 'form' of lages, towns and cities that work well. The planning system has a developments and their use, i.e. their layout, scale, density, key role in facilitating the urban design process, especially as accessibility, landscape, appearance and the way in which areas increasing attention is also being paid towards environmental function. The policies cover not just the design of individual sites 'sustainability'. The design of buildings and land use patterns and buildings, but also the spaces in between them, the linkages have a crucial impact upon natural resources and ecological pro- and relationships between the various built-environment compo- cesses. The planning system, by encouraging designs that inte- nents and public space, in order to create or maintain places that grate with natural processes, can play an important part in coun- people want to work and/or live in. The quality of the urban envi- tering such global problems as the greenhouse effect. ronment affects everyone, and good design is necessary for positive change to occur.

3.1.2 The design policies apply to all types of development throughout the borough. In some parts of the borough, the condition of the environment is so poor, that special design policies apply, to secure enhancement of their townscape and public realm.

3.1.3 The Chapter also includes policies for the preservation of our built heritage and its settings. Again, the concern is not just for individual historic buildings, but also includes the conservation of areas of special architectural or historic character. Specific policies on environmental protection are covered in Chapter 4, while the natural environment, notably wildlife and nature conservation, are addressed in Chapter 10 on Open Space & Recreation. Special design policies apply within the Wembley Regeneration Area chapter (Chapter 14).

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BRENT'S URBAN CHARACTER 3.2.8 Such improvements to the environment cannot be achieved by the Council's actions alone. Co-operation between the Council, 3.2.4 The built-environment within the borough is of relatively recent local communities and local businesses is essential and the history; from the 19th to 20th centuries. As is typical of much of Council has launched its Local Agenda 21 Action Plan, bringing London, there is a multi-centred structure from amalgamated vil- together these different sections of the community in partnership. lages. Main roads well-defined by densely developed frontages, The policies and proposals in the UDP have been designed to link the main town centre districts to each other and the wider ensure that the land-use planning system contributes to the north/west London area. The North Circular Road, however, is a objectives of the Action Plan. The Council will encourage com- significant barrier between the more affluent north/west of the bor- munity participation at all stages of the planning and design pro- ough and the poorer south/east area, and also has less frontage- cess and will seek to raise awareness of design-quality issues in definition. the community.

3.2.5 Brent's development has tended to reflect its accessibility from London. The British Rail lines and the Metropolitan Railway 3.3 STRATEGIC CONTEXT enabled suburban 'Metroland' development boosted by the British 3.3.1 The Town and Country Planning Act 1990 requires that develop- Empire Exhibition in Wembley Park in 1924/25. Much of the ment plans include policies in respect of, '..the conservation of the architecture of Brent reflects the styles of these times. As a result, natural beauty and amenity of the land', as well as 'the improve- buildings in Brent display a wide variety of local design character- ment of the physical environment'. istics. This variety has been added to by new cultural groups who have introduced new architectural styles. A recent example 3.3.2 Government policy is set out in Planning Policy Guidance Notes would be the Swaminarayan temple in Neasden. The wide range (PPGs). General Policy and Principles (PPG1) revised in 1997, of environmental conditions within the Borough, includes: gives particular advice in the field of design control, stating that; 'The appearance of proposed development and its relationships • Well-planned leafy suburbs; to its surroundings are material considerations'. PPG1 continues: • Dense 19th-century inner city housing; 'Development plans..... should provide applicants with clear indi- • 1960's & early 1970's high-rise residential estates and office cations of planning authorities' design expectations. Such advice blocks; should avoid excessive prescription and detail and concentrate • Two of London's largest industrial estates; Wembley Stadium plan policies on broad matters of scale, density, height, massing, & Park Royal; layout, landscaping and access'. However, local distinctiveness • A large number of district and local shopping centres of vary- is to be maintained and planning authorities may concern them- ing quality. selves with detailed design where this may have a significant effect on the character or quality of an area. Overall it stresses 3.2.6 A common problem with the design of many of the high-rise hous- that the 'aim should be for any development to result in a benefit ing estates was their use of standardised building forms with little in environmental and landscape terms'. Guidance in PPG3 or no regard to local character and architectural styles, often (Housing) goes further: Local planning authorities should adopt resulting in an unattractive visual appearance. They lacked policies which: defined street frontages leading to inadequate natural surveillance of street activity. In addition, the grounds were often domi- • Create places and spaces with the needs of people in mind, nated by asphalt, with an excessive proportion of sites covered by which are attractive, have their own distinct identity, but roads and parking areas with a consequent lack of space for respect and enhance local character; effective landscaping and amenity. The resulting environment did • Promote designs and layouts which are safe and take little to promote a sense of community and shared space and account of public health, crime prevention and community often contributed to an atmosphere of insecurity and alienation in safety considerations; and some parts of the borough. The overall standard of building • Place the needs of people before ease of traffic movement in (including interiors) and of urban design, was often very poor, and designing the layout of residential development. many of these properties have short life spans. 3.3.3 'Development Plans' (PPG12) stresses that environmental issues 3.2.7 Brent is not a borough of uniform character, but one of striking be taken comprehensively and consistently into account, includ- contrasts; between suburban areas in the north (with a reasoning, development plans having: able range of facilities and a strong sense of community), and southern inner-city areas (with a limited range of cultural and • Policies and proposals for the improvement of the physical recreational facilities and fear of crime). Much of Brent lacks the and natural environment in urban areas, including sustaining higher environmental quality evidenced in neighbouring bor- the character and vitality of town centres, making provision for oughs. There is now widespread recognition within the borough tree planting and the general revitalisation of urban areas; of an urgent need for substantial improvements to the quality of • Policies which stress the need for better urban design includ- the urban environment. ing the appearance of proposed development and relationship to its surroundings; • Policies which help preserve the built and archaeological heritage.

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3.3.4 Government advice on Conservation Areas is to be found in PPG It stated that effective policy and guidance should focus on how 15 on 'Planning and the Historic Environment'. 'The physical sur- development form (aspects such as layout, scale and appear- vivals of our past are valued and protected for their own sake, as ance) can be brought together in a particular local content to a central part of our cultural heritage...Their presence adds to the achieve the urban design objectives. quality of our lives, by enhancing our familiar and cherished local scene and sustaining the sense of local distinctiveness'. In rela- Development plans should set out general design policies imple- tion to the demolition of buildings in Conservation Areas, It states menting the overall urban design principles, and criteria against that 'The general presumption should be in favour of retaining the achievement of these objectives can be judged. A UDP could buildings which make a positive contribution to the character or also include design policies relating to specific areas, specific appearance of a Conservation Area'. PPG16 'Archaeology and sites or recurrent design issues. The plan could also explain how Planning', provides advice on archeological remains. design issues are to be managed in the planning process, such as when and how supplementary planning guidance will be pre- 3.3.5 Regional Planning Guidance for the South East (RPG9) prioritis- pared. The plan should also explain in what context, appraisals es improving the quality of life in urban areas to make them have been carried out, in developing policy. attractive places to live, work, spend leisure time and invest. Within the context of the UK Sustainable Development Strategy, it 3.3.8 The Urban Task Force report 'Towards An Urban Renaissance' emphasises the need to maximise the re-use and redevelopment highlighted the importance of urban design for achieving high of land and buildings without the loss of valued parts of the built quality dwellings at higher densities on previously developed environment and within the capacity of areas to absorb more land. Its recommendations included: development while maintaining and enhancing urban quality. • Introducing a national urban design framework, the key princi- 3.3.6 Government guidance on planning London's environment is prin- ples of which should be disseminated through planning and cipally provided through Strategic Planning Guidance for London funding guidance, and supported by best practice guidelines; (RPG3, May 1996). It identifies 14 core components contributing • Adopting an integrated design-led approach to regeneration to the quality of London's built-environment, suggests a number through pilot projects funded by Government; of urban quality goals to be incorporated in boroughs' strategic • Requiring planning authorities to produce unified public realm policies. It also suggests that boroughs should, in addition to & open space strategies, covering provision, design, manage identifying buildings and areas of special quality and promoting ment, maintenance and funding. policies for their conservation and enhancement, also acknowl- edge the role of conservation in regeneration initiatives. The DETR’s White Paper, ‘Our Towns and Cities: The Future - Delivering an Urban Renaissance’, (Nov. 2000) set out the 3.3.7 The Government published 'By Design - Urban design in the visions, planning policy and programmes to be pursued. A key Planning System: Towards Better Practice', (June 2000). It states policy is to secure better planning and design which is sustain- that good urban design depends upon: able, to improve the quality of people’s lives.

• A clear framework provided by development plans and sup- 3.3.9 Other relevant Best Practice guidance includes the ‘Urban Design plementary guidance delivered consistently, including through Compendium’ by English Partnerships and the Housing development control; Corporation, which outlined key aspects of urban design focus to • A sensitive response to the local context; be considered in regenerative development projects. They are: • Judgements of what is feasible in terms of economic and market conditions; and • Appreciating the context - Places for people: Interpreting and • An imaginative and appropriate design approach by those using character resources and local aspirations; who design development and the people who manage the • Creating the Urban structure - Enrich the existing: Working planning process. with the landscape and enhancing interrelations between urban elements at every scale (city, town, neighbourhood); It sets out the key objectives of urban design as: • Making Connections - Sustainable movement systems: Putting foot, cycle and public transport infrastructure before • Character - A place with its own identity; cars. Also mixing uses and forms ensuring visual integration; • Continuity and enclosure- A place where public and private • Detailing the Place - Buildings and the public realm interface, spaces are clearly distinguished; and their design for change. • Quality of the public realm- A place with attractive and suc- • Implementation - Managing the investment: Issues of viability cessful outdoor areas; and delivery mechanisms to ensure lasting quality. • Ease of movement - A place that is easy to get to and move through; 3.3.10 The Mayor of London’s Draft London Plan (DLP) June 2002, set • Legibility - A place that has a clear image and is easy to out urban design principles for London’s development as a sus- understand; tainable, compact city. These include maximising the potential of • Adaptability - A place that can change easily; and sites, enhancing the quality of the public realm, promoting world • Diversity - A place with variety and choice. class architecture and design, the sustainable use of resources, and sensitive management of London’s historic assets.

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3.4 POLICY OBJECTIVES 1. Promoting awareness of design issues amongst applicants, their agents (predominantly non-architects), developers and 3.4.1 In accordance with the overall aim of making the Borough a more within the Council; attractive place in which to live and work, the policies in this Chapter, contribute towards achieving the following objectives: 2. Setting a higher standard for submissions of supporting material with planning applications; 1. Reinforcing the attractive qualities of Brent's built-environment, to establish positive images and identities, and 3. Providing an overall UDP policy framework for assessing the enhance the quality of life for all its inhabitants; design quality of development schemes, consisting of: 2. Securing a higher standard of architectural and urban design • General, Borough-wide urban design policies; for all development, ensuring sympathetic integration within • Use & topic-specific policies such as mixed-uses, etc.; their context and respecting principal views across the • Context-specific policies for corridors and gateways Borough; needing public realm enhancement; 3. Promoting high quality development and investment in • Area-specific policies such as for Conservation Areas and Brent's built-environment, particularly for areas identified as Areas of Distinctive Residential Character. most needing improvement, to improve the sustainability and effectiveness of urban areas within the Borough; 4. Preparing Supplementary Design Guidance to support UDP 4. Preserving, managing and enhancing the Borough's built her- policy implementation: itage; • Design Strategies and Frameworks for areas in need of 5. Working, in partnership with the community, to promote a sus- townscape and public realm enhancement; tainable, fully accessible and safe environment; • Design & Landscape Guidance for specific design issues, 6. Raising local awareness about urban design issues, and pro- distinct quarters and/or character areas within the borough; moting appreciation of the built environment in Brent. • Planning, Design & Development briefs for key sites.

5. Pursuing a higher standard of design in all new buildings and 3.5 BOROUGH STRATEGY alterations to existing buildings, through development control 3.5.1 In line with increasing 'quality of life' expectations, the Council and negotiation. considers that the improvement of the Borough's environment is a very high priority. Poor environmental conditions make the Borough an unattractive place in which to live, work and play, affecting how people feel about their area, their safety and economic prospects. A poor quality environment also acts as a serious disincentive to commercial investment. A high quality environment is essential for attracting high quality investment. For this reason, the need is to focus more attention on raising the quality of urban and building design, in order to secure the long- term environmental and economic regeneration of the Borough.

3.5.2 It is also recognised that achieving this objective requires clearer design advice, and a borough-wide Urban Quality Survey was therefore carried out to inform the strategy and policies in this chapter. The Council's 'Urban Quality Survey' involved carrying- out a qualitative audit of Brent's built-environment on a thematic, representative basis (i.e. conservation, town centre, residential, open space, industrial and opportunity areas). These were assessed against a range of urban design criteria, providing a baseline of information about the conditions of various places within the Borough, and the effects of the previous policy approach. POLICIES AND PROPOSALS 3.5.3 The Borough strategy aims to substantially raise design stan- 3.6 DESIGN SUBMISSIONS dards and thereby, the quality of the urban environment in Brent. It is recognised that as development is an incremental process, 3.6.1 Proposals for development are put forward by a range of appli- higher design standards will need to be rigorously applied to all cants such as; developers, design professionals, businesses and proposals for development within the borough. The strategy for lay people, not all of whom have a detailed knowledge of the achieving these policy objectives is both comprehensive and hier- development process. To raise design standards, it is important archical, comprising the following key elements: to explicitly state what the Council's expectations are.

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DESIGN GUIDANCE effort to ensure an appropriate design quality. Government guidance in PPG1 recommends the preparation of urban design 3.6.2 The Council will from time to time, in consultation with the public statements to demonstrate that a range of design issues have and other interested bodies, issue supplementary guidance to been adequately considered by appropriately qualified and/or elaborate on various aspects of urban, building and landscape experienced designers, and that due account is taken of urban design. The purpose of such guidance is to amplify policies and sustainability goals. The Council produced new Supplementary proposals of the Plan including detailed matters of design and lay- Design Guidance Note 4 (SPG4) to guide applicants on how to out, such as any technical standards that may be appropriate. prepare full and brief Design Statements. Such guidance contributes to raising public awareness of design issues, and encouraging applicants to consider the effect of their 3.6.7 The term ‘new’ within the policy is intended to encompass rede- proposed development on the quality of the local environment. velopment schemes as well as wholly new development. It does The Planning Authority will use this guidance as a basis for not include small domestic extensions, changes of use/conver- assessing the design quality of development proposals. sions or refurbishment, as the built structure in these instances Proposals will be expected to have regard to this guidance, which would either not change at all or would not change sufficiently to will be a material consideration in determining planning applica- exert any appreciable impact. tions. External space steps away DESIGN BRIEFING from gardens 3.6.3 Effective briefing is a prerequisite for good design. Briefing is the to reduce method by which the client or developer can instruct their design- overlooking. ers on their requirements and can realise, with professional feed- Source: Pound back, what precise benefits are possible from a development. Lane redevel- Proposals that are discussed early on with the Planning Authority opment, provide an opportunity to inform the briefing stage long before Design designs have been formalised. Time spent on briefing can help Statement, eliminate late changes of mind and save expensive delays. HTA.

DESIGN PRESENTATION

3.6.4 In order to properly assess proposals for development, it is impor- BE1 URBAN DESIGN STATEMENTS tant for adequate information to be produced to a professional standard. The scope of information required to demonstrate An 'Urban Design Statement' should be submitted for design quality will depend on the complexity of the proposal and all new development proposals. On all sites of 0.3 whether it is at outline, full or detailed stage. All proposals for hectare or more, and sites likely to have a significant development must be accompanied by the appropriate, scaled impact on the public realm, in conservation areas, and and annotated drawings of the proposed development shown in sites affecting the setting of listed buildings or major its context, as detailed in Guidance note on making a Planning new regeneration projects, this statement should Application. Significant, major or complex proposals should also include matters relevant to the scheme, such as: be accompanied by three-dimensional (3D) representations such (a) Important features (trees, hedgerows, buildings, as an axonometric or perspective drawing, a CAD presentation etc) within and/or forming the edges of the site; and/or a portable scaled model. (b) The location and nature of existing & potential links 3.6.5 Applicants should be aware that separate permission from the to and through the site, to facilities outside it (Policy BE3); Council's Building Control unit may also be required under the Building Regulations. It is therefore important at the outset, to (c) Important views within and out of the site, and seek the advice of qualified architects, designers and engineers landmarks visible outside the site; who are experienced in dealing with design and structural work. (d) The relationship of the site to surrounding area (levels, etc); DESIGN STATEMENTS (e) How the design relates to and enhances its urban context (Policies BE2, BE4, BE5 and BE7) as well as 3.6.6 The process of designing a development for a particular site the concept and principles behind the architectural should start with an assessment of its physical nature and local & landscape design (Policies BE6 and BE9); and conditions. It should be followed by a rational explanation of how the development relates to the site's contextual features and con- (f) How the development contributes to urban sustainability & regeneration (Policies BE11 and BE12). tributes towards sustainability objectives. 'Off the shelf' designs and corporate styles, whether of commercial buildings or housing, On smaller and/or uncontroversial proposals, a brief which do not reflect the specific context of a place, will not be statement of the design approach should be provided. acceptable. The Council will expect applicants to have made an

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3.7 URBAN DESIGN PRINCIPLES happily fit into many settings where the environment has been built up over many generations. In addition, good architecture is 3.7.1 The plan’s urban design policies do not seek to restrict design often architecture that surprises, and the Council's desire to see creativity. They are intended to discourage the submission of selective adoption of local design characteristics need not pre- poorly considered schemes, safeguard basic amenity standards, clude the introduction of innovative designs that relate well to their and promote better, more sensitive design, striking a balance surroundings. such that the existing character of areas is respected (where this is attractive and worth preserving), while architects and developers have the freedom to originate new design solutions where BE2 TOWNSCAPE: LOCAL CONTEXT & appropriate. Generally, good design will be encouraged, while CHARACTER obviously poor designs will be resisted. The following policies, outline the general design criteria that will be used to assess the Proposals should be designed with regard to their design-quality of all applications. local context, making a positive contribution to the character of the area. Account should be taken of: 3.7.2 Development proposals will be assessed with regard to their (a)The existing landforms and natural features; overall effect on urban quality, and should demonstrate that all the following urban design objectives have been adequately (b)The need to respect or improve the quality of exist- addressed: ing urban spaces, materials, townscape or historical features which contribute favourably to the character of an area; and 1. TOWNSCAPE: LOCAL CONTEXT & CHARACTER (POLICY BE2); (c)The opportunity for improvement or variety within an area of poor or uniform character, by creating a 2. URBAN STRUCTURE: SPACE & MOVEMENT (BE3 & new area of distinctive quality on suitable sites. BE4); Proposals should not cause harm to the character 3. URBAN CLARITY & SAFETY (BE5); and/or appearance of an area, or have an unacceptable visual impact on Conservation Areas, Areas of 4. THE PUBLIC REALM: LANDSCAPE & STREETSCAPE Distinctive Residential Character, Listed Buildings, (BE6, BE7 & BE8); Views, Landmarks, Green Chains or Metropolitan Open Land. 5. ARCHITECTURAL QUALITY (BE9 & BE10); Application of these criteria need not preclude the sen- 6. SUSTAINABILITY: INTENSITY, MIXED-USES & sitive introduction of renewable technologies, innova- SUSTAINABLE DESIGN (BE11 & BE12). tive contemporary designs and designs which reflect the cultural diversity of the area. 1. TOWNSCAPE: LOCAL CONTEXT & CHARACTER 2. URBAN STRUCTURE: SPACE & 3.7.3 A knowledge and understanding of local context (topographical, MOVEMENT functional and visual characteristics of an area) is necessary in order to successfully integrate new development into the built- environment. The Borough is made up of areas of distinct identi- SPATIAL ORGANISATION ties and varying quality. In an established urban area such as Brent, development proposals on most sites should examine and 3.7.5 One of the basic principles underlying the design of urban areas respond to local design and landscape characteristics derived is the enclosure of space by built structures, primarily buildings. from the landforms and natural features, colours, materials and Enclosed urban spaces can be visually pleasing by increasing texture, as well as the uses, heights, scale, bulk and design of variety and visual interest, and are experienced as being more buildings. The important contextual cues depend on the scale of 'comfortable' at the pedestrian scale, often contributing to a sense the proposed development. More extensive proposals need to of 'belonging' or community, which can foster a safer, more consider a wider range of general characteristics, while single secure environment. They can also contribute to road safety by infill schemes and extensions need to respond to more detailed influencing drivers' perception of speed in residential areas. characteristics on the particular street on which they are located. 3.7.6 In order to provide an interesting and stimulating urban environ- 3.7.4 Buildings in Brent express a wide variety of local design charac- ment, development should create streets and spaces of varied teristics, many of which are worthy of protection, and this variety character. The degree of enclosure achieved in public spaces of design has been added to by new cultural groups who have within a development should be designed according to the types introduced fresh architectural styles. Modern buildings that selec- of spaces provided, and variation in their scale, form, treatment tively adopt some of the characteristics of existing buildings can and edges can be used to achieve individual identity and charac-

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ter. Townscape features such as gateways, landmarks, level- 3.7.9 It is recommended in the 1998 'Places, Streets and Movement' changes, and focal points such as; prominent corner sites, can publication by DETR, that a Movement Framework be designed also be used to provide drama and interest, while visual linkages for new development, to ensure that travel on foot, by bicycle and can be established between streets and spaces, using vistas and public transport have priority, and are properly integrated within a framed views. scheme. The advantage of such a comprehensive strategy at the outset, is the safeguarding of routes for the different forms of 3.7.7 Continuity, in terms of having regard to established building lines, movement, which it would be difficult or impossible to fit into the is important for reinforcing the edge of spaces within the urban design later on. environment. In order to maintain enclosure, the built frontage of the street should be as continuous as possible, without large gaps between buildings or deep setbacks from the public footpaths. BE3 URBAN STRUCTURE: SPACE & MOVEMENT Variations to the building line should only be used where they can denote important or public buildings, create well-defined spaces Proposals should have regard for the existing urban that are both useable and pedestrian friendly, or where they serve grain, development patterns and density in the layout a townscape function such as marking a junction or helping to of development sites, and should be designed to frame a particular view. ensure that:

(a) Spaces are satisfactorily enclosed by built-form. All MOVEMENT: PERMEABILITY & ACCESSIBILITY spaces between and around buildings should be created to be functional, and attractive for their 3.7.8 The first major design consideration for access to any new devel- intended users; opment, concerns the network of public routes and spaces on the (b) Its layout is defined by pedestrian circulation, tak- edges or within the site. An important aspect of a good urban ing the form of urban blocks; environment is its 'permeability', that is, the availability of convenient and safe, non-vehicular public routes linked to streets, facili- (c) Particular emphasis is placed on prominent corner ties and amenities. The location of public spaces should help peo- sites, entrance points, and creating vistas and pub- ple find their way around the borough by reinforcing intersections lic areas; and of traffic and pedestrian routes. The permeability of the surround- (d) It respects the form of the street of which it is a ing area needs to be assessed, taking account of desirable public part, by building, or responding to the established routes through or around the site and creating opportunities to line of frontages, unless there is a clear urban design or planning justification;

(e) Connections are established where appropriate, to open space and regard given to the potential for green landscaping.

Development layouts should also make explicit, an overall movement framework, which should:

(i) Prioritise movement by foot, cycle and public transport;

(ii) Encourage convenient pedestrian access to important civic areas by retaining existing, or providing new, routes and linkages which contribute to the contribute to wider aspirations of cycleways or footpath networks. permeability of an area; Any proposal which would result in the complete loss of a public route will only be acceptable if a satisfactory alternative, linked to (iii) Minimise traffic conflicts between vehicles, pedes- existing facilities and adjoining public spaces, is provided, as new trians and cyclists by ensuring a clear delineation of routes which are separated from their surroundings are more like- routes and unencumbered entrances and circulation; and ly to be unsafe and vandal-prone. (iv) Integrate the proposed development with public transport and car parking facilities.

ACCESS FOR DISABLED PEOPLE

3.7.10 The second major design consideration related to movement, concerns the equitable access to the development for disabled people. Equity is an important dimension of sustainability, and access is a major problem for large sections of the community, for whom parts of the environment can be unusable. The most acute disadvantage can be faced by disabled people and a significant

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proportion of the community (risen overall from 11.4% in 1991 to buildings and land under its control have adequate facilities and 15.6% in the 2001 census) suffer from some form of mobility dis- access. Other chapters of the Plan contain specific policies on ability, whether through a limiting long-term illness, age or injury. access for disabled people. This section of the community has a basic right to use the parts of the environment that everyone else takes for granted. 3.7.14 In addition to making the built environment accessible to disabled people, and the consequent increased opportunities this brings, 3.7.11 There are a wide range of disabilities; in addition to those who are good physical access benefits everyone, particularly the elderly wheelchair-bound, there are the 'ambulant disabled', with and families with young children. Good access is good design impaired sight, hearing, speech or a combination of these. There and planning. are also those with disabling health problems, such as heart or respiratory conditions, rheumatism and arthritis. The elderly, pregnant women and parents with young children and pushchairs BE4 ACCESS FOR DISABLED PEOPLE also tend to find access to the built-environment challenging. The various needs of all of these groups need to be taken into account Developments open to the general public or used for in design decisions, as inconsiderate urban and building design employment or educational purposes shall include has a considerable effect on the quality of life of these significant suitable access and facilities for disabled people , sections of the community. which should also be provided in schemes for changes of use, extensions and alterations unless practical considerations dictate otherwise.

The policy does not apply where there are separate requirements under the Building Regulations.

3. URBAN CLARITY & SAFETY

3.7.12 The Disability Discrimination Act 1995, requires that buildings to which the general public are admitted, including places of UNDERSTANDABLE PLACES employment and education, are accessible to disabled people 3.7.15 The 'ability of users to understand a place' and find their way and have suitable parking and toilet facilities. The Planning Acts, around it, is very important in two ways. In order to benefit fully as modified by the Disability Discrimination Act 1995, requires from the choices and qualities within a townscape, people, espe- that planning authorities draw the attention of developers to the cially visitors, need to be able to quickly understand both the lay- provisions of the 1995 Act and to the British Standard BS8300: out of a place and what goes on there. Legible layouts and activ- 2001 for disabled access. BS8300 and the Building Regulations ities make it possible for people to form a clear mental picture of 2000, Approved Document M (2004 edition) also set out minimum the main physical features in a place, and of the main patterns of standards with which access provision should comply. The use of buildings and spaces. Therefore, a 'legibility analysis' of a Disability Discrimination Act 1995 requires all providers of goods, site's context is an important part of good design. This involves facilities and services to take reasonable measures to ensure that considering the significance and clarity of existing physical they are not discriminating against disabled people. The Office of aspects such as: the Deputy Prime Minister has published a good practice guide • Paths (movement channels e.g: streets); for the planning system, ‘Planning and Access for Disabled • Edges (boundaries and barriers); People’. Strategic developments should also have regard to the • Nodes (movement junctions and meeting places); specific policy on inclusive design in the draft London Plan, which • Districts (distinct areas, quarters); is supported by a draft best practise guide, ‘Accessible London’ • Landmarks (visible points of reference).

3.7.13 The standard design guidance for access for disabled people; The design of a new development may integrate with or reinforce 'Designing for Accessibility' 2004 edition, is a joint publication by these existing features, and/or form new features, to enhance or CAE (Centre for Accessible Environments) and the Royal Institute improve an area's identity. of British Architects (RIBA). The Council will expect all developments and refurbishment schemes requiring planning permission to have regard to those standards which are incorporated in the Council's draft Supplementary Planning Guidance (SPG 12),, but it will not impose more onerous requirements than those set by 'Part M' of the Building Regulations. This should enable disabled people to visit and use buildings and their surroundings. The Council will endeavour to improve access and facilities for disabled people and will make particular efforts to ensure that all

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WELL-USED SPACES tive way of making the Borough safer, than the negativity of shutters, barbed wire and other physical crime prevention devices, 3.7.16 In order for a place to be understandable, it is also important for which may provide well-fortified private spaces, but result in very the function and ownership of spaces to be clear. The three main hostile public spaces. The informal surveillance of public and space-types are; public, private and semi-private, of which public semi-private spaces is an important community safety concept spaces, such as streets, footpaths, squares and parks are the recognised by the 'Secured By Design' Police initiative, and is most important in urban design terms, because they can be used best achieved when buildings front onto these spaces, and when for civic activities by everyone. Private spaces, such as rear gar- these front elevations also contain the main entrances. In order dens by contrast, serve only the occupants of the related houses to further crime prevention and to enhance personal security, or flats for their private outdoor activities. Semi-private spaces include residents' parking areas, courtyards, driveways and/or 3.7.21 The Council will assess development proposals according to the front gardens, which usually form a privacy-maintaining buffer or criteria set out in policy BE5 and having regard to its transition zone between the public realm and buildings marking Supplementary Planning Guidance (SPG10) Community Safety. the beginning of the private domains. Where appropriate, conditions will be attached to permissions, requiring the residential and/or commercial elements within a 3.7.17 The means of distinguishing between these spaces need not development to comply with the relevant British Standards and always involve a barrier such as a wall or fence and can often be with the aims and objectives of 'Designing-Out Crime' and/or very subtle, using changes in level or surface textures, building 'Secured by Design' principles. edges and soft landscaping to define each area. If public, private and semi-private spaces are to function effectively, these differences must be clearly discernible to their users, because unclear BE5 URBAN CLARITY & SAFETY or ambiguous spaces lack defined ownership and often do not operate as intended, leading to problems with loss of privacy, Development should be designed to be understand- inadequate maintenance, and inappropriate behaviour. The loca- able to users, free from physical hazards and to reduce tion of public spaces should also help people find their way the opportunities for crime, incorporating the aims around the borough by reinforcing intersections of traffic and and objectives of both 'Secured By Design' and pedestrian routes. 'Designing-Out Crime' concepts, such that:

(a) Clear relationships are created between existing COMMUNITY SAFETY & DESIGNING-OUT and proposed urban features outside and within a CRIME site, so that users know how to move into and through the development; 3.7.18 The fear and reality of crime is a major factor preventing the full (b) Public, private and semi-private spaces are clearly enjoyment and use of the environment. A reputation for high lev- defined in terms of their use and control; els of crime can also be a factor in hindering the economic regeneration of an area. Safety and the perception of safety is there- (c) The informal surveillance of public and semi-private fore an important issue. The Council, in cooperation with the spaces around buildings is maximised through the police and the local community, is carrying out a Community positioning of fenestration, entrances and other forms of overlooking; Safety Programme designed to improve the safety of streets and Council premises, to minimise opportunities for crime and to raise (d) Front elevations should address the principal awareness of the ways in which crime may be prevented. adjoining streets containing, where possible, habitable rooms and actively-used main entrances, with 3.7.19 Successful crime prevention often depends on a wide range of private areas to the rear of the property. Significant measures in which the planning process can assist in 'designing- areas of blank walls and parking should be avoided on back-of-pavement locations.; out' crime at the outset of the design process. Circular 5/94 'Planning Out Crime', states that crime prevention is capable of (e) Entrances are overlooked by development, provid- being a material consideration in considering planning applica- ed with good lighting and are visible from the tions. It is the intention of the Council and Police Service to street; reduce the impact of crime within the Borough by ensuring that all (f) Rear gardens do not adjoin public space, or if not development proposals have satisfactorily sought to design-out possible, should have a secure barrier; crime in line with the advice contained in Circular 5/94 and having (g) Parking spaces are provided within view of proper- regard to the principles of the police 'Secured by Design' initiative. ties, and if not possible are made safe in other Brent and the Police will seek to incorporate these measures as ways, and are not normally accessible via the rear early as possible in the design process. gardens of residential properties; and

3.7.20 The large majority of all crime is committed only when the oppor- (h) Public spaces and accessways through or adjoining a site are overlooked by development, provided tunity presents itself and design can play a part in deterring such with good lighting, set away from cover and pro- crime through improved layout, lighting and more secure barriers. vide clear sight lines, and should not run next to There is plenty of evidence that a combination of good design, rear gardens. management and community involvement, is a much more effec-

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legal agreements the Council will seek to protect and retain trees, shrubs, and hedgerows (see also policy BE32). Where trees and other landscape features are identified for retention, it is very important for appropriate contracting and site supervision procedures to be in place to protect them from damage during and after construction. This is an integral aspect of the design and implementation of the development. The Planning Authority will expect the details of such arrangements to be provided in a Landscape Method Statement. 4. THE PUBLIC REALM: LANDSCAPE & 3.7.26 The quality and suitability of new planting is also crucial to ensur- STREETSCAPE ing the ongoing sustainability of the Borough’s landscape. Use of 3.7.22 The 'public realm', as distinct from the private domain, refers to all semi-mature or advanced nursery stock will be particularly impor- the physically and visually-accessible space such as; forecourts, tant for screening and boundary treatments. Care will be needed streets, pavements, squares, parks, open spaces and the with security fencing which should not create an oppressive effect facades of the buildings, or other structures, that define them. It and should be softened by planting. The Council will adopt is, as the main setting for human interaction, arguably, the most Supplementary ‘Landscape Design Guidance’, during the Plan important part of the built-environment. However, as evidenced period. from Brent's Urban Quality Survey 1999, the quality of the public realm in some locations within the Borough has continued to decline; from the proliferation of fly-posting, graffiti, advertisement & signage clutter, mediocre and poorly maintained buildings, des- olate public spaces, traffic congested streets and lack of pedestrian vitality particularly at night. This has led to perceptions of insecurity and an increasing tendency towards 'gated' developments in the private realm. In order to reverse these trends, special attention needs to be paid to the design and maintenance of the landscape and streetscape.

LANDSCAPE BE6 PUBLIC REALM: LANDSCAPE DESIGN 3.7.23 The quality of the built environment is greatly enhanced by considering site planning and the integrated use of hard landscape A high standard of landscape design is required as an (e.g. paving, street furniture) and soft landscape (trees, shrubs, integral element of development schemes. This will grasses) treatments at an early stage in the design process. be expected to include: These need to be designed in relation to the arrangement of (a) A design which reflects the way in which the area spaces, their usage, access, circulation and safety criteria, bear- will be used and the character of the locality and ing in mind the overall location of a scheme. Applicants are surrounding buildings; advised to seek professional advice from a qualified landscape architect, regardless of the scale of the development. (b) An adequately landscaped frontage (including trees and shrubs) on commercial developments outside town centres; 3.7.24 The landscape of a site and the street frontage provide the setting for buildings and make an essential contribution to what consti- (c) Retention of existing mature trees, shrubs and tutes the character of an area. Soft landscaping is at a premium hedges, particularly where these form part of the within the town centres and other urban parts of the Borough. In character of an area; addition to the ecological, aesthetic and micro-climatic benefits, (d) New planting of an appropriate specification established vegetation helps integrate architecture with the urban (species, size, density of planting) with semi- landscape, adding to development value. mature or advanced nursery stock; (e) New, integrally-designed, structural landscaping on 3.7.25 The Council is committed to retaining and preserving the best of appropriate larger sites ; the Borough's landscape which has taken years to reach maturity, (f) Boundary treatments such as: fencing, railings, etc. and will ensure that all new developments make a positive and which complement the development and enhance continuing contribution to the Borough's landscape character and the streetscene; that as many existing landscape features as possible are retained. Ensuring adequate maintenance and management (g) Screening of access roads and obtrusive develop- schemes for landscape is of particular importance (Circular ment from neighbouring residential properties; and 11/95). Existing vegetation usually needs less maintenance and (h) Approval of any landscape scheme and implemen- management than new planting, and the species contribute to the tation, management and/or maintenance pro- existing character of the area. Through the use of conditions and grammes, before work on site commences.

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THE STREET ENVIRONMENT 3.7.31 As well as protecting the existing streetscape, the Council will endeavour to enhance street planting. This will be particularly 3.7.27 The frontage and setting of buildings forms an essential part of important in the case of major developments where it is not possi- the street scene, being also important environmentally particular- ble to provide landscaping on site. ly through the absorption of runoff and dust particles. Although the Council seeks to ensure a safe, accessible and informative street environment for all residents, visitors and tourists, in terms of suitable surfaces, adequate signage and sufficient facilities, it does not have control over parts of the street and trunk roads managed by statutory undertakers and the Highways Agency.

3.7.28 Lamposts, seats, traffic signs and other items of 'street furniture' are necessary and useful, but increasing numbers and poor design and siting can create clutter, detracting from the appearance of the street scene. In recognising that street furniture can add interest, provide information and make a positive contribution to the quality of the physical surroundings, the Council has made considerable efforts to eliminate clutter from the streets by reducing the number of signs and posts. The Council also tries to BE7 PUBLIC REALM: STREETSCAPE ensure that all such items are well designed and located. Where street furniture is the responsibility of statutory undertakers then A high quality of design and materials will be required the Council will use its influence in this regard. In sensitive areas, for the street environment. The design and provision such as Conservation Areas, the design of lamp posts and of of all important street elements and furniture (includ- seating can greatly assist in preserving and enhancing local char- ing public art) will be coordinated, wherever possible, acter. Regard will be had to 'Streets for All’, a guide to the to make a positive contribution, avoid unnecessary Management of London's Streets' prepared by English Heritage clutter, and ensure a safe, informative and attractive with the active involvement of the London Boroughs. It gives environment. best practice guidance on street management issues. In the siting of street furniture the access requirements of the utility Public realm improvements, including street furniture, providers will be taken into account. public art and the planting of new street greenery will be promoted and encouraged. Where appropriate, RESIDENTIAL STREET FRONTAGES through Planning Obligations, the enhancement of the public realm that forms the setting for significant and 3.7.29 Many residential parts of the Borough have an open suburban major developments, will be sought, particularly in character, which is deserving of protection. Random extensions areas requiring improvement to the public realm or and developments which fill in the spaces between buildings can with low tree coverage. gradually erode this character. In order to retain the open character of streets and street junctions and to retain an adequate space Within residential areas, the following will be resisted for landscaping, the flank and rear walls of properties should be (both for existing and new developments) where they set in by 2m from the edge of the property where this adjoins a would detract from the character of the area and street, unless the wall would follow the building line of an adjoin- where planning permission is required:- ing property. (The normal 2m set-in may be reduced to 1m in cer- (a) The excessive infilling of space between buildings tain densely developed parts of the Borough). and between buildings and the road;

3.7.30 Maintaining adequate green space between a building and the (b) The loss of paving, front walls, railings or hedges of road is important but there is great pressure to use this space for character and common to the street, which should be restored or reproduced where practical; other purposes: hard-standings and crossovers, road widening and so on. Forecourt parking is a particular problem: the pres- (c) Hardsurfacing occupying more than half of a front sure to avoid on-street parking must be balanced against a num- garden area; and ber of other factors, especially the need to preserve adequate (d) Forecourt parking, where this would cause (b) or front green space. Where Permitted Parking Areas are introduced, the Council will consider the use of Article 4 Directions (c) And where such parking would detract from the streetscape or setting of the property, or create a (see Glossary) to protect the contribution of forecourts to the road/pedestrian safety problem. street scene (see also policy TRN15 on forming an access to a road). In Conservation Areas and in Areas Of Distinctive Residential Character, a high quality of street furniture will be required to preserve or enhance the character of these areas.

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LIGHTING & LIGHT POLLUTION 5. ARCHITECTURAL QUALITY

3.7.32 The imaginative use of lighting can be a powerful way of show- 3.7.34 The Council is keen to promote high quality architectural design, casing buildings, landscape and topographical features, defining in order to improve living and working conditions and raise the routes and boundaries as well as emphasising views and land- profile of Brent. This section covers aspects of architectural mark features. It can thus make a significant contribution towards design which can impact significantly on the quality and vitality of the Council's objective of improving the overall experience of the spaces in between them. Although it is not appropriate for major areas within the Borough, beyond the daylight hours. This design policies to prescribe particular styles of architecture, it is will require considering the lighting within Wembley, and other still necessary to provide guidance on the main principles to be centres such as Kilburn, Harlesden and Cricklewood, taking observed, for instance, in the form and elevational treatment of account of their night time economy, safety, security, desired buildings, to ensure a good quality and harmonious composition image, residential amenity, energy use and light pollution, as a in various locations. A surprisingly high number of buildings do whole. not benefit from the design skills of architects, and creativity can often be stifled by clients' preferences for standard pattern book or corporate solutions. Design policies which require the exercise of architectural skill, innovation, and artistic creativity and expression, can therefore serve as a useful tool for securing more innovative, site-specific design solutions.

3.7.35 The Council wishes to promote respect for local character in the 3.7.33 Lighting is essential in many instances for security reasons as design of new buildings by ensuring that they are in harmony with well as for traffic and pedestrian safety, and is just as important for their settings and surroundings, particularly where these affect enhancing buildings of architectural and historic significance. open spaces that contribute strongly to the character of the Poor or insensitively designed schemes can, however, lead to Borough. Amongst those local design characteristics which 'light pollution' where excessive amounts of lighting diminish the should be assessed are the: siting, orientation, plot width, foot- integrity of the night-time sky, and result in unnecessarily high print, major proportions, detailing, roofscape, fenestration scale, energy consumption. Where there is a danger of this, lighting emphasis and rhythm of adjoining development. However, should be designed to minimise glare and spillage, and kept to respect for local design characteristics need not mean slavish the minimum required for security and operational uses. replicas with no element of originality, or the use of characteristic Applicants are referred to the Institute of Lighting Engineers’ traditional features unrelated to any overall design concept. In Guidance Notes for the Reduction of Light Pollution. It may also particular locations, including industrial and commercial areas be desirable to screen lighting installations from neighbouring and some main road frontages, a bold, innovative design which residential areas and roads, and consider minimising the visual does not clash with the surrounding area, may serve to add visual impact of lighting apparatus on daytime views through the height, interest. In areas with poor character and environments, the width, design, location and surface treatment. introduction of fresh architectural styles can be beneficial, and the introduction of high quality innovative designs will be encouraged where these can positively contribute to the appearance of the BE8 LIGHTING & LIGHTPOLLUTION Borough.

Sensitively designed proposals which create and USE, CIVIC FUNCTION & LOCATION improve lighting are encouraged where it contributes to the overall spectacle and image of major areas such 3.7.36 Most new buildings should not dominate the townscape of estab- as Wembley and enhances the experience of town lished urban areas, but blend carefully into them. Notable excep- centres with significant night time uses, such as tions in which the use or function of a particular building may justi- Kilburn, Harlesden and Cricklewood. fy a greater significance in the townscape, include important public buildings, such as town halls, libraries, theatres, religious build- Development proposals should however, conserve ings & sports centres. The size and scale of new buildings should energy through the use of low energy or renewable therefore be related to their public importance and location. This lighting systems where appropriate, and should pre- does not preclude changes in scale or massing for a design pur- serve the darkness of the night time sky, particularly pose, such as closing a vista or corner-site treatments to provide near Metropolitan Open Land and Public Open Spaces. a local landmark building. and Lighting should be controlled to avoid nuisance to road users, harm to residential amenity and/or detri- MATERIALS ment to local distinctiveness. 3.7.37 The use of appropriate materials is also important for integrating a Where appropriate, conditions will be used in control- new building with its surroundings. The choice of facing materials ling the intensity of lighting to avoid nuisance to road should include proper consideration of their quality, fixing meth- users, harm to residential amenity and/or detriment ods, colour, texture and profile. In all cases, durability, water run- to local distinctiveness. off, and the ability to withstand weathering, must be considered,

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in addition to their aesthetic suitability. The Council is concerned HIGH BUILDINGS to ensure that buildings do not deteriorate in appearance because of inadequate materials and detailing, and will favour the use of 3.7.39 Although it is recognised that high buildings can act as landmarks durable materials wherever possible. Some finishes and eleva- and focal points, and can play an important economic role, the tional treatments, e.g. highly reflective glass, may therefore not Council considers that new development should generally be appropriate in sensitive locations such as within Conservation respect, though not necessarily replicate, the traditional scale and Areas and Areas of Distinctive Residential Character. character of the existing surroundings. High buildings are considered appropriate only in a few locations in the Borough where their impact can be contained and where they would contribute EXTENSIONS & ALTERATIONS TO BUILDINGS towards overall regeneration. In sensitive areas, the likely effect 3.7.38 The design of extensions and alterations should start with an of high buildings on Listed Buildings and Conservation Areas for appraisal of the existing building, in order to produce a comple- instance, will determine their appropriateness. Policy BE10 sets mentary and harmonious addition. The Council will need to be out the framework for considering building heights. satisfied that matters of detail have been fully considered from the start. Extensions are covered by Policy H24 in chapter 5 and SPG5: Extending Your Home. Detailed design advice on conversions and amenity considerations in new residential development is provided in SPG17: Residential Design Standards.

BE9 ARCHITECTURAL QUALITY

New buildings, extensions and alterations to existing buildings, should embody a creative and appropriate design solution, specific to their site's shape, size, location and development opportunities, and should be designed to: 3.7.40 There is no formal definition of a High Building, but they are generally taken to be more than 25m high (82 feet or 9 storeys) or of (a) Be of a scale, massing and height that is appropriate to their setting, civic function and/or town- any height which significantly exceeds that of the surrounding scape location; development. Different parts of the Borough are sensitive to different building heights and this is reflected in Policy BE10. The (b) Respect, whilst not necessarily replicating, the pos- Council will consult other London boroughs on proposals for itive local design and landscape characteristics of buildings over 40m (133 feet) in the Wembley Regeneration Area adjoining development, and satisfactorily relate and on proposals for buildings of over 30m (100 feet) elsewhere them; in the Borough. The Council will also consult the GLA, the (c) Exhibit a consistent and well-considered applica- Commission for Architecture and the Built Environment (CABE), tion of the principles of any chosen style; and English Heritage on proposals for high buildings in general; (d) Have attractive front elevations which have a direct the Ministry of Defence for buildings covered by the Town and relationship with the street at ground level, with Country Planning (Aerodromes and Technical Sites) Direction well-proportioned windows, and habitable rooms 1992, and British Waterways for buildings in or visible from the and entrances on the frontage, wherever possible; Grand Union Canal Corridor. In the event of the Council receiving (e) Be laid out to ensure that buildings and spaces are a planning application for an exceptionally high structure or build- of a scale, design and relationship to each other, ing (over 91m or 300 feet), the Council will consult the Civil which promotes the amenity of users, providing a Aviation Authority. By virtue of the Town and Country Planning satisfactory level of sunlighting, daylighting, priva- (Mayor for London) Order, the Mayor of London will need to be cy and outlook for existing and proposed residents; notified of buildings in the Borough over 30m in height. and

(f) Employ materials of high quality and durability, 3.7.41 The combined effect of a concern to restrict high buildings to loca- that are of compatible or complementary colour tions where their impact can be contained and of other policies in and texture, to the surrounding area. the Plan, particularly that on major purpose built offices (EMP15), is to restrict tall office buildings to the Wembley Regeneration Particular attention will be given to these matters in Area which has very good public transport access appropriate to Areas Of Medium-High Townscape and Public Realm such development and can accommodate the visual impact of Quality (See paragraph 3.8.3), in areas abutting Green such buildings. The design of modern industrial plant may also Chains and Metropolitan Open Land, and for proposals create the need for high buildings, for this purpose Park Royal is affecting Conservation Areas, and Areas Of Distinctive identified as an appropriate area. Other areas where high build- Residential Character. ings might be acceptable in environmental quality terms, such as the low lying areas around the North Circular Road, are not identified in the Plan as appropriate locations for high density uses.

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6. SUSTAINABILITY: INTENSITY, MIXED BE10 HIGH BUILDINGS USES & SUSTAINABLE DESIGN

High Buildings (over 25m) are most appropriate where HIGHER-INTENSITY DEVELOPMENT their visual and other impact can be accommodated. Preferred locations are the Wembley Regeneration 3.7.43 Until recently, high density urban development has been associ- Area & the Park Royal Area (inset plans). Such propos- ated with poor quality environments and the numerous social als should: problems of the high-rise residential blocks. Increasingly however, the positive features of urban density and concentration of (a) Be of outstanding architectural and urban design quality, with a distinct profile and roofscape, prefer- uses has begun to be recognised as essential to successful ably emphasising a point of civic or visual signifi- urban areas. Indeed, providing the design is of sufficient quality, cance, or a centre of urban activity, transport inter- higher-intensity development produces some of the most sustain- change or regeneration; able of human habitats. Intensive urban uses allow people to live and work in close proximity, reducing car trips. In addition, they (b) Be set in the context of, and be carefully related to, encourage economic and social interactions leading to its surroundings, both existing and proposed, and to any other high buildings in the locality and to open widespread regeneration benefits. Environmentally, many of the space; most attractive and sought after urban areas in London, and more widely, are well-managed high-density neighbourhoods. In (c) Secure a complete and well designed setting of appropriate locations, therefore, it is important to use the intensity, lower buildings and/or landscaped open space, so or density, of development as a positive planning tool to reinforce that it interacts in a positive manner with, and contributes to, its surroundings at street level; the economic and social potential possessed by individual areas. This approach is also encouraged by more recent government (d) Avoid marring the skyline or intruding to the detri- policy guidance, and well-designed schemes will be welcomed. ment of local, medium and long-distance views of important landmarks (see Policy BE34); LOCATION & TYPES OF MIXED USES (e) Avoid a significantly harmful effect on the microcli- mate, and amenities of the area, through matters 3.7.44 Mixed-use developments enhance the quality of urban areas by such as turbulence, noise reflection or overshadow- ensuring a vital mix of uses, which enhance the richness of expe- ing; rience for those living or working there. Mixed uses can also aid (f) Demonstrate how the design contributes to sustain- community safety and contribute to other planning objectives ability objectives (see Policy BE12); such as the provision of housing and the achievement of vital and viable town centres, as well as a reduction in car use through (g) Avoid blocking important telecommunications channels, without mitigating measures; increased pedestrian activity. In fact, reducing the need to travel is another key benefit of developing a mix of land uses. The ben- (h) Take into account, in their design and location, rela- efits of having a mix of land uses at the neighbourhood scale are tionship to airports and air routes, drainage and that it enables people to walk or cycle to local facilities and may water channels, communication and transport links, even encourage people to live and work locally. In a neighbour- and industrial plant and chimneys; hood with a mix of uses not every building will have more than (i) Have regard, in their location, height and design on one use: quiet, single use residential streets still have a key role. their impact on the character (including setting) of Listed Buildings and Conservation Areas; and 3.7.45 This section indicates where and in what circumstances sites (j) Provide, where appropriate, a design statement should be developed with a mix of land uses, what additional (See Policy BE1) and a visual impact study including uses (e.g. 'secondary uses') should co-exist with the primary use, photomontages and maps of areas from which the and the main design considerations. The sites most suitable for building would be visible. development with a mix of uses in Brent are those where an existing mixed-use character can be built upon, as in town centres, or 3.7.42 High buildings can be an asset if well designed and properly where opportunities mean that they can be newly established. located. They should preferably be located where they mark a Selectivity is crucial because, as RPG3 notes, where a develop- gateway or transport interchange, terminate a key view or ment involving a mix of uses is located where it encourages emphasise a location of civic importance. They should be distinc- cross-commuting trips by car, the benefits of a mix are lost. The tive and memorable enough to act as orientation features within policies only apply where the plan does not already stipulate a the townscape, and clearly distinguishing and articulating their particular use or range of uses on a site. It therefore, does not roofscapes and street level podiums to visually break up their normally apply in Strategic & Borough Employment Areas overall height into 3 recognisable sections. For religious build- (SEA/BEAs), nor in Hospital and Higher/Further Education (HFE) ings, a flexible approach will be taken to the inclusion of spires, zones (which in any event are often partially self-contained devel- minarets, domes, etc. which can provide a visual focus to a developments with a mix of uses). The preferred locations are within opment and reflect its function and the visual diversity of the Areas of Very Good & Good Public Transport Accessibility (as Borough. defined in the Transport chapter, section 6.7).

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3.7.46 The primary use will depend on design considerations, such as the prominence of a use within the site, just as much as BE11 INTENSIVE AND MIXED-USE floorspace. Where public transport improvements in the form of DEVELOPMENTS significant additional facilities (such as additional access points or enlarged station facilities) are provided, these will also be consid- Proposals for higher densities than that prevalent in ered as a secondary use meeting the aims of the policy. Also the surrounding area will be encouraged in appropri- where large developments of a public or institutional nature con- ate locations, which will include town centre locations tain within them significant ancillary activities which reduce the in Areas of Very Good & Good Public Transport need to travel (e.g. gift shops and cafes) these can also be said to Accessibility (as defined in the Transport Chapter sec- satisfy the policy, providing the development as a whole completion 6.7), and transport interchanges (Policy TRN6). ments the mix of uses in the area. Proposals in these areas are encouraged to include a mix of compatible land uses. 3.7.47 It is recognised that the exact mix and proportion of uses will vary in different locations and that, in some circumstances, addition of Proposals in the above locations, or for a change of secondary uses(s) will not be practical; such as where it cannot use, that fail to incorporate an appropriate element of be physically achieved on the site because of the operational secondary use(s), where single uses would undermine needs of the primary user. The nature of a development, includ- the existing character or prejudice the regeneration ing the sub-categories within a use class, can also be considered prospects of an area, will be resisted, taking into as to whether a secondary use is required. The secondary use account: should be appropriate to the site's location e.g. a town centre (a) The scale and nature of the proposed development use open to visiting members of the public, in or adjoining shop- relative to the mix of land uses in the surrounding ping centres; or a priority use (Policy STR1). Occasionally, an area, and innovative secondary use may be proposed which complements the site and area so well that those uses listed above may not be (b) The feasibility of incorporating secondary use(s) given the nature of the primary use and the site required. The Council will use phasing or other conditions to characteristics. ensure secondary uses are implemented. Particular attention will be paid to the design of intensive and mixed-use developments, which should DESIGN OF HIGHER-INTENSITY & MIXED- achieve a satisfactory relationship between individual USES units and uses in terms of their layout, stacking, the adjoining area(s) between them, and protection of the 3.7.48 Careful design is necessary in higher-intensity and mixed-use amenity of adjoining and proposed residents. developments, to preserve the quality and amenity of individual units/users and because some combinations of uses are not as Uses open to visiting members of the public (such as compatible as others. The careful juxtaposition of uses will be shops and food and drink uses) should be located to crucial to the success of mixed-use schemes. Where the vertical have a significant ground floor window display and 'stacking' of uses is the most appropriate way of achieving a mix, entrance. the issue of the design and arrangement of uses is particularly important. The relationship between food and drink (A3) uses Residential accommodation (other than live-work) and residential uses requires special attention (See Policy SH10). should be functionally independent of commercial or Some uses require separate ground floor access to achieve the business uses and should be separately accessed at benefits of mixed use in terms of variety and pedestrian access. street level.

SUSTAINABLE DESIGN & CONSTRUCTION

3.7.49 Urban sustainability depends on the way towns and buildings are built, maintained and used. The DETR’s ‘Building a Better Quality of Life: A Strategy for More Sustainable Construction’ (2000) recognised that buildings contribute directly and indirectly to the consumption of energy and resources and to environmental pollution, affecting our activities, health and well being. Buildings designed and constructed sustainably are now recognised as likely to provide healthier and more comfortable conditions. However, although Sustainability Appraisals were required of Development Plans, this was not applied to development proposals, beyond Environmental Impact Assessments (EIA) for the largest, most important schemes. Regional Planning Guidance

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for the South East (RPG 9) 2001, also recognises that: “The 3.7.54 Developments involving passive or active solar installations may design of individual developments will be a major influence on the have Building Regulations implications, so advice should be extent to which they are sustainable...” (Para. 5.9). sought from Building Control. They may also require planning consent. Where proposed on listed buildings, in conservation 3.7.50 The environmental and social effects at each stage of modern areas or other sensitive settings, care should be taken to ensure building and development processes can include for example: no harm is caused to the character of such buildings or areas.

• Energy consumed from heating, lighting and ventilation of 3.7.55 Even at the local level, urban design interventions can help buildings; reduce the impact of air pollutants, and positively affect micro-cli- • Detrimental effects of winning raw materials (mining/quarry- matic conditions. When locating particular uses and features ing) on the environment; (play areas, sports fields, sitting areas used often or for long peri- • Adverse effects of many modern building materials and ser- ods by elderly and the sick, outdoor cafes, bus stops, building vice systems on people's health (e.g. sick building syn- entrances, windows, intake-vents), attention should be given to drome); their sensitivity to air pollution. Preventative or ameliorative mea- • Pollution from air-conditioning and heating systems used in sures should be adopted when these uses are to be located near buildings; places liable to suffer from high emissions (heavily trafficked • Waste generated during the demolition (90 million tonnes in streets and busy intersections, taxi stands, bus depots, tunnel or 1998), construction and operation of buildings. garage entrances, exhaust vents and locations upwind of polluting industries), as well as in designated Air Quality Management 3.7.51 The Council therefore expects applicants to consider sustainabili- Areas (see also Policy EP3 in chapter 4). ty issues from the early site-analysis and concept-design stages of their proposals, as well as throughout the detailed design and 3.7.56 Developers should pay special attention to sound insulation specification process. Attention from an early stage is crucial, as between converted dwellings (party walls and floors) and within schemes cannot be redeemed at the latter stages if the conceptu- mixed-use developments, as much higher insulation levels will be al design has not addressed sustainability issues. This is not needed at the boundaries between commercial and residential always a straight-forward process and nearly always involves units. some kind of environmental trade-off. 3.7.57 In the long term, improving built environment sustainability could bring social and economic as well as environmental benefits for example, potentially providing employment for many people through large-scale insulation, renovation and de-construction programmes. The Award-winning BRE Environmental Offices, Garston. 3.7.58 The Council has published Supplementary Planning Guidance on Source: Terence O’ Rourke ’Sustainable Design, Construction & Pollution Control', (SPG19) covering design for sustainable use of energy, water, building materials, site practices and pollution control measures (noise, land contamination and air quality). This is accompanied by a development control Checklist for developments meeting specific thresholds. A best practice Householders guide has also been published. These 3.7.52 The layout of new development can do much to promote energy will assist residents, designers and builders to save energy and conservation and hence reduce the emissions of greenhouse water, to reuse materials or choose sustainable materials for refur- gases by, for example, orientating buildings so that principal hab- bishment, extension and new build projects in the Borough, and to itable rooms face south, thus maximising passive solar gain. minimise nuisance and pollution during and after construction. Further information can be found in the DETR/DTI design guide 'Planning for Passive Solar Gain'. It is also important that servicing, refuse storage arrangements and landscaping are duly considered.

3.7.53 Buildings can also be orientated so as to minimise heat loss from prevailing winds. It is also important that new buildings do not disrupt local movement patterns or cause air turbulence problems, and applicants should demonstrate how it is intended to minimise or mitigate any adverse conditions. High buildings deserve special attention, as it is now widely acknowledged that they exert significant impacts (e.g. concentration of pollutants, sunlight 3.7.58 Applicants for strategic developments referable to the Mayor of reduction, wind deflection, energy consumption), making sustain- London, should also address the sustainable design, energy and ability an important consideration in assessing their acceptability other relevant policies set out in the draft London Plan, and its pro- at the local level. posed strategic best practice guide.

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features), there has undoubtedly been a significant level of suc- BE12 SUSTAINABLE DESIGN PRINCIPLES cess in maintaining, and in some areas even enhancing, the quality of their townscape and public realm. Proposals should embody sustainable design principles, commensurate with the scale and type of devel- 3.8.2 The Council's 'Urban Quality Survey' 1999, has revealed the very opment, including taking account of: considerable discrepancy that now exists between the quality of buildings and spaces within designated heritage areas, and the Sustainable Design predominantly poor environment in the other areas of the bor- (a) Incorporating built forms, technologies, orienta- ough. This serves as a clear indication of the importance and tion and layout that will contribute to reduced success of design and planning controls in securing a quality energy consumption (e.g. ventilation, heating/ environment. cooling, lighting) and associated emissions;

(b) Avoiding negative micro-climatic effects (e.g. wind AREAS OF LOW TOWNSCAPE OR PUBLIC turbulence, noise reflection); REALM QUALITY (c) The potential for the re-use of existing buildings 3.8.3 Beyond the designated heritage areas, there are contexts of vary- and materials and environmental effect of building ing quality, which require a comparable level of positive design materials used; policy and development control in order to effect a higher stan- (d) Making adequate, integrally-designed provision for dard of urban and building design. Priority design areas are the storage and recycling of waste; therefore being designated to facilitate targeted policy attention. The first of these are Areas of Low Townscape or Public Realm (e) The potential for the management or recycling of Quality indicated on Map BE1. Areas identified as being of low water; quality will be prioritised for townscape and public realm enhance- Sustainable Construction ments and innovative contemporary building design. Within these areas, in order to encourage their environmental regenera- (f) Methods to protect important flora, fauna and/or tion, planning standards (density, parking, etc.) may be more flex- topographical features during construction and to ibly applied, provided developments are of the highest design minimise disturbance to local amenity; quality. Other areas not identified on the map, are Areas of Medium-High Townscape and Public Realm Quality and, for pro- (g) Methods to maximise recycling and re-use, as well posals within them, the contextual criteria in Policies BE2 & BE9 as minimising waste during demolition and con- will be more strictly applied. struction;

Pollution Control

(h) Sustainable remediation of brownfield sites rede- BE13 AREAS OF LOW TOWNSCAPE OR veloped for sensitive uses, will be sought, and PUBLIC REALM QUALITY where contamination remains in-situ, a monitoring regime will need to be agreed; Particular regard will be had to the design and attractiveness of all development proposals in Areas of Low (i) Measures to minimise the impact of poor air quality Townscape or Public Realm Quality (See Map BE1). on sensitive users in Air Quality Management Areas (See Policy EP3); and Development proposals within these areas will be expected to: (j) Noise levels from traffic, trains (near railway lines) or other significant noise-generators. (a) Have an independence of form and design, make a positive design statement and show creative use of In assessing the sustainability of schemes under these materials; headings, regard will be had to the supplementary (b) Create, where appropriate, new compositions and planning guidance. points of interest, being disciplined, however, by the existing building lines and the overall scale of the area; and

3.8 PRIORITY AREAS FOR TOWNSCAPE (c) Have regard to any approved Enhancement & PUBLIC REALM ENHANCEMENT Strategy for the area and make a contribution towards its implementation (in terms of external works and landscaping), public realm enhancement URBAN QUALITY IN BRENT commensurate with the scale of the proposed development. 3.8.1 In recent years, planning in Brent as in many other Boroughs, has tended, to focus more attention and resources, on conserving the The Council will produce Townscape & Public Realm best of its built heritage. Whilst these efforts have not had a uni- Enhancement Strategies for Areas of Low Townscape form effect in all of Brent's designated conservation areas (in or Public Realm Quality. terms of preventing the erosion of some historical or architectural

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TRANSPORT CORRIDORS & GATEWAYS ROAD & RAIL CORRIDORS

GRAND UNION CANAL CORRIDOR 3.8.5 The continual upgrading of the Borough's image for visitors (including potential investors) and residents is an important pre- 3.8.4 The Grand Union Canal runs for approximately two miles through requisite for regenerating the local economy. For many visitors Brent. Throughout its length it represents an important recre- the lasting impression of places in Brent is gleaned as they travel ational and ecological resource. Although the character of the into and through the Borough. These corridors and gateways canalside environment can be poor, it offers great potential for also affect the quality of life of residents who use them on a daily quality waterside developments and the Council is intending to basis. Major transport corridors link places in Brent to the rest of conduct a canal corridor study in conjunction with British London and also divide the Borough into sectors. They therefore, Waterways to explore this potential further. Policy OS5 in often serve as important paths and districts in their own right. It is Chapter 5 considers development of the canal in relation to its important to define a 'beginning' and 'end' to corridors, in order to function as a green chain. Policy PR4 covers the canal in Park establish or enhance local character and identity, and create a Royal. The policy below also sets out the Council's requirements good impression. regarding the provision of moorings on the canal. Opportunities to create moorings may arise through the development process, 3.8.6 Public realm enhancements in designated corridors will be particularly in the major canalside redevelopment areas covered achieved through a combination of design and planning control in the Park Royal Chapter (Chapter 13). Non-residential moor- (negotiating improvements to proposals) and Council initiatives ings do not require planning permission but they can be regulated (planning and highway powers or other direct actions). The through planning obligations associated with canalside develop- Council will prepare urban design frameworks for these corridors ments. and development briefs for key sites along them, in order to: • Provide a better experience and first impression for visitors; • Guide, orientate and inform visitors about areas, attractions and facilities both along the route and in the main town centres before arrival; • Improve and/or reinforce the character and identity of parts of, or entire, corridor areas; • Ensure co-ordinated enhancement of their public realm; and • Promote the provision and use of public transport.

Transport corridors are indicated on Map BE2. The enhancement of Olympic Way within the stadium precinct, is covered by policies within the Wembley Regeneration Area Inset (Chapter 14). BE14 GRAND UNION CANAL CORRIDOR

Developments adjoining or visible from the Grand Union Canal Policy Area (as shown on the proposals map) should wherever possible:

(a) Be designed to benefit from and complement canalside settings through, where appropriate, development ‘facing’ the canal;

(b) Enhance or create views through and from the MAIN GATEWAYS development, from and towards the canal; (c) Provide landscaping and pedestrian routes to parts 3.8.7 Gateways can help provide an identifiable definition of these qual- of the development site adjoining the waterside; ities. In order to develop these gateways, a collaborative and co- (d) Conserve structures and features associated with ordinated urban design approach will be required for the purpos- the working life of the canal. es of: • Creating an enhanced sense of arrival and welcome; Development should not reduce the navigable area of • Creating a series of structures to serve as landmarks; the canal nor cantilever or bridge over the towing path • Identifying suitable levels of signage; or canal except for road, railway or footbridges. • Reflecting the enhancement strategies for individual corridors; Residential moorings will be permitted on the non- • Responding to development opportunities on adjacent sites; towpath side or in new basins or marinas and should • Enhancing the quality of the public realm. not interfere with navigation or other uses of the bank. Non-obtrusive servicing and infrastructure The main gateways are at major road junctions and are also should be provided. shown on Map BE2. The Park Royal North-Western Gateway is covered by policy PR6 within the Park Royal Inset (Chapter 13).

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BE15 TRANSPORT CORRIDORS & GATEWAYS (e) schemes of townscape improvement, particularly in the main shopping areas. Particular regard will be had to the design and attractiveness of all development proposals in the vicinity Priorities for small scale improvement schemes will be of, and visible from Transport Corridors. those which:

1) Will provide or improve greenspace in deficient The following road and rail corridors (See Map BE2) areas; or are priorities for Townscape and Public Realm enhancement during the Plan Period and where 2) Address severe localised pockets with poor environments outside the areas chosen for comprehen- opportunities arise, attractive views and important sive public realm improvement; or local landmarks should be opened up from these corridors: 3) Promote improvements suggested by the local community. 1. North Circular Road; 2. Harrow Road; 3. Kilburn High Road; 3.9 OTHER STRUCTURES 4. The Stadium Access Corridor; 5. From Fryent Way, Dudden Hill Lane & Willesden PLANT, VENTILATION & AIR-HANDLING High Road to Willesden Lane; EQUIPMENT 6. The Chiltern Line (between Sudbury & Willesden 3.9.1 This includes all building services equipment likely to have an Green stations); impact on the external environment. Generally, every effort 7. The Jubilee & Metropolitan line (between Wembley should be made to accommodate all plant, equipment and duct- Park & Willesden Green stations); and ing within existing buildings and structures, making use of all 8. The Euston West Coast Line (between Willesden internal voids and spaces, before considering external options. Junction & Wembley Central). All new buildings such as shops, restaurants, offices and industrial premises should include appropriately designed service ducts Urban Design Frameworks will be produced for each to provide unobtrusive ventilation, servicing and cabling. Where Corridor and for the Main Borough Gateways, to guide external ducting and pipework is unavoidable, flank or rear wall the form of development and ensure a co-ordinated locations are preferable, depending on their visibility and provided enhancement strategy. such equipment does not obscure windows, are not inserted within visually sensitive windows, or result in loss of daylight or outlook to neighbouring properties. Roof level equipment should not 3.8.8 Certain special policies for protecting and/or enhancing the public cause unacceptable damage to the character and appearance of realm in specific areas (e.g. Olympic Way) are set out in the Inset the proposed building, or those in the locality. Where acceptable, Plan chapters. The Council is also undertaking, in partnership it should be located in the least conspicuous position, include with other bodies, enhancement schemes in industrial estates, adequate screening and should be designed as an integral part of town centres and housing estates. These are covered in more the overall form and appearance of the building. Thought should detail in the relevant chapters of the plan. also be given to servicing and access requirements for all plant.

BE16 OTHER PUBLIC REALM INITIATIVES BE17 BUILDING-SERVICES EQUIPMENT

Public realm enhancements will be supported in the All air-cooling, heating, ventilation, extraction and parts of the borough with rundown and/or unattrac- conditional systems, as well as any ancillary plant, tive environments. Within these areas the following ducting and equipment likely to be visually intrusive, will be undertaken or supported: should in the first instance, be accommodated within the internal envelope of proposed buildings. (a) Schemes to introduce new, or improve existing, greenspace; Where this is not practicable they should be located in (b) Traffic calming and traffic management schemes visually inconspicuous positions, with a minimal effect to reduce conflicts between motor vehicles and on the use, character & appearance of proposed and pedestrians; nearby buildings, and local amenity. (c) Improvements to street furniture and street lighting; Where building services equipment cannot be satisfac- (d) Measures to improve industrial and commercial ser- torily relocated or ‘designed-out’ through the use of vicing; and passive systems, then it should be considered as part /... of an overall integrated architectural design.

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TELECOMMUNICATIONS EQUIPMENT Planning Guidance. Where satellite dishes require planning consent the Council will seek to minimise their often considerable 3.9.2 Telecommunications are a rapidly growing and increasingly visual impact. essential component of modern economic infrastructure. London's future will be increasingly dependent upon it being a 3.9.5 The Council will, with information from the Radio-communications hub of a world wide information network. Government advice on Agency and Radio Sites Databank, draw up a register of existing Telecommunications is given in PPG8 revised in 2001; this seeks masts and other structures (such as roof sited base stations), to to balance the need to foster the growth of telecommunications which new telecommunication apparatus could be attached. It is with the protection of amenity. It requires development plans to also recognised that the location of such equipment on residential be alive to the growth and characteristics of modern telecommu- tower blocks can give rise to radio and television interference. nications. PPG8 makes it clear that such interference is a material planning consideration when not covered by other legislation. Regard will 3.9.3 Most satellite dishes and other minor telecommunications devel- be had to the potential impact of development on those sites. opments do not require planning permission, being permitted Site-sharing, rather than mast sharing, may be more appropriate under the Town and Country Planning General Development in some cases for environmental or planning reasons. Technical Order (GPDO) 1995. Planning permission is required in or design factors may, in other instances, also indicate a new site Conservation Areas that are subject to Article 4 directions. The entirely. Particular attention will be given to screening and plant- Government proposed changes to the GPDO for satellite (not ing, and sites will need to be large enough to accommodate such mobile phone) and other antennas in 2003, but these have yet to landscaping. be finalised.

BE18 SATELLITE DISHES

Applications for satellite dishes should satisfy the following criteria, being:

(a) As small in size and as few in number as possible;

(b) Shared by as many users as is feasible;

(c) Located as unobtrusively as possible, usually on the rear elevation of buildings, and not visible above the apex of the roof;

(d) Located so as not to interfere with doors or windows of neighbouring properties; and

(e) Removed as soon as they become obsolete. 3.9.6 To protect visual amenity in sensitive areas, where it is deemed Satellite dishes will only be permitted on Listed preferable for mast development to be confined to one site, the Buildings, if it can be demonstrated that they would Council may, where practicable, encourage operators to enter not harm any features of special architectural or his- into a planning obligation with the relevant landowner to ensure toric interest which it possesses. the site remains available for sharing. Where a ground-based mast is to be erected within Brent's Conservation Areas or Sites In view of the need to preserve or enhance the charac- of Special Scientific Interest, the amendments to the regulations ter or appearance of conservation areas, they are have now introduced a requirement for operators to make 'An unlikely to be acceptable on the front elevations of application for the Planning Authority's determination concerning buildings within Conservation Areas. prior approval of siting and appearance'. This is also required before the installation of certain apparatus under permitted development rights. The Authority has a fixed 56-day period in which to 3.9.4 Quite different considerations apply to proposals by licensed determine whether or not 'prior approval' is required, and notify telecommunications operators. These run a national public ser- the operator of its decision. vice network with many systems operating on a line of sight basis requiring frequent base stations and relays. Preferably, such 3.9.7 It is a condition of the prior approval procedures that equipment equipment should be located on existing tall buildings but, when should be sited so as to minimise its effect on the external masts are to be used, the Council will expect the potential for appearance of any building on which it is installed. This will par- mast sharing to be explored fully in order to avoid their prolifera- ticularly apply in those sensitive areas listed in Policy BE19. If, in tion. Part 24 of the General Permitted Development Order 1995, the view of the Council, the equipment has not been so sited then dealing with telecommunications was amended in 1998 (SI it may require its re-siting. The installation of such apparatus on 2001). The amendments are explained in ‘Circular 4/99: Planning listed buildings will require listed building consent which, if this for Telecommunications' (July 1999). Advice on the siting of satel- damages the character of the building, will not be given. Factors lite dishes is available as part of the Council's Supplementary to be considered concerning the appearance of the mast and

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ancillary apparatus include materials, colour and design. The use ADVERTISEMENTS of appropriate materials and colour may help make a mast less obtrusive, and the planning authority will also consider the overall 3.9.9 As PPG19 (Outdoor Advertisement Control) emphasises, outdoor shape of the apparatus and effect of either a solid or open frame- advertising is essential to commercial activity, but advertisements work construction. tend by their nature to be prominent and can be unsuitable in some locations. They can, however, enliven drab surroundings, 3.9.8 The Government-commissioned Stewart Report (May 2000) from screen eyesores and sometimes may offer an opportunity to the Independent Expert Group on Mobile Phones, considered improve the environment, for example by including landscaping effects from their use and from associated technology. It conclud- on the site. The Council will assess advertisement schemes sole- ed "the balance of evidence indicates that there is no general risk ly by the statutory criteria of amenity and public safety. The poli- to the health of people living near to base stations on the basis cies below give an indication of the key amenity and safety issues that exposures are expected to be a small fraction of the guide- relevant in the Supplementary Planning Guidance on lines." It recommended a precautionary approach on the basis of Advertisements published by the Council. gaps in current scientific knowledge. The Government accepted this and requires all new facilities to meet guidelines by the International Commission on Non-Ironising Radiation Protection BE20 ADVERTISEMENT ON BUILDINGS (ICNIRP) set in accordance with the precautionary approach. Local authorities may not set their own unilateral moratoriums or Advertisements (including awnings) on buildings will limits on such development. only be approved when designed to be in keeping with the scale and character of the building, and surround- BE19 OTHER FORMS OF TELECOMMUNICA- ing area, and limited to avoid an excessive display. TIONS DEVELOPMENT Large signs on flank walls at a high level will not be approved. In considering applications for other forms of telecommunications apparatus, the following will be taken Shop signs should be confined to fascia level and no into account, in so far as is technically and legally fea- more than one small projecting box sign per frontage sible, whether: will normally be allowed (see also Policy SH21).

(a) The operator has explored the possibility of erecting antenna on existing buildings or other structures;

(b) The operator has explored the possibility of sharing an existing mast,replacing it with one suitable for joint use, or of erecting one suitable for joint use;

(c) So far as practicable, any mast and/or equipment is sited and designed so as to minimise their visual impact on the skyline and setting;

(d) Reasonable steps have been taken to ensure that the minimum number of pieces of apparatus are erected;

(e) Technologies to miniaturise and or camouflage equipment have been fully explored;

(f) The proposal includes a statement stipulating that the facility when operational will not exceed INCIRP guidelines for public exposure; and

(g) There is clear evidence that significant electromag- netic interference will arise, or will probably arise, and that no practical remedy is available.

The visual impact of telecommunications apparatus 3.9.10 Poorly located advertisement hoardings can be particularly obtru- will be minimised upon Listed Buildings, Areas Of sive and may in some cases pose a danger to traffic. It is there- Distinctive Residential Character and Metropolitan fore necessary to restrict the types of location where such hoard- Open Land. ings will be permitted. Supplementary guidance (SPG7) Shop- fronts & Shopsigns deals with shop advertisements & security Proposals to locate ground-based masts within features. Conservation Areas or Sites Of Special Scientific Interest, or in close proximity to schools or hospitals, 3.9.11 As explained in Supplementary Guidance (SPG8): Advertise- must be accompanied by adequate information for ments other than Shops, advertisement hoardings are only likely assessment and special justification for such a loca- to be acceptable if they enhance the appearance of an area. tion demonstrating that there are no alternative sites.

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Freestanding hoardings and hoardings on buildings must there- 3.10.2 The London Borough of Brent forms part of London's suburban fore satisfy the criteria within Policy BE21 and SPG8. The fringe and reflects a complex and varied mix of styles linking, and acceptability of other types of advertisement (on street furniture, sometimes obliterating, earlier village settlements. The develop- pole signs, etc) also depends on their ability to make a positive ment of the Metropolitan Railway from 1863 encouraged subur- contribution to the local environment and criteria are set out in the ban development, (as did the 1924-1925 British Empire Exhibition guidance document. at Wembley Park). Such was the intensity of inter-war development that, in the 1930s Middlesex was the fastest developing county in the country. BE21 ADVERTISEMENT HOARDINGS 3.10.3 The architectural styles of Brent therefore date from these peri- Advertisement hoardings and other freestanding ods. There is a wide range of architectural styles from the simple advertisements will only be approved where they to the ornate, from Victorian ltalianate and Gothic Revival to Sub- enhance the appearance of an area. Public realm urban 'Arts & Crafts' and planned "village" settlements. Such a enhancements, such as landscaping or public art, will diverse heritage is an essential part of the character of the be sought by a planning obligation, as part of adver- Borough. Furthermore, street scenes and leafy lanes, with their tisement hoarding schemes. They will not be trees and gardens, have matured in the course of sixty or so approved in the following areas: years to give a variety of residential environments, some of which are particularly attractive and worthy of preservation. (a) Predominantly residential areas;

(b) On or adjacent to conservation areas and listed buildings; LISTED BUILDINGS (c) On open space, or where they would block important views across it, or where they would obscure STATUTORY LISTED BUILDINGS other important views, landscaping or groups of trees; 3.10.4 In accordance with Section 1 of the Planning (Listed Buildings (d) Where it would lead to advertisement clutter, and Conservation Areas) Act 1990, the Secretary of State for detract from public realm enhancements within the Culture, Media and Sport is required to compile lists of buildings area and/or prejudice regeneration initiatives; of special architectural or historic interest, known as Statutory Lists. Appendix BE4 provides details of buildings in the Borough (e) On railway embankments; and that are included in the Statutory List. Further appropriate build- (f) On major roads and road junctions where distrac- ings will be recommended to the Secretary of State for Culture, tion to drivers could be prejudicial to highway safe- Media and Sport, for inclusion in the Statutory List. Buildings on ty. these lists are classified in Grades to show their nationally assessed importance:-

• GRADE I: These are buildings of exceptional interest: Brent has one such building; • GRADE II* (six in Brent); • GRADE II: These are buildings of special interest which are classified.

3.10.5 There is a general legal presumption in favour of the retention of listed buildings. The fact that a building is listed however, does not mean that no changes can be made to its appearance or its physical fabric: but it does mean that proposals for demolition (including alterations involving demolition of a material part) of a 3.10 URBAN CONSERVATION listed building, and for changes which affect its character as a building of special architectural or historic interest (and this BRENT'S HERITAGE includes objects or structures fixed to it or buildings in its grounds) must obtain 'listed building consent' from the Local Planning 3.10.1 The Council has as a key aim the need to enhance the architec- Authority. PPG15 provides advice on the identification and pro- tural heritage of the Borough. Conserving the best of the bor- tection of historic buildings and lists the tests that must be passed ough's built environment is of major importance and policies, for loss of a listed buildings to be acceptable. Listed building con- strategies and work programmes are designed to achieve just sent will only be granted in exceptional circumstances, when this this. There is a need to conserve the best of our built heritage meets the specific criteria of paragraphs 3.17-3.19 in PPG15 against pressure for redevelopment and unsympathetic alter- including: (a) the condition of the building(s), the feasibility of ation. This is achieved through considered application of both repair and maintenance in relation to its importance and contin- national and local policies.

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ued use value; (b) the adequacy of efforts made to retain the subject of a local list. Buildings on a local list enjoy no statutory building in use; and (c) exceptionally, the merits of alternative pro- protection but the compilation of the list by the Local Planning posals for the site. Authority provides a means whereby attention can be drawn to the particular character or importance of a building in the local 3.10.6 Compared with other London Boroughs, Brent has few notable streetscene when it is affected by some form of development pro- buildings. The Council is therefore particularly concerned that all posal. The Council first established such a list in December 1975. those buildings or groups of buildings of architectural or historic The Local List is kept under review. A list of the properties cur- interest that are on the Statutory List should be preserved and rently on the Local List can be found in Appendix BE3. enhanced. 3.10.8 Where a locally listed building is within a Conservation Area, policies BE25-27 apply. The Council will wish to give full considera- BE22 PROTECTION OF STATUTORY LISTED tion to the justification for the redevelopment of any building on BUILDINGS the local list affected by development proposals. The Council will expect to see clear and convincing evidence that all reasonable The demolition or unsympathetic alteration of build- efforts have been made to sustain existing uses or find new uses, ings (including interiors and parts of buildings) on the and these efforts have failed; that preservation in some form of Statutory List will be strongly resisted. charitable or community ownership is not possible or suitable or that redevelopment would produce substantial benefits for the Applications for planning permission and/or Listed local community which would decisively outweigh the loss result- Building Consent affecting the extension, future use, ing from demolition. The Council would not expect to give con- or appearance of a Listed Building shall have special sent for redevelopment simply because this is more economically regard to the desirability of preserving its special attractive to the developer than repair and re-use or because the character. developer acquired the building at a price that reflected the potential for redevelopment rather than the condition and constraints of the existing building.

BE23 SETTING OF LISTED BUILDINGS BE24 LOCALLY LISTED BUILDINGS

Development which would adversely affect the setting The special character of buildings on the local list will of a listed building, will not be permitted. be protected and enhanced. Proposals for the demolition or unsympathetic alteration of locally listed buildings (including parts of buildings) will be discouraged unless alternative use of the building is unviable or the planning benefits for the community substantially outweigh the loss resulting from demolition.

LISTED BUILDINGS 'AT RISK'

3.10.9 English Heritage maintains a register of statutory listed buildings that are 'at risk' through neglect and decay, or vulnerable to becoming so. Very few buildings were on this register in 1999, but it included the Grade I Old St Andrews Church, which has been vulnerable to vandalism, and the derelict Palace of Arts and Dollis Hill House (both have now been removed from the Listed Building Schedule). Brent is preparing action plans for Listed Buildings at risk. The plan contains site specific proposals for all buildings on the list lacking a beneficial use. Where possible, the Council will endeavour to work with individual owners to restore and rehabilitate Listed Buildings at risk. However, where it is deemed necessary, the Council will not hesitate to invoke its pow- LOCALLY LISTED BUILDINGS ers under Section 48 and 54 of the 1990 Listed Buildings and 3.10.7 In addition to those buildings found to have exceptional or special Conservation Act to serve 'Urgent Works Notices' and 'Building architectural or historic interest on a national scale, there are Repair Notices'. other buildings of particular importance locally but which do not quite meet the listing criteria set down by the Department of Culture, Media and Sport. Such buildings to be held in 'guardian- ship' by the Council in lieu of changing listing criteria, form the

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CONSERVATION AREAS 3.10.12 In 1999/2000 Brent carried out a comprehensive review of its heritage assets. This has enabled a consistent approach whereby 3.10.10 Conservation Areas are "areas of special architectural or historic the best areas, representative of certain key forms of develop- interest, the character or appearance of which it is desirable to ment (e.g. architect designed garden suburbs), are designated. preserve or enhance". The Unitary Development Plan applies The review had the aim of ensuring a more consistent basis of national policies and guidance to the specific and particular needs designation and that those features and areas that deserved to of the Borough. Conservation Areas are identified on the be conserved had manageable and justifiable controls in place. Proposals Map and their addresses are to be found in Appendix BE1. The number and extent of Conservation Areas will be kept 3.10.13 There are 22 Conservation Areas in Brent. They range enor- under review. More detailed policies are presented as mously in character, from the stucco Victorian Villas of South Supplementary Planning Guidance, Conservation Area Design Kilburn to the thatched cottages of Buck Lane. The Council's first Guides, rather than included in the plan itself. Conservation Area was designated at Roe Green Village in 1968. The Borough is particularly blessed with attractive and unusual suburban estates, such as Sudbury Court, Mount Stewart and Northwick Circle, built during the expansion of London in the '20s and '30s. From an earlier period, attractive Victorian estates are protected in areas such as Mapesbury and Queens Park.

3.10.14 Designation is just the beginning of the conservation process. Conservation will only have a firm basis where the features that define the character of conservation areas are identified by a survey and analysis of the architecture and history and enhancement opportunities of an area. On this basis character summaries have been published for most conservation areas. These contain a brief historical description of landscape and townscape elements, identification of characteristic, historic and architectural elements worthy of preservation or enhancement, and a brief justification of the boundary locations. These character appraisals are also very important for development control management.

3.10.15 Designation enables the Council to exercise control over the demolition of buildings and the loss of trees. In addition there are other controls set out in the Town and Country Planning General Permitted Development Order restricting 'permitted development' rights (Article 4{1} see Glossary). Following on from the character statements the Council is undertaking a process of conservation CONSERVATION AREA STRATEGY AND area management. This examines how these controls are being, MANAGEMENT and should be, implemented. Depending on the qualities and 3.10.11 There is no standard specification as to what constitutes a merits of each Conservation Area, the safeguards provided by the Conservation Area and they will naturally be of many different General Permitted Development Order may not be adequate to kinds. The Council has a duty to decide which parts of the retain the character of the area and a degree of 'fine tuning' Borough should be designated as Conservation Areas and to through an Article 4 Direction (which confers additional powers of keep the question of designating further areas under review. control: see Glossary) may be issued where justified. Areas cur- Conservation areas have been designated in the past when they rently covered by directions are shown on Map BE3 were under threat or under local pressure. Therefore, the date of designation is in no way representative of the relative quality of the area.

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3.10.16 The public has a right to expect clear guidance on how planning controls will be exercised in conservation areas, especially when special controls are introduced. Successful conservation depends on a positive approach by the Council and the interest and co-operation of the public. For this reason the Council is committed to the preparation of Conservation Area design guides. These comprise special policies for each Conservation Area, issued as supplementary planning guidance, giving clear guidance on what applications will and will not be approved. They will be the subject of detailed consultation with local residents. Design guides have already been published for 10 conservation areas. Schemes in a Conservation Area cannot be assessed without reference to how the details of the scheme relate to the surrounding area: hence, 'outline' applications are not acceptable in these circumstances. ALTERATIONS & EXTENSIONS TO BUILDINGS CONSERVATION-LED REGENERATION IN CONSERVATION AREAS

3.10.17 Restoring and finding beneficial uses to historic buildings is a key 3.10.18 The main threat to most of Brent's conservation areas is not the component of the Borough's strategies for regeneration. This threatened loss of buildings but the gradual erosion and alteration makes best use of existing resources and can transform the of individual elevational features, that together, give the conserva- image of an area. Brent is working with English Heritage to tion areas their special character. This is particularly the case ensure that best use is made of the listed buildings in Wembley, with rendering/painting, roofing replacements, and replacement mainly the Arena (surviving buildings from the British Empire of original windows. In all cases the presumption will be in favour Exhibition have now been removed from the Statutory List), in the of retention of original materials, which are often hard to replace. regeneration proposals for Wembley, but only in exceptional For example carefully maintained box sash windows can last for cases would this approach be appropriate (see policy WEM22). generations and can be supplemented by internal secondary glazing. It is recognised however that in many cases replacements will be necessary. It is the appearance of the replacement BE25 DEVELOPMENT IN CONSERVATION AREAS which is relevant rather than the construction methods or materials, but some materials, such as UVPC windows, will require par- Development proposals and new uses in Conservation ticularly careful design to mimic the originals, and 'off the peg' Areas, or outside them but affecting their setting or designs will not be appropriate. The Council has published a views into or out of the area, shall pay special atten- Window Design Guide. tion to the preservation or enhancement of the character or appearance of the area. BE26 ALTERATIONS & EXTENSIONS TO New development and enhancement proposals in BUILDINGS IN CONSERVATION AREAS Conservation Areas shall have particular regard to any specific design policies as may be prepared by the Alterations to elevations of buildings in conservation council, in co-operation with the local community, to areas, including window designs and shopfronts ensure that the scale and form of new developments should (as far as this is practicable) retain the original consistent with the preservation or enhancement of design and materials, or where not practical be sym- the character or appearance of the area. pathetic to the original design in terms of dimensions, texture and appearance, having regard to any design To protect the overall prevailing character of buildings guidance issued by the planning authority. and frontages in Conservation Areas from unsympathetic alterations, the council will declare directions Characteristic features such as doors, canopies, win- under article 4 (2) of the General Permitted dows, roof details (e.g. chimneys, chimney pots, roof Development Order to control certain types of 'permit- line and pitch) and party wall upstands should be ted development', after due public consultation. retained, even when these elements may be redundant. Applications for development in Conservation Areas will not be accepted in 'outline' form only. Extensions to buildings in conservation areas should not alter the scale or roofline of the building detrimental to the unity or character of the conservation area and should be complementary to the original building in elevational features.

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DEMOLITION & GAP SITES IN CONSERVATION AREAS BE28 OPEN SPACE IN CONSERVATION AREAS

3.10.19 Conservation Areas have special protection in that most works of Landscaped areas, gardens, trees, hedges and bound- demolition require a particular form of consent (Conservation ary treatments, should be retained where they form Area Consent). The Council will use this power to control unnec- an integral part of the character or appearance of essary demolition of buildings. It should be noted that 'building' is Conservation Area. also defined by statute as part of a building. The provision of additional planting to enhance street 3.10.20 Where demolition is proposed to be accompanied by redevelop- scenes is encouraged. ment then planning permission for this will normally be required. The Council will require this to be a full planning application rather than an outline, to show what is to be substituted. In the past AREAS OF DISTINCTIVE RESIDENTIAL demolition in Conservation Areas without new development has CHARACTER left detrimental gap sites, this will be resisted. 3.10.22 Although the Borough has many residential areas with a pleasant character, there are a number of well-established residential estates which possess readily identifiable and distinctive characteristics and a high standard of residential amenity which would be particularly threatened by unsympathetic development. Their coherent design and pleasant setting warrant designation as Areas of Distinctive Residential Character (ADRC) so that a more co-ordinated approach to design control may be achieved. This is not to suggest that other areas are not of merit, only that the forms of development which the planning system has powers to control present a particular danger to the character of those areas designated as ADRC's. In addition to the normal design and housing policies, and their associated standards, particular considerations apply in the areas designated in Policy BE29. ADRC's are identified on the Proposals Map and the properties affected are listed in Appendix BE3.

BE27 DEMOLITION & GAP SITES IN BE29 AREAS OF DISTINCTIVE RESIDENTIAL CONSERVATION AREAS CHARACTER

Consent will not be given for the demolition of a In Areas Of Distinctive Residential Character, as building, or alteration involving demolition of part of a shown on the Proposals Map, particular attention will building, in a conservation area unless the building, or be paid to the design, height and space between build- part of the building, positively detracts from the char- ings in order to protect their individual qualities and acter or appearance of the Conservation Area. character.

Where demolition in a Conservation Area is acceptable and this would form a gap site, then a full planning application will be required to accompany the applica- ENABLING DEVELOPMENT AND THE ONSERVATION OF ERITAGE SSETS tion for Conservation Area Consent, showing details of C H A what is to be substituted. 3.10.23 Many planning decisions affect the integrity of elements of the historic environment, heritage assets (heritage asset is used in Replacement buildings should be seen as a stimulus to the policy as shorthand for archaeological remains and ancient imaginative, high quality design and an opportunity to monuments, listed buildings and conservation areas). On occa- enhance the area. sion development is proposed contrary to normal planning policy, in order to finance a secure future of the asset itself, such as res- cuing it from dereliction, this is known as 'enabling development'. OPEN SPACE IN CONSERVATION AREAS These are not decisions to be taken lightly and policies for this 3.10.21 An essential element of the Borough's Conservation Areas is the are required by PPG15. The policy below sets down the strict landscaping and garden areas within them. These have taken tests proposed by English Heritage, to ensure that the balance of many years to mature and must be treated with respect by new public advantage is in favour of securing the future of the heritage developments if the character of these areas is not to be harmed. asset.

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3.10.24 If it is decided that a proposal meets the criteria below then the (which may include excavation) and record. These principles are benefits will need to be defined and secured. To ensure that the embodied in the Office of the Deputy Prime Minister’s Planning impact of the development is precisely defined at the outset this Policy Guidance Note on Archaeology (PPG16). would normally be through the granting of full rather than outline planning permission. The achievement of the heritage objective 3.10.26 In 1988, the Council adopted a comprehensive policy which iden- should be securely and enforceably linked to it through a planning tified a number of archaeological sites of interest and endorsed obligation. The heritage asset should be repaired to an agreed the Code of Practice on archaeological rescue work agreed standard, or the funds made available to do so, as early as possi- between the British Property Federation and the Standing ble in the course of the enabling development, ideally at the out- Conference of Archaeological Unit Managers. The support of all set and certainly before completion or occupation. The planning interested parties will be sought. authority will closely monitor implementation. 3.10.27 Where development may affect land of archaeological importance, the Council expects a preliminary site evaluation to take BE30 ENABLING DEVELOPMENT & HERITAGE place. This requirement applies both to 'Archaeological Priority ASSET CONSERVATION Areas' which are known, or to likely sites of prehistoric settlement and to 'Sites of Archaeological Importance' where there have Enabling development to secure the future of heritage been important or concentrated finds in the past. Archaeological assets will only be acceptable where all of the follow- sites should be properly investigated and excavated by a recog- ing are met: nised archaeological organisation such as, the Institute of Field Archaeologists (IFA) before development takes place. In appro- (a) The enabling development will not materially detract from the archaeological, architectural, his- priate cases, the most important archaeological remains and their toric or landscape interest, or materially harm its settings should be permanently preserved. Interpretation and setting; presentation to the public is a key part of this process. The Council will therefore seek provision for the analysis and public (b) The proposal avoids the fragmentation of manage- display of finds. Sites of Archaeological Importance and ment of the heritage asset; Archaeological Priority Areas are listed in Appendix BE5. (c) The enabling development will secure the long term Archaeological Priority Areas are also shown on the Proposals future of the heritage asset, and where applicable, Map. Further information on archaeological sites is contained in its continued use for a sympathetic purpose; the publication 'Archaeology in Brent'. (d) The problem arises from the inherent needs of the heritage asset, rather than the circumstances of the 3.10.28 A computerised and mapped databank is provided by the Greater present owner or the purchase price paid; London Sites and Monuments Record operated by English (e) Financial assistance is not available from any other Heritage. source;

(f) It is demonstrated that the amount of enabling BE31 SITES OF ARCHAEOLOGICAL INTEREST development is the minimum necessary to secure the future of the heritage asset, and that its form For developments involving groundwork on Sites Of minimises dis-benefits; and Archaeological Importance or in Archaeological (g) The value or benefit of the survival or enhancement Priority Areas, the following is required: of the heritage asset outweighs the long-term cost to the community (i.e. the dis-benefits) of providing (a) That applicants have the archaeological implica- the enabling development. tions of their proposals assessed by means of a recognised archaeological group (if necessary by a preliminary site investigation);

SITES OF ARCHAEOLOGICAL (b) Nationally important archaeological remains and INTEREST their settings are permanently preserved in situ, and where practicable, made available for public 3.10.25 Archaeological remains constitute the principal surviving evi- display and access; dence of the Borough's past but are a finite and fragile resource that is vulnerable to modern development and land use. Once (c) For archaeological remains of regional importance, the desirability of this will be weighed against other removed, that part of the Borough's past is lost forever. The factors such as the need for the proposed develop- Council considers that the archaeology of the Borough is a com- ment; munity asset as an educational, recreational and tourist resource: its preservation is a legitimate objective, against which the needs (d) Otherwise provision is made so that sites are prop- of development must be balanced and assessed. The destruc- erly investigated and excavated before develop- tion of such remains should be avoided wherever possible and ment begins; and should never take place without prior archaeological assessment, (e) Landowners and developers work in accordance with the British archaeologists' and developers' code of practice.

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MONUMENTS AND EARTHWORKS open spaces in sound condition. It will treat, or at a last resort following the undertaking of a risk assessment, remove trees which 3.10.29 There are no scheduled Ancient Monuments in the Borough but become dangerous or which damage buildings. The Council will there are structures and earthworks of local interest which the undertake a planting and replacement programme to ensure a Council intends to safeguard. continuity and increase of tree and shrub cover throughout the Borough, particularly in areas with a poor existing cover and those areas identified with open space deficiency and nature con- BE32 MONUMENTS AND EARTHWORKS servation deficiency. Wherever possible, the Council will take the opportunity to plant native species including forest type trees, and The fabric and setting are protected of the following will seek out sites suitable for an urban forestry programme. The four Ancient Monuments of local importance: Council recognises the importance of highway trees in forming a strategic link for wildlife between natural green spaces. It will also (a) Medieval ditch and embankment, Old Church Lane, Kingsbury; encourage private individuals, bodies, the business sector and industry to plant trees and shrubs. (b) Sarsen Stone, Slough Lane, Kingsbury;

The Council will continue to make tree preservation orders to protect trees of high amenity value, particu- TREES AND TREE PRESERVATION larly where trees are at risk from development. The removal of protected trees will only be permitted 3.10.30 The Council recognises the contribution that trees can make to where all of the following criteria are met: the character and amenity of an area and that there is a need to (a) There is a high level of tree coverage in the locality; preserve, maintain and, where appropriate, replace existing trees. Trees bring many benefits beyond their obvious landscape (b) The protected trees do not provide the functions of and amenity value: screening or separation; (c) Replacement trees, of suitable maturity and protec- • They are the principal agent for removing carbon dioxide, one tion, and of potentially equal value are provided of the 'Greenhouse Gases', from the atmosphere and are a within or outside the site, e.g. as roadside planting; major net producer of oxygen; and • Evidence from the National Urban Forestry Unit in 1998 (d) The protected trees are not of exceptional land- shows that urban trees have "… positive impact on the inci- scape value. dence of Asthma, skin cancer and stress-related illnesses by filtering polluted air, reducing smog formation and shading out solar radiation..."; • Trees bring natural elements and wildlife habitats into urban surroundings, all of which increase the quality of life for residents of the local community - International Society of Arboriculture (ISA); • Trees intercept water, store some of it, lessen stormwater run-off and reduce the possibility of flooding; • Trees also have a role to play in noise reduction; • At a local level, trees filter dust from the air, counteract pollution, provide shade in summer, reduce wind speed and sup- VIEWS AND LANDMARKS port urban bird species. 3.10.32 Because of the undulating nature of the Borough there are many Trees of high amenity value on private land can be protected by fine views of nearby open spaces, groups of trees, significant Tree Preservation Orders under the Town and Country Planning buildings and other features. These landmarks and the views to Acts. A programme for the preparation of new orders and updat- them are a valuable amenity to the Borough and need to be con- ing former orders is underway. sidered and protected when new developments are proposed that may affect them. Views of Wembley Stadium, and of St. 3.10.31 Brent is responsible for planting and maintaining trees on the Mary's Church, Harrow-on-the-Hill are considered to be particu- highways, including pavements, roadside open spaces, traffic larly important views worthy of protection. A general indication of islands and shopping centres. The Council recognises the vital these views is shown on Map BE4. Detailed maps of the viewing role that trees have in the Borough and will promote and maintain corridors for these views will be produced by the Council as a healthy, vibrant street scene. The Council will endeavour to Supplementary Design Guidance. These views are in addition to improve the quality and coverage of trees, shrubs and woodlands views across the areas of open character set out in Policy OS4 in throughout the Borough and maintain trees in streets and public Chapter 10.

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APPENDIX BE1: SCHEDULE OF PROPER- BE34 VIEWS & LANDMARKS TIES IN CONSERVATION AREAS

In co-operation with other London Boroughs, the (A) Remnants Of Former Villages Now Surrounded By Planning Authority will, in assessing development pro- Urbanisation posals, have regard to any impact on views of those Local Landmarks and from those Local Viewpoints that 1. SUDBURY COTTAGES are set out in Appendix BE5. Particular regard will be (Designated in January 1993) had to the impact of development proposals on the listed views of the important landmarks of:- A satellite settlement of Sudbury once on the edge of Sudbury Common. A small group of eighteenth and nineteenth century cottages survives at the junction of 1. St. Mary's Church, Harrow-on-the-Hill; and medieval lanes in an otherwise suburban setting. 2. Wembley Stadium (See Policy WEM19). Assessment of impact will include that on the back- Elms Lane 114,116 drop and setting of these views. Sudbury Court Road 96-110

2. WEMBLEY HIGH STREET (Designated in March 1990)

The original hamlet of Wembley but the properties were rebuilt about 1880. Not to be confused with Wembley High Road.

Dagmar Avenue Green Man P.H. High Street 3-12 (consec.) and Land adj. Wembley Hill Road 119-125, 131-135 Manor Court 1-4 (consec.)

(B) Attractive Estates Of Victorian/Edwardian Houses, Townhouses And Villas

3. BRONDESBURY (Designated in March 1990)

The Conservation Area represents a slice through Victorian suburban development in the period 1872-1899 townhouses of decorative and attractive designs for the emerging middle classes.

Cavendish Road 5-27, 4-24 Chatsworth Road 32 Christchurch Avenue 37-53, 34-50 and adj. land R/O 41-51 Mapesbury Road 1-15, 2-8, 12-16, Thanet Lodge Mowbray Road 1-45, 2-14

4. KILBURN

(Designated in January 1993) Designers include: Solomon Barnett, George German, AC Hendry Watkin and GH Wickes

Part of the Brondesbury Estate which was developed in four different periods between 1850 and 1899. The pedimented doorways in Brondesbury Road (by Wickes) and Watkin's terracotta work are particular features. The Victorian architecture is attractively varied.

Brondesbury Road 25-107, 2-116 Brondesbury Villas 1-109 and land adj, 2-146 and land adj., Honiton Road 1-36 (consec.) Lynton Road 1-38 (consec.)

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5. MAPESBURY Design Guide and direction in force. (Designated in December 1982) Brooksville Avenue Salusbury House, Wimborne House, 1-31, 2C-40 Builders include:- Charles Cheshir, John Neal and Company, Callow and Wright, Carlisle Road 1-47, 2-34 CWB Simmonds, GAC Bridge Chamberlayne Road Kensal Rise Primary School Chevening Road 1-75, 77-195, 2-74*, 6-122, Vicarage, The Stone Hall One of the largest of the Conservation Areas in Brent which comprises a mostly Creighton Road 1-37, 2-38 unaltered town-house development of 1895-1905. Parts of the estate, however, Dudley Road 1-15, 2-12 date from the late 1870s and other streets from 1920. The attractive brick houses Dunmore Road 1-5 (consec.) with their pleasing detailing are set in a well-treed street scene of low front boundary Harvist Road 13-71, 71A, 73-193, 195-265*, 6-70, 72-116* brick walls and tall square entrance pillars. Hopefield Avenue 1-43, 2-44 Kempe Road 1-47, 29-97, 2-46 , 48-130 Design Guide and Direction in force. Keslake Road 1-41, 43-125*, 2-40, 42-114 Kingswood Avenue 1-45 (consec.), Park Lodge Anson Road 3-61, 2-48, Anson Hall Milman Road 1-47 (consec.) Chichele Road 85-99, Alexandra Mansions and Doral Court Montrose Avenue 1-43, 2-44 Dartmouth Road 1-153, 2A,2-118 Westly Crt. Peploe Road 1-15 Dawlish Road 1-4 consec, out-building Radnor Road 1-11, 2-12 Exeter Road Byron Court, 1A, 3A, 1-87, 2A, 2-48, Exeter Mansions, St Laurence's Close 1-25 (consec.) Mondesfield and Nigel Court Summerfield Avenue 1-43, 2-40 Hoveden Road 1-35, 2-18 Tiverton Road 2 Keyes Road 1-37, 6-50 Windermere Avenue 1-43, 2-44 Lydford Road 10-22 Mapesbury Road Teignmouth Crt, 17-45, 22-50 8. SOUTH KILBURN Petrie Close 1-12 (Designated in February 1979) St. Gabriel's Road 1-97, 2-64 Builder: James Bailey Teignmouth Road Teignmouth Lodge, 1-89, 4-114 Walm Lane 129-197, 110-226, St. Gabriel's Church Part of the Kilburn Park estate of stucco and stock brick villas dating from 1861- 1873, many of which are listed. They display ornate architectural designs of 6. NORTH KILBURN Italianate origin which the builder took from pattern books of the period. (Designated March 1994) Most of the properties are listed . Architects: William J Watts, George German, W.A. Prior Kilburn Park Stn. The Waterloo Estate built between 1886 and 1896 by several builders; fine orna- Cambridge Avenue 2-56 mental movement terraces on Torbay and adjoining roads contrast with Gothic town Cambridge Gardens 1-25 Consec. houses on Dyne Road and ornate three storey houses on the streets off Kilburn Cambridge Road 61-63 High Road. Canterbury Road 111 Chichester Road Chichester House, 55, 2-14, 50-60 Design Guide and Direction in force. Kilburn High Road 41-61 Manor Mews Buckley Road 1-59, 2-48 Oxford Road 2-52 Burton Road 1-31, 2-32 Princess Road 9-67, 22-84 Callcott Road 1-81, 2-54 Clarence Road 1-19, 2-10 Dunster Gardens 1-23, 2-44 (C) Workers Cottage Estates Dyne Road 1-93, 10-82 Plympton Avenue 1-25, 2-26 9. NEASDEN VILLAGE Plympton Road 1-45, 2-64 (Designated in November 1987) Streatley Road 1-51, 2-48 Torbay Road 1a-91, 2-78 This is a village estate of two-storey stock brick terraced houses built in 1882-83 and Willesden Lane 144-160 1904-5 to house workers of the Metropolitan railway and power company. The grid iron street pattern is now providing the setting for a high quality cottage development 7. QUEEN'S PARK by Paddington Churches Housing Association. (Designated in July 1986) Design Guide and Direction in force. (N.B although the direction only covers part of Attractive late Victorian and Edwardian houses (1895-1905) complement the char- the conservation area permitted development rights are removed for the remainder acter of a 30-acre park, opened in 1887. The surrounding streets of mixed pleasant of the conservation area through a planning condition). design provide a "frame" defining and enhancing the park itself.

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Aylesbury Street 1-77, 2-78 Willesden Green Baptist Church, The Spotted Dog, Chesham Street 1-51, 2-20 Stevens Cottages Neasden Lane North Brill House, Chalfont House, 391-409 Huddlestone Road Huddlestone Hall Quainton Street 1-103, 2-84 Linacre Road 41 Verney Street 1-77, 2-78 St Andrews Rd Vicarage, Social Services Offices Walm Lane 1a-47, 58-92 , Willesden Green Station and 1-24 Rutland (D) Historic Cemeteries And Properties Associated With Them Park Mansions Willesden Grn Stn Parade 10. KENSAL GREEN 1,3,5 (Designated in March 1990) Willesden Lane Electric House, 275-293, Presbyterian Church of Wales, 1- 9 Queens Parade, 265-273, This includes a grouping of listed Georgian properties, the earliest being about 1820 but the majority dating from the opening of the cemetery (1832) which lies opposite. (F) Areas Associated With The Architect E G Trobridge Harrow Road 776-864 14. BUCK LANE, KINGSBURY 11.PADDINGTON CEMETERY (Designated in February 1979) (Designated in January 1993) Cemetery by Thomas Little (1855) for London Cemeteries Company. Ash Tree Dell 1-51, 2-64 Buck Lane 1-45, 2-48, 86-104, Upminster House, Highfort Court, The Cemetery and its listed chapels and ornate buildings in Willesden Lane (includ- Stonegate Court, The Triangle ing James Brooks' school) form an important Victorian group. Hay Lane 56-68 Hayland Close 1-21 (Consec.) Cemetery including entrance lodges in Willesden Lane. Highfield Avenue 46-66, Mountaire Court, Shirley Court, Tudor Gates Willesden Lane 134-136, 138/ Christchurch, Pear Close 1-18 (Consec.) Brondesbury School Wakemans Hill Ave. Rochester Court, Whitecastle Mansions The Prince of Wales PH 15. ST ANDREWS (E) Well-preserved Victorian Town Centres (Designated in December 1983; extended January 1993)

12. HARLESDEN Attractive street with mock-Tudor buildings by Simmonds, one of the Mapesbury (Designated in March 1994) Area architects, and fanciful brick flats with exquisite detailing by Trobridge similar to his Buck Lane style. Also included is a 13th Century church (Grade I listed building) Attractive grouping of victorian parades focussed around Jubilee Clock. Contains a with medieval ditch and embankment. The Conservation Area, which includes a cul- number of listed buildings, All Souls Church (E.J.Tarver) and The Green Man Public de-sac of bungalows by P. Rains (1927) and flats of the Kingsbury Park estate by House and adjoining terrace (Harrison and Ward) are of note. Samuel Yeo (1937) is centred on the "new" church of St Andrews (grade II*), a striking church of major importance by Daukes, transferred from the West End to this Design guide in force. site in 1933-34.

High Street 1-85, 2-104, 97-109, The Royal Oak PH and The Green Birchen Grove 49-51 Man PH Church Lane St. Andrew's New Church, Church Hall and Vicarage Station Road All Souls Church and Vicarage Church Walk 1-12, 14-16 Wendover Road Post Office Leith Close 2-32, 1-35 Manor Parade 1-18 Old Church Lane 1-29, 6-28, 40-44,1-4 Orchard Lodge, St Andrew's Old Acton Lane Church and Presbytery of Our Lady ofWilleseden Church and Cemetery, The Lodge, rear of Old St. The Croft 1 Andrews Church Tavistock Road Methodist Church St Andrews Rd 1-23, 2-24, Hazledene Tudor Gardens 1-5, 2-2a 12. WILLESDEN GREEN Tudor Close 1-26 (consec.), Tudor Lodge, Sandon (Designated in January 1993) Wells Drive 1-31, 2-32

AVictorian commercial centre with buildings of note by several well-known archi- (G) Architect designed Garden Suburbs tects: James Brooks, Newman and Newman and Gabriel contributed St Andrews Church, the library and the bank premises respectively. Sexton's Spotted Dog 16. HOMESTEAD PARK (1881) and Clark's faience-tiled Met. Station of 1924 are worthy of note. (Designated in January 1993) Designer: William E Sanders Heathfield Park 1-41, 2-10, Synagogue High Road 1-151, 2-108, St Andrew's Church, former Library,

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An unusual cluster of twenty cottages this, arranged in triplets (1926). The *indicates addresses not covered by the direction. hedgerows are an outstanding feature of the layout. 19. MOUNT STEWART Direction and special policy in force. (Designated in January 1993) Builders: F & C Costin Homestead Park 1-23 and 2-18 Part of the John Lyon Farm Estate developed by the Costins using their pattern 17. ROE GREEN VILLAGE book of high quality mock-Tudor designs. There is an extensive range of bay win- (Designated in November 1968) dows, leaded lights and brickwork and a high standard of joinery. Architect: Sir Frank Baines Design Guide and Direction in force. An estate of two-storey cottages built in 1918-1920 by the Government's Office of Works in a Garden Village style. The mixed use of materials - bricks and render, Abercorn Gardens 21-27 tiles and slates - and details of design, including rainwater goods, chimneys, and Bouverie Gardens 1-19, 2-22 cottage windows create an attractive village scene. Carlisle Gardens 1, 2-8 Grenfell Gardens 1-17, 2-18 Design guide and Direction in force. Mount Stewart Ave. 1-37, 2-84, Mount Stewart School Shaftesbury Avenue 1-103, 2-104 Bacon Lane 2-50 Sheridan Gardens 1-19, 2-26 Goldsmith Lane 1-95, 2-58 Trevelyan Crescent 1-67, 2-74 Roe End 1-26 (consec.) Roe Lane 1-59, 2-98 Scudamore Lane 1-7, 2-8 20. NORTHWICK CIRCLE Shortscroft 1-17, 2-24 (Designated in April 1989) Stag Lane 316-364 Builders: F & C Costin

(I) Suburban Estates By Renowned Inter-War An excellent example of suburban town planning in mock-Tudor style, incorporating Developers a focal point and radiating street pattern. Substantial gardens add to the open character. 18. BARN HILL (Designated in March 1990 and January 1993) Ashridge Close 1-11, 2-12 Builders: Haymills Briar Road 1-35, 39-55, 2-44 Dovedale Avenue 1-21, 2-22 Mock-Tudor housing estate of 1926-29 on a steep hillside on which remnants sur- Draycott Avenue Gardens r/o 37-39 vive of a Landscape by Repton (1792). The street scenes, landscaping and views Draycott Close 1-7, 2-12 and adj. premises between buildings are especially important. Greystone Gardens 1-21, 2-40 Lapstone Gardens 1-41, 2A, 2-26 Design guide and Direction in force. Mentmore Close 1-11, 2-12 Norcombe Gardens 2, 4 Barn Hill 1-99, 2-46, 46a, b, c, Barn House, 48-88 Northwick Circle 1-34 incl. Barn Rise 3-53, 55-73*, 2-50, 52-60*, 62-66 Upton Gardens 1, 2-22 Barn Way 1-35, 37- 69*, 2-48 ,50-76* Wellacre Road 1-9, 2-20 Basing Hill 1-55*, 2-70* Winchfield Close 1-21, 2-26 Beverley Gardens 1-55*, 2-58* Woodcock Hill 6, 68 and St Johns Church Brampton Grove 1-37*, 2-28*, 46-64* Charlton Road 1-12* Corringham Road 1-53, 2-42 East Hill 1-31*, 2-18* 21. SUDBURY COURT Eversley Ave 1-33, 2-34 (Designated in January 1990 and January 1993) Forty Avenue 1-18 Grand Parade* Builders: Comben and Wakeling Grendon Gardens 1-7, 15-45, 2-10, 12a, 12-34 Mayfields 1-41*, 2-40 * This is one of the best mock-Tudor estates in the Borough. Dating from 1929-1935, Mayfields Close 1-16 (consec.) * the houses have a distinctive appearance with many fine features. Mature hedges, Midholm 1-23, 2-26, 28-32* trees and shrubs are a significant feature of the street scenes of this garden suburb. The Crossways 1-29, 2-32 West Hill 43-71*, 66-104*,106 Design Guide and Direction in force. Wickliffe Gardens 1-9, 2-12 Abbotts Drive 91, 111-197, 76-158 Audrey Gardens 1-39, 2A, 2-46

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Blockley Road 33 - 83, 93, 42-108 Blenheim Gardens 1-50 Campden Crescent 1-27, 2-28 East Lane 16-30 Carlton Ave West 83-145, 100-188, 204-212 East Lane 198-264, 1-18 Court Parade Chelmsford Square Hill Road 1-7, 2-8 Holt Road 1, 2-6 Chelmsford Square 1-41 and 2-40 Norval Road 1-107, 131, 12-74, 96 Phillimore Gardens 1-35, 2-16 Pasture Close 1-30 Consec. Dobree Estate Pasture Road 1-91, 2-60 Bryan Avenue 1-19 Paxford Road 41-119, 42-118 Peter Avenue 1-55, 18-52 Stapenhill Road 1-31, 2-32 Alexandra Avenue 3-37, 2-38 The Crescent 1-19, 2-24 Dobree Avenue 1-39, 2-28 The Fairway 1-137, 2-138 Rowden Avenue 1-27, 2-20 The Green 1-3, and adj. open space Watford Road 232-234, 268-278 Dudding Hill Estate

Aberdeen Road 1-31, 2-37, Fairlight and Kingsway House Dewsbury Road 1-57 and 2-58 (K) High Quality Pre-War Modernist Flatted Dudden Hill Lane 111-143 Development Ellesmere Road 1-59 and 2-64 Fleetwood Road 1-57 and 2-42 22. LAWNS COURT Geary Road 1-35 and 2-20 (Designated June 1995) Hamilton Road 1-69 and 2-70 Architects: Cashmaill Day and Lander Lancaster Road 1-27 and 2-72 Mulgrave Road 1-37 and 2-52 Dignified white maisonettes by noted architects around matured landscape setting, Normanby Road 1-65 and 2-48 strong horizontal emphasis with art-deco detailing. Elms Lane Lawns Court, 1-50 (all) the Avenue Wembley Bengeworth Road 1 Elms Lane 13-99, 18-108, One Hundred Elms Farmhouse and Elmwood Rec. Ground Elmwood Court Land to rear APPENDIX BE2 SCHEDULE OF PROPERTIES IN GRAND UNION Rowan Close 1-12, 12a CANAL POLICY AREA St. Andrews Ave 1-7, 2-8 St. Georges Close 1-12 Canal, towpath and public open space, footpaths and adjoining cycleways. The Sudbury Court Road 77-85, 86-92 Grand Junction Arms PH and Pleasure Boat PH. Buildings fronting canal, Atcraft site. Langholm, Waxlow Road and adjoining yard. Keswick Gardens/Princes Court

Keswick Gardens 1-26 (all) APPENDIX BE3 SCHEDULE OF PROPERTIES IN AREAS OF Park Lane Park Lane Primary School DISTINCTIVE RESIDENTIAL CHARACTER Princes Court 1-41 (all)

Alverstone Road Laing's Queensbury Estate

Alverstone Road 1-23, 2-14 Brinkburn Close 1-14 (all) Sidmouth Road 1-25,18-44 Brinkburn Gardens 1-67 and 2-96, All Saints Church and Church Hall Milverton Road 45-53, 50-60 Beverley Drive 1-193 and 2-186 Calder Gardens 1-51, 2-40 Blenheim Gardens NW2 Dryburgh Gardens 1-75 and 2-74 Girton Avenue 65-123 and 58-126 Blenheim Gardens 1-67, 2a and 2-98 Holyrood Gardens 1-75 and 2-92 Grosvenor Gardens 1-17 and 22 Melrose Gardens 1-34 (all) Stanley Gardens 1-23 and 2-22 North Way 21-73 and 30-76 Walm Lane 71-127 Sandhurst Close 119-133 Sandhurst Road 111-145 and 122-138 Blenheim Gardens HA9 Sherborne Gardens 1-37 (all)

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Stag Lane 78-150, 244 APPENDIX BE4 SCHEDULE OF LISTED BUILDINGS Tewkesbury Gardens 1-69, and 2-82 Tintern Avenue 1-99, and 2-80 Although the Council has made every effort to ensure that this schedule is accurate Waltham Drive 1-23 and 2-6 and up to date it does not supersede the statutory list document itself which is liable Whitby Gardens 1-19 and 2-20 to alteration. As buildings may sometimes change their name or address if there is Wimborne Drive 1-3 and 2-36 any doubt whether a building is listed, then you should check with the Brent Planning Service. Littleton/Pebworth Roads Harlesden/Willesden Green Amery Road 1-69 and 2-54 Littleton Crescent 2-34 Statutory List Littleton Road 1-49 and 2-38 105-109 High Street (Harlesden) Grade II Mulgrave Road 1-17 and 4-38 All Souls Church, Station Road Grade II* Pebworth Road 1-59 and 2-76 Brent Viaduct Railway Bridge, Watford Road 243-269 North Circular Road Grade II Christchurch, Willesden Lane Grade II North Wembley Station Area Church of Our Lady of Willesden, Acton Lane Grade II Church of St Mary, Neasden Lane Grade II* East Lane 159-163, The Chequered Flag Church of St. Andrew, High Road Willesden Grade II* Llanover Road 59-137 and 66-130 Jubilee Clock, High Street (Harlesden) Grade II Peel Road 1-53 and 2-78 St Matthew's Church, St Mary's Road Grade II Pembroke Road 48-54 St. Andrew's Church Schools, St Andrew's Road Grade II St. Andrew's Vicarage, St. Andrew's Road Grade II Okehampton Road Stonebridge Park P.H., Hillside Grade II St Michaels Church, St Michaels Road Grade II Crediton Road 1-49, 2-50 The Green Man P.H., High Street (Harlesden) Grade II Dundonald Road 1-43, 2-44 Okehampton Road 17-65, 2-56 The Local List Wrentham Avenue 1-65, 2-86 'Hurworth', 2 Morland Gardens 1 and 2 Church Cottages, Neasden Lane Salmon Street 15-19, 45 Brondesbury Park 163 and 167 Willesden Lane Kingsmere Court 5-14 175 High Street Salmon Street 101-305, 100-284, 1-15 Paddocks Green (incl) Willesden Green United Synagogue, Heathfield Park Slough Lane 37-107, 38-128 247 Willesden Lane 97-103 High Street, Sudbury Court East Bank Premises, 86 Craven Park Road Barclay's Bank, 5 High Road, Willesden Abbotts Drive 1-89, 2-74 Brondesbury Mews and adjoining public lavatories, Willesden Lane Blockley Road 1-31, 2-40 Drill Hall, Pound Lane Carlton Ave West 1-81, 2-98 Hindu Temple, Willesden Lane Dean Court 1-25, 2-20 Royal Oak P.H., High Street East Court 1-56 consec Services Rendered Club, 1 Morland Gardens East Lane 184-196 Stonebridge Primary School, Shakespeare Avenue Holt Road 3-29, 8-48 The 'Spotted Dog' P.H., 38 High Road, Willesden Langham Gardens 1-51, 2-36 Former Willesden College of Technology Annexe, Dudden Hill Lane Nathans Road 1-75, 2-100 Willesden Green Library, High Road Norval Road 133-179, 98-146 Willesden Green Station, Walm Lane Oldborough Road 1-67, 2-82 Willesden Seventh-Day Adventist Church, Pound Lane Paxford Road 7-39, 8-40 Willesden Vestry Hall, Neasden Lane Shelley Gardens 7-45, 8-46 Spencer Road 1-55, 2-52 Kilburn/Kensal West Court 1-33 consec Statutory List 1-6, 12-18 (Consec) Cambridge Gardens Grade II 10, 18-56 Cambridge Avenue, Kilburn Grade II 12-52 Oxford Road Grade II 22-84, 9-29, 33-41, 45-67 Princess Road Grade II 61-63 Cambridge Road Grade II

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842 Harrow Road Grade II Church of the Holy Innocents, Kingsbury Road Grade II Gaumont State Cinema, New Church of St. Andrew, Church Lane Grade II* 195-199 Kilburn High Road Grade II* Old Church of St Andrew, Old Church Lane Grade I Kilburn Park Underground Station, Tombs of Sir Timothy Wetherilt, Henry Wetherilt, William Frederick Ashton, Edwin Cambridge Ave. Grade II Austen Abbey, Thomas Raworth and Joseph Finch, Old St Andrews Churchyard, Cambridge Hall, Cambridge Avenue Grade II Old Church Lane Grade II Prince of Wales P.H., 11 Cambridge Gardens Grade II Telephone Kiosk, Stag Lane Grade II Telephone Kiosk, Harvist Road Grade I Top Rank Bingo Hall, 1, Burnt Oak Broadway Grade II The Chapels, Paddington Cemetery, Mecca Bingo Hall, Burnt Oak Broadway Grade II Willesden Lane Grade II Queen Park Bandstand Grade II The Local List Kingsley Court, Willesden Green Grade II 12, 15-16 Hayland Close 134 Slough Lane 299-313 Preston Road 3-5, 43-45 Buck Lane The Local List 345-351 Stag Lane, Kingsbury 10 Brondesbury Road Dam Keeper's Cottage, Birchen Grove 134-136 Willesden Lane Snooker Club, Edgware Road, Colindale Electric House, Willesden Lane Kenton Grange & Stabling Block, Kenton Road 2-14 Chichester Road Kilburn Polytechnic Annexe, Edgware Road 253 Kilburn Lane Kingsbury Manor walled garden and Veterans Club, Kingsbury Road 259-267 Kilburn High Road Tudor Gates, Whitecastle Mansions, Highfort Court, Buck Lane 325 Kilburn High Road Rochester Court, Stonegate Court, Buck Lane/Wakemans Hill 41-61 Kilburn High Road Shell Cottage, 44 Kingsbury Road 50-60 Chichester Road The Trough, Old Kenton Lane 6-10 Oxford Road Symal House, Holmstall Avenue 76-82 Brondesbury Road 810 Harrow Road 822-834 Harrow Road Neasden/Cricklewood 836-840 Harrow Road 850-856 Harrow Road Statutory List 858-864 Harrow Road Church of St. Gabriel, Walm Lane Grade II 95-119 Malvern Road Dollis Hill House, Dollis Hill Lane Grade II 96-98 Brondesbury Road Dollis Hill Synagogue and Railings, Parkside Grade II Bandstand in Queens Park, Kingswood Avenue St Francis Church, Fleetwood Road Grade II Canterbury House, Canterbury Road St Michaels Church, St Michaels Road Grade II Christchurch School, 138 Willesden Lane The Grange, Neasden Lane Grade II Duke of Cambridge P.H., 71 Cambridge Road The Old Oxgate, Coles Green Grade II * Foresters Hall, 269 Kilburn High Road Kilburn Library, 42 Salusbury Road Kilburn Polytechnic, 24-34 Glengall Road Local List Prince of Wales P.H., Willesden Lane 112-114 Dollis Hill Lane The Brondesbury P.H., 111 Canterbury Road 63-65 Shoot-up-Hill The Cock P.H., 125 Kilburn High Road Former Post Office Research Station, Gates & Bunker, Brook Road The Goose & Granite P.H., Kilburn High Road Metropolitan Water Board Pump House & Chimney, St Michael's Road The Stone Hall, Chevening Road The Castle, Riffle Road West Kilburn Baptist Church, Carlton Vale Church of St Paul, Dollis Hill Gladstone Park Primary School Kingsbury/Kenton

Statutory List Wembley/Alperton 152, 154 (Midcot), 156 (Hayland), Slough Lane Grade II Kingsbury Manor, Kingsbury Road Grade II Statutory List Brent Town Hall, Forty Lane Grade II 96-98 Sudbury Court Road Grade II 148 Slough Lane Grade II 971-977 Harrow Road Grade II 142 Slough Lane Grade II Church of St. John, Boundary Walls & Lych Gate Grade II 1/1a-5/5a, gatepiers between 5/5a & 6/6a, 6/6a-7/7a, 8/8, 9/9a, 10-10a, 11/11a Church of St. John, High Road Grade II &12/12a Old St Andrews Mansions, Old Church Lane Garden Walls etc., Barham Old Court Grade II Grade II Outbuilding, Hundred Elms Farm, Elms Lane Grade II *

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St. Andrews Church Hall, Harrow Road Grade II Kenelm Close 7-12 incl. St. Andrews Church, Harrow Road Grade II Kingsbury Road 'The Plough' P.H. St Georges Church and adjoining vicarage Leeland Way 13-36 incl. Harrow Road Grade II Manor Drive 30-42, 47-55 Sudbury Town Station Grade II Manor Farm Road 140-166 Telephone Kiosks (3) Empire Way Grade II Manor House Drive 2-8, 32-40 Wembley Arena, Empire Way Grade II Mayfield Close 9 Wembley Park Lodge, 114 Wembley Hill Road Grade II Neasden Lane Vicarage at No.18 and 178-200 and St Mary's Church Local List Neasden Lane North Corner of Quainton Street Old Church Lane Old St. Andrews Church and Churchyard 'Never-Stop' Railway, North End Road Park Lane 52 1-3 Stanley Avenue Park Parade 38-42 Charles Goddard House, Harrow Road Pleasant Way 2-8 incl. Wembley United Synagogue, Forty Avenue Preston Hill Bruce House at 195-197 106-110 Sudbury Court Road Primrose Way 2-18 incl. 170-184 Watford Road Roe Green Caffrey Gardens 2-4 Stanley Avenue Runbury Circle 2-14, 15-49 2-4, 12-16, 114-116 Elms Lane Salmon Street s/o Big Bush Farm and 161-195 incl. Wembley Fire station and Cottages 591-593, Harrow Road South Way s/o office block redevelopment Old Police Station, Harrow Road, Wembley Springwell Avenue 1-3, 2-16 595 Harrow Road Stag Lane Roberts Court 797-807, 854-868 Harrow Road, Sudbury Sudbury Court Road 55-69 Barham Old Court The Drive Glenwood, Follaton and Green Shade Canal Cottage, Twyford Abbey Road The Mall Kingsbury Police Station Cyprus Works, Third Way Uxendon Hill 17-45, 14-26 Guinness Brewery, St. James Avenue, Park Royal Watford Road Sudbury School Hundred Elms Farm Welsh Harp Reservoir Open Space Wrigleys Factory, East Lane Wentworth Hill 2-12 Alperton Underground Station, Ealing Road Wykeham Hill 1-15 The Greyhound, P.H., Oakington Manor Drive

ARCHAEOLOGICAL PRIORITY AREAS APPENDIX BE5 SITES OF ARCHAEOLOGICAL IMPORTANCE AND ARCHAEOLOGICAL Harlesden: Area of High Street and mediaeval village: PRIORITY AREAS Acton Lane County Court, 11-13, 2-18, Church of Our Sites of Archaeological Importance Lady of Willesden Avenue Road 5 and 6 Acton Lane 31-39 and church Bramshill Road 1-23 and 2-26 Barn Hill Site near pond Buckingham Mews 1-25 (all) Blackbird Hill 'The Blackbirds' P.H. The Croft 1-17 Brondesbury Park Delmore, Everton, Shirley Crownhill Road R/o Convent of Jesus and Mary Buck Lane Mead Court Harlesden Gardens 1-11, 2a, 2-16 Chalkhill Davy House High Street 9-145, 16-158, 'The Green Man', 1-4 Manor Parade, Clarendon Gardens 1-3, 2-6 Unemployment Exchange Clifford Road Allotment Site Leghorn Road 71-79 and 118-136 Coles Green Road Coles Green Court, Delta Court and the Old Oxgate Farm Manor Park Road Vacant Site, Coliseum, Salvation Army Hall, 34-54 Deerhurst Road 2-8 Park Parade 1-42, 'Royal Oak' P.H., St. Josephs School, 62-72 Disraeli Road Adj. 38 Rucklidge Avenue 1-21, 2-14, Warehouse, 1-8 Willows Terrace Dyson Court 1-24 inc. and Claxton House Sellons Avenue 1-11 and 2-12 Elms Lane 52-62, Hundred Elms Farm House Station Road All Souls Church, 3-23, 10-30 Fairfields Crescent 1-15 and Fairfields Tavistock Road 4, Methodist Church Forty Lane 21-27 Wendover Road 1-29, 6-20, Post Office, Electricity Sub-station Fryent Way Track to the west of Green Close 6-7 Kingsbury: Area of church, earthwork and moated site: Grove Park Grove Park Special School High Street, Wembley 3-12 Church Lane Former vicarage and St Andrews Church John Perrin Place 1-80 Old Church Lane 1-29, 16-26, 40-44, St Andrews vicarage, Old St

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Andrews Mansions, St. Andrews Old Church and Local Landmarks Cemeteries; Village Mews St Andrews Road The Lodge, Hazeldene Cadbury Schweppes Building, Dollis Hill Lane Tudor Gardens 1-17 Christchurch, Willesden Lane Wells Drive 25-29 Pumping Station, Gladstone Park Guinness Brewery, Park Royal Sudbury: Area of mediaeval settlement and Archbishops Manor House: Jubilee Clock, Harlesden High Street Kilburn State Cinema Aspen Drive 11-31, 31a, 31b, 33-39,2-46 New St Andrews Church Bengeworth Road 1-15, 2-12 Poplars, Ridge of Barn Hill Court Parade (East Lane)1-18, 32, 33-38 St Augustines Church (in Westminster) Dyson Court 1-24 inc. and Claxton House Swaminarayan Temple, Brentfield Road Welsh Harp Reservoir

Elms Lane 1-8 Georgian House, 65-95, Rec. ground, 28-86, 98-116, Hundred Elms Farm House Local Viewpoints Kenelm Close 1-25 (all) Perrin Road 1-4, Clinic, Sudbury JMI school Barn Hill Rowan Close 1-12 (all) 12a Bridgewater Road St Georges Close 1-12 (all) Elmwood Park Sudbury Court Drive 35-97, 40-110 Gladstone Park Watford Road 27-135, 1-14 (all), Cornerways, 149-165, Gotford Hill 170-184, Garage, 206-218 Willow Way King Edward VII Park 1-9 consec. One Tree Hill Recreation Ground Silver Jubilee Park Church End: Area of church and mediaeval village: Wakemans Hill (Crest of)

Church Road 179-235, 146-234 & White Hart Hotel Cobbold Road 107-123 Garnet Road Open Space and Hall Views of Wembley Stadium are listed in policy WEM20. Ilex Road 1-67 and 2-18 Neasden Lane St Mary's Church; Parish centre, Vicarage; Church Viewpoints over Brent from adjoining boroughs are identified in the UDP's of those Cottages and Willesden Vestry Hall, 18-20a, Roberts authorities. Court Preston Gardens No buildings Roundwood Road 2-6; Hall White Hart Lane 5 (former Motor Body Works)

APPENDIX BE6 VIEWS AND VIEWPOINTS

Views of Important Landmarks

(a) Mill Hill Park to St Mary's Church Harrow-on-the-Hill (b) Wakeman's Hill to St Mary's Church Harrow-on-the-Hill (c) Gotford Hill to St Mary's Church Harrow-on-the-Hill (d) Barnhill to St Mary's Church Harrow-on-the-Hill (e) Golders Hill Park to St Mary's Church Harrow-on-the-Hill (f) Parliament Hill to St Mary's Church Harrow-on-the-Hill (g) King Edward VII Park to St Mary's Church Harrow-on-the-Hill (h) One Tree Hill to St Mary's Church Harrow-on-the-Hill (i) Elmwood Park to St Mary's Church Harrow-on-the-Hill (j) Guinness Open Space to St Mary's Church Harrow-on-the-Hill (k) Swaminaryan Temple, Brentfield Road

Policy WEM17 lists views of Wembley Stadium.

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Brent Unitary Development Plan - 2004 62 ENVIRONMENTAL PROTECTION 4 ENVIRONMENTAL PROTECTION

Page 4.11 ENERGY 73

4.1 INTRODUCTION 64 EP14 NEW ENERGY, RENEWABLE ENERGY AND FUEL STORAGE DEVELOPMENT 74 4.2 BACKGROUND 64 4.12 INFRASTRUCTURE AND STATUTORY 4.3 STRATEGIC CONTEXT 64 UNDERTAKERS 74

4.4 POLICY OBJECTIVES 65 EP15 INFRASTRUCTURE 74

4.5 BOROUGH STRATEGY 65 EP16 OPERATIONAL REQUIREMENTS OF STATUTORY UNDERTAKERS 74

POLICIES & PROPOSALS 4.13 LAND CAUSING POOR AMENITY 75

EP17 LAND CAUSING POOR AMENITY 75 4.6 ENVIRONMENTAL IMPACT 65 APPENDIX EP1 SCHEDULE OF SITES SUBJECT EP1 ENVIRONMENTAL IMPACT ASSESSMENT 66 TO FLOODING 75

4.7 NOISE AND VIBRATION 66

EP2 NOISE & VIBRATION 66

4.8 AIR QUALITY & POLLUTION 66

EP3 LOCAL AIR QUALITY MANAGEMENT 68

EP4 POTENTIALLY POLLUTING DEVELOPMENT 68

EP5 DEVELOPMENT AFFECTING EXISTING POTENTIALLY POLLUTING DEVELOPMENT 69

EP6 CONTAMINATED LAND 69

4.9 HAZARDOUS SUBSTANCES 69

EP7 HAZARDOUS SUBSTANCES 70

EP8 NOTIFIABLE INSTALLATIONS 70

4.10 WATER 70

EP9 WATER QUALITY 71

EP10 PROTECTION OF SURFACE WATER 71

EP11 WATER SUPPLY - DEMAND MANAGEMENT 72

EP12 FLOOD PREVENTION 72

EP13 WATER RUN OFF - SOURCE CONTROL 73

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4.1 INTRODUCTION 4.3 STRATEGIC CONTEXT

4.1.1 This chapter covers land-use policies designed to protect specific 4.3.1 The Town and Country Planning Act 1990 requires that develop- features of the environment, such as air and water quality. It also ment plans include policies in respect of, '..the conservation of the contains policies for public protection; such as from risk of flood- natural beauty and amenity of the land', as well as 'the improve- ing and from hazardous substances. Some of these areas fall ment of the physical environment'. under the remit of the Environment Agency which has powers to protect and enhance water courses, to prosecute polluters and 4.3.2 National Government Guidance on environmental issues in plans promote nature conservation and water recreation. The applica- is provided by Planning Policy Guidance Note 12 'Development tion of these policies in day to day planning decisions will there- Plans' (PPG12). It makes reference to the need for plans to take fore be complementary to this agency's role. into account natural resource considerations, including water, and to include policies on pollution, flood prevention, noise pollution, 4.1.2 Other chapters contain policies specific to a number of environ- hazardous installations, the protection of groundwater and the mental features, for example Open Space and Waste have their provision of adequate infrastructure. own chapters, and trees/landscaping and environmental improvement are covered in the Built Environment chapter. The environ- 4.3.3 PPG1 (General Policy and Principles) sets out the role of the mental impact of traffic is covered in the Transport chapter. planning system in terms of hazardous substances and noise. Details of how the plan as a whole will be used to bring about PPG1 overall stresses that the 'aim should be for any develop- more sustainable development is set down in Part I of the plan. ment to result in a benefit in environmental and landscape terms'.

4.1.3 The protection and active management of Brent's environment is 4.3.4 Regional Planning Guidance for the South East (RPG9) stresses a vital component of achieving sustainable development. If the need for sustainable development and environmental Brent's stock of key environmental features is undermined, then improvement so that 'urban areas provide a good environment in Brent will become a more unhealthy and unwelcome place which to live and work'. detracting from the character, appearance and quality of the local environment in which people live, work and travel and which pro- 4.3.5 RPG3 (Strategic Planning Guidance for London Planning vide habitats for wildlife. Poor environmental conditions can make Authorities) stresses the need to reduce pollutants at source by the Borough an unattractive place in which to live and work and discouraging unacceptable development and guiding develop- act as a disincentive to commercial investment. ment to acceptable locations. It also emphasises London's considerable consumption of water and energy and consequent aris- 4.1.4 The design of buildings as well as land use patterns (see policies ings of sewage and pollution from energy consumption - planning STR2, STR5 and STR11 in Part I of this Plan) have a crucial has an important role in managing this consumption. impact upon natural resources and ecological processes. The planning system, by encouraging designs that integrate with natu- 4.3.6 Draft Planning Policy Statement 22 (PPS22): Renewable Energy, ral processes, can play an important part in countering such glob- November 2003 sets out the Government’s broad policy objec- al problems as the greenhouse effect. tives for renewable energy in England and its proposed planning policies. Many of the draft policies are based on existing PPG22 4.1.5 Success in this area cannot be achieved by Brent Council's and aim to assist the UK to meet targets for the reduction of emis- actions alone. Co-operation between the Council, local commu- sions of greenhouse gases. PPG 23 and 24 contain detailed nities and local businesses is essential, and the Council aims to advice on planning for pollution control and noise respectively. work in partnership wherever possible. Brent Council encour- PPG25 'Development and Flood Risk', July 2001 emphasises the ages community participation at all stages of the planning and positive role of land use planning in reducing the danger of flood design process and will seek to raise awareness of environmental risk. issues in the community. 4.3.7 On pollution, RPG3 states that land use policies should help to avoid the concentration of different polluting activities from differ- 4.2 BACKGROUND ent sources and should encourage sustainable practice and development to reduce pollution. RPG3 also contains specific 4.2.1 Brent participated in the London-wide State of the Environment advice on policies on pollution, air quality, water and sewerage, Report for London. Amongst other matters the 1996 report energy, noise and contaminated land (see relevant sections of the showed that Brent has typical energy use per person for Outer chapter). London Boroughs and that Brent has the joint third highest number of water pollution incidents amongst boroughs. More recent 4.3.8 The Mayor’s Draft London Plan (Spatial Strategy for Greater air quality monitoring data shows that much of Brent suffers from London), June 2002 included environmental protection policies poor air quality levels. Much of the Borough also suffers from including: high noise levels, especially from traffic and railways. Some parts • Improving air quality (Policy 4A.6), of the Borough, such as in congested town centres and along the • Energy efficiency and renewable energy (Policy 4A.7), North Circular Road, suffer from multiple environmental problems • Energy assessment (Policy 4A.8), of noise and pollution leading to a poor quality of life. • Providing for renewable energy (Policy 4A.9),

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• Supporting the provision of renewable energy (Policy 4A.10), • The Precautionary Principle: In some policy areas there are • Water supply and quality (Policy 4A.11), potentially significant risks to the environment but scientific • Reducing noise (Policy 4A.12), knowledge is not conclusive. In these cases the precaution- • Climate change (Policy 4A.13), ary principle dictates that development should not go ahead; • Bringing contaminated land into beneficial use (Policy 4A.14). • The Best Practical Environmental Option: So that the option providing the most benefits or least damage to the environment is chosen. 4.3.9 In January 2004 the Mayor of London had published a series of strategy documents setting out his policies for London including: 4.5.4 The Council has undertaken an Environmental Appraisal of the • Air quality strategy (September 2002), plan, which was subject to public consultation, assessing whether • Biodiversity strategy (July 2002), or not individual policies are supportive or contrary to the princi- • Municipal waste strategy (September 2003). ples of sustainable development.

Draft strategies included: 4.5.5 In implementing the policies in this chapter the planning authority • Energy strategy (January 2003), will apply the Polluter Pays principle. A significant amount of envi- • Ambient noise strategy (March 2003). ronmental damage occurs because those who are responsible do not have to bear the costs. Where environmental damage is threatened, or caused, then the costs of any necessary protection 4.4 POLICY OBJECTIVES measures should be borne by those responsible and not society at large. 4.4.1 Taking into account the state of Brent's environment, and the various requirements of government policy and guidance, the objectives of the Unitary Development Plan's policies towards environ- POLICIES AND mental protection are as follows: PROPOSALS

1. To work, in partnership with the community, business and the Environment Agency, to monitor and protect the environment 4.6 ENVIRONMENTAL IMPACT of Brent - especially towards meeting national and interna- 4.6.1 The planning authority will take full account of the wider environ- tional environmental standards; mental impacts that a proposal may have, whether impact from 2. To locate development where residential amenities can be nuisance, on the natural environment, from the traffic likely to be protected and where sustainable business practices are generated by the proposed development or from any other unhindered; sources. 3. To integrate measures for the sustainable use and management of resources into new development and regeneration 4.6.2 Certain development schemes can have a significant environ- pro-grammes. mental effect. In these cases, European and UK law requires, taking account of factors such as the nature, size and/or location of the development, a statutory assessment of the environmental 4.5 BOROUGH STRATEGY impacts of the proposal in the form of an Environmental Impact Assessment (EIA). In practice this will normally apply only to 4.5.1 The strategy of the plan towards environmental protection is to major developments of more than local importance (see Circular ensure that national standards of acceptable environmental 2/99, Office of the Deputy Prime Minister (ODPM). Where such impact (e.g. air quality) are met, by ensuring that planning and an assessment is required, the developer must compile detailed non-planning controls support the achievement of these stan- information about the likely main environmental effects, as well as dards. the need for the development and alternatives to it. This information is known as an 'Environmental Statement' (ES) and must be 4.5.2 This needs to be seen alongside a number of other corporate taken into account by the planning authority in making its deci- strategies of the Council. Brent’s Community Plan ‘A Plan for sion. The public must also be informed of the main reasons for Brent 2003 - 2008’ has been adopted, which represents a com- the decision. bined statement of the needs and priorities of local people and identifies some of the policies that have been adopted by local 4.6.3 PPG 23 on Planning and Pollution Control also indicates that service-providers to meet these needs. More detailed Brent where an application relates to development for which an ES is strategies, such as the Air Quality Action Plan, and its Health not required by the regulations, the planning authority will need to Strategy, have been framed alongside the Unitary Development determine what environmental information is required for a proper Plan, with the UDP providing the land use planning element. judgement to be made on the application.

4.5.3 In assessing appropriate locations for development Brent has applied two key principles of sustainable development:

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4.7.6 The impact of ambient noise and vibration from transport (includ- EP1 ENVIRONMENTAL IMPACT ing road, rail and aircraft) on the local environment is recognised ASSESSMENT in the European Environmental Noise Directive 2002/49/EC as a pollutant which needs to be managed. The Government has Where a development is judged likely to have launched a 5 year process towards a National Ambient Noise significant effects upon the environment by virtue of Strategy including noise mapping and practical actions including factors such as its nature, size and/or location, a planning and transport controls. The Greater London Authority statutory environmental statement will be required to Act 1999 gave the London Mayor a duty to prepare a London be submitted with the application. This should also Ambient Noise Strategy. The Council will have regard to the assess the need for the development and alternatives Mayor’s strategy to safeguard the amenity of the local community. to it, mitigation and monitoring measures. 4.7.7 Noise from construction is inherent in any development large or small. The Council is aware of the ongoing impact of such devel- 4.7 NOISE & VIBRATION opment especially major developments such as Wembley or the rail infrastructure. Environmental Health can ensure under the 4.7.1 Noise and/or vibration is a common problem in Brent. Such prob- Control of Pollution Act 1974 that controls are put in place to min- lems mainly arise from road traffic, railway and industrial/com- imise the impact of any development to local residents from noise mercial noise. or vibration. The Council’s Supplementary Planning Guidance 19 on Sustainable Design, Construction and Pollution Control 4.7.2 For new developments such as housing, care is taken to ensure (SPG19) provides guidance on noise (see also Policy BE12). that the noise levels within the development area fall within a set category before development takes place. These categories are defined in Government Guidance (PPG24) based on noise levels EP2 NOISE & VIBRATION from road, rail, air and industrial noise. Category A requires no consideration, categories B & C require consideration to be given I) Noise &/or vibration generating development will to ensure adequate protection against noise. Category D indi- be permitted unless it would create, or worsen, noise cates planning permission shall not be given. levels above acceptable levels. In particular they will not be permitted where they would harm existing or 4.7.3 BS 6472:1992 "Evaluation of human exposure to vibration in proposed noise sensitive development (e.g. housing, buildings" details methods for assessing vibration in relation to hospitals, schools) in the area, and if this cannot be acceptable levels for proposed developments next to, for exam- acceptably attenuated. ple, railways. This information shall be required prior to such developments to assess the feasibility of development. II) Noise sensitive development will be permitted unless its users would suffer noise levels above 4.7.4 Standard levels of insulation are required by the Building acceptable levels, and if this cannot be acceptably Regulations and guidance is given by BS8223:1987 in relation to attenuated. steady and intrusive noise for living rooms and bedrooms. However, this does not take into account varying ambient noise Necessary noise insulation will be secured by condi- levels and therefore additional requirements may be imposed by tion. the planning system. Also changes of use, for example from a shop to a public house or a mini-cab office, would not require Building Regulations consent but planning conditions controlling noise can be imposed. New noise sources can be controlled through the powers of the Environmental Protection Act 1990, but only in retrospect once they become a nuisance. Therefore such 4.8 AIR QUALITYAND issues shall be addressed at the planning stage through the appli- POLLUTION cation of planning conditions in relation to sound insulation and attenuation of plant noise such as extractors/air-conditioning etc, AIR QUALITY MANAGEMENT where these measures can be practically implemented. Where music entertainment is proposed, reports from independent 4.8.1 Poor air quality has fundamental impacts on health and the quali- acoustic consultants detailing sound insulation measures appro- ty of life. National policies on air pollution are expected to deliver priate to the use of the building use shall be provided, and if satis- a significant improvement in air quality. However, it is recognised factory their findings implemented. that there is an important local dimension to air quality. Local factors, such as density of traffic or geography etc. can create 4.7.5 The environmental impact resulting from cumulative background "hotspots" which require local air quality management solutions. noise due to the introduction of new industry and commercial enterprise shall be addressed through enforcement conditions at the planning stage with reference to BS4142: rating industrial LOCAL AIR QUALITY MANAGEMENT noise affecting mixed residential and industrial areas. Part IV of the Environment Act 1995 provides a

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national and local framework for tackling air pollu- • The entire area south of the North Circular Road due to the tion. Under the Act, the Secretary of State has published a National Air Quality Strategy (recently number of times target levels have been breached and reviewed), that provides a framework of standards because of the presence of many schools and other sensi- and objectives for pollutants of most concern, includ- tive sites; ing small particles. It also includes a timetable for achieving these objectives by 2003-2010 and sets • All main road corridors north of the North Circular Road out the steps the Government is taking as well as including all housing, schools and hospitals along the North measures it expects others to take to see that objec- Circular Road, Bridgewater Road, Ealing Road, Harrow tives are met. Road, Watford Road, Kenton Road, Kingsbury Road, Locally there is a system of air quality management Edgware Road, Blackbird Hill, Forty Avenue, Forty Lane and in which local authorities are required to carry out regular reviews of present and likely future air quali- East Lane. ty. If standards and objectives are not being met, nor are likely to be met, within a period specified in regu- The map showing these is available on the Council’s website, lations or the National Strategy, the local authorities are required to designate an Air Quality Management select Environmental Heath and the Air Quality Management Area (AQMA). It will then be necessary for the Areas links. authority to prepare an assessment of the air quality in the AQMA and an Air Quality Action Plan of measures to be taken within a timetable for implementa- 4.8.4 Air Quality issues do not respect local planning boundaries and tion to ensure the achievement of standards and planning decisions can have cross boundary air quality implica- objectives within the designated AQMA. tions. Therefore some AQMAs (such as the North Circular Road) may have to cross Borough boundaries. The definition of these 4.8.2 The principal pollutants of concern are as follows: areas will vary over time because of monitoring. At the time this UDP was adopted, Supplementary Planning Guidance on air Figure 1 Main Pollutants to Air Quality quality management was being drafted for Boroughs in West London to consider adopting for their own areas, if appropriate. Substance Main Health Main Airborne Problems Sources AIR QUALITY AND PLANNING DECISIONS Benzene Carcinogenic Petrol Engines / Petrol stations 4.8.5 The impact of a development on air quality is a material consider- 1,3 -Butadiene Carcinogenic Petrol Engines ation in determining planning applications; this includes both the direct effects from a development as well as indirect effects, such Carbon Monoxide Toxic Petrol Engines as emissions from road traffic increases caused by development.

Lead Toxic Petrol Engines 4.8.6 For major development, especially that likely to attract high traffic levels, air quality dispersion models and assessments should be Nitrogen Dioxide Respiratory illness Road Traffic submitted with the application as part of the transport impact and Electricity assessment (this is already a requirement for applications subject Generation to statutory environmental impact assessment). The specific type of air quality model(s) to be used should be discussed with offi-

Pm10 Respiratory illness Diesel Engines / Waste manage cers in the Council’s Environmental Health Unit. SPG19 provides ment facilities guidance on air quality measures (See Policy BE12) and the Mayor’s Air Quality Strategy. Sulphur Dioxide Respiratory illness Electricity Generation & Industry

BRENT'S AIR QUALITY ACTION PLAN

4.8.3 Brent's approach to improving air quality is to follow the approach recommended by government of first monitoring sources of pollutants, then modelling dispersion of pollutants and where national pollution objective levels will be breached, and then declaring Air Quality Management Areas (AQMAs) in these locations. Where an AQMA has been designated there is a requirement to prepare an action plan to meet national objectives. On 2 April 2001, following a public consultation, Brent declared parts of the Borough as AQMAs including:

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4.8.10 As well as controlling the location of potentially polluting sources, EP3 LOCAL AIR QUALITY MANAGEMENT the planning authority also has to consider the pollution issues arising from proposals to site new development in close proximity In considering development proposals and in prepar- to existing pollution sources. The Council will seek advice from ing traffic management measures regard will be had pollution control authorities where new development (for example to impacts upon air quality - especially affecting or in housing schemes or developments attracting significant number Air Quality Management Areas - Development propos- of people such as shopping, entertainment or office complexes) is als should not harm the achievement of National Air proposed close to an existing pollution source. The Council will Quality Objectives. also need to consider the cumulative impact that could arise from the addition of a new potentially polluting development to an exist- Air Quality Management Areas will be designated ing pollution source. (with adjoining London Boroughs where necessary) where air quality levels are forecast to be at unacceptable levels.

Development proposals that would significantly contribute to air pollution are required to submit an assessment of the likely dispersion of pollutants with the planning application.

POTENTIALLY POLLUTING DEVELOPMENT

4.8.7 The possibility that development could cause pollution is an important aspect of the overall environmental impact of development, and therefore needs to be taken into account in planning decisions. This does not just include air quality impact but also other aspects of pollution such as smell and dust. Applicants for planning permission should provide sufficient information on the pollution aspects of their proposals to enable a sound planning decision to be made. In considering applications for potentially polluting development, the planning authority will consult with, and take into account the views of, the appropriate pollution control authorities. EP4 POTENTIALLY POLLUTING DEVELOPMENT 4.8.8 Where the development is likely to meet the requirements of the pollution control authority, the Council will nevertheless need to Developments should be located and operated so as to be satisfied that: limit pollution (including smell and dust) to levels specified in National Air Quality Objectives and espe- • the location and siting are such that the amenity and charac- cially where it affects Air Quality Management Areas. ter of the surrounding area are protected, • there is no significant element at risk of a polluting incident or The onus will be on developers of potentially polluting from continued exposure and uses to demonstrate that the level of pollution would • development options for neighbouring or otherwise affected be acceptable, and compatible with requirements sites are not unjustifiably constrained as a result. Conditions under the Environmental Protection Act (any aspects relating, for example, to hours of operation may need to be of the development necessary to discharge such con- proposed. Potentially polluting industrial developments that sents, e.g. chimney heights, should be included with meet the relevant planning and pollution control requirements the planning application). are most likely to be considered acceptable in Strategic and Borough Employment Areas. Developments will not be permitted which:

(a) Present an unacceptable risk of a polluting incident 4.8.9 In recent years, the scope and effectiveness of non-planning con- and where that risk might have a wide land-use trols over pollution have been extended through new legislation. impact on the social, economic or environmental Local authority pollution inspectors and the Environment Agency well-being of the area; or have responsibility for air and water quality respectively. (b) Impose unacceptable constraints on adjoining or Industrial processes with the greatest pollution potential are reg- otherwise affected sites. ulated under the Pollution Prevention and Control Act 1999.

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4.8.13 Although the responsibility for dealing with contamination rests EP5 DEVELOPMENT AFFECTING EXISTING with the developer (and legal liability lies with the original polluter), POTENTIALLY POLLUTING the planning authority will need to know what account has been DEVELOPMENT taken of contamination when dealing with planning applications. Therefore, once these sites, or sites adjacent to these areas, Where proposed new development near to potentially become available for redevelopment, it is essential that a full polluting sources would be subject to unacceptable technical investigation is carried out, at the expense of the devel- risk, or the operations of the potentially polluting oper and in a form agreed by the Council, and that the develop- source concerned would be unacceptably prejudiced, ment incorporates any necessary remediation (which the draft cir- or would give rise to unacceptable cumulative impact, cular stresses is the responsibility of the developer). For the the development will be refused. development to be approved, it must be shown that the site poses no risk to human health, controlled waters or other sensitive receptors and that every effort has been taken to deal with pollutants. Therefore, an assessment of that risk must be made using CONTAMINATED LAND tools such as C.L.E.A . model or similar. The best way of dealing with potential risks to health is to identify which sites may be con- 4.8.11 Sites which have previously accommodated a polluting industrial taminated early. Very few sites are so contaminated that they use or which have had a history of landfill, are potentially contam- cannot be re-used at all but the choice of new uses may be inated. Contaminated land is defined by the Environment Act restricted by the contamination and the cost of dealing with it. The 1995 in terms of substances in, on, or under land where signifi- Council will seek to ensure, in conjunction with English cant harm is or would be caused. Partnerships, that contaminated land is brought into beneficial use in accordance with the other policies of this Plan and will 4.8.12 The Government's Policy is that any works needed for a contami- apply for appropriate funding. nated site should deal with any unacceptable risks to health, safety or the environment, taking into account its actual or intended 4.8.14 Guidance on contaminated land and a range of remediation mea- uses. The preferred approach is that contamination should be sures is provided in SPG19. See also Policy BE12. dealt with on the site itself. Contaminated land has now become an issue of growing interest to government, industry and the public due to research revealing the potential risk to human health EP6 CONTAMINATED LAND posed by toxic and contaminative substances within land, and pressure on land resources making recycling of previously used When development is proposed on or near a site urban land a priority of government policy. National policy is in suspected of being significantly contaminated then an favour of on-site treatment as landfill is contrary to national waste investigation of the hazards posed and any necessary policy (see waste chapter), this will require design changes, such remedial measures will be required from the as building above contamination and outlet pipes for venting. ‘Dig developer, prior to the determination of a planning and Dump’ will only be permitted where it is within the site area or application. on-site treatment is not the best practical environmental option. Where contamination is found any development THE REFORMED LAW ON CONTAMINATED LAND should be capable of being built and occupied safely, (fit for the purpose of the end user) without adverse Section 57 of the Environment Act 1995 sets down a new regime environmental impact. There will be a presumption in for dealing with contaminated land which came into force in 2000. favour of on-site treatment. Conditions will be Legislative and planning regimes are being formulated to treat imposed requiring action to comply with national stan- past contamination problems and prevent its occurrence in the dards, prior to the commencement of the develop- future. This will be implemented primarily by local authorities with ment, together with any required monitoring mea- the support and assistance of the Environment Agency. sures.

• Local authorities must produce a strategy setting out how Where contamination is suspected of being less they intend to prioritise the investigation and identification of severe, or where initial investigation is not possible, contaminated land. If the site is seriously contaminated it then conditions will be imposed requiring investiga- may be designated a "special site" and becomes the respon- tion, and for necessary remedial action as above. sibility of the Environment Agency; • The local authority must identify the person responsible for clean up and consult them on how to remediate the site. If no voluntary agreement is reached a remediation notice is served, against which there is a right of appeal; 4.9 HAZARDOUS SUBSTANCES • Clean up is required to make the site "suitable for use"; 4.9.1 The Planning (Hazardous Substances) Act 1990 provides for the • If the works are not carried out the Local Authority may carry control of the presence or use of hazardous substances and intro- out remediation and recover its costs. duced the concept of hazardous substances consent in the UK.

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The controls are designed to ensure that hazardous substances 4.10 WATER can only be kept or used in significant amounts after the responsible authorities have had the opportunity to assess the degree of 4.10.1 Brent has a main river running through it - the River Brent - as well risk arising to persons in the surrounding area. Even after all as several tributaries, such as the Wealdstone Brook. The health and safety controls have been complied with, there Borough also contains part of the Grand Union Canal and its remains a residual risk to the surrounding area and these plan- feeder. The quality of the water environment in Brent is of serious ning controls allow for this risk to be assessed. There are circum- concern. Many watercourses suffer from pollution and poor sew- stances where controlled amounts of hazardous substances may erage connections. Brent's waterways are an underused be brought onto land, or the way it is used upon that land, without resource offering considerable potential for recreation and regen- there being any associated development requiring planning per- eration. For this reason, Brent is a member of London's mission. Planning policies on controlling such hazards are now Waterway Partnership co-ordinating and funding waterside required by European Directive 96/82/EC on the control of major- regeneration, and is jointly planning waterway rehabilitation pro- accident hazards (the SEVESO II Directive). jects. The policies in this section address the quality of Brent's water environment and public safety issues (i.e. flooding). The Open Space chapter contains special policies on the recreational EP7 HAZARDOUS SUBSTANCES use of waterways and waterside open spaces and a special policy on the Grand Union Canal is contained in the Built Developments involving hazardous substances, or Environment Chapter, Policy BE14. uses requiring hazardous substances consent, will not be approved unless there is no unacceptable risk to occupiers, to public health and safety, or to nature conservation. The location of such uses in or near residential areas will not be permitted. Development adjoining areas in hazardous use will be controlled if this would otherwise create an unacceptable risk.

4.9.2 Certain sites and pipelines are designated as notifiable installations by virtue of the quantities of hazardous substances that are stored or used in them. Policies on these are required by Directive 96/82/EC on the control of major-accident hazards (the SEVESO II Directive). Whilst they are subject to stringent controls under existing health and safety legislation, it is considered prudent to control the kinds of development permitted in the vicinity of these installations. The Council will therefore consult with GROUNDWATER AND SURFACE WATER the Health and Safety Executive where applications are received QUALITY within the vicinity of the any notifiable installation in the Borough (the distances varying according to the substances involved). 4.10.2 The water quality of inland watercourses is an important area of The only such installation at present sited in the Borough is concern. Poor quality water may be made worse by abstraction Transco High Pressure Pipeline and for which the appropriate practices for drinking water and industrial water supply, conse- 'consultation distance' is 6 metres. Development is only likely to quently limiting future availability, including for recreation and con- be affected if foundations would affect the pipeline or where there servation. Particular problems can arise if developments disturb are surface installations. In most areas, however, it runs down contaminated land (which needs to be sealed against the leakage the centre of roads. of polluted matter). The Council will support initiatives to improve surface water quality.

EP8 NOTIFIABLE INSTALLATIONS 4.10.3 Also of concern is the need to protect groundwater resources. It is better to prevent pollution than to deal with subsequent contam- Proposals for developments to be sited within the ination. The Council therefore gives its support to initiatives to consultation distances for notifiable installations and prevent groundwater pollution. which would substantially increase the number of people at risk, and/or would result in unacceptable risk (including to nature conservation), will not be permitted.

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EP9 WATER QUALITY EP10 PROTECTION OF SURFACE WATER

Development will be refused (following consultation Development will be refused which harms watercours- with the Environment Agency) which would pose an es. In particular: unacceptable risk to the quality of groundwater or (a) The culverting or canalisation of further surface which would have a detrimental effect upon the quali- water will be refused, and the restoration of water- ty of surface water. courses to their natural state will be encouraged;

(b) Drainage into surface water will be limited to that which is essential and which does not harm the water environment; PROTECTION OF SURFACE WATER (c) Development should not restrict access to the 4.10.4 Watercourses are a precious natural resource. The water envi- waterside for recreation or for essential flood pre- ronment is sensitive to change and needs to be protected. vention or maintenance work; Watercourses and wetlands can easily be damaged by develop- (d) Development should seek to protect and integrate ment. Watercourses should be retained in their natural state the natural functions of surface waters, including wherever possible, including watercourse vegetation, and lost ponds, to safeguard habitats and maximise their watercourses restored where practical. amenity value; (e) Waterside or wetland habitat should not be materi- 4.10.5 Culverting or canalisation should be avoided as it effectively ally harmed; and removes all natural interest. It is the duty of the Environment (f) Development should not cause harm through alter- Agency to protect and enhance watercourses, to prosecute pol- ing the water table. luters and to promote nature conservation and water recreation. Brent will work closely with the Agency in implementing this policy.

4.10.6 Ponds are small water bodies, both natural and man made. They have a popular appeal, enabling people to experience wildlife on their own doorstep. Ponds support distinctive communities of ani- mals and plants and these can include rare species. Over the last century there has been a decrease, estimated at about 75%, in the number of ponds in Britain. The land surrounding a pond is an important component of the habitat. Degradation of this 'buffer zone' is a reason for ponds becoming less suitable for many ani- mals, such as amphibians and dragonflies, which breed in ponds but which spend much of their adult life away from the water WATER SUPPLY - DEMAND MANAGEMENT (Wildlife & Freshwater: An Agenda for Sustainable Management, English Nature 1997). 4.10.7 The combination of climate change, increasing water use and new development are producing serious concerns about the adequacy of future supplies of water in the South East of England. The Environment Agency is responsibility for planning water resources. Their role is to ensure that there is enough water for people to use, and that this water is taken in a way that prevents long-term environmental damage. Controlling the demand for water at the point of use is part of this. This is a planning matter, as recognised by PPG 12, as it is not controlled by other legislation, such as the building regulations, as demand management measures are now seen as central to sustainable land use planning in all areas, and as it has an impact upon the use of land elsewhere. Measures that can be used include metering all new homes, low-flush WCs and, in certain circumstances recycling 'greywater', i.e. safely re-used water, such as from washing, within the dwelling, see also Policy BE12.

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in Appendix EP1. The flood prevention work to the River Brent EP11 WATER SUPPLY - DEMAND and its tributaries that has taken place over the last twenty-five MANAGEMENT years, now largely completed, has greatly reduced the risk of flooding. The effectiveness of this scheme is, however, depen- Larger new developments, especially housing dent on flood storage being available in the Welsh Harp developments, should, where practical incorporate Reservoir. Some developments still require appropriate flood measures to reduce the demand for water from the prevention measures to be taken and the Council will consult with mains supply network. the Environment Agency and local water companies.

4.10.12 Development outside areas at risk from flooding may cause flood- FLOOD RISK ing elsewhere through increased surface water run-off. Undeveloped land acts like a sponge, soaking up surface rainwa- 4.10.8 Flooding is a natural phenomenon and the effects cannot entirely ter, allowing it to drain away slowly to watercourses. All non and be prevented. Rivers drain groundwater and surface water run off semi-permeable surfaces i.e. hardstanding, built development, from the land, via the drains into rivers and streams in Brent. remove this natural drainage capacity thus increasing surface River channels have a limited capacity and when a river rises water run-off. Heavy and persistent rain may overload the storm above its banks it floods the adjoining land, known as the flood drain and watercourse capacity causing flooding on floodplains plain. Floodplain storage reduces the peak flood flow in the river and surcharging from drains. Foul drains may become overload- which can reduce flood levels and the risk of flooding down- ed causing pollution. Areas with inadequate storm drainage are stream. Development on the flood plain reduces it’s storage listed in Appendix EP1. In these areas on-site storage of rainwa- capacity thereby increasing the risk of flooding. Flood risk is influ- ter may be required. enced by both the statistical probability of a flood occurring and the scale of the potential consequence. Climate change effects may Increase the frequency of extreme weather events and the risk of flooding. Reducing the danger of flood risk through minimising run-off and protecting flood plains is therefore an important role of the planning system, as emphasised in PPG25 ‘Development and Flood Risk’.

4.10.9 The planning system has acknowledged the natural function of open land and flood plains in reducing the risk of flooding. It is often more cost effective to work with nature rather than fight against it. Government policy is to reduce the risks to people and the environment from flooding. PPG25 'Development and Flood Risk' outlines how flood risk issues should be considered at all stages of the planning and development process in order to reduce future damage to property and loss of life.

4.10.10 The Government has adopted a precautionary approach in dealing with flood risk. This requires planning authorities to: 1. apply a risk-based approach, known as the sequential approach/test, when determining planning applications, EP12 FLOOD PREVENTION 2. take advice from the Environment Agency. On land liable to river flooding, as defined on the The sequential approach involves giving priority to allocating or proposals map, new development or the intensifica- permitting sites for development according to three Flood Zones: tion of existing development will be refused, unless 1. little or no risk; appropriate flood compensation measures are taken. 2. low or medium risk; and 3. high risk. Development should not pose an increased risk of flooding by increasing the rate of run-off into local Table 1 in PPG25 identifies the appropriate planning response to watercourses. development in each of the three Zones, although local planning authorities should take account of the level of actual risk, including the effects of flood risk on both local public transport availabil- WATER RUN-OFF SOURCE CONTROL ity and the surrounding road network. 4.10.13 Rainfall in urban areas drains off roads, industrial and residential 4.10.11 Brent has identified all areas at risk of flooding where appropriate areas. Thames Water and the Environment Agency insist that flood compensation measures will be required before develop- surface water discharge from new development is controlled and ment is permitted. This area is shown on the Proposal Map and adequate on-site storage is provided. This reduces flooding

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downstream of proposed development. Drainage to nearby 4.11.4 The Council has been involved in promoting energy efficiency for waterways via surface water outfalls often leads to high levels of some time. The Home Energy Conservation Act (HECA) places a water contamination, including oil, organic matter and toxic met- responsibility on the Council to promote energy efficiency in the als. For this reason there is now much greater awareness and wider community to improve the energy efficiency of the housing attention to more sustainable forms of urban drainage - of control- stock by 30% by the year 2006. It is intended that improvements ling run-off and contamination at source. The environmental in energy efficiency will reduce CO2 emissions. At the same time, impact can be reduced through good design and practice. it will lead to reduced fuel bills, improved health and generation of Amongst those that have proven useful are porous paving and local employment opportunities when such work is undertaken. roads, roadside swales, infiltration trenches and basins and Part L1 of the Building Regulations sets down minimum energy detention ponds. Further details can be found in the Environment efficiency targets in respect of newbuild dwellings, conversion to Agency's 'A Guide to Sustainable Urban Drainage' (1997), Urban flats, replacement windows and extensions to existing dwellings. Drainage the Natural Way (1993) and Brent’s Supplementary Planning Guidance on Sustainable Design, Construction and Pollution Control (SPG19) which shows how these techniques NEW ENERGY, RENEWABLE ENERGY, & FUEL can be applied in typical Brent situations. STORAGE DEVELOPMENT

4.11.5 Greater use of renewable energy (e.g. solar & wind) is to be par- EP13 WATER RUN OFF - SOURCE CONTROL ticularly encouraged as this is an underused resource in Brent and a study by the London Research Centre indicates great The building and landscape design of developments potential within London. PPG22 encourages renewable energy should incorporate, where practicable, measures to because of its reduced CO2 production compared to conventional control surface water run-off and prevent water con- energy sources and the consequent concern to reduce the risk of tamination at source. global warming, through the Government's requirement for energy producers to fulfil a non-fossil obligation. PPG22 ‘Renewable Energy - Annex on Photovoltaics’ March 2002 states that photovoltaic (or PV) technology can play a small but significant part in delivering the Government’s target to produce 10%. of electricity 4.11 ENERGY from renewable sources by 2010. 4.11.1 The use of energy is central to virtually all the goods and services which contribute to quality of life. However, the environmental 4.11.6 There are limited opportunities for large-scale renewable energy side-effects of our modern dependence on fossil fuels is now a schemes in Brent. Nevertheless, the technologies of solar panels cause of worldwide concern. Whenever fossil fuels are used to and photovoltaic cells, and passive solar design techniques create energy, the result is the creation of carbon dioxide and var- should be explored. Proposals for such should accord with poli- ious pollutants such as sulphur dioxide and nitrogen oxides. cies applied in conservation areas and in relation to listed build- These gases are a prime cause of acid-rain, which has seriously ings. damaged the eco-systems and corroded buildings. Carbon dioxide (CO2), while not a pollutant, is a major contributor to global 4.11.7 One of the greatest environmental issues relating to energy is warming. Fossil fuel burning in vehicle or power stations also transport. The pattern of land uses and transport infrastructure in cause the bulk of health threatening air pollution. an area is fundamental to local transport energy demand and its environmental effects. The Council's planning policies aim to 4.11.2 The Energy White Paper ‘Our energy future - creating a low car- encourage a shift away from using the car towards less energy bon economy’ February 2004 and the Mayor's draft Energy intensive forms of transport; for example, urban areas can be Strategy will require action by local authorities to tackle energy designed so as to avoid lengthy journeys (particularly by car) issues. The papers encourage local authorities to develop ener- between homes and workplaces and other regular destinations gy efficiency initiatives and strategies, promote renewables (see Policy STR5 in Part 1). Diesel and petrol engine exhaust amongst other measures to decrease CO2 emissions and reduce pollution is a problem that continues to worsen. In Brent, there will energy consumption. be more sophisticated pollution monitoring and tougher regulation (see Policy EP3). Alternative fuels like liquid petroleum gas 4.11.3 The Government aims to move beyond its Kyoto Protocol target (LPG), compressed natural gas (CNG) and electric powered vehi- towards its goal of reducing emissions of carbon dioxide by 20 cles are alternatives to reduce the level of diesel and petrol per cent below 1990 levels by 2010 and to put itself on a path to engine exhaust pollution. reduce carbon dioxide emissions by 60% by 2050 has set challenging national targets on reducing CO2 emissions including a 4.11.8 Conventional power stations produce large amounts of waste 30% reduction in domestic energy consumption. Energy produc- heat as a by-product of the generating process, with the result tion in buildings accounts for 40-50% of the UKs emissions of that their average energy efficiency is around 30%, with the most CO2. To achieve this Brent will have to considerably improve efficient rarely exceeding 35%. Combined Heat and Power sta- energy efficiency and develop renewable energy. See also Policy tions (CHPs), or co-generation systems, use this waste heat to BE12 and SPG19. provide hot water for central heating systems and general purposes, in addition to producing electricity. This means that they

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can achieve efficiencies of 80-90% and, at the same, time enable 4.12 INFRASTRUCTURE AND STATUTORY reductions in emissions of carbon dioxide, sulphur dioxide and UNDERTAKERS nitrogen oxides to be made. In addition to environmental benefits, CHP schemes can also bring significant cost savings to the INFRASTRUCTURE consumer (see also waste chapter Policy W10). 4.12.1 A number of existing services provided by the utilities (particularly sewerage systems and sewage treatment works) are becoming EP14 NEW ENERGY, RENEWABLE ENERGY overloaded. It is important that development does not proceed AND FUEL STORAGE DEVELOPMENT ahead of the ability of sewerage facilities and receiving sewerage treatment works to be able to deal with increased flows. Unless Development of new energy and fuel storage facilities additional infrastructure is provided, this may result in the pollu- will only be permitted where they meet local deficien- tion of watercourses and lead to public health risks. Although cy of energy supply. Proposals for renewable energy additional capacity will be provided where necessary to meet the which meet the need for increasing use of renewable demands of new development, some time must be allowed for energy would, however, be welcomed. This is condi- this to be implemented. Developers are therefore recommended tional on development having an acceptable visual and to consult with the utility providers at an early stage. environmental impact, and where large movements of fuel are required, to have an acceptable transport impact (Policy TRN1), with a presumption in favour of EP15 INFRASTRUCTURE rail or water movement. New petrol stations will be encouraged to install LPG and CNG refuelling pumps. Infrastructure of adequate capacity and design (particularly water supply and sewerage) should be avail- Development should be of a form not to prejudice able in time, and be adequate to serve development future realistic use of renewable energy. (following consultation with the utility undertakers and Brent Council). Where necessary, conditions will High voltage cabling should remain underground, be imposed phasing development, and/or planning unless this is economically, environmentally or opera- obligations will be secured, to ensure that new facili- tionally unfeasible. ties are brought forward.

Major development proposals, especially housing developments, should where possible, make reasonable measures to incorporate Combined Heat and STATUTORY UNDERTAKERS Power, or equivalent, where this would be viable and available. 4.12.2 Utility companies and authorities include the gas, electricity, telephone, water, sewerage, post, public transport and the emergency and police services. Many of these are substantial landowners in the Borough. With the continuous process of review of these services and of their operational requirements, there is often the need to dispose of surplus land and buildings and conversely the need to acquire more modern buildings and equipment. These are important services essential to the community and, to that end, the Council will support the provision of public services to meet the needs of the Borough and guide the individual authorities and companies to appropriate sites.

EP16 OPERATIONAL REQUIREMENTS OF STATUTORY UNDERTAKERS

Developments will be supported which provide adequate plant and equipment, land and buildings available for the operational requirements of public utility companies and authorities, subject to impact on residential amenity and local environmental conditions.

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4.13 LAND CAUSING POOR APPENDIX EP1 AMENITY SCHEDULE OF SITES SUBJECT TO FLOODING 4.13.1 Local authorities have limited powers, through section 215 of the Town and Country Planning Act 1990, to require the improvement Quainton Street Area - Land Liable to River Flooding of land adversely affecting the amenity of the neighbourhood. Such powers will be exercised where they will be effective. All or part of the land occupied by the following properties: However it should be noted that the powers are limited and cannot be used simply for gardens which are overgrown. Also, where Birchen Grove 2-24; 54-68 rubbish is the main problems environmental health legislation may be more appropriate. Finally, the problem is often absent Blackbird Hill 1-19 Talbot Court owners (such as the sick elderly) for which enforcement is unde- sirable and impractical. Braemar Avenue Electricity sub-station 2-16

EP17 LAND CAUSING POOR AMENITY Chesham Street 1-9; 2-16

The Council will consider serving notices requiring the Coombe Road 3; 6; Sellar House; Roger Stone Court improvement of property and/or land where it is properties fronting Neasden Lane North clearly adversely affecting the amenity of the neigh- (Godfrey Davis and McDonalds) Harp bourhood. Island Close 95-100; 101-106; 107-110; 111-116,117-128

Neasden Lane North 391-409; 494-504; Open Space Poplar Grove 35-50; 51-67 (incl); garage Quainton Street 1-103; 2-84 Runbury Circle 15-25 The Close 13-17; 14- 18 Verney Street 1-77

Chalkhill Youth and Community Centre and Sports Ground

Marshland below Welsh Harp Dam

Tokyngton - Land Liable to River Flooding

Area outlined on Proposals Map

Sites subject to flooding due to foul sewer surcharging

Belverdere Way, Kenton

The Mall, Kenton

Chapman Crescent, Kenton

Christchurch Avenue, NW6

Cavendish Road, NW6

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Brent Unitary Development Plan - 2004 76 HOUSING 5 HOUSING

Page H12 RESIDENTIAL QUALITY - LAYOUT CONSIDERA- TIONS 92 5.1 INTRODUCTION 78 5.12 RESIDENTIAL DENSITY 92 5.2 BACKGROUND 78 H13 RESIDENTIAL DENSITY 93 5.3 STRATEGIC CONTEXT 80 H14 MINIMUM RESIDENTIAL DENSITY 94 5.4 BOROUGH POLICY OBJECTIVES 81 5.13 DEVELOPMENT IN EXISTING 5.5 BOROUGH STRATEGY 81 RESIDENTIAL AREAS 94

POLICIES & PROPOSALS H15 BACKLAND DEVELOPMENT 94

5.6 ADDITIONAL HOUSING 83 H16 FRONTAGE REDEVELOPMENT 94

H1 ADDITIONAL HOUSING 83 5.14 SUB-DIVISION OF EXISTING HOUSING - FLAT CONVERSIONS 95 5.7 AFFORDABLE HOUSING 83 H17 FLAT CONVERSIONS 95 H2 REQUIREMENT FOR AFFORDABLE HOUSING 85 H18 THE QUALITY OF FLAT CONVERSIONS 96 H3 PROPORTION OF AFFORDABLE HOUSING SOUGHT 86 H19 FLAT CONVERSIONS - ACCESS & PARKING 97 H4 OFF-SITE AFFORDABLE HOUSING - 'PROVISION IN LIEU' 87 5.15 FLATS OVER AND ADJOINING BUILD- INGS IN SHOPPING CENTRES 97 H5 KEY WORKER HOUSING 87 H20 FLATS OVER AND ADJOINING BUILDINGS IN H6 PROTECTION OF EXISTING AFFORDABLE SHOPPING CENTRES 97 HOUSING (INCLUDING HMOS) 88 5.16 DOMESTIC EXTENSIONS 97 5.8 ESTATE REGENERATION 88 H21 DOMESTIC EXTENSIONS 97 H7 MAJOR ESTATE REGENERATION AREAS 89 5.17 RESIDENTIAL AMENITY 98 5.9 LOSS OF HOUSING 89 H22 PROTECTION OF RESIDENTIAL AMENITY 98 H8 RESISTING LOSS OF HOUSING 89

5.18 SUPPORTED HOUSING 98 5.10 SELF CONTAINED HOUSING 89

H9 DWELLING MIX 90 H23 SUPPORTED HOUSING / DAY-CENTRES - PRINCIPLE OF DEVELOPMENT 99 H10 CONTAINMENT OF DWELLINGS 90 H24 SUPPORTED HOUSING- 5.11 NEW RESIDENTIAL DEVELOPMENT 90 CONVERSIONS / EXTENSIONS 99

H11 HOUSING ON BROWNFIELD SITES 91

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5.19 SHELTERED HOUSING 100 5.1 INTRODUCTION H25 SHELTERED HOUSING 100 5.1.1 This chapter contains policies covering new housing of all types, 5.20 ACCESSIBLE HOUSING 100 created both from conversion and new development. Policies on mixed-use development are contained in the Built Environment H26 ACCESSIBLE HOUSING 101 chapter. The Employment chapter contains special policies on office conversions and work-live development. 5.21 HOSTELS AND HOMELESS 101 ACCOMMODATION 5.1.2 The Council's roles as a planning authority and a housing authority are distinct but complementary. Increasing the quality, provi- H27 HOSTEL ACCOMMODATION 102 sion and affordability of housing in the Borough will require a partnership between a variety of private housebuilders and landlords, 5.22 GYPSY / TRAVELLERS SITES 102 registered social landlords and the Council in its roles as both housing and planning authority. In line with national policy, Brent H28 GYPSY / TRAVELLERS SITES 102 closely allies its housing strategy and its UDP. The housing strategy will regularly assess housing needs in the Borough.

APPENDIX H1 KEY HOUSING INFORMATION 103 5.1.3 As a housing authority the Borough has published its Housing Strategy 2002-2007 which has (among others) the following APPENDIX H2 SECURING AFFORDABLE HOUSING 104 aims:

APPENDIX H3 THE CALCULATION OF DENSITY 104 1. To increase the supply of affordable housing and thereby reduce homelessness. MAP H1 MAJOR ESTATE REGENERATION 2. To improve the quality of existing stock; AREAS 105 3. To integrate housing issues with other corporate plans and initiatives; MAP H2 DISTRIBUTION OF SUPPORTED 4. To link housing regeneration with other regeneration projects. HOUSING IN BRENT 106 5.2 BACKGROUND

5.2.1 Shelter is one of the most fundamental human needs. The issue of meeting the housing needs arising from the projected additional '4.4 million households' has become the centre of media attention. A recent Government policy announcement (Sustainable Communities: building for the future, 2003) seeks to significantly increase the amount of housing built on previously developed land within urban areas. This chapter seeks to positively meet this challenge.

5.2.2 The other key factor highlighting this as a priority is the Brent housing needs and conditions surveys - indicating that Brent has one of the highest levels of housing need - and some of the worst housing conditions - in the Country. Brent has one of the highest number of families in temporary accommodation in London. However, previous UDP targets for affordable housing provision have not been met. This is a social exclusion issue that affects all Brent residents because of the exceptionally high costs of temporary accommodation as a result of the shortage of permanent affordable housing. The programme to rebuild most of the Council's major social housing estates has also come forward.

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HOUSEHOLD CHANGE; NATIONALLY AND LONDON 5.2.8 As the Census is only undertaken every ten years and does not provide all the necessary information on housing needs and 5.2.3 In 1999, the ODPM published 1996 based household projections. dwelling stock condition, the Council regularly carries out its own Taking England as a whole there will be an extra 3.8 million Housing Needs and Stock Condition Surveys. The surveys households projected to form between 1996 and 2021. However undertaken in 1997 and 2002 informed the review of the previous they are trend based and are simply projections - the Government UDP (1996). The 2003 Housing Needs Survey encompassed all uses them to inform policy. tenures whereas the complementary Stock Condition Survey excluded the Council’s own housing stock (about 10,000 5.2.4 Taking the 1996 based household projections at their face value, dwellings). Both surveys were undertaken in accordance with if directly translated into policy then London would require an Government guidance (Local housing needs assessment: a increase of 21.4% in its number of dwellings. The projected guide to good practice, ODPM, 2000). These surveys enable an increases approximate to two additional boroughs in terms of evaluation of the Borough’s housing position against other metro- population and six additional boroughs in terms of households. politan and national data bases, such as the English House Of the projected national growth in the number of households Condition Survey (2001). 57% arises from population growth, 20% from changes in the age structure, and 23% from changing family structures. Around 70% 5.2.9 Their key findings are summarised below and will be updated reg- of the growth is expected to consist of single-person households, ularly: arising from divorce and separations, people choosing to live alone (of all age groups, and for longer periods of time), and peo- • 20,404 households live in statutorily unfit and overcrowded ple living longer and outliving their partners. The increase in the etc housing (20.3%). population is due to inward international migration and fewer • Brent is the fourth most overcrowded London borough. deaths not being offset by fewer births and decreased outward • 90% of those whose housing is so poor they need rehousing migration. cannot afford market housing. • Residents median household income (excluding benefits) 5.2.5 Recent GLA projections show that: was £16,063. • 4116 ‘homeless households’ are in Council temporary accom- • The number of households in London is projected to increase modation; largest number in West London by 20,700 each year to 2016; • Brent needs at least 3,386 new affordable homes annually. • 70% of the growth will be one person households, predominantly single men and divorcees; 5.2.10 The reasons for the overall very high level of need are numerous • 70% of the additional households will need social rent or but include: intermediate affordable housing provision. • The very poor state of much of the housing stock, over 70% is at least 60years old; significantly higher than most boroughs; HOUSING PROVISION AND NEEDS IN BRENT • Poverty due to the high level of households with special needs; 5.2.6 The Census (2001) identified 261,232 residents living in 99,991 • High land prices in London; individual households with an average household size of 2.6 per- • Low pay in much of the Brent economy; sons, representing an overcrowding level of 24%. These figures, • Large household sizes leading to overcrowding; substantially higher than most London boroughs, reflects Brent’s • Growing numbers on council and housing association waiting distinct ethno-cultural demography, which makes the Borough lists; one of the few authorities in England where ethnic and cultural • General growth in household formation; minority residents comprise the majority of the population. This is • Growing levels of homelessness and families in temporary likely to contribute towards a substantially greater growth in new accommodation; and households than in London generally (20% :14%, GLA Population • Loss of units as a result of estate development. Forecasts). 5.2.11 Whilst, in previous years, providers of affordable housing have 5.2.7 Slightly more Brent households live in houses (54%) than in flats been successful in securing larger sites at a period of depression (46%). The relatively high respective proportions of households in the housing market; this period has come to an end and larger living in semi or detached houses (35%) and in purpose built flats sites seem to be in increasingly short supply. This situation has (27%) illustrates the range of Brent’s dwelling stock and the been exacerbated by Right to Buy social rental stock loss, the Borough’s diverse townscape; which ranges from suburbia in the implications of the Borough's Estates Regeneration programme North to very dense inner city streets of terraced houses and flat- and the Government’s ‘Decent Homes by 2010’ improvement ted blocks in the South. Just over half of Brent households live in strategy. owner occupier homes (54%), with most of the remainder either renting from a social landlord (25%) or privately (17%) . Appendix 1 provides more key housing data from the Census and other sources.

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5.3 STRATEGIC CONTEXT importance of socially inclusive communities and stresses that “The planning system has an important role in creating communi- 5.3.1 This section covers the broad thrust of national, regional and met- ties with a better mix of housing- in terms of size , type and afford- ropolitan strategy to ensure sustainable housing development. ability - than is currently available.” (para. 1). Policy on specific topics (such as provision, density and affordable housing) is covered in the specific sections. REGIONAL STRATEGY 5.3.8 Regional Planning Guidance for the South East (RPG9, 2001) NATIONAL HOUSING AND PLANNING stresses that the provision of housing should be achieved without STRATEGY continuing the trend to more dispersed and land-intensive pat- 5.3.2 The evolving Government strategy on sustainable housing devel- terns of development. It recognises the need for a plan, monitor opment, including the growing emphasis on affordable housing and manage approach. It proposes provision for an average of provision, was generally set out in Towards an urban renais- 23,000 dwellings per year in London. Dwelling completions sance (2000) and more specifically in The Way Forward for should be monitored and provision levels reviewed at least every Housing (2000). This strategy has been, recently, further elabo- 5 years. At least 60% of all new housing development in the rated in Sustainable Communities: building for the future (2003) region should be on previously developed land. Targets for which emphasises that a key requirement to ensure socially affordable housing should be set locally and sufficient affordable inclusive sustainable communities is; housing should be provided to meet locally assessed needs. “A well-integrated mix of decent homes of different types and tenures to support a range of household sizes, ages and METROPOLITAN STRATEGY incomes...” (page 4). 5.3.9 Sustainable communities in London: Building For The Future (ODPM, 2003) sets out the Government‘s strategy for new 5.3.3 The Government’s planning strategy for housing provision pro- housing provision in London, to be overseen by the London poses regionally led strategies to revitalise towns and cities and Housing Board which will regularly publish a London Housing protect the countryside by making the best possible use of recy- Strategy. This Strategy encourages the preparation of sub cled land. It proposes to raise the national proportion of new regional strategies, such as Building Communities: A Housing homes to be built on previously developed land to 60 per cent Strategy For West London (2003) which has been prepared to over the next 10 years, which will be refined in the light of regional co-ordinate the housing and planning strategies of seven bor- targets. It emphasises that national household projections are oughs, including Brent. guidance not building requirements. 5.3.10 Strategic Guidance for London Planning Authorities (RPG3, 1996) notes the limited supply of land in London and the imbal- 5.3.4 This 'Plan, Monitor and Manage' approach will be subject to mon- ance between supply and demand for housing; especially in the itoring by the Secretary of State "we need to avoid unduly restrict- light of projections of increased population and a proportionately ing supply and thus increasing the pressure on the ability of both greater increase in the number of households. As a result it the social housing and market housing sectors to maintain the advises that: supply of affordable housing" (Planning for the Communities of the Future, 2000, para 22). Local authorities have to monitor and “Boroughs should seek to make the maximum contribution to report on the effects of their decisions. meeting the demands for housing in London and to encourage the provision of well designed housing of all types whilst safe- 5.3.5 Planning Policy Guidance Note 12 Development Plans (PPG12) stresses the importance of identification of sources of land sup- guarding the quality of the environment.” (para. 4.1). ply, in particular the use of the National Land Use Database. Development should be related to infrastructure and there should 5.3.11 RPG3 requires Brent's UDP to demonstrate how the Borough will be targets for development on previously used sites. exceed the minimum revised allocation of 6,850 dwellings from 1992-2006 (LPAC 1994 housing capacity study). Over 5,700 had 5.3.6 Planning Policy Guidance Note 3 Housing (PPG3, 2000), which already been completed between 1992 and 1999. RPG3 provides the Government’s primary planning guidance on sus- requires Boroughs to allocate sites for housing development tainable housing development, advises local authorities to pro- where “...other uses are unlikely to come forward.” (para. 4.14). vide sufficient housing to meet the requirements of the whole Boroughs are required to have regard to four components of new community, including those with special needs and for affordable housing supply (para. 4.6), and UDP policies to maximise housing, and to provide this housing as part of mixed communi- dwelling provision should be tested against them (para. 4.9): ties. PPG3 gives priority to re-using previously developed land within urban areas and creating more sustainable patterns of New dwellings provided on sites redeveloped or made avail- development. This is achieved by exploiting sites accessible to • able from other uses, including a housing component in suit- public transport, encouraging mixed uses, and by accommodating higher densities through changed design standards but able mixed use development; ensuring that good design creates high quality environments in • The adaptation of existing buildings in other uses for housing; which people will choose to live. • The redevelopment of land used for housing to a higher density; 5.3.7 The Government has recently indicated its intention to significant- • The conversion of the existing housing stock for occupation ly revise PPG3 and has published a draft (Influencing the Size, by more households Type and Affordability of Housing, 2003) which emphasises the

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5.3.12 RPG3 will soon be replaced by the Mayor of London’s Spatial NEED FOR ADDITIONAL AFFORDABLE Development Strategy for Greater London (The London Plan) HOUSING which is fundamentally based on the concept of the socially inclusive ‘compact city’, in which brownfield land is maximised for new 5.5.2 Brent has regularly assessed the Borough’s growing affordable development, through higher densities, in areas with good public housing needs in surveys undertaken in 1997, 2002 and 2003 (all transport accessibility, and mixed use schemes, so as to maintain by Fordham Research Services). Brent’s 2003 Housing Need existing open spaces. The draft London Plan includes housing Survey employs the Government’s preferred definition of afford- targets for the London boroughs, based on the Borough’s esti- able housing need as; mates of housing capacity, to enable the provision of the estimated additional 23,000 homes (50% affordable) that London annu- “households lacking their own own housing or living in housing ally requires to meet the housing needs of a projected 700,000 which is inadequate or unsuitable, who are unlikely to be able to additional residents by 2016. This forms the basis of the housing meet their needs in the housing market without some assistance” requirement figures set out in this Plan which is statutorily (Local Housing Needs Assessment: A Guide to Good Practice, required to be in ‘general conformity’ with The London Plan. ODPM, 2000, page 116).

5.5.3 This very restrictive definition therefore excludes lower income 5.4 BOROUGH POLICY OBJECTIVES households who are concerned about the insecurity of their, short term, private tenancies and hence would prefer social rental 5.4.1 Taking into account the state of Brent's housing and the accommodation. It also effectively ignores high rental cost con- Borough's housing need, and the various requirements of govern- cerns as it assumes a potential housing benefit subsidy, even ment policy and guidance, the objectives of the Unitary though this may frustrate access to much private rental housing. Development Plan's policies towards sustainable housing development are as follows: 5.5.4 Brent’s Housing Needs Survey uses the, Government recommended, Basic Needs Assessment Model which involves the 1. To ensure the development of mixed and balanced residential evaluation of existing and estimated newly arising housing needs. communities where areas suffering from social exclusion are Any household need which can be resolved through the improve- regenerated; ment of their existing accommodation or the ability to afford the 2. To significantly increase the supply of affordable dwellings; required type of accommodation, is discounted to establish the 3. To give Borough residents the opportunity for a decent home by minimum essential affordable housing need of 6,430 dwellings. making reasonable dwelling provision to meet household This figure is further refined, to include an annualised ‘backlog’ growth; reduction and offset against recent affordable housing relettings 4. To improve the existing dwelling stock; and new provision, to generate a net affordable housing require- 5. To regenerate the major run-down estates in the Borough; ment of 3,386 dwellings a year. A figure several times in excess 6. To link housing regeneration with other regeneration pro- of recent annual total new housing provision in Brent and almost grammes; ten fold the new affordable housing provision level; graphically 7. To ensure the participation of local residents in meeting their illustrating the Borough’s acute affordable housing need which is housing needs; significantly in excess of the total housing target from 1997 to 8. To ensure that new dwellings are located where they will min- 2016 as set out in Policy H1. imise energy use and the need to travel and maximise the re- use of previously developed urban land; 9. To ensure that new housing is provided alongside its necessary THE BRENT HOUSING PROVISION STUDY new infrastructure, open space and community facilities; and 1999 10. To ensure that the needs of Borough residents with special housing need is met. 5.5.5 In order to comply with the requirements of RPG3 to estimate the extent to which earlier estimates of the supply of new housing can be increased, the Borough has carried out a detailed study of the 5.5 BOROUGH STRATEGY potential provision of new housing, in conjunction with a Londonwide study (London’s Housing Capacity, GLA, 2000) and 5.5.1 Brent's aim is for everybody to have the opportunity for a decent the National Land Use Database (a study of previously developed home. Brent's overall strategy is to achieve mixed and balanced urban land available for development). The study also examined communities of quality housing where social exclusion is tackled, the rate at which previously unidentified sites (so called windfall making best use of previously developed land and buildings. This sites) have been coming forward. The study examined two will mean both improvements to the existing stock and new build- aspects which may affect current completion and windfall trends. ing; with particular priority to the regeneration of the major Firstly, by comparing past sources of housing land by land-use to estates. potential development sites that came forward through the National Land-Use Database the Council has been able to estimate the degree to which these trends could be continued in the

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future. Secondly, the Council assessed the potential increases in 5.5.11 These provision levels have been set on the assumption of provision that could arise through the four changes in supply indi- windfall rates being maintained and sufficient financing by the cated in RPG3. public sector or otherwise in order to support these additional dwellings. If these assumptions prove not to be correct, or if one 5.5.6 Walkable Neighbourhoods; changes in density policy and car- or more particular sources of supply perform less well or better parking standards will increase this level of provision, by adopting than expected, it does not imply that other sources of supply the ‘Sustainable Residential Quality’ (SRQ) approach towards should be adjusted accordingly. The Council will monitor overall assessing housing provision focusing on such neighbourhoods, completion levels and, as part of the overall 'plan, monitor and where new housing can often do most to sustain the vitality of manage' approach, assess in future regular reviews of the Plan those centres and where the need to travel can be minimised. what action needs to be taken. The most potential for housing was found to lie at the edges of town centres and restricting residential parking could significantly MAKING BETTER USE OF EXISTING increase potential capacity. This approach endorsed in Policy PROPERTIES STR19 will involve new site survey work and a 'design-led' approach where the potential for housing on each site is 5.5.12 One key way where the activities of the Council can meet both assessed individually. Such 'walkable neighbourhoods' are housing need and support other planning objectives is through defined for the purposes of this Plan as that area within reason- making better use of existing vacant property, in accordance with able (600m) walking distance of a district or major town centre - PPG3 (paragraph 41) and RPG9 (Policy H4). For example, in measured by actual walking distance and excluding barriers such 1997 the Council launched it's Empty Property Strategy. About as major roads. half of all empty homes are due to house sales / deaths / moving into care etc. But the overall number is unacceptably high and 5.5.7 The outcome of the study is that current housebuilding rates can the national aim is to reduce it from 5% to 3%. broadly continue through some increased use of previously developed land and slightly increased densities. It is therefore 5.5.13 The Council Tax Register indicates 5,268 empty homes in the proposed to set (in Policy STR18) an additional dwelling target of Borough in 2003, the vast majority being in the private sector. 9,600 (minimum) between 1997 and 2016 (an average of 480 77% of the 4,272 private owned empty homes have been vacant units / year). This figure encompasses sites identified within the for more than six months, representing 4.6% of all privately Plan, windfall sites, changes of use to housing and conversions. owned housing stock. Whereas, all of the public sector’s (Council and Registered Social Landlords) 663 void (empty) dwellings are 5.5.8 The study examined how affordable housing policies in the either between lettings or in housing regeneration schemes. A replacement plan would apply, resulting in approximately 2,600 dedicated empty property team is working with the private sector, additional units. Together with additional sites purchased outright promoting flats above shops and encouraging housing use not by registered social landlords on projected levels of funding a tar- just of empty homes but empty properties in general suitable for get was set, as part of the overall housing target (in Policy residential use. STR18) of 4,800 additional affordable dwellings (minimum) between 1997 and 2016 (an average of 240 units per year). Without the strong policies in the Plan it would not be possible to attain this rate and the housing performance of the Borough, as assessed by GOL, would fall, leading to a substantial cut in Government funding. Even with this additional housing most of the new households in housing need would have to be housed, at least temporarily, in subsidised private sector housing (at considerable cost to the taxpayer).

AFFORDABILITY & THE PLAN STRATEGY 5.5.9 The Boroughwide target will be a guide in allocating and negotiating on individual housing sites as to how much affordable housing will normally be expected to be secured. Brent will carefully mon- 5.5.14 Because Brent has some of the highest housing needs in itor the progress of affordable housing completions and permis- London, with relatively high housing prices, but lower than the sions (see Appendix 1) and the development of housing need, London average household income (£21,552 as compared to proposing adjustments to the affordable housing target where £27,000), and given the importance of the planning issues sur- necessary. rounding estate regeneration, the Plan priorities affordable housing (Policy STR1). This would not mean that affordable housing 5.5.10 The Borough proposes to work closely with other boroughs, par- would predominate over other land uses - the Council would still ticularly its West London Sub Regional Housing Strategy part- continue its aim of an overall balance and distribution of land ners, and strategic bodies on a unified approach to the assess- uses, and given that these are mostly small sites set against a ment of affordable housing needs and targets and to ensure that residential backdrop this aim would be strengthened. Nor would it all boroughs reasonably contribute to meeting London's housing mean a lessening of a commitment to regeneration. After all peo- needs. ple only need affordable housing when they have no job, have low household income or cannot work.

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5.7 AFFORDABLE HOUSING POLICIES AND PROPOSALS 5.7.1 This section looks at exactly what 'affordable' housing means in the Brent context, how much of it is needed in the Borough and how it might be provided. Affordable housing does not mean 5.6 ADDITIONAL HOUSING 'council housing'; it is an objective term relating cost of housing to 5.6.1 Brent’s additional housing figures have been incorporated into the income, rather than specific to a tenure. However, it is the cost of GLA’s London Housing Capacity Study which the Government general market housing (such as housing for sale freehold / has accepted in RPG9. As well as bringing empty housing into leasehold or private sector housing for rent) that necessitates a use, empty and underused buildings can be converted into new 'social housing' sector - this can span local authority housing, housing, as promoted in PPG3. Making good use of previously housing associations, trusts, co-operatives and similar bodies - developed land can also be a sustainable use of existing generally for rent but also including various forms of shared own- resources. ership and subsidised housing to buy and rent at below market cost. The majority of affordable housing in the Borough is no 5.6.2 The draft London Plan, 2002, sets out in Table 3A.1 additional longer Council managed. homes targets for London 1997-2016. It requires Brent to provide 13,510 extra homes between 1997 and 2016. This is based on NATIONAL POLICY CONTEXT the Housing Capacity Study published by the GLA (2000). Brent’s capacity for new self contained dwellings, to be produced 5.7.2 PPG3 states: that a community's need for a mix of housing types, including affordable housing is a material planning consid- through new build and conversion, is 9,647 with a potential total of eration which should be taken into account in formulating devel- 13,510 homes including non self-contained dwellings and vacant opment plan policies. dwellings brought back into use. These capacity figures are rounded up in The draft London Plan and form the basis of 5.7.3 Circular 06/98 Planning and Affordable Housing, states that the Brent’s additional housing requirements from 1997 to 2016. aim of Government policy is to secure mixed and balanced communities to avoid areas of social exclusion. Where affordable 5.6.3 The additional housing target will be comprised of housing on housing is to be provided the preference is to provide it as part of small and large sites, office conversions, conversions of residen- the development. Affordable housing encompasses low cost tial dwellings and work-live units. The supply of housing is set out market and subsidised housing that will be available to people in the GLA’s Housing Capacity Study 2000. Also identified in this who cannot afford to rent or buy homes generally available on the study was an element of windfall dwellings. This is supply that is open market. anticipated given current and future trends but not yet identified on particular sites. These various components of housing supply 5.7.4 Authorities should make a rigorous assessment of need for will be monitored over the Plan period to identify the contribution affordable housing. Where the assessment demonstrates a need each will have, to meet or exceed the Plan’s housing targets. then local authorities should include in the Plan a policy for seeking an element of affordable housing on suitable sites and indi- 5.6.4 The housing development trend in recent years indicates that cate in the Plan how many affordable homes need to be provided Brent is on target to meet its capacity allocation as permissions in the Plan’s area(s). In assessing the suitability of sites for afford- and completions rates are exceeding the GLA’s annual monitor- able housing (including windfall sites) the planning authority ing indicator of 480 new self contained dwellings per year (see should take into account site size, suitability and the economics of Appendix 1). provision and the need to secure a successful housing development.

H1 ADDITIONAL HOUSING 5.7.5 Draft PPG3 proposes the cancellation of Circular 6/98 in favour of giving local authorities substantially greater flexibility in securing A net addition of at least 9,650 (480 per year) new the level and types of affordable housing that best meet their local dwellings (13,510 including vacancies and non-self- identified needs. This would permit authorities to further reduce contained dwellings) should be provided between site size thresholds and define specific tenures to satisfy afford- 1997 and 2016 (of which at least 4,800 of the new able housing needs, which may exceed overall housing provision. dwellings should be affordable), subject to suitable Draft PPG3 also proposes to remove the Circular 6/98 presump- locations (Policy STR19) and the maintenance of a tion that ‘low cost market housing’ is universally ‘affordable’. quality environment. REGIONAL POLICY CONTEXT

5.7.6 RPG9 specifically recognises the need for substantial new affordable housing provision in the South East (para 8.7) by setting out indicators equivalent to 42% - 44% of the total dwellings provision being affordable (Policy MON1).

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METROPOLITAN POLICY CONTEXT boroughs rather than most Outer London ones. The 'official' definition of 'Outer London' is based on the historic boundary of the 5.7.7 RPG3 states that UDP policies on affordable housing are best London County Council - rather than modern day realities. It is implemented by taking a clear and consistent view of the needs of argued then that Brent is best characterised as an 'Inner London' the Borough in the context of London as a whole. RPG3 sug- borough for purposes of this threshold - especially as Brent is gests that Boroughs should; “...identify sites or areas which are considered an Inner London borough by the Housing particularly suitable for affordable housing...” (para. 4.21). Corporation; and that a realistic threshold of 15 units / 0.5 Ha should apply. Particularly as the housing provision study shows 5.7.8 The Government’s national affordable housing strategy as specif- that in comparison to the proposed threshold the Circular thresh- ically applicable to London has been recently elaborated in old would only result in just over 500 affordable units from identi- Sustainable Communities in London: Building For The Future fied sites, as there were few previously developed large sites, (2003) which notes with particular concern that; with a predominance of small sites. But these small sites could provide 200 extra affordable units with the lower threshold. “The demands of the capital’s economic and population growth have not been matched by an increase in the supply of housing . 5.7.13 The Council will encourage the provision of affordable housing Skills shortages are often linked to a lack of affordable housing below the ‘Inner London’ threshold and will have regard to the which is pricing key workers out of the housing market.” (page 4). Mayor of London’s proposals in The draft London Plan not to include a site threshold for affordable housing. 5.7.9 The draft London Plan emphasises the key importance of affordable housing and proposes that 50% of all new dwellings should THE DEFINITION OF AFFORDABILITY be affordable. It specifically indicates, on the basis of detailed housing market viability research, that this target should be attain- 5.7.14 The Council is proposing to follow, as the basis of policy, the able in boroughs with land values and house prices such as in RPG3 definition of affordable housing as housing affordable to Brent. “...households...in unsuitable accommodation and [who] cannot afford market housing...” (Para. 4.21). “Affordable housing is here 5.7.10 The Draft London Plan (DLP) Policy 3A.8 specifies that the 50% taken to mean both subsidised and market housing designed for affordable housing element should be provided on the basis of those whose incomes generally deny them the opportunity to pur- 35% social rental and 15% intermediate housing which are chase houses on the open market, as a result of the local relation- defined as: ship between income and market price.” (para 4.19). None-the- less this 'local relationship' needs to be elaborated. The formula “Social Housing - Housing usually provided by a Registered used by the policy is based on typical lending formula for mort- Social Landlord or Housing Authority, using public subsidy, at lev- gages and ODPM suggested maximum rental levels els no higher than Housing Corporation target rents.” (DLP, para. (source:Appendix A2 Brent Housing Needs Survey 1998). It does 3A.31). not imply regulation of housing association rents and is entirely neutral of tenure, as any tenure falling below the definition will be “Intermediate Housing - Sub-market housing substantially above regarded as affordable. Housing Corporation target rents, but substantially below open market levels. This category includes low-cost home ownership 5.7.15 None-the-less RPG3 recognises, however, that “Boroughs may schemes and key worker housing. It may also include some low find this need can only be realistically met through the promotion cost market housing where its price is close to other forms of of subsidised housing (whether in the public or private sector).” intermediate housing.” (DLP, para. 3A.31). (para. 4.19), and Brent falls into this category. It is accepted that 'typical' outgoings for some specialist forms of accommodation THE AFFORDABLE HOUSING SITE SIZE may be, of necessity, higher than normal, e.g. key workers hous- THRESHOLD ing / homeless persons accommodation. To meet the meet the definition of affordable housing, housing must be so in perpetuity, 5.7.11 The 'size-threshold' is the level above which 'large' housing sites i.e. affordable to both initial and subsequent occupiers. The should include affordable housing. Circular 06/98 classifies Brent involvement of a registered social landlord is considered sufficient as an Outer London borough which has higher site size threshold to meet this test. (25 dwellings) than Inner London (15). However, it does concede that some authorities may be able to demonstrate exceptional 5.7.16 The Brent Housing Need Survey 2003 established that it is nec- local constraints which may justify a lowering of the higher thresh- essary to ensure a satisfactory range of affordable dwelling type old. This flexibility is substantially expanded in the proposed revi- and size to meet the Borough’s specific need to accommodate sions to PPG3 which seeks to have a lower nation wide threshold family households, as it requires a minimum household income of of 15 dwellings, which may be further reduced if the local authori- £46,000 (assuming £10,000 savings) to purchase the cheapest ty can justify this in terms of acute housing need. two bed flat in Brent. Larger families, who particularly tend to require affordable housing, face a very significant shortfall 5.7.12 In terms of almost every conceivable measure - overcrowding, between the estimated demand and supply of three (866 : 115) housing need, poverty, demographics, regeneration needs etc. and four or more bedroom (744 : 28) affordable units. Brent most closely matches the characteristics of Inner London

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5.7.17 The Survey also found that about a third of the households in Definition of Affordable Housing: a dwelling is defined as housing need, mostly requiring one and two bedroom dwellings, affordable housing where it has the smallest number of would be able to afford intermediate housing, including shared rooms appropriate to alleviate the needs of a household equity housing. Therefore, shared ownership housing will have a in unsuitable accommodation, which cannot afford to supporting role to play in contributing to meeting part of this need. pay an amount on that property equivalent to:- one third of gross household income on a mortgage or renting tak- 5.7.18 'Priority need' as defined by Section 59 of the Housing Act 1985 is ing up 35% of net household income. This should principally where the applicant, or person who might reasonably equate to a periodic outgoing for the household on rent, be expected to reside with them, has dependent children, is preg- lease or mortgage equivalent to that for similar accom- nant, or is vulnerable through mental or physical illness, modation provided by registered social landlord in the disability or old age. Borough for accommodation of similar size and quality (as listed in the annual housing strategy).

THE PROPORTION OF AFFORDABLE HOUSING SOUGHT

5.7.19 Because of this scale of need for affordable housing there is a strong case that the maximum reasonable proportion of the total UDP housing provision (as stipulated in The draft London Plan Policy 3A.7) should be allocated as being for affordable purposes, having regard to the Boroughwide target (Policy STR18). The policy below sets out the criteria listed in national, regional and metropolitan policy. In carrying out its housing provision survey the Borough has analysed sites with regard to their suitability for affordable housing by the factors listed in this policy. The Council H2 REQUIREMENT FOR AFFORDABLE has also increased certainty; by specifically identifying large HOUSING housing and mixed-use sites on the proposals map where this would not prejudice other planning objectives, and indicative Housing developments in the Borough capable of pro- affordable housing targets are set in the site specific proposals viding 15 or more units gross, or 0.5 Ha or more in size chapter, for sites not solely allocated for affordable housing. (irrespective of the number of units), should, where Major town centre opportunity sites (where the priority is for town suitable according to Policy H2, include provision for centre uses such as retail and leisure) have not had targets set. affordable housing on-site (other than where Policy Moreover, policy guidance in Circular 06/98 and RPG3 now H4 applies). This should contribute towards the require that where affordable housing polices have been included Boroughwide target for affordable housing and be in development plans, local authorities should develop both plan available to Borough residents (both initial and subse- area wide targets and indicative site specific targets for affordable quent occupiers). The artificial subdivision of sites housing provision. with the effect of circumventing this policy will not be permitted. The Council will encourage provision of 5.7.20 In order to arrive at Boroughwide and site specific targets howev- affordable housing on suitable sites below the thresh- er it is necessary to set a target percentage based on the range of old set out in this Policy. typical site conditions - as well as for a basis for negotiation on future windfall sites. The level has been set based on what has A range of unit sizes of affordable housing, having been achieved through operation of the previous interim policy, regard to local circumstances and site characteristics, and is therefore considered reasonable, having regard to the should be provided. Where this is being provided by exceptional level of housing need, and relative shortage of large registered social landlords the requirements of those sites (referred to in section 5.5). The dwelling mix of the afford- in 'priority need' should be determined following con- able proportion would need to meet the requirements of those in sultation with such bodies. priority need following consultation with registered social landlords operating in the Borough. Units should also meet Housing The tenure of different elements of a scheme should Corporation Scheme Development Standards. not be apparent from the siting, design or layout. 5.7.21 Affordable housing can sometimes be more difficult to secure as The affordable element should be available for occu- part of conversions from other land-uses (e.g. offices) than for pation at the same time as other elements or sooner new-build sites, for example because of management problems as may be appropriate. of affordable and general market housing within the same building. A similar situation may apply to work-live schemes, where the residential element may generate an affordable housing liability. Therefore, when such housing is provided regard will be had

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to the special opportunities or constraints of the site in consider- Brent? Such proposals need to demonstrate that it would not ing whether or how much affordable housing should be provided occupy a site suitable for those in priority need (i.e. family hous- on-site (there may instead be opportunities for provision-in-lieu ing), which could increase overall homelessness. where on-site provision is impractical). This flexible approach would recognise that these potential constraints may not apply 5.7.27 Affordable housing will generally be secured by the means set out and the building can be easily convertible to affordable housing. in Appendix H2.

5.7.22 The RPG3 definition of affordable housing includes both low cost market housing and subsidised housing. However the housing H3 PROPORTION OF AFFORDABLE needs study shows the disproportion between Brent's low HOUSING SOUGHT incomes and high house prices meant that low-cost discounted general market new-build (as well as work-live proposals) would In assessing the scale of affordable housing required be unlikely to meet the affordability criteria of any of those in of sites above the size threshold (Policy H1), the maxi- housing need. This being more expensive than the cheapest mum reasonable proportion of affordable housing will general market converted accommodation. Such housing would be sought and secured (generally 30%-50% of units be less unaffordable, but it would not meet the definition of afford- on suitable sites) having regard to the Boroughwide able; this reality has been recently recognised by the proposed target (Policy STR18), & to the following factors: revision of PPG3. The policy set out below recognises the sup- (a) Any exceptional costs associated with the site plementary role that such housing plays to affordable housing. It above those normally encountered; is also inappropriate to use the proposed lower car parking standard for low-cost general market housing as they have higher car (b) The physical suitability of the site for affordable ownership. housing; (c) The walking distance of the site to a shopping cen- 5.7.23 The Brent Housing Survey 2003 estimated that about 32% of tre & local services; households requiring affordable housing could potentially avail of (d) The public transport accessibility of the site; (sites intermediate housing. However, this was largely restricted to with good or very good accessibility are considered those needing only one and two bedroom units and even in this particularly suitable); category was mainly confined to the cost bands just above social (e) The housing needs of the local area and the need to rental levels and very much below market rental and purchase secure a mix of housing types, sizes and levels of prices. This situation has therefore been reflected in the Council’s affordability in the locality; draft Supplementary Planning Guidance on Affordable Housing (2003) which normally specifies a ratio of 70% rental and 30% (f) Any site-specific indicative target (set out in site intermediate units in accordance with The draft London Plan specific proposals) assessed by these criteria; and Policy 3A.8. (g) The costs associated with the achievement of other planning objectives. 5.7.24 Particular considerations apply to sheltered housing, a very specific segment of the housing market, and where their relative low For developments involving conversions of buildings cost is a significant selling point. However, as Circular 6/98 states from other land-uses, where the site is suitable for “...local assessments of needs for affordable housing may show redevelopment, the special opportunities or con- that there are elderly households who cannot afford sheltered straints of the building will be considered. housing provided by the market.” (footnote 2). This is the case in Brent where the Council’s draft Older Persons Housing Strategy For developments involving conversions of buildings (2003) has estimated that Brent has a very substantial need for from other land-uses, where the site is suitable for additional affordable, primarily social rental, sheltered accommo- redevelopment, the special opportunities or con- dation. straints of the building will be considered.

5.7.25 In order to meet the housing needs of Borough residents, affordable housing not available to Borough residents (through being on the housing register of another borough, for example) would OFF SITE PROVISION-IN-LIEU not count towards the Boroughwide or any site specific target. However this is acceptable providing that the affordable housing 5.7.28 Brent only accepts cash-in-lieu provision of affordable housing, in component normally required is available to Borough residents very limited circumstances as: elsewhere in the development. • They mitigate against mixed communities and socially bal- 5.7.26 Policy H3 will be used to assess proposals for ‘key-worker’ hous- anced development; ing (e.g. nurses, teachers etc. see glossary.). The tests are the • They usually result in less affordable housing being provided; same as for all affordable housing, is it affordable? how will this • The calculation of the cash payments can be more complex be secured? would it be for Brent’s needs e.g. an institution in to calculate and administer than on-site provision; and

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• In Brent and other areas the shortage of sites for affordable who need / are likely to move cannot afford market housing and housing can be more pronounced than a shortage of housing 26% will be dependent on social rental housing. Most of the 31% finance. who can potentially afford intermediate housing can only do so at the lower end of the cost spectrum. The Survey estimated a key- 5.7.29 On most housing sites, there will be no reason why affordable worker affordable housing need for 356 homes per year of whom housing could not be provided. Circular 6/98, PPG3 and the draft 137 require three or more bedrooms, indicating the need to London Plan all state a presumption in favour of providing afford- ensure that key worker housing provision satisfies the full range able housing as part of the development. Failure to do so could of household demographic requirements. justify refusal of planning permission. It will only be where, for example, a flatted development cannot reasonably be divided into affordable housing units or where service charges for the scheme make units unaffordable that cash-in-lieu payments may be con- H5 KEY WORKER HOUSING sidered (The Council may seek justification of the service charge need and level). Key Worker Housing should include a proportion (30- 50%) of units affordable to those employees on low incomes. Key worker housing should not replace H4 OFF-SITE AFFORDABLE HOUSING - affordable housing for those in greatest housing need 'PROVISION IN LIEU' as set out in Policies H1 and H2 except where it:

(i) May be developed on sites where a high proportion Where affordable housing is appropriate this should of housing for those in greatest housing need is be provided 'in-situ' other than in exceptional circum- unsuitable (for example some sites in the Wembley stances. Regeneration Area); and

(ii) May assist in the economic viability of providing affordable housing on small sites.

5.7.30 The Council will set out in more detail how it calculates cash-in- Key Worker Housing should also: lieu payments in supplementary planning guidance on affordable (a) Give priority to employees working in Brent; housing. (b) Support a range of tenures; and

KEY WORKER HOUSING (c) Provide a range of dwelling sizes (except where a Brent employer has a specified need for a particular 5.7.31 Key worker housing usually refers to housing for key service size of accommodation). workers, essential to the economic functioning of a city (e.g. transport workers, health workers, teachers etc) but whose income may be insufficient for them to rent or buy on the open PROTECTION OF EXISTING AFFORDABLE market. Brent will support the provision of this housing where at HOUSING (INCLUDING HMOS) least a proportion is affordable (in this context meeting the housing needs of workers or households who earn between £12- 5.7.34 The following policy prevents this loss of existing affordable hous- 25,000 (at 2001 salary levels) and is delivered on sites that would ing, in accordance with RPG3 (para 4.29), unless the loss is the not otherwise provide affordable housing for those in greatest only means of securing essential improvements to the quality of housing need (set out in Policy H2). An appropriate proportion of affordable housing remaining / rebuilt on-site. In some cases key worker housing is also acceptable as part of the affordable there may be a need for a smaller number of larger units. housing requirements under Policies H2 and H3 where there is a Affordable housing is wider than that just within the C3 (dwelling) recognised local need for such housing. use class. It can include student and nurse hostels and houses in multiple occupancy (HMO) and the policy covers all of these. 5.7.32 Priority should be given to workers in Brent (a more sustainable Where affordable housing, such as hostels, is linked to an exist- approach) and schemes should provide a range of unit sizes. ing institution which is being relocated the affordable housing can Key worker housing will be particularly appropriate in areas where be replaced by housing at the new institution. 'high-need family-sized' housing is inappropriate on the scale envisaged under Policy H2 (see particularly Wembley Inset Plan). 5.7.35 The Council recognises that some residential accommodation It may also be appropriate to ensure the delivery of affordable that is not self-contained, including Houses-in-Multiple housing on small housing development sites where affordable Occupation (HMOs), meets an identified need for relatively housing is required. affordable accommodation and facilitates mobility of labour. The upgrading of such properties is a major priority of the Council. In 5.7.33 The Brent Housing Needs Survey 2003 specifically investigated some cases the self containment of a small proportion of units the particular housing requirements of the Borough’s key worker within an HMO may be permitted where it results in the upgrading residents (employed in the health, social services, education, of the remainder of units or facilitates management, unless the local government, public transport and the emergency servic- property is incapable of meeting modern standards. es).The Survey revealed that 57% of the key worker households

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• That though conventionally described as 'estates' many are H6 PROTECTION OF EXISTING actually widely varying in character and the solutions of some AFFORDABLE HOUSING (INCLUDING may arise through thinking beyond their boundaries and HMOS) beyond focusing on problems of the public stock alone; and that The net loss of affordable housing units (including • The needs of existing residents needs to come first - in that purpose built hostels and houses in multiple occupan- they already suffer from a poor environment. cy), or land part of affordable housing sites to non- affordable housing use, will be resisted unless this is 5.8.5 One of the key aims in each project has been to reduce their per- the only means of securing essential improvements to ception as 'estates' to break them into a series of smaller dwelling the quality of affordable housing remaining / rebuilt groups each better related in layout and form to adjoining streets on-site, or its suitability for residents in priority need, and housing. This may require thinking outside the traditional role or the property is incapable of being brought up to of the Council as landlord of public stock. The securing of Housing Act or Building Regulations standards. balanced and mixed communities may require increased general market / shared ownership housing - which may also provide gap 5.8 ESTATE REGENERATION funding. 5.8.1 The Government’s overarching ‘social inclusiveness’ strategy, 5.8.6 Most of the estates were developed in a predominantly flatted recognises the need to physically and socially regenerate poorly form. Resident consultation has previously found a strong designed and badly constructed, mono-tenurial, housing estates preference for more traditional forms of housing with gardens. On through multi agency programmes such as New Deals For Communities. A strategy supported by PPG3, RPG9, RPG3 and The draft London Plan.

5.8.2 A number of major Council estates count as amongst the most deprived areas in the Borough as judged by housing need, environmental, health, social and economic indicators. Most were built in the 1960s and 1970s, when there was a heavy reliance on Bison and Resiform system building methods. These methods have since proved to be problematic and to produce poor quality housing. By the 1990's many of the estates in Brent were in need of some form of redevelopment or refurbishment, in total over 9,800 dwellings were affected. To some estates this has led to a lowering of densities. The respond to this the Council has formulated its Estates anticipated scale of loss is fully accounted for in the Borough's Regeneration Strategy. The two principal aims of this are: provision study. The result of these programmes has also meant the loss of units (much of it unusable) but its replacement by new • The transformation of the housing stock on these estates into high quality affordable stock - surely a real gain in housing terms. high quality affordable housing through either refurbishment On estates programmes that might come forward - such as or redevelopment; and Brentfield and St Raphaels - there may be scope for raising • To achieve the renewal of local communities and improve the densities. quality of individual lives by associated social and economic development programmes. 5.8.7 In the case of South Kilburn, the whole of the former Carlton Ward (now split between the Queens Park and Kilburn wards) was 5.8.3 There can be no doubting the Council’s commitment to estate selected as a New Deals for Communities Area in May 2001, and regeneration: the redevelopment of the Chalkhill estate in Policy H7 applies to the whole area. Alternative regeneration Wembley Park is underway, as is that of the Stonebridge and strategies for redevelopment and / or refurbishment are being Church End estates. Proposals have been recently prepared for developed by the New Deals for Communities in partnership with the Barham Park estate. the Council and local residents as part of a Master Planning process. The Master Plan process will examine opportunities to 5.8.4 Because of the different status of each regeneration programme introduce a range of housing types and tenures, improved com- the UDP as a whole reflects: munity facilities and new leisure and health facilities. The South Kilburn Master Plan will form the basis for supplementary plan- • That those schemes that have been granted permission set ning guidance and once agreed will guide future development in precedents for the planning of the Borough as a whole - in the area. particular on overall dwelling provision targets; • That because of uncertainty over funding regimes and future 5.8.8 On some estates it may be necessary to decant residents to regeneration strategies the Plan needs to have a 'loose fit' housing outside the designated regeneration areas, as shown on approach to the form of redevelopment - if any - that takes the Proposals Map. This is to enable the initial phase of demoli- place in future projects; tion and redevelopment, or refurbishment, to proceed.

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H7 MAJOR ESTATE REGENERATION AREAS H8 RESISTING LOSS OF HOUSING

Development should not result in the net loss of resi- In the Major Estate Regeneration Areas (MERAs), as dential accommodation where such accommodation shown on the proposals map, refurbishment and / or can still be used, with or without adaptation, for per- redevelopment is sought and supported, and should: manent residential purposes; or loss of land within the boundary of sites in housing use to non-housing uses. (a) Demonstrate the full involvement of local residents in planning and design; Where a development entails demolition or other loss of dwellings, comparable replacement will be (b) Be according to a masterplan demonstrating how required. Specific exceptions to this policy are set out different phases of development / different design- in the Community Facilities chapter. ers are co-ordinated;

(c) Involve the minimum loss of existing affordable housing consistent with providing quality new stock of the form wanted by residents - and where off-site provision is needed demonstrate that this is feasible;

(d) Include a mix of house types/tenures, land uses, and community, facilities to help secure mixed and balanced communities;

(e) Ensure through an overall landscape design framework a proper balance between private and public open space with sufficient provision for children's play space and formal and informal public open 5.10 SELF CONTAINED HOUSING space;

(f) Be exemplars in terms of their approach towards NATIONAL AND REGIONAL POLICY CONTEXT design, telecommunications, energy / renewables and water use, re-use of materials and measures to 5.10.1 PPG3 advises that “Local authorities should take account of reduce the use of the car; and assessments of local need in determining the type and size of additional housing for which they should plan.” (para 11). The (g) Provide appropriate community, health, leisure and training facilities. proposed redraft of PPG3 goes significantly further in advising that “where there are appropriate local plan policies in place, local authorities should reject developments that conflict with the objective of widening housing choice” (para 15).

5.9 LOSS OF HOUSING 5.10.2 RPG9 states that “A range of dwelling types and sizes should be provided...” in local plans which should “...set out clearly the mix 5.9.1 The already noted Government guidance and The draft London of dwelling types and sizes that would reasonably be expected...” Plan’s emphasis on the need to increase housing provision clear- (Policy H4). ly infers a general presumption against loss of the existing dwelling stock unless there are justifiable reasons. It is a statuto- METROPOLITAN POLICY CONTEXT ry requirement that ‘Notice of Intent’ to demolish residential buildings must be given to the Council in advance of demolition. 5.10.3 RPG3 encourages “...a mix of housing types...” based upon the “...assessment of local needs...” (paragraph 4.20). The draft 5.9.2 The Brent Housing Needs Survey 2003 illustrates that the London Plan requires boroughs to ensure that “...new develop- Borough cannot afford to lose housing. Where a development ments offer a range of housing choices in terms of the mix of proposal entails demolition or change of use of residential accom- housing sizes and types...” (Policy 3A.4). modation, the Council will seek replacement dwellings comparable with the standard and the amount of accommodation lost. BOROUGH POLICY OBJECTIVE This is in order to maintain the overall amount and quality of the dwelling stock and to ensure that the dwelling target in Policy 5.10.4 The size of new dwellings cannot be solely left to the market as STR18 is not jeopardised. The only exceptions are for a strictly the Council has an obligation to ensure that its Plan adequately defined range of community facilities. The policy also prevents provides for the demographic housing needs of the Borough’s loss to short-term leased accommodation, which requires permis- residents whose average household size (2.6 persons) is one of sion in London. the highest in the country, indicating the need to ensure an adequate proportion of family size housing in new developments. Family housing is defined for the purpose of this Plan as providing two or more bedrooms.

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5.10.5 The Plan also recognises that the amenity benefits of new housing should be available to a variety of household types and sizes H10 CONTAINMENT OF DWELLINGS throughout society - not just the largest households and / or those with the highest incomes. And that a 'planned under-occu- New residential accommodation should be self-con- pancy' of large homes occupied by small households is a wasteful use of land. Finally, there are good planning reasons for tained unless it is designed to meet the known needs ensuring that child densities do not vary too widely between of a named institution and suitable management neighbourhoods - to ensure mixed and balanced communities arrangements are secured as part of the planning and to avoid the social problems that can result from very high application. Such accommodation should be provided child densities. to the same standards as self-contained units, and will only be acceptable where the site is not suitable for 5.10.6 There may be scope for additional housing, both to meet the family accommodation, and does not result in the loss demands for larger homes, to accommodate priority needs, and of existing self-contained accommodation. Non self smaller dwellings for single person households, to avoid under contained accommodation should be located within an occupancy. This assists the Plan in securing mixed and balanced area with good or very good public transport accessi- communities in larger new housing developments between all bility. household types and between market and affordable housing. The Council will therefore seek to achieve a mixture of family and non-family units in all large developments wherever practicable to ensure mixed and balanced communities. Examples of sites unsuited to family occupation, where non-family units may be more suitable, could include sites where there is no, or limited, scope for external amenity areas, or not having the appropriate quality of environment for families.

H9 DWELLING MIX

On developments capable of 15 or more dwellings, or 5.11 NEW RESIDENTIAL DEVELOPMENT residential sites of 0.5 ha or more, irrespective of the number of dwellings, a mix of family and non-family 5.11.1 The Government’s overarching national, regional and metropoli- units will be required, having regard to local circum- tan housing and planning strategies emphasise the need to max- stances and site characteristics. Exceptions may be imise, high quality, well designed, new housing development, made for developments of sheltered or supported with the necessary complementary open space amenities, and housing, housing in or adjoining town centres or other community facilities provision, on ‘brownfield land’ (previ- where the site is unsuited to family occupation. ously developed sites). This strategic approach is further Special regard will be had to affordable housing devel- endorsed in The draft London Plan. opments designed to meet the needs of a particular priority group. THE LOCATION OF NEW RESIDENTIAL DEVELOPMENT

5.11.2 Policy STR19 governs acceptable locations for residential 5.10.7 Most new dwellings created through new-build or conversion will development. Housing will be promoted on previously developed be self-contained in terms of facilities. In the future, develop- urban land which the Plan does not protect for other land uses. ments of 'Co-Housing' or similar, where some facilities are shared Sites should provide acceptable residential amenity for existing may become as popular as they are elsewhere in the world. and proposed residents, be accessible by means other than the There may also be a requirement for ‘cluster housing units’, par- private car and provide necessary infrastructure. This policy has ticularly for specific types of key workers, such as nurses. been used to assess housing sites identified within the Plan and However, it is essential that any innovative types of non-self con- will also be used to assess windfall sites. tained accommodation should provide an overall high standard of accommodation, suitable for its residents’ needs, otherwise they will be treated as hostel or house in multiple occupation accom- COMMUNITY FACILITIES IN NEW modation as appropriate. Similarly retention of some shared facil- RESIDENTIAL DEVELOPMENT ities may well be for the benefit of existing tenants where houses in multiple occupancy are upgraded. 5.11.3 New residential development may also have to comply with Policies OS7 and OS18 on new open space and children's play facilities respectively; Policy BE7 on retention of existing trees and landscape features and Policy CF5 on community facilities in large scale development, in accordance with the relevant advice and criteria of PPG3, RPG9, RPG3 and The draft London Plan.

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allocated for housing in the Plan, contributing a very small proportion of the housing requirement over the Plan period. It is therefore not proposed to bring forward anymore greenfield sites for development other than those set out in this Plan, and the ad-hoc release of greenfield sites would not therefore be appropriate unless strategic housing requirements are not being met. Housing supply will be monitored throughout the life of the Plan (see Appendix 1).

5.11.7 Circular 1/2000 gives specific advice to London boroughs and indicates how the agreed annual rate of housing provision will be met. The draft London Plan also proposes to closely monitor annual housing provision. The Council will monitor the contribution from the various elements of supply, including site specific proposals set out in Chapter 15 of the Plan. MAXIMISING HOUSING ON PREVIOUSLY DEVELOPED LAND

5.11.4 The strategy of the Plan (Policy STR3) is to maximise housing on URBAN DESIGN QUALITY IN NEW previously developed urban land, commonly referred to as RESIDENTIAL DEVELOPMENT 'brownfield' land. This has a specific technical definition, see the Glossary. The Borough is using the results of the National Land 5.11.8 The Council is firmly committed to securing quality at every stage Use Database to identify and prioritise the more difficult sites in of the development process. By quality, the Council means the order to work with bodies such as English Partnerships and the extent to which development meets the needs of all those who London Development Agency to bring them into productive use. use and view development. As well as the general policies in the Built Environment chapter, the Housing chapter contains special policies tailored to the issues that arise in new residential devel- H11 HOUSING ON BROWNFIELD SITES opment. A guiding shared objective of Government strategy, as evidenced in By Design: Better Places to Live (2001), the draft Housing will be promoted on previously developed London Plan, and the UDP is to tackle this through emphasising urban land which the Plan does not protect for other the role of urban design in securing the characteristics that create land uses. interesting places. These techniques have been increasingly used in Brent, including on a number of major schemes, and are Previously developed sites which do not come forward leading to a notable improvement in residential quality. for development in the short / medium term will be prioritised through: 5.11.9 Urban design emphasises how people use, move around and experience places. A responsive people-centred design (a) Preparing development briefs; approach leads to a shift away from designing residential layouts (b) Improving the access to and / or environment around the needs of the car, towards pedestrian friendly develop- around sites,where feasible and necessary; ment designed around the needs of people. Secondly, it empha- (c) Assembling sites where necessary; sises the importance of context, the setting of developments and the characteristics of sites, in designing an appropriate solution. (d) Undertaking land restoration and / or remediation where required; and 5.11.10 The policies below are not intended to limit the creative freedom (e) Working in partnership with other bodies. of architects and designers and should not preclude the use of innovative approaches provided that it can be demonstrated that 5.11.5 The Government's sequential approach as set out in PPG3 is the approach will be as effective as more traditional ones. Nor do designed to restrict development of 'greenfield' sites whilst appro- they dictate any particular style or elevational treatment, although priate 'brownfield' housing opportunities remain unrealised. The they do caution against the over-use of standard house 'patterns' Plan sets a brownfield target of 95% of additional housing from used without discrimination, or over-dependency on ‘cul-de-sac’ 2000-2010. In the light of the housing provision survey this is layouts. considered achievable as many more brownfield sites are now allocated in the Plan and those few greenfield sites identified for 5.11.11 Rather, the policy is predictated upon an urban design framework housing are solely to secure a wider planning purpose (such as a being set for individual sites. The context of a site should define better arrangement of private and public open space on major the sense of place that an urban design framework is setting out estates). to create. This means that pedestrian circulation should be put at the heart of site layout and built form. For this reason a ‘roads 5.11.6 The GLA Housing Capacity Study (London’s Housing Capacity, first’ approach to layout design, including outline applications for 2000) demonstrates that Brent is able to meet most of its housing layout without siting details, is not acceptable. All sites with, or requirements on brownfield land. Very few greenfield sites are large enough to require, internal roads / footways, will be required

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to submit an 'Urban Design Statement' with the application (Policy 5.11.13 A key aspect of quality will be ensuing that areas are designed in BE1). This will show how pedestrian movement within the site a comprehensive and compatible way over time. links to adjoining sites (taking into account community safety and other considerations) and will shape the means of access and layout of the scheme . 5.12 RESIDENTIAL DENSITY

5.12.1 Density is a measure of the intensity of development of a residen- HOUSING STANDARDS & QUALITY tial plot. It is conventionally measured in habitable rooms per hectare (hrh), see Appendix H3. 5.11.12 The Borough is keen to encourage a much more 'design-led' approach to the density of housing development where the NATIONAL AND REGIONAL POLICY CONTEXT design is tailored to the context of the site. However, it is still necessary to give designers and housing developers a clear under- 5.12.2 PPG3 and PPG13 promote increasing densities at locations with standing of the level of expected amenity that residents should good public transport accessibility such as at or around town and enjoy as a result of proposed development. The Borough has district centres. replaced conventional arithmetical housing 'standards' with a new approach. The policy sets down those amenities that both exist- 5.12.3 RPG9 specifically supports raising densities (Policy Q3) and max- ing and proposed residents should be entitled to expect, i.e. a imising housing opportunities through the ‘Sustainable minimum acceptable standard of privacy, daylighting etc. The Residential Quality’ or design led approach (first advocated by onus will then be on the designer to demonstrate how these will LPAC, 1998). More recently, Circular 1/2002 (Town and country be met. In those cases where the 'back-to-back' distances planning (residential density) (London and South East England)) between habitable room facing windows is less than 20m, the has stipulated minimum densities. Council will expect particularly skilled design to ensure acceptable quality. The Council has amended its highway and parking METROPOLITAN POLICY CONTEXT standards to encourage more traditional interconnected street layouts with on-street parking. 5.12.4 RPG3 states “The Secretary of State considers that the next review of UDPs should be the occasion for each Borough to examine the scope for raising densities.” (para 8.12) and that H12 RESIDENTIAL QUALITY - LAYOUT ‘town cramming’ can be avoided through better design and CONSIDERATIONS “...clear straightforward policies on standards and layout.” (para 8.13). The Secretary of State did not consider that it would be The layout and urban design of residential develop- helpful to set out a Londonwide density guideline (para 8.11). It ment should comply with policies in the Built does list however a range of factors which should be considered Environment chapter, and in addition they should: in the re-assessment of density policy (paras 8.11-8.14).

(a) Have a site layout which reinforces or creates an attractive and distinctive identity, appropriate to its 5.12.5 These and additional factors together with a more design led locality, creating a clear sense of place; approach have been employed in The draft London Plan Table 4B.1 Density location and parking matrix to indicate an appropri- (b) Have housing facing onto streets and defining ate range of densities from suburban to central London new roads; housing development. The Mayor emphasises that increasing (c) Have access and internal layout which achieves housing densities is a key requirement to implement the Compact traffic safety where cars are subsidiary to cyclists City strategy. and pedestrians, normally preventing vehicles from travelling greater than 32 Kph (20 mph). Cul-de- DENSITY AND SUSTAINABILITY sacs should only be used in parts of development sites that cannot be serviced in any other way. 5.12.6 The sustainability argument in favour of increasing densities is Gated communities will not be permitted; that: (d) Have an appropriate level of car-parking, and cycle parking, where dedicated on-street car parking is • It increases the viability of public transport through increasing maximised as opposed to in-curtilage parking; and it's potential clientele; (e) Avoid an excessive coverage of tarmac or hard • It increases the potential local market for local shops and landscaping and have an amount and quality of services, open landscaped areas appropriate to the character • It compensates for lower population in a neighbourhood of the area, and local availability of open space, and resulting from smaller household sizes, - thereby reducing the the needs of prospective residents. need to travel; and • Higher density housing is more energy efficient and is required to make Combined Heat and Power / District Heating schemes economic.

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5.12.7 Higher density developments do not have an intrinsically lower energy consumption - this depends just as much on a supporting THE FACTORS LIKELY TO AFFECT DENSITY IN infrastructure, transport and parking policies, and urban design and pattern of land-uses throughout the urban area. In short den- MORE DETAIL sity must be carefully planned. • The size and shape of the site. Larger and more regularly shaped sites are able to take higher densities than smaller and more irregularly shaped ones, however larg- THE 'DESIGN-LED' APPROACH TO DENSITY er sites should also have a range of densities including (on appropriate sites) a substantial proportion of units 5.12.8 The density of the Borough varies between its inner-urban with gardens; Victorian / Edwardian core and outer Brent which has a more • Whether the site is within a town or district centre. open 'Metroland' suburban character. Adopting a 'design-led' These are appropriate for higher densities where they approach to density means that full regard is paid to the context of have good public transport accessibility. building heights, development patterns etc. Whilst high quality • The density and character of housing in the surrounding residential development is possible at almost any density this area. Densities will be higher in areas of an urban char- does not mean that this would be compatible with local character, acter, than those of a suburban character. In or with providing appropriate levels of amenity. SPG17 sets out Conservation Areas this should be the primary consider- the standards, particularly in terms of noise insulation, day and ation; sun-lighting for higher densities. The Council’s more flexible • The type of development. Appropriate densities will vary approach to development standards (such as lower parking and by the type of accommodation proposed. Certain higher road standards) makes this possible. density building forms may appeal to some types of households in more central locations. 5.12.9 Whilst there may be areas of a high quality suburban character • The amenity and needs of potential residents. This that are unsuitable for significantly higher densities, the areas includes the need to ensure adequate privacy, daylight- where there is the best case for moderately higher densities (in ing and sunlighting and protection from noise. Family terms of sustainability, vitality and access to services) are areas accommodation will require more spacious development with good or better public transport, as well as town and district than that for non-families. Where areas are proposed centres with good public transport accessibility. The main factors for clearance and re-development, the expressed prefer- which affect the suitable density for a site are listed in Policy H13 ence of future residents will be particularly important; and are explained in more detail in the checklist below. Once the • The constraints of adjoining land uses and the amenity parking standard for a residential development is defined, space of adjoining residents. Matters such as overshadowing, set around and between buildings, and building heights agreed, overlooking etc.; then density should follow from these urban design considera- • The constraints and opportunities of the site; tions. Further guidance on the importance of these factors in • Whether the development is proposed as a car-free generating appropriate design related densities, will be provided housing development. An increased density may be during the Plan period, within SPG17. appropriate; • Whether the development is for affordable or supported housing. The lower parking standards appropriate for H13 RESIDENTIAL DENSITY such development permit increased densities; • Child Density. Developments with high child densities The primary consideration in determining the appro- (number of children per site area) are not suitable for priate density of new residential development will be high residential densities. There will also be space achieving an appropriate urban design which makes requirements for children's play areas; efficient use of land (particularly on previously used • The opportunities the site presents for passive solar gain sites) and meets the amenity needs of potential resi- and / or district heating. Sites suitable for passive solar dents. The most dense developments will be appropri- gain (e.g. south facing) may require, depending on lay- ate in those parts of the Borough with good or very out, densities below a certain level, whilst district heat- good public transport accessibility. Surrounding den- ing, to be economic, requires a minimum density; sities should be at least matched unless this would • The public transport accessibility of the site. Sites with harm residential amenity. good or better public transport accessibility are more suitable for increased densities, sites with very poor The density of a site should also have regard to the public transport accessibility have very limited scope for context and nature of the proposal, the constraints additional housing; and opportunities of the site and the type of housing • The capacity and level of use of the road access to the proposed. site. Sites accessed via a quiet and narrow residential cul-de-sac may require decreased densities or traffic reduction measures to prevent unacceptable noise from traffic;

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• Whether the development is proposed to be mixed use. retain garden areas commensurate with their size and general Density calculations may be less meaningful and other character. The Council will regard 10m as the minimum rear gar- factors need to be considered; den depth to protect privacy although other planning require- • Whether the development is infill, frontage redevelop- ments may result in a greater depth in some circumstances. ment or backland development. The relationship of the development to adjoining housing is an important consideration for such sites; H15 BACKLAND DEVELOPMENT • Existing landscape features on the site. Where these are required to be retained then a lower density may result. Where backland development is proposed special regard will be paid to the following:-

(a) The density and height of the proposal which 5.12.10 In order to meet the Boroughwide housing target in Policy STR18 should be subsidiary to the frontage housing; it is important that full and effective use is made of all suitable sites for housing. If fewer dwellings are built on these than sites (b) The privacy and outlook from existing dwellings are capable of then there will be additional pressure to build on and in particular gardens; unsuitable sites. (c) Any proposed demolition of existing dwellings or parts of dwellings to form accesses. If this would create an unattractive breach in a consistent street H14 MINIMUM RESIDENTIAL DENSITY frontage this will not be permitted; (d) Access arrangements which would cause significant Planning permission will be refused where develop- nuisance to neighbouring properties will not be ment would under-utilise a site, where there are no permitted. 'Tandem' developments (backland pressing considerations to protect the character of an housing sharing a frontage house access) will not area. Outline permissions will be the subject of a con- be permitted; dition specifying a minimum number of dwellings at (e) That sufficient garden depth and area is retained by reserved matters stage. existing dwellings commensurate with their size and character;

(f) The effect and cumulative impact of the development on the loss of garden habitat; and 5.13 DEVELOPMENT IN EXISTING (g) The effect on the character of Conservation Areas, RESIDENTIAL AREAS where the proposed development is within or adjacent to a Conservation Area. 5.13.1 Development in existing residential areas, whether by the redevelopment of existing dwellings or 'backland' development, may provide additional dwellings to meet the housing allocations referred to in Strategic Guidance and The draft London Plan. But 5.13.3 'Frontage Redevelopment' involving the demolition of existing such development can have a severely detrimental impact on the houses for new development can radically alter the appearance character of the surrounding residential area and on the ameni- and quality of the street scene, particularly in areas with dwellings ties of adjoining dwellings. In some areas, including of a consistent and attractive character. New development Conservation Areas and Areas of Distinctive Residential extending into the rear of the site can also result in a loss of priva- Character, such development proposals may be inappropriate. cy and general amenity to adjoining dwellings. Frontage develop- Where 'backland' or redevelopment schemes may be acceptable, ments to higher densities should respect the character of the they must be designed so as to be in keeping with the surround- area. For example, redevelopment of a large detached property ing area, and generally at a compatible density. would be better in the form of a block of flats rather than the introduction of an alien terrace. 5.13.2 'Backland Development' is housing development on land behind the rear building line of existing housing (including where this is H16 FRONTAGE REDEVELOPMENT being redeveloped), either formally used as gardens or partially enclosed by gardens. In assessing proposals for this type of Where frontage redevelopment is proposed within an development, special emphasis will be placed on the potential existing residential area the replacement housing impact on the privacy of existing dwellings and from the additional must make an equal or greater contribution to the traffic generated. In addition proposals will be assessed in rela- character and quality of the streetscene. The spacing tion to the impact of the loss of garden areas which individually around the development should be compatible with and cumulatively have a nature conservation value and make a the character of the surrounding area. positive contribution to the diversity of flora and fauna in the Borough. Satisfactory access will need to be provided, and problems of community safety will need to be addressed. If rear gardens of existing dwellings are subdivided, existing dwellings must

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5.14.5 There are, however, a number of specific circumstances in which In the event of redevelopment extending beyond the conversions are not normally acceptable, or need to be restricted. rear building line of an adjoining property, the propos- Firstly, where they lead to a loss of small purpose-built family al should not have a detrimental effect upon its resi- dwellings which meet a specific housing need in a Borough with a dential amenities. disproportionately high number of larger families. The Council therefore needs to ensure the retention of small purpose built Return frontage development should be compatible houses and flats, in order to retain mixed and balanced communi- with any open character of corner sites, be subsidiary ties with a variety of housing sizes. to the frontage building and retain an appropriate garden depth for the existing and proposed dwellings. 5.14.6 Secondly, conversions are not acceptable, where access to the property would be dangerous i.e. directly from a trunk road or This does not preclude the application of the princi- where vehicles would reverse onto the Strategic Road Network ples of Policy H14. (see also Policy TRN15). Thirdly, on some streets the configuration of properties do not lend themselves to conversion. An example is Windsor Crescent, a street of three storey town houses with very narrow frontages where the layout of the original dwellings, although exceeding 110m2, precludes satisfactory con- 5.14 SUB-DIVISION OF EXISTING version. HOUSING - FLAT CONVERSIONS

H17 FLAT CONVERSIONS NATIONAL AND REGIONAL POLICY CONTEXT

The conversion of dwelling houses into flats will be 5.14.1 PPG3 promotes the sub division and conversion of existing permitted, unless one of the following apply:- dwellings as an important source of new housing provision (a) The property has an original (unextended) floor (paras 21 & 41). Guidance which is reiterated at regional level in area of less than 110m2 or of less than 140m2 if the RPG9 (Policy H5). property is in a location where conversions are restricted (see Policy H22);

METROPOLITAN POLICY CONTEXT (b) The property has direct access onto a Trunk Road (the North Circular Road) or where vehicles would access or egress onto a London Distributor Road in 5.14.2 RPG3 identifies the subdivision of dwellings into flats as one of reverse gear; or the four key areas where boroughs need to demonstrate that they have sought to increase provision. “Boroughs should...review (c) The configuration of the property does not lend itself to conversion. policies so they encourage rather than hinder the conversion of existing dwellings.” (para 4.18). RPG3 goes further to state that;

“In particular, parking standards should not be used unnecessari- DEFINITION OF ORIGINAL FLOOR AREA ly to restrict the supply of conversions, especially where the location is well served by public transport. Boroughs which wish to This is calculated so as to exclude any exten- have generous minimum parking standards in such areas will sions, garages (including converted garages) or need to give a full and adequate reasoning as to why such stan- loft conversions to the original (i.e. pre-1948 dards are deemed necessary.” (para 8.16). unextended) property. The calculation excludes the area of outside walls but includes inside 5.14.3 Conversions were identified as an important source of new hous- walls, partitions, cupboards and chimney breasts. ing provision in the London Housing Capacity Study (London’s Only the floorspace of rooms with an existing Housing Capacity, GLA, 2000) which has informed The draft headroom of at least 2m is counted. London Plan (Table 3A.1). IMPROVING THE QUALITY AND DESIGN OF CONVERSIONS BOROUGH POLICY OBJECTIVES 5.14.7 Much of the concern about flat conversion activity in the 1980s 5.14.4. The conversion of existing houses into two or more flats is an related to the poor quality of many of the conversions. Whilst the important means of increasing the number of dwellings in the Council would previously have had limited control over most inter- Borough and can also make a valuable contribution to the rehabil- nal standards RPG3 states that “Boroughs may consider identify- itation of the housing stock. The broad approach of the Council, ing criteria to encourage a good quality of [flat conversion] devel- therefore, is to encourage conversion activity as long as the units opment.” (para 8.16). Ministerial decision on appeal has also so created form satisfactory dwellings and provide a range of unit sizes.

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held that converted flats must be suitable for occupation and have adequate natural light. Sound insulation between converted flats is subject to provisions under the Building Regulations. (l) The subdivision of floors between flat units will be permitted only where the size and layout of units is satisfactory and no units have a solely north facing 5.14.8 New dwellings created through conversions provide an important aspect, or include wholly internal kitchens. means of increasing the range of dwelling sizes available to people seeking accommodation in the Borough. The Council is concerned that such units should provide good standards of accommodation, meet a variety of housing needs and do not result in FLAT CONVERSION AND ON-STREET PARKING over-intensive use of the property. 5.14.9 Brent has always taken a positive approach to flat conversions. It H18 THE QUALITY OF FLAT CONVERSIONS has encouraged conversion of suitable property unless it leads to dangerous on-street parking or excessive forecourt parking. In Flat conversions should provide an acceptable stan- effect the Borough has not had a conventional 'off-street parking dard of accommodation to future residents, should not requirement' and operates a flexible approach which would allow be over-intensive, in terms of the number and size of flat conversions without off-street parking in other than ‘heavy proposed units and / or the size of extensions pro- parked streets’. On heavily parked streets there is clear evidence posed and should have an acceptable visual impact on that intensive conversions generate additional on-street parking the street: pressure and this causes a problem, it is difficult to enforce at night and causes difficulties for the emergency services. Here (a) The layout of rooms within conversion schemes should avoid differing types of room being 'stacked' there is a need to assesses the on-street parking impact and a over or under each other; or 'handed' next to each 'unit restriction' policy applies, to prevent over-intensive conver- other; sions.

(b) All rooms should have regard to room size stan- 5.14.10 As the basis for this the Borough has operated a regular overnight dards (SPG17); parking survey. It measures the percentage of cars parked on- (c) Conversion schemes should, where practicable, be street of the safe and legal maximum level of parking. At over designed to be accessible to disabled persons, 80% safe two-way flow is hindered and is classified as 'heavily unless the property has a lower ground floor level; parked'. Streets cease to be defined as 'heavily' parked only after (d) The units should have adequate circulation and they fail to meet the relevant criteria for two consecutive years. storage space; Streets in excess of 400m in length are considered in separate blocks. Streets or parts of streets that currently fall into these cat- (e) Shared corridor access should be safe, internal and convenient; as well as requiring units to be self- egories are listed in Appendix TRN3. The justification for an contained; overnight parking survey is that this is the best measure of the difficulty of parking for residents and means that on-street parking (f) Flat conversions will be restricted to one 120L bin by shoppers, commuters, employees etc. do not affect the survey per flat with accompanying bin stores & screening; figures. (g) Where practical secure cycle storage (PS16) should be provided; 5.14.11 Over time, and in conjunction with the implementation of the (h) Where possible rear gardens should be retained or Borough's parking strategy, it is hoped to have a phased reduc- provided, without subdivision; tion in the Borough's residential parking standards. The Plan’s standards also include a reduced standard for developments by (i) Plans should be accompanied by full details of registered social landlords; reflecting lower car ownership as a external alterations; and disproportionately high number of low income households com- (j) Except where a dwelling is located on a large plot, prise the 37% of Brent households without access to a car significant side or rear extensions should not be (Census 2001). It should be noted that this does not apply to pri- erected to raise the number of flats permitted in a vate leasing schemes (as an appeal has held that these do not conversion scheme and roof-space or existing hab- secure affordability in perpetuity). As many cars are parked on- itable basements should, without extension, be street most of the week, but only occasionally used, the sugges- large enough to contain a one-bedroom unit to Plan standards. tion has been made that use be made of so-called 'Car Clubs' - where residents pay for access to a shared car. These are (k) Schemes should, where practicable, include a range becoming increasingly common on the continent and in such of unit sizes suitable to various needs, and where schemes one car typically replaces six previously. A relaxed atti- the dwelling to be converted has a rear garden, tude to parking for residential development (including conver- then a family unit (2 or more bedrooms) on the sions) operates in these circumstances. ground floor / sub-basement floor should be included, with direct access to the garden; and

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However it should not be used to justify over-intensive exten- H19 FLAT CONVERSIONS - ACCESS & sions, use of roofs or sub-division of floors - which could lead to PARKING rear service roads being blocked by parked cars.

Conversion schemes should have safe and convenient pedestrian access. Where off- street parking is pro- H20 FLATS OVER AND ADJOINING posed, this should also utilise a safe access. BUILDINGS IN SHOPPING CENTRES

If the parking standard for the converted dwelling(s) Proposals to convert accommodation above shop is greater than for the pre-converted dwelling(s) then premises into self contained residential units will be the impact of the additional parking will be assessed. permitted subject to the conversion not involving This parking can be provided on street if off-street excessive extension. A more flexible approach parking would result in an excessive area of parking towards development standards will be applied, how- on the forecourt (see Policy BE7), or where rear gar- ever utilisation of roofspace or subdivision of floors den parking would be detrimental to the amenities of should not result in an unsatisfactory standard of adjoining properties, or where on-street parking accommodation when judged by Policy H18. All flats would not create a traffic safety hazard. On-street should be accessed independently from the shop unit. parking will not be acceptable where either:

(a) A street or section of street is heavily parked; or

(b) Where the location presents particular traffic safety hazards.

Where such on-street parking is unacceptable then the number of units permitted in the resultant scheme will be restricted to a maximum of one unit per 75m of the original floor area the property possesses.

Exceptions to this policy will be allowed for where Car 5.16 DOMESTIC EXTENSIONS Clubs operate and development is secured as part of these. 5.16.1 Extensions and other building alterations can provide significant improvements to the Borough's dwelling stock in terms of the physical renewal of buildings and the increased availability of dwelling rooms and bedspaces. However, such development should respect the local character and streetscene of an area. 5.15 FLATS OVER AND ADJOINING Such development is also recognised as meeting the special BUILDINGS IN SHOPPING CENTRES needs of large families. In providing a flexible response to changing social and demographic needs, applications for extensions 5.15.1 PPG3 encourages the provision of residential accommodation and alterations will be acceptable provided they meet the require- above shops and commercial buildings and advises authorities to ments of policy. Additional guidance is provided in SPG5 Altering take, where possible, “...a more flexible approach to development and Extending your Home. plan standards with regard to densities, car parking, amenity space and overlooking.” (para 41). Guidance which is reiterated at regional level in RPG9 (Policy H5). H21 DOMESTIC EXTENSIONS

5.15.2 RPG3 advises that the housing use of vacant premises above Extensions to domestic properties should be accept- retail and commercial buildings “...should be encouraged and able when judged against the following criteria, and facilitated through planning policies.” (para 4.14). Guidance having regard to supplementary planning guidance: which is reiterated in The draft London Plan and detailed in the (a) The extension should complement the existing recent draft Best Practice Guidance (Making Better Use of house and should not alter its general scale and Supermarket Sites, GLA , 2004). character;

5.15.3 This is one area of potential housing provision that can particular- (b) The extension should respect the amenity, privacy, daylight and sunlight of adjoining properties and ly meet the needs of smaller households and contribute to town the local character of the area and the streetscene; centre regeneration and reducing the need to travel. Changes to and residential parking standards permit a more flexible approach to conversions of non-residential accommodation and a much lower (c) Adequate amenity space and garden depth for the standard for affordable housing and housing in town centres. In original house must be maintained. some circumstances 'car-free' housing may be permitted.

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5.17 RESIDENTIAL AMENITY emphasis on allowing people to remain in their own homes as long as possible. For example, many people with special needs 5.17.1 The Council generally seeks to protect the environment of resi- (such as those with a physical disability) would be able to live in dential areas from the intrusion of uses that are incompatible with mainstream housing if there was greater provision of easily residential areas by virtue of noise, nuisance, disturbance, pollu- adaptable housing (such as those meeting lifetime homes criteria, tion etc. The particular problems associated with industrial activi- or wheelchair access capability). Alternatively if there was ties that may cause a nuisance in residential areas are dealt with greater provision of supported accommodation (meeting a partic- in the Environmental Protection and Employment chapters. ular identified need), then this would result in the freeing up of (frequently under-occupied) mainstream housing.

H22 PROTECTION OF RESIDENTIAL NATIONAL AND REGIONAL POLICY CONTEXT AMENITY 5.18.4 PPG12 advises that development plans should consider the spe- The establishment of new incompatible non-residen- cific needs of particular population sectors such as the elderly, tial uses in predominantly residential areas will not be disabled and disadvantaged people. Advice reiterated in PPG3 permitted. In particular, developments which will (para 13). result in an intensification of use likely to have an adverse environmental and traffic impact will not be 5.18.5 RPG9 advises that development plans should “...meet the permitted. assessed needs of all sectors of the community, including elderly and disabled households...” (Policy H4).

METROPOLITAN POLICY CONTEXT

5.18.6 RPG3 specifically recognises the specialised housing requirements of groups such as the disabled, the elderly, the chronically or terminally sick, those subject to care in the community, women seeking refuge, students and those living in hostels. It notes the need for different types of housing to meet those needs, having regard to the Borough's Housing Strategy statement. It recom- 5.18 SUPPORTED HOUSING mends that policies for special housing should be flexible but should encourage a mix of housing provision. 5.18.1 The greater emphasis on community care for the disabled, elderly people, children in need and others, whereby they are moved 5.18.7 RPG3 also states that UDP's should: from large institutions to smaller scale residential accommodation within the community, has contributed to a trend of applications • Clearly define the definitions and categories they are using to for supported housing and day-care provision. define supported housing, and have policies meeting each specialised need; DEFINITION • Identify sites particularly suitable for supported housing provision and have regard to their location in respect of other uses 5.18.2 Supported housing refers to housing with care for those who are and transport facilities; and unable to live independently in their own homes. The level of care • Show what standards will be applied in negotiation with can vary from 24 hour residential cover (such as in a nursing developers to meet the needs of the disabled (4.27). home) to an officer calling in on a regular basis (for example, supported housing provided by a housing association). As long as 5.18.8 Draft London Plan Policy 3A.4 Housing Choice enjoins boroughs there are more than six occupants and care is provided, this type that their UDPs should include provision for appropriate support- of housing falls within use class C2 (residential institution) along ed housing. with hospitals and residential schools and colleges. If there is six or less occupants (whether with or without care) then the dwelling WHO IS IN NEED OF SUPPORTED HOUSING IN falls within C3 (dwelling) use class. This section excludes non- BRENT? supervised (including that for young single homelessness, refugees and students) and minimum care provision hostels, 5.18.9 Brent’s Housing Strategy identifies the key groups as: elders, and such as ‘Bed and Breakfast’ homeless hostels, which is a sepa- people with mental health, drugs and alcohol, learning disability, rate use. Policies in this section also cover non-residential day- physical disability and HIV / Aids problems, single homeless peo- centres for those in special needs. ple and children and young people. This does not mean that people who fit a particular category necessarily require supported 5.18.3 Supported housing should not be considered in isolation from housing, nor that there are not other special needs groups in the mainstream housing. Recently there has been a blurring of the Borough. distinction between supported and mainstream housing, with the

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CLARIFICATION OF PLANNING NURSING HOMES & RESIDENTIAL CARE CONSIDERATIONS HOMES

5.18.10 SPG2 lists the issues that the Council can and cannot take into 5.18.15 Non-borough residents have occupied much of the nursing home account when considering a planning application. In addition this / care home developments in the Borough. This has lost housing section aims to clarify two issues which are frequently mentioned land and is overstraining local services. Therefore additional as objections. nursing homes / care homes will not be considered to meet the 'needs test' in the policy unless the applicants can demonstrate 5.18.11 Fear of Crime; Public perception of harm has been held by the clear evidence of local need. Courts to be a material planning consideration where there is clear evidence that harm will be caused. H23 SUPPORTED HOUSING / DAY-CENTRES 5.18.12 Level of Care Inside the Facility; This cannot be considered mate- - PRINCIPLE OF DEVELOPMENT rial in planning terms where this relates to the care of residents, rather than the level of amenities provided and the management Applications for supported housing / day centres of impact on residential amenity. Children’s, residential care and should meet a known need in the Borough. They are nursing homes in the Borough are monitored by Social Services acceptable in residential areas, and on suitable sites in and the National Care Standards Commission as appropriate. or adjoining town / district centres; unless:- Other forms of supported housing in the Borough are regulated (a) The location and / or scale of development would internally or through meeting the criteria by which they get their be inappropriate in terms of the impact of the pro- funding. Therefore it would not be appropriate for the Borough to posed client group on residential amenity, unless dictate any particular level of care - such as 24 hour supervision - these can be secured through management meas- unless there are exceptional grounds to do and this is not regulat- ures; ed by other means. However such management agreements (b) The proposed client group would overstress local should be submitted with and secured as part of planning applica- health and / or social services; tion which consider, for example, management of activity on the street. Improved links between Planning and Social Services are (c) Over-concentration of these facilities would harm ensuring that the nature of the supported housing development local amenity; (including the level of care) is submitted with the planning applica- (d) The site lacks suitable access for any necessary tion, which in many cases will help calm public fears. ambulances and / or minibuses;

(e) The site, other than for a client group totally dependent on carers, lacks access to local shopping LOCATION & CONCENTRATION / public transport facilities within 400m (without gradients greater than 1:12 on the route); or 5.18.13 Mapping decisions since 1992 indicates that the permissions (f) The scale of the development is incompatible with granted are relatively evenly distributed throughout the Borough. the character of the area. However against the backdrop of the existing supported housing provision, it is apparent that there is a concentration of mental Where development for other categories of the C2 health provision in parts of the Borough. Particularly in Harlesden use-class would cause such a problem, then conditions where there is a clear perception amongst education, health and will be imposed restricting development to the client social service providers in this area, that this is over-stressing group applied for, or one or more sub-categories of local services. the use-class.

5.18.14 For people living in special forms of accommodation and their visitors, proximity and safe and convenient access to local facilities and public transport are important. A location which required peo- 5.18.16 Conversion of small properties (with or without extensions) to pro- ple to cross busy main roads to reach these facilities would be vide supported housing accommodation can cause harm through unacceptable. Proximity to local shops and services is of particu- overintensive use . lar importance to the elderly and to people with mobility difficulties who are still sufficiently mobile to make use of these facilities. Some developments that rely on coach and mini-bus movements H24 SUPPORTED HOUSING - will be permissible only where their location allows for satisfactory CONVERSIONS / EXTENSIONS access arrangements to cater for these vehicles. Identical locational considerations also apply to day centres which the policy Applications for supported housing involving the con- also covers. version or extension of an existing property built for residential purposes, should:

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Developments should have a reasonable standard of (a) Have an original (pre-1948) unextended internal amenity and communal facilities for prospective resi- floor area of at least 110m2; and dents. (b) The conversion should be within the original envelope of the building unless modest extension is nec- Occupation will be restricted to elderly persons, dis- essary to provide the required standard of care. abled people, carers, dependent persons who are cared for by these, and their partners, by planning condition.

5.19 SHELTERED HOUSING 5.19.1 Sheltered housing is defined by the National Housing and Town Planning Council as "housing which is purpose-built or converted exclusively for…elderly people with a package of estate manage- 5.20 ACCESSIBLE HOUSING ment services and which consists of grouped, self-contained NATIONAL AND REGIONAL POLICY CONTEXT accommodation with an emergency alarm system, usually with communal facility and normally with a resident warden". 5.20.1 Planning Policy Guidance Note 1 recognises that “Proposals for the development of land provide the opportunity to secure a more 5.19.2 At one end of the spectrum are self-contained units with reduced accessible environment for everyone, including wheelchair communal facilities. These are referred to as 'Category I users...” (para 33). Planning authorities are therefore advised to Sheltered Housing' and fall within the C3 use class. At the other consider “... the need for accessible housing.” (para 33). PPG3 is grouped flats with greater communal facilities and warden sup- and RPG9 stresses that accessible housing should be enabled port. These are termed Category II Sheltered Housing. Where where local needs assessment warrants. sheltered housing does not meet the Plan’s affordability definition, the Council will require a proportion of affordable housing within a 5.20.2 Planning and Access for Disabled People: A Good Practice Guide sheltered housing scheme, where this is practicable; as Brent’s (ODPM, 2003) provides detailed advice on the provision of new draft Older Persons Housing Strategy (2004) has identified a sub- housing that is accessible by people with disabilities in accor- stantial underprovision of affordable sheltered housing in the dance with the Building Regulations Part M. Borough. Further advice on this will be provided in supplementary planning guidance. The affordable sheltered housing stock METROPOLITAN POLICY CONTEXT formerly provided by the Council has been transferred to RSL management. 5.20.3 RPG3 recognising that some boroughs have historically sought to require ‘mobility standard housing’ advises “it is important that 5.19.3 Sheltered housing schemes need to be located near to local sufficient housing is provided or adapted to meet the needs of shopping facilities and in locations with moderate or better public those with disabilities “ (4.25). transport accessibility, because of their lower car ownership and reduced mobility. For this reason special reduced parking stan- 5.20.4 The GLA Household Survey (2002) estimates that meeting dards apply. However, it is necessary to control occupancy by London’s current very substantial shortage and future need will condition to persons 60 years or over or their partners or surviving require 23,000 new wheelchair accessible homes in the next ten partners. There is less likelihood of stress on local medical years. The Draft London Plan Policy 3A.4 accordingly requires services or increased concentration of elderly residents than that: supported housing as most residents are likely already to reside in the area. • All new housing is built to ‘lifetime home’ standards; and • Ten per cent of new housing is designed to be wheelchair accessible or easily adaptable for residents who are wheelchair users.

H25 SHELTERED HOUSING The Mayor has recently published draft Accessible London Supplementary Planning Guidance detailing how draft Policy Sheltered housing is permitted in locations with mod- 3A.4 can be implemented. erate or better public transport accessibility (as defined in the Transport Chapter section 6.7), which 5.20.5 Lifetime Homes (originally promoted by the Joseph Rowntree have access to local shopping facilities within 400m Trust) incorporate requirements, such as having ground floor bed (without gradients greater than 1:12 on the route). space and a wheelchair accessible ground floor toilet. The idea is to design all housing so that those who become moderately dis- /... abled can continue to live in their existing homes. Also they can be more readily and cheaply converted if disability becomes more severe. It should not be considered as supported housing rather

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as extending general needs housing to meet the needs of a life- • Youth Hostel type premises providing short term, budget time. A reduced version of the standard is required to satisfy Part accommodation, with very basic amenities, for, mainly young, M Building Regulations. Although this matter is partially covered ‘tourists’; and by the building regulations, planning will still have a role in ensur- • Homeless temporary accommodation i.e. on a ‘Bed and ing accessibility to entrances from the outside environment. Breakfast’ basis.

5.20.6 Wheelchair housing is specifically built to meet the needs of HOSTELS FOR THE HOMELESS wheelchair users (Wheelchair Housing Design Guide, National Wheelchair Housing Group, 1997). Most of this new housing is 5.21.3 Over the last two decades, the persistence of homelessness has currently being provided through affordable housing schemes. been the most graphic reminder and expression of the Borough’s General market housing can later be adapted to close to this housing need. The Borough has a rising number of homeless standard through the widespread introduction of the lifetime families. There are currently over 4,000 homeless households in homes standard. temporary accommodation provided by the Council. Historically many of these would have been in so-called 'Bed & Breakfast' BRENT’S ACCESSIBLE HOUSING NEEDS (B&B) hostel accommodation, but the Council has been able to steadily reduce such usage to a fraction of the former situation by 5.20.7 Brent’s Housing Needs and Stock Condition Surveys (2003) using a wide range of accommodation, including short term pri- have estimated that the Borough has 9,286 households with a vate leased homes, short -life housing and purpose built hostels, physically disabled resident(s). 1,252 of whom require accommo- providing much superior accommodation. The Council hopes to dation with a wheelchair accessibility not presently provided. This end the use of ‘B&B’ accommodation for its own homeless fami- need is identified across all tenures but is particularly prevalent in lies, for all but the most short term emergency use, by April 2004, the owner occupation sector where demand greatly exceeds sup- in line with Government strategy, and hopes that other boroughs, ply. Brent’s draft Older Persons Housing Strategy (2003) has whose own homeless placements account for the majority of also identified a disportionate need for accommodation suitable Brent’s ‘B&B’ family occupants, will follow suit. for older residents. 5.21.4 The use of 'B&B' hostels for the accommodation of homeless per- 5.20.8 The Council intends therefore, following a review of the Borough’s sons, albeit on a temporary basis, has long been recognised as recent lifetime and wheelchair accessible homes development, to an expedient but unsatisfactory solution to acute housing need. prepare Supplementary Planning Guidance as to how the historic For the majority of such residents the accommodation is general- severe shortfall between this demand and supply can be ly too small and too limited in the amenities available for normal addressed through the planning system. day to day living. For neighbours, the greater intensity of use associated with a hostel use can impose marked changes in the H26 ACCESSIBLE HOUSING character of an area. Hostel development can also lead to the loss of permanent residential units (typically Use Class C3) con- The site layout, accesses, and circulation around new trary to UDP Policy H8, thus compromising the capacity to find and converted dwellings should facilitate their use by long term housing solutions and hence contributing to an increase disabled and elderly people. in the underlying causes of homelessness. Indeed, the need of homeless persons, is permanent housing.

5.21.5 The Council recognises that it is necessary to ensure that Brent’s 5.21 HOSTELS AND HOMELESS temporary accommodation supply is prioritised, in so far as possi- ACCOMMODATION ble, to meet Borough needs. At times when preferred alternatives are in short supply, there may exceptionally be a case for granting DEFINITION a limited number of temporary consents for hostel accommodation to meet the short term needs for emergency homeless 5.21.1 Hostel accommodation is a ‘sui generis’ use (as identified by the accommodation. In considering the desirable time period the Use Classes Order, 1987). The use of residential accommoda- Borough will need to balance the desire of ensuring persons are tion for temporary sleeping purposes for less than ninety consec- placed for short time periods only and the need for proprietors to utive nights is a material change of use requiring planning permis- underwrite investments. There can be no guarantee that applica- sion (GLC General Powers Acts 1973 and 1983). A change of tions to renew temporary consents will be renewed. The rever- use from a hostel to a hotel (Use Class C1, ‘tourist accommoda- sion to residential may be secured and the conversion to hotels tion’) will require planning permission, as will a hotel housing a resisted. material number of homeless families and persons. 5.21.6 It is important that Brent has first call on such accommodation - 5.21.2 Policy H27 encompasses types of hostel provision, such as rather than other boroughs. The legitimacy of restricting to 'Brent only' registered homeless people has been upheld on appeal. • Foyers, combined residential and employment training provi- None-the-less proprietors have to invest heavily in properties to sion for young persons; bring it up to standard and they risk losing their livelihood if Brent • Purpose built hostels for students and workers; requirements fall. Therefore occupancy will be restricted by con-

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dition so that Brent homeless residents have 'first-call' when rooms become vacant, but that otherwise they can be let short- term, individually, to other boroughs. To put the needs of individ- III]The above criteria on loss of permanent residential accommodation may be relaxed for homeless hos- ual proprietors of hostels above this concern would be to put a pri- tels for families at times when preferred alterna- vate interest above a public one. tives for homeless accommodation are in short supply. Such consents will be granted on a temporary 5.21.7 Those in homeless accommodation have a much higher propor- basis (3-5 years) and will be limited to Brent tion of special needs than the national average especially where Homeless families only, for initial occupancy, and hostels can be accessed without reference from a specialist on a 'first call' basis when rooms become vacant. agency (i.e. so-called 'direct access' hostels for the street homeless). Therefore the same locational principles applying for sup- Where temporary hostels are refused further consent, ported housing applies to these. To prevent accommodation for they should revert back to permanent residential the street homeless 'silting up' there is an urgent need to secure accommodation, if this was the previous lawful use. increased 'move on' accommodation. These facilities require a Loss of hostels to hotels will be considered against high level of staffing and support. Temporary winter shelters for Policies TEA6 and TEA7. the homeless often come forward with very short lead in times. Brent will process and treat such applications sympathetically.

5.21.8 RPG3 advises that planning policies controlling hostel provision should be criteria based and also, in the case of purpose built student and worker accommodation, should aim to secure their loca- 5.22 GYPSY / TRAVELLERS SITES tion so as to minimise the travel need (para 4.26). 5.22.1 RPG3 advises that development plans should support the provision of sites to accommodate Gypsies and Travellers where there is a local identified need by indicating appropriate locational and H27 HOSTEL ACCOMMODATION other criteria in accordance with Circular 18/94.

Hostel accommodation should not result in the loss of 5.22.2 The Draft London Plan Policy 3A.13 states that boroughs should permanent residential accommodation or be on a site protect existing sites and review their current pitch capacity. suitable for permanent residential accommodation, Additional sites should be provided to satisfy unmet need but unless it meets a need in III below and should: these should not be located on Metropolitan Open Land or other open land protected from development. (a) Be located in or adjoining town centres, or in residential areas with easy access to local services and good / very good public transport accessibility; 5.22.3 The Council has provided a modern, well equipped site on Great Central Way, as a response to a study into the need for such facil- (b) Not result in over-intensive development, or over- ities in the Borough. Proposals for private sites, including those in concentration of facilities; respect of ‘travelling showpeople’ will be evaluated in accordance (c) Not be harmful to residential amenity, unless this with the above Government and draft London Plan criteria. can be controlled through management measures submitted with, and secured, as part of the application; H28 GYPSY / TRAVELLERS SITES (d) Where appropriate have adequate amenity areas for families with children preferably on site, or if Applications for gypsy / travellers sites, and travelling not practical, in the immediate vicinity; showpeople's sites should: (e) Where some or all residents may have special (a) Meet a need for such accommodation which is not needs, be subject to Policy H23; being met in the Borough or elsewhere in London, whilst avoiding over-concentration of such facilities (f) Meet a need for the facility and where necessary be in Brent in comparison to other boroughs; restricted by condition to that type of hostel; and (b) Have acceptable road and pedestrian access and be (g) It complies with the criteria for conversions / accessible to local services and public transport; extensions set out in Policy H24. (c) Be located away from existing residential areas; I] Purpose built student / worker hostels should be located at or close to the institution they serve or (d) Be suitably screened and landscaped; and with easy public transport access to it. (e) Be on a site environmentally acceptable for resi- II] Foyer accommodation will be permitted at suitable dential development (Policy STR19). sites - with particular priority to the Wembley Park area serving the proposed National Stadium. Mixed business / residential sites will be permitted in suitable locations. /...

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1944-1964 6,241 6.8 APPENDIX H1: Post 1964 14,101 15.3 BRENT KEY HOUSING INFORMATION Total 91,899 1. EXISTING HOUSING STOCK Source- Brent Housing Stock Condition Survey 2003:NB - excludes Table 1: Household Composition c10,000 Council dwellings, the majority built after 1944

Total Households with residents 99,991 2. HOUSING DEVELOPMENT IN BRENT

Average household size 2.61 persons Table 5: Net Dwellings Planning Permissions

One Person Households 28.9% (34.7% London) Year 2000 2001 2002 2003

Five + Person Households 12.1% (8.3% London) Total 598 764 624 926

Table 2: Type of Accommodation Affordable 373 274 282 323

Type Number % Table 6: Net Dwellings Completed

Semi / detached houses 34,391 34.4 Year 2000 2001 2002 2003

Terraced Houses 18,911 18.9 Total 566 964 307 1063

Purpose Built Flats 26,721 26.7 Affordable 319 469 95 399

Converted Flats 18,696 18.7 Table 7: Source of Dwellings Completed In 2003

Caravan .etc. 121 0.1 Type Number %

Shared Dwellings 1,151 1.2 New Build 740 69.6

Total 99,991 Conversion 272 25.6

Table 3: Type of Tenure Change Of Use 51 4.8

Type Number % Total 1,063

Owner Occupation 55,928 55.9 Table 8: Size of Dwellings Completed In 2003

Social Rented 23,881 23.9 Bedrooms Number %

Private Rented 18,171 18.2 One 268 25.2

Other 2,011 2.0 Two 620 58.3

Total 99,991 Three 79 7.5

Source-(Tables 1,2,3)- Census 2001 Four+ 96 9.0

Table 4: Age of Brent Dwellings Total 1,063

Construction Date Number % Source-Brent Planning Housing Monitoring (provisional)

Pre-1919 25,645 27.9 Net self contained dwellings includes work-live units

1919-1944 45,912 50.0

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clear intention of Government policy on funding social housing that units APPENDIX H2: gained through planning should be additional and not a drain on limited capital funding. The Council will therefore take the following position so SECURING AFFORDABLE HOUSING gains in land value are not subsidised.

The Council proposes to, as a general rule, use standard clauses - either as planning conditions or obligations as appropriate - linked to strict defini- APPLICATIONS TO REMOVE AFFORDABLE tion of terms in the UDP- to secure affordable housing; especially when to HOUSING REQUIREMENTS be provided by registered social landlords & for speculative developments. If funding is not available the 'cascade' format suggested in The Council will not approve an application to remove an affordable hous- Circular 06/98 (para. 19) would call into play the procedure in the next ing condition / obligation or reduce provision from such a condition / obli- section. Such conditions will also be appropriate where the proposed gation unless there has been no demand for the land / units, or a reduced lower parking standard for affordable housing is used. In most cases proportion of the land / units, from a registered social landlord of units of a involvement of a registered social landlord per se will be considered suffi- form / location meeting their requirements. cient to secure affordability in perpetuity. Very few Borough residents in housing need will be in a financial position to exercise their rights under These should have been actively marketed over a reasonable period to all the housing acts to use purchase grants to 'staircase' to partial or full own- such bodies operating within Brent; at no more than site preparation costs ership. On some high value sites however it may be necessary to secure reasonably relating to that part of the site, plus existing use value, and affordability in perpetuity through removing the section on rights under the where this valuation has been confirmed by an independent valuer housing acts / 'staircasing'. (approved by the Council and paid for by the developer). Where a relax- ation is permitted first consideration will be given to off-site provision followed by an alternative scheme of low-cost market housing on site. PROPOSED SCOPE OF REQUIREMENT:

The use of the residential accommodation secured as affordable housing APPENDIX H3: as part of planning permission shall secure, as such, a minimum number of X units available to Brent residents provided as a result of the total CALCULATION OF DENSITY development. The provisions of this agreement shall: Density is calculated as follows: (1) Not bind any mortgagee of the provider of affordable housing or any receiver or manager (including an administrative receiver) appointed Number of Habitable Rooms pursuant to the Law of Property Act 1925 or otherwise by a party who Site Area has provided loan facilities to the provider of affordable housing; (2) Cease to apply to any part of the affordable housing land and the DEFINITION OF A HABITABLE ROOM affordable housing units on such part being transferred or leased by any mortgagee of the provider of affordable housing or any receiver Habitable rooms are all rooms except hallways, bathrooms, WCs, laundry or manager (including an administrative receiver) appointed pursuant rooms and storage cupboards. Only kitchens of above 13 sq.m. count as to the Law of Property Act 1925 or otherwise by a party who has pro- habitable rooms. Bedsitting rooms are counted as 1.5 habitable rooms. vided loan facilities to the provider of affordable housing; The maximum size for a single habitable room is counted as 18 sq.m, (3) Cease to apply to any part of the affordable housing land and the where the room could be easily subdivided to provide an additional bed- affordable housing units where the provider of affordable housing room. Larger rooms are counted as 2 habitable rooms. shall be required to dispose of any part pursuant to a right to buy under the Housing Act 1985 or the Housing Act 1996 or any similar or SITE AREA substitute right applicable or the initial grant of a shared equity lease granted in respect of any part or shall be required to sell to a tenant For purposes of calculating residential density, site area includes the part with the benefit of a voluntary purchase grant provided under the of the site used for residential purposes, together with associated amenity Housing Act 1996 (or any similar provision in subsequent legislation). and landscaping space. It excludes existing or proposed areas of public open space which bound or are contained within a site. It also includes an area up to half the width of the longest adjacent road, to a maximum width Provision of ‘Affordable housing’, in this context means use by, or first sale of 6m. (Derived from RICS Code of Measures Practice, 1977). The artifi- to, a body for the purposes of providing housing accommodation to meet cial subdivision of sites between elements of family and non-family hous- the objectives of a registered social landlord (being a registered housing ing, so as to gain the benefits of the higher non-family density, will not be association, trust or co-operative eligible to receive a Housing Association permitted. Grant).

Despite the above there may be occasions where a developer claims that affordable housing cannot be provided on site and they may apply to discharge a condition or obligation, where they claim to have offered a site to a provider of affordable housing at nominal or no discount. It is the

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Brent Unitary Development Plan - 2004 106 TRANSPORT 6 TRANSPORT

Page 6.9 ROADS, SAFETY AND TRAFFIC MANAGEMENT 122 6.1 INTRODUCTION 108 TRN12 ROAD SAFETY AND TRAFFIC 6.2 BACKGROUND 108 MANAGEMENT 122

6.3 STRATEGIC CONTEXT 109 TRN13 TRAFFIC CALMING 123

6.4 POLICY OBJECTIVES 111 TRN14 HIGHWAY DESIGN 123

6.5 BOROUGH STRATEGY 112 TRN15 FORMING AN ACCESS TO A ROAD 124

TRN16 THE LONDON ROAD NETWORK 124

POLICIES & PROPOSALS TRN17 RESTRICTIONS ON NEW ROADS 125

6.6 THE TRANSPORT IMPACT OF TRN18 GLA ROADS - THE NORTH DEVELOPMENT PROPOSALS 113 CIRCULAR ROAD 125

TRN1 TRANSPORT ASSESSMENT 113 TRN19 IMPROVEMENTS TO STRATEGIC ROAD JUNCTIONS 126 TRN2 PUBLIC TRANSPORT INTEGRATION 114 TRN20 LONDON DISTRIBUTOR ROADS 126 TRN3 ENVIRONMENTAL IMPACT OF TRAFFIC 114 TRN21 LOCAL TRAFFIC MANAGEMENT TRN4 MEASURES TO MAKE TRANSPORT STRATEGIES 126 IMPACT ACCEPTABLE 116 6.10 PARKING AND TRAFFIC RESTRAINT 126 TRN5 TRANSPORT INFRASTRUCTURE - DESIGN AND ENVIRONMENTAL TRN22 PARKING STANDARDS - NON- CONSIDERATIONS 116 RESIDENTIAL DEVELOPMENTS 128

6.7 PUBLIC TRANSPORT 116 TRN23 PARKING STANDARDS - RESIDENTIAL DEVELOPMENTS 129 TRN6 INTENSIVE DEVELOPMENT AT SELECTED TRANSPORT INTERCHANGES 117 TRN24 ON-STREET PARKING 130

TRN7 NEW RAIL AND UNDERGROUND TRN25 PARKING IN TOWN CENTRES 131 INFRASTRUCTURE 119 TRN26 RE-USE OF SURPLUS CAR PARKING 131 TRN8 NEW RAIL STATIONS - DESIGN CONSIDERATIONS 119 TRN27 RETENTION OF ESSENTIAL OFF-STREET PARKING 131 TRN9 BUS PRIORITY 120 TRN28 RESTRICTIONS ON OFF-STREET PUBLIC 6.8 WALKING AND CYCLING 120 PARKING AND CONTRACT PARKING 132

TRN10 WALKABLE ENVIRONMENTS 121 TRN29 STATION CAR PARKS 132

TRN11 THE LONDON CYCLE NETWORK 122 TRN30 COACHES AND TAXIS 132

TRN31 DESIGN AND LAND TAKE OF CAR PARKS 133

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6.1 INTRODUCTION

6.11 FREIGHT 133 6.1.1 Policies in this chapter are concerned with the integration of land- use decisions with decisions on transport investment and man- TRN32 PROVISION AND PROTECTION OF RAIL agement - within the locational framework in the part I (strategy) AND WATER FREIGHT FACILITIES 133 section of the Plan - this way reliance on the private car can be reduced. The policies relate to the transport impact of develop- TRN33 RESTRICTION OF HEAVY GOODS ment, and to new transport proposals with land-use implications. VEHICLES THROUGH RESIDENTIAL AREAS 133 6.1.2 The level of resources available for transport investment cannot be predicted over the lifetime of the Plan. The Council's interim TRN34 SERVICING IN NEW DEVELOPMENT 133 transport plan (to become a local implementation plan for the Mayor of London's Integrated Transport Strategy) will roll forward 6.12 TRANSPORT NEEDS OF DISABLED spending proposals annually. The Council is also in the process PEOPLE & OTHERS WITH of reviewing its Road Safety Plan, developing a Road Traffic MOBILITY DIFFICULTIES Reduction Plan and an Air Quality Action Plan (which will be 133 drawn together within the new local implementation plan), which also set out detailed measures for implementation taken in the TRN35 TRANSPORT ACCESS FOR DISABLED light of the policies in the Unitary Development Plan. The UDP PEOPLE & OTHERS WITH MOBILITY has also had full regard to these complementary strategies. DIFFICULTIES 134 6.1.3 Many of the measures that will need to be implemented fall out- APPENDIX TRN1 BRENT’S ROAD NETWORK 134 side the control of planning, or the Borough. Brent's transport problems do not begin or end at its borders. A sustainable trans- APPENDIX TRN2 PARKING AND SERVICING port strategy for Brent is only meaningful as one piece in the jig- STANDARDS 135 saw of a sustainable transport strategy for London - implemented in partnership with transport operators and the various London- APPENDIX TRN3 HEAVILY PARKED STREETS 140 wide transport bodies. The most important contribution of planning to this is to influence the design, amount of parking, traffic MAP TRN1 PUBLIC TRANSPORT and environmental impact, and location of new development. ACCESSIBILITY 146

MAP TRN2 LONDON BUS PRIORITY AND 6.2 BACKGROUND CYCLE NETWORKS 147 EXISTING TRANSPORT CONDITIONS MAP TRN3 BRENT’S ROAD NETWORK 148 6.2.1 The Borough has a complex road and rail- based public transport network, with: 45 daytime bus routes, 5 night bus routes, serving nearly 600 stops, and 26 Network Rail and London Underground stations. Although, overall, rail/tube infrastructure is good, the Borough suffers from poor interchange in key regeneration areas such as Park Royal, Wembley and Harlesden. Linkages between bus and tube/rail, and between tube lines need to be improved.

6.2.2 The North Circular Road (A406) is the backbone of the road network in Brent, and broadly divides the more suburban north of the Borough from the more densely urbanised south. It is the main orbital road within North London but, as a consequence, there is severe pollution and noise impacts upon the residential areas adjoining it.

6.2.3 On-street parking problems are extensive in shopping areas, in older industrial and commercial areas and older terraced streets and in areas around underground and rail stations.

6.2.4 In Brent car ownership is low when compared with national levels; 37% of households have no access to a car, with marked variations throughout the Borough (source 2001 census). Most trips

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made by Brent residents are within Brent or to other parts of outer 6.2.8 One of the main concerns is over poor air quality. This is worst on north-west London. Only 16% of all daily trips are made into major roads such as the North Circular Road, where lead and Central London (source LATS 1991). particulate matter (pm10 ) levels, arising principally from commercial vehicles, create a severe public health problem. Residential THE PROBLEMS THIS CAUSES properties along such roads also suffer from unacceptably high noise levels. 6.2.5 The trend is for traffic levels to continue to grow, with increasing Brent car ownership and use and decreasing journey speeds in 6.2.9 Also, the regeneration of some areas may be hindered unless the London. This growth has had unacceptable consequences public transport infrastructure can be upgraded to cope with including: planned development and local residents are able to travel to work using alternatives to the private car. 1) Economic Impacts • Congestion affecting the ability of firms to obtain and make deliveries and to attract a workforce; 6.3 STRATEGIC CONTEXT • Discouraging inward investment in urban areas. THE GOVERNMENT'S INTEGRATED TRANSPORT 2) Social Impacts WHITE PAPER 1998 • Affecting and limiting choices of non-car transport modes, such as cycling, walking and buses; 6.3.1 The main theme of the White Paper is integration which it defines • The social & health problems (e.g. stress) resulting from long as: integration within and between different types of transport to and difficult commuting times; make connections work; between transport and environment poli- • Safety of vulnerable road users, in particular children and the cy for a better environment; with land use planning to reduce the elderly. need to travel; and between transport and our policies on education, health and wealth creation so that transport helps make a 3) Environmental Impacts fairer, more inclusive society. • Poor air quality and the consequent impact on public health; • Noise & vibration; 6.3.2 The White Paper aims to achieve a better balance so that people • The severance and visual impact of transport, both directly are encouraged to reduce car usage in favour of more environ- and indirectly, on the form and appearance of places; mentally friendly modes, such as public transport. Amongst the • The loss of non-renewable resources, e.g. oil; planning related measures proposed are: • The effect on global warming through the release of green house gases. 1. New income streams for local authorities to tackle pollution and congestion by levying charges for driving into town cen- 6.2.6 Traffic growth within a limited capacity of road network inevitably tres and for workplace parking; produces traffic congestion, which has exacerbated the problems 2. Interim Transport Plans (in the case of London), to deliver listed above. For example slow moving traffic has a greater air five-year strategies to meet local needs. These will cover all quality impact. But improving traffic movement universally, how- forms of transport and include local targets for improving air ever, might simply encourage car traffic growth, and could lead to quality, road safety, walking and cycling, public transport and a shift away from public transport. road traffic reduction. In London this will take the form of an Integrated Transport Strategy to be drawn up by the proposed 6.2.7 The advantages of non-car modes in reducing these problems is Mayor with the boroughs bidding for funding through 'Local illustrated below: Implementation Plans'; 3. Greater investment in bus services, through up-graded Environmental Impact of Different Modes of Motorised Quality Partnerships between local authorities and operators; Transport 4. A Strategic Rail Authority, which will take on the task of managing passenger railway franchising, driving up service quali- Energy Pollution Noise ty; -Particulates Decibels 5. Better Land Use Planning; it proposes emphasising access to (Index v. Bus=1) leisure, jobs and services by foot, bicycle and public transport. Policies for parking should support this. Development Car 2.3 1.5 3.8 plans should better safeguard facilities for sustainable transport. New housing should avoid undue reliance on the car. Bus 1.0 1.0 1.0 Future development in Brent, along with future spatial plans, should complement the Council’s Local Implementation Plan Tube 1.4 0.2 <0.001 for Transport. Where appropriate, proposed (journey generating) development, such as major places of employment/res- Source: LT (1995) and AEA Technology (1994) - data applies idential proposals, should be supported by a Sustainable to London, adjusted for patronage. Travel Plan, where it is anticipated a development may gener-

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ate significant additional journeys. As a result, major develop- unlikely to be well served by non-car modes for uses which are ment should only take place where excellent , dedicated, pub- not travel intensive. It states that “Developers putting forward lic transport can be guaranteed. large development proposals (possibly incorporating a number of individual elements) which involve major travel demand need to GUIDANCE ON PREPARING FULL LOCAL be flexible in terms of considering the potential for tailoring, reduc- TRANSPORT PLANS 2000 ing, or splitting projects so that they can be accommodated in the preferred locations or on existing sites, particularly those which 6.3.3 This stresses the importance of integrating local transport plans are highly accessible by non-car modes.” (para 27). and development plans, and that ideally their preparation should take place in parallel. Authorities need to undertake a fundamen- 6.3.9 It recommends negotiating improvements to public transport as tal review of their transport strategy. Planning polices on parking part of development proposals, in order to reduce the need to need to minimise the level of parking associated with develop- travel by car and parking at such sites. It states “The development through the adoption of maximum standards. In London, ment plan should indicate the likely nature and scope of contribu- boroughs will have to prepare local implementation plans of how tions which will be sought towards transport improvements as they intend to implement the Mayor’s Transport Strategy. part of development in particularly areas or on key sites. This will give a greater certainty to developers as to what will be expected as part of development proposals and also provide a firmer basis for investment decisions in the plan area.” (para 83). Transport PPG12 DEVELOPMENT PLANS (1999) assessments should be submitted with major developments and 6.3.4 This stresses the role of development plans in integrating trans- should illustrate the likely modal split of journeys, and details of port and land use policies. The development plan strategy should proposed measures to improve public transport, walking and underpin the land use issues arising from the implementation of a cycling and reduce the number and impact of motorised journeys local transport plan. Development plans should include specific associated with the development. The role of green transport policies and proposals on the overall development of the trans- plans is stressed in this regard, and these can be required where port network and related services. Traffic reduction and air quali- transport impact is a particular concern. ty targets should be included.

6.3.5 There is a strong presumption against the building of new roads THE NATIONAL AIR QUALITY STRATEGY unless all other options (assessed through a multi-modal (1997) AND ACCOMPANYING CIRCULARS appraisal including of public transport improvements) are shown (15/97) to be impractical (para 5.18). It states “alternative uses related to sustainable transport should be considered first for sites now sur- 6.3.10 This sets out a new system of local air quality management in plus to transport requirements” (para 5.23). which local authorities will take the lead. Local authorities are required to identify and designate Air Quality Management Areas (AQMAs), with air quality action plans setting out how acceptable levels of air quality can be reached by 2005. Development Plans PPG13: TRANSPORT (2001) and Air Quality Action Plans should have regard to each other, 6.3.6 The guidance aims to promote more sustainable transport choic- and it is stressed that the impact of a development on air quality is es and reduce the need to travel, especially by car. It stresses a material planning consideration. that strategies in the development plan and the transport plan should complement each other and that consideration of development plan allocations and local transport investment and priorities MAYOR OF LONDON TRANSPORT STRATEGY are closely linked. (2001)

6.3.7 Amongst the main planning policies that it promotes is to focus 6.3.11 The (London) Mayor’s Transport Strategy is being implemented, major generators of travel demand in town and district centres in the main, by the interim Local Implementation Plan, 2001 and near to major transport interchanges and to locate day to day (ILIP), and since then, via the annual Borough Spending Plan facilities in local centres so that they are accessible by walking (BSP) submissions. A statutory document which will supersede and cycling. A key planning objective is to ensure that jobs, shop- the ‘ILIP’, known as the ‘LIP’ (Local Implementation Plan), will be ping, leisure and services are highly accessible by public trans- developed by Brent and all London Boroughs between July 2004 port, walking and cycling. It particularly stresses contributing to and December 2005. This Process begins with the preparation of social inclusion by ensuring that development is accessible by a draft LIP, following consultation with the Boroughs, carried out public transport from deprived areas. It requires parking policies during April/May 2004. The Council has submitted a comprehen- which restrain the overall amount of parking to reduce reliance on sive response to the Draft LIP Guidance, which is attached to this the car for work and other journeys. document. It is stated, that the policies and proposals set out in the Strategy should, over the next ten years, noticeably reduce 6.3.8 It requires development plans to allocate sites for intensive devel- the growth in traffic that would occur across Greater London if opment, potentially mixed-use, where these are highly accessible present trends were to continue. In outer London, recognising by non-car modes, and conversely allocate or re-allocate sites that the car will remain the dominant means of travel, even with

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the Strategy’s proposed improvements to public transport, walk- London from the busiest international airport in the world ing and cycling, the net effect is likely to be a reduction in the (Heathrow). The National Stadium will also become a focus for growth in traffic by a third to 5% , over the next ten years. national and international trips. For this reason it is essential that Brent's strategy is compatible with those of other West London 6.3.12 Boroughs are encouraged to introduce local measures to reduce Boroughs. Consequently West London Leadership has prepared this growth further. The lower level of growth in outer London will an integrated transport strategy for West London for this purpose, happen over a longer timescale, in particular reflecting longer focussing on improving radial links and improving integration at term changes in population and land use patterns. In outer major regeneration locations. London town centres there is the potential to achieve zero growth, particularly where through traffic can be removed. The traffic THE DRAFT LONDON PLAN (SPATIAL reductions that are actually achieved will be influenced by the DEVELOPMENT STRATEGY FOR GREATER range of measures introduced at the local level by boroughs, as LONDON) well as Londonwide initiatives. Action by all London’s local authorities will be required if the targets are to be attained. The Mayor 6.3.17 The Draft London Plan emphasises that transport planning and will support local borough initiatives that aim to achieve greater spatial development must be integrated. It states that good public reductions in traffic in specific areas, especially in town centres transport access, the provision of means of travel such as walk- and where traffic goes through unsuitable areas, and will assist ing, cycling and the use of buses, and a reduction in dependence the boroughs in meeting their obligations under the Road Traffic on the private car are all necessary conditions for sustainable Reduction Act 1997. development. Development generating large amounts of travel needs to be concentrated where adequate public transport capacity exists or is planned. REGIONAL PLANNING GUIDANCE FOR THE SOUTH EAST (RPG9, 2001) 6.3.18 In promoting reduced dependence on the private car it is recognised that control over the inefficient and unattractive use of 6.3.13 This sets out the regional transport strategy for the South-East. It scarce land for car parking is necessary. The Draft London Plan states that the management of future travel demand will be a cru- includes maximum parking standards to be taken into account cial aspect of this, including restraint on car parking. It sets down when drawing up UDP policies and standards, whilst taking a range for maximum parking standards for B1 uses within Outer account of local circumstances. London. In the South-East a more rigorous approach towards parking standards is required than in PPG13. 6.4 POLICY OBJECTIVES STRATEGIC GUIDANCE FOR LONDON PLANNING AUTHORITIES (RPG3, 1996) 6.4.1 Taking into account the background to transport in the Borough, and the various requirements of Government policy and guid- 6.3.14 Encourages boroughs to “work in partnership with both public ance, the objectives of the Unitary Development Plan's policies transport operators and private developers in linking development towards transport are as follows: sites with improved public transport infrastructure and interchange points, and in maximising developer contributions” (para 1. To reduce the environmental by-products of traffic, such as 7.9). It advises that boroughs should safeguard new rail infras- noise, vehicle emissions and accidents; tructure in UDPs. It also advises the mapping of the London Bus 2. To reduce the need to travel, especially by the private car. To Network, and the inclusion of plan priorities promoting good promote social inclusion by planning for houses, jobs and access by and to, buses in new development. local facilities in close proximity and ensuring access for the whole community to development, whilst minimising sever- 6.3.15 The guidance emphasises the importance of plan policies pro- ance of communities by traffic; moting walking and cycling. On parking policy it encourages bor- 3. To co-ordinate planning and regeneration to achieve transport oughs “to seek a balanced approach which recognises the legiti- improvements which enhance the attractiveness of regenera- mate need for parking to meet economic objectives and enhance tion areas, as well as ensuring that development in regenera the respective position of their areas but set that against the envi- tion areas is designed and located so that it is attractive to ronmentally damaging effects of traffic movement and the impact access by public transport, where necessary by securing ser- of parked cars.” (Para 7.46). It sets down maximum parking stan- vice improvements; dards Londonwide for employment generating land-uses. 4. To ensure that the Borough's residents, workforce and visitors have real choices in the means of transport they use, and that it is convenient, frequent and reliable, in a Borough free of WEST LONDON TRANSPORT STRATEGY excessive traffic volumes and congested parking. In particular to improve the quality of accessibility by public transport, 6.3.16 The importance of Brent's transport system within West London walking and cycling; must be stressed. West London functions as the national gate- 5. To make better use of existing roadspace reducing the envi- way to Central London from much of the north-west and south- ronmental impact of traffic by prioritising sustainable modes of west of the country, and as the international gateway into Central transport - such as walking, cycling and buses - in managing

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traffic. Using this to minimise the amount of roadbuilding to 6.5.5 With the national shift away from building roads, priority needs to principally that which essential to secure access to poorly be given to making better use of existing roads. The table below accessed regeneration areas; sets out a framework for doing this in Brent. This cannot mean 6. To ensure that the needs for freight transport and servicing simply increasing their capacity to take through traffic - this is like- are met - including a greater emphasis on non-road based ly to be counterproductive and have unacceptable air quality freight transport; implications. Priority is given to the movement of 'people and 7. To ensure that planning decisions support the targets set in goods' rather than vehicles per-se. the Borough's Air Quality Strategy, Traffic Reduction Plan and Road Safety Strategy. Framework for Making Better Use of Brent's Roads

i) First priority is given to ensuring that the management of roadspace improves road safety. Public transport is the safest mode; 6.5 BOROUGH STRATEGY ii) It will not be possible to manage this roadspace in line with the 6.5.1 The three key aims of the UDP - Improving the environment, current rates of growth in car ownership and use. To improve air regenerating run down areas and providing access for the whole quality and to free road capacity for road based public transport community - are conflicting if unsustainable modes, such as the and cycling it will be necessary to plan for and implement mea- private car, predominate. Transport is very rarely an end in itself - sures which control this trend; its role is to facilitate social and economic activities. Therefore land use decisions need to be integrated with the public transport iii) All of Brent's roads are part of the wider London Road Network. network and the development of an integrated transport system The top tiers of this need to take essential through traffic, such as linked to regeneration programmes and environmental improve- freight, as well as buses prioritised through traffic management ment. Integration also needs to be more comprehensive; there measures such as segregation, priority routing and signalling - needs to be sufficient public transport to take journeys shifted and other through trips which cannot presently be transferred to from the private car, it also requires a greater emphasis to the public transport; neglected mode of transport that does the integrating - i.e. walking - and on means of integration, such as interchange facilities. iv) It is environmentally unacceptable for through traffic to use local Public transport will not be used unless there are walkable envi- residential roads, hence steps need to be taken to remove this ronments at the beginning and end of the public transport compo- traffic, such as traffic calming and management measures. In nent of the journey. considering such measures, the highway authority will consult with local residents, businesses and the emergency services; 6.5.2 The Borough strategy is to focus transport investment, especially public transport investment, in support of key regeneration oppor- v) The Planning and Highway Authority will consider whether or not tunities (including town centres which are the areas most likely to the through traffic generated or attracted by development is be accessible by public transport) and to provide additional acceptable in terms of the capacity and functions of the Strategic capacity in areas of high demand, in order to achieve a significant Road Network and London Distributor Roads, whilst wholly dis- shift away from the use of the private car. This will be reinforced counting any potential any local roads may have for carrying by restricting parking in developments and increasing on-street through traffic; parking controls. Focusing development in these areas can also reduce the need to travel, by locating jobs, homes and services in vi) To ensure that there is road capacity to meet these aims there proximity to each of these. will be a need to extend on-street parking controls, as well as introducing traffic restraint measures such as restricting private 6.5.3 The problem for rail and underground is a lack of services on non-residential parking. some lines and lack of interchange facilities. For the road based transport system improvements will require a re-allocation of road space away from cars towards public transport, cycling and walking.

6.5.4 Early attention needs to be given to reducing those types of car- borne trips that can be most easily shifted to more sustainable modes. Examples include trips carrying children to and from school, shorter trips than can be easily made by foot and cycle, and work trips to town centres and other areas with good public transport. Longer term measures need to be focused on the more difficult issue of commuter and shopper journeys, although some measures can have an early impact - such as parking restraint.

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POLICIES AND PROPOSALS

6.6 THE TRANSPORT IMPACT OF DEVELOPMENT PROPOSALS 6.6.1 The traditional method of dealing with the impact of traffic from development has been superseded by requirements for a more comprehensive assessment of impact, via transport impact assessment. This looks at what impact development has on travel patterns for all modes of transport, i.e. walking cycling, car- use, public transport etc.

6.6.2 Note: The allocation in the Plan of areas for development or redevelopment carries no guarantee that particular proposals submit- TRN1 TRANSPORT ASSESSMENT ted for planning permission will be acceptable on transport grounds, either to the Borough, or (where relevant) other bodies Planning applications will be assessed, as appropriate, with a role as highways authority (i.e. adjoining boroughs on for their transport impact, including cumulative boundary roads, the Traffic Director for London and/or the impacts - on the environment and on the road net- Department of Transport. In many cases a detailed view of the work, and all transport modes, including: public trans- transport implications of a development can only be formed at the port, walking and cycling. time the application is submitted, and in the light of up to date highway and public transport capacity, and environmental infor- Developments having a potentially significant impact mation. on the transport network should submit a Transport Assessment (TA). This should incorporate proposed traffic reduction measures by the developer (e.g. TRANSPORT ASSESSMENTS Green Transport Plans).

6.6.3 Major and other developments likely to have a significant trans- Where this transport impact is demonstrated to have port impact should be submitted with a formal Transport Impact an unacceptable public transport or environmental Assessment (TIA). This is a written statement providing detailed impact (as defined in policies TRN2 & TRN3) then the information on the range of transport conditions both before and application will be refused, unless measures are after a proposed development has been built, including details on secured as part of the application (policy TRN4) how existing conditions are likely to change as a result of any making this acceptable. other committed development or transportation proposals in the area. These should cover all modes of transport including public transport, walking and cycling. If there is not a full Environmental Statement (Policy EP1) accompanying the planning application, PUBLIC TRANSPORT INTEGRATION then the effect of additional traffic on air pollution and noise should also be included. For smaller schemes, aspects of their 6.6.5 Policy TRN2 judges the harm that can potentially result when transport impact would still need to be assessed through the nor- development is proposed without the necessary public transport mal development control process (against the policies of the infrastructure and/or services to access it sustainably. The impact Plan). of good public transport by itself is likely to be low in that it is a necessary but not sufficient condition for public transport patron- 6.6.4 It is important that TIAs are objective and accurate assessments age. Most will still drive if they have access to a parking space at of a proposal rather than simply promotional literature. They the end of a journey. Therefore the policy needs to be read along- need to positively identify & tackle the transport problems associ- side the Plan's restraint-based policy on parking for non-residen- ated with a development and suggest solutions. For this reason it tial development (Policy TRN22), which mean that most trips to is not recommended that they are prepared after a development the development will need to be by public transport; and the is designed but instead in parallel with the early design stages. In Plan's policy on the 'Sequential Approach' (Policy STR2) which many cases, such as where a development is for a specific occu- requires development attracting significant numbers of people, in pier, it will be possible to incorporate proposed traffic reduction the first instance, to be located in town centres. As the new park- measures (e.g. green commuter plans) with the TIA; in such ing standards are much lower than the parking demand for most cases their inclusion will be a requirement. For speculative out- uses, these uses may not be appropriate in locations where a line schemes, conditions should be placed on the outline con- deficiency in public transport means that unacceptable on-street sents requiring such plans to be submitted and approved by the parking will occur; especially where there are not sufficient on- local planning authority, when the appropriate reserved matters are determined.

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street parking controls to contain this, and/or where this would significantly increase the number and/or length of journeys by the TRN3 ENVIRONMENTAL IMPACT OF TRAFFIC private car. Where a planning application would cause or worsen 6.6.6 Integration: To provide an attractive alternative to the car, public an unacceptable environmental impact from traffic transport must operate as a true network. Existing measures generated it will be refused, including where: such as the Londonwide travelcard and Londonwide bus network (a) The anticipated level of car generation/attraction is planning need to be built on to provide more through-ticketing, greater than the parking to be provided on site in better connections and co-ordination of services, wider availability accordance with the Plan's standards and any of information and improved waiting facilities. The Government resulting on-street parking would cause unaccept- has commissioned the Chartered Institute of Transport (CIT) to able traffic management problems; and/or produce an audit or check-list to address a wide range of possible (b) The proposal would have unacceptable environ- interchange improvements (concentrating in most detail on physi- mental problems such as noise or air quality (espe- cal aspects of interchange). cially affecting air quality management areas); and/or

(c) The development would not be easily and safely TRN2 PUBLIC TRANSPORT INTEGRATION accessible to pedestrians and/or cyclists; and/or

Development should benefit and not harm the (d) Additional traffic generated would have unaccept- operation of the public transport network, and should able consequences in terms of access/convenience be located where the public transport accessibility is for pedestrians and/or cyclists; and/or sufficient to service the scale and intensity of the use; (e) The proposals would produce unacceptable road in particular: safety problems; and/or

(a) The capacity of the public transport network, with- (f) The capacity of the highway network is unable to in convenient and safe walking distance of the site, cope with additional traffic without producing should be sufficient to accommodate any increase unacceptable levels of traffic congestion - especial- in passenger trips to an acceptable level of service; ly where this would hinder the ability of the Strategic Road Network and/or London Distributor (b) Any significant increase in traffic generated by Roads to cope with through trips, or would intro- development, and/or associated highway works, duce through traffic onto local roads; and/or should not cause material harm to the speed and/or reliability of bus services, especially on the (g) The proposal would cause a significant increase in London Bus Priority Network; and the number and/or the length of journeys made by the private car. (c) The proposal should make proper opportunity for interchange facilities between public transport modes or services.

MAKING TRANSPORT IMPACT ACCEPTABLE ENVIRONMENTAL IMPACT OF TRAFFIC 6.6.9 Where the transport impact of development proposals would be 6.6.7 Apart from the impact on public transport there are a range of unacceptable according to the preceding policies, the planning other environmental issues that comprise transport impact. and highway authorities will consider what measures, if any, may There are both direct environmental effects (e.g. noise), and indi- be possible to acceptably mitigate this. National policy supports rect effects arising from congestion, such as nuisance, loss of air the use of such measures (RPG3 para 6.9, PPG13 paras 6-12- quality, etc. 6.14, Circular 1/97 para B10), including the use of contributions to improve accessibility through improved public transport or other 6.6.8 Although the transport impact of a development may be accept- appropriate forms of infrastructure - not necessarily those imme- able to the highway authority in terms of its legal obligations on diately confined to the site. These measures will be strictly and capacity, traffic reduction, safety etc., the planning authority must proportionally related to the development in question, which may consider wider issues in making it's decision e.g. noise from traf- include access improvements to the area in which the develop- fic, inconvenience to existing highway users from generated traf- ment is situated, and will not be used to relieve existing problems fic etc. unless the development would exacerbate an already unacceptable situation. Not every development can be made acceptable in transport terms; sometimes it might just be the wrong use in the wrong location or it might require a thorough redesign or a reduction in scale.

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6.6.10 Where the Plan's new 'restraint based' parking standards (policy public transport may not be an adequate substitute for a develop- TRN22) are applied there is the danger of unacceptable on-street ment that is poorly located as, even after the contributions, the parking where limited or no on-street parking controls exist. A site may not be as accessible as other sites, such as those in contribution towards bringing forward an existing programmed town centres. It needs to be considered, therefore, whether the scheme, or creating a new scheme, may help tackle this problem improvements make public transport a genuine alternative to car (see Policy TRN25). use such that it will significantly affect the modal split of travel to a development. Secondly, any contribution might only be over the 6.6.11 The organisation that would occupy a development can also help short term (e.g. 3 years) but the services provided needs to be by producing company strategies such as 'green transport plans'. viable in the medium term. The main purpose of revenue contri- These can be of significant benefit in encouraging, for example, butions therefore should be for 'pump priming'. Money is needed employees or other users of a development to reduce their car- because the early stages of a development may not generate use, and are now tax-free. A good Green Transport Plan should enough demand to justify services being provided in their own preferably include annual % targets for car-reduction and include right. However, it is always necessary to provide public transport management arrangements to continuously map and monitor early in the life of a development to ensure that people have a car-use and travel patterns of employees with incentives and choice of transport modes and do not become dependent on car information to employees to reduce car-use. These incentives use. It will not be sufficient to anticipate that operators will service should ideally be subject to monitoring and review at least every a development - this should be discussed with the operators and two years and this shall be the responsibility of a named manag- the planning authority at an early stage. er. Some examples of the measures that should be considered include: 6.6.15 Securing Developer Contributions; As a general rule developer contributions will be sought to secure transport improvements • Car sharing; sufficient to overcome any transport impact objections arising • Travel awareness and incentives to walk, cycle and/or use from the development. public transport; • Flexitime and staggered working hours; 6.6.16 If what could reasonably be sought through developer contribu- • Teleworking; tions from a single planning obligation, is not sufficient to over- • Communal travel arrangements for employees (e.g. coach- come transport objections, and it is desirable that the scheme es); and goes ahead on regeneration grounds, then the approach in these • Local recruiting and training arrangements. circumstances may be:

6.6.12 Public transport contributions; Whilst it is desirable for develop- (i) To grant permission subject to a condition linking the imple- ments to be located close to the public transport network, it is mentation of the development or phases of the development recognised that for some areas, particularly certain parts of some to specific improvements (subject to the requirements of rele- regeneration areas, developments attracting significant numbers vant transport authorities); or of people could be acceptable providing there are public transport (ii) To secure from the developer a contribution to the cost of improvements, in order for the overall transport impact to be infrastructure improvements; or acceptable. Improvements could take the form of new capital (iii) To secure from the developer a contribution designed to items or revenue costs such as new or enhanced bus or rail ser- enable a project which is already programmed to be brought vices that provide links to a development or from the development forward; or to existing town and/or local centres and major facilities such as (iv) For a number of developers to contribute jointly to the hospitals. improvements required, such as through an infrastructure accord, . 6.6.13 Such improvements will be sought where the public transport impact of the development is unacceptable (Policy TRN2), for schemes attracting significant numbers of people, having regards to the following normal minimum thresholds for seeking public transport improvement obligations - also having regard to the intensity of the use:

i] Where the capacity of the public transport network is unacceptable (only the very largest schemes); ii] In areas of low public transport accessibility, for schemes of 250m2 or over; iii] In areas of moderate public transport accessibility, for schemes of 500m2 or over.

6.6.14 Two fundamental issues need to be addressed when considering developer contributions towards public transport, particularly for revenue support of services. Firstly, developer contributions for

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6.6.18 Sufficient attention must be paid to the impact of such improve- TRN4 MEASURES TO MAKE TRANSPORT ments on the full range of transport modes. For example new IMPACT ACCEPTABLE roundabouts permitted as part of new developments have made movements more difficult for pedestrians, cyclists and buses. For Where transport impact is unacceptable, measures this reason large roundabouts or pedestrian subways may now will be considered, individually or in combination, be unacceptable. which could acceptably mitigate this and enable the development to go ahead - and where necessary 6.6.18a Under the Disability Discrimination Act, from 2004 buildings and secured at the developers expense, including: transport infrastructure would require reasonable alterations to to provide access for disabled people (see DETR "Guidelines in (a) Public transport improvements sufficient to service the scheme or to integrate it with the surrounding Design of Interchanges, Terminals and Stops”). area: Developments attracting a significant number of trips in areas with low or moderate public transport accessibility will only be acceptable when TRN5 TRANSPORT INFRASTRUCTURE - significant public transport improvements (particu- DESIGN AND ENVIRONMENTAL larly to bus facilities and/or services) are secured CONSIDERATIONS which are both viable and justifiable in the longer term; Proposals for new transport infrastructure (including (b) The extension or bringing forward of on-street associated street furniture) will be assessed against parking controls/waiting restrictions; the following criteria:

(c) Improvements to pedestrian and/or cycle facilities; (a) They should not undermine the role of a road within the London Road Network (Policy TRN16); (d) Traffic calming measures; (b) Where necessary area wide traffic calming facilities (e) Acceptable road safety and essential highway should be included to prevent inappropriate traffic improvements, not necessarily restricted to junc- using local roads through residential areas. tions and road lengths adjacent to the develop- Proposals should not unacceptably divert traffic ment, providing these improvements are limited to problems elsewhere; measures necessary to make the transport impact acceptable; and (c) New roads or highway proposals should not be at the expense of alternative public transport (f) Management measures to reduce car usage to an improvements, which could have comparable bene- acceptable level (e.g. green transport plans). fits with fewer environmental problems;

Such measures should be necessary for the scheme to (d) They should not result in significant loss of housing, go ahead and be related to the development, should community or employment premises, or areas of be consistent with any existing or proposed parking importance to nature conservation; controls and Local Area Transport Strategy (Policy (e) They should not result in greater severance of local TRN22) covering the area, and should not communities; and unacceptably divert traffic problems elsewhere. (f) They should make a positive contribution to the public realm and/or the setting of open spaces or Wherever possible measures should be completed buildings (especially concerning conservation areas before the development is completed/ operational. and listed buildings).

(g) They should not have an adverse impact on the ease of movement for pedestrians, cyclists and people with disabilities.

NEW TRANSPORT INFRASTRUCTURE - ASSESSING IMPACT 6.7 PUBLIC TRANSPORT 6.6.17 Brent has adopted a common framework for the assessment of the design and other environmental impacts of transport infrastructure in line with the approach to assessment outlined in the PUBLIC TRANSPORT ACCESSIBILITY Integrated Transport White Paper. This policy covers both new public transport infrastructure, new roads proposed under Policy 6.7.1 Transport for London have produced a map of how accessible dif- TRN17 and other new highway proposals (such as junction ferent parts of London are to public transport. This is intended to improvements). help boroughs, transport operators and regulators, and above all the future Mayor, plan for better public transport. Its main functions will be to help to:

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• Decide what sorts of development should be located in what parts of London; DEVELOPMENT AT TRANSPORT INTERCHANGES • Decide where public transport frequency and/or routes should be increased; 6.7.5 There are a number of tube and rail stations in Brent that are pro- • Show those parts of London where a reduction in the use of posed to have, or already have, potential for comprehensive the private car might most easily be achieved. upgrading incorporating bus-interchange facilities; some in connection with the National Stadium proposals. These will become, 6.7.2 The accessibility map works by mapping London according to or are already, focal points with good public transport accessibility public transport accessibility levels. The higher the level the more and, as such, will be appropriate for high density development accessible a site is to London's public transport network. Brent with a mix of land uses (see Built Environment Chapter, Policy uses it as the basis of its policies which relate the location, form BE11). and intensity of development to the public transport necessary to serve it in a sustainable manner (Part I Policy STR5). Hence developments that attract significant numbers of people, such as TRN6 INTENSIVE DEVELOPMENT AT new shopping and leisure facilities, should be located in areas SELECTED TRANSPORT INTERCHANGES with the highest levels. Otherwise experience shows that too many people will use their cars to get to them and the traffic and Intensive development is supported on appropriate environmental problems will get worse. The Borough is divided sites at/adjoining the following existing or proposed into four categories of Public Transport Accessibility (PT transport interchanges: Accessibility) - see Map TRN1. It should be noted that the description of 'good' and 'low' etc. are relative to Brent. By nation- • Kilburn (Jubilee Line); al standards areas this is quite good, but measured by Central • Kilburn High Road; London standards is poor. • Park Royal Interchange (see Policy PR5); • Queens Park; 6.7.3 It is a simple measure based on adding up the walking time to a • Willesden Junction Hub; public transport stop to the average waiting time once there. If • Wembley Central (see Policy WEM30); there is a real choice of public transport services (e.g. more than • Wembley Park (see Policy WEM31); one station or multiple bus routes) then the higher the level will • Wembley Stadium (see Policy WEM32). be. Being a deliberately simple measure however, it can only be used to judge just one aspect of the quality of public transport in Development should make full and effective use of the an area. Other things that need to be assessed are the quality of site, have a mix of land uses, (if required to by Policy public transport interchanges, the capacity of stations and the BE11) and should be orientated around pedestrians, public transport network in general, how walkable links to public buses and cyclists (with good links to the transport transport stops are and how efficient the public transport network interchange), rather than the private car. is in an area in order to be able to get from a to b. Looking at the public transport level of a site should, therefore, be just the start- The phasing and nature of development should ensure ing point of judging whether public transport is good enough that it complements the comprehensive development there. of the area.

6.7.4 The parts of Brent with the highest public transport level are generally town centres. Hence these should be the focus for intensive development. Areas close to stations and along main bus RAIL AND UNDERGROUND routes may also have high levels where there is a good frequency of service. Developers may be able to upgrade the public trans- 6.7.6 The Borough is served by 25 underground and rail stations. port level of a site by paying for new facilities/services/ increased Lines to the Midlands, the Chilterns, the North West of England frequencies (Policy TRN4). However, it is very difficult to signifi- and to Scotland pass through the Borough. cantly alter the London Public Transport Accessibility Map unless the scale of new development can pay for major upgrading. 6.7.7 The main problems associated with parts of the existing network Permitting development in areas with poor public transport acces- are infrequent and unreliable services, difficulties of access for sibility in the hope or expectation that it can improve can lead to those with mobility difficulties; poor quality of stations and inade- people's car use patterns becoming set, which are then very diffi- quate interchange facilities. The following are the key proposed cult to change. For all of these reasons the London Public rail/underground improvements affecting the Borough which have Transport Accessibility Map should be seen as a tool for applying a reasonable prospect of going ahead: the government's sequential approach directing intensive development to the most sustainable locations. This will help ensure • Three Stations strategy for Wembley; Redevelopment of that developments are accessible to the whole community, not Wembley Park, Wembley Stadium and Wembley Central sta- just those with access to a car. tions to provide adequate capacity for the intensive train service (approaching a peak of 100 trains per hour) which will be necessary to ensure the success of the new National Stadium

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as a public transport venue. Details of these proposals and • Willesden Junction Hub; Rebuilding of the ticket office, an associated development is contained in a special policy within improved Station approach, bus turn-around and waiting the Wembley Regeneration Area Inset Plan Chapter (policy area, and bus/rail interchange. Brent supports an additional WEM 10). phase of the project to re-instate the main line platforms; • Orbital Rail Services; Potential for continued improved services on the North and West London lines, new stations on the West London line and the longer term potential to link these as part of an 'outer circle line'; NEW RAIL AND UNDERGROUND • Channel Tunnel; Connections from the Borough to the termi- INFRASTRUCTURE nus at St Pancras and the international station at Stratford. Direct access to these international stations will be possible 6.7.8 The main proposals in the Borough for the provision of new rail via Metropolitan and Jubilee/North London lines respectively. and underground infrastructure, other than those associated with There is also the potential for direct Channel Tunnel services the National Stadium, are listed in the policy below. Of these pro- to the National Stadium if under-used freight track (in the jects only the East-West Crossrail scheme involves a statutory Hythe Road area in Hammersmith & Fulham) is upgraded to safeguarding line. All other projects involve existing operational establish a link between the West London Line and the or highway land. Dudding Hill Line. Tunnel freight services already use Willesden-Brent sidings for marshalling; 6.7.9 In most cases new stations will require permission in not being • The Chiltern Line; Proposals for enhanced frequency of ser- fully contained within operational land, and as they contain addi- vices and station improvements (Chiltern Metro); tional non-operational uses. The location of new stations is not • East-West Crossrail; Formal safeguarding directions protect under the control of the Borough but is the responsibility of those the proposed East-West Crossrail line to protect it from alter- responsible for the track and rail/tube services. However, the native development, but no implementation package has Council can promote the building or rebuilding of stations - espe- been put in place. cially where these are related to development proposals. • Park Royal Interchange; The Council, in conjunction with the London Borough of Ealing, is seeking the provision of a new Central Line Station with a link to the Piccadilly line as part of the Park Royal Western Gateway development proposals, with improved pedestrian access and bus interchange facilities (see Policy PR5); • Intermediate Modes; London Transport (now Transport for London) published a series of proposals for 'intermediate modes'. In terms of capital expenditure and capacity they would be 'intermediate' between buses and rail and can take a number of forms including guided busways, trolleybuses and trams/light rail. The Council has examined long term options for provision of an intermediate mode route from Wembley to Park Royal Interchange.

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TRN7 NEW RAIL AND UNDERGROUND INFRASTRUCTURE

The following new Rail and Underground infrastructure projects are supported, and will, where necessary, be safeguarded:

(a) East-West Crossrail; The area shown on the proposals map is safeguarded, as required by the Government;

(b) Park Royal Interchange; As a necessary requirement of large scale trip-attracting development here (see Policy PR5);

(c) Willesden Junction Hub. Planning decisions should ensure that development proposals are fully integrated with these. achieved. It is nevertheless considered essential to provide connections between the main residential areas of the Borough and the main employment, shopping and recreational areas and schools and hospitals, including improved connections as part of TRN8 NEW RAIL STATIONS - DESIGN new and improved public transport infrastructure. The Council CONSIDERATIONS will continue to monitor the level of accessibility provided by bus services and will seek improvements to frequencies of existing The upgrading of existing stations, and the formation services and the introduction of new services as necessary. of new interchange facilities on appropriate sites, is supported. These should, where practical, have: 6.7.12 It is important for the general convenience of passengers, and in particular elderly persons, disabled people, and parents with (a) A visual impact and setting appropriate for a building which is be a community focal point and land- young children, that suitable shelter and waiting facilities, with mark; seats, are provided at bus stops. The Council will press for these at all appropriate locations on the bus network and will press for (b) Interchange facilities with buses; the relocation of unsuitably located bus stops, stands and turning (c) Disabled access from buses and the street to trains facilities. (where there are no separate requirements under the building regulations); 6.7.13 One important development in bus service has been the introduc- (d) Adequate secure cycle parking facilities; and tion of the 'Countdown' project pioneered on route 18 and being introduced on the whole of the London Bus Priority Network. This (e) Good lighting and have good community safety allows passengers to see the waiting time for and destination of arrangements for passengers, both when staffed buses and has considerably raised bus patronage. and unstaffed.

6.7.14 The London Bus Priority Network; is a Londonwide strategic prior- BUSES ity for transport investment (Part I Policy STR6). It is shown on Map TRN2 and the proposals map. It will increase the speed and 6.7.10 Road based public transport will play an increasing role in meet- reliability of bus services. Of particular priority will be improving ing access needs in London, as car use becomes increasingly access by buses to and between town centres - and across whole problematic and for trips which are less well suited for tube/rail, routes not just within Boroughs. Improvements will often involve especially journeys in the northern part of Brent where travel pat- a re-allocation of road space away from cars. The measures terns are more dispersed, although the majority of bus trips cur- introduced will be compatible with UDP policies and meet the rently are in the South of the Borough. Bus and rail are also com- needs of businesses, pedestrians, pedal cyclists and the related plementary, for example bus services can be used to access rail environment. The bus network in Brent has a large scale and stations and widen their catchment. coverage and many services run outside the London Bus Priority Network. The Route 16 along the Edgware Road is being used 6.7.11 Transport for London’s aspirational standard for access to bus as a pilot for enhanced priority measures. services is that no property should be more than 10 minutes walking distance (at most 400m, and preferably less than 300m) from 6.7.15 The Borough has five bus garages in Cricklewood, Alperton, a bus stop. There are parts of the Borough where this is not North Wembley and Willesden Junction. Even if no longer need- achieved. It is recognised that in some areas physical ed by one operator the Council will expect that the possibility of restrictions, such as road widths and gradients and sensitive local environments, may prevent the minimum standard being

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use by another to be fully explored before their loss is considered. 6.8.2 More and more Londoners are starting to use their cars rather Some of these garages require substantial upgrading to bring than walking for relatively short journeys. But more car-use them up to modern standards, which Brent will encourage. makes walking feel unpleasant and unsafe, leading to a vicious circle of decline. Walking makes up over a third of all journeys in 6.7.16 The Borough fully supports the TfL London Bus Priority Action London (source LPAC), but this can be substantially increased as 1 Plan. This embodies the schemes already developed in the even for journeys of under /2 KM, over 20% are made by car. It is London Bus Priority Network, the London Bus Initiative, Bus Plus therefore important that development is located where walking is and a number of initiatives covering orbital bus routes developed a viable means of access. Promoting walking also promotes pub- in conjunction with West London Transport Strategy. The Bus pri- lic transport use - walkable environments are necessary at the ority Action Plan will intensify bus priority measures over the beginning and end of public transport trips. whole bus network in 2004-8 and will rely on strong partnership between the Borough and TfL 6.8.3 To be 'walkable' development should offer safe, convenient and direct routes for pedestrians. The 'walkability' of the environment will also depend on removing conflicts with other modes of transport - especially the private car. TRN9 BUS PRIORITY 6.8.4 LPAC advice suggests that good urban design for walking has the The Bus Priority Action Plan (as shown on the propos- following features: als map) will be implemented in partnership with the bus operators, Transport for London and other strate- • Connected: easy to get from place to place without meeting gic bodies. dead ends; • Convenient: direct routes without unnecessary detours; Developments that abut the bus priority network will, • Comfortable: smooth, wide and unobstructed footpaths; where appropriate, be required to provide for the • Convivial: friendly, busy, interesting streets; efficient operation of bus services including bus • Conspicuous: easy to read signs and information. facility and/or highway improvements, and/or service improvements (following consultation with 6.8.5 Those with mobility difficulties may include disabled people, Transport for London); where the need for such school children, the elderly, and those with young children. For facilities arise directly from the need to service the the purposes of this policy, pedestrians and 'walkable' does not development by public transport. just include those on two feet but covers the full range of access needs. Those with mobility difficulties will benefit from level The loss of existing bus garages will be resisted where access at pedestrian crossing points. The needs of such groups this would result in a deterioration in the frequency, should be fully taken into account in considering the suitability of coverage or reliability of bus services. The improve- 'shared' pedestrian and cyclist facilities. ment of existing, and provision of new bus garages is encouraged. 6.8.6 Pedestrians have the same right to use the public highway as other road users. Footways however belong to pedestrians, which requires them to be free of obstructions and obstacles. 6.7.17 Community Transport; This sector presents an opportunity for Enforcement will therefore continue of unauthorised footway 'bridging the gap' between the more traditional forms of public parking. transport (i.e. timetable operation on fixed routes) and wholly demand-responsive means of transport, such as the car. It may 6.8.7 Consent is needed under the Planning Acts to block or divert a well represent the best opportunity for the development of a more public right of way. The Council maintains a 'definitive map' of accessible 'door-to-door' public transport alternative. The Council public rights of way, but in addition to this are 'permissive' rights of will continue to liaise with Brent Community Transport and similar way which have been in use by the public for many years. voluntary groups over the provision of community transport facilities. 6.8.8 A network of London Metropolitan Walks is proposed, primarily for recreational purposes - this is covered by Policy OS21 in chapter 10.

6.8 WALKING AND CYCLING 6.8.9 Safer Routes to School; The Council is especially concerned with the road safety of children - this applies particularly to their jour- WALKING neys to school. So Brent, in partnership with local schools, is 6.8.1 The importance of walking as a mode of transport has been high- undertaking a 'safer routes to school' programme to encourage lighted by the publication of LPAC's (London Planning Advisory children to walk or cycle, or go by bus to school along safe, traffic Committee) 'Advice on a Strategy for Walking in London' and the calmed routes. Government's draft 'Developing a Strategy for Walking ' and Integrated Transport White Paper. Transport for London are also proposing a Walking Plan.

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6.8.10 In addition, a significant proportion of morning peak hour car trips are by parents taking their children to school. The successful introduction of safe routes to school by bus, cycle, or walking, will both improve road safety and contribute towards the goals of sustainable transport & development. A pilot safe routes to school project has been successfully implemented in the Harlesden area.

TRN10 WALKABLE ENVIRONMENTS

The 'walkability' of the public environment should be maintained and enhanced - especially to key destinations such as schools, shopping centres and public transport, and for those with mobility difficulties. This neither pedestrians nor cyclists is put at risk. Cycle parking facili- applies both to the impact of development proposals, ties will be increased at railway and tube stations, in shopping and traffic management and highway & pedestrian centres, and at schools, hospitals and leisure facilities. A design improvement measures. guide for the network has been jointly produced by the boroughs.

New development should have safe walking routes 6.8.13 However, if the target is to be met improvements are also neces- which are, overlooked, convenient and attractive, sary outside the London Cycle Network. The needs of cyclists within the site and to surrounding facilities and areas. throughout the network need to be assessed. Direct main roads These should normally be along streets, or where not usually carry the most cyclists despite congestion, pollution and practical or desirable, overlooked pedestrian routes. the higher risk of accidents. Measures to provide facilities on main roads e.g. cycle lanes and advanced stop lines at traffic signals, There should be level access at pedestrian crossing should be developed to complement the proposed London Cycle points. Network routes. Traffic calming can also encourage more cycling off defined routes. Developments or applications which would block or unacceptably divert public rights of way will not be 6.8.14 More attention needs to be paid to the needs of cyclists in the permitted. design and layout of new developments. The policy incorporates the key principles of this for improving conditions for cyclists taken from the 1998 Institution of Highways and Transportation Guidelines on Cycle Audit and Review.

CYCLING 6.8.15 Provision for safe, secure and convenient cycle parking needs to be provided at all destinations including homes, schools, facto- 6.8.11 Cycling is a viable alternative means of transport for many local ries, offices, hospitals, places of entertainment, etc. Whilst journeys in London. Almost two thirds of all trips in London are 'Sheffield' stands (see glossary) will continue to be used in public under 5km in length (source London Cycling Strategy), and many areas, where long term parking is envisaged cycle lockers would of these could be made by cycle if convenient and safe conditions be more secure and provide storage for vulnerable cycle acces- are created. Six cycles can move in the space of one car, up to sories. Changing facilities with showers, dryers and lockers are 12 cycles can be parked in one car space. The National Cycling also important especially at places of employment - and will be Strategy recognises that improving facilities for cycling both sought by negotiation. makes it safer to cycle; and can reduce car use dramatically at a comparatively low cost. The target is for 10% of all trips to be made by cycle by 2012 (Source LPAC 'A Cycle Strategy for London' 1997).

6.8.12 The London Cycle Network will offer over 2900 km of safe, signed cycle routes. It is now being implemented as a strategic priority (Policy STR7). It is shown on Map TRN2 and the proposals map. Cycle lanes will be provided where possible, especially along or parallel to main roads. Some sections of the network will be along quieter local roads whereas other routes will be away from roads (across parks, etc.). Shared use with pedestrians will only be authorised where it is safe. Such schemes will be subject to rigorous design guidelines and independent safety audits which ensure they are in an appropriate location and that the safety of

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TRN11 THE LONDON CYCLE NETWORK TRN12 ROAD SAFETY AND TRAFFIC MANAGEMENT The London Cycle Network and associated links (as shown on the proposals map) will be implemented. In considering traffic management measures, and in Development should facilitate or incorporate the assessing planning applications, priority will be given network (including where a safer and/or more to road safety issues - particularly those affecting the convenient route can be provided). convenience and safety of vulnerable road users such as pedestrians and cyclists. Major developments will be expected to contribute towards improvement in links to and on the London Essential through traffic will be encouraged to use the Cycle Network, where the need for such facilities arise Strategic Road Network and London Distributor Roads directly from the need to service the development by (Policy TRN20), through traffic will be discouraged, as sustainable modes. far as practical, on local roads, through the use of traffic calming and other measures (Policy TRN13). Changes or additions to the highway network, Development proposals which conflict with this, in including from development, will be assessed for their terms of traffic management and/or road safety, will impact on cycling - examining the coherence, be refused. directness, attractiveness, safety and comfort of routes. Measures to improve conditions for cyclists will be assessed in the following order of declining preference: traffic reduction, traffic calming, junction TRAFFIC CALMING treatment and traffic management, redistribution of the carriageway, and off-road provision. 6.9.3 Traffic calming is an engineering or urban design measure designed to reduce the environmental impact of traffic (by reduc- Developments should comply with the plan's minimum ing speeds) in the area concerned and to allow all classes of road Cycle Parking Standard (PS16); with cycle parking users (cars, pedestrians, buses, cyclists, etc.) to interact more situated in a convenient, secure and, where appropri- safely. It is not specifically to remove or prevent traffic from using ate, sheltered location. Priority will be given to local roads but to lessen the impact of that traffic, hence the name improving cycle parking at stations and in town traffic calming. In residential areas accidents are not always con- centres. centrated at readily identifiable points. Therefore, there is an important role for area-wide traffic calming, and the introduction of 20 mph limits (the highest comparatively safe speed for residential areas) to reduce accidents or road safety problems in parts of the Borough which have a specific character or boundary. Traffic 6.9 ROADS, SAFETY AND calming can also re-inforce traffic management measures which TRAFFIC MANAGEMENT seek to ensure traffic does not conflict with the road's role within the London Road Network. It is important that traffic calming is of ROAD SAFETY a form which does not have a detrimental effect on bus services or the provision of emergency services. Measures will be pro- 6.9.1 The Secretary of State have set a target of a reduction in road gressed following consultation with local residents, Transport for casualties by one third by the year 2000. New targets will shortly London, businesses and the emergency services. be set for 2010. The Council has set down a road safety plan showing how this can be achieved. As well as continuing accident 6.9.4 Traffic calming should also cover the design of the road layout investigation and prevention work focusing on accident itself. For example, junctions with narrowed kerb radii and 'blackspots', the Council will make road safety central to its devel- schemes with an 'urban' layout can both reduce traffic speeds, opment control and traffic management activities. Accordingly and have a more appropriate layout to the character of London. priority will be given to vulnerable, and sustainable, modes of Brent's SPG13, Layout Standards for Access Roads, includes transport such as pedestrians and cyclists. To this end certain model designs. local access roads will be designated as having pedestrian priority. 6.9.5 Home Zones: are residential streets in which the road space is shared between motor vehicles and other road users, with the 6.9.2 To aid road safety, and to protect environmentally sensitive areas needs of pedestrians, including children, and cyclists coming first. such as residential streets, it will be necessary to restrict through Restricted parking, signing, traffic calming and modifications to traffic (excluding local buses) from using local roads. To this end street design will be necessary to encourage low speeds. Some it will be necessary to define a road network so that traffic is guid- parts of Brent may be suitable for these with residents support. ed on to the roads where it is most suited.

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TRN13 TRAFFIC CALMING TRN14 HIGHWAY DESIGN

Traffic calming and other engineering or urban design New highway layouts, visibility splays and accesses to measures will be used where there is evidence of a and within development should be designed to a high level of traffic accidents, or vehicle speeds, which satisfactory standard in terms of safety, function, cause road safety problems - in particular on local acceptable speeds, lighting and appearance (see distributor and local access roads. Policies BE3 & H12).

Traffic calming schemes should, where appropriate, For a site with a new road network the proposal include environmental improvements such as hard and should have efficient internal circulation as well as soft landscaping, and should be completed before the integrating with the existing road network in a development is first used or occupied. Such schemes convenient manner; including for emergency service should be of a design and nature so as not to harm the vehicles, pedestrians, cyclists and, where appropriate, viability of road based public transport and to buses. maintain access for emergency services. Where buses would need to use a road, such as in New roads serving residential developments should large developments and, where appropriate, through incorporate traffic calming measures as an integral roads, then the access points, roads, stop locations element of their design, so that, where appropriate, and highway layout should be suitable for the routing design speeds are below 32 kph (20 mph). of bus services, and for pedestrians.

Home zones will be introduced in suitable residential areas. ACCESSES TO ROADS

6.9.8 A certain amount of parking on streets can bring activity and have a traffic calming effect. Where casual parking is likely to take HIGHWAY DESIGN place streets should be designed to accommodate it. The priority 6.9.6 In accordance with the Plan's transport planning priority of is that vehicles should not be allowed to dominate the space, or to improving road safety the planning and highways authorities will inconvenience pedestrians and cyclists. However there will con- fully consider road safety issues in all of its development control tinue to be demand from householders to form accesses to the and traffic planning work. When considering new highway works highway for the benefit of in-curtilage parking. Where the car- a road safety audit may be undertaken, especially for new roads. riageway is wide enough to permit on-street parking on both sides It is possible, however, to achieve safe designs without the con- of the road (greater than about 8m in two-way streets and 6m in ventional measures of excessive use of wide roads, large visibility one-way streets), then the amount of on-street parking lost by splays and cul-de-sac layouts. In this regard the planning and crossovers will usually be greater than the amount gained highways authorities will follow the advice in the official DETR through off-street parking - and it is more important to keep unal- manual ', Places, Streets & Movement' (see the sections on located parking than allocated in-curtilage parking, as it can be street design in the Built Environment and Housing Chapters). more flexibly used. One exception is where a house is used by a Where roads would need to carry bus services the layout should single household (rather than flats) where one car can 'shadow eliminate double-running, avoid large loops, facilitate direct A-B park' on-street in front of a crossover. Therefore in most of the routings and include plenty of accessible kerb space. The design densely developed streets in Brent, where flats are common, the of pedestrian and bus routes should take place at the same time creation of off-street parking acceptable under Policy BE7 (maxi- as the design of roads and car parks. Bus stops need to be as mum Þ of front garden area) is likely to be no greater than the close to entrances as are the car parks. amount lost on-street. If the street is heavily parked this loss of on-street parking may cause double parking, with its associated 6.9.7 The adoption of an existing private street or proposed new road highway safety and traffic management difficulties, and so such allows the Council to control its use and ensure that it is built and applications will be refused. Even if the creation of a large off- maintained to an appropriate standard, in terms of visual appear- street parking area is practicable, this will be limited on grounds of ance, and lighting. The Council will therefore adopt highways traffic restraint. where this results in a clear public benefit. Proposals for the adoption of existing private streets are included in the Wembley 6.9.9 The Council publishes Supplementary Planning Guidance Regeneration Area Chapter. The planning and highways authori- (SPG3) giving further advice and guidance in this area which the ties will take into account the likelihood of highway adoption when planning authority will have regard to in considering such plan- considering development proposals. ning applications. The combined effect of this policy and SPG and Policy BE7 will be a stricter approach to front garden parking and boundary treatments preventing the excessive turning over of gardens to bleak hardsurfaced areas.

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TRN15 FORMING AN ACCESS TO A ROAD TRN16 THE LONDON ROAD NETWORK

An application for the creation of an access from a Development proposals should support and not dwelling to a highway (other than the North Circular undermine the role of roads within the London Road Road) will be acceptable where: Network (as set out in RPG3).

(a) The location of the access would be at a safe point with adequate visibility; and The North Circular Road (A406), is designated as a GLA Road. (b) The access and amount of off-street parking proposed would be visually acceptable (having regard Roads listed as such in Appendix TRN1, are designated to existing highway verges and trees affected and as London Distributor Roads. Policy BE7); and

(c) When the street is Heavily Parked (Policy TRN24), All other roads are Local Roads, and are categorised as the proposal should not result in the loss of more local access roads, unless listed as local distributor than one on-street space, and, where there is con- roads in Appendix TRN1. trolled parking, would not result in the creation of more off-street spaces than permitted by the park- Strategic and distributor roads to which policies of this ing standard (PS14). plan apply are defined on the proposals map.

BRENT’S ROAD NETWORK NEW ROADS

6.9.10 A new categorisation for the London Road Network is set out in 6.9.11 Building more roads simply to handle projected increases in traffic Strategic Planning Guidance for London Planning Authorities is both self-defeating (through creating 'induced traffic') and envi- (RPG3). This is summarised below. Appendix TRN1 to this chap- ronmentally unacceptable. The policy is based on the LPAC ter lists the Borough's roads that come under the different cate- framework for assessing new highway proposals, and the PPG13 gories. These are shown on Map TRN3, and, in the case of the ‘multi-modal’ assessment framework.. It recognises that the case upper tiers, on the proposals map.

The Revised Categories of the London Road Network

Tier Category

1 GLA Roads

To attract and serve longer distance movements throughout London, esp. freight and public transport. To link London to the National Road Network. General presumption against new accesses or increased use of existing accesses. Lower tier road access always preferred.Separate or segregated pedestrian and cycle facilities on high speed sections.

2 London Distributor Roads

To attract and serve traffic crossing boroughs. To link centres within London to each other and to Tier 1. To attract freight traffic away from Tier 3. To provide attractive routes for bus services. New frontage development should not significantly affect the traffic distribution function of the road. Measures to assist cyclist and buses, most of the London Bus Priority Network on this tier. Kerbside loading and parking should not generally interfere with junction capacity.

3 Local Distributor and Access Roads

Local distributor roadsroad : To distribute traffic within a borough. Dependent on local conditions. Bus and cycle priorities. Kerbside parking and loading. Local access roads:roads to serve frontage properties. Minimal restrictions, commensurate with scale of development. Parking controls and traffic calming to prevent extraneous traffic. Special facilities for local bus, pedestrian and cycle movements.

Source: RPG3

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will need to be made in regeneration and highway terms for new scope for further industrial and warehousing development here, roads and that the alternatives should be fully and rigorously which would be an appropriate use of the limited strategic examined. resource of NCR access.

6.9.15 The North Circular Road presents special air quality problems. TRN17 RESTRICTIONS ON NEW ROADS Although air quality management should, if properly implemented, reduce many of the Borough's air quality problems, there can The construction of additional roadspace will be be no guarantee of this in the case of development close to the resisted unless: North Circular Road. This is because it will continue to be a key part of the Strategic Road Network for London, helping to solve (a) It is necessary to provide essential access to, or within, regeneration areas; air quality and traffic problems in Central London by diverting traffic away. Notwithstanding improved fuel emission standards, the (b) It is necessary to provide access to, or circulation sheer volume of traffic on this road, even if significantly reduced, within, a development site; or would present severe air quality problems for the foreseeable (c) It is necessary to remove traffic from an area pre- future. Most pollutants will disperse rapidly away from the road, dominantly used by pedestrians, where this would and, if traffic levels elsewhere are reduced, then it should not pre- have net benefits in terms of air quality, pedestrian sent a Boroughwide problem. However, there will continue to be safety and the environment generally. unacceptably high-permanent concentrations of certain pollutants for areas close to the road. Air quality sensitive development will not be permitted in areas which the Council's roadside monitoring shows are above acceptable pollution levels.

THE NORTH CIRCULAR ROAD

6.9.12 The A406 North Circular Road (NCR) is designated as both a TRN18 GLA ROADS - THE NORTH Trunk Road, GLA Road and a Priority (Red) Route. Substantial CIRCULAR ROAD improvements to the North Circular Road between Hanger Lane and Staples Corner have now been completed and the road The number of additional access points along the forms a key element in the London Road Network in channelling North Circular Road will be restricted to the minimum essential traffic, especially freight, away from Inner London. number necessary to secure regeneration of adjoining Proposals for it's re-alignment in the Dog Lane area have now Strategic Employment Areas. been suspended from the national roads programme, and so these are now formally abandoned in the UDP. The emphasis will Improved bus and cycle provision alongside the road, now be on making better use of the road. PPG13 advises against and measures to reduce community severance, will be new accesses onto primary routes such as this, as this would sought. conflict with their strategic role of carrying through traffic, but acknowledges that this is sometimes necessary to secure regen- Air quality sensitive development (e.g. housing, hospi- eration. Please note the North Circular Road improvements tals, schools) will be restricted in areas close to the included in the previous UDP have now been formally abandoned North Circular Road, where they would suffer air by the Secretary of State. quality below accepted levels.

6.9.13 As a Red Route and GLA road, traffic management measures are under the control of the GLA, who has recently published a revised network plan with more emphasis on traffic restraint and providing for non-car modes. Also as a Trunk Road the Highways NEW STRATEGIC ROAD JUNCTIONS Authority is the Highways Agency (of the Department of Environment, Transport & Regions). Currently the North Circular 6.9.16 Brent considers that there are exceptional cases to be made for Road is predominantly focused around the needs of car users. improvements to two key junctions linking regeneration areas to Brent will seek a more balanced approach with emphasis on the trunk road network, i.e. The Park Royal Western Gateway off other transport modes. Western Avenue and the access to the stadium area off the North Circular Road. In both of these cases the highway authority for 6.9.14 Strategic Guidance for London Planning Authorities (RPG3) the trunk road accesses is the Secretary of State for Transport advises Boroughs to plan for development away from such roads. (Highways Agency). Discussions have taken place with them and There has been considerable pressure to locate retail and leisure the Traffic Director for London - the approval of both is required. developments adjoining the NCR but the operation of the The Integrated Transport White Paper proposes a slightly more 'sequential approach' to developments attracting significant num- flexible approach towards accesses to regeneration areas from bers of people (Policy STR2) will steer development towards town the Trunk Road Network. It is hoped that some part of both pro- centres in the first instance. Also the industrial areas accessed posals will be included within the National Roads Programme. In from the NCR are of strategic importance. There continues to be

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order not to increase congestion both should be left turn in-out most of the London Bus Priority Network is located on these only and have public transport priority (for example bus gates with roads. It will be necessary to restrict waiting, loading and unload- selective vehicle detection). ing on much of this network.

6.9.17 Park Royal Western Gateway Access; Twyford Abbey Road is one of the most used access roads to Park Royal but it is a nar- TRN20 LONDON DISTRIBUTOR ROADS row residential road accessing directly onto the Hanger Land Gyratory. The proposals for the Park Royal Western Gateway New access points, or where development will result (see Policy PR5) provide the opportunity for a new access primar- in the increased use of existing access points, along ily to Western Avenue (the A40) designed to further access for London Distributor Roads (as listed in Appendix essential (mainly freight) vehicles to Park Royal. This access will TRN1), must not harm their role of distributing traffic partly be in Ealing and may enable the closure of Twyford Abbey across London - in particular bus traffic. Road (mainly in Ealing) & the northern arm of Coronation Road to through traffic. It will also permit bus priority measures in the surrounding area including a bus-only link onto Twyford Abbey Road. The Transport Strategy for the Park Royal Area (see Policy PR2) LOCAL TRAFFIC MANAGEMENT and the proposed Park Royal Interchange Station should ensure that it does not become a more attractive means of making com- 6.9.20 Part of Brent's approach to traffic management is based upon muter trips. servicing key regeneration areas in a sustainable manner by, amongst other means, re-prioritising the use of roadspace on key 6.9.18 Brent Park; Great Central Way will continue to be the main means links to them. It is also particularly important to improve links from by which vehicular traffic will access the National Stadium. The housing areas (especially those suffering from social exclusion) to proposed improvements to this will ensure a direct link between the major employment areas so that Brent's transport system can the stadium and the trunk road network (the A406). This improve- more efficiently service the Borough's labour market. Different ment will ensure that coaches do not queue back onto the A406, approaches will therefore be needed for different parts of the whilst ensuring that local traffic to the St Raphaels Estate is not Borough, but as part of a coherent overall strategy. Local Traffic adversely affected. There will be a bus priority gate. The Management Strategies will therefore be prepared. These will Transport Strategy for the National Stadium Area (see chapter 14, comprise of Integrated Traffic Management Areas which will treat section 7) should ensure that it does not increase the number of the defined areas in a comprehensive fashion, in order to deliver car trips to the Stadium & the employment area around it. the objective of the Interim Transport Plan. The areas currently defined and the issues they address are set out below.

TRN19 IMPROVEMENTS TO STRATEGIC ROAD JUNCTIONS TRN21 LOCAL TRAFFIC MANAGEMENT STRATEGIES Proposals for the following new left turn in-out only strategic junctions, serving regeneration areas are In preparing traffic management measures and in con- supported, providing they have, or facilitate, public sidering development proposals, regard will be had to transport priority: the Local Traffic Management Strategy for that area - as published in the Interim Transport Plan and subse- (a) Park Royal Western Gateway Access;and quent Local Implementation Plan. (b) Brent Park - Junction servicing the Stadium Area. Contributions will be secured from developments which require these improvements to mitigate the transport impact of the development to acceptable levels. 6.10 PARKING AND TRAFFIC RESTRAINT

PRIVATE NON-RESIDENTIAL PARKING

LONDON DISTRIBUTOR ROADS 6.10.1 The level of private non-residential parking provided within devel- 6.9.19 London Distributor Roads consist generally of existing 'A' roads opments is a major influence on peak hour traffic volumes. other than Strategic Routes of National or Regional Importance. Therefore setting maximum restraint based parking standards They should attract and serve drivers making journeys between can help reduce car use. and across boroughs and to counties bordering Greater London. London Distributor Roads generally have to provide access to 6.10.2 Part I Policy STR6 refers to the need for these new standards to adjacent land uses, but their primary function must be to act as be co-ordinated. Brent will work with adjoining boroughs to part of the network for through traffic in and around London. They ensure that parking standards are compatible as possible at also need, where appropriate, to give priority to bus services as Borough boundaries. In order to achieve consistency across all

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Issues addressed in Local “Interim Traffic Management Area” Strategies

National Stadium/Wembley This is set out in the Wembley Regeneration Area Inset Plan chapter.

Park Royal This is set out in the Park Royal Inset Plan chapter.

Neasden Dollis Hill traffic calming, waiting and loading restrictions, traffic management on industrial estate.

South Wembley Controlled parking zone, traffic calming, pedestrian facilities on High Road.

Willesden Controlled parking, pedestrian improvements, traffic calming in streets around High Road.

Kilburn Controlled parking, pedestrian improvements, traffic calming in South and North Kilburn, Home Zone in Brondesbury.

Queensbury Controlled parking in Queensbury Station area, waiting and loading restrictions outside, junction improvements to Stag Lane/Princes Avenue.

Kingsbury Controlled parking zone, traffic calming and management schemes.

Sudbury Controlled parking centred on district centre, traffic calming in Sudbury Court, Maybank Avenue and Rugby Road, Queue relocation measures.

Kenton Woodcock Hill area traffic calming scheme, junction improvements including Woodcock Hill/Draycott Avenue, waiting and loading restrictions.

Harlesden Review of controlled parking zone centred on town centre. Extension of St Marys Road area traffic calming, waiting and loading restrictions outside of CPZ.

A404 Corridor (Harrow Road) Completion of bus priority, increased space for pedestrians and cyclists, entry treatments on critical side roads, queue management to reduce air pollution.

Route 83 Corridor Orbital Bus priority, entry treatments on critical side roads, measures to control vehicle speed.

The North Circular Road In conjunction with the Traffic Director for London to block unsafe and unauthorised residential accesses, to facilitate improved bus services, especially improved access by bus to Neasden Town Centre.

The Edgware Road In conjunction with the London Borough of Camden to implement bus priority measures, to improve pedestrian crossing facilities, to introduce CPZs on side roads near rail stations.

Detailed proposals, traffic reduction targets and traffic management measures are listed in the Borough's Interim Transport Plan. Note: Some local areas overlap.

uses this approach has been extended to all other non-residential - this could harm the viability of new public transport services uses, assuming similar modal splits in terms of those needing to through cementing car-commuting patterns in the early phases of use public transport to get to work. a development.

6.10.3 In order not to give an incentive to development in areas without 6.10.4 Operational Parking is permitted and required to cater for those good public transport accessibility - including 'out-of-centre' essential trips which cannot be made by public transport. Such development - the Plan includes standards which apply across trips would include provision for people who are unable to use the Borough (with limited exemptions in certain regeneration public transport because of a disability (Policy TRN35), people areas). By the same reasoning it does not, as a rule, allow tem- working unsociable hours, and people maintaining the building or porary increases in parking to reflect poor current public transport the specific needs of a particular activity (in which case the onus will be on the applicant to demonstrate special need).

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Operational parking is part of the overall parking maximum (not additional) and does not include provision for commuter or visitor TRN22 PARKING STANDARDS - NON- trips. RESIDENTIAL DEVELOPMENTS

6.10.5 The minimum operational level will be assessed on a case by Non-residential development should make provision case basis. Exceptionally spaces may be commuted below the for vehicular parking in accordance with the maximum 50% level, but no lower than to cater for special needs, see stan- standards set out in Appendix TRN2. The application dard PS5. Experience suggests that operational spaces are of these standards may be varied depending on the often taken instead by those arriving first at work or for senior level of public transport accessibility to the site and staff; conditions controlling their occupancy will therefore be nec- the contribution that the development would make to essary. reducing the use of the private car.

6.10.6 One problem in Brent is that parts of the main regeneration areas, The level of such parking should not however be such as in the Wembley Stadium and Park Royal Industrial below minimum operational levels (including required Estates, have low public transport accessibility. The policies of disabled persons parking - policy TRN35). Conditions the Plan as a whole encourage less trip intensive development in will be imposed requiring operational parking to be these areas. However, in order to promote regeneration in accor- retained as such dance with RPG3 it is considered necessary to allow for a clearly 1 defined and limited exception, in Policy TRN22, to normal parking An increase of up to /3 in these parking standards standards where a development would not go ahead without it, will exceptionally be made in Strategic Employment and the transport impact is acceptable overall. This exception will Areas, Park Royal and the National Stadium Policy be reviewed in the light of possible public transport improvements Area, providing the applicants can demonstrate all of in these areas (including those that might be secured by develop- the following: ment) and the introduction of restraint based parking standards (a) It is a key regeneration proposal supportive of on a regional level throughout the country (so that Brent does not regeneration projects in the area; and suffer a competitive disadvantage in seeking inward investment). In considering variations from the standards in Appendix TRN2, (b) The transport and environmental impact of the regard will be had to the maximum standards set by national plan- scheme is acceptable; and ning guidance (annex D to PPG13) and the standards in strategic (c) The proposal secures significant and sufficient pub- guidance for London as set out in the draft London Plan. lic transport/walking/ cycling improvements, and/or contributions towards on-street parking 6.10.7 The fact that a development complies with one of the plan's non- controls, and implementation of a green transport residential parking standards does not mean however, that its plan. transport impact will be acceptable. This still needs to be tested against Policy TRN1. In some cases the resultant amount of on- street parking might be unacceptable, especially without the introduction of on-street parking controls (see Policy TRN4). Another RESIDENTIAL PARKING option is the secured introduction of measures by employers like green commuter plans (see Policy TRN4) which discourage car 6.10.9 Parking at home and on residential streets is becoming an commuting and encourage alternatives. increasingly difficult issue. Many of those who use public transport for work trips may still own a car for leisure and shopping 6.10.8 Limiting the provision of large free car parks for out-of-centre trips. Car ownership is less of a problem than car use, but cars shop and leisure uses can help shift the balance towards town owned tend to be used. A balanced approach is required; restrict- and district centres and can discourage the use of the car. In line ing private off-street parking alone could lead to dangerous on- with RPG3 (para 5.7) the Plan now requires these to be charged, street parking on some of Brent's congested streets (see Policy and shared with similar nearby facilities. TRN24) but providing more parking spaces than is strictly necessary is a wasteful and visually intrusive use of land.

6.10.10 The standards backed up by this policy consequently do not encourage car ownership by adopting an approach of anticipating demand and simply providing for it. Car-ownership in Brent is not as high as might be anticipated. In 2001 only 20% of Brent households had two or more cars, and 37% had no access to a car at all. The new lower standards reflect this.

6.10.11 'Unallocated' means parking not within the curtilage of any particular dwellinghouse. As such it can be much more efficiently used. All new units do not have to have two off-street parking spaces on the assumption that the unit would generate up to this number.

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Rather, spaces unused by those with no car can be utilised by other car users, and the overall number of parking spaces can be TRN23 PARKING STANDARDS - reduced. RESIDENTIAL DEVELOPMENTS

6.10.12 Brent has undertaken research into car use in recent affordable Residential developments should not provide more housing developments. These typically only generate 3 cars for parking than the levels as listed in standard PS14 for every 4 units, so similarly a reduced standard applies. that type of housing, with its maximum assigned parking levels. Lower standards apply for developments of 6.10.13 Although there is no evidence within Brent of car-ownership lev- affordable housing and for units in town centres with els varying by public transport accessibility, it is considered appro- good and very good public transport accessibility. priate to lessen the standard in areas of greatest public transport Where development provides or retains off-street accessibility so as to reflect increased future traffic restraint, and parking at this level then on-street parking will not be to enable more intensive housing development and innovative assessed. designs in town centres and the most densely developed parts of the Borough. Exceptionally 'car-free' housing developments may be permitted in areas with good and very good public 6.10.14 Strategic Guidance for London Planning Authorities (RPG3) transport accessibility where occupation is restricted notes the potential for 'car-free' housing developments. It is con- by condition to those who have signed binding agree- sidered important that people voluntarily choose to live, rather ments not to be car owners (other than for pooled than are forced to live, in such developments. It is also important communal vehicles). Such persons will not be granted that they subsequently do not buy a car, taking advantage of the residents parking permits. fact that these units are likely to be cheaper and could transfer traffic problems onto adjoining streets. It is therefore essential On local access roads outside heavily parked streets that an occupancy condition applies to such developments ensur- (Policy TRN24) parking may be provided on-street, for ing that the occupation is limited to persons who do not own, pos- the frontage of the development only, providing this is sess or have any legal interest in any motor vehicle and who are safe and sufficient carriageway width remains. not registered keepers of motor vehicles and who do not have regular access to motor vehicles for the purposes of social and/or - domestic use. For the purposes of this condition ‘motor vehicle(s)’ would include cars, vans, goods vehicles, buses or coaches. Car pooling arrangements, where agreed by the local plan- ON-STREET PARKING ning authority, may be acceptable however. 6.10.17 The availability of off-street residential parking in many areas of 6.10.15 A limited amount of on-street parking may be acceptable, but this the Borough is limited by the form of original housing. As car should not intrude onto neighbouring frontages or be dangerous - ownership has increased demand has begun to outstrip capacity. such as on Heavily Parked Streets (Policy TRN24), including It is recognised that the Council's new 'restraint based' approach where on-street parking is caused by loss of existing off-street to non-residential parking standards (Policy TRN22) will generate parking through development.. pressure for additional on-street parking on residential roads near town centres and employment areas. To manage this problem a 6.10.16 Although hospitals are formally a residential (C2) use, they are so 'Parking Strategy' is being drawn up by Brent, in tandem with the different from other 'residential institutions' that they have their Unitary Development Plan. own special parking standard which is covered by Policy TRN22. 6.10.18 The coverage of on-street parking controls will be a factor in judging whether the transport impact of a proposal is acceptable (Policy TRN1) and whether the extension of controls can solve this (Policy TRN4). A phased programme to extend controlled parking zones will be necessary; both will be carried out in tandem as part of the Local Area Transport Strategy for the area in question (Policy TRN21). This will be a particular priority in the south-east of the Borough.

6.10.19 The Borough's overall parking strategy will include a comprehensive audit of the available on-street and off-street parking supply and problems caused. Many of the difficulties regarding the allocation of on-street parking space (between residents and other users) can only be solved if additional permitted parking (such as the introduction of controlled parking zones) is introduced. The present coverage of such zones is poorer in Brent than in many other London boroughs, and this is unsatisfactory.

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6.10.20 A limited amount of on-street parking is both acceptable and SPECIFIC PARKING ISSUES preferable to losing too much front garden space (Policy BE7); PARKING IN TOWN CENTRES but when there is excessive on-street parking this can be dangerous for pedestrians, and can hamper the flow of traffic. Overnight 6.10.22 The revised parking standards remove any inherent bias that pre- parking is the main concern, as this is when most residents cars viously applied to out-of-town retail and leisure developments. are parked and when parking controls are difficult to enforce. It is The operation of the 'sequential test' (see Town Centres and accepted that in circumstances where 80% or more of the safe Shopping Chapter and Part I Policy STR2) will mean that town on-street parking capacity of a street is exceeded then two-way centres will be the main focus for developments attracting signifi- flow is restricted. When on-street parking reaches very high levels cant numbers of trips. As PPG6 notes, in town centres the main illegal corner parking and double parking can cause particular need is for parking which serves the centre as a whole rather than problems for the emergency services. Such streets have been dedicated parking for individual developments. classified as 'Heavily Parked Streets' and the results of the latest survey of such streets is listed as Appendix TRN3. A special poli- 6.10.23 As Brent's town centres are very different in terms of their existing cy applies to flat conversions on such streets (see Policy H19). short-term parking provision, customer base and public transport accessibility, individual parking plans, designed to promote their 6.10.21 In assessing whether or not to require contributions for CPZs the vitality and viability, will be necessary. These will identify all types planning & highway authorities will need to assess the scale of of parking available within a centre, including on-street and pri- likely unacceptable impact against what an obligation could vate non-residential, and will identify conflicts and potential short- achieve. The Council will consider the time it will take to introduce ages/surpluses. These will form the basis of assessing what level on-street controls and the practicality of bringing schemes for- of parking should be provided for town centre developments. ward. If a CPZ is certain to be in place within a year then the tem- Where there is sufficient existing capacity then additional public porary impact may be bearable, if not then, exceptionally for parking may be unacceptable, or additional parking capacity may changes of use and small extensions, a condition restricting occu- be generated by more realistic charging levels. LPAC suggest, as pation until controls are in place may be introduced. If pro- a general rule, 85% occupancy of public parking spaces at grammed, but likely to be in place after a year, then a contribution charges equivalent for similar centres, as a test of sufficiency. It is towards bringing a scheme forward may be desirable, or a condi- important that the charging and management of town centre park- tion restricting occupation until controls are in place. For very ing discourages commuter parking and favours short-stay shop- large schemes where no CPZ is programmed, the scale of impact pers parking. may be such as to require the full implementation of a new CPZ. For very small schemes (such as those for 1-9 dwellings or 6.10.24 It is expected that the desirable level of short stay parking will vary <200m2 for non-residential development) a requirement for pay- considerably between centres. For example in Wembley it might ments may be relaxed unless the transport impact is so great as shorten car trips by local residents which might otherwise have to be wholly unacceptable. The amount asked for will be propor- gone 'out-of-town' or 'out-of-area', unlike, say, in Kilburn which tionate to the costs of introducing the CPZ in question and the has higher densities, lower car ownership and better public trans- proportion of this area on which cars accessing a development port. Account will be taken of evidence from town centre heath are likely to park. checks, the potential for the introduction of on-street parking controls and whether there is capacity for the highway network to deliver further car trips without adversely affecting trips by walk- TRN24 ON-STREET PARKING ing, cycling or public transport.

On street parking controls will be introduced or extended, subject to public consultation, where commuter and/or other forms of on-street parking has, or will have following development, an unacceptable impact on road safety, emergency service access, amenity or traffic management.

Priority will be given to the extension of on-street parking controls in Willesden and areas adjoining Inner London Boroughs, and areas which will be affected by the proposed National Stadium.

Where the net effect of on-street parking generated by a development is likely to cause significant safety or traffic management problems, then contributions to introduce, extend, or bring forward on-street controls may be secured. If such controls are not practical then the development may be unacceptable.

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ESSENTIAL PARKING TRN25 PARKING IN TOWN CENTRES 6.10.26 Brent recognises that some forms of off-street parking do meet an When considering development proposals in town essential need and therefore have to be provided and protected. centres regard will be had to the impact of any Policy TRN27 below is based on the 'hierarchy of parking need' generated on-street parking on the operation of the proposed by the London Traffic Management and Parking centre and the availability of on and off-street public Guidance which recognises that if the number of parking spaces parking spaces within easy walking distance of the at the end of a journey is restricted there must be some means of site. The maximum additional amount of parking 'rationing' that which remains. provided by individual development shall be no greater than the maximum standard for freestanding 6.10.27 Similarly it is recognised that some essential parking is needed development, unless existing parking spaces in the for certain types of trips to public buildings, facilities and spaces. town centre are being re-located from a worse The Plan's approach is to identify the minimum necessary location. amount of such parking which discourages dangerous and/or inconvenient on-street parking, whilst not making parking so plen- Development which would add or lose short term tiful that public transport is discouraged. publicly available parking in a town centre will only be permitted where there is insufficient or sufficient 6.10.28 The Plan's parking standards set an operational minimum level of (respectively) short-term public parking available, at private off-street parking for different types of development. Loss charges typical for equivalent centres, to support it's of parking below these operational levels will therefore be vitality and viability. resisted.

Major developments in town centres of uses open to visiting members of the public are required to have TRN27 RETENTION OF ESSENTIAL OFF-STREET their parking in the form of shared public parking, not PARKING reserved for customers of that development, with maximum stay restrictions (see Policy TRN28). Development which results in the net loss of essential off-street parking will be resisted. Essential parking is defined as (in declining order of priority):

RE-USE OF (a) Operational private non-residential parking (includ- SURPLUS ing parking for disabled persons) in accordance CAR-PARK- with the parking standard (PS15) and policy ING (TRN22) for such;

(b) Town centre public off-street parking complying 6.10.25 Brent encourages with the parking plan for that town centre (See the re-use and Policy TRN25); redevelopment of land that was previ- (c) Other public off-street parking strictly necessary to ously in parking use but which is now surplus to requirements. serve public buildings, facilities and spaces - such as parks;and The Council's revised parking standards and policies will mean that land will be released for other development; particularly (d) Off-street residential parking in accordance with important in a Borough with limited land resources and many the minimum parking standard (PS14) and policy claims on its use. Except where the plan indicates a particular (TRN23) for such. use, the alternative use of these sites is determined in accordance with policy STR1. PUBLIC OFF-STREET & CONTRACT PARKING

TRN26 RE-USE OF SURPLUS CAR PARKING 6.10.29 The provision of public off-street and contract parking should be managed to complement Brent's traffic restraint policy. A policy of The loss to alternative use of car-parking will be per- traffic restraint based only on restricting the supply of parking mitted in the following circumstances: spaces at new development and on managing on-street space, will become ineffective if other off-street spaces are allowed to (a) Where the transport impact of this loss is acceptable (policy TRN1); and increase to cater for the displaced car trips.

(b) Public off-street and contract parking which would 6.10.30 Applications for public off-street car-parking generally relate to now be unacceptable (policy TRN28); and charged parking by the day or part of the day for visiting members (c) Station car parking which would now be unaccept- of the general public. New general parking areas within public able (policy TRN29); facilities such as hospitals, etc., are covered by the plan's parking standards for such facilities, and Policy TRN22. In some loca-

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tions, however, there is a danger that any significant parking area whether alternatives, including 'feeder' bus services, as an inte- could become available for charged use, either for use by com- gral part of the ordinary bus network would have net benefits in muters, or for National Stadium area events. It is essential that terms of reducing the number or length car journeys. Policy such proposals are judged against this policy. TRN27 applies to any surplus spaces. Where stations are in town centres, short stay public car parking may be acceptable in 6.10.31 Management agreements are necessary to ensure an hourly pric- accordance with Policy TRN25. ing structure favouring essential short stay trips (up to two hours) and to deter commuters by levying a punitive charge on long stay parking (over six hours). The cost per hour, not just the total TRN29 STATION CAR PARKS charge, needs to increase with the length of stay. Applications should include details of hours of operation, access control and The future of car parks serving stations will be layout of spaces. Contract parking is parking by contract under- reviewed in the plan period. Their loss will only be taken by those who work or live elsewhere. acceptable where on-street parking controls and necessary replacement 'feeder' bus services are in place or secured. TRN28 RESTRICTIONS ON OFF-STREET PUBLIC PARKING AND CONTRACT PARKING COACHES & TAXIS Public off-street car parking will only be allowed where it can be shown to meet an essential parking 6.10.34 Licensed taxis are an important part of London's transport system need (as defined by Policy TRN27), and providing the and result in the need for less on-street and off-street parking and applicant enters into an agreement for a management a more efficient use of resources than reliance on private cars. regime and pricing structure, including annual They also provide a facility which is of great use to the business reviews, to deter commuter parking. community and enhance London's international competitiveness. Where insufficient provision is made for taxis, however, problems Contract Parking will only be permitted where it is of alighting and turning can occur on the public highway. It is part of the acceptable residential (Policy TRN23) or unacceptable to divert these problems onto surrounding streets. operational parking (Policy TRN22) of a named Mini-cabs are covered by a special policy in the Town Centres & occupier. Shopping Chapter.

5% of all spaces should be for disabled persons. 6.10.35 Essential coach parking facilities are also important for tourism. The strategy for dealing with these in the National Stadium area is Applications for 10 or more parking spaces will be contained in the Wembley Regeneration Area chapter. subject to a condition preventing the charging of car parking, where there is a risk of use by commuters or National Stadium (or associated development) users. TRN30 COACHES AND TAXIS This will not apply to parking dedicated to rail and tube stations of the National Stadium. Developments likely to attract significant numbers of visiting members of the public should include Planning permissions will be for a temporary period adequate taxi parking facilities where boarding and only (normally three years) to prevent the develop- alighting does not obstruct the public highway. ment potential of sites being sterilised, and for parking needs to be reviewed. Development likely to attract significant coach traffic (e.g. larger hotels and exhibition facilities) should include adequate coach stopping and parking facilities which ensure that unloading and alighting do not obstruct the public highway. STATION CAR-PARKS

6.10.32 A number of tube and rail stations in the Borough have associated car parks. This can produce 'rail-heading' with traffic attracted to an area to achieve lower rail fares. Drivers seeking to avoid the THE DESIGN OF CAR PARKS charges for these facilities also cause severe parking problems in nearby residential streets. 6.10.36 Car parks associated with some forms of development have tended to get bigger. Irrespective of the impact of these on travel pat- 6.10.33 All station car parks will, therefore, need to be reviewed in combi- terns they can be highly visually obtrusive presenting a 'sea of nation with the review of on-street parking controls required by cars' as the public face of a development. Good design can help policy TRN24. A Transport Impact Assessment will be necessary overcome this problem through careful use of landscaping and which looks at driving patterns of existing users and considers the positioning of buildings to visually break up large parking

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areas; and by ensuring they are as small as they can be without causing traffic problems. Large hard surfaced areas can also HGVSINRESIDENTIAL AREAS cause water run-off problems and this may cause flooding problems or damage water quality. To avoid the problems identified in 6.11.2 Brent has gradually introduced controls to prevent the through this policy large car parks may be required to be structured (i.e. movement of Heavy Goods Vehicles (HGVs) through residential multi-storey or underground) whilst being attractive and safe. areas.

TRN31 DESIGN AND LAND TAKE OF CAR PARKS TRN33 RESTRICTION OF HEAVY GOODS VEHICLES THROUGH RESIDENTIAL Car parks should be carefully designed to be safe, AREAS appropriately screened and landscaped, have convenient pedestrian links to the development, and Heavy goods vehicles will be excluded from residential should not be located or, of a scale, to be visually areas, through the use, where appropriate, of traffic obtrusive or cause water run-off problems. management measures such as area weight bans, width restrictions and weight restrictions. Car parks of greater than 50 spaces may be required to be structured, whilst being designed to be attractive and safe.

SERVICING IN NEW DEVELOPMENT

6.11.3 Appendix TRN2 lists servicing requirements for certain classes of development. For these classes the loss of existing servicing 6.11 FREIGHT facilities will be resisted.

MOVEMENT OF FREIGHT TRN34 SERVICING IN NEW DEVELOPMENT 6.11.1 Efficient handling and transport of freight is crucial for the regeneration of the industrial areas of the Borough. Rail and water are The provision of servicing facilities is required in all much more sustainable means of transporting freight, over longer development covered by the Plan's standards in distances, than by road, and, particularly given the opening of the Appendix TRN2, and the loss of such facilities will be Channel Tunnel, they can be more economic. Even where move- resisted. ment by road is necessary for part of the journey, transhipment to rail/water for the remainder is to be preferred. Grants under the Railways Act may be available to develop new facilities. There are opportunities for railfreight related development within the Park Royal and Wembley (Brent Park) Strategic Employment 6.12 TRANSPORT NEEDS OF DISABLED Areas. PEOPLE & OTHERS WITH MOBILITY DIFFICULTIES

TRN32 PROVISION AND PROTECTION OF RAIL 6.12.1 Until recently there were only restricted opportunities for disabled AND WATER FREIGHT FACILITIES people - which includes the full range of physical, sensory and cognitive disabilities, including elderly people - and others with Their will be a presumption in favour of the transfer of mobility difficulties such as children or those with young children, freight from road, to rail and water movement & to use either the rail or bus networks. This requires inclusive transhipment. For longer distance movements the design so that the whole community can access new develop- provision of sidings, within suitable new development. The bus companies and Transport for London are heavily ments adjoining railway lines, is supported. investing in features, such as low floors and colour contrasted Warehousing development, adjoining rail lines where grab rails on buses, that will help ease some of the difficulties rail access can be provided, should include sidings. encountered. Level access to stops is equally important, together with visual information systems. Existing sidings will be protected where these are adaptable to serve anticipated needs. 6.12.2 The Council will press the public transport operators to improve the accessibility of their vehicles for disabled people and others with mobility difficulties and will support the development and expansion of a core network of fully accessible stations in London.

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6.12.3 'Mobility Bus' service for disabled people is provided by Transport Craven Park (southern arm) for London. 'Door-to-door' transport is available through the Craven Park Road Borough financed 'Taxicard' scheme, Brent Community Cricklewood Broadway Transport's community car scheme and the Transport for London Dudden Hill Lane financed 'Dial-a-ride' services. The number or length of journeys Edgware Road that can be undertaken using the Borough-provided services is Empire Way limited by the availability of finance and voluntary drivers. Within Forty Lane budget limitations, the Council will seek improvements to these Fryent Way schemes to reflect the needs of the majority of users. Harrow Road High Road Wembley 6.12.4 The Plan recognises the need for convenient car parking spaces High Road Willesden (between Dudden Hill Lane and Willesden Lane) to be reserved for disabled car users to permit their access both High Street Harlesden to new developments (see policy TRN22) and to town centres. Hillside Reserved bays and drop off/pick up points need to be both care- Honeypot Lane fully positioned and designed, especially in shopping centres - Kenton Road both in pedestrian areas, on feeder roads and in car-parks near Kilburn High Road by, and developers should note, as well as the parking standards, Kingsbury Road the Council's Supplementary Planning Guidance (SPG12) on Manor Park Road Access for Disabled People. Neasden Lane North (between Blackbird Hill & North Circular Road) Salmon Street (between Fryent Way & Blackbird Hill) Shoot-up-Hill TRN35 TRANSPORT ACCESS FOR DISABLED Station Road (Harlesden) PEOPLE & OTHERS WITH MOBILITY Sudbury Court Drive DIFFICULTIES Watford Road Wembley Hill Road (from Empire Way to Harrow Road) Access to parking areas and public transport within Willesden Lane development should facilitate access for disabled people & others with mobility difficulties LOCAL DISTRIBUTOR ROADS Designated car parking spaces should be set aside for the exclusive use of holders of disabled persons Abbey Road parking permits. The number and layout of spaces is Acton Lane to comply with the plan's standard (PS15). Beresford Avenue Beverely Drive Access to town centres for holders of disabled parking Brentfield Road permits, community and public transport for disabled Bridge Road people will be prioritised. Brondesbury Park Carlisle Road Carlton Vale Chamberlyne Road Chaplin Road APPENDIX TRN1 Chichele Road Church Lane, Kingsbury Church Road (South of High Road) BRENT'S ROAD NETWORK Copland Avenue Coronation Road GLA ROADS Craven Park (Northern arms) Crawford Avenue A406 North Circular Road and sliproads (a trunk road and a priority (red) Crest Road route). Cumberland Road Dollis Hill Lane Donnington Road (NW10) Drury Way LONDON DISTRIBUTOR ROADS East Lane Blackbird Hill Empire Way Brentfield Engineers' Way Bridge Road Fifth Way Bridgewater Road First Way Burnt Oak Broadway Fourth Way

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Forty Avenue PS4 GARAGES AND ASSIGNED PARKING 136 Great Central Way Harlesden Road (between Park Parade and Robson Avenue) PS5 COMMUTED PAYMENTS REPLACEMENT OF ESSENTIAL PARKING Harrow Road (between Sudbury Court Drive and Watford Road) Harrowdene Road 136 High Road Willesden (between Neasden Lane & Dudden Hill Lane and Church Lane and Neasden Lane) PS6 BUSINESS (USE CLASS B1) AND FINANCIAL AND Kilburn Lane (between Chamberlayne Road and Harrow Road) PROFESSIONAL SERVICES (USE CLASS A2), GENERAL Kilburn Park Road (South of Carlton Vale) INDUSTRY (USE CLASS B2) AND WAREHOUSING (USE Knatchbull Road CLASS B8) 136 The Mall Manor Farm Road (east of Bilton Road) PS7 SHOPS (USE CLASS A1) LESS THAN 2000M2 137 Mapesbury Road Mordant Road (between Winchelsea Road and Acton Lane) PS8 SHOPS (USE CLASS A1), 2000M2 AND OVER 137 Mount Pleasent Neasden Lane (between Dudden Hill Lane and High Road Willesden) PS9 FOOD AND DRINK USES (USE CLASS A3) 137 Oxgate Lane The Paddocks PS10 ASSEMBLY AND LEISURE (USE CLASS D2) AND THEATRES Park Parade 137 Pound Lane Preston Hill (south of the Mall) PS11 HOTELS (USE CLASS C1) 137 Preston Road Queensbury Station Parade PS12 NON-RESIDENTIAL INSTITUTIONS (USE CLASS D1) AND Rainsford Road HOSPITALS (USE CLASS C2) 137 Robson Avenue Roe Green PS13 RESIDENTIAL INSTITUTIONS (USE CLASS C2) AND HOSTELS Salusbury Road 137 Sidmouth Road South Way PS14 RESIDENTIAL DEVELOPMENT (USE CLASS C3) 138 Stag Lane Tanfield Avenue PS15 STANDARD FOR WIDE BAY PARKING 138 The Avenue Tudor Gardens PS16 CYCLE PARKING STANDARDS 139 Twyford Abbey Road (between Hanger Lane & Coronation Road and Rainsford Road and Abbey Road) PS17 SHOP (USE CLASS A1) SERVICING, UNITS LESS THAN Walm Lane (between Willesden Lane and Chichele Road) 2000M2 GROSS FLOOR AREA 139 Wembley Hill Road Wembley Park Drive PS18 SHOP (USE CLASS A1) SERVICING, UNITS GREATER THAN Wembley Park Lane 2000M2 GROSS FLOOR AREA 140 Whitby Avenue Whichester Avenue PS19 BUSINESS (USE CLASS B1), FINANCIAL AND PROFESSIONAL Winchelsea Road (USE CLASS A2), GENERAL INDUSTRY (USE CLASS B2) Woodcock Hill AND WAREHOUSING (USE CLASS B8) SERVICING 140 Wrottesley Road. PS20 FOOD AND DRINK (USE CLASS A3) SERVICING 140 All other roads are local access roads. PS21 HOTEL (USE CLASS C1) SERVICING 140

APPENDIX TRN2 PS22 RESIDENTIAL INSTITUTIONS (USE CLASS C1), HOSTELS, AND HOSPITALS (USE CLASS C2) SERVICING. 140 PARKING AND SERVICING STANDARDS

Standard Page

PS1 OPERATION OF THESE PARKING STANDARDS 136

PS2 MAXIMUM AND MINIMUM STANDARDS 136

PS3 REGENERATION EXCEPTION 136

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CAR PARKING STANDARDS for commuter or visitor trips. Assessment of the necessary minimum amount of operational parking is proposed to be made on a PS1 case by case basis. Where an acceptable proposal comes forward OPERATION OF THESE PARKING STANDARDS to intensify the use of a site in an area with very good public transport accessibility with a controlled parking zone then the maximum The maximum and/or minimum level of car-parking to be provided standard will not be increased, so as not to increase car-use. for a new development, redevelopment or change of use is set out in this section. For the policy context refer to Policies TRN22 & For developments below the maximum parking threshold relating to TRN23. a standards for a single space (e.g. B1 developments less than 300M2) may still have one space. For developments of multiple Floor areas referred to throughout relate to gross floor area small units below this level it is therefore acceptable to allow maxi- (GFA=Gross Floor Area), as defined in the Royal Institute of mum parking to be assessed unit by unit, rather than the normal Chartered Surveyors (RICS) code of measuring practice, unless practice of the scheme as a whole. specifically stated otherwise. Reference to the types of development conforms to the Use Classes specified in the Town and PS3 Country Planning (Use Classes) Order 1987, as amended (see REGENERATION EXCEPTION Glossary). 1 An increase of up to /3 in parking will exceptionally be made in Car-parking spaces are generally to be provided off the highway or Strategic Employment Areas, Park Royal and the National Stadium where new roads are being constructed on unallocated bays con- Policy Area, providing the applicants can demonstrate the following: tiguous to it. PS14 allows in some cases parking on existing high- (a) it is a key regeneration proposal supportive of regeneration pro- ways for residential development. Spaces must be clear of turning jects in the area; and (b) the transport and environmental impact and circulation areas and be independently accessible. of the scheme is acceptable; and (c) the proposal secures significant and sufficient public transport/walking/cycling improvements, Where a change of use is proposed, the traffic impact and parking and/or contributions towards on-street parking controls, and imple- standards applying to the previous and proposed uses will be com- mentation of a green transport plan. pared. For mixed-use schemes regard will be had to shadow parking between uses at different times of the day. PS5 Replacement of Essential Parking For outline applications parking areas/layout will be part of the siting reserved matter (unless the parking is structured when it will be In some limited circumstances it may be acceptable to replace park- part of the design reserved matter). A condition should be put on ing which the Plan protects as essential (Policy TRN27) in an alter- the outline application setting a maximum parking level for the site - native location, but within easy walking distance. Examples are where uses/floor areas are known. In addition, and where shared town centre public parking or parking for disabled people, uses/floor areas are not known, a condition will be placed on the where it is lost or not practical to provide on-site but where suitable outline application requiring details of parking (at no greater levels sites can be identified in that centre. In such circumstances plan- than revised UDP standards) to be submitted with applications to ning obligations may be used to secure this. Also the Council may discharge reserved matters on uses and siting. In some cases this accept payments to improve public transport, etc. The Plan does may need to be determined at the same point as access & landscap- not, however, allow replacement of spaces required to meet the ing reserved matters. standards for parking for disabled people or cycles unless suitable on-street spaces can be identified and funded. The minimum normal parking space dimension is 2.4m wide by 4.8m depth. The normal standard minimum dimension for a parking PS6 bay is given in SPG12 Access for Disabled People: Designing for BUSINESS (USE CLASS B1) AND FINANCIAL AND Accessibility. SPG13, Layout Standards for Access Roads gives a PROFESSIONAL SERVICES (USE CLASS A2), GENERAL number of examples where different dimensions apply. INDUSTRY (USE CLASS B2) AND WAREHOUSING (USE CLASS B8) PS2 MAXIMUM AND MINIMUM STANDARDS Maximum of one space per 300 m2 Gross Floor Area in or adjacent to the Major Town Centres and District Centres where Standards PS6-PS14 are Maxima. However, minimum Operational public transport access is good or very good. Elsewhere a standard Parking (as part of but not additional to the maxima) is required to of 1 space per 150 m2 Gross Floor Area applies. cater for essential trips which cannot be made by public transport; including parking provision for people who are unable to use public This standard will also apply for non-ancillary office space in other transport because of a disability, people working unsociable hours, developments i.e. of over 150m2 office space or where offices and people maintaining the building or the specific needs of a par- space exceeds 20% Gross Floor Area, irrespective of floor area. ticular activity (in which case the onus will be on the applicant to demonstrate special need). Operational parking is part of the overall For changes of use to A2 in shopping centres no parking is required parking maximum (not additional) and does not include provision in addition to the current use.

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On street parking and servicing (including trade customers of cash PS11 and carry warehouses) is unacceptable. HOTELS (USE CLASS C1)

For Live-Work development apply the residential parking standard Maximum of 1 space per 5 bedrooms only, but with a 50% reduction to reflect the reduced need to travel; servicing areas should be separate. Plus maximum of 1 space per 5 employees

PS7 Employee parking is based on maximum accumulation levels. SHOPS (USE CLASS A1) LESS THAN 2000M2 Ancillary restaurants/bars open to non-residents apply the A3 stan- Up to Gross Floor Area 400 m2 1 space dards.

Plus 1 space each extra 100m2 Gross Floor Area pro-rata thereafter Where hotels have 50 rooms+, one coach space should be provided per 50 rooms. The standard also covers 'quasi-retail' uses such as (e.g. private members clubs, advice centres, amusement centres, launderettes, PS12 internet cafes and international call centres). NON-RESIDENTIAL INSTITUTIONS (USE CLASS D1) AND HOSPITALS (USE CLASS C2) Special attention will be paid to the impact of shops requiring large amounts of on-street servicing of shoppers. Type of Establishment

PS8 Places of Worship 2 spaces for every 5 visitors, based SHOPS (USE CLASS A1), 2000M2 AND OVER on maximum capacity.

Maximum of 1 space per 50 m2 Gross Floor Area inin oror adjaadja- Hospitals 1 space per 5 beds cent to the Major Town Centres and District Centres where public transport access is good or very good. Elsewhere a Education, Other Health and Community Facilities standard of 1 space per 25 m2 Gross Floor Area applies. 1 space per 5 workers

PS9 An additional space would be allowable for each health-care worker FOOD AND DRINK USES (USE CLASS A3) who requires the use of a car in the course of his/her duties. Consideration may be given to dedicated on street 'doctor' bays. Up to Gross Floor Area 400 m2 1 space For all education and health uses, the maximum additional Plus 1 space each extra 100m2 Gross Floor Area pro-rata visitor/student parking should be 20% of the employee parking, thereafter with a minimum provision of one space.

A development or change of use should not have an adverse effect For community facilities, the maximum additional parking for on traffic conditions associated with on-street parking (taking into visitors should be 5% of the maximum attendance. account such factors as road safety and bus operation) and on- street parking on residential side streets should not adversely effect For day nurseries and educational uses special attention will be paid residential amenity (having regard to proposed hours of use and the to setting down facilities and the impact of on-street parking on res- nature of the use). idential roads at the opening and close of sessions.

For 'takeaway' uses special attention will be paid to on-street stop- Religious buildings catering for festivals attracting large numbers of ping and/or parking of delivery vehicles and the impact of this on attendees may be required to enter into special traffic management road safety and/or bus operation. arrangements.

PS10 PS13 ASSEMBLY AND LEISURE (USE CLASS D2) AND THEATRES RESIDENTIAL INSTITUTIONS (USE CLASS C2) AND HOSTELS Spaces equivalent to 1 in 60 patrons, based on maximum patron capacity, plus one space per 200m2 non Residential Institutions (other than elderly persons permanent seating/assembly area. housing): 1 space per 10 bedrooms

Maximum employee parking of one space per 5 employees Hostels (inc. Student Housing and HMOs): 1 space per 16 bedrooms

Maximum employee parking as Hotels.

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PS14 transport accessibility and a controlled parking zone (CPZ), a RESIDENTIAL DEVELOPMENT (USE CLASS C3) reduced provision of 0.7 spaces per unit applies for 1-2 bedroom units and 1.2 space per unit for 3+ bedrooms. Spaces should be Type of Dwelling Spaces per Unit unallocated as far as practical.

New Dwellings For Work-Live development apply the residential parking standard only, but with a 50% reduction to reflect the reduced need to trav- 1 bedroom 1.0 el; servicing areas should be separate.

2 bedroom 1.2 An exception can be made for affordable housing by a registered social landlord of up to 50% reduced provision (after all other 3 bedroom 1.6 reductions).

4+bedrooms 2.0 The siting of communal parking areas will be carefully controlled so that they are convenient for use by residents. Large expanses of Elderly Persons Accommodation surface car-parking unrelieved by screening and landscaping will not be considered acceptable. Category 1 0.5

Category 2 0.25 PARKING FOR DISABLED PEOPLE

Category 2.5(very sheltered) 0.1 PS15 STANDARD FOR WIDE BAY PARKING Plus 1 warden space Shops (A1), Financial and Professional Services (A2), Food and The total parking provision for the development as a whole should Drink (A3), Hotels (C1), Hospitals (C2), Non-Residential Institutions be divided between assigned (allocated to an individual unit, such (D1) and Assembly and Leisure (D2), Business (B1), General as front garden parking), and unassigned spaces. As unassigned Industry (B2) and Warehousing (B8), Residential Institutions (C2) spaces can be used more flexibly and reduce the overall provision, and Hostels: at least 50% of spaces should be unassigned for 1 or 2 bedroom 5% of spaces (1 minimum) should be dedicat properties, with 20% of spaces unassigned for larger properties. A ed for disabled use maximum of two parking spaces per unit may be assigned. Assigned spaces may be hardstandings, garages, or car ports. New Dwellings (C3): Conditions may be imposed to ensure that garages remain available 1 space per wheelchair unit, next to the for the parking of a car. dwelling.

On local access roads outside heavily parked streets visitor parking For other dwellings if a parking space capable of being widened to may be provided on-street, for the frontage of the development 3.3m wide is not adjacent to the dwelling then 10% of spaces with- only, providing this is safe and sufficient carriageway width remains. in 30m of the dwelling should be capable of being widened to 3.3m For infill schemes normal parking may be provided in this manner if wide there is no satisfactory way to accommodate off street parking. In developments with new roads this is acceptable for all parking and A minimum of one space will be required for developments of 10 or new roads should be designed to accommodate such casual more units. The application of this standard will have regard to the parking. constraints and opportunities of the site. For changes of use involving smaller properties consideration will be given to the provision of Provisions apply to new dwellings. For conversions, any additional dedicated on-street disabled persons bays (see Policy TRN35). requirement is the standard for the converted dwellings, minus the standard for the pre-converted dwelling or building (in counting Spaces should be marked and reserved for disabled people, existing and proposed off-street parking, only parking complying although where five or fewer total parking spaces are provided one with other Plan policies, i.e. Policy BE7 specifying the maximum use or two of these may be wide bay but not marked; and reserved to of front gardens, can be counted). In line with the above on-street be available for future provision. parking accounting for any overspill might be acceptable on local access roads, if they are not heavily parked streets. The normal standard minimum dimension for a parking bay is given in SPG12 Access for Disabled People: Designing for Accessibility. For conversions of non-residential buildings regard will be had to restrictions on space around the building. Where a development scheme contains a number of units then the requirements of the scheme as a whole, will be considered. For both new dwellings and conversions in areas with very good public transport accessibility, and town centres with good public Where car parking is adjacent to a home it should be capable of

Brent Unitary Development Plan - 2004 138 TRANSPORT enlargement to attain 3.3m width. 1 in 20 of all parking spaces (1 Libraries 1 space per 10 staff in 10 where the parking standard is reduced for housing by a regis- plus 1 space per 10 for visitors tered social landlord) should be 3.3m wide at the outset and accessible as a visitor space. Other, universities, colleges etc. 1 space per 8 The distance from the car-parking space to the building served staff/students should be kept to a minimum (and never greater than 50m) and should be level or gently sloping. Business/Offices (B1a) & Financial and Professional Services (A2)

In larger public buildings a number of spaces should be wide 125 sqm. with a minimum of 2 spaces enough to be used by accessible mini-buses. General Industry (B2), Light Industry/R&D (B1b, B1c) & In addition, buildings open to the general public should, provide a Warehousing (B8) proportion of 'wide bays' for parent and child parking etc on top of 500 sqm. with a Minimum of 2 spaces the above standard. Student Hostels 1 space per 2 students CYCLE PARKING Residential Institutions (C2) PS16 1 space per 8 staff CYCLE PARKING STANDARDS Housing (C3) - ground floor level Use 1 space per GFA Normal (including where practical flat conversions) Shops (A1) 1 space per unit (garages count) Food Retail 125 sqm. Sheltered 1 space per 5 staff Non-Food Retail 300 sqm. Transport - bus and train stations Food and Drink (A3) To Meet Local Demand

Pubs/Wine Bars 100 sqm. Cycle parking provision should normally be by 'Sheffield' type stands (each of which provides two spaces), or wall mounted stands of Take Aways 50 sqm. similar utility. However secure lockers may be suitable at workplaces, stations and in residential developments. For workplaces Restaurants, Cafes 1 space per 20 seats over 2000 sqm. secure lockers will be required as will suitable cycle with a minimum of 2 spaces changing/showering facilities for both sexes. Long stay cycle parking should be under cover. Cycle parking should be within 50m of Assembly and Leisure (D2) the building it serves if it to be well used.

Theatres and Cinemas Source: London Cycle Network Design Guide, as adopted by LPAC. 1 space per 50 seats with a minimum of 2 spaces SERVICING STANDARDS Leisure/Sports Centres/Swimming Pools 1 space per 10 staff plus 1 PS17 space per 5 staff for visitors SHOP (USE CLASS A1) SERVICING, UNITS LESS THAN 2000M2 GROSS FLOOR AREA Non-Residential Institutions (D1) One full sized lorry bay is required per 1000m2 (10,760 sq.ft), or Schools - primary part thereof. When applying this standard, existing servicing facili- 1 space per 10 staff ties in the immediate vicinity may be taken into consideration provided that they are convenient and availability for use by the pro- Schools - secondary posed development can be ensured. 1 space per 10 staff/students Where development consists of a number of small shop units, full sized lorry bays sufficient for the total floor area of the development Doctors/Dentists Surgeries, Health Centres and Clinics should be provided. These bays would be shared amongst several 1 space per 5 staff shop units. In addition a bay suitable for 'transit' sized vehicles plus 1 space per 5 for visitors should be provided for every two units.

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•Where shop units are not provided with individual full-size bays, PS22 particular attention should be paid to refuse collection facili- RESIDENTIAL INSTITUTIONS (USE CLASS C1), HOSTELS, ties. AND HOSPITALS (USE CLASS C2) SERVICING. •These servicing requirements will be applied to open areas that are proposed for retail markets. Hospital developments must provide facilities for at least 8m rigid vehicles. PS18 SHOP (USE CLASS A1) SERVICING, UNITS GREATER THAN Suitable sized facilities should be provided for buses and/or ambu- 2000M2 GROSS FLOOR AREA lances catering for the client group.

One full sized lorry bay for each 2000m2 Gross Floor Area or part thereof. APPENDIX TRN3 PS19 BUSINESS (USE CLASS B1), FINANCIAL AND PROFESSIONAL (USE CLASS A2), GENERAL INDUSTRY HEAVILY PARKED STREETS (USE CLASS B2) AND WAREHOUSING (USE CLASS B8) SERVICING A

Units under 100m2 Gross Floor Area and 'live-work' units will be Aberdeen Road required to provide a loading bay that can accommodate a 'transit' Abbotts Drive sized vehicle. Acland Road Ada Road Units between 100m2-280m2 Gross Floor Area must have loading Aldershot Road bays that can accommodate at least an 8m rigid vehicle. Alric Avenue Allington Road Where units less than 280m2 are proposed the development as a All Soul's Avenue (between Holland Road and Phillimore Gardens) whole must be capable of handling full-sized vehicles. This applies Ambleside Road to unloading and turning in particular. Amery Gardens Ancona Road Units 280m2-2000m2 Gross Floor Area must have at least one full Anson Road (between Cricklewood Broadway and Chichele Road) sized loading bay. Ash Grove Ashburnham Road Units larger than 2000m2 must have at least two full sized loading Ashcombe Park bays. Ashdon Road Ashford Road B1(a) office units need only be served by 8m rigid vehicles, Ash Tree Dell although such developments over 5000m2 should have provision for Aspen Drive the maximum sized rigid vehicles. Attewood Avenue Avondale Avenue All service bays for car repairs (B2) should provide one off-street Aylesbury Street parking space for vehicles awaiting repair/delivery. B Baird Close PS20 Balmoral Road FOOD AND DRINK (USE CLASS A3) SERVICING Ballogie Avenue Barham Close Public houses need to be serviced by 10m rigid vehicles. Other A3 Barrs Road uses are generally able to be serviced by 'transit' sized vehicles, but Bathurst Gardens consideration should be given to the needs of refuse collection vehi- Bayford Road cles which are generally 10m rigid vehicles. Beaconsfield Road Beatrice Avenue Belmont Avenue PS21 Belton Road HOTEL (USE CLASS C1) SERVICING Berens Road Bermans Way Hotel developments must provide facilities for at least 8m rigid vehi- Bertie Road cles. Where a major public bar is included, the requirement will be Beverley Gardens (between West Hill and as for A3 uses. Uxendon Hill)

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Bishop Way Churchmead Road Bolton Road Clarence Road Bouverie Gardens Clayton Avenue Braemar Avenue NW10 Clifford Gardens Braemar Avenue (Wembley) Clifton Road Bramston Road Clifton Way Brent Way Cobbold Road (between Roundwood Brendon Avenue Road and Franklin Road) Brentfield Close Codling Way Brenthurst Road Colin Road Briar Road, NW2 College Road NW10 Bridgeway Colwyn Road Brondesbury Road Colyton Close Brondesbury Villas Compton Road Brownlow Road Conley Road Brooksville Avenue Cooper Road Bruce Road Croxden Close Buchanan Gardens Craigmuir Park Buckingham Road Cranhurst Road Buckley Road Crediton Road Burns Road, NW10 Creighton Road Burrows Road Cromwell Road Burton Road Crummock Gardens Buxton Road Crouch Road Byron Road, Wembley D C Dagmar Gardens Cairnfield Avenue Deacon Road Cambridge Road (between Kilburn Park Dean Road Road and Stafford Road) Denmark Road Canterbury Terrace Deanscroft Avenue Callcott Road Denzil Road Carlyon Close Dewsbury Road Caple Road Dimsdale Drive Carlisle Road NW6 Dollis Hill Lane (between Edgware Road Casselden Road and Coles Green Road) Cedar Road Donaldson Road Chadwick Road Doreen Avenue Chalfont Avenue Dors Close Chambers Lane Douglas Avenue Chandos Road Douglas Road Chaplin Road (Wembley) (between Ealing Doyle Gardens (between College Road and All Souls Avenue) Road and Scarle Road/Napier Road) Dunster Drive Chaplin Road NW2 Durand Way Chapter Road Drayton Road Charteris Road Dudley Road Charlton Road NW10 Dundonald Road Chatsworth Avenue Dunmore Road Chesham Street Dunster Gardens Chestnut Avenue Dyne Road Chestnut Grove Chevening Road (between Salusbury Road and Kingswood Road) E Chichele Road Eagle Road Chippenham Avenue Ealing Road (Cromwell Court) Chippenham Gardens Eden Close Chipstead Gardens Earlsmead Road Church Drive Egerton Road Cholmodeley Avenue Elgar Avenue Churchill Road Ellesmere Road (between Aberdeen Road and Hamilton Road)

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Elm Way Hawthorn Road Elmwood Crescent Haydon Close Elton Avenue Hazeldean Road Eric Road Hazelmere Road Esmond Road Hazel Road Essex Road Heber Road Evelyn Avenue Henley Road Exton Crescent Herbert Gardens Eyhurst Close Herne Close Highcroft F Highfield Avenue, Wembley Fairfields Close Highfield Avenue, NW9 Fairlight Avenue Highfield Close Fairview Avenue Hiley Road Felixstowe Road Hillcroft Crescent Fembank Avenue Hillfield Avenue Fleetwood Road (between Lancaster Road and Hamilton Road) Holden Avenue Field Way Holland Road NW10 Finch Close Holly Close Forest Gate Hollycroft Avenue Fortune Gate Road Homefield Close Foxlees Honeywood Road Furness Road (between Harrow Road and Holland Road) Honiton Road Hopefield Avenue G Howard Road Gardenway Huddlestone Road Garnet Road Geary Road (between Lancaster Road and Hamilton Road) I Georgian Court Ilex Road Girton Avenue (between Winchester Inman Road Avenue and Wimborne Drive) Ivy Road Gladstone Park Gardens Glendale Gardens J Jackman Mews Glengall Road Glynfield Road Goldsmith Lane K Gorefield Place Kathleen Avenue Gowan Road Kelceda Close Grand Avenue East Kempe Road Greenhill Park Kenilworth Road Greenhill Road Kenwyn Drive Gresham Road Keslake Road Greyhound Road Kilburn Park Road Grittleton Avenue Kings Drive (between Greenhill Way and end) Groveway Kingsley Road Grove Road Kingsmead Avenue Guilsborough Close Kingswood Avenue Kingthorpe Road H Halstow Road L Harley Close Lancaster Road Hamilton Road Lancelot Avenue Hanover Road Lane Close Hardinge Road Langler Road Harlesden Gardens Langdon Court Harrowdene Close Lansdowne Grove Hartland Road Larch Road Harvist Road (between Milman Road and Chamberlayne Road) Larkway Close Harwood Close Lechmere Road

Brent Unitary Development Plan - 2004 142 TRANSPORT

Leeland Way Normansmead Leghorn Road Northview Crescent Leigh Gardens Leighton Gardens O Leith Close Oakdale Avenue Lennon Road Oak Tree Dell Leopold Road Oakington Manor Drive (between Victoria Avenue and Chalfont Avenue) Lewis Crescent Oakleigh Court Leybourne Road Oaklands Road Liddell Gardens Odessa Road Linacre Road Okehampton Road Linden Avenue NW10 Oldfield Road Litchfield Gardens Olive Road Lovat Close Orchard Close, Wembley Lushington Road Osbome Road Lyon Park Avenue (between Hillfield Avenue and Mount Pleasant) Oxgate Gardens Lyndhurst Close Lynton Road P Page Close M Palermo Road Magnolia Court Park Avenue NW2 (between St Pauls Avenue and High Road) Malvern Road Park Chase Manor Close Park Close Mardale Drive Park Road NW10 Marloes Close Park View Marian Way Parkfield Road Marquis Close Peel Road Maybank Avenue (between The Rise and Pember Road Rosebank Avenue) Perkin Close Maybury Gardens Pine Road Mead Plat Plympton Avenue Meadow Way, Wembley Plympton Road Meadow Way, NW9 Poplar Grove Meadowbank Road Preston Gardens Melrose Avenue Princes Court Meyrick Road Princess Road Midstrath Road Priory Close Minet Avenue (between Bramshil Road and Harley Road) Priory Park Road NW6 Minet Gardens Prout Grove Mitchellbrook Way Purves Road Monks Park Q Monks Park Gardens Monson Road Queen Victoria Avenue Montrose Avenue Queensbury Road, NW9 Mora Road Mortimer Road R Mount Road Radcliffe Avenue Mount View Road Radnor Road Rainham Road N Randall Avenue (between North Circular Napier Road NW1O Road and Tanfield Avenue) Neasden Close Ranelagh Road NW10 Neville Close Ravensworth Road Newcombe Park Redfern Road Newton Road NW2 Reeves Avenue Nicoll Road Regent Street Nightingale Road Ridge Close Normans Close Ridley Road Normanby Road Riffel Road

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Riverside Gardens T Rockhall Road Roe End Talisman Way Rosebank Avenue Tanfield Avenue Rosecroft Walk Tatam Road Roundwood Road Temple Road Rowley Close Tennyson Road Rucklidge Avenue The Boltons Rudolph Road The Chine Rupert Road The Circle Russell Close The Close (Barnhill Road) Rustic Place The Dell The Glen S The Grange Saint Julian's Road The Grove Sandringham Road The Retreat Seaton Road The Rise Selbie Avenue The Ridgeway, NW9 Sellons Avenue Thurlby Road Selwyn Road Tiverton Road, Wembley Severn Way Torbay Road Shorts Croft Tower Road Sidmouth Road (between Willesden Lane Trevyan Gardens and Brondesbury Park) Tudor Court North (East) Southview Avenue Tubbs Road Spezia Road Tunley Road Springwell Avenue Tylers Gate St. Alban's Road Twybridge Way St. Andrew's Close, NW2 U St Georges Close St. James' Gardens Uphill Drive St Johns Avenue St. John's Close V St Margarets Road Valley Gardens St Marys Road Vane Close St Paul's Avenue Victoria Court St Thomas's Road Victoria Mews Stancroft Victor Grove Stafford Road Victor Road Stapleford Avenue Victoria Road (between Salusbury Road and Honiton Road Stanley Road and Kilburn High Road and Donaldson Road) Stanley Park Drive Village Way Station Approach Villiers Road Station Crescent Vincent Road Station Terrace Vine Court Stoll Close Stonebridge Way W Stonebridge Park Wakemans Hill Avenue (between Summit Close and Buck Lane) Streatley Road Wakeman Road Stracey Road Walm Lane (between Dartmouth Road and St. Gabriel's Road and between Strode Road Keyes Road and Hoveden Road) Sudbury Crescent Waylett Place Suffolk Road Wells Drive Summerfield Avenue Wembley Way SunIeigh Road Wendover Road Sunny View Wellington Road Sunnymead Road Westbury Avenue Swinton Close West Ella Road Westbury Road

Brent Unitary Development Plan - 2004 144 TRANSPORT

Westview Close West Way Whitmore Gardens Willesden Lane (between Kilburn High Road and Tennyson Road) Whitby Gardens Winchester Avenue Windermere Avenue NW6 Windermere Grove Windsor Crescent Windsor Road Winslow Close Woodheyes Road Woodside Avenue Woodside Close Woodside End Woodville Road Wotton Road Wrentham Avenue Wyld Way (between Vivian Avenue and Park View)

Y Yewfieid Road

Brent Unitary Development Plan - 2004 145 TRANSPORT

Source: London Transport CAPITAL model, December 1999.

N.B. This map is indicative only.

Brent Unitary Development Plan - 2004 146 TRANSPORT

Brent Unitary Development Plan - 2004 147 TRANSPORT

Brent Unitary Development Plan - 2004 148 EMPLOYMENT 7 EMPLOYMENT

Page EMP13 BAD-NEIGHBOUR USES 159

7.1 INTRODUCTION 150 7.8 TYPES OF EMPLOYMENT DEVELOPMENT 159 7.2 BACKGROUND 150 EMP14 DESIGN OF BUSINESS DEVELOPMENTS 160 7.3 STRATEGIC CONTEXT 152 EMP15 LOCATION OF B1 BUSINESS DEVELOPMENT 160 7.4 POLICY OBJECTIVES 153 EMP16 BUSINESS PARKS AND/OR TECHNOLOGY 7.5 BOROUGH STRATEGY 153 PARKS 161

EMP17 REUSE OF REDUNDANT OFFICES 161 POLICIES & PROPOSALS EMP18 GENERAL INDUSTRIAL DEVELOPMENTS 162 7.6 GENERAL 154 EMP19 WAREHOUSE DEVELOPMENTS 162 EMP1 NAMED OCCUPIERS & EXISTING EMPLOYERS 154 EMP20 CREATIVE INDUSTRY PROPOSALS 162

EMP2 SMALL AND MEDIUM SIZED ENTERPRISES 154 EMP21 WORK-LIVE DEVELOPMENT 163

EMP3 CHILDCARE FACILITIES IN EMP22 HOME-WORKING 163 EMPLOYMENT DEVELOPMENTS 154 7.9 SPECIAL POLICY AREAS 163 EMP4 ACCESS TO EMPLOYMENT OPPORTUNITIES155 EMP23 HASSOP ROAD SPECIAL POLICY AREA 164 7.7 EMPLOYMENT AREAS PLANNING FRAMEWORK 155 EMP24 THE BRENTWATER ESTATE 164

EMP5 DESIGNATION OF STRATEGIC EMPLOYMENT MAP EMP1 UNEMPLOYMENT IN BRENT 165 AREAS 156

EMP6 EMPLOYEE FACILITIES IN STRATEGIC EMPLOYMENT AREAS 156

EMP7 BOROUGH EMPLOYMENT AREAS 156

EMP8 PROTECTION OF STRATEGIC AND BOROUGH EMPLOYMENT AREAS 157

EMP9 DEVELOPMENT OF LOCAL EMPLOYMENT SITES 158

EMP10 THE ENVIRONMENTAL IMPACT OF EMPLOYMENT DEVELOPMENT 158

EMP11 REGENERATION OF EMPLOYMENT AREAS 159

EMP12 PUBLIC REALM ENHANCEMENT IN EMPLOYMENT AREAS 159

Brent Unitary Development Plan - 2004 149 EMPLOYMENT

last 20 years, spreading far wider than Brent, have led to the loss of much of Brent's previously dominant manufacturing base. By 1994 there were 12,600 jobs in manufacturing, compared with 32,200 in 1981.

7.2.2 The Brent Economic Baseline Study of 1995 found that investment in the area was expected to be higher than the UK average due to investment in the Park Royal intermediate area (as so designated until the end of 1999). Employment in Brent was expected to increase so that by 2004 it would be around 10% higher than its lowest level in 1994. Further steady losses are expected in manufacturing but significant employment growth is expected in distribution, hotels and catering, other services and in construction.

7.2.3 The government has stated that it believes that an active and thriving manufacturing sector is vital to the success of London's economy. To this end it has launched the London Manufacturing Initiative. Increasing London's share of new "high tech" employment is important through targeting potential inward investors and through identifying sites, facilitating access and improving the environmental quality and access of employment areas.

7.2.4 The Council has made particular efforts as a planning authority, 7.1 INTRODUCTION especially since the adoption of its Industrial Land Strategy in 1984, to create a degree of certainty for industrial occupiers and 7.1.1 Policies in this Chapter relate to employment uses which are investors alike by protecting good quality industrial land in the defined as comprising the following use classes: Borough from the speculative effects of the intrusion into industrial areas of higher value uses such as retailing or housing. • B1 (such as offices, research & development, light industry); • B2 (such as general industry / manufacturing); • B8, (warehousing & distribution); and ECONOMIC ACTIVITY • Closely related uses not falling within a use class - Sui Generis (such as haulage yards, bus garages and MOT test- 7.2.5 Employers in Brent, like many others in London, have continued ing stations), but which are commonly found in industrial to restructure their industrial activities in favour of non-metropoli- estates. Car sales are not an employment use, but may be tan locations sometimes involving the total closure of their ancillary to car repairs. London factories. As redevelopment in accordance with modern standards takes place, generally with single storey buildings and 7.1.2 Employment in other service industries is subject to policies else- higher standards of parking and servicing, lower employment where in the Plan. For example, the development of retail densities result. employment in the Borough is dealt with in the Town Centres and Shopping Chapter and employment in hotels in the Tourism, 7.2.6 New firms, however, have been moving in and occupying sites Entertainment and the Arts Chapter. For these other activities the within industrial and business areas. These include smaller man- service provided and its accessibility to customers are the defin- ufacturers, especially in food processing, wholesale and producing planning issues, and not simply the employment generated. tion warehousing and distribution, a cluster of computer related firms in the Staples Corner area, and a wide range of generally 7.1.3 Developments of waste related industries are covered by policies small service sector firms, e.g. plumbers merchants. in the Waste chapter. Development of, or close to, potentially polluting industry is covered by the special policies in the 7.2.7 There is evidence of buoyant demand for the best located indus- Environmental Protection chapter. trial land and premises. The apparent strengthening of demand for industrial land that occurred in the late 1980's was undoubtedly influenced by reductions in the amount of land available for 7.2 BACKGROUND industrial development not only in Brent but also elsewhere in North West London. Substantial losses to uses such as housing 7.2.1 Brent's economy and its associated employment structure has and retailing have taken place in Brent: over 40 hectares (100 undergone substantial change in recent years. Brent has tradi- acres) of industrial land were transferred to these uses between tionally played an important role in London's economy and partic- 1984 and 1991. ularly that of North West London providing substantial areas of land to accommodate manufacturing industry. Trends over the

Brent Unitary Development Plan - 2004 150 EMPLOYMENT

UNEMPLOYMENT AND EMPLOYMENT industries, such as engineering, continued their decline they were replaced by a wide range of industrial and quasi-industrial uses 7.2.8 The GLA claimant count unemployment rate in Brent in January serving the London economy. But most importantly, from the land 2004 was 6.4%, compared with a Greater London average of use planning viewpoint, this process of change has resulted in 4.9%, and an Outer London average of 3.7%. The rate in Brent is fewer jobs being accommodated on redeveloped sites. actually more similar to the inner London rate; 6.9%. For certain groups in the Borough the rate of unemployment is exceptional: 7.2.11 The Inspector at the Inquiry into Brent’s first UDP in 1993 con- the January 2004 male claimant count unemployment rate for two cluded that land readily available for industrial development in wards in the Borough (Stonebridge and Harlesden) exceeds 15% PEAs (Primary Employment Areas, the previous designation for and the rate for Carlton exceeds 25%. (Comparable rates for protected employment land) ‘is in short supply’. In 1997 a similar women, because of their differing eligibility for unemployment survey revealed that the land readily available for industrial devel- benefit, are not available). (Source: GLA & ONS claimant count). opment stood at around 15 hectares, less than 4% of all land in The 2001 Census illustrates the differences in unemployment the PEAs. In respect of the Strategic Employment Areas (SEAs) rates found between ethnic groups; “Unemployment rates for and Borough Employment Areas (BEAs), (the current designa- Black and minority ethnic (BME) workers across Greater London tions for protected employment land), Brent’s Employment Land averaged 11.3 per cent - more than twice as high as rates for Demand Study (December 2001), estimated that only just over 25 White groups (5.3 per cent). Within the BME population, there is hectares of land was realistically available for industrial develop- a huge variation in unemployment rates. Unemployment levels ment, even though larger amounts of land were unused or under- were very high for Bangladeshi and Black workers. One fifth of used. There has also been a relatively rapid take-up of newly Bangladeshi people active in the employment market were unem- released land at the rear of Central Middlesex Hospital. This pro- ployed. Rates for Black groups ranged from 12.3 for the Black vides evidence that there is strong demand for new industrial Caribbean group up to 17.6 per cent for the Black Other group. In development in the Borough and in the Park Royal area in partic- contrast, Indian workers had unemployment levels (5.9 per cent) ular. which were fairly close to those for White groups.” (Unemployment in London, An analysis of 2001 Census data, 7.2.12 The restructuring of the economy away from manufacturing gen- GLA, November 2003). Thus, the general unemployment rates erally, and within manufacturing away from relatively large may well underestimate the difficulties in gaining access to jobs employers in the engineering sector to a range of smaller compa- for groups of people in the community. nies in a variety of economic activities, has brought special problems of adjustment. Undoubtedly skill mismatches have devel- 7.2.9 In addition, evidence from the Census of Employment shows that oped and the balance between male and female jobs has the number of employees in the Borough was falling faster at the changed: between 1991 and 2001, the proportion of jobs held by beginning of the 1990's than had previously been the case. The the female population grew from 44% to 46%. Furthermore, the number of employees in the Borough declined by 18,000 over the traditional contribution of large engineering companies in provid- decade 1981 to 1991, an average rate of around 1,800 jobs per ing access for young people into skilled jobs through apprentice- annum. The results of the 1993 Census of Employment show ships has diminished. Thus the provision of childcare and training that the pace of decline had quickened since 1991 with a reduc- have a key part to play in facilitating the adjustment process. tion of 9,300 in the number of employees working in the Borough between 1991 and 1993 - an average annual rate of loss of 4,650. 7.2.13 A feature of planning for employment since 1987 has been the The 1995 Annual Employment Survey (changed from the previ- introduction of the Business Use Class (B1) bringing together ously mandatory census into a random survey), indicated a loss light industry, offices and research and development activities into of about 2,000 jobs since 1993. However, since 1995 the Annual one class for planning purposes (see Glossary). Subsequent Employment Survey (replaced by the Annual Business Inquiry in changes to the General Development Order resulted in transfers 1999) has shown that there has been a gradual growth in employ- of buildings and land from General Industry (B2) to the new ment with an overall increase of 17,500 in the number of employ- Business Use being allowed without the need for planning per- ees working in the Borough between 1995 and 2000. There is mission. The direct effect of these changes, therefore, is that thus a continuing need to maintain employment land levels in the general industrial premises in the Borough effectively have per- Borough to support this growth. mission for any use within the Business Use Class, including offices, although most buildings built for industrial purposes are unsuitable for conversion for office purposes. However, demand SUPPLY OF INDUSTRIAL LAND for such conversions is low and national and regional policy now allows for locational policies for purpose-built offices. 7.2.10 Changes in employment land within the Borough, comprising in total approximately 400 hectares (about 1,000 acres) have been BRENT'S ECONOMIC DEVELOPMENT STRATEGY assessed. The pattern that emerges mirrors that which is appar- - PARTNERS FOR PROSPERITY; ent from changes in employment levels. The amount of vacant land and premises in employment use increased by 22.7% 7.2.14 This strategy, agreed in 1995, is based upon a partnership between 1991 and 1996. However, a drop of 11.8 % in vacancies approach to regeneration (with TECs, adjoining boroughs and - from 69.2 ha in 1996 to 61 ha in 2000, demonstrates an increas- regeneration partnerships) - and was one of the first in the country ing uptake of premises. Whilst Brent's traditional manufacturing developed jointly with the local training and enterprise Council. It

Brent Unitary Development Plan - 2004 151 EMPLOYMENT

proposes projects across sectoral and geographic boundaries to Locations (Park Royal, Wembley Stadium, Staples Corner in maximise opportunities. It proposes a limited number of 'anchor' Brent) and Industrial Business Parks (Park Royal and East Lane). projects such as those relating to Wembley / the National Guidance sees the areas identified as strategic by LPAC as being Stadium, the North Circular Road and the creation of a high tech- those which should be promoted as destinations for major regen- nology business park. It aims to maximise the benefits arising erating investment with preference being given to retaining them from international connections via Heathrow Airport and the for employment uses. The Draft London Plan, June 2002, carries Channel Tunnel. these designations forward. According to RPG3, other sites may be safeguarded provided this can be justified on the basis of the contribution that the employment on or associated with these 7.3 STRATEGIC CONTEXT sites makes to the economy of the Borough and of London as a whole and there continues to be a prospect of productive use. 7.3.1 National guidance on planning policy, PPG1 (February 1997), suggests that a sustainable planning framework 'should include 7.3.5 The Economic Development Strategy for London Success provision for the nation's needs for industrial and commercial Through Diversity (July 2001) will guide the future strategy of the development'. PPG12 (December 1999) on development plans Mayor and the London Development Agency. It contains a char- stresses the legal requirement for plans to have regard to eco- ter for London which sets out four priority areas: economic nomic considerations. A range of sites is necessary to encourage growth; knowledge and learning; diversity, inclusion and renewal; industrial and commercial development. Plans may include prior- and sustainable development. ities for economic development. PPG13 (March 1994) on transport stresses the importance of opportunities for people to work 7.3.6 To aid economic growth the strategy has set the following role near their homes in order to reduce the need to travel. Travel and goals: intensive uses (such as offices) should be located in areas with good public transport accessibility. Distribution and warehousing • Supporting London's economic growth, both as a world busi- uses should have good access to the trunk road network and, ness centre and as a balanced regional economy; where possible, railheads or wharves. • Developing London's role as a world business centre and European business capital with multicultural diversity as one 7.3.2 PPG4 Industrial and Commercial Development and Small Firms, of its major strengths; (November 1992), states that development plans should contain • Ensuring London continues to support a broad range of eco- clear land use policies for different types of industrial and com- nomic activity; mercial development and have positive policies for small busi- • Encouraging competitiveness, creativity and enterprise, par- nesses. In particular, it stresses that there should be sufficient ticularly amongst small and medium sized enterprises; land available which is readily capable of development and well • Modernising London's infrastructure; served by infrastructure, with a variety of sites to meet needs • Creating new investment and land use opportunities for eco- (para 6). Some uses, such as residential, may be incompatible nomic growth; with some industrial activities, such as those which are potentially • Building on London's position as a world leader in the applica- polluting - whilst in other cases commercial development of an tion of information and communications technologies; and appropriate scale might be acceptable within residential areas. • Promoting and supporting the development of the social economy. 7.3.3 PPG12 (December 1999) Development Plans stresses the importance the Government gives towards promoting economic 7.3.7 The Strategy also identifies the challenge for London; “Jobs and competitiveness; “The aim is to create conditions in which busi- population in London have shown an overall pattern of growth ness can compete freely, develop and exploit new technologies since the 1980s and are forecast to continue to do so. However, and generate sustainable jobs.” (para 4.7). The guidance states this growth has not been matched by adequate investment in that Local Authorities should; “...look to provide a range of suit- infrastructure or public services. London is now experiencing crit- able sites in their plans for industrial and commercial develop- ical inadequacies and shortages - in transport, skills, housing and ment which take account of the needs of existing and future busi- business premises.” The strategy further states that “Alongside nesses.” (para 4.9). the global city lies another city: a city of suburbs and factories. Supporting the breadth of the London economy is not an alterna- 7.3.4 RPG9 (Regional Planning Guidance for the South East), March tive policy choice to building upon London's established strengths 2001, stresses the importance of allocating employment land but a complementary one.” In relation to Brent the strategy within an overall strategy for urban renaissance. RPG3 - specifically states that; “The continued renewal of Park Royal as a Strategic Planning Guidance for London Planning Authorities major business area, and the realisation of the opportunity that (May 1996), offers considerable support for the objectives that Wembley offers as a new regeneration focus in inner west underlie Brent's UDP policies - the promotion of development London, are also priorities.” suitable for B1, B2 and B8 uses. RPG3 strongly reflects the Government's concern to promote the revival of manufacturing in London. Unlike earlier guidance, RPG3 offers a geographical dimension to the planning of employment land in London. It endorses the identification by LPAC of Preferred Industrial

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7.5.2 In order to achieve an effective use of land in the Borough and to 7.4 POLICY OBJECTIVES minimise the conflict between employment uses and other land uses, especially residential use, the Council has developed a 7.4.1 In the light of the substantial changes affecting the local economy, strategy for the development and accommodation of industrial, and persistent high levels of unemployment among sections of business and warehousing uses. Although concern to maximise the Borough's population, the objectives underlying the Council's employment opportunities is a major consideration, there is also a planning policies towards economic activities and employment in need to ensure a balanced land-use mix for the Borough, so as to the Borough are as follows: minimise the need to travel, to widen the range of employment opportunities in the Borough, to ensure that jobs are not lost else- 1. To maintain existing employment-generating activities in the where and to make the Borough's economy robust to changes in Borough and allow for their expansion by promoting the mod- the economic cycle. Therefore, comparing employment levels of ernisation and regeneration of the industrial infrastructure and an existing and a proposed development is not always looking at upgrading the environment throughout the Borough's employ- the full picture. ment areas; 2. To sustain a wide range of employment opportunities in the 7.5.3 The Council has designated Strategic Employment Areas Borough by attracting new employment uses, particularly in (SEAs), corresponding to the areas identified within RPG3 the growing innovative / creative industries, and encourage (Strategic Planning Guidance for London Planning Authorities, the establishment of small businesses through maintaining a May 1996) which are best suited to long-term retention in industri- stock of sites at a variety of sizes and enabling the provision al and related uses and appropriate for major development and of a wide range of suitable premises; redevelopment to suit the requirements of modern industry, in 3. To ensure that employment premises are accessible to the terms of accessibility to the Strategic Road Network, size, etc. By whole community by a choice of travel modes, and reduce directing industrial activities to these areas, the Council is able to the traffic impact of new employment development, particular- ensure that industrial and related uses are accommodated satis- ly by car; factorily whilst protecting residential areas from the environmental 4. To ensure that where alternative uses are proposed for those and traffic impact of their activities. employment sites that are not suited to retention in employment use, or where it is considered that the site is no longer 7.5.4 The remaining main estates / areas with good access to the required for employment use such as redundant or obsolete London Distributor Road Network are classified as Borough purpose-built offices, new uses are in accordance with the pri- Employment Areas (BEAs). The different classification of sites orities of the plan; does not primarily represent a hierarchy of importance. Rather 5. To tackle persistent unemployment in the Borough by this planning framework represents the different catchment area increasing skills training for local people through opportunities functions. Whilst strategic areas are important for the whole of provided by development, and facilitate local opportunities for London, Borough areas are those important to Brent. They are self-employment. smaller estates which, although less well connected to the Strategic Road Network, mostly have good roads links and are 7.4.2 In striving to secure these objectives, the Council recognises the often better connected to the residential areas which may provide importance of an attractive environment and of the provision of their workforce. training and childcare in generating new employment and maintaining existing jobs in the Borough. 7.5.5 Whilst the Strategic Employment Areas and Borough Employment Areas will continue to be the focus for major industri- 7.4.3 These aims will be furthered not only by the policies in this Plan al activities, a number of other locations (Local Employment Sites but through the promotion, training and premises management - LESs) throughout the Borough are in industrial and other forms and development activities set out in the Council's Economic of employment use providing valuable local employment opportu- Development Plan. nities. These are all smaller sites in B1/B2, B8 or other employment use, and are not specifically identified on the proposals map as this classification depends on the lawful use of the site. The 7.5 BOROUGH STRATEGY total area of land covered by such designations, other than very small sites of less than 0.15 Ha [1/2 an acre] is estimated at 7.5.1 The Council's strategy is one of achieving sustainable economic approximately 418Ha. Additionally, the Council has identified a development - as part of the overall sustainable development number of other locations as being suitable for purpose-built strategy of the plan. Above all this means making best use of the office accommodation. existing resources of the Borough, its locational links which can reduce the need to travel and attract investment, and the skills and abilities of its workforce. It also means creating sustainable employment that is genuinely available to local people including those suffering from social exclusion.

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INWARD INVESTMENT AND EXISTING POLICIES AND OCCUPIERS PROPOSALS 7.6.3 Where proposals relate to accommodation for named industrial occupiers, including the expansion plans of local firms, in order to 7.6 GENERAL support their employment activities, the Council will make every 7.6.1 The Council's policies towards industry, business and warehous- effort to accommodate their needs, including ancillary office ing developments in the Borough are designed to achieve its floorspace, provided that they are compatible with the remainder objectives of making the Borough an attractive place for workers of the employment area. and employers alike and of widening access among Borough residents to job opportunities in the Borough. The policies aim to encourage regeneration of the borough's main employment areas EMP1 NAMED OCCUPIERS & EXISTING for existing industrial and quasi-industrial activities and to attract EMPLOYERS new employment in the industrial, business and office sectors by ensuring that a wide range of different types of premises are Special consideration will be given to the particular available. floorspace and design requirements of named industrial occupiers and of existing employers. 7.6.2 Generally a high standard of design, layout and appearance will be required. Sustaining a pleasant environment will also be promoted by the provision of adequate facilities for the disposal and SMALL AND MEDIUM SIZED ENTERPRISES recycling of waste and through landscaping schemes that provide for a continuing programme of maintenance. To ensure the avail- 7.6.4 Small and medium sized enterprises (SMEs) have been the ability of premises to meet the needs of a wide range of occu- major source of employment growth in most western economies piers, including small businesses, developments should include in recent years. It is important that these have access to smaller varying sizes of units. The Building Regulations ensure disabled properties (including small office suites) and are able to expand. access to new buildings. Policy W8 (Criterion A) seeks to ensure the provision of adequate space for waste and recycling in development. Further, in order to help make jobs created in the EMP2 SMALL AND MEDIUM SIZED Borough available to local residents, the Council will seek to ENTERPRISES negotiate agreements with developers / employers to provide floorspace for training and childcare. Such facilities can help to Proposals to expand small and medium sized enter- minimise the extent to which new development adds to existing prises will generally be permitted where development commuting levels. All proposals for employment developments proposals would not result in loss of residential ameni- will also be considered in the light of other policies in the Plan, ty or residential units. especially those relating to environmental quality, to the protection of green spaces and waterways, and to nature conservation. In considering applications for employment development, the CHILDCARE FACILITIES IN EMPLOYMENT Council will have regard to its guidelines on the design of employ- DEVELOPMENTS ment developments, for the provision of childcare floorspace within them and on access for disabled people (SPG12, 14 and 18). 7.6.5 Rising female participation in the workforce, as well as rising numbers of male lone parents, has created an increased need for the provision of childcare facilities at places of work. This can help 'welfare to work' and a number of other national objectives. SPG14 gives special design guidance on this topic.

EMP3 CHILDCARE FACILITIES IN EMPLOYMENT DEVELOPMENTS

In large schemes with significant employment levels (normally over 5,000 m2) the scope for the provision of childcare facilities will be explored through the use of planning obligations.

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ACCESS TO EMPLOYMENT OPPORTUNITIES 7.7.2 The Strategic and Borough Employment Areas consist of coherent areas of land which are, in terms of environment, road 7.6.6 Many local firms and large retailing developments in the Borough, access, location, parking and operating conditions well suited for have not been taking advantage of under-utilised sectors of the retention in employment use. Taking into account the reduced labour market whilst at the same time there are significant num- site coverage and employment density that usually accompanies bers of young people who are unemployed and / or have low lev- redevelopment, the defined Strategic and Borough Employment els of achievement. Also there are high levels of unemployment Areas are considered to include the minimum amount of land amongst ethic minorities and other disadvantaged groups (includ- required to accommodate industrial and related uses. The ing from discrimination) and concentrations in low-skilled manual Council will regularly review the supply of and demand for such and part-time work. Brent is working in partnership with the North land uses. This information will be used to inform any alterations West London TEC and training providers to improve local skills to the boundaries of the designated employment areas through and employment opportunities and to develop a Boroughwide the UDP Review process.

7.7.3 The Council's policies towards development in Strategic and Borough Employment Areas generally provide for unrestricted B1 development in Business Zones and, elsewhere in these areas, schemes designed to accommodate general industry and warehousing uses. The design of schemes for general industrial purposes will also provide for occupation by light industrial uses (B1(c)). Other industrial-type uses are also provided for through Policy EMP13 and, in Strategic Employment Areas, complementary facilities for employees are encouraged through Policy EMP6. Proposals to redevelop sites which are already occupied by uses not normally permitted under the policies of this Chapter will be expected to comply with the policies of this chapter. Exceptions may be made, however, to permit the re-establishment of existing uses. local employment action project (LEAP). These projects can also reduce the need to travel and therefore the environmental prob- 7.7.4 Parts of the Strategic and Borough Employment Areas have lems of car-based commuting. already been redeveloped and now provide an appropriate operating environment for present day industry. It is important that this investment is safeguarded by the complementary modernisation EMP4 ACCESS TO EMPLOYMENT of the older parts of these areas and by protecting them from the OPPORTUNITIES further intrusion of other uses which could cause operating conflicts with industrial activities. The Council will seek the provision of training, associated facilities and information on vacancies in large schemes where this would assist in reducing social STRATEGIC EMPLOYMENT AREAS exclusion or traffic reduction. 7.7.5 Of the areas that are best suited to retention in industrial use, four of them have significance to London as a whole and, as indicated in paragraph 7.7.1, are recognised in Strategic Planning Guidance for London as Preferred Industrial Locations and/or 7.7 EMPLOYMENT AREA PLANNING Business Parks. Three of these areas benefit from direct access FRAMEWORK to the North Circular Road. It is within these areas that regeneration and major infrastructural funding should be focused with 7.7.1 Brent has a variety of industrial areas ranging in size and impor- SRB funding for Park Royal and Wembley Park already providing tance from the largest estates with strategic significance, e.g. substantial infrastructural and environmental improvements. Park Royal, other areas which make a major contribution to employment provision and the local economy but which may not be as well placed strategically, down to small sites whose importance is in providing local employment opportunities. These areas are categorised as either Strategic or Borough Employment areas or Local Employment Sites. There are major differences between the North and particularly the South-West of the Borough which have major sites, and the South-East which has scattered smaller sites in residential areas. The framework is designed to take account and manage the issues arising from this.

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EMP5 DESIGNATION OF STRATEGIC EMPLOYMENT AREAS BOROUGH EMPLOYMENT AREAS

The following areas have been designated as Strategic 7.7.7 As well as the Strategic Employment Areas several other areas Employment Areas and are defined on the Proposals are also considered well suited to retention in industrial use Map: because they are cohesive areas which benefit from good, direct access from main roads and are generally capable of accommo- Park Royal (including Beresford and Abbeydale Estates, and the part of Hythe Road area in Brent) dating industrial uses, including bad-neighbour uses, without significant adverse impact on residential amenity. Wembley Stadium/Neasden

Staples Corner 7.7.8 Whilst the Strategic and Borough Employment Areas will continue to be the focus for major industrial activities, many other locations East Lane (Local Employment Sites) throughout the Borough are in Employment area regeneration funding will be focused industrial and other forms of employment use providing valuable in these areas for the purposes of: local employment opportunities. Additionally, the Council has identified a number of other locations as being suitable for (a) Improving their infrastructure, environment and operating conditions; purpose-built office accommodation. Elsewhere in the Borough, proposals for employment developments will be considered in the (b) Providing suitable land and premises to attract new light of their likely environmental impact and of other policies in enterprises to the borough; and the Plan, particularly Policies H8 and H28 in Chapter 5. (c) Providing suitable land and premises to relocate employment uses from elsewhere in the Borough. EMP7 BOROUGH EMPLOYMENT AREAS

The following areas have been designated as Borough FACILITIES FOR EMPLOYEES IN STRATEGIC EMPLOYMENT AREAS Employment Areas and are defined on the Proposals Map: 7.7.6 The Council recognises that, in order for the Borough's Strategic Alperton Employment Areas to be attractive places to work, they need to be accessible to facilities for employees - convenience shopping, Brentfield Road lunch-time and small-scale leisure facilities. In smaller Borough Church End Employment Areas, for example at Colindale, shopping facilities Colindale are generally available in close proximity. However, the Strategic Employment Areas are less well-served, and it may be neces- Cricklewood sary to permit the development of small-scale eating, shopping Honeypot Lane North and leisure uses as an exception to the Council's normal policies restricting development in such areas to industry, warehousing Honeypot Lane South and business uses. Kingsbury

Neasden Lane

EMP6 EMPLOYEE FACILITIES IN STRATEGIC EMPLOYMENT AREAS

Small-Scale Leisure, Eating and Shopping Facilities THE PROTECTION OF STRATEGIC AND (generally less than 200m2 gross) will be considered BOROUGH EMPLOYMENT AREAS as an exception to the plan’s normal policies applying within Strategic Employment Areas, subject to the fol- 7.7.9 The Strategic and Borough Employment Areas have two general lowing: purposes. The first purpose is to maintain the economic base of the Borough by creating a climate of certainty that these areas will (a) The facility is intended primarily to meet the needs of workers in the vicinity; and continue to provide a good environment for industry, business and warehousing uses. Without that certainty, industrial and (b) It does not attract significant levels of visitor traffic related investment would sometimes be deterred, or deflected into the area, or exacerbate existing traffic condi- elsewhere in the Borough. The second related purpose therefore tions. is to prevent a type of 'planning inversion' whereby, on the one The loss of such facilities will be resisted where this hand, land in the Strategic & Borough Employment Areas is rede- would lead to a deficiency of employee facilities within veloped for uses such as housing, retailing and pure office devel- a Strategic Employment Area.

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opment for which there are better locations in the Borough and, sites and consequently, they have not been defined on the on the other hand, industrial activities are accommodated in Proposals Map. As the policy applies to sites in employment use, unsatisfactory, predominantly residential locations elsewhere. once developed, the policy no longer applies. Hassop Road area, Local Employment Site is the subject of a separate Policy 7.7.10 The need to protect land in these Employment Areas from the (EMP23) in Section 7.9 of this Chapter and is defined on the harmful effects of 'hope value' that are associated with the Proposals Map. prospect of development for higher value uses is not the only reason for resisting that type of development. The Council also has 7.7.13 In recent years a number of these sites have come under intense to consider that, for example, allowing large retail development in pressure for redevelopment for alternative uses, mainly new retail them can have harmful practical effects, such as the introduction development and housing, and substantial amounts of land have of customer traffic that can lead to operating difficulties for indus- been released to such uses. In some cases, proposals for trial occupiers. And permitting new housing development can alternative uses have been advanced while employment uses lead to pressure to curtail industrial uses in the vicinity: PPG4, remain in occupation, causing considerable uncertainty and dis- which sets out Government guidance on 'Industrial and ruption to the employers and workforce involved. Commercial Development and Small Firms', warns local authorities to guard against this possibility. Where there are exist- 7.7.14 In order to maintain local job opportunities dispersed throughout ing non-employment uses in these employment areas, applica- the Borough, which can mean less travel to workplaces, it is con- tions to extend or redevelop them on the original site will be considered necessary to retain Local Employment Sites for employ- sidered against the appropriate locational policies of the plan (e.g. ment use where this remains a viable and desirable option i.e. SH3). where demand for them exists and they are not adversely affecting residential amenity. This means ensuring that proposals for 7.7.11 UDP Policy for the Strategic & Borough Employment Areas effec- alternative development do not directly lead to the dislocation of tively reserves land for industry, warehousing and related uses existing industrial and business activities unless they are ade- and, in Business Zones, for mixed B1 developments. Some pro- quately relocated locally. These sites can be especially important vision is made for services and shops for workers and businesses in providing the types of premises suitable for small firms and for in Strategic Employment Areas but not to the extent that extra new enterprises, including those established by people from eth- traffic is drawn into the area or that more land than necessary is nic minority communities in the Borough. lost to 'employment' uses. 7.7.15 Generally the Council will encourage the continued occupation of Local Employment Sites by employment-generating uses, either EMP8 PROTECTION OF STRATEGIC AND through the continuation of existing uses or through redevelop- BOROUGH EMPLOYMENT AREAS ment for new industry, business or warehousing activities. However, where an employment use causes severe disturbance In the Strategic and Borough Employment Areas the in relation to surrounding residential uses it may be appropriate following employment uses will be permitted: for the use to be extinguished (see Policy EMP13). Where such intrusive uses need to be removed, it may nevertheless still be a) Industry (Class B2); possible for the site to be redeveloped to accommodate employment uses that have an acceptable impact on the local environ- b) Warehousing (Class B8), subject to the requirement. In permitting new employment uses on existing sites within ments of Policies EMP14 and EMP15; and residential areas, careful consideration will be given to the effect c) Closely related uses not falling within a use class of the proposal on neighbours. Policy H28 in Chapter 5 precludes but which are commonly found on industrial the establishment of new incompatible uses in residential areas. estates(such as haulage yards, bus garages and Conditions such as those limiting the hours of operation and, on MOT testing stations). traffic generation grounds, restricting the uses within the B1 Use Proposals for other uses, or for the expansion of exist- Class may need to be imposed and environmental improvements ing uses not falling within the above categories, will ensured. not be permitted where they would result in a loss of land in employment use. 7.7.16 Some Local Employment Sites, by virtue of their siting, size or access, may be unsuitable for redevelopment to meet modern standards for employment uses. Where this is the case, alternative uses in accordance with Policy EMP9 (a) and (b) will be per- LOCAL EMPLOYMENT SITES mitted if it can be shown that there is no effective demand for the existing premises for industry, business or warehousing use, and 7.7.12 Outside the Strategic and Borough Employment Areas, there are there is no reasonable prospect in the medium term of re-use. a number of other sites which provide, or are capable of Lack of effective demand will normally be demonstrated by, for providing, local employment opportunities. These sites include example, the vacancy of comparable land or premises in the those on the fringes of S.E.A.s and B.E.A.s, scattered large sites vicinity or by the lack of success in finding an occupier after vigor- and a considerable number of smaller sites dispersed throughout the Borough including its residential areas. There are many such

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ous marketing efforts. The vacancy of the premises for at least two years despite marketing efforts would generally be seen as EMP10 THE ENVIRONMENTAL IMPACT OF confirming a lack of effective demand. EMPLOYMENT DEVELOPMENT

Development within employment areas / sites should EMP9 DEVELOPMENT OF LOCAL EMPLOYMENT not have an unacceptable environmental impact on SITES other employment uses and any nearby residential properties in terms of appearance, noise, dust, pollu- Development of Local Employment Sites for uses other tion, hours of use, access and servicing. Conditions than those employment uses identified in paragraph may be imposed concerning such matters as insula- 7.1.1 will not be permitted except where:- tion, hours of use, etc. to minimise the environmental impact. Where development is proposed that has a (a) Unacceptable environmental problems are or, would be, associated with the use of the site for sensitive boundary with residential property then employment use (as defined in para. 7.1.1). The buildings designed solely for Research & Development Council will identify sites where alternative uses / light industrial (B1b & B1c uses) will be permitted. would be appropriate; or B1 development of a domestic scale is acceptable (b) There is no effective demand for the premises and within residential areas - subject to satisfactory trans- there is no reasonable prospect in the medium term of re-use, or redevelopment to modern standards port impact & accessibility and no loss of residential for B1, B2 or B8 uses of an environmentally appro- property. priate kind. General industry (B2), or distribution & warehousing Where either (a) or (b) apply, alternative uses will (B8) will not be permitted within residential areas. normally be expected to provide housing, including where required by policy a substantial element of affordable housing, and / or accommodation for com- THE ENVIRONMENTAL IMPACT OF munity groups and / or, in local open space deficiency EMPLOYMENT DEVELOPMENT areas (see map OS1 in chapter 10), new open space. 7.7.19 As regeneration has proceeded apace within the Borough many Where a site is in or adjacent to a town or district cen- areas perceived as 'dirty' industrial estates have recast them- tre, and contributes to regeneration, then uses for selves as modern business / industrial areas. This has required a which the sequential approach (policy STR2) applies careful balance, however, between traditional industrial activities, will also be permitted, providing it accords with the waste uses and car repairs on the one hand, and modern light relevant policies elsewhere in the plan. Development industrial and business premises on the other. Whilst Strategic proposals on sites adjacent to District Centres should and Borough Employment areas will be the most suitable loca- be appropriately sized so that they are consistent with tions for uses harmful to residential amenity it is also important to the scale and function of the centre. have regard to the impact of development on other employment uses. The character of the particular part of the employment area is crucial. Some are suitable for 'bad-neighbour' uses, whilst other parts, particularly 'Business Zones', may not be.

7.7.17 In order to offset the loss to the community of the employment 7.7.20 In the case of car servicing (as distinct from major repairs), spe- potential of Local Employment Sites, development in the circum- cial problems can arise. Firstly, the servicing activities them- stances indicated in Policy EMP9 should normally provide for selves can generate significant levels of private car traffic. housing including affordable housing. Other uses which may be Secondly, the servicing activities are often associated with car appropriate are community facilities and open space. In some sales (which is a separate sui-generic use class), an activity accessible locations, however, Local Employment Sites can pro- which on its own is more suitably located on the fringes of shop- vide a useful means of accommodating demand for new shopping areas (see the special policy contained in the Town Centres ping facilities that does not conflict with the Council's shopping and Shopping chapter). In considering applications for such uses policies, for example adjacent to town centres. in employment areas, the Council will need to have special regard to the balance between repairs and sales (so that the sales are 7.7.18 As a general rule, the Council will positively identify sites for alter- ancillary to the employment use) and the use is located in a way native uses only after they have become vacant, and it is evident that is compatible with the functioning of the area as an employ- that the site is no longer appropriate for employment purposes. In ment area. Conditions will be used to maintain a minimum pro- such circumstances the Council will prepare Planning Briefs for portion of car repair floor space. their redevelopment. Exceptionally, in open space deficiency areas the Council will identify sites that are suitable for the cre- 7.7.21 Despite the benefits of mixed-uses there will still be some uses, ation of new open space in advance of their vacation by employ- especially those falling within the B2 general industry use class, ment uses. that are best sited away from residential areas. In this way resi-

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dential amenity can be protected and it can be ensured that the BAD-NEIGHBOUR USES operations of business are not prejudiced by the operation of environmental health controls. Non-residential developments 7.7.24 Because Strategic and Borough Employment Areas provide loca- adjoining residential gardens are covered by SPG17. tions where the disruptive effects of industrial activities on residential areas can be minimised, they are the only locations in the Borough where potentially polluting industrial activities are likely to be environmentally acceptable (see policies EP4 and EP5 in Chapter 4). They can also offer the most suitable locations for a wide range of quasi-industrial activities such as open yard uses and car repairs. Car repairs that involve environmentally-disruptive activities such as panel beating and paint spraying can most satisfactorily be located in Strategic and Borough Employment Areas. REGENERATION OF EMPLOYMENT AREAS 7.7.25 Considerable problems are often encountered in accommodating 7.7.22 Although a lot of progress has been made in modernising Brent's open yard uses, such as those connected with the building and industrial estates, particularly in Park Royal which has benefited waste recycling trades. These uses generally have an adverse from the promotion of renewal by Park Royal Partnership and the impact on the amenity of neighbouring occupiers. Where overall regeneration funding provided by Harlesden City Challenge, the planning benefits can be achieved, such as securing the removal Single Regeneration Budget (SRB) and Assisted Area status, and of such uses from sites where they cause severe disturbance, the in the Wembley Stadium estate where the SRB is funding infras- Council will consider assembling sites in suitable locations to tructural and environmental improvements, there are neverthe- accommodate these uses. In identifying sites particular attention less still many areas which display problems of inadequate infras- will be paid to compatibility with neighbouring uses. tructure and structural obsolescence. In order to continue tackling these problems the Council will continue to promote and encourage renewal, particularly in the Strategic Employment EMP13 BAD-NEIGHBOUR USES Areas, by bidding for funds as well as undertaking improvements directly when resources permit. This should in turn encourage Applications in Strategic and Borough Employment private investment and confidence in the main employment Areas for quasi-industrial uses such as open yard and areas. car servicing will be considered in relation to their impact on neighbouring uses and on the functioning of the area as a general industrial area. EMP11 REGENERATION OF EMPLOYMENT AREAS Opportunities and resources will be identified to provide sites for the accommodation of open yard uses In Strategic and Borough Employment Areas redevel- where significant planning benefits can be achieved opment for industry and warehousing will be encour- through their removal from inappropriate locations. aged and development that contributes to improved access and appearance is supported.

7.7.23 The regeneration of employment areas has and will be consider- 7.8 TYPES OF EMPLOYMENT ably assisted by the co-ordination of improvements to the public DEVELOPMENT realm to improve the image of these areas. This will also require high standards of design and landscaping and the prevention of BUSINESS (B1) DEVELOPMENTS intrusive advertising. 7.8.1 Business developments can provide for a variety of types of employment use. In order to comply with the Government's EMP12 PUBLIC REALM ENHANCEMENT IN Strategic Guidance, the Council will generally require develop- EMPLOYMENT AREAS ments to be designed so as to be capable of accommodating the full range of uses covered by the Business Use Class. The There should be an integrated approach to advertise- Council publishes Supplementary Planning Guidance SPG18 on ments, landscaping, street furniture, public art, light- Employment Developments including guidelines for the flexible ing and signage in employment areas. Subject to design of Business development. In Town Centres, however, the resources, enhancement schemes for these features attraction of additional large vehicles associated with an industrial will be carried out. Proposals should neither detract use would be detrimental to the functioning of the town centre. In from the achievement of such schemes nor reduce the these circumstances, proposals designed to accommodate office benefits which could be gained. uses only will be acceptable.

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7.8.2 Not all parts of Strategic and Borough Employment Areas have sibility, particularly by public transport. Policy EMP15 sets out the good public transport access. The Council is working to improve scale of development considered appropriate in different parts of public transport in the Borough especially to areas where employ- the Borough. These policies apply both to stand-alone office ment uses are concentrated, but until those improvements are developments and to the office component of mixed schemes. secured the Council regards only certain locations as being suitable for Business Use developments, with their higher 7.8.5 The Wembley Park Area, having good public transport accessibil- employment densities. It is also important that the servicing of ity, has long been regarded by the Council as the most suitable general industrial activities is protected as far as possible from the location for major office development. Public transport improve- higher private car traffic generation associated with developments ments associated with the regeneration of the area, particularly accommodating all the uses within the Business Use Class. the public transport improvements associated with the develop- Accordingly the Council has identified Business Zones within its ment of the new National Stadium, will enhance the accessibility Strategic and Borough Employment Areas for the accommoda- of the area. Additionally, it is considered that, among the tion of Business uses. The location of these Business Zones are Borough's town centres, only Wembley is capable of accommo- shown on the main Proposals Map. The location and extent of dating major office development. With improvements to public these Business Zones will be reviewed from time to time as signif- transport, the Northern, Western, and Eastern (around Willesden icant changes in public transport accessibility occur. (See also Junction Hub see policy TRN6) gateways to Park Royal are also Policies in Part I of this Plan and section 6.7 of the Transport considered to be suitable major purpose-built office locations. chapter.) 7.8.6 Many of the remainder of the Borough's town centres can also 7.8.3 New developments designed for Business Use purposes will provide an appropriate environment for office employment. It is in generally be considered appropriate outside Business Zones only these town centres that shopping and lunch-time facilities are in two circumstances: firstly, if the scheme as a whole helps to available for office workers. Moreover the Borough's town cen- eliminate deficiencies in the public transport infrastructure, tres are relatively well-placed with respect to public transport ser- whether in local access to the public transport system or more vices. Providing that the scale of the accommodation is in keep- general deficiencies in the area, sufficient to upgrade public trans- ing with the town centre, new office developments can also assist port accessibility to the required degree. This could for example in the regeneration of the centre not only through physical include the introduction of a new bus service in association with a improvements in the appearance of the centre but also by bring- proposed business development. Alternatively, business uses ing additional weekday trade to the shops and services there. could be permitted at a location where a new rail station, for The Council will encourage, through agreement, the availability of example, was to be constructed. The second circumstance in office car parks for public use outside office hours (see policy which developments designed for Business Use purposes will be TRN25). In considering applications for office development in considered appropriate outside Business Zones is where the these locations, regard will be had to the way in which the pro- proposal concerns a sensitive site on the boundary of a S.E.A. or posed development complements the role of the town centres B.E.A., where general industrial development would have an and contributes to their modernisation and regeneration. adverse impact on residential neighbours. As indicated in para. 7.7.3, exceptions to policies may be made to permit the re-establishment of existing uses. Special consideration will be given to EMP15 LOCATION OF B1 BUSINESS proposals for redevelopment for B1 purposes of premises in DEVELOPMENT existing Business use. I] Purpose-built commercial and public office developments attracting a lot of people will be directed to EMP14 DESIGN OF BUSINESS DEVELOPMENTS sites in or adjoining town or district centres, subject to the proposal being of a suitable scale and Except where Purpose-Built Offices are permitted, character for the centre. proposals for Business Uses (B1) should, where possi- In addition, major purpose-built commercial and ble, be designed flexibly so as to provide for industrial public office developments will be permitted in the as well as other uses within the Business Use Class in National Stadium Policy Area (see Wembley accordance with the plan's standards with respect to Regeneration Area chapter) and the Park Royal Parking and Servicing (Appendix TRN2). Gateways (subject to policies in the Park Royal Inset Plan on improving public transport).

II] Proposals in Strategic and Borough Employment Areas predominantly of development designed PURPOSE-BUILT OFFICE ACCOMMODATION solely for those types of B1 (business) use not cov- 7.8.4 With the introduction of the new Business Class, an increasing ered by I], will be directed to the business zones amount of office accommodation is provided in multi-purpose shown on the proposals map, or in other locations business units: nevertheless proposals for purpose-built accom- where substantial improvements to the public modation continue to come forward. The Council wishes to transport accessibility of the site is secured, or where policy EMP10 applies. encourage such developments but also to ensure that their scale is compatible with their surroundings and with the level of acces-

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BUSINESS PARKS AND TECHNOLOGY PARKS local institutions. The industrial area immediately to the east of the proposed National Stadium, is a possible suitable site. Park 7.8.8 London only had three business parks (with permission for a Royal has a number of major sites with potentially good public fourth) and four technology parks in 2000 - in comparison to other transport links. Each of these areas meet the criteria for LPAC’s major cities this is a significant underprovision. They generally ‘Business Parks in an Urban Setting’. represent high quality environments of modern purpose-built premises in a landscaped setting. Where proposed as technolo- ALTERNATIVE USE OF REDUNDANT OFFICES gy parks they can be attractive to high technology firms such as those in computing, biotechnology, electronics and the media, 7.8.10 Recent years have seen an oversupply of offices across London often with technology transfer links to academic and / or research and for much of the vacant space there is little current demand for institutions. PPG 12 stresses the importance of these ‘knowledge its re-occupation as offices and there is unlikely to be any in the clusters’ in securing international competitiveness. Some smaller foreseeable future with potential office occupiers generally prefer- scale parks can be attractive for incubator units; others offer ring new purpose-built accommodation. This is a particular prob- space which can maintain expanding firms within London, whilst lem in Brent with the Borough's main office location, i.e. Wembley others can be especially attractive for inward investment purpos- Park, having experienced a very high vacancy rate (about 37,000 es for UK headquarters. The former London Planning Advisory m2 estimated to be vacant in the Wembley area alone in 1997). Committee proposed 'Business Parks in an Urban Setting' to help In such circumstances it is appropriate to allow the conversion or counter the attractiveness of Business Parks in the South East redevelopment of redundant office buildings to other uses and, in outside London. particular housing because of the overriding need identified. However, not all former office buildings in the Borough are suitable for conversion or redevelopment as residential accommoda- EMP16 BUSINESS PARKS AND / OR tion, particularly those in Strategic & Borough Employment Areas. TECHNOLOGY PARKS Other appropriate alternative uses, depending on the level of public transport accessibility, include hotels and educational use. Business Parks and / or Technology Parks will be permitted in the following locations (subject to any specific policies in the Plan): EMP17 REUSE OF REDUNDANT OFFICES

Park Royal Gateways (policies PR5 & PR6), and Central Middlesex Hospital (proposed science park, Outside Strategic & Borough Employment Areas, appli- policy PR7); cations for the re-use or redevelopment of redundant purpose-built office buildings for appropriate alterna- Wembley Stadium Business Park (policy WEM6). tive use will be permitted. A more flexible approach Development will be subject to the public transport towards development standards will be applied, sub- improvements set down in the specific policies being ject to maintenance of an acceptable residential envi- secured. ronment. Appropriate alternative uses will include:

Residential use (incl. student / worker hostels) where an acceptable residential environment (see policy H18) can be provided;

Hotels where they accord with locational policies TEA6 or TEA7 and WEM3; and

Education use, where the site has Very Good or Good Public Transport Accessibility.

GENERAL INDUSTRY

7.8.11 As noted earlier, the Strategic and Borough Employment Areas are best suited to the long-term retention of industry. As well as 7.8.9 Strategic Guidance and LPAC advice both recognise the potential providing an environment suited to the operational needs of and importance of this sector. Brent has particular potential to industry itself, these areas have been defined on the basis that make provision in that: their location minimises any adverse impact on residential areas. They are thus the areas in the Borough where circumstances are • there are good transport links to Heathrow airport and Central appropriate to provide good quality sites for general industry in London; and accordance with Strategic Guidance. In a limited number of • suitably located land is available. instances, however, the boundary between the employment area and residential areas may be a sensitive one: in these circum- A number of major sites have been identified in the inset plans, in stances it may be necessary to restrict development to light addition there will be a need to secure the Research and industrial uses (see Policy EMP10). Development Function (B1b) and technology transfer links to

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7.8.12 Conformity with the Council's standards and guidelines for gener- CREATIVE INDUSTRIES al industrial development will ensure that, in speculative proposals, good quality space is provided that has the flexibility to 7.8.15 Recent forecasts suggest that employment in creative industries accommodate a wide range of potential industrial occupiers, may increase by 10,000 workers in the decade up to 2007 (LBB including small businesses and light industrial uses (B1(c)). (The Employment Land Demand Study, December 2001). These Council's guidelines on industrial development are set out in industries include audio-visual (film, TV, music), printing & pub- Supplementary Planning Guidance, SPG18.) lishing, advertising, design, visual arts, crafts and the performing arts. These have been a major source of small business growth and, being a highly innovative sector, has led to London being EMP18 GENERAL INDUSTRIAL DEVELOPMENTS seen as at the 'cutting edge' in a number of fields. This has multi- plier effects in other industries such as tourism. However, start up In Strategic and Borough Employment Areas, outside businesses require the provision of cheap, small-scale premises, Business Zones, new developments should be but they can often be out-bid by higher value activities. designed to be suitable for general industry (B2) except where development accords with policy EMP22. Servicing arrangements will normally be EMP20 CREATIVE INDUSTRY PROPOSALS required to conform to the plan’s standards for general industrial development (Appendix TRN2). Favourable consideration will be given to proposals for the creation of new low cost production facilities for the Creative Industries - including the temporary use of vacant space. WAREHOUSING

7.8.13 In recognition of the inter-relationship between industry and warehousing (storage and distribution) and the need to ensure flexibility in employment developments, the Council encourages schemes designed so as to accommodate both industry and warehousing and requires that flexibility in units of less than 2,500 sq.m. (27,000 sq.ft). The extra heavy traffic generated by major distribution warehousing developments can, however, be an unwelcome addition to the levels of traffic on an already congested road network. Proposals for very large warehouses (over 10,000 sq m) are most likely to be acceptable in the Neasden Strategic Employment Area and that part of the Park Royal Strategic Employment Area adjoining Abbey Road and to the north of the canal. This is because such schemes are likely to WORK-LIVE DEVELOPMENT generate substantial movements of large articulated lorries and these areas have immediate access to the strategic road net- 7.8.16 Work-live accommodation is the provision of integrated working work. The Neasden SEA has the added advantage of rail access. and living accommodation within a single self-contained unit. Elsewhere, the environmental impact of warehousing develop- This form of accommodation can provide a means for new busi- ment will need to be carefully assessed. ness to establish itself by reducing costs as well as providing accommodation for a wider range of uses embracing the full 7.8.14 The overall extent of warehousing development will be kept under range of B1 (business and light industrial) uses and contribute to review to ensure that the Strategic and Borough Employment regeneration by bringing derelict sites and buildings into use. Areas continue to provide adequate space and an appropriate They can also significantly reduce the need to travel. They have operating environment for industrial activities and, in Business proved to be popular elsewhere in London with the new 'creative' Zones, for Business uses. industries and there has been substantial interest in developing work-live units in Brent. Work-live units are subject to Policy H2.

EMP19 WAREHOUSE DEVELOPMENTS 7.8.17 Work-live units are what is known as a 'composite' B1 (business) and C3 (dwelling) use. Being a composite use there would nor- Proposals for the development of warehouses of over mally be 'permitted development' rights to change to solely one 2,500 sq m will be permitted in Strategic Employment use or the other; these rights will have to be removed by condi- Areas and Borough Employment Areas, subject to an tion, as would other residential permitted development rights, to acceptable environmental and transport impact, par- prevent the loss of the employment element. In order to ensure ticularly in terms of traffic generation and having good that the Plan’s strategic aim of protecting employment land is not access to the strategic road network. This Policy will compromised, proposals on existing or former employment sites also apply to proposals for extensions or changes of will be required to demonstrate that the residential element will be use which would result in a warehouse of over 2,500 subsidiary to the work element. An indicative ratio of 70:30 in sq m. favour of the work element will be sought.

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7.8.22 Conditions may be imposed to ensure that the homeworking ele- EMP21 WORK-LIVE DEVELOPMENT ment is used only by those who live in the residential unit. Any permission granted would be for a limited period only, in order that Proposals for work-live development (composite B1 / the Council may retain the power to require the employment use C3 uses) will be permitted where environmental to cease, if nuisance is caused. The Council may also impose a impact is acceptable, including on Local Employment condition limiting the employment use to a single stipulated use, Sites. The work areas must be of a design and suffi- in order that the character of the use permitted does not change cient size, and have adequate floor loading, to take the without its prior and express consent, and may consider making full range of B1 uses, including light industry, as well the permission personal to a named person or persons, where it as having separate servicing. feels these safeguards to be necessary.

Where development takes place on an existing or for- 7.8.23 This policy does not however, aim to restrict residents' permitted mer employment site, the residential element should development rights to carry on their own trade or profession from be subsidiary to the work element. home, where this is done in a way which does not cause nuisance, and where the premises continues to be used primarily for Conditions will be applied removing residential per- residential purposes. mitted development rights to ensure that work areas are maintained as such and to ensure that those living there also work there. EMP22 HOME-WORKING

Planning permission will be granted (normally for a temporary period) for a change of use from residential HOME-WORKING to mixed residential and employment use, if the resi- 7.8.18 It is recognised that working patterns are changing and innova- dential character of the area is not harmed, including tions in information technology make it increasingly possible to meeting all of the following criteria: work from home. Home-working provides a valuable source of (a) The home-working is carried out by those who live employment for residents who cannot travel to work or who prefer in the same residential unit; to work at home. (b) Adequate sound proofing is provided where the 7.8.19 In view of the problems with high unemployment within the bor- proposal involves the operation of noisy equipment (only one such item of equipment per dwelling is ough, home-working is consistent with the Council's employment allowed); objectives and contributes towards key sustainability objectives (from reduced traffic congestion and its associated pollution). It is (c) The proposal does not fall within the B2 or B8 Use often the first stage in the establishment of small businesses, Class and can be carried out without detriment to encouraged by PPG4, which also recognises however, that the amenity of that area; where the employment use becomes intrusive or dominant, plan- (d) The proposal does not lead to a significant increase ning permission should be required and may be refused. PPG4 in traffic generation, parking or servicing activity; also advises local authorities to take steps to ensure that such (e) There is no permanent loss of a residential unit; developments are effectively controlled. (f) The use reverts to residential use once the home- 7.8.20 Whether home-working requires planning permission or not working ceases; and depends largely on the scale of the activities. Permission is likely (g) The use can be properly serviced by utilities. to be required where -

• The scale of the business use is such that it cannot be considered wholly ancillary to the residential; • The business results in a marked increase in traffic or people 7.9 SPECIAL POLICY AREAS calling; The business involves activities unusual in a residential area; • HASSOP ROAD • The business disturbs neighbours at unreasonable hours or creates other forms of nuisance such as noise or smells; 7.9.1 This area of Local Employment Sites, with its main road frontage • Out-buildings (such as garden sheds) are used for commer- on to Cricklewood Broadway, is a long-established busy employ- cial storage, with regular deliveries being made. ment area. Many of the small businesses which front both sides of Hassop Road cause problems to the access and servicing 7.8.21 The plan’s policy on this issue is intended to facilitate small scale arrangements in the road itself and partly in the adjoining residen- homeworking, and not larger scale activities, particularly those in tial area. the B2 or B8 Use classes (such as car repairs) which would cause environmental nuisance, detriment to residential amenity or take the dwelling out of residential use.

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7.9.2 Although these businesses do cause problems, many have lawful use rights and the Council has very little control over them. In the EMP24 THE BRENTWATER ESTATE special environmental circumstances of this area, it is important, however, to ensure that future piecemeal development or rede- In considering planning applications affecting the velopment of the area will result in a reduction of adverse impacts Brentwater Estate (i.e. that part of the Staples Corner and improved operating conditions within and around the area. SEA north of the North Circular Road) rationalisation Policy EMP23 sets out the special considerations which are rele- in the number of access points on to the North Circular vant to this area. In addition, the Council will have regard to its Road (A406) will be sought. guidelines for development in the area, set out in Supplementary Planning Guidance (SPG16). Consideration will be given to the The consolidation of sites into more developable introduction of 'Permitted Parking' in adjoining residential streets. parcels will be encouraged. Developments should have an attractive design and landscaped frontage onto the A406. EMP23 HASSOP ROAD SPECIAL POLICY AREA

In considering development or redevelopment proposals for employment uses in the Hassop road area as identified on the proposals map, special attention will be paid to the following factors:-

(a) The impact of the proposed development on neighbouring occupiers (including the height of buildings); and

(b) The extent to which noise and fumes can be controlled and premises can be screened.

In order to minimise the impact on neighbouring residential uses, conditions controlling hours of operation may, depending on the nature of the development proposed, be necessary.

STAPLES CORNER NORTH (BRENTWATER ESTATE)

7.9.3 The Brentwater estate is that part of the Staples Corner SEA north of the A406 North Circular Road. Here regeneration is hindered by a poor environment, fractured land ownership patterns and poor means of access.

7.9.4 Although it is directly served by the trunk road network, the access points onto it are sub-standard. It consists of several narrow sites, most with direct access to the A406, some requiring their own signalling arrangements which interrupt the flow of traffic on the A406. Proposals to improve this have been dropped from the national road programme because of the low accident record.

7.9.5 The main issue however, is that the poor access is hindering the potential to rectify the Borough's shortage of modern industrial units with good access to the trunk road network. The Council will, therefore, continue to press for the re-introduction of proposals to the national road programme on regeneration grounds. In the interim, as sites come forward for development, the Council will examine, on a site by site basis, the scope for improvement and will encourage the consolidation of sites into more developable parcels.

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Brent Unitary Development Plan - 2004 165 EMPLOYMENT

Brent Unitary Development Plan - 2004 166 TOWN CENTRES & SHOPPING 8 TOWN CENTRES & SHOPPING

Page SH14 MINI-CAB OFFICES 181

8.1 INTRODUCTION 168 SH15 LOSS OF RESIDENTIAL ABOVE SHOPS 182

8.2 BACKGROUND 168 SH16 LOCAL CENTRES 182

8.3 STRATEGIC CONTEXT 171 SH17 ISOLATED SHOP UNITS 183

8.4 POLICY OBJECTIVES 172 SH18 OTHER SHOPPING PARADES 183

8.5 BOROUGH STRATEGY 173 8.9 ENVIRONMENTAL & DESIGN CONSIDERATIONS 183

SH19 REAR SERVICING 183 POLICIES & PROPOSALS SH20 NEW DEVELOPMENT IN OR ADJOINING 8.6 TOWN CENTRES 173 TOWN CENTRES 184

SH1 NETWORK OF TOWN CENTRES 174 SH21 SHOPFRONT DESIGN 184

SH2 MAJOR TOWN CENTRES 174 SH22 EXTENSIONS TO SHOPS 184

8.7 THE LOCATION OF SH23 FORECOURT TRADING 184 DEVELOPMENTS 174 SH24 PRIVATE FORECOURTS 184 SH3 MAJOR TOWN CENTRES AND DISTRICT CENTRES 176 SH25 CUSTOMER FACILITIES IN MAJOR SCHEMES 184

SH4 LOCAL CENTRES 176 8.10 RETAIL MARKETS & CAR-BOOT SALES 184 SH5 OUT-OF-CENTRE RETAIL DEVELOPMENTS 177 SH26 EXISTING RETAIL MARKETS 185 8.8 NON-RETAIL USES 177 SH27 NEW RETAIL MARKETS 186 SH6 NON-RETAIL USES APPROPRIATE TO PRIMARY SHOPPING FRONTAGES 178 SH28 CAR-BOOT SALES 187

SH7 CHANGE OF USE FROM RETAIL TO NON- SH29 RESTRICTIONS OF PERMITTED CAR-BOOT RETAIL 178 SALES 187

SH8 CONDITIONS ON NON-RETAIL USES 178 8.11 SPECIAL POLICIES FOR CERTAIN CENTRES 187 SH9 SECONDARY SHOPPING FRONTAGES 179 SH30 KILBURN TOWN CENTRE REGENERATION 187 SH10 FOOD AND DRINK (A3) USES 180 SH31 DEVELOPMENT OF EALING ROAD TOWN SH11 CONDITIONS FOR A3 USES 180 CENTRE 188

SH12 CUSTOMER TOILET FACILITIES FOR A3 USES SH32 PUBLIC PARKING/REAR SERVICING IN 180 EALING ROAD 188

SH13 AMUSEMENT CENTRES 181

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SH33 PUBLIC REALM IMPROVEMENTS IN 8.1.3 Other Council units can introduce traffic calming and parking HARLESDEN 189 measures or enforce legislation concerning health & safety, food, trading standards, and hours of trading. SH34 REAR SERVICING IN HARLESDEN 189

SH35 SHOPFRONT & URBAN DESIGN IN HARLESDEN 8.2 BACKGROUND 189 8.2.1 Traditionally, town centres have fulfilled a wider role than simply SH36 KENSAL RISE 189 as places to shop. They were a focus for community, cultural and entertainment activities, as well as providing a base for business APPENDIX SH1 TOWN CENTRES (PRIMARY AND and financial services such as banks and building societies. Their SECONDARY FRONTAGES) AND LOCAL CENTRES image and appearance are important to local community life and 190 identity and they are a priority for environmental improvement in the Council's strategy of regenerating the Borough and its neigh- APPENDIX SH2 DEFINITION OF EALING ROAD TOWN bourhoods. Town centres are also generally accessible to the CENTRE 192 whole community, both for those with the use of a car and the significant number of households that do not have a car. The overall MAP SH1 SHOPPING PROVISION IN BRENT 1999 193 objectives of Brent's UDP, to enhance the environmental quality of life in Brent, to promote regenerative investment and to ensure MAP SH2 PROTECTED SHOPPING FRONTAGES 194 access to facilities for all, can therefore be furthered by policies and proposals in the Plan that affect town centres and shopping.

8.2.2 Within Brent, as elsewhere, a hierarchy of shopping centres has evolved over a considerable period of time. These range from the 8.1 INTRODUCTION Borough's two major town centres of Wembley and Kilburn, which 8.1.1 Shopping remains an activity integral to people's lives, fulfilling cater for a range of shopping and service needs, to small local essential needs such as buying food to eat and clothes to wear as shopping centres and parades which provide a purely local ser- well as enabling other social requirements to be met. So the vice. Centres in Brent reflect the diversity of the Borough as a quantity, quality and location of shops has a significant effect on whole. Certain medium sized or smaller centres are relatively our quality of life. Town Centres therefore serve as the communi- prosperous and, although suffering from the widespread prob- ty focus not only of most shopping facilities, but also of services, lems of traffic congestion and poor environment for pedestrian leisure and cultural venues, thereby providing a range of retail, shoppers, are generally bustling and full of vitality. Ealing Road service and arts-based employment. As a result, policies in this town centre especially, has grown in status and evolved as a spe- Chapter cover the wide range of issues and land uses relating to cialist centre for the large Asian community, serving not only the town centre functions. In particular it includes policies for all cen- local area but also the wider area of north west London. On the tres in the borough, as well as for shopping & other activities. It other hand, certain of the larger centres in the Borough, such as generally covers the A1, A2, A3, B1a, C1, D1 & D2 Use Classes. Wembley, Kilburn, Harlesden and Willesden Green are less pros- These will also have an impact on other UDP policy areas, for perous: although they continue to provide a valuable service for instance, on employment provision, requirements for transport, the local community, they are in need of an injection of new provision of cultural facilities, and the quality and attractiveness of investment, especially the provision of new shopping or leisure the civic environment. facilities and environmental, parking and traffic improvements, if they are to continue to fulfil their role. Although Harlesden has THE COUNCIL'S POWERS undoubtedly benefited from the City Challenge, a programme of ongoing management and improvements are needed to prevent 8.1.2 The Planning Authority's powers to influence retailing are limited a deterioration of gains and attract much needed further invest- by the fact that the development and letting of shops is almost ment into the centre. entirely undertaken by private enterprise. Powers under the Town & Country Planning Act 1990 (as amended) give the Planning Authority control over the change of use of retail shops to food & drink uses, but not between different retail uses. In fact, it is only with the proposed changes to the Use Classes Order, that it will be possible to control between food & drink uses (A3 and new A4 & A5 Classes). The Planning Authority may, in limited instances be able to control the size and type of shop units in new shopping development, through planning conditions and planning obligations with developers. It has powers to control the installation of new shop fronts and the display of certain advertisements. The Planning Authority also has compulsory purchase powers, which can be used for site assembly where resources permit.

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RETAILING TRENDS & CHANGES IN BRENT Western Avenue and Safeway opposite Brent Cross. The scale of this out-of-centre development has undoubtedly inhibited 8.2.3 Retailing is a dynamic sector, which has evolved considerably investment in the Borough's main town centres. over the last two decades. In line with national trends, there has been a rapid expansion, since the 1980's, of out-of-town centre 8.2.7 An analysis of the location of new retail development over the last superstores within the borough, characterised by larger ten years shows that by far the largest of this (approx. 73,000 m2) floorspace (20-50,000 sq. ft), more efficient stores with associat- has occurred outside the Borough's town centres, over six times ed free car parking. In part, the type and location of these new as much as development within town centres (approx.11,000 m2). retail developments, have reflected changing tastes and shop- The main exceptions are the developments in Ealing Road, ping habits as well as new retailing methods and formats, for Kenton and Harlesden mentioned above. instance 'drive-through' restaurants and mini-supermarkets at petrol-filling stations. These factors, together with changes in SHOPPING HABITS & PERCEPTIONS OF consumer behaviour influenced by higher levels of car ownership, CENTRES increased numbers of women in the workforce, and the drift towards the surburbs, have encouraged bulk-buying and an 8.2.8 Results from the 1999 borough-wide Household Shopping increasing number of shopping trips by car. Survey indicated that up to 34% of residents do their main food shopping by means other than the car, and confirm the inaccessi- 8.2.4 As required by Government planning policy and guidance, the bility of the out- of- centre stores for many of the borough's resi- Council has carried out and updated a 'Health Check' process dents. This has led to the existence of what have been termed by (town centre performance assessments), the detailed results of policy analysts, 'Food Deserts', where good quality food provision which are published separately. The documents set out a number has fled town centres and those on low incomes have to buy of indicators, which depict the relative health of Brent's centres. more expensive, poorer quality food as they cannot travel out of These include for instance, the shopping habits & views of local town to shop. Most residents did their main non-food shopping at residents, pedestrian flows, the level of vacancies, the range and Brent Cross (28%), Harrow (16%) and Central London (10%), type of shops and services present, including the number of multi- with just under one-fifth using Wembley or Kilburn. The quality ples, the relative rank order of centres in London and the state of and variety of shops, the environmental quality of centres, avail- the town centre environment. The results of this process have ability of parking and other facilities, were understandably, signifi- informed the review of the Council’s planning strategy and poli- cant factors in residents' shopping decisions, as did their percep- cies set out in this chapter. tions of the safety of centres, when choosing where to spend their leisure time. 8.2.5 In 1980, there was only one large store outside the Borough's town centres catering principally for car-borne shoppers. This was Comet on the North Circular Road, which had a floorspace of 840 sq. metres. By 1990, however, there were 32 large stores outside town centres, with a total floor area of over 100,000 sq. metres (over 1 million sq. ft.), more than the total retail floorspace of Wembley, Harlesden and Willesden Green combined. These large stores consist mainly of retail warehouses, for example MFI and B&Q, selling household goods such as furniture, carpets and DIY materials, but also include 4 large superstores selling mainly food (e.g.,Tesco at Brent Park and Safeway at Honeypot Lane).

8.2.9 The present pattern of shopping provision, with a large amount of food and bulky household goods shopping undertaken outside the Borough's established centres, is now well established and is likely to persist into the foreseeable future. Trends in retail development are to a large extent dependent upon the health of the 8.2.6 There are also a number of large stores just outside the Borough national economy. It is especially important that efforts are made which have undoubtedly had an impact within Brent. Of particular to improve the attractiveness of the Borough's centres so that importance was the opening of Brent Cross shopping centre in they can take advantage of investment opportunities when there 1976, just over the Borough boundary in Barnet. There have also is a general renewal of investment in retail development and con- been several more recent large foodstore developments just out- tinue to be the main focus for shopping and other service, cultural side the Borough such as Tesco in the former Hoover building on and entertainment activity.

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RANK ORDER OF BRENT'S CENTRES quality of shops has declined steadily since the opening of Brent Cross in the mid-1970's and more markedly in recent years with 8.2.10 The number of multiple shops has been declining in Brent's larger the closure of such stores as C&A and British Home Stores. centres relative to most competing centres nearby and this is reflected in the position of Brent's centres in the rank order of cen- 8.2.13 Despite the obvious problems of many of Brent's centres, it is not tres across London shown below in the Hillier Parker ranking of a picture of decline everywhere. Ealing Road has grown in centres within London. Since 2001, only the top 10 centres in strength as a specialist, Asian-led shopping centre, as evidenced Greater London have been ranked, and Brent’s centres no longer by its expansion and the level of activity which has resulted in feature within this hierarchy. major conflict between traffic and local residential amenity. There have also been some notable successes during the last four Hillier Parker Ranking years in achieving some large new retail development in town centres; with the Sainsbury store in Kenton (1995), and Budgens 1971 1984 1989 1995 2001 in Harlesden, (1995) within the new Manor Park development (of 105) (of 168) (of Top 10) achieved with the help of City Challenge funding. There has also been the development of Lidl (1998) and other stores within a Wembley 11 17 21 34 NL Wembley Stadium retail park adjacent to the Wembley Park centre, stemming from the needs of non-resident office workers and Kilburn 21 22 21 34 NL those visiting the Stadium and nearby Arena, Conference Centre and Exhibition Halls. The most recent development is Asda Harlesden 41 49 74 NL NL (1999) in Chalkhill near Wembley Park.

Burnt Oak NR 60 53 60 NL 8.2.14 However, these developments in town centres have occurred in tandem with closures of some other town centre stores, and pro- Willesden NR 95 105 133 NL posals by a number of food retailers to substantially extend their Green existing superstores. It is notable that Wembley and Kilburn are Kingsbury NR NI 105 95 NL the only major centres in north-west London that have not attracted a large shopping redevelopment scheme in recent years, NR Not Ranked NI Newly Included NL No Longer Ranked though the Council is continuing its efforts to attract such investment into Wembley.

8.2.11 This shows the changes in the relative position of centres over a period of time. Although the ordering of centres for each year was VACANCY RATES & NON-RETAIL USES based on different indicators (primarily an assessment of retail turnover or retailer representation), it does provide a broad indica- 8.2.15 The decline in many of Brent's town centres is reflected in the tion of the relative importance of individual centres when com- increase in the level of vacancies. In general vacancy rates pared to other centres across London. The general picture of increased between 1987 and 1997. Many centres in the inner decline in the relative importance, and therefore the attraction to part of Brent, suffered from a particularly severe loss of retail shoppers and other visitors, of Wembley in particular, is clearly shops and experienced very high levels of vacancies. Centres shown. where there were high vacancy rates (over 15% in1999) within the primary shopping frontage include Kensal Rise and Kenton, RETAIL DEVELOPMENT IN TOWN CENTRES while Neasden, Kingsbury , Harlesden, and Colindale all have vacancy rates of over one-tenth. In 2001, Neasden, Kenton, 8.2.12 Although there has been little investment in terms of new shop- Sudbury and Kensal Rise had vacancies of over 15% in the pri- ping developments within the Borough's town centres, a number mary frontage, with Kingsbury and Wembley having over 10%, of the larger town centres still retain a range of service uses, and by 2003, improvement is shown by only four centres; Burnt restaurants and fast food outlets normally associated with suc- Oak, Kenton, Kensal Rise and Sudbury, having a vacancy rate of cessful centres. Brent centres have generally seen a steady over 10% in their primary frontages. decline in the number of good quality shops within them. This has been particularly pronounced in Wembley where the range and 8.2.16 The level of non-retail frontage is, as would be expected, higher in the secondary shopping frontage than the primary frontage for nearly all of Brent's town centres. Certain centres, such as Sudbury, Wembley Park, Kensal Rise, Kenton and Neasden, had over half of the primary frontage in non-retail use in 2003, an improvement on the 2001 situation which had also included Queens Park and Willesden Green. Levels of A3 uses vary across all of the town centres; Cricklewood, Kilburn, Willesden Green, Harlesden, Wembley, Kenton, Kensal Rise and Sudbury above 15% with Colindale, Neasden, Wembley Park and Queens Park at over 20% in 2003.

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8.2.17 The policies and proposals set out in the following sections reflect 8.3.3 PPG6 - Town Centres and Retail Developments (June 1996) the economic and social importance of town centres in the life of the Borough. In addition, the particular problems of Ealing Road, Local planning authorities are required to: Queens Park and the Kilburn and Harlesden town centres require • Adopt a plan-led approach to promoting development in town specific approaches which are included in a separate section at centres, both through policies and the identification of loca- the end of this Chapter. tions and sites for development. UDP's should indicate a range and hierarchy of centres, where investment in new retail and other development will be promoted and existing provision enhanced. • Apply the sequential approach to selecting sites for development, for retail, employment, entertainment, leisure and other key town centre uses which attract a lot of people. This means that first preference for new retail development should be town centre sites, followed by edge-of-centre sites, district and local centres and only then out-of-centre sites in locations that are accessible by a choice of means of transport. • Encourage appropriately-sized local supermarkets and seek to retain post offices and pharmacies in existing district and local centres. Their inclusion in out-of-town retail developments should be discouraged. The guidance expresses clear support for local centres. • Promote mixed-use development and retention of key town centre uses. It is recommended that diversification is the best way of dealing with declining town centres and it is pointed out that different but complementary uses, during the day and in the evening, can reinforce each other, making town centres more attractive to local residents, shoppers and visitors. • The Secretary of State has supplemented PPG6 with a Ministerial Statement in November 1999 that for out-of-centre sites not allocated in a development plan a need for the pro- 8.3 STRATEGIC CONTEXT posal must also be demonstrated. 8.3.1 Government retail policy has undergone a change in emphasis, Draft PPS6, which is intended to replace PPG6, was published the first being the need to move towards more sustainable for consultation in December 2003. developments which reduce the reliance on the car. This was introduced in guidance on Transport (PPG13), in 1994, which 8.3.4 RPG3 Strategic Guidance for London (1996) stated that major trip generating developments such as large stores should be located where they facilitate multi-purpose trips Strategic Guidance for London draws on the guidance set out in and are capable of being well served by public transport, usually PPG6. It states that 'town centres should continue to be the main town centres. The second aim, in recognition of the damaging focus for the provision of shopping facilities' and supports mea- effect out of centre developments have had on town centres, was sures to improve the environment and enhance the attractive- to prevent further damage by limiting the growth of out of town ness of centres to shoppers. It also accepts that the needs of shopping. The principle of limiting further out of centre develop- shoppers without access to a car 'should be met by shops which ment has also been extended to other major trip-generating uses are easily accessible'. Local planning authorities are required to: traditionally found in town centres, of which there has been out of centre development in recent years, especially cinemas • Apply the sequential approach contained within PPG6, i.e. of and other leisure uses. preferred locations for new retail development, allowing out of centre development only where existing centres are inca- 8.3.2 PPG13 2001 states that 'planning polices will help to reduce pable of providing good retailing opportunities. some of the need for car journeys-by reducing the physical sepa- • Note the hierarchy identified for London town centres, in ration of key land uses - and enable people to make sustainable which both Wembley and Kilburn in Brent are shown as major transport choices.' It also provides guidance on the location of centres. It is emphasised that the hierarchy is not rigid and major generators of travel demand (such as retail and leisure that centres may increase their position whilst others may developments) and, in particular, makes it clear that these should revert to a more local role. be located where there is genuine and easy access by a range of • Have regard to the effects of development proposals in their transport modes. Town centres are the preferred locations for own and neighbouring centres. The role of town centres in these. Town centre hierarchies, taking account of public transport acting as a focus for a variety of activities, such as services, accessibility, should be defined at the strategic level. leisure and entertainment, other commercial activities and housing is made clear and it is also appropriate to identify

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sites for primary health care which should be accessible by tre developments should be resisted in all but the most exception- public transport. A number of other uses such as hotels and al cases. Boroughs are also expected to resist the intensification, education uses are considered to be appropriate within town expansion and renewal of existing out of centre retail develop- centres. ments. • Identify opportunities for change of use and mixed use in town centres, consideration should be given to introduce or 8.3.7 Government guidance in PPG12 and Draft PPS12 (Oct 2003) increase the provision of residential, business or other com- also has implications for shopping development, particularly the munity services. Boroughs should also formulate policies that the integration of land-use and transport policy when considering encourage uses that serve the community and visitors, the location of new developments. including policies for art, culture and entertainment, leisure facilities, restaurants and hotels. • Devise policies to encourage the conversion of vacant 8.4 POLICY OBJECTIVES premises to business and other service uses. The Guidance states that in town centres that contain vacant office and retail 8.4.1 In the light of the above, the main aim of the Council's planning premises that seem unlikely to be reused for such purposes, policies towards town centres in the Borough is: conversion to other service and business uses should be encouraged. To improve environmental conditions within the Borough's centres, to regenerate the centres in terms of the facilities they 8.3.5 The Draft London Plan (June 2002) provide and their physical structure; and to ensure that they are fully accessible to the whole community. The Mayor of London’s Draft London Plan (DLP) highlights the importance of the retail, leisure and cultural sectors to London’s 8.4.2 In order to achieve these aims, shopping policies in this chapter economy and World City status. It recognises the role of town address the following objectives: centres in accommodating these and other activities such as offices and housing and the need for regeneration initiatives to 1. To maintain the vitality and viability of established town cen- help re-establish town centres as distinctive centres of community tres and to promote their physical and economic regenera- life. It also acknowledges the complexity of London’s pattern of tion: in particular, to maintain and promote Wembley and town centres, and sets out a typology of 5 key categories of cen- Kilburn as Major Town Centres within London; tres across London. These comprise: 2. To ensure that major new shopping or leisure development sustains and enhances the vitality and viability of existing • 2 International centres - Knightsbridge and West End are centres which provide accessible shops and services to the major locations for globally significant specialist or compari- whole community; son shops. 3. To create an attractive and pleasant environment within shop- • 10 Metropolitan centres - Primarily suburban of which none ping centres; are in Brent, with cross-Borough catchments and over 4. To identify and protect the primary retail areas within town 100,000 sq.m of retail floorspace including high level/variety centres to ensure that shopping facilities are conveniently of comparison shopping, multiples and department stores. located together whilst ensuring that centres can diversify and • 35 Major centres - Primarily in inner London, which includes offer a range of services; Wembley and Kilburn. These are important shopping and 5. To ensure that local shopping facilities are available to resi- service centres with over 50,000 sq.m of retail floorspace, dents who do not live close to the main shopping centres and some leisure facilities and Boroughwide catchments; to maintain a range of shops and services within them. • 156 district centres - Provide convenience or specialist shopping. These include 11 in Brent: Harlesden, Willesden Green, Burnt Oak, Cricklewood, Neasden, Kenton, Colindale, Preston Road, Ealing Road, Kingsbury and Wembley Park; • Over 1200 Local/Neighbourhood centres - Provide vital local shops and services. There are 36 in Brent (See Appendix SH1)

8.3.6 The DLP thereby identifies a network of strategic town centres across London, consisting of these International, Metropolitan, Major and District centres. Policies for these include an obligation for the Mayor and Boroughs to support town centres by enhancing access, strengthening their wider role, carrying out regular ‘Health Checks’ and town centre management. The Mayor also expects Boroughs to assess retail need, capacity, and provide appropriate sites where needed, firstly within a centre, or if not available, on the edge of the town centre, or else, in or on the edge of other appropriate centres within the network. Out of cen-

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8.5 BOROUGH STRATEGY POLICIES AND 8.5.1 Brent's town centres form part of a wider network of town centres PROPOSALS in London defined in the draft London Plan. Such a network of Centres across the borough helps to define locations where an appropriate level of provision of shopping, services and other 8.6 TOWN CENTRES activities for the community may be made. Brent's Major Town Centres (as designated in the draft London Plan) are the heart of NETWORK OF TOWN CENTRES this network, providing for borough residents' bulk convenience shopping needs and a wide range of comparison shopping and 8.6.1 There are a number of centres in Brent which, because of their other services. The category of town centre the draft London size, status, range of shops and other facilities and the extent of Plan defines below this is that of district centres. In Brent these their catchment areas, can be appropriately designated as town clearly fall into one of two types. Main District Centres comple- centres. It is in these centres that the Council will concentrate ment the Major Centres, usually include a food supermarket and efforts to achieve environmental improvements and ensure good offer a similar range of shops and services on a smaller scale, accessibility for the whole community. In particular, there is a serving as a focus for business, social, community and leisure need to ensure ease of access to shops and other facilities from uses for the part of the borough which they serve. Other District public transport. They have been divided into either major town Centres provide for convenience shopping, an element of com- centres within London, Main District Centres (and Other District parison shopping needs and some other services. Local Centres centres) according to their size and the facilities they provide. provide for day-to-day convenience shopping needs for a locality. This is in accordance with the draft London Plan and Strategic planning guidance. It is also recognised however, that centres 8.5.2 Overall the Council's strategy is that shopping facilities, services continue to evolve and that relative positions in the hierarchy can and significant leisure developments that are needed by resi- change over time. Centres within Brent will be monitored and dents, should be easily accessible, on foot, by cycle or by public their categorisation reviewed if appropriate. transport, by being located in the borough's town centres. This strategy is to ensure less mobile and/or less affluent residents have convenient access to good quality food shopping, services and leisure, by reducing the need to travel to these facilities, particularly by car. This is in line with the Council's sustainable development objectives of reducing the adverse environmental effects associated with reliance on the car (e.g. congestion, pollution) and positively contributes towards its equally important sustainability objectives of improving health and social equity.

8.5.3 The main elements of this town centre strategy are outlined below:

• An emphasis on the consolidation and improvement of existing town and local centres, allowing for expansion of shopping floorspace in appropriate locations, such as Wembley; • Steering new major trip-generating development (shopping, offices & leisure) into the Major Town Centres, particularly Wembley and Kilburn; • Ensuring that any expansion in District Centres has no adverse impact on the vitality and viability of Major Town Centres, i.e: Wembley and Kilburn; • Attracting a wide range of uses to town and local centres, particularly by encouraging the development of arts, culture and leisure facilities in appropriate locations, while retaining their basic retail functions; • Recognising and supporting the specialist roles that are developing at certain centres, e.g. Ealing Road (Asian-led), Harlesden (evening economy) and Kensal Rise (restaurants) whilst controlling the impact on residential amenity; • Supporting existing retail markets and allowing new retail or specialist markets, where appropriate, to extend the range of local shopping opportunities and employment, enliven centres and attract shoppers.

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8.7 LOCATION OF DEVELOPMENTS SH1 NETWORK OF TOWN CENTRES 8.7.1 Given that the main aims of Council policy are to improve shop- The Council will, resources permitting, use its powers ping and other facilities and ensure that they are accessible to all to improve the attractiveness of the borough's town sections of the community, including those without access to a centres listed below. This will include measures to car, then it is important that major developments should be direct- attract appropriate investment and to improve ed to those locations which are most accessible by public trans- accessibility, the range of facilities and the port, i.e. town centres. In this way, shopping facilities and other environment:- services can be conveniently located together and, for example, a visit to a food shop can be combined with a visit to other shops MAJOR TOWN CENTRES: and services, thus reducing the need to make additional journeys. Wembley This is particularly important for those without access to a car Kilburn* such as the elderly and those with caring responsibilities. New MAIN DISTRICT CENTRES: retail investment is also vital if Brent's run-down centres are to be regenerated and thus continue to be important foci for their local Burnt Oak* Cricklewood* communities. Major retail developments would provide the town Harlesden centres with a considerable boost, increasing their attractiveness Kingsbury Willesden Green to shoppers and bringing infrastructure improvements in the form Ealing Road of better servicing, car parking and road improvements. These considerations also apply to other key town centre uses which OTHER DISTRICT CENTRES: generate high numbers of visitors such as leisure and entertain- Wembley Park ment facilities. Colindale Kensal Rise Kenton* 8.7.2 In order to promote major development in town centres, the Neasden sequential approach set out in Government policy will be applied Preston Road Queens Park when considering the location of new retail and other major Sudbury development such as cinemas. This means that first preference will be for development on sites in Wembley and Kilburn, then on the edge of these centres. If no suitable sites are available in NB.* Certain centres, because of administrative boundaries, are divid- these locations then development will be permitted in, then on the ed between Brent and neighbouring London Boroughs. Policies edge of Main District Centres and then Other District Centres, within this Plan apply only to that part of the centre in Brent, where proposals should be of a scale and function appropriate to although there will be close liaison with neighbouring Boroughs to that town centre. Only if there are no sites available in any cen- ensure compatibility of policies and proposals for the centres as a tres, including where applicable those in neighbouring Boroughs, whole. will development be permitted in out-of-centre locations with moderate, good or very good public transport accessibility. 8.6.2 Of the above town centres, Kilburn and Wembley are identified as Major Town Centres within London. Council policy seeks to 8.7.3 In these circumstances developers will have to demonstrate a maintain and improve shopping and other facilities in these two need for the development (in terms of a deficiency that cannot centres in line with their status as Major Town Centres. These currently be met in a town centre, including proposals for their centres are considered by the Council as priorities for regenera- regeneration); and that there will be no significant impact on the tion and initiatives will be pursued in both centres, with bids for vitality and viability of town centres, either in or outside the Government and other funding where appropriate. For Kilburn Borough. The requirement to demonstrate need should not be major regeneration initiatives will be pursued jointly with Camden. regarded as fulfilled simply by showing that there is capacity (in The Wembley Regeneration Area Inset chapter includes policies physical terms) or demand (in terms of available expenditure and identifies potential development sites for the regeneration of within the proposal’s catchment area) for the proposed develop- the centre. In both centres the strategies for regeneration are ment. The existence of capacity or demand may form part of the based upon diversification of use and focus on the need to demonstration of need, but the significance of the factors which expand leisure and entertainment activities as well as encourag- may show need will be determined according to the particular cir- ing the more traditional shopping role. cumstances of each case.

8.7.4 Developers putting forward large development proposals (possi- SH2 MAJOR TOWN CENTRES bly incorporating a number of elements) need to be flexible about the format, design and scale of development. Rather than Planning proposals should support the maintenance proposing large-scale development that can only be accommo- and improvement of shopping and other facilities in dated in an out-of-centre location, developers should demon- Kilburn and Wembley town centres in accordance with strate why they could not develop elements of larger schemes in their status as major town centres. town centre locations, tailoring, reducing or splitting projects so that they can be accommodated in preferred areas or on existing

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sites including converting, upgrading or extending existing town able to justify an out of centre location in accordance with the centre buildings. In particular, car parking should be reduced to sequential approach to development set out above. Certain below the maximum standards to fit schemes on more central types of shop selling durable goods (usually called retail ware- sites and pharmacies and post offices should not be included in houses) may exceptionally be allowed to locate outside town cen- large out-of-centre stores. tres. As the lines they trade in are not required on a daily basis, there is likely to be less impact of the vitality and viability of town 8.7.5 For shopping purposes, an edge-of-centre location is normally centres. Also the nature of the goods sold, e.g. DIY Stores, taken to be within 200-300 metres of the primary shopping area. Garden Centres, Furniture Stores, makes available and suitable However, the existence and nature of pedestrian links between a sites in or adjoining town centres difficult to find. In addition, such store and the town centre, and the layout of the store can be proposals might not be compatible with the scale or function of a equally important factors to consider, as well as the role it plays in town centre. This does not mean that retail warehousing should relation to the centre. Without sensitive integration into the prima- be exempt from the sequential approach. In considering propos- ry shopping area (quality walking links, removal of barriers, etc.), als for such stores account will be taken of the nature of goods such 'edge-of-centre' stores simply 'turn their back' on the town sold and whether the format of a particular store is such that the centre and exert the same effects in undermining it as out-of-cen- benefits will be lost if the scale is reduced so as to be accommo- tre stores, whilst adding to traffic congestion at the centre. On the dated on town centre sites. It is acknowledged, however, that other hand, at Wembley, where the new Stadium and other facili- increasing use of home delivery is lessening the requirement for ties will be a major attractor of trips, good, attractive pedestrian stores with large on-site warehousing and large parking areas for links, with active frontages along those links, will mean that the loading. Many showroom type facilities can equally be located in acceptable distance of new development from the Primary area or adjoining town centres. Retail warehouses are also required to could be extended beyond 300 metres. This will depend upon locate where there is reasonably good public transport access whether such links exist or are planned at the time that develop- (moderate or better as defined in the Plan) so that they are acces- ment is proposed. sible to the whole community.

8.7.6 Given that the objective of the following policies is to sustain and enhance town centres by directing new development to them, and by limiting it in out-of-centre locations, then the policy must also apply to proposals for extensions to existing stores/facilities, proposed extensions to the range of goods sold, or range of activities, where this is restricted by conditions, and to relevant proposed changes of use.

8.7.7 The Plan identifies a number of sites within or on the edge of Wembley and Harlesden town centres which are suitable for large-scale development (see the inset plan for Wembley and Site Specific Proposals section). However, there may be other opportunities within the Borough's town centres either through redevelopment or by assembling sites of sufficient size which are currently in a multiplicity of ownerships. The Council will consider assembling sites through compulsory purchase as appropriate.

RETAIL WAREHOUSES

8.7.8 In the last twenty-five years there has been considerable development in the Borough of retail warehouses which sell durable goods on former industrial sites outside the main shopping cen- 8.7.10 The amount of pressure for and the scale of retail development tres. If the Borough's town centres are to be regenerated by on industrial land in the Borough has meant that the Council has attracting private investment to undertake major shopping devel- had to restrict such development to certain Local Employment opment or redevelopment schemes, then it is essential that there Sites where access by both public and private transport is reason- should be limits on the amount of development that is allowed to ably good. The relevant policies for development on Local locate outside the main town centres. Employment Sites are contained in Chapter 7, Policy EMP9.

8.7.9 The principal considerations in determining whether or not new 8.7.11 Traffic generation and environmental impact, as well as the shopping development should be permitted outside town centres effects on the vitality and viability of town centres, are likely to is the likely effects on the vitality and viability of the centres, the vary significantly between different types of store. Therefore, it application of the sequential approach and whether there is a will be necessary in granting permission for retail warehouses need for the store. The plan's policies seek to minimise the outside town centres to restrict the nature of the goods sold, in effects of out of town development by limiting this to certain types particular to prevent sales of goods that can best be provided in of store which, because of their particular requirements, may be town centres.

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WAREHOUSE CLUBS COMBINED ECONOMIC AND TRANSPORT ASSESSMENTS 8.7.12 Warehouse clubs are businesses that specialise in the bulk sale of a wide range of goods from large buildings with large car parks. 8.7.16 All applications for major development of over 1000 sq m gross to They generally share characteristics of both retail and 'cash and which the sequential approach applies should be accompanied carry' wholesale operations and operators may limit access to by a combined economic and transport evaluation. These should businesses, organisations or classes of individual and may agree be in accordance with the methodology set out in the DETR to limit the number of lines sold. They often share many of the report "The Impact of Large Food Stores…" 1998. These will characteristics of very large retail outlets, in which case they form the basis for considering the economic and transport impact should be treated as if they were retail businesses. of development.

8.7.13 In considering proposals for warehouse clubs, similar criteria will be applied as for purely retail uses, including a requirement that there are no sequentially preferable sites and that it should not SH3 MAJOR TOWN CENTRES AND DISTRICT have an unacceptable impact on the vitality and viability of town CENTRES centres. Where warehouse clubs are proposed on employment land such proposals will also be considered against the policies in In the Major Town Centres and District Centres pro- the Employment Chapter which seek to safeguard employment posals for retailing and other key town centre uses land. In addition, to ensure that the retail element is not expanded which attract a lot of people will be determined in or intensified in the future, it will be necessary to secure the non- accordance with the sequential approach set out in retail element of the use by means of a section 106 agreement. paragraph 8.7.2. Proposals should be consistent with the scale and function of the centre within which they 'DRIVE THROUGH' RESTAURANTS are located.

8.7.14 'Drive-through' developments are becoming more common, par- Proposals for sites on the edge of Major Town Centres ticularly for food and drink uses. Being designed primarily around and District Centres, will be required to comply with the private car, rather than for more sustainable modes, they can the above and in addition they should demonstrate: encourage car use. Except where they serve the needs of trav- (i) A need for the development in the format proposed; ellers along the North Circular Road, such facilities are better located in or adjoining existing centres, thus promoting their vitali- (ii) That no sequentially preferable site is available ty and viability. (In this context 'drive-through' means where the (see Policy STR2); design and/or location of the facility tends to be specifically (iii) That there would be no unacceptable impact on focused around the needs of car-borne customers). the vitality and viability of other town or district centres; and

DEVELOPMENT AT PETROL FILLING STATIONS (iv) That the development would be accessible by a choice of means of transport. 8.7.15 Shops in petrol filling stations are an A1 shop use. Often they are part of a composite use with car sales (sui-generis) and/or car repairs (B2). In the latter case proposals for the re-development of such facilities are covered by policies relating to business, industry and warehousing uses (Chapter 7). In recent years tradi- SH4 LOCAL CENTRES tionally located filling stations have come under immense pressure from stations within supermarket developments. As a con- In local centres, proposals for small scale retailing and sequence many proposals have come forward to add additional town centre uses, will be permitted where they serve retail, and/or 'drive-through' food and drink facilities to existing a local catchment area, meeting people's day to day stations with a consequential further impact on town centres. needs. Proposals for the development of retail or restaurant/ take-away uses at petrol filling stations will be determined in accordance with Proposals for larger scale retailing or other facilities the sequential approach set out in policies SH3, SH4 & SH5 will be required to comply with criteria (i) (ii) and (iv) unless the development is small-scale or ancillary to the filling governing the consideration of edge-of-centre devel- station. Any development should have an acceptable traffic opments as set out in Policy SH3 above. impact and should not have an adverse effect on the amenity of adjoining residential areas

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complementary activities are concentrated in the principal parts of SH5 OUT OF CENTRE RETAIL DEVELOP- the Borough's shopping centres, where they are more accessible MENTS for the purpose of comparison and choice.

Out-of-centre proposals for the development of retail- 8.8.4 In order to prevent a haphazard spread of vacancies and the pro- ing and other key town centre uses will only be per- liferation of non-retail uses in the principal parts of shopping cen- mitted where: tres, primary shopping frontages have been defined for the town centres listed in Policy SH1. The designation of the primary (a) There is a need for the proposal, in the format proposed; frontage is based on such factors as pedestrian activity, the location of the largest units and the presence of the main shops. The (b) There is no sequentially preferable site available extent of the primary shopping frontages for each town centre are (see Policy STR2); set out in Appendix SH1. The types of non-retail use considered (c) The proposal, either by itself or cumulatively with appropriate to such primary shopping frontages are set out in other recently completed developments or commit- Policy SH6 and the circumstances under which these non-retail ments, would not have an unacceptable impact on uses will normally be permitted to locate in primary frontages are the vitality and viability of Town or District centres; set out in Policy SH7. The factors which are taken into account and relate to the quality of servicing facilities, whether the proposal (d) The site is, or could be made, accessible by a choice would result in an excessive concentration of non-retail uses, the of means of transport, including having moderate proportion of the primary frontage in non-retail use and the vacan- or better public transport accessibility, and suitable cy rate in the primary frontage. pedestrian and cycle access exists, or could be provided. 8.8.5 The Council, in common with other local authorities and organisa- In addition, wherever possible, such developments tions, considers that the total amount of frontage in non-retail use should be combined with other existing out-of-centre should not generally exceed 35%. However, it is also the developments. Council's view that, during periods of low consumer expenditure and consequent high levels of vacant units in shopping centres, it is preferable to have appropriate alternative use of shop units rather than to allow an excessive build up of vacancies which is likely to be even more damaging than a high concentration of 8.8 NON-RETAIL USES non-retail uses. After assessing vacancy levels in the Borough's 8.8.1 For a number of years, there has been a steady increase in non- centres, it is the Council's view that where these are over 10% the retail uses in Brent's town centres and, particularly for those cen- centre would benefit from the further introduction of appropriate tres in decline, diversity of use should be encouraged. All town service uses. In these circumstances therefore, the Council will centres consist of more than just retail shops and their accessibil- allow additional non-retail uses above the normal 35% level. ity makes them particularly useful for a range of activities serving However, in order to prevent the over-domination of any particular the community; for example restaurants, leisure and entertain- centre by such uses, they will be permitted only up to a limit of ment venues, as well as financial and professional services, and 50% of the frontage. primary health facilities 8.8.6 Due to the lack of good quality rear servicing facilities within town 8.8.2 Although certain types of non-retail use are complementary to the centres in Brent, care must be taken to ensure that these scarce retail function of a town centre, and contribute to its overall vitality, resources are fully utilised. Therefore, only the non-retail uses an excess is seen to cause two major problems: where good rear servicing would be well used shall generally be allowed within these areas as outlined in Policy SH19. (a) If the growth of non-retail uses leads to a net loss of retail units, there will be a reduction in the choice available to shoppers, 8.8.7 The point at which an excessive concentration of non-retail uses with the possibility of the disappearance of particular types of is reached will depend upon such factors as the size of units, the shops and a decline in the attractiveness of the centre. length of frontage and the number of adjoining units in non-retail use. (b) The creation of "dead frontage", where there is a general absence of window displays, can lead to a loss of vitality and 8.8.8 In some circumstances, the introduction of a new non-retail use lessen the attractiveness of the centre for shoppers. The problem can enhance the attractiveness of the centre rather than reduce is exacerbated if non-retail uses are concentrated in a particular the service provided to shoppers. For example the introduction of frontage rather than dispersed evenly throughout the shopping a financial institution or a food and drink (Use Class A3) use pro- area. viding a new service tailored to the needs of a particular group in the community may enhance the range of services provided. 8.8.3 Additionally, at a time when the number of retail units is generally These considerations are reflected in Policy SH7(d). Where a contracting, it is also considered necessary to control the location non-retail use would normally be refused on the basis of the crite- of non-retail uses within shopping areas so that shopping and

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ria set out in Policy SH7(b)-(c) but is permitted on the basis of 8.8.10 One of the major problems with an excess of non-retail uses is Policy SH7(d), conditions will be imposed restricting the use to the amount of dead frontage which, owing to the general absence that applied for. of window displays and to the small numbers of customers, usually leads to a loss of vitality and lessens the attractiveness of the 8.8.9 It is recognised that criteria (b) - (c) could unreasonably hinder the centre for shoppers. The provision of a window display can be expansion plans of existing services in a centre thus forcing them ensured, however, by attaching a condition to permission. There to move elsewhere. In such circumstances, consideration will may also be occasions where a particular use within a Use Class also be given to whether or not a proposal is an extension to an (see Glossary) would be appropriate in a shopping parade, e.g. existing business in the centre. It is considered important that library or doctor's surgery, whereas other uses within the same businesses should be allowed the opportunity to expand to meet Use Class, e.g. school, would not. To ensure that premises can- local demand. not change to inappropriate uses, conditions limiting the use may be applied. Such conditions would not generally be applied to SH6 NON-RETAIL USES APPROPRIATE TO Class A1 (retail) and A2 (financial and professional services) PRIMARY SHOPPING FRONTAGES uses.

Non-retail uses proposed in primary shopping frontages will be acceptable providing they comply with policy SH7 and are confined to one of the following uses :-

(a) Financial and professional services, (Use Class A2) e.g., bank, estate agent, internet/telephone services, employment agency, betting office, building society, advice bureau; or

(b) Food and drink, (Use Class A3) e.g., restaurant, public house, cafe, wine bar, hot food take away (subject to policies SH9, SH10 and SH11); SH8 CONDITIONS ON NON-RETAIL USES (c) Libraries. Where necessary, conditions will be attached to planning consents for non-retail uses in order to min- SH7 CHANGE OF USE FROM RETAIL TO NON- imise the amount of 'dead frontage' and to ensure that RETAIL premises cannot change, without planning permission, to non-retail uses which are inappropriate in a Where primary shopping frontages have been defined, shopping parade. applications for change of use from retail to those non-retail uses listed in policy SH6 will be determined after taking account of all of the following criteria:- 8.8.11 Within Secondary Shopping frontages of Town Centres (identified on the Proposals Map), other non-retail uses will be allowed, (a) Non-retail uses which do not require rear servicing facilities of a standard which would comply with where they provide a service for visiting members of the public the plan’s standards will not be permitted where e.g. leisure and health uses. In exceptional circumstances, such facilities exist or are programmed, and where where there are units on the edge of a centre which have been these are limited within the centre; vacant for a long time, it may be possible to allow a change to residential use, providing that the unit in question is located on the (b) The location of the proposal in relation to existing periphery of the centre and that the loss of active frontage does non-retail units. Applications should not result in an excessive concentration of units or continuous not break the cohesiveness of the parade. Long term vacancy non-retail frontage within any parade or street will normally be regarded as being over two years, with evidence block; of active marketing throughout that time.

(c) The overall proportion of primary frontage in established non-retail use. Application should not generally increase the proportion of non-retail frontage to over 35%. However, if vacancy rates exceed 10% of primary frontage then changes of use to non-retail may be permitted up to a maximum of 50%;

(d) Whether the particular use proposed enhances the range of services provided or enhances the specialist role of a centre; and

(e) Whether the proposal is an extension to an existing business.

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SH9 SECONDARY SHOPPING FRONTAGES THE IMPACT OF FOOD AND DRINK (A3) USES ON RESIDENTIAL AMENITY AND THE Within secondary shopping frontages of town centres ENVIRONMENT non-retail uses that provide a service to visiting members of the general public will be permitted, e.g. 8.8.14 In addition to the problems outlined above that are likely to ensue leisure uses, subject to residential amenity, highway with an over-concentration of non-retail uses generally, specific and traffic considerations. problems of noise and disturbance impacting upon local residential amenity can result from the growth in the numbers of night Exceptionally, the Council may permit changes to resi- time uses such as pubs, wine bars and nightclubs. It is consid- dential use where all the following criteria are met: ered necessary, given the level of concern in particular localities in the Borough about their effects, to apply additional controls to (a) The property has been vacant for a long time and is on the periphery of the centre; such uses. Especially in the larger centres, it is their growth in the secondary parts of town centres, where residential property is (b) It will not result in a break in the active frontage often above or in close proximity to the shop units, that has nor in a loss of vitality and viability of the centre; caused most concern. It is acknowledged in government guid- and ance (PPG6) that the cumulative effects of concentrations of par- (c) A satisfactory residential environment can be pro- ticular types of use, including loss of residential amenity, is a fac- vided. tor that ought to be weighed with others when making decisions. Environmental problems are caused by smells, noise & vibration (including from air-conditioning and ventilation equipment) and high levels of servicing. Litter problems can be caused, particu- 8.8.12 There have been a number of large scale retail developments larly from takeaways, and the increasing use of deliveries can within, or on the edge of, some town centres, with layouts that do cause forecourt obstruction and noise problems, as well as traffic not fit into the traditional street frontage pattern. These are listed problems from stopping vehicles. as off-street shopping frontage in appendix SH1. For the purposes of policy SH7 the length of these frontages will not be taken into account fin calculating the percentage of primary frontage in retail use.

THE EVENING AND NIGHT-TIME ECONOMY

8.8.13 Evening and night-time activity in centres has been one of the largest growth areas in recent years, providing an opportunity for the range of activities in centres to diversify. The growth in the number of bars and restaurants is a response to increased demand as people have more disposable income and are prepared to spend more on eating out. It is likely to continue growing in the future. Compared to some areas, centres in Brent have not experienced the same levels of expansion in this sector, an expansion which should be encouraged if Brent's declining centres are to thrive in the future. Also, the lack of people in town 8.8.15 Premises predominantly serving alcohol require particular atten- centres after shops and offices close creates a neglected and tion, especially from late night activity. Although sales of alcohol unsafe environment and a lack of vitality. By providing a broader are controlled by licensing, PPG6 emphasises that any environ- evening and night-time economy centres will be safer and can be mental problems should be at an acceptable level and controlled enjoyed by a broader section of the population without fear. The from the outset. Issues that may need to be addressed at the development of alternative attractions to the traditional pub & club planning stage include amplified noise, disturbance from traffic based culture can encourage people who currently do not use the and obstruction of pavements, especially on side streets and from centres in the evenings because of fear of crime. This requires slamming of car doors. All of the above problems will be exacer- careful control and management. Not all A3 and similar uses will bated from late night closures, especially from large numbers be appropriate. Extended opening hours may not be acceptable leaving premises in a short period of time. in areas close to residential areas and should not simply push back the problems caused at 'closing time'. The staggering of 8.8.16 Similar environmental problems to those resulting from certain A3 closing times can help in this regard. Careful management and uses can also be caused by function rooms and nightclubs. partnership with the police are essential, as is better lighting and Similar considerations to those for A3 uses will apply, therefore, CCTV (for which developments might be invited to contribute). when applications for these uses are determined. The policy also Consideration can be given to the greater use of pavements by applies to extensions to extend existing premises or to increase restaurants for tables in the evenings particularly. the hours of operation.

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an A3 use, impose appropriate conditions restricting the use with- SH10 FOOD AND DRINK (A3) USES in the Use Class or limiting the operation in order to minimise any adverse environmental or traffic impact. A3 uses are acceptable in the Borough's centres providing that they comply with the requirements of either policy SH7 or SH9, and the requirements below. SH11 CONDITIONS FOR A3 USES Where the proposal is of a scale to attract large numbers of people it will be considered against policies Where permission is granted for an A3 or a similar use, SH3-SH5 (the Sequential Approach). A3 uses should or for an extension of such a use, appropriate not result in the creation of traffic congestion, car conditions may be imposed relating to hours of parking problems or a reduction in highway safety in opening, the scale and number of functions, noise, surrounding areas and not adversely affect the ameni- emission of fumes, use of forecourts, the disposal of ty of residential occupiers. refuse, or restricting the sale of hot food to be consumed off the premises. In considering proposals, account will be taken of:

(a) The proximity of residential accommodation;

(b) The specific nature and size of the use proposed; 8.8.18 It is particularly important for certain groups, e.g. the elderly, chil- (c) The character of the area and the concentration dren, disabled people, expectant mothers, etc., that adequate toi- and existing level of disturbance from A3 and let facilities are provided within cafes and restaurants, the majori- similar uses; ty of which are located within town centres. Improved toilet facilities mean that all members of the population have greater oppor- (d) Whether the proposed hours of operation would result in residential disturbance; and tunities to make both shopping and leisure trips. Part M of the Building Regulations will ensure that these facilities are provided (e) The practicality of providing extract ducting, in newly-built restaurants. However, where restaurants are creat- ventilation, grease traps and/or noise insulation. ed by a change of use of existing premises, the Regulations do Consideration will be given to granting permission for not require the provision of facilities that are accessible to dis- a specific use within the A3 use class, restricted by abled people. As most new restaurants are provided as a result conditions, where it can be demonstrated that this of a change of use, the Council will encourage the provision of would not result in unacceptable environmental facilities which are fully accessible to disabled people. impact.

SH12 CUSTOMER TOILET FACILITIES FOR A3 USES

Where customer toilet facilities are provided on change of use to class A3, applicants will be encouraged to include reasonable provision for disabled people.

AMUSEMENT CENTRES

8.8.19 Amusement centres can cause particular problems because of the nature of the activity: consequently, the following policy 8.8.17 The Use Classes Order 1987 (see Glossary) describes A3 uses applies to these uses. as those for the sale of food or drink for consumption on the premises or of hot food off the premises. Therefore uses such as restaurants, cafes, take-aways, pubs and wine-bars all fall within the same Use Class. Although the Use Classes Order allows a change of use from restaurant to wine bar or public house without requiring planning permission, the Council considers that such a change would often result in a significant increase in disturbance to the surrounding area, in terms of the number of customers, noise, traffic generation, etc., and would not always be desirable. Similarly, in some locations vehicular traffic attracted by a takeaway food shop may cause a hazard to other road users or nuisance to residents. In these and other comparable circumstances, therefore, the Council may, when granting permission for

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wise of off-street parking will be a strong material consideration in SH13 AMUSEMENT CENTRES determining planning applications. Where off-street parking is limited (and this may be the case in some of the secondary shop- Amusement centres will be acceptable only in ping frontage locations suited to such uses), Policy SH15 will per- Secondary Shopping Frontages, subject to: mit consent on a temporary basis only.

(a) The proposed use should not cause loss of amenity to residential occupiers; SH14 MINI-CAB OFFICES (b) The premises should not be located in proximity to schools, religious buildings and similar sensitive Mini-cab offices and similar operations will be uses; permitted only if traffic safety problems would not be (c) The likely impact from parking should not cause caused, and where they are located away from pre- loss of amenity to adjoining uses or result in condi- dominantly residential areas. Regard will be had to tions prejudicial to the free flow and safe move- the concentration of such operations. ment of traffic. This will be particularly important where games of a sessional nature are proposed; If sufficient off-street parking cannot be provided and then consent may be granted for radio-controlled (d) The proposal should not result in a concentration of operation only, on a temporary basis so this can be amusement centres in a particular location which monitored. Noise insulation and controls on hours of could be detrimental to the character of the area. use will normally be necessary if there are adjoining residential properties.

LEISURE, ARTS, CULTURE AND ENTERTAINMENT USES OFFICES 8.8.20 The Council recognises the contribution made by recreational and arts, culture and entertainment (ACE) facilities to the vitality 8.8.23 The Council encourages appropriately sized office development of town centres particularly in terms of bringing night-time activity to locate in larger centres because public transport, shopping and to centres but in also facilitating multi-purpose trips. It will encour- other facilities are available for the use of employees, and also age their location within town centres where they are most acces- because offices can complement the Council's other objectives sible and can contribute to town centre regeneration. Such uses for the physical and economic regeneration of the Borough's include cinemas, theatres and certain other recreational facilities. Town Centres (See policies EMP15-EMP17 in Chapter 7). (Ground floor uses in such developments will be subject to Policies SH6-SH9.) Proposals for major development will be sub- LIBRARIES ject to the sequential approach as set out in policies SH3-SH5, and TEA1 in the Tourism, Entertainment and the Arts chapter. 8.8.24 Research into library provision in Brent has shown that two-thirds of library users combine their library visit with at least one other MINI-CAB OFFICES AND SIMILAR USES stop, generally to shop. Although many libraries are in or adjacent to shopping centres, and therefore generally have good 8.8.21 Mini-cab offices generally wish to locate in town centres, although access by public transport, a small number of libraries are not so a primary frontage location is not considered appropriate. well placed. Where new libraries are proposed they should be Because of the traffic and environmental problems that mini-cab located within or adjacent to shopping centres, although existing operations can cause, they have been specifically excluded from libraries which are well used should be protected and improved. the B1 (offices/light industry) Use Class. Noise insulation may be The Council's strategy for libraries is contained in Chapter 11, a requirement of permission for mini-cab offices where the effect section 11.2. of noise from the use is likely to lead to a loss of amenity in nearby residential property. The provision of such insulation is not RESIDENTIAL ACCOMMODATION ABOVE SHOPS covered by the Building Regulations. The Council has experienced many problems from mini-cab firms that have stated that 8.8.25 Residential accommodation above shops is generally welcomed they will be operating on a radio-controlled basis only but, in prac- in the Borough's Shopping Centres. It contributes to the stock of tice, have frequent visits by drivers to their base, causing loss of affordable accommodation and the presence of residents can act amenity and traffic safety problems. This is a particular problem as a deterrent to crime. On the other hand there is also demand where there is a concentration of such operations. Policy SH14 for accommodation above shops from commercial uses such as also applies to activities, such as 'couriers', which operate in a shops themselves, restaurants or small office occupiers such as similar manner to mini-cabs. solicitors or accountants, all of which require a Town Centre location. Such commercial activity can make a major contribution to 8.8.22 The size of premises occupied can be a poor indicator of the the overall vitality of a centre and are important in fostering eco- intensity of such uses, therefore it is not possible to set down a nomic and physical regeneration. specific parking requirement. However, the availability or other-

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8.8.26 Although there is a general presumption against the loss of LOCAL CENTRES residential accommodation across the Borough (see Policy H7 in Chapter 5), an exception has been made for vacant residential 8.8.29 The function of local centres and parades is largely to meet the units above the ground floor of the Primary and Secondary day to day needs of local residents and they are particularly valu- Shopping frontage of the Borough's major town centres, i.e. able for disabled people and the less mobile. It is important, Wembley and Kilburn. These centres are the Borough's priorities therefore, to ensure that local shopping facilities remain easily for regeneration and where a wide range of activities is appropri- accessible to local residents, especially those who do not live ate. Alternative uses allowed are commercial or community uses close to town centres. Those local centres and parades which (e.g. health facilities) that are compatible with a town centre loca- the Council wishes to maintain are set out in Appendix SH1. tion. In this way, a wider range of activities can be encouraged in the heart of the town centres, thus increasing their attractiveness to visitors and promoting their regeneration. NON-RETAIL USES IN LOCAL CENTRES

8.8.27 In Secondary frontages, change of use from residential will be 8.8.30 In view of the limited size of local centres, it is essential to retain allowed only if the proposed use is ancillary to the use below. In retail uses or essential services in these centres. Consequently, this way, existing shops and other businesses will be allowed to only appropriate non-retail uses as set out in Policy SH6 or those expand to upper floors, thus encouraging their retention in a which provide an essential local service, will be allowed. centre. New businesses, which require more accommodation However, to help ensure that service uses do not over-dominate a than the ground floor can provide, such as for staff facilities, will local shopping parade, the proportion of units in non-retail use will also be encouraged to locate in these centres. At the same time be controlled. Proposals for changes of use to residential will be the pressure from other alternative uses, such as storage, which considered on the same terms as those in secondary shopping do not necessarily require a town centre location, will be min- frontages as explained in paragraph 8.8.11. imised. The inclusion of upper floor residential units as part of mixed use developments will nevertheless be encouraged as these can also help to regenerate Town Centres (see Policy BE14 SH16 LOCAL CENTRES in Chapter 3). The plan recognises that some shopping frontages no longer can perform a useful shopping or service function and Within local shopping centres (listed in Appendix SH1) re-use or redevelopment for uses such as residential may be per- non-retail uses will be permitted where the proposed missible (See policies H2 and SH18). use is considered appropriate, as identified in Policy SH6, or provides an essential service to visiting mem- 8.8.28 In allowing a change of use to an activity not associated with the bers of the public, e.g. doctor's surgery, and will result ground floor premises, it is important for the safety and conve- in no more than 35% of the shop units being in non- nience of the public that independent access from the main road retail use. Where vacancy rates are 10% of units, or is provided (See also Policy CF13). more, further appropriate non-retail uses may be allowed up to a maximum of 50% of units.

SH15 LOSS OF RESIDENTIAL ABOVE SHOPS Exceptions may be allowed where the proposal is an extension to an existing business or the proposed use The loss of long-term vacant residential accommoda- will extend the range of local services available. tion will be permitted above the ground floor in designated shopping frontages in Wembley and Kilburn Exceptionally, the Council may permit changes to resi- town centres. Subject to the following: dential use where all the following criteria are met:

(a) The proposed alternative uses is a commercial or (a) The property has been vacant for a long time and is community use which will help to sustain or on the periphery of the centre; enhance the vitality and viability of the town cen- (b) it will not result in a break in the active frontage tre; nor in a loss of vitality and viability of the centre; (b) Where the proposed non-residential upper floor use and is to operate separately from that on the ground (c) A satisfactory residential environment can be pro- floor, independent direct access will be required; vided. (c) For secondary shopping frontages ,only if the proposed alternative use is ancillary to the use below;

(d) There is no loss of a purpose-built flat of a modern ISOLATED SHOP UNITS standard or of a flat that has a separate balcony access; and 8.8.31 Outside the town centres and local shopping parades, there are a (e) The proposed use should not be detrimental to the number of isolated shop units, mainly in residential areas, which amenity of neighbouring residential occupiers. provide a useful service to the locality. These shops should remain in retail use if possible, particularly where there are no protected frontages (i.e. frontages designated as 'Primary' or as

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part of a Local Centre in Appendix SH1) within 400 metres. ties and public transport accessibility. These measures are made Where a loss of retail is allowed, the most appropriate alternative more effective through town centre management, which can bring uses would be those compatible with residential areas, for exam- together public agencies, residents, businesses and investors ple residential and community uses. Map SH2 gives a general and ensure the proper co-ordination and development of services indication of those areas that are more than 400 metres from a to the town centre. General environmental improvements, such protected frontage. as upgrading shop fronts, tree and shrub planting and the provision of seating and amenity areas are also required. Development schemes within town centres, therefore, should SH17 ISOLATED SHOP UNITS contribute to the improvement of facilities and environmental quality generally. Policies and proposals for alleviating the major Change of use of isolated shop units to non-retail use traffic problems within Wembley town centre are set out in the will not be permitted if there are no other protected Inset Plan in Chapter 14. Relevant policies for improving built retail frontages within 400 metres. Where an isolated environmental quality are included in Chapter 3 on the Built shop has been vacant for over a year appropriate Environment, Section 3.8. alternative uses will be permitted. In considering applications for such uses, particular regard will be paid to the possible effect on the amenity of adjoining residential properties.

OTHER SHOPPING PARADES

8.8.32 Outside the town centres and protected local parades and shops, there are a number of other shopping parades which, because of a reduction in the demand for local shops and services, are no longer essential to meet local shopping needs. In such parades alternative uses will be considered SH19 REAR SERVICING

SH18 OTHER SHOPPING PARADES The council will use its powers to provide, retain and, where necessary, improve facilities for rear servicing In shopping parades outside the primary and by vehicles of retail and service outlets. secondary areas and protected local parades identified in Appendix SH1, change of use to appropriate alternative use will be permitted. Priorities for alternative 8.9.2 There are a number of considerations which apply to all shops use are set out in Policy STR1. whether in town centres, local parades or major new developments and reference to the following policies will be made when- A more flexible approach towards development stan- ever appropriate. All new shopping developments, whether town dards will be applied, subject to maintenance of a centre developments, retail warehouses and superstores in out- quality residential environment (Policy H21). of-town-centre locations, or extensions to existing shops, must be capable of operation without adverse effects on the local environment and the amenity of local residents, and must be of a high standard of design in keeping with the existing character of the area. This includes orientation towards the street in shopping centres. Parking standards for retail developments are included in 8.9 ENVIRONMENTAL & DESIGN Chapter 7 and detailed standards relating to shopfront design are CONSIDERATIONS set out in the Council's Supplementary Planning Guidance .

8.9.3 As shopping trips are one of the most frequent reasons for going ENVIRONMENTAL QUALITY & TRAFFIC IN outside the home, there should be access to and ease of use of TOWN CENTRES town centres by all members of the public. To that end the 8.9.1 If the Council's objective of maintaining and enhancing the vitality Council will aim to ensure that, where appropriate, all town centre and viability of established town centres is to be achieved, then, developments provide a satisfactory level of accessibility for dis- as well as regenerating them by securing major development, abled people. Good access to new shops will be provided by Part there is also a need for other measures which will make the cen- M of the Building Regulations but, in the case of changes of use tres more attractive to shoppers and businesses. These include or alterations, these improvements will need to be negotiated. measures to alleviate traffic congestion, to reduce vehicle/pedes- The Council's Supplementary Planning Guidance includes guid- trian conflict and to improve rear servicing and car parking facili- ance concerning access for disabled people.

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SH20 NEW DEVELOPMENT IN OR ADJOINING SH23 FORECOURT TRADING TOWN CENTRES Planning permission for forecourt trading will be In or adjoining town centres, development should be granted only where such development (including any orientated towards the street. means of enclosure that may be required by the relevant licensing authority) will not cause obstruction to pedestrians, prams and wheelchairs nor result in an adverse effect upon the character and appearance of the area in which it is to be located.

SH24 PRIVATE FORECOURTS

The council will consider taking private forecourts into the public highway where this would improve the shopping environment and pedestrian safety.

SH21 SHOPFRONT DESIGN 8.9.5 In order to make shopping easier the Council considers that certain additional facilities for disabled people and child carers New shopfronts should be of a standard of design, should be provided in major retail developments. This is particu- which respects the shopfront designs of adjoining larly important in large stores and shopping centres where shop- properties and avoid excessive advertising and pers spend a significant proportion of their time. These should encroaching on upper stories, and have appropriate include toilets and childcare facilities i.e. baby changing and feed- materials and proportions. The Council will ensure ing areas and crèches. These will particularly benefit women who that a co-ordinated approach is maintained to matters comprise the majority of shoppers and carers of children. Details of design and to choice of materials and street concerning the design and type of facilities the Council wishes to furniture. see provided in new developments are included in Supplementary Planning Guidance (SPG14). Roller shutters should allow a view of the shop during closed hours (except in the case of open-fronted shops). Full access for disabled people should be SH25 CUSTOMER FACILITIES IN MAJOR included. SCHEMES

In retail developments with a gross area greater than 2,000 m2 (21,530 sq.ft.), the provision of facilities for 8.9.4 Extensions to the fronts of shops can disrupt the building lines of childcare including, in major schemes, a crèche and shopping parades and, consequently, will not normally be play facilities for shoppers' children, will be welcomed. allowed. Policies are also required to control forecourt trading because of problems of obstruction and the effect on the charac- Where the need for them arises from the development ter of an area, although in certain centres where the pavements and they are of a scale in proportion to the proposal. are wide, e.g. parts of Wembley, the centre can be made more Where customer toilet facilities are provided on attractive to potential users, especially in the evenings, by use of change of use, applicants will be encouraged to the pavements for restaurant tables. include reasonable provision for disabled people.

SH22 EXTENSIONS TO SHOPS

Front Extensions to shops should retain adequate 8.10 RETAIL MARKETS & CAR-BOOT space for rear servicing and secure storage for waste SALES materials. 8.10.1 There has been growing pressure in recent years for the establishment of retail markets in the Borough. These, if properly regu- Front extensions should not breach the established lated, can add vitality and character to existing shopping centres, building line within existing shopping parades, includ- and may help to attract more shoppers. Markets are regulated by ing that on upper storeys. a number of legislative instruments. The Town & Country Planning (General Permitted Development) Order 1995 governs

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the period that any land can be used for holding a market, after 8.10.7 The market in Kilburn Square is the only one with permanent which planning permission is required. The London Local stalls in the east of the Borough. It is an integral part of Kilburn Authorities Act 1996 (Part III), governs the licensing of what are town centre, adding to its character and vitality. termed 'occasional sales', i.e; five or more buyers and sellers operating from a site that is not part of a highway or building 8.10.8 The Sunday Market held in Wembley Stadium's car park is the (except a car park) and including no less than five stalls, stands, biggest in north London after Camden Market. Although well vehicles or pitches from which articles are sold. Applications for served by buses and Wembley Park underground station, it also licenses are considered by Brent's Health Safety & Licensing generates a significant amount of vehicular traffic within the area. Service. These do not cover markets held in accordance with Policy WEM26 supports the retention of the market whilst control- planning permission, nor those with an established use, or which ling its environmental and retail impact . have been held continuously since before the 1st July 1948. In addition, the Trade Description Act 1994, Trademarks Act 1968, 8.10.9 Wembley also has a covered mini-market in Lancelot road, just Consumer protection Act 1987, and many other Statutes and off the High Road. It is the only permanent market in the western Regulations, including European Directives and Codes of part of the Borough. However, due to its location towards one Practice, are enforced by Brent & Harrow Trading Standards on end of the centre and opposite the busy junction with Ealing Road all market traders. and the High Road, the town centre does not benefit visually from its presence. There is also a popular open air market in Willesden 8.10.2 This means that persons exercising their permitted development which is held twice a week in the car park of the Moll Darbys pub- rights, who also receive payment from those trading in the sale, lic house on Church Road. must nevertheless apply for a license which usually imposes conditions relating to: the time of commencement; the duration of the sale; arrangements for accommodating customers vehicles; SH26 EXISTING RETAIL MARKETS arrangements for controlling road congestion, litter and noise; a requirement that the names and addresses of sellers are publicly The retention of existing retail markets will be displayed; a requirement that the person holding the sale display encouraged and, where affected by development their full name and business address, and full name & address of proposals and where feasible, their replacement in person appointed to receive complaints about the sale in a promi- town centre locations will be sought. nent position. The improvement of environmental conditions associated with existing retail markets will also be RETAIL MARKETS sought, including storage and preparation space for traders to meet public health requirements. 8.10.3 The existence of stall holders in retail markets and non- licensed traders such as news- vendors and flower-sellers, 8.10.10 Further proposals for retail markets should be in line with the complements the range and variety of retail provision in the Council's shopping strategy, which is primarily designed to Borough. These can make a positive contribution to the vitality of improve the shopping services within the Borough by directing shopping centres and provide interest and colour to the street new investment to existing town centres. However, the scale of scene, adding to the identity and character of the shopping areas such development should be in keeping with the size of the centre where they are situated. They provide a retail presence in areas and should have regard to the impact on the surrounding area deficient in local shops and catering units, and variety where trad- and on other centres. In addition, any sites chosen should be ing from conventional shop premises would not normally be physically suitable: they should be hard surfaced with adequate viable or suitable. Such trading is either 'on-street' (requiring a servicing and parking arrangements for stall holders and not sub- license to trade on the public highway), or 'off-street' (by agree- ject to any highway limitations. ment between landowner and trader). They are also important starting points for the establishment of new businesses by local residents, particularly by the and ethnic minority groups.

8.10.6 Another potential form of retail development concerns mobile stalls (i.e those comprised of caravans or other adapted vehicles stationed in lay-bys, highway verges, industrial estates or within the curtilage of a public house or other building). Although most are permitted development and do not constitute a significant problem at the present time, the Council will monitor the number and effects of such developments, particularly near sensitive areas, due to their potentially intrusive visual impact, and a possible future increase in their number, in light of the regeneration initiatives ongoing in parts of the Borough.

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be admitted into the grounds, noise from car doors slamming and SH27 NEW RETAIL MARKETS loud music from cars, general disturbance from customers cars entering and leaving grounds, traffic generated on congested The scale of any new retail markets in the Borough's roads, parking problems, and problems with litter generated out- Major centres will be limited because of the potential side the grounds. impact on the viability of established shops. Wembley Central Square in its present form, is identified as the 8.10.13 The policy aims to ensure they do not have a detrimental effect on preferred location for any new retail market. residential amenities, the local environment, or the vitality and viability of any nearby town centre. It also addresses some of the Favourable consideration will be given, however, to main issues of concern expressed by residents such as safety, proposals for new specialist and crafts markets, which control of noise, congestion, etc. Any permission given should add to diversity and range of goods particularly in be temporary in order that the Planning Authority may retain the Wembley and Harlesden. power to require the Car-Boot Sale to cease if nuisance is caused. In considering whether the scale of activity under criteria The provision of new off-street, covered, or street (a) is excessive a minimum of about 20% of the total site area for markets or individual market stalls will be encouraged circulation and an area of not less than 45m2 per car will be on sites in or adjacent to the Major & Other District assumed, in addition to any spatial constraints imposed by other Centres, in accordance with the following criteria: criteria. An acceptable management plan under (f) should include: i) commencement time and duration of the sale with regard to the (a) The scale of the market does not have an adverse effect on the vitality and viability of a town centre potential impact on residential amenity, ii) a site layout plan showing as a whole; vehicle trading areas, maximum number of vehicles, spacing and aisle widths, iii) arrangements for marshalling access into the site (b) The operation of the market would not have a and safety measures that will be put in place to prevent or deal with major detrimental effect on residential amenities; accidents, iv) for large sales, a pre-booking system for not less than (c) Access to the market does not result in a loss of 50% of pitches, and v) signage, with arrangements for the display shoppers' car parking: provision for the parking of and/or collection of sellers' details as a best practice measure. stall holders' vehicles will be required on site with facilities for customers' parking in the vicinity; and 8.10.14 The nature of goods on sale, are not, strictly speaking a planning (d) In the case of street markets, particular considera- issue, although the increasing use of car-boot sales by traders tion will be given to highway safety and arrange- selling new goods could indirectly affect the vitality and viability ments for adequate clearance of rubbish. of nearby town centres if the sales have a large enough catchment area.

EXCEPTIONAL RESTRICTIONS OF PERMITTED CAR-BOOT-SALES SALES 8.10.11 In recent years, there has been an increase in the number of car- 8.10.15 The Council considers that car-boot sales are essentially 'non- boot sales being held in the borough. It is recognised that these retail' markets (by non-traders dealing in second-hand/recycled can often be a popular means for the local community to recycle goods), and therefore come within the definition of a market in unwanted articles, socialise informally, and for those on low- Part 4 (Class B) of the General Permitted Development Order incomes to purchase second hand goods at well below shop (GPDO) 1995. The GPDO permits the holding of a market, with- prices. However, these activities in predominantly residential out planning permission, for not more than 14 days a year. areas often cause disturbance to local residents, particularly However, in certain locations, such car-boot-sales may cause when there is excessive noise at unsociable hours as well as considerable problems, in the absence of adequate controls. If unsightly (permanent) advertisements, litter and significant traffic the Council receives persistent complaints or considers any car- and parking stress. In order to protect residential amenity, appli- boot-sales to be causing problems, then it may use its powers cations for car-boot sales will generally be refused unless it is under Article 4 of the Town and Country Planning Act 1990 to demonstrated that the proposed sales would not have an adverse remove the permitted development rights. This would mean that impact on the locality. all proposals to hold car-boot sales in the specified area would require planning permission. 8.10.12 There are currently at least six private car-boot sales operating weekly within the Borough. With the exception of the Wembley stadium and Bridge Park Centre car-boot sales on Saturdays, they are all held in school car parks and playground areas. The problems associated with car boot sales relate to their often clos- er proximity to residential areas, being located outside existing centres. Particularly for sales operating on Sundays, in predominantly residential areas, the complaints from neighbours have included; trading cars queuing up early in the morning waiting to

Brent Unitary Development Plan - 2004 186 TOWN CENTRES & SHOPPING

8.11 SPECIAL POLICIES FOR SH28 CAR-BOOT SALES CERTAIN CENTRES

Proposals for regular Car Boot Sales will be assessed with regard to their overall impact, and will not be KILBURN permitted unless all the following criteria are met or are secured as part of the application: 8.11.1 Kilburn was the first of Brent's town centres to be developed and has continued to be a major centre for inner North West London. (a) The scale of activity, in terms of the number of pitches, is not excessive: It has retained its status as a strategic centre but there has been little retail investment in recent years, and it suffers from a poor (b) Any additional traffic generated by the sales would general environment. The centre has good public transport links, not cause unacceptable impact on residential but adjoining residential streets are heavily used for shoppers' amenity on the existing road network nor consti- parking. The Council, together with Camden Council, is pursuing tute a safety hazard; a regeneration initiative for the centre and a strategy for the future (c) Provision for the parking of all trading vehicles is was drawn up by URBED in 1997. made on-site with 20% of the site area reserved for customer parking and facilities for additional parking in close proximity; SH30 KILBURN TOWN CENTRE (d) The proposal should include adequate arrange- REGENERATION ments for the control of noise, the storage and/or collection of litter during the sales, as well as the The Council will work with the London Borough of disposal of rubbish afterwards; Camden to develop and implement a programme of (e) The access and parking arrangements for both action for Kilburn town centre to achieve economic trading and customer vehicles would not cause regeneration and environmental improvement and to noise disturbance to nearby residents at unsociable ensure the general good management of the shopping hours; and area. (f) The production of an agreed Management Plan ensuring the delivery of the above arrangements.

Any permission granted would be for a limited period 8.11.2 Entertainment and recreational uses have always been an inte- only (normally 18 months). Permission will also be gral part of the character of Kilburn and have brought diversity subject to a Planning Obligation waiving an appropri- and vitality to the centre. In recent years however, there has been ate proportion of permitted development rights, on an increase in licensed premises, particularly in the northern part the cessation of the planning permission, equivalent to of the centre and in Willesden Lane. Some of these premises the period of the calendar year for which the sale has provide entertainment and have extended opening hours. The been operational. parking and general activities associated with these uses and the clubs and other establishments already in the area have resulted In all cases, permission will be made personal to a in a severe loss of amenity to residents in the adjoining streets. named person or persons, to ensure that the responsi- (See Glossary for definition of A3 uses.) bility and arrangements for the operation of the sale do not change without the knowledge and express consent of the Planning Authority.

SH29 RESTRICTIONS OF PERMITTED CAR- BOOT SALES

In exceptional circumstances, the Council may apply to the Secretary of State for approval to serve an Article 4 direction - removing the permitted development rights to hold a sale for 14 days a year - in particularly sensitive areas, where they cause unacceptable nuisance to local residents, detriment to local amenity, the environment and/or road networks.

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EALING ROAD 8.11.6 Haynes Road currently serves Nos. 111-141 Ealing Road. The intention is to extend this to Nos. 99-109 on redevelopment. Nos. 8.11.3 Ealing Road Town Centre is a specialist Asian-led shopping cen- 99-103 have been redeveloped, reserving a rear service road tre whose commercial success over recent years has trans- which could be extended to Haynes Road when the opportunity formed the area from a series of local shopping parades to a thriv- arises. ing shopping centre. Located in a residential area, it serves both the local community and the wider population for whom it fulfils a 8.11.7 The busiest stretch on the western side of the centre comprises specialist role. Due to the centre's location and the constraints Nos. 160-218 Ealing Road. These are currently serviced by imposed by the road and building pattern, a number of environ- roads which are too narrow for modern purposes and in a poor mental problems arise. Generally the Borough wide policies in state of repair. Studies have shown that improved service roads this Plan are sufficient to address these problems but there are can be provided to the rear of these properties, although this certain issues which require specific policies. In particular, any would involve considerable demolition of property. The improve- extension of the centre beyond its existing boundary is likely to ments to rear servicing will, therefore, have to be carried out upon exacerbate congestion and associated problems: therefore the redevelopment of the shops. The Council's standards for rear Council will pursue a policy of restricting the growth of the centre service roads are contained in Supplementary Planning whilst maintaining and consolidating its current success. Shops Guidance SPG13. and businesses which wish to locate in the general area will be directed to Wembley Town Centre where the Council is encourag- 8.11.8 There are limited opportunities for providing car parking within the ing businesses and focusing resources as part of its regeneration town centre and therefore it is essential that all opportunities, strategy for that centre. however small, are pursued. Policy TRN25 in Chapter 6 sets out the Council's commitment to securing an appropriate level of 8.11.4 To help alleviate the problems of Ealing Road, the Council will short-stay car parking in town centres, including Ealing Road seek, as part of any further new development schemes within the Town Centre. The Council is investigating, with local traders, the centre, rear servicing improvements, public car parking and a site land to the rear of Haynes Road as a potential public parking for public conveniences. area.

SH31 DEVELOPMENT OF EALING ROAD TOWN SH32 PUBLIC PARKING/REAR SERVICING IN CENTRE EALING ROAD

Further expansion of Ealing Road town centre beyond The Council, together with local traders, will examine the town centre boundary shown on the proposals the feasibility of providing public car parking to the map and defined in Appendix SH2 will be resisted. rear of Haynes road. The Council will, subject to the findings, seek to negotiate with the owners of the land and, where necessary, acquire the land to provide parking facilities. Further opportunities to provide public parking and rear servicing will be sought on redevelopment.

HARLESDEN

8.11.9 Harlesden, although benefiting from investment in the centre through the City Challenge scheme during the early 1990's which arrested its decline, continues to require support from the planning system to maintain its role as a Major District Centre and to ensure that the improvements made are sustained. The centre 8.11.5 The level of traffic congestion and its associated problems of ille- continues to suffer from traffic congestion and relatively poor links gal parking/loading within the town centre are exacerbated by the to the main station, Willesden Junction, 500 metres away. severe lack of rear servicing to the commercial properties. Most of the Town Centre lacks adequate rear servicing. The Council 8.11.10 Although the centre has seen some new development in recent has policies to protect existing rear servicing and parking facilities years, with the provision of a modern supermarket, new shop (Policy SH19 and, in Chapter 6, Policy TRN34). Any improve- units and public car parking, the Council will continue to encour- ments or provision of new facilities would involve the demolition of age and promote appropriate town centre development, e.g. some property. The potential exists to improve the rear service shops and leisure uses, on sites within or adjacent to the centre in roads to Nos. 99-141 Ealing Road (Haynes Road) and to Nos. accordance with the sequential approach to development. 160-192 and 194-218 Ealing Road.

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QUEENS PARK SH33 PUBLIC REALM IMPROVEMENTS IN HARLESDEN 8.11.13 Queens Park District Centre has been undergoing major change. Alongside the increasing popularity of the surrounding residential The Council will work, in partnership with local area, the centre has seen the opening of new restaurants and residents and businesses, to regenerate and improve shops and the centre has virtually no vacancies. The area imme- the local environment in Harlesden. diately to the north is undergoing regeneration, with recent development of new mixed and specialist uses re-using the attractive Victorian buildings. This change is to be welcomed. In order to ensure that the expansion and growth of the centre occurs in a 8.11.11 One specific concern is the lack of rear servicing facilities for manner which maintains the character of the buildings, does not shops in the centre resulting in service vehicles obstructing traffic cause traffic problems, maintains employment and complements and reducing visibility for drivers. It is therefore sensible that the the district centre, site specific proposal DP3 in Chapter 15 sets opportunity to provide rear servicing on redevelopment should not out specific requirements for development. be missed, nor should existing facilities be lost without adequate replacement.

SH34 REAR SERVICING IN HARLESDEN

The provision of off-street servicing will be sought in new development within the town centre. Development resulting in the loss of existing servicing facilities without adequate replacement will not be permitted.

8.11.12 Of particular importance in Harlesden, in view of the presence of KENSAL RISE several listed buildings and the designation of part of the centre as a conservation area, is attention to urban design quality and 8.11.14 Kensal Rise is a centre which has declined considerably in recent environmental conditions generally. Much improvement was years, with a high level of vacancies and an increase in non-retail achieved during the course of City Challenge and this should not uses. The area has not benefited from the increasing popularity be allowed to deteriorate and the aim is to make further improve- of the surrounding residential area, unlike premises on the ments. If the town centre is to be re-established with a strong Harrow Road. Proposals to diversify and regenerate the centre sense of place and identity, new buildings should reflect the best are welcomed. features of its established character and materials and street furniture should be chosen as part of a comprehensive design SH36 KENSAL RISE treatment. There is also a need to improve the overall standard The regeneration of Kensal Rise District Centre will be of shop front and advertisement promoted, in partnership with local traders and resi- design. In making applications dents associations. Proposals to diversify the range of for new shopfronts in Harlesden, uses, whilst maintaining or improving day-to-day regard should be had to the sup- shopping facilities, are supported. plementary guidance contained in the Harlesden Shopfront Design Guide.

SH35 SHOPFRONT & URBAN DESIGN IN HARLESDEN

Development in Harlesden should respect the character of the shopfronts and buildings having regard to supplementary planning guidance contained in the Harlesden Shopfront Design Guide.

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Burnt Oak Broadway 33-51 APPENDIX SH1: Secondary Frontage TOWN CENTRES (PRIMARY AND Burnt Oak Broadway 15-31 SECONDARY FRONTAGES) AND LOCAL CENTRES Allied Carpets Holmstall Parade 1-15

EALING ROAD

MAJOR TOWN CENTRES: Primary Frontage Ealing Road 160-242a, 99-141 WEMBLEY Secondary Frontage Primary Frontage Ealing Road 134-158 Wembley High Road 444b-548, 397-501 HARLESDEN Central Square 1-43 Park Lane 6-8, 1-11 Primary Frontage St Johns Road 1-9 Harlesden High Street 2-114, 1-93 Bank Buildings 1-11(inclusive) Manor Parade All properties Secondary Frontage The Croft All properties Wembley High Road 313-337, 367-395, 503-569 Craven Park Road 1-21, 2-8 326-354, 400-406, 412- Acton Lane 2-6 444, 550-612 Tavistock Road Units 1-6 Harlesden Wembley Hill Road 23-31 Plaza Neeld Parade 1-12 Wembley Hill Road 1-19 Secondary Frontage Ealing Road 2-60, 3-17, 1-7 Plaza Harlesden High Street 116-122, 95-109 Parade Craven Park Road 10-86, 23-59, Library Parade Coronet Parade 1-6 Manor Park Road 158-166 Sevenex Parade 1-8 Park Parade 1-9 (inclusive) Lancelot Parade 1-5 Off-Street Shopping Frontage Tavistock Road Unit 7 Harlesden Plaza KILBURN WILLESDEN GREEN Primary Frontage Kilburn High Road 79-205 Primary Frontage Kilburn Square (fronting High Road 92-94 (inclu Willesden High Road 2-88, 1-121 at ground floor level) sive) Walm Lane 1-47, 58-92 Queens Parade 1-12 Secondary Frontage Willesden Lane 291-293 Kilburn Bridge 1-12 Kilburn High Road 41-63, 67-77, 207-405 Secondary Frontage Kilburn Square 96-109 (inclusive) Willesden High Road 147-167, 100-142 Willesden Lane 11-85, 2-70 Station Parade 2-26 Exeter Road 2-8 Walm Lane 53-69 Oxford Road 2-4 Coventry Close 1-3 Off-Street Shopping Frontage Cambridge Avenue 6-10 High Road Somerfields Glengall Road 1-5, 2-8 Priory Park Road 2-4 KINGSBURY Dyne Road 2b-2f Primary Frontage MAIN DISTRICT CENTRES: Kingsbury Road 449-573, 532-660 Kingsbury Arcade 1-22 BURNT OAK Secondary Frontage Primary Frontage Kingsbury Road 419-447, 510-530

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Fryent Way 1-5 Secondary Frontage Chamberlayne Road 32-78, 98-106, 37-45, CRICKLEWOOD 103-119 Bridge House 1-4 Primary Frontage Station Terrace 15-20 Cricklewood Broadway 83-217 Keslake Mansions 1-7

Secondary Frontage QUEENS PARK Cricklewood Broadway 7-81, 219-241 Chichele Road 2-4 Primary Frontage Salusbury Road 26-36, 46-62, 43-101

OTHER DISTRICT CENTRES: SUDBURY

NEASDEN Primary Frontage Harrow Road 784-822, Primary Frontage 753-779 Neasden Lane 270-352, 237-309 Secondary Frontage North Circular Road 536-540, 560-570 Harrow Road 781-797, 824-830 Secondary Frontage Watford Road 2-36 Neasden Lane North 354-388 Neasden Lane 232-260 WEMBLEY PARK North Circular Road 572-580 Primary Frontage KENTON Bridge Road 7-55

Primary Frontage Secondary Frontage Kenton Road 177-235 Wembley Park Dr . 87-147, 100-126 Secondary Frontage Empire Way 10-16 Kenton Road 85-137 Grand Parade 1-18

Off-Street Shopping Frontage Off-Street Shopping Frontage Nash Way Sainsburys Forty Lane ASDA Wembley Park Drive Units1-4 Stadium COLINDALE Retail Park Primary Frontage Edgware Road 167-223 LOCAL CENTRES:

Secondary Frontage ACTON LANE Edgware Road 225-295 Acton Lane 75-99

PRESTON ROAD BLACKBIRD HILL Blackbird Hill 25-51 Primary Frontage Preston Road 197-279, 192-296 CANTERBURY ROAD Secondary Frontage Peel Precinct 1-7, 16-24 Preston Road 298-308, 314-324, 176-190 CARLYON ROAD Carlton Parade 1-5 Carlyon Road 36-50

KENSAL RISE CHAMBERLAYNE RD. Chamberlayne Rd 4-30 Primary Frontage Chamberlayne Road 47-101 CHURCH LANE SOUTH Station Terrace 21-30 Church Lane 151-177, 216-232, 244-282

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COLLEGE PARADE Queensbury Stn Parade 1-26 Salusbury Road 12-20 ROE GREEN VILLAGE CHURCH END Stag Lane 338-346 Church Road 132-190, 179-203 SIDMOUTH ROAD COLLEGE PARK Sidmouth Parade 1-10 Harrow Road 994-1020, 1074-1104 Sidmouth Road 27

COLLEGE ROAD SOUTH KENTON College Road 104-120 Ennerdale Court 1-4 Mariel House 1-4 DUDDEN HILL PDE Windermere Ave 118-128 Dudden Hill Parade 1-4 STATION ROAD EAST LANE Station Road 25-63, 46-60 The Broadway 1-20 ST JOHNS AVENUE GLADSTONE PARADE St Johns Avenue 88-96 Gladstone Parade 4-9 (Edgware Road) WATFORD ROAD GOOSEACRE Watford Road 201-223 Kenton Road 425-447 WATFORD ROAD HAMILTON ROAD Court Parade 1-17, 32-38 Hamilton Road 1a-1d WEMBLEY HILL BURNLEY ROAD Harrow Road 293-311, 300-322 Burnley Road 78-82 WILLESDEN HIGH RD HARROW ROAD Willesden High Road 254-290, 271-285 Harrow Road 875-881 WILLESDEN LANE HAY LANE Willesden Lane 72-98 Hay Lane 5-27

HEATHER PARK Heather Park Parade 1-10 APPENDIX SH2: DEFINITION OF EALING ROAD TOWN CENTRE KINGSBURY GREEN Kingsbury Road 235-275 Ealing Road Town Centre is defined as follows:-

KILBURN LANE Ealing Road 134 - 242a Kilburn Lane W9 291-305 Ealing Road 99-147 Eagle Road 1 MALVERN ROAD/SHIRLAND ROAD Haynes Road All properties Shirland Road 197-201 Malvern Road 1-41

MONKS PARK Harrow Road 2-74

NORTH WEMBLEY East Lane 181-215

OXGATE Oxgate Parade, Coles Green Rd. 1-9

QUEENSBURY

Brent Unitary Development Plan - 2004 192 TOWN CENTRES & SHOPPING

Brent Unitary Development Plan - 2004 193 TOWN CENTRES & SHOPPING

N.B. This map is indicative only

Brent Unitary Development Plan - 2004 194 TOURISM, ENTERTAINMENT & THE ARTS

TOURISM,ENTERTAINMENT 9 & THE ARTS

Page 9.1 INTRODUCTION

9.1 INTRODUCTION 195 9.1.1 Policies in this chapter are concerned with tourism, entertainment and the arts, which embrace a wide range of activities. These 9.2 BACKGROUND 196 include arts, culture and entertainment (ACE) facilities which range from high culture to popular entertainment. These activities 9.3 STRATEGIC CONTEXT 196 include the visual arts (art, sculpture, photography), the literary arts (books and publishing), and the performing arts and enter- 9.4 POLICY OBJECTIVES 196 tainment (music, film, theatre, dance, radio, television / video), as well as including popular entertainment such as bingo or ice 9.5 BOROUGH STRATEGY 196 shows. This chapter also encompasses hotel development. It is the intention of this chapter to include only those facilities open to visiting members of the public. POLICIES & PROPOSALS 9.1.2 With the exception of the- 9.6 LOCATION OF TOURIST, VISITOR AND atres, land uses encompass- ACE USES 197 ing the above facilities will generally fall within the D2 TEA1 LOCATION OF LARGE-SCALE TOURIST, VISITOR use class (assembly and AND ACE USES 197 leisure) and are covered by policies in this chapter. TEA2 LOCATION OF SMALL-SCALE TOURIST, VISITOR However, policies applying AND ACE USES 197 to indoor sports facilities falling within the D2 use 9.7 PROTECTION OF EXISTING ARTS, class are covered by the CULTURAL AND ENTERTAINMENT open space chapter. Special FACILITIES 198 policies apply to assembly and leisure uses within the TEA3 PROTECTION OF EXISTING ACE FACILITIES 198 Wembley Regeneration Area inset plan chapter. A number of D1 uses (non-residential institutions) attract large numbers of visitors 9.8 PUBLIC ART 198 but are most conveniently covered by the Community Facilities chapter. Special policies towards development with a mix of land TEA4 PUBLIC ART 198 uses are set out in the Built Environment chapter.

9.9 SHORT TERM USE OF VACANT BUILDINGS 9.1.3 Tourism and associated arts, culture and entertainment facilities FOR ACE ACTIVITIES 198 are playing an increasingly prominent role in the London economy, with long term economic benefits. They also have an impor- TEA5 SHORT TERM USE OF VACANT BUILDINGS FOR tant role to play in the local economy, providing both direct and ACE FACILITIES 199 indirect employment opportunities, as well as supporting a wider range of local services and facilities that can be used by local res- 9.10 HOTELS 199 idents. Thus tourism and ACE facilities can contribute significantly to achieving local objectives, in particular: TEA6 LARGE-SCALE HOTEL DEVELOPMENT 199 • The vitality of the community; TEA7 SMALL-SCALE HOTEL DEVELOPMENT 200 • The local economy by direct employment; • By maintaining and improving the attractiveness of the area TEA8 HOTELS - ACCESS FOR DISABLED PEOPLE 200 to commerce and industry; and, • By enhancing the life and tourism of the Borough's town centres.

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9.2 BACKGROUND RPG3 Strategic Guidance for London Planning Authorities (May 1996) 9.2.1 Brent's premier visitor attraction is Wembley Stadium, to be rebuilt as the New National Stadium, and the associated facilities 9.3.4 RPG3 makes reference to the ability of arts, culture and entertain- of Wembley Arena, Conference Centre and Exhibition Halls. The ment activities to contribute significantly to the life and attractive- 'Asian jewellery' quarter in Ealing Road also attract visitors on a ness of London, as well as being important employers of labour in regional, national and international basis compared with most of their own right. Boroughs' are asked to identify areas where Brent's other visitor attractions which attract more local visitors. these activities can be concentrated, and ensure that policies Local visitor attractions in Brent include the Welsh Harp and maintain a quality environment (to further enhance and encour- Fryent Country Park, the Sunday Market in Wembley, the Kilburn age such activities). Particular emphasis is placed on the need Tricycle Complex and the Brent Arts Centre, Gladstone Park. for Boroughs to demonstrate flexibility in dealing with applications, in particular where mixed uses would be beneficial. The 9.2.2 Adequate hotel accommodation is important to serve both tourists guidance points out the considerable opportunities for arts related and business visitors to Brent. The government has set a target, activities to be located in and around town centres, but that out of in RPG3, for 10,000 additional hotel rooms in London, based on centre, car-dependent leisure and entertainment facilities should forecasts of demand (predominantly from overseas visitors), be discouraged. The guidance also stresses that the Wembley between 1995 and the end of 2000. The Department of Culture Stadium complex is an area capable of accommodating high vol- Media and Sport in their Tourism Strategy ‘Tomorrow’s Tourism’ umes of spectators to major events because of its good accessi- speaks of a further 10,000 rooms between 2001 and the end of bility to public transport. 2009. Even if this growth does not materialise, hotel development in Brent may still increase. This is due to pressure for hotel devel- 9.3.5 RPG3 also makes reference to tourism and the necessity to opment in Central London being pushed out towards Boroughs' embrace opportunities vital to the future success of the capitals' with good transport links, such as Brent. There are a significant economy. Measures to improve the quality of London's environ- number of hotel rooms in outstanding permissions in the ment and transport systems will assist in making it more attractive Wembley Stadium Area. to visitors, as well as encouraging a more positive approach to the enhancement of tourist sites and development of visitor facilities.

9.3 STRATEGIC CONTEXT 9.3.6 In respect of hotels, RPG3 asks boroughs' to encourage development for a range of accommodation in areas accessible to public 9.3.1 Government policy on tourism, entertainment and the arts is set transport, and which benefit the local economy. Boroughs' should out at a national level in Planning Policy Guidance notes on Town consider the re-use of office space for hotels (in appropriate loca- Centres and Retail Developments (PPG6) and Tourism (PPG21). tions), and include proposals for conference and exhibition space Of particular importance is PPG6 which emphasises the 'sequen- on appropriate sites. tial approach' to selecting sites for development attracting significant numbers of people. Strategic policy is also included in Strategic Guidance for London Planning Authorities (RPG3) 9.4 POLICY OBJECTIVES issued in May 1996. The key features of these guidance notes relevant to tourism, entertainment and the arts are set out below. 1. To use new tourist and visitor attractions, hotels and ACE facilities as a base for regenerating the Boroughs' town cen- PPG6 Town Centres and Retail Developments (June 1996) tres where they can support and regenerate the local economy; 9.3.2 PPG 6 emphasises the sequential approach to selecting sites for 2. To promote new tourist and visitor attractions, hotels and ACE development attracting significant numbers of people, including facilities, provided that such developments maintain the leisure uses and hotels. This is summarised in paragraph 8.3.4 of amenity enjoyed by nearby residents; the Town Centres & Shopping chapter. The need for a plan-led 3. To protect existing tourist, entertainment and arts facilities in approach to promoting development in town centres, both good locations and ensure that they are open to all of Brent's through policies, and the identification of locations and sites for communities; and development, is emphasised. 4. To promote the provision of public art in the Borough.

PPG21 Tourism (November 1992) 9.5 BOROUGH STRATEGY 9.3.3 PPG 21 recognises that the planning system should facilitate and encourage tourist provision while tackling any adverse effects of 9.5.1 The planning issues that tourist, visitor and arts uses and hotels existing tourist activity in a positive manner. present: potential impact on residential amenity, traffic impact, etc., are addressed in a strategy to direct them to Brent's town centres in line with the 'sequential approach'. Edge-of-centre locations will only be considered if this is not possible. The development of large-scale tourist, visitor and arts uses and hotels will only be considered in out-of-centre sites in exceptional circum-

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stances where an equivalent level of public transport accessibility can be achieved and the amenity of residents maintained. TEA1 LOCATION OF LARGE SCALE TOURIST, Smaller-scale tourist and visitor attractions, hotels and ACE facili- VISITOR AND ACE USES ties may be considered in residential areas where there is no unacceptable loss of residential amenity. Leisure facilities are The location of tourist, visitor and ACE uses attracting particularly appropriate within some mixed-use development, as significant numbers of members of the public should this can reduce the need to travel. The reduction of the need to accord with the sequential approach (Policy STR2) and travel, especially for large scale leisure uses, will only come about comply with Policy SH3. through the application of the plan's restraint-based parking standards and developments being designed to facilitate public trans- Such development should have an acceptable impact port, and being friendly to pedestrians and cyclists. on residential amenity, and include measures to limit disturbance where appropriate.

POLICIES AND Development of these uses within the Wembley PROPOSALS Regeneration Area should comply with the special policies in the Wembley Inset Chapter.

9.6 LOCATION OF TOURIST, VISITOR Contributions will be sought to help meet the needs of AND ACE USES the increase in the number of visitors.

LARGE-SCALE USES SMALL-SCALE USES 9.6.1 Large-scale tourist, visitor and ACE uses will be encouraged to locate in town centres in line with the sequential approach to selecting sites for development. This is because town centres 9.6.4 Small-scale tourist, offer a wide range of supporting facilities and are most accessible visitor and ACE in terms of public transport. Moreover, large-scale visitor attrac- uses are often best tions, hotel and ACE activities can play an important part in the located in town cen- regeneration of town centres and act as a magnet to other such tres. However, it is facilities. They are generally not suitable in residential areas on recognised that this account of the noise, traffic and parking problems they may gen- may not always be erate. Large-scale tourist, visitor and ACE uses can be defined appropriate and that by either the area of floor space or by virtue of the number of visi- some sites with tors attracted to it. The sequential approach to development moderate or better applies to change of use and extensions as well as new develop- public accessibility ment. may be suitable. Proposals for small-scale tourist, visitor and ACE uses may there- 9.6.2 The plan as a whole sets down preferred locations for major fore be located in residential areas but residential amenity should leisure developments in town centres, but recognises the particu- be protected. lar role the Wembley Stadium Area may play in the provision of large-scale leisure facilities, in order that it can be regenerated to the benefit of the Borough and London as a whole. Policy TEA1 TEA2 LOCATION OF SMALL-SCALE TOURIST, therefore needs to be read alongside policies WEM1 and WEM3 VISITOR AND ACE USES in the Wembley Regeneration Area chapter. The location of large and small scale hotel Proposals for small-scale tourist, visitor and ACE uses development are dealt should be located in or adjoining town or district cen- with in policies TEA6 and tres. Where this is not appropriate, small-scale TEA7 respectively. tourist, visitor and ACE uses should be located on sites with moderate or better public transport accessibility 9.6.3 Contributions will be (as defined in the Transport Chapter section 6.7) and sought from large-scale which are easily and safely accessible by cycling and development to help pro- walking. vide facilities to meet the needs of the increased When proposed within residential areas or in mixed- numbers of visitors to the use schemes with residential accommodation, this is area, such as extra sign- subject to the protection of neighbourhood amenity. posting, improved pedestrian and cycling facilities, public toilets, and so on.

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9.7 PROTECTION OF EXISTING ARTS, 9.8.3 In view of the integral part that ACE can play in the economic and CULTURE AND ENTERTAINMENT social regeneration of the Borough, it is appropriate to consider FACILITIES the provision of ACE uses in most large scale mixed commercial developments. The Council will, in appropriate circumstances, 9.7.1 There has sometimes been a difficulty in maintaining and creating secure such provision through the use of planning obligations. the space for the carrying out of specific types of ACE activity, such as cinemas, theatres and visual arts. This is because of the competition from other land uses which can often outbid such TEA4 PUBLIC ART ACE activities. The Council will encourage the development of new ACE proposals for these uses, and resist the loss of existing In large-scale developments public art or Arts, Culture facilities, unless their loss is compensated for. and Entertainment facilities will be sought either within the scheme or nearby.

TEA3 PROTECTION OF EXISTING ACE FACILITIES

The loss of ACE facilities for performance or display of 9.9 SHORT TERM USE OF VACANT art will not be permitted unless suitably located BUILDINGS FOR ACE ACTIVITIES replacement facilities are provided, or some other form of relevant compensatory provision is made. 9.9.1 The Council recognises the important role local voluntary and community groups play in the arts. The Council has identified a shortage of buildings for non-commercial ACE activities such as art studio space. It has attempted to help various community arts groups to find premises. The problem of voluntary groups finding suitable accommodation has been exacerbated by new financial arrangements which have accompanied Local Management of Schools and which have increased hiring costs beyond a level that many local arts groups can afford.

9.9.2 It may prove possible for the Council to lease out some of its buildings for ACE uses and to encourage the private sector to do the same where premises could be made available on a short- term basis pending future proposals. Such short-term or temporary occupation of buildings for ACE purposes will of course be encouraged only when the particular use in question is acceptable in terms of its impact on the surrounding area. Where this is 9.8 PUBLIC ART the case, other policies in the plan may nevertheless preclude a permanent planning permission for the ACE use (for example: 9.8.1 Developments can benefit significantly from the provision of suit- strategic employment areas requires land and buildings generally able works of art or artistic features. In recent years, the Council to be retained for employment purposes). In such circumstances (through various types of regeneration funding) has managed to it may, however, be possible to grant temporary permissions for both fund works of public art as well as secure public art in devel- occupation by ACE uses of buildings that may otherwise lie opments within the Borough through planning obligations. vacant for a period of time.

9.8.2 It is the Council's intention, therefore, that in new developments the provision of art or artistic features should be considered as a matter of good planning practice. The Arts Council suggest that on development a sum of up to 1% of the development cost is set aside to provide works of art, craft or decoration. Given the lack of public art in Brent and the need to improve the public realm of the Borough, particularly in town centres, the Council applies a public art policy in suitable developments. This is not intended to impose pieces of sculpture on an unsuspecting public. Public art can take a variety of forms: examples include sculpture, paint- ings, murals, street furniture, metalwork, floor, wall and window designs such as tiling, paving and stained glass. The design and execution of public art should fully involve the local community in which it is located, and be properly related to the wider public realm or buildings in the area.

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TEA5 SHORT TERM USE OF VACANT BUILDINGS FOR ACE FACILITIES

The use and refurbishment of vacant or short life property for arts, cultural or entertainment activities will be considered favourably provided that the particular uses are compatible with the surrounding area. Planning permission may be granted on a temporary basis.

9.10 HOTELS 9.10.1 For the purposes of this plan, the definition of Hotels covers uses within the C1 (hotels) use class, such as commercial serviced accommodation including guest houses and bed and breakfast establishments open to visiting members of the public on a short stay basis. Many premises described as 'hotels' in Brent are in fact in use as accommodation for homeless persons. This is a separate hostel use covered by policies within the Housing chapter (Policy H27).

9.10.2 At present there are 15 mostly small-scale hotels operating in the TEA6 LARGE-SCALE HOTEL DEVELOPMENT Borough, and a number of larger hotels in Wembley. Further hotel development will be considered favourably where it is locat- Planning permission will be granted for large-scale ed in town centres or at the edge of town centres, where it has hotels where: good public transport accessibility or where this can be achieved. (a) The site is located within a town centre, edge-of- Other appropriate locations include the National Stadium Policy centre or the National Stadium Policy Area Area (see Wembley Regeneration Area chapter). Large-scale (WEM3); or hotels are also considered acceptable where they adjoin a public transport interchange because of the excellent public transport (b) It utilises redundant office space in locations in the above areas or elsewhere with good or very good accessibility (See also policy TRN6). In addition to setting out public transport accessibility (as defined in the locational criteria, policy TEA6 requires that proposals for large- Transport Chapter section 6.7); or scale hotel development also comply with the Council's coach and taxi parking standards, that the proposal does not have an (c) The site adjoins a public transport interchange adverse effect on the residential amenity or character of the area, where intensive development is permitted (Policy TRN6); or does not result in the loss of accommodation best used for permanent residential purposes. And where:

(d) The proposal does not have an unacceptable traffic 9.10.3 The locational requirements for small-scale hotel developments impact (Policy TRN1), and complies with Policy are different as they impact less on surrounding areas and do not TRN30 on taxi and coach parking; require such a high level of public transport accessibility as large- (e) The proposal does not have a significant adverse scale developments. Small-scale hotel development may be impact on the residential amenity or character of more suitable in residential areas, subject to impact on residential the area; and amenity. A minimum floorspace limit is necessary to prevent the conversion of unsuitable smaller houses. (f) The proposal does not result in the loss of land or accommodation that can best be used, with or without adaptation, for permanent residential purposes.

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TEA7 SMALL-SCALE HOTEL DEVELOPMENT TEA8 HOTELS - ACCESS FOR DISABLED PEOPLE Small-scale hotels will be permitted where they meet the following criteria: Where appropriate, the provision of a comparable standard of access for disabled people as set by the (a) The proposal does not result in the loss of a site or accommodation whose best use is for residential building regulations, will be sought in hotel extensions purposes, or would not lead to loss of a hostel or conversions, which, when complete, would provide which is needed for homeless accommodation for 20 or more bedrooms and would not be subject to Brent residents (Policy H27); those regulations.

(b) By reason of scale and intensity of use it does not have an adverse impact on the residential amenity or character of the area;

(d) It is in an area with moderate or better public transport accessibility (as defined in the Transport Chapter section 6.7);

(e) The design is sensitive to, and compatible with, the character of the surrounding area;

(f) It does not create highway safety or traffic problems (Policy TRN1); and

(g) Preferably they should be located on the London Distributor road network (Policy TRN20).

ACCESS FOR DISABLED PEOPLE IN HOTELS

9.10.4 The Council wishes to ensure that all new hotel development in the Borough provides for the access needs of all, including disabled people. Part M of the Building regulations 1991 (1992 edition) required that one out of every twenty hotel bedrooms should be suitable for use by disabled people. This applied to new hotels and extensions to them. There was no requirement to provide higher access standards than exist in the main building if this is not the case. There was also no obligation to improve disabled access arrangements after carrying out alterations or if the hotel is created by conversion.

Because of the lack of existing provision of hotel bedspaces for disabled people, and the nature of the existing stock, the Council sought a comparable level of access for disabled people, when a building was altered, converted or created through a change of use, outside of the scope of the 1991 building regulations.

From 1 May 2004 the revised Approved Document Part M (2004 edition) of the Building regulations 2000 'Access to and use of buildings' applies to new hotels, extensions and materials alterations, including change of use of a room. Part M, 2004, Section 4.4 states 'A proportion of the sleeping accommodation in hotels, motels and student accommodation should be designed for independent use by wheelchair users. The remainder should include facilities that make them suitable for people who do not use a wheelchair, but may have mobility, sensory, dexterity or learning difficulties.'.

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OPEN SPACE, SPORT & 10 RECREATION

Page NATURE CONSERVATION IMPORTANCE 211

10.1 INTRODUCTION 202 OS13 DEVELOPMENT ON SITES OF BOROUGH (GRADE II) AND LOCAL NATURE CONSERVATION IMPOR- 10.2 BACKGROUND 202 TANCE 211

10.3 STRATEGIC CONTEXT 203 OS14 WILDLIFE CORRIDORS 211

10.4 POLICY OBJECTIVES 205 OS15 SPECIES PROTECTION 212

10.5 BOROUGH STRATEGY 205 OS16 WELSH HARP & FRYENT COUNTRY PARK 212

POLICIES & PROPOSALS OS17 NEW WILDLIFE HABITATS 213

10.11 INDOOR SPORTS AND RECREATION 10.6 STRATEGIC OPEN SPACE 205 AND OTHER OUTDOOR USES 213

OS1 DESIGNATION OF MOL 205 OS18 CHILDREN’S PLAY AREAS 213

OS2 ACCEPTABLE USES ON MOL 205 OS19 LOCATION OF INDOOR SPORTS FACILITIES 214

OS3 DEVELOPMENT ON MOL 206 OS20 SITE SPECIFIC SPORT PROPOSALS 214

OS4 AREAS OF OPEN CHARACTER 206 10.12 METROPOLITAN WALKS 214

OS5 GREEN CHAINS 206 OS21 METROPOLITAN WALKS 214

10.7 PUBLIC OPEN SPACE 207 10.13 ALLOTMENTS 215

OS6 PUBLIC OPEN SPACE 207 OS22 ALLOTMENTS 215

OS7 PROVISION OF PUBLIC OPEN SPACE 208 10.14 CEMETERIES 215

10.8 OUTDOOR SPORTS PITCHES AND OS23 CEMETERIES & CREMATORIA 216 SPORTS FACILITIES 208 APPENDIX OS1 SCHEDULE OF SITES OF NATURE OS8 PROTECTION OF SPORTS GROUNDS CONSERVATION IMPORTANCE 217 209 MAP OS1 LOCAL LEVEL OPEN SPACE AND OPEN SPACE OS9 DUAL USE OPEN SPACE 210 DEFICIENCY 218

OS10 ACCESS TO SPORTS FACILITIES 210 MAP OS2 DISTRICT LEVEL OPEN SPACE AND OPEN SPACE DEFICIENCY 219 10.9 OTHER URBAN GREEN SPACE 210 MAP OS3 AREAS OF NATURE CONSERVATION DEFICIENCY OS11 URBAN GREENSPACE 211 220

10.10 WILDLIFE AND NATURE CONSERVATION 211

OS12 DEVELOPMENT ON SSSIS AND SITES OF METROPOLITAN AND BOROUGH (GRADE I)

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Council's Sports Strategy (1999), the Sports and Leisure Development Framework for Brent (2003) and the Brent Playing Pitch Strategy (2004). 10.1 INTRODUCTION 10.1.4 Although Brent is, in general, a densely developed urban area, 10.1.1 This chapter contains policies that aim to address the need to there are parts of the Borough which have a more natural charac- retain open spaces in the Borough, create new green areas, ter and these open spaces and amenity areas, including the vari- improve recreational facilities, and access to them, and preserve ous waterways, provide a welcome contrast with the surrounding nature conservation sites and wildlife habitats. These policies built up areas. Brent is fortunate in that it contains a number of can be seen as part of a broader approach to preserving and sites of major metropolitan significance for nature conservation enhancing the environment of the Borough in support of the and wildlife with many other areas offering great potential for fur- Council's Environmental Policy and improving sport and recre- ther creation of wildlife habitats. Natural and wildlife habitats are ation through the Borough's Sports Strategy. an important educational, recreational and social resource for the Borough: good sites are a scarce resource in London and 10.1.2 Open Space plays an important part in the lives of the Borough's deserve protection. Nature conservation is a land use in its own residents. Not only does it meet recreational needs but it also right and must be considered very carefully whenever develop- contributes to the landscape and nature conservation value of the ment and land use change are proposed. Borough. It is essential for everyone's well-being that there should be green 'lungs' in urban areas such as Brent that are densely developed and have no Green Belt land. Although the 10.2 BACKGROUND Borough contains areas of Metropolitan Open Land such as the Welsh Harp, Fryent Country Park and Northwick Park, which pro- 10.2.1 A trend in this and many other London boroughs has been the vide substantial breaks in the built-up area and are of significance growing pressure to develop private and education sports to London, it suffers from a considerable deficiency of local parks grounds which are no longer required by their owners. The loss and small areas of public open space. According to recognised of such facilities has accelerated over recent years (over 36 standards it is the southern part of the Borough that is most defi- hectares (89 acres) of open space in Brent, mostly in the form of cient in open space and the Borough as a whole is under-provid- sports grounds, has been lost to development since 1993). Their ed with built sports facilities. Most of the facilities within Brent's continued loss is not sustainable. The emphasis in this Plan is to open spaces are in need of improvement. conserve remaining sports ground use, in accordance with the Brent Playing Pitch Strategy recommendations. It is a critical 10.1.3 Nationally there has been a general increase in both leisure time resource and now must be protected as such. and expenditure on leisure activities. This has been accompanied by increased participation in a wider range of sporting and 10.2.2 As well as a general lack of open space there are also insufficient recreational activities. The Council's aim is to extend the provi- children's play areas in the Borough, and many of the existing sion and widen the range of leisure, sport and recreation facilities ones are of a very poor quality. There is a need to encourage the to meet the needs of the Borough, but recognising that the provision of new play areas, particularly in those areas most defi- Council's own resources are very limited. The Council's planning cient in play space, and the improvement of existing ones. strategy towards sport and recreation facilities is informed by the

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10.2.3 Demand for allotment space, which had fallen for a number of • Promotion of social inclusion and community cohesion; years, has recently begun to substantially increase and the • Health and well being; and Council is endeavouring to improve the quality of existing sites • Promoting more sustainable development. that are actively cultivated. When allotments are dis-used, proposals for development will be considered providing other allot- 10.3.4 PPG17 recognises that while local authorities should determine ment sites or open spaces are improved by way of compensation the levels and types of amenity space their residents require. for their loss. They should do so through “...robust assessments of the existing and future needs of their communities for open space, sports and 10.2.4 In addition to the general shortage of open space, certain groups recreational facilities.” (para. 1). Detailed advice to their under- in the community do not have equal access to the sports and taking is provided in Assessing Needs and Opportunities (ODPM, leisure facilities in the Borough (notably disabled people, women 2002). and members of ethnic minority groups). The Plan needs to consider how to improve access for the community as a whole, espe- 10.3.5 Such assessments should consider locational accessibility in cially those groups identified by Sport England as having low par- accordance with Planning Policy Guidance Note 13 Transport, ticipation rates. which places emphasis on “...open space and recreational facilities in locations likely to be accessible without use of a car.” 10.2.5 It is important to recognise that not all new sports and recreation (PPG13, para. 20). facilities require open space sites. Some intensive indoor sports and recreation pursuits, such as health and fitness clubs, are best 10.3.6 Planning Policy Guidance Note 2 Green Belts (PPG2, 1995) pro- accommodated in town centres where they would meet the motes the protection and the maintenance of the open character sequential approach advocated by the Government as well as of large tracts of Green Belt and Metropolitan Open Land desig- assisting in the achievement of the Council's regeneration objec- nated primarily to prevent urban sprawl and the merging of urban tives. settlements.

10.3.7 This national planning guidance is reiterated and reinforced at the 10.3 STRATEGIC CONTEXT regional level in Regional Planning Guidance for the South East (RPG9, 2001) which advises that local plans should properly 10.3.1 The Government’s overarching strategy for sustainable develop- recognise the contribution which “...open spaces can make to ment recognises the key importance of protecting and enhancing urban areas in terms of their recreational, nature conservation the natural environment, including open space for passive and and wider environmental and social benefits...” (Policy Q2a). active recreation, such as sport, and its biodiversity. A fundamental principle of sustainable planning which is endorsed, at nation- METROPOLITAN POLICY CONTEXT al, regional and metropolitan levels as outlined below: 10.3.8 Strategic Guidance for London Planning Authorities (RPG3, 1996) recognises that “One of London’s greatest assets is its OPEN SPACE framework of green space and open land.” (para. 7.1). Boroughs NATIONAL AND REGIONAL POLICY CONTEXT are advised to;

10.3.2 A Better Quality of Life: a Strategy for Sustainable Development “...analyse critically the characteristics and uses of open space, for the UK (1999) emphasises that existing open space should be with particular reference to their amenity value, ecological contri- protected and stresses that “Opportunities should be taken to cre- bution and public access to them. Increasing pressures for active ate more green spaces...” (para. 7.66). The recognition that open leisure and recreational pursuits need to be considered against space “...can make a difference to the quality of people’s lives in the value of the areas for passive enjoyment and nature conser- urban settings.” is acknowledged in the Government’s urban vation.” (para. 7.2). renaissance strategy, Our Towns and Cities: the Future (2001). 10.3.9 RPG3 advises that open space of strategic value to London 10.3.3 Detailed planning guidance on protecting and promoting the role should be designated as Metropolitan Open Land (MOL) to which of all types of open space is provided in Planning Policy Guidance a presumption against inappropriate development applies. RPG3 Note 17 Planning for Open Space, Sport and Recreation (PPG17, also urges authorities to consider the valuable role of ‘green 2002) which declares that; chains’, consulting with neighbouring planning authorities as appropriate. Boroughs are also advised to identify and reduce “Open spaces, sport and recreation all underpin people’s quality ‘areas of open space deficiencies’. of life. Well designed and implemented planning policies for open space, sport and recreation are therefore fundamental to deliver- 10.3.10 The draft London Plan identifies the protection of the natural envi- ing broader Government objectives.” ronment as a key constituent element - ‘the city’s breathing spaces’ - in its overarching ‘Compact City’ strategy. The draft The Government’s objectives include: Plan’s strategic Policy 2A.10 aims to protect and promote London’s network of open space while draft Policy 2A.11 similarly • Supporting an urban renaissance; protects its aquatic counterpart, the Blue Ribbon network.

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Detailed advice as to their protection and promotion is provided in “...sports and recreational facilities have a vital role to play in pro- the Guide to Preparing Open Space Strategies (GLA, June moting healthy living and preventing illness, and in the social 2003). development of children of all ages through play, sporting activities and interaction with others.” (Page 4).

Hence PPG17 stresses that; NATURE CONSERVATION AND WILDLIFE

NATIONAL AND REGIONAL POLICY CONTEXT “Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertak- 10.3.11 The UK Biodiversity Action Plan (1994) and the more recent bio- en which has clearly shown the open space or the building and diversity strategy for England (Working with the Grain of Nature, land to be surplus to requirements.” (para. 10). DEFRA, 2002) detail the national strategy on the implementation of the UN Biodiversity Convention (and similar international com- 10.3.17 PPG17 advises planning authorities of their responsibilities to mitments). take full account of communities existing and future need for recreational space and to resist development pressures where 10.3.12 Planning Policy Guidance Note 9 Nature Conservation (PPG9, these conflict with the wider public interest. It specifically notes 1994) stresses the importance of taking into account nature con- that all types of playing fields are of significance for their recre- servation objectives in urban areas where there is wildlife of local ational and amenity value and for their contribution to green as well as national importance and to ensure that both are pro- spaces in towns. PPG17 recommends that sports and recre- tected in UDP's. Plans should be based on adequate information ational facilities of high quality or of a particular value to a local about species and habitats. UDP's should also consider the pro- community should be afforded protection through appropriate vision of new habitats. policies in plans.

10.3.13 Planning Policy Guidance Note 12 Development Plans (PPG12, 10.3.18 PPG17 stresses that playing fields should normally be protected 1999) emphasises the role plans have to play in enhancing biodi- to meet the long term needs for sport in the community. The prin- versity and protecting soil and land resources. Guidance which is ciple exceptions being where: further emphasised in RPG9 Policies E1& 2. • The proposed development is ancillary to the sporting or METROPOLITAN POLICY CONTEXT recreational use of the site; • The proposed development affects land which is incapable of 10.3.14 RPG3 advises boroughs to ensure that nature conservation forming a playing pitch (or part thereof); objectives are taken into account where there is a local nature • The loss of playing fields would be offset through the provi- conservation interest. The Guidance recommends the use of the sion of comparable alternative facilities ideally representing a London Ecology Unit's (LEU) sites hierarchy and LEU Ecology qualitative improvement; or Handbooks for each borough to inform the drafting of appropriate • The proposed development is for an outdoor or indoor sports policies (para. 7.24). facility of sufficient community benefit to outweigh the loss of the playing field. (Para. 15) 10.3.15 The Mayor of London has published a statutory Biodiversity Strategy (Connecting with London’s Nature, 2002) which is sup- 10.3.19 RPG9 Policy E6 further emphasises the need to properly plan for ported by The draft London Plan, Policy 3D.12 Biodiversity and sport and recreational provision to meet diverse community nature conservation. This requires boroughs to protect Sites of needs. Metropolitan Importance for Nature Conservation and to similarly identify and protect Sites of Borough and Local Importance for METROPOLITAN POLICY CONTEXT Nature Conservation. Detailed implementation advice is provided in Design for Biodiversity (London Development Agency & 10.3.20 RPG3, recognising that sport and recreation “...improve the quali- Partners, 2003). ty of life...” (para. 7.20), emphasises the importance of devising land use policies to take account of sport and recreation facilities including playing fields based on Sport England’s Regional SPORT AND RECREATION Strategy and Playing Pitch Strategy. Sport England are now statutory consultees on applications involving most forms of NATIONAL AND REGIONAL POLICY CONTEXT. sports facility.

10.3.16 Planning Policy Guidance Note 17 Planning for Open Space, 10.3.21 The draft London Plan, Policy 3D.6, sets out the Mayor’s strategic Sport and Recreation (PPG17, 2002) emphasises the objectives for sports which recognise that Government’s vision that; “London needs to develop a wide range of high quality but affordable sports facilities, which are accessible to all sections of the community including disabled people. New provision should be focussed in areas with the greatest identified need.” (3D.32).

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10.4 BOROUGH POLICY OBJECTIVES “...resist development on Metropolitan Open Land (MOL) unless it is clearly ancillary to the enjoyment of open space. Ancillary uses 10.4.1 In the face of the trends and pressures outlined above, the main will only be acceptable where they do not have an adverse impact objectives for open space and leisure provision are listed below: on the openness of MOL.” (Policy 3D.10).

1. Preserve and enhance the open nature of large strategic open 10.6.3 Both RPG3 and The draft London Plan support LPAC's (now spaces and protect other smaller parks and public open spaces replaced by the GLA) Strategic Advice which contains indicators from inappropriate development; for the identification of MOL. Metropolitan Open Land is defined 2. Protect and enhance those sites which have a nature conserva- as any strategic open land, publicly or privately owned, with or tion and wildlife value and to create new ones where appropri- without public access, which fulfils one or more of the following ate. To preserve and enhance habitats to ensure biodiversity; criteria: 3. Prevent the further loss of sports grounds, sports pitches and other sporting facilities and reduce the deficit of sports pitches 1. It contributes to the physical structure of London, clearly distin- in the Borough; guishable from the built up area; 4. Reduce areas of public open space deficiency and improve 2. It provides open air facilities for leisure, recreation, sport, arts, overall access to open spaces, notably in the south of the cultural activities and tourism which serves the whole or signifi- Borough; cant parts of London; 5. Improve the quality and coverage of appropriate facilities such 3. It contains features or landscape of historic, recreational, nature as play areas; conservation or habitat interest of value at a metropolitan or 6. Increase opportunities for those groups denied access to exist national level. ing sports and recreation facilities such as disabled people, women and ethnic community groups; OS1 DESIGNATION OF MOL 7. Extend the dual use of school playing fields, where appropriate; 8. Provide a good coverage of sports centres across the Borough The following areas are designated and protected as and new facilities in appropriate locations linked to the econom- Metropolitan Open Land: ic aims of the plan. (a) Fryent Country Park, including Barn Hill open space and adjoining sports grounds (part of the former LT sports ground at Old Kenton Lane and Kingsbury 10.5 BOROUGH STRATEGY Green Primary School playing fields) and allotments at Old Kenton Lane; 10.5.1 The overall strategy towards open space and recreation is to set (b) Welsh Harp, Silver Jubilee Park and Neasden standards for their provision and to protect and enhance the stock Recreation Ground; of open space in the Borough. It also seeks the provision of new and improved open space through the development process in (c) Northwick Park including the Ducker Pond; areas where there are the greatest deficiencies, in areas suffering (d) Alperton Cemetery; and from social exclusion and in areas in need of regeneration. (e) Gladstone Park. Protection of existing sports pitch provision is required and improvements in the quality and quantity of such provision will be These are defined on the proposals map. sought.

10.6.4 RPG3 points to PPG2 on Green Belts for a list of appropriate POLICIES AND uses on MOL: PROPOSALS OS2 ACCEPTABLE USES ON MOL

10.6 STRATEGIC OPEN SPACE The predominantly open character of Metropolitan Open Land will be preserved. Uses which may be METROPOLITAN OPEN LAND acceptable on MOL are restricted to: • Public and private open space and playing fields; 10.6.1 Certain open spaces in the Borough have a strategic importance and a significance (generally because of its size and catchment • Agriculture, woodlands and orchards; area) extending beyond the Borough's boundaries. The open • Rivers, canals, reservoirs, lakes, docks and other character of these areas will be preserved by designating them as open water; Metropolitan Open Land (MOL). The status of MOL was • Golf courses; enhanced in RPG3 which conferred on it a similar presumption against development as exists in the Green Belt. • Allotments and nursery gardens; • Cemeteries; and 10.6.2 A presumption reiterated and reinforced in The draft London Plan with a commitment to; • Nature conservation.

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10.6.5 The above list is a broad indication of the type of uses acceptable ignation is to safeguard open land from built development, to on MOL. However, not all uses are acceptable on all sites. For maintain and improve access (including access for disabled peo- example, while golf courses are normally an acceptable use, this ple) through the chains to provide opportunities for informal recre- may not be so if they conflict with other MOL uses such as nature ation, to enhance visual amenity and to safeguard their nature conservation or where they conflict with policies protecting areas conservation value. The Council will also encourage provision of of high landscape value (see for example Policy OS16). the missing links in the chains where they are not continuous, as well as linking chains across borough boundaries. The Council 10.6.6 Occasionally limited development in the form of buildings may be will consult and co-ordinate action with adjoining boroughs. required to enhance the use of MOL for open space use. For example, changing rooms may be necessary to increase the 10.6.9 Green Chains are identified on the Proposals Map. They are not recreational value of a particular open space. Policy OS3 confined to the boundaries of the canal and river but also include ensures that building on MOL is limited to such circumstances. adjoining open spaces. The Council has a long term objective of providing a series of these linked open spaces along the River Brent. The Council also aims to increase the number and quality OS3 DEVELOPMENT ON MOL of open spaces along the Grand Union Canal (see also Policy BE14) to enhance its value for wildlife and tourism. Both the Within Metropolitan Open Land development will not River Brent and Grand Union Canal will form part of the proposed be permitted unless: West London Waterway Walks, as agreed by local authorities and interested bodies, with the aims of improving access, signage, the (a) Any proposed building or use is complementary to the land uses listed in Policy OS2; and natural environment and landscape as well as conserving waterside buildings and encouraging waterway improvements. (b) Any development is small in scale and is required to Development along the River Brent is also subject to the Plan’s preserve or enhance activities associated with the policy on the prevention of flooding (Policy EP12). particular open space. 10.6.10 The Council’s implementation strategy for the River Brent, the Grand Union Canal and other Borough waterways will be AREAS OF OPEN CHARACTER informed by the Mayor’s Blue Ribbon Network Strategy and, in 10.6.7 In addition to MOL, there are large open areas which are particu- particular, The draft London Plan, Policies BR2 (Biodiversity), larly prominent and visible from the main road network. Although BR3 (Natural Landscape) , BR6 (Flood Defences) and BR20 these areas are generally not large enough nor sufficiently widely (Access). used to be of strategic importance (and not therefore appropriate for designation as Metropolitan Open Land), they are nevertheless of great significance to the Borough as a whole. For this rea- OS5 GREEN CHAINS son the open character and sense of openness of such areas require special protection, in accordance with RPG3 and The The continuity of the following green chains will be draft London Plan. maintained and, where practical, extended:

(a) River Brent; and

OS4 AREAS OF OPEN CHARACTER (b) The Grand Union Canal. Wherever development proposals are submitted on The areas of open character identified below and on land adjoining the River Brent and the towpath side of the proposals map will be protected and enhanced: the Grand Union Canal, a landscaped area of public open space will normally be required adjacent to the • Vale Farm, fronting East Lane; waterway, incorporating a public footpath with provi- • Roe Green Park, Kingsbury Road; sion for a cycle way and screening of any unsightly • L.T. Sports Ground, Forty Avenue and Bridge Road; features abutting the area. Where the area above cannot be provided in full, the Council will consider • John Billam Playing Fields, Woodcock Hill; contributions to improvements on the Green Chain as • Barham Park, Harrow Road; and a whole. • Sports Grounds fronting The Mall. Development proposals on the off-side of the Grand Union Canal should not erode the open character of GREEN CHAINS the canal where this exists. The extension of open spaces and pedestrian access (including bridging the 10.6.8 Green Chains, as recognised in both RPG3 and The draft London canal) will be sought on the off-side of the canal Plan, are areas of public and private land which are linked to pro- where appropriate and subject to operational require- vide a visual and physical network of open spaces through the ments. Borough and beyond. In Brent, they follow rivers and canals, linking into green spaces in adjoining boroughs. The purpose of des-

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10.6.11 The Council recognises the value of the Grand Union Canal as a 3D.11, recommends that boroughs should produce open space recreational feature for the Borough and also as an important strategies in accordance with the Guide to Preparing Open Space wildlife corridor as well as comprising an unbroken Green Chain Strategies (GLA, 2003). through the Borough. Conservation objectives are being pursued with the Greater London Authority and the adjacent boroughs, together with organisations such as British Waterways and other interest groups.

10.6.12 The Council aims to improve the appearance, use (especially for leisure purposes), accessibility and wildlife value of the Grand Union Canal and the canal feeder. Regard will be had to the Development Control Guidelines published by the, former, London Canals Committee (1999) for canalside redevelopment and The draft London Plan, Policies BR 19 (Sport and Leisure), and BR23 (Design). The Council's additional landscaping requirements are designed to maintain the character of the canal 10.7.4 Brent lacks both local open space and district open space. Parts as well as to promote the gradual improvement of the Canal of the Borough south of the North Circular Road, such as Green Chain. See also UDP Policy BE14. Willesden Green, Brondesbury and Kilburn are especially deficient in open space. Given the lack of open space in the Borough and its poor distribution, it is important to protect local open spaces which help to maintain and improve the environmental quality of the Borough and to provide for recreation. The exception to Policy OS6 below is the redevelopment of Kingsbury Swimming Pool (see Policy OS19). The Proposals Map indicates the location of all existing and proposed public open spaces over 1 hectare in the Borough. The policy applies to all public open spaces in the Borough.

OS6 PUBLIC OPEN SPACE 10.7 PUBLIC OPEN SPACE Development of public open space will not be permit- 10.7.1 Brent is a highly developed London borough with a considerable ted unless it is required to maintain or enhance activi- overall deficiency of public open space; it has less open space ties associated with the open space. per head of population than some boroughs that adjoin Central London. Guidelines that may be used to determine whether a particular area has satisfactory access to open space were initially set out in the Greater London Development Plan (GLDP) and TABLE OS1: commended in RPG3 (Table 7.1). These guidelines, which have STANDARDS TO ASSESS OPEN SPACE DEFICIENCY been recently reiterated in the The draft London Plan, (Table 3D.1), establish a hierarchy of different sized parks providing dif- TYPE OF APPROX SIZE DISTANCE ferent facilities, each with minimum access standards. OPEN SPACE FROM HOME

10.7.2 For example, households that live further than 400 metres (a quarter of a mile) from a park of over 2 hectares (5 acres) are METROPOLITAN 60 HECTARES 3200M considered to be in a local open space deficiency area. PARKS (150 ACRES) (2 MILES) Households that live over 1200 metres (three quarters of a mile) from a park of 20 hectares (50 acres) are considered to be in an area that is deficient in district open space. The Council has DISTRICT PARKS 20 HECTARES 1200M 3 accepted these guidelines, set out in Table OS1, as an appropri- (50 ACRES) ( /4 MILE) ate measure of open space deficiency and also as a long-term goal for open space provision throughout the Borough, in accor- LOCAL PARKS 2 HECTARES 400 M 1 dance with RPG3 which advises Boroughs to “...seek to reduce (5 ACRES) ( /4 MILE) deficiencies in open space...” (para. 7.19). OPEN SPACE UNDER 2 LESS THAN 10.7.3 The draft London Plan endorses and reinforces this approach to MAKING PARTIAL HECTARES 400M identifying areas of open space deficiency (Policy 3D.9 Meeting CONTRIBUTION (UNDER 5 (LESS THAN 1 People’s Needs for Open Space). The draft London Plan, Policy TO LOCAL PRVSN ACRES) /4 MILE)

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Maps OS1 and OS2 show existing public open space deficiencies in residential areas in Brent at Local and District levels respectively. A substantial new residential development could affect the pattern of open space deficiency in the Borough. Measurements are 10.8 OUTDOOR SPORTS PITCHES AND based on actual walking distances taking into account obstructions SPORTS FACILITIES and not as the crow flies. The maps should therefore be used as a 10.8.1 The Brent Playing Pitch Survey, undertaken by the Council in guide as the actual deficiency areas will be larger. 2003 in conjunction with Sport England showed a deficit of sports pitches in all the major pitch sports: soccer, rugby, cricket and 10.7.5 It is recognised that within local public open space deficiency hockey using Sports England standards. Brent is significantly areas it is unlikely that development sites will come forward to below the National Playing Fields Association (NPFA) standards remove the deficiency. However, experience has shown that, on pitch provision. The Council's experience shows that a short- subject to proper management, small-scale sites make a valuable age of lettable quality pitches exists for all sports with many of the contribution to help meet the deficiency. Small sites can provide pitches the Council manages being over-used. The diversity of wildlife habitats and so reduce areas of wildlife deficiency. These cultures in the Borough means that an appropriate level of provi- small sites may also provide a starting point for a larger scheme sion for Brent would exceed the Sports Council's standards. The or, in combination with other small sites, can meet some of the Council will have regard to these sports pitch requirement figures open space needs in high deficiency areas. Public open space which it will calculate for the Borough when applications are made will be considered as a key land use should any sites or buildings concerning the development of sports grounds. become available in local public open space deficiency areas. Policy OS7 will be applied in existing predominantly residential 10.8.2 Between 1980 and 1990, some 17 hectares (41 acres) of private areas or where large scale mixed development is proposed. sports grounds were redeveloped, representing 17.5% of the 95 Public open space will be sought in addition to any amenity space hectares (234 acres) of privately owned or leased sports grounds required by the development itself. that existed in 1980. Just over one hectare (of 17 hectares) has been retained as open space within the redeveloped private sports grounds, under planning agreements. During the last OS7 PROVISION OF PUBLIC OPEN SPACE decade the loss of private recreational land (primarily in the form of sports pitches) in Brent accelerated. A further 36 hectares (91 The provision of new or extended public open space acres) of open space, mostly in the form of sports grounds has (including provision for maintenance) will be sought been developed since the deposit of the first Unitary on appropriate sites in local public open space defi- Development Plan in 1992 and other proposals exist to erode the ciency areas when redevelopment takes place (includ- stock of playing fields further. The pressure on some schools to ing where new development creates a deficiency). develop their playing fields remains.

10.8.3 PPG17 advises that playing fields of value or high quality should normally be protected except under limited circumstances. The Council's view is that the historical loss of sports grounds is not sustainable and its assessment is that a strong policy of protection is dictated by Brent's circumstances. Only in this way can it hope to address the shortage of sports pitches to meet its own needs as well as the needs of inner London boroughs looking to outer London to help meet their sports and recreation demands.

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PPG3 on Housing supports Brent's approach. It notes that clear evidence should be provided that adequate local provision of OS8 PROTECTION OF SPORTS GROUNDS playing fields remains before development of sports grounds should be considered. Given Brent's current pitch shortages this The development of sports grounds (including non- is not the case and a policy protecting sports grounds is required. pitch based facilities and ancillary facilities) or open The policy also applies to former sports grounds, or parts of space will not be permitted in areas of local public sports grounds, which are currently dis-used or under-used. open space deficiency. Elsewhere the development of sports grounds will only be permitted where the 10.8.4 Where, exceptionally, loss of a small part of a sports ground is development of a small part (the minimum required) necessary to secure the future of the remainder (and is outside a is essential to safeguard or improve the remainder and deficiency area), a clear business case must be made, including overall sports provision is not lost, so that either: a demonstration that the enabling element is no more than that (a) The development is ancillary to the principal use of financially required, and that the size of the remaining area the site as a playing field or playing fields, and does remains viable in both sporting and financial terms. Any develop- not affect the quantity or quality of pitches or ment of sports grounds should not lead to sports pitch or sports adversely affect their use; or provision loss (based on the maximum capacity of the sports (b) The development affects only land incapable of ground rather than its current use) unless that loss is compensat- forming, or forming part of, a playing pitch, and ed for by the provision of pitches and ancillary facilities elsewhere does not result in the loss of, or inability to make in a suitable location to a comparable quantity and quality. This use of any playing pitch (including the maintenance provision would need to be made prior to commencement of the of adequate safety margins), a reduction in the size development. of the playing area of any playing pitch or the loss of any other sporting / ancillary facility on the site; 10.8.5 Alternatively other sports facilities may be provided to compen- or sate for the loss of sports grounds where they are of significant (c) The playing field or playing fields which would be community sporting benefit. In order to compensate for any loss lost as a result of the proposed development would of public amenity from partial loss of open space, programmes to be replaced by a playing field or playing fields of an secure free public use at certain times will be secured, particularly equivalent or better quality and of equivalent or for local schools. The policy does not justify the cumulative loss greater quantity, in a suitable location and subject of sports pitches or grounds at any one site. to equivalent or better management arrangements, prior to the commencement of the development; or

10.8.6 It is a statutory requirement for the Council to consult Sport (d) The proposed development is for an indoor (subject England on proposals for development which affects playing to Policy OS19) or outdoor sports facility, the provi- fields. Local authorities must also notify the relevant Government sion of which would be of sufficient benefit to the department if they are minded to give planning permission for a development of sport as to outweigh the detriment development on educational playing fields. The Council will also caused by the loss of the playing field or playing consult with local residents and amenity groups on proposals for fields. the disposal or alternative use of playing fields.

DUAL USE OPEN SPACE

10.8.7 Some school playing fields and other facilities lend themselves to use by the general public, this extended use of school playing fields and other recreation facilities, such as gymnasia, is known as dual use. In most cases this is confined to passive recreation of school playing fields, such as walking, sitting out, etc. but can include dual use of a wider range of facilities. There is dual use of school facilities at Copland school for example. The Council considers that there is further potential, through dual use, for increased sporting and recreational use of existing school and other facilities. OSP9 sets out a proposal where dual use is integral to the potential development of a new school. Since the main user will always have first call on the facilities, open space deficiencies can only be partially alleviated in this way.

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OS9 DUAL USE OPEN SPACE OS10 ACCESS TO SPORTS FACILITIES

The dual use of education open space will be promot- The Council will, where possible: ed, particularly where there is a deficiency of public (a) Adapt the Council's sport and recreation facilities to open space. The dual use of facilities will be sought help those groups identified in its sports strategy as where schools bring forward significant development having low rates of participation in sport; proposals. (b) Provide facilities that meet the needs of all groups in the community;

(c) Adjust provision as new sports develop; and IMPROVING ACCESS TO SPORTS AND (d) Encourage other facility providers to take similar RECREATION FACILITIES action.

10.8.8 As well as the overall shortage of sports facilities, access to indoor and outdoor facilities remains uneven among different groups in the Borough, a feature identified by the Council in its Sports Strategy (1999). Aspects of this inequality can be redressed through planning policies and through sports manage- 10.9 OTHER URBAN GREEN SPACE ment practices. The Council will continue, where possible, to 10.9.1 PPG17 advises local authorities to take full account of the com- adapt its existing facilities to allow full access by disabled people. munity's need for recreational space, not solely sports pitches, a Making sports facilities accessible to carers of young children, for position confirmed in RPG3 and reiterated in The draft London example by improving changing facilities and providing childcare Plan, Policy 3D.10. LPAC defined open space to which public facilities, will also be considered wherever possible. Other access is restricted, or not formally established, but which is groups in the community have also experienced difficulty in find- capable of meeting recreational and non-recreational needs, as ing sports facilities including pitches. There is a shortage of gael- Urban Greenspace. Urban greenspace excludes previously ic football pitches suitable for use by interested schools, for exam- developed urban land. For the purposes of this Plan, Policy OS8 ple, and clubs which draw heavily from the African, Caribbean deals with urban greenspace with formal sports use. Policy OS9 and Asian communities do not always have access to the same considers other Urban Green Space meeting open space needs level of facilities as many other long established clubs. The in Brent. Development of existing Urban Green Space will nor- Council's commitment to widen access to sport and recreation mally be refused unless it is replaced on site or elsewhere (usual- applies equally to indoor facilities (see also Policy OS20). ly in open space deficiency areas) or it possess no recreational, amenity or nature conservation value.

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10.10.3 The London Ecology Unit has also identified sites of Borough OS11 URBAN GREENSPACE (Grade II) and local importance in terms of their wildlife and nature conservation value (see Appendix OS1): they may not Development of Urban Greenspace (not considered in have such an intrinsically rich habitat but they do have an impor- Policy OS8) will be refused unless the following apply: tant local wildlife value. Policy OS13 below ensures that development has no adverse consequences on these sites or that com- (a) Urban Greenspace can be replaced on site, nearby or in an area of open space deficiency; and pensatory provision is made.

(b) The site has no recreational, amenity or nature conservation value. OS13 DEVELOPMENT ON SITES OF BOROUGH (GRADE II) AND LOCAL NATURE CONSERVATION IMPORTANCE 10.10 WILDLIFE AND NATURE CONSERVATION Development will not be permitted on sites of Borough (Grade II) and Local Nature Conservation Importance 10.10.1 Several parts of the Borough have significant nature conservation shown on the proposals map unless it is demonstrated value, with many other areas offering great potential for further that there will be no adverse effect on nature conser- creation of wildlife habitats. The Council's nature conservation vation or that compensatory provision for wildlife is policies are based on information contained in the Ecology made. Handbook No 31, Nature Conservation in Brent, 2000. Sites of wildlife conservation value are classified by the, former, London WILDLIFE CORRIDORS Ecology Unit (LEU, now part of the GLA) as sites of Metropolitan, Borough (Grade I and Grade II) or Local Nature Conservation 10.10.4 Wildlife corridors are areas of land often linking sites of known Importance or sites which form a Wildlife Corridor. Nearly all sites nature conservation value; typically they run along river corridors, were surveyed. The development process will allow other sites to such as Wealdstone Brook, and railway lines as well as linked be surveyed and some of these are likely to be of nature conser- areas of open space. They need not be made up solely of land of vation value: new sites will be designated as appropriate. The proven wildlife value. It is particularly important to maintain these Council will co-operate with adjoining boroughs to ensure that links so that ecological communities do not suffer the vulnerability sites and corridors which cross borough boundaries are main- that arises from isolation. Wildlife Corridors are often of high tained. amenity value, particularly for train commuters passing through the developed parts of London. Green Chains act as wildlife cor- 10.10.2 The various nature conservation sites have a hierarchy of value, ridors, but wildlife corridors also include links that are not accessi- the Sites of Special Scientific Interest (SSSI's) as well as sites of ble to the public, for example railway embankments. On wider Metropolitan and Borough (Grade I) importance contain intrinsi- railway embankments, some sites could be dedicated to nature cally rich habitats and will therefore be protected from develop- conservation and a number of these are protected by woodland ment (see Appendix OS1 for a list of sites). In accordance with protection orders. Regard will be had to the operational require- section 28 of the Wildlife and Countryside Act 1981, the Council ments of the transport undertakers. will consult English Nature concerning proposed development that affects the SSSI. The Council also consults English Nature 10.10.5 The designation of these meets the requirements of PPG9 para- on a range of land-use operations that might affect the SSSI. graph 15 which states that “Statutory and non-statutory sites, together with...features which provide wildlife corridors, links or stepping stones from one habitat to another, all help to form a network necessary to ensure the maintenance of the current range OS12 DEVELOPMENT ON SSSIS AND SITES OF and diversity of our flora, fauna, geological and landform features METROPOLITAN, AND BOROUGH and the survival of important species.” (GRADE I) NATURE CONSERVATION IMPORTANCE OS14 WILDLIFE CORRIDORS Development will not be permitted on or adjacent to Sites of Special Scientific Interest and Sites of Wildlife corridors, as shown on the proposals map, will Metropolitan and Borough (Grade I) Nature be protected from developments which sever or other- Conservation Importance shown on the proposals wise unacceptably harm their importance for wildlife map, unless it is demonstrated, that there will be no conservation and / or visual amenity, unless, where adverse effect on nature conservation. appropriate, compensatory provision is provided. In the case of the Wealdstone Brook any development which affects its open setting will be resisted.

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SPECIES PROTECTION Waterways and other interested parties: initiatives include a joint conservation agreement to protect the area. It is hoped that the 10.10.6 As well as preserving habitat on which wildlife depends, PPG9 on co-operation of all of these parties, and the Environment Agency, Nature Conservation also deals with the protection of species and will ensure a secure future for the reservoir as a nature conserva- recommends the use of conditions or planning obligations under tion and recreation area. The Council's general policy in respect which the developer would take steps to secure the protection of of development proposals affecting SSSI's and sites of species. The LEU advises boroughs to ensure that developers Metropolitan and Borough Nature Conservation importance also take action to reduce disturbance to a minimum and provide (Policy OS12) applies to the Welsh Harp. The special considera- adequate alternative habitats to sustain at least current levels of tions that relate to the Welsh Harp are set out in Policy OS16 population when sites with protected or important species are below. The Council will continue to interpret and promote the proposed for development. landscape and nature conservation value of both the Welsh Harp and the Fryent Country Park. 10.10.7 The LEU also recommended that boroughs should prepare local Biodiversity Action Plans (BAP) which should not only address 10.10.11 Fryent Country Park is one of the best areas for traditionally man- national priority species listed in the UK Plan, but should also take aged neutral grasslands in Greater London and has a rich grass- into account local priorities in order to preserve our familiar land flora as well as many ponds, woodland and 11km of wildlife. This advice informed The draft London Plan injunction hedgerows - many of medieval origin. The wooded area around that development should be resisted where it “...would have a sig- Barn Hill was laid out by Humphry Repton in 1793 and is a good nificant adverse impact on the population or conservation status surviving example of his work: it includes a mature deciduous of protected or priority species.” (Policy 3D.12). woodland; wetland meadows; Tudor and older hedgerows following ancient parish boundaries, such as Hell Lane; and a Saxon 10.10.8 The Brent Biodiversity Action Plan (BAP, 2001) recognises the hedgerow which is the best surviving section of parish boundary importance of sites and wildlife at a local level and has informed hedge in North West London. The Council will protect the the Mayor’s London-wide Biodiversity Strategy (Connecting with Country Park as a Local Nature Reserve under the provisions London, 2002) and the London Biodiversity Action Plan (London contained in the National Parks and Access to the Countryside Biodiversity Partnership, 2001). Act, 1949.

OS15 SPECIES PROTECTION OS16 WELSH HARP & FRYENT COUNTRY PARK

Development which would have an adverse impact on On the Welsh Harp and Fryent Country Park, planning protected species or national or local Biodiversity decisions should: Action Plan species that are uncommon or under (a) Ensure that both areas are protected from any pro- threat in London will be refused, unless steps to posals which would affect their integrity as unique secure the protection of the species are implemented. environments;

(b) Protect any areas designated as local nature reserves;

MAJOR NATURE CONSERVATION AND (c) Improve access for the local community; and ECREATION REAS R A (d) Protect the areas for predominantly informal recreation. 10.10.9 Brent Reservoir, or the Welsh Harp, is an area of nearly 70 hectares (170 acres) of urban countryside and water. It has matured into a very attractive recreational centre and a valuable habitat for wildlife and plants. Much of the area has been desig- 10.10.12 To help promote nature conser- nated as a Site of Special Scientific Interest by English Nature in vation in the Borough, the order to protect its rich variety of plants and other wildlife, and the Council intends to produce Council has designated part of the reservoir as a Local Nature management plans for major Reserve. The Council recognises the unique value of the Welsh public open spaces which have Harp Reservoir and its surrounding open land for both recreation important nature conservation and wildlife conservation. value. These will help resolve conflicts between different uses, for example nature conservation and active recreation. The man- 10.10.10 The Welsh Harp has been identified in The draft London Plan as agement plans will examine what kinds of uses are acceptable an important element of London’s Blue Ribbon Network (Map and what improvements are needed (such as access for disabled BR1). Part of the Welsh Harp is in the London Borough of Barnet people) although they will not deal with day to day maintenance and, in order to resolve potential conflicts between recreation and issues. The local community will be involved in the production of conservation and to consider the future development and protec- these plans and the Council will consult interested parties such as tion of the area as a whole, the Welsh Harp Joint Consultative English Nature. The Welsh Harp and Fryent Country Park will be Committee has been established with Barnet Council, British the priorities for the production of these management plans.

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CREATION OF NEW WILDLIFE HABITATS 10.11.3 Measured against the National Playing Fields Association (NPFA) standards on children's play space, the Borough is seriously defi- 10.10.13 Within London good wildlife habitats are a scarce resource and cient in play space. Meeting the NPFA standards on children's the Council intends to protect and enhance existing sites which play space is a long term goal for the Borough as a whole, as is a have a nature conservation value (see Policy STR36). It is impor- satisfactory distribution within the Borough. The NPFA recom- tant to ensure that new developments cause the minimum dam- mend that pre-school children's play areas should be located age and disturbance to landscape, wildlife and wildlife habitats. within 150 metres of family dwellings and 400 metres for junior All new developments should exploit opportunities to improve the play areas. These should be accessible without having to cross environment both from an amenity and wildlife viewpoint. Where main roads. The areas of deficiency are shown on Map OS1. land adjacent to nature conservation sites is developed the Council will seek to extend wildlife habitats into the development 10.11.4 New housing developments over 15 units (or over 0.5 hectare) site (using native species wherever possible). In areas of wildlife and larger scale mixed developments will, where appropriate, be deficiency (defined as over 1km from accessible sites of expected to provide children's play areas to the NPFA standards Metropolitan or Borough nature conservation importance) (see where they are not met or provide contributions to allow such pro- Map OS3) the Council will seek part of any development site for vision to be made within the vicinity or in a deficiency area. the creation and maintenance of wildlife habitat. The develop- Arrangements for their long term maintenance will also be sought ment process may create derelict sites which can sometimes lie through planning obligations. Existing play areas will not be undeveloped for some time. The Council will seek the temporary allowed to be redeveloped unless they are replaced within the site use of such sites for nature conservation purposes. or at a more appropriate location.

OS17 NEW WILDLIFE HABITATS

The creation of wildlife habitats will be sought as part of the landscaping scheme in major developments in the following locations:

(a) Adjacent to areas of nature conservation importance; and

(b) In areas of wildlife deficiency (see Map OS3). The temporary use of derelict sites for nature conservation purposes will be encouraged.

10.11 INDOOR SPORTS & RECREATION & OTHER OUTDOOR USES

OS18 CHILDREN'S PLAY AREAS CHILDREN'S PLAY AREAS

10.11.1 There is a considerable deficiency in children's play provision in The provision of suitable play areas for pre-school and Brent, not only in terms of the land area devoted to play facilities junior children to NPFA standards will be sought in and the quality of provision but, more importantly, in terms of its residential developments over 15 units (or 0.5 Ha in distribution around the Borough. size) or in large scale mixed developments. Where such provision may not be appropriate, contributions 10.11.2 Most of the children's play areas in Brent are provided either with- to their provision in a more appropriate location will in public open spaces or on housing estates. Many of the more be acceptable. recent open space acquisitions in the south of the Borough are being used primarily for children's play: they are generally less Arrangements for the long term maintenance of these than half a hectare (one acre) in size and are therefore ideally play areas will be sought through planning obliga- suited to play provision. Despite the laying out of new play areas tions. and the improvement of many more, a large number of the play areas in Brent are poor, lack modern equipment, safety surfaces Redevelopment of existing play areas will only be con- and not all are fenced to make them dog free. Some residential sidered where they are provided within the develop- areas do not have reasonable access to any play areas at all. ment site or at a more appropriate location.

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OS20 SITE SPECIFIC SPORT PROPOSALS INDOOR SPORTS CENTRES AND INDOOR RECREATION The Council has set out site specific proposals for the 10.11.5 There is growing interest in the provision of commercially operat- provision of indoor (with some outdoor) facilities at ed recreation facilities. Previously these were of a reasonably Vale Farm and Kingsbury. It will also bring forward small scale such as snooker clubs, but now schemes of a much proposals for the re-provision of Willesden Sports larger scale, e.g. indoor cricket and tennis centres, health and fit- Centre and Athletics Stadium. These proposals require ness clubs are being considered. The location of sports and extensive site areas. In each case there are no recreation uses should generally accord with the sequential sequentially preferable locations and the proposals approach: first consideration being given to town centres, then are included in the Plan on that basis. edge of town centres, district centres and only then out-of-town sites with good public transport access. See also Policies STR2, SH3 and TEA1.

10.11.6 The Council will also seek the provision of childcare facilities in major indoor schemes and a comparable level of access for disabled people, where appropriate, when a new sports facility is created by conversion or extension, where such a change is outside the scope of the Building Regulations. The principles governing proposals for smaller-scale indoor sports and recreation activities, set out in Policy TEA2, apply to small scale indoor sports and recreation proposals.

OS19 LOCATION OF INDOOR SPORTS FACILITIES

Large-scale indoor sports, leisure and recreation facili- 10.12 METROPOLITAN WALKS ties should be located in accordance with the sequential approach (Policy SH3). 10.12.1 PPG 17 advises local authorities to promote and enable walking as a recreational activity. The draft London Plan promotes “...high Where reasonable and practicable, in major schemes, quality walking routes...” (Policy 3C.18), as identified on its Map the provision of childcare facilities will be sought. The 3C.5 London’s network of promoted and proposed walking site should be designed to be accessible to disabled routes. The Mayor will further detail measures to promote recre- people where external works are not covered by the ational walking in the proposed Walking Plan (Transport for Building Regulations. London).

Proposals for small-scale sport, leisure and recreation 10.12.2 A network of Metropolitan Walks has been formulated by the facilities, that do not attract a lot of people, should London Walking Forum. It is intended that Metropolitan Walks accord with the principles set out in Policy TEA2. such as the Capital Ring (an outer London orbital footpath) will be way-marked and will have information points along them. The Council intends to implement those sections of the Metropolitan route network within the Borough (the River Brent Green Chain 10.11.7 Brent has comprehensively set out its strategy to develop and and the Capital Ring Metropolitan Walks are set out in the enhance a very wide range of sporting and leisure activities in A Proposals Map) and ensure that development near the route Sports And Leisure Development Framework For Brent (2003), takes account of the route and, where appropriate, contributes to which identifies the need for new and enhanced facilities and its implementation by providing way-marking and information, enabling resources in accordance with residents and users priori- route greening and improving pedestrian safety. ties. This Strategy complements other surveys which have examined potential locations for indoor facilities requiring extensive site areas, and which need to be co-located with outdoor sports facili- OS21 METROPOLITAN WALKS ties (as they share changing facilities and have indoor and outdoor elements to the same sport), in accordance with the sequen- The character of paths and other routes which form tial approach, as part of its review of existing sports provision (see Brent's Network of Metropolitan Walks will be protect- Brent's Sports Strategy, 1999). These locations accord with the ed. Development on or near to the route will be sequential approach and are therefore included as site specific expected to take full account of Brent's Metropolitan proposals in Chapter 15 of the Plan or proposals within Policy Walks network (shown on the Proposals Map). OS20 below.

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10.13 ALLOTMENTS OS22 ALLOTMENTS 10.13.1 Development Plans are statutorily required to make provision for allotments where there is an identified requirement (Allotments Allotments, other than those identified in Chapter 15, Act 1925). PPG17 (para. 14) specifically reiterates the advice of will be protected from development unless: PPG3 (Annex C) that allotments must not be regarded as ‘previ- (a) The Council’s future assessments show allotments ously developed land’. The draft London Plan recommends to be surplus to requirements strong protection for allotments (para. 3D.45). The Thorpe Report (1969) recommended national guidelines for allotment (b) They are extensively disused provision which have been beyond the ability of the Borough to (c) A consideration is given to other open space func- meet. tions the allotment site may perform

10.13.2 The review of the former UDP (1996) took place against a back- Where there is no up to date assessment by the ground of accelerating lack of interest in allotment cultivation with Council, the applicant should demonstrate through an consequential rising vacancies and disused plots. An assess- independent assessment that allotment land is surplus ment undertaken by the Parks Service showed that the two allot- to requirements. ments for which there are site specific proposals (see Chapter 15) were surplus to requirements, and the Council considered what The loss of the site’s nature conservation, recreational other functions these sites could perform before designating or visual amenity value is compensated for by means these sites for alternative uses. It should also be noted that of a planning obligation regarding contributions Council does not currently rely on Greenfield sites other than towards the upgrading of other allotment sites, provi- those identified in the Plan to meet its housing requirements. sion of replacement open space, or some other form of relevant compensatory provision. 10.13.3 Other allotment sites in the Borough are well occupied and should not be built on unless future assessments show these allotments to be surplus to requirements, in accordance with the advice of PPG17. Particularly, as the historic decline appears to have been reversed with a growing interest in horticulture leading to a significant decline in vacancies and even waiting lists for some allot- 10.14 CEMETERIES ments. The Council has responded to these changes with a programme to upgrade and improve its allotments where feasible. 10.14.1 RPG3 advises that boroughs should make provision for burial space where possible (para. 7.26). A position reiterated in The 10.13.4 Allotments, aside from the site specific proposals will be protected draft London Plan, which also emphasises the requirement to from development. Where they are surplus to requirements, the consider “...the special needs of certain religious or cultural Council will consider other open space functions that the sites groups for whom burial is the only option.” (Policy 3A.28). The may perform. in accordance with (PPG17). Even where develop- draft Plan also supports the ‘sustainable cemeteries’ (including ment may be permitted, the allotments open space, recreational reuse of graves) strategy promoted by the, former, LPAC (1997). and amenity value must be compensated for by means of a planning obligation contributing towards the upgrading of other allot- 10.14.2 Existing capacity has been maintained in Brent's existing ceme- ment sites, or by provision of replacement or improvements to teries by using all available areas of them. The Council's main other open space. cemetery is at Carpenders Park near Watford. It has space for burials well into the next millennium although access by public transport is poor. There are no crematoria in the Borough: the nearest are located at Hendon, Golders Green, Kensal Green and Ruislip. There are unmet demands from different religious denominations. The Hindu population would like a crematorium more suited to their customs and needs. The Muslim population are served by a separate burial ground at Carpenders Park but not in the Borough.

10.14.3 The Council recognise the practical difficulties in siting cemeteries and crematoria in built up areas such as Brent. The Crematorium Act, 1902 (amended by the Greater London Council (General Powers Act) 1971) set standard distances requiring that new crematoria are normally located 100 yards (91 metres) from any residential property and 50 yards (46 metres) from a highway. As crematoria are not an appropriate use of MOL, then it is difficult to find areas in Brent that would fulfil the standards.

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10.14.4 While the existing cemeteries and churchyards in Brent have important historical, architectural, habitat and passive recreational value, the Council are concerned that they are a user of scarce land resources. The Council will, through its own management practices, seek to re-use its burial space. Through the Confederation of Burial Authorities, of which it is a member, the Council will also seek the necessary changes in legislation to facilitate the further re-use of existing burial space before finding further land for burial use.

OS23 CEMETERIES & CREMATORIA

The demand for burial space and cremation will be met inside and outside the Borough without encroaching on sports or open air recreation facilities, or impacting adversely on areas of nature conservation importance, and as far as possible in locations accessible to public transport. Where practicable, all existing cemetery space should be re-used before new burial facilities are approved, provision will be made for recording memorials for historical purposes and protecting those of particular interest. Special consideration will be given to cemetery and cremation facilities meeting unmet needs of religious or ethnic groups in the Borough.

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APPENDIX OS1 SCHEDULE OF SITES OF NATURE CONSERVATION Br.BII 7 Abbey Road Mounds IMPORTANCE Br.BII 8 Coronation Road Pastures and Guinness Siding Sites of Special Scientific Interest (SSSI) Br.BII 9 Grange Roundabout Nature Area Welsh Harp Br.BII 10 St John's Old Burial Ground Sites of Metropolitan Nature Conservation Importance Br.BII 11 Wealdstone Brook from Kenton to the Jubilee Line M6 Grand Union Canal Br.BII 12 St Mary's Churchyard, Willesden M35 The Welsh Harp Br.BII 13 One Tree Hill M36 Fryent Country Park Br.BII 14 Roe Green Park Sites of Borough (Grade I) Nature Conservation Importance Br.BII 15 Willesden Reservoir Br.BI 1 Quainton Street Open Space Sites of Local Nature Conservation Importance Br.BI 2 Dollis Hill Rough Br.L 1 River Brent west of Stonebridge Br BI 3 Northwick Park and the Ducker Pool Br.L 2 Meadow Way Copse Br.BI 4 Old St Andrew's Churchyard, Kingsbury Br.L 3 Kingsbury Hospital Wood Br.BI 5 Brent Bends Br.L 4 Wealdstone Brook (Wembley Park section) Br.BI 6 Railside Habitats Br.L 5 Brentfield Open Space and Leicester Road A.Silverlink Metro between Brondesbury and Willesden Junction. Br.L 6 Grove Park and Tramway Brook B. Metropolitan line between Kilburn and Neasden Br.L 7 The Pimple C. Dudding Hill Loop between Cricklewood and Harlesden Br.L 8 Queens Park D. Harlesden to Wembley Central, including the Wembley Brook Br.L 9 The Old Orchard E. Piccadilly Line between River Brent and Sudbury Hill Br.L 10 Elmwood Park F. Chiltern Line between River Brent and Sudbury Hill Harrow Br.L 11 Alperton Cemetery G. Jubilee lineside from Stanmore Junction northwards to Queensbury Br.L 12 Barham Park

H. Northwick Park and Kenton railsides Br.L 13 Wembley Park Sports Field

Sites of Borough (Grade II) Nature Conservation Importance Br.L 14 Brett Crescent Backland

Br.BII 1 The Canal Feeder and River Slade Br.L 15 Barham Primary School Wildlife Area

Br.BII 2 Paddington Cemetery Br.L 16 Byron Court Primary School Nature Reserve

Br.BII 3 Gladstone Park Br.L 17 The Orchard - Malorees Infants and Junior School

Br.BII 4 Roundwood Park and Willesden New Cemetery

Br.BII 5 Tokyngton wildflower area and the Brent

Br.BII 6 Harp Island

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N.B. This map is indicative only

Brent Unitary Development Plan - 2004 218 OPEN SPACE, SPORT & RECREATION

N.B. This map is indicative only

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N.B. This map is indicative only

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11 COMMUNITY FACILITIES

Page 11.9 HOSPITALS AND HIGHER & FURTHER EDUCATION 228 11.1 INTRODUCTION 222 CF12 NORTHWICK PARK HOSPITAL/HIGHER & FURTHER 11.2 BACKGROUND 222 EDUCATION (HFE) ZONE 229

11.3 STRATEGIC CONTEXT 222 11.10 PRIMARY HEALTH CARE 229

11.4 POLICY OBJECTIVES 223 CF13 PRIMARY HEALTH CARE/GP SURGERIES 230

11.5 BOROUGH STRATEGY 223 11.11 PLACES OF WORSHIP 230

CF14 PLACES OF WORSHIP 230 POLICIES & PROPOSALS 11.12 LIBRARIES 231 11.6 GENERAL - LOCATION AND PROVISION 223

CF1 LOCATION OF LARGE SCALE COMMUNITY FACILITIES 224

CF2 LOCATION OF SMALL SCALE COMMUNITY FACILITIES 224

CF3 PROTECTION OF COMMUNITY FACILITIES 224

CF4 COMMUNITY FACILITIES CAPABLE OF HOLDING FUNCTIONS 225

CF5 COMMUNITY FACILITIES IN LARGE SCALE DEVELOPMENTS 225

11.7 EDUCATION 225

CF6 SCHOOL PLACES 226

CF7 NEW SCHOOLS 227

CF8 SCHOOL EXTENSIONS 227

CF9 TEMPORARY CLASSROOMS 227

CF10 DEVELOPMENT WITHIN SCHOOL GROUNDS 228

11.8 DAY NURSERIES 228

CF11 DAY NURSERIES 228

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The growth in groups acquiring existing community facilities and 11.1 INTRODUCTION other land uses for schools, places of worship and for wider community use has been considerable. The pressure from groups to 11.1.1 This chapter concentrates on the issues concerned with the land- re-use redundant community buildings and find sites for new use requirements of community services, notably because of the buildings remains in the Borough. Planning policies must reflect high requirements of Brent's ethnically diverse communities. It this reality to accommodate the legitimate aspirations of its citi- also relates to needs arising from household and population zens for places for prayer, education and meetings of all kinds. growth and the changing structures of service providers. Community facilities include health, education and those relating 11.2.3 Failure to make proper land use strategy and planning policy pro- to religious worship. They are significant local employers and vision to enable equality of opportunity and access to community contribute towards regeneration. services, could contribute to indirect discrimination : contrary to the anti discrimination legislation pertaining to ethnicity, gender 11.1.2 For the Purposes of the UDP 'Community Facilities' includes the and disability. In addition to this general requirement, the Council uses falling within 'Use Class' D1 namely: must ensure that its land use strategy and planning policies to enable education, health and social care provision and service • For the provision of any medical or health service except for delivery complies with their respective legislative and regulatory the use of premises attached to the residence of the consul- requirements. tant or practitioner; • As a crèche, day nursery or day centre; 11.2.4 The provision of community facilities has been a key aspect of • For the provision of education; certain recent regeneration schemes. With health and education • For the display of works of art; 'action zones', the provision of such facilities are now seen by the • As a museum; Government as key to combating social exclusion - with priority • As a public library or public reading room; being given to areas with a concentration of deprivation. • As a public hall or exhibition hall; • For, or in connection with, public worship or religious instruc- 11.2.5 Population and household growth, particularly that caused by tion. new housing development, is putting great pressure on a number of existing community facilities, for example school places. Also 11.1.3 And for the following sub-categories of Use Class C2: the changing make-up of the community creates needs for different types of facilities e.g. places of worship. Finally changing • Use as a hospital; lifestyle & education patterns create new needs for facilities such • Use as a residential school, college or training centre. as higher education and day nurseries. This chapter tackles the issues brought about by these changes. 11.1.4 Indoor sports facilities fall within the D2 "Assembly and Leisure" use class and are dealt with in the Open Space chapter. The Open Space chapter also now contains policies on the develop- 11.3 STRATEGIC CONTEXT ment of cemeteries and crematoria. Water and sewerage, energy and infrastructural issues in general are dealt with in the NATIONAL POLICY CONTEXT Environmental Protection chapter. Special needs housing, including nursing homes, and day care facilities for people with 11.3.1 The Government’s overarching ‘social inclusion’ strategy, as special needs are dealt with in the Housing chapter. exemplified in ‘Bringing Britain Together (ODPM, 1998) and the Neighbourhood Renewal Strategy, emphasises the role of community services and facilities provision in redressing historical 11.2 BACKGROUND exclusion, discrimination, deprivation and disadvantagement. Such services and facilities can also enable ‘community empow- 11.2.1 The 2001 Census indicated that Brent is one of the most ethnical- erment’. The Government’s National Health Service (NHS) Plan ly diverse local authorities in Britain, with the majority of its resi- (2000) and its educational counterpart, The Learning Age : A dents from a wide range of ethnic and cultural minority communi- Renaissance for A New Britain (2000), are of particular impor- ties (a proportion only exceeded in London by LB Newham). tance for the local delivery of the key health and educational ser- Brent also suffers substantially higher than the London average vices. socio-economic deprivation and disadvantagement levels; five neighbourhoods fall within the country’s top 10% most deprived 11.3.2 Planning Policy Guidance Note 12 Development Plans (PPG12, localities. 2000) stresses that social considerations are one of the factors that plans are required to have regard to: 11.2.2 This diverse range of needs gives rise to a high demand for community facilities for general use, including statutory services provi- • Authorities should consider the relationship of planning poli- sion, and also to meet the needs of a wide range of voluntary cies to social needs - including their impact on groups such sector, particularly ethnic and religious, groups. Although some of as ethnic minorities, religious groups, elderly and disabled these groups are able to compete in the market for land and buildings, other groups have high needs and low levels of resources.

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people, women, single parent families, students and disad- • Policy 3A.16, resists the loss of social infrastructure, including vantaged and deprived people living in deprived areas (para libraries and community halls; 4.13); • Policies 3A.17, 18 & 19, supports health services improve- • Plans should make provision for land for schools and higher ment and modernisation; education, health facilities, places of worship and other com- • Policies 3A.21 & 22, educational facilities; and munity facilities (para 4.14). • Policy 3A.23, facilities to address London’s diverse population needs. 11.3.3 As new housing development could potentially overstress an area’s existing community services and facilities, Planning Policy Guidance Note 3 Housing (PPG3, 2000) specifically advises that 11.4 BOROUGH POLICY OBJECTIVES new housing proposals should be assessed in terms of the capacity of existing and potential “social infrastructure (such as 1. To ensure that community facilities are located where they schools and hospitals ) to absorb further development and the reduce the need to travel, and where appropriate support town cost of adding further infrastructure” (para 31). centres; 2. To ensure that community facilities are accessible to the whole 11.3.4 Circular 1/97 (Planning Obligations) stresses that the provision of, community; or funding contributions to, facilities (e.g. educational facilities), 3. To ensure that regeneration projects include the significant may be sought through development providing that such facilities upgrading of community facilities serving deprived communi are directly related to the development proposal and the need for ties; them arises from its implementation, and they are reasonable and 4. To meet the projected shortfall in school places in parts of the directly related in scale and kind (para B10). Such provision can Borough; and be ensured through a Planning Obligation (Section 106) 5. To improve primary health care facilities through the develop Agreement. ment of more purpose built group practice facilities.

REGIONAL POLICY CONTEXT 11.5 BOROUGH STRATEGY 11.3.5 Regional Planning Guidance for the South East (RPG9, 2001) emphasises that “health, education, and other social considera- 11.5.1 The strategy for community facilities in the Plan is based upon the tions and infrastructure requirements need to be taken into key principle in the Part I 'Strategy' section of providing for mixed account fully in development planning”. Policy Q6 further specifi- and balanced communities. This will require a full range of com- cally advises that local plans should facilitate the ‘modernisation munity facilities located where each part of Brent can access strategy’ of local health service providers. RPG9 also stresses these whilst minimising the need to travel by the private car. the need to ensure that community facilities are accessible by Similarly it requires protection of those facilities that still meet a sustainable transport modes. local need.

METROPOLITAN POLICY CONTEXT POLICIES AND 11.3.6 Strategic Guidance for London Planning Authorities (RPG3) PROPOSALS advises that :

• Boroughs are best placed to frame detailed policies for 11.6 GENERAL - LOCATION AND London's diverse communities (para 1.12); PROVISION • Areas of deprivation require comprehensive programmes to improve their social infrastructure (para 2.14); COMMUNITY FACILITIES - LOCATION • Town centres are stressed as appropriate locations for primary health care, education and other uses which serve the 11.6.1 Where community uses such as colleges and hospitals attract community - as this reduces the need to travel (para 5.12); large numbers of visitors then Government policy reflected in the • Residents should have access to community facilities such as "sequential approach" requires that in the first instance they be primary health care, education, and places of worship (para directed towards town centres (listed in the Town Centres & 8.14). Shopping chapter), before smaller centres are considered, and that sites have moderate or better public transport accessibility (defined in Transport chapter para 6.7.2) for pedestrians and 11.3.7 The draft London Plan, which will replace RPG3, emphasises that cyclists. Conversely, smaller facilities serving local catchments addressing ‘social polarisation’ requires policies “sensitive to the should be located in smaller local centres. The policy takes into needs of communities of interest and identity” (3A.90) . Policy account the extensive space requirements of some community 2A.6 notes that community infrastructure provision, such as facility uses. schools and hospitals, is a key sustainable development criteria. Particular community infrastructural elements are specifically protected and promoted by:

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11.6.2 Small scale community facilities may not have the same location- CF1 LOCATION OF LARGE SCALE al requirements as their larger scale counterparts. While town COMMUNITY FACILITIES centres are a preferred location for smaller scale community facilities, it is recognised that some sites with moderate or better pub- Proposals for community facilities attracting large lic transport accessibility may be suitable. Proposals for local numbers of visitors, should be located either: facilities may be appropriately located in residential areas but residential amenity should be protected. (a) In the first instance in town centres (excluding ground floor areas in the primary shopping PROTECTION OF EXISTING COMMUNITY frontage); or FACILITIES

(b) Secondly, if no suitable town centre sites are avail- 11.6.3 In order to protect the existing stock of community facilities, any able, on the edges of town centres. development that involves loss of community facilities will normally be refused. The Council will, where practical, encourage the Where there are no suitable sites in these areas re-use of facilities for community purposes that are no longer (having regard to the space requirements of the use) required by an existing community or religious group, by another then sites with good or very good public transport such group. accessibility (as defined in the Transport Chapter section 6.7), which are easily & safely accessible by 11.6.4 Several former local authority buildings are now used as educa- cycling and walking, are acceptable. Alternatively tional establishments by different ethnic and religious groups. public transport accessibility should be raised to this There is still an unmet demand from other groups for denomina- level. tional grant maintained schools and this has put pressure on residential and office accommodation. Protection therefore of such Hospital related uses may also be located within the community facilities is designed to retain buildings best suited Hospital Zone at Central Middlesex Hospital (see Park and located for community facilities use to continue. Royal Inset Plan Policy PR7), or hospital and/or education uses in the Hospital & Higher and Further Education Zone in Northwick Park (Policy CF12). CF3 PROTECTION OF COMMUNITY Community uses may also be located in the area cov- FACILITIES ered by Policy PR6 (see Park Royal Inset Plan). The loss of a community use falling within the D1 use class will be resisted unless the facility is appropriately replaced, or adequate compensation is made for its loss, or unless both the site and any buildings are unsuitable for redevelopment for community uses. CF2 LOCATION OF SMALL SCALE COMMUNITY FACILITIES Exceptionally a reduction in the size of a community facility may be permitted where the facility is too large Proposals for community facilities serving a neigh- for modern needs and the development is essential to bourhood or district function should be located in or secure community use (with equivalent community adjoining a town or local centre. Where there are no access) on the remainder of the site. suitable sites in these areas, small-scale community facilities should be located on a site with moderate or better public transport accessibility (as defined in the Transport Chapter section 6.7) which is easily & safely accessible by cycling and walking. COMMUNITY FACILITIES CAPABLE OF HOLDING FUNCTIONS Proposals for community facilities serving local catchments may also be located elsewhere within 11.6.5 Proposals for community facilities capable of holding functions residential areas outside centres, subject to the need to demonstrate an acceptable transport impact and, where protection of neighbourhood amenity. appropriate should not lead to unacceptable increases in the level of noise and disturbance to any nearby residential areas. Conditions will be imposed on proposals where this would limit any unacceptable impact on residential amenity. Particular problems may also arise with extensions to existing facilities.

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11.7.2 The majority of the Local Education Authority’s (LEA) maintained CF4 COMMUNITY FACILITIES CAPABLE OF schools are currently operating at near, and in some cases at well HOLDING FUNCTIONS over, their capacity levels as illustrated in the Brent School Organisation Plan 2003-2008. Only two of the LEA’s fourteen Proposals for community facilities capable of holding secondary schools and seventeen of its sixty primary schools functions, including extensions of existing facilities, have any substantial under-utilised capacity (over the 10% level will be assessed according to the following criteria: regarded as necessary to ensure the requisite flexibility to cope with short term roll fluctuations). (a) The proposal should have an acceptable transport impact (Policy TRN1); and 11.7.3 These current enrollment figures significantly inflate this apparent limited capacity to accommodate the projected overall pupil (b) There should be an acceptable impact from noise increase; as much of the higher concentrations of vacant school generated both from the use and traffic generated places are located in ‘faith’ (denominational/religious) schools, by it (Policy EP2). particularly secondary schools with a Christian ethos, which may not be attractive to pupils of other and no religious beliefs, or Where necessary conditions will be applied on hours those preferring gender separate (single sex) schools. Other con- of use, music amplification and/or sound insulation to centrations of vacancies, particularly in the primary sector, reflect attenuate sound. short term roll decreases as a result of extensive housing estate regeneration programmes. Where the number and/or scale of functions could have an unacceptable impact on residential amenity 11.7.4 Faith schools, offering culturally sensitive education to meet spe- these will be limited by condition. cific needs, account for a third of the LEA’s primary schools (11 Roman Catholic, 5 Church of England, 3 Jewish and 1 Islamic) and four of its secondary schools (3 Roman Catholic and 1 COMMUNITY FACILITIES IN NEW Jewish). A further existing Jewish girls secondary and an Islamic DEVELOPMENT primary school are currently seeking LEA voluntary assisted status. The number of such LEA maintained faith schools is likely to 11.6.6 Apart from protecting the existing stock of community buildings, further increase during the lifetime of this Plan, particularly to there is still the need to make additional provision, particularly meet specific Islamic, and possibly Hindu, educational needs. where new residential development adds to demand. This will Some of which is currently provided by non LEA schools, such as ensure that residents of new communities have the opportunity to the Swaminaryan school in Neasden. walk to facilities such as community centres, GP surgeries, day nurseries, etc. In some cases it may be possible to upgrade 11.7.5 In addition to specific ethno-cultural factors generating a demand existing facilities but this will not be possible in every case. for more specialised educational provision, the Borough is likely to generally experience increased diffused demand as a result of the Government’s strategy to increase provision at both the nurs- CF5 COMMUNITY FACILITIES IN LARGE ery age and the post-16 ends of the educational spectrum, SCALE DEVELOPMENTS together with class size reductions. The Government’s encour- agement of curriculum specialisation (such as technology, lan- Community facilities will be secured in very large scale guages and sports) is also likely to further significantly reduce the residential or mixed-use schemes, where these are historic ‘pre-parental choice’ propensity to attend the nearest necessary to meet the needs of the new community school. 20% of Brent’s pupils’ nearest or preferred school is cur- and the need for them arises as a result of the devel- rently outside the Borough. However, this level is being steadily opment. reduced due to the combination of the Borough’s increasing rate of improved school performance and the adjacent boroughs strategy to prioritise their own residents for their available school places. 11.7 EDUCATION 11.7.6 New housing developments in recent years has generated con- SCHOOL PLACES siderable further stress on school capacity, initially in the North of the Borough, but increasingly in other parts, with the result that a 11.7.1 Educational needs and provision reflects the wide diversity of at least one new secondary school and several primary schools, Brent’s population - over 70% of pupils are from ethnic and cultur- in addition to substantial expansion of existing schools, are likely al minorities, speaking some 120 languages - and high growth to be required during the life time of this Plan. Both PPG3 and rate, has resulting in a much greater need for both school places Circular 1/97 advise that contributions towards providing the pro- and diversity of schools than most other boroughs. The Borough jected additional school places from housing developers may be has recently been identified by the Government (DfES) as one of sought and secured through the Planning Obligation Agreement the two London education authorities projected to face major process (Section 106). school place provision difficulties by 2008.

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11.7.7 The contributions secured by planning obligations would be NUMBER OF CHILDREN GENERATED FOR required to part fund the one-off capital costs of provision of new EACH SCHOOL CATEGORY (I.E. PRIMARY) permanent and temporary classroom space in order to meet ris- X COST OF NEW SCHOOL PLACE FOR ing school rolls. Funds will not be used to revenue fund the run- THAT SCHOOL CATEGORY ning of teaching and other costs in schools which is reflected in = COST OF PROVIDING EXTRA SCHOOL the Government's funding formula for schools. Nor are funds PLACES. required to make up any existing deficiency, rather the deficiency that will solely arise from the planned new housing. 11.7.11 From London Research Centre (now Greater London Authority) 11.7.8 The Council will consider all relevant schools within the catch- data, the Borough is able to estimate the number of children like- ment area of a proposed development (catchment areas vary ly to occupy housing of different sizes. These are set out below: according to pupil age). Where shortages of places exist, by nursery, primary or secondary sector the Council will apply the relevant parts of the formula (see below). The issue is not NUMBER OF CHILDREN PER HOUSE TYPE whether pupils are schooled within a particular borough but whether additional housing would introduce children to within the Bedrooms 2 3 4+ catchment area of a school with a shortage of spaces. Having said this, Brent has an obligation to offer choice for Brent pupils to Nursery 0.08 0.14 0.22 be taught at Brent schools irrespective of whether there are schools in adjoining boroughs with spare places. Primary 0.45 0.8 1.27

11.7.9 Central Government issues Supplementary Credit Approvals to Secondary 0.08 0.14 0.22 local authorities (to borrow funds) in order to meet rising school rolls. However these approvals are contingent on local authorities using their best endeavours to secure planning obligations as 11.7.12 The table is based on London Research Centre 'Child Yield' esti- enabling funding. mates; based on the typical proportion of children attending each school type (i.e. 13% nursery, 73% primary, 14% secondary). It assumes that a third of all children will be within the catchment of CF6 SCHOOL PLACES the existing school. New dwellings with two, three, or four bedrooms tend to be occupied, in the earlier years at least, by young Contributions to build new school classrooms and couples with young children. They are not therefore wholly typical associated facilities will be required where new hous- of the wider population in the Borough. This difference, although ing development would worsen or create a shortage of it may reduce and finally disappear after several years, becomes school places. of particular importance in the case of large new housing developments. The payments will apply to new housing developments (whether by new build or by change of use which will 11.7.13 Cost estimates will be based on the actual individual costs of also include accommodation for homeless families) extending the schools affected and will be calculated on a case- capable of development for 10 or more units (or 0.3+ by-case basis. The payments will apply where a development is ha irrespective of the number of units) that contain within the catchment area of a school with no capacity or where a two or more bedrooms. development within the catchment of a school would generate sufficient children to use up all spare capacity in that school. All The formula for calculating such contributions is set payments will be maintained within a ringfenced fund for expand- out below: ing places in schools which have, or would have, as a result of the development, no spare capacity. This will ensure that funding from planning obligations can be targeted at the nearest relevant school. 11.7.10 The formula for calculating the payment is as follows: 11.7.14 Because of the administrative overhead of administering payments on small schemes the policy only applies to schemes of NUMBER OF SCHOOL AGE CHILDREN PER over 0.3 Ha+/sites capable of 10+ units. It will also apply to HOUSE TYPE changes of use to family residential uses that generate school X NUMBER OF UNITS OF EACH HOUSE children. TYPE = NUMBER OF CHILDREN GENERATED. 11.7.15 The LRC's calculations already allow for a proportion of school- age children that would not need to move school following a move into a new housing development. However, the Council accepts that in the case of affordable housing, a much higher proportion of children than that already accounted for by the LRC figures, will

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already be in the catchment area for local schools (which research suggests is around 40% as opposed to around 15%). CF7 NEW SCHOOLS This is because the Council will have significant nomination rights to new housing association development and these will be exist- Proposals for new schools should meet a need for ing Borough residents, many of whom will already attend local additional school places within the Borough (including schools at capacity or will not move from existing schools. The where there is an insufficient choice of schools within Council will therefore accept a discount in payments of 25% from Brent). A proposal which conflicts with the Plan's pri- affordable housing providers. ority framework for land-uses (Policy STR1) will only be permitted where the shortage of school places is so serious as to outweigh the potential loss of priority land-uses.

New schools should have an acceptable transport impact and will be subject to measures to reduce car use (Policy TRN1).

CF8 SCHOOL EXTENSIONS

Proposals are supported to enlarge school size to enable sub-standard schools to meet DfES standards, or where it is necessary to accommodate the forecast SCHOOL EXTENSIONS/NEW SCHOOLS growth in pupil numbers. Compulsory purchase powers will be used where the need for space is acute. 11.7.16 In recent years substantial educational development has taken place throughout schools in Brent with the construction of the School extensions should have an acceptable Jewish Free School (a secondary school relocated from transport impact and will be subject to measures to Camden), the transformation of the former Willesden High School reduce car-use (Policy TRN1). into the City Capital Academy and the expansion of Wembley High and Kingsbury Green Primary. The Government’s recent Building Schools for the Future strategy envisages major school TEMPORARY CLASSROOMS building refurbishment and improvement which could have significant land use implications in Brent, including possible compulso- 11.7.20 On occasion, schools have had to resort to the use of temporary ry purchase of land, as only a few schools have sufficient land to classroom buildings as an expedient to accommodate rising accommodate additional space to DfES standards. school rolls. The standard of accommodation is lower than a new permanent structure and they are often visually intrusive. As a 11.7.17 In most cases expansion of existing schools and the development general principle temporary classroom buildings will be accept- of new schools will require sites which could be developed for able but will be time limited. alternative land-uses. In these cases the benefits of school expansion or new school provision need to be balanced against the potential loss of a large site from other priority land uses (such CF9 TEMPORARY CLASSROOMS as housing, particularly affordable housing). Any planning permission granted for temporary class- 11.7.18 The difficulty of identifying suitable sites is also likely to affect the rooms will be time limited. development of non LEA schools, particularly the evolution of voluntary schools to a point where they could qualify for LEA funding status. For example, the Islamia School in Salusbury Rd which originally commenced in a former LEA redundant school evolved to become the first Muslim denominational grant main- DEVELOPMENT WITHIN SCHOOL GROUNDS tained school in the country. 11.7.21 With increased funding pressures on schools, and devolved man- 11.7.19 It is estimated that approximately 10% of morning peak traffic is agement of their budgets, there has been increasing pressure to accounted for by the 'school run'. There is evidence that where site commercial facilities (e.g. sports halls/theatres) within school schools take measures to reduce car use this has been success- premises, to be shared between school and public use. These ful. Therefore, there is a requirement that, where both new and can provide both a welcome source of funding and new communi- expanded schools are proposed, measures are taken to reduce ty facilities but some caution must be shown when proposals car use. come forward. It is important that facilities are related to the school and do not prejudice any future expansion of the school that may be needed. Development of school playing fields is

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dealt with in Policy OS8. The Council would also expect that the 11.8.5 Problems can occur when large numbers of children are pro- provision of non-educational uses on school sites would give posed to be accommodated within small premises - especially opportunities to increase dual use of school facilities. Normal where large extensions are proposed to increase the number of development control criteria regarding traffic, access and residen- children. Large numbers of parents (10+) driving to pick-up/drop- tial amenity would also need to be satisfied. off children at the same time can cause a nuisance and this is exacerbated if there is more than one session.

11.8.6 Policy CF11 allows for a loss of residential accommodation recog- CF10 DEVELOPMENT WITHIN SCHOOL nising the need for quality day nurseries. However for very large GROUNDS premises - such as those on three or more floors - the degree of residential loss may be unacceptable. Proposals for non-educational use on parts of schools sites, which would result in those sites falling below DfES standards, will be refused. CF11 DAY NURSERIES

Development will be permitted which complements Nurseries and other day care provision for young the educational functions of the school, does not prej- children, and the extension of such premises, will be udice any future necessary expansion of the school permitted providing: and, where appropriate, allows the dual use of school (a) The amenity of neighbouring residential properties facilities. is not adversely affected, especially when sessional care is proposed;

(b) The property is large enough (minimum 110m2 original un-extended floor area) and has adequate external amenity area - for this reason detached 11.8 DAY NURSERIES properties are more suitable than other residential properties; 11.8.1 Nurseries, crèches and other forms of child care for young children provide important social and skill development opportunities. (c) In order to protect residential amenity &/or high way safety, the development should have safe Their provision may also beneficially enable parents and other transport access. The number of children attending child carers to undertake employment or other activities.The a nursery may be limited where there are no on-site Borough, in line with Government strategy, offers universal nurs- turning facilities for cars and increased numbers of ery and other child care opportunities for all three year olds and children would cause highway safety or neighbour also the four year olds not yet eligible for entry to primary school nuisance problems; reception class. (d) Conditions may be applied limiting the use to that applied for; 11.8.2 Most of this provision is directly provided by the LEA in the specialist nursery classes attached to virtually all of the Boroughs’ pri- (e) The proposal, including any extensions, should not mary schools or its four larger nursery schools. As this LEA provi- result in the over-intensive use of the premises; sion could be overstretched in particular localities by new housing and development, a contribution to enabling the required additional (f) Any loss of residential accommodation is kept to provision will normally be required in accordance with Policy CF6. the minimum necessary to ensure a good standard of facility, and does not result in the loss of more 11.8.3 Other pre- school education and child care facilities are provided, than one unit. for varying time periods, by a wide range of voluntary sector and private play groups, crèches, nurseries and independent schools. Under the Children’s Act 1989 as amended by the Care 11.9 HOSPITALS AND HIGHER & Standards Act 2000, nurseries, playgroups and crèches for chil- FURTHER EDUCATION (HFE) dren under 8 are normally subject to registration with the Office for Standards in Education (Ofsted). 11.9.1 Central Middlesex and Northwick Park are defined as 'HFE zones' where a concentration of hospitals and further / higher 11.8.4 Planning permission is likely to be required where the above are education uses (and their supporting uses) are permitted (as proposed through new development or created by a change of identified on the proposals map). The advantage of this approach use (use of existing public halls will not require permission). is that it provides certainty over where such uses will be and will Registered childminders may look after up to three children under not be permitted and provides a concentration of supporting facil- 5 years without requiring planning permission. SPG 14 Childcare ities which reduces the need to travel (RPG3 para 4.26 notes that Facilities provides guidance as to the planning requirements for student / nurses etc. hostels should be accessible by foot or pub- premises providing child care. lic transport from the institutions they serve).

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11.9.2 This raises a number of issues. There has been pressure to site retail facilities within these campus areas. Whilst some small scale facilities can reduce the need to travel there has also been pressure to locate facilities with wider catchments (i.e. 'drive- through' restaurants). Facilities are therefore required to primarily serve visitors and staff and should thus be restricted in scale (under 200m2). There may be a conflict between the desirability of locating accommodation on site - to prevent previous housing land being lost elsewhere - and providing space for commercial developments such as 'technoparks' and commercial special needs housing. To a degree these problems can be resolved by long-term masterplanning.

11.9.3 Finally high-levels of car-use are still prevalent in these areas. The Council's 'restraint-based' parking standards for institutional 11.10 PRIMARY HEALTH CARE uses, whilst recognising essential operational requirements, will require lower car parking provision in new facilities within these 11.10.1 Brent’s particular combination of high levels of socio-economic campuses. The introduction of 'green transport plans' (see sec- deprivation concentrations and very diverse population is reflect- tion 6.6.11) are particularly suited to such institutional uses. ed in its residents disproportionately high chronic diseases levels, higher infant mortality and lower life expectancy rates than the 11.9.4 The Northwick Park Hospital and Higher and Further Education London average, particularly in South Brent, (as illustrated in the Zone (including the University of Westminster campus) is dealt Brent Primary Care Trust Public Health Report 2002/3). This has with below, the Central Middlesex Hospital Zone is considered in led to the Government designating a large part of the Borough as the Park Royal Inset Plan Policy PR7. a Health Action Zone, one of only four in London.

11.9.5 The Borough is also served by a number of other Further 11.10.2 Primary health care provision, i.e. National Health Service facili- Education facilities, notably the College of North West London ties other than hospitals (see Policy CF12), is the statutory whose campuses in Wembley, Willesden and Kilburn provide a responsibility of the Brent Primary Care Trust (PCT). The PCT is wide variety of vocational and academic courses for 15,000 stu- required to publish a Local Delivery Plan outlining its strategy for dents, many of whom are Brent residents. health service delivery, improvements and health promotion, whose implementation is detailed in Locality Plans for the five PCT organisational areas . Most of the PCT’s health services are CF12 NORTHWICK PARK HOSPITAL/HIGHER delivered through the Borough’s 79 General Practitioners surg- & FURTHER EDUCATION (HFE) ZONE eries (GPs) and larger health clinics, which employ 163 doctors and 263 nurses. The PCT also arranges NHS dental and optical Within the Northwick Park HFE zone as shown on the treatments and pharmacy services. proposals map the following uses are permitted: 11.10.3 The PCT’s general strategy is to reorganise the smaller GP prac- • Hospital/healthcare; tices, often accommodated in inadequate premises, into larger • Higher & Further Education; multi- practice groupings in purpose built primary care centre/ • Ancillary housing/hostel accommodation (e.g. clinics which are capable of providing a wider range of health and nurses home); social care services in accessible locations. Much of the proposed new capital investment will be delivered through the Local • Associated supported housing; and Improvement Finance Trust (LIFT) initiative. • Associated sporting facilities and ancillary retail facilities for workers and visitors to the institution 11.10.4 The Council encourages purpose built modern group practice 2 (restricted to <200m ). clinics (such as those proposed/provided within the redeveloped Development in the area should generally accord with Willesden and Kingbury hospitals). Whilst more central facilities an agreed development framework with a require- might be further away from the residential areas they serve, they ment to implement measures designed to reduce car might be more accessible by public transport. Such facilities are use. also promoted in major new housing/mixed-use developments (see Policy CF5).

11.10.5 In the shorter term, the need to attract doctors to areas less well serviced may require the conversion of residential premises to GP surgeries or the extension of surgeries in residential premises (see SPG15 Medical Practice Accommodation). Health service requirements may make it difficult to maintain residential accommodation as part of conversions. For this reason loss of residen-

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tial use may be permitted where there are no reasonable opportu- there is a shortage of adequate premises, particularly for the nities for shared group practice facilities. It should be noted that newer religious congregations. New purpose built places of wor- this loss only applies to primary health care facilities meeting a ship, notably the Swaminaryan Temple in Brentfield Road, have local need (e.g. doctors, dentists etc.) not to the generality of been created in recent years. Development should not result in other facilities which are better located in town and district cen- the loss of protected land uses such as residential property, other tres. than in exceptional circumstances.

11.11.2 The major problem experienced concerns large congregations, especially at times of major religious festivals and attendant CF13 PRIMARY HEALTH CARE/GP noise/traffic problems. Applicants should address how these SURGERIES problems will be managed as part of the application.

In partnership with the health care providers, the improvement of primary health care facilities is supported. The development or extension of primary health care facilities/GP surgeries will be permitted in residential areas and in town and local centres where:-

(a) There is no significant loss of residential amenity;

(b) The development would not create highway safety or traffic problems (Policy TRN1);

(c) If the premises is a dwelling then where the property is large enough (minimum 110m2 original unextended floor area); and

(d) Facilities are accessible to the whole community.

If there is a loss of residential accommodation, or large-scale extensions to properties previously in use as residential is proposed, then this will be permitted where:

(i) The proposal is essential to the operational requirements of the practice; and

(ii) There is a shortage of facilities serving a local need in the area; and

(iii) Shared group practice facilities are not a practical or desirable option. CF14 PLACES OF WORSHIP Purpose-built, group practice facilities are generally encouraged. The provision of religious meeting places for all denominations is permitted, where there will be no Where necessary a condition will be applied limiting significant loss of residential amenity or unacceptable the use to that applied for. transport impact (Policy TRN1) - especially at the time of religious festivals.

A proposal which conflicts with the plan's priority framework for land-uses (Policy STR1) may only be permitted where a shortage of places of worship is so 11.11 PLACES OF WORSHIP serious as to outweigh the potential loss of priority land-uses. 11.11.1 Brent’s population diversity is reflected in its residents religious affiliations : 48 % Christian, 17% Hindu, 12% Muslim (Census 2001). Although there are many general community buildings, meeting rooms and religious buildings in Brent, the great diversity of cultural, ethnic and religious groups within the Borough means

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11.12 LIBRARIES

11.12.1 The Council provides 12 libraries in the Borough. There is no central Borough library but Willesden Green is the main reference library and offers modern facilities including a wide range of community, artistic and other activities.

11.12.2 The North of the Borough has no equivalent facility. The largest facility is the Town Hall library which is classified as a "strategic" library like Willesden Green. The problem is that it does not have the space to expand its range of services . The Council is considering the provision of a new central library within the Wembley area (see Policy WEM22 in the Wembley Regeneration Area chapter).

11.12.3 Of the remaining libraries, Barham Park, Ealing Road, Harlesden, Kilburn, Kingsbury and Preston Road are classified as "district libraries" whilst Cricklewood, Kensal Rise, Neasden and Tokyngton are classified as "neighbourhood" libraries. A number of smaller libraries, both in the north and south of the Borough, offer a more limited range of services than the larger ones and have limited space for expansion. These libraries generally fulfil a different function than the larger ones, serving a localised community.

11.12.4 The potential exists to relocate some library facilities into more multi-use facilities with other education and community functions such as that typified by the Willesden Green complex. An appropriate balance needs to be struck between smaller libraries and the development of a smaller number of "centres of excellence". The Council’s Library Service Position Statement 2003 sets out proposals for the future of the Borough’s libraries, including new developments and refurbishments. Major new libraries should be located in town centres or in areas of good public transport accessibility (Policy CF1). Smaller scale new libraries, amongst other things, relate more to local community needs and should be located close to the communities that use them (Policy CF2). However the most accessible locations are still town or district centres.

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Brent Unitary Development Plan - 2004 232 WASTE 12 WASTE

Page W9 CONSTRUCTION / MOVEMENT OF SPOIL 241

12.1 INTRODUCTION 234 12.11 INCINERATION 241

12.2 BACKGROUND 234 W10 INCINERATORS 242

12.3 STRATEGIC CONTEXT 234 12.12 WASTE DISPOSAL 242

12.4 POLICY OBJECTIVES 237 W11 WASTE TRANSFER FACILITIES / WASTE TO LANDFILL 242 12.5 BOROUGH STRATEGY 237 12.13 AGGREGATES 242

POLICIES & PROPOSALS W12 AGGREGATE EXTRACTION 243

12.6 KEY PRINCIPLES OF SUSTAINABLE WASTE MANAGEMENT 237

W1 THE WASTE MANAGEMENT HIERARCHY 237

W2 THE PROXIMITY PRINCIPLE 238

W3 NEW WASTE MANAGEMENT / MANUFACTURING PROPOSALS - ENVIRONMENTAL AND ACCESS CRITERIA 238

12.7 DEVELOPMENT AFFECTING WASTE MANAGEMENT FACILITIES 238

W4 WASTE MANAGEMENT / MANUFACTURING AREAS 239

W5 SAFEGUARDING OF WASTE FACILITIES 239

W6 PROPOSALS FOR WASTE MANAGEMENT FACILITIES OUTSIDE WASTE MANAGEMENT / MANUFACTURING AREAS 239

12.8 REDUCTION, RE-USE AND RECYCLING 240

W7 LOCAL RECYCLING POINTS AND FACILITIES 240

12.9 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE 240

W8 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE 241

12.10 CONSTRUCTION / MOVEMENT OF SPOIL 241

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12.2.4 The London and South East Regional Planning Conference 12.1 INTRODUCTION (SERPLAN) forecast in 1997 that all then available landfill capacity would be exhausted within 15 years, and this assumes opti- 12.1.1 'Waste', for the purposes of this chapter is defined as those previ- mistic levels of increase for waste reduction and recycling. This is ously used materials for which the Borough and other bodies due to a decline in the number of new waste disposal sites from have a statutory management responsibility. This chapter is con- minerals working, the filling up of old sites, stricter standards and cerned with land-use, and not the Borough's own waste manage- higher costs for landfill, and a resistance to 'landraising' (like land- ment strategy which is separate. fill only a banked up new area is created). Current contracts for landfill are reaching their end and the economics which made 12.1.2 As a waste planning authority (WPA) Brent has responsibility for landfill the cheapest option have completely changed; landfill is waste land-use planning. This involves determining applications taxed and the tax is anticipated to double, and alternatives for change of use to or development of waste management facili- receive tax credits (such as recycling credits and Non-Fossil Fuel ties. The Borough has a statutory requirement to include waste Obligation for incinerators with energy recovery). policies as part of its Unitary Development Plan. 12.2.5 This year (2004), Brent is likely to send in the region of 110,000 12.1.3 The Borough may need to deal with applications for planning per- tonnes of household waste to landfill, incurring a landfill tax bill of mission dealing with waste which fall outside the Borough's approximately £4,620,000. The above figure relates to the waste responsibilities for collection and disposal of 'controlled' waste. that Brent controls directly as a waste collection authority - there Examples could include private waste transfer and recycling facil- is further waste from Parks, Highways and Housing that is han- ities for construction waste and incinerators for other forms of dled by contractors and which is paid for indirectly. Thus, the true waste (such as sewage sludge). costs of the landfill tax are higher. Clearly, as landfill tax, rises so other options for waste management become more attractive in cost terms. Recycling rates for Brent are published annually as 12.2 BACKGROUND Best Value Performance Indicators.

12.2.1 'Sustainable Waste Management' is the key objective of all cur- 12.2.6 It is necessary that there is a radical change of direction in waste rent national policies on waste. This concept improves on the old management. The previous system of a dustbin per household idea of 'waste disposal' in that waste is never truly disposed of; collected once a week is increasingly outmoded. Bins are not even landfill requires continued management. Given the sustain- sufficient by themselves to cope with waste - leading to flytipping, ability focus of the UDP, on meeting the needs of future genera- the need for expensive street sweeping, park clearance etc. tions in ways which are both economic and enhance the quality of life, it is clear that current waste management practices are unsustainable even in the short term, are increasingly uneconom- ic and are detracting from the quality of life. One key aspect of 12.3 STRATEGIC CONTEXT Sustainable Waste Management, therefore is to treat waste as a resource. 12.3.1 There are three key, but simple, considerations that are relevant, however, and these are reflected in all of the strategic policy doc- 12.2.2 As over 70% of the Borough’s waste is non-household (e.g. uments below; otherwise when a planning application for a waste industrial / commercial / construction / demolition waste), the management facility is received the considerations that apply are problem is much larger than just the Borough's own waste-man- mostly the same as those that apply to most other industrial agement responsibilities. The Borough also has to deal with pri- premises - an incinerator, for example, is just 'a factory which pro- vate sector applications for dealing with these forms of waste. duces energy'. Given the poor location and design of many existing facilities and the need for new facilities to deal with waste more sustainably, the 12.3.2 Best Practicable Environmental Option (BPEO). In consider- key issue is therefore that of land - how Brent can best and fairly ing the best option for dealing with each type of waste the goal is contribute to dealing with London's waste and to ensure that to use the best practicable environmental option for waste man- enough land is available in the right places. agement. For example landfill will not be the BPEO for most types of waste. This applies both to consideration of processes in • The Key Problem: space available for London's waste is run- applications for integrated pollution control (which under the prin- ning out, and time is running very short. Alternatives all have ciple of 'non-duplication' above are not material planning consid- land use requirements. erations) and to consideration of choice of disposal methods and to locations of management facilities. 12.2.3 The nearly seven million people of London generate over seventeen million tonnes of waste a year, a quarter (4.4 million) of which 12.3.3 It is important to use the principle in the context of each type of is collected by Local Authorities, and the volume of waste is slight- waste and each area. In some circumstances, for example, land- ly rising (Source: The Mayor’s Municipal Waste Management fill will still be the BPEO for some types of waste. The other two Strategy, 2003). 76% of London’s, and 97.5% of Brent's waste principles derive directly from BPEO. goes to landfill; in Brent's case all in Bedfordshire and Buckinghamshire (93 / 94 data).

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12.3.4 The Waste Management Hierarchy. The different waste man- no untreated waste from London goes to landfill outside it after- agement options can be ranked in a hierarchy that gives some wards. The principle needs to be applied flexibly where it conflicts idea of the relative sustainability of each. The hierarchy proposed with BPEO. For example a nearby facility in another region may below by the Mayor’s Municipal Waste Management Strategy is be more proximate and sometimes transporting difficult to dis- an elaboration of the national one, to reflect London's unique pose of waste to specialist facilities in another region may be the needs: BPEO.

12.3.8 Of relevance is the EC Waste Framework Directive (91/156/EEC, as amended). Its key directives are to ensure that waste is recovered or disposed of without endangering human health, causing a nuisance through noise, or harming places of special interest; and that an integrated and adequate network of waste management facilities is provided and it embodies the proximity principle, BPEO and the waste hierarchy. Planning decisions made after 1/5/94 must implement the aims of the directive. It ensures that landfills must be sealed against leachate (polluted water leaking); a factor which has added significantly to landfill costs.

12.3.9 The Government's Waste Strategy 2000, states the government's key aim of sustainable waste management, which is to cut down on the amount of waste we produce. It aims to substantially increase recycling and composting. Where it does not make sense to recycle waste, consideration should be given to using it as a fuel. Local authorities must make realistic assessments of likely future requirements for the number, type and siting of waste 12.3.5 The Government in Waste Strategy 2000 for England and Wales treatment facilities in their area in the light of this waste strategy. (DEFRA, 2000) state that; As required, the Mayor of London has produced a Municipal Waste Strategy; Rethinking Rubbish in London (September “The concept of the waste hierarchy suggests that the most effec- 2003). The Strategy includes proposals and policies for the tive environmental solution may often be to reduce the generation recovery, treatment and disposal of London's municipal waste; of waste. However, where further reduction is not practicable, “The Mayor’s Vision for Waste in London is that by 2020, munici- products and materials can sometimes be used again, either for pal waste should no longer compromise London’s future as a sus- the same or a different purpose. Failing that, value should be tainable city.” (page xiii). The following policy objectives are set recovered from waste through recycling or composting, or out: through energy recovery. Only if none of the above offer an appropriate solution should waste be incinerated without energy 1. London will aim to exceed the recycling and composting tar- recovery, or disposed to landfill.” (paragraph 5.2). gets for household waste set by the Government. These are currently, as set out in Waste Strategy 2000;

12.3.6 The Proximity Principle. The proximity principle promotes the • To recycle or compost at least 25 per cent of household concept that any waste which is created, should aim to be dis- waste by 2005; posed of, or otherwise managed, in close proximity to the point • To recycle or compost at least 30 per cent of household that it is generated. There are four main reasons for this: waste by 2010; and • To recycle or compost at least 33 per cent of household (i) it encourages all those who create waste to take more respon- waste by 2015. (Policy 1). sibility by requiring them to consider carefully the effects of managing the waste they create; 2. London will aim to meet the recovery targets for municipal (ii) it is more likely to accord with the principles of sustainable waste set by the Government, by prioritising reduction, recy- development by avoiding environmental damage which could be cling and composting. The Mayor will insist that waste author- caused by transporting waste over long distances; ities consider options to maximise the reduction, reuse, recy- (iii) it may assist the local economy; and cling and composting of municipal waste from all sources (iv) overall costs should be lower. before considering the recovery of materials and energy from the residual waste. The targets are currently, as set out in 12.3.7 Deriving from the proximity principle is that of regional self-suffi- Waste Strategy 2000 ; ciency. This is that each regional planning area should deal with all the waste generated within its area. Government policy is that • To recover value from 40 per cent of municipal waste by each region should plan to achieve this over a period of at least 2005; 10 years. With the shortage of landfill space in the South-East • To recover value from 45 per cent of municipal waste by outside London the principle has recently been extended so that 2010; and

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• To recover value from 67 per cent of municipal waste by 12.3.15 On local facilities, it states "...Boroughs should not attempt to pro- 2015. (Policy 2). hibit developments from their areas but should work with local communities to ensure that amenity is safeguarded." (paragraph 3. The Mayor aspires to higher targets for recycling and com- 9.16). UDPs should have locational policies for licensed civic posting and considers they can be achieved in the longer amenity and collection / recycling points which minimise both nui- term. (Policy 3). sance and travel to them.

12.3.10 The DETR consultation document Limiting Landfill (October 12.3.16 PPG10 Planning and Waste Management (1999). The objectives 1999) lists options for meeting the targets of the EC landfill direc- of the planning system are set out as: tive for reducing the amount of bio-degradable waste going to landfill. • To provide a framework which enables adequate provision to be made for waste management facilities to meet the needs 12.3.11 Regional Planning Guidance for the South East (RPG9), March of society for the re-use, recovery and disposal of waste, tak- 2001, states that a critical issue for waste planning policies for the ing account of the potential for waste minimisation and the region is to ensure that there is adequate provision for the re-use, particular needs of special waste; recovery and disposal of waste, taking account of the potential for • To help meet the needs of business and encourage competi- waste minimisation. It states that "It is unlikely that London will tiveness; achieve self-sufficiency in the short term and disposal to landfill • To encourage sensitive waste management practices in order sites outside the capital will therefore continue to play an impor- to preserve or enhance the overall quality of the environment tant role. However, the Mayor’s strategies will be required to take and to minimise risks to human health; account of Government policy and EU legislation and to make • To have regard to the need to protect areas of designated provision for the necessary waste management and disposal landscape and nature conservation value from inappropriate facilities to meet London’s future needs for municipal and other development; waste streams so that there is a progressive reduction in the • To minimise adverse environmental impact arising from the amount of untreated wastes exported to ROSE (Rest Of South handling, processing, transport and disposal of waste; East) for disposal as alternative waste management facilities are • To consider what new facilities may be needed, in the light of established in London." (paragraph. 10.15). wastes forecast to arise; and • To ensure that the opportunities for incorporating re-use / 12.3.12 Strategic Guidance for London Planning Authorities (RPG3), May recycling in new developments are properly considered. 1996, sets out government policy for London, to which Boroughs (paragraph. 5). must have regard in preparing their development plans. It recommends that planning authorities "...should already be investigat- 12.3.17 It states that the planning system should not unnecessarily inhibit ing and planning alternative methods of waste management." market trends in waste management, and that other land-use (paragraph 9.10). The guidance lays particular stress on encour- policies and objectives should not prevent an adequate network aging household recycling, as it is minimal in parts of London. It of facilities being established whilst carefully considering the sit- states that Boroughs will need to consider the siting and design of ing of waste facilities in relation to existing and, where possible, collection points for household wastes, the need for recycling and potential surrounding land-uses (paragraph. 29). incineration / energy recovery plant (including combined heat and power) in their areas, and for waste transfer / bulk reducing sta- 12.3.18 Appraisal of policy options is central to PPG10 It states: tions. "...WPAs (Waste Planning Authorities) should appraise the policy 12.3.13 It states "Disposal methods should reflect an acceptable balance options in terms of the social, environmental and economic locally and for London as a whole, paying regard to economics, effects in order to demonstrate: land use and the environment, the effects on potential for development in the area and the use of different modes of transport for a) all practicable options have been assessed; and the movement of wastes and residues." (paragraph 9.11) and b) the selected policies represent the best balance of social, urges Boroughs to co-operate and work collectively. environmental and economic costs and benefits, after full consideration of the BPEO and the principles of sustainable 12.3.14 It states that, where appropriate, UDPs should identify areas of development." (paragraph. 28). search and / or specific sites for developments for the above forms of waste and to demonstrate that mutually acceptable and 12.3.19 It states "Plans should identify existing waste management sites workable arrangements for waste transfer and disposal exist with capacity for the future and, where practicable, new or extend- between originating and receiving authorities (paragraph 9.13). ed sites sufficient to make adequate future provision of waste Whether or not sites have been identified Boroughs should set management facilities.” (Paragraph.33). out criteria-based policies against which proposals for waste management facilities can be considered (paragraph 9.14). It 12.3.20 The Mayor’s Draft London Plan (DLP), (June 2002), contains poli- sets down a presumption in favour of the movement of significant cies providing the stear for waste planning across London. Policy amounts of waste by rail or water (paragraph 9.15). 4A.1 Waste Strategy and targets makes a partnership approach commitment to minimise the level of waste generated, increase

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reuse and recycling and composting of waste and reduce landfill disposal. The Policy requires that Boroughs ensure that land POLICIES AND resources are available to implement the Mayor's municipal PROPOSALS waste management strategy, Waste Strategy 2000, the Landfill directive and other EU directives on waste. This Policy also 12.6 KEY PRINCIPLES OF SUSTAINABLE makes a presumption against any increase in mass burn inciner- WASTE MANAGEMENT ation capacity. 12.6.1 In considering every application for waste management uses, the 12.3.21 DLP Policy 4A.2 Spatial policies for waste management sets out aim is to use the best practical environmental option (BPEO) in what Boroughs ought to address, in reviewing UDPs, in order to choosing the best method of waste management. For example, support the Mayor’s Municipal Waste Management Strategy, the landfill will not be the best practical environmental option for most proximity principle and the need to plan for all waste streams. types of waste. This applies both to consideration of processes in The policy also states that the Mayor will also produce applications for integrated pollution control (which under the legal Supplementary Planning Guidance on planning for waste to pro- principle of 'non-duplication' are not material planning considera- mote the co-ordination of Boroughs’ waste policies. He also tions) and to consideration of choice of waste management meth- intends to press for powers to prepare a London-wide Waste ods and consequently to locations of waste management facilities Local Plan. The Mayor is committed to working with the South (which are). East England and East England regional authorities to co-ordinate the strategic waste management across the three regions. 12.6.2 The different waste management options can be ranked in a hierarchy that gives some idea of the relative sustainability of each. The waste hierarchy proposed by the Mayor’s Municipal Waste Management Strategy, which is based upon the national one, is 12.4 POLICY OBJECTIVES considered appropriate for Brent as discussed at paragraph 12.3.4. 1. To pursue a "recycling-intensive" option as opposed to an "incineration-intensive" one. This should not completely rule 12.6.3 Whilst the waste management hierarchy represents the overall out the role of incineration with energy recovery as a fall back priorities for waste, it will not remain true for all types where it con- option if recycling and reduction targets unavoidably cannot flicts with BPEO. For example, incineration may well be the only be met. option for some forms of waste (such as clinical and sewage 2. To reduce the amount of waste arising in Brent by 20% from sludge, which cannot be dumped at sea from 1998), whilst dis- 1995 levels by 2015, and to increase the proportion of waste posal is still the only practical option for some forms of hazardous recycled to 40% by 2005. waste. The hierarchy provides a checklist: can the waste be 3. To ensure that sufficient land is allocated for a variety of reduced? can it be re-used? can it be recycled?; and helps us find waste management facilities and options; the best place in the hierarchy for each type of waste. 4. To minimise transport associated with waste; 5. To ensure that the best practical environmental option is used in managing waste; and W1 THE WASTE MANAGEMENT HIERARCHY 6. To minimise the environmental impact of waste management processes. A planning application for a waste management facility will be assessed against whether it utilises the best practical environmental option (BPEO). An application 12.5 BOROUGH STRATEGY which conflicts with this will not be permitted.

12.5.1 Brent's strategy follows this national and regional framework In assessing applications, regard will be had to seeking to implement a "recycling-intensive" option as opposed to whether it contributes towards the overall manage- an "incineration-intensive" one. This should not completely rule ment of waste in the following order of declining pri- out the role of incineration with energy recovery as a fall back ority: option if recycling and reduction targets unavoidably cannot be (1) Waste minimisation; met. This will require a spatial framework for the location of different types of waste industries, hence 'Waste Management / (2) Re-use; Manufacturing' Areas are proposed. (3) Recycling and / or composting;

(4) Energy recovery;

(5) Disposal (including non-energy recovery treatment and landfill).

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12.6.4 The proximity principle promotes the concept that any waste which is created, should aim to be disposed of, or otherwise managed, in close proximity to the point that it is generated. The poli- (b) The development should have acceptable means of access. Where a proposal would generate signifi- cy will be applied flexibly where it conflicts with BPEO. To satisfy cant HGV movements then it should have a short, the principle of regional self-sufficiency (see paragraph. 12.6.2) safe and direct link onto the London Distributor may require provision for the management of a proportion of Road Network and be within close proximity to the waste from outside the borough. Strategic Road Network. Where proposals deal with large volumes of waste (>20,000 tonnes) there will be a presumption in favour of rail or W2 THE PROXIMITY PRINCIPLE water transhipment minimising road use;

(c) The proposal should be designed and operated to Waste management facilities, should be of a scale and minimise its environmental impact. It should not catchment area to minimise the environmental impact give rise to significant visual, odour, dust and pollu- of the transport of waste through dealing with it as tion, noise, water quality and overall impact - hav- close as possible to its source. ing regard to regeneration proposals in the area and adjoining land-uses (see policies EP1, EP3, EP4, Development should not prejudice the ability to group EP9 & EP10), unless these can and will be satisfac- together complementary waste management facilities torily mitigated; and on suitable sites. (d) For proposals requiring environmental assessment, there should be a need for the development.

12.6.5 This policy covers all waste-management / manufacturing facilities, including: materials reclamation facilities, recycling, waste transfer and bulk reduction, construction / demolition waste recycling and storage, composting, anaerobic digestion and 12.7 DEVELOPMENT AFFECTING WASTE incineration. In addition to planning requirements, many waste MANAGEMENT FACILITIES activities will also require a waste management license from the Environment Agency which would establish further environmental 12.7.1 The purpose of designating waste management / manufacturing criteria. areas is to ensure that sufficient land is allocated in Brent for a variety of waste management facilities and options. Currently a 12.6.6 Problems of odour can often be lessened through 'negative pres- number of waste management facilities are poorly located and sure' buildings and air-filtration systems. Good design, even sites do not have sufficient spare capacity to be able to adapt to good functional design, can and has been applied to 'shed' devel- meet the demands of the Mayor’s Municipal Waste Management opments. There is no reason why enclosed waste facilities can- Strategy. This will require a 'clustering' of complementary waste not be important pieces of architecture in their own right - in a sim- management and manufacturing uses, e.g. secondary-materials ilar way to Victorian water facilities. recycling industries benefit from being located next to depots / materials reclamation facilities, transfer stations etc. 12.6.7 The acceptable distance of a proposal from the London Distributor Road network (under criterion b) will depend upon the 12.7.2 Flexibility will be the key to planning for these sites. Preferred scale of the plant and the uses along the link. Overall the Council options may change through time. Some options may require wishes to see as short a link as possible. space for large scale sustainable waste management facilities - and as such they may not be suitable in the first instance for multiple small facilities. There would be a strong incentive to ensure that buildings in such areas are, where possible, flexibly W3 NEW WASTE MANAGEMENT / designed. Sites need to be safeguarded until the choices MANUFACTURING PROPOSALS - between certain options becomes clearer. Potential space for ENVIRONMENTAL AND ACCESS small scale incineration may also need to be provided in case CRITERIA reduction / recycling targets are unavoidably not met. The need for weighbridges is another requirement. The following criteria will be used to assess proposals for a waste-management / manufacturing facility: 12.7.3 Despite Brent having one of the highest levels of industrial land in North West London suitable sites are difficult to come by. This is (a) Ground conditions should be suitable for the facility; because such sites have strict locational requirements in terms of their need for large sites and good road and rail access. Such /... sites can potentially generate up to ten times more HGV traffic than an industrial development of the same size. Such locational requirements are also relevant to the designation of employment areas; - but are even stricter for waste uses - very close road access to the strategic road network, and preferably to rail, is

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desirable to minimise the environmental impact of traffic. Regeneration of older employment areas means that they are W5 SAFEGUARDING OF WASTE FACILITIES less and less seen as 'industrial estates' in the old sense of places where 'bad-neighbour' use can be located - rather they are seen (A)Lawful waste management facilities within waste as clean and modern places for business investment. However management / manufacturing areas will be safe- treating waste as a resource means that manufacturing industries guarded for waste management / manufacturing based on the recycling of secondary materials could lead to con- use - especially where sites have existing or poten- siderable growth in manufacturing in London. Waste minimisa- tial rail access - unless an alternative acceptable tion clubs such as the PREMIER scheme in Park Royal have also site is secured (policies W2 and W3) and changes in proven that industry dealing with its own waste is good business. waste management mean that the site is no longer required for acceptable waste management purpos- The key is to ensure that 'waste management and manufacturing' es. areas are situated in the right locations within employment areas and are designed and managed with sufficient environmental (B)Lawful waste management facilities outside waste controls that the problems with existing sites are avoided. management / manufacturing areas will be safeguarded only where they comply, or where they can 12.7.4 Areas have been chosen which meet the objectives of policies be upgraded to comply, with policy W3 (New Waste Management / Manufacturing Proposals - W3 (New Waste Management / Manufacturing Proposals - Environmental and Access Criteria). Environmental and Access Criteria) & W2 (the Proximity Principle). No site is ideal given the severe land pressures that the Borough is facing. Household and non-household waste have quite different locational requirements in terms of the application of the 'proximity principle' and the economics of collection. W6 PROPOSALS FOR WASTE MANAGEMENT FACILITIES OUTSIDE WASTE MANAGE 12.7.5 The Park Royal Partnership has commissioned a waste study for MENT / MANUFACTURING AREAS Park Royal. This looked at current and future waste management and planning issues in Park Royal with the aim of stimulating (I) A planning application for a small (less than 0.3Ha) regeneration by developing links to modern recycling based man- household waste collection, recycling and compost- ufacturing activities. This found that there were clear market ing facility, or for a local area commercial, con- opportunities in Park Royal. struction, demolition waste facility (see policy W7) or timber station, or an extension to such a facility, will be permitted on employment sites outside W4 WASTE MANAGEMENT / Waste Management and Manufacturing Areas, and subject to policy W3. MANUFACTURING AREAS (II) Outside waste management and manufacturing The following sites are safeguarded as Waste areas, waste management / manufacturing facili- Management / Manufacturing Areas, unless the non- ties, other than those described in (I) above, or the viability, in the medium term, for this, is conclusively extension, intensification or continuation of an existing such facility, will only be permitted where: demonstrated. Such development will be directed to these areas, unless policy W5 permits (a) the proposal complies with the waste manage- facilities outside them: ment hierarchy (policy W1) and policy W3 (environmental and access considerations); 1. Charringtons Yard / Neasden Goods Yard (subject to Policy WEM31); and (b) a suitable site within a waste management / manufacturing area, or in Park Royal in the 2. Alperton (part of the former depot and adjoining wider Park Royal area in adjoining Boroughs, land). is not available, and the proposal does not create an excessive concentration of waste management facilities in any one locality;

12.7.6 As well as a need to identify land for new waste management / (c) a local shortage of such facilities exists (policy manufacturing facilities there is also a need to safeguard existing W2) and potential alternative sites are less facilities. So as to ensure that sufficient sites are available. suitable when judged against policy W3 (environmental and access criteria); and 12.7.7 The following policy sets down criteria for consideration of pro- (d) the site lies within a Strategic or Borough posals outside waste management and manufacturing areas. Employment Area (policy EMP8). Generally these will be small-scale local facilities.

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12.8 REDUCTION, RE-USE & RECYCLING W7 LOCAL RECYCLING POINTS AND FACILITIES

Recycling points should be located in convenient and prominent, but not in obtrusive locations, or locations which would be harmful to residential amenity. They should be located at places attracting significant numbers of the public - such as supermarket forecourts and public car parks - and deal with the types of waste originating at the site / in the area.

Large retail proposals should also facilitate and / or incorporate proposals for the overall reduction and recycling of waste.

12.9 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE 12.8.1 The pursuit of a 'recycling-intensive' option does not automatically save energy and resources - this will depend on the type and dis- 12.9.1. The policy below covers all such facilities including scrap metal tribution of facilities. Large amounts of energy can be expended yards / car breakers etc. during the recycling process, for example, where special car journeys have to be made to recycling sites, or where re-processing 12.9.2 Brent has, on the whole, a comparable number of waste transfer is energy intensive or where materials have to be transported facilities to many other London Boroughs. This number is under- long distances. The long term aim must be for provision to be standable considering waste facilities often deal with industrial made for doorstep collection of separated waste, which would cut commercial waste and / or require an industrial location and that out unnecessary journeys and increase the proportion of waste Brent is strategically important in terms of its supply of industrial recycled. Brent has set itself a target of increasing the percent- land and premises. However Brent does have some of the age of households served by the kerbside recyclable materials largest such facilities and one of the highest concentrations of collection scheme to 76% of all suitable properties by 2003 / 2004 construction / demolition / commercial facilities in London. These and to decrease the number of green box complaints to 18000 by facilities are operating in inappropriate locations (conflicting with 2003 / 2004. regeneration proposals such as for the Wembley area) and their lawful use status means that modern environmental controls can- 12.8.2 The Council's own recycling activity has previously been focused not be applied. In terms of other waste recycling facilities Brent is at the Council's Civic Amenity site (at First Way, Wembley), which definitely underprovided. It is also particularly difficult to apply the has banks for: cardboard, scrap metal, textiles, books, shoes, foil, 'proximity principle' to such developments as they may take con- paper, glass, mixed cans and a waste engine oil reclamation tank, tracts or waste from wide areas and a wide variety of sources. and through Bring-Bank collection schemes. There are a number of "Bring Bank" schemes operating throughout the Borough cov- 12.9.3 With the increasing cost of aggregates (due to the decline in num- ering a range of materials. ber of workings) and the cost of the landfill tax, the construction waste industry in particular can only increase. Construction / 12.8.3 Where 'Bring' recycling facilities are used, the government's tar- demolition waste recycled as aggregates reduces the need for get was for these to be 'easily accessible' to 80% of households minerals extraction with its associated environmental costs. The by the year 2000 (within 1/2 mile, or 2 miles where the recycling Government target in Minerals Planning Guidance Note 6 facility is located with other frequently used facilities, e.g. super- (MPG6, Guidelines for aggregates provision in England, 1994) is markets). 100% of Brent’s households are within 1 mile of a recy- for 13% of all aggregates to come from recycling by 2006. On- cling site. site crushing and recycling may be possible, particularly on larger sites. Although MPG6 states that such sites should be 4-6 Ha min (to gain the highest grade product from separation and to maximise its aggregate displacement potential), pressure in Brent will be for much smaller sites.

12.9.4 Future strategy must be based on moving towards smaller covered facilities serving local catchment areas; information submitted with planning applications will be essential in assessing whether this is proposed. There are not the very large scale sites

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in Brent available to meet the requirements of MPG6. For operations that involve the stockpiling of material, the Institute of Demolition Engineers recommends a minimum site size of 1 ha. (C)Construction / demolition waste facilities, aggre- The DETR report ‘Controlling the Environmental Effects of gate handling facilities and concrete transfer sta- Recycled and Secondary Aggregates Production: Good Practice tions should have acceptable road access and Guidance’ finds that the minimum size of site will also depend on preferably rail or water access, and have an accept- the range of activities proposed, and only 'stand-alone' or 'interim' able noise and dust impact, be integrated with facilities need to be as large as set out in MPG6. Brent has a pro- recycling facilities and be compatible with surrounding land uses. liferation of smaller open sites causing significant nuisance and harm to amenity. These sites cannot be practically, or desirably, extended to the size required by MPG6, and they enjoy lawful use rights. The issue then is how to improve them. The Environment Agency has been refusing applications to alter or extend licenses 12.10 CONSTRUCTION / MOVEMENT OF for such facilities in Brent unless they are covered over. A devel- SPOIL oper should include a supporting feasibility study and proposed license restrictions with their applications in support of an applica- 12.10.1 The number and scale of development sites in the Wembley area tion. More importantly, however, there will be a need, especially and of the major estates in particular, means that demolition / con- for major developments, to re-use / recycle waste on site as construction could have a negative impact on local residents unless struction material or aggregates - but not to simply raise the level carefully controlled. of the site which is the equivalent of an unauthorised landfill site. Such a move could contribute in a major way to the reduction in lorry traffic in London. W9 CONSTRUCTION / MOVEMENT OF SPOIL

12.9.5 The Borough also has a particular concentration of waste hauliers For large redevelopment sites (>1Ha), details of meth- operating from within residential areas. These all will require ods for minimising / processing construction waste, licensing and often will require planning permission - the Courts and construction method statements to minimise nui- have determined that whether or not the vehicle is parked on the sance to residents, will be required as part of the street is not material, what matters is whether the property is used application, with a presumption in favour of rail or as a 'base'. Brent will work with the Environment Agency on more water movement where re-use is not possible. effective enforcement of firms causing a nuisance. Recycling should be to as high a grade of recycled product as possible to minimise primary aggregate use.

W8 CONSTRUCTION / DEMOLITION / COMMERCIAL WASTE

(A)All commercial and industrial facilities should have 12.11 INCINERATION adequate on-site facilities for the storage, recycling and handling of waste arisings. 12.11.1 The Borough's planning policies for waste are based upon the adoption of a 'recycling-intensive' approach. However even here (B)Planning applications for storage / recycling / transfer facilities dealing with construction / demo- incineration has a residual role. The economies of scale in rela- lition / commercial waste should assist a move tion to incinerators mean that a large facility serving several away from large open sites, and 'skip-based' sites Boroughs may be promoted. However there is a tension between with large catchment areas, towards smaller, cov- this and the minimisation of road transport (the 'proximity princi- ered, facilities where waste generated within the ple'). Such facilities would cover less than 2Ha of land and could locality is processed and re-used within the locality. fulfil a longer term role in a recycling-based strategy if recycling / Sites should preferably be in a Strategic reduction targets are unavoidably not met. Smaller scale facilities Employment Area (policy EMP5). Waste haulage also make distribution of heat easier and it might be possible to uses will not be permitted in residential areas. expand capacity gradually. The policy below sets down the additional criteria to be met as well as policies W1-W3, and W4 / W5. The granting of permission will be subject to the applicant entering into a planning obligation to I) ensure that vehicles are covered, control mud, use 12.11.2 Overall, in a recycling-based strategy, incineration capacity appropriate routes and II) to limit the catchment should only be promoted for waste not economically and / or sus- area, where appropriate. Conditions will be used to tainably capable of being recycled or for residual waste. The restrict the height and amount of any open storage. recent government document 'Less Waste More Value' states that ‘energy recovery should not be undertaken without first con- /... sideration being given to the possibilities of composting and material recycling' (paragraph 3.3.5).

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12.11.3 Waste to energy incinerators should not consume the bulk of waste from their catchment areas but allow recycling to grow. This is why applicants will need to demonstrate how proposals (d) The catchment area of the plant should be limited so as to comply with the proximity principle (policy will contribute towards a recycling-based strategy. For example W2) and have an acceptable transport impact (poli- recycling facilities can be incorporated on-site in order to separate cy TRN1); out recyclable waste. There is currently a debate about whether incineration is the BPEO for separated paper waste. It is impor- (e) The proposal should be integrated with on site or tant to understand however that this is compatible with a 'recy- adjoining recycling and material reclamation facili- cling intensive' option as this requires separation and small scale ties; incineration for residual waste anyway. Prioritising recycling is (f) The proposal should incorporate energy recovery - reflected in the government document 'Less Waste More Value' preferably incorporating district heating proposals; which states: "Local authorities considering energy from waste and will...want to guard against over-reliance on this option...In partic- (g) Given their size and visual prominence particular ular, they will need to ensure that the use of energy from waste attention should be paid to the quality of design plants does not direct waste from recycling and composting" and its skyline impact (policy BE10). (page 72).

12.11.4 Policy EP4 sets down in detail those circumstances when pollution can be a material consideration. Any incinerator proposal would be one of the few waste management facilities in the Borough likely to require Integrated Pollution Control consent 12.12 WASTE DISPOSAL from the Environment Agency. It is best practice for such applica- 12.12.1 Waste transfer stations serve a crucial intermediate role between tions to be submitted at the same time as planning permission is collection vehicles and large scale waste management facilities. applied for and a copy sent to the local planning authority. The distance between the two is often too great for an economic Without such information, Brent may use its powers under the run by a collection vehicle. Sometimes commercial and construc- applications regulations to consider the proposal invalid. tion waste is transferred to a hardstanding before final transfer to Incinerator proposals will almost certainly require an a bulk carrier. Bulk reduction (usually of household waste) Environmental Assessment to be submitted with the application reduces the environmental impact of transport to final waste man- (see policy EP1). agement, and storage on site is rarely more than 24-36 hours. With proposals for London taking a more proactive role in the 12.11.5 The advent of air-quality management will have a particular bear- management of its own waste the need for a number of existing ing on the assessment of pollution impacts (policy EP3). major bulk transfer stations may be reduced although some of Although new models of incinerator seem to have largely solved these sites may be suitable for other waste management uses. the problems that dogged previous types (e.g. dioxins), concern remains about possible cumulative and other impacts of Nox (nitrogen oxide) and PM10s (particulates). W11 WASTE TRANSFER FACILITIES / WASTE TO LANDFILL

W10 INCINERATORS A waste transfer station / bulk reduction facility handling putrescible waste, will not be permitted unless Waste incinerator proposals will be assessed against the operations are fully enclosed within a building, the following criteria: and where odour can be controlled, and subject to policy W3 (environmental and access criteria). (a) The proposed scale, location, phasing and waste category to be incinerated should not hinder London and Brent's proposals to radically increase Planning applications will be refused which would waste reduction, re-use and recycling; prejudice a shift over the plan period towards the final transport of household waste residuals to landfill by (b) Any potential pollution from the development rail or water modes - with transport by road being a should comply with policy EP4, and policy EP3 on fallback option in emergencies only. air-quality management; particular attention should be paid to particulate dust pollution and odour;

(c) The application should be accompanied by full environmental information (including where required a formal environmental assessment) looking at its 12.13 AGGREGATES individual and cumulative impacts together with other existing and proposed facilities (policy EP1); 12.13.1 Strategic Guidance (RPG3) requires UDPs to address minerals issues and to provide for depots, with a presumption in favour of /... movement by rail or water, and the recycling of waste materials. The 'proximity principle' also applies to trans-shipment locations.

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It identifies the need for a transfer facility in North or West London to accept aggregates from the East Midlands. Brent would need to be satisfied that any site put forward was the best within this broad area and that suitable alternative sites had been fully compared within the environmental assessment (see policy W2).

12.13.2 New aggregates recycling / transfer facilities will be judged against policy W8. Particular attention should be paid to dust suppression - water supplies should be adequate for dust suppression or temporary pipework should be provided. By virtue of their large water consumption greywater recycling facilities should be provided (policy EP11).

W12 AGGREGATE EXTRACTION

An application for minerals extraction will be judged against their environmental & traffic impact (policy W3) and the potential for contributing towards the London minerals landbank. Secondary aggregates usage will need to be fully explored before primary aggregates extraction is considered.

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Brent Unitary Development Plan - 2004 244 PARK ROYAL 13 PARK ROYAL

Page

13.1 INTRODUCTION 246

13.2 BACKGROUND 246

13.3 STRATEGIC CONTEXT 246

13.4 POLICY OBJECTIVES 247

13.5 BOROUGH STRATEGY 247

POLICIES & PROPOSALS

13.6 GENERAL 247

PR1 MAJOR DEVELOPMENTS IN PARK ROYAL 247

13.7 TRANSPORT IN PARK ROYAL 247

PR2 TRANSPORT IMPROVEMENTS IN PARK ROYAL 248

13.8 PUBLIC REALM IMPROVEMENTS IN PARK ROYAL 249

PR3 PUBLIC REALM IMPROVEMENTS IN PARK ROYAL 249

PR4 THE GRAND UNION CANAL IN PARK ROYAL 249

13.9 PARK ROYAL WESTERN GATEWAY OPPORTUNITY SITE 249

PR5 PARK ROYAL WESTERN GATEWAY OPPORTUNITY SITE 250

13.10 PARK ROYAL NORTH WESTERN GATEWAY OPPORTUNITY SITES 250

PR6 PARK ROYAL NORTH WESTERN GATEWAY OPPORTUNITY SITES 251

13.11 CENTRAL MIDDLESEX HOSPITAL 252

PR7 CENTRAL MIDDLESEX HOSPITAL ZONE 252

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13.1 INTRODUCTION industries. It is estimated by the Park Royal Partnership that a further 10,000 jobs might be created in Park Royal as a whole 13.1.1 The policies in this Chapter relate to the inset area of the propos- with new infrastructure to service a number of key 'gateway' sites. als map covering Park Royal. Park Royal is London's largest industrial and business park, covering 650 Ha. Approximately 13.2.4 The partnership has succeeded in attracting much new invest- 40% of the estate is within Brent, 50% in Ealing and 10% in ment to the area, and indeed much of the Brent part of Park Royal Hammersmith & Fulham. It is home to over 1200 businesses has been redeveloped in recent years. It has begun work on employing over 35,000 people. It is located equidistant between examining more radical ways of upgrading the area's outmoded Central London and Heathrow Airport and is directly linked to the infrastructure through the preparation of a regeneration strategy, A40/M40 Western Avenue and the A406 North Circular Road. with the support of the Government Office for London, for the whole Park Royal area. 13.1.2 Special regeneration planning issues arise within this area, hence the need for a separate chapter and an inset to the proposals 13.2.5 The scale and intensity of much recent business, industrial and map. These policies only relate to the part of Park Royal within warehousing development in Park Royal, has been a testament Brent but they are complemented by the policies adopted by to the continuing role these uses have in London, where good Ealing and Hammersmith & Fulham councils in their own Unitary quality and attractive sites can be provided with access to the Development Plans. It is important that there is a co-ordinated strategic road network. The special policies in this chapter are and consistent UDP policy framework as applied to the three designed to maximise the opportunities raised by a number of Boroughs over Park Royal as a whole, and the three Boroughs major sites and to ensure that their infrastructure and develop- have worked to achieve this, both in their initial UDPs and in their ment is well integrated with the surrounding area - in particular so UDP reviews. A small part of the Park Royal Strategic it can tap the potential labour market offered by the adjoining Employment Area lies outside this inset map area as it is a contin- deprived areas of Stonebridge and Harlesden. uation of the Hythe Road area in Hammersmith and Fulham. 13.2.6 The increasing tendency of warehousing to locate in the area raises issues concerning traffic generation from heavy goods 13.2 BACKGROUND vehicles and the reduction in the number of jobs generated. However, the shift towards 'just-in-time' distribution and produc- 13.2.1 The area was developed mainly in the 1930s on the former Royal tion warehousing has led to growth in this sector, and to higher Agricultural showground. As such, its infrastructure and many of employment than traditional warehousing. its buildings are outdated. Whilst the area suffered considerably from the manufacturing recession of the early 1980s, the main food processing employers of the area, Guinness, Heinz and 13.3 STRATEGIC CONTEXT United Biscuits remained - attracted by proximity to the metropolitan market - but all three shed staff and consolidated their sites. 13.3.1 Regional Planning Guidance for the South East (RPG9), March This, together with the disposal of land by the Central Middlesex 2001, - stresses the importance of allocating employment land Hospital and manufacturing operations, created many redevelop- within an overall strategy for urban renaissance. Strategic ment opportunities. The development of the Park Royal Link Planning Guidance for London Planning Authorities (RPG3 - May Road (Abbey Road), and other infrastructure improvements pur- 1996) offers a geographical dimension to the planning of employ- sued by the former Harlesden City Challenge have been crucial in ment land in London. It highlights Park Royal as lying within a opening up many of these as inward investment sites. West London Regeneration Corridor, of fundamental regional and national importance. Development focused on public transport 13.2.2 To tackle the area's problems and to attract new investment, the infrastructure is particularly stressed. It endorses the identifica- Park Royal Partnership has been set up between the three local tion by LPAC of Preferred Industrial Locations (including Park authorities, the private sector and Training and Enterprise Royal) and Industrial / Business Parks (also including Park Councils; with the support of Central Government. Park Royal Royal). The Draft London Plan, (June 2002), has carried these Partnership, which is a company limited by guarantee, has been designations forward. set up with the overall aim of: 13.3.2 The Borough supports, through West London Leadership, the 'Building on its prime location and traditional strengths, to achieve Strategic Development Framework for West London. The the regeneration of Park Royal by promoting substantial physical, Strategic Development Framework aims to make West London economic and social improvements for the benefit of businesses into an international business centre, based on its key locational and communities in West London' advantages. Park Royal is also being promoted for manufacturing opportunities, with the redevelopment of out-dated property 13.2.3 Park Royal offers many property development opportunities, with and the creation of advanced manufacturing inward investment over 200 sites of different sizes available at the end of 1998. Park sites as priorities. Royal also benefits from European Objective 2 status, with grants available for eligible projects in both manufacturing and service 13.3.3 The London Borough of Ealing, in partnership with Brent, has produced a draft strategy for the central area of Park Royal (which straddles the boundary between the two boroughs). It is antici-

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pated that the draft strategy will act as a framework for local ser- 13.5.2 The second reason why a special approach is needed towards vices, private sector involvement and regeneration projects and Park Royal is because of the poor quality of much of the existing will help to deliver the aims of both Boroughs. Ealing identify the environment, coupled with the considerable regeneration poten- area as a Neighbourhood Centre in their UDP. Brent is likely to tial the area enjoys - especially in attracting inward employment designate this area as a Local Centre in the future revision of the investment. Plan. 13.5.3 A number of special policies apply within the Park Royal area. Infrastructure improvements can and must be achieved alongside 13.4 POLICY OBJECTIVES the development of major sites. Two opportunity areas in particular, the western and northern gateways, will require special treat- 13.4.1 The objectives for planning in Park Royal are as follows: ment - within the context of a transport strategy for Park Royal as a whole. Benefiting from new or improved access to the trunk 1. Building on its prime location and traditional strengths, to road network, each 'gateway' area will be opened up for develop- achieve the regeneration of Park Royal by promoting substan- ment. However, if the benefits of these road improvements are tial physical, economic and social improvements for the benefit not to be lost by attracting additional car trips, there must be an of businesses and communities in West London; accompanying shift towards public transport use for commuting. 2. To achieve the upgrading of infrastructure in the area and rede- This will be achieved by public transport improvements linking the velopment of outmoded employment premises to modern stan- existing and proposed stations and employment premises in the dards - co-ordinated with landscaping and other improvements area to their residential hinterlands. The strategy underlying the to the public realm; policies in this chapter is, therefore, designed to ensure that the 3. To achieve the development of new employment floorspace on development of sites and the provision of new infrastructure are under-utilised sites within the area; achieved, as far as possible, in tandem. 4. To utilise the resource of the Grand Union Canal as a catalyst for environmental improvement and regeneration; 5. To improve links to the trunk road network, especially for freight traffic, complemented by alterations to the internal local distributor road network which will discourage through traffic; POLICIES AND 6. To ensure that the limited road capacity to and within Park PROPOSALS Royal does not hinder job creation, through the reduction of reliance on the private car; 7. To improve existing stations, provide a new Park Royal inter- 13.6 GENERAL change station and improve bus services linking stations and 13.6.1 To facilitate the regeneration of Park Royal, and to fulfil the objec- places of employment, penetrating to the heart of the estate; tives of the plan, it is essential that major development proposals 8. To ensure that major developments benefit Park Royal and its make a positive contribution to local infrastructure and the envi- wider community as a whole, including reducing the need to ronment. The assessment of whether development is considered travel by providing local training and employment opportunities; 'major' or not will depend on a number of factors, principally size, and but also intensity of use and prominence of position. 9. To ensure that the Central Middlesex Hospital can operate effectively. PR1 MAJOR DEVELOPMENTS IN PARK ROYAL

Major developments within the Park Royal Inset Area 13.5 BOROUGH STRATEGY will be expected to make a substantial contribution towards the overall enhancement and regeneration of 13.5.1 The strategy of the plan towards Park Royal is based around rein- the area. Planning obligations will be secured for the forcing its role as the Borough's main Strategic Employment Area improvement of local infrastructure and public trans- (policy EMP5 in Chapter 7). The achievement of the full employ- port, where the transport impact of the proposal justi- ment potential of the area, however, is dependent upon major fies such measures. improvements to its infrastructure; without which a number of major sites could not be developed in an environmentally acceptable manner with the ability to support large numbers of commuter trips. (The Strategic Employment Area policies apply unless specifically modified by the special policies for the Major Opportunity Sites). 13.7 TRANSPORT IN PARK ROYAL

13.7.1 The Park Royal Partnership and the three Boroughs prepare an annual Interim Transport Plan for Park Royal. This contains a regularly updated transport strategy for Park Royal, the key elements of which are to:-

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13.7.8 The Park Royal Partnership is promoting an area travel plan ini- • Improve access for essential traffic,from the trunk road net- tiative. This includes promoting travel awareness amongst com- work, to the estate; panies, including setting up car-share databases and provision of • Reduce the need to travel by private car by substantially public transport information within companies. increasing public transport accessibility and improving the conditions for cycling and walking; 13.7.9 The aim of the policy is to concentrate traffic onto a safer internal • Manage unrestrained private vehicle travel into and out of the local distributor road network - with traffic management measures estate, principally by limiting on-street and off-street parking; to reduce the use of the area as a 'rat-run'. When sites come for- • Manage 'rat-running' through the estate; ward for redevelopment there should be a consolidation of • Improve accessibility to development sites by sustainable access points onto the local distributor road network. A range of modes; and measures will be investigated to restrict through movement in the • Develop effective alternatives to road freight transport. area. There is no intention to expand the capacity of the internal local distributor network for private vehicles beyond existing pro- 13.7.2 Park Royal's transport problems have been analysed in several grammed junction improvement works. studies by consultants. It has been generally highlighted that the area's prime strategic location is being adversely affected by the 13.7.10 The Grand Union Canal can also play an enhanced transport problems of through traffic, on-street servicing and car parking, as role, particularly for the movement of freight (see policy TRN32). well as an inadequate internal road network and poor public transport links within the area. PR2 TRANSPORT IMPROVEMENTS IN PARK 13.7.3 Intrusion of through traffic is a particularly significant problem. In ROYAL spite of traffic delays on roads entering and leaving Park Royal, some eastbound traffic leaves the A40 to 'rat run' on parallel The following transport improvements serving Park routes through the area, rejoining at Gypsy Corner (in Ealing), or Royal will be pursued: further east at White City (in Hammersmith & Fulham). According (a) New / upgraded stations, including Willesden to a survey in 1993, such traffic accounts for 20% of the east- Junction Hub and Park Royal Interchange; bound flow on Coronation Road and up to 4% of the corresponding flow on the A40. (b) Bus priority / service improvements on key routes linking stations, employment areas and their residential hinterland; 13.7.4 Although current and proposed rail links serve the periphery of Park Royal, access into the heart of the estate is poor. A 15-20 (c) An improved cycle network and pedestrian routes; minute walk is required from any of the existing stations. (d) Action to restrict the use and parking of cars within the area by extending the scope of existing parking 13.7.5 The A40 and the North Circular Road are heavily congested both controls; on, and increasingly off, peak so that the benefits of a location (e) The concentration of traffic on the existing and pro- close to these major links is diminishing. While the area is tra- posed local distributor road network within Park versed by a number of North-South distributor links, there are no Royal - whilst restricting through traffic; major East-West links. (f) The construction of the Western Gateway Link 13.7.6 The agreed Park Royal Partnership strategy, reflected in the poli- Road (see policy PR5); and cy below, relies upon improving existing stations, providing new (g) The promotion of the area travel plan initiative. stations and new services. Improved bus services would link stations and the employment areas, penetrating the heart of the Such measures will be secured where they are neces- estate, and their deprived residential hinterlands. Increasing fur- sary to mitigate the transport impact of development ther on-street parking controls, together with stricter parking stan- to acceptable levels. dards, will reduce congestion and reliance on the car. Improved links to the trunk road network will be complemented by alterations to the internal local distributor road network which will discourage through traffic. 13.8 PUBLIC REALM IMPROVEMENTS IN 13.7.7 The first major components of implementing this strategy are the PARK ROYAL Single Regeneration Budget (SRB) schemes for Willesden Hub (see policy TRN7) and Park Royal Western Gateway (see poli- 13.8.1 There remain large areas of Park Royal which present a poor cies TRN7 and PR5). A new Park Royal Interchange Station is appearance, with a lack of greenery and a poor public realm. For also planned between the Piccadilly and Central Lines, and new / this reason, special policies are necessary to bring the local envi- improved stations in Ealing, with improved bus services, are pro- ronment up to levels to be expected in a modern business envi- posed. A proposed new road access to the A40 Western Avenue ronment. A major programme of public realm improvements, has SRB funding. including a programme of business forecourt improvements, is being pursued. Of central importance, is the need to present a

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better 'face' to Park Royal in terms of the development of 13.9 PARK ROYAL WESTERN GATEWAY attractive visual gateways at certain locations, and co-ordinated OPPORTUNITY SITE improvement to the public realm. Also important is the maximisa- tion of existing assets, such as the Grand Union Canal (see also 13.9.1 This site, as identified on the proposals map, includes the former policies on canalside development BE14 & OS5). The require- Guinness Brewery buildings fronting the new brewery, playing ment in Policy PR4 of opening up the canal, will be applied in a fields and a clubhouse. pragmatic and flexible manner where existing industrial premises are being upgraded or redeveloped. The London Waterways 13.9.2 This site is recognised as a major development site and regener- Partnership can offer grants for canalside improvements. ation opportunity. It has the potential to be predominantly serviced by public transport through the development of 'Park Royal Interchange', a proposed interchange station between the PR3 PUBLIC REALM IMPROVEMENTS IN Piccadilly and Central Lines. This will open up a development site PARK ROYAL of approximately 32Ha, split between Brent and Ealing.

All major development in Park Royal should contribute 13.9.3 Because of its visual prominence, potential accessibility and towards its greening and the co-ordinated enhance- equidistant location between Heathrow and Central London, the ment of its public realm. In particular, development site offers major potential for inward investment, including a new adjoining or visible from trunk roads or the Grand Guinness HQ. This could attract international organisations to Union Canal should present a clear and attractive visu- Park Royal. There is a shortage in Outer London of the type of al 'gateway' with integral landscaping; and for major accommodation proposed for the site, and development could developments of 2Ha+, new public spaces should be lead to London being better able to compete with business parks provided where a need arises from the proposal. in the rest of the South East. As such, a planning brief has been prepared for the site by Brent and Ealing, including land outside the boundaries of the Strategic Employment Area.

13.9.4 Apart from the development of the new station the principle of development on the site raises three key issues:

13.9.5 The first issue concerns access. Residual road access cannot be by Twyford Abbey Road, a residential road which may be considered for closure to through traffic. A left turn only access onto the A40 Western Avenue is proposed as a replacement, together with a U-turn facility to allow right turns to serve Park Royal in Ealing. These have SRB funding, subject to developer contributions. Any resultant development proposal needs to be accompanied by a Transport Impact Assessment. Access improvements to Western Avenue would need to be agreed with the Highways Agency and be accompanied by major public transport improvements to avoid unacceptably adding to traffic congestion. Overall, the potential exists to relieve congestion on the Hanger Lane gyratory by limiting movements to and from the gyratory via Twyford Abbey Road.

PR4 THE GRAND UNION CANAL IN PARK 13.9.6 The second issue concerns the architectural qualities of the origi- ROYAL nal brewery complex, including associated housing and community facilities, and its setting in open space. The old brewery has Development adjoining the Grand Union Canal in Park brick facades designed by Sir Giles Gilbert Scott and are Locally Royal should support the aim of opening it up to the Listed (UDP policy BE23). Providing that the replacement build- surrounding area and should maximise the potential ings achieve a notable quality and unity of appearance to the ben- of a canalside setting for imaginative design and pub- efit of the western gateway, the demolition of the existing brewery lic amenities. buildings is considered acceptable. The plan supports the principle of promoting conservation as a catalyst for regeneration. Canalside moorings and footbridges, should be provid- However, for this site such an approach could not deliver a ed, as part of development schemes, at the following scheme which would financially support the necessary Western locations (as shown on the proposals map): Gateway infrastructure, and this loss would significantly undermine the long term regeneration of the western part of Park (a) Park Royal North-Western Gateway (Twyford TipWest) - see policy PR6; and Royal.

(b) Between Willenfield Road and Waxlow Road.

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13.9.7 The third issue concerns the potential loss of open space. Policies in the Open Space, Sport and Recreation chapter, and policy STR34, protect playing fields - but can in some circum- (d) Major development is subject to the construction of stances permit limited development according to strict criteria. the Western Gateway Link Road, and "Concord The potential for a prominent employment generating 'gateway' Link" (within the London Borough of Ealing), and development into Park Royal, in connection with the proposed shall include a link road from Coronation Road to Park Royal interchange station, means that partial development Rainsford Road (whilst retaining the railway sid- of the open space, will, on balance, be considered acceptable - ings) and there should be traffic restrictions on providing there are sufficient compensatory benefits in terms of Twyford Abbey Road and Coronation Road. It should include sufficient improvements to the trunk new public open space and compensation for loss of playing road network to enable the development to be fields. The approved planning brief has proposed an open space accessed safely without unacceptably causing con- with public links joining together the two adjoining areas of gestion (see also policy TRN16). The development Metropolitan Open Land in Ealing. Given this change in circum- overall will be subject to a satisfactory Transport stances, it is proposed that open space secured as part of the Impact Assessment (see policy TRN1). development of the western gateway facilitates the creation of a new linked area of Metropolitan Open Land, linking land in Brent and Ealing.

PR5 PARK ROYAL WESTERN GATEWAY OPPORTUNITY SITE

Major development, including a business park, is promoted. This should incorporate a new Park Royal Interchange Station on the Central Line with a link to the Piccadilly Line.

Partial loss of open space within the site, will be permitted if it is essential to achieve the above, including the incorporation of the new station and other significant improvements to public transport facilities and services in the area. A minimum 2ha of additional public open space should be provided, together with compensatory provision for the loss of playing fields. This public open space shall form a link between the areas of Metropolitan Open Land designated in Ealing 13.10 PARK ROYAL NORTH-WESTERN (Jellicoe Mounds and Twyford Abbey). GATEWAY OPPORTUNITY SITES

Development is subject to the following: 13.10.1 This area is the former Twyford Tip now divided by the new Abbey Road into two sites, East and West, as well as the strip of land (a) Purpose built offices and / or hotels are located outside the Strategic Employment Area part of the fronting the north side of the North Circular Road. The area is a site and adjoining the proposed Park Royal major regeneration and employment opportunity and is highly Interchange Station; visually prominent from the North Circular Road. The development of Abbey Road has created the potential for a high quality (b) Loss of locally listed buildings in the area will be development that acts as a dramatic visual 'gateway' to the north- considered against policy BE23 and the regenera- ern part of Park Royal. tion benefits of proposed replacement development. In particular, any proposed replacement buildings should be of equal or greater quality and 13.10.2 The prominent position of these sites means that a particularly unity; high standard of design is required on the North Circular and Abbey Road frontages. This standard may be achieved, provid- (c) Any application shall be accompanied by an urban ing care is taken, with a variety of uses acceptable within the poli- design framework, showing how different phases will be developed and the relationship between cy. For example car-sales, industry and warehousing, should built and landscaped areas; avoid blank facades, uninteresting roof profiles and dominance by frontage parking.

/... 13.10.3 A waste transfer station is on the eastern part of the former Twyford Tip. Road-borne waste to landfill is the least favoured waste management option and, as explained in the Waste chapter, waste transfer facilities should ideally be rail based and be

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large enough to contain complementary recycling and waste manufacturing facilities. In itself this site is not large enough to accommodate such facilities. Nor is the site ideally located in strategic terms. Larger and better located alternatives to it exist for domestic waste in Brent and in neighbouring boroughs. The draft Park Royal Waste Strategy identifies alternative locations within Park Royal for commercial waste management and manufacturing. Finally, as part of a wider 'gateway' site, the continued presence of a transfer facility is hindering major regenerative development of the adjoining site. Therefore, alternative proposals for the site are welcomed and alternative waste management options are favoured.

13.10.4 Although there is an existing planning consent for major mixed- use development including leisure and limited retail uses, the site is not allocated for land uses attracting large numbers of people, such as retail and leisure facilities (like shopping malls and multi- plex cinemas) which are directed to sites in or adjacent to town centres in the first instance in accordance with the sequential approach to such development (see policies SH3, SH4, SH5 & WEM3).

13.10.5 It is acknowledged that the site is an exceptional one by virtue of its prominent location on the main gateway into Park Royal off the North Circular Road and that, consequently, a high quality devel- PR6 PARK ROYAL NORTH WESTERN opment which will provide a dramatic visual gateway is desirable. GATEWAY OPPORTUNITY SITES The site is also exceptional in that there are high costs associated with the removal of spoil from the site and, although some public Development of the Park Royal North-Western subsidy is likely to be available, any developer of the site will have Gateway (as identified on the proposals map) is pro- to contribute also. A high value use on the site may be necessary, moted for major employment development (including therefore, if appropriate development is to be achieved. The offices), community facilities, live-work and for other development of offices is unlikely to impact on town centres or on employment generating uses which the plan does not efforts to regenerate the Wembley area to the same extent as direct to the Wembley Regeneration Area. Develop- development for retail, leisure or hotel use and are, therefore, ment should provide a strong visual 'gateway' to Park considered acceptable here. It should be possible to upgrade Royal, including appropriate design, landscaping and bus services and pedestrian and cycle linkages to the site from parking layout. Purpose-built offices or major com- Stonebridge Park station to a degree which would partially community facilities are only acceptable if there are sub- pensate for its public transport accessibility, which is not good. stantial improvements to bus services and facilities, Other potential uses of the site which would be acceptable are car and substantial upgrading of the quality of the pedes- sales and community facilities. trian and cycle link to Stonebridge Park station.

13.10.6 The existing rifle club facilities on the eastern part of the Twyford Development of the former Twyford Tip site should Tip site are considered of London-wide value by Sport England include remediation and / or removal of existing con- and, therefore, measures to relocate the club will be secured as taminated soil (Policy EP6) and the western part shall part of any consent for development. include a minimum of 0.1 Ha public open space. Measures to assist in the relocation of the existing rifle club will be secured on the eastern part of the site.

Applications to intensify existing waste management operations will be refused.

South of the North Circular Road individual sites should have restricted single access to Abbey Road only.

Environmental Improvements along the North Circular Road, linking to the London Borough of Ealing, will be sought from major development.

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13.11 CENTRAL MIDDLESEX HOSPITAL Development in the area should generally accord with an agreed development framework agreed with the 13.11.1 At the Central Middlesex Hospital in Park Royal, the disposal of NHS Hospital Trust, with a requirement to implement allotment and other lands to its rear has led to the creation of a measures designed to reduce car-use and is subject to new business / industrial park. This has funded a series of new sufficient improvements to public transport services & healthcare buildings. There are benefits in designating a hospital facilities to accommodate any intensification. zone, in terms of ensuring complementary facilities are located close to one another, thus reducing the need to travel, and ensur- Development for employment uses is permitted on ing that any conflict between the hospital and employment use is sites on the boundaries of the zone, whereon they minimised (see Community Facilities chapter para 11.9.1). shall become part of the Park Royal Strategic Development on the boundary with this area should not prejudice Employment Area. the functioning of the hospital. Development on sensitive boundaries with hospital 13.11.2 Although the extent of the hospital facilities has yet to be finalised, uses shall not prejudice the hospital's operation. it is considered that a boundary for the hospital site can be identified whilst retaining some flexibility over the use of certain sites adjacent to the boundary where hospital or employment uses will be permitted. Major new healthcare facilities, a science park and associated facilities are proposed, and for this reason, part of the area is proposed as a major opportunity site (including land currently in short term employment use).

13.11.3 Brent has been in close discussion with the Hospital Trust regarding a development framework for the area which will determine the future development of individual plots for a variety of purposes.

PR7 CENTRAL MIDDLESEX HOSPITAL ZONE

Within the Central Middlesex Hospital Zone, as shown on the proposals map, the following uses are permitted:

• Hospital / healthcare;

• Associated Higher & Further Education;

• Ancillary housing / hostel accommodation (e.g. Nurses Homes) & supported housing;

• Associated administrative offices or small scale offices providing business services to Park Royal (A2 use);

• Small scale retail / leisure facilities necessary to service visitors to the hospital and workers in the area (generally less than 200m2); and

• Associated sporting facilities, including a minimum of 0.1Ha of open space.

In addition, in the Central Middlesex Hospital, Major Opportunity Site development for Business / Technology Park with ancillary facilities will be permitted.

/...

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Page WEM13 TRANSPORT IMPACT OF THE PROPOSED NATIONAL STADIUM 264 14.1 INTRODUCTION 254 WEM14 STADIUM ACCESS CORRIDOR 264 14.2 BACKGROUND - WEMBLEY TODAY 254 WEM15 ESTATE ACCESS CORRIDOR 264 14.3 STRATEGIC CONTEXT 254 14.8 URBAN DESIGN QUALITY 14.4 POLICY OBJECTIVES 255 IN WEMBLEY 264

14.5 BOROUGH STRATEGY 255 WEM16 URBAN DESIGN QUALITY - WEMBLEY REGENERATION AREA 265

POLICIES & PROPOSALS WEM17 THE PUBLIC REALM - WEMBLEY REGENERATION AREA 265 14.6 REGENERATION FRAMEWORK FOR WEMBLEY 256 WEM18 DESIGN OF BUILDINGS ALONG OLYMPIC WAY 266 WEM1 REGENERATION OF WEMBLEY 257 WEM19 VIEWS OF THE STADIUM 266 WEM2 PEDESTRIAN ROUTE/PROMENADE 257 WEM20 RIVER BRENT CORRIDOR/WATER COURSES IN WEM3 LOCATION OF LARGE SCALE RETAIL, LEISURE WEMBLEY 267 AND ENTERTAINMENT USES 258 14.9 WEMBLEY TOWN CENTRE 267 WEM4 RESIDENTIAL DEVELOPMENT WITHIN THE WEMBLEY REGENERATION AREA 259 WEM21 WEMBLEY TOWN CENTRE 268

WEM5 RELOCATION OF EXISTING BUSINESSES 259 WEM22 LIBRARIES IN WEMBLEY 268

WEM6 WEMBLEY STADIUM BUSINESS PARK 260 14.10 OTHER SHOPPING AREAS 268

WEM7 ACCESS TO DEVELOPMENT - THE NATIONAL WEM23 WEMBLEY PARK DISTRICT CENTRE 268 STADIUM POLICY AREA 260 WEM24 THE WEMBLEY STADIUM MARKET 269 WEM8 THE NATIONAL STADIUM POLICY AREA - DEVELOPMENT OUTSIDE THE AREA OF VERY 14.11 MAJOR DEVELOPMENT OPPORTUNITIES GOOD PUBLIC TRANSPORT ACCESSIBILITY 260 IN WEMBLEY 269

WEM9 COMPREHENSIVE DEVELOPMENT - THE WEM25 THE NATIONAL STADIUM 269 NATIONAL STADIUM POLICY AREA 261 WEM26 SPORTING FACILITIES 270 14.7 TRANSPORT IN WEMBLEY 261 WEM27 OPPORTUNITY SITES AT THE JUNCTION OF WEM10 IMPROVED RAIL STATIONS AND PEDESTRIAN OLYMPIC WAY AND ENGINEERS WAY 270 LINKS 262 WEM28 WEMBLEY TOWN CENTRE OPPORTUNITY WEM11 ON-STREET PARKING CONTROLS FOR WEMBLEY SITES 271 262 WEM29 WEMBLEY PARK STATION SITE 272 WEM12 SHORT STAY CAR PARKING IN THE WEMBLEY REGENERATION AREA 263

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WEM30 WEMBLEY STADIUM STATION/SOUTH WAY ture. Consequently, it now has a run-down appearance, not fitting SITE 272 an internationally renowned location and suffers from severe traffic congestion (see Town Centres and Shopping chapter section WEM31 CHARRINGTONS YARD/NEASDEN GOODS 8.2). Despite its decline, it remains the largest centre wholly with- YARD 273 in the Borough, with over 50,000 sqm. of floorspace and over 200 units, and includes a number of national multiple stores such as Woolworths and Marks and Spencer. It is currently categorised MAP WEM1 LONG DISTANCE VIEWS OF WEMBLEY as a major centre within London and remains an important focus STADIUM 274 for the local community.

MAP WEM2 SHORT DISTANCE AND INTERNAL 14.2.3 Another, though smaller, focus for the local community is VIEWS OF WEMBLEY STADIUM 275 Wembley Park district centre which in recent years has become increasingly important as a shopping and service centre building on its very good public transport access and location on the principal 'gateway' to the Stadium. 14.1 INTRODUCTION 14.2.4 The industrial estate, which is an important source of jobs, suf- 14.1.1 The UDP provides the statutory land-use framework for the fers from a poor environment, poor access by public transport regeneration of the Wembley Area. The inset plan area includes and its road system does not meet the needs of firms on the the Stadium and its surroundings, its main approaches and estate. On occasion there is conflict with traffic from events at the Wembley town centre. In this way the perception of ‘two stadium. There are a number of vacant sites and premises in the Wembleys’ - the Stadium area and the town centre - can be over- area. come and the area planned as a whole. 14.2.5 In recent years the commercial area north and west of the 14.1.2 In December 1996 the Sports Council confirmed Wembley as the Stadium, characterised by a number of large purpose-built offices chosen location for a new English National Stadium. The site of and older commercial premises as well as the Wembley complex the Stadium is surrounded by a declining industrial and commer- of exhibition halls, Conference Centre and Arena, has also cial environment and it is adjacent to a declining and run-down declined to the extent that much of the office space in the area is town centre. This is an inappropriate setting for the new Stadium. vacant (estimated at about 37,000 sq m in 1997). The conse- The redevelopment of the Stadium, which has now commenced, quent loss of employment has had a depressing effect on the provides the ideal opportunity to deliver the much-needed regen- local economy of the area emphasising the need for regenera- eration of the Wembley area by acting as a catalyst for invest- tion. ment. There are a number of potential major development sites in the area. These, if appropriately developed, can further 14.2.6 The area now benefits from regeneration funding, including London's position as a World City by providing major sporting, Single Regeneration Budget, Assisted Area status and European recreational and entertainment facilities and accommodation for Objective 2 status. In addition, the Government has set up the visitors, and can also benefit the local community by providing Wembley Task Force to co-ordinate the regeneration of the area improved shops, services, new housing, transport and environ- and secure necessary infrastructure improvements. National and ment as well as job opportunities. European regeneration funding is being co-ordinated to this end.

14.2 BACKGROUND - WEMBLEY TODAY 14.3 STRATEGIC CONTEXT

14.2.1 The area covered by the inset plan benefits from very good public 14.3.1 In recent years there has been a change in emphasis in transport accessibility, with 3 rail/underground stations serving Government planning guidance towards more sustainable devel- the area. The public transport system, however, has severe prob- opments which reduce the reliance on the car and, in recognition lems of poor capacity, interchange and the quality of stations. The of the damaging effect out of centre developments have had on main roads in Wembley are often congested and local residents town centres, to prevent further damage by limiting the growth of suffer from the impact of events. In addition, the environment of out of town shopping and leisure. the area is generally poor, especially in the town centre and the Wembley industrial estate. Although the Stadium, Arena and 14.3.2 The new approach is included in Strategic Guidance for London Conference Centre continue to attract national and international Planning Authorities (RPG3) issued in May 1996 and revised visitors, they no longer meet expectations in terms of the quality PPG6 on Retail Developments and Town Centres issued in June of facilities. Despite this the Wembley brand image remains 1996. The key features of strategic guidance (RPG3) relevant to strong and is known throughout the world. the Wembley area are set out below:

14.2.2 Of particular concern has been the long term decline of the town • Wembley Park is highlighted as lying within a West London centre, which has suffered from the impact of nearby new retail Regeneration corridor of fundamental regional and national developments and a lack of investment in its transport infrastruc- importance. Development focused on public transport infras-

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tructure is particularly stressed. Wembley Stadium/ • To minimise any negative environmental impacts of the new Conference Centre is highlighted as enjoying good public National Stadium and associated development. transport access which there are plans to enhance, thereby • To ensure that development in the area is environmentally improving the area’s ability to attract high volumes of partici- sustainable. pants and spectators to major events in competition with other centres in the UK and Europe. • Developments to enhance the sporting facilities of sites of 14.5 BOROUGH STRATEGY national and international importance, such as Wembley Stadium, should be encouraged. 14.5.1 The planning strategy for the Wembley area aims to promote the • It identifies a hierarchy of town centres for London with regeneration of the area as a regional sports, entertainment and Wembley shown as a major centre. leisure destination, taking advantage of the opportunities present- • It endorses the identification by the London Planning Advisory ed by the National Stadium development and the potential for Committee (LPAC) of Preferred Industrial Locations, including development of sites in the surrounding area. The Council’s aim the Wembley Stadium area. Guidance sees the areas identi- is to achieve a critical mass of visitor attractions, building on the fied as strategic by LPAC as being those which should be area’s current role as a major leisure and entertainment centre for promoted as destinations for major regenerating investment London. This can include leisure, sporting and retail uses as well with preference being given to retaining them for employment as new hotels and places to eat and drink. Such uses will be com- uses. plementary to the Stadium and other existing attractions in the area such as the Arena and Conference Centre, the retention or 14.3.3 The Borough supports, through West London Leadership, the enhancement of which the Council supports. The intention is that Strategic Development Framework for West London which pro- Wembley will become an all year round visitor destination cater- motes Wembley as a key development node for leisure-driven ing for a range of entertainment and leisure activities as well as regeneration. Stadium and Arena events and conferences.

14.5.2 At the same time it is important to ensure that new development 14.4 POLICY OBJECTIVES also fully benefits local people rather than adversely affecting their ability to access facilities. In accordance with 14.4.1 The objectives for the area are as follows: Government guidance, development which attracts significant numbers of the general pub- • To promote the development of the lic must, therefore, be accessible and sus- National Stadium, and associated tainable, by being either located in the town sporting, leisure, tourism and centre or nearby with good pedestrian mixed-use development so that links to the centre. This will require an Wembley becomes a major improved link from major sites around visitor destination, capable of the Stadium to Wembley Town Centre. A attracting international sport- key element of the strategy, therefore, is ing festivals and other major the provision of a pedestrian route or events to London. promenade linking the three stations in • To ensure that the develop- the area together. In this way the area ment around the National as a whole can benefit from regenera- Stadium is compatible and tion. In due course the development of co-ordinated with comprehen- these sites and westwards links could lead sive regeneration proposals in to the eastwards shift in the core of the the surrounding area and that the town centre, evolving into an expanded vitality and viability of Wembley town strategic town centre for London. Proposals centre is enhanced. that are reliant upon access by car, and not linked • To ensure that the local community benefit to the town centre, could potentially undermine it and from the new National Stadium and other regenerative are not, therefore, acceptable. The area around the Stadium development. should be developed comprehensively if the desired linkages, • To provide a world class setting for a world class Stadium. shared infrastructure and an appropriate setting for the Stadium is • To secure the preservation and enhancement of the integrity to be achieved. The Council will, if necessary, use its planning and setting of the three listed buildings close to the Stadium. powers to ensure that development is comprehensive. • To provide an enhanced transport system which can clear event pedestrians and traffic, whilst minimising nuisance to 14.5.3 It is envisaged that the existing town centre will evolve so that it local residents. plays a complementary role to new development near the • To achieve a shift away from use of the car in favour of public Stadium to the east. The centre can develop and expand its role transport, walking and cycling. in meeting local and specialist needs . At the same time, the east- • To ensure that the infrastructure of Wembley is upgraded to ern end of the centre can benefit from its proximity to new devel- support the proposed developments.

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opment to the east, and build on the centre's role as a 'gateway' facilities improved. The usage of Wembley Central Station for to the Stadium, by developing the evening economy with food accessing events can also be increased, and an attractive service and drink and other evening entertainment uses. provided for users of the town centre and visitors to the area generally. In addition, because of the need to minimise the 14.5.4 The major part of the industrial estate to the east of the inset area, impact of the Stadium on businesses in the area, and to promote which remains an important provider of employment of strategic appropriate regeneration of the Stadium and the area around it, importance to London, is protected for employment uses (see certain road improvements are considered necessary. policy EMP5). The development of modern business uses will be encouraged adjacent to the re-aligned eastern road access to the 14.5.7 Finally, a key part of the strategy is to provide clear urban design Stadium. guidance so as to achieve a high quality of design, including that of the public realm. The success of the whole area is fundamen- 14.5.5 The planning strategy should also enhance the prospects of tally dependent on the creation of a world class environment. It is Wembley becoming the focus for international sporting festivals important that visitors are attracted to the area, principally by the and, in particular, help support a future London Olympic bid. existing and proposed visitor attractions, but also that they should Experience elsewhere suggests that there are significant advan- feel comfortable in a high quality attractive environment. tages in creating a cluster of associated sporting facilities. Attracting more people to the area, and encouraging them to Therefore policies allow for the future provision of sporting and stay, will provide a major boost to the local economy and local ancillary facilities which should be located, preferably, in close people will benefit from better shops, services and leisure oppor- proximity to the Stadium. Sporting facilities that do not attract tunities as well as improved job prospects. large numbers of people will generally not require the same level of public transport access, nor do they need to be as closely linked to the town centre as other uses envisaged for the area, POLICIES AND therefore a location north and east of the Stadium adjacent to the PROPOSALS employment area would be appropriate. 14.6 REGENERATION FRAMEWORK FOR 14.5.6 The area as a whole has a number of advantages, with particu- WEMBLEY larly good rail connections to Central London, as well as direct links to the strategic road network. However, the existing trans- 14.6.1 The key development sites for regenerating the area are located port infrastructure is out of date and of poor quality and will in the Wembley Park / Stadium area east of the town centre. In require upgrading to support the level of development envisaged accordance with the area's strategic role as a regional sport, as it is currently a major constraint upon development. Major leisure and entertainment destination, development for uses com- transport improvements are therefore an essential component of patible with this are particularly encouraged. In addition, develop- the strategy to regenerate the area, and development in the area ment that would result in an expansion of the town centre, so that will be expected to contribute to these and other infrastructure it can develop as a strategic centre for London as outlined above, improvements. The strategy proposes an integrated approach will also be encouraged. Regeneration of the Strategic towards land-use and transport so that major opportunity sites Employment Area east of the Stadium for industry and warehous- can be accessed in a sustainable manner. The emphasis is on ing will also be sought, with business uses promoted adjacent to improvements to public transport together with traffic manage- a new Stadium Access Corridor . ment measures to alleviate congestion and the impact of traffic on pedestrians, particularly in the town centre. It is particularly important that the problems of the stations are addressed. The capacity of Wembley Park station will have to be increased and

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also be provided along the route, especially adjacent to the new WEM1 REGENERATION OF WEMBLEY Stadium so that there is an opportunity for visitors to gather and linger. The design of the route should also address the differ- The Regeneration of the Wembley Area as a regional ences in level from Olympic Way and South Way to the Stadium sport, entertainment and leisure, including hotel, concourse. In addition it will help encourage vitality on non-event destination will be supported. The regeneration of days. It is intended that this promenade and the public spaces Wembley town centre is also supported, which may along it becomes a new focal point for public activities and the involve the eastward expansion of the existing centre means of structuring the major development on sites around it. towards the Stadium. Industrial and business development is promoted in the Strategic Employment Area 14.6.3 The promenade and public space proposals are likely to be to the east of the Stadium. New residential develop- developed over time and eventually form a major new public ment may also be appropriate where an acceptable space for London. Major development in the area should con- residential environment can be ensured. tribute towards the development of this route.

WEM2 PEDESTRIAN ROUTE/PROMENADE PROPOSED PEDESTRIAN FRAMEWORK A pedestrian route will be sought to the north and 14.6.2 A key element of the planning strategy for the area is improved west of the Stadium linking Olympic Way to Wembley pedestrian links, particularly the development of a pedestrian Town Centre, as part of the development of opportuni- route or promenade from Wembley Park station through to ty sites referred to in Policy WEM28. Contributions to Wembley town centre which will link the three stations in the area the development of the route will be sought from together and serve development alongside it. (See policy development served by it, or it should be demonstrat- WEM10 on the Three Stations Strategy.) The northern part of this ed how development will contribute to securing the pedestrian link will be Olympic Way, then it is intended that it route. should curve westwards past, and linking with, the new Stadium concourse through to Wembley Hill Road and then to the town Development along the route should, where centre, either via the High Road or through the Chiltern Line possible, have active and animated frontages at Cutting site if developed. This would create a 'Wembley ground floor level. Promenade' and be the key physical element in linking new development close to the Stadium with the town centre and in Public spaces will be sought adjacent to the route and improving links between the three stations. Other pedestrian the Stadium concourse. routes should link to it, thus providing an overall pedestrian framework for the area. The form and nature of the promenade should be such that pedestrian journeys do not simply terminate at the Stadium but that visitors may be attracted to surrounding development and through to the town centre. Public spaces should

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LOCATION OF DEVELOPMENT of linked trips that are made both from the town centre to the Stadium area and vice versa. It may, therefore, be appropriate to LARGE SCALE RETAIL, LEISURE AND ENTER- characterise the key opportunity sites as edge of centre, depend- TAINMENT USES ing on whether a link exists or is planned at the time the development is proposed. An attractive pedestrian route, as well as pro- 14.6.4 In order to ensure that development in the area is accessible to moting linked trips, will also facilitate ease of access for visitors to the whole community, an area has been defined from Wembley the new Stadium, and surrounding attractions, from the High Park to Wembley town centre which broadly corresponds to the Road and, in particular, from Wembley Central station. area of good and very good public transport accessibility. This area, known as the National Stadium Policy Area, has the capacity to deal with current major events and the potential for this WEM3 LOCATION OF LARGE SCALE capacity to be enhanced to cope with an increase in the number RETAIL, LEISURE AND of visitors. ENTERTAINMENT USES

14.6.5 Although a range of uses attracting large numbers of visitors or Large scale leisure entertainment and retail uses will customers will be appropriate within the National Stadium Policy be directed to the National Stadium Policy Area, sub- Area, it is necessary to ensure that development does not have ject to compliance with the sequential approach to an adverse effect on the ability of local people to easily access a selecting sites for such uses (see Policy SH3 of the good range of shops and services. Development should also Town Centres and Shopping chapter), and to the meet the objective, set out in Government planning guidance, of requirements of policy WEM8 relating to public trans- allowing for multi-purpose trips by locating facilities close to one port accessibility . New development on the Major another and by providing good pedestrian links between them. Opportunity Sites to the east of Wembley town centre This is the basis of the sequential approach to development, should function as an extension of the existing town explained in the Town Centres and Shopping chapter (policy centre and be integrated with it. It should benefit the SH3), by which development should be directed in the first town centre in quantitative and qualitative terms and instance to the town centre. Within the National Stadium Policy enhance its role as a gateway to the National Stadium Area, large scale leisure, entertainment and retail uses are appro- and associated development. To that end, develop- priate subject to the sequential approach to site selection being ment should provide, or contribute towards, improved applied. Any major foodstore development should be within the pedestrian links to the town centre. The links should, town centre, given such a store's role in meeting local needs and where possible, have pedestrian and dedicated bus the current lack of a good quality facility within the town centre. priority, and continuous active frontages. Section 14.9 explains in more detail how it is envisaged the town centre can develop and identifies measures for improving the Major foodstores will be directed to sites within or environment of the centre. adjoining the existing town centre (see Policy WEM28). Elsewhere, foodstores will be restricted to a 14.6.6 In applying the sequential approach to proposed development maximum of 2,000 sqm. gross floorspace. east of the existing town centre, considerations will include the proximity of proposed development to the edge of the existing centre, the ability to use a pedestrian link with the High Road easily, and the attractiveness of the route. If a proposed development contributes to regeneration of the town centre and the area HOTELS around the Stadium, this will be a significant material consideration in determining a planning application for that proposal since 14.6.8 There has been substantial demand for hotel development in the the regeneration of these areas is important, as explained in para- area. Wembley has been singled out by The London Tourist graphs 4.1.1 - 4.2.6. Retail proposals could have a significant Board and London First as one of the three most promising loca- role to play in regenerating the town centre, providing that new tions for hotel development in London. Large hotels are encour- development facilitates the making of linked trips with the existing aged to locate in the National Stadium Policy Area (see policy centre. The provision of a good, attractive pedestrian route with TEA6). active frontages along it will help achieve this. OFFICES 14.6.7 The key opportunity sites in the Wembley Area are close to the Stadium and extend to within 50 metres of the edge of the town 14.6.9 There has been limited demand for new office development in the centre at Wembley Hill Road (as defined by the extent of the area for a number of years now and the amount of available Secondary frontage). Although this point is over 400 metres from vacant floorspace remains relatively high despite the fact that the designated Primary frontage, given the proximity to the town some offices have changed to alternative use. However, the loca- centre, the provision of an attractive pedestrian link will allow tional advantages of the area and the impetus provided by regen- linked trips to be made between the existing High Road and new eration may lead to a revival of demand for office space and, development to the east. The presence of the Stadium and other therefore new development proposals. New purpose-built office existing attractions in the vicinity is likely to increase the number development will be directed to the National Stadium Policy Area

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(see policy EMP16). There may also be pressure for the alternative use of existing redundant office buildings. The most common WEM4 RESIDENTIAL DEVELOPMENT WITHIN type of conversion of redundant office buildings in London is to THE WEMBLEY REGENERATION AREA residential use. Much of the National Stadium Policy Area suffers noise and disturbance from events so is unlikely to be suitable for Higher density residential development is encouraged residential conversion. Conversion to hotels is more likely to be within the Wembley Regeneration Area, particularly acceptable in the area. Policy WEM4 deals with the provision of Wembley Town Centre. Development on sites capable new residential development, including conversions, in the area. of 15 or more units should be a mixture of general market housing and affordable housing suitable for smaller households (including key workers) - unless 'provision-in-lieu' (Policy H4) is more appropriate .

Residential development/conversion in the National Stadium Policy Area east of Empire Way/Wembley Hill Road will be acceptable where:

(a) It is in locations where residents would not suffer undue inconvenience from restrictions on access during event days and where they would not suffer from unacceptable noise; (b) It is a subsidiary element (preferably on upper floors) of a more comprehensive mixed-use proposal (Policy BE11); and (c) The site is outside the Strategic Employment Area.

EMPLOYMENT DEVELOPMENT RESIDENTIAL DEVELOPMENT 14.6.11 The area to the east of the National Stadium Policy Area has sig- 14.6.10 High density residential development was a feature of the early nificant regeneration opportunities. The Wembley Park employ- development of parts of Wembley. New residential development ment area is currently one of the main employment areas of North could play a key role in the regeneration of the area adding to the West London and is, consequently, identified in the Employment vitality of the area. The Council is keen to ensure that there is not chapter as a Strategic Employment Area (SEA). It is well away an over-concentration of a single type of housing and that the from the Stadium where the operation of businesses, because of housing provided is suitable for non-family households. There the provision of new road access, can benefit from a minimum of are practical difficulties in developing housing in certain parts of interference from Stadium and other events. That part of the the National Stadium Policy Area, however, as the sheer scale of existing industrial estate close to the Stadium has not been crowd movements, together with associated access controls, included in the SEA and provides opportunities for new facilities to means that on event days many residents in the Wembley Park be developed, subject to the provision of appropriate access. area suffer from restrictions on access to and from their homes. Residential amenity in the area also suffers from noise from major 14.6.12 If redevelopment of existing employment sites for other uses events, particularly concerts at the Stadium. occurs, then existing employment may be lost. There is a clear need, therefore, for a strategy to relocate firms locally so that there is no net loss of employment in the area. Permission for the alternative use of occupied employment sites within the area, therefore, will be granted only if the occupier can be satisfactorily relocated locally.

WEM5 RELOCATION OF EXISTING BUSINESSES

The satisfactory relocation of displaced businesses will be sought where development involves the loss of employment uses (as defined in the Employment Chapter).

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WEMBLEY STADIUM BUSINESS PARK to secure a desired modal split which minimises car-use so that development is orientated towards public transport, walking and 14.6.13 An area between First Way and Fourth Way contains a number of cycling. vacant and under-used sites with very poor road links and a number of private roads. The proposed road improvements to form the Stadium Access Corridor (policy WEM14) will facilitate the WEM7 ACCESS TO DEVELOPMENT - THE regeneration of the area including the creation of a new road cir- NATIONAL STADIUM POLICY AREA culation system and improved vehicular access. The redevelopment of this area for business uses in high quality buildings and Development in the National Stadium Policy Area landscaping, will be encouraged, subject to improved public should be designed principally for access by public transport accessibility. transport, walking and cycling rather than by private car. As a result, planning obligations will be secured for the improvement of local infrastructure and public WEM6 WEMBLEY STADIUM BUSINESS PARK transport, where the transport impact of the proposal justifies such measures. The redevelopment for business uses of the area east of the Stadium (as shown on the proposals map) will be encouraged (see also Policy WEM14). DEVELOPMENT OUTSIDE THE AREA OF VERY GOOD PUBLIC TRANSPORT ACCESSIBILITY Development attracting large numbers of workers should contribute to public transport improvements 14.6.16 The main reason why the National Stadium Policy Area is which are appropriate to the scale of development deemed appropriate for uses attracting large numbers of visiting proposed and the overall aim of significantly increas- members of the public is that most of it lies within the area of very ing public transport usage and reducing use of the pri- good public transport accessibility (see Transport Chapter section vate car. 6.7). However, part of it to the east of the Stadium lies outside this area. Although physically suitable for uses attracting large numbers of people, this will only be acceptable in transport impact terms if there is an improvement in public transport accessibility DEVELOPMENT PRINCIPLES within the area. Examples of the type of development which may be appropriate are sports or conferencing facilities. Uses such as MIXED USES retail or leisure are unlikely to be acceptable if subject to the sequential approach to site selection. 14.6.14 There is also a general requirement for a mix of land uses within the National Stadium Policy Area. This will help achieve the objective of transforming Wembley into a vital urban area with a WEM8 THE NATIONAL STADIUM POLICY AREA rich mix of uses. A wide range of uses will be acceptable includ- - DEVELOPMENT OUTSIDE THE AREA OF ing hotels, housing (subject to policy WEM4), offices, retail, food VERY GOOD PUBLIC TRANSPORT and drink, etc. In determining applications, regard will be had to ACCESSIBILITY the closeness of the relationship to the town centre and to the nature of uses proposed. For example a high retail component Development to the east of the Stadium outside the might be acceptable on sites close to Wembley town centre area of very good public transport accessibility (as whereas event-based leisure facilities are more appropriately shown on the proposals map) which would attract located on sites further away from the town centre. See also poli- large numbers of people, will be permitted only where cy BE11 in the Built Environment chapter. there are accompanying major improvements to public transport and accompanying links to a station. ACCESS TO DEVELOPMENT COMPREHENSIVE DEVELOPMENT 14.6.15 Policies TRN 1-TRN 4 in the Transport Chapter will be used to assess the transport impact of major development as well as the 14.6.17 It is recognised that land ownership within the area is in part frag- special policies in section 14.7 of this chapter. It is likely that sub- mented and that land assembly will be required to create appro- stantial contributions will be required for a range of transport mea- priate development sites. There is a need, therefore, for a com- sures, which will be sought from development. The necessary prehensive approach to development so that the full regeneration infrastructure will include improvements to the stations serving benefits can be realised. Also, it will not be possible to achieve the area as well as links to them (policy WEM 10), and an the proposed pedestrian linkages and shared infrastructure nec- improved link to the North Circular Road (policy WEM14), without essary for the area, particularly the shared parking, (see policy which the potential scale of regeneration might not be achieved. WEM12) by the uncoordinated development of individual sites. This will be necessary even with a very high modal split in favour For this reason it is considered important that the key sites to the of public transport. A balanced package of measures is required north and west of the Stadium are developed comprehensively. Further guidance on this is provided by supplementary planning

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guidance, which includes a design framework for the area togeth- • To create a road access to the Stadium that, as well as serv- er with development briefs for opportunity sites. The Council is ing as the main vehicular access is also of a high quality in prepared to use its full range of planning powers, including where environmental terms providing a world class setting for the necessary compulsory purchase, to ensure that there is a com- National Stadium; prehensive approach to development. • To improve bus priority and interchange in Wembley, especially on orbital routes linking stations, and to improve the frequency and penetration of bus services to the east of the WEM9 COMPREHENSIVE DEVELOPMENT- Stadium; THE NATIONAL STADIUM POLICY AREA • To reduce traffic, improve servicing, and reduce pedestrian/ vehicular conflict in Wembley High Road so that a pedestrian- The area to the north and west of the Stadium, as friendly environment is created. shown on the proposals map, should be developed comprehensively in accordance with the guidance THE LOCAL TRANSPORT STRATEGY FOR provided by the design framework for the area and WEMBLEY other relevant supplementary planning guidance. On other sites, development should demonstrate how 14.7.4 If major regeneration opportunities in the area are to be realised, good links to, and a proper relationship with, then major transport improvements are necessary. The local adjoining sites are achieved. transport strategy (policy TRN21) for Wembley is, therefore, based around the following principles:-

• For the Stadium to operate effectively, with an acceptable level of parking, there is a need to secure major public trans- 14.7 TRANSPORT IN WEMBLEY port improvements. • Pedestrians using public transport to access the Stadium and 14.7.1 A key to successful regeneration in the Wembley area is good major opportunity sites in the area should benefit from a radi- transport. Development proposals are calling into question the cally upgraded pedestrian environment. existing transport system and its ability to serve the new National • Segregation, as far as possible, of event and non-event traf- Stadium and the wider Wembley Complex, especially in terms of fic. An improved junction with the A406 North Circular Road attracting international sporting events and being able to cope will be sought if the scale of new development proposed war- with increased numbers of events, whilst also maintaining its local rants it (see policy TRN19). functions. • Limitations on junction and highway capacity will also require controls on the total amount of car parking provided and the 14.7.2 The problems of the town centre are accentuated by conflicts in management of it. use of its road system, between buses, other traffic and pedestri- • To avoid unacceptable parking and traffic related impacts in ans, lack or rear servicing and a poor pedestrian environment. residential areas, there needs to be an expansion of both Whilst much of the area enjoys a good level of public transport event related and non-event related on-street parking con- accessibility, the convenience for public transport users is trols, with a corresponding increase in other traffic restraint extremely poor, with buses taking some time to get through the and calming programmes. town centre, and interchange facilities at the three stations being unattractive and substandard. A comprehensive upgrading of the THE ‘THREE STATIONS STRATEGY’ infrastructure for the area is needed. 14.7.5 The experience of visitors to Wembley is currently marred by the THE DETAILED TRANSPORT OBJECTIVES FOR poor quality of the ‘gateways’ to the area, in particular the road WEMBLEY links to the east and the three stations. There are also key problems associated with the three stations in Wembley in terms of 14.7.3 The wider objectives for transport are supplemented by a number their ability to service the increased visitor flows to the proposed of more detailed transport objectives for Wembley as follows: - National Stadium, with its increased capacity which may be exacerbated by the development of further new visitor attractions. No • To achieve regeneration in the area whilst ensuring that the one station alone can cope with the likely scale of visitors. There transport network can operate efficiently; is a need, therefore, for an upgrading of all three stations, • To develop an enhanced transport system capable of safely improved interchange and safe and upgraded routes from the clearing all event pedestrians and vehicles broadly within 90 stations to the proposed Stadium. All three stations also offer minutes, in line with the objective of the Stadium planning opportunities for major redevelopment (see policies WEM 28, 29 brief; & 30). • To provides links to strategic rail proposals such as Crossrail and the Heathrow-City Link; 14.7.6 To address these issues the ‘three stations strategy’ attempts to • To achieve a balanced upgrading of the capacity, quality and secure integrated improvements to the stations as well as ease of interchange of the three railway stations in Wembley; improved pedestrian links from them to the centres of activity.

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WEM11 ON-STREET PARKING CONTROLS FOR WEMBLEY

As part of the application for the proposed National Stadium and other major development, measures will be secured to enhance/extend on-street parking controls in the area and around key stations for accessing the area, to control any increase in on-street parking problems.

SHORT STAY CAR PARKING IN THE WEMBLEY REGENERATION AREA

WEM10 IMPROVED RAIL STATIONS AND 14.7.8 Wembley Town Centre Car Parking. At present there are approx- PEDESTRIAN LINKS imately 550 off-street and 210 on-street car parking spaces in Wembley Town Centre. There is a comparatively poor level of An upgrading of all three rail stations in Wembley will take up of off-street spaces (about 60% on weekdays) indicating be secured, including improved interchange facilities the poor quality and location of existing car parks. The level of and pedestrian links to them, and, if necessary, an congestion on Wembley High Road is a disincentive to those increase in the capacity of the rail networks serving wishing to access the centre by car. This can be overcome to them. Development should be in accordance with the some extent by the provision good quality car parks at the eastern general policy on the design of new stations (TRN8). and western ends of the High Road. The aim is to achieve this, through new development opportunities and by improving two principal car parks, at Montrose Crescent and Elm Road. It will then be possible for certain other, poorly located, car parks to be PARKING STRATEGY FOR THE phased out and the sites developed. WEMBLEY REGENERATION AREA 14.7.9 Parking around the National Stadium. The level of capacity in the ON-STREET PARKING AND TRAFFIC highway network will put a limit on the level of visitor parking in MANAGEMENT the National Stadium Policy Area. Much of the parking will be available solely for the Stadium (to its agreed parking level) on 14.7.7 It is the Council's view that the operation of the new National event days, but should also be made available for use by other Stadium will only be effective with a comprehensive review of facilities in the area at other times. Further details are given in the parking controls and a strategy for reducing travel to the Stadium development framework for the area. As major planning applica- by car. In addition to the event-related parking problems there is tions come forward, transport assessments should examine how increasing pressure on residential streets in the Wembley area for much parking potential remains in the area. If the provision of parking space because of increasing car ownership and com- short term, managed parking for the Stadium and other visitor muter pressure close to the three stations and commercial areas. attractions was shared, then this would significantly reduce costs The wider regeneration proposals in the National Stadium Policy and represent an effective use of land. It is important that the pro- Area pose the risk that this currently unacceptable situation will posed shared parking measures are practical and do not under- be exacerbated. The Council has already introduced areas of mine the overall goal of parking restraint. If full capacity is controlled parking in Wembley Hill and is committed to extend reached then the level of parking will remain constant whilst the those areas following an ongoing programme of consultation and amount of development in the area increases. This will achieve a review. As part of the Stadium redevelopment, it will be neces- modal shift away from car use over time. In aiming to reduce the sary, therefore, to secure on-street parking and management traffic impact of the Stadium, and reduce private car traffic to it, it measures extending over a large area, including areas around will be necessary to restrict the operation of temporary charged stations remote from the Stadium. parking for events on new development. It will also be necessary to prevent new development overcoming the limitations on the amount of parking allowed through the use of off-site contract parking. This will generally require applicants to enter into a planning obligation (both for developments of parking and uses which could make use of parking nearby). Policy TRN29 in the Transport chapter deals with such controls.

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sures will be sought from developments in the Wembley WEM12 SHORT STAY CAR PARKING IN THE Regeneration Area, to ensure that they do not cause unaccept- WEMBLEY REGENERATION AREA able transport impact:- (a) Improvements to visitor signage; Parking within the National Stadium Policy Area for (b) New cycle facilities, routes and lanes; major new developments attracting visiting members (c) Public transport improvements including new bus routes/ser- of the public, should be shared, public parking. This vice improvements; should have maximum stay restrictions and not be (d) Junction improvements, turning restrictions and road closures reserved for individual developments (other than - with bus, pedestrian and cyclist priority; hotels, Stadium event day parking and for essential (e) Traffic management measures to concentrate traffic on the operational parking). In assessing the appropriate existing and proposed local distributor road network so that amount of parking for a development, regard will be the Estate and Stadium Access Corridors serve their primary had to the amount of existing publicly available function rather than becoming through routes; parking in the area, and the capacity and accessibility (f) The promotion of an area travel plan initiative in line with of public transport, as well as the standards in the regional and national guidance. Plan. Parking provision should not exceed the standards specified in TRN22. Parking areas for Major 14.7.11 The section below deals specifically with the transport impact of Opportunity Sites, identified in WEM27, should be pre- the proposed National Stadium to which special considerations dominantly accessed from First Way via the proposed apply. Stadium Access Corridor, and be located to be convenient to serve all of these sites. Smaller satellite car parks may also be acceptable. TRANSPORT IMPACT OF THE NATIONAL STADIUM The total number of additional off-street visitor parking spaces permitted will be limited (including spaces 14.7.12 Stadium traffic currently has a negative impact on local residents for the new National Stadium, policy WEM13) to the and businesses and attracts a high level of trips by the private car. level that environmental constraints and highway The proposed 15% increase in the capacity of the Stadium, capacity in the area can sustain. When this level is together with a necessary reduction in parking, could place reached, no further parking will be required or stress on transport networks in the area. Obligations have been permitted. 10% of spaces should be to disabled secured as part of the Stadium development to avoid this by persons parking standards (having regard to SPG12). securing transport improvements of sufficient capacity to support a significant shift in modal share, particularly in favour of public transport. A period of 90 minutes for clearing crowds is set by the police as the maximum desirable period for its policing measures to clear the Stadium, its surrounds and the stations.

14.7.13 The current level of parking for the Stadium is too high by modern standards and it should be reduced on environmental and traffic management grounds. Currently, parking is mainly sub-standard nose-to-tail parking. The Stadium planning brief includes targets for shifting from cars to public transport over time. There will need to be a minimum number of disabled parking spaces to accommodate wheelchair users and to meet the requirements for independent access under the Disabilities Discrimination Act 1998. If the enhanced public transport system is unable to cope adequately with peak crowds then additional measures, such as park & ride, will be sought. THE TRANSPORT IMPACT OF DEVELOPMENT

14.7.10 Transport assessments (TAs) will be required for major development which is likely to have a significant transport impact, as required by policy TRN1 in the Transport chapter. Policy TRN4 identifies measures that may be required to overcome unacceptable transport impact of development. In addition to the requirements of the policies in this section the following range of mea-

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WEM13 TRANSPORT IMPACT OF THE PROPOSED WEM14 STADIUM ACCESS CORRIDOR NATIONAL STADIUM An upgraded & realigned South Way and Great Central Planning applications for the proposed National Way will be secured as the main access road to the Stadium should include a transport impact assessment Stadium and Stadium complex (as shown on the pro- demonstrating how transport networks will be able to posals map). cope with peak event demand, by all modes, within 90 minutes. This should also show how the public trans- New buildings alongside the proposed new Stadium port share of trips can be increased significantly, with Access Corridor should contribute positively towards an associated phased reduction in parking, having this route as a 'gateway' to the Stadium, in terms of regard to the targets set in the Stadium planning brief. scale, design, landscape treatment and orientation to face the road. The number of parking spaces to disabled persons parking standards (having regard to SPG12) should be sufficient to accommodate demand from disabled WEM15 ESTATE ACCESS CORRIDOR persons seating, and other users/employees of the Stadium and related facilities. A new access corridor (as shown on the proposals map) will be provided to the north-western part of the On non-event days a maximum of 500 spaces will be Wembley Park Strategic Employment Area. The available for the activities within the stadium (hotel, improvement and adoption of private streets in the offices, banqueting, visitor attraction, etc.) and the area will be sought. remainder of parking will be secured as part of the shared public, short-term parking pool for the area (Policy WEM12). Planning obligations will be secured to prevent event usage of this in excess of the BUS INFRASTRUCTURE/ PRIORITY approved parking level for the Stadium. MEASURES

Safe, convenient and attractive pedestrian access, 14.7.15 The Council wishes to promote interchange with bus services at separated from traffic, should be provided to the the three main rail stations. Three routes have been identified in Stadium from adjacent parking areas and Wembley the Wembley area for consideration and action including a need Park and Wembley Stadium stations. to provide orbital bus priority linkage between the three rail stations serving the Wembley area.

CYCLING

14.7.16 Because the final internal road layouts in much of the area have NEW ROAD PROPOSALS yet to be determined, it is not yet possible to set precise route alignments of the London Cycle Network. In addition to the 14.7.14 Two important proposals, agreed in principle by the Council, are London network there is a need for supplementary routes which new road alignments. The Stadium Access Corridor, from feed into the strategic routes and provide access to the whole of Hannah Close to the Stadium complex, will provide for event- the area. Preliminary routes as shown on the inset map are related traffic flows and will also provide a dramatic eastern axial Olympic Way and the Stadium Access Corridor, and links to pro- vista for the National Stadium and help ensure that it is an appro- posed footbridges linked to the Stadium road proposals. priate venue for hosting major international sporting events. Routes/Links should be included in major developments, as Current access arrangements are substandard in these regards required by policy TRN11. and disruptive to businesses in the area. The route should incorporate cycle facilities and structural landscaping. The design of buildings along this route should be commensurate with an 14.8 URBAN DESIGN QUALITY IN approach to a venue of international importance. The Estate WEMBLEY Access Corridor will enhance general access to the industrial estate as well as the residential area off North-End Road, and will provide a level of independent access to these areas during URBAN DESIGN PRINCIPLES FOR WEMBLEY events. Both of these road proposals are likely to have a fundamental effect on the area and will create new potential develop- 14.8.1 The design of buildings and the public realm requires special ment sites. Both roads will incorporate provision for pedestrians emphasis within the Wembley Regeneration Area. The following and cyclists. urban design principles have been adopted for the area, to sup- plement the overall regeneration objectives and the boroughwide principles outlined in the Built Environment chapter:

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• A world class setting for a world class Stadium. This is to ensure that the public realm and new public spaces give the WEM17 THE PUBLIC REALM - WEMBLEY new National Stadium the setting it deserves. REGENERATION AREA • A visually linked series of places of distinctive architectural character with pedestrian priority. The proposed pedestrian Development within the Wembley Regeneration Area route will provide a unifying theme and strong link between should contribute towards the creation of a pedestrian the three stations, as well as providing opportunities for active - friendly and distinctive public realm around and frontages at ground floor level. Providing opportunities for between buildings including, where appropriate, the architectural expression are taken, then new places and land- provision of public art and new structural landscaping. mark buildings can be created. The area should become an attractive place to walk around, not dominated by the car Regard should be had to the integrated approach to visually or physically. advertisements, landscaping, street furniture, public • Greater density and mix of use. Redevelopment at signifi- art, lighting and signage in the area set out in supple- cantly greater density and intensity of use than at present will mentary planning guidance. be encouraged, with higher land values helping to fund the new urban structure. There should be a mix of complementary uses, both across the area and within individual major opportunity sites. • Adaptability of buildings for international sporting festivals. This is to ensure that development and infrastructure supports, and does not prejudice, bids for major international events, especially the Olympics.

WEM16 URBAN DESIGN QUALITY - WEMBLEY REGENERATION AREA

Development within the Wembley Regeneration Area should contribute towards the creation of a world class environment. Development should help produce a distinctive and identifiable place, with a vital urban mixed-use character, where the pedestrian has priority, rather than one dominated by roads and cars.

In drawing up proposals special regard should be given to design guidance for the area issued as Man catching a star by local artist Danny Lane supplementary planning guidance.

DESIGN OF BUILDINGS ON OLYMPIC WAY 14.8.2 Achieving urban quality and a high quality public realm is fundamental to turning the area around. Investment in the National 14.8.3 Olympic Way forms the northern part of the proposed pedestrian Stadium must set the context and precedent for high quality route linking the three stations as well as being the the most development in the surrounding area, with an integrated famous and most used pedestrian approach to Wembley approach to street furniture, public art, etc. Places should aid the Stadium, acting as a processional way with its dramatic visual ter- orientation of the public in moving around, be safe, robust, attrac- mination by the Stadium. It also provides a setting for the listed tive, coherent, adaptable, and memorable, using high quality Palace of Industry, one of the few remaining original buildings materials. This can be re-inforced by structural landscaping. from the Empire exhibition at Wembley. The design and scale of buildings along Olympic Way should provide a dramatic processional route to the Stadium, but also have regard to the setting of the Palace of Industry. As a pedestrianised concourse fronting onto key opportunity sites, it will also be necessary for this to act as the main pedestrian access to these sites.

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WEM18 DESIGN OF BUILDINGS ALONG WEM19 VIEWS OF THE STADIUM OLYMPIC WAY Regard will be had to the impact of development on Olympic Way will be improved as the main vista to the the views of the National Stadium and on its backdrop Stadium and development along it should not detract and setting (as shown on maps WEM1 & WEM2 and from views of the Stadium as a focal point or the set- listed below): ting of listed buildings. Long/middle distance views Olympic Way should be retained as a public pedestrian 1. Barn Hill, Wembley; access to development along it, which should act as a 2. St Mary's Church, Harrow-on-the-Hill; gateway to the area, and have active/animated 3. Elmwood Park, Sudbury; frontages, orientated towards Olympic Way, which can 4. Horsenden Hill, Perivale; be managed on Stadium event days. Developments should where possible have alternative points of 5. One Tree Hill, Alperton; access for use on event days. 6. Hanger Hill Park, Ealing; 7. Station Road, Hendon; Improvements will be secured to the environment of 8. Honeypot Lane, Harrow; Olympic Way from the major developments which will 9. Gladstone Park, NW2. be accessed from it. Short distance and internal views 1. The Ironbridge, North Circular Road; 2. Wembley Park Station; VIEWS OF THE STADIUM 3. South Way at the River Brent Bridge; 4. Junction of South Way and Wembley Hill Road; 14.8.4 The new National Stadium will, like the existing Stadium, be an important landmark in North West London. Consequently, both 5. Engineers Way at the junction with Empire Way; long and short distance views should be protected. Policy 6. Bakerloo Line & Railtrack Railway line north of WEM19 lists the views which should be protected (see also policy Stonebridge Station; BE34 in the Built Environment Chapter). 7. Jubilee Line and Metropolitan Line north of Neasden Station.

BRENT RIVER PARK

14.8.5 Brent Council, in partnership with the Environment Agency, English Partnerships, the London Riverways Partnership and the River Restoration Centre, is to carry out a major restoration of habitat along the River Brent. The stretch of river and embankment in the inset area has become degraded over many years. This is part of a more ambitious plan to restore the River Brent here to a more natural form with cycle and pedestrian links. The links proposed in this section will join the proposed Estate and Stadium Access Corridors. These links will be subject to rigorous design guidelines and independent safety audits which ensure they are in an appropriate location and that the safety of neither pedestrians nor cyclists is put at risk. The Wealdstone Brook is also an underused resource in the area. In addition, there are a number of culverted water courses in the area which it is intended should be restored to a natural state.

14.8.6 It is proposed to implement the provision of an extension to the River Brent open space adjacent to the Metropolitan Line, where land has been secured through a planning obligation. This is a key missing link in the River Brent Green Chain.

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14.9.3 The role of the existing town centre will change with a greater WEM20 RIVER BRENT CORRIDOR/WATER diversification of uses and better local facilities provided on oppor- COURSES IN WEMBLEY tunity sites. Policy WEM21 and policies in the Town Centres and Shopping Chapter deal with the issues surrounding proposals for The setting and quality of the River Brent Corridor and such diversification. the Wealdstone Brook will be improved. In particular there will be cycle and pedestrian links along the River 14.9.4 Any eastwards shift in the core of the town centre may result, ini- Brent Corridor with habitat enhancement measures. tially at least, in a further decline in the High Road towards the western end. To counter this the specialist ethnic shopping role of The restoration of former water courses will be the centre, already buoyant in Ealing Road as a jewellery quarter, sought. will be encouraged to grow so that this western end of the High Road, already showing serious decline, can be regenerated. There are a number of key development sites within the town centre and these are dealt with in paragraphs 14.11.7 - 14.11.12. Policies which deal with diversification of use, identifying Primary and Secondary shopping frontages, and controlling the effects of food and drink uses (e.g. pubs) on residential amenity, are included in the Town Centres and Shopping chapter (section 8.8).

WEMBLEY LINK 14.9 WEMBLEY TOWN CENTRE 14.9.5 This is the collective term for a range of environmental and trans- 14.9.1 Brent Council is firmly committed to securing the regeneration of port improvements which are intended to not only improve the Wembley town centre, particularly building on its role as a 'gate- environment for the visitor, but improve bus priority and provide a way' to the National Stadium by encouraging more evening, spe- better link from Wembley town centre and Wembley Central cialist and leisure uses, as well as providing modern shopping Station to the new Stadium and the wider Wembley Complex. facilities to meet local needs. In 1997 Brent published its (See also section 14.6 on the Proposed Pedestrian Route). 'Wembley Gateway Regeneration Strategy', which included proposals for a radical improvement of the environment of the centre 14.9.6 Pedestrian congestion on narrow pavements means that there is and an overall diversification of uses. This identifies a number of an urgent need to upgrade the pedestrian environment in the key opportunity sites, with emphasis on the regeneration of Central section between Wembley Central Station and Park Lane. Square with leisure-led redevelopment. The strategy relies to a Redevelopment of Central Square (see policy WEM29) can pro- large extent on investment to remove vehicular/pedestrian con- vide the opportunity to open the site up to the High Road at one of flict and aid bus priority and interchange, thus making the centre its most congested sections, creating a transport interchange at more attractive to both investors and shoppers. the station whilst maintaining two way traffic flow with bus lay-bys.

14.9.2 The major development sites to the east of the town centre pro- 14.9.7 Additional, dedicated, bus priority measures will be sought, where vide an opportunity to extend the town centre. The pedestrian practicable, to relieve unacceptable congestion. This could route from Wembley Town Centre to the Wembley complex is cur- incorporate a bus interchange on the Chiltern Line cutting site and rently poorly defined with weak visual links. Any development increased pedestrian priority on the High Road itself. on these opportunity sites would be dependent on these functioning as an extension to the town centre, so that shoppers and 14.9.8 Alongside these physical and management measures, improve- other visitors can take advantage of facilities being conveniently ments to the pedestrian environment are needed between the located close to one another, and thus make linked trips. Policy station and the Wembley Complex. These co-ordinated improve- WEM3 deals with the location of major retail, leisure and enter- ments should see a radically upgraded public realm, free of clut- tainment uses, whilst policy WEM2 seeks the provision of this ter, with links to the Stadium clearly signposted and with specially pedestrian route linking the town centre to Olympic Way. designed and distinctive street furniture. This will not only facilitate better use of Wembley Central station for events at the new Stadium as part of the overall 'Three Stations Strategy' (see also policy WEM10) but will also benefit shoppers and other users of the town centre.

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14.9.9 Pedestrian congestion on narrow pavements in Wembley town centre is compounded by the presence of bus passenger queues, LIBRARIES IN WEMBLEY street furniture and queues at cash dispensers. These problems particularly affect disabled people and those having to push 14.9.10 The Council is promoting a single major library or "Wembley prams. The most affected part of the centre is the north side of Culture Complex" offering a range of library and cultural facilities the High Road between Lancelot Road and Park Lane. Wider to modern standards. The most appropriate location for a new pavements will be sought in this location on redevelopment. central library would be within the town centre. The proposed library would update and replace one or more of the existing libraries including that on Ealing Road. WEM21 WEMBLEY TOWN CENTRE

Proposals for the diversification and regeneration of WEM22 LIBRARIES IN WEMBLEY Wembley Town Centre, consistent with policies in the Town Centres and Shopping Chapter, are supported. Any new strategic library serving the Wembley area should be located within the town centre. This may A comprehensive programme of environmental include associated cultural/museum and educational improvements will be undertaken in Wembley town facilities as well as a shop, crèche and cafe facilities. centre between Wembley Central station and the The preferred location for a new library is Central wider Wembley Complex to improve the pedestrian Square. environment and encourage greater usage of Wembley Central station for major events at Wembley Stadium.

Development should not lead to increased congestion 14.10 OTHER SHOPPING AREAS on the High Road and should contribute, where necessary, towards measures which would reduce WEMBLEY PARK DISTRICT CENTRE conflict between buses and other traffic, reduce congestion and reduce conflict between pedestrians 14.10.1 Wembley Park centre has expanded in recent years, particularly and traffic. Dedicated bus interchange measures will with the development of the Stadium retail park and the new Asda be promoted on Major Opportunity Sites linking to store. Demand for food and drink (A3) uses from visitors to the Wembley Town Centre. Stadium and other sport and entertainment facilities has also led to a high proportion of such uses. Given the presence of a large Rear servicing and, where appropriate, wider superstore on the edge of the centre it is not considered neces- pavements, will be sought on development. sary to limit any further demand for changes of use from A1 to A2 or A3 uses in the part of the centre south of the Station which Policy WEM3 deals with the location of large new may result from an increase in the numbers of visitors to the area. retail, leisure and entertainment uses in the National Stadium Policy Area. WEM23 WEMBLEY PARK DISTRICT CENTRE

Change of use of shops to uses providing facilities to visiting members of the public will be permitted south of Wembley Park Station (subject to policy SH10 for A3 uses).

THE STADIUM MARKET

14.10.2 The Sunday Market, which currently operates on the Stadium car park, is a popular facility for both local residents and visitors. Regeneration of the area around the Stadium may result in loss of the market from its current site, however the Council would support proposals to retain the market in the area, providing that there is no additional impact either on the vitality and viability of the town centre or on the environment, such as through extension onto public areas such as Olympic Way.

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WEM24 THE WEMBLEY STADIUM MARKET WEM25 THE NATIONAL STADIUM

Proposals to relocate of the Wembley Stadium Sunday Proposals are supported for the re-development of the Market will be supported, providing that there is no Stadium as the English National Stadium on its additional impact either on the vitality and viability of existing site, to create as powerful an image, as the the town centre or on the local environment. existing building (the site is shown on the proposals map). The new Stadium should:

(a) Where possible have active frontages at ground floor level and address and complement surround 14.11 MAJOR DEVELOPMENT ing public space and development parcels; and OPPORTUNITIES IN WEMBLEY (b) Have an acceptable environmental and transport impact (See policies EP1, TRN1, WEM7, and THE ENGLISH NATIONAL STADIUM WEM13). The existing Stadium access ramp should be replaced 14.11.1 The Council's detailed planning guidance for the proposed with access facilities that provide an appropriate National Stadium is contained in the planning, design and devel- setting. opment brief, published in May 1998 following extensive consultation. The policies for the Stadium included in this chapter deal Development of adjacent sites should demonstrate with the key planning requirements of the proposed development. that the Stadium can be properly served and that the impacts on the Stadium are acceptable. 14.11.2 Brent shares the view of Sport England that the dramatic termina- tion of the vista when viewed from Wembley Park Station should In considering the planning application, regard will be be retained. This, and the need to terminate it with a landmark, had to guidance in the Stadium planning, design and set parameters for the design and location of the Stadium. development brief.

14.11.3 The replacement of the Stadium access ramp from Olympic Way, which is a requirement of English Heritage, is necessary to provide an appropriate setting for the new Stadium.

14.11.4 It is important that that Stadium development has a synergy with adjoining proposed development and the surrounding area. It should set the scene for the future regeneration of the wider area. The Stadium application must comprehensively address its wider setting.

SPORTING FACILITIES

14.11.5 There is a strong possibility that a bid to hold the Olympic Games in London will be made, in which case Wembley may be the focus for major events and the need to provide further sports facilities in the area may arise. In any event, if the new Stadium is to be capable of hosting major athletics meetings, warm-up facilities will be required in close proximity to the Stadium. Whilst it is acknowledged that such a facility does not have to be built at the same time as the Stadium, the Stadium should not prejudice the potential for such future provision. The warm-up facility could be temporary, e.g. laid down on the car park to serve a particular event, or permanent. If a permanent facility is provided then, to maximise usage, it would ideally be available for community use. The area immediately to the south-east of the Stadium is considered to be the best location for a permanent facility.

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WEM26 SPORTING FACILITIES WEM27 OPPORTUNITY SITES AT THE JUNCTION OF OLYMPIC WAY AND ENGINEERS The development of additional sporting facilities WAY around the Stadium that complement the Stadium and Arena and contribute to regeneration objectives will The development of the Major Opportunity Sites at the be supported. junction of Olympic Way and Engineers Way (as shown on the proposals map) are promoted for uses If athletics warm up facilities, including a track, are which contribute towards the development of a required, these should be located adjacent to the visitor destination of regional importance, including National Stadium. The Stadium and other develop- major retail/leisure uses permitted by Policy WEM3, ment should not prejudice the future provision of such and other uses including offices, hotels and residen- facilities. If permanent facilities are to be provided, tial. Only foodstores with a floorspace below 2500 sq then local community access will be sought. m gross are considered acceptable. Particular attention should be given to the need to provide good pedestrian linkages to Wembley town centre and Wembley Park Station. These sites are included within the area identified for comprehensive development OPPORTUNITY SITES NORTH OF THE STADIUM and should be developed in a comprehensive manner 14.11.6 There is considerable potential for large-scale development on (see Policy WEM9). Major new conference, arena and four major sites at the junction of Engineers Way and Olympic exhibition facilities are supported and promoted. Way. It is important that any development of these sites, together with the South Way site and intervening land, should be compre- Any development of the existing Stadium car/coach hensive so as to take advantage of shared infrastructure, includ- park should include replacement structured car parking car parking where appropriate, provide the pedestrian linking (WEM12). ages and make a significant contribution to the setting of the Bus interchange facilities will be sought, ideally next Stadium (policy WEM9). Uses should comply with policy WEM3. to stations, together with measures to improve bus Also relevant is policy WEM18, which requires development to penetration. complement the setting of the Stadium and Olympic Way. A development framework and/or development briefs will be pre- The provision of new sports facilities will be supported. pared for these sites.

OPPORTUNITY SITES WITHIN THE TOWN CENTRE

14.11.7 There are a number of opportunity sites within Wembley Town Centre which are appropriate for a range of town centre uses such as retail, leisure, etc. Certain sites contain existing residential uses, which should be retained or replaced, or short-term shoppers parking. A reduction in the amount of parking on development will only be acceptable if it accords with policy WEM12.

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14.11.8 Two key sites are the adjoining Curtis Lane and Central Square sites. Good, safe pedestrian linkages between these sites, the WEM28 WEMBLEY TOWN CENTRE High Road and public car parks are essential and there should, OPPORTUNITY SITES preferably, be a direct pedestrian link between them. The following opportunity sites, as shown on the pro- 14.11.9 Wembley Central Station adjacent to Central Square suffers from posals map, are promoted for uses appropriate to a very poor quality facilities, interchange and access. town centre such as retail or leisure. Housing will be Redevelopment of Central Square should, ideally, include the acceptable where it is an element of a mixed-use station ticket hall together with new bus interchange facilities and scheme, and active frontages are provided at ground should, at least, not prejudice provision for setting back of the floor level where development links with the town High Road to provide a westbound bus lay-by. centre.

(a) Elm Road - development should retain a major 14.11.10 Retention of public car parking on the Elm Road site is also a shoppers short-stay public car park of at least requirement of development as is need to allow for junction 120 spaces. Road and junction improvements improvements at the Park Lane junction should also be incorporated and development should be set back behind the Park Lane building 14.11.11 The frontage of Copland school onto the High Road is a potential line; development site. The replacement of school facilities on site will (b) Curtis Lane - development should retain shoppers be a requirement of any development. short-stay public car parking in accordance with an assessment of the need for such parking in the 14.11.12 The Chiltern Line Cutting site is ideally positioned for a develop- town centre and in the light of policies to pro- ment to take advantage of the benefits of the National Stadium mote sustainable travel patterns. Improved whilst also being adjacent to the town centre. The site is therefore pedestrian links from the site to the High Road a key one in linking the Wembley Complex to the town centre. It and Central Square should be provided; suffers from a number of development constraints including the (c) Wembley Market and adjoining land; topography, ground conditions and the need to retain some of its ecological value (the cutting is designated as a site of Borough (d) Central Square - development should not prejudice provision for set-back of the High Road to Grade 1 Nature Conservation Importance). All of these matters provide a westbound bus lay-by, and should pro- would need to be addressed at application stage. However, the vide improved bus/train interchange facilities, site benefits from good public transport links and is capable of replacement housing, improvements to the public being accessed by car. As well as dedicated public transport realm and shoppers short-stay car parking and a facilities serving the development, there is also the potential to pedestrian link to the Curtis Lane Site; provide a bus interchange/terminus serving Wembley Town (e) Copland School - This proposal relates to that Centre. A range of town centre uses would be appropriate on the part of the Copland School site, close to Wembley site as well as housing . High Road, identified on the Proposals Map. Development should be compatible with the school and the siting of replacement school facilities should not result in the loss of playing fields south of the public footpath. The street trees along the frontage to the High Road should be retained. Proposals should include safety improvements to Cecil Avenue junction; and

(f) Chiltern Line Cutting - Development should be in accordance with an agreed masterplan for the site. This should indicate how the development will relate to the High Road and how attractive pedestrian links through the site, from the High Road to Wembley Hill Road and the Wembley complex will be achieved. Dedicated public transport facilities will be sought. Development should not have a significant adverse effect on the residential amenities of the occupiers of adjacent housing. The nature conservation value of the site should be fully assessed, and adequate measures to mitigate any loss of nature conservation value should be undertaken, including the provision of a 'green link' through the site. Full information should be provided to determine the stability of the ground and to identify any remedial measures required.

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STATION OPPORTUNITY SITES/TRANSPORT INTERCHANGES WEM30 WEMBLEY STADIUM STATION/SOUTH WAY SITE WEMBLEY PARK STATION SITE This site should be developed comprehensively with 14.11.13 This site comprises the proposed new Wembley Park station and other adjacent sites as identified in Policy WEM9 anda substantial areas of car-parking adjoining which offers potential in particular should not prejudice the provision of a for development subject to accompanying on-street parking con- new station. Pedestrian links from the station controls and the provision of enhanced feeder bus services (see course to the Stadium and Wembley Hill Policy TRN29). Appropriate uses on the site should comply with Road/Wembley Town Centre should be provided, Policy WEM3. Redevelopment of the station should include together with bus and taxi interchange facilities. improvements to access for those using pushchairs and wheelchairs as well as an increase in the capacity of the station Development should not prejudice the continued clo- and better bus interchange facilities. The station is also the most sure of South Way on event days unless an alternative appropriate location for a tourist information office, a need for traffic free route from the station is provided. which has been identified in the Council’s Tourism Development Strategy. The design of the development should be appropriate to the site’s prominent location near the Stadium and 14.11.14 Plans have been approved to increase its capacity which would the proposed pedestrian promenade to Wembley town better serve the National Stadium. In addition, highway schemes centre. Regard should be had to guidance for the site are necessary outside the station boundary to reduce congestion in planning briefs. and increase safety whilst making provision for enhanced interchange facilities for taxis and buses, together with improved pedestrian crossing facilities. CHARRINGTONS YARD/NEASDEN GOODS YARD

WEM29 WEMBLEY PARK STATION SITE 14.11.16 Charringtons Yard is a large open site, exceptionally well located for waste facilities in terms of its centrality in the Borough, its rail The redevelopment of Wembley Park Station is access and access close to the North Circular Road. This site is promoted in conjunction with the regeneration of the an especially sensitive one as it is on the 'eastern gateway' to the area. The design of the development should be Stadium, hence buildings would need to be of a much higher appropriate to this landmark site which forms the axis quality of design than normally expected in an industrial area. to one of the main visual gateways to the National Because of its sensitivity, and the proximity of the adjoining resi- Stadium. dential area, the site would not be suitable for a relocated transfer station, or for other types of waste use with a similar impact (see The reduction of parking at the station below 550 policy W11). spaces will be accepted (subject to Policy TRN29). 14.11.17 A rail spur between Charringtons Yard and Neasden Goods Yard Development fronting Olympic Square should enhance could provide a high-speed rail link between the proposed its setting. The provision of premises for a tourist Heathrow City Link and the Chiltern Line. This would enable information office will be sought. trains to access Wembley Park station from Paddington and Heathrow. It is in the interests of improving public transport access to the Stadium that the future provision of this line should WEMBLEY STADIUM STATION/SOUTH WAY not be prejudiced. SITE

14.11.15 This site comprises Wembley Stadium station and adjoining land and is located very close to, and on one of the main pedestrian approaches to, the Stadium. Consequently, particular care should be paid to the design of any development. Contributions to public transport improvements, including the improvement of Wembley Stadium station, will be sought as part of the development of the site. Buildings should have active frontages to the proposed pedestrian route and contribute towards its provision. Appropriate uses on the site should be in accordance with policy WEM3. The site forms part of the area identified for comprehensive development (Policy WEM9).

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WEM31 CHARRINGTONS YARD/NEASDEN GOODS YARD

The design (including landscape design and other measures to protect against visual intrusion and mitigate against the effects of noise and dust pollution) of development should act as an appropriate eastern gateway to the Wembley Regeneration Area. Use of the site should benefit from its good rail access.

Charringtons Yard is safeguarded as a waste management/manufacturing area (policy W4), providing development can be compatible with its sensitive location. Use of any part of the site remaining after the provision of a waste facility should be in accordance with policy EMP8 for Strategic Employment Areas which includes, on a screened part of the site a small aggregate transfer/construction waste recycling facility. Uses should be sited with due sensitivity to the adjoining residential area.

Development should not prejudice the provision of a permanent way for trains using the Heathrow-City Link to access Wembley Park station.

Brent Unitary Development Plan - 2004 273 WEMBLEY REGENERATION AREA

MAP WEM1 Long Distance Views Of Wembley Stadium

1 2

3 ✹ 9

4 5

Views

Brent Unitary Development Plan - 2004 274 WEMBLEY REGENERATION AREA

MAP WEM2 Short Distance and Internal Views of Wembley Stadium

7 5

3 1 4

Views

Brent Unitary Development Plan - 2004 275 WEMBLEY REGENERATION AREA

Brent Unitary Development Plan - 2004 276 SITE SPECIFIC PROPOSALS 15 SITE SPECIFIC PROPOSALS

SCHEDULE OF SITES The following schedule identifies all the sites in the Borough for which there are specific planning proposals. Most sites are in private ownership (rather than in Council ownership) and implementation will in most cases be upon redevelopment rather than directly by the Council. The sites are shown on the Proposals map with a reference number linking them to the Schedule.

The sites are divided into 5 categories which are:-

Major Opportunity Sites (MOS)

Housing &/or Mixed Use Sites (HP)

General Development (DP)

Open Space (OSP)

Transport (TP)

Each site-specific proposal includes details of the uses proposed, the site area, the policy context (i.e. which main policies in the Plan apply to the site), any additional relevant information (including planning permissions, if any) and an indication of when the scheme is likely to be implemented within the 10 year Plan period. If there is a range of acceptable uses these are separated by '/' marks. If there is a requirement for a use '&' is used instead.

The phasing categories are:-

Short-term - development anticipated within the next 3 years.

Mid-term - development within 3-5 years.

Long-term - 5-10 years.

The Schedule includes proposals for development sites which involve a change in the use of the land. Details of development sites within Inset Plan Areas are set out in Chapters 13 and 14, this includes most Major Opportunities Sites. The schedule also includes sites required for highway improvements where this would involve additional land beyond the existing boundaries of the public highway.

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MAJOR OPPORTUNITY Proposals: Town-Centre and Mixed Uses SITES Policy Context: Kilburn Major Town Centre Development Objectives: Enhancement of shopping facilities and townscape in Kilburn. Comprehensive approach to redevelopment. Re-inforcement of building line, whilst main- PLANNING AREA: HARLESDEN/WILLESDEN taining adequate footway width and trees as far as possible. Replacement of any trees lost. New public space with new trees on Kilburn High Road frontage with good Map Ref: MOS1 links through to Kilburn Square. No loss of Kilburn Location: Car Park r/o 189 - 235, 187 Church Road Square open space with active frontages onto Kilburn Phasing: Mid-term Area Ha: 0.37 Square and Kilburn High Road. Servicing from rear. No Proposals: Housing/Mixed use, retention of trees and open space loss of shoppers car-parking. More intensive develop- retention of reduced car park on part of site. ment including housing and small-business units on Policy Context: Site adjoins Church Road local shopping centre and upper storeys is permitted subject to a quality design. Church End MERA. Development Objectives: Comprehensive development compatible with adjoining local shopping centre and Church End PLANNING AREA: redevelopment. Regeneration of Church End. Creation NEASDEN/CRICKLEWOOD of a lively place, with a high quality environment, safe and convenient pedestrian routes and safe and attractive public spaces. Some use of any adjoining surplus Map Ref: MOS5 highway capacity may be acceptable. Location: 641 - 665 North Circular Road Phasing: Mid-term Area Ha: 1.56 Proposals: Employment use. PLANNING AREA: Policy Context: Strategic Employment Area KINGSBURY/KENTON Development Objectives: Single access onto A406 North Circular Road. Loss of residential is acceptable.

Map Ref: MOS2 Location: Land at rear of Oriental City, 57 Grove Park PLANNING AREA: Phasing: Mid-term Area Ha: 1.36 WEMBLEY Proposals: Community use/Employment use - light industry and warehousing/ Housing, including affordable housing in accordance with policies H2 and H3. Map Ref: MOS6 Policy Context: local employment site. Location: Atlip Site/Dadoos/Alpine Horn, Atlip Road, Ealing Development Objectives: Access from Grove Park or existing rear Road access. Access for housing and location of housing site Phasing: Short-term Area Ha: 1.94 should be at Grove Park. Proposals: On Atlip site B1, Live-work, where necessary element of affordable housing to support live-work proposals. Residential acceptable on remainder of site. Footbridge PLANNING AREA: link across Grand Union Canal linking Carlyon Estate KILBURN/KENSAL with Ealing Road and Alperton Station. Industrial servicing road through site linking Sunleigh Road Industrial Estate through to Ealing Road. Map Ref: MOS3 Policy Context: Atlip is a local employment site. Location: Kilburn State (Former cinema) and land to the rear Development Objectives: Creation of pedestrian route linking canal Phasing: Mid-term Area Ha: 0.71 to Ealing Road. Retention of some employment uses on Proposals: Community , retail, or arts/culture/entertainment or site. Enhancement of canal site. employment use suitable for retaining integrity of listed building. Map Ref: MOS7 Policy Context: Listed building Location: Former Hirst Research Centre, 50 East Lane Development Objectives: Redundant part of grade II* listed build- Phasing: Short-Term Area Ha: 3.63 ing. Planning brief to be produced balancing retention of Proposals: Housing. Mixture of affordable and general market (min- heritage value with the introduction of compatible uses. imum 45% units/52% habitable rooms affordable with appropriate level of family housing), in accordance with Map Ref: MOS4 policy H3, with agreed phasing of affordable housing Location: 103 - 125 Kilburn High Road and Kilburn Square and general market housing. Live-work/Employment Market also suitable. Phasing: Mid-Term Area: 0.48 Policy Context: Employment, Housing and affordable housing poli-

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cies. units only, minimum of 34 units. Contribution to school Development Objectives: If major housing site: There should be an places. appropriate landscaped buffer to the adjoining Strategic Employment Area and two access points onto East Lane, Map Ref: HP3 with the replacement of the adjoining existing cycle and Location: Former Allotments, Townsend Lane pedestrian route through the development. Phasing: Short-term Area Ha: 0.56 Development guidelines for the site provide more Proposals: Affordable Housing detailed advice on urban design, mix, and road layout. Policy Context: Allotments policy. The development should provide mainly residential Development Objectives: Disused former allotments. Affordable accommodation with scope for small units with mixed housing gain. Planning Obligation required to compen- use (including primary care and day nursery) on the East sate for loss of allotments, by providing improvements Lane frontage. The development should include chil- to other allotments/open spaces. dren's play facilities, contributions towards school places, and appropriate amenity open space. If Employment Use: Principally B1(b), B1(c), B2, B8. PLANNING AREA: Attention should be given between boundary of HARLESDEN/WILLESDEN Residential and Employment area to maintain residential amenity. Map Ref: HP4 Map Ref: MOS8 Location: Manor Park Works, 28 Manor Park Road Location: Industrial Estate, Rosemont Road, Ealing Road Phasing: Long-term Area Ha: 0.25 Phasing: Short-term Area Ha: 1.7 Proposals: Housing with a substantial proportion of affordable hous- Proposals: Employment/Live-work Use. ing. Policy Context: Borough Employment Area, Business Zone. Policy Context: Local Employment Site. Development Objectives: Enhancement of canalside. Improved Development Objectives: Housing gain, replacement of bad-neigh- access to Ealing Road. Retention of employment uses. bour uses. Minimum of 9 affordable units. Development to address canal. Map Ref: HP5 Location: Land n/t Islamic College for Advanced Studies, 1 St Andrews Road Phasing: Short-term Area Ha: 0.26 HOUSING &/OR MIXED USE SITES Proposals: Affordable Housing Release Site to rear of statutory listed building, bordering Conservation Area. School extension would be an alternative use. PLANNING AREA: Policy Context: Site adjoins Conservation Area and listed building. KINGSBURY/KENTON Development Objectives: High quality design appropriate to setting. Retention of children's play-space and part of car park. School proposals would require proper assessment of Map Ref: HP1 transport impact and necessary measures, e.g. Green Location: Kenmo House, 381 Kenton Road/ Eurofame House, Travel Plan. 2 Woodgrange Avenue Phasing: Long-term Area Ha: 0.255 Map Ref: HP6 Proposals: Redevelopment for housing. Location: 391-395 Chapter Road Policy Context: Car sales with four flats above and adjoining redun- Phasing: Mid-term Area Ha: 0.25 dant office block. Proposals: Retention of Community Use & Live-work/affordable Development Objectives: To secure housing gain in the area. housing. Policy Context: Community Facilities and Local Employment Sites on Map Ref: HP2 different parts of site Location: Kingsbury Hospital, 106 Honeypot Lane Development Objectives: Former industrial building partially in com- Phasing: Short-term Area Ha: 3.36 munity use well suited to Live-work development & com- Proposals: Housing/Health-care facilities. munity use. Housing not suitable if developed next to Policy Context: Community Facilities policy existing bad-neighbour industry on part of site. Development Objectives: Planning Brief agreed and outline planning permission granted. Integrated residential develop- Map Ref: HP7 ment of high quality design which provides a proportion Location: 92a - 96 Villiers Road of affordable housing in 3-4 bed units, protection of the Phasing: Short-term Area Ha: 0.21 ecological value of the site, high quality landscaping and Proposals: Affordable Housing. provision of play-space. Minimum Number of Units over- Policy Context: Affordable Housing Release Site. all/affordable: 30% of housing Affordable, in 3&4 bed Development Objectives: Current business use creates traffic

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problems in residential area. Proposals: New community hospital and primary health care facilities with housing on remainder of site. Map Ref: HP8 Policy Context: Community Facilities policies. Location: Land to the rear of 2 Morland Gardens Development Objectives: Consideration should be given to retaining Phasing: Mid-term Area Ha: 0.25 original hospital buildings on site. Minimum of 77 Proposals: Housing with a substantial proportion of affordable affordable units. housing. Policy Context: Adjoins locally listed building and major estate Map Ref: HP15 regeneration area. Location: 1 - 12 Queens Parade, Willesden Lane Development Objectives: Adjoins locally listed building. Should be Phasing: Mid-term Area Ha: 0.06 compatible with adjoining Stonebridge regeneration Proposals: Housing above rebuilt shops/uses appropriate in a town initiatives. Minimum of 7 affordable units. centre. Policy Context: Site in Conservation Area & Town Centre. Map Ref: HP9 Development Objectives: Key corner site in Conservation Area with Location: Gwenneth Rickus Building, 242 Brentfield Road potential to provide for local needs of town centre and Phasing: Long-term Area Ha: 0.6 improve street scene. Proposals: Affordable Housing and Community Facilities. Alternative to redevelopment is the conversion of exist- Map Ref: HP16 ing building. Location: Land to rear of 112 High Street Policy Context: Community Facilities policies, Affordable Housing Phasing: Short-term Area Ha: 0.05 Release Site. Proposals: Affordable Housing/Live-work. Development Objectives: Affordable Housing gain and retention of Policy Context: Site in Harlesden Town Centre. community facilities, or reuse of building. Development Objectives: No on-site car parking permitted.

Map Ref: HP10 Map Ref: HP17 Location: 28A Mordaunt Road Location: Uffington Road Phasing: Mid-term Area Ha: 0.37 Phasing: Long-term Area Ha: 0.92 Proposals: Affordable Housing. Proposals: Sheltered Housing. Policy Context: Affordable Housing Release Site. Policy Context: Existing residential area. Development Objectives: Affordable housing gain. Development Objectives: Comprehensive redevelopment of existing sheltered housing. Map Ref: HP11 Location: Former Willesden Court House, 1 St Marys Road Map Ref: HP18 Phasing: Short-term Area Ha: 0.15 Location: Works Litchfield Gardens/Hawthorne Road NW2 Proposals: Community use/housing/offices/Food and drink/ ACE Phasing: Medium Term uses. Area Ha: 0.2 Policy Context: Site in Harlesden Town Centre. Proposals: Housing, including a substantial proportion of affordable Development Objectives: Uses contributing to regeneration of housing in accordance with policy H3. Harlesden. Retention of existing buildings. Policy Context: Local Employment Site, Affordable Housing. Development Objectives: Existing industry causing loss of amenity Map Ref: HP12 of neighbours. Site capable of 10+ units. Location: 103 - 107 Mount Pleasant Road Phasing: Mid-term Area Ha: 0.22 Proposals: Affordable housing. PLANNING AREA: Policy Context: Affordable Housing Release Site. KILBURN/KENSAL Development Objectives: Affordable housing gain.

Map Ref: HP13 Map Ref: HP19 Location: Pound Lane Health Clinic, 61 Pound Lane Location: 3 - 6 Banister Road Phasing: Mid-term Area Ha: 0.3 Phasing: Short-term Area Ha: 0.46 Proposals: Affordable housing. Proposals: Live-work & Affordable Housing, or Employment. Policy Context: Affordable Housing Release Site. Policy Context: Local employment site, affordable housing release Development Objectives: Community use should be retained on site. ground floor or on part of site or retained elsewhere in Development Objectives: Re-use of redundant building , retention local area. of employment if possible. Affordable housing away from railway line if essential to secure employment/live- Map Ref: HP14 work on part of site. Location: Willesden General Hospital, 150 Harlesden Road Phasing: Mid-term Area Ha: 2.59

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Map Ref: HP20 Development Objectives: Acceptable access needs to be formed Location: Neptune Showers, 45 - 45a Pember Road from Harrowdene Road. Phasing: Short-term Area Ha: 0.15 Proposals: Housing. Map Ref: HP26 Policy Context: Local Employment Site. Location: Land Adjoining Sudbury and Harrow Road Station, Development Objectives: Bad neighbour site therefore 100% 749 Harrow Road affordable housing required may be modified if applicant Phasing: Long-term Area Ha: 0.61 can demonstrate reasons for exception to be made. Proposals: Station interchange & housing / uses appropriate in a district centre. Map Ref: HP21 Policy Context: District centre. Location: Canterbury Works, 8 Canterbury Road Development Objectives: Provision of improved station interchange Phasing: Short-term Area Ha: 0.24 and local facilities. Approved planning brief. Proposals: Affordable Housing/Live-work. Policy Context: Car Breakers site suitable for affordable housing or Map Ref: HP27 live-work scheme. Location: Builders Yard, 63 Station Grove Development Objectives: Affordable housing gain. Potential lead Phasing: Mid-term Area Ha: 0.22 contamination to be resolved. Proposals: Affordable Housing. Policy Context: Affordable Housing Release Site Map Ref: HP22 Development Objectives: Affordable housing gain. Location: Victoria Mews Phasing: Mid-term Area Ha: 0.14 Map Ref: HP28 Proposals: Consolidation of residential use. Location: Land adjoining St Johns Church, 614 High Road Policy Context: Residential area. Phasing: Mid-term Area Ha: 0.62 Development Objectives: The current use of the mews for Proposals: Foyer/Housing. employment purposes has an adverse impact on nearby Policy Context: Adjoins grade II listed building. residential properties. Need to consolidate housing and Development Objectives: Requires specialist conservation archi- lose bad neighbour uses. tect. Picturesque setting of church to be maintained. Retention of community use but not necessarily in exist- Map Ref: HP23 ing building - requires boundary treatment - retention of Location: 669-671 Harrow Road trees and provision of railings to front of site. Phasing: Mid-term Area Ha: 0.02 Proposals: Hostel Use. Map Ref: HP29 Policy Context: Residential area. Location: Land adjoining St Andrews Church, 956 Harrow Development Objectives: Outstanding planning permission for new Road build student hostel. Phasing: Mid-term Area Ha: 1.03 Proposals: Housing/replacement affordable housing/community facilities/retention of comparable facilities to meet the PLANNING AREA: needs of existing community users. WEMBLEY Policy Context: Adjoins grade II listed building. Development Objectives: Requires specialist conservation architect. Church Gardens housing needs to be replaced. Map Ref: HP24 Replacement community buildings to rear of church. Location: Site of Former Phillips Garage, 204 Watford Road Trees protected by TPO to be retained. Picturesque set- Phasing: Short-term Area Ha: 0.33 ting of church to be maintained. Retention of footpath Proposals: Affordable Housing. between Elms Lane and Church Gardens/Harrow Road. Policy Context: Housing. Land adjoins and partially in Sudbury Court Conservation Area. Map Ref: HP30 Development Objectives: Approved planning brief. Requires contri- Location: 242-252 Bridgewater Road bution towards School Places generated by family-sized Phasing: Mid-term Area Ha: 0.42 housing development. Development should preserve or Proposals: Housing. enhance Sudbury Court Conservation Area and its set- Policy Context: Existing residential area. ting. Development Objectives: Comprehensive development only. Minimum of 8 affordable units. Retention of trees on Map Ref: HP25 embankment. Location: Allotments r/o 96 - 112, 98 Harrowdene Road Phasing: Mid-term Area Ha: 0.52 Map Ref: HP31 Proposals: Affordable Housing on disused allotments, including area Location: Sudbury Crescent of public open space. Phasing: Long-term Area Ha: 0.62 Policy Context: Affordable housing & Allotments policy. Proposals: Consolidation of residential use and environmental

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improvements. Residential use, only allowed as part of mixed-use Policy Context: Adjoining district centre. Mixture of employment and schemes, and where confined to floors above ground residential uses. floor level. Development Objectives: Improvements to inappropriately located Policy Context: Local Employment Sites adjoining Queens Park uses to benefit residential environment. District Centre Development Objectives: Re-use, and retention of original features, of attractive Victorian buildings. Maintenance of mews character of Lonsdale Road. Creating a Mixed-Use char- GENERAL DEVELOPMENT acter for the area. Active frontages at ground floor for PROPOSALS buildings adjoining the district centre. Measures to ensure an acceptable transport impact will be secured.

PLANNING AREA: HARLESDEN/WILLESDEN PLANNING AREA: NEASDEN/CRICKLEWOOD

Map Ref: DP1 Location: Grange Road, NW10 Map Ref: DP4 Phasing: Mid-term Area Ha: 0.05 Location: Dollis Hill House - Gladstone Park, 95 Dollis Hill Proposals: Retain in library use with use for storage by Borough Lane Museum. Phasing: Short-term Area Ha: 0.47 Policy Context: Site in town centre. Proposals: Enabling development to secure future of listed building Development Objectives: Provision of community facility. at risk, whilst protecting the integrity of the park, including A3 use, hotel, community facilities, arts centre/gallery, conference centre, theatre, offices, hotel. PLANNING AREA: Policy Context: Metropolitan Open Land, Listed building. KINGSBURY/KENTON Development Objectives: Vacant shell of fire damaged Grade II listed building at risk owned by Brent Council. Uses acceptable on Metropolitan Open Land will be permitted, in Map Ref: DP2 addition exceptional circumstances exist to permit limit- Location: Site of former Kingsbury Pool, 282A Kingsbury ed inappropriate uses on Metropolitan Open Land within Road the building, where these are essential to the restoration Phasing: Mid-term Area Ha: 1.2 and character of the listed building. Strict control will be Proposals: Leisure Pool/Sports/Leisure (not cinema) and food & exercised over associated use of adjoining land to main- drink (A3) uses. tain the openness of Metropolitan Open Land. Building Policy Context: Open area of Borough wide importance. styles and materials should respect the existing building. Development Objectives: Approved Planning Brief. Comprehensive Use of the premises (in part or in whole) for general development of high quality design to provide a vital mix community use will be sought in connection with any of uses focusing on leisure activities which represent the development scheme. parkland setting. Any loss of public open space, should be small in scale and the minimum required to enable Map Ref: DP5 the provision of sports and community facilities. Location: Grange Museum Roundabout Development of uses other than replacement indoor Phasing: Mid-term Area Ha: 0.49 sports/ outdoor sports associated with the open space Proposals: Community/A3 or other uses securing future of listed should demonstrate the application of a sequential building. approach (policy SH5) and be the minimum required to Policy Context: Site of Borough Grade II nature conservation impor- enable the provision of sports and community facilities. tance. Opportunity to use renewable technologies. Development Objectives: Grade II listed building. Borough Museum to move to Grange Road NW2. Retention of nature site and introduction of compatible uses.

PLANNING AREA: KILBURN/KENSAL PLANNING AREA: WEMBLEY Map ref: DP3 Location: Lonsdale Road and Salusbury Road, North of Queens Park District Centre Map Ref: DP6 Phasing: Short Term Area Ha: 2.7 Location: Old St Andrews Church and Church Yard, Old Proposals: B1/Live-work/ACE/A1/A3/Community & Leisure uses. Church Lane

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Phasing: Mid-term Area Ha: 0.81 PLANNING AREA: Proposals: Uses securing future use of church and churchyard set- HARLESDEN/WILLESDEN ting. Policy Context: Grade I listed building. Map Ref: OSP3 Development Objectives: Both church and churchyard listed build- Location: Ex Evefield Day Nursery, 178 North Circular Road ings at risk. Need to revitalise these facilities and then Phasing: Mid-term Area Ha: 0.15 bring back into active community use. Proposals: Public Open Space Policy Context: Former community use. Map Ref: DP7 Development Objectives: Improved community facilities. Site of Location: Former Unisys Building, 5 - 7 Brentfield demolished day nursery, land owned by Brent. Phasing: Short-term Area Ha: 1.31 Consultation exercise to determine exact nature of open Proposals: Hotel or Offices . space use. Policy Context: Redundant Offices. Development Objectives: To bring redundant building back into appropriate beneficial use. PLANNING AREA: WEMBLEY

OPEN SPACE PROPOSALS Map Ref: OSP4 Location: Vale Farm Sports Centre, 76 Watford Road Phasing: Long-term Area Ha: 2.9 PLANNING AREA: Proposals: Development of indoor and outdoor sports facilities with- KILBURN/KENSAL in the existing athletics track, to enhance the existing sport and recreation facilities. This proposal does not entail the loss of any public open space. Map Ref: OSP1 Policy Context: Private open space. Location: Land adjacent to 864 Harrow Road Development Objectives: Improved sports facilities. Phasing: Short-term Area Ha: 0.09 Proposals: Housing on part of site, public open space on majority of Map Ref: OSP5 site and contribution to open space provision/improve- Location: Site of Former GEC Sports Ground, 125A Preston ments in local area. Road Policy Context: Previously an open space proposal - lack of funding Phasing: Short-term Area Ha: 3.04 to CPO requires a consolidation of existing open space in Proposals: Laying out of public open space with new sports facili- area. ties. Development Objectives: Improvement to open space in Kensal Policy Context: Former private open space. Rise. Small amount of housing compatible with adjoining Development Objectives: To secure sufficient public space to meet listed building in conservation area. Remainder to be laid area of local public open space deficiency and improve out by developer as open space. Planning obligation to sports facilities. Include tree planting around open improve nearby open spaces will also be sought. space.

Map Ref: OSP6 Location: Northwick Park West, 280 Watford Road PLANNING AREA: KINGSBURY/KENTON Phasing: Short-term Area Ha: 13.94 Proposals: Golf Course, Driving Range and ancillary facilities appropriate to Metropolitan Open Land. Map Ref: OSP2 Policy Context: Metropolitan Open Land. Location: London Transport Sports Ground, 37 Old Kenton Development Objectives: Approved planning brief. To maintain Lane nature conservation features, provide appropriate vehic- Phasing: Short-term Area Ha: 2.76 ular and maintain pedestrian access, not visually intrude Proposals: Sports pavilion which may be used in part as a visitor upon open character of area. Improvements to recre- facility for the Country Park. Uses appropriate to ational facilities in Borough. Metropolitan Open Land, ancillary to/compatible with aims of Fryent Country Park adjoining. Reinstatement of Map Ref: OSP7 open space. Location: Copland School Playing Fields Policy Context: Metropolitan open land. Phasing: Short-term Area Ha: 0.30 Development Objectives: Land secured by Brent through planning Proposals: Play area in area of deficiency. Maintenance of dual use obligation as compensation for loss of sports grounds. of playing fields. Policy Context: School playing fields. Development Objectives: Provision of play area and playing fields.

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TRANSPORT PROPOSALS PLANNING AREA: NEASDEN/CRICKLEWOOD PLANNING AREA: KINGSBURY/KENTON Map Ref: TP5 Location: Oxgate Lane/Staples Corner Map Ref: TP1 Phasing: Long-term Location: 1-15 Holmstall Parade & 1- 31 Burnt Oak Proposals: Link with acceptable gradient to be constructed and Broadway adopted to improve servicing to industrial estate. Phasing: Long-term Policy Context: Strategic employment area. Proposals: Provision of parking bays and landscaping to provide a Development Objectives: Link in the proposed internal road net- more attractive and safer shopping environment. work of the Staples Corner Industrial Area. The Council Policy Context: Town centre. will undertake full consultation on design of the schemes Development Objectives: Pavement and forecourts with poor with affected interests. Ground level at unit adjacent to environmental conditions prejudicial to pedestrian and new road to be raised by 1.2m by development. vehicular traffic. Map Ref: TP6 Map Ref: TP2 Location: Humber Road/Oxgate Lane Location: Frontages of 12-24 Carlisle Road Phasing: Long-term Phasing: Long-term Proposals: Service road to be constructed on redevelopment of site Proposals: A one metre strip of land will be required along the south to improve accessibility, servicing and general manage- side of Carlisle Road for highway widening when these ment. sites are redeveloped. Policy Context: Strategic employment area. Policy Context: Borough employment area. Development Objectives: Link in the proposed internal road net- Development Objectives: Existing private forecourt and industrial work of the Staples Corner Industrial Area. The Council buildings with unsatisfactory servicing and parking will undertake full consultation on design of the schemes conditions. with affected interests.

Map Ref: TP3 Map Ref: TP7 Location: Land at the junction of Hay Lane and Edgware Location: Site adjoining The Link, Staples Corner. Road Phasing: Mid-term Phasing: Long-term Proposals: North bound link from the A406 North Circular Road to Proposals: A one metre strip of landscaping is safeguarded for the Edgware Road. junction improvements. Works to be carried out by Policy Context: Strategic Road. future developers. Development Objectives: Land secured by planning obligation. Policy Context: Local employment site. Junction of roads congested. Development adding to Development Objectives: To cater for "right turn" lane when it is traffic levels here should contribute to costs of this link. required for future development.

Map Ref: TP4 PLANNING AREA: Location: Continuation of Barningham Way to Kingsbury WEMBLEY Road (Frontage of Castell Safety International and Power Equipment and part of Knightsbridge cars). Map Ref: TP8 Phasing: Long-term Location: Site adjoining IKEA, North Circular Road Proposals: Unadopted road. Land required on the east side of Phasing: Mid-term Barningham Way for highway widening and adoption Proposals: Bus Lay By. when adjoining sites are redeveloped. Developers will Policy Context: Strategic Road. be expected to carry out such work as part of the Development Objectives: Land secured by planning obligation. redevelopment. Development requiring improved public transport in this Policy Context: Borough employment area. locality should contribute to costs of this lay by. Development Objectives: Substandard highway infrastructure to service established industrial estate. Map Ref: TP9 Location: Glacier Way/Ealing Road Slip Lane Phasing: Mid-term Proposals: Junction improvements. Policy Context: Adjoining supermarket & employment uses. Development Objectives: Any development that increases use of

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junction will be required to fund junction improvements. Land has been acquired by Brent.

Map Ref: TP10 Location: Cross-Rail Safeguarding Phasing: Long-Term Proposals: Safeguarded for rail improvements. Policy Context: Strategic Transport Proposal. Development Objectives: Safeguarded by Secretary of State.

Brent Unitary Development Plan - 2004 285 SITE SPECIFIC PROPOSALS

Brent Unitary Development Plan - 2004 286 GLOSSARY 16 GLOSSARY

Affordable Housing Business Use

See Housing Chapter section 5.7.14. Use for the purposes of offices, research and development or industry, providing (Class B1) that such a use can be carried out Amenity Space in a residential area without detriment to the amenity of that area (definition derived from "The Use Classes Order 1987" - Amenity space should normally have some sunlight, and should Department of the Environment Statutory Instrument 764, 1987). normally be directly accessible from a room other than a bedroom. It excludes the first 2m of space at the side of dwellings Brownfield Sites (measured from the boundary) and the first 6m of front garden space (measured from the front boundary) which are treated as See under previously developed urban land. landscaping space and not exclusively amenity space. The large majority of amenity space should be grassed and landscaped. Care in the Community For family housing and category 1 elderly persons accommodation, amenity space should mainly be provided in the form of gar- Programme of support and service provision in ordinary housing dens (in the latter case wheelchair accessible planting bays within the local community for people with mental or physical dis- should be provided). ability or other problems requiring special support. The aim is to enable a more independent life than would be possible in a larger Ancillary Use institution.

A use appropriate to the primary use of a building or piece of land Children's Play Space e.g. storage and office floorspace in a factory. In new residential developments intended for families, a standard Article 4 (2) Direction of 3 sq.m. local play space per child bed space in addition to the appropriate amenity space standard will normally be applied. (All A direction granted by the local planning authority following public bedrooms other than the main bedroom are counted as child consultation under the Town and Country Planning (General bedspaces with bedrooms at or above the Council's size stan- Permitted Development) Order 1995. It can be used to remove dards for double bedrooms being counted as two child "Permitted Development" rights for certain forms of householder bedspaces.) development in conservation areas. The removal of permitted development rights outside these categories and/or outside con- Circulars servation areas still requires the confirmation of the Secretary of State for The Environment under Article 4(1). Occasional government advice to aid interpretation of legislation and to advise local authorities on government expectations in Black and Minority Ethnic Groups (BME) their delivery of services.

This term is specifically used by the Census to globally aggregate Commercial Development and distinguish groups on a racial basis from those classified as ‘white’. However, this ‘white’ category includes Census enumerat- New building for warehousing and storage; the term may also ed communities in Brent, such as the Irish, who regard them- include shopping and office development. selves as constituting a distinct ethnic minority. Other population sectors, such as Kurdish and Orthodox Jewish, who are not Commercial Improvement Area (CIA) specifically enumerated by the Census, may also have distinct cultural characteristics, effectively similar to ethnic minorities. An area declared under the Inner Urban Areas Act 1978 (s.4) Such groups are therefore encompassed in the term ‘ethno-cul- which is mainly commercial in character and where grants and tural’ as used in this Plan. loans may be available for improvements to buildings and to the amenity of the area.

Brent Unitary Development Plan - 2004 287 GLOSSARY

Conservation Area Foyer Accommodation

An area of special architectural or historic interest identified by the Supervised non-self contained accommodation for young single Local Planning Authority under the Planning (Listed Buildings & people, often linked to training programmes. Conservation Areas) Act 1990. There is a statutory duty to preserve or enhance the character or appearance of such areas. General Permitted Development Order (GPDO) Buildings in such areas are protected from unauthorised demolition in part or in full, and trees may not be felled or pruned without Statement by central government of the type and scale of 14 days notice. Development which does not require Planning Permission.

Convenience Goods General Industrial Use (Class B2)

Those items which are usually purchased from shops on a regu- An industrial use, other than those which can be carried out in any lar basis, by virtue of availability and convenience, rather than as residential area without detriment to the amenity of that area, and a result of the comparison of products. which is not in Classes B3-B7 of the Use Classes Order (definition derived from "The Use Classes Order 1987" - Department of Deficiency Area the Environment Statutory Instrument 764, 1987).

Area which is beyond a reasonable distance from a facility such Green Transport Plans as a shop, park or community centre. A document submitted as part of a transport impact assessment Development Control setting down proposed measures by the developer to deliver sustainable transport objectives, including: measures for reducing The activity of the local planning authority to decide whether car usage (particularly single occupancy journeys) & promoting development may proceed and thus Planning Permission be and securing increased use of walking, cycling and public trans- given, with reference to the development plan for the area and port. (See Para 6.6.11). other material considerations. Habitable Room Development Plan Habitable rooms are all rooms except hallways, bathrooms, WCs, For the purposes of the Town and Country Planning Act 1990 the laundry rooms and storage cupboards. development plan for any London Borough is the Unitary Development Plan. For the purposes of density calculations solely only kitchens of above 13sqm. count as habitable rooms; bedsitting rooms are Durable Goods counted as 1.5 habitable rooms. The maximum size for a single habitable room is counted as 18sqm, where the room can be eas- Goods for which purchase involves comparison by the customer ily subdivided to provide an additional bedroom. With larger and which while not being purchased frequently must neverthe- rooms counted as two habitable rooms. less be stocked in a wide range of size, styles, colours and qualities e.g. clothes and footwear, fashion wear, fabrics, jewellery, fur- For all other purposes including daylighting, sunlighting, privacy niture and goods normally sold at specialist shops and general and outlook kitchens are counted as habitable rooms whatever stores. (definition derived from "Development Control Policy Note their size. 13" - Department of the Environment, 1977). In accordance with BS206:Part 2:1992 for purposes of daylighting Dwelling and sunlighting habitable rooms will be assessed in the following order of declining importance: Kitchens, living rooms, bedrooms. A building or any part of a building that forms a separate and self- contained set of premises designed to be occupied by a single Highway family or household. (definition derived from "The Census 1981 Definitions Great Britain" - Office of Population Censuses and An area of land for which the public has the right of way to pass Surveys, 1981). under or through.

Employment Use Housing Density

See para 7.1.1 The number of dwellings per Net Residential Area, measured in Habitable Rooms per hectare. Ethno-cultural

See Black and Ethnic Minorities.

Brent Unitary Development Plan - 2004 288 GLOSSARY

Household Permitted Development

One person living alone or persons living at the same address Minor development which, by virtue of the General Permitted with common housekeeping or sharing a common living or sitting Development Order, does not require planning permission. room. Planning Brief Industrial Improvement Area (IIA) A description of the type of development which the Council would An area declared under the Inner Urban Areas Act 1978 (s.4) expect on particular development sites, including land uses, fea- which is mainly industrial in character and where grants and tures to be retained, overall design considerations and Planning loans may be available for improvements to buildings and to the Advantage where appropriate. amenity of the area. Planning Obligation Key Worker Housing A legal undertaking entered into in connection with a planning A ‘key worker’ for the purpose of eligibility for affordable housing permission under Section 106 of the Town and Country Planning provision in this Plan is defined as a person employed in directly Act 1990. Such obligations may restrict development or use of delivering a vital service, such as health, education, police and land; require operations or activities to be carried out in, on, under transport etc, that the local planning and housing authority deems or over the land; require the land to be used in any specified way; is essential for the maintenance of a sustainable community. or require payments to be made to the planning authority either in Affordable housing provision may ameliorate the recruitment and a single sum or periodically. Planning obligations may be created retention problems that affect service delivery. by agreement or by unilateral undertakings on the part of the developer/owner of the land. Large Retail Development Planning Permission Development for retail use which provides for more than a purely local service such as a superstore (over 2,500 sq metres) Formal approval given by a local planning authority for Development requiring planning permission (see General Listed Building Development Order), usually valid for five years for a full permission or three years for an outline permission in which details are A building of special architectural or historic interest included on a reserved for subsequent approval. statutory list compiled by the DoE. Planning Permission is required for the demolition or alteration of such a building. Previously Developed Urban Land

Local Employment Sites Previously-developed land is that which is or was occupied by a permanent structure (excluding agricultural and forestry build- Sites, outside the Primary Employment Areas, which provide, or ings), and associated fixed surface infrastructure1. The definition are capable of providing, local employment opportunities. These covers the curtilage of the development2. Previously-developed sites include those on the fringes of Primary Employment Areas, land may occur in both built-up and rural settings. The definition scattered large sites and smaller sites dispersed throughout the includes defence buildings, and land used for mineral extraction Borough including those in residential areas. and waste disposal where provision for restoration has not been made through development control procedures3. Metropolitan Open Land (MOL) The definition excludes land and buildings that have been used Areas of predominantly open land forming islands and wedges in for agricultural or forestry purposes and land in built-up areas the built up area and which provide it with strategic and attractive which has not been developed previously (e.g. parks, recreation breaks. Strategic Guidance stresses that there should be a pre- grounds, and allotments - even though these areas may contain sumption against development in these areas. certain urban features such as paths, pavilions and other buildings). Also excluded is land that was previously developed but Non-conforming Use where the remains of any structure or activity have blended into the landscape in the process of time (to the extent that it can rea- Any use which would be out of character and keeping with the sonably be considered as part of the natural surroundings), and established predominant use of an area, e.g. a general industrial where there is a clear reason that could outweigh the re-use of use located in a primarily residential area. the site - such as its contribution to nature conservation - or it has subsequently been put to an amenity use and cannot be regarded Non-Retail Use as requiring redevelopment.

Use within shopping centres that are not within Use Class A1. 1: In other words, the urban land uses as defined by the DETR's Land- Use Change Statistics (excluding 'urban land not previously developed').

Brent Unitary Development Plan - 2004 289 GLOSSARY

2: The curtilage is defined as the area of land attached to a building. Site of Special Scientific Interest (SSSI) All of the land within the curtilage of the site (as defined above) will also be defined as previously developed. The curtilage will be that as defined for the A site of special interest by reason of its flora, fauna, geological or DETR/ Ordnance Survey/ Land Use Change Statistics classification. physiographical features.

However, this does not mean that the whole area of the curtilage should Sequential Approach therefore be redeveloped. For example, where the footprint of a building only occupies a proportion of a site of which the remainder is open land Government policy directing uses that attract a lot of people, such (such as at an airfield or a hospital) the whole site should not normally be as retail and leisure, to town centres in the first instance. This is developed to the boundary of the curtilage. The local planning authority explained in detail in the Town Centres and Shopping Chapter should make a judgement about site layout in this context, bearing in mind section 8.7. A modified version of it also applies to housing (see other planning considerations, such as protection of open space or playing policy H10). fields or development in the countryside, how the site relates to the surrounding area and requirements for on-site open space, buffer strips, land- Spatial Development Strategy scaped areas, etc, and how the site relates to the surrounding area. The future Mayor of London’s planning strategy, as well as the 3: This relates to minerals and waste sites which are to remain unre- spatial policy framework for all of the Mayor’s other strategies. stored after use because the planning permission allowing them did not include a restoration condition. All other such sites will be restored to 'green- Supplementary Planning Guidance field' status, by virtue of the planning condition. Guidance additional and supplementary to the Unitary Source: PPG3 Development Plan on how to implement its policies. For example on domestic extensions and shopfronts. Primary Shopping Frontage Strategic Centres That area of a shopping centre which is generally the busiest, and contains the largest shop units and major multiples. These are Town centres considered to be of strategic importance to London, primarily in use Class A1. (See also Secondary Shopping which are the main locations for cultural, entertainment and Frontage). leisure facilities, as well as shopping. LPAC have identified 33 such centres. Residential Density Strategic Guidance (RPG3) The existing or proposed number of habitable rooms (defined above) in a given area - usually expressed in terms of habitable Provided by the Secretary of State for the Environment in 1993 to rooms per hectare or acre (definition derived from "The Greater guide London Boroughs in preparing their Unitary Development London Development Plan", G.L.C., 1976). Plans.

Retail Warehouse Strategic Employment Area

A single level retail store selling non-food goods direct to the pub- Coherent areas of land within the main industrial estates which lic on the premises, usually occupying a purpose built structure are, in terms of environment, road access, location, parking and with associated car parking, or an existing converted warehouse operating conditions, well suited for retention in industrial use. or industrial building. Superstore Section 106 A large food retail outlet of over 3700 sq m (gross floorspace). The section of the Town and Country Planning Act 1990 that provides for the creation of 'Planning Obligations' (defined above). Sui-Generis

Secondary Shopping Frontage Uses not falling within a defined use class, e.g. car sales, waste transfer, hostels, theatres, launderettes, petrol stations and That part of a shopping centre outside the Primary Frontage usu- amusement arcades. ally on the fringe, where units are generally smaller and there is a higher proportion of non-retail uses (see Primary Shopping Sustainable Development Frontage). Development which meets the needs of the present without com- Sheffield cycle stand promising the ability of future generations to meet their own needs and aspirations. A steel loop to which a bicycle can be securely attached.

Brent Unitary Development Plan - 2004 290 GLOSSARY

Urban Grain Use for the provision of residential accommodation and care to people in need of care (other than a use in Class C3), or use as a hospital or nurs- A measure of the typical pattern of building plots and streets in ing home, or use as a residential school, college or training centre. urban areas. For example, older areas typically have a 'fine grain' with many streets and smaller plots. Class C3 Dwellinghouses

White Groups Use as a dwellinghouse (whether or not as a sole or main residence):

This term is used here to refer to the three White groups of British, (a) by a single person or by people living together as a family; Irish and Other. (b) by not more than six residents living together as a single household Use Classes Order (including a household where care is provided for residents).

The Town & Country Planning (Use Classes) Order 1987 lists 16 Class D1 Non Residential Institutions classes of use. A change from one use to another use within the same Class does not constitute development and consequently Places of worship, day nurseries, medical services, museums etc. does not require planning permission. Some of the most widely used use classes include: Class D2 Assembly and Leisure

Class A1 Shops Use as cinemas, bingo halls and indoor sports etc.

Class A2 Financial or Professional Services

Financial or Professional Services (other than health or medical services), being services which it is appropriate to provide in a shopping area, and where the services are provided principally to visiting members of the public.

Class A3 Food and Drink

Use for the sale of food or drink for consumption on the premises or of hot food for consumption off the premises.

Class B1 Business

Use for all or any of the following purposes-

(a) as an office other than a use within Class A2,

(b) for research and development of products or processes.,or

(c) for any industrial process. being a use which can be carried out in any residential area without detriment to the amenity of that area by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust or grit.

Class B2 General Industrial

use for the carrying on of an industrial process other than one falling within Class B1, or special industrial groups Classes B3 to B7.

Class B8 Storage or Distribution

Class C1 Hotels

Use as a hotel, boarding or guest house or as a hostel where, in each case, no significant element of care is provided.

Class C2 Residential Institutions

Brent Unitary Development Plan - 2004 291 GLOSSARY

LIST OF ABBREVIATIONS

ACE Arts, Culture and Entertainment LRC London Research Centre

ADRC Area of Distinctive Residential Character LTB London Tourist Board

AQMA Air Quality Management Area MERA Major Estate Regeneration Area

BEA Borough Employment Area NHS National Health Service

BME Black and Minority Ethnic groups NLUD National Land Use Database

CIA Commercial Improvement Area NRA National Rivers Authority

C.L.E.A . Contaminated land exposure assessment model ODPM Office of the Deputy Prime Minister

CPZ Controlled Parking Zone ONS Office of National Statistics

DCMS Department for Culture, Media and Sport PFI Private Finance Initiative

DfEE Department for Education and Employment PPG Planning Policy Guidance

DETR Department of the Environment, Transport and Regions SDS Spatial Development Strategy

DLP The draft London Plan SEA Strategic Employment Area

EA Environment Agency SRB Single Regeneration Budget

GLA Greater London Authority SSSI Site of Special Scientific Interest

GOL Government Office for London SPG Supplementary Planning Guidance

GPDO General Permitted Development Order TfL Transport for London

HIP Housing Investment Programme TPO Tree Preservation Order

HMO Housing in Multiple Occupancy SERPLAN South East Regional Planning Conference

HFE Higher and Further Education UDP Unitary Development Plan

IIA Industrial Improvement Area

ITP Interim Transport Plan

LA21 Local Agenda 21

LBB London Borough of Brent

LEA Local Education Authority

LES Local Employment Site

LPA Local Planning Authority

LPAC London Planning Advisory Committee

Brent Unitary Development Plan - 2004 292 INDEX 17INDEX

A Conversions 3 Heritage 43 A40/M40 Western Avenue 246 Corporate Strategy 4 High Buildings 34 Access for People with Disabilities 28 Creative Industries 162 Higher & Further Education (HFE) 229 Accessible Housing 100 Cricklewood 170 Higher-Intensity Development 35 Advertisements 42 Crime 4 Home-working 163 Affordability 84 Cycling 10, 116, 120, 121, 264 Hospitals 223, 224 Affordable housing 11, 81, 83, 138 D Hostels 137, 228 Aggregates 242 Day nurseries 228 Hostels for the Homeless 101 Air Quality 66, 67 Design 132 Hotels 137, 199, 200 Air Quality Action Plan 67, 108 Design Briefing 26 Household Change 79 Air Quality Management 66 Design Guidance 26 Housing 7, 10, 15, 78 Air Quality Management Areas 67, 68 Design Statements 26 Housing information 103 Allotments 9, 203, 215 Design Submissions 25 Housing Provision and Needs 79 Alperton 8 Designing-Out Crime 30 Housing Renewal 3 Amenity Space 291 'Design-Led' Approach to Density 93 I Amusement Centres 180 Developer Contributions 115 Incineration 241 Ancillary Use 291 Disabled people 5, 133 Industrial Land 151 Architectural Quality 34 'Drive Through' Restaurants 176 Industry 161 Area Consultative Forums 15 Dual Use Open Space 209 Information technology 7 Areas Of Distinctive Residential Character Durable Goods 292 Infrastructure 74, 113, 118 47 E Integrated Transport 15, 108 Areas Of Low Townscape or Public Realm Ealing 246, 248, 249 Integrated Transport Strategy 109 Quality 38 Ealing Road 168, 170, 188 Integrated Transport White Paper 109 Areas of Open Character 206 East-West Crossrail 118 Integration 114 Arena 170 Edgware Road 127 Intermediate Modes 118 Arts, Culture and Entertainment Facilities Elderly people 5 International headquarters 7 198 Elderly Persons Accommodation 138, 99, International sporting festivals 255 Assembly and Leisure 137, 139 100 Inward Investment 15, 109, 154 B Employment 7, 149 J Bakerloo Line 4 Enabling Development 47 Jubilee Line 4 Best Practical Environmental Option 65, 234 Energy 11, 36-38 K Borough Employment Areas 9, 156 Environment Agency 65, 71 Kensal Rise 189 Brent Cross 169 Environmental Impact 65 Kenton 3, 170 Brent Park 126 Environmental Impact Assessment 65 Key Worker Housing 87 Brent’s Road Network 124 Environmental Impact of Employment Kilburn 3, 168, 170, 187 Brent's Road Network 134 158 Kingsbury 3, 170 British Empire Exhibition 23, 265 Environmental Statement 65 Brownfield Sites 9, 291 Estate Access Corridor 264 L Buses 116, 119, 264 Ethnic minorities 5, 151, 222 Land causing poor amenity 75 Business /Technology Parks 161 Euston Line 4 Landmarks 49 Landscape 31 C F Leisure 7, 8, 181 Camden 127 Flooding 72, 75 Libraries 181, 231, 268 Car Parks 132 Food and Drink 140, 179 Lighting 33 Car-Boot-Sales 186 Food and drinks industries 7 Listed Buildings 43 Care in the Community 291 Freight 8, 133, 247 Listed Buildings 'at Risk' 44 Cemeteries 215 Fryent Country Park 4, 8, 202, 212 Local Agenda 21 4, 23 Central Line 248, 249 Function rooms 179, 225 Local Area Transport Strategies 126 Central London 3, 7, 8, 13, 125 G Local Centres 182 Central Middlesex Hospital 246, 252 Gateways 39, 249 Local Distributor Roads 134 Channel Tunnel 118 Giles Gilbert Scott 249 Local Employment Sites 9, 157, 289 Children's Play 213 Global warming 109 Local Transport Plans 110 Childrens Play Space 291 Government Office for London 246 Locally Listed Buildings 44 Chiltern Line 4, 118 Grand Union Canal 39, 70, 247, 249 London Bus Priority Network 10, 119 Cinemas 139 Green Chains 13, 206 London Canals Committee 207 Circular 2/99 65 Green transport plans 115 London Cycle Network 10 Circular 4/99 41 Greenfield sites 9 London Distributor Roads 124, 126, 134 Coaches 132 Groundwater 70 London Ecology Unit 204, 211 Colindale 8, 170 Guinness 246 London Pride Waste Action Plan 14 Community Facilities 222, 223, 224 Gypsy/ Travellers Sites 102 London Research Centre 226 Community Safety 4, 30 London Road Network 124 Community Transport 120 H London Tourist Board 13 Competitiveness 6 Habitable Room 288 LPAC 255 Comprehensive Development 260 Hammersmith & Fulham 246, 248 Congestion 8, 109 Harlesden 3, 168, 170, 188, 246 M Conservation 15 Hazardous Substances 69 Major Estate Regeneration Areas 11, 89 Conservation Area 292 Health Check 169 Major Opportunity Sites 9 Conservation Areas 45 Heathrow airport 7, 246 Manufacturing 3, 7 Contaminated Land 69 Heavily Parked Streets 140 Metropolitan Line 4 Contract Parking 131 Heinz 246 Metropolitan Open Land 13, 202, 203, 205

Brent Unitary Development Plan - 2004 293 INDEX

Metropolitan Walks 214 R Three stations strategy 261, 267 Mini-Cab Offices 181 Rail 117, 118 Tokyngton 75 Mixed Uses 35 Recycling 240 Tourist, visitor and ACE uses 197 Mixed-use development 9 Red Route 125 Town centres 6, 8, 173, 190, 170 Monitoring 15 Regeneration 6, 9, 15, 159 Traffic Director for London 127 MPG6 240 Regional Planning Guidance for the South Traffic Management 122, 262 N East 246 Traffic Reduction Plan 108 National Land Use Database 15 Residential Density 92 Traffic Restraint 126 National Playing Fields Association 208 Residential Development 138 Training and Enterprise Councils 246 National Stadium 3, 13, 15, 127, 254, 255, Residential Parking 128 Transport 108, 247, 261, 263 265, 270 Restaurants 139, 179 Transport Corridors & Gateways 39 National Stadium Policy Area 258, 260, 262 Retail 8, 170 Transport impact 225 Nature Conservation 204, 211 Retail Markets 184, 185 Transport Impact Assessments 113 Neasden 127 River Brent 3, 15, 70, 267 Transport Infrastructure 116 Night-time Economy 179 Road & Rail Corridors 39 Transport Interchanges 117, 272 Noise 66, 109 Road Safety 122 Transport Impact 113, 114 North Circular Road 3, 4, 8, 23, 34, 108, Road Safety Plan 108 Trees 49 125, 134, 164, 169 RPG3 -6, 9, 24, 64, 124, 125, 128, 129, Twyford Abbey Road 249 North Circular Road 246 152, 171, 236, 254 U North London Line 4 RPG9 5, 24, 111, 152, 236 UK Strategy for Sustainable Development 5 Northwick Park 202 S Underground 117, 118 Northwick Park Hospital 229 Satellite Dishes 41 Unemployment 8, 151 O School extensions 227 United Biscuits 246 Offices 161, 181, 258 School grounds 227 Urban Conservation 43 Olympic Way 257, 264, 265, 267 School Places 225, 226 Urban design 5, 22, 27, 264, 265 Olympics 265 Schools 227 Urban Design Quality 91 On-street parking 129, 262 Secured by Design 30 Urban Green Space 210 Open Space 10, 64 Sequential approach 7, 9, 113 Use Classes Order 291 Open Space Deficiency 207 SERPLAN 6, 234 V Opportunity Sites 270, 271 Sheltered Housing 100 Vibration 66, 109 Other Structures 40 Shopping 4 Views 266, 274 P Single parent families 5 Views and landmarks 11, 49 Single Regeneration Budget 248 Park Royal 12, 127 W Site of Special Scientific Interest (SSSI) Park Royal Interchange 118, 248, 249 Walkable neighbourhoods 10, 11, 82 212, 217 Park Royal North-Western Gateway 250 Walking 10, 120 Sites of Archaeological Interest 48 Park Royal Partnership 246 Warehousing 162 Small and medium sized enterprises (SMEs) Park Royal Western Gateway 126, 248, 249 Waste 9, 14-16, 233 154 Parking 126, 130, 262 Waste Management/Manufacturing Areas South East 7 Parking and Servicing Standards 135 273, 241-243 South East Region 5 Parking for Disabled People 138 Waste disposal 242 Spatial Development Strategy 6 Parking in Town Centres 130 Waste Management Hierarchy 235 Species Protection 212 Parking Standards 136 Water 70 Sport 9 Pedestrians 116 Water Supply 71 Sport England 208 Petrol Filling Stations 176 Wealdstone Brook 70 Sporting facilities 270 Piccadilly 248, 249 Welsh Harp 3, 8, 75, 202, 212 Sports Grounds 202 Piccadilly Line 4 Wembley 7, 15, 168, 170, 254, 255 Sports Pitches 208 Places of Worship 230 Wembley Central Station 256-258, 271 Sports Strategy 4, 202 Planning Brief 293 Wembley Park 170, 254 Stadium Access Corridor 260, 264 Planning Obligation 293 Wembley Park District Centre 268 Staples Corner 7, 164 Planning Permission 293 Wembley Park Station 272 Station Car-parks 132 Polluter Pays 65 'Wembley Promenade' 257 Statutory undertakers 74 Pollution 66 Wembley Stadium 3, 257 Stonebridge 246 Population 7, 9 Wembley Stadium Business Park 260 Strategic & Borough Employment Areas Potentially Polluting Development 68 Wembley Stadium Station 272 159, 160 PPG 15 24 Wembley Task Force 254 Strategic Development Framework for West PPG1 5, 64, 152 Wembley Town Centre 262, 267, 268 London 7 PPG12 5, 23, 152 West London 8, 247 Strategic Employment Areas 9, 155-156, PPG13 110, 152, 171 West London Leadership 7, 246 247, 259 PPG23 236 West London Transport Strategy 111 Strategic Guidance 2 PPG24 66 Western Avenue 248 Strategic Rail Authority 109 PPG3 23 Wildlife Corridors 211 Strategic Road Network 9, 10 PPG4 152 Wildlife Habitats 213 Street Environment 32 PPG6 9, 171, 254 Willesden Green 168, 231 Students 5 Previously Developed Urban Land 293 Willesden Hub 248 Suburbs 3 Private Non-Residential Parking 126 Willesden Junction Hub 118 Sudbury 170 Promenade 255, 257 Work-Live 138, 162 Supported Housing 98, 229, 252 Proposals Map 2 World City 6, 254 Surface Water 70, 71 Public Art 198 Sustainability Indicators 15 Public Open Space 207 Sustainable Design & Construction 36 Public Realm 31, 265 Sustainable development 5, 14, 24, 36 Public transport 9, 10, 115, 116 Sustainable Waste Management 234 Public transport accessibility 5, 115, 116, 117, 260 T Public transport contributions 115 Taxis 132 Public Transport Impact 113 Telecommunications Equipment 41 Q Teleworking 115 Temporary classrooms 227 Queens Park 3, 170, 189 The Precautionary Principle 65 Theatres 137, 139

Brent Unitary Development Plan - 2004 294 Proposals Map (Wembley & Park Royal Insets are on reverse side) Published by:

The Planning Service Brent House 349 High Road Wembley Middlesex HA9 6BZ

For further information contact:

Tel: 020-8937 5230 Email: [email protected] http://www.brent.gov.uk/planning.nsf