AGENDA ITEM: 6 Page nos. 20 – 367 (enclosures circulated separately)
Meeting Cabinet Date 6 September 2010 Subject Local Development Framework – Core Strategy – Publication Stage Report of Cabinet Member for Housing, Planning, and Regeneration Summary The Local Development Framework (LDF) is one of the most important statutory plans that must be produced for Barnet. Developed through working with strategic partners the LDF is the spatial mechanism for delivery of the Sustainable Community Strategy and the Three Strands Approach: Protect, Enhance and Consolidate Growth. The Core Strategy is the key document and sits at the heart of the LDF. It sets out where, when and how change will take place, providing a shared vision of what Barnet will be like as a place in 2026. All other planning documents need to accord with its strategic direction and key planning policies. The Publication Stage provides the final opportunity for public consultation on the Core Strategy.
Officer Contributors Director of Planning, Housing and Regeneration Assistant Director, Strategy (Planning & Housing) Status (public or exempt) Public Wards affected All Enclosures (separately Appendix A: Core Strategy – Publication Stage circulated) Appendix B: Representations and Responses For decision by Cabinet Function of Executive Reason for urgency / N/A exemption from call-in
Contact for further information: Nick Lynch - Planning Policy (LDF) Manager - 0208 359 4211
20 1. RECOMMENDATIONS 1.1 That the Core Strategy – Publication Stage be approved for a period of at least six weeks of public engagement.
1.2 That the Director of Planning, Housing and Regeneration be authorised in consultation with the Cabinet Member for Housing, Planning and Regeneration to agree any consequent changes to the Core Strategy – Publication Stage
1.3 That responses to final consultation on the Core Strategy are reported back to Cabinet prior to submission to the Secretary of State.
2. RELEVANT PREVIOUS DECISIONS
2.1 26 February 2007 Cabinet (Decision Item 5) approved the Local Development Scheme (LDS, the project programme for the Local Development Framework) which includes preparing the Core Strategy. On 31 March 2007 revisions to the LDS were approved by the Council Leader and on 29 May 2007 (item 5) further changes were approved by the Director of Planning and Environmental Protection under delegated powers.
2.2 18 June 2008 Cabinet (Decision Item 7) approved Core Strategy Issues and Options.
2.3 22 April 2009 Cabinet (Decision Item 6) approved a request to the Secretary of State for Communities and Local Government to issue a direction saving all the policies of the UDP other than those listed in the Appendix.
2.4 On 21 October 2009 Cabinet (Decision Item 9) approved the Core Strategy – Direction of Travel.
3. CORPORATE PRIORITIES AND POLICY CONSIDERATIONS 3.1 All three priorities in the Corporate Plan 2010 to 2013 are embedded within the Core Strategy. 3.2 In providing better services with less money the Core Strategy addresses the need to: - make more efficient use of our community assets in order to improve service delivery. Further integration of services such as libraries and children’s centres in 'hubs' is highlighted as the way forward establish the Community Infrastructure Levy as the replacement for S106 funding and set out the evidence on infrastructure requirements in the Infrastructure Delivery Plan which will form the basis for a CIL charging schedule 3.3 In sharing opportunities and sharing responsibilities the Core Strategy addresses the need to: -
21 provide increased housing choice in mixed communities including extra care housing and the need for lifetime homes in order to promote independence and to support vulnerable adults; enable children and young people to develop skills and acquire the knowledge to lead successful adult lives through our programme for improvements to the schools estate, provision of children's centres and commissioning of youth services; improve delivery of clinical care as well as targeting unhealthy lifestyles and tackling health inequalities; 3.4 In enabling Barnet to continue to be a successful London Suburb the Core Strategy addresses the need to: - protect and enhance our natural environment through provision of new improved, multi-functional and accessible green spaces that form part of a Londonwide green grid. protect and enhance our suburban environment by ensuring that development respects local context and Barnet’s distinctive local character. ensure economic prosperity and enterprise through a mix of compatible uses is provided in vibrant town centres including retail, housing and affordable and flexible workspace for business to create local employment opportunities; make Barnet a safer place and through our programme of town centre frameworks enhance our suburban town centres as places which engender civic pride and activity; develop a better understanding of how new and growing communities in the regeneration areas integrate cohesively and transform prospects to become thriving diverse neighbourhoods support GPs and the plans of the NHS Barnet to deliver modern primary care
3.5 The Coalition Government will publish in this Parliament a Decentralisation and Localism Bill. It proposes that the main benefits of the Bill will be: Empowering local people. Freeing local government from central and regional control. Giving local communities a real share in local growth. A more efficient and more local planning system. The LDF Core Strategy will be updated to reflect the Bill and the Localism Agenda.
3.6 The LDF Core Strategy is required to be in harmony with the Sustainable Community Strategy 2008 - 2018. The themes and ambitions of the Sustainable Community Strategy are reflected throughout the Publication Stage and Table 1 in Appendix A sets out the linkage between themes, ambitions, Core Strategy objectives and the policy framework. Reference to the planned revision of the Sustainable Community Strategy has been added
22 to the Core Strategy and will be updated prior to the Examination in Public in Spring 2010.
3.5 The Three Strands Approach sets out our approach to planning, development and regeneration over the next 15 years and is the Core Strategy priority spatial policy. The approach of protection of Green Belt and open spaces; enhancement of high quality suburbs, the historic environment and vibrant town centres; and management of targeted and consolidated housing growth in the pipeline in areas undergoing significant regeneration and strategic development provides the foundation for 'place shaping' Barnet.
3.6 The Core Strategy – Publication Stage also reflects the spatial dimensions of the Children and Young People's Plan, Older Adults Strategy, Housing Strategy, Health and Well-being Commissioning Framework and the Safer Communities Strategy.
4. RISK MANAGEMENT ISSUES
4.1 Failure to replace the UDP (adopted in 2006) with an up-to-date development plan will hinder delivery of sustainable growth, proper planning of infrastructure and protection and enhancement of what makes Barnet distinctive as a place. As the UDP becomes less relevant and ultimately outdated in the absence of a LDF replacement the Council's ability to justify and defend planning decisions including at appeal will be weakened.
4.2 The Core Strategy has to be in general conformity with the adopted London Plan even though it is currently under review. The Mayor of London published his draft London Plan in October 2009 and expects to have completed the review of the London Plan by winter 2011/ 2012. Any departure from the existing London Plan requires robust local justification. It is therefore important to carefully align local policy development with the London wide review. Barnet’s LDF Core Strategy will also closely reflect the direction of travel of the new Mayor’s London Plan.
4.3 At the London Plan Examination in Public on July 9th 2010 the Secretary of State clarified the implications of the revocation of Regional Spatial Strategies (RSS) for London and the devolvement of powers to the Mayor of London. Although, following the revocation of RSS, targets on matters such as housing are no longer required in London the setting of such targets is a matter for the Mayor of London and partners to consider.
4.4 Targets in the draft revised London Plan set Barnet a target for 2026 of 33,800 new homes. This proposed target exceeds our expectation of housing delivery by 2026 which is 28,000. We have objected to the higher target on the basis that Barnet’s capacity for major development is finite and that fewer new major opportunity areas are being identified in the borough. We intend to appear at the Examination in Public into the draft revised London Plan in autumn 2010 to challenge the long term housing target and seek to move to the consolidated position of 28,000 pipeline new homes target.
23 4.5 The Core Strategy will be subject to an Examination in Public by an Independent Planning Inspector. The Inspector will assess soundness of the document on the basis of it being justifiable, effective and consistent with national policy. If the Core Strategy is found unsound we will be required to go back to an earlier stage which would seriously delay plan-making in Barnet. The Planning Advisory Service has produced a template to assess soundness at different stages of preparation of LDF documents.
4.6 As part of the Planning Inspectorate's 'early engagement' programme an inspector visited Barnet on 22 October 2009 and provided an assessment of the LDF Direction of Travel. The Inspector considered that the document to be a good start towards the final Core Strategy. His main concern is the failure to meet London Plan housing targets. This is a significant risk to the Council which needs to be balanced against the consolidation and sustainability of growth objectives.
5. EQUALITIES AND DIVERSITY ISSUES
5.1 The Core Strategy will provide a high-level framework to help improve opportunities and quality of life. It will ensure the delivery of community benefits including educational and healthcare facilities; a range and mix of housing including affordable housing; highways improvements; and open space provision for future and existing residents from all of Barnet’s diverse communities. Any new buildings and public spaces within future development will be required to be compliant with disability legislation. 5.2 The Core Strategy will be accompanied by an Equalities Impact Assessment (EqIA) which will address the six questions for assessing equalities in the Corporate Plan and will ensure that policies developed and implemented through the LDF process contribute to improving the lives of local communities. 5.3 In order to understand the needs, aspirations and views of all of Barnet’s diverse communities we will continue to ensure that consultation is as far reaching as possible. The nine-week period of consultation on the Direction of Travel included Barnet Civic Network, Citizen’s Panel and the Area Forums. Through partnership with CommUNITY Barnet we sought to reach a wide audience of residents and community stakeholders by attending scheduled meetings. Officers publicised the Core Strategy – Direction of Travel at meetings including the Federation of Residents Associations in Barnet (FORAB), Barnet Multicultural Network, Barnet 55+ Forum, Barnet Women’s Design Group, Barnet Homes Hub and Barnet Landlord Business Club. Through the Citizen’s Panel we ensured greater participation of younger people as part of a Panel event in December 2009.
6. USE OF RESOURCES IMPLICATIONS (Finance, Procurement, Performance & Value for Money, Staffing, IT, Property, Sustainability)
6.1 The cost of preparing the Local Development Framework is included in the Planning, Housing and Regeneration Directorate’s approved budget in 2010/11.
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6.2 The Coalition Government has set out a new approach to housing growth to shift power back into the hands of individuals, communities and councils and give communities a real share in growth. As part of the Decentralisation and Localism Bill it will set out a package of incentives which would provide Council Tax matchfunding on every new house built and a higher rate on each new affordable home.
6.3 Use of IT and existing community events for publicising the Core Strategy, Site Allocations and Development Management Policies documents will be maximised in order to reduce process, consultation and production costs whilst optimising channel change and access by planning customers.
7. LEGAL ISSUES
7.1 The Planning & Compulsory Purchase Act 2004 and the Town and Country Planning (Local Development) (England) Regulations 2004 provide guidance on the preparation and adoption of Local Development documents, of which Core Strategy is the key document setting out the objectives and the policies.
7.2 Upon adoption the LDF Core Strategy becomes a statutory Development Plan Document that provides part of Barnet's legal planning policy framework.
8. CONSTITUTIONAL POWERS
8.1 Constitution, Part 3 (Responsibility for Functions) Section 3 (Responsibilities of the Executive).
9 BACKGROUND INFORMATION
9.1 The LDF Core Strategy comprises the long-term spatial vision and strategic place-shaping objectives for Barnet; A spatial strategy, core policies, and a monitoring and implementation framework with clear objectives for delivery. The Core Strategy should be kept under review and maintain a 15 year time-horizon. Barnet's Core Strategy is targeted for adoption in 2011 and therefore looks ahead to 2026.
9.2 The benefits of an adopted Core Strategy are very significant in planning terms as it places the Council’s Three Strands Approach of Protect, Enhance and Consolidated Growth on a statutory footing. It also provides more certainty for residents, developers, local strategic partners and utility providers. An adopted Strategy creates the planning framework for successfully implementing a One-Barnet approach helping the Council as well as our key partners to understand how we will shape the future development of the borough.
9.3 The Publication Stage represents the final consultation stage in the development of the Core Strategy. Following consultation on this stage the Core Strategy will be submitted to the Planning Inspectorate in late 2010. The
25 Core Strategy will then be subject to an Examination in Public in Spring 2011 and adoption of the Core Strategy is envisaged by late Summer 2011.
9.4 Engagement on the previous stage of the Core Strategy – Direction of Travel which ended in January 2010 generated over 2,000 comments from 334 respondents including residents, community and amenity groups, landowners and developers, as well as the Greater London Authority, Government Office for London, Local Strategic Partnership partners and national agencies including English Heritage and the Environment Agency.
9.5 In summary policies on town centres, travel and distribution of growth generated most responses and objections while the Three Strands Approach attracted most supporting comments. Our responses to comments on the Direction of Travel are set out at Appendix B.
9.6 The following sub-headings reflect representations received : -
Housing Growth and Infrastructure Borough-wide responses from residents and community groups mainly focused on the level of housing growth and the timely delivery of infrastructure including transport facilities, schools and healthcare. In terms of housing we have highlighted those parts of the Borough where we expect the majority of housing growth and regeneration to take place and when it is likely to be delivered.
The housing target is 28,000 new homes by 2026 but there has been significant re-appraisal of the components of this target which secures a period of ‘consolidation’ of planned, approved and pipeline growth. The target now includes an allowance for private sector small scale development, vacant properties being returned to use and non self contained accommodation. This amounts to 6,000 new homes. Out of the remaining 22,000 new homes there will be 17,000 in the growth and development areas (Brent Cross-Cricklewood, Colindale and Mill Hill East) and 2,400 in the priority housing regeneration estates. The remaining sites have been largely identified through planning consents, planning briefs and emerging town centre frameworks.
As part of its evidence base the Core Strategy is required to provide an Infrastructure Delivery Plan (IDP) which sets out what will be delivered in the next 15 years, where it will be located, when it will be delivered and how it will be funded. The IDP is a corporately owned piece of evidence which reflects the capital programmes of the council and key partners including NHS Barnet.
Housing Density Borough-wide responses from residents and community groups also focused on housing density and the impact of housing development on main thoroughfares.
In terms of housing density the Core Strategy is aligned with the approach in the Draft London Plan of optimising through taking into account context and transport accessibility rather than maximising density. The specific identification of thoroughfares as having housing potential for infill development has been deleted from the Core Strategy. Any planning proposals for such locations
26 will be primarily considered against the Development Management Policies DPD which will eventually replace ‘saved’ policies in the UDP.
Affordable Housing Respondents highlighted concerns about level of affordable homes to be delivered, as well as the dwelling mix.
With evidence from the draft North London Strategic Housing Market Assessment (SHMA) supported by an Affordable Housing Viability Assessment we will seek a local affordable housing target of 30% and a minimum numeric target of 5,500 new affordable homes by 2025/26. These figures are still subject to final agreement within the North London sub-region on the SHMA. Our preference for family accommodation is also clearly set out.
New Barnet Town Centre Over 250 residents in the New Barnet area submitted a pro-forma objecting to the identification of their town centre as a priority for mixed use development and East Barnet Road as a thoroughfare having potential for residential infill.
New Barnet is no longer identified as a priority town centre. The emerging Town Centre Framework for New Barnet will provide a framework for managing future change including brownfield site opportunities. Future development proposals in New Barnet will be primarily considered against the Development Management Policies DPD which will eventually replace ‘saved’ policies in the UDP. Reference to East Barnet Road as a thoroughfare and the identification of thoroughfares as having housing potential has been deleted from the Core Strategy.
Draft Revised London Plan Concerns were also expressed by respondents about alignment with the Draft London Plan. Although the Draft London Plan was published in October 2010 its own direction of travel influenced Barnet’s Core Strategy in the various iterations. The Mayor has made detailed comments on the document as set out in Appendix B. Most of these have related to transport but he also raised issues about tall buildings, distinctiveness and the role of the night time economy.
On the basis of an assessment of existing and proposed locations of tall buildings (defined as being 8+ storeys in height) we ensure that future proposals will only be considered subject to no demonstrable impact on their surroundings. The Publication Stage of the Core Strategy makes it more explicit what sets Barnet apart from its neighbours and addresses the role of Barnet’s town centres in promoting a healthy night time economy.
Government Office for London (GOL) GOL considered the Core Strategy to be progressing well with a strong spatial concept and appreciated its brevity and limited number of policies. GOL suggested improvements in terms of adding more detail to delivery of homes including a borough wide target for affordable housing, jobs and retail floorspace in order to make better links with the evidence base. They also recommended re-formatting the document so that policies flowed more logically and that the
27 Three Strands policy CS1 clearly set out the linkages between Growth with more thematic policies on Protection and Enhancement.
The policy order and Policy CS 1 have been revised accordingly. Policies CS 3, CS 5 and CS 7 have been revised to incorporate quantity and timelines for major housing, retail and jobs growth. Policy on CS 4 on Providing Quality Homes has set an overall target for affordable housing.
LSP Partners LSP partners including NHS Barnet and Middlesex University have been largely supportive of our approach and have suggested amendments to improve the document. The submission by the Metropolitan Police Authority highlighted the need to address modern policing requirements including allowing policing facilities on designated employment sites. Given the limited stock of employment land in Barnet and the role it plays in promoting prosperity the Core Strategy does not support such re-designation. However Policy CS 11 on Making Barnet a Safer Place highlights our commitment to work with the Metropolitan Police to provide re-modelling of its estate as a basis for an effective and responsive police service.
Evidence base Concerns were also expressed about the availability of evidence to support the Direction of Travel. We intend at submission stage to make all LDF evidence freely available on our web-site. Work is nearing completion on a Strategic Housing Market Assessment to provide an up to date picture of housing need in Barnet and provide an appropriate approach to providing affordable housing and family homes. We are also completing work on improving our understanding of the supply and demand for community spaces in Barnet.
9.7 In order to secure a strategic policy framework for the future regeneration of Brent Cross Cricklewood a new policy has been added to the Core Strategy. This policy provides a link with the ‘saved’ policies of the UDP on Brent Cross Cricklewood and the Development Framework Supplementary Planning Guidance that was adopted in 2005. The new Core Strategy policy sets out that any future applications for the area will be determined in accordance with the saved UDP policies, Development Framework and London Plan.
9.8 The Core Strategy has been updated to reflect curbs on capital expenditure announced in the Coalition Government’s Emergency Budget in June 2010 and the end of the Building Schools for the Future Programme. It has also been revised to highlight the Future Shape Programme and its impact on spatial planning. The need for greater co-location with other public agencies and making more efficient use of community facilities is the focus of Policy CS 10 – Enabling Integrated Community Facilities and Uses. Facilitating behaviour change and a new relationship with citizens is a focus of policies on town centres, travel, use of natural resources and waste.
9.9 The section on providing effective and efficient travel has been rewritten in order to set out more detail on what we are doing to , ensure more efficient use of the road network, deliver high quality transport systems in regeneration areas,
28 more environmentally friendly transport networks and taking a comprehensive approach to tackling the school run.
9.10 The Core Strategy Publication Stage reflects the recommendations in the February 2010 Cabinet Report on Responding to the Recession - Suburban Town Centres. This includes redefining the role of each town centre based on appropriate functions, support for creation of larger shop units to meet demand from bigger retailers and flexibility on temporary permissions to reduce, in the short term, the number of vacant properties.
9.11 The Publication Stage document (Appendix A) sets out a Core Strategy policy framework of 15 policies. In summary these are:
Barnet's Spatial Strategy - Protection, Enhancement and Growth - sets out the vision of how Barnet will change and where that change will happen Brent Cross Cricklewood – ensures that existing policy framework as set out in ‘saved’ policies of the UDP is retained as basis for determining future planning applications Distribution of Growth in Meeting Housing Aspirations - sets out the most sustainable locations for consolidated housing growth and regeneration in the west of the borough together with the priority housing estates and town centres. It also sets out how much these areas will contribute to an estimated supply of 28,000 new units between 2011/12 and 2025/26. Providing Quality Homes and Housing Choice in Barnet - sets out need to provide wider choice in accessing housing in terms of tenures, types and size. It highlights that an appropriate level and mix of affordable housing will be determined following a viability assessment. Policy sets criteria based approach for meeting needs of Gypsies and Travellers. Protecting and Enhancing Barnet's Character to Create High Quality Places - sets out our priorities for high quality design and the importance of protecting and enhancing Barnet’s rich historical heritage and what makes Barnet distinctive in particular our quality environment of suburban family houses and gardens. Provides basis for more detailed design guidance on suburban streets whose residential character has changed or may change in future. Sets out guidance on tall buildings and protecting important local views. Promoting Barnet's Town Centres - sets out priorities for improving larger town centres, ensuring efficient use of land and buildings in such locations. It also provides protection for local neighbourhood centres and parades of shops because of their contribution to suburbs. Protecting and Enhancing Barnet's Open Spaces - ensures that access to open spaces is improved and that they become more attractive as places to a wider range of users. Highlights protection and enhancement of biodiversity. Promoting a Strong and Prosperous Barnet - sets out how we support an enterprising borough and local businesses (especially small to medium enterprises) and residents (particularly in developing skills) to access the regeneration opportunities in a changing borough. Providing Effective and Efficient Travel – sets out priorities of ensuring more efficient use of the road network including taking a comprehensive approach to tackling the school run. Highlights delivery of high quality transport systems in
29 regeneration areas and more environmentally friendly transport networks. Enabling Integrated Community Facilities and Uses – ensures community buildings including schools, libraries and meeting spaces are located where they are easily accessible and that new and existing provision is used more efficiently for joint service delivery Improving Health and Well Being – supports the plans of NHS Barnet and its successors to deliver modern primary care and the creation of healthier neighbourhoods. It also highlights that residential care homes are overprovided and should be remodelled to widen housing choice Making Barnet a Safer Place - ensures that streets, town centres and open spaces feel safer and that new development designs out crime. It also highlights partnership working with the Metropolitan Police on re-modelling its estate as a basis for an effective and responsive police service in Barnet Ensuring the Efficient Use of Natural Resources - sets out our priorities to reduce carbon emissions and use energy and water more efficiently as well as reduce the impact of noise and air pollution Dealing with our Waste - promotes waste minimisation and provides link to the North London Waste Plan Delivering the Core Strategy - sets out monitoring arrangements and provides context for the Infrastructure Delivery Plan and how the necessary infrastructure will be funded and delivered
10. LIST OF BACKGROUND PAPERS
10.1 Local Development Scheme, June 2007
10.2 Statement of Community Involvement, June 2007
10.3 Anyone wanting to inspect these papers should contact Nick Lynch on 0208 359 4211.
Legal: PD CFO: CM
30 Core Strategy Publication Stage
APPENDIX A
DRAFT
Local Development
Framework
Barnet’s Core Strategy
Publication Stage
September 2010
31 Core Strategy Publication Stage
List of policies
Policy CS 1 Barnet’s Place Shaping Strategy – The Three Strands Approach Policy CS 2 Brent Cross - Cricklewood Policy CS 3 Distribution of growth in meeting housing aspirations Policy CS 4 Providing quality homes and housing choice in Barnet Policy CS 5 Protecting and Enhancing Barnet’s character to create high quality places Policy CS 6 Promoting Barnet’s Town Centres Policy CS 7 Enhancing and Protecting Barnet’s open Spaces Policy CS 8 Promoting a strong and prosperous Barnet Policy CS 9 Providing effective and efficient travel Policy CS 10 Enabling integrated community facilities and uses Policy CS 11 Improving health and well-being in Barnet Policy CS 12 Making Barnet a safer place Policy CS 13 Ensuring the efficient use of natural resources Policy CS 14 Dealing with our waste Policy CS 15 Delivering the Core Strategy
32 Core Strategy Publication Stage
1 Introduction 1.1 What are the LDF and the Core Strategy? 1.1.1 The Local Development Framework (LDF) will eventually replace the Unitary Development Plan (UDP) (adopted May 2006). It will embody spatial planning – the practice of ‘place shaping’ to deliver positive social, economic and environmental outcomes and provide the overarching local policy framework for delivering sustainable development in Barnet. The LDF is described as a ‘folder’ of separate documents, the most important of which is the Core Strategy. This will contain the ‘vision’ for the LDF and the most fundamental, cross-cutting objectives and policies that the local authority and its partners will seek to deliver. 1.1.2 Barnet’s LDF will primarily consist of a suite of Development Plan Documents (DPD’s) and Supplementary Planning Documents (SPDs) the Core Strategy DPD which sets out the vision, objectives and related strategic policies; the Site Allocations DPD which identifies future sites for development the Development Management Policies DPD which sets out policy framework for decision making on planning applications the Mill Hill East Area Action Plan DPD (adopted January 2009) the Colindale Area Action Plan DPD (adopted March 2010) the emerging North London Waste Plan DPD (preferred options October 2009) a suite of ‘supplementary planning documents’ and ‘design guidance notes’ which provide more detailed guidance on determining planning applications and S106 requirements the Local Development Scheme for Barnet which sets out the timetable for the above documents the Statement of Community Involvement which sets out the principles on how Barnet will consult with the community the Annual Monitoring Report which assesses the performance of the LDF and identifies significant trends affecting Barnet 1.1.3 Government policy towards spatial planning is contained in Planning Policy Statement 1 – Delivering Sustainable Development and is further amplified in other Planning Policy Statements. We must take account of government guidance, for example, the requirement to meet local and regional housing needs. If a local interpretation of national planning policy is proposed, this must be justified. It is not necessary for the Core Strategy to repeat either national or London Plan policy. 1.1.4 The Coalition Government has set out its intention to shift power back into the hands of individuals, communities and councils and give local people a real share in growth. Critical to this new approach known as Localism will be the following : Giving local people real power to control the way in which places develop; Rewarding local communities so that development occurs where people see the benefits of such development Creating a strong and well considered local plan which is locally determined and which provides enough jobs and homes to meet the aspirations of the area.
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1.2 Purpose of Barnet’s Core Strategy 1.2.1 The Core Strategy will contribute to achieving the vision and objectives of Barnet’s Sustainable Community Strategy and will help our partners and other organisations to deliver relevant parts of their programmes. It will cover the physical aspects of location and land use traditionally covered by planning. It also addresses other factors that make places attractive and distinctive as well as sustainable and successful. It will help to shape the kind of place that Barnet will be in the future, balancing the needs of residents, businesses and future generations. 1.2.2 The Core Strategy should also accord with strategies and programmes which are the product of partnership working with members of Barnet's Local Strategic Partnership (Barnet College, CommUNITY Barnet, Metropolitan Police, Middlesex University and NHS Barnet). The Core Strategy should not conflict unnecessarily with the plans of neighbouring London boroughs and adjacent local authorities in Hertfordshire. 1.2.3 The Core Strategy must also be shown to be viable and flexible so as to allow for future changes in circumstances, including different policy frameworks or changes to the local, regional or national economy. This is important as the current economic climate presents significant challenges for place shaping. When investment in house building and job creation starts to flow again the Core Strategy will provide the framework and certainty that will attract capital investment to Barnet allowing us to guide and steer investment in ways that the community has signed up to. 1.2.4 In 2008 we asked for your views on the key issues and challenges facing Barnet for the next 15 years and the 80 proposed options for dealing with them. In response we received 23,000 comments from nearly 500 individual respondents. Our consideration of these views is set out in the Issues and Options Consultation Report. 1.2.5 In 2009 we asked for your views on our Direction of Travel which set out our preferred approach for managing the change that a growing Barnet faces over the next 15 years. The results of the consultation which are set out in the accompanying Consultation Report have helped to inform the development of our Core Strategy – Publication Stage. 1.2.6 Consultation on our Direction of Travel ran from November 2009 until January 2010 and included meetings and presentations to a wide variety of groups and stakeholders including Barnet’s Area Forums, Citizen’s Panel and Civic Network. In response we received over 2,100 comments from 334 individual respondents. As part of the consultation on this document we will publish a Consultation Report that gives detail of the consultation carried out, summarises the feedback from events and sets out our response. The results of the consultation helped to inform the development of our Core Strategy – Publication Stage. We have considered these and together with the background evidence, the sustainability appraisal (see below), the London Plan and the implications of its current review, the national planning framework provided by Planning Policy Statements/Guidance (both emerging and adopted) we have produced the Core Strategy – Publication Stage. 1.2.7 In order to look forward over fifteen years the Core Strategy has been produced using the most up to date and relevant information available. This is outlined in our published LDF evidence base (as listed at para 3.2.1). This evidence will be kept under review.
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1.3 Relationship of Barnet's Core Strategy to Area Action Plans for Colindale and Mill Hill East 1.3.1 The adopted London Plan has identified Colindale (201 hectares) as an Opportunity Area with a minimum target of 10,000 new homes and 500 new jobs delivered between 2001 and 2026. The draft revised London Plan (October 2009) has identified the wider Colindale / Burnt Oak Opportunity Area comprising 262 hectares of land in Barnet and Brent as having capacity for 2,000 jobs and a minimum housing target of 12,500 new homes between 2011 and 2031. Opportunity Areas have been identified in the adopted London Plan on the basis that they have significant capacity to accommodate new housing, commercial and other development linked to existing or potential improvements to public transport accessibility. The planning framework for Colindale is set out in the Area Action Plan adopted in March 2010. The AAP sets a target of 9,800 new homes by 2021 and a minimum of 1,000 jobs. 1.3.2 The adopted London Plan has also identified Mill Hill East (48 hectares) as an Area for Intensification with a minimum target of 3,500 new homes and 500 new jobs delivered between 2001 and 2026. The draft revised London Plan (October 2009) has identified Mill Hill East as having capacity for 1,800 jobs and a minimum housing target of 2,100 new homes between 2011 and 2031. The planning framework for Mill Hill East is set out in the Area Action Plan adopted in January 2009. The AAP sets a target of 2,000 new homes by 2024 and a minimum of 500 jobs. 1.3.3 In order to support early delivery of housing, we decided, in agreement with advice from the Greater London Authority (GLA) and Government Office for London, to prepare both the Colindale and Mill Hill East Area Action Plans ahead of this borough-wide Core Strategy. 1.3.4 In common with the Core Strategy the AAPs have been prepared in the full light of Barnet’s place shaping and corporate regeneration strategy, the ‘Three Strands Approach’. With the London Plan providing the regional spatial strategy for both the AAPs and the Core Strategy, both have been prepared within the same strategic and corporate policy context which will ensure conformity and consistency. 1.4 Relationship of Barnet's Core Strategy to Brent Cross - Cricklewood Development Framework 1.4.1 The adopted London Plan identifies Brent Cross Cricklewood (323 hectares) as an Opportunity Area with a minimum target of 20,000 jobs and 10,000 homes delivered between 2001 and 2026. The draft revised London Plan (October 2009) has identified Brent Cross Cricklewood as having capacity for 20,000 jobs and a minimum housing target of 10,000 new homes between 2011 and 2031. 1.4.2 In December 2005 together with the Mayor for London we adopted the Cricklewood, Brent Cross and West Hendon Regeneration Area Development Framework as Supplementary Planning Guidance. This Development Framework was produced in collaboration with the GLA, other stakeholders and the Brent Cross Cricklewood Development Partners. The Development Framework, which is highlighted in the London Plan, was produced to guide and inform design and delivery of development with the aim of achieving high quality comprehensive redevelopment of the area around a new sustainable mixed use town centre spanning the North Circular Road. 1.4.3 A partnership of key landowners and developers (Brent Cross - Cricklewood Development Partners) submitted in March 2008 an outline planning application for the comprehensive regeneration of the area. This has included extensive pre and post application consultation with the council and its partners, the GLA, Transport for
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London, the Highways Agency, the Environment Agency and other agencies and stakeholders including the local community. In November 2009 the council resolved to approve the outline application subject to completion of a Section 106 Agreement. 1.4.4 In March 2010 the Mayor of London stated that he was content for Barnet to determine the application, subject to the decision of the Secretary of State for Communities and Local Government. In June 2010 the Secretary of State informed the Council that he considered that as the application did not raise issues of more than local importance it would be appropriate for the local authority to determine it. 1.4.5 The Development Framework was prepared in parallel with the development of UDP policies on Brent Cross – Cricklewood as listed in Appendix A. This suite of UDP policies were saved by the Direction issued by the Secretary of State on May 13 2009. In view of the progress that has been made towards the implementation of the saved UDP policies on Brent Cross – Cricklewood we consider that it is inappropriate at this time to replace them. In order to provide a policy framework to secure the future comprehensive redevelopment of Brent Cross Cricklewood these ‘saved’ policies will continue to operate until it is considered appropriate to replace them. Monitoring indicators for the Brent Cross – Cricklewood policy set out in Appendix B will have regard to the progress made in the implementation and delivery of regeneration. These indicators will provide the basis for the review of the Core Strategy and may, if necessary or appropriate, lead to introduction of new DPD or SPD to further guide and control the comprehensive regeneration of Brent Cross – Cricklewood.
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2 The strategic context for Barnet 2.1 Barnet's Sustainable Community Strategy 2008 - 2018 - Barnet - a successful city-suburb 2.1.1 The Sustainable Community Strategy is the ‘umbrella strategy’ for all the plans and strategies of our key partners. The Local Strategic Partnership has revised the borough’s Sustainable Community Strategy (SCS) for the period 2008 to 2018. The Sustainable Community Strategy 2008 - 2018 sets out the strategic vision for Barnet as a place and provides the vehicle for considering and deciding how to address difficult cross-cutting issues such as maintaining the quality of life that makes the borough an attractive place to live. The four SCS themes inform the Core Strategy: growing successfully safer, stronger and cleaner Barnet investing in children and young people healthier Barnet (including older people) 2.1.2 Our spatial vision as a successful London suburb is highlighted in Barnet’s Sustainable Community Strategy and delivered through the Local Area Agreement (LAA). Table 1 sets out how the four themes and eighteen ambitions of the SCS are reflected in the Core Strategy – Publication Stage. 2.1.3 The Sustainable Community Strategy will be revised prior to the Examination in Public into the Core Strategy and references to it will be updated accordingly. 2.2 Barnet's Local Area Agreement 2.2.1 The Local Area Agreement (LAA) sets out improvement targets for the priorities of a local area. The Council and its public sector partners are under a duty to co-operate to agree LAA targets and have regard to them in exercising day to day functions. A total of 35 LAA targets have been selected from a set of 198 National Indicators to reflect Barnet's priorities of ‘driving success’ and ‘tackling disadvantage’. Barnet's LAA runs until March 2011. 2.2.2 From 2011/12 our ‘One Barnet’ approach will help local strategic partners to jointly formulate an action plan to make this happen and deliver a range of services that put the community first. 2.3 Three Strands Approach – Protection, Enhancement and Consolidated Growth 2.3.1 The Council and its partners have a prominent role in place-shaping and Barnet’s spatial development priorities are currently defined in the innovative Three Strands Approach to planning, development and regeneration. The purpose of the Core Strategy is to guide the growth identified in the borough to ensure that the qualities that make Barnet an attractive place to live are maintained and enhanced. Three Strands provides the spatial vision that underpins the Core Strategy and the Local Development Framework. The three strands are: Strand 1. Absolute protection of the Green Belt, Metropolitan Open Land and other valued open space from inappropriate development Strand 2. Enhancement and protection of Barnet’s suburbs, town centres and historic areas Strand 3. Consolidated growth in areas in need of renewal and investment.
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2.3.2 The Core Strategy sets out the major areas across the borough where development and regeneration is expected and the policies developed for them. 2.3.3 The Three Strands Approach allows for consolidated growth in housing and employment to be accommodated within Barnet's existing built up area. Where there is already planned or approved pipeline growth this is consolidated in areas in need of renewal and investment and where regeneration delivers significant and lasting economic and wider benefits to communities in Barnet. 2.3.4 Consolidated growth concentrates new development in the most accessible locations around public transport nodes and town centres where social and physical infrastructure is to be improved. This broad approach can meet the sustainable design principles for a compact city. It can make the best use of development sites, respect the local character of the built and green environment, provide for a mix of uses, and be safe, attractive and accessible to all users. It can also help adapt to and mitigate the effects of climate change. Most importantly, the green belt and the one-third of the borough that comprises green open spaces, is protected from future urbanisation and development to ensure a high quality suburb. 2.3.5 The Core Strategy is our key planning document. The accompanying Development Management Policies DPD complements the Core Strategy and provides more detailed policy considerations to Strand 1 and Strand 2. 2.4 Future Shape Programme 2.4.1 Barnet initiated its Future Shape Programme in 2008 in order to address a number of challenges that the council was facing including increasing customer demands, providing more services with less money, static public satisfaction and intractable problems such as disadvantage where public expenditure seemed to have little effect. These problems have been exacerbated by the global recession. 2.4.2 The basis of Future Shape is the following three key principles : One public sector approach – working together in a more joined up way with our public sector partners to deliver better services Relentless drive for efficiency – delivering more choice for better value New relationship with citizens – enabling residents to help one another to access the information and support they need 2.4.3 As part of Future Shape we are working with our public sector partners to share resources, including customer services and our property assets, and work together to achieve economies of scale. We are setting up a Customer Service Organisation to consolidate access services across the council. This will then be extended to other public sector partners. 2.4.4 In developing a new relationship with citizens we are encouraging self-help and behaviour change in order to release resources to help those most in need of public services. Through the creation of a common insight function we will develop a shared understanding across the council and partner organisations of what life is like for residents and businesses in Barnet and be able to identify the future challenges and our readiness to address them. 2.4.5 Barnet’s Infrastructure Delivery Plan (IDP) forms a key part of the LDF evidence base. It creates a valued dataset for successfully implementing a One Barnet approach. The dataset enables the Council and its partners to understand how we will shape the future of Barnet.
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2.5 Barnet's Corporate Plan 2.5.1 The Corporate Plan which is updated annually defines our priorities over a three year period and what we, through working with our partners, intend to achieve. It demonstrates our shared commitments with partners and identifies our top priority improvement initiatives. 2.5.2 The 2010/13 Corporate Plan contains three priorities: Better services with less money – our Future Shape programme is about delivering better outcomes more effectively, efficiently, equitably and economically to leave our customers feeling more satisfied Sharing opportunities and sharing responsibilities – some residents need more support than others and we will work with them to put them on the pathway to success Successful London suburb – enabling Barnet to grow sustainably by supporting prosperity whilst preserving and enhancing the physical environment. Supporting excellence in our schools and centres of learning. Working with the police and NHS Barnet to ensure that the borough remains a safe and healthy place to live, work and study 2.5.3 All three priorities in the Corporate Plan 2010 to 2013 are embedded within the Core Strategy: In providing better services with less money the Core Strategy addresses the need to : make more efficient use of our community assets in order to improve service delivery. Further integration of services such as libraries and children’s centres in 'hubs' is highlighted as the way forward; establish the Community Infrastructure Levy (CIL) as the replacement for S106 funding and set out the evidence on infrastructure requirements in an Infrastructure Delivery Plan which will form the basis for a CIL charging schedule In sharing opportunities and sharing responsibilities the Core Strategy addresses the need to : . provide increased housing choice in mixed communities including extra care housing and the need for lifetime homes in order to promote independence and to support vulnerable adults; . enable children and young people to develop skills and acquire the knowledge to lead successful adult lives through our programme for improvements to the schools estate, provision of children's centres and commissioning of youth services; . improve delivery of primary health care provision as well as targeting unhealthy lifestyles and tackling health inequalities, educating citizens to their own responsibilities In enabling Barnet to continue to be a successful London Suburb the Core Strategy addresses the need to : protect and enhance our natural environment through provision of new, improved, multi-functional and accessible green spaces that form part of a London-wide green grid; protect and enhance our built environment by ensuring that development respects local context and Barnet’s distinctive local character;
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ensure that a mix of compatible uses is provided in vibrant town centres including retail, housing and affordable and flexible workspace for business; make Barnet a safer place and through our programme of town centre frameworks turn our town centres into places which people want to visit and spend time and money in; support integration and cohesion between established communities and the new communities in the growth areas ; support the plans of NHS Barnet to deliver modern primary care 2.6 Other Barnet strategies and plans 2.6.1 The Core Strategy also reflects the spatial dimensions of a range of other plans and strategies which support Barnet’s wider priorities. These include the Children and Young People's Plan, Older Adults Strategy, Housing Strategy, Health and Well- being Commissioning Framework and the Safer Communities Strategy. These policies, programmes and strategies have all been considered as important markers in the development of the Core Strategy and form part of the evidence base. 2.7 Barnet - voice of the suburbs 2.7.1 Barnet has been a key player in researching and developing national, regional and local policy on successful city-suburbs and their key role in the wider city economy. Barnet has led the thinking on a range of suburban issues in London. Working with the Leadership Centre for Local Government the “Successful Suburbs” report was published in May 2007. This highlights the strengths of the suburbs, including the relatively high quality of the suburban environment, high skills level and the generally high quality of life. 2.7.2 Barnet has also contributed to the London Council’s report “Successful Suburbs – the Case for Investment in London’s Suburban Communities” published in March 2009. This highlighted that the case for investment in our suburbs is not a case for the movement of existing investment from inner priority areas to outer London; it is about unlocking the potential of suburbs to contribute more to the performance of the capital as a whole. The Successful Suburbs Report identified unlocking the potential of the following for investment: Revitalising economic activity in the suburbs - particularly the focus on improving town centres Investing in infrastructure to meet a changing and growing population - particularly the investment in community and health facilities and in transport Reducing the suburb’s carbon footprint through, in particular, focussing on behaviour change These priorities are reflected throughout our Core Strategy. 2.8 London Plan 2.8.1 The adopted London Plan (Consolidated with Alterations since 2004), published in February 2008, provides the London-wide context for borough planning policies. This version is currently the statutory development plan for the borough and the starting point for decisions on planning applications. The Core Strategy must have cognisance of this strategic background and be in general conformity with it as well as being consistent with national planning guidance. 2.8.2 London elected a new Mayor in May 2008. In order to set a clear spatial framework which reflects his policies and priorities the Mayor instigated a full review of the
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London Plan. In October 2009 the Mayor published the draft revised London Plan and set out a vision for the sustainable development of the city up to 2031. The Mayor’s vision is that London should exceI among global cities – expanding opportunities for all its people and enterprises, achieving the highest environmental standards and quality of life and leading the world in its approach to tackling the urban challenges of the 21st century, particularly that of climate change. 2.8.3 The Mayor’s vision is supported by the following six detailed objectives which ensure London is A city that meets the challenges of economic and population growth An internationally competitive and successful city A city of diverse, strong, secure and accessible neighbourhoods A city that delights the senses A city that becomes a world leader in improving the environment A city where it is easy, safe and convenient for everyone to access jobs, opportunities and facilities 2.8.4 The review of the London Plan is expected to be completed by the Mayor in 2011. Our Core Strategy will be adopted before the review is completed. It is therefore necessary for this document to reflect the policy approach of the existing adopted London Plan while signposting the changes in direction to the strategic policy as set out in the draft revised London Plan.. 2.8.5 In 2008 the Mayor established the Outer London Commission to examine the extent to which the Outer London boroughs can contribute to the economic success of London as a whole, identify the factors which are holding it back from making that contribution and make recommendations to be taken forward in the draft revised London Plan and the Mayor’s other Strategies on Economic Development and Transport. The Commission's Interim Conclusions were published in July 2009 and were considered by the Mayor in the draft revised London Plan published in October 2009. 2.8.6 Outer London is where 60 per cent of Londoners live and where over 40 per cent of London’s jobs are located. The draft revised London Plan seeks a more dispersed and polycentric pattern of development in London focused on a network of town centres. Such dispersal can help address the pressures on the transport network into central London created by the imbalance between where people live and where they work. The draft revised London Plan sets out a vision and strategy for Outer London recognising the diversity of the area and its key contribution to the quality of life in London as a whole. A high quality of life is essential to London’s future success. Providing places where people will want to work and live, will be important to attracting and retaining the kind of economic sectors which may lift growth in outer London. 2.9 North West London – Luton Corridor 2.9.1 Barnet does not sit in isolation. In the production of this Core Strategy we have taken account of our relationship with neighbouring authorities in London and Hertfordshire as well as those areas with whom we share transport links. The spatial context for Barnet is provided in Map 1. 2.9.2 The concept of the North West London to Luton Corridor and links between Brent Cross / Wembley / Kings Cross and out to Bedfordshire provides a basis for coordinated working between the relevant local authorities and key agencies including Transport for London. The London element of the corridor is currently
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projected to deliver approximately 100,000 new jobs to 2026 (London – Luton Corridor Prospectus, January 2009). Improving transport links along the corridor will be vital to facilitating this anticipated growth in employment. 2.10 Sustainability Appraisal 2.10.1 We need to carry out a sustainability appraisal of the Core Strategy and other relevant Local Development Framework documents. This promotes sustainable strategies and policies through an assessment of their environmental, social and economic impacts. It helps us to identify and minimise any potential harmful impacts of our strategy and policies and to maximise the beneficial impacts. 2.10.2 As the first stage of the sustainability appraisal of the Core Strategy we prepared a Scoping Report, which looked at the baseline information and relevant plans, policies and programmes. This was sent to statutory consultees for comment in line with the Regulations. Following this we have carried out an appraisal of the options considered in Core Strategy Issues and Options and the Direction of Travel. This has been followed by a final appraisal of the Core Strategy. 2.10.3 We also carried out a screening assessment of the Core Strategy to ascertain its impact on sites of European importance for habitats or species. The screening assessment found that no significant effects were likely. Therefore we have not carried out a Task Two (Appropriate Assessment) of the Habitats Regulations Appropriate Assessment process. 2.11 Equalities Impact Assessment 2.11.1 We have also undertaken an Equalities Impact Assessment of the Core Strategy in order to highlight the likely impact on identified key equalities groups (in terms of race, gender, disability, age, sexual orientation and faith) who are considered to be at particular risk of discrimination and inequality of opportunity. The Equalities Impact Assessment has found that the Core Strategy does not create any adverse impacts for any of the identified groups. 2.12 Monitoring 2.12.1 The Core Strategy is not a static document. Monitoring mechanisms make it a living document that is capable of being changed in part or in full. We will monitor the effectiveness of the Core Strategy in delivering its objectives by assessing its performance against a series of indicators. A number of indicators will be included for each policy in the Core Strategy. These are set out in Appendix B. Each year we publish an Annual Monitoring Report. This will: assess the performance of the Core Strategy and other LDF documents following their adoption identify the need to reassess or review any policies or approaches make sure the context and assumptions behind our approach are still relevant; and identify trends in the wider social, economic and environmental issues facing Barnet.
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Map 1 – Spatial context for Barnet
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3 Preparing Barnet's Core Strategy 3.1 Consultation 3.1.1 The process for preparing the Core Strategy, which includes three rounds of public consultation, is set out in the table below.
Evidence gathering of background information and consultation on issues and options for the future of Barnet
Developing our preferred approach which sets out our direction of travel and consultation on it, alongside the sustainability appraisal
Preparing the Core Strategy document for submission to the government and further consultation on this (Publication Stage)
3.1.2 The Publication Stage of the Core Strategy has been developed on the basis of: What you told us – the response to consultation on Barnet’s Core Strategy Direction of Travel. This is set out in the Core Strategy (Direction of Travel) Consultation Report What the evidence shows – the picture presented by the studies we have commissioned or evidence we have collected What is happening at the national and regional level – our approach must be consistent with national planning guidance and the London Plan, unless we have strong evidence that a different approach is more appropriate What is happening with Barnet’s Sustainable Community Strategy and other boroughwide strategies produced by the Council and its partners such as the Barnet Children and Young People’s Plan, Older Adult’s Strategy, Housing Strategy, Health and Well-being Commissioning Framework and the Safer Communities Strategy 3.2 Evidence gathering – What makes Barnet distinctive? 3.2.1 It is important that our strategy for the future development of the borough is based on an understanding of the characteristics that make Barnet what it is, and a knowledge of how it is likely to change. We have been collecting information from many sources to help us identify the key issues and opportunities for the future of the borough and provide a strong basis for our planning strategy and policies. (This information is usually known as the “evidence base”).
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3.2.2 Barnet's published evidence base for the Core Strategy includes, but is not limited to, the following – Demographic information including Census data and GLA projections the Sustainability Appraisal Barnet’s Annual Monitoring Reports Barnet Town Centres Floorspace Needs Assessment and 2010 Update Town Centre Health Checks Barnet Employment Land Review Joint Strategic Needs Assessment for Health and Social Care Crime, Disorder and Substance Misuse Strategic Assessment Barnet Open Spaces, Sport and Recreational Facilities Needs Assessment North London Strategic Flood Risk Assessment London Strategic Housing Land Availability Assessment London Regional Landscape Framework BRE Housing Stock Model Update for Barnet 2009 Barnet’s Housing Needs Study 2006 Barnet's Characterisation Study Barnet’s Affordable Housing Viability Assessment 3.2.3 The following components of the evidence base are in production / nearing completion: Barnet's Infrastructure Delivery Plan Decentralised Energy Planning Initiative North London Strategic Housing Market Assessment North London Sub Regional Transport Study Barnet’s Playing Pitch Assessment Barnet’s Tall Buildings Study 3.2.4 Subject to prioritisation by the GLA as part of their management of the Drain London project to map, model and manage surface water flooding across London we will also produce the following: Surface Water Management Plan 3.3 Consideration of National and Regional Policy 3.3.1 National planning policy is set out in a suite of Planning Policy Statements (PPS) and Planning Policy Guidance notes (PPG). The Core Strategy must be consistent with national planning policy unless we have strong evidence that an alternative approach is more appropriate in Barnet. 3.3.2 The Mayor of London’s London Plan sets a social, economic and environmental framework for the future development of the city, providing the London-wide context for borough planning policies. Our LDF documents must be in general conformity with the London Plan. 3.4 Other Barnet plans and strategies 3.4.1 As highlighted earlier the Core Strategy needs to take into account other plans and strategies that influence the future of Barnet. It contributes to achieving the vision in the Sustainable Community Strategy and other strategies of the Council and its
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main partners. The Core Strategy aims to translate the vision of the Sustainable Community Strategy into a set of priorities and policies to shape the way we want a future Barnet to be and create a framework for delivery. 3.4.2 The Mayor of London’s London Plan sets a social, economic and environmental framework for the future development of the city, providing the London-wide context for borough planning policies. Our LDF documents must be in general conformity with the London Plan. 3.5 How is Barnet’s Core Strategy structured?
Introduction Introduction to Barnet’s LDF
Policy context
What makes Barnet distinctive? Barnet – the place Challenges facing the borough
The Place Our spatial vision
Shaping Strategy The objectives
The policies
Delivery and monitoring
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4 Barnet - the place 4.1 Barnet’s character 4.1.1 Barnet comprises a variety of townscapes, many attractive and reflecting the long history of settlements, influenced by topography and the pattern of transport routes. Large parts of the borough are designated as Conservation Areas in order to reflect their special character and value. Much of the borough has been developed as low density suburbs with the average density of 36 persons per hectare, the 8th lowest in London. 4.1.2 Barnet has a rich architectural heritage which includes the only Historic Battlefield (Battle of Barnet – 1471) in London. Nearly forty sites of archaeological importance containing prehistoric, Roman and medieval remains have been identified across the borough. Barnet contains over 1,300 Listed Buildings, two Scheduled Ancient Monuments at Brockley Hill in Edgware and Manor House in Finchley, three registered Historic Parks and Gardens at St Marylebone Cemetery, Avenue House Gardens and Golders Green Crematorium. 4.1.3 To appreciate Barnet’s character it is necessary to understand how it has grown in the last 150 years from a population of 6,400 living in villages in the mid 19th century to one of 345,800 residents living in a successful London suburb in 2010. One of the key features of Barnet is its topography, a rolling landscape of valleys and ridges cut out by tributaries of the Thames. The north of the borough forms the high points of the Thames Basin and three ridgelines run broadly east to west across the top of the borough through Chipping Barnet, Totteridge and Mill Hill. A fourth ridgeline runs north-south through Whetstone down towards Hampstead Heath, the route of the Great North Road. 4.1.4 In the first half of the twentieth century development spread from established commuter settlements such as Chipping Barnet, New Barnet, Friern Barnet and Finchley with suburban housing transforming the landscapes of Edgware and Hendon as well as the south of the borough. Boundaries between settlements became blurred and a continuous residential sprawl from Chipping Barnet to the south of the Borough became evident. After 1945 settlements expanded more gradually based on increased car ownership and expansion of the bus and trolleybus network. The introduction of the Green Belt in 1947 halted development around New Barnet and Chipping Barnet as well as restricting growth at Mill Hill and Totteridge. This set the scene for the borough in the present day. 4.1.5 Reflecting the level of post war growth the population reached a post war peak of 319,000 in 1951 and declined in the second half of the twentieth century to 290,000 in 1981. Only recently has Barnet’s population exceeded the levels of 1951. 4.2 Barnet’s places 4.2.1 Barnet is the fourth largest London borough by area (86.7 sq km) and home to a growing and diverse population. About 38% of the borough is undeveloped, 28% is designated green belt and 8% is metropolitan open land (which includes around 200 parks, allotments, playing fields and agricultural land). 4.2.2 The rest of the borough is made up of suburban areas with a population density of 38.63 people per hectare. This is lower than for London as a whole (48.12 people per hectare but nearly ten times the figure for England (3.94 people per hectare).
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4.2.3 We expect significant growth in Barnet’s population and economy over the next twenty years. Work is well underway on planning of the Opportunity Areas (Brent Cross - Cricklewood and Colindale) and Area of Intensification (Mill Hill East) identified in the London Plan. The development of these areas is expected to deliver 17,000 new homes by 2026. 4.3 Barnet’s people 4.3.1 According to the ONS mid year estimate for 2008 Barnet has a population of 338,100. According to ONS projections Barnet is now the most populous borough in London with an estimated population of 345,800 residents in 2010. Barnet is the tenth largest single tier authority in England and Wales. Based on GLA figures which factor in the house building growth Barnet’s population is projected to reach 384,600 by 2026, an increase of 14% on present levels. 4.3.2 It is estimated that 7.5% of the population are new to Barnet each year through birth or in-migration. Natural increase (the difference between the number of births and deaths) is the most significant contributor to Barnet’s growth. According to ONS data
Barnet's hybrid solution to population projections
400,000
390,000
380,000
370,000
360,000
350,000 GLA 2008 Round 340,000 Projections (2009)
Total population Total 330,000 ONS SNPP (2008-based, 320,000 published 2010) ONS MYE 310,000 (2009) 300,000 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
for 2009 there were 5,300 live births in Barnet. Only Newham, Ealing and Wandsworth have a higher level of births. With 2,400 deaths in 2009 this amounts to an NI of 2,900. 4.3.3 People are also leaving Barnet. The North London Strategic Housing Needs Assessment estimates that 475 households per annum move out mainly towards Hertfordshire. 4.3.4 Barnet’s population will change our existing communities, attracting a much younger and diverse population. Over the next ten years there will be a marked increase in the number of children aged between 5-14 years old and number of people over the age of 65. 4.3.5 In 2010, 13.8 per cent of the local population is estimated to be over 65. By 2015, that cohort is expected to grow by 5,400 individuals –double the average rate of growth for the borough (11.3% compared to an average of 5.7%). The increase in the proportion
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of the population over 90 is even more significant, with that cohort projected to grow by a third between 2010 and 2015. Significant growth is also expected within the 45- 59 year old age group. 4.3.6 However, growth is not limited to the older residents – the rising birth rate of recent years also means that there is above average growth in Barnet’s younger population (most significantly ages five to nine), as the babies of the end of the last decade gradually work their way through the age bands. Barnet has the second largest population of children and young people in London. This age group is more diverse than the adult population. About 40% of primary school pupils in the borough and 37% of secondary school pupils have English as a second language. 4.3.7 Despite this boom in the youngest residents, the borough is expected to experience a general decline in older children and young adults (15 to 24 year olds). After a spike in the 25 to 29 year old cohort there is another relative decline in the 35 to 44 year old group. This decline is likely to be a consequence of young professionals leaving London having gained the experience they wanted and/or being priced out of the borough’s housing market as they think about starting a family. 4.3.8 Nearly a third of Barnet’s population belongs to a black or minority ethnic group. Projections are that this will grow to 36% by 2018. Barnet has the largest Jewish community in the UK and one of the largest populations of Chinese. Around 170 first languages are spoken in Barnet’s schools. After English the next most used languages are Gujarati, Farsi and Somali. 4.3.9 Barnet has a historical legacy of new communities being welcomed and feeling involved. The Government’s National Indicator 1 measures the proportion of people who believe people from different backgrounds get on well together in their local area. Barnet is the place with the greatest diversity of communities that has scored highly on this indicator. Nearly 84% of residents agreed in the 2008 Place Survey that their local area is a place where people from different backgrounds get on well. 4.3.10 The 2001 Census records that nearly 73% of Barnet’s population described their health as good. Residents are healthier overall than their London counterparts as measured by mental illness, death rates from major causes, sickness benefit claimants and alcohol related hospital admissions. The Standardised Mortality Rate (SMR) for Barnet is 88, the 8th lowest rate in London. Out of Barnet’s neighbouring authorities only Harrow has a lower SMR. 4.3.11 Profiling information from Mosaic, which classifies people into 11 socio-economic groups and within these groups into 61 different types, reveals two significant groups in Barnet – ‘career professionals living in sought after locations’ and ‘educated, young single people living in areas of transient populations’. According to Mosaic these groups make up 56% of Barnet households.1 4.4 Deprivation in Barnet 4.4.1 Whilst Barnet is a generally prosperous borough there is significant deprivation in certain areas with a wide gap between the richest and the poorest. According to CACI Paycheck data for 2008 10.5% of Barnet households have incomes in excess of £75,000 a year while 11.6% have incomes less than £15,000. Household incomes vary between the north and south of the borough with the average income in the wealthiest ward (Garden Suburb) 60% higher than that of the poorest.
1 Experian, Mosaic Public Sector 2010
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4.4.2 Barnet is the 128th most deprived authority out of 354 English districts. It has six areas within the top 10% most deprived nationally2. Overall deprivation is substantially higher in Burnt Oak and Colindale than the rest of the borough. One area in Colindale has over a fifth of its working age population in employment deprivation (i.e. involuntarily excluded from work). 4.4.3 Although the average life expectancy of residents is almost 2 years above the English average, though it is about a year below this in the most deprived wards. 4.5 A safer Barnet 4.5.1 Our annual resident’s survey 2008 reveals that in most wards residents feel safe in the day. However about 1 in 5 respondents say that they feel unsafe in the evening. Greater fears about safety are expressed in Edgware, Burnt Oak, Colindale, West Hendon and Woodhouse. An exception is Underhill ward where 1 in 2 respondents stated they felt fairly or very unsafe in the evening. 4.6 Barnet’s economy 4.6.1 Barnet has the most town centres in London. There are 29 major, district and local town centres which vary in size and purpose as well as performance. 4.6.2 The town centres provide a total area of retail floorspace that is only exceeded by Westminster and Kensington and Chelsea and is the greatest of any outer London borough. Brent Cross is London’s only self contained regional shopping centre. Proposals for Brent Cross – Cricklewood as set out in the Development Framework will transform it into a sustainable new town centre as part of the wider regeneration of the area complementing the role of other town centres nearby. 4.6.3 Barnet’s resident population is well qualified. Our schools perform well with 56% of pupils attaining 5 A to C GCSEs including English and Maths. Around 35% of the adult population having a university degree or equivalent – 4% higher than the London average and 15% higher than the England average. Studies have identified a need for more vocational and intermediate courses to ensure residents and businesses can take advantage of future growth. Despite being one of the most well educated boroughs in London there is a significant number of residents with no qualifications and a persistent number of 16 to 19 year NEETs (Not in Education, Employment or Training). 4.6.4 Barnet benefits from a strong higher and further education sector which provides jobs as well as education, training and business support for residents and employers. Barnet has proportionately fewer manufacturing jobs than London or Great Britain as a whole, but rather more in distribution, hotels & restaurants, public administration, education & health. 4.6.5 Many of the people who work in Barnet also live here. Nearly 75% of the 112,000 jobs in the borough are held by Barnet residents, one of the highest figures in London. The majority of working residents are employed in the public sector or financial services. 4.6.6 Barnet is not a dormitory suburb. The borough has a large number of VAT-registered businesses, the third highest in London, and the fifth highest in Great Britain. Up to 44% of local businesses are engaged in property and business services and make an important contribution to the life of our town centres.
2 Index of Multiple Deprivation, 2007
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4.7 Homes in Barnet 4.7.1 At present there are 140,000 households in Barnet and this is expected to increase to 167,000 by 2026. Household composition is changing. The trend in London is that while the number of married households is declining, the number of cohabiting, lone- parent and multiple person households is increasing. The rise of the single person household and its impact on reducing average household size can obscure the complex housing picture. 4.7.2 Barnet is typical of many outer London suburbs in having a high proportion of owner occupied housing, a strong private rented sector, and a smaller supply of social rented accommodation. Barnet’s housing stock of 133,000 units, which is predominantly an older stock of over 50 years in age, is mainly in a good condition. 4.7.3 About 62% of the stock comprises houses (terraced, semi-detached or detached) and 38% are flats and maisonettes. Almost 60% have 3 or more bedrooms, and only a very small percentage contain only one bedroom. Housing tenure in Barnet is similar to other outer London boroughs, with 72% in owner occupation, but unlike the rest of London more housing is rented from the private sector (16%) than the social rented sector (13%). 4.7.4 Barnet's private rented sector is dominated by 1 and 2 bed units. This would suggest that this is predominantly flatted development. The owner occupied stock is dominated by 3 and 4+ bed units which are typically houses. 4.7.5 The 2006 Housing Needs Survey estimated that 5.4% of all households in Barnet are overcrowded while 32.7% under-occupy their dwelling. 4.7.6 There are several affordability indexes that compare earnings of the people who work in an area with the price of local housing. The larger the ratio of prices to earnings then the more expensive the housing is for the local workforce. According to these indexes Barnet experiences high financial barriers to owner occupation compared with the rest of the country. In 2007 Barnet had the 28th highest affordability ratio of England’s 355 districts. 4.7.7 Regenerating our largest and most deprived housing estates forms a central part of Barnet's future. Over 3,000 units will be replaced at Dollis Valley, Grahame Park, Stonegrove - Spur Road and West Hendon. 4.8 Barnet’s environment 4.8.1 Barnet is rich in green spaces and biodiversity containing 68 Sites of Importance for Nature Conservation, including seven of which are local nature reserves. The Brent Reservoir, (also known as the Welsh Harp) which lies partly in the borough, is a Site of Special Scientific Interest. There are three landscape character types in Barnet - the Barnet Plateau, Finchley Ridge and Hampstead Ridge each with their own natural signatures. 4.8.2 On average residents produce around 431 kg of waste each per year. The amount of household waste recycled has increased from 9% to 31% from 2000 to 2008. This has helped to decrease the overall level of municipal waste going to landfill from 72% in 2000 to 53% in 2008.
4.8.3 Domestic CO2 emissions in Barnet are near the national average. Reflecting its older, more than 50 year old housing stock, Barnet has the fourth highest per capita domestic emissions in London.
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4.9 Barnet’s transport 4.9.1 Barnet is characterised by high car ownership (73% of households have access to a car3) but also has high public transport usage, 62% of Barnet residents use public transport at least once a week.4 Many of Barnet’s residents travel to work in central London and use the radial underground services of the Northern and Piccadilly Lines. However orbital routes are less well served by public transport and therefore people travelling within the borough or to adjoining areas often have little choice but to rely on private transport. 4.9.2 According to the 2001 Census about 146,000 residents are employed either full or part time. Of these 59,600 work in the borough (of whom 39% drive to work) with 86,300 working outside the borough (of whom 42% drive). A further 47,300 people commute into the borough (66% of whom drive). 4.10 Barnet’s setting 4.10.1 Barnet does not sit in isolation. In the production of this Core Strategy we have taken account of the spatial variations to change across the borough and our relationships with neighbouring authorities in London and Hertfordshire as well as those areas with whom we share transport links. 4.10.2 The western part of the borough forms part of the North-West London Luton Corridor. The Corridor threads through Barnet and its neighbouring boroughs of Brent, Camden and Harrow and extends along the route of M1 / Thameslink up to Luton. The Corridor in Barnet is rapidly changing with pockets of deprivation undergoing renewal and regeneration. Growth within the Corridor is focused on a series of major urban regeneration projects including Kings Cross and Wembley as well as Brent Cross – Cricklewood. Thousands of new homes are also being provided at Colindale, Harrow town centre and West Hampstead. 4.10.3 The eastern part of Barnet has a generally stable population. It adjoins Enfield and housing growth is planned around the North Circular Road and in New Southgate through renewal, refurbishment and redevelopment. 4.10.4 The northern part of Barnet is predominantly Green Belt which extends into Hertfordshire has a generally stable population. The Watling Chase Community Forest covers the northern part of Barnet. 4.10.5 The southern part of Barnet especially in areas such as East Finchley is becoming more ‘metropolitan’. 4.11 Barnet and the arts, culture and creative industry 4.11.1 Barnet is home to a rich diversity of groups involved in arts, music, theatre, literature, visual arts and film. Demands for performance and exhibition space are therefore high. Support and publicity for over 100 groups engaged in the arts is provided by an independent charity – the Barnet Borough Arts Council. 4.11.2 Barnet is home to the Phoenix in East Finchley. Dating back to 1910 it is one of the oldest cinemas in Britain as well as one of the leading independents in London. Barnet is also home to one of the most modern arts venues in London. The artsdepot in North Finchley opened in 2004 and remains the only professional arts venue in Barnet providing a variety of spaces for drama, dance and visual arts.
3 LTDS, 2006-09 4 Barnet Annual Residents Survey, 2007
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4.11.3 GLA Economics have conducted a comprehensive survey of creative industries in London. In 2010 they published data5 on creative employment and businesses by local authority area in London. Barnet has one of the highest concentrations of creative industry firms in Outer London. The survey identified 2,135 creative industry firms in Barnet in 2008. Over two thirds of these firms are engaged in creative industries such as leisure software and music and performance. 4.11.4 According to work by Four Greens in 2005 creative industries in Barnet are more likely to be business oriented and focus on advertising and publishing. Barnet’s creative businesses are more likely to be based in the south and east of the borough.
5 GLA Economics – London’s Creative Workforce – 2009 Update – Working Paper 40
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5 The challenges we face 5.1.1 Barnet is a vibrant, diverse and successful London suburb Barnet residents live healthier and longer lives than average and Barnet is a place where people from different backgrounds get on well together. People choose to live here because of our: clean and green environment with access to Green Belt and quality open spaces excellent schools low levels of crime good radial transport links high quality housing and public spaces 5.1.2 In a period of significant change for the borough, we are committed to maintaining and building on these assets to ensure that Barnet remains a desirable place to live. 5.1.3 Public services are set to feel the long term impacts of the global recession with cuts in funding from Government expected to continue through the first half of this Core Strategy’s life-time. In order to provide services that increase satisfaction and provide better outcomes for residents at less cost the council and its partners has developed the Future Shape Programme. This new relationship is about simplifying public service systems and processes, making them more open to citizen influence so that we are certain that we are utilising resources in the best possible way. It is also about encouraging self-help and behaviour change and freeing up capacity so that we can focus on those residents with the most complex and multiple needs; working together to solve the most difficult issues Barnet is facing. 5.1.4 We also recognise that there are some people in Barnet who experience a disproportionately high level of deprivation, and do not have the opportunity to share in the borough’s success. We have six super output areas within the ten per cent most deprived nationally. To establish our status as a truly successful London suburb we must ensure that all our residents benefit from our success. Most of the public spending on disadvantaged members of the community is focussed on addressing the problems of disadvantage rather than addressing what causes them in the first place. We are reducing multiple disadvantage by working together with Barnet citizens and our key partners to analyse the underlying causes so that we can create effective responses to increase general levels of prosperity for all. 5.1.5 The popularity of Barnet as a place means we continue to grow. Over the next two decades we will build 28,000 new homes and regenerate our areas of concentrated deprivation. The growth in the borough will change our existing communities, attracting a much younger and ethnically diverse population. Over the next 10 years there will be a marked increase in the number of children aged between 5-14 years old and number of people over 65. The age groups that will grow are those that are more likely to use public services and resources more frequently. This will place increased pressure on school places and services for the frail elderly. 5.1.6 In 20 years our population is likely to exceed 384,000. With this growth will come new business, retail and leisure facilities and significant employment opportunities. 5.1.7 Managing the growth in the borough will be a major challenge. Alongside this growth we must maintain and build on those qualities that make Barnet such a desirable place to live and work, whilst also helping to create new, socially integrated communities. Our Three Strands Approach to planning, “Protect, Enhance and
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Consolidated Growth” recognises that sustainable development in Barnet needs different approaches. 5.1.8 Through the Future Shape Programme we are developing a common insight function in order to develop a finer understanding of what life is like for residents and businesses in Barnet. It will identify the future challenges for people, communities and the place as a whole. The infrastructure to support growth including schools, further and higher education establishments, healthcare, community facilities, parks, utilities and improvements to transport connectivity needs to be developed on a collective understanding of how the needs of our residents are changing. 5.1.9 The global recession and its aftermath is placing pressure on many of Barnet’s residents, communities and businesses. This requires an agile and flexible response built on a solid understanding of their needs and economic trends. We need to support residents and businesses to enable them to deal with the changes they will face. 5.1.10 In order to protect the suburban distinctiveness of the borough we have to make more efficient use of previously developed land. We are faced with an imbalanced housing stock with one household in three considered to under-occupy, while the demands for increased housing choice, affordable housing, and family homes to meet aspirations of home ownership are increasing. Providing a greater range of attractive and locally accessible housing choices for older people could help free up suburban family homes that attract young families. 5.1.11 The varying performance of our 20 town centres creates a challenge for the Core Strategy. Whilst recognising there is no one size fits all solution a clearer steer is required on their role and function in a changing borough. 5.1.12 We need to understand what minimising the impact on natural resources means in Barnet as there is a clear tension between the benefits of an economically vibrant and developing community and the environmental impact of the activities of that community. We must engage with residents and businesses who are environmentally concerned and work together as role models to increase awareness, facilitate behaviour change and demonstrate the longer term economic benefits of good environmental practice. 5.1.13 On agendas such as healthy lifestyles and efficient use of natural resources, solutions must lie in finding new ways of doing things through working with citizens and creating the conditions in which together we can achieve the outcomes that residents tell us they want. 5.1.14 Each of these challenges has an impact or effect on the spatial development of the borough and on one or more of the Three Strands: Protect, Enhance, Grow. This has contributed to the development of the vision and objectives of this Core Strategy.
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6 Vision and objectives 6.1.1 In 2008, the Local Strategic Partnership agreed Barnet’s Sustainable Community Strategy, which sets out a shared vision and strategy for the borough. We are using the vision from the Community Strategy as the overarching vision for Barnet’s Local Development Framework Core Strategy and other related policy documents to ensure Barnet is a successful city suburb as the borough changes, develops and grows. Our vision is : ‘It is 2026. Barnet is known nationally and internationally as a successful London suburb. Its new, inclusive and thriving neighbourhoods have made it one of the largest boroughs in London. Residents enjoy access to large green open spaces, clean streets, an excellent transport network and affordable, decent homes. It is a place where both young and old can enjoy fulfilling and healthy lives. There is consistently high educational attainment and new local employment opportunities. Crime and the fear of crime remain low and communities – established and recently formed – take pride in their area. Public services are of a consistently high standard and meet the needs of the diverse population they serve. Barnet is a successful London suburb where people want to live and enjoy a high quality of life. We aim to continue to promote this vision by building on the known and relevant success factors. However, a truly successful suburb will be one where all residents have the opportunity to share in wider success. We therefore also need to tackle disadvantage by securing an improved quality of life for those experiencing multiple disadvantage’. 6.1.2 Four themes (and sub ambitions) were identified in the Sustainable Community Strategy to achieve this vision: growing successfully safer, stronger and cleaner Barnet investing in children and young people healthier Barnet (including older people) The linkage between these themes, the underlying ambitions and the Core Strategy policy framework are set out in Table 1. 6.1.3 The Sustainable Community Strategy will be revised prior to the Examination in Public into the Core Strategy and references to it will be updated accordingly. 6.2 Barnet’s core objectives 6.2.1 We have developed a series of core objectives in order to deliver the LDF vision. These are: To manage housing growth to meet housing aspirations - to promote the development of the major regeneration and development areas, priority estates and town centres in order to provide in the range of 20,000 new homes (contributing to a borough total of 28,000 new homes) by 2026 to meet local and regional housing needs; - to regenerate the priority housing estates at Dollis Valley, Grahame Park, Granville Road, Stonegrove - Spur Road and West Hendon to replace 3,000
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existing homes with a greater range of accommodation that provides access to affordable and decent new homes; - to provide a range of housing, including family and extra care accommodation, that enables choice between types and tenures, as well as over lifetimes and within neighbourhoods. To meet social infrastructure needs - to ensure provision for community needs arising from housing growth including education, health, policing, social care and integrated community facilities; - to provide new and improved primary and secondary schools through capital investment programmes - to support the improvement and expansion of further and higher education to meet needs of a growing population and economy; and - to provide community facilities to meet the changing needs of Barnet's diverse communities. To promote Barnet as a place of economic growth and prosperity - to support the continued vitality and viability of 20 town centres, focusing commercial investment in our priority centres of Chipping Barnet, Edgware, Finchley Church End, and North Finchley; - to ensure that the regeneration of Brent Cross - Cricklewood creates a new metropolitan town centre and commercial district that serves the sub-region and beyond; - to ensure that in the borough's main commercial areas including designated employment locations and town centres there are sufficient opportunities available to help business grow and prosper; and - to ensure that residents are equipped with the skills to access the 21,0006 jobs that the regeneration of the major growth areas will deliver by 2025/26. To provide effective and efficient travel - to ensure more efficient use of the road network including taking a comprehensive approach to tackling the school run; - to deliver high quality transport systems in regeneration areas and provide more environmentally friendly transport networks To promote strong and cohesive communities - to enable communities to become confident and cohesive by providing facilities through which residents can play a part, diversity is valued and local pride is promoted; - to create the conditions for a safer and more secure Barnet by designing out crime and reducing anti-social behaviour, particularly in known ‘hotspots’. To promote healthy living and well-being - to secure a healthier Barnet by addressing the factors underpinning poor health and well-being and educating citizens as to their own responsibilities for health.
6 Based on existing London Plan
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- to provide opportunities for vulnerable people to live more independent lives by planning for appropriate facilities and support services that can meet their future needs. To protect and enhance the suburbs - to respect and enrich Barnet’s distinctive built heritage by protecting the historic environment and enhancing the high quality suburban character of townscapes and conservation areas. - to promote heritage led regeneration to make better use of our historic assets and engender civic pride in them To ensure efficient use of land and natural resources - to promote mixed use development of previously developed land in the major growth areas and larger town centres. - to reduce energy demand through the highest possible standards for design and construction and identify opportunities for decentralised heating networks - to minimise waste and maximise re-use and recycling and promote an appropriate framework for integrated waste management. To enhance and protect our green and natural open spaces - to improve access to, and enhance the quality of the Green Belt, Metropolitan Open Land and other open spaces as places for recreation and biodiversity. - to create new and enhanced public open spaces to support of Barnet's growing population, including at least 18 ha in Brent Cross – Cricklewood, Colindale and Mill Hill East. 6.2.2 The linkage between these objectives, the themes and ambitions of the Sustainable Community Strategy themes and the Core Strategy policies that help deliver each objective are set out below Table 1 – Linkage between the Core Strategy and Barnet’s Sustainable Community Strategy Sustainable Community Strategy for Barnet 2008- Core Strategy Objectives Core Strategy Policies 2018; Themes & Ambitions Theme - Growing Successfully Ambition: Delivering Sustainable To manage housing growth to meet Distribution of Housing Growth Housing Growth housing aspirations Protecting and Enhancing Barnet’s To protect and enhance the suburbs Character and Creating High Quality Places Providing Quality Homes and Housing Choice in Barnet
Ambition: Keep Barnet moving To ensure efficient use of land and Providing effective and efficient travel natural resources Ensuring the efficient use of natural To provide effective and efficient resources travel
Ambition: People are equipped To promote Barnet as a place of Promoting a strong and prosperous with the right skills to take economic growth and prosperity Barnet advantage of employment opportunities
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Ambition: Environmentally To ensure efficient use of land and Enhancing and protecting Barnet’s open sensitive natural resources spaces To enhance and protect our green Ensuring the efficient use of natural and natural open spaces resources To provide effective and efficient Providing effective and efficient travel travel Ambition: Creating vibrant and To promote Barnet as a place of Promoting a strong and prosperous viable town centres economic growth and prosperity Barnet Promoting Barnet’s Town Centres Theme - Safer, Stronger and Cleaner Barnet Ambition: Reduce crime and To promote Barnet as a place of Promoting Barnet’s Town Centres make residents feel safe economic growth and prosperity Making Barnet a Safer Place To promote strong and cohesive communities Ambition: Strong and cohesive To meet social infrastructure needs Enabling integrated community facilities communities To promote strong and cohesive and uses communities Making Barnet a Safer Place To protect and enhance the suburbs Protecting and Enhancing Barnet’s Character to Create High Quality Places Ambition: Clean and green To ensure efficient use of land and Enhancing and protecting Barnet’s open natural resources spaces To enhance and protect our green Ensuring the efficient use of natural and natural open spaces resources To promote Barnet as a place of Promoting Barnet’s Town Centres economic growth and prosperity Providing effective and efficient travel To provide effective and efficient travel Theme - Investing in Children and Young People Ambition: Every school a good To meet social infrastructure needs Enabling integrated community facilities school for every child and uses Ambition: Improving employability To promote Barnet as a place of Promoting a strong and prosperous economic growth and prosperity Barnet Ambition: Ensuring children are To meet social infrastructure needs Enabling integrated community facilities safe at home, safe at school and and uses safe in the community Making Barnet a Safer Place Ambition: Personalising services To meet social infrastructure needs Enabling integrated community facilities for children and young people in To manage housing growth to meet and uses vulnerable groups housing aspirations Providing Quality Homes and Housing Choice in Barnet Ambition: Building resilience, To meet social infrastructure needs Enabling integrated community facilities supporting independence To manage housing growth to meet and uses housing aspirations Providing Quality Homes and Housing Choice in Barnet Ambition: Helping children and To meet social infrastructure needs Enabling integrated community facilities their families to make healthy To promote healthy living and well- and uses choices being Improving health and well being in Barnet To enhance and protect our green Enhancing and protecting Barnet’s open and natural open spaces spaces Theme - Healthier Barnet (including older people) Ambition: Creating a health To meet social infrastructure needs Improving health and well being in Barnet supporting environment To promote healthy living and well- Enabling integrated community facilities being and uses To manage housing growth to meet Providing Quality Homes and Housing housing aspirations Choice in Barnet
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Ambition: Bringing user To meet social infrastructure needs Improving health and well being in Barnet experience to healthcare To promote healthy living and well- Enabling integrated community facilities improvement being and uses Ambition: Improving health and To manage housing growth to meet Improving health and well being in Barnet well-being housing aspirations Providing Quality Homes and Housing To meet social infrastructure needs Choice in Barnet To promote healthy living and well- Enabling integrated community facilities being and uses To provide effective and efficient Providing effective and efficient travel travel Ambition: Promoting choice and To manage housing growth to meet Improving health and well being in Barnet maximising the independence of housing aspirations Providing Quality Homes and Housing adults, particularly those who need To meet social infrastructure needs Choice in Barnet additional support. To promote healthy living and well- Enabling integrated community facilities being and uses
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Map 2 – The key diagram
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7 Barnet's place shaping strategy 7.1 Protection, enhancement and consolidated growth - The Three Strands approach 7.1.1 Barnet is a vibrant, diverse and successful London suburb. Barnet contributes to London's success as a global city because it is home to a large number of highly qualified people who choose to live here because of the high quality of life. This quality is demonstrated through excellent schools attainment, attractive suburbs and open spaces, good levels of health and well-being, low crime rates and diverse but cohesive communities. The popularity of Barnet as a place to live means that the borough continues to grow. 7.1.2 The London Councils Successful Suburbs report (published March 2009) highlights the strengths of the suburbs, including the relatively high quality of the suburban environment, high skills level and generally high quality of life. 7.1.3 There is a tension between the demands of growth and maintaining the conditions for a good and improving quality of life and a concern about the loss of what makes living in Barnet a distinctive experience. Quality of life covers a broad range of cross-cutting policy areas on design, heritage, local character and views, access and inclusive design, safety, green infrastructure, biodiversity, air quality, soundscapes7 and all the policy areas that contribute to making Barnet a special place. 7.1.4 Housing development needs to be supported by infrastructure. Barnet’s Infrastructure Delivery Plan sets out the anticipated timing of infrastructure provision (although not phasing). Timing and phasing will depend on a variety of factors, including when the development envisaged by this Core Strategy takes place, the availability of funding such as from Growth Area Fund and the timing of major investment. In many cases the confirmation of funding for infrastructure is limited to the short term. Nevertheless, it is important to identify medium to long term infrastructure priorities even where funding has not yet been confirmed as the Core Strategy will guide the future decision making of the Council and its partners in relation to infrastructure provision. 7.1.5 In order for Barnet to remain as a place where people choose to live the Three Strands Approach has been developed. The Three Strands are: Protection - absolute protection for the Green Belt and open spaces Enhancement - enhancing and conserving the best of Barnet suburbia and Barnet's 20 town centres Consolidated growth in areas in need of renewal and investment 7.2 Consolidated growth 7.2.1 Our overall strategy is to manage growth in Barnet so that it meets our needs for homes, jobs and services in a way that conserves and enhances the character of the borough. Where there is already planned or approved pipeline growth this is consolidated in areas in need of renewal and investment and where regeneration delivers significant and lasting economic and wider benefits to the residents and communities of Barnet, particularly in the west of the borough.
7 A soundscape is the combination of sounds that arises from natural sounds such as the wind and sounds caused by human activity such as traffic.
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7.2.2 Policy CS 1 sets out the spatial development strategy for Barnet. This sets out our overarching Three Strands Approach to protect, enhance and consolidate planned and pipeline growth. Three Strands ensures that in consolidating planned and pipeline growth we can provide stronger protection for the suburbs, gardens and Green Belt and enhance our quality residential neighbourhoods and town centres. Three Strands helps to keep what is best about the borough, what makes Barnet a distinctive place. 7.2.3 Consolidated growth will predominantly be delivered in two regeneration areas - Brent Cross – Cricklewood and Colindale; and the development area of Mill Hill East. These areas will be the primary focus of housing and employment growth and are identified in the London Plan as having significant potential for accommodating new homes and jobs. 7.2.4 The regeneration of Brent Cross - Cricklewood is expected to deliver over 20,0008 jobs by 2026/27 with Colindale and Mill Hill East adding 1,500 new jobs9. In terms of housing delivery these regeneration and development areas are expected to deliver up to 17,000 new homes within the next 15 years. 7.2.5 It is vital that the transport facilities and services, utilities and social infrastructure needed to make development work and support local communities is provided, particularly in the parts of Barnet that will experience most growth in future years. Through Barnet’s Infrastructure Delivery Plan we will have regard to the investment and operational plans of infrastructure providers and work with our partners and other relevant organisations to secure ‘critical’, ‘necessary’ or ‘preferred’ infrastructure in order to deliver the objectives of the Core Strategy. Section 20 sets out how the Core Strategy will be delivered and provides more detail on the Infrastructure Delivery Plan. Mill Hill East Development Area The Mill Hill East AAP was adopted in January 2009. The relationship of Mill Hill East to the London Plan is set out at para 1.3.2 The Mill Hill East AAP area covers 48 hectares of land, of which 31 hectares is proposed for the development of around 2,000 additional residential units. The AAP vision is that Mill Hill East represents a major regeneration and development opportunity in the heart of Barnet. Within 15 years the Mill Hill East area will have been transformed through one of the highest quality sustainable developments in North London. Within a green suburban context it will provide new homes and business opportunities with high quality community services, transport and access to open space and leisure facilities. The AAP seeks to ensure that development takes place in a balanced and coordinated manner by setting out a comprehensive framework to guide the delivery of housing, employment, leisure and associated community facilities, infrastructure, transport initiatives, environmental protection and enhancement. Mill Hill East will be a major focus for the creation of new jobs and homes and the development of a sustainable community, building upon the area’s strategic location. Development will comprise: o a total of around 2,660 residential units including 2,000 new homes by 2024; o in line with the existing London Plan target of 50% of housing provision being affordable the maximum amount of affordable housing will be sought having regard to this target and to a viability assessment;
8 Based on existing London Plan and Cricklewood, Brent Cross and West Hendon Development Framework SPG 2005 9 Figure reflects the jobs totals identified in adopted AAPs. Draft Revised London Plan has identified jobs capacity of 3,800 for Colindale and Mill Hill East
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Core Strategy Publication Stage o a minimum of 500 jobs by 2024 (replacement of existing jobs and creation of new jobs) with a focus on the provision of small-medium sized workspace and support for local businesses and designation of an additional 1 hectare of adjacent land for employment use; o around 5.5 ha of public open space including children’s play facilities, formal sports provision and natural areas by 2024. o a new mixed use high street comprising around 1,000 m2 of retail floorspace in a small retail parade by 2024; o a new 2 form entry primary school on a 1.7 ha site between 2016 and 2020; o between 2011 and 2015 a local healthcare facility (approximately 500 m2 floorspace) to accommodate 2 to 3 GPs serving the new community in line with guidance from NHS Barnet ; o transport improvements to mitigate the phased impact of the development including new roads, improvements to existing junctions, public transport enhancements including better facilities at Mill Hill East station, facilities for pedestrians and cyclists and comprehensive travel planning.
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Map 3 – Mill Hill East development area
Colindale Regeneration Area The Colindale AAP was adopted in March 2010. The relationship of Colindale to the London Plan is set out at para 1.3.1 The Colindale AAP area covers 200 hectares. The AAP’s vision is that Colindale will, by 2021, be a vibrant successful and diverse neighbourhood where people will want to live, work and visit. It will accommodate high quality, sustainable developments within four 'Corridors of Change' and a new neighbourhood centre. Colindale will become a successful suburb in North
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London, providing existing and new communities with high quality local services, improved transport and access to enhanced green space and leisure facilities. Colindale represents an opportunity to deliver sustainable housing growth, a new compact neighbourhood centre in an area well served by improved public transport services and high quality public open space. Colindale will make the single largest housing and affordable housing contribution to the Borough over the next 10-15 years and one of the biggest in North London with approximately 10,00010 new homes, of which nearly 5,300 already have planning permission and hundreds are under construction or completed. Four Corridors of Change have been identified in the Colindale Area Action Plan o Colindale Avenue o Aerodrome Road o Edgware Road o Grahame Park Way Colindale Avenue will provide the vibrant heart and gateway of Colindale as a sustainable mixed-use neighbourhood centre anchored by a new public transport interchange with pedestrian piazzas. This Corridor will provide a new convenience food store of up to 2,500 m2 in the neighbourhood centre. It will also include a new location for Barnet College, support for relocation of Middlesex University’s student accommodation and support for provision of a new primary healthcare facility. The quality of, and access to, Montrose Park will be improved as will the environment of the Silk Stream. In the Colindale Avenue Corridor of Change between 2007 and 2021 approximately : 2,370 new homes are expected to be developed and 200 new jobs generated Aerodrome Road will bring forward the largest and most significant phase of growth in transforming Colindale. This Corridor will become a focus for living, learning and working forging new connections with the surrounding area to create a new eastern movement gateway into Colindale and connect to a new public transport interchange and the new quarter of Beaufort Park. A new 5 ha Aerodrome Park will be provided as will new commercial facilities along Aerodrome Road to support consolidation and redevelopment of the Metropolitan Police Peel Centre to provide modern police training facilities. On Peel Centre East this Corridor will provide a site for a new primary school and a new 1,000 bed student village for Middlesex University In the Aerodrome Road Corridor of Change between 2007 and 2021 approximately : 4,180 new homes are expected to be developed and 760 new jobs generated Edgware Road which borders London Borough of Brent, will become a thriving mixed-use urban corridor providing focus for employment, housing and bulky retail (selling goods such as furniture, DIY or washing machines). This Corridor will provide an improved gateway to Colindale incorporating tall buildings where appropriate and key junction improvements to increase travel movement and new or improved public transport provision. A co-ordinated approach to the public realm with TfL and London Borough of Brent will help establish a formal, tree lined urban boulevard to create a lively, busy and thriving place. In the Edgware Road Corridor of Change between 2007 and 2021 approximately: 925 new homes are expected to be developed There will be no net loss of jobs
10 The Colindale AAP identifies a total of 9,806 new homes to be delivered by 2021.
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Grahame Park Way will, through the redevelopment of Grahame Park Estate and the Barnet College site, create a vibrant, mixed use neighbourhood. This Corridor will also provide for the replacement of the neighbourhood centre at Grahame Park. Other planned development includes a new primary healthcare facility, a new 2 form entry primary school on the former Barnet College site and the use and expansion of the RAF Museum as a key cultural, tourist and community facility. In the Grahame Park Way Corridor of Change between 2007 and 2021 approximately : 2,335 new homes are expected to be developed and 70 new jobs generated. Proposals for the wider Colindale area include : Transport improvements to link development with the wider area and increase connectivity and permeability within Colindale. Highway improvements include : Junction improvements on the A5 and A41 by 2016 New street (Peel Access Link) connecting Aerodrome Road and Colindeep Lane by 2021 o in line with the existing London Plan target of 50% of housing provision being affordable the maximum amount of affordable housing will be sought having regard to this target and to a viability assessment. A new public piazza at Colindale Avenue by 2016 Improvements to Montrose Park by 2016 and delivery of the new Aerodrome Park by 2021 5,000m2 gross of retail in the new neighbourhood centres by 2016 Up to 1,000 new jobs by 2021 Two new, 2 form entry primary schools at former Barnet College site by 2016 and Peel Centre East by 2021. A Colindale-wide CHP and district heating system supported by energy centres at Colindale Hospital and Peel Centre West by 2016 A new 4,000m2 community centre in Zenith House by 2016
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Map 4 – Colindale regeneration area
Brent Cross – Cricklewood Regeneration Area11 Together with the Mayor of London we have identified Brent Cross – Cricklewood as a major opportunity for regeneration. Brent Cross-Cricklewood was included as an important strategic project in both the London Plan and the UDP. In December 2005 the Cricklewood, Brent Cross
11 This information will be updated to reflect progress with this proposal
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Core Strategy Publication Stage and West Hendon Regeneration Area Development Framework was adopted by the council and the Mayor as Supplementary Planning Guidance. This Development Framework was produced in collaboration with the Mayor and the Greater London Authority, landowners and developers in order to guide and inform the design and delivery of the development with the aim of achieving high quality comprehensive redevelopment of the area around a new sustainable mixed use town centre spanning the North Circular Road. The UDP policies relating to Brent Cross-Cricklewood were saved by a Direction of the Secretary of State dated May 13 2009. The London Plan and the UDP saved policies combined with the Development Framework establishes a series of strategic principles for the comprehensive redevelopment of the area to create a new town centre, the overall vision for which is set out in UDP Policy GCrick in the following terms : ‘The Cricklewod, Brent Cross and West Hendon Regeneration Area, as defined on the Proposals Map, will be a major focus for the creation of new jobs and homes, building upon the area’s strategic location and its key rail facilities. All new development will be built to the highest standards of design as well as to the highest environmental standards. A new town centre, developed over the Plan period, will be fully integrated into the regeneration scheme.’ The Development Framework expands upon this vision and provides detailed guidance within the scope of the saved UDP policies as to what will be acceptable to support regeneration in terms of land uses, design principles and housing densities. The regeneration area of Brent Cross – Cricklewood is identified on Map 5 An outline planning application which will establish a masterplan and framework for the comprehensive regeneration of the Brent Cross Cricklewood Area in accordance with relevant development plan policies was submitted by a partnership of key landowners and developers (BXC Development Partners) in March 2008. This has included extensive pre and post application consultation with the council, the GLA, Transport for London, the Highways Agency, the Environment Agency and other agencies and stakeholders including the local community. In November 2009 the council resolved to approve the outline application subject to completion of a Section 106 Agreement. These proposals represent the largest and most important development in Barnet and one of London’s most important strategic proposals. The application proposes the creation of a sustainable new mixed use town centre for Barnet and North London including substantial residential, commercial and retail uses. A resolution to grant an outline planning permission for the establishment of a masterplan and framework for the comprehensive regeneration of the Brent Cross Cricklewood Area in accordance with relevant development plan policies was approved in November 2009. In June 2010 the Secretary of State informed Barnet that the application should be determined by the local planning authority and a further resolution to grant the permission was passed by the council on June 29 2010, taking account of detailed drafting of the conditions and Section 106 agreement as well as recent changes in national and regional planning policy. It is anticipated that the permission will be issued before October 29 2010. These proposals represent the largest and most important development in Barnet and one of London’s most strategic proposals. The proposals include approximately 7,550 housing units, of which, subject to a viability assessment, 2,250 are targeted to be affordable. The Brent Cross Shopping Centre will be transformed into an outward-facing town centre with approximately double the current amount of floorspace, which will be focused on a new High Street which traverses the North Circular Road. The application proposals comprise a net addition of 55,000m2 gross comparison retail floorspace as part of town centre north. The High Street south of the North Circular Road will comprise a mix of town centre and residential uses and will include new schools and community uses as well as a new food superstore (to replace
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Phase 2 will comprise the remainder of the new town centre shopping area north of the North Circular Road and elements adjacent to the primary development areas to the south. This will include the replacements for the Whitefield Secondary School and Mapledown Special Needs School, completion of the improvements to Clitterhouse Playing Fields, a replacement for Hendon Leisure Centre and a new Health Centre, Brent Cross Bus Station, step-free access at Brent Cross Underground and Cricklewood stations, M1/A406 junction improvements and development around Cricklewood Lane. The completion of Phase 2 represents completion of the new town centre core. Phase 3 comprises predominantly residential development completing the Eastern Lands development zone, including a private hospital, residential development to the west of Brent Cross Shopping Centre on the north side of the A406, completion of River Brent works and completion of the A406 pedestrian bridge Phase 4 comprises the new road link across the Midland Mainline, a new rail freight facility, residential development to the south of Brent Terrace, Gas Governor Square and Millennium Green Park Phase 5 comprises residential development and local retail facilities along the length of Brent Terrace, new Thameslink Rail Station close to Staples Corner and Brent Terrace Park Phase 6 comprises high rise business accommodation known as the Station Quarter, retail and hotel development adjacent to the new rail station including Northern Nature Park and new Tower Square. Phase 7 comprises business and retail development on the site of the existing Brent South Shopping Park. Status of Brent Cross – Cricklewood Proposal In the event that planning permission is ultimately refused for this proposed development or if the planning permission is not implemented, the Core Strategy and the Local Development Scheme may need to be reviewed and in the meantime it is intended that any future planning applications will be determined in accordance with relevant policies of the Core Strategy and other LDF documents, as well as the London Plan, the saved UDP policies and the Development Framework, subject to any future reviews of these documents.
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Map 5 – Brent Cross – Cricklewood regeneration area
7.2.6 In the adopted London Plan Barnet has been set a housing target of 20,550 new homes over the ten year period 2007/08 to 2017/18. This equates to an annual housing target of 2,055 new homes per annum. Following completion of the Mayor's Strategic Housing Land Availability Assessment (SHLAA) this figure has been revised up to 2021 as part of the draft revised London Plan. The revised housing target for Barnet is 22,550 new homes equal to 2,255 new homes per annum over the ten year period 2011/12 to 2021/22. 7.2.7 Barnet has been set the challenge of meeting the fourth highest housing target in London over the ten year period 2011/12 to 2021/22. The target over the next 10
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years largely reflects the opportunities that are coming forward in Brent Cross – Cricklewood, Colindale and Mill Hill East and the priority housing estates as shown in Table 2. 7.2.8 Table 2 shows that nearly 15,000 new homes will be delivered in regeneration and development areas and priority housing estates by 2021 as part of our identified development pipeline. Looking beyond 2021 we expect opportunities for housing development to diminish reflecting that the borough’s capacity is finite. The draft revised London Plan states that boroughs should roll forward their target’s (Barnet’s new target is 2,255 new homes per annum) to cover their 15 year plan periods. This roll forward which is not based on an assessment of capacity would set Barnet a housing target of 33,825 new homes between 2011/12 and 2025/26. Table 2 – Barnet’s development pipeline and incremental housing growth– 2011/12 to 2025/26
SOURCE 2011-16 2016- 21 2021 -26 TOTAL 1 Incremental small housing schemes incorporating windfall allowance 1228 980 980 3188 2 non self contained accommodation 635 635 635 1905 3 vacant properties 395 395 395 1185 4 Total Town Centre sites 648 40 195 883
5 Total Other Major sites 1136 8 175 1319 6 Priority Housing Estates12 1086 764 517 2367 Regeneration and Development Areas Brent Cross - Cricklewood 53 3113 3205 6371 Mill Hill East AAP 928 1000 200 2128 Colindale AAP 5270 2462 652 8384 North London Business Park / Oakleigh Road South Planning Brief 150 250 0 400 7 Total Regeneration and Development Areas 6351 6575 4057 16983
Borough Total (sum of 1 to 7) 11479 9397 6954 27830
7.2.9 Most of major housing development in Barnet for the next 15 years is either already planned, pipeline approved or granted planning permission. Table 2 provides a breakdown of housing development and illustrates our targeted housing growth and expected windfalls from small sites up to 2026. It estimates that nearly 28,000 new homes will be developed by 2026. Over 6,000 new homes are expected to be generated incrementally by small housing schemes, non self contained accommodation and vacants. The remaining 22,000 new homes represents consolidated housing growth as they are known schemes located in our regeneration and development areas, priority housing estates, town centres and other major sites. These known schemes form Barnet’s Housing Development Pipeline. 7.2.10 Our expectation of housing delivery in the medium and long term assumes that small sites (schemes of less than 10 units largely generated by the private sector) will continue to make a contribution to housing supply in Barnet. According to the Londonwide SHLAA small sites are expected to contribute 196 homes per annum
12 Excluding Grahame Park, which is included in the Colindale AAP figures.
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while non self contained accommodation will provide 127 new homes per annum and vacant units brought back into use will provide 79 new homes per annum. We assume on the basis of the Londonwide SHLAA and the implementation of existing live permissions that small sites will contribute over 3,000 new homes to housing supply between 2011/12 and 2025/26. According to the SHLAA non self contained accommodation such as Homes in Multiple Occupation (HMOs) and student halls of residence is expected to contribute under 2,000 new homes while vacant units being brought back into use are expected to provide over 1,000 new homes. 7.2.11 In addition to the delivery from major growth areas of 17,000 new homes it is a major priority to regenerate failed housing estates in Barnet. Major estates at Dollis Valley, Grahame Park, Granville Road, Spur Road - Stonegrove and West Hendon will be subject to long term programmes of regeneration in order to tackle poor quality housing, social isolation and transform these areas into successful mixed tenure places. These estates (excluding Grahame Park which is counted as part of the Colindale regeneration area) will provide nearly 2,400 new homes by 2026 7.2.12 The town centre areas are considered appropriate locations for uses that will lead to a significant increase in travel demand (retail, leisure and other commercial uses) although the quantum of development at these locations will be less than that in the identified growth areas. The priority town centres of Chipping Barnet, Edgware, Finchley Church End and North Finchley will be the main focus for commercial development and residential growth as part of mixed use development. Smaller scale development opportunities have also been identified in the remaining district town centres in Barnet as shown on Map 6 and will be promoted in the Site Allocations DPD. Table 2 provides estimates of capacity rather than rigid targets. Our town centres are estimated to have capacity to deliver nearly 900 new homes. 7.2.13 Outside of the areas identified in the Core Strategy there are smaller scale developments of schemes typically between 10 and 25 units which are expected to provide 1,300 new homes over the next 15 years. 7.2.14 Figure 1 sets out Barnet's most recent housing trajectory showing how we expect the borough to grow in the next 15 years. Our housing trajectory tracks the expected supply of housing over the lifetime of the Core Strategy. It provides a ‘snapshot’ as the trajectory evolves over time to reflect changing circumstances. The housing trajectory is updated every year and published in Barnet’s Annual Monitoring Report.
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Figure 1 – Housing Trajectory for Barnet
Barnet Housing Trajectory 2011/12 - 2025/26
7000 Past Completions
6000 Projected Completions
MANAGE - Annual requirement taking 5000 account of past/projected completions PLAN - Strategic Allocation (annualised) 4000
3000 25442565 2464 2202 2311 Dwellings 19031945 1842 2000 1704 1704 1534 1446 1569 1251 1294 1186 1310 1263 1053 10351156 834 1000 607 673 454 244 0 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 / / / / / / / / / / / / / / / / / / / / / / / / / / 0 0 0 0 0 0 0 0 0 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 0 2 3 4 5 6 2 1
7.3 Protection 7.3.1 Protecting our open spaces is important to the health and well being of our residents and their quality of life. They provide opportunities for sport, recreation and play, reducing urban heating and flood risk as well as breaking up built areas. The Three Strands Approach highlights that careful stewardship and protection of these assets is fundamental to the borough's spatial planning vision. 7.3.2 While over a third of the borough is protected open space another third is considered to be classic suburban development within which there are variations in building typology, size and tenure which provides a very mixed character. The Three Strands Approach highlights that the design, layout and use of the built environment can affect the quality of people's lives as well as having an impact on the perception of Barnet and the vitality of the area. The Core Strategy sets a framework for more detailed design work through the Development Management Policies DPD and subsequent Supplementary Planning Documents on Residential Design Guidance and Green Infrastructure. 7.4 Enhancement 7.4.1 Through the careful design of buildings and spaces new development brings with it the opportunity to improve townscape and landscape quality. Proposals that come forward in the growth areas should be creative and innovative, be sensitive to existing buildings and surrounding areas, incorporate both urban and green spaces and include appropriate landmark buildings including tall buildings. Overall the design of the new development schemes will be expected to enhance the qualities of its immediate location and wider setting, as well as improve the quality of life for those people living and working in the area.
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Policy CS 1 – Barnet’s Place Shaping Strategy – Protection, Enhancement and Consolidated Growth – The Three Strands Approach Barnet’s place shaping strategy is to concentrate and consolidate housing and economic growth in well located areas that provide opportunities for development, creating a quality environment that will have positive economic impacts on the deprived neighbourhoods that surround them. The key diagram sets out the areas where we expect housing and economic growth. The council, along with its partners, will focus major housing and economic growth in the most suitable locations and manage it to ensure that we deliver sustainable development, while continuing to conserve and enhance the distinctiveness of Barnet as a place to live work and visit. An appropriate level of transport provision will be provided as the regeneration schemes roll out. We will seek the highest standards of urban design in order to generate development proposals of landmark quality and create a safe and attractive environment for people who live in, work in or visit Barnet’s areas of housing and economic growth. We will only consider tall buildings subject to them not having an unacceptably harmful impact on their surroundings. We will work with partners and other relevant organisations to secure ‘critical’, ‘necessary’ and ‘preferred’ infrastructure as set out in Barnet’s Infrastructure Delivery Plan and ensure that new development funds infrastructure through S106 and other funding mechanisms. As our focus of housing and employment growth we will promote opportunities on the west side of the borough in the strategically identified North West London – Luton Coordination Corridor. We will promote the following regeneration and development areas in the west of the borough: Brent Cross – Cricklewood regeneration area - 7,500 new homes Colindale regeneration area - 10,000 new homes Mill Hill East development area – 2,000 new homes Core Strategy Policy CS 3 sets out the areas where we expect 28,000 new homes to be delivered between 2011/12 and 2025/26 Core Strategy Policy CS 4 sets out our aim to create successful communities by providing quality homes and housing choice Consolidated growth will be complimented by: Protection of Green Belt and Metropolitan Open Land that covers over one third of Barnet Core Strategy Policy CS 5 sets out how we will ensure that development helps to protect and enhance Barnet’s heritage and character Core Strategy Policy CS 7 sets out how in order to create a greener Barnet we will enhance and protect our open spaces Enhancement of priority town centres (Chipping Barnet, Edgware, Finchley Church End and North Finchley) where we will promote mixed use development in accordance with the place making policies set out within the Core Strategy; the historic suburban environment comprising 18 conservation areas, 1,300 listed buildings and registered historic parks and gardens
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Core Strategy Policy CS 6 sets out how we will realise development opportunities in town centres in order to promote them as successful and vibrant places Core Strategy Policy CS 8 sets out how in order to provide opportunity for economic advancement we will ensure a strong and prosperous Barnet
7.5 Brent Cross - Cricklewood regeneration area 7.5.1 The policy framework for Brent Cross – Cricklewood is designed to promote comprehensive re-development of the Brent Cross – Cricklewood regeneration area (as shown in Map 5) which can take advantage of its strategic location and facilitate the regeneration of the surrounding communities in Barnet and the adjoining boroughs. 7.5.2 In view of the substantial progress that has been made towards the implementation of the relevant UDP saved policies on Brent Cross – Cricklewood we consider that it is inappropriate at this time to replace the suite of policies listed in Appendix A. In order to provide a detailed policy framework to secure the future comprehensive redevelopment of Brent Cross Cricklewood these ‘saved’ policies will continue to operate unless and until it is considered appropriate to replace them. Specific monitoring indicators for Brent Cross – Cricklewood are set out in Appendix B. These indicators are closely aligned with the progress to be made under the imminent planning permission in securing the implementation and delivery of regeneration before 2015/16 including in particular key infrastructure as identified in the Infrastructure Delivery Plan and providing new housing. These indicators will provide the basis for the review of the Core Strategy and may if necessary or appropriate lead to introduction of new DPD or SPD to further guide and control the comprehensive regeneration of the Brent Cross – Cricklewood area Policy CS 2 – Brent Cross – Cricklewood Brent Cross – Cricklewood is identified as an Area of Opportunity in the London Plan and on Map 5. It will be a major focus for the creation of new jobs and homes, building upon the area’s strategic location and its key rail facilities. We will seek comprehensive redevelopment of Brent Cross – Cricklewood in accordance with the London Plan, the saved UDP policies and the adopted Development Framework. This will provide the key elements of the local planning policy framework for deciding future planning applications unless and until replaced by new DPD or SPD as a result of the LDF Monitoring and review process. It is considered likely that comprehensive regeneration will be achieved in accordance with the planning permission which is resolved to be granted to the BXC Development Partners. If this proves unlikely then we will consider whether in the circumstances the LDF needs to be reviewed. Specific monitoring indicators for Brent Cross – Cricklewood are set out in Appendix B and we will have regard to them in monitoring the progress made in the implementation and delivery of regeneration, including the achievement of important milestones (as set out in Appendix B) towards the initiation of development under the planning permission described in the information box on Brent Cross – Cricklewood. It is anticipated that the BXC Development Partners are committed to progressing the project as quickly as reasonably practicable towards commencement of the development under the permission subject to securing the necessary planning approvals, highways orders and site assembly. On the basis of these indicators we expect that comprehensive re-development will commence in relation to Phase 1 at some time between 2015 and 2017.
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If in the light of progress made in securing pre-commencement approvals and other related procedures as well as actual delivery of the development these milestones are not achieved (or are not likely to be capable of being delivered) we will consider the possible need for a review of the Core Strategy policy on Brent Cross – Cricklewood in the light of progress that is being made in delivering this important strategic project.
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8 Distribution of housing growth 8.1.1 Barnet is the most populous borough in London. Barnet is growing and its population is changing. By 2026 it is estimated that an additional 40,000 people will be living here, an increase of 14%. 8.1.2 The Green Belt and Metropolitan Open Land accounts for nearly 37% of Barnet representing one of the major challenges to new housing development in the borough. If we are to adapt successfully to Barnet’s growing population and protect Green Belt and Metropolitan Open Land we need to make the best use of brownfield (also known as previously developed) land. 8.1.3 Current national planning guidance on housing set out in Planning Policy Statement 3 - Housing, advises that high quality housing should aim to create places that meet the needs of people, maintain and improve local character, and are accessible to open spaces, give choice to transport options and local facilities. 8.1.4 The overall spatial strategy for Barnet is illustrated in the Key Diagram – Map 2. This shows the broad location of Barnet’s growth areas. The North West London-Luton Coordination Corridor is a growth area of regional importance. Development has been identified on the western side of the borough at Brent Cross as well as Colindale and Mill Hill East as Barnet’s strategic contribution to the corridor. 8.1.5 Policy CS 3 sets out our housing growth target and when, where and how this growth will be delivered in Barnet. Barnet's housing trajectory up to 2025/26 shows that in the region of 28,000 new homes will be built in Barnet over the 15 year life of this Core Strategy (between 2011/12 and 2025/26). Development sites in the regeneration and development areas are identified in the Mill Hill East Area Action Plan (adopted 2009), the Colindale Area Action Pan (adopted 2010), and the adopted Brent Cross Cricklewood and West Hendon Development Framework (Supplementary Planning Guidance adopted in 2005). Of this figure over 17,000 new homes will reflect the potential of Colindale, Cricklewood - Brent Cross and Mill Hill East. The North London Business Park and Oakleigh Road South is identified as a smaller development area in the west of the borough. It is estimated that 400 new homes will be delivered as part of a mixed use development in accordance with the adopted planning brief of June 2006. 8.1.6 It is estimated that in the region of 2,400 new homes will be delivered through the regeneration of housing estates at Dollis Valley (subject to a new masterplan), Granville Road, Stonegrove / Spur Road and West Hendon13. 8.1.7 Choices and opportunities for town centre enhancement and infill will be identified through the programme of priority town centre frameworks for Chipping Barnet, Edgware, Finchley Church End and North Finchley and the Site Allocations DPD. Our town centres have the capacity to deliver a further 900 new homes by 2025/26. Policy CS 6 - Promoting Barnet's Town Centres sets out our approach to all town centres in Barnet. 8.1.8 Our Annual Monitoring Report (AMR) includes the Housing Trajectory which provides more detail on how London Plan targets are being delivered. The AMR also sets out Barnet's five year supply of housing and the allocated schemes that make up the components of supply. As supporting evidence for the Core Strategy
13 The number of new homes at Grahame Park is already included within the Colindale AAP.
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we have published a trajectory that extends to 2025/26 (see Figure 2). This trajectory will be updated annually. 8.1.9 Central to our overall approach to adapting to Barnet’s targeted housing growth is ensuring that it is managed in a way that provides opportunity and benefits to the borough and that it protects and enhances our environment, heritage and quality of life. 8.1.10 A key part of our Core Strategy is to ensure that our growing population is supported by necessary infrastructure and services. Barnet’s Infrastructure Delivery Plan identifies the borough’s infrastructure needs up to 2026 and sets out the key infrastructure programmes and projects needed to deliver the Core Strategy. 8.2 Mixed use development 8.2.1 The provision of an appropriate mix of uses can also contribute to managing Barnet’s growth and making efficient use of brownfield land. The benefits of a mix of uses is that they can : reduce the need to travel, reducing congestion and helping to improve air and noise quality increase the supply of housing especially above ground floor commercial development in town centres promote successful places with a range of activities that are used throughout the day, increasing safety and security 8.2.2 Encouraging greater housing development within or on the edge of some of Barnet’s town centres is an option that allows mixed uses such as flats above shops which add vibrancy and greater all round activity. This can provide attractive locations for people who want to live close to services, jobs and public transport, for example, older people, single people and couples. Town centre locations may not be suitable for the majority of families or for those who need access to their own car, as parking is likely to be restricted. Encouraging a mix of uses including residential means that valuable space is utilised more efficiently through multi-purpose use of facilities such as car parks and local services. 8.2.3 Further detail on our approach to mixed use development will be set out in the Development Management Policies DPD. The Site Allocations DPD will allocate specific sites for a mix of uses and provide guidance on their future development. 8.3 Optimising housing density to achieve appropriate development 8.3.1 One way of making the most efficient use of our land and buildings is to encourage higher densities. We will encourage higher density development in the regeneration and development areas, the four priority town centres and other identified locations that are accessible by public transport. However density should not drive development, it is an important factor to take into account along with local context, design, transport accessibility and infrastructure. 8.3.2 The adopted London Plan sets out an approach to maximising the potential of sites, ensuring the maximum intensity of use compatible with local context and public transport capacity. With regard to the existing London Plan matrix we will expect to optimise densities rather than maximise them. However there will be instances where developments are appropriate within the upper end of the density range set out in the draft revised London Plan. We will utilise the proposed new density matrix in the draft revised London Plan to reflect local context, public transport accessibility and availability of social infrastructure.
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Policy CS 3 - Distribution of Growth in Meeting Housing Aspirations On the basis of our Three Strands Approach we expect that in the range of 28,000 new homes will be provided within the lifetime of this Core Strategy 2011/12 to 2025/26. As our focus of growth we will promote opportunities on the west side of the borough in the strategically identified North West London – Luton Coordination Corridor. We will promote the following regeneration and development areas in the Corridor: Brent Cross - Cricklewood Colindale Mill Hill East These areas are expected to provide in the range of 17,000 new homes between 2011/12 to 2025/26. An appropriate level of transport provision will be provided as the regeneration schemes roll out. We will, in order to meet the Decent Homes standard, and deliver a greater range and variety of accommodation, also promote the regeneration of priority housing estates at: Dollis Valley Grahame Park14 Granville Road Stonegrove and Spur Road West Hendon These areas are expected to provide in the range of 2,400 new homes between 2011/12 to 2025/26 We will also promote the development area of the North London Business Park and Oakleigh Road South in order to develop 400 new homes by 2020/21 as part of a mixed use development in accordance with the adopted Planning Brief of June 2006 Through the regeneration and development areas, regeneration estates and town centres housing will be provided in the following 5 year phases 2011/12 to 2015/16 Colindale 5,300 new homes Mill Hill East 900 new homes West Hendon 680 new homes Granville Road 140 new homes Stonegrove and Spur Road; 120 new homes Dollis Valley 160 new homes North London Business Park 150 new homes TOTAL 7,500 new homes 2016/17 to 2020/21 Brent Cross - Cricklewood 3,100 new homes Colindale 2,600 new homes Mill Hill East 1,000 new homes West Hendon 420 new homes
14 The regeneration of Grahame Park is incorporated into the Colindale regeneration area
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Stonegrove and Spur Road 80 new homes Dollis Valley 270 new homes North London Business Park 150 new homes TOTAL 7,620 new homes 2021/22 to 2025/26 Brent Cross - Cricklewood 3,200 new homes Colindale 300 new homes Mill Hill East 200 new homes West Hendon 410 new homes Dollis Valley 110 new homes TOTAL 4,220 new homes Through a programme of town centre strategies we will develop frameworks for the town centres of Chipping Barnet, Edgware, Finchley Church End and North Finchley. These locations will provide the main focus for enhancement and infill housing development: and will provide for residential uses above ground floor level Our strategic approach on further development opportunity sites will be set within the context of the density matrix in the existing London Plan. We will seek to optimise rather than simply maximise housing density to reflect local context, public transport accessibility and provision of social infrastructure.
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9 Providing quality homes and housing choice in Barnet 9.1.1 In order to create successful communities we need to maximise housing choice providing a range of sizes and types of accommodation that can meet aspirations and increase access to affordable and decent new homes. This includes homes for those who need larger dwellings including families, as well as homes for smaller households such as single key workers, or older and vulnerable people who may require accommodation in order to live independently. 9.1.2 Barnet's specialist Housing Strategy adopted in April 2010 sets out our housing priorities and how we are going to deliver these by 2025. Our overarching objective is 'providing housing choices that meet the needs and aspirations of Barnet residents`. Our Housing Strategy emphasises that to improve choice we need to increase housing supply, including family sized homes. We also need to improve the condition and energy efficiency of the existing housing stock, promote mixed communities and maximise opportunities for home ownership. We need to provide housing related support options to maximise independence. 9.1.3 A key message from Barnet’s Housing Strategy is that we do not consider that social rented housing is the only suitable option for people in housing need, when the private rented sector can in many cases provide flexibility and choice, as well as meeting housing aspirations. 9.1.4 Public investment in housing is likely to be significantly reduced during the lifetime of this Core Strategy. Our partners have responsibilities for delivering housing, including Registered Social Landlords, private developers and land owners. We are committed to exploring new and innovative investment models within Barnet that will deliver new homes and increase the housing choices available to residents. 9.1.5 In focusing on the quality of housing that is needed and the types of homes that are required we will consider sustainability, the efficient use of natural resources, standard of design and construction, contribution to local character and integration of the development with social, green and physical infrastructure. These wider considerations are dealt with throughout the Core Strategy. 9.2 Homes of different sizes 9.2.1 The range of housing sizes sought in Barnet should reflect how we expect households to change in the next fifteen years. Barnet has a housing stock of 133,000 units. The majority of units are houses which account for 62% of the stock. The range of home sizes we seek should reflect the size and type of households that we expect to live in Barnet. The housing needs of the borough should take into account the size of households, affordability and the special needs of vulnerable people. Although the largest type of households in Barnet are families that comprise 2 adults with 2 or more dependent children (25%), 22% of households are pensioners, 16% are single adults and 22% are 2 adults either with no children or with non-dependent children. 9.2.2 We know from household projections that Barnet’s households are forecast to get smaller; the average household size will fall to 2.29 persons per household by 2016. The household size makeup is therefore very mixed. Add to this the variations in wealth, culture, ethnicity, sexual orientation, physical and mental disability combined
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with the relative attractiveness of the borough for different types of households and a complex picture of future housing need emerges. 9.2.3 Barnet’s Core Strategy has to address the demands for family accommodation at lower densities while meeting the demands for higher densities driven by the planned growth as part of our development pipeline and housing targets in the London Plan. This is combined with the need to protect the Green Belt and the borough’s open spaces. As well as accommodating families we should make sure that developments do not deter shared or multi-generational usage, particularly with an ageing population, to ensure the delivery of truly mixed communities in lifetime neighbourhoods. 9.2.4 Section 4.3 on Barnet’s People has set out how the population is changing and how the number of births in Barnet is one of the highest in London. With high levels of planned housing growth and a changing population with more children and more older residents a key concern for the council is that residents are able to secure access to the right accommodation in the right place. It is important that the size and mix of homes delivered will match the size and composition of Barnet’s changing population. In assessing our housing supply we conducted research on ‘are we building the right homes for the next generation?’. 9.2.5 We found that between 2005/06 and 2008/09 that one and two bed units are the dominate type of unit built in Barnet accounting for nearly 80% of new homes. New build developments have provided the main source of supply of units representing 76% of housing developments in the borough. Other forms of development such as change of use (i.e. from office to residential) and conversions (i.e. from houses to flats) as well as extensions also contribute to housing development in the borough but they are likely to produce smaller units as they utilise existing stock. Over 50% of residential conversions generate one bedroom units. Family homes such as those containing three bedrooms or more are likely to be generated via new-build developments. 9.2.6 Housing supply in Barnet is currently skewed towards flatted development. Almost 86% of additional housing supply has been provided by flats. There are no flats provided that have over four bedrooms so its potential for family accommodation is limited. Our priorities for family homes are set against this background of a changing population and trends in housing supply. 9.2.7 The Mayor’s Strategic Housing Market Assessment (SHMA) for London suggests that the largest requirement for market as well as social rented housing are 2 bedroom units while the largest requirement for intermediate housing is 4+ beds. Barnet, as part of the North London Housing sub-region has jointly commissioned a Strategic Housing Market Assessment (SHMA). 9.2.8 On the basis of evidence on recent household formation, in-migration, out-migration and projected household dissolution for each borough the North London SHMA has identified housing mix requirements by dwelling size and tenure type over the next five years for Barnet. The dwelling size priorities will guide the mix of housing sought across Barnet and provide a basis for determining the mix of homes on individual sites. Details of how the priorities will be used to guide development proposals are set out in the Development Management Policies DPD. Our dwelling size priorities are for family accommodation across all tenures : For social rented housing –homes with 3 bedrooms are the highest priority For intermediate affordable housing – homes with 4 bedrooms are the highest priority
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For market housing – homes with 4 bedrooms are the highest priority, homes with 3 bedrooms are a medium priority 9.2.9 The North London SHMA bed size requirement model, based on housing affordability according to London Plan definitions, in general supports our prioritisation of family accommodation. It shows that in the market sector there is the need for family homes of at least 2 bedrooms, in particular 4+ beds. This supports our stated levels of priority. In the intermediate and social sector there is also a marked need for 4+ beds as well as 2 and 3 beds. 9.3 Special needs housing 9.3.1 About 31% of older people in Barnet live alone and this proportion is expected to increase. There are households with support needs in all housing tenures in Barnet although the most serious problems are in the rented sectors. According to the 2006 Housing Needs Survey nearly one in three of support needs households live in the private rented sector, about one in five are in Barnet Homes15 stock. Those households with support needs who are also in unsuitable housing are most likely to be owner occupiers who have a mortgage. 9.3.2 Older people in Barnet are more likely to be owner occupiers without a mortgage and more likely to under occupy their properties with 75% of older occupiers living in 3 or 4 bed properties. Many older people households are asset rich but cash poor, and struggle to maintain their homes. National research reveals that the majority of older people would prefer to either remain living in their home, or would prefer accommodation which is part of the ordinary housing stock but is designed to meet their needs. With the numbers of Barnet residents living into their 70s and 80s set to increase we have calculated the amount of housing that will be required to meet the needs of an ageing population. 9.3.3 On the basis of the model recommended in Lifetime Homes: Lifetime Neighbourhoods - National Strategy for Housing in an Ageing Society we estimate that our housing requirements for special needs are changing. Our analysis shows there is an oversupply of traditional rented sheltered housing with a peak of 300 units expected by 2015. It also highlights the need to provide more housing which can provide care and support for the increasing number of lone residents over the age of 75 years. At present there is limited housing choice for older people requiring an alternative to general housing. Sheltered housing for rent accounts for 89% of specialist accommodation for older people. 9.3.4 The Ageing Society assessment shows a continuous requirement for extra care accommodation of about 500 additional homes over the next 15 years. Extra care housing comprises properties which are ordinary flats suitable for older people which provide security and privacy but have a range of facilities on the premises, with support and 24 hour care. We are currently exploring the potential for remodelling the Barnet Homes sheltered housing accommodation as sheltered plus housing, in order to address higher support needs of tenants, and extra care hubs which can provide homes for those in need of supported housing including older people and young disabled people. Such hubs will have the potential to provide support services to a wider community of people. 9.3.5 The Ageing Society assessment also highlights the over-supply of residential care homes in Barnet. We are therefore, in order to widen housing choice, encouraging
15 Barnet Homes is an arms length management organisation which manages housing stock on behalf of the Council
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the remodelling of residential care homes in Barnet. Policy CS 11 - Improving Health and Well Being in Barnet addresses the issue of care homes. 9.3.6 We recognise the importance of helping to promote independence for vulnerable young people, particularly those leaving care, and the need for accommodation to be accompanied by support services. Such services will help provide a pathway away from worklessness and reduce dependency, helping these young people to achieve long term stability within their lives. 9.4 Addressing other housing needs 9.4.1 For many residents the private rented sector provides a flexible option which is more likely to be available in an area of their own choice. The properties are often of a high quality and indistinguishable from properties in owner occupation. 9.4.2 We have commissioned research in the North London Housing Sub Region to map the housing needs of Black and Minority Ethnic (BME) groups. This showed that employment opportunities were much more important to households than housing, but also that social rented housing was seen as the least desirable tenure, acting at best as a stepping stone to other tenures, in particular owner occupation. 9.4.3 Barnet’s 2006 Housing Needs Survey estimated that there are about 18,000 households in the borough that contain at least one person with a recognised support need, and that the greatest need amongst these households was for a wide range of adaptations and improvements to the home. A level access shower unit and a lift/stair lift are the most commonly required. 9.4.4 Lifetime homes are homes specifically designed to address a wide-range of mobility difficulties without being tailored to the specific circumstances of the household. In order to deliver well-designed homes where people will want to live and stay a proposal will be expected to meet Building for Life standards. Through a partnership led by CABE and the Home Builders Federation the Building for Life website sets out 20 criteria which provide a national standard for well designed homes and neighbourhoods. We will also expect that 10% of new homes will be fully wheelchair accessible. 9.5 Affordable homes 9.5.1 Home ownership remains beyond the reach of many residents in Barnet and the numbers in temporary accommodation remains unacceptably high. The private rented sector now provides more homes for people in housing need than the social rented sector. The reduction in mortgage credit has restricted housing choices for many residents with standard home ownership the most expensive tenure. Shared ownership in Barnet is generally cheaper than the cost of renting a similar home privately. High house prices partly reflect the attractiveness of Barnet’s suburban environment but mean that many sections of the community are priced out of market housing. One of the implications is that people may leave Barnet so as to find cheaper housing locations, or choose to live in overcrowded conditions. Some may take on debts that they are unable to afford. There are therefore social, economic and equitable dimensions to the lack of affordable housing in Barnet (and London as a whole). 9.5.2 We are keen to encourage a ‘housing journey’ for as many as possible so as to meet the aspirations of home ownership. Housing and planning policies and strategies can assist in providing greater flexibility between tenures, maximising housing choice on a lifelong pathway from social rented through intermediate and into owner occupation.
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9.5.3 We have completed a Strategic Housing Market Assessment (SHMA) (see para 9.2.4) which identifies future housing requirements for all types of housing in Barnet for the coming 5 years. Once household formation and migration in and out of the borough are taken into account the SHMA estimates a need for 643 new homes per annum (equivalent to 3,215 new homes by 2015/16). This SHMA figure for Barnet to meet its identified housing requirements is significantly lower than the existing annual London Plan target of 1,886 new homes per annum for Barnet, which the Mayor has increased further to 2,025 in the draft revised London Plan. 9.5.4 In order to calculate our affordable housing requirement the SHMA has broken down the all tenure housing requirement to reflect the proportion of households (18.2%) in North London that reside in Barnet. This generates a figure for 1,826 new affordable homes by 2015/16. To meet our identified housing requirements this equates to a 15 year figure of 5,478 new affordable homes by 2025/26 equal to 366 per annum. This is Barnet’s minimum affordable housing target. 9.5.5 Barnet has the fourth highest housing target in London as the borough has the capacity to deliver more housing than is needed locally and is capable of making a significant contribution to London’s overall growth as a Successful London Suburb and Opportunity Borough. In order to make such a contribution and to accord with the draft revised London Plan we will seek to deliver 30% of new homes as being affordable. This equates to a 30% boroughwide affordable housing target. 9.5.6 Barnet’s Affordable Housing Viability Study has tested the ability of a range of sites throughout Barnet to provide varying levels of affordable housing, with and without grant and with various tenure mixes, on a range of sites in various existing uses. For the purposes of establishing an affordable housing target, if a residential scheme with a given level of affordable housing and other planning obligations has a higher value than the existing use value plus a margin to incentivise the owner to release the site for development, the scheme can be judged to be viable. The Study supports a 30% affordable boroughwide housing target as being financially viable. 9.5.7 The Area Action Plans for Mill Hill East and Colindale both set out an affordable housing policy which seeks, in line with the adopted London Plan 50% target, to negotiate the maximum reasonable amount of affordable housing subject to viability. 9.5.8 The results of the SHMA reflect that although Barnet has a small social housing stock the council is pro-active in utilising the private sector to house households in housing need who are unable to access social rented housing. An increased supply of decent housing in the private rented sector is of value to households wanting to live in Barnet but not able to access owner occupation. The SHMA is based on affordability considerations. It does not account for housing allocations policies of local authorities specifically in terms of single and couple households with no other reasonable preference16 criteria such as medical or welfare reasons to be allocated social rented accommodation. The SHMA also fails to understand housing aspirations such as those already identified amongst BME communities. These factors have skewed the SHMA results for intermediate accommodation in Barnet. 9.5.9 The Mayor proposes in the draft revised London Plan that as a long term strategic target 60% of new affordable housing should be for social renting, especially for families, and that 40% should be for the range of intermediate housing products outlined in the London Housing Strategy to meet different needs. We share the Mayor’s objective to widen home ownership through providing a range of different
16 ‘reasonable preference’ defined in Housing Act 1996 (as amended)
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types of intermediate housing and we will seek to ensure that 60% of affordable housing is social rented and 40 % intermediate. 9.5.10 In February 2007 we adopted a Supplementary Planning Document (SPD) on Affordable Housing in order to clearly set out Barnet’s approach and provide detailed advice and implementation guidance to developers, including Registered Social Landlords (RSLs). We will revise the SPD to reflect our Core Strategy policy direction on affordable housing. 9.5.11 The existing policy framework on affordable housing as set out in the adopted London Plan supports an approach where half of the housing provision over the period to 2016 should be affordable and that contributions to affordable housing will be required from all developments of 10 units or more or exceeding 0.4 ha in area. The draft revised London Plan requires boroughs to set a numeric target for the amount of affordable housing needed over the life of their LDFs and separate targets for social rented and intermediate housing. The draft revised London Plan also expects sites that are capable of delivering 10 units or more to provide affordable housing. 9.5.12 Since the introduction of a 50% affordable housing target at 10 units or more in 2006 there has been a reduction in affordable housing delivery in Barnet because of a decrease in proposals for small to medium-sized residential sites. Prior to the economic downturn the viability of these sites appears to have been impacted by inflexible top-down targets and a low trigger threshold which caused developers to either submit residential developments of up to 9 units or landowners chose not to develop a site. Through our Development Management Policies DPD we will set out details on the mechanisms for providing affordable housing and for determining applications. 9.5.13 Affordable housing provision is normally required on-site. In exceptional circumstances it may be provided off-site or through a commuted payment. These exceptional circumstances will be set out in our Affordable Housing SPD otherwise para 3.67 in the draft revised London Plan will apply. 9.6 Gypsies and travellers 9.6.1 Circular 01/2006 states that Core Strategies should set out criteria for the location of gypsy and traveller sites in order to guide the allocation of sites and to meet unexpected demand. We will seek to identify appropriate sites for Gypsies and Travellers through the Site Allocations DPD.
Policy CS 4 - Providing quality homes and housing choice in Barnet We will aim to create successful communities in Barnet by: seeking to ensure a mix of housing products in the affordable and market sectors to provide choice for all households and enable Barnet residents to progress on a housing journey that can meet the aspirations of home ownership seeking a range of dwelling sizes and types of housing including family and lifetime homes that meets our identified housing priorities and does not undermine suburban character or local distinctiveness seeking a variety of housing related support options that maximise the independence of vulnerable residents including young people, people with disabilities, older people, homeless people and other vulnerable adults
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delivering a minimum affordable housing target of 5,500 new affordable homes by 2025/26 and seeking a boroughwide target of 30% affordable homes on sites capable of accommodating ten or more dwellings seeking an appropriate mix of affordable housing of 60% social rented and 40% intermediate for Barnet that will support our objectives of widening home ownership and providing family homes on sites which are suitable for the provision of an element of affordable housing, we may exceptionally accept the provision of off-site housing, or a commuted payment instead of such provision Within the Site Allocations DPD we will seek to identify land to meet the long term needs of Gypsies and Travellers, having regard to: potential of the site for good management impact on local environment, character and amenity access to essential services including water and waste disposal We will monitor the delivery of additional housing against our target of 28,000 new homes by 2025/26 and will seek to maintain supply at the rate necessary to meet or exceed the target. In seeking to maintain the housing supply we will adjust the type and mix of housing sought, having regard to the financial viability of development, the housing market and the needs of different groups.
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10 Protecting and enhancing Barnet's character to create high quality places 10.1.1 Much of Barnet’s character is derived from those areas that are already protected by planning policy – Conservation Areas, Green Belt, Metropolitan Open Land, Sites of Nature Conservation Importance, Historic Parks and Gardens. Our 18 conservation areas include Hampstead Garden Suburb and some other small enclaves of classic suburbs, and attractive former villages such as Mill Hill, Monken Hadley and Totteridge. 10.1.2 Hampstead Garden Suburb is internationally recognised as one of the finest examples of early twentieth century domestic architecture and town planning. It is unique among the Conservation Areas in Barnet in that the Suburb is protected both by the Council’s statutory powers and by the Hampstead Garden Suburb Trust which has separate legal powers to ‘maintain and preserve the present character and amenities of Hampstead Garden Suburb’. 10.1.3 Conservation areas were introduced in 1967 through the Civic Amenities Act. They are defined as ‘areas of special architectural or historic interest,’ the character and appearance of which should be preserved or enhanced. It is the quality and interest of an area, rather than that of individual buildings, which is the prime consideration in identifying a potential conservation area. Outside of these designations and the major housing growth areas identified in the Key Diagram are other areas of high quality residential stock that remain unprotected and at risk from unmanaged growth. Most of Barnet’s suburbs although they contribute to the distinctiveness of the Borough do not merit designation as conservation areas which benefit from statutory protection. 10.1.4 Barnet contains a variety of density levels, buildings and townscape typologies which reflect its historical development. The borough is predominantly suburban in character and is mainly made up from detached, semi-detached and terraced housing. Most of Barnet’s town centres have evolved from villages and have historically grown as a consequence of the topography of Barnet. 10.1.5 Most residential streets in Barnet, including Victorian and Edwardian terraces and interwar suburbs, follow a conventional perimeter block structure which comprises houses facing onto the street with private enclosed gardens behind. This structure is a proven model of urban development and a fundamental element of good design. Infill development and flatted schemes in particular can weaken this relationship between building and street. 10.1.6 For Barnet to grow successfully it is imperative that safeguards are in place to protect and enhance the suburban quality of the borough. There is a need to identify the physical elements within the built environment that give Barnet its character and highlight those areas of the borough that may require further protection from development. 10.2 Barnet’s suburban character 10.2.1 We commissioned the Barnet Characterisation Study to identify those areas of the borough that can accommodate growth and those that should be safeguarded. In examining the built environment we are able to highlight the uniformity of suburban streets and the contribution of suburban detached, semi-detached and terraced houses to local character. The Study identified primary and secondary typologies
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which underline the special local distinctiveness of places that are worthy of protection from development. 10.2.2 The assessment also provides direction for development to places that have lost their uniformity (and most of their character) through incremental and insensitive development. The main thoroughfares of Barnet identified on the Key Diagram are roads that were once dominated by large Victorian and Edwardian buildings. Since 1945 many of these buildings have been demolished and replaced by low rise apartment blocks with flat roofs. Policy CS 3 - Distribution of Growth in Meeting Housing Aspirations highlights these areas as having potential for successful infill development which respects existing plot structure and building massing. 10.2.3 The Barnet Characterisation Study excluded major growth areas, Green Belt and conservation areas and then broke down the remaining urban area of Barnet as shown on Map 6 into five different primary typologies. These are: box development e.g. out of town retail such as Friern Bridge Retail Park campus development e.g. Middlesex University at Hendon cores and town centres e.g. Chipping Barnet residential estates e.g. Sweets Way in Whetstone residential streets e.g. Brunswick Avenue in Brunswick Park
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Map 6 – Barnet Urban Area outside of Regeneration and Development Areas, Conservation Areas and Green Belt
10.2.4 The Study focused on the residential streets of the borough. These streets were characterised by houses facing onto a street, where pedestrian movement and vehicular movement are integrated. Residential streets were assessed in the Study in terms of: density building types and units
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enclosure, street width, setbacks and building height architectural treatment / style / period landscape character / streetscape and topography 10.2.5 On the basis of this assessment six secondary typologies were identified: linear rural – the product of sporadic, piecemeal growth along country lanes or tracks which are often later widened or straightened to take more traffic yet retain their informal character – example - Barnet Road which meanders from Whalebone Park to Barnet Gate, EN 5 suburban periphery - possess a very wide street profile and a leafy and exclusive character. Detached houses are set well back from the highway with substantial mature front gardens. Car parking is integrated into front gardens or private garages. Predominantly in the east of the Borough – example – Oakleigh Avenue, N20 suburban – product of the interwar period, the time of Barnet’s fastest growth and the period which most strongly typifies the borough. The prevailing suburban model was detached or semi-detached. After 1930 more houses were built with garages and driveways. Distributed throughout Barnet – example – Broadfields Avenue, HA 8 suburban terrace – product of a range of architectural styles, including Victorian and Edwardian, as well as inter-war when most were built. Retains strong sense of cohesion and consistency. A smaller variant of speculative semi-detached housing which is a product of municipal or tied housing development. Largely inspired by arts and crafts movement – Distributed in southern and eastern halves of Barnet - example – Berkley Crescent, EN 4 urban terrace – focused mainly in south and east of borough and close to overground rail stations and largely Victorian and Edwardian in origin – example – The Drive, NW 11 flats – purpose built and generally bulkier, typically replacing one or more Victorian / Edwardian period houses within existing street frontages. Distributed along main thoroughfares including A5 and A1000 – example – Lyonsdown Road, EN 5 10.2.6 Through our Development Management Policies DPD we will, in order to protect and enhance Barnet’s distinctive character, provide policy to clarify the key considerations that new design should adhere to. This policy framework for our residential suburbs will be supported by our Residential Design Guidance SPD which will within the context of the six secondary typologies identified in the Characterisation Study provide design guidelines for those places with a consistent and coherent architectural character and design guidance for places where further flatted development will not detract from prevailing character. 10.2.7 The Core Strategy aims to address strategic needs for family accommodation. The main source of supply to meet demand is largely provided by our suburban housing stock. We therefore need to protect such housing within established residential streets which, because of their rhythm and cohesiveness, contribute to local character. 10.3 Barnet’s landscape character 10.3.1 The rolling landscape and valleys and ridgelines as shown on Map 7 have had a key role in defining the character of Barnet. Natural England in their London Regional Landscape Framework identified two landscape character types in Barnet
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Barnet Plateau which has the key natural characteristic of providing long views from remnant healthy commons forms part of a plateau of higher land on the north-west rim of the London Basin. The area extends eastwards to the Dollis Brook through East Barnet, southwards as far as the Welsh Harp Reservoir. High Barnet at 134 metres above sea level is one of the highest points of the Barnet Plateau which retains a field and farmland character to its natural spaces; pockets of traditional countryside remain within the urban fabric of London. Ancient woodland has been retained, as well as remnant heathland communities, and there are spectacular views from many high points along the plateau. Nature reserves and public paths (including the London Loop and Dollis Valley Green Walk) already take advantage of these elevated sites, but much is also to be seen from the major routes into London from the major roads (A5, M1) and railway lines running across the Landscape Type into the city centre. The Dollis Brook, Silk Stream and River Brent form part of a wide network of streams and ponds throughout the area. Finchley Ridge which has the key natural characteristic of ridgetop blocks of ancient woodland on former common land extends north-west across from Finchley to East Barnet. The hills and ridges (including Oakleigh Park which is 94 metres above sea level) are separated by streams flowing south to the Brent River (Dollis Brook and Silk Stream) and east to the River Lea (Pymme’s Brook and Salmon Brook). Hendon, Finchley, Friern Barnet and East Barnet extend along the valley sides and across ridgetops, with linear open space corridors along some of the streams and railway tracks and larger open spaces (amenity grass and trees), golf courses and cemeteries on the valley sides. There are also some small but prominent blocks of woodland (e.g. Coppett’s Wood). 10.3.2 There is a need to reconnect the natural and built environments through the development of green infrastructure which ensures multifunctional greenspaces that benefit communities and biodiversity as well as mitigating climate change. Our approach to developing green infrastructure is set out in Policy CS7. The development of Barnet’s Green Grid is based on the identification of these two distinctive landscape types and our Green Infrastructure SPD will aim to enhance the key characteristics of Ridge and Plateau.
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Map 7 – Barnet’s Topography
10.4 Barnet’s heritage 10.4.1 Barnet has a broad range of heritage assets. We will protect and enhance those heritage assets that are designated as Conservation Areas. Such assets are designated because of their special architectural or historic interest and their character or appearance. Barnet’s Conservation Areas are of varying size and character, ranging from the large garden suburb estates at Hampstead Garden Suburb to historic settlements at Monken Hadley, Mill Hill and Totteridge, a small 19th Century model farm (College Farm, Finchley) and workers cottages at the Railway Terraces in Cricklewood. Our Conservation Areas are shown on the Proposals Map. As part of our historical environmental record we have a rolling programme of conservation area appraisals that provide further guidance on the characteristics of these areas and expect to have complete coverage by 2012. Our aim is that no appraisal is more than five years old. 10.4.2 We also need to protect and enhance our other heritage assets. Barnet has a rich archaeological and architectural heritage which includes the only Historic Battlefield (Battle of Barnet – 1471) in London. Nearly forty sites of archaeological importance containing prehistoric, Roman and medieval remains have been identified across the borough. Barnet contains over 1,300 nationally Listed Buildings, two Scheduled
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Ancient Monuments at Brockley Hill in Edgware and Manor House in Finchley, three registered Historic Parks and Gardens at St Marylebone Cemetery, Avenue House Garden and Golders Green Crematorium. We will consult with English Heritage over proposals affecting these parks and gardens. 10.4.3 As a further reflection of Barnet’s heritage and another element of our historical environmental record we have a Local List (established 1986) which identifies buildings of local importance. We will aim to ensure that the special character of such buildings is protected and enhanced. 10.5 High quality places 10.5.1 As well as preserving this heritage we should also enhance it by creating buildings of equally high quality. High quality design creates places that are welcoming, make people feel safe and are enjoyable and easy to use. 10.5.2 New development should improve the quality of buildings, landscaping and the street environment and, through this improve the experience of Barnet for residents and visitors. We will therefore insist on high quality design throughout the borough. 10.5.3 PPS1 Delivering Sustainable Development says that “policies should promote high quality inclusive design in the layout of new developments”. In accordance with PPS 1 we will not accept design that is considered inappropriate to its context or which fails to take opportunities to improve the character and quality of an area and the way it functions. 10.5.4 The Commission for Architecture and the Built Environment (CABE) advise on well- designed buildings, places and spaces. When assessing urban design we will take into account the general principles set out in By Design. Urban design in the planning system towards better practice, produced by CABE, as well as other current design advice by relevant bodies. 10.5.5 Barnet will have regard to the following overarching principles outlined in By Design to promote and assess successful new development as part of the Development Management Policies DPD and our Residential Design Guidance SPD and suite of Design Guidance Notes. The core design principles are : Character: to promote a sense of place by responding to locally distinctive characteristics and patterns of development Continuity and enclosure: to promote places where public and private spaces are clearly defined and building frontages positively contribute to the urban fabric Quality of the public realm: to promote attractive, safe, inclusive public spaces and routes Ease of movement: to create accessible and permeable places that are easy to move through Legibility: promoting recognisable routes, landmarks and entrances Adaptability: promoting buildings and places that can change use easily Diversity: promoting places with variety and choice through mixes of uses and building types 10.5.6 We also support the principles of the Police flagship initiative Secured by Design. This focuses on crime prevention at the design, layout and construction stages of development by seeking to ‘design out crime’ and recognises the links to creating a mixed and balanced community as further outlined under the section on making Barnet a safer place. These principles work mutually with and support those principles identified above from By Design.
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10.5.7 Barnet also promotes the aims of Building for Life to evaluate the quality of schemes through 20 criteria which consider: environment and the community; character; streets, parking and pedestrianisation; and design and construction. Major housing schemes can be assessed under these criteria. 10.5.8 Good design is safe and accessible, and responds flexibly to the needs of its users. It creates buildings that have minimal negative impact on the environment, during construction and beyond. The construction and use of buildings currently accounts for around half of national carbon emissions and it is therefore vital that new and redeveloped buildings are designed to have a positive impact on their environment. Our Sustainable Design and Construction SPD sets out our approach to these matters. 10.5.9 High quality design also takes account of its surroundings and what is distinctive and valued about the local area. Feedback from Barnet residents on our Characterisation Study is that the borough is considered distinctive as a place because of the sum of its constituent parts clustered around a network of 20 town centres and their suburbs. A description of Barnet’s character is set out above. Most development in Barnet involves the replacement, extension or conversion of existing buildings so taking account of context and local character is particularly important. We will therefore expect the design of new buildings and places to respond to the local area and its defining characteristics and reinforce or create local distinctiveness. 10.6 Tall buildings and Barnet’s skyline 10.6.1 Following the Characterisation Study we commissioned a complementary piece of work on tall buildings. The Tall Buildings Study provides supplementary information on the nature of tall buildings in Barnet and their impact on their surroundings. The Study also provides advice on the issues which should be evaluated when proposals for tall buildings are considered. 10.6.2 The predominant character of Barnet is two or at most three storeys. As Barnet changes over the next fifteen years it is expected that there will be pressure for tall buildings (defined in Barnet as being eight storeys or more) to play a part in new development. While tall buildings offer the opportunity for intensive use, their siting and design should be carefully considered in order to not detract from the nature of surrounding places and the quality of life for those living and working around them. 10.6.3 We need to understand the impact of existing tall buildings in order to guide decisions for the future. Our Tall Buildings Study identified 21 clusters of tall buildings as shown on Map 8. The existing buildings fall into a number of distinct groupings: Historic corridors – The two key historic routes in Barnet are the Edgware Road corridor following the route of the Roman Watling Street along the valley bottom and the A1000 Corridor – the old route of the Great North Road linking the old town centres along the ridge line. Both of these routes have been the focus for continual renewal and intensification over time and include a spread of tall buildings. Town centre clusters – The centres at Finchley Church End, New Barnet and Edgware all feature clusters of taller buildings, helping to emphasise their importance as both services centres and also transport nodes. Residential clusters – There are a number of residential estates which feature tall buildings, typically dating from the 1960s, including Stone Grove and Spur Road, New Brent Street, Claremont Road and Granville Road. Like many other
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London suburbs these towers are generally not well regarded and in many cases are the subject of comprehensive renewal programmes. Beyond the identifiable clusters there are also a couple of incidental residential buildings on Cat Hill, and the eastern end of Friern Barnet Road. Non-residential buildings – away from the key corridors and centres there are a number of other non-residential tall buildings. These include the group of three towers at the police training centre in Hendon and the National Institute of Medical Research establishment on the Ridgeway, along with the offices of Pentland PLC on Squires Lane. 10.6.4 Barnet has a number of attractive views of skyline ridges and/or significant buildings which contribute to the quality of the townscape and the landscape. Map 8 shows the distribution of existing tall buildings (8 storeys and above) and locally important views that contribute to the character of Barnet. These views include : A Mill Field towards Harrow on the Hill B Golders Hill Park towards Harrow on the Hill C Hampstead Heath Extension towards Hampstead Garden Suburb D King George Playing Fields, Hadley Green towards Central London and Canary Wharf 10.6.5 We will seek to ensure that development is compatible with such views in terms of setting, scale and massing and will resist proposals that we consider would cause harm to them. Development will not generally be acceptable if it obstructs important local views or skylines. 10.6.6 The Edgware Road corridor forms an important part of Barnet’s consolidated growth in the next 15 years. As it lies in a valley floor taller buildings along this route are less likely to have a significant impact on key views from elevated vantage points. 10.6.7 The Tall Buildings Study sets out guidance on assessing the impact of any future proposals. Key considerations in assessing proposals for tall buildings include : Proximity and access to green open space to compensate for reduced private amenity space Integration into urban grain establishing a relationship with surrounding street network Use of active street frontages and podium blocks to establish a human scale Impact on important local views although some proposals may contribute to legibility if they don’t impede or block the main subject of the view Impact on historic environment and presumption that tall buildings are not appropriate within or in close to conservation areas and in close proximity to significant listed buildings Access to good public transport access, shops and services Landmark tall buildings should only be located in a place that warrants marking such as a town centre
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Map 8 – Important local views and existing tall buildings
D D
C A
B
10.7 Residential gardens 10.7.1 In June 2010 PPS 3 on Housing was revised to remove private residential gardens from the definition of previously developed land. This revision and added protection has been welcomed as gardens have an important contribution to make to the suburb and its quality of life. Barnet’s Characterisation Study identified the severe impact of off-street car parking and consequent loss of front gardens on the dominant street typologies as set out at para 10.2.5. 10.7.2 The contribution of the development of gardens to housing supply has been factored into the 2009 Londonwide Strategic Housing Land Availability Assessment (SHLAA) which forms the basis for Barnet’s housing target in the draft revised London Plan. According to the SHLAA between 2004 and 2007 about 58 units per annum were
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completed on garden land in Barnet. Table 2 sets out the SHLAA windfall allowance for small sites, equal to 196 units per annum, which with a presumption against garden development in the draft revised London Plan includes only a very small contribution from gardens of about 5 units per annum. As gardens are no longer classified as previously developed land we do not expect them to make a contribution to housing supply in Barnet. 10.7.3 Permissions for the development of garden land have in the past made a contribution to meeting our housing targets. However as Barnet has clearly identified areas for targeted housing growth we will take a robust approach to proposals that involve the loss of gardens and is detrimental to the suburban character that makes Barnet a distinctive place. 10.7.4 Our Development Management Policies DPD will set out a criteria based policy for assessing proposals involving gardens.
Policy CS 5 - Protecting and enhancing Barnet’s character to create high quality places We will ensure that development in Barnet respects local context and distinctive local character creating places and buildings of high quality design that : are safe and attractive and fully accessible provide vibrant, attractive and accessible public spaces respect and enhance the distinctive natural landscapes of Barnet protect and enhance the gardens of residential properties protecting important local views from places within Barnet enhance the borough’s high quality suburbs and historic areas through the provision of buildings of the highest quality that are sustainable and adaptable protect and enhance Barnet’s rich heritage including conservation areas, listed buildings and historic parks and gardens; and London’s only battlefield site The Barnet Characterisation Study forms the baseline for the identification of places with a consistent and coherent architectural character. Within the typologies identified in the Characterisation Study we will through our Development Management Policies DPD and Residential Design Guidance SPD develop a framework to protect and enhance those high quality suburbs in Barnet not protected by Conservation Area designations. Tall Buildings Tall buildings (in excess of 8 storeys) will only be considered subject to the key considerations outlined in the Tall Buildings Study. These considerations include Proximity and access to green open space Integration into urban grain and use of active street frontages and podium blocks Impact on important local views Impact on historic environment Access to good public transport, shops and services Landmark tall buildings should only be located in places that warrant marking
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11 Vibrant suburban town centres 11.1.1 Our suburban town centres are the economic, civic, retail, leisure and transport hubs of Barnet and a good indicator of the economic, environmental and social health of the borough. The network of 20 town centres in Barnet plus Brent Cross contributes significantly to the economic prosperity of Outer London as a whole. Each centre has a special character that contributes to Barnet's distinctiveness and nearly every resident lives within half a mile of a town centre. 11.1.2 In the draft revised London Plan the Mayor has highlighted London’s town centres as a strategic focus for commercial development outside central London and for intensification including through residential development. This represents a change of direction from the existing London Plan which focused on strengthening Central London as the place for commercial activity. Emerging town centre policy should ensure that the evolution of town centres provides improving, convenient and sustainable access to the widest range of competitively priced goods and services. The Mayor considers that town centres have a role in accommodating long term growth pressures and meeting local retail, employment, leisure and civic needs and highlights their contribution to a sense of place and local identity. 11.1.3 Having a variety of town centres with different functions provides diversity and choice for people living and working in the borough and also attracts people from elsewhere. Jobs in retail and other services make up more than half of all jobs in the borough. 11.2 Planning for sustainable economic growth 11.2.1 Planning Policy Statement 4 – Planning for Sustainable Economic Growth (December 2009) sets out national objectives for creating prosperous economies, and in particular to promote the vitality and viability of town centres as important places for local communities 11.2.2 In order to achieve this : New economic growth and development of town centre uses should be focused on existing centres, offering a range of services to communities in an attractive and safe environment, remedying deficiencies in provision in places with poor access to facilities. Ensure competition between retailers and enhanced consumer choice through innovative and efficient shopping, leisure, tourism and local services in town centres Conserve, and where appropriate, enhance the heritage of centres in order to provide a sense of place and focus for the community and for civic activity. 11.2.3 National guidance defines the main town centre uses. This definition includes retail development, leisure, entertainment facilities such as cinemas, restaurants, pubs, offices and theatres, museums and hotels. 11.2.4 Development proposals for main town centre uses in edge of centre or out of centre locations need to demonstrate that the proposal site has been identified through a sequential approach. The developer has to demonstrate that there are no town centre sites to accommodate the proposed development and that they have demonstrated flexibility in terms of floorspace, format and configuration, car parking and scope for disaggregation.
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11.3 Barnet's distinctive town centres 11.3.1 Barnet has a complex pattern of town centres with a hierarchy comprised of Edgware, a major centre, along with 14 district centres, 5 local centres and 10 neighbourhood centres. Map 8 shows the distribution of Barnet's major, district and local town centres. The borough has the most district town centres in London. Our town centres reflect Barnet’s heritage. Parts of the district centres of Burnt Oak, Chipping Barnet, Finchley Church End, Golders Green and Temple Fortune all form part of a conservation area. It is therefore important that the historic environment of town centres is protected and enhanced. 11.3.2 Table 3 sets out the position of town centres in the London Plan hierarchy. In December 2007 we produced a review 'Creating Vibrant Suburban Town Centres in Barnet' which assessed the performance of town centres. The review highlighted that: 95% of residents do their main shopping in Barnet’s town centres three quarters of residents visit town centres in Barnet up to four times a week two thirds of residents use Barnet’s town centres for evening leisure activities Barnet’s town centres are accessible – walking is the second most popular mode of access and those who walk to town centres spend more money there 11.3.3 The review highlighted what could improve the town centres including more retail provision, more affordable car parking, better public realm and less anti social behaviour. It found that in our priority centres: Chipping Barnet is considered to have problems with car parking and negative perceptions on safety Edgware is considered to have poor public realm Finchley Church End is considered to be a popular place for food shopping North Finchley is the second most visited town centre in the borough after Brent Cross and has the second highest financial turnover of town centres In our other district town centres: Whetstone is considered a clean, safe and pleasant place to shop Golders Green and Whetstone have changed their functions from providing a range of comparison and convenience goods to become more dependent on leisure services and evening economy roles, (i.e. restaurants, cafes, bars and clubs) In our local town centres : East Barnet and East Finchley have limited capacity for major commercial growth but retain a ‘village’ feel 11.3.4 In order to provide an overview of the health of the town centre network and to consider the capacity for future retail development in Barnet a Town Centre Floorspace Needs Assessment (TCFNA) was conducted in 2008/09. The 2008/09 Needs Assessment concluded that: Brent Cross and Edgware, the borough’s two largest centres are generally performing well and in line with their respective positions in the retail hierarchy North Finchley, Chipping Barnet, East Finchley, Golders Green, Mill Hill, Temple Fortune and Whetstone district centres are vital and viable and performing their role in the town centre hierarchy well
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Brent Street, Burnt Oak, Cricklewood, Colindale - The Hyde, Finchley Church End and Hendon Central district centres are not as healthy as some of the other centres in the hierarchy with a lower quality retail offer, fewer multiple retailers and more limited comparison goods provision New Barnet is the only district centre which has less than average provision in all retail categories and a number of vacant units contributing to an above average vacancy rate the five local centres in the borough - East Barnet, West Hendon, Friern Barnet, Childs Hill and Market Place - are more comparable in terms of their overall scale and offer which is largely service-orientated. West Hendon appears most dilapidated, deprived and in need of enhancement, something the report recognises Barnet is seeking to address through its regeneration programme the ten neighbourhood centres are also broadly inline with their status at the base of the retail hierarchy 11.3.5 The TCFNA compared the main centres in Barnet, specifically Brent Cross, Edgware and North Finchley with other centres in the sub region. The aim of this exercise was to understand where Barnet’s residents were spending their money. It found that Brent Cross attracted the highest number of shoppers from Barnet, with approximately £570m of comparison goods expenditure, equating to 26.6% of the total available from within the survey area. This was followed by Central London (West End). Other competing centres with Brent Cross, Edgware and North Finchley were Harrow, Watford, Enfield, Wood Green and Borehamwood; although North Finchley attracted the third highest number of shoppers from the survey area. The survey took place before Westfield Shopping Centre in West London opened in October 2008. 11.3.6 In 2010 we updated retail capacity projections in order to take into account new planning commitments granted consent since the 2009 TCFNA, the economic downturn and to help consider investor interest in retail development in Barnet. The update sets out : the total available pot of convenience and comparison goods expenditure; identifies claims on this expenditure (in terms of existing retail space in Barnet); ability to increase sales efficiency; retail planning commitments not yet implemented; and when existing claims on expenditure have been deducted the amount of residual expenditure to support new retail floorspace can be highlighted. 11.3.7 The TCFNA broke the borough down into the following sub-areas West Edgware, Mill Hill and Burnt Oak North New Barnet, Chipping Barnet East North Finchley, Finchley Church End, East Finchley, Whetstone South West Hendon, Brent Cross, Cricklewood South East Golders Green, Temple Fortune, Brent Street 11.4 Retail need and capacity - convenience goods 11.4.1 The TCFNA highlighted good convenience store provision in Barnet. Edgware and all district centres have at least one convenience store, with the larger centres having larger stores and a greater product range. Independent retailers – butchers, bakers, greengrocers and delicatessens - are also present in district centres. There is also good convenience provision in the local and neighbourhood centres. As well
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as eight out of centre supermarkets in Barnet there are 54 local parades and shops in the borough. These local parades and shops supplement the retail offer in Barnet’s larger town centres. 11.4.2 The 2010 Update provides an indication of residual capacity for convenience goods after taking into account existing commitments and identified developments in the pipeline up to 2026. Capacity at Brent Cross – Cricklewood is not expected to come forward until at least 2016 to 2021. The Update concludes that there is residual global capacity to support 2,200m2 net additional convenience goods provision over and above existing commitments in planning consents, and pipeline developments such as those identified in area action plans or development frameworks. We therefore should plan to meet this need in accordance with PPS4 (Policy EC5). This capacity represents a global figure that could be met by several small-scale developments such as extensions and reconfigurations to existing stores across the Borough and does not necessarily suggest capacity for a single large supermarket. 11.4.3 Across the borough capacity is expected to mainly come forward in the East and West. Limited increases in convenience capacity of 7,000m2 by 2021 to 2026 are forecast in the East, and of 2,500m2 in the West. In the North sub-area residual convenience capacity is not forecast to be significant assuming that pipeline development comes forward. The South West is forecast to have on the basis of existing market share an oversupply of convenience goods floorspace before 2026 as a result of the creation of a new town centre at Brent Cross-Cricklewood. However the successful regeneration of Brent Cross-Cricklewood will increase market share and support the new convenience floorspace. 11.4.4 Identification of convenience capacity does not equate to support for new supermarket provision. Capacity should therefore be addressed incrementally. On the basis of the analysis in the TCFNA and 2010 Update there is little quantitative need to plan further significant convenience goods provision in the lifetime of the Core Strategy. 11.5 Retail need and capacity - comparison goods 11.5.1 The TCFNA highlighted good comparison goods provision in Brent Cross, Edgware, North Finchley, Chipping Barnet, Mill Hill, Temple Fortune and Whetstone. There is mixed performance amongst town centres and out of centre retail parks such as Staples Corner and Friern Bridge. 11.5.2 The 2010 Update highlighted that growth in comparison goods expenditure is much lower than previously anticipated in the TCFNA. This is largely due to the impact of the recession. Capacity at Brent Cross – Cricklewood is not expected to come forward until at least 2016 to 2021. The Update concludes that there is residual global capacity to support 16,800 m2 net additional comparison goods provision over and above existing commitments in planning consents, and pipeline developments such as those identified in area action plans or development frameworks. 11.5.3 Across the borough capacity is expected to mainly come forward in the East and West. Limited increases in comparison capacity of under 5,000m2 by 2021 to 2026 are forecast in both the East and South West sub areas, and of 6,500m2 in the West. In the North and South East sub-areas residual comparison capacity is not forecast to be significant. 11.5.4 With this level of residual capacity for comparison goods it is appropriate to plan for modest comparison goods development within Barnet including extensions to stores in town centres. Assuming continued expenditure growth there will be increased
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capacity for comparison goods beyond the Brent Cross Cricklewood development and this should be absorbed by development opportunities in Edgware, North Finchley and Chipping Barnet. Table 3 - Barnet’s network of town centres Metropolitan centres are located mainly in Outer London; these centres serve wide sub regional catchment areas and offer a high level and range of comparison shopping. They typically have over 100,000 m2 of retail floorspace, including multiple retailers and department stores. Metropolitan centres also have significant employment, service and leisure functions. Although Brent Cross has limited convenience and service provision, this will be addressed in the redevelopment of the Brent Cross Cricklewood area which will create a new town centre which will have a Metropolitan role. Major centres are important shopping and service centres, often with a borough-wide catchment. Their attractiveness for retailing is derived from a mix of both comparison and convenience shopping. Some major centres, which have developed sizeable catchment areas, also have some leisure and entertainment functions. Major centres normally have over 50,000 m2 of retail floorspace. Edgware has a wide variety of retail provision serving a major centre. District centres have traditionally provided convenience goods and services for more local communities and are distributed across Barnet. Some district centres have developed specialist shopping functions, often as a result of their lower rents. Developing the capacity of district centres for convenience shopping is critical to ensure access to goods and services at the local level. Many of Barnet’s district centres are linear in nature, which may need to be consolidated to make more efficient use of land and transport capacity. Neighbourhood and more Local centres provide services for local communities and are of cumulative strategic significance. Local centres have a comparable service-orientated offer of shops. Neighbourhood centres occupy the base of the retail hierarchy and are largely service orientated with cafes, takeaways, health and beauty services, newsagents and small convenience stores.
11.6 Brent Cross - Cricklewood 11.6.1 Brent Cross is London’s only regional shopping centre and Barnet’s largest shopping location, but it is not yet designated as a town centre in the London Plan. A Development Framework for the area was adopted in 2005 and plans are now in place, including specific development proposals to regenerate Brent Cross - Cricklewood. Planning processes are now at an advanced stage for the specific development proposals to regenerate Brent Cross Cricklewood. Progress on these proposals is set out in Section 7 of the Core Strategy. 11.6.2 The Core Strategy and the saved UDP policies envisage the conversion and expansion of the existing ‘out of centre’ Brent Cross Shopping Centre into a mixed use town centre which will extend across the A406 North Circular Road and will be well-integrated to the rest of the Brent Cross - Cricklewood area. 11.6.3 The proposals comprise a net addition of 55,000 m2 gross comparison retail floorspace as part of the new town centre which is equivalent to the quantum established by the adopted UDP. Comparison floorspace will feature up to 61,545 m2 of new floorspace with 6,545 m2 of existing floorspace within Brent Cross Shopping Centre to be decommissioned.
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11.6.4 The draft revised London Plan has identified Brent Cross Cricklewood as a potential Outer London Development Centre (OLDC). With its greater than sub regional reach in its retail strategic functions Brent Cross Cricklewood has the potential for strategically significant growth in retail as well as office development. An OLDC is considered a location more appropriate to accommodating the scale and nature of growth likely to come forward, to minimise need to travel and to complement existing structures. 11.7 Town centre frameworks 11.7.1 In order to create the right environment to enable and facilitate private sector investment and growth in Barnet's town centres we produced a Suburban Town Centre Strategy in April 2008. This focused on eight objectives: improve the appearance of Barnet’s town centres ensure effective control of parking arrangements manage development opportunities and changes in planning use effectively effectively regulate the street trading environment maximise take up of trade waste contracts improve residents’ feelings of safety and security improve access to information on town centres ensure consistency with other corporate programmes 11.7.2 The TCFNA identified the capacity of Barnet’s centres to accommodate new development by 2026. Key opportunities for substantial enhancement in comparison retail offer are located within Edgware and North Finchley. Chipping Barnet provides opportunities to increase comparison goods provision. The Suburban Town Centre Strategy identified centres where more detailed planning frameworks will support the potential for future growth and manage anticipated change. These are: Chipping Barnet Edgware North Finchley Finchley Church End 11.7.3 A number of these centres are also located at significant public transport nodes and it is vital that plans and proposals for these centres are taken forward in partnership with Transport for London. 11.7.4 The town centre frameworks will focus on main town centre uses – retail, leisure, entertainment (cinemas and theatres), offices, museums and hotels and : address the mixture of land uses, primarily for retail (at ground floor level) but also including residential, leisure, employment and community facilities and will develop a strategy for the town centre, which provides a framework for making decisions on current and future proposals, in a manner that facilitates the overall improvement of the area create a strategy, which promotes and maximises existing and future movement opportunities including public transport and pedestrian and cycle connections encourage high quality buildings and public spaces throughout the centre to help foster local distinctiveness promote a safer and more secure environment in which all sectors of the community can have a sense of ownership of and pride in the town centre
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create a clear role for the town centre in the context of the planned growth at Brent Cross and other centres identified for change identify and take account of the opportunities and constraints for sustainable development 11.7.5 Frameworks will be subject to community engagement and will inform the next stage of the Core Strategy and the development of the Site Allocations DPD. 11.7.6 In addition to the priority town centres identified above there are also accessible town centres such as Golders Green, New Barnet and Whetstone where a planned approach including planning briefs or frameworks will be appropriate for managing development opportunities. 11.7.7 Development opportunities have also been identified at Burnt Oak, Colindale – the Hyde and Cricklewood that will enhance the vitality and viability as well as overall attractiveness of these centres. Further opportunities for a second wave of town centre enhancement will be pursued at smaller centres that attract private sector interest or have been highlighted for priority action. 11.8 Neighbourhood centres and shopping parades 11.8.1 Suburban Barnet also contains a large number of neighbourhood centres and local parades of shops. These shops fulfil a vital need for many residents without access to a car or who are reluctant to travel to larger centres. Neighbourhood centres can provide local services in sustainable locations, particularly for lower density suburbs, such as hairdressers and cafes and these cater for different communities. These centres make a major contribution to the sustainability and cohesion of neighbourhoods. 11.9 Role and function of town centres 11.9.1 The recession has not caused the decline of town centres but exacerbated existing problems, many of which were already indentified in “Creating Vibrant Suburban Town Centres in Barnet” in December 2007. Many high streets are “outmoded” and have been “struggling for years, lacking the investment or the vision to offer customers a compelling choice and so failing to compete with better experiences in neighbouring towns or retail parks”. Online retail has also had an impact. 11.9.2 While several national foodstore operators have returned to the high street with small convenience stores in recent years there has still been a continued polarisation towards larger town centres and the provision of larger stores in these larger centres. Where smaller centres have been unable to diversify their offer or create niche markets they have suffered. 11.9.3 We recognise that the continued vibrancy and diversity of services offered in our town centres, neighbourhood centres and local parades of shops depends on access by all who want to use them. A balance must be found that encourages people to use local businesses in preference to out-of-town retail developments and this will be reflected in the provision of parking which encourages turnover whilst retaining facilities for loading and the disabled. Careful management is also required to protect Barnet’s town centres from commuter parking by people travelling into Central London. 11.9.4 We are committed to ensuring that planning is focussed on supporting vibrant town centres through:
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Redefining the role of each town centre based on the function which will provide the most potential (e.g. thereby allowing changes of use to support this redefined role) The creation of larger shop units to meet demand from major retailers The granting of temporary permissions to reduce, in the short term, the number of vacant properties Developing a planned strategy for housing intensification, and social infrastructure improvement for the edges of town centres, where applicable 11.9.5 One of the key principles guiding the Future Shape Programme is to develop a new relationship with citizens. While the Council recognises its role in supporting the borough’s town centres and ensuring their continued success, a range of other stakeholders from retailers, residents and investors have a role at least as significant to play. We therefore support more active engagement, networking and self-help among key players across the town centre network. 11.9.6 A 2009 report on town centres by the London Development Agency (LDA)17 recognises that “if long-term changes in the operation of the retail market are negatively affecting town centres, conceptualising them as primary retail driven places can impede innovative solutions, whereas other town centre functions (leisure, local services, meeting place, employment space) might offer equal or more potential”. It is also considered that as a result of retail decline, some town centres have contracted and created an opportunity for unplanned incremental development of a quality that has added little value to declining town centres. The LDA study considers that “edges of town centres would profit from more proactive planning and design strategies so that these locations are strengthened…”. The decline of retail, particularly outside the core of town centres should therefore be seen as an opportunity to consider a planned strategy for housing development utilising the Town Centre Frameworks and planning briefs for managing development opportunities in other town centres. 11.10 Other town centre uses 11.10.1 Barnet currently has a good provision and choice of commercial leisure and tourist facilities. The market largely determines the need for additional facilities such as cinemas, bingo, bowling, health and fitness and hotels. There is scope for centres to improve their evening economy offer and provision of restaurant and public house uses within secondary frontages. 11.10.2 If planning policies are very restrictive with regard to allowing changes in use, for example, from retail to businesses, it can result in high vacancy rates and a decline in the vitality of the centre as workers’ and visitors’ disposable income supports town centre and retail activities. There will always be changes taking place in the network of town centres, particularly in a borough as large as Barnet with such a diversity of centres and anticipated growth. People’s habits change, businesses flourish or decline at the national, city and local level, and certain factors such as the fear of crime fluctuate. 11.10.3 In order to maintain the vitality and viability of town centres, PPS 4 recommends that retail floorspace is concentrated within the core of commercial locations and that other town centre uses such as leisure, offices and community facilities are allowed on the fringe of the core. The boundaries of Barnet’s network of town centres have
17 'SEVEN - Housing Intensification in seven South London town centres'
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not been specifically defined although the primary and secondary retail frontages of major and district centres are shown on the Proposals Map. In order to clarify between town centre and edge-of-centre sites we will undertake further work on frontages and boundaries. 11.11 Evening economy 11.11.1 It is important that town centres in Barnet maintain and enhance their provision of pubs and restaurants and other leisure facilities in order to encourage a healthy evening economy. We do however recognise the attractions of Central London and competing centres outside Barnet. Town centres at Cricklewood and Whetstone have been identified in the Draft London Plan as night time economy clusters of more than local significance. North Finchley is also a popular evening destination attracting the largest market share of Barnet households visiting pubs and clubs. The development of Brent Cross Cricklewood will include a range of bars, restaurants and other leisure activities which are designed to bring life to the area in the evenings. The Development Management Policies DPD will address diversification of the night time economy in order to enable a mix of activities and contribute to making public spaces in town centres feel safe. 11.12 Cinemas 11.12.1 There are four cinemas providing 21 screens within the borough. Barnet’s town centres have suffered from multiplex cinemas in out of centre locations such as Cineworld at Staples Corner and Vue at Great North Leisure Park. A cinema is proposed as part of the Brent Cross- Cricklewood proposal. Apart from this proposal cinema provision is considered adequate to meet current demand. 11.13 Health and fitness clubs 11.13.1 According to the TCFNA the town centres of North Finchley and Mill Hill have proved popular locations for health and fitness clubs. Such facilities form an appropriate use as part of mixed use schemes and contribute to a healthy evening economy. 11.14 Hotels 11.14.1 Most of the existing hotels in Barnet are not in town centres and this is contrary to PPS 4. According to the GLA Hotel Demand Survey (2006) there is a net additional rooms requirement of 500 rooms by 2026. This forecast assumed high growth rates and was produced prior to the global economy downturn. The Brent Cross Development Framework includes a mix of leisure uses including hotel and conference facilities. 11.15 Markets and affordable retail units 11.15.1 We support a dynamic, competitive and diverse retail sector which also provides for small and medium sized enterprises. Markets at Burnt Oak (Watling Market), Chipping Barnet (Barnet Market) and North Finchley (Lodge Lane Car Park) serve a multitude of roles. They have long historical associations with the development of these places as retail centres ranging from 800 years at Barnet Market to over 70 at Watling Market in Burnt Oak. They can also provide greater retail choice and affordability as well as help to meet the needs of Barnet’s diverse communities. 11.15.2 The availability and accessibility of local shops are an important aspect of 'Lifetime Neighbourhoods'. It is also important that the retail sector is diverse and successful and that new independent shops are given the opportunity to establish themselves as part of the retail offer in Barnet’s successful town centres. In accordance with
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Circular 5/05 – Planning Obligations we will investigate the potential for utilising S106 contributions from major retail developments (over 2,500 m2) to ensure provision of affordable retail units. We will provide further guidance on affordable shops through our SPD on Contributions to Enterprise, Employment and Training.
Policy CS 6 – Promoting Barnet's town centres In order to promote competitive town centre environments and provide consumer choice we will realise development opportunities for the town centres of Edgware, North Finchley, Finchley Church End, and Chipping Barnet. We will pursue the individual planning objectives for each centre as set out in their Town Centre Frameworks through the delivery of environmental, design, transport and community safety measures we will promote successful and vibrant centres throughout Barnet to serve the needs of residents, workers and visitors and ensure that new development is of an appropriate scale and character for the centre in which it is located In order to create a distinct and attractive business offer we will promote Brent Cross/Cricklewood as a new metropolitan town centre and an Outer London Development Centre following successful mixed use regeneration which delivers an additional 55,000m2 (net) of comparison floorspace and 370,000 m2 of office floorspace as part of a mix of uses that accords with the London Plan and the saved suite of UDP Policies on Brent Cross- Cricklewood we will promote the distribution of retail growth to meet the capacity for an additional 2,200 m2 of convenience goods floorspace across Barnet by 2021 -2026. The majority of the convenience capacity arises in the East sub-area (centred on the District Centre of North Finchley) and West sub-area (centred on the Major Centre of Edgware) beyond 2016. We will therefore not plan further significant convenience goods provision before 2026 we will promote the distribution of retail growth to meet the capacity for an additional 16,800 m2 of comparison goods floorspace across Barnet by 2021 -2026. The majority of this capacity arises in the East, West and South West sub-areas. On basis of continued expenditure growth we will in addition support comparison goods provision in Edgware, North Finchley and Chipping Barnet we will ensure that food, drink, entertainment uses as part of a healthy night time economy in our town centres do not have a harmful effect on residents and the local area we will ensure the efficient use of land and buildings in all town centres, encouraging a mix of compatible uses including retail, managed affordable and flexible workspace, leisure and residential that add to the vibrancy of the area whilst respecting character we will take a planned approach to development opportunities in Golders Green, Whetstone and New Barnet we will through our Site Allocations DPD promote development opportunities in our smaller District Centres at Burnt Oak, Colindale – the Hyde and Cricklewood that enhance the overall attractiveness of these centres we will, in order for them to compete with other centres and particularly out of centre retail parks and shops, support retail uses in town centres by improvements to the public realm, the public transport network, short-trip parking and accessibility by cyclists and pedestrians we will seek to protect and enhance more ‘local’ neighbourhood centres and parades of shops in terms of their potential contribution to sustainable suburbs and shopping; and
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we will seek to protect existing markets as part of the retail offer of Burnt Oak, Chipping Barnet and North Finchley town centres and, where appropriate, use S106 contributions to ensure the provision of 'affordable shops' in new retail development.
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Map 9 – Town centres and employment sites
Employment Sites Site Name Site Name 15 Grenville Place 1 Oakleigh Road South 16 Bunns Lane 2 Garrick Industrial Estate 17 Granard Business Centre 3 Brunswick Industrial Park 18 Colindale Business Park 4 Lancaster Road Industrial Estate 13 Falkland Road Industrial Estate 5 Barnet Trading Estate 14 Pricklers Hill 6 Queens Road Inustrial Estate Local Town Centres 7 Mill Hill Industrial Estate Site Name 8 Hadley Manor Trading Estate A Childs Hill 9 Bittacy Business Centre B Market Place 10 Connaught Business Centre C East Barnet 11 Finchley Industrial Estate D West Hendon 12 Colindale Technology Park E Friern Barnet
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12 Enhancing and protecting Barnet’s open spaces 12.1.1 Barnet is one of the greenest boroughs in London with 28% of its area designated as Green Belt (2,466 ha) and 8% as Metropolitan Open Land (MOL) (690 ha). Barnet has over 200 parks and open spaces covering 848 hectares and 67 sites of nature conservation importance plus a site of special scientific interest at Welsh Harp Reservoir. There are 1192 ha of public open space in Barnet covering 14% of the borough. This includes those parts of Green Belt and MOL which are accessible to the public. 12.1.2 The Sustainable Community Strategy highlights the importance of Barnet’s green open spaces and that we all want to live in an attractive, clean and green environment. Our open spaces and outdoor sports and recreational facilities are an important element of the borough’s character and careful protection of these assets is fundamental to delivering the spatial vision. Our open spaces form an integral part to the character of 11 of Barnet’s 18 Conservation Areas. 12.1.3 Reflecting its outer London location many parts of Barnet have relatively easy access to open countryside. However people need green spaces close to where they live and green infrastructure (a strategic network of green spaces) can provide for a natural and healthy environment. A network of well designed, well maintained open spaces and outdoor sports and recreational facilities is vital to Barnet’s success as a place to live. 12.1.4 Our policy on open space seeks to ensure that the growth identified in Policy CS 3 - Distribution of Growth in Meeting Housing Aspirations will be supported by increases and improvements in open space provision including outdoor sport and recreation opportunities, and that development makes provision for biodiversity 12.1.5 Barnet's Open Space, Sport and Recreational Facilities Needs Assessment provides evidence on the existing open space network and its intrinsic values. It provides a basis for improving the quality and potential uses of open spaces to cater for increasing future demand arising from growth and the changing needs of the community. 12.1.6 The success and value of an open space network is dependent on three principal factors: the quantity, quality and accessibility of open spaces. National guidance on the production of an assessment of open space, sport and recreational facilities recognises that delivering the objectives of PPG 17 – Planning for Open Space, Sport and Recreation will depend much more on improving and enhancing the accessibility and quality of existing spaces rather than simply on new provision. The Assessment identifies quality as the overriding factor that affects the public’s satisfaction with the open space network followed by distance and the ability to access open spaces. The Assessment therefore provides an analysis of the quality and accessibility of existing open spaces and sets out a series of recommendations for improvement. In addition we also recognise that our parks serve as a vital focal point for formal and informal community activities including fairs and festivals. 12.1.7 The Assessment will enable us to set within the Development Management Policies DPD local space standards for public parks, children’s play facilities, outdoor sports provision, and natural and semi-natural green space (including Metropolitan Open Land). In applying these standards it is recognised that open spaces are multi- functional and any one space may fulfil a range of purposes.
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Map 10 – Public open space deficiency
12.1.8 The Assessment highlights opportunities for improving the quantity and quality of open spaces in Barnet, including better linkages in order to provide a more integrated and coherent network of open space. 12.1.9 Map 9 identifies those areas of the borough that are deficient in public open space. The more rural northern half of Barnet has the largest area of public open spaces but these are the least accessible. This provides a context for levels of formal provision and does not reflect informal use of open space nor patterns of usage of Barnet’s or neighbouring borough parks such as Hampstead Heath and Canons Park. 12.1.10 The Assessment review of areas of deficiency in public open space supported those areas identified in Barnet’s 2006 Unitary Development Plan. Areas highlighted as having a deficiency in district parks ie being more than 1.2 kms from such a park included North and East Finchley, Brent Cross – Cricklewood and Edgware. Areas highlighted as having a deficiency in local parks ie being more than 0.4 kms from such a park included New Barnet, Oakleigh Park, Edgware, North Finchley, Mill Hill and Hendon.
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12.2 Barnet’s parks 12.2.1 Barnet has a total of 73 public parks ranging from Hamilton Road Playground (0.04 ha) to Monken Hadley Common (41 ha). These are categorised according to the public open space hierarchy in the London Plan. A park covering 20 hectares or more is a District Park. Local Parks cover less than 20 hectares. Barnet has seven District Parks and 66 Local Parks providing a total area of 488 ha. 12.2.2 The primary green space assets in the borough are the 16 Premier Parks. With a Premier Park located within a one mile radius of almost every home in the borough these parks are managed to provide a high quality, recreational experience with an appropriate range of safe and accessible facilities to appeal to all ages (ranging from outdoor gyms at Oak Hill Park to skate parks at Friary Park). 12.2.3 Barnet has 57 other public parks which are not Premier Parks. A wider green space management and improvement approach is required to meet increasing need and demand for quality open space. Following publication of the Assessment we will develop a Parks and Open Spaces Strategy. 12.2.4 The Assessment highlighted that although many parks are of high quality, in particular the Premier Parks, there are a number of parks where improvements could be made to improve their attractiveness. Measures to improve quality will be taken forward through our Parks and Open Spaces Strategy. 12.2.5 Accessibility to open space can be improved through pedestrian and cycle links as well as bus routes where practicable. The Dollis Valley Green Walk and the Capital Ring are strategic walking routes that cross Barnet. The 17 km long Dollis Valley Green Walk incorporating Brent Park, Hendon, Windsor Open Space Finchley, Riverside Walk / Gardens, North Finchley, and Brook Farm / Wyatts Farm, Whetstone provides an important green corridor for wildlife and recreational use through the heart of Barnet. Dollis Valley Green Walk has received funding from the Mayor of London's Help a London Park scheme to improve the quality and safety of London's parks. The Capital Ring is a key green route that encircles London. The routes that go through Barnet are Section 10 (South Kenton to Hendon Park) and Section 11 (Hendon Park to Highgate).
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Map 11 – Barnet’s green spaces and play areas
12.2.6 In order to tackle deficiencies and under provision of public open space and to ensure adequate new open space is provided in Barnet’s growth areas we will ensure additional on-site open space or improvements to accessibility. Barnet’s growth areas contain proposals to increase the supply of, as well as enhance, public open space in Barnet. The three main growth areas will create 18.5 ha of additional public open space as well as enhance provision at Bittacy Hill Park, Clitterhouse Fields, Montrose Park and Grahame Park. There are no significant opportunities for new open spaces in North and East Finchley. The priority in these areas will be to improve access to existing parks.
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12.2.7 The concept of a regional park in North West London has been highlighted by the Mayor in the existing London Plan and the North West London to Luton Corridor Prospectus for Sustainable Co-ordinated Growth. The area extending from Welsh Harp along the River Brent and its tributaries (Dollis Brook and Silk Stream) together with the Dollis Valley Green Walk has been identified as having potential for designation as a regional park. 12.3 Children’s play facilities 12.3.1 Having more high-quality and safe places to play is a priority for both children and parents, both in terms of physical health and emotional wellbeing. As with parks, children’s play facilities are not evenly distributed through Barnet. The distribution of play provision for children is set out in Map 10. The Assessment identified 49 sites in the borough that provide formal play space for children, this equates to 0.5m2 of space per child under 15 years. 12.3.2 Less than half of the parks in Barnet have play provision for children. Overall 54% of Barnet’s area is not within 600m of formal equipped areas for play and a significant increase in facilities is required as Barnet’s population gets younger. The Assessment highlighted the need to improve access through public rights of way to play areas at Deansbrook Play Area, Fairway Children’s Playground and Edgwarebury Park. It also identified 15 open spaces in areas with deficiency that have potential to provide play equipment 12.4 Playing pitches and outdoor sports 12.4.1 Barnet is relatively well provided for in terms of distribution of playing pitches with 277 pitches covering nearly 160 hectares. There is 0.51 ha of playing pitches per 1,000 residents and almost the entire borough is within 1.2km of a playing pitch. Despite good geographical coverage there is demand for additional provision because of issues related to the quality of the existing pitches (mainly due to poor drainage) and the lack of accessibility. The Assessment identified 13 sites that are not accessible in terms of walking, cycling, bus or rail. We are developing a Playing Pitch Strategy in accordance with Sport England’s guidance ‘Towards a Level Playing Field’. This will guide future provision and management of new sports pitches in Barnet. 12.4.2 The borough is considered to have a good distribution of bowling greens and tennis courts mainly within parks. Provision for basketball and netball courts is concentrated in the west of the borough around Burnt Oak. Further work is required on assessing distribution of these facilities outside of open spaces. 12.5 Natural and semi natural space 12.5.1 Barnet has a rich wildlife resource. Barnet’s natural space covers rivers, open water, grassed areas, forest / woodland, natural heath, scrubland, common and wetland. The Assessment identified 743 ha of natural greenspace which has public access including 10 sites that are larger than 20 hectares. The distribution of natural space is set out in Map 11. There is 2.36 ha of publicly accessible natural greenspace per 1,000 residents and as with parks there is a significant variation in distribution between the north and south of the borough.
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Map 12 – Barnet’s natural spaces
12.5.2 The borough contains one Site of Special Scientific Interest – the Welsh Harp Reservoir - into which the River Brent and Silk Stream flow. The Reservoir was created in 1835 as a water supply for the canal network and is jointly managed by Barnet and Brent council with British Waterways. As the largest expanse of water in Barnet it provides an important recreational as well as a rich wildlife resource. The Reservoir together with the River Brent, Silk Stream and Pymmes Brook form part of the Blue Ribbon Network for London which has its own set of policies in the London Plan. 12.5.3 In line with London Plan standards the majority of the Borough is within 1km of Metropolitan or Borough Grade Nature Conservation sites and 500m of any nature
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conservation site. The Assessment identified fifteen nature conservation sites that have poor accessibility in terms of walking, cycling, bus or rail and highlighted that access could be enhanced by improved signage. 12.5.4 Consideration should be given to the need for species to move between different types of habitats along our rivers and streams as well as green corridors. We want to maintain networks of natural habitats by avoiding their fragmentation and isolation and will seek to identify ‘missing links’. We will use the Site Allocations document to identify sites where enhanced or new measures to support biodiversity and nature conservation may be supported as part of proposals. Even where no additional open space is being created we will ensure that the development is designed in a way to enable it to replace and enhance biodiversity. This could include green roofs and green facades. Our SPD on Sustainable Design and Construction sets out specific design principles in relation to biodiversity. 12.5.5 We will favour the provision of habitat for species identified in the London Biodiversity Action Plan. 12.6 Green infrastructure and the Green Grid 12.6.1 Our open spaces have to be multi-functional if they are going to meet the needs of our communities. Green infrastructure can provide a range of environmental benefits including flood water storage, sustainable drainage, urban cooling and access to shady outdoor space. It also provides habitats for wildlife and through the creation and enhancement of ‘green corridors’ should aid the natural migration of species responding to the changing climate. 12.6.2 Emerging national guidance requires us to set out a strategic approach for the creation, protection and management of networks of green infrastructure. Infrastructure should be provided where it will reduce the impact of climate change and retain, enhance or create green corridors that enable linkages between rural, urban fringe and urban green spaces
12.6.3 Preparation of Barnet’s Infrastructure Delivery Plan has identified the need to look at development of an integrated borough-wide strategy for delivering green infrastructure in order to make most effective use of all potential capital and revenue funding sources available, particularly in relation to open spaces. 12.6.4 In the draft revised London Plan the Mayor has set out his support for an All London Green Grid and the development of an enhanced network of green spaces that can serve to shape and support sustainable communities, respond to the challenges of climate change and deliver an improved quality of life. 12.6.5 The Green Grid approach provides a strategic framework for creating, improving, managing and maintaining high quality Green Infrastructure. As a reflection of its topography Barnet will form part of two Green Grid networks – Lea Valley and Finchley Ridge, and Brent Valley and Barnet Plateau. We will work with neighbouring authorities to establish Area Frameworks for these Green Grid Areas. The Frameworks will facilitate planning, management and maintenance of the Green Grid and integrate it within the LDF highlighting and accelerating the delivery of key green infrastructure projects. The Frameworks will provide the basis for securing revenue funding to create new spaces and maintain them in perpetuity. 12.7 Trees 12.7.1 Trees are important for their historic and aesthetic values. They also provide habitat, shading, cooling and air filtering. With 36,000 street trees in Barnet, the second highest number in London, they make an important contribution to quality of life. The
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Mayor wants to utilise Borough Tree Strategies to increase tree cover in London, with 2 million additional trees by 2025. Barnet's existing Tree Strategy will be subject to review in 2011. 12.7.2 The Watling Chase Community Forest forms part of Barnet’s green infrastructure. The community forest established in 1991 covers an area of 188 km2 and extends from the northern part of Barnet into south Hertfordshire. The aim of the Community Forest as set out in the Watling Chase Forest Plan, is to see much of the area under positive and appropriate management by 2025. This will include a substantial increase in trees and woodland achieved through management of existing woodlands and new planting. 12.8 Sustainable food production 12.8.1 Our agricultural land and our allotments may also have potential for sustainable food production which can contribute to our economy and healthier lifestyles as well as reduce the number of food miles between producer and consumer. Barnet provides 6% of London's farmland18. The Outer London Commission highlighted that farms have the potential to play a greater role in the economy of Outer London. The Barnet Federation of Allotment and Horticultural Societies lists 46 allotment sites in Barnet providing a total of over 4,000 plots. Allotments are an important asset within Barnet, providing a wide range of benefits including protecting open space leisure and healthy exercise as well as providing healthy low cost food production for communities and the environment. 12.8.2 We recognise the benefits for health, community cohesiveness and our local landscape from making better use of our land for food growing. We support the Mayor’s Capital Growth Initiative to create 2,012 new community food growing spaces in London by end of 2012 and are keen to promote sustainable local food production given our significant and well used allotment holdings and extensive former agricultural lands.
Policy CS 7 - Enhancing and Protecting Barnet’s Open Spaces In order to create a greener Barnet we will enhance and protect Barnet’s Open Spaces by: protecting designated open spaces, including Green Belt and Metropolitan Open Land, and other suitable land with the potential to be used as open space Meeting increased demand for access to open space and opportunities for physical activity, by tackling deficiencies and under provision through: securing additional on-site open space or other open space improvements in the identified growth areas including 8 ha of new provision at Brent Cross – Cricklewood, 5.5 ha of new provision at Mill Hill East and 5 ha at Colindale improving access to open spaces particularly in North and East Finchley and other areas of public open space deficiency identified by Map 9. We will seek to improve provision in these areas of deficiency with the objective of increasing the area of the borough that has access to district and local parks in accordance with the London Plan criteria securing improvements to open spaces including provision for children’s play, sports facilities and better access arrangements, where opportunities arise, from all developments that create an additional demand for open space
18 The Mayor's Food Strategy, 2006
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maintaining and improving the greening of the environment through the protection of incidental greenspace, trees, hedgerows and watercourses enabling green corridors to link Barnet’s rural, urban fringe and urban green spaces protecting existing Sites of Nature Conservation Importance and working with our partners including the London Wildlife Trust to improve protection and enhancement of biodiversity in Barnet ensuring that development protects existing site ecology and makes the fullest contributions to enhancing biodiversity, both through on-site measures and by contribution to local biodiversity improvements; and enhancing local food production through the protection of allotments and support for community food growing including the Mayor’s Capital Growth Initiative In supporting new green infrastructure we will:
as part of the All London Green Grid work with neighbouring authorities to establish Area Frameworks as the basis for identification, creation and management of new green spaces as part of: Lea Valley and Finchley Ridge Green Grid Area Brent Valley and Barnet Plateau Green Grid Area Reflect the policies and objectives in the Watling Chase Forest Plan when assessing development proposals in the area covered by the Community Forest
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13 Promoting a strong and prosperous Barnet 13.1 Business opportunities and economic prosperity 13.1.1 Knowledge and learning are central to economic growth and competitiveness. Barnet’s residents are highly qualified with close to 40% of those of working age being qualified to NVQ4+. These high qualification levels are reflected in the residents’ occupational profile, with the vast majority of Barnet’s residents working in Managerial and Professional occupations – the knowledge economy19. Currently our highly qualified residents commute out of Barnet to access job opportunities in the West End and the City and the wider London region. Increased opportunities for home-working and improved access to local business support services will reduce the need to travel. 13.1.2 Barnet’s future economic growth is projected to be increasingly in service-orientated employment and high level knowledge-based jobs with growing numbers of higher skilled workers in financial, retail, business and professional services. The availability of commercial land and buildings together with investment in transport and housing which allows workers, suppliers and customers to access and be accessed by Barnet’s businesses is crucial to economic growth. 13.1.3 Economic development is defined in PPS 4 – Planning for Sustainable Economic Growth as providing employment opportunities, generating wealth or producing or generating an economic output or product. Economic development therefore includes development within the B Use Classes, public and community uses and main town centre uses. PPS 4 maintains a focus on a service based economy and requires a robust evidence base to understand existing business needs and likely changes to the market. Plans have to take into account “new or emerging sectors likely to locate in their area, such as those producing low carbon goods or services.” Plans are also required to plan positively for the “location, promotion and expansion of clusters or networks of knowledge driven or high technology industries”, 13.1.4 A number of significant changes within the borough will support economic growth and prosperity over the next 15-20 years. A new economic hub at Brent Cross - Cricklewood will emerge as the “Gateway of North London”. The creation of over 20,000 new jobs and a new Metropolitan Town Centre will transform the sub regional economy of north London. The hub will be well connected by new and improved transport links to Central London, including a new station on the Midland Mainline and Thameslink routes and form one of the critical nodes on the emerging North West London – Luton Coordination Corridor. Another significant economic node on this growth corridor is Colindale where an Area Action Plan will support planned growth of 10,000 new homes and 1,000 jobs over a 10-15 year period. 13.1.5 As part of our evidence base we commissioned an Employment Land Study to examine supply and demand for office and industrial floorspace in Barnet. As a town centre use the Town Centre Floorspace Needs Assessment also examined the office market. The distribution of safeguarded employment sites including town centres is shown on Map 8.
19 The knowledge economy is characterised by the rise of professional, managerial and scientific and technical occupations in all sectors - the local futures group - the London knowledge economy - 2006
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13.2 Barnet’s office market 13.2.1 Barnet is not considered to be a strategic office location at present. The borough has about 446,000 m2 of office floorspace focused in six major office locations (Edgware, Hendon, Golders Green, and Finchley Church End town centres and The Hyde and North London Business Park) as well as along the major thoroughfares of the A5 and A1000. The majority of office stock is of a secondary nature ie above retail or as part of a mixed used development with a predominance of units under 465m2. The office stock is not modern, over 60% of office floorspace in Barnet is pre-1970. 13.2.2 An analysis of office take-up shows most demand coming from small businesses and larger organisations already based in Barnet. Take-up is dominated by leasing transactions for under 232 m2, including tenants such as small insurance companies, solicitors, building firms and publishers. The dominance of these smaller transactions, means that rents are high on a £ per m2 basis. Take-up is more healthy than with comparable boroughs such as Harrow suggesting that access to M1 and North Circular Road may account for popularity of small office units. 13.2.3 The regeneration of Brent Cross will create a new commercial district including a new office quarter. The Station Quarter at Brent Cross - Cricklewood will form the commercial hub for the new development. It will include approximately 370,000 m2 of office space which would provide accommodation for an estimated 17,000 employees. The predominant use within this zone is business and employment with some retail and other commercial uses at ground floor and some residential at upper levels. The draft revised London Plan recognises that Brent Cross – Cricklewood will become a strategic office location which, with its retail offer, will justify designation as an Outer London Development Centre. 13.2.4 It is likely that the development at Brent Cross Cricklewood will meet a large part of the growth in service-orientated employment. The majority of demand is for smaller units which is consistent with the borough’s current office stock profile. Barnet’s town centres will continue to play a role in supplying flexible and affordable office space to smaller businesses including home workers. 13.3 Barnet's industrial land 13.3.1 Barnet's industrial20 stock totals about 437,000 m2 and is focused on the 20 designated industrial estates as shown on Map 8. The quality of stock is assessed below. As with its office stock demand has been local rather than attracting any significant numbers of large ‘in-coming’ occupiers and take-up is dominated by lease transactions for small space. 13.3.2 Proposals for Brent Cross – Cricklewood will involve the displacement of existing industrial uses and distribution and warehouse uses. This includes the Claremont Way Industrial Estate. We will work with developers to ensure that such uses receive assistance in relocating. Provision for relocation of the waste transfer facility and rail freight facility together with business, industrial and warehouse and distribution uses will be made on the land bordered by the A5 and Midland Main Line railway (as identified in the Brent Cross – Cricklewood Development Framework). 13.4 Future employment growth 13.4.1 Based on predicted employment growth of between 12 and 17% between 2009 and 2026 the Barnet Employment Land Study has, using employment land densities and
20 Industrial land comprises light industry, research and development, general industry, storage and distribution
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employment plot ratios, converted growth into a demand for land of 13.4 to 13.5 ha between 2009 and 2026. To meet this additional demand we will direct new business development to Brent Cross – Cricklewood and then to the regeneration and development areas of Colindale and Mill Hill East. There is capacity for the forecast level of provision to be exceeded, subject to market conditions over the plan period. We anticipate that smaller scale business development will also be attracted to our town centres 13.5 Safeguarding of employment land 13.5.1 The Employment Land Study identified 18.8 ha of land that forms recognisable clusters of employment uses in Barnet and assessed whether this land is fit for purpose, accessible and marketable. The assessment considered that 36% of employment land was fit for purpose and should be safeguarded, a further 61% was considered to also justify safeguarding as locations where employment uses remain viable but may require refurbishment and improvement to retain future employment. The dominance of small occupiers in Barnet means that there is a strong case to safeguard those sites which would appear to meet local demand. The clusters that scored poorly tended to be on constrained sites in predominantly residential areas. Only 3% of land was considered worthy of release for alternative uses. 13.5.2 The Mayor’s Supplementary Planning Guidance on Industrial Capacity (March 2008) sets out a framework for planning, monitoring and managing surplus employment land in London over the next 20 years. Barnet is classified as a borough that is suited to limited transfer of designated employment industrial sites to other uses. Our approach is therefore to safeguard and support those locations that are capable of addressing the needs of modern business. Our Development Management Policies DPD will provide more detail on the safeguarding of employment sites. 13.6 Supporting local business 13.6.1 In order to develop a sound understanding of local economic conditions to inform strategies and strengthen the economic role of local authorities we are required to produce a Local Economic Assessment. This will provide an update to the evidence produced as part of the Employment Land Study. 13.6.2 More than 12% of the adult population are self-employed, the highest level of any London borough. Barnet has traditionally had a high level of entrepreneurship with significantly higher levels of VAT registrations than most adjoining Boroughs and comfortably higher than comparable outer London Boroughs (SQW study 2006) The survival rate of VAT- based businesses is similar in Barnet as in London as a whole: 22% of businesses have traded for less than 2 years and 36% for at least 10 years. 13.6.3 Self-employment is a work pattern usually associated with creative industries such as leisure software, music and performance, fashion and advertising. The creative industry sector although not as significant in size as finance and business services does exhibit a need to cluster around town centres and access generic business support as well as start-up and specialist accommodation. Research by GLA Economics reveals that Barnet is home to over 2,000 firms engaged in creative industries, one of the highest levels in Outer London. The Arts and Creative Industries in North London – Strategy and Action Plan 2006 -2012 identified clusters in the southern and eastern halves of Barnet with a particular focus on North Finchley town centre. 13.6.4 We are developing a better insight into the experience of businesses in Barnet, particularly in our town centres, and we will continue to use S106 planning obligations imaginatively to support local business. In order to support small and
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medium-sized enterprises in Barnet and enable them to be more aware of, and bid for, local construction contracts we employ a ‘Business Links Officer’, funded by contributions from S106 towards employment and skills needs. 13.6.5 Providing affordable and flexible workspace helps small to medium businesses, particularly home-workers in the knowledge economy and those engaged in creative industries, to continue their valuable contribution to Barnet’s prosperity. As well as safeguarding existing employment sites we will encourage the provision of employment floorspace, particularly in town centres, to meet the changing needs of modern business. Through S106 on new development we will ensure the provision of affordable premises such as enterprise hubs / innovation centres that are flexible and attractive to home-workers and small businesses. Such facilities can provide access to services and business advice which would otherwise be beyond their resources. Providing a range of facilities in the borough will enable start-ups as well as existing businesses to grow and prosper within Barnet. Our SPD on Contributions to Enterprise, Employment and Training will provide guidance on when and how we secure new provision for affordable workspace. 13.6.6 We also need to be more flexible with regard to the temporary re-use of vacant premises, such as shops and offices, particularly in our town centres. Such accommodation can provide short term opportunities for enterprise and should provide opportunities for the creative industries to cluster and bring added value and activity to town centres. 13.7 Further and higher education and skills training 13.7.1 Barnet aims to be recognised as the home of a leading university with an international reputation. Middlesex University has relocated its main campus to Hendon – The Burroughs with new state-of-the-art teaching and research facilities and a resources centre alongside its existing buildings. Middlesex University has a vital role to play in providing higher educational opportunities at its Hendon Campus and in supporting local businesses through applied research and consultancy, including Knowledge Transfer Partnerships21, and supporting small and medium enterprise start-ups and incubator units. 13.7.2 We also work in partnership with Barnet College and new facilities are on site in High Barnet and planned for Colindale as part of the regeneration of that area. 13.7.3 Although many of Barnet’s residents are employed in highly skilled jobs that contribute to London’s knowledge economy and have above average qualifications, it is important that there is a range of local jobs that suit different levels of skills and abilities. The types of service jobs found in Barnet can usually provide flexibility so that people can work part-time or from home. 13.7.4 The London economy is likely to become more reliant on high levels of skills and knowledge-based competencies. We need to enhance the levels of skill and qualification attainment among residents, in order to respond to the ongoing industrial and occupational shifts and fully exploit emerging initiatives within Barnet. We will continue to support the Construction Training Initiative operated by Notting Hill Housing Trust in order to help our unemployed residents develop the essential skills that developers will require in delivering new housing in Barnet. 13.7.5 Although in Barnet the percentage of working age population with little or no skills (7%) is well below the national average of 14% this is not evenly spread. Within
21 Knowledge Transfer Partnerships involve collaborative projects for carrying out research or developing products.
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Burnt Oak Ward 46% of the population has low or no qualifications. Tackling worklessness is an important issue within Barnet and we recognise the need to create a pathway to sustainable employment. Research by GLA Economics states that the main barriers to accessing work are: poor access to job opportunities lack of basic employability skills employer attitudes including discrimination and specific barriers such as childcare costs Within Barnet there are some pockets particularly on the western side where residents have qualification and skills gaps. Without action such residents may not benefit from the job opportunities being created by new development. 13.7.6 Although the proportion of 16-18 year olds in Barnet not in education, employment or training (NEET), is lower than national levels it accounts for nearly 1 in 20 of that age group. In terms of getting NEET young people job ready an Employer Engagement Strategy for Barnet is being developed and ongoing links with employers have continued to be strengthened through the Education Business Partnership. Through S106 planning obligations we will seek to overcome barriers to accessing employment in Barnet by increasing opportunities for training for residents providing them with the skills to access the forecast increase in jobs. 13.7.7 Key partners in the Borough, including the Council, Barnet College, Middlesex University and Job Centre Plus, have formed the Skills Development Group to progress the skills development agenda. A borough-wide Skills Development Plan has been agreed by the Group in order that the Borough can respond to the emerging opportunities and to ensure that business skills requirements are being met. The action plan focuses on the following strategic issues: reduce the number of young people becoming Not in Education Employment or Training (NEET) improve opportunities for work related learning and alternative curriculum improve labour market capacity for Barnet residents resulting from new development opportunities improve opportunities for those at risk of being excluded from the labour market. 13.7.8 These strategic issues are addressed through five ‘Action Areas’: increase the supply of basic employability skills develop vocational and intermediate skills develop a workforce development gateway enhance entry to employment increase the supply of construction skills 13.7.9 We are working with development partners across all of the regeneration projects to identify what skills sets are required and also encouraging the use of local labour. Section 106 agreements for each of the regeneration schemes require the development of an employment and training strategy for the area, including apprenticeships and training in areas such as construction. The employment and training strategies are linked to the Skills Development Plan and are developed in consultation with the member partners of the Skills Development Group.
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Policy CS 8 – Promoting a strong and prosperous Barnet The Council and its partners will ensure a strong and prosperous Barnet that provides opportunity for economic advancement. We will support Barnet residents in accessing work by: Delivering 1,500 new jobs in our growth areas of Colindale and Mill Hill East by 2021 and a total of 20,000 new jobs in Brent Cross-Cricklewood by 2026 Attracting business growth as part of Brent Cross - Cricklewood with further provision in the other growth areas and town centres to meet the forecast demand for business space of 13.5 ha by 2026 requiring major developments to provide financial contributions and to deliver employment and training initiatives in line with the Skills Development Plan; working in partnership with the Skills Development Group in delivering the skills agenda required for a growing borough in a successful London suburb We will support businesses by: safeguarding existing employment sites that meet the needs of modern business. encouraging development that improves the quality of existing employment provision encouraging new mixed use commercial floorspace in our priority town centres (Edgware, North Finchley, Finchley Church End and Chipping Barnet) where access to public transport is good in order to support small to medium sized enterprises new employment provision should include a range of unit sizes and types such as affordable and flexible workspaces and home working hubs through the Skills Development Group building an understanding about the experience of local businesses and their skills needs encouraging partnership working between providers of further and higher education and local business
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14 Providing effective and efficient travel 14.1 Introduction 14.1.1 One of the key purposes of Barnet’s Core Strategy is to ensure that the high quality of the borough is preserved whilst at the same time ensuring that the anticipated growth of this London suburb can be achieved and remain successful through the delivery of the necessary social and physical infrastructure. Barnet considers that it is crucial to match people’s needs to transport provision at lowest cost. Providing effective and efficient travel services and facilities across the borough is essential to delivering successful growth in Barnet, which will help ensure that economic prosperity is maintained and enhanced. Map 13 – Transport links in Barnet
14.2 Getting around Barnet 14.2.1 Barnet residents make 914,000 trips per day, travelling in total nearly 4.7 million kilometres (kms). This represents 5% of all trips in London and each person makes 3.1 trips per day and travels 15.7 kms, compared to the London average of 2.6 trips and 14.9 kms respectively. Shopping and personal business each account for 29% of trips, followed by work and education, at 21% and 12% respectively. Over half the journeys made are wholly within the borough (52%), 11% are to Enfield, Haringey and Waltham Forest, 32% to other places in London and 5% to locations outside London.
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14.2.2 Map 13 shows that the borough is well served by public transport for radial travel. As well as underground and national rail services into Central London it has a network of bus services, which in some cases provide high frequency services on multiple routes along radial corridors, such as the A5, A41/A502 Brent Street, A109 and B550 Colney Hatch Lane. 14.2.3 The borough has high levels of car ownership and as a suburban location is reliant on the car for many necessary journeys, nevertheless many residents use public transport. The car is the dominant transport mode in outer London and will remain so for the foreseeable future. Half the trips made by Barnet residents are by car and motorcycle. Nearly 80% 22of our residents live in households with a motor vehicle, yet 62% use public transport at least once a week with one third using it daily. Whilst many residents choose to commute by public transport (41% of journeys to work23), there is clearly a strong desire to own and use a car for other trip purposes, particularly in the more outer suburban areas of the borough. 14.3 Barnet's road network 14.3.1 Barnet is a growing borough and the population is forecast to increase by 14% by 2026. Poor transport accessibility and barriers to movement are major inhibitors to growth and investment in radial links is a priority including to existing town centres which themselves require improvement. There are significant issues with many radial and other links across Barnet and we are exploring opportunities for improving these as part of our regeneration schemes and through long term approaches to improving strategic transport infrastructure. There are significant anticipated increases in movement in Barnet's regeneration and development areas which will require investment in highway infrastructure as well as access improvements to existing public transport interchanges, for example, within the Brent Cross Cricklewood (BXC) and Colindale regeneration areas. Major improvements are also required on the strategic road network, especially the A406 (North Circular Road) at Staples Corner, Henly’s Corner and Golders Green Road junctions. While the Staples Corner scheme will be delivered as part of the BXC regeneration, the other major improvements are currently envisaged to take place beyond the life of the existing TfL Business Plan (2018). Securing all possible external funding is and will be a priority. 14.3.2 Currently 49% of trips are by car as driver or passenger24 and as shown by Map 14 traffic congestion is particularly acute along the A5 corridor and on the A1, A598, A1000, A41 and A406 North Circular Road, the significant east-west link in north London. 14.3.3 Packages of investment to reduce delays to all road users are being pursued through partnership working with key stakeholders such as TfL and major developers for the regeneration schemes, and through securing Local Implementation Plan (LIP) and other funding for particular measures. Further details of these improvements are set out in Barnet’s Infrastructure Delivery Plan. A more comprehensive improvement at Henly’s Corner beyond that of the currently proposed TfL scheme is seen as essential to securing the long term growth and prosperity across Barnet.
22 Barnet residents’ survey 2007 - 78% of residents have a motor vehicle in the household. 62% use public transport at least once per week – 33% use it daily. 23 2001 Census – usual travel to work excluding those working mainly at or from home 24 London Travel Demand Survey (2007-2009 Combined Household Survey database) as reported to the borough in MTS IMPLEMENTATION TARGETS - DATA REPORTS 2008 (2008/09) (Nov 2009)
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Map 14 – Traffic congestion hotspots in Barnet
14.3.4 In his revised draft London Plan (October 2009) the Mayor has indicated (in tables 6.1 and 6.2) his intention to establish a parking regime which balances the environmental desirability of reducing car use with the need to provide attractive viable development in town centres, while recognising that many people will continue to travel by car, particularly in Outer London. The Mayor intends to introduce new standards for cycle parking, and for parking spaces and power points for electric cars in order to provide support for these forms of transport. 14.3.5 Our approach to parking provision is to accept the need for management and restraint, but to apply it carefully and appropriately, and in all cases reflecting local circumstances. Parking standards in new developments will vary across the borough to reflect the transport, particularly the public transport, accessibility of individual locations. The standards set out in the Development Management Policies DPD will therefore contain a degree of flexibility with the intention that car parking provision will reflect the needs and travel habits of our residents and businesses and appropriate development-related new transport infrastructure will be provided. 14.4 Barnet's public transport network 14.4.1 Public transport trips make up some 20% of journeys by Barnet residents (11% by bus, 7% by underground and 2% by rail, with taxi contributing a further 1%).
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14.4.2 Map 13 shows the rail services that Barnet residents use. Underground rail services in Barnet and on its borders (Northern and Piccadilly Lines) are key to public transport provision as they provide direct connections to central London. First Capital Connect provide rail services on the Thameslink Line and on the Great Northern route. The Council is supportive of the principles of Step Free Access at all rail stations in the Borough and strongly supports the Thameslink Upgrade programme. Whilst welcoming the ongoing improvements, Barnet is opposed to any future downgrading or splitting of the Northern Line. 14.4.3 The bus is an element of the public transport network in Barnet. The network as shown by Map 15 is focussed on moving people on the radial corridors (paralleling the Northern Line). In general bus journeys in Barnet are slower than car journeys, even when the time taken to park is taken into account. Map 15 - Barnet's bus network
14.4.4 Through ongoing regeneration in the North West London - Luton Corridor, particularly in the vicinity of Brent Cross Cricklewood (BXC) and Colindale regeneration areas, and around development opportunities presented by public transport nodes such as Finchley Central and Edgware we are seeking to deliver improved public transport services and facilities. Improved bus provision (in terms of configuration as well as capacity) will have to play a key role in meeting the transport needs of current and future residents (up to 374,000 by 2018 from 335,000 in 2008,
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and to 421,000 by 2031, a 30% increase from 2006). A number of new and extended bus services are being pursued through the BXC and Colindale regeneration schemes, including better links between the two areas. 14.5 Walking and cycling in Barnet 14.5.1 Walking is an important mode of travel for short journeys (29% of all trips25), but cycling tends to be limited (1%), at least in part due to the topography of Barnet and its rolling landscape of valleys and ridges. There is a good network of cycle routes signed along quiet roads, and some good off-road routes across the borough. 14.6 Investing in infrastructure 14.6.1 Despite having the fourth highest housing target in the revised draft London Plan (22,550 new homes between 2011 and 2021) Barnet does not benefit from the levels in public transport investment seen in other parts of the capital, such as the Olympic sites, Crossrail and Central London. We therefore take a realistic approach towards use of the car, public transport, walking and cycling based on sound evidence including our accompanying infrastructure delivery programme, planned improvements in the TfL Business Plan and Network Rail’s Thameslink Enhancement Programme which is strongly supported. We are also pursuing innovative models of financing significant transport improvements including tax incremental models. 14.6.2 Increasing travel demand without proportionate infrastructure investment across the modes leads to increased congestion and reduced reliability of transport networks and services. Reducing car use as part of an overall transport strategy can tackle congestion particularly in urban areas. In suburban areas such as Barnet this is more challenging (except in some town centres) as the lower public transport accessibility limits transport choice for many journeys. Nevertheless the reallocation of road space from general traffic to specific modes is an alternative that has been adopted, such as along the A5 corridor. Increased priority for public transport helps make it more attractive, but does so at the risk of further increasing congestion and can displace traffic elsewhere on the highway network to less appropriate routes. This is contrary to Barnet’s approach which is to ensure that traffic uses appropriate routes, and in particular that through traffic uses the main road network. Any need for additional bus priority measures will therefore be carefully considered by the council. 14.6.3 Given the existing transport issues outlined above, our four inter-related and complementary transport priorities to provide effective and efficient travel in Barnet are: Ensuring more efficient use of the local road network; Taking a comprehensive approach to tackling the school run; Delivery of high quality transport systems in regeneration areas; and More environmentally friendly transport networks. 14.6.4 As part of our evidence base for the LDF and the LIP further work has been undertaken to develop these priorities into a comprehensive approach to improving transport in Barnet, as set out below. Barnet considers it is at the forefront of suburban transport policy and will engage where others wish to benchmark against the Barnet approach. We will also consider adopting the approaches of others where proven to work elsewhere and, crucially, be applicable to Barnet.
25 London Travel Demand Survey, 2006-09 as reported in Developing a Sub-regional Transport Plan Interim report on challenges & opportunities 18/02/2010 – TfL planning
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14.6.5 The LDF is also supported by the TfL North London Sub Regional Transport Study (SRTS) which is looking at the cumulative impact of all the planned growth and committed schemes across the area. The assessment year is 2031 and the study is accounting for all the major regeneration proposals in Barnet, together with our aspirations for major improvements along the A406, and other proposals for strategic improvements to the movement networks in the borough. Planned developments and growth in adjacent boroughs, such as at Wembley is also accounted for. Taken together this helps ensure that the study, and the Barnet LDF, are both robust pieces of work. 14.7 Ensuring more efficient use of the local road network 14.7.1 Without large scale capital investment in new capacity we have to make better use of the existing road network. Complementing the other elements of our approach we have prioritised the reduction of congestion, the main concern of Barnet residents, and welcome the Mayor of London’s proposals to smooth the flow of traffic. Tackling the causes of peak hour congestion will help to make the local road network operate more efficiently for all road users. We will work with TfL to proactively review the existing traffic signals with the aim of rationalising their provision where they are no longer needed or where there are clear benefits in doing so, and removal is a safe and practicable option, for example by replacing pelican crossings with zebra crossings. Moreover, any new traffic signals will only be introduced as part of new developments on an exception basis, justified on road safety grounds and / or to reduce congestion at key locations where traffic is becoming increasingly delayed in peak periods. 14.7.2 We will continue to invest in improvements to the condition of roads and footways in the borough, and seek developer contributions towards this where appropriate. Maintenance and utility work can have a serious impact on the transport network, so we will continue to work hard to co-ordinate such activity and minimise the impact on all road users. We will also continue to ensure that construction related traffic is effectively controlled through the requirement for developers to adhere to Construction Management Plans. 14.7.3 Barnet’s road network is classified within a hierarchy based on the functions each type of road provides to road users and adjacent land uses. The Council will seek to ensure that roads are used appropriately according to their status in the defined hierarchy, and details will be set out in the Development Management Policies DPD. 14.7.4 Barnet continues to seek through development management work to ensure that appropriate enhancements are made to the affected road network in order to accommodate the new users, whilst at the same time helping to address existing pinch-points, particularly in regeneration areas including BXC, Colindale, Mill Hill East, Stonegrove and West Hendon. Examples include A406 junctions with the A5, M1 and A41 as part of BXC, A5/Colindale Avenue junction improvement as part of Colindale, various new and improved junctions in the Mill Hill East area, Canon’s Corner roundabout improvements in Stonegrove and A5 on-line improvements and removal of the Perryfield Way gyratory system as part of West Hendon, 14.7.5 Parking is also key to ensuring that the road network is used efficiently and Barnet will continue to manage a parking regime for new developments which recognises that many residents will continue to own and travel by car. Complementing the use of car clubs which can be successful in suburban locations and which are starting to appear in Barnet, we will seek appropriate parking ratios in locations with the highest public transport accessibility, chiefly in town centres and regeneration areas. On street parking management and controls will continue to be applied appropriately
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taking into consideration local conditions and issues, and to ensure the free flow of traffic, although there will be a presumption against any new controlled parking zones (CPZs). 14.7.6 With increased on-line services and growth of home based workers, combined with more flexible working practices, we expect the pattern of commuter travel to change further as more people are able to travel outside the busiest times. In accommodating a change from the conventional 'Monday to Friday, 9 to 5' pattern we are supportive of improved e-infrastructure and access to business services and managed workspaces in town centre locations that may come forward as part of planning applications. The Council is leading by example with flexible working policies and equipping staff to enable them to work remotely. 14.7.7 To help improve the efficient use of the Barnet road network we will work with TfL on improving the local bus network, with the aim of more closely and efficiently matching demand and capacity, and in particular seek to ensure that buses use appropriate roads and do not impact unduly on residential streets. We will also seek a review of the night bus network and to provide appropriate facilities for coaches, private hire vehicles and taxis. 14.7.8 Safety of the road network also remains a major priority. Accident rates in Barnet have fallen dramatically since 2000 (136 people were killed or seriously injured in road traffic accidents in the borough in 2008 compared with 261 in 200026) and we will continue, where resources allow, to deliver local road safety schemes to target particular locations with high numbers of personal injury accidents. We will seek to ensure that any new transport interchanges are designed to help address personal safety and reflect the principles of Secured by Design. 14.8 Taking a comprehensive approach to tackling the school run 14.8.1 We have identified the school run as a key factor in contributing to peak hour congestion (accounting for approximately 30% of car trips by Barnet residents in the AM peak) which negatively impacts on the Council’s ambition of keeping Barnet moving. Action is required to manage peak period travel if worsening transport network conditions are to be avoided and we will continue to take positive action in this area centred around our work with schools to develop and implement progressive school travel plans. 14.8.2 We will ensure that School Travel Plans in Barnet are both monitored and effective, and that if necessary remedial measures are taken if targets are not met, and encourage the dissemination of good practice among the borough’s schools. To date Barnet has been very successful in starting to address this major issue, achieving a 12% reduction in the numbers of pupils driven to school. It is important to note that Barnet is a comparatively safe borough and parents and guardians concerns about child safety are largely unfounded (nearly 2% of accidents in London, which involved the death or serious injury of a child, happened in Barnet in 2009). However much more remains to be done and some STPs are only partly adhered so we will prioritise this area of work. In particular we will take more direct action through seeking to increase the availability of funding to implement complementary traffic management improvements in the neighbourhoods around our schools including taking positive action to prevent any pupil parking, promoting car sharing and improved cycle parking facilities, and will encourage more children to walk and cycle to and from school.
26 TfL Road Safety Unit, from data reported to the police in accordance with the Stats 19 national reporting system
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14.9 Delivery of high quality transport systems in regeneration areas 14.9.1 Barnet's aspirations for consolidated growth are set out at CS1 (Place Shaping Strategy), CS2 (Distribution of Growth) and CS4 (Town Centres). Development along the North West London to Luton Corridor, provides opportunities to deliver high quality transport improvements in a planned and structured manner, and closely co-ordinated with other transport authorities, including adjacent boroughs. The Major growth areas in the Borough are at various stages of the planning process and are supported by their associated Area Action Plans, Development Frameworks, Transport Assessments, Travel Plans, negotiated planning (S106) and highway agreements, planning conditions and delivery plans. These demonstrate how these mixed use developments, with phased delivery and monitoring programmes will deliver travel requirements in a way that is manageable and appropriately funded, with residential development being located in close proximity to everyday services and facilities. Outside these areas we will continue to require Transport Statements, Transport Assessments and Travel Plans as part of the on-going Development Control process. Good design and best practice will be enshrined in this process, as detailed in the Development Management Policies DPD. Through detailed assessment work for the approved Area Action Plans in Colindale and Mill Hill East, and through the Transport Assessment for BXC we will continue to ensure that transport capacity is closely aligned with the predicted demand. Concentrated mixed use development is generally being sought that will help reduce the need to travel longer distances. 14.9.2 A sponsored project, building on the “London to Luton corridor Prospectus”, is planned to ensure all relevant authorities work together on a co-ordinated and focused approach to the A5 corridor. Barnet is also investigating the possibility of a high quality bus scheme along the A5, which is being explored through the North London SRTS. 14.9.3 Expected traffic movements in these growth areas have resulted in investment being pursued for access improvements to existing public transport interchanges to help achieve a step change in the public transport accessibility level. For example, within the BXC, Colindale and Mill Hill East regeneration and development areas, where the relevant bus, train and tube stations are all planned to be improved. Work to date has also highlighted the need for improvements on the strategic road network, especially the A406 (North Circular Road), A5 and A401 including Staples Corner interchange for A5 / A406. Major upgrades to the Thameslink rail corridor and the Northern Line programmed. All of the above is being cumulatively assessed as part of the SRTS. At BXC efficient use of the transport system will be assisted by utilising existing spare and future new planned capacity on the rail network, particularly in the contrapeak direction. 14.9.4 A number of well served town centres, such as Edgware, Golders Green and Brent Cross Shopping Centre are already public transport hubs and there are opportunities to increase the density of activity within these centres so that people can access local services by various means of transport. At BXC in particular the regeneration scheme includes a new bus station at the Shopping Centre, many new and enhanced bus services, including better bus links between BXC and Colindale and neighbouring boroughs, a bus-based rapid transit system, improvements at the existing Brent Cross tube and Cricklewood train stations and a new railway station on the midland mainline with many passengers expected to reverse commute and arrive in the ‘contra-peak’ direction, from Central London in the morning, helping to utilise spare rail capacity. Planned development and enhancement programmes in town centres will provide opportunities to improve the public realm, public transport
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services, short-trip making via walking, parking and servicing arrangements and, particularly, accessibility; helping to make town centres more attractive places to visit. Town centres are also prime locations for enhancement and new development opportunities are being explored in places such as North Finchley, Finchley Church End and Golders Green. 14.9.5 We support measures to efficiently and effectively manage freight activity arising from new development and existing buildings. Delivery & Servicing Plans are intended to improve the safety and reliability of deliveries, help reduce congestion and minimise costs and impact. Consolidation Logistics Plans are intended to effectively manage all types of construction freight vehicle movement. 14.10 More environmentally friendly transport networks 14.10.1 Traffic is a significant contributor to poor air quality in Barnet with the highest levels of oxides of nitrogen and particulates concentrated around major roads. In Barnet the issue of climate change and the contribution of traffic to it will be mitigated through support for mixed use developments, particularly in our regeneration areas and by comprehensively tackling the school run. Major improvements such as the Thameslink and Northern Line upgrade programmes and the new mainline train station at Brent Cross will also have a significant positive impact. 14.10.2 However with the car remaining the most dominant form of travel in outer London, then the way in which they are powered needs to be made more efficient, using fuels which are less polluting, particularly in terms of carbon emissions. For electric vehicles to become more popular, infrastructure will be required to allow such vehicles to be recharged. We are keen to encourage greater numbers of electric vehicles to help keep Barnet moving while minimising emissions and recognise that although some people will have access to off-street parking at home there will be a need for charging facilities in public places. We await new legislation permitting the installation of charging points on-street. In the meantime we are ensuring that the private sector funds the necessary infrastructure where this can be achieved and support the implementation of charging points within private areas of new and existing developments. 14.10.3 Travel planning associated with major developments also has a role to play in this priority. At BXC for example the developers have submitted a framework travel plan for all land uses as part of the outline application which includes mode split targets for each of the seven proposed phases of development, and the Council has established a management regime to ensure that the developer monitors the actual mode split and phases of development can only come forward if the targets are being met or additional transport measures are proposed to ensure as far as possible that the mode split targets are met. 14.10.4 Efficiencies in the freight sector can also contribute to a reduced need for travel and in turn reduce CO2 emissions. These can be achieved by the promotion of Freight Quality Partnerships, Delivery and Servicing Plans, Construction Logistics Plans and Consolidation Centres which form part of the applications for many of our major sites and regeneration schemes, notably at Brent Cross. Freight Quality Partnerships are voluntary partnerships between the Freight Industry, its customers, Local and Regional Authorities, and other stakeholders who meet regularly with the aim of developing an understanding of local distribution issues and promote constructive solutions, reconciling the need for access for goods and services with environmental and social concerns. 14.10.5 Public transport operations require facilities such as depots, interchanges and bus standing areas in order to operate flexibly and efficiently and the Council will seek
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suitable opportunities to provide these as development sites come forward and as part of our Site Allocation DPD. Policy CS 9 – Providing effective and efficient travel We will promote the delivery of appropriate transport infrastructure in order to support growth, relieve pressure on Barnet's transport network and reduce the impact of travel whilst maintaining freedom and ability to move at will. We will ensure that new development funds infrastructure (through Section 106 and other funding mechanisms) that enables Barnet to keep the existing traffic moving and cope with new movements both by all modes of transport. Ensuring more efficient use of the local road network In order to enable traffic to flow more smoothly we will prioritise the reduction of congestion, including through encouraging trips to route according to the road hierarchy, the implementation of development related schemes that also address pinch-points, a review of traffic signals, parking management measures and more efficient freight movements. We will continue to invest in improvements to the condition of roads and footways in the borough to ensure that the local road network operates efficiently and safely, and seek to improve co-ordination of maintenance and utility works We will continue to manage a parking regime which recognises that many Barnet residents will continue to own and travel by car We will work with TfL to review and improve the bus network We will continue to make travel safer and attractive by improving street lighting and security coverage at transport interchanges and around bus stops as well as delivering, where resources permit, targeted local safety schemes. Taking a comprehensive approach to tackling the school run We will seek to improve the effectiveness of our School Travel Plans to achieve a greater reduction in car based journeys and increase levels in walking and cycling to and from school We will implement complementary traffic management schemes outside schools, including preventing pupil parking Delivery of high quality transport systems in regeneration areas We will ensure that development is matched to capacity and promote key transport infrastructure proposals in our town centres and regeneration areas to support Barnet’s growth, in particular we will seek the following: Pursue housing and commercial growth in the areas outlined in CS1 (Spatial Strategy), CS2 (Distribution of Growth), and CS4 (Town Centres To ensure major planning proposals incorporate Transport Assessments, Travel Plans, Delivery and Servicing Plans, mitigation measures and S106 contributions / planning conditions and that adequate capacity and high quality safe transport facilities are delivered in line with demand for schemes that have phased delivery programmes With partners, high quality public transport improvements along the A5 corridor Bus service enhancements as part of the Boroughs regeneration schemes, particularly at BXC and Colindale, including a new state of the art bus station as part of the redevelopment of the Brent Cross Shopping Centre and better bus services connecting these two key areas in Barnet
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A Rapid Transit Bus Service at BXC - a dedicated bus service system which will link the key interchanges and destinations in the growth area We will promote public transport provision that is accessible to people with physical or sensory impairment including a new step-free rail station at BXC together with improvements to Brent Cross underground and Cricklewood train stations Major Improvements to the strategic road network, especially the A406 (North Circular Road) at Staples Corner and the A41 interchanges, and in the long term Golders Green Road and Henlys Corner Town centre development opportunities and enhancement programmes to improve the public realm, public transport services, short-trip making by walking, parking and servicing controls and accessibility improvements To strongly support improvements to rail services in the borough including upgrades to the Thameslink and Northern Line routes (but no splitting of the latter). More environmentally friendly transport networks We will support the use of low emission vehicles including electric cars through provision of charging points in new developments We will encourage mixed use development that will help to reduce the distances people need to travel to access everyday goods and services We will require the minimisation of road based freight movements associated with the roll- out of our regeneration schemes through, for BXC, the establishment of a (preferably rail based) construction consolidation centre, and for all regeneration schemes, the use of Delivery, Servicing, and Construction Management Plans. Through the development management process and partnership working we will seek further efficiencies and inter-modal transfer through the implementation of the Rail Freight Facility as part of the Brent Cross Cricklewood Proposals, and the promotion of Consolidation Centres and Freight Quality Partnerships. Identify and safeguard land for transport purposes (as per our site allocation DPD)
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15 Enabling integrated community facilities and uses 15.1 Introduction 15.1.1 A key part of our strategy for managing Barnet's future growth is ensuring that the services, facilities and infrastructure to support the local community and visitors are provided in suitable locations to meet increasing demand. The provision of community facilities plays a key role in meeting the Sustainable Community Strategy theme of a Safer, Stronger and Cleaner Barnet. People of all ages and backgrounds should feel they can contribute to improving the borough both through their own behaviour and by working together with others. 15.1.2 Many community services and facilities are provided by our partners such as Barnet College, CommUNITY Barnet and the Metropolitan Police. As part of our LDF evidence base we are developing a greater understanding of supply and demand for community facilities. This will inform our Infrastructure Delivery Plan. The government’s announcement of Housing Growth Area Funding support to Barnet as a growing ‘Opportunity Borough’ and the Community Infrastructure Levy will potentially assist future funding of infrastructure, together with traditional Section 106 funding and the Barnet Financing Plan27. 15.2 One public sector approach 15.2.1 Barnet's Customer Access Strategy provides a platform for further improvements to our customer access and service arrangements. Through partnership working we are developing a 'one public sector' approach which entails that land is used efficiently and that high quality community facilities are provided in the right locations and are designed to meet the needs of customers. This approach is exemplified in the new customer access facility which was developed for the west of the borough in 2009 at Burnt Oak Library. Further development of our customer access strategy and delivery plan will identify customer access points elsewhere in Barnet to complement coverage in the west of the borough. 15.2.2 We will work with partners including NHS Barnet and its successor bodies on projects which enable us to progress better service integration as already demonstrated by the links between children's centres at Oak Lane which provides health services and the Newstead Road facility in East Finchley. We will work in partnership to explore opportunities for children's and young people's health services at Edgware Community Hospital. 15.2.3 NHS Barnet has proposed a new model for primary healthcare provision. The new model would consist of hubs which consist of community hospitals and primary care centres. Hubs will function beyond office hours and provide extended hours access to a range of services, including co-located GP services. Connected GP practices and other services would form the ‘spokes’ of this model. To ensure there is integration across the services provided at Children’s Centres and hubs, each centre will be formally linked to a hub to provide accessible health care, advice and sign posting. There will be a need to build further capacity in Children’s Centres to respond to the health agenda and to support the pathway for primary and community
27 A local solution to funding infrastructure investment in Barnet using a combination of locally generated revenue sources to raise (and repay) finance directly from either public or private sources.
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services for children. They will be an important vehicle for maternity, paediatrics, and children’s community nursing. In addition there is potential to link with existing, geographically based Learning Networks, which are the means by which head teachers collaborate on school improvement, and preventative initiatives are commissioned, for example through extended schools and parenting initiatives. 15.2.4 We will work with NHS Barnet and its successor bodies to site services where access can be improved, particularly for vulnerable groups. 15.3 Barnet's libraries 15.3.1 Barnet's libraries act as a community hub providing access to flexible meeting space and wireless connectivity as well as the Council and our partner’s services. Barnet's library estate includes 16 library buildings. Most of the buildings in the library estate date from an age when models of service delivery were very different from today and when disabled access was not addressed. We will utilise opportunities for improved provision through major regeneration programmes as at Grahame Park (2013) and seek new facilities as part of major regeneration programmes such as Brent Cross - Cricklewood. 15.4 Leisure centres and swimming pools 15.4.1 In partnership with Greenwich Leisure Ltd we manage seven leisure centres and pools within the borough. Additional sports facilities include Barnet Copthall Stadium, which is considered to be North London's premier athletics venue. The council also manages an all weather sports pitch at Grahame Park. 15.4.2 We are developing a Leisure Facilities Strategy which will provide direction for any future public sector development. We have commissioned modelling work to measure and map current and future unmet need and access to public sector facilities as well as identify optimal locations to address projected unmet need. More generally, we encourage the development of new and improved leisure facilities where demand can be demonstrated and which support our Sport, Physical Activity & Physical Education Strategy 2008-2013. 15.4.3 In ensuring more efficient use of leisure facilities and greater footfall, co-location will be explored with other community provision on a site by site basis. In terms of the school estate we will seek to maximise use of school sport and leisure facilities by the wider community. 15.5 Arts and culture 15.5.1 Barnet is home to nearly 100 arts, music, theatre, literature, visual arts and film groups across the Borough. These groups and the facilities that they use serve our residents as well as those who work and visit the borough. We recognise that arts and cultural facilities are an important community asset contributing to community cohesion and a sense of identity and place as Barnet changes. 15.5.2 We are aware that there are many rooms suitable for use for clubs, classes, meetings and rehearsals, the spaces for public performance of theatre, dance, musical theatre and music are limited in number and mainly on the western side of the Borough. There is also a shortage of spaces for exhibitions. 15.5.3 In order to create vibrant town centres we will support the temporary use of vacant shops for performance and creative work. Co-location for arts and culture will be explored with other community provision on a site by site basis. In terms of the school estate we will seek to maximise use of performance space in schools by the wider community.
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15.6 Provision for children and young people 15.6.1 Results in our primary and secondary schools place Barnet in the top quartile nationally. Barnet has the second highest population of under 20 year olds in London. The Children and Young People Plan provides a strategic framework to continue the progress we are making in improving outcomes for the 25 % of the population that are under 20 years. 15.6.2 Within the major regeneration areas we have researched the need for education facilities that will result from the growth in population, for example, new primary schools are proposed at Mill Hill East and Colindale AAP growth locations, and existing schools in Brent Cross - Cricklewood will be replaced to higher standards and larger capacity. Planning for new provision will be closely linked to the distribution and delivery of housing growth as highlighted in the housing trajectory at Figure 2. 15.6.3 Barnet’s school estate faces a number of challenges including the need to improve the physical condition and suitability of stock and cater for rising pupil numbers. Barnet’s ‘First Class Schools Programme’ is already delivering a new generation of primary schools funded through the sale of surplus land, capital grant, borrowing and section 106 contributions. The first schools to be developed are Whitings Hill (opened in September 2009), The Hyde, Parkfield and Underhill Infant School where a new children's centre has been built, followed by Broadfields, Northway and Fairway schools and Colindale primary school. Some additional capacity has been provided within these new buildings and future capital investment will need to be directed toward meeting the increasing demand for primary school places. 15.6.4 In July 2010 the national Building Schools for the Future (BSF) programme was stopped. As part of the BSF programme the following six schools were identified as priorities for investment: St Mary’s C of E High, Copthall Girls, Bishop Douglass RC, The Ravenscroft, Oak Lodge special school and The Pavilion Pupil Referral Unit. The re-construction of East Barnet School, a Building Schools for the Future pathfinder project, is now well underway and on schedule to open in September 2010. Linked to this scheme, the new parent promoted Jewish Community Secondary School (JCOSS) is on track to open from September 2010 and will offer a unique, inclusive Jewish education to Barnet’s large Jewish community. 15.6.5 Although the BSF programme has stopped we will continue to identify opportunities to improve the condition of secondary schools in Barnet and to provide sufficient school places, building on the success of the investment programme which has already delivered four new primary schools and one secondary school on time and on budget. The government’s ‘Free Schools’ programme may also help to meet some additional demand for school places. 15.6.6 Barnet has a uniquely diverse range of schools with high numbers of Church of England, Catholic and Jewish schools, as well as several single sex and selective secondary schools. Meeting parental choice for particular types of school remains a priority. We welcome approaches from schools within the independent sector that want to join the maintained sector, or from groups wishing to set up a ‘Free School’, where parental demand is proven and the school provides premises that conform with basic school requirements as set out in relevant guidance from the Department for Education (DfE). 28
28 Building Bulletin 99 – Briefing Framework for Primary School Projects and Building Bulletin 98 – Briefing Framework for Secondary School Projects or their replacements.
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15.6.7 In addressing educational needs within Barnet and responding to the need for parental choice we will through the Site Allocations DPD seek to allocate sites for development that are capable of providing new school premises including parent promoted schools that meet the requirements set out in DfE guidance. 15.6.8 In order to make more efficient use of the schools estate and provide extended services in and around schools, locality-based commissioning has been established in Barnet to plan the development of extended services in a locality, agreeing local priorities and allocating funds. This commissioning, based on four ‘learning networks’, supports schools to deliver a core offer of 'wrap around' childcare, study support, parent support as well as signposting to other services and opportunities for community use. All new primary and secondary schools will be designed with community use in mind, to enable a full range of extended services to be provided. New and refurbished schools will provide modern learning environments making full use of ICT, and buildings will meet strict sustainable design criteria. 15.6.9 Children's Centres provide a range of services including childcare, access to jobs and training, health care advice and parenting support. Barnet has 21 designated Children’s Centres, many of which are co-located in a range of services including schools and libraries. 15.6.10 Other facilities for young people include multi-agency drop in centres. Existing provision in Barnet includes centres at Woodhouse Road, and at Hendon Youth Base. For future provision of youth facilities, the emphasis will be on providing a range of positive activities across the borough from a wide range of locations. There is a strong emphasis on involving young people in the commissioning of youth services to ensure that provision is well placed and meets demand 15.7 Provision for older people 15.7.1 In line with national trends Barnet faces an increase in the numbers of older people. The borough has the second highest number of people over 65 in London. Future generations of older people have different expectations and aspirations. Life expectancy has been increasing over some time and there are increasing numbers of older people living at home with long term conditions, and also dementia. We will need to retain a small number of buildings providing day services to support those people with high dependency needs to continue to live successfully in the community. For others however we are working on alternative models that promote choice and well being that will meet the needs and aspirations of the new cohort of older people. 15.8 Provision for communities 15.8.1 Barnet is the 2nd most religiously diverse and 16th most ethnically diverse borough in Britain. Residents have a shared sense of belonging to Barnet, four residents in five consider that the borough is a place where people from different backgrounds get on well together. As Barnet grows it will become more representative of London as a global city attracting younger and more ethnically diverse communities. It is imperative that as this change occurs these new communities are socially integrated and established communities do not become polarised. 15.8.2 Community cohesion needs to be measured across Barnet but there is a need to focus on the growth areas and the places that surround them. Such a focus should provide us with a better understanding of the borough's communities and the choices that they make. 15.8.3 We recognise that for many community groups it has proved difficult to maintain or extend existing buildings due to obsolescence, site constraints or the high value of
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land in the borough together with an inability to mitigate their impact on the local area. This has led to some people having to travel outside the borough to meet and pursue community or faith related activities. 15.8.4 We will support multi-purpose community facilities that make efficient use of premises providing a range of services at one accessible location. We are currently examining the space needs, both current and future, of community groups in Barnet to better understand existing provision and to be able to plan for them in the future. 15.8.5 When new developments result in an increased demand for community spaces they will also be expected to make commensurate provision for new, or improvements to existing facilities. This will help to meet the needs of new residents and mitigate impacts on the existing community. 15.8.6 Community facilities can provide a range of services in one location. Grouping such facilities together allows more services to be provided in a single place. As part of a one public sector approach we are working with partners to integrate services and make efficient use of premises. This will enable residents to access advice and assistance in the most convenient way. Policy CS 10 – Enabling Integrated Community Facilities and Uses The Council will work with our partners to ensure that community facilities including schools, libraries, leisure centres and pools, community meeting places and facilities for younger and older people, are provided for Barnet’s communities. We will: ensure that our programmes for capital investment in schools and services for young people address the needs of a growing, more diverse and increasingly younger population promote the role of schools as ‘community hubs’, providing a wide range of educational, advice, leisure and support services to children, families and the wider community support the enhancement of community facilities ensuring their efficient use and the provision of multi-purpose community hubs that can provide a range of services to the community at a single accessible location expect development that increases the demand for community facilities and services to make appropriate contributions towards new and accessible facilities, particularly within the regeneration and development areas of the borough or improving existing provision, particularly within town centres In addressing educational needs within Barnet and responding to the need for parental choice we will support proposals for parent promoted schools or ‘Free Schools’ that: Conform with DfE guidance on becoming a new school and Meet parental demand for school places and Provide educational facilities that conform with basic school requirements as set out in relevant DfE guidance. Through the Site Allocations DPD we will seek to allocate sites for development that are capable of providing new school premises including parent promoted schools that meet DCSF requirements.
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16 Improving health and well-being 16.1 Introduction 16.1.1 An important aspect of the quality of life of the suburb is the contribution to healthier sustainable environments and neighbourhoods. All strands of the Three Strands Approach to planning, development and regeneration capture the interdependence of protecting open spaces for leisure and recreation uses, enhancing the best of the suburbs which present healthy and safe neighbourhoods, and growth that provides quality and sustainable regeneration. 16.1.2 Understanding our population is the first step to being able to improve health and well-being and promote healthy choices for individuals to make healthy choices to lead healthy lives. This is a cross cutting theme for the Core Strategy. 16.1.3 Within health and social care the intention is to shift the focus away from intensive and institutionalised care such as residential care homes towards an earlier and better targeted allocation of services, preventing or delaying the onset of ill health and enabling well-being. Spatial planning can address unhealthy lifestyles, such as obesity, particularly in children, through the provision of accessible parks, allotments, open spaces, leisure facilities and an attractive and safe public realm which encourages walking and cycling. Links between health and the opportunities for physical activity are made in sections on open spaces. 16.1.4 The level of growth in the acute health sector in recent years now needs to be reversed. The effect of the increase in acute spend is one of the key reasons for the financial challenges faced by NHS Barnet and if not reversed will result in the PCT not being able to maintain expenditure in other areas, rather than increase investment as required to deliver health benefits for Barnet residents. The NHS also have to ensure that they obtain value for money from all commissioned services and that they decommission services where effectiveness or efficacy of services is not demonstrated. Implications of the 2010 Health White Paper The July 2010 White Paper ‘Equity and Excellence – Liberating the NHS’ sets out proposals to replace Primary Care Trusts (PCT) from 2013 with groups of GPs who will commission health services. PCT responsibilities for local health improvement will transfer to councils. Councils will lead on promoting integration and partnership working between the NHS, social care, public health and other local services and strategies Health and well-being boards will be created to integrate commissioning of local NHS services, social care and health improvement. As proposals on improving health and well-being become clearer with publication of White Papers on public health and social care this section will be updated. 16.1.5 Barnet’s Primary and Community Services Commissioning Strategy (published in January 2010) sets out how NHS Barnet (the Primary Care Trust (PCT)), with partners will use the resources available to ensure that primary care and community services respond to changes in population need, in the economic climate, and in national health policy in order to provide high quality, sustainable healthcare that meets population needs and delivers improved health and well-being 16.1.6 Improving health and well-being requires more than improving access to a GP surgery. There is an important link between the environment in which we live and
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how healthy we are, both physically and mentally. One of the key aims of the Sustainable Community Strategy is to create a health supporting environment by working together to identify and address the factors underpinning health inequalities in Barnet. This includes ensuring that new developments provide for a quality of life that facilitates healthier lifestyles. 16.1.7 Barnet's Health and Well-being Commissioning Framework guides how public agencies in Barnet will work with providers to plan and shape services to improve the health and well being of adults in the borough and help people remain independent. This includes targeting of universal health and other services to meet prioritised needs and aspirations, particularly for the most vulnerable groups. The framework specifically sets out the vision, objectives and desired outcomes for improving the health and well-being of adults in Barnet and the commissioning standards for services working to deliver these. It also sets out a work programme for the Adult Strategy Group (ASG), the core commissioning group for adult health and well- being. 16.1.8 Aligned with the Health and Well-being Commissioning Framework our Joint Strategic Needs Assessment (JSNA) for Health and Social Care provides a basis for how we can enable people to live healthy lifestyles while at the same time continue to promote independence, choice and control for vulnerable people and their carers. 16.2 Addressing poor health and health inequalities 16.2.1 Coronary heart disease, cancer and respiratory problems are the three biggest causes of premature death in Barnet, although rates are lower than for England as a whole. We believe that in Barnet agencies such as the Council and NHS Barnet should work alongside individuals and the wider community to support them to adopt and maintain healthy lifestyles. The JSNA helps us understand the needs of local people so that information can be tailored to encourage them to change behaviour such as stopping smoking, taking up exercise, drinking sensibly and accessing cancer screening. 16.2.2 Obese adults are at a greater risk of premature death and are more likely to suffer from conditions such as diabetes, heart disease, hypertension, stroke, cancer and respiratory disorders. Obesity is becoming an increasing problem in Barnet and, as a lifestyle choice, is second only to smoking as a significant avoidable risk factor for poor health and premature death. NHS Barnet29 estimates that there are over 100,000 overweight adults, over 50,000 obese adults and just over 4,000 morbidly obese adults living in Barnet. Approximately 14,000 residents of Barnet have been diagnosed with diabetes, however it is thought the actual number of sufferers is likely to be much higher. 16.2.3 Health inequalities exist in Barnet spatially and by gender. Men in affluent wards such as Hampstead Garden Suburb have an average life expectancy which is up to seven years longer than their counterparts in Colindale. For women the largest difference is five years between Hampstead Garden Suburb and more deprived West Finchley.
29 NHS Barnet - Commissioning Strategic Plan 2009 – 2014/15 January 2010
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Map 16 – Deprivation in Barnet
The English Indicies of Deprivation 2007 Communities and Local Government © Crown Copyright 2007 16.2.4 Map 16 shows the distribution of deprivation in Barnet. Those living in the most deprived areas display high death rates from cardiovascular disease (CVD) and cancer; have a high prevalence of diabetes, mental health problems and a range of other chronic diseases. The fall in overall death rates from cancer in our most deprived electoral wards (-8%) has not been as marked as that in the more affluent wards (-32%). Death rates from coronary heart disease (CHD) for people living in the seven most deprived wards are worse than the national average. 16.2.5 'Finding the 5000' is an initiative between the Council and NHS Barnet to reduce morbidity and mortality from CVD. Through the screening of 20% of Barnet’s population it will target people in the most deprived areas of Barnet. 16.3 Clinical care 16.3.1 The health of Barnet’s population is generally better than the UK average but the public is concerned that there are too few GPs and that local hospitals do not provide sufficiently high standards of care. Primary care is defined as the provision of basic healthcare where a person first makes contact with the health service outside
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of hospital. Community healthcare is defined as any healthcare that could take place outside of an acute hospital. 16.3.2 Primary care provision in Barnet currently consists of: 69 GP contracts; 76 dental contracts; 81 ophthalmic contracts; and 77 pharmacies. Primary care is based on a GP-led model. GPs are central to the co-ordination and delivery of patient care, it is important to use other providers in care provision to increase GP capacity for more complex work, improve continuity of care across providers and ensure limited funds are used to best effect. 16.3.3 NHS Barnet are developing a clinical infrastructure model that responds to clinical needs and the future vision for Primary and Community Services across Barnet. This model will review the condition; location and capacity of NHS Barnet’s existing clinical accommodation and incorporate a gap analysis of the existing clinical infrastructure against future requirements. NHS Barnet will publish a Strategic Implementation Plan that clearly sets out estate priorities for investment including a fourth hub likely to be at Brent Cross – Cricklewood. 16.3.4 The Barnet primary and community care service model is based on a continuum of care from promoting health and well-being, to self-care, non-complex and complex care. People are expected to move between these levels at different times of their life, and we want primary and community services to focus on keeping individuals healthy for as long as possible, and then returning them to good health where possible, following periods of higher level care. All levels of care can be provided in a primary and community care setting, with services only provided in hospital where their level of complexity, or the ability to achieve economies of scale, means that a hospital setting is the most effective place for provision of that care. 16.3.5 Barnet’s Primary and Community Services Commissioning Strategy does not cover acute hospital services, it sets out NHS Barnet’s intention to dramatically reduce the amount of healthcare that occurs in an acute setting. Commissioning of acute services has been delegated by all North Central London PCTs to a new Acute Commissioning Agency, who will respond to the strategic direction for primary care and community services through the commissioning arrangements with local acute trusts. 16.3.6 NHS Barnet has developed a strategy for services to meet the needs of the borough within the context of NHS London’s health strategy: A Framework for Action. The Barnet Enfield and Haringey Clinical Strategy - Your Health Your Future: Safer Closer Better, 2007 sets out the local vision for change in the way healthcare is delivered to patients in Barnet. The Clinical Strategy states that : people should be helped to remain healthy and independent, have real choices and greater access in both health and social care; and services should be integrated, built around the needs of individuals, promoting independence and choice. 16.3.7 NHS Barnet has developed a new hub and spoke model to deliver primary and community care services which considers planning and delivering health services in settings that include the patient’s own home, GP practices and community hospitals and primary care centres. 16.3.8 In Barnet, the proposed system could comprise four hubs each serving populations of 80,000 to 100,000. The hubs include two community hospitals at Edgware (which opened in 2005) and Finchley Memorial (which is programmed to open in 2013); Vale Drive Health Centre will become a hub. The current use of Vale Drive will be reviewed to ensure it is used to full effect;
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A primary care centre will be developed in Brent Cross-Cricklewood as part of a community hub. This will see health and social care services co-located for easy access for residents; Federated spokes that include GPs, pharmacists, dentists and optometrists. 16.3.9 The hubs are not of equal size, nor do they provide the exact same range of services. In planning for the size and shape of the hubs Healthcare for London recommended To focus on the shift of care to locations closer to patients’ homes, to provide specialist care provided in centralised sites, and to separate emergency and planned care To plan services around population size, volume and throughput necessary to maintain clinical safety and outcomes, and integrated care pathways taking account of existing infrastructure and estates so that these can be best utilised to deliver new models of provision The overriding principle in the development of models for London is to ‘localise where possible and specialise where necessary’ 16.3.10 The quality of the remaining primary care estate varies from purpose built, modern premises to the ground floor of a semi-detached house. Since 2006, many practices have improved their DDA compliance through work undertaken as part of a PCT wide initiative. However, genuine equality of access for those with disabilities still remains poor in some practices. 16.3.11 Our three biggest providers of acute and mental healthcare are: Barnet and Chase Farm Hospitals NHS Trust; the Royal Free Hampstead NHS Trust and Barnet, Enfield and Haringey Mental Health NHS Trust. We envisage a reduction of beds and capacity in our main hospitals and a renewed focus for these Trusts on delivering specialist care 16.4 Residential care homes 16.4.1 We have a number of strategies for addressing the needs of Older People. The Older Adults Strategy - Living Longer, Living Better and the Older People's Commissioning Strategy - Independence, Choice and Control set our strategic framework for addressing the needs of older people in Barnet. These strategies envisage an increasing amount of care taking place at home in order to promote independence and activity. 16.4.2 Barnet has a good record on helping people to live independently. We have the second highest score in London for NI 139 which measures the extent to which older people consider they receive the support they need to remain at home. On the basis of current and projected needs future services will have to be more flexible, diverse and tailored to the needs of individuals. Helping people stay at home for as long as they want to will require a fundamental shift away from the focus on treating the results of ill-health towards the promotion of health and the wider well-being agenda. The number of places required in residential care homes will fall, and the volume of services delivered locally will rise. 16.4.3 Barnet has an oversupply of residential care homes. Our Joint Strategic Needs Assessment shows that while Barnet has been successful in reducing the rate of admission to residential care, the numbers of people living in this type of accommodation remains relatively high within our local authority comparator group. NHS Barnet and the Council’s Adult Social Services have concerns about overprovision and the associated costs for non-local need. We will therefore
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encourage the remodelling of such facilities as other forms of provision for older people such as extra care housing. 16.4.4 Residential and nursing homes in Barnet may register places for the care of older people who have dementia and places for people who require nursing care. Places for people who require neither type of specialist care are known as 'mainstream places'. The current supply of mainstream residential places in Barnet exceeds placements made by the Council. The oversupply of mainstream places is a national issue. There are 76 registered care / nursing homes for older people in Barnet. Two large nursing homes (250 beds and 94 beds) are being developed in Barnet and this will place additional demands on primary care and specialist mental health resources. The effect of this additional supply is to increase the potential of cross border purchasing from outside Barnet. This will place a greater burden on NHS Barnet and our budget. 16.4.5 Commissioning is now more focused on providing places for people with dementia as demand has not decreased. However, it is considered that sufficient capacity will be achieved through existing homes. Although the demand for nursing home places is constant current supply is sufficient to meet demand. 16.4.6 Overall the numbers of people with impairment and deficiency will increase over the next 20 years. The policy directives for the NHS to 'shift care closer to home' is aimed to provide more choice and flexibility in how health care needs are met. These changes will place significant pressures on social care systems as more people are treated in the community.
Policy CS 11 – Improving health and well being in Barnet We will improve health and well-being in Barnet by: supporting the plans of NHS Barnet and from 2013 its successor bodies (including GP Consortiums) to deliver modern primary and community care supporting healthier neighbourhoods through targeting of unhealthy lifestyles such as those which cause obesity and addressing health inequalities in terms of ill health and access to health facilities as identified in the Joint Strategic Needs Assessment supporting the remodelling of residential care homes to other forms of special accommodation in order to widen housing choice and to reduce over supply ensuring that additional residential care home provision is only supported when evidence of local need can be demonstrated and that the proposal addresses the priorities of NHS Barnet, or its successor bodies, and the Council’s Adult Social Services.
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17 Making Barnet a safer place 17.1.1 Despite Barnet being amongst the safest boroughs in London, crime and anti-social behaviour are a key concern of local residents. The Sustainable Community Strategy highlights that crime has a harmful effect on communities through its actual impact and fear of becoming a victim. Barnet's growth presents several challenges for community safety and cohesiveness. Young people have identified crime as the most important issue affecting them. People aged 14 to 16 in Barnet are 10 times more likely to be a victim of street robbery than a person in their 30s. As Barnet's population is forecast to become younger there are increased risks of young people being victims as well as perpetrators of crime. 17.1.2 Understanding how we can create safer environments through regeneration and development opportunities is key to the 'place-shaping' agenda. The creation of new communities in regeneration areas could pose significant challenges to cohesion. As Barnet grows there is a need to better understand how change is taking place geographically and demographically. There is a noticeable trend that the west of the borough is getting younger while the east gets older. 17.1.3 With increased diversity and population mobility it is important that new communities integrate cohesively with settled ones and that hate crime does not increase, and that it is reported and tackled effectively when it does happen. 17.1.4 With more visitors and greater activity in Barnet's vibrant town centres the opportunities for alcohol related disorder could increase. At present most alcohol related disorders occur at the weekends and are evenly distributed across the borough, although North Finchley is the main hotspot. 17.1.5 Through our 21 Safer Neighbourhood teams, the Children and Young People's Partnership Board and other forms of community engagement we are developing our understanding of how people experience crime and what drives their fears of becoming a victim. This includes focusing on why residents feel less safe in Barnet's town centres. 17.1.6 The planning system plays an important part in reducing the opportunity for crime and disorder and making places safer. Well planned, mixed use areas, good quality public realm, carefully designed buildings, open spaces and neighbourhoods can “design out” crime and help to reduce the fear of crime. We expect development proposals to reflect guidance in the publication Safer Places : The Planning System and Crime Prevention (2004) and the principles of Secured by Design the official UK Police flagship initiative for 'designing out crime'. We will seek to ensure that any new transport interchanges are designed to help address personal safety and reflect Secured by Design principles. 17.1.7 As the borough grows, new neighbourhoods emerge and existing suburban and town centres change, sensitive planning of uses, activities and open spaces can help improve community safety. Greater collaboration with the Metropolitan Police and Barnet Safer Communities Partnerships inputting to the spatial planning of these areas will enhance safer neighbourhoods. More detail on the approach we will take to make Barnet safer will be provided in the Development Management Policies DPD. 17.1.8 The Metropolitan Police Authority published its Asset Management Plan in 2007 which set out how they will improve the management of their stations, offices, safer neighbourhood bases and custody centres in Barnet. Proposals in the 2007 document included a new strategically located custody centre rather than in existing
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police stations, as well as a new patrol base in a single warehouse-style building providing accommodation of operational police officers and their vehicles. The document suggests a move towards more local ‘front counter’ facilities and Safer Neighbourhood Team bases across the borough to provide enhanced accessibility. We support the aim of Safer Neighbourhood Teams to make neighbourhoods safer places to live in, work in and visit and will work with the Borough Commander to refresh this document and provide modern, accessible and customer friendly facilities in the right locations in Barnet.
Policy CS 12 - Making Barnet a safer place We will aim to make Barnet a safer place. It is important that we ensure through the management of growth that Barnet is a place where people from different communities get on together. We will: work with our partners to tackle crime, fear of crime and anti-social behaviour; work with the Metropolitan Police to provide re-modelling of its estate as a basis for an effective and responsive police service in Barnet; support the work of Safer Neighbourhood Teams to make our neighbourhoods safer places to live in, work in and visit; encourage appropriate security and community safety measures in buildings, spaces and the transport system; require developers to demonstrate that they have incorporated design principles which contribute to community safety and security in all new development; ensure that through the town centre strategy programme we promote safer and more secure town centre environments; and promote safer streets and public areas including open spaces.
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18 Ensuring the efficient use of natural resources 18.1 Introduction 18.1.1 Climate change is one of the greatest challenges the world is facing and a key priority for Barnet’s future is to reduce the borough’s carbon footprint where possible particularly in new development. Reducing carbon dioxide (CO2) emissions, adapting to future climate change, ensuring resource use is kept within sustainable levels, promoting biodiversity and improving quality of life are all key issues for Barnet. We recognise the need to urgently reduce our carbon dioxide emissions to sustainable and equitable levels in line with national energy and climate change targets and that this challenge has to be addressed through behaviour change by public services, citizens and businesses. 18.1.2 National planning policy on climate change has been subject to significant change since the publication of the Planning Policy Statement on Planning and Climate Change in December 2007. 18.1.3 The adopted London Plan provides a strong basis for ensuring new development addresses environmental issues. The broad development strategy of the London Plan is to make the best use of land and other finite resources; to ensure development is accessible by a choice of means of transport and takes account of available and planned infrastructure; ensures that physical constraints (such as flood risks) are taken into account; and promotes mixed use development, the integration of open spaces and well designed neighbourhoods that are safe and improve the quality of life of residents and diverse communities. 18.1.4 In meeting the challenges of the London Plan we have to ensure that our first priority is to use less energy, secondly to supply energy more efficiently and thirdly to use renewable energy. 18.1.5 Barnet’s Sustainable Community Strategy highlights that we must actively minimise and address the impact of climate change in order for Barnet to remain an attractive place for existing and future residents and businesses. The Sustainable Community Strategy recognises that increases in Barnet's population will put significant pressure on the environment and that we need to reduce the amount of waste we create, increase the amount we recycle, and use energy more efficiently 18.1.6 Reducing our environmental impact whilst supporting growth is a major challenge. In meeting that challenge and demonstrating local leadership we have taken several steps 18.1.7 Barnet’s Environmental Policy – A Greener City-Suburb 2008/09 – 2011/12 provides local leadership in reducing emissions of CO2 and reducing waste. 18.2 Barnet's Local Area Agreement 18.2.1 Through Barnet's Local Area Agreement we have set ourselves challenging target on carbon and waste reduction. We aim to reduce per capita CO2 emissions from a 2005 level of 5.6 tonnes per capita by 11% by 2010/11(NI 186). We aim to reduce residual household waste per head from 733kg in 2008/9 to 625kg by 2010/11 (NI191). 18.3 Carbon Emissions Reduction Action Plan
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18.3.1 We are working closely with the Energy Saving Trust to reduce our carbon emissions and through a Carbon Emissions Reduction Action Plan (February 2009) are working to reduce energy use across all local authority energy related activities. Key objectives of the action plan are to promote sustainable energy use by the community and to raise awareness and encourage action on climate change amongst residents, businesses and staff. 18.4 Barnet's Waste Prevention Strategy 18.4.1 We introduced compulsory recycling across the borough in 2005. Barnet's Waste Prevention Strategy 2005 - 2020 sets out that the best way to deal with waste is to prevent it. The Strategy highlights the need to share responsibility for our waste and change our behaviour. 18.5 Flooding 18.5.1 We are producing a Multi Agency Response Plan to help prepare for future flood events in Barnet and to comply with the statutory duties of the Civil Contingencies Act 2004 and the recommendations of the Pitt Review 2008. 18.6 Sustainable design and construction 18.6.1 There is a wide range of measures which developers can incorporate to make their developments more sustainable for example the use of passive solar design, natural ventilation, green and brown roofs, sustainable drainage systems and rainwater systems. In June 2007 we published a Supplementary Planning Document (SPD) on Sustainable Design and Construction which sets out our requirements for environmental design and construction management. The SPD sets out requirements on air, noise, water and habitat quality in order to achieve protection and enhancement of the environment. It also sets out requirements on energy, water, waste and materials in order to achieve the prudent use of natural resources. The SPD requirements are linked to existing national standards and guidance and will be updated in line with emerging opportunities and future developments. The SPD sets out the areas where Barnet needs to go further and faster, whilst providing a complementary relationship between the Local Development Framework, London Plan and the Building Regulations / Code for Sustainable Homes. 18.6.2 The Core Strategy can influence future development in the borough to make the fullest contribution to the mitigation of, and adaptation, to climate change. It can also help to reduce flood risk, the incidence of fuel poverty with more fuel efficient dwellings. Through adopting sustainable design and construction measures as well as prioritising decentralised energy generation carbon dioxide emissions can be minimised. There is also a role for the Core Strategy in addressing the level of emissions from the existing building stock and pattern of development. 18.7 Reducing carbon emissions in new and existing development 18.7.1 New development provides the opportunity to deliver modern homes which meet the highest standards of energy efficiency currently available and helps to minimise carbon emissions. 18.8 Code for Sustainable Homes 18.8.1 The Code for Sustainable Homes sets out standards for the sustainability of new housing development. Minimum levels of the six stage Code are scheduled to become mandatory for new homes under future changes to the building regulations. Code Level 3 is equivalent to a 25% reduction in carbon emissions. Through high standards of design and build quality this can be achieved without the use of
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renewable energy. The sustainability of commercial and community buildings is classified by BREEAM standards. The SPD on Sustainable Design and Construction sets levels for the Code and for BREEAM. 18.9 Combined heat and power 18.9.1 Combined heat and power (CHP) and combined cooling heat and power (CCHP) can be a more sustainable and efficient means of supplying heat and power than traditional energy supply systems. Barnet has explored opportunities for the use of these technologies in the major regeneration and development areas, and this is exemplified in the Area Action Plans of Colindale and Mill Hill East. In other major areas of mixed use growth (including town centres) we will promote strategic sustainable energy infrastructure and work with developers to identify land and access for CHP / CCHP plant and district heating connections where appropriate. 18.9.2 Barnet is currently involved in the Decentralised Energy Masterplanning initiative which is part of a London-wide programme of support, led by the LDA. We are working jointly with consultants and the London Borough of Brent on a ‘heat mapping’ exercise that matches heat sources with heat users to help identify opportunities for decentralised energy both within and cross-borough. This will provide an evidence base which identifies the locations where we can prioritise the development of decentralised energy networks in relation to existing and future development. 18.9.3 More detailed policy to encourage Decentralised Energy networks, including a requirement to support heat networks through physical or financial contributions will be covered in the Development Management Policies DPD. 18.10 Barnet’s existing housing stock 18.10.1 Nearly two thirds of Barnet’s housing stock was built before 1944 (compared to a national figure of 40%). To better understand the condition of the existing private housing stock in Barnet we have used the Building Research Establishment Housing Stock Model. The Model will provide an estimate of properties with poor insulation as highlighted by the SAP (Standard Assessment Procedure) rating. SAP is the Government's recommended system for energy rating of dwellings and is based on the annual energy costs for space and water heating. 18.10.2 The Model relates the condition of a dwelling to the characteristics of the local area and provides estimates for private sector housing for dwellings failing the Decent Homes Standard in Barnet and the reasons why. It highlighted that 22,000 properties in the private sector had inadequate thermal comfort and over 14,000 properties had a SAP rating of less than 35. The BRE Model showed that households in the west of the Borough were more likely to fail the Decent Homes standard and be occupied by a vulnerable person. 18.10.3 We recognise that the wider housing stock in the borough has a relatively high level of carbon emissions compared to the London average, and we have operated a private sector decent homes programme targeted at vulnerable households, which has seen homes provided with measures to reduce fuel poverty, such as insulation, and improvements to heating systems. We will continue to target the resources available to us at the most vulnerable households in the private sector. We recognise that doing more than encouraging self sufficient private owners to invest in energy efficiency measures to their homes is a challenge that needs to be tackled in partnership with regional and national government. 18.10.4 In order to inform the Colindale Area Action Plan a thermal masterplanning assessment was undertaken to better understand energy demand in particular the
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seasonal and daily fluctuations in energy use. The assessment highlighted existing buildings in supporting the viability of a district heating and CHP network as a mix of energy demands is required to ensure that the heat produced can be used locally at the time it is produced. 18.10.5 With 75% of carbon emissions generated by existing buildings there are opportunities to improve home insulation and provide decentralised energy in order to benefit from new CHP. More detailed policy to support retrofitting of the older housing stock taking into account impact on the residential character of the borough will be covered in the Development Management Policies DPD. 18.11 Renewable energy 18.11.1 The sustainable planning of neighbourhoods is strongly linked to how they need, source and use energy. 18.11.2 The adopted London Plan contains a suite of policies on climate change adaptation and mitigation. Policies include 20% on site renewable energy generation. Barnet's SPD on Sustainable Design and Construction sets out our local requirements for minimising the consumption of non-renewable energy sources. In the draft revised London Plan the Mayor has set out at Table 5.1 his targets for the installation of different renewable energy technologies to generate more electricity and heat up to 2025. We will implement London Plan policies in conjunction with our SPD. 18.11.3 We consider that expectations on renewable energy are changing. We therefore want to capitalise on opportunities to reduce the use of natural resources and to promote sustainable locations for integrated land uses. Our priority is to utilise high quality design delivered through our SPD on Sustainable Design and Construction to ensure efficient use of energy rather than seek an unproven technological fix. Combined Heat and Power could offer the most cost effective way of ensuring major development in Barnet contributes to the Mayor's carbon dioxide reduction targets. 18.12 Choosing sustainable locations for development 18.12.1 Measures to reduce the overall carbon footprint of a development are as important as the use of renewable energy. The location of development and the mix of land uses have a significant effect on the amount of natural resources we use for transport and energy for heating and cooling. In order to reduce pressure on our valuable Green Belt sites we encourage proposals that make best use of previously developed land. 18.12.2 In considering site allocations we will choose locations in areas of lowest flood risk. Policy CS 6 Distribution of Growth aims to make the best use of previously developed land which can be planned at higher densities, mainly in the western part of the borough, and in accessible town centres. These locations are either relatively well-served by public transport or will become better served as a result of planned regeneration and development. These locations will be developed with a mix of uses, encouraging the possibility of living and working in closer proximity, and will include the necessary infrastructure nearby. These areas will therefore offer exemplary sustainable locations and furthermore, will be planned so as to include the highest standards of design and construction, including dealing with waste on site. 18.12.3 The greening of the built environment provides a significant contribution to climate change adaptation. We will therefore produce a Green Infrastructure SPD to provide guidance on landscaping, trees, biodiversity and sustainable urban drainage systems.
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18.13 Air and noise pollution 18.13.1 Levels of noise and air pollution have a major bearing on the health and well being of all Barnet residents. The majority of Barnet's housing growth will take place in areas that already suffer from air and noise pollution. The design of the built environment has an important role in managing the degree to which people are exposed to pollution. Within Barnet emissions from traffic have the most severe and pervasive impact on air quality. 18.13.2 The whole borough is an Air Quality Management Area (AQMA). An Air Quality Action Plan has been developed to improve air quality and is updated each year. We will take into account the impact on air quality when assessing development proposals. Regard will be paid to the Air Quality Action Plan and to Cleaning London's Air: The Mayor's Air Quality Strategy. Where development could potentially cause significant harm to air quality, an Air Quality Assessment will be required. Further guidance on air quality and when assessments are required is provided in our SPD on Sustainable Design and Construction. 18.13.3 Persistent and intermittent noises such as those made by industrial activities, transport, construction and congregations of people can undermine quality of life. We will take into account noise considerations when assessing development proposals. Regard will be made to the Mayor's Ambient Noise Strategy as a reference source for understanding noise and identifying best practice. We will require Noise Impact Assessments for developments likely to generate or be exposed to significant noise. Further guidance on noise quality and when assessments will be required is provided in our SPD on Sustainable Design and Construction. 18.14 Flooding and water management 18.14.1 One of the major impacts of climate change will be to increase risk of flooding from watercourses (known as fluvial flooding) and sewers (known as surface water flooding). The risk based Sequential Test as set out in PPS 25 – Development and Flood Risk should be applied at all stages of planning. Its aim is to steer new development to areas at the lowest probability of flooding. Barnet has 14kms of streams and brooks and the North London Strategic Flood Risk Assessment identified fluvial flooding from Dollis Brook, Silk Stream, Pymmes Brook and their associated tributaries as the primary source of flood risk in the borough. Surface water flooding in Barnet presents a low to moderate risk to the borough while sewer flooding is also noted for being low risk. Groundwater flooding was found to be a relatively low risk due to the impermeable geology (primarily London Clay) and depth of the groundwater table. 18.14.2 The Pitt Review recommended that the Environment Agency, supported by local authorities and water companies should urgently identify the areas that are at highest risk from surface water flooding. In 2009 the Environment Agency published maps highlighting those areas where a more detailed study of surface water flooding may be appropriate within strategic flood risk assessments and Surface Water Management Plans (SWMPs). 18.14.3 In August 2009 the Department for Environment, Food and Rural Affairs (DEFRA) estimated that 10,800 properties in Barnet are at risk of surface water flooding due to severe rainfall. According to DEFRA Barnet is the 25th most susceptible local authority to surface water flooding. The Drain London Forum representing 32 London boroughs has been awarded £3.2 million for the development of SWMPs.
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18.14.4 The Pitt Review recommended that SWMPs as set out under PPS25 and co- ordinated by local authorities should provide the basis for managing all local flood risk. The output from these assessments should help to inform development allocations within the Site Allocations DPD and outline the requirements for site- specific Flood Risk Assessments (FRAs) to be carried out by developers. 18.14.5 Barnet’s main water courses are of fair to poor chemical quality according to assessments carried out by the Environment Agency. Maintaining the quality of water, especially groundwater, is important in ensuring the borough’s population has a good quality domestic water supply. Water pollution can also affect the supply of water for leisure, industrial and agricultural uses and have a harmful impact upon riverside habitats. We will work with the Environment Agency to restrict development which may threaten the quality of either ground or surface water. The SPD on Sustainable Design and Construction provides guidance on the use of Sustainable Urban Drainage Systems (SUDS) to enable better control of water during periods of peak rainfall. 18.14.6 Water is a precious resource and it is essential that new development seeks to be efficient in using water, seeking wherever possible to reduce consumption. This can be achieved through grey water systems and rainwater harvesting. Further details on recommended technologies are set out in the SPD on Sustainable Design and Construction. Policy CS 13 - Ensuring the efficient use of natural resources We will seek to minimise Barnet’s contribution to climate change and ensure that through the efficient use of natural resources the borough develops in a way which respects environmental limits and improves quality of life. We will promote the highest environmental standards for development and through our SPDs on Sustainable Design and Construction and Green Infrastructure. We will continue working to deliver exemplary levels of sustainability throughout Barnet We will expect all development to be energy-efficient and seek to minimise any wasted heat or power. In line with the London Plan we will expect major development to reduce carbon dioxide emissions by at least 20 per cent through use of on-site energy generation We will maximise opportunities for implementing new district-wide networks supplied by decentralised energy (including renewable generation) in partnership with key stakeholders in areas of major mixed use growth including town centres. Where feasible we will expect all development to contribute to new and existing frameworks We will make Barnet a water efficient borough and minimise the potential for fluvial and surface flooding by ensuring development does not cause harm to the water environment, water quality and drainage systems. Development should utilise Sustainable Urban Drainage Systems (SUDS) in order to reduce surface water run-off and ensure such run- off is managed as close to its source as possible We will improve air and noise quality by requiring Air Quality Assessments and Noise Impact Assessments from development in line with Barnet's SPD on Sustainable Design and Construction
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19 Dealing with our waste 19.1.1 Managing the amount of waste we produce is a key component of being environmentally sensitive and growing successfully. We need to find better ways of dealing with our waste and taking more responsibility for dealing with it within London rather than burying it in landfill in places such as Bedfordshire. 19.1.2 The Sustainable Community Strategy highlights that in order to minimise and address the impact of climate change we need to reduce the amount of waste we create and increase the amount we recycle. We were the first local authority in the country to introduce compulsory recycling in March 2005, and will continue to work to improve services for residents, and engage with them more effectively using improved intelligence and targeted approaches. 19.1.3 As part of the proposals for Brent Cross – Cricklewood a rail linked waste handling and recycling facility is proposed on a site adjoining Edgware Road (A5). This will be developed in partnership with the North London Waste Authority who will vacate the existing Hendon Waste Transfer Station, the site of which is required for comprehensive regeneration. It is intended that this facility will sort recyclable material t and will treat non-recyclable waste to enable it to be converted for a fuel for the Combined Heat and Power facility at Staples Corner which also forms part of the proposals for Brent Cross – Cricklewood. 19.1.4 The North London Waste Authority (NLWA) and the seven boroughs that are members of it have produced a Joint Waste Strategy which plans for managing the waste collected by the boroughs until 2020. This will be used to facilitate the provision of new waste management facilities and services, to increase recycling and recovery and divert more waste away from going to landfill. 19.1.5 The Mayor of London has set in the adopted London Plan a target of 85% self- sufficiency across all waste streams by 2020. This will require new facilities using new technologies that deal with waste as a resource to be developed across London. Barnet has been allocated an apportionment target of 210,000 tonnes of waste per annum in 2010 rising to 327,000 tonnes per annum by 2020. We need to identify sufficient land to provide capacity to deal with this waste target and have joined with six other North London boroughs to produce the North London Waste Plan (NLWP). The NLWP is a Development Plan Document which will form part of Barnet’s LDF. It will sit alongside the North London Joint Waste Strategy to secure the sustainable management of waste. Policy CS 14 – Dealing with our waste We will encourage sustainable waste management by: promoting waste prevention, re-use, recycling, composting and resource efficiency over landfill requiring developments to provide waste and recycling facilities which fit current and future collection practices and targets designating sites through the NLWP to meet an aggregated apportionment target across the seven North London boroughs. These sites will be the principle locations considered suitable for waste facilities safeguarding a Waste Management Facility in the Brent Cross - Cricklewood Regeneration Area.
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20 Delivering the Core Strategy 20.1 Introduction 20.1.1 The policy suite of the Core Strategy and of other LDF documents such as the Development Management Policies and Site Allocations DPDs will provide the framework for decisions on planning applications. 20.2 Working with our partners 20.2.1 During the preparation of this Core Strategy we have worked with, and secured the involvement and commitment of, our delivery partners including Barnet’s Local Strategic Partnership (LSP) and other key bodies. The Local Strategic Partnership recognises that it has an important role to play in relation to the delivery of this Core Strategy, in particular in bringing forward the infrastructure requirements that will be identified in Barnet's Infrastructure Delivery Plan (IDP). We are currently considering innovative ways to achieve this, in particular the financing aspects (the Barnet Financing Plan) to take forward the delivery of infrastructure. Opportunities for partnership working and the joint delivery of services are also being explored to optimise the delivery of Core Strategy objectives. 20.2.2 The IDP provides the mechanism for monitoring capital investment across our local public sector partner areas, to make plans corporately known and shared. Details are meant to be clearly exposed so that all partners know what is being delivered, where it is to happen and which agency is responsible for that delivery. However, funding does not need to be proven in order for items to be incorporated into the IDP, instead the objective is that all funding streams are visible and known and the IDP is used to identify gaps. 20.2.3 The IDP will provide a valuable dataset of all building and service re-profiling measures being undertaken across public sector bodies in Barnet to improve capacity and cost-effectiveness of infrastructure and public services. Close working with stakeholders and partners to align and better coordinate delivery programmes through the IDP will enable service improvements and efficiency savings. 20.2.4 We developed an innovative Engagement Agreement with NHS Barnet in 2009 to strengthen links between strategic planning and operational delivery. This provides a basis for close joint working between the Council and NHS Barnet. The Engagement Agreement sets out the key components of Barnet’s growth, its programme for delivering change and predicted impact on healthcare provision. It sets out the roles and responsibilities of officers in each organisation and identifies appropriate workstreams focusing on key issues highlighted in Barnet’s emerging Core Strategy. This helps to establish clear links across both organisations to facilitate continued integration. 20.2.5 The Council, its partners and central government have agreed Barnet's Local Area Agreement (LAA), which contains a range of goals and targets to improve our services. The Core Strategy will contribute to delivering a number of these outcomes. The indicators we will use to monitor the success of the Core Strategy have been aligned with those in the Local Area Agreement where possible. 20.3 Infrastructure delivery 20.3.1 The Infrastructure Delivery Plan (IDP) provides a high-level risk assessment and cost analysis framework for the delivery of infrastructure necessary to improve opportunities for and quality of life of the Borough’s residents. It details the delivery
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of ‘critical’, ‘necessary’ and ‘preferred’ community benefits including educational and healthcare facilities; highways improvements; and open space provision for future and existing residents from all of the Borough’s diverse communities. 20.3.2 The IDP contains information on the type, timing and potential costs of the infrastructure needed to support the housing development set out in the Core Strategy. The IDP and its subsequent updates will enable the Council and LSP partners to plan effectively for population change and to maximise the potential benefits associated with this to achieve wider economic, social and environmental objectives. 20.3.3 Barnet’s IDP also sets out a broad concept of ‘prioritisation of infrastructure’ to ensure that the Council focuses on delivery of the right infrastructure at the right times that best serves the Borough and enhances Barnet as a successful London suburb. This responds to the anticipated timing for delivery of major housing developments, divided into three time periods: 2011-15, 2016-20 and 2021-25. The objective of prioritisation is also to recognise that some infrastructure is required as a result of population growth and change, whereas other infrastructure is primarily needed to improve overall quality of life for residents or to achieve wider sustainability objectives. The IDP therefore identifies which infrastructure is critical in relation to delivering Core Strategy objectives, which infrastructure is necessary but not critical, and which is preferred if funding is available. 20.3.4 Barnet’s IDP is structured in three sections relating to physical infrastructure, social infrastructure and green infrastructure. Each section is divided into broad headings which are further subdivided into each key aspect as follows. 20.4 Physical infrastructure
Movement and Public transport improvements, Highways, Junction Connectivity Improvements, Parking, Cycling and Pedestrians
Utilities Electricity, Gas , Water and Telecoms
20.5 Social infrastructure
Education Further and Higher Education, Secondary, Primary, Early Years and Special needs,
Health Primary Care, Specialist Pathways, Unscheduled Care, Ambulance Service and Acute Care
Community Libraries, Arts and Exhibition Spaces, Community Facilities Centres, Youth Provision, Religious Facilities, Other Facilities.
Sport and Sports Centres, Sports Pitches, Swimming Pools, Recreation Play Facilities
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Police and Justice Back Office, Customer Facing, Courts
Fire and Rescue Emergency Planning, Fire and Rescue Services
20.6 Green infrastructure
Open Spaces Natural Open Spaces, Parks, Green Chains, Hard Landscaping, Biodiversity
Energy Decentralised Energy, Energy Efficiency
Waste Waste Collection, Waste Transfer, Local Recycling Facilities
Flooding Fluvial Flood Prevention, Localised Flood Prevention, Drainage Network
20.6.1 Opportunities for better coordination in Barnet of utilities upgrade and highways improvement programmes could be facilitated through the analysis and alignment of the investment programmes detailed in the IDP. Furthermore in regeneration and development areas by making the detailed costs of key infrastructure investment visible, there is potential to ensure utilities are laid so as to reduce long term road maintenance costs by insisting upon more effective and shared ways of laying the utilities. 20.7 Community Infrastructure Levy 20.7.1 In April 2010 Regulations were published to enable local authorities to set a Community Infrastructure Levy (CIL), a standard charge to be decided upon by authorities which will contribute to the costs of infrastructure arising from new development. The government intends to produce further guidance on how this will operate but has signalled that it intends the definition of infrastructure to be covered by CIL to be as wide as possible to encompass physical, social and green infrastructure such as schools and parks. CIL should apply to most forms of development including residential and commercial development. Negotiated planning obligations will still be possible for site specific issues and to allow for affordable housing to be delivered on site. 20.7.2 On basis that these proposals are progressed, we will investigate the appropriateness of developing a Barnet CIL and whether this represents the most appropriate way of delivering the aims of this Core Strategy. Such an approach would build upon our current approach of using standard formulae to calculate contributions towards providing school places and contributions to libraries. The Barnet Infrastructure Delivery Plan will develop a robust methodology to set a viable charging schedule for CIL. 20.7.3 As part of the introduction of CIL new restrictions on the use of S106 were introduced in order for the two mechanisms to complement each other. Failure to utilise the information from the Infrastructure Delivery Plan towards the delivery of a Community Infrastructure Levy could limit the Council’s ability to secure financial
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contributions towards infrastructure from development. Therefore, once detailed Community Infrastructure Levy guidance is published by the government, existing Section 106 guidance must be replaced with a new ‘charging schedule’ by July 2014. 20.8 Planning obligations 20.8.1 We will use planning obligations (also known as S106 agreements) in appropriate circumstances and in accordance with Circular 05/05 - Planning Obligations, to influence the nature of a development or mitigate or compensate for its potential affects. Where existing and planned provision of infrastructure, facilities and services are not adequate to meet the needs generated by a proposal, we will negotiate planning obligations to secure measures to meet those needs. 20.8.2 Planning obligations can help to contribute to the success of a development and achieving our aims for a site, its local area and the borough as a whole. They can enhance the quality of a development and enable proposals to go ahead that would otherwise be refused. Planning obligations will only be sought where it is not possible to deal with the matter through the imposition of a condition on a planning permission. 20.8.3 The items sought through a planning obligation will vary depending on the development scheme and its location. Our S106 priorities are: priorities for residential development improvements to public transport infrastructure, systems and services education provision affordable or special needs housing priorities for commercial development improvements to public transport infrastructure, systems and services small business accommodation and training programmes to promote local employment and economic prosperity town centre regeneration, promotion, management and physical environmental improvements other benefits sought as appropriate highway improvements environmental improvements provision of open space other community facilities 20.8.4 In considering planning obligations, we will take into account the range of benefits a development provides. The extent to which a development is publicly funded will also be taken into account and policy applied flexibly in such cases. Pooled contributions will be used when the combined impact of a number of schemes creates the need for infrastructure or works. 20.8.5 Additional detail on our approach to planning obligations is set out in the Interim Guidance Note on Section 106 which has been brought forward in response to the recession. 20.9 Cross boundary working 20.9.1 We are working with neighbouring boroughs, the wider North London sub-region and other north London local authorities to ensure that Barnet's Core Strategy takes
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account of their plans and programmes as well as the spending and delivery plans of regional bodies such as Transport for London. 20.10 North London - Luton corridor 20.10.1 We will continue to work with Transport for London and Brent, Camden, and Harrow councils to develop a strategic approach to the management of locations with major growth potential along the London section of the London-Luton-Bedford co- ordination corridor. This focuses on the strategic co-ordination of infrastructure (including transport) to support and co-ordinate the growth potential of areas such as Brent Cross, Cricklewood, Mill Hill East and Colindale. 20.10.2 In partnership with Brent, Camden and Harrow we are working on developing the corridor concept further, starting with more detailed work on transport infrastructure and through engaging key partners to the north of London, such as Luton and Watford councils. This work will help build the case for investment in transport and social infrastructure to support growth (including that set out in this Core Strategy) by providing a basis for discussions with national providers as well as Transport for London. 20.11 Co-ordinating with neighbouring boroughs 20.11.1 We also work closely with neighbouring boroughs to ensure that a consistent approach is taken in relation to growth areas and town centres which adjoin or cross borough boundaries. The south west boundary of the Colindale Area Action Plan separates Barnet from Brent. Both boroughs recognise the opportunities for growth along the Edgware Road. The North Circular Road Area Action Plan adjoins our boundary with Enfield and we are discussing the impact of development of 2,000 new homes, delivered through renewal, refurbishment or redevelopment, on local transport and community infrastructure. We are discussing more detailed regeneration proposals as part of the New Southgate Supplementary Planning Document. As part of the Mayor’s All London Green Grid we will work with neighbouring authorities as well as the Corporation of London (responsible for management of Hampstead Heath) in the production of Green Grid Area Frameworks for Lea Valley and Finchley Ridge and Brent Valley and Barnet Plateau. 20.11.2 We have prepared some of our key evidence studies for this Core Strategy in conjunction with our neighbouring authorities: a Strategic Housing Market Assessment has been jointly undertaken with the other North London housing sub-region boroughs (Barnet, Enfield, Hackney, Haringey, Islington and Westminster) an Strategic Flood Risk Assessment has been produced jointly with Enfield, Hackney, Haringey and Islington A Decentralised Energy Initiative with Brent and the London Development Agency 20.12 Monitoring 20.12.1 We will monitor the effectiveness of the Core Strategy in delivering its objectives by assessing performance against a series of indicators as set out in Appendix B. These include core indicators, set by the government, and local, Barnet -specific indicators. 20.12.2 Each year we will publish an Annual Monitoring Report, which will:
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assess the performance of the Core Strategy and other LDF documents by considering progress against the indicators proposed set out Barnet's updated housing trajectory identify the need to reassess or review any policies or approaches make sure the context and assumptions behind our strategy and policies are still relevant identify trends in the wider social, economic and environmental issues facing Barnet Policy CS 15 - Delivering the Core Strategy We will work with Barnet's Local Strategic Partnership and other partners to deliver the vision, objectives and policies of this Core Strategy. We will: Utilise the Infrastructure Delivery Plan to improve understanding of current and future assets and their long term investment and management work with relevant providers to ensure that necessary infrastructure is secured to support Barnet's consolidated growth and development and provide the facilities needed for the borough's communities. use planning obligations and other suitable funding mechanisms to secure infrastructure, facilities and services to meet needs generated by development and mitigate the impact of development; work with neighbouring boroughs to co-ordinate delivery across boundaries; and monitor the implementation of the Core Strategy and publish the results in our Annual Monitoring Report.
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Appendix A – Brent Cross – Cricklewood
Suite of ‘Saved’ UDP Policies on Brent Cross – Cricklewood
Policy GCrick Cricklewood, Brent Cross and West Hendon Regeneration Area
Policy C1 Comprehensive Development
Policy C1(A) West Hendon
Policy C2 Urban Design – High Quality
Policy C3 Urban Design – Amenity
Policy C4 Sustainable Design
Policy C5 West Hendon and Cricklewood Town Centres
Policy C6 Brent Cross New Town Centre
Policy C7 Transport Improvements
Policy C8 Parking Standards
Policy C9 Housing and Community Development
Policy C10 Employment
Policy C11 Implementation
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Appendix B – Core Strategy Monitoring Indicators Proposed indicators CS Policy NI – National indicator reported annually by every Council LBB COI – Core output indicator reported in Barnet’s AMR LAA – Reported in the Local Area Agreement 2008 – 2011 LP AMR – Reported in the London Plan AMR LBBNew – New indicator to be reported
CS1: Barnet’s Net additional dwellings per annum (LAA 154) Place Shaping Housing quality – building for life (LBB COI) Strategy Amount of borough designated Metropolitan Open Land/Green Belt (LBB New) Coverage of Town Centres with Town Centre Frameworks or their equivalent (LBB New) CS2: Brent This section sets out the key monitoring indicators which we will use to monitor proactively progress being made towards initiation of the development permitted by the [proposed] planning Cross permission for the Brent Cross – Cricklewood regeneration project which is described in the information box contained in Section 7 of the Core Strategy and referred to in Policy CS 2. This Cricklewood is an important strategic policy and if the anticipated progress towards implementation of the planning permission (or any associated permission) is not achieved, we will consider whether there is a need to review the Core Strategy and/or to consider alternative policy initiatives to fulfil the community’s needs. We will not apply the milestones set out in this section rigidly. They will be used in a flexible and sensible manner to gauge progress towards implementation of this important regeneration project and to assess the risk that the benefits and outputs from it (as anticipated in the core strategy) may be delayed or lost. If such a risk is found to exist in the course of monitoring and review, will carefully consider measures that may be needed to address it, including the possibility of a review of the core strategy.
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Proposed indicators CS Policy NI – National indicator reported annually by every Council LBB COI – Core output indicator reported in Barnet’s AMR LAA – Reported in the Local Area Agreement 2008 – 2011 LP AMR – Reported in the London Plan AMR LBBNew – New indicator to be reported Between 2010 and end 2012 Grant of the planning permission for Brent Cross-Cricklewood; Completion of a Planning Performance Agreement in accordance with paragraph 22 of Schedule 2 to the Initial Planning Agreement; BXC Public Consultation Strategy approved (Condition 1.23) and planning and development forums established (if appropriate); Detailed topographical and geotechnical surveys undertaken; Existing Open Space site measurement approved (Condition 2.3) Detailed relevant transportation survey work undertaken to underpin the pre-commencement transport approvals under the permission; Discharge of relevant pre-reserved matters conditions, including: o A5 Corridor Study (Condition 2.7) o Construction Consolidation Centre Feasibility Report carried out and approved (Condition 1.9); o Framework Servicing and Delivery Strategy (Condition 1.21) o Phase 1 Transport Report (Condition 37) o Area Wide Walking and Cycling Study (Condition 1.20); o BXC Mobility Feasibility Study and Strategy (Condition 1.25) o RDF Feasibility Study submitted and approved (Condition 35.3); o Vacuum Waste Collection System Feasibility Study approved (Condition 1.24) o Construction Accesses approved in relation to the CHP/CCHP and WHF (condition 8.4); Work commenced in relation to detailed design of the Site Engineering and Preparation Works (Condition 1.8) including: o Identification of Remediation Zones and Sub-Zones for Phase 1 (Condition 31.1) o Commence preparation of the Site Specific Remediation Strategy for Remediation Zones in Phase 1 (Condition 28.7)
CS2: Brent Cross Cricklewood Detailed design work in relation to alignment of the primary and secondary road network within the development as the basis for fixing the Highways Orders needed to enable the development to proceed (Condition 13.1); Site assembly process progressed by way of: o negotiations with existing owners and occupiers o site acquisition strategy agreed and approved o progress in preparing the Residential Relocation Strategy (Condition 1.10) and the Business Relocation Strategy (Condition 46.3) o Compulsory Purchase Order boundary defined Site referencing process for the CPO commenced.
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Proposed indicators CS Policy NI – National indicator reported annually by every Council LBB COI – Core output indicator reported in Barnet’s AMR LAA – Reported in the Local Area Agreement 2008 – 2011 LP AMR – Reported in the London Plan AMR LBBNew – New indicator to be reported Between 2013 and 2014 Consultative Access Forum established Inclusive Access Strategy and Wayfinding Strategy approved (Condition 1.26) Clitterhouse Mobility Scheme approved (Condition 2.2) Pedestrian and Cycle Strategy approved (Condition 2.8) Estate Management Framework approved (Condition 7) Employment Skills Action Plan approved (Condition 10) Phase Car Parking Standards and Phase Car Parking Standards approved for Phase 1 (Condition 11.2) Scheme for Existing Landscape features in Phase 1 and Phase 1 arboricultural method statement approved (Condition 27) Site Engineering and Preparation Works (Phase 1) approved (Condition 1.8) including approvals to: o Identification of Remediation Zones and Sub-Zones for Phase 1 (Condition 31.1) o Commence preparation of the Site Specific Remediation Strategy for Remediation Zones in Phase 1 (Condition 28.7) Detailed approvals (Condition 13.1) obtained for: o primary and secondary roads in Phase 1 o Bridge Structure B1 (A406 Templehof Bridge) o Brent Cross Pedestrian Underpass o Bus Station Temporary Enhancement Works o Eastern River Brent Alteration and Diversion Works o River Brent Bridges (as relevant to the Eastern River Brent Alteration and Diversion Works) o Clarefield Park Temporary Replacement Open Space o Clitterhouse Playing Fields (Part 1); Other Phase 1A reserved matters approvals (Condition 1.2.1); Revised Indicative Construction Programme approved (Conditions 4.3, 4.4 and 5.3); Primary Development Delivery Programme and Detailed Delivery (Non PDP) Programme approved (Condition 5); Highways Orders made and/or promoted;
CS2: Brent Cross Cricklewood CPO made and submitted for confirmation. Between 2015 and 2016 CPO Confirmed; All Phase 1 interests acquired; All requisite interests in Phase 1 site bound into the Planning Obligations under the Initial Planning Agreement (Condition 6); All Necessary Consents for Phase 1 Critical Infrastructure (Pre-Phase) (including highways agreements and bonds) completed and in place (Condition 13.1); Phase 1A commences 2016/17 and will be carried out in accordance with the Primary Development Delivery Programme; Phase 1B reserved matters applications submitted and approved (2016/17);
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Proposed indicators CS Policy NI – National indicator reported annually by every Council LBB COI – Core output indicator reported in Barnet’s AMR LAA – Reported in the Local Area Agreement 2008 – 2011 LP AMR – Reported in the London Plan AMR LBBNew – New indicator to be reported Between 2016 and 2018 Phase 1B Commences and will be carried out in accordance with the Primary Development Delivery Programme Plot 1C Commences and will be carried out in accordance with the Primary Development Delivery Programme. Net additional dwellings per annum (LAA 154) CS3: Distribution Net additional dwellings in BXC, Colindale, Mill Hill East, West Hendon, Dollis Valley, Stonegrove and Spur Road and North London Business Park as a proportion of the annual total of growth in (LBB New). meeting housing aspirations Five year land supply (LBB COI) Percentage of dwellings completed at less than 30 dph, 30 to 50 dph and above 50 dph (LP AMR). Affordable homes delivered (gross) (LAA 155) CS4: Providing Delivery of housing mix in line with the Sub Regional Strategic Housing Market Assessment (LBB AMR) quality homes Tenure split (LBB AMR) and housing choice in Barnet Net additional gypsy and traveller pitches (LBB COI) Lifetime Homes and Wheelchair Accessible homes approved (LP AMR)
CS5: Protecting Net additional dwellings outside the growth areas, regeneration estates and identified thoroughfares (LBB New) and enhancing Number of buildings on the buildings at risk register (LBB New) Barnet’s Number of Conservation Area Appraisals less than 5 years old (LBB New) character Housing quality – building for life (LBB COI) CS6: Promoting Total amount of new floorspace for Town Centre Uses (LBB COI) Barnet’s town Net additional dwellings in town centres (LBB New) centres Coverage of Town Centres with Town Centre Frameworks or their equivalent (LBB New)
CS7: Enhancing Protection of open space (LP AMR) and protecting % of borough with public access to open space and nature (LBB New) Barnet’s open Proportion of Local Sites where positive conservation management has been or is being implemented (NI 197) Spaces Children and young people’s satisfaction with parks and play areas (NI 199) Total amount of net additional floorspace – by type and location [employment areas, town centres or other] (LBB COI New) CS8: Promoting Net new business VAT registrations (LBB New) a strong and Employment land available - by type (LBB COI) prosperous Commercial rents per m2 across borough (LBB New) Barnet Number of employment placements secured through S106 (LBB New) 16 to 18 year olds who are not in education, training or employment (NEET) (LAA 117) CS9: Providing Development and delivery of new bus routes (LBB New)
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Proposed indicators CS Policy NI – National indicator reported annually by every Council LBB COI – Core output indicator reported in Barnet’s AMR LAA – Reported in the Local Area Agreement 2008 – 2011 LP AMR – Reported in the London Plan AMR LBBNew – New indicator to be reported integrated and Number of Green travel plans provided as part of major applications (LBB New) efficient travel Children travelling to school – mode of travel usually used (LAA NI 198) Number of electric car parking spaces (LBB New) Delivery of step free access (LBB New) CS10: Enabling Delivery of the facilities identified in the Infrastructure Delivery Plan (LBB New) integrated New schools provided as part of the first class schools/new part private schools community Achieving independence for older people through intermediate care/rehabilitation (LAA 125) facilities and uses
CS11: Improving % of borough with public access to open space and nature (LBB New) health and well- Mortality rates from all circulatory diseases at ages under 75 (LAA 121) being in Barnet
CS12: Making Perceptions that people in the area treat one another with respect and consideration (NI 23) Barnet a safer Perceptions of anti-social behaviour (NI 17) place Overall/general satisfaction with local area (LAA & NI5)
CS13: Ensuring Per capita CO2 emissions in the Borough (LAA 186) the efficient use Number of planning permissions granted contrary to EA advice on either flood defence or water quality grounds (LBB COI) of natural Number of units connected to a decentralised energy network (LBB New) resources Air Quality and NOx and primary PM10 emissions (LBB Air Quality Management Area) Capacity of waste management facilities both new and existing (The North London Waste Plan will identify indicators and targets across all seven boroughs which will be reported in CS14: Dealing each boroughs AMR) with our waste Residual household waste per head (LAA 191) CS15: Delivering Delivery of identified infrastructure projects in the IDP (LBB New) the Core Strategy
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Appendix C – Core Strategy and Replacement of UDP Saved Policies (2006)30
Replaced by Replaced by UDP saved policies (2006) Core Strategy Development Policy Management Policy GSD Sustainable Development CS13 DM03 GMixed Use Mixed Use CS3, CS9 DM09 GWaste – Waste Disposal CS14 GBEnv1 Character CS5 DM01 GBEnv2 Design CS5 DM02 GBEnv3 Safe Environment CS5, CS12 DM02 GBEnv4 Special Area CS5 GL1 Sport and Recreation CS7, CS10 DM11, DM13 GL2 Tourist Facilities CS6 DM09 GRoadNet Road Network CS9 DM14 GParking Parking DM14 GCS1 Community Facilities CS10 DM11 GEMP1 Protecting Employment Sites CS8 DM12 GEMP2 Promoting Business Activities CS8 GEMP3 Maximising Job Creation CS8 DM09, DM10, DM12 GEMP4 Protecting Employment Land CS8 DM12 GTCR1 Retailing and Town Centres CS6 DM09, DM10 GTCR2 Range of retail services CS6 DM09, DM10 GCrick Cricklewood, Brent Cross and West Hendon regeneration area CS2 ENV5 – Aggregates Facilities DM01, DM03 ENV6 – Light Pollution CS13 DM01 Policy ENV7 – Air Pollution CS13 DM03 Policy ENV12 – Noise Generating Development CS13 DM03 Policy ENV13 – Minimising Noise Disturbance CS13 DM03 Policy ENV14 – Contaminated Land DM03 Policy ENV15 – Notifiable Installations DM03 Policy D1 – High Quality Design CS1, CS5 DM02 Policy D2 – Character CS5 DM02 Policy D3 – Spaces CS5 DM02 Policy D4 – Over-development CS5 DM01, DM02 Policy D5 – Outlook DM01, DM02 Policy D6 – Street Interest CS1, CS5 DM02 Policy D9 – Designing Out Crime CS12 DM02 Policy D10 – Improving Community Safety CS7, CS12 DM02 Policy D11 – Landscaping CS1, CS5 DM01, DM02, DM13 Policy D12 – Tree Preservation Orders CS7 DM13 Policy D13 – Tree Protection and Enhancement CS7 DM13 Policy D14 – Important Hedgerows CS7 DM13 Policy D15 – Other Hedgerows CS7 DM13
30 Excluding policies on Brent Cross –Cricklewood in Appendix A
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Policy D16 – Telecommunications DM15 Policy D17 – High Buildings – Acceptable Locations CS1 DM01 Policy D18 – High Buildings – Unacceptable Locations CS1 DM01 Policy D21 – Hoardings CS6 DM02 Policy D22 – Design and Shopfronts DM01 Policy D23 – Traditional Shopfronts DM01 Policy D24 – New Shopfronts DM09 Policy HC1 – Conservation Areas – Preserving or Enhancing CS5 DM04 Policy HC2 – Conservation Areas – Outline Applications DM04 Policy HC5 – Areas of Special Character CS5 DM01 Policy HC6 – West Heath/Golders Hill Park Area Policy HC7 – Development in West Heath/Golders Hill Park Area Policy HC8 – The Bishop’s Avenue Policy HC14 – Locally Listed Buildings – Demolition DM04 Policy HC15 – Locally Listed Buildings – Safeguarding DM04 Policy HC17 – Archaeological Remains CS5 DM04 Policy HC22 – Battlefield Site CS5 DM04 Policy O1 – Green Belt/Metropolitan Land CS7 DM13 Policy O2 - Green Belt/Metropolitan Land – New buildings and uses DM13 Policy O3 - Green Belt/Metropolitan Land – Extensions of buildings DM13 Policy O4 – Green Belt – Major developed sites Policy O5 - Green Belt/Metropolitan Land – Replacement of existing dwellings DM13 Policy O6 - Green Belt/Metropolitan Land – Re-use of buildings DM13 Policy O7 - Green Belt/Metropolitan Land -adjacent land DM13 Policy O8 – Green Belt – Agricultural Land Policy O12 – Green Chains CS7 DM13 Policy O13 – Green Corridors CS7 DM13 Policy O17 – Ecological Impact Statement DM13 Policy O18 – Watling Chase Community Forest CS7 DM13 Policy L1 – Arts, Culture and Entertainment (ACE) – Loss of Facilities CS10 DM11 Policy L3 – Arts, Culture and Entertainment Facilities – Development Criteria DM09, DM11 Policy L5 – Arts, Culture and Entertainment Facilities – Planning Obligations CS15 Policy L6 – Designing in Art CS15 Policy L7 – Tourist Facilities – Preferred Locations CS6 DM09 Policy L8 – Tourist Facilities – Retention CS6 Policy L10 – Hotels – Development Criteria DM09 Policy L11 – Public Open Space CS7 DM13 Policy L12 – Public Open Space – Areas of Deficiency CS7 DM13 Policy L13 – New Public Routes CS7 DM13 Policy L14 – Public Open Space – Improved Provision CS7 DM13 Policy L15 – Metropolitan Walks CS7 Policy L16 – Allotments CS7 DM13 Policy L19 – Sports Grounds and Playing Fields – New Provision CS7 DM13 Policy L20 – Floodlighting of Sports Facilities DM01 Policy L21 – Synthetic Sports Pitches CS7 DM13 Policy L22 – Golf Courses Policy L23 – Indoor Sports and Recreation Facilities – Protection CS10 DM11 Policy L24 – Indoor Sports and Recreation Facilities – New Provision CS10 DM11 Policy L25 – Indoor Sports and Recreation Facilities – Preferred Locations CS10 DM11, DM13 Policy L26 – Indoor/Outdoor Sports and Recreation Facilities CS7, CS10 DM11 Policy L27 – Indoor/Outdoor Sports and Recreation Facilities CS7, CS10 DM11 Policy M1 – Transport Accessibility CS9 DM14, DM09
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Policy M2 – Transport Impact Assessments CS9 DM14 Policy M3 – Travel Plans CS9 DM14 Policy M4 – Pedestrians and Cyclists – Widening Opportunities CS9 DM14 Policy M5 – Pedestrians and Cyclists – Improved Facilities CS9 DM14 Policy M6 – Public Transport – Use CS9 Policy M7 – Public Transport – Improvements CS9 Policy M8 – Road Hierarchy DM14 Policy M9 – Road Improvement Schemes CS9, CS15 Policy M10 – Reducing Traffic Impact CS9 Policy M11 – Safety of Road Users CS11 DM14 Policy M12 – Safety of Road Network CS11 Policy M13 – Safe Access to New Development CS11 DM14 Policy M14 – Parking Standards DM14 Policy M15 – Rail Freight CS9 Policy M16 – Lorries – Controls on Movements Policy M17 – Lorries – Deliveries and Servicing CS9 DM12 Policy H1 – Housing – Allocated Sites CS3 Policy H2 – Housing – Other Sites CS3 Policy H3 – Loss of Residential Uses DM05 Policy H5 – Affordable Housing CS4 DM08 Policy H8 – Affordable Housing – Commuted Payments DM08 Policy H9 – Houses in Multiple Occupation CS4 DM07 Policy H10 – Accommodation for Homeless People CS4 DM07 Policy H11 – Accommodation for Homeless People – Planning Obligations Policy H12 – Special Needs Housing CS4, CS10 DM07 Policy H15 – Sites for Gypsies and Other Travelling People CS4 Policy H16 – Residential Development – Character CS5 DM01 Policy H17 – Residential Development – Privacy Standards CS5 DM01 Policy H18 – Residential Development – Amenity Space Standards DM01, DM02 Policy H20 – Residential Development – Public Recreational Space CS7 DM13 Policy H21 – Residential Density CS3 Policy H23 – Conversion of Residential Property CS4, CS5 DM01 Policy H24 – Conversion of Non-residential Uses CS8, CS6, CS10 DM01, DM02 Policy H26 – Conversion of Residential Property – Design DM02 Policy H27 – Extensions to Residential Property DM01 Policy CS1 – Community and Religious Facilities CS10 DM11 Policy CS2 – Community and Religious Facilities – Planning Obligations CS10, CS15 DM11 Policy CS3 – Community and Religious Facilities – Protection CS10 DM11 Policy CS4 – Educational Facilities CS10 DM11 Policy CS5 – Educational Facilities – Shared Use CS10 DM11 Policy CS6 – New School Sites CS10 DM11 Policy CS7 – Surplus Educational Land and Buildings CS10 DM11 Policy CS8 – Educational Needs CS10 DM11 Policy CS9 – Enlargement of School Facilities CS10 DM11 Policy CS10 – Health Care Facilities CS10, CS11 DM11 Policy CS11 – Health Care Facilities – Multiple Use CS10, CS11 DM11 Policy CS12 – Social Day Care Facilities CS10, CS11 DM11 Policy CS13 – Health and Social Care Facilities CS10, CS11 DM11 Policy CS14 – Surplus Health Care Facilities CS10, CS11 DM11 Policy CS15 – Cemeteries and Crematoria Policy CS16 – Utility Companies and Statutory Undertakers CS15 Policy GEMP1 – Protecting Employment Sites CS8 DM12
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Publication Stage
Policy EMP1 – Primary Industrial Sites and Business Parks CS8 DM12 Policy EMP2 – Employment Land – Protection CS8 DM12 Policy EMP3 – Employment Land – Consolidation CS8 DM12 Policy EMP4 – North London Business Park CS3 Policy EMP5 – Warehousing CS8 DM12 Policy EMP6 – Offices – New Development CS8 DM12 Policy EMP7 – Offices – Re-use CS8 DM12 Policy EMP8 – Small Businesses CS8 DM12 Policy EMP9 – New Residential Development Policy EMP10 – Live Work Accommodation Policy TCR1 – Sequential Approach CS6 DM09 Policy TCR2 – Town Centre Development Sites – Identified CS6, CS3 Policy TCR3 – Town Centre Development Sites – New Policy TCR5 – Edge-of-Centre CS6 DM09 Policy TCR7 – Out-of-Centre Locations DM09 Policy TCR10 – Primary Retail Frontages DM09 Policy TCR11 – Secondary Retail Frontages DM09 Policy TCR12 – Evening Uses in Town Centres CS6 DM09 Policy TCR13 – Residential Development in Town Centres CS6 DM09 Policy TCR14 – Minicab Offices Policy TCR15 – Car Showrooms Policy TCR16 – New Markets CS6 Policy TCR18 – Mixed Use Development CS3 DM09 Policy TCR17 – North Finchley Town Centre CS3, CS6 Policy TCR19 – Neighbourhood Centres, Shopping Parades and Local Shops CS6 DM09 Policy TCR21 – Town Centre Environmental Quality CS5, CS6 Policy TCR22 – Design of New Retail Development DM09 Policy IMP1 – Priorities for Planning Obligations CS15 Policy IMP2 – Use of Planning Obligations CS15
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Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations
# Initials Surname Body Policy Comments Council’s response Council’s proposed action Representor # Representation 2 1 Universities CS1 Barnet's Drivers Jonas is instructed by Universities Superannuation Scheme (USS) to advise on We welcome this support None 4 Superannuation place shaping planning matters in respect of its commercial assets at Finchley Industrial Centre and 0 Scheme (USS) strategy Capitol Park in Colindale. USS therefore has an active interest in the formulation of planning policy in the LB Barnet. The overarching vision promoted by the LB Barnet seeks to ensure that Barnet is known nationally and internationally as a successful city suburb, consistently secure new employment opportunities and make Barnet a place where people want to live and enjoy a high quality of life. A number of core objectives are outlined within the document to secure this aim. USS agrees with the council's objectives which seek to promote Barnet as a place of economic growth and prosperity and to ensure efficient use of land. In addition USS agrees with the council's three strands approach particularly strand 3 which seeks to achieve growth that is sustainable so as to achieve successful regeneration and high quality development. USS agrees with Policy CS 1 as it seeks to promote growth in Barnet and to provide opportunity for economic advancement. 2 1 Ian Dubber Workspace CS1 Barnet's Workspace supports the planned economic growth in the west of the borough and the The Core Strategy clearly None 4 Group PLC place shaping Opportunity and Intensification areas however this sets out the places where 1 strategy would not prevent development from being delivered in other locations within the borou major growth is going to gh. Such a rigid restriction would undermine the principles of PPS1 and PPS3 which pr happen in the borough. omote sustainable communities. Furthermore such an approach would have a negative However this does not impact upon the property market in Barnet and could sterilise some areas and undermi preclude proposals for ne housing delivery. smaller growth coming forward outside these areas. 2 2 Peter Storey Friern Village CS1 Barnet's Growth must be limited and public transport infrastructure must be improved prior to Policy in the Core Strategy None 4 Residents place shaping any other building work. Provision must be given to providing community centres and sets out what key transport 2 Association strategy parks. infrastructure is going to be Green spaces must be a part of any new development. provided to support growth. The Infrastructure Delivery Plan sets out what, when, where and how it translates into delivery over the next 15 years including transport, community facilities and parks. It would be for TFL as the London wide strategic transport authority to review the entire proposed light rail scheme as it proposed to cross several London boroughs. We expect new development to make a contribution to the provision of open space.
175 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 2 A2 Dominion CS1 Barnet's Our client notes that the above section states that ‘a new rail linked Waste Handling The Core Strategy has been New policy 7 Housing place shaping Recycling Facility to replace and significantly enhance the existing Hendon Waste revised and a new policy on C2 on Brent 4 strategy Transfer Station facility is proposed on a site fronting Edgware Road (A5) and Geron Brent Cross Cricklewood Cross – Way. This will be secured in partnership with the North London Waste Authority whose introduced in order to make Cricklewood existing Hendon Waste Transfer Station will close’. Furthermore, Preferred Policy CS 1 clear that the planning seeks to concentrate housing growth in well located areas that provide opportunities for framework for the area growth. As such it is identified that the Council will focus major housing and economic consists of the Core growth in the most suitable locations and that the focus for housing and employment Strategy, London Plan, growth will be in the strategically identified North West London – Luton Coordination saved suite of UDP policies Corridor. Preferred Policy CS 1 states that Brent Cross – Cricklewood, along with on Brent Cross Cricklewood Colindale and Mill Hill East are growth areas and the Key Diagram – Map2, identifies and the Development that the former Parcel Force Site on Edgware Road to be within this growth area. Framework SPG. The former Parcelforce site is identified for residential-led redevelopment in the Brent Cross Cricklewood Regeneration Area Framework SPG (2005) and UDP policy, with a planning application currently under consideration for this type of development. The Core Strategy policy should reflect the adopted SPG, the UDP and the planning application for the regeneration area which now has a resolution to approve, with the provision of a building for business uses which would provide a buffer between the former Parcelforce site and the proposed Waste Handling Recycling Facility. The adopted SPG states that this adjacent building should be sensitively designed to minimise potential ‘bad neighbour’ relationships, with one façade designed to address the proposed waste handling facility and the other designed to suitably address the residential-led redevelopment of the former Parcelforce site. The policy and preamble should be amended to accurately reflect the adopted SPG and the planning application for the regeneration area which now has a resolution to approve.
3 4 Asda Stores Ltd CS1 Barnet's We support the Council’s intention to enhance the existing centres within the Borough There are several brownfield None 7 place shaping and fully agree that New Barnet should be listed as an existing centre which the site opportunities in and on 9 strategy Council aim to enhance. the edge of New Barnet and New Barnet is an identified centre that has suffered from decline in recent years. In it is important that we adopt accordance with national policy it is highly suitable for mixed use development and this an planned approach to such should be encouraged to maintain and enhance the vitality and viability of the centre. opportunities. The New Specific policy should be included that acknowledges that central site should bring Barnet Town Centre forward very high density development in order to make the best use of accessible Framework is being Brownfield sites, in line with Government guidance. developed to manage change in consultation with the community. PPS1 recommends that all those involved in the development process should aim for high quality and inclusive design. Density should not drive development; it is an important factor, along with the local context, design, transport and infrastructure. The Core Strategy clearly sets out that we seek high quality design that is 176 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations appropriate to the growth being sought.
4 2 Matthew Thomas Bride Hall CS1 Barnet's Bride Hall is supportive of the Three Strands Approach that has been developed as the We welcome this support None 0 Holdings Ltd place shaping over-arching vision for planning, development and regeneration within the Borough. In 4 strategy particular, Bride Hall sees Strands Two and Three as issues that it can have a positive influence on through our interest in The Broadwalk Shopping Centre.
4 3 Matthew Thomas Bride Hall CS1 Barnet's Policy CS1 identifies Edgware Town Centre as a suitable location for major growth and The Site Allocations DPD is None 0 Holdings Ltd place shaping an area that needs enhancement over the coming years. This approach is supported as the appropriate document for 4 strategy The Broadwalk Centre in Edgware has the capacity to accommodate additional site specific considerations development consisting of a mix of retail, leisure and residential uses. Plans are now alongside the Town Centre being prepared for a substantial extension to the store that will secure the vitality and Framework. viability of the Town Centre. It is important to ensure that any such proposals are Residential is not recognised capable of delivery and the initial plans contain a mix of uses that is yet to be finalised as a main town centre use. as demand for these uses is assessed. Therefore a flexible planning policy position for The Core Strategy supports the Town Centre is supported to ensure that Edgware has the range of services that residential as part of mixed are suitable to its role as a Major Centre. Residential use is currently being considered use developments in town as a component of the proposals, it is also considered, however, that the main function centres that contribute to of the centre as a retail destination that serves the wider Edgware and Barnet area their vitality and viability. should be the primary development objective. It is therefore important that any inclusion of residential units as part of these proposals is entirely appropriate and does not compromise the primary function of the Broadwalk Centre. 4 1 Julia Hines Age Concern CS1 Barnet's We support the 3 Strands Approach We welcome this support None 1 place shaping 8 strategy
177 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Tesco Stores CS1 Barnet's The policy should acknowledge that, in accordance with national and regional policy, CS 1 represents our place None 2 Ltd place shaping promoting the vitality and viability of centres will in some cases mean growth and shaping strategy. Our 7 strategy intensification. The Consultation Draft Replacement London Plan (October 2009) approach to town centre places a new emphasis on enhancing the Outer London economy by identifying and regeneration is clear and bringing forward capacity in and around town centres and enhancing town centres consistent with national through higher density mixed use development. The policy refers to the enhancement policy and the revised draft of the “six largest town centres”. To accord with PPS4 and the London Plan the policy London Plan. The Three should refer to promoting the vitality and viability of centres (as important places for Strands Approach sets a communities) rather than ‘enhancing’. This applies to all designated centres in the clear spatial agenda for borough, not just the six largest town centres. Barnet whereby growth is complimented by protection and enhancement. Our approach to promoting town centres falls under the enhancement strand. The policy is in line with national and regional policy and there is no need to repeat what is said in the London Plan. 4 3 Dennis Pepper Barnet Borough CS1 Barnet's References throughout the document to the provision and use of Barnet’s The greening of the built Revise 3 Group London place shaping green/open/natural spaces show a worryingly narrow view. They should be protected, environment provides a section on 0 Wildlife Trust strategy we are told, because they ‘are important to the health of our residents’ and because significant contribution to open spaces they ‘provide opportunities for sport, recreation and play’ (7.1.13). However, our climate change adaptation. to add ‘natural’ environment is not primarily a human plaything, though people may well enjoy The provision of green references to the benefits that flow from it. infrastructure is highlighted Blue Ribbon throughout the Core Network, Strategy. We do recognise Watling that not only people will be Chase affected and have added Community references to green Forest and corridors, Blue Ribbon green Network and Watling Chase corridors Community Forest. 4 3 Starfield CS1 Barnet's We concur with the enhancement of the six largest town centres, including the We welcome this support None 3 Properties / St place shaping promotion of mixed-use developments 1 James strategy Investments
178 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Robert Newton CS1 Barnet's Reason: The existing wording of Policy CS1 does not reflect Paragraph 2.3.1 and it Policy CS1 has been revised None 3 place shaping should. to make it much clearer how 6 strategy Under the heading “Protection of” add to “Green Belt and Metropolitan Open Land that it sets the spatial agenda covers over one third of Barnet” the words “together with other valued open space to and how the main place include parks, public and private playing fields, public and private amenity open spaces shaping policies sit within the and the Borough’s allotment sites” Three Strands Approach. The heading “Enhancement of” should be changed to “Enhancement and Protection of” Through the Development Under the heading “Enhancement and Protection of” Management policies we will Add to the first bullet point on Town Centres the words “within the existing town centre establish town centre envelopes that will not be extended to include adjoining suburban houses.” boundaries for major and Add a new bullet point with the words “Barnet’s suburban housing stock and suburban district town centres. shopping parades.” Amend the wording of Paragraphs 7.1.1 to 7.1.14 where necessary to reflect these changes to Policy CS1.
4 1 P E Pickering CS1 Barnet's There are several other places where the Policy is weaker than the text paragraphs that The supporting text is more None 3 place shaping support it. This is dangerous, since citizens relying on the text may be lulled into a false expansive because it sets 7 strategy sense of security, though an Inspector on appeal would follow the Policy wording. The the context for the policy. Council must harmonise the wording of all Policies with that of the supporting text. The text forms part of the Policy CS1 This includes the words "Protection of Green Belt and Metropolitan Open development plan and is Land . . . " Paragraph 2.3.1 however includes 'other valued open space' as well as therefore a material 'Green Belt and Metropolitan Open Land'. consideration. Policy CS5 'Other valued open space' must be added in CS1. clearly sets out our approach to protecting open space. 4 2 Zenda Green Mill Hill CS1 Barnet’s Central to the Core Strategy is the Council’s Three Strand Approach. Strand 1- The Infrastructure Delivery Publish 3 Preservation place shaping Absolute protection of the Green Belt, Metropolitan Open Land and other open space Plan sets out what, when, monitoring 9 Society strategy from inappropriate development. We recognise that it is more important than ever to where and how it translates indicators in protect our Green Open Spaces and Green Belt Land especially with the demand for into delivery over the next 15 Appendix B. dwellings in Barnet. However Barnet Council need to be stronger about protecting the years including transport, Our Conservation Area and vigilance in the Green Belt needs to be improved. We are community faculties and monitoring concerned that Barnet Council will be unable to take swift action on the ever increasing parks. In the section on indicators will number of encroachment, inappropriate and deviation from agreed planning Making Barnet a Safer Place measure applications, and with the lack of enforcement officers, Barnet presently seem to be we highlight that community community unable to cope with the current amount of enforcement actions outstanding. We are cohesion needs to be cohesion. also concerned within this strand what “inappropriate developments” actually means. measured across the Strand 2- Enhancement and protection of Barnet’s suburbs, town centres and historic borough with a focus on
179 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations areas. growth areas such as Mill Barnet’s strengths as a successful suburb are underpinned by it’s historic character, Hill East and the areas that wealth and quality of green spaces,medium to low density housing, good public surround them. The adopted transport links and (reasonably good) community facilities. However with the projected AAP for Mill Hill East is in increase in people living and working within Barnet this will change the character of the general conformity with the area forever. Mill Hill East is already losing green space to massive development. How London Plan. Over its 15 can our suburbs be truly protected when their character is being eroded?Strand 3- year life span the area is Growth that is sustainable so as to achieve successful regeneration and high quality expected to deliver 2,000 development. Mill Hill Preservation Society would argue that sustainable communities new homes. come with time. How are the increased population of Barnet expected to socially integrate so quickly? Sudden growth can break good community spirit. Where are the new facilities that will be required for the ever increasing Barnet population? Also Mill Hill Preservation Society needs clarity. The London Plan set’s 3,500 new homes for Mill Hill East by 2026 (P2) yet this LDF commits to a total of around 2,600 residential units including 2,000 new units (P26) Please can we have clarification on the true amount.The Core Strategy key policies (CS1 to CS14) have the greatest influence on change. Mill Hill Preservation Society will comment on these in turn.
4 3 Zenda Green Mill Hill CS1 Barnet’s This should place further emphasis on Barnet’s existing historic and suburban The Characterisation Study None 3 Preservation place shaping character. Key growth areas, and in particular the Mill Hill East AAP, should will help inform the 9 Society strategy acknowledge the impact that such a significant increase in density will have on the protection of the suburban surrounding suburban character. character with further policies identified in the Development Management DPD. 4 3 Brent Cross CS1 Barnet’s Minor modifications are suggested to paragraph 7.1.7 to ensure consistency with the In the absence of an None 4 Cricklewood place shaping application as submitted including reference to 27,000 jobs rather than 20,000. approved application for 0 Development strategy Brent Cross-Cricklewood the Partners Core Strategy will retain reference to the targets in the existing London Plan.
180 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Brent Cross CS1 Barnets The text box supporting Policy CS1 explains the nature of the BXC proposals. It is We have revised this Revise 4 Cricklewood place shaping suggested that the text is revised to state : information box to reflect information 0 Development strategy Resolution to grant an outline permission for the application which will establishment of progress on the planning box on Brent Partners a masterplan and framework for the comprehensive regeneration of the Brent Cross process and to support the Cross Cricklewood Area in accordance with relevant development plan policies was submitted introduction of a new Cricklewood in March 2008 approved in November 2009….. strategic policy on Brent The application proposals include approximately 7,550 housing units, of which 2,250 Cross - Cricklewood (CS2). are expected targeted, subject to tests of viability, to be affordable. In addition the application proposes proposals involve the radical transformation as well as the approximate doubling in size of Brent Cross Shopping Centre, which will be focused on a new High Street which traverses the North Circular Road. …… This The High Street south of the North Circular Road will include new schools and comprise a mix of uses including community uses……….. o subject to feasibility studies, a new Waste Handling Facility and Combined Heat and Power Plant are also proposed as part of Phase 1 and will provide a significant proportion of renewable on site energy generation;……. o contributions toward improvements to Brent Cross Underground and Cricklewood stations are proposed; o significant improvements to bus services in North West London including a new Rapid Transit Service between Cricklewood Station, Brent Cross Station and the new town centre shopping areas with potential extension to other nearby tube stations such as Hendon Central: and……. Brent Cross - Cricklewood will is expected to be delivered over a twenty year timescale in seven phases. Phase 1 will include around 50% of the proposed new retail development focused on Brent Cross Shopping Centre which in terms of viability will provide………. Around 1,300 housing units will be provided in Phase 1. The implementation of the development will depend on a number of factors including viability, phasing and delivery.
181 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Warren Forsyth Middlesex CS1 Barnet’s The University supports the regenerative development initiatives that form part of the Agreed Revise 4 University place shaping Three Strands Approach, as identified in 7.1.7, and is keen to play a positive role, information 1 strategy particularly in the Colindale growth area. There is a slight inaccuracy in the description box on of the Colindale proposals as currently set out, which the University suggests should be Colindale to rectified. While existing Middlesex University halls of residence are within the Colindale reflect Avenue Corridor of change, the proposal is to replace these and provide additional existing and student accommodation in a new student village within the Aerodrome Road Corridor of proposed Change. This will enable the existing halls site to be redeveloped for housing and student mixed uses and to provide for necessary highway/junction arrangements. The new housing student village is proposed indicatively at the eastern end of the new Aerodrome Park where it would be easily accessible by foot or cycle from the Middlesex University Hendon campus. We suggest that the text describing the Colindale Avenue proposals be amended by replacing in the third sentence the words “.new student accommodation for Middlesex University…” by “…the relocation of Middlesex University student accommodation to the Aerodrome Road Corridor of Change…”. There should also be a corresponding amendment to the text for Aerodrome Road. We suggest that the last sentence be amended to read “A new 5 ha Aerodrome Park will be provided, as will new commercial facilities along Aerodrome Road and a new student village for Middlesex University, to support consolidation and redevelopment of the Peel Centre.”
4 3 British Library CS1 Barnet’s The BL welcomes Barnet’s place shaping strategy – ‘The Three Strands’ which We welcome this support None 4 place shaping includes the optimisation of opportunities for major development growth, through 2 strategy regeneration of previously developed land (paragraph 7.1.4). The BL is supportive of the strategy to focus development on previously developed land and Colindale’s allocation as a ‘growth area’ within Policy CS1. The BL support the principles of Policy CS1 to “concentrate housing growth in well located areas that provide opportunities for growth, creating a sustainable quality environment that will have positive economic impacts on the deprived neighbourhoods that surround them.” The BL site sits within the Colindale Avenue ‘Corridor of Change’ as identified in the CAAP. The BL site is in a particularly sustainable location being in such close proximity to the Colindale tube station and the bus services on Colindale Avenue. The site’s housing allocation will help contribute to the delivery of 2,370 new homes between 2007 and 2021 in the Colindale Avenue area of change. This will go some way to the delivery of 10,000 new homes in Colindale as a whole over the CAAP period, helping to meet the Core Strategy’s spatial vision objectives for the Borough. The BL welcome the acknowledgement of the Colindale growth area and reference to the CAAP in the Core Strategy. 4 7 Graham Saunders English Heritage CS1 Barnets The wording of the Policy could be strengthened with regards to the enhancement of Agree amendment. The Policy CS 1 4 place shaping the Borough’s historic environment. At present the Policy is disjointed and not Core Strategy clearly sets has been 6 strategy sufficiently robust. out how the protection and revised to. In particular we would seek to ensure the protection and enhancement of the historic enhancement strands will suburban environment of all Borough heritage assets. This includes conservation compliment growth. Barnet’s areas, listed buildings, registered historic parks and gardens and other buildings and heritage and historic spaces of local character importance. environment will be In addition the historic environment of the Borough’s town centres should also be enhanced and protected protected and enhanced.
182 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 HI (Brent Cross) CS1 Barnets Policy CS1, which seeks to promote housing and employment growth within Brent The Core Strategy has been New policy 5 Ltd place shaping Cross Cricklewood highlights in the amplification and supporting text, that "The bridging revised to reflect that C2 on Brent 1 strategy of the North Circular road with a new Metropolitan scale sustainable town centre will proposals on Brent Cross Cross – create the heart and focus of activities at the 'hub' of Brent Cross Cricklewood." Whilst Cricklewood are well Cricklewood. a resolution to grant consent for the outline application was made at the planning advanced. With a new policy and committee meeting on 19 November 2009, the precise detail of this bridge link is to be on Brent Cross Cricklewood supporting considered at the Reserved Matters stage. It is therefore considered, at this stage, that we make it clear that the text. Revise no commitment can be given to such link, as there is no formal planning permission to planning framework for the information reasonably suggest that it can be delivered. area consists of the Core box on Brent The Core Strategy also refers to the Cricklewood, Brent Cross and West Hendon Strategy, London Plan, Cross - Regeneration Area Development Framework SPG, however, the supporting text for saved suite of UDP policies Cricklewood policy CS1 only refers to the outline application, which is yet to be granted formal on Brent Cross Cricklewood planning permission, and therefore cannot be re As advocated in PPS12 'plans should and the Development be able to show how they will handle contingencies: it may not always be possible to Framework SPG. The new have maximum certainty about the deliverability of the strategy. Authorities should not policy is subject to specific necessarily rely on a review of the plan as a means of handling uncertainty'. In these indicators to reflect progress terms, there appears no alternative policy for the regeneration of the Brent Cross on implementation of Cricklewood and West Hendon Area, should consent not be granted or the scheme proposals and infrastructure fails to be delivered. In addition, reliance is placed on Supplementary Planning before 2015/16. If milestones Guidance that was adopted in 2005. As acknowledged in PPS12 'Council's should not are not delivered or are not produce planning guidance other than SPD where guidance is intended to be used in capable of being delivered decision making or the coordination of development. this will prompt a review of This could be construed as wishing to circumvent the provisions for consultation and the Core Strategy sustainability appraisal'. The document has not been formulated on the basis of the most up to date background information, as is required for the Core Strategy, as such may soon, if it is not already become outdated. Therefore, the regeneration of the Brent Cross Cricklewood and West Hendon Regeneration Area should be brought forward by way of an Area Action Plan or Supplementary Planning Document, whereby mechanisms are in place under the LDF system for continual review, consultation and update as required.
183 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Mike Dawson Finchley Society CS1 Barnet’s We agree that it is a better option to concentrate housing growth in well-located areas, With supporting None 5 9 place shaping so protecting the suburbs. Our concern is that the areas identified are being over- infrastructure development 5 strategy developed, and with too narrow a range of housing type (affordable) rather than with can be sustainable so delivering a greater range and variety of accommodation. This position is exacerbated therefore no change to policy by allowing large-scale developments to hive-off required affordable housing to is necessary. Our two development sites, which already have such development. Too high a concentration of adopted AAPs for Colindale this type could be creating the ghettos of tomorrow. and Mill Hill East have The scale of regeneration at Colindale cannot be called ‘sustainable’ when it is demonstrated that it can be acknowledged that: delivered. “The wider strategic network (roads) in this part of London is congested, and there are a number of strategic constraints on Traffic levels and speeds which are beyond the There is no confusion on scope of the AAP.” policy protection of the You know there are problems, which will worsen, so you simply ignore them! You then Green Belt. For clarification plan overdevelopment by claiming travel within the area (of new housing) will be please see national planning improved. Add to this the increased pressure from developing the A5 corridor and a policy guidance (PPG) note truly unsustainable community is being developed. Knowingly creating sustainability 2 on Green Belts. problems for the surrounding area of Barnet cannot be a sound policy. Brent Cross and its impact Policy on protection of Green Belt and the suburbs is confused, depending on which on Barnet's Town Centres document/section of Barnet’s LDF you read. For example, Green Belt land will either were considered as part of get: ‘Absolute protection or, ‘protection from inappropriate development’ the planning application Enhancement of the six largest town centres is welcomed. Retail space here needs to which the council resolved to include shops that can found at Brent Cross to limit car use. What we see planned is a approve subject to S106 in huge expansion of Brent Cross retail space that will threaten the viability of these six November 2009 town centres. Again, confused policy plus denial of the impact of traffic/transport issues The housing target in the caused by residents distant to Brent Cross having to travel there. Core Policy CS 1, paragraph should be amended to read: Strategy is lower than that of The Council, along with its partners, will focus major housing and economic growth in the revised draft London the most suitable locations and manage it to ensure that we deliver sustainable Plan and this presents a development and infrastructure, while continuing to conserve and enhance the challenge for Barnet. Further distinctiveness of Barnet as a place to live work and visit. clarification on the 15 year Policy CS 1, add new paragraph to read: housing target is provided at Growth will be maintained to a level required by the London Plan but not exceeded. paragraph 7.1.10 Sustainability appraisals will include a test of the impact of development on surrounding areas, to include the local road network and infrastructure
4 2 Patrick Blake Highways CS1 Barnet’s The HA is supportive of the Three Strands Approach which concentrates new We would welcome the Publish 5 Agency place shaping development in the most accessible locations around public transport nodes and town Highways Agencies Infrastructure 6 strategy centres where social and physical infrastructure is to be improved. However, it is contribution to our Delivery Plan recommended that development should be appropriately phased with infrastructure Infrastructure Delivery Plan. provision. This will help ensure that the development is in line with national guidance We consider that the policy and hence PPS12 (2008). wording is clear that infrastructure is secured to support growth. The where, when, what and how is set out in the Infrastructure Delivery Plan.
184 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 HIGH Trust CS1 Barnet’s I support the approach outlined in Policy CS1 that seeks to concentrate new housing in We welcome this support None 5 place shaping well located areas. Encouraging growth towards well connected areas of the Borough is 7 strategy in accordance with the Governments approach of sustainable development and creating quality environments. Existing urban centres such as Whetstone are suitable areas to focus new development as they provide a range of services such as shopping and leisure facilities as well as access to jobs and the transport network. This approach would also facilitate the improvement of existing infrastructure, the benefits of which could trickle down to the least prosperous areas of the borough. 4 2 David Howard Federation of CS1 Barnet’s Barnet’s document while purporting to be based on the Three Strands policy actually The Three Strands approach None 6 Residents place shaping promotes Growth at the expense of Protection and Enhancement. References to the sets a clear spatial agenda 4 Associations in strategy Three Strands policy appear to refer to later editions which water down the more for Barnet. This place Barnet (FORAB) prescriptive clauses of the original 22nd November 2004 version which is the only one shaping strategy is integral approved by councillors at Cabinet. to our Core Strategy which was approved by Cabinet on 21 October 2009. 4 3 marcus dickinson CS1 Barnet’s More cycle friendly roads The promotion of public None 6 place shaping transport, walking and 5 strategy cycling are all included within the section on providing effective and efficient travel. 4 3 A Reid Mount Anvil Plc CS1 Barnet’s The promotion of Finchley Central (Church End) as a location for high-density mixed- We welcome this support None 6 place shaping use development, as stated in CS1, is supported. The Core Strategy (8.31) stresses 6 strategy the optimisation of housing density. However, in town centre locations, with good public transport accessibility and good access to shops services and infrastructure, densities should be maximised in order to achieve other policies within the LDF. 4 1 Pauline McKinnell Cricklewood CS1 Barnet’s A small amount of growth would be acceptable but the growth envisaged in the Brent In November 2009 the None 6 Community place shaping Cross - Cricklewood will completely change the character of our area. The Forum Council resolved to grant 7 Forum strategy wants low rise housing, protection of all our green spaces, and no demolition of existing planning permission for the housing, leisure and community buildings. We want the Council to lead on this not Brent Cross Cricklewood multi-national developers application. 4 3 Pauline McKinnell Cricklewood CS1 Barnet’s protection of all green spaces as essential to health of all Barnet residents. We make clear links in the None 6 Community place shaping Core Strategy between 7 Forum strategy health and provision of open spaces. 4 4 Government CS1 Barnet’s Barnet’s three strands approach is clearly set out in Section 7. This is the heart of the We welcome this support Revise 7 Office for place shaping spatial strategy and needs more detail and expansion. It would be helpful if the and agree to update the information 0 London strategy description of each of the sub-areas; Mill Hill East, Colindale and Brent Cross information boxes. boxes on Cricklewood each contained information on anticipated delivery of jobs, homes, retail each of the floorspace and any other key uses. growth areas
4 5 Government CS1 Barnet’s It would benefit Section 7 including Policy CS1 (Place Shaping Strategy) if the relevant Agree Revise CS 1 7 Office for place shaping thematic policies for each of the ‘3 Strands’ could be identified and appropriately cross and add 0 London strategy referenced, This would clarify how the policy is to be put into practice and help link the maps of the more spatial policies at the beginning of the document with the more thematic policies growth areas later in the document. These sub-area descriptions would benefit from individual maps to illustrate the text.
185 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 David Howard New Barnet CS1 Barnet’s Policy CS1 states that New Barnet is one of the six largest town centres in Barnet. This Reference to New Barnet Revise CS 1 7 Community place shaping is factually incorrect. New Barnet is in fact the smallest district town centre sited entirely has been removed from CS and 1 Association strategy within LB Barnet as measured by either number of units or total floor space. This is set 1 and supporting text. We supporting out clearly in Appendix 2C of the GVA Grimley Town Centre Floor space Needs consider that it no longer text Assessment dated April 2009. In addition, New Barnet is identified in the London Plan merits specific designation as one of the smallest district centres in Greater London. as a priority centre. Any We therefore wish the reference to New Barnet to be deleted from Policy CS1 and at proposed development section 7.1.10 should reflect the scale of the town centre and be guided by the emerging Town Centre Framework for New Barnet. This Framework provides the basis for managing change in New Barnet. 4 2 David Howard New Barnet CS1 Barnet’s Para 7.1.10 , 7.1.11 see New Barnet as a focus for commercial development and Agree. New Barnet is no Revise CS1 7 1 Community place shaping residential growth and acknowledge this will lead to a significant increase in travel longer promoted as a priority Key Diagram 1 Association strategy demand. This is contrary to the successful suburbs, developments in character and town centre. The major and CS3 to other desirable phrases used elsewhere in the document. It is totally unacceptable to transport thoroughfares are remove New make blanket statements that infill developments and residential growth will take place no longer promoted in the Barnet as a along main thoroughfares. Selective infill may be acceptable but not demolition of Core Strategy. Proposals priority centre existing streetscapes to replace them with more ugly blocks of flats. Delete reference to that come forward in New and the New Barnet Barnet or along such routes major will be considered primarily thoroughfare against saved policies in the s UDP or their replacements in the Development Management Policies DPD. 4 2 David Howard New Barnet CS1 Barnet’s 7.1.14 sets out what makes the suburbs successful so adopt these standards across The Three Strands approach None 7 2 Community place shaping the board using the 22/11/2004 version of the Three Strands Policy. sets a clear spatial agenda 1 Association strategy for Barnet. This place shaping strategy is integral to our Core Strategy which was approved by Cabinet on 21 October 2009. 4 1 Andrew Newby Barnet Green CS1 Barnet’s Brent Cross should be dropped as a growth area. The existing shopping mall already Brent Cross is London's only None 7 Party place shaping creates too much congestion, pollution and greenhouse gases, while drawing people regional shopping centre and 7 strategy away from nearby community shopping areas such as Hendon, Temple Fortune and an area of strategic Golders Green. Those communities should be supported instead. importance. Its regeneration is highlighted in the London Plan. 4 3 Andrew Newby Barnet Green CS1 Barnet’s I favour focussing development on existing town centres but would like to see attention All centres are promoted in None 7 Party place shaping also given to other town centres such as East Finchley, Hendon, Temple Fortune and the policy and a clear 7 strategy Golders Green. hierarchy is set out in the text. 4 1 Steven Deller CS1 Barnet’s The removal of Cricklewood from the Borough of Barnet. This policy is about outer Cricklewood is an integral None 7 place shaping London suburbs. It proves that it is inappropriate for inner city Cricklewood to remain in part of Barnet and proposals 8 strategy a borough that is completely alien in outlook and culture from the local community. The for the regeneration of the policy is for inappropriate overdevelopment in Cricklewood in order to protect the area are well established at communities that reflect the suburban areas of the borough a borough and London level in the UDP and London Plan. 186 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Steven Deller CS1 Barnet’s This will translate as support these six at the expense of everybody else These are priority town None 7 place shaping centres with the best 8 strategy opportunities for attracting commercial investment. 4 1 Dorothy Badrick UKOSF CS1 Barnet’s The plans for Brent Cross Redevelopment are a gross overdevelopment and are These issues were None 8 place shaping incompatible with the local area. The traffic proposals are nonsense and will not work. considered as part of the 0 strategy The rapid transit system, the bus, will just get stuck in the traffic. Why take down a Brent Cross – Cricklewood mature and pleasant estate Whitefield, and replace it with rabbit hutches? The planning application which compensation package which will allow current home owners only enough to buy a part the council resolved to share in a lease of inferior accommodation is theft. If the regeneration works North approve subject to S106 in London grinds to a halt and all our high streets turn into urban deserts. If it doesn't then November 2009 you are building the slums of the future. Why did the possibility of a 140m chimney spewing out particulates only come to prominence at the planning meeting? which idiot decided that its ideal location was next to a primary school and a housing conservation area? Why have the developers ignored local opinion particularly regarding the plans for Clitterhouse playing fields which are incompatible with PPGs for MOL? What about the only green space in the centre of Cricklewood outside of B and Q which residents are desperate to retain? How on earth do the developers think that Claremont Road can take a third traffic lane
when traffic already at rush hours is backed up to The Vale and beyond? A third Lane will exacerbate not alleviate the problems. What about our health? Has anyone checked air quality in the area which must break EU guidelines. Are you trying to asphyxiate us? Who picks up the public health bill? These proposals are completely unrealistic and not feasible. 4 2 Dorothy Badrick UKOSF CS1 Barnet’s Since the appalling mess and costs that you have allowed to develop around Hendon The Core Strategy is a None 8 place shaping Football Club site and see above for Clitterhouse Playing fields. Why do you not protect strategic document which 0 strategy MOL and follow the PPGs ALL OVER THE BOROUGH not just where you already clearly identifies sport have a sufficiency of green space but in Cricklewood where it is so sorely needed. Stop facilities as part of the overdevelopment, hands off our sports facilities. Since the loss of the Hendon Football infrastructure requirement to Club facility where are our playing fields and our built sport facilities? Are you proud of support growth. We are your record of being the worst in the country for sport provision and one of the lowest preparing a playing pitch spending boroughs on facilities for young people. Whilst protecting your more affluent strategy which will follow areas you do it at the expense of the poorer arrears of the borough, you should be Sport England's guidance ashamed of the record. and will guide future provision of and management of such facilities. 4 3 Dorothy Badrick UKOSF CS1 Barnet’s And what about Cricklewood steeped in local history. Another example of the north/ The Core Strategy is a None 8 place shaping south divide in the borough. Why not John Laings first garden state, the Pennine Drive borough wide document and 0 strategy Estate a conservation area rather than the hell of bedsits you are allowing it to become. we have identified those How much more traffic and people do you expect to cram into one of the most areas that have the greatest overcrowded areas of Barnet? Why should we take all the excess people and traffic? opportunities and are the How about spreading it around a bit. How about approaches to limit growth in already most appropriate locations overcrowded locations. Don't infill why not use Totteridge Common. Regeneration yes, for growth. overdevelopment no. 4 1 David Dobbs CS1 Barnet’s I disagree with the general approach of 'strategic' growth of these areas. Whilst The approach set out in the None 8 place shaping agreeing that redevelopment is required, I do not agree that the growth is required. I Core Strategy aims to 1 strategy believe that the primary focus should be on redevelopment of town centres. ensure that the borough remains a successful suburb. The Core Strategy is required to address the challenges that we face as 187 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations such a place. There are opportunities for growth and it is imperative that we manage this.
4 2 David Dobbs CS1 Barnet’s I disagree to the extent that protection of the green belt will inevitably lead to an over We are committed to None 8 place shaping development of residential housing in already crowded urban areas within the borough. protecting the Green Belt 1 strategy Therefore I believe that the green areas should be subject to a limited development - and that is enshrined in our these should be focused on eco-housing. place shaping strategy - the Three Strands Approach. 4 3 David Dobbs CS1 Barnet’s I don't believe that mixed use development really works and the most recent We consider that mixed use None 8 place shaping developments at North Finchley were disastrous and clearly indicate that the vision was development does work and 1 strategy wrong. The conservation areas should be maintained as far as possible. represents a sustainable use of land and a means of mitigating climate change. 4 1 Maria Nash Barnet Women's CS1 Barnet’s Local & Borough wide concerns have not been fully addressed yet. Environmental & All new homes are required Publish 8 Design Group place shaping disabled access has not been updated yet for the next 15 years. Policy from a women's to be built to lifetime homes Infrastructure 3 strategy concept has not been included, either from a mother who has several small children to standards by the London Delivery Plan elderly/disabled women. Particularly Brent Cross has only got the most minimum of Plan. This also includes a standards in its planning, travel has not been addressed at all and the A406 is a health requirement for 10% of hazard with excessive vehicles having to sit for hours at the bottle neck now what will housing to be wheelchair happen when there are several more thousand people living, working or visiting the accessible. In line with area. The waste system has also not been fully addressed which would have a huge PPS12 we do not need to impact on local and borough travel. There is no West to East or East to West borough repeat this policy. The Mayor transport. It can only be achieved by changing several buses and no tube or train intends to produce SPG on services for people on the North East of the Borough to get to Brent Cross or West the quality and design of Hendon housing developments. In providing quality homes and housing choice we support lifetime neighbourhoods and Building for Life Standards. 4 2 Maria Nash Barnet Women's CS1 Barnet’s Policy has to be set in stone that no open land either public or private is not built on. The Core Strategy has to be Addition of 8 Design Group place shaping With the increase of population over the years we require spaces to breath in, play in, flexible and capable of monitoring 3 strategy exercise in and relax in. addressing changing indicators at circumstances. We set out a Appendix B number of indicators to monitor its progress. Each policy in the Core Strategy will be monitored based on specific indicators and reported in the Annual Monitoring Report. This will provide clear evidence of policy delivery and a basis for review of the Core Strategy
188 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Maria Nash Barnet Women's CS1 Barnet’s New Barnet is not a large town centre and the concerns of the local residents are being Reference to New Barnet Revise CS 1 8 Design Group place shaping ignored. Democracy requires every ones voice to be heard and the majority to decide has been removed from CS and 3 strategy not the selected few who think that they know what everyone wants 1 and supporting text. We supporting consider that it no longer text merits specific designation as a priority centre. Any proposed development should reflect the scale of the town centre and be guided by the emerging Town Centre Framework for New Barnet. This Framework provides the basis for managing change in New Barnet. 4 1 Robert Shutler Woodside Park CS1 Barnet’s Less growth in population Barnet is an attractive place None 8 Garden Suburb place shaping where people want to live. 5 Residents strategy Population growth is Association inevitable. 4 2 Robert Shutler Woodside Park CS1 Barnet’s The edges of the green belt should not be subject to the same restrictive rules as the PPG 2 – Green Belts covers None 8 Garden Suburb place shaping centre of the green belt this issue and the Core 5 Residents strategy Strategy supports PPG 2. Association 4 3 Robert Shutler Woodside Park CS1 Barnet’s Anyone prepared to invest in the High Streets, already ruined by the Council because These are priority town None 8 Garden Suburb place shaping of parking restrictions, should be welcome with open arms. Why restrict everything by centres with the best 5 Residents strategy stating mixed use? opportunities for attracting Association commercial investment. We consider that mixed use development does work and represents a sustainable use of land and a means of mitigating climate change. 4 2 Michael Storey CS1 Barnet’s New Barnet is NOT a proper town centre - it doesn't even have a bank! I think that you New Barnet has been Revise CS1 8 place shaping are overstating its importance because you believe that New Barnet needs identified as a district centre Key Diagram 7 strategy 'redeveloping' (i.e. pulling down - like Sainsbury's did on one side of the road) and in the London Plan and its and CS3 to replacing with uninspiring large-scale retail developments, complete with flats. Not only place within Barnet's remove New that, but to facilitate this, you intend to turn the A110 into a through road to network of town centres is Barnet as a accommodate the new supermarket(s). Residents don't want it, the politicians don't clear. New Barnet is no priority centre want it, the retail need isn't there and the train bridge won't allow it. You should be longer promoted as a priority and the ashamed of yourselves. I am horrified that you want to allow major infill on the A110 town centre. The major major (Cat Hill-Brookhill Road-East Barnet Road). This will utterly transform the character of transport thoroughfares are thoroughfare Cat Hill irrevocably. I presume you're trying to encourage people to hurtle through New no longer promoted in the s Barnet as fast as possible, because there won't be anything worth stopping to look at. Core Strategy. Proposals that come forward in New Barnet or along such routes will be considered primarily against saved policies in the UDP or their replacements in the Development Management Policies DPD. 4 1 Glen Rollings Greater London CS1 Barnet’s This policy serves as a useful introductory objective that ‘sets the scene’ for Barnet’s Policy CS 1 has been Amend 8 3 Authority place shaping attitude to growth. It would be useful to add a section that relates to Barnet Council’s updated accordingly. Para Policy CS 5 8 strategy desire to seek high-quality design that is appropriate to the growth being sought. 7.1.17 refers to creative and to provide 189 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Locations that have the potential for tall buildings should also be identified, in line with innovative proposals in the guidance on the Mayor’s policies on tall and large-scale buildings. growth areas and proposals for emphasises that schemes tall buildings will be expected to enhance the qualities of its location and setting. As part of our LDF evidence base we are producing a Tall Buildings Study which supports guidance on assessing proposals for tall buildings. . 4 1 Glen Rollings Greater London CS1 Barnet’s TFL would like to see the addition of a paragraph under Policy CS.1 which states We have revised policy CS1 Revise CS 1 8 4 Authority place shaping “ensure that an appropriate level of transport capacity and accessibility is provided in to add a reference to an 8 strategy advance of or concurrently with development demand” in accordance with London Plan appropriate level of transport policy 3C.1 Integrating transport and development and policy 6.3 Assessing transport in provision. the Consolidated draft replacement London Plan (October 2009).
4 1 Glen Rollings Greater London CS1 Barnet’s TFL welcomes the reference to growth in accessible locations under paragraph 7.2.1; This is a reference to an None 8 5 Authority place shaping however TFL does not feel the statement that “car trips and road congestion will alternative option identified 8 strategy increase as development takes place in areas with poor public transport” is valid or and not pursued for the appropriate and wishes to see it removed, however, if development is discouraged in reasons set out in paragraph areas with low PTAL then the above statement may not apply. 7.2.1 of the Direction of Travel document.
1 John Dix CS1 Barnet’s Policy CS1 states that New Barnet is one of the six largest town centres in Barnet. This See response at 471/2 Revise CS 1 place shaping is factually incorrect. New Barnet is in fact the smallest district town centre sited entirely and strategy within LB Barnet as measured by either number of units or total floorspace. This is set supporting out clearly in Appendix 2C of the GVA Grimley Town Centre Floorspace Needs text Assessment dated April 2009 and which I have summarised in the table below. In addition, New Barnet is identified in the London Plan as one of the smallest district centres in Greater London. I therefore wish the reference to New Barnet to be deleted from Policy CS1 and at section 7.1.10. P New Barnet CS1 Barnet’s Policy CS1 states that New Barnet is one of the six largest town centres in Barnet. This See response at 471/2 Revise CS 1 r place shaping is factually incorrect. New Barnet is in fact the smallest district town centre sited entirely and of strategy within LB Barnet as measured by either number of units or total floorspace. This is set supporting o out clearly in Appendix 2C of the BVA Grimley Town Centre Floorspace Needs text r Assessment dated April 2009. In addition, new Barnet is identified in the London Plan m as one of the smallest district centres in Greater London. Recommendation made for a references to New Barnet to be deleted from Policy CS1 and at section 7.1.10
P Save our CS1 Barnet’s Save us from further high rise development, improve our failed housing estates and The Core Strategy aims to None et suburbs place shaping otherwise direct new development to designated regeneration and development areas manage change and Three iti strategy Strands makes it clear that o growth can be complimented n by protection and enhancement of the places that help shape Barnet.
190 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 2 Ian Dubber Workspace CS3 Workspace supports the identification of strategic housing development sites but PPS4 recognises mixed use None 4 Group PLC Distribution of considers that development should be considered across the whole borough. In developments role in 1 growth particular, this policy should promote mixed use developments on existing commercial facilitating economic (formerly sites. It is important that the Core Strategy is responsive in a positive manner to development. PPS4 also CS2) changing economic conditions and therefore development sites should be considered recommends at EC2(h) that and encouraged on a site by site basis as they come forward for development. we should where necessary safeguard land from other Workspace seeks to continue to provide good value small business units, in line with uses to facilitate a broad the key objectives of the London Plan. In order to do this, some of their premises will range of that economic require regeneration and renewal to meet the modern and future needs of London’s development. PPS4 retains businesses. Such regeneration requires funding and Workspace proposes that if this is the requirement for an to be privately funded, a high value economic driver such as a residential use will be assessment of land. Barnet's necessary to enable redevelopment and ensure the overall viability of regeneration. Employment Land Survey The benefits include the creation of modern business units, which can continue to be provides evidence of the provided as good value rental accommodation whilst increasing the efficient use of need for employment land. urban land and delivery of housing through the provision of sustainable mixed-use The Development development. Management Policies DPD will provide further detail on policy for existing employment sites in relation to mixed use.
2 5 Peter Storey Friern Village CS3 Housing density must be no higher than currently experienced in Barnet. People The Core Strategy aims to None 4 Residents Distribution of generally prefer to live in houses not flats above businesses. make efficient use of 2 Association growth previously developed land (formerly and therefore higher CS2) densities will be appropriate in accessible locations. We need to provide housing choice in meeting aspirations. In order to do that we have to provide a range of accommodation including flats. The housing mix is supported by the Strategic Housing Market Assessment.
191 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 2 Peter Hewitt CS3 What the above excerpts tell us residents of East and New Barnet is that if such LDF Reference to New Barnet Remove New 4 Distribution of Core Strategy is adopted there will be little to prevent powerful commercial and has been removed from CS Barnet from 4 growth construction interests from exploiting the [alleged] 'potential' as mentioned in S.8.1 3 and supporting text. We CS3 and (formerly above. The supermarket giants ASDA and TESCO who are fidgeting impatiently on the consider that it no longer supporting CS2) sidelines, along with the construction industry, so excited about the in-fill possibilities merits specific designation text and eager to enjoy a share of the anticipated 'regeneration' bonanza. All will be jostling as a priority centre. And is to transform the appearance and character of a supposedly moribund New Barnet therefore not considered in along the entire 'major thoroughfare' [as designated in S.8] of East Barnet Road - the same way as North Brookhill - Cat Hill. Few developers can be expected to heed the Core Strategy Finchley or Edgware. Any Direction of Travel's recommendation for higher density mixed-use development insofar proposed development as it purports to favour a balance of older Victorian/Edwardian properties and new, should reflect the scale of flatted residential units, the latter being rather more lucrative! the town centre and be In addition to which regard to the LDF Policy CS2 it would be very naïve and/or guided by the emerging unrealistic indeed to expect Barnet's Town Planners to either reverse or to somehow Town Centre Framework for remedy appalling vandalistic consequences incurred by TESCO acquiring and then so New Barnet. This shamefully leaving derelict and unsightly so much residential and retail property in New Framework provides the Barnet. The suggestion that it is some kind of deliberate collusive arrangement basis for managing change between Barnet Council and TESCO, not to mention ASDA's Albert Road gas works in New Barnet. Major site, is not at all without some justification. thoroughfares are no longer My objection therefore is that New Barnet should be regarded as a 'town centre' in the identified as having potential context of the LDF's Core Strategy document. In no way, except possibly having a for infill housing Sainsbury's supermarket, can it be equated wit such retail centres as Whetstone, North development Finchley or Edgware etc. The fact that the A110 runs through New Barnet should not be the sole criteria for categorising it as such. Moreover, as will be commented on below at S.10 New Barnet has the same 'feel', 'atmosphere' and 'character' as East Barnet, more commonly referred to as 'The Village'. While the description of 'Village' may not wholly embrace New Barnet it is nevertheless not inappropriate to assert that both centres have co-existed and evolved as an integral outer suburban entity. Unquestionably this is how most residents in East and New Barnet have preferred to regard it. 8.1.8 '…and having a character more appropriate to higher density mixed use development…such locations include the six town centres of…',one such being New Barnet 8.1.9 Elaborates on 8.1.8 by referring to 'infill development estimated to have the potential to deliver a further 1,200 new homes'. Policy statement CS2 [applicable to S.8 informs the reader, inter alia, '…which will provide for residential uses above ground- floor level [for the six aforementioned town centres and along major transport routes] which include the A110.
3 3 A2 Dominion CS3 Our client notes that Preferred Policy CS 2 expects that in the range of 28,000 new We welcome this support. Introduction 7 Housing Distribution of homes will be provided within the lifetime of the Core Strategy between 2011/12 to The new policy CS2 on of new policy 4 growth 2026/27. Our client supports the focus of housing in the western side of the borough at Brent Cross-Cricklewood CS2 on Brent (formerly Brent Cross – Cricklewood, Colindale and Mill Hill East, and particularly the approach provides a link with the Cross- CS2) that the Edgware Road is a sustainable location for major infill housing development. Development Framework Cricklewood The regeneration of the western side of the Borough will lead to the revitalisation and SPG and the saved policies successful growth of Barnet, which is a core element in achieving high quality housing of the UDP relating to the growth and economic prosperity and should be brought forward immediately. CS2 growth area. should be amended to include reference to of the requirements of SPG and UDP policy which are effectively being rolled forward in this preferred policy.
192 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 5 Asda Stores Ltd CS3 As a highly accessible town centre, we agree that New Barnet represents a sustainable In order to ensure that None 7 Distribution of location for development within the Borough. In this context we support the promotion brownfield site opportunities 9 growth of new housing development within the centre of New Barnet. It is important that policy are managed in the right way (formerly makes clear the need to progress town centre strategies swiftly in order to provide a a Town Centre Framework CS2) framework for development. for New Barnet has been developed to provide a strategy for the future of the town centres in consultation with the community. 3 6 Asda Stores Ltd CS3 We welcome acknowledgment that the centre of New Barnet is identified as a location The figure for town centres Revise 7 Distribution of where residential development will be promoted. However, we are concerned that the as set out in Table 2 and supporting 9 growth provision of a figure for potential provision (1,200 by 2026/2027) amongst the various repeated in supporting text text to CS3 (formerly centres in the Borough could be used as ceiling figure to prejudice development. We to CS3 provides an CS2) request that this is clarified within the text. indication of capacity, it is not a target. 4 4 Starfield CS3 We concur with the promotion of the six largest town centres as the main focus of We welcome this support None 3 Properties / St Distribution of enhancement and infill housing development in parallel with the promotion of residential 1 James growth uses above ground level in town centres. Investments (formerly CS2) 4 3 Robert Newton CS3 Reason: The existing wording of Policy CS2 does not reflect Paragraph 2.3.1 and it The draft revised London None 3 Distribution of should. Re-write the third paragraph of Policy CS2 to read: “We will also support the Plan is clear on the use of 6 growth following locations with good access to public transport where the PTAL rating is 4 or the density matrix and states (formerly above as the main focus for enhancement and infill housing development but will that it is not appropriate to CS2) ensure that the density complies with and does not exceed the proposed new density apply the table matrix detailed in Policy 3.4, Table 3.2 and Paragraphs 3.22 to 3.25 of the London Plan mechanistically. There will Consultation Draft Replacement Plan (October 2009): be opportunities for higher And add to the first bullet point on town centres the words: “within the existing town density development within centre envelopes that will not be extended to include adjoining suburban houses.” the upper range of the matrix in Barnet.
193 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Robert Newton CS3 Delete the wording following the third bullet point and replace with: “In the limited PPS4 makes clear that Revise CS3 3 Distribution of number of areas where there is a dominance of flatted development as will be defined residential is not a main town to remove 6 growth in the Site Allocation and Development Management Policy DPDs, whilst otherwise centre use. major (formerly protecting and safeguarding suburban housing and shopping parades located along Major thoroughfares are no thoroughfare CS2) major transport and other important routes.” longer identified as having s In the introduction to the fourth paragraph of Policy CS2 after the words “We will” insert potential for infill housing the words: “adopt Policy 3.5, Table 3.3 and Paragraphs 3.26 to 3.33 of the London Plan development Consultation Draft Replacement Plan (October 2009) with regard to the quality and We are supportive of the design of housing and space standards and……” Rewrite the fifth paragraph to read: Mayors approach to the “Our strategic approach on further development opportunity will be set within the quality and design of context of the proposed new density matrix detailed in Policy 3.4, Table 3.2 and housing including the Paragraphs 3.22 to 3.25 of the London Plan Consultation Draft Replacement Plan housing (October 2009) to reflect local context, public transport accessibility and availability of Density matrix and the new social and other infrastructure. We will ensure that the density of any development space standards in the draft complies with and does not exceed that set out in the proposed new density matrix and revised London Plan. If the that developments comply with Policy 3.5, Table 3.3 and Paragraphs 3.26 to 3.33 of the standards pass scrutiny and London Plan Consultation Draft Replacement Plan (October 2009) with regard to the form part of the final London quality and design of housing and space standards.” Plan they will replace the standards set out in the SPD on Sustainable Design and Construction.
Amend the wording of Paragraphs 8.1.1 to 8.3.1 where necessary to reflect these changes to Policy CS2 and in particular rewrite the last sentence of Paragraph 8.3.1 to read: “We will utilise the proposed new density matrix detailed in Policy 3.4, Table 3.2 and Paragraphs 3.22 to 3.25 of the London Plan Consultation Draft Replacement Plan (October 2009) to reflect local context, public transport accessibility and availability of social and other infrastructure. We will ensure that the density of any development complies with and does not exceed that set out in the proposed new density matrix.”
4 2 P E Pickering CS3 The third bullet point, which advocates major housing development on main roads is Major thoroughfares are no Revise CS3 3 Distribution of unacceptable as it stands, and needs a lot of qualification. It will otherwise permit huge longer identified as having to remove 7 growth blocks of flats in totally inappropriate places. I suggest wording like 'Housing potential for infill housing major (formerly development will be appropriate on sections of major transport routes, but should development thoroughfare CS2) always be in tune with the established character of the location'. s
4 5 Brent Cross CS3 Policy CS2 deals with the distribution of housing growth across the borough and Policy CS3 has been revised Revise CS 3 4 Cricklewood Distribution of suggests that BXC will accommodate 7,500 new homes. However, the application to clearly set out how growth 0 Development growth seeks permission for a defined quantum of residential floorspace that is estimated to will be delivered in the 15 Partners (formerly deliver in the region of 7,550 dwellings, rather than a definitive residential unit figure. year life span of the Core CS2) Also add Our strategic approach on further development within growth areas and Strategy. opportunity sites will be set within the context of the density matrix in the existing London Plan. .. 4 3 British Library CS3 The BL understands that LB Barnet intend to focus growth in the strategically identified We welcome this support None 4 Distribution of “North West London – Luton Coordination Corridor”, specifically in the growth areas of 2 growth Brent Cross – Cricklewood, Colindale and Mill Hill East. The BL supports the focus of (formerly growth in strategically identified areas as opposed to organic growth which may lead to CS2) piecemeal development. The BL support the allocation of 10,000 new homes in Colindale.
194 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 Graham Saunders English Heritage CS3 Support the approach of optimising densities as oppose to maximising them. In We welcome this support None 4 Distribution of particular we are keen to ensure that when densities for a site are being established 6 growth that the contextual qualities of the site and its surroundings in terms of local character (formerly and impact upon historic environment are being explicitly factored into the capacity of CS2) the site. This approach should be applied to all sites regardless of scale, location and nature of development.
4 1 Mike Dawson Finchley Society CS3 Barnet Council’s Core Strategy, Direction of Travel (DoT), claims that, The Londonwide SHLAA Publish 5 Distribution of “It will embody spatial planning – the practice of ‘place shaping’ to deliver positive assessed all potential Infrastructure 5 growth social, economic and environmental outcomes and provide the overarching local policy housing sites in Barnet and Delivery Plan (formerly framework for delivering sustainable development in Barnet.” looked at the likelihood of CS2) To achieve sustainability you should first assess where development is possible and on them coming forward and what scale. Housing targets in Barnet’s DoT are greater than those required by the their potential housing yield. Mayor of London and National Policy made on the basis of projected demand, not what On the basis of this evidence is sustainable in the local community. housing targets were set for Infrastructure to support expansion must first be in place, a condition set by Barnet Barnet. Council in many policies including DoT. Like so many other ideas in the DoT, Barnet’s An infrastructure delivery proposed ‘bond’ to secure infrastructure remains only a proposal. plan setting out the where, when, what and how of infrastructure delivery will accompany the publication version of the Core Strategy.
4 3 Mike Dawson Finchley Society CS3 DoT policies will together deliver negative social and environmental outcomes provided The existing London Plan Revise 5 Distribution of by an overarching local policy framework for delivering unsustainable development in target runs to 2021 and the supporting 5 growth Barnet. Working to givens for increases in housing, planning huge expansion of out of Core Strategy runs to 2026 text to CS3 (formerly town shopping while stating the most sustainable shopping is in Town Centres, will which explains the apparent CS2) create an unsustainable and congested Barnet. Barnet’s own target of 28,000 homes is disparity. Further clarification some 25% above that required by the London Plan of 22,055 homes to be achieved by on the 15 year housing 2026. target is provided in the supporting text for CS3. 4 7 Mike Dawson Finchley Society CS3 There is a lack of evidence to support Barnet’s figures for housing growth, how this is We refer to our earlier None 5 Distribution of sustainable, particularly in terms of traffic congestion and how the required responses at 455/3 and 5 growth infrastructure will be provided. When commenting on Barnet’s ‘Issues and Options’, it 455/1 (formerly was a requirement of the Mayor of London that: “They should show how vision, CS2) objectives and strategy will be delivered And by whom. This includes the requirement for sound infrastructure planning including what physical, social and green infrastructure is needed to support the proposed level of growth; and identifies needs and costs, phasing of development, funding and responsibilities for delivery…”, and considers: “Further work is required to reduce reliance on the car and increase cycling and on the transport implications of development.” The required Infrastructure is not provided in DoT, and is required to be in place by the Mayor of London before this Core Strategy, DoT is acceptable.
195 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Mike Dawson Finchley Society CS3 Mill Hill East We question that this site is suitable for so many new homes. The original The opportunity to None 5 5 Distribution of AAP planned for 2,000 new homes giving a total of 2660 residential units that includes specifically comment on the 5 growth those already there. growth in Mill Hill East was (formerly The current outline plan would give a total of 2906 homes, already a 10% increase on during the development of CS2) the AAP. This number could rise more in the final planning application. With work, retail the Area Action Plan. The and infrastructure space, the developer estimates an increase of 11,000 people in the adopted AAP for Mill Hill area, which they estimate will mean 400 additional car journeys in the rush hour. East is in general conformity We believe that the estimate of 400 additional car journeys in the rush hour is far too with the London Plan. Over low. Approximately 50% of working people in Barnet travel by car. Assuming one in four its 15 year life span the area of the new population of 8,500 people work, this equates to 1,125 car journeys during is expected to delivery 2,000 the rush hour. Local roads are already congested; at rush hour the roundabout at new homes. Kelly’s Corner is already a particular problem. Northern Line or travel by car. Busses The boroughwide policy for cannot significantly relieve pressure on public transport as the roads do not have bus affordable housing delivery lanes, resulting in busses having to use the congested/blocked roads during rush-hour. is dependent on further Instead of providing sustainable homes, the Mill Hill East AAP is based on putting as evidence. Both viability at many homes as possible on a site, despite its poor public transport and congested local the sub regional strategic roads. Even though Regional and London plans have named this site as one with housing market assessment potential for development, Barnet’s LDF should make its own realistic and sustainable have informed policy in the plan and avoid creating traffic chaos to local and through-travellers. Publication version. A We note the comment in this item, that: viability assessment of “in line with the London Plan target of 50% of housing provision being affordable the affordable housing delivery maximum amount of affordable housing will be sought having regard to this target and is required by national to a viability assessment” Planning Policy Statement 3. Reference to ‘…a viability assessment…’ is a clear sign that the 50% target for affordable housing will not nearly be met. As with so many recent major housing projects in Barnet, the Council/Developer fails to provide London Plan requirements for affordable housing. Previous large developments (50+ residential units) have seen affordable housing requirements well below those required by the London Plan, and all too often hived-off to another site. The same applies for social housing. In the LDF we hear much of mixed communities and avoiding the problems of segregated communities of the past. For Barnet the reality is somewhat different. Social/affordable housing numbers for new developments are lower that required by the London Plan and to maximise profits for the developer are often side-shifted to an alternative site. The plan for Mill Hill East puts what little affordable housing that is planned furthest away from public transport. Those who are most likely to need public transport as their only means of transport have to walk the furthest.
196 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Mike Dawson Finchley Society CS3 Colindale AAP The opportunity to None 5 6 Distribution of As a part of the huge developments planned for the West of Barnet, Colindale will see specifically comment on the 5 growth 10,000 new homes by 2025. It is estimated that demand at Colindale Station will nearly growth in Colindale was (formerly double by 2021. No assessment is shown for how the Underground system will cope during the development of CS2) with passenger demand from Colindale, yet alone other stations on this public transport the Area Action Plan. system where demand will increase by population growth, plus mode shift from the car. Meanwhile, Colindale’s AAP, 3.5.8, states: “The wider strategic network (roads) in this part of London is congested, and there are a number of strategic constraints on traffic levels and speeds which are beyond the scope of the AAP.” So that’s okay then! Because the AAP accepts ‘strategic problems’ in road transport in this area it is simply ignored while housing development goes on unchecked. Improvements to connectivity within the area mean little as through-roads and the surrounding area have ‘strategic problems’. Sustainability is not only mentioned far too much in DoT, its principals are also ignored far too often for the sake of growth.
4 1 Mike Dawson Finchley Society CS3 Brent Cross – Cricklewood: These issues were None 5 7 Distribution of If a new truly sustainable town centre of that envisaged could be built without a huge considered as part of the 5 growth increase (doubling) in the size of retail space at Brent Cross, it could be a positive Brent Cross Cricklewood (formerly move. Such a huge shopping centre will attract customers from within and outside the planning application CS2) borough creating huge increases in traffic. considered by committee on We are told that housing Partnerships are developing with the North West London 16 November 2009. boroughs of Brent, Camden and Harrow. It is unfortunate that this Partnership does not extend to Brent Cross. Camden and Brent are against the plan, citing the threat to Town Centres and traffic congestion as the main reasons. Even before phase one starts we are told a 50% increase in Brent Cross retail will happen but that housing targets will be lowered. Again we see profit taking precedence over sustainability. The proposed affordable housing target is 33% below that required by the London Plan and seems likely to fall more as profit wins over policy, be it for mixed communities, sustainability or In ‘later phases’ we are told a small library, replacement Leisure Centre and new rail freight facility will be built. What happened to the policy of ‘Infrastructure’ before development? Even if the waste handling/combined heat and power plant is built, this means the majority of waste will arrive by road in a network that Barnet Council states currently suffers from blockages, particularly around the A.406. Barnet Council estimates 29,000 extra car journeys a day to this already congested area. Camden and Brent council have unanimously voted against the development due to the traffic, lack of clarity in the plans and the impact on local high streets. Barnet’s own Town Centres will also suffer from an expanded Brent Cross.
197 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Mike Dawson Finchley Society CS3 Roads that are believed to be suitable for higher density homes include: We have identified those None 5 0 Distribution of “Further opportunities for higher density residential development of appropriate scale major transport routes where 5 growth and mass will be identified on the major thoroughfares of… A504 (Hendon Lane…” we consider flatted (formerly Hendon Lane has been quoted as being unacceptable development that should not be development for smaller CS2) allowed to happen elsewhere. It must therefore be wrong to select it a place for higher households is more density development. appropriate than family homes. The major transport routes do not provide a good environment for families.
4 2 Mike Dawson Finchley Society CS3 The claim that: We refer to our earlier None 5 1 Distribution of “Central to our overall approach to adapting to Barnet’s future growth is ensuring that it responses at 455/3 and 5 growth is managed in a sustainable way… that it protects and enhances our environment, 455/1 (formerly heritage and quality of life” The Inspector examined the CS2) Is not supported by evidence. Too many new homes are proposed. Building a home to Colindale AAP and found it new standards of sustainability does not make the overall proposal sustainable. sound. It is therefore the Proposals such as Colindale AAP ignore the evidence of a congested strategic road most appropriate strategy for network while proclaiming an improved local road network for the AAP. the regeneration of Colindale and is founded on a robust and credible evidence base.
4 2 Mike Dawson Finchley Society CS3 Include the wording below in this policy: A requirement of PPS12 is Publish 5 3 Distribution of New housing in the identified development areas should only proceed if the area can that the strategy must be Infrastructure 5 growth sustain the prescribed level of growth. Where it is acknowledged that local deliverable and based on Delivery Plan (formerly infrastructure, be it roads, schools, etc, cannot support proposed housing increases the sound infrastructure CS2) development should be reduced to a level that can be accommodated, or infrastructure planning. The Infrastructure improvements made to cater for the housing proposed. Delivery Plan sets out what Policy CS 2 - Amend as below: physical, social, and green We will also promote the following sustainable locations with good access to public infrastructure is needed to transport (PTAL 3-6) as the main focus of enhancement and major infill housing enable and support the development. Development must not ‘canyonise’ the highway and be in character with amount of development the area: proposed for Barnet.
4 4 MWG Scott Garden and CS3 It is difficult to believe that Barnet will exceed or meet its current housing target The Development None 6 Plant Centre Distribution of expressed in the Core Strategy as 20,055 new homes by 2016/17 in terms of these Management Policies DPD 2 Developments growth houses being affordable and, in a range of dwelling sizes and types of housing (i.e. will provide further detail on Ltd (formerly including housing for large families) in a strategy wholly dependant on redeveloping policy for housing mix and CS2) existing areas (Brent Cross – Cricklewood, Colindale and Mill Hill East) at higher private amenity space. densities. Even assuming that it is possible to develop a range of larger units of The Core Strategy clearly accommodation at affordable prices in such high density developments, they are sets out a 15 year housing unlikely to be in the form of the suburban housing development with access to open target of 28,000 units up to space at ground floor level which is so important for families, and which is recognised in 2026. Our housing mix is the Core Strategy as the attractive element of the suburbs in Barnet. informed by evidence from the SHMA on household types and is set out in supporting text to at CS4. 198 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 David Howard Federation of CS3 The strategy is aiming to deliver a greater number of units than required by the existing The housing targets in the Revise 6 Residents Distribution of London Plan and the draft revised London Plan. There is an obsession with delivering Core Strategy are lower than supporting 4 Associations in growth large numbers of flats to the detriment of quality. There are too many one and two that of the draft London Plan text to CS3 Barnet (FORAB) (formerly bedroom rabbit hutches for hobbits often in high rise out of character large blocks and and this presents a CS2) insufficient numbers of three and four bedroom family houses with gardens. The challenge for Barnet. Further provision for affordable housing in a variety of tenures is weak. clarification on the 15 year housing targets is provided in the supporting text to CS3. Our housing mix is informed by evidence from the SHMA on household types and is set out in supporting text to at CS4 4 4 Pauline McKinnell Cricklewood CS3 These areas are becoming congested with traffic which is destroying the enjoyment of Development of Brent Cross None 6 Community Distribution of life for residents along this corridor. We welcome new housing but residents should be Cricklewood has been 7 Forum growth listened to as they know how much and where it could be built to integrate with existing subject to substantial (formerly communities. community involvement. CS2) 4 5 Pauline McKinnell Cricklewood CS3 Traffic increase will need to be looked at along A5 already slow moving at rush hours. Transport Assessments None 6 Community Distribution of Don't know about the other areas. have been carried out for the 7 Forum growth three major regeneration and (formerly development areas in the CS2) borough, two of which have been adopted as Area Action Plans. The AAPs included proposals to improve road junctions. 4 6 Pauline McKinnell Cricklewood CS3 As long as the regeneration does really improve them i.e. no more ugly buildings. Again Our housing mix is informed None 6 Community Distribution of residents should be listened to. Don't think housing density should be optimised by evidence from the SHMA 7 Forum growth anywhere in the borough. Homes should be built that people want to live in. Also on household types and is (formerly existing homes should be improved not knocked down and rebuilt. What a waste of set out in supporting text to CS2) resources. CS4 4 6 Government CS3 Policy CS2 (Distribution of Housing Growth) must be absolutely clear in setting out We have revised CS3 and Revise CS3 7 Office for Distribution of what the total housing target is and when, where and how housing will be delivered. We supporting text to clearly set and add new 0 London growth recommend that policy includes the following information; out the sources of the table 2 on (formerly a) Total housing delivery target for plan period (15 years from date of adoption); 28,000 units we expect to targeted CS2) b) Annualised housing target; deliver within the lifetime of housing c) Housing target broken down by key sites and by expected delivery period (0-5, 6-10, the Core Strategy and growth and 11-15 years). highlight that Barnet’s windfalls d) Explanation of any shortfall between a) and c) above. capacity to deliver housing is finite
4 7 Government CS3 Policy CS2 (Distribution of Housing Growth) and CS 7 (Providing Quality Homes) are Agree Revise order 7 Office for Distribution of both housing policies. It would be helpful if the structure of the Core strategy kept of policies so 0 London growth similar topics together. that CS7 (formerly becomes CS2) CS 4
199 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Government CS3 Housing trajectory – explanation required as to why housing completions appears to fall We have revised the Revise 7 5 Office for Distribution of to zero in 2015/16. trajectory to cover the housing 0 London growth lifetime of the Core Strategy trajectory (formerly CS2) 4 3 David Howard New Barnet CS3 Policy CS2 states that Barnet will promote the following sustainable locations with good Agree Revise CS 3 7 Community Distribution of access to public transport as the main focus of enhancement and major infill housing and 1 Association growth development. In the same policy it makes reference to the A110 East Barnet Road as supporting (formerly one of these locations. The Barnet Characterisation Study states that in New Barnet, text CS2) “There is an overall consistency of massing within the built form, with most residential units rising to two or three storeys at most”. There is a significant risk that identifying East Barnet Road as a location for major infill housing development will put it in direct conflict with the evidence of the Characterisation Study.
We therefore wish the reference to New Barnet or A110 East Barnet Road to be removed from Policy CS2 and from sections 7.1.11, 8.1.8 and 8.1.9
4 1 David Howard New Barnet CS3 Para 5.1.10. People in larger homes will always continue to under occupy when the We are supportive of the None 7 8 Community Distribution of only choice is new rabbit hutches for hobbits. Britain builds the smallest new homes in Mayors approach to the 1 Association growth the developed world (see www.swingacat.info) we will be demolishing today’s new quality and design of (formerly homes within 30 years just as we are demolishing Graham Park and Stonegrove. housing including the CS2) housing density matrix and the new space standards in the draft London Plan. If the standards pass scrutiny and form part of the final London Plan they will replace the standards set out in the SPD on Sustainable Design and Construction. 4 2 David Howard New Barnet CS3 Para 8.1.8/9, 8.2.2 are too wide ranging and while some of the aspirations may apply to Agree Revise CS 3 7 4 Community Distribution of other town centres they do not apply to New Barnet and it should be excluded from the and 1 Association growth list supporting (formerly text CS2) 4 3 Steven Deller CS3 In other words shove all the housing in areas that are unpopular with the Barnet The strategic growth corridor None 7 Distribution of establishment. Barnet is already too big and should be broken up as a borough. This is on the western side of the 8 growth exactly what you haven't done with Cricklewood, where you plan to increase housing borough is the product of (formerly by 250% in an area that is totally bound by six lane motorways and with no real plans joint working with Camden, CS2) for any meaningful infrastructure Brent and Harrow as well as the GLA and Luton and Watford Councils. This work will help build the case for investment in transport and social infrastructure to support growth. 4 4 David Dobbs CS3 Housing growth in this area should be promoted, but firstly there needs to be proper An infrastructure delivery Publish 8 Distribution of development to underpin these areas as desirable for families to live in. Currently this is plan setting out the where, Infrastructure 1 growth not the case. House building should be considered after other developments to improve when, what and how of Delivery Plan (formerly the community infrastructure in these areas. infrastructure delivery will CS2) accompany the publication 200 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations version of the Core Strategy.
4 5 David Dobbs CS3 Theses are areas already have a high density of buildings - further developments Please refer to our earlier None 8 Distribution of above ground floor level are not desirable (I refer again to the North Finchley response on mixed use 1 growth development). development at 481/3 (formerly CS2) 4 7 David Dobbs CS3 To optimise housing density from current levels to reflect these factors would require a The approach on optimising None 8 Distribution of baseline reduction in housing. The local infrastructure currently isn't suitable to meet density is clear in reflecting 1 growth the needs of the local population. Public transport and the NHS are already at levels in local context, public (formerly excess of safe capacity. transport accessibility and CS2) social infrastructure. It does not start from current levels of housing. 4 4 Maria Nash Barnet Women's CS3 High rise dwellings are not required in Barnet, we are known as a green borough with The draft revised London None 8 Design Group Distribution of family homes and spaces for children to grow up in. Skyscrapers are for offices in Plan is clear on the use of 3 growth industrial areas or Dubai hotels not for raising families or housing the vulnerable elderly the density matrix and states (formerly that it is not appropriate to CS2) apply the table mechanistically. There will be opportunities for higher density development within the upper range of the matrix in Barnet. We will be guided in assessing any future proposals for tall buildings by a Tall Buildings Study which will follow advice by CABE/English Heritage. 4 5 Maria Nash Barnet Women's CS3 The concerns of the local people are being ignored. Meaningful involvement is what is Consultation on the Direction None 8 Design Group Distribution of required. Not consultations were no matter what feedback we give you ignore it. We of Travel included meetings 3 growth need more time to involve more people to get their views with many more inclusive and presentations to a wide (formerly methods so that disabled people could also have a say especially about transport variety of groups and CS2) stakeholders explaining what we were doing, why we were doing it and how they could get involved. 4 6 Maria Nash Barnet Women's CS3 Why should people who are vulnerable - young, old, poor or disabled not have the We aim to provide housing None 8 Design Group Distribution of opportunity to live in houses rather then high rise flats so that the developers can make choice that meets needs and 3 growth money from council properties by putting more and more people on estates aspirations of residents. The (formerly regeneration of housing CS2) estates will help provide decent homes.
201 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 Maria Nash Barnet Women's CS3 To actually involve the people who live, work and visit Barnet on how many homes they These are specific transport None 8 Design Group Distribution of want, where they want the homes and where they need hospitals. GPs surgeries etc. and operational issues that 3 growth We have been asking for cross borough transport for ever and nothing has been done can be considered by the (formerly yet. Barnet won't allow double taxi card swipes nor does it have Capital Taxi scheme. review of the Transport Local CS2) Barnet's disabled & elderly people have to pay more then any other person living in Implementation Plan. London because of the lack of decent transport and Barnet's policy of ignoring vulnerable peoples needs
4 4 Robert Shutler Woodside Park CS3 The amount of housing and the increase in population being promoted is far too much Our approach is clear and None 8 Garden Suburb Distribution of and based on inaccurate figures in the first place. Everyone (except the Council it consistent with national 5 Residents growth seems) knows that the 2001 Census was totally inaccurate. policy and the draft London Association (formerly Plan. The Three Strands CS2) Approach sets a clear spatial agenda for Barnet whereby growth is complimented by protection and enhancement. 4 5 Robert Shutler Woodside Park CS3 Can you please have a decent standard of architecture and not the cheap and nasty This is a borough wide None 8 Garden Suburb Distribution of stuff being designed at present. strategic document which is 5 Residents growth in accord with CABE advice Association (formerly on Planning for Places - CS2) Delivering Good Design Through Core Strategies. 4 4 Michael Storey CS3 In normal circumstances, I would support this statement, but I know you'll use it to We refer to our earlier None 8 Distribution of shoehorn hundreds of unwanted 1- and 2-bed flats in New Barnet (something there response at 487/2 on New 7 growth was a surplus of even at the top of the property market) once you've finished shooing in Barnet. (formerly Tesco and their mob. CS2) 4 8 Glen Rollings Greater London CS3 Revision of housing targets in accordance with draft replacement London Plan. See We have updated the Revise CS3 8 Authority Distribution of comments on housing provision below. supporting text to CS 3 to supporting 8 growth highlight figures in the text (formerly adopted and draft London CS2) Plan. 4 1 Glen Rollings Greater London CS3 TFL recommends that the Mill Hill East and Colindale boxes should include the Additional text has been Revise 8 1 Authority Distribution of statement “delivery of a fully accessible Underground station and improvements to bus, added to the Mill Hill East information 8 growth walking and cycling capacity in order to ensure that an appropriate level of transport and Colindale boxes to boxes and (formerly capacity and accessibility is provided in advance of or concurrently with development clarify the range of CS9 CS2) demand”, in accordance with London Plan policy 3C.1 Integrating transport and improvements that are being supporting development and policy 6.1 of the Transport strategy in the Consolidated draft sought in these areas. text replacement London Plan (October 2009). Additional text has also been added to the section on providing integrated and efficient travel. 4 1 Glen Rollings Greater London CS3 TFL recommends that a reference be made to delivering step free access at Brent Additional text has been Revise 8 2 Authority Distribution of Cross Underground station. added to the box. Additional information 8 growth text has also been added to boxes and (formerly the section on providing CS9 CS2) integrated and efficient supporting travel. text
202 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Glen Rollings Greater London CS3 The draft replacement London Plan sets targets for Brent Cross and Cricklewood to We have updated paragraph Amend 8 6 Authority Distribution of provide 10,000 new homes (although the site is partially within the London Borough of 1.3.1 and 1.4.1 to highlight paragraphs 8 growth Brent), Colindale 12,500 homes, and Mill Hill East 2,100 homes in the period to 2031. figures in the adopted and (formerly The figures within the draft policy should be updated to reflect these. draft London Plan. CS2) 4 1 Glen Rollings Greater London CS3 The density matrix should be used in conjunction with the public transport accessibility We have revised the Revise 8 7 Authority Distribution of level, and its potential for future improvement. Additionally, density at any level should supporting text to highlight supporting 8 growth be design-led, and while it is correct to optimise rather than maximise, there will be the importance of design and text to CS3 (formerly instances where developments are appropriate within the upper end of the range. The context CS2) explanatory text should be expanded to stress the importance of design and context.
4 1 Glen Rollings Greater London CS3 TFL would like to see the addition of a paragraph under Policy CS.2 which states that We have revised policy CS1 Revise CS1 8 8 Authority Distribution of LB Barnet will “ensure that a relative level of transport capacity and accessibility is to add a reference to an 8 growth provided in advance of or concurrently with development demand” in accordance with appropriate level of transport (formerly London Plan policy 3C.1 Integrating transport and development and policy 6.1 of the capacity and accessibility. CS2) Transport strategy in the Consolidated draft replacement London Plan (October 2009).
4 2 Glen Rollings Greater London CS3 The housing figures should be updated to be in line with the draft replacement London See response at 488/16 Amend 8 8 Authority Distribution of Plan and draft revised Housing SPG. paragraphs 8 growth (formerly CS2) 2 John Dix CS3 Policy CS2 states that Barnet will promote the following sustainable locations with good Major thoroughfares are no Revise CS3 Distribution of access to public transport as the main focus of enhancement and major infill housing longer identified as having to remove growth development. In the same policy it makes reference to the A110 East Barnet Road as potential for infill housing major (formerly one of these locations. The Barnet Characterisation Study states that in New Barnet, development thoroughfare CS2) “There is an overall consistency of massing within the built form, with most residential s units rising two or three storeys at most”. There is a significant risk that identifying East Barnet Road as a location for major infill housing development will put it in direct conflict with the evidence of the Characterisation Study. 3 John Dix CS3 In addition, it is clear that the infrastructure in New Barnet cannot cope with additional Agree. The Albert Road site Revise CS3 Distribution of infill properties. Local schools are full, and dependent on temporary classrooms to meet will be identified in our and growth the current intake. It is exceptionally difficult to get an NHS dentist and doctors’ lists are emerging Site Allocations supporting (formerly full. Over Christmas the problems arising from the lack of gas supply and the electricity DPD. text CS2) cables burning out in Crescent Road due to excess demand illustrate how finely Our Infrastructure Delivery balanced the utilities network is already. Further infill housing will only serve to make Plan sets out the what, power cuts a more frequent occurrence. A small residential development on the Albert when, where and how of Road Gasworks site, where new utility services could be specifically installed, would infrastructure delivery over seem to offer a more practical solution. the next 15 years. I therefore wish the reference to New Barnet or A110 East Barnet Road to be removed from Policy CS2 and from sections 7.1.11, 8.1.8 and 8.1.9.
203 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 John Dix CS3 In addition Policy C2 also identifies North London Business Park (NLBP) as a site for The Planning Brief for NLBP None Distribution of mixed use development including 400 new homes. This is the only Business Park in the which promotes mixed use growth borough and is a major centre for potential employment. In the new Draft London Plan, development was adopted in (formerly October 2009, this site is identified in Policy 2.17 as a Strategic Industrial Location (SIL) 2006 following public CS2) and detailed specifically in Annex A3.1 as an Industrial Business Park (IBP). Policy consultation and discussions 2.17 specifically states that as part of LDF preparation Boroughs should: “identify SILs with the GLA. on Proposals Maps and develop local policies to protect their function, to enhance their attractiveness and competitiveness for industrial type activities including access improvements”. I cannot see how a proposal for 400 homes on this site meets this requirement. I would therefore ask that North London Business Park is deleted from Policy CS2. P New Barnet CS3 Policy CS2 states that Barnet will promote the following sustainable locations with good Agree Revise CS3 r Distribution of access to public transport as the main focus of enhancement and major infill housing and of growth development. In the same policy it makes reference to the A110 East Barnet Road as supporting o (formerly one of these locations. The Barnet Characterisation Study states that in New Barnet, text r CS2) ‘There is an overall consistency of massing within the built form, with most residential m units rising to two or three storeys at most’. There is a significant risk that identifying a East Barnet Road as a location for major infill housing development will put it in direct conflict with the evidence of the Characterisation Study. It is recommended that reference to New Barnet or A110 East Barnet Road to be removed from Policy CS2 and from sections 7.1.11, 8.1.8 and 8.1.9
204 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 8 Ian Dubber Workspace CS4 Quality The housing mix should be determined on a site by site basis. It is important that the A key objective of the Core Revise CS4 4 Group PLC homes and market housing mix is determined by the private sector so that residential schemes can Strategy is to provide and 1 housing respond to the market demands and site specifics at any one time, taking into account housing choice in meeting supporting choice market signals. the aspirations of existing text (formerly The size of dwellings relates more to age and wealth than it does to the sizes of and future residents. CS7) households. Households typically build up wealth through the course of a lifetime. In line with guidance set out Using a lifecycle model household’s ma start with smaller housing but progress up a in PPS3 the support of the housing ladder over the course of a lifetime looking for larger properties when they Strategic Housing Market have children and when they are able to afford to do so. As they age and children Assessment helps determine mover away from home, many households choose to remain in their existing housing the dwelling mix for new rather than downsize. There is therefore typically no direct relationship between house residential schemes. size and household size in the private sector. The social sector is more regulated in On the basis of the SHMA, that housing is allocated in relation to the housing size required but it is s It is apparent an affordable housing that housing and planning policies have little influence over who occupies housing, viability assessment and particularly in the private sector. Workspace therefore would support a flexible local circumstances we have approach to providing for the mix of market and affordable housing. Workspace also set an appropriate level considers that the dwelling mix should be considered on a site by site basis. of affordable housing and Workspace supports the principle of affordable housing provision in new developments tenure mix. for the purposes of securing local need and ensuring a mixed and sustainable community. However, such provision should be considered on a site by site basis, together with its viability and the regeneration benefits a scheme could provide. Workspace objects to the requirement to provide 50% affordable housing on development sites. Workspace considers that affordable housing should be considered subject to site characteristics, location and overall scheme It is apparent that housing and planning policies have little influence over who occupies housing, particularly in the private sector. Workspace therefore would support a flexible approach to providing for the mix of market and affordable housing. Workspace considers that the dwelling mix should be considered on a site by site basis. Workspace supports the principle of affordable housing provision in new developments for the purposes of securing local need and ensuring a mixed and sustainable community. However, such provision should be considered on a site by site basis, together with its viability and the regeneration benefits a scheme could provide. Workspace objects to the requirement to provide 50% affordable housing on development sites. Workspace considers that affordable housing should be considered subject to site characteristics, location and overall scheme viability. PPS3 states in paragraph 29 that affordable housing targets should take into account the risks to housing delivery. Indeed a number of core strategies such as Blythe Valley and Wakefield have been found unsound on the basis that they have not assessed the viability of affordable provision. Workspace agrees that the tenure mix of 70% social rented housing and 30% intermediate affordable housing should be considered as guidelines and open to negotiation. Workspace considers that the affordable housing tenure be determined on a site by site basis. Workspace also considers it important that the tenure mix be indicative only and open to negotiation whereby issues such as schemes viability and the economic and social benefits of regeneration should be taken into consideration.
205 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 1 McCarthy and CS4 Quality My client McCarthy & Stone Retirement Lifestyles is pleased to see such detailed The Core Strategy promotes None 4 Stone homes and consideration of older persons housing needs. We would add that there is a lack of housing choice and 3 Retirement housing housing choice in the sheltered accommodation as identified by 13.4.2 where we are recognises this is an issue Lifestyles Ltd choice told that 89% of the sheltered accommodation in the borough is for rent. Combine this for older people. The private (formerly with comment 13.4.1 that the older people in Barnet are more likely to be owner sector for older persons CS7) occupiers and more likely to under occupy their properties then it points to an identified therefore has a role to play housing need in the borough for private sector for sale sheltered accommodation and in delivering appropriate extra care housing. My client would wish the Core Strategy to acknowledge the role accommodation. private sector older persons accommodation will have in meeting housing need. 3 7 A2 Dominion CS4 Quality Preferred Policy CS 7 does not set out a preferred mix of dwelling sizes and types of A key objective of the Core Revise CS4 7 Housing homes and housing for all tenures, advocating that each site should be considered on its own Strategy is to provide and 4 housing merits and the character of the area. This policy should go further and state that not housing choice in meeting supporting choice every location will be appropriate for all types of housing. In addition, where more site the aspirations of existing text (formerly specific guidance is available to advise on the local requirements then this document and future residents. CS7) should take precedent. In line with guidance set out Preferred Policy CS 7 also identifies that the Borough will aim to create successful in PPS3 the support of the communities by securing an appropriate level of affordable housing for Barnet that will Strategic Housing Market support the Council’s objectives of widening home ownership and providing family Assessment helps determine homes. The level on affordable housing will be based on a Borough wide assessment the dwelling mix for new of viability of affordable and will have regard to the Mayor’s strategic housing target that residential schemes. 50% of housing provision should be affordable on sites of 10 or more units. Policy CS 7 also notes that with regard to the London Plan objective of a 70:30 social rented to intermediate ratio, an appropriate affordable mix will be negotiated to deliver wider sustainable development and regeneration objectives. 3 1 Asda Stores Ltd CS4 Quality We welcome policy that seeks the development of a mixture of dwellings throughout Please see response at Revise CS4 7 7 homes and the Borough. Policy should allow flexibility for the Council to review the merits of each 374/7 and 9 housing respective proposals having regard to site constraints and the viability and deliverability supporting choice of the scheme. text (formerly CS7) 3 1 Asda Stores Ltd CS4 Quality It is important that the Council’s affordable housing policy reflects local requirements A key objective of the Core Revise CS4 7 8 homes and and has regard to the constraints and viability of each respective scheme. Strategy is to provide and 9 housing housing choice in meeting supporting choice the aspirations of existing text (formerly and future residents. CS7) 3 1 Asda Stores Ltd CS4 Quality In setting a 50% target the London Plan notes that this target includes affordable Please see response at Revise CS4 7 9 homes and housing from all sources and not just that secured through planning obligations. It 374/7 and 9 housing comprises all types and tenure of housing associations, intermediate housing, non-self supporting choice contained accommodation, gains from conversions and from bringing long-term vacant text (formerly properties into use as a new housing. CS7)
206 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations The London Plan advises Council’s that in estimating the provision of affordable units from private residential or mixed use developments that they should take into account economic viability, highlighting that in all but the highest value sites it is unlikely that the development will be able to fund development of 50% of units as affordable. On this basis we welcome confirmation that policy in Barnet will not be dictated by the London Plan but will be based on Barnet’s assessment of local needs. Further to this however, the Council should make clear that when agreeing proportion of affordable housing to be included within housing developments that will do so having regard to the specific merits of the proposals, including design requirements, viability and deliverability.
4 5 Matthew Thomas Bride Hall CS4 Quality Bride Hall is supportive of the flexible approach taken to the provision of affordable We welcome this support None 0 Holdings Ltd homes and housing. 4 housing choice (formerly CS7) 4 1 Julia Hines Age Concern CS4 Quality In addition older people believe that new homes should be designed with walk in We do recognise this as an None 1 1 homes and showers as these are easier for older people with disabilities to use than baths. issue but detailed design 8 housing considerations are not choice appropriate for the Core (formerly strategy CS7) 4 1 Julia Hines Age Concern CS4 Quality We are concerned about the lack of fixed targets for affordable housing. Recent On the basis of evidence Revise CS4 1 5 homes and weather conditions have shown the importance of having key workers in, for example, from the SHMA we have and 8 housing health and social care and public transport, living within the borough to ensure crucial now set an affordable supporting choice services can be provided. housing target for the next text (formerly We support mixed and balanced developments, because we do not see the alternative 15 years which is supported CS7) (pockets of deprivation) as being supportive to the needs of older people within the by an economic viability borough. 'Older people within the borough assessment strongly support the provision of sheltered housing. A key objective of the Core Strategy is to provide housing choice in meeting the aspirations of existing and future residents. Sheltered housing should form part of a range of choice for older people. 4 2 Gaby Kagan Labour Group CS4 Quality At section 5, ‘The challenges we face’ the Strategy lists high quality housing as one of On the basis of evidence Revise CS4 2 homes and the reasons people choose to live here, but the fact remains that many people cannot from the SHMA we have and 9 housing afford to live in Barnet with average house prices in the borough between £300,000 and now set an affordable supporting choice £400,000. To secure a mortgage on a property valued at £300,000 a household income housing target for the next text (formerly of about £100,000 would be required, but it is estimated that only 10.5% of residents 15 years which is supported CS7) earn in excess of £75,000 a year, with 11.6% earning less than £15,000. Throughout by an economic viability the Strategy we read about the ‘aspirations of home ownership’ and there’s frequent assessment reference to ‘housing choice’ but on the council's own data even low cost or shared ownership schemes are out of reach of many people in the borough, and therefore greater emphasis must be placed on building affordable homes for rent as well as to buy. Without a serious commitment to providing more quality affordable homes for rent inevitably only more affluent people will be able to afford to live in Barnet.
207 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Housing gets a mention in section 6 on Vision and Objectives where again the promise is ‘to manage housing growth to meet housing aspirations’. Reference is made to regeneration of the estates, Dollis Valley, Grahame Park Stonegrove/Spur Road and West Hendon to replace the existing homes with ‘a greater range of accommodation that provides access to affordable and decent homes.’ But the original estates had a total of 3688 homes, all of which were affordable social rented and the regeneration schemes will not deliver any net increase in affordable housing. In fact, there may be a net loss of affordable housing. The phase underway at Stonegrove/Spur Road for example has been allowed to proceed with a reduction in the number of affordable homes initially agreed.. The current London Plan stipulates that Barnet needs to build 20, 550 houses in the next 10 years, 50% of which needs to be affordable. The 50% affordable units target is also a Barnet UDP policy and in our Affordable Housing SPD. More recently the new Mayor of London made it clear that he is expecting Barnet to build its share (3,369) of the 50,000 affordable homes he promised to deliver in London over 3 years.
4 7 Gaby Kagan Labour Group CS4 Quality Policy CS11 could give more prominence to the work of the Safer Neighbourhood Agree Reference to 2 homes and Teams. They are not actually mentioned in the text of the policy. They have made a safer 9 housing difference and many have developed a detailed knowledge of their local areas that neighbourho choice might add value to planning and development, for example, of town centres. od teams (formerly added to CS7) CS12. 4 3 Georgia Wrighton Women's CS4 Quality BWDG welcome that Barnet are seeking to provide housing size and type to meet the All new homes are required None 3 Design Group homes and diversity of the growing population, however, provision of lifetime homes is a key part of to be built to lifetime homes 3 housing meeting the needs of a diverse population throughout its life and for those who are less standards by the London choice mobile or require wheelchair access. Therefore all new homes should be provided to Plan. This also includes a (formerly Lifetime Home standards and provide at least 10% wheelchair accessible housing. requirement for 10% of CS7) Lifetime Neighbourhoods should also be a driving principle behind all new housing to be wheelchair developments and changes to existing neighbourhoods. Furthermore, Barnet should accessible. In line with produce its own Supplementary Planning Document setting out what is expected of PPS12 we do not need to developers for Lifetime Homes, Neighbourhoods and Wheelchair accessible housing. repeat this policy. The Mayor intends to produce SPG on the quality and design of housing developments. In providing quality homes and housing choice we support lifetime neighbourhoods and Building for Life Standards. 4 4 Georgia Wrighton Women's CS4 Quality The retention of social rented housing in existing neighbourhoods and provision of the On the basis of evidence Revise CS4 3 Design Group homes and many more social rented units needed in the Borough is a key concern for the BWDG. from the SHMA we have and 3 housing The BDWG would like to see 50% of all new housing provided as affordable housing now set an affordable supporting choice with 70% social rented and 30% intermediate housing, with a proportion also for co- housing target for the next text (formerly operatives. 15 years which is supported CS7) by an economic viability assessment 4 8 Robert Newton CS4 Quality Add the following additional bullet points: On the basis of evidence Revise CS4 3 homes and from the SHMA we have and 6 housing now set an affordable supporting choice housing target for the next text (formerly 15 years which is supported CS7) by an economic viability assessment 208 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations “Ensuring that developments comply with Policy 3.5, Table 3.3 and Paragraphs 3.26 to Density has already been 3.33 of the London Plan Consultation Draft Replacement Plan (October 2009) with addressed at policy CS3 and regard to the quality and design of housing and space standards.”“Encouraging and there is no need to repeat promoting the provision of homes suitable for older people in town centre and other policy. The Core Strategy accessible locations with good local service provision so as to provide opportunities for does seek to promote relocation and the release of under occupied family houses.” housing choice in meeting “Ensuring that new housing provision in the Borough is more balanced to satisfy the the aspirations of existing demand for houses with gardens and to address the shortage of larger houses in and future residents, young particular at the same time as inhibiting opportunities to replace single family housing and old. The issue of limited by conversion and redevelopment for flatted accommodation.” 'Reason. To ensure housing choice for older adequate construction standards, make provision for older people whilst facilitating the persons is recognised as is release of under occupied houses and halting the loss of family housing. Amend the their desire to remain within wording of Paragraphs 13.1.1 to 13.10.1 where necessary to reflect these changes to their neighbourhoods and Policy CS7. enjoy a good quality of life. Reason. To ensure adequate construction standards, make provision for older people We will set out policy on whilst facilitating the release of under occupied houses and halting the loss of family older persons housing that are in short supply to flatted development that is being adequately accommodation in the provided for under Strand 3 of the Three Strands Approach. Development Management Policies DPD.
4 1 Brent Cross CS4 Quality Policy CS7 sets out the Council’s approach to housing in the borough. With regard to On the basis of evidence Revise CS4 4 0 Cricklewood homes and the appropriate level of affordable housing, the policy states that regard will be had to from the SHMA we have and 0 Development housing the Mayor’s strategic housing target of 50% and the social rented: intermediate split of now set an affordable supporting Partners choice 70:30, as set out in the adopted London Plan. As noted in explanatory paragraph housing target for the next text (formerly 13.9.6, the policy should be updated in the future as necessary to reflect the emerging 15 years which is supported CS7) strategic policy direction of the new London Plan. by an economic viability assessment 4 7 British Library CS4 Quality The BL supports this flexible approach to affordable housing provision and is pleased to Please see response at Revise CS4 4 homes and note that the CAAP sets an affordable housing policy in line with the London Plan 50% 374/7 and 2 housing target to negotiate the maximum reasonable amount subject to viability. Paragraph supporting choice 3.54 of the London Plan states that “the Mayor wishes to encourage, not restrain text (formerly residential development and boroughs should take a reasonable and flexible approach CS7) on a site-by-site basis” The BL supports a site by site approach being taken to affordable housing provision, mix of housing units and housing density, taking into account the constraints and opportunities of each housing site, rather than a blanket requirement being implemented across the whole of the borough.
4 7 Metropolitan CS4 Quality The MPA support the provision of affordable housing and in particular key worker We welcome this support None 4 Police Authority homes and housing in line with the London Plan. 3 housing choice (formerly CS7)
209 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Mike Dawson Finchley Society CS4 Quality The sector with the least choice and greatest need of homes in Barnet is affordable We have responded to the None 5 0 homes and housing (DoT, item, 13.2.5): issue already at 455/3 5 housing “We know that there is a surplus of accommodation in the private rented sector in all choice sizes while there is a shortfall of affordable housing in all sizes.” On affordable housing (formerly DoT (item, 13.2.6) also claims that housing density is driven by targets for Barnet in the please see response at CS7) London Plan: 374/7 “Barnet’s Core Strategy has to address the demands for family accommodation at lower densities while meeting the demands for higher densities driven by the planned growth and regional housing targets in the London Plan.” Barnet’s own target of 28,000 homes is some 25% above that required by the London Plan of 22,055 homes to be achieved by 2026. It must therefore be possible to provide more lower density accommodation while still fulfilling London Plan requirements. Policy CS 7, bullet point 4 and the final paragraph of CS 7 should be amended to read: • securing a mix of affordable housing for Barnet that will support our objectives of widening home ownership and providing family homes. This mix will be based on a borough wide standard of affordable housing required by the Mayor’s strategic housing target of 50% (or as in the amended plan to come) of housing provision should be affordable and that the threshold for negotiating provision should be set at 10 units. With regard to the London Plan objective of a 70:30 social rented to intermediate ratio, we will negotiate an appropriate affordable mix which delivers wider sustainable development and regeneration objectives final paragraph: We will monitor the delivery of additional housing against the target (of 20,055 new homes by 2016/17) set within the London Plan and will seek to maintain supply at the rate necessary to meet the target. In seeking to maintain the housing supply we will adjust the type and mix of housings
4 3 MWG Scott Garden and CS4 Quality Paragraph 13.1.1 ‘We have to maximise housing choice providing a range of sizes and Please see response at Revise CS4 6 Plant Centre homes and types of accommodation that can meet aspirations and increase access to affordable 374/7 and 2 housing and decent new homes.’ supporting Developments choice ‘This includes homes for those who need large places to live including families’. text Ltd (formerly Paragraph 13.2.3 states ‘The Mayor’s SHMA for London suggests that the biggest CS7) requirement for market as well as social rented housing are two bedroom units while the biggest requirement for intermediate housing is four plus beds’. Paragraph 13.9.1 states ‘Home ownership remains beyond the reach of many residents in the borough; the numbers in temporary accommodation remain unacceptably high.’ The above sentiments are expressed in Policy CS7 as: • ‘Seeking to ensure a mix of housing products in the affordable and market sectors to provide choice for all households’ • ‘Seeking a range of dwelling sizes and types of housing including family and lifetime homes’ • ‘Securing an appropriate level and mix of affordable housing for Barnet’
210 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 MWG Scott Garden and CS4 Quality Paragraph 13.7.1 states that Barnet’s current housing target is to provide a minimum of We are required to Revise 6 Plant Centre homes and 20,055 new homes by 2016/17. The 2008/9 Barnet AMR is unavailable but the Barnet demonstrate sufficient supporting 2 Developments housing Housing Strategy up to 2026/27, Figure 1 on page 30, indicates that past records of supply for the delivery of our text to CS1 Ltd choice housing completions, and those projected for 2009/10 and 2010/11, all fall beneath the housing target by national (formerly planned housing completion target (which is in any event a minimum not a maximum). policy contained in PPS3. CS7) In the current economic climate the ambitious housing targets for 2011/12 to 2013/14 Clarification of the 15 year are unlikely to be achieved. There is no evidence provided in the Core Strategy of housing target is provided in there being sufficient deliverable (i.e. suitable, available and achievable) sites for supporting text to CS1 housing to substantiate the next five years housing target, particularly bearing in mind that such housing provision should not be just one or two bedroom accommodation in flats but also family affordable housing to meet the requirements set down in Policy CS7: • ‘Ensure a mix of housing products in the affordable and market sectors to provide choice for all households.’ • ‘Seeking a range of dwelling sizes and types of housing including family and lifetime homes.’ • ‘Securing an appropriate level and mix of affordable housing for Barnet.’
4 2 Pauline McKinnell Cricklewood CS4 Quality Don't agree with 1 million extra people of the London Plan. Think you should deliver the Please see response at Revise CS4 6 6 Community homes and housing needs of the borough which I believe is short of affordable housing of all sorts, 374/7 and 7 Forum housing private and public. supporting choice text (formerly CS7) 4 1 Government CS4 Quality Policy CS7 (Providing Quality Homes) states that affordable housing and the social to Agreed. On basis of Revise CS 4 7 1 Office for homes and intermediate ratio provisions will have “regard to the London Plan” objectives. PPS3, evidence from the SHMA 0 London housing Para 29 requires Local Planning Authorities to set an overall target for the amount of and the viability study we choice affordable housing to be provided and to set targets for social-rented and intermediate have set a target for (formerly affordable where appropriate. The policy should therefore state a specific target for affordable housing and a CS7) Barnet. tenure split 4 2 Andrew Newby Barnet Green CS4 Quality This section makes the right noises but is meaningless because it fails to specify what Please see response at Revise CS4 7 2 Party homes and the housing mix might be or what the appropriate level of affordable housing might be. 374/7 and 7 housing It makes no mention of housing for rent supporting choice text (formerly CS7) 4 2 Andrew Newby Barnet Green CS4 Quality This clause would be fine if it didn't include several get out clauses: "having regard to A viability assessment of None 7 4 Party homes and the financial viability of development, the housing market and the needs of different affordable housing delivery 7 housing groups" which would allow the council to duck its obligations. is required by national choice Planning Policy Statement 3. (formerly CS7) 4 2 David Dobbs CS4 Quality Agreed in principle, but there needs to be more regard to the needs to 'affected' Proposals for such sites will None 8 5 homes and residents who may be in close proximity to such site allocations. Also, such allocations involve engagement with 1 housing for Gypsies and Travellers need to be limited or prescribed in some way to prevent local communities. choice creeping enlargement. (formerly CS7)
211 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Maria Nash Barnet Women's CS4 Quality Barnet needs to have an Accessible Housing Register to ensure the homes that are All new homes are required None 8 4 Design Group homes and specifically built or adapted for disabled people and wheelchairs users remain for other to be built to lifetime homes 3 housing disabled residents in Barnet standards by the London choice Plan. This also includes a (formerly requirement for 10% of CS7) housing to be wheelchair accessible. In line with PPS12 we do not need to repeat this policy. The Mayor intends to produce SPG on the quality and design of housing developments. In providing quality homes and housing choice we support lifetime neighbourhoods and Building for Life Standards. 4 2 Maria Nash Barnet Women's CS4 Quality Plus there should be more access to mental health and care services which move with Identifying the sites to None 8 5 Design Group homes and Gypsies and Travellers address their long term 3 housing needs would address these choice issues. (formerly CS7) 4 2 Michael Storey CS4 Quality MORE FAMILY HOUSES. LESS 1- AND 2-BED FLATS. In line with guidance set out None 8 1 homes and Build more houses, build less flats. Don't seek to outstrip the London Plan. Keep more in PPS3 the housing mix is 7 housing flats out of New Barnet - there are already a surplus. supported by the sub choice regional Strategic Housing (formerly Market Assessment. CS7) 4 2 Glen Rollings Greater London CS4 Quality The draft replacement London Plan and Housing SPG do not include the 50% target, We have developed our Revise policy 8 9 Authority homes and but continue to seek the maximum reasonable provision of affordable housing. In approach to affordable CS4 and 8 housing addition the aspirational tenure split has been revised to 60% social rented to 40% housing on the basis of supporting choice intermediate housing. Also, the figure for housing provision is set out as 22,550 in the evidence from the Strategic text (formerly draft replacement London Plan. Housing Market Assessment CS7) 'Consideration should normally only be given to off-site provision where an alternative and the affordable housing site or sites have been identified which would enable affordable housing provision more viability study together with appropriate to the identified needs to be met and where the project is deliverable prior PPS3 and the adopted and to the on site market development being completed. draft versions of the London 'The dwelling mix should be appropriate to the area and relate to housing need. The Plan. housing mix proposed should therefore maximise the potential of the site as set out in policy 3A.3 of the London Plan and relate to the London Plan density as set out in draft London Plan table 3.2.
212 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 3 Ian Dubber Workspace CS5 Workspace supports the promotion of high quality design in new developments that PPS1 recommends that all None 4 Group PLC Protecting create unique places with a local character. Workspace considers that the design of those involved in the 1 and new residential developments should be considered on a site by site basis. Workspace development process should enhancing considers that the Council should seek to achieve high-density residential development aim for high quality and Barnet to maximise the use of redundant and underused land. inclusive design. Density (formerly should not drive CS3) development; it is an important factor, along with the local context, design, transport and infrastructure. The CS clearly sets out that we seek high quality design that is appropriate to the growth being sought. 3 7 Asda Stores Ltd CS5 It should be clear that policy will not stifle contemporary design and high density PPS1 recommends that all None 7 Protecting development where this is considered appropriate against other policies set out in the those involved in the 9 and strategy and compliments the surrounding area. development process should enhancing aim for high quality and Barnet inclusive design. Density (formerly should not drive CS3) development; it is an important factor, along with the local context, design, transport and infrastructure. The CS clearly sets out that we seek high quality design that is appropriate to the growth being sought. 4 9 Julia Hines Age Concern CS5 We support the protection of front and back gardens because of the contribution they We welcome this support None 1 Protecting make to the character, biodiversity and flood defences within the borough. 8 and enhancing Barnet (formerly CS3) 4 5 Dennis Pepper Barnet Borough CS5 We approve the DPDs concern over the loss of front and rear gardens to off-street We do recognise the None 3 Group London Protecting parking and backland development and welcome the intention to take ‘robust’ action to importance of protecting 0 Wildlife Trust and protect them. By protecting the suburb’s distinctive character in this way, the council gardens for biodiversity and enhancing would also be protecting wildlife habitats and corridors, many of which are currently sustainability as well as local Barnet being lost to thoughtless and indiscriminate ‘improvements.’ character however without (formerly We think this objective should be incorporated into Policy CS3. draconian measures we are CS3) unable to prevent residents exercising their rights through permitted development to make minor alterations to their properties front and back gardens.
213 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Robert Newton CS5 Reason: The existing wording of Policy CS3 does not reflect Paragraph 2.3.1 and it The Development None 3 Protecting should. Rewrite the second paragraph of Policy CS3 to read: “In order to further Management Policies DPD 6 and protect the Borough’s suburban houses outside the existing conservation areas, we will will provide a more detailed enhancing require the retention of houses and gardens for single family occupation except in policy framework for Barnet specific areas designated in the site allocation and development management DPDs. protection, conversion and (formerly Additionally, the draft Barnet Characterisation study will provide the basis for redevelopment of suburban CS3) assessments of individual areas for the purposes of providing detailed guidance for housing. We are producing house extension and appropriate infill development. In the second line of the third Residential Design Guidance paragraph replace the word “encourage” with the word “require”. Replace the fourth SPD to provide design paragraph with: guidelines for places with a Replace the fourth paragraph with: “We will produce: • Design guidelines for the limited consistent and coherent number of areas where there is a dominance of flatted development as will be defined architectural character. The in the Site Allocation and Development Management Policy DPDs, whilst otherwise Residential Design Guidance protecting and safeguarding suburban housing and shopping parades and suburban SPD will address infill housing on the edge of town centres. development. Design • Design guidelines on the quality and design of housing and space standards that will Guidance Note 5 addresses require compliance with Policy 3.5, Table 3.3 and Paragraphs 3.26 to 3.33 of the extensions to houses and London Plan Consultation Draft Replacement Plan (October 2009). has recently been revised. • Policies in the Development Management DPD for safeguarding the front and rear Without draconian powers gardens of houses and the stock of larger family houses together with the safeguarding we are unable to prevent of public and private amenity open space and allotment sites.” residents exercising their Amend the wording of Paragraphs 9.1.1 to 9.3.3 where necessary to reflect these rights through permitted changes to Policy CS3. development to make minor alterations to their front gardens. We are supportive of the Mayors approach to the quality and design of housing including the housing density matrix and the new space standards in the draft London Plan. If the standards pass scrutiny and form part of the final London Plan they will replace the standards set out in the SPD on Sustainable Design and Construction.
214 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 P E Pickering CS5 I welcome the proposal to identify places of special locally distinctive character. I The Development None 3 Protecting suggest adding 'in association with local voluntary organisations' between 'identify' and Management Policies DPD 7 and 'places'. It is essential however those areas outside those places should not be 'free- will provide further detail on enhancing for-alls' for developers, and the policy should include words to make that clear. policy relating to protecting Barnet The words in brackets in the last bullet point but one are unacceptable and should be the boroughs character. (formerly removed or heavily qualified, for instance by reading in their place '(as may be the case Please see response to CS3) along parts - especially near town centres - of the main thoroughfares . . .)' I look 437/2 on major forward to seeing the detailed design guidelines in draft and commenting on them. thoroughfares
4 4 Zenda Green Mill Hill CS5 Policy CS3 – Protecting and enhancing Barnet’s character (P42) makes reference to The Characterisation Study Revise 3 Preservation Protecting Barnet’s distinctive character, but focuses disproportionately on the built form. It should has focused on the built supporting 9 Society and be more explicit about the value of green spaces and green belt. It is unclear how the environment and not the text to CS5 enhancing findings of the Draft Characterisation Study have influenced policy and there is no map Green Belt as it is in the on landscape Barnet or plan to indicate how the character areas will be defined. suburbs that the challenge of character (formerly managing change is types and CS3) greatest. The Open Space CS7 on the Needs Assessment has Green Grid examined the qualitative as well as quantitative aspects of public open space. The Development Management Policies DPD will provide further development of policy for protecting the suburbs. Natural England have identified at least two landscape character areas in Barnet – Barnet Plateau and Finchley Ridge as part of the London Regional Landscape Framework. These types form the basis for our Green Grid areas and the further development of green infrastructure. 4 7 Warren Forsyth Middlesex CS5 The University welcomes the recognition in paragraph 9.1.7 that campus development We welcome this support None 4 University Protecting such as the Middlesex University campus at Hendon is a distinctive primary urban 1 and typology. This has underpinned the Masterplanning work for the development and enhancing expansion of the Hendon Civic and University Quarter at Hendon that will enable Barnet Middlesex University’s currently dispersed programmes at Trent Park and Cat Hill to be (formerly consolidated in Barnet within the Hendon flagship campus. CS3) 4 4 British Library CS5 The BL notes and supports Policy CS3 which seeks to ensure development in Barnet We welcome this support None 4 Protecting respects local context and distinctive local character. The BL recognise that detailed 2 and design guidelines will be produced in the future for a number of areas in the borough. enhancing The BL wishes to be consulted in the production of these documents. The BL note and Barnet support that such guidance should not be overly prescriptive. (formerly 215 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations CS3)
4 4 Metropolitan CS5 The MPA recognise the importance of good design in ensuring new developments are The Development Revise 4 Police Authority Protecting safe and secure, therefore helping reduce crime. The MPA support the development of Management Policies DPD supporting 3 and safe and attractive building layouts, however it is recommended that reference to the will provide further detail on text of CS 5 enhancing use of 'Secured by Design' principles are included within this policy, concurrent with policy for design. to refer to Barnet government guidance within PPS1 which states that Council's should prepare Secured by (formerly development plans which promote inclusive, healthy, safe and crime free communities. Design CS3) This further provides excellent guidance to developers and other built environment Principles professionals. Furthermore, the MPA note that Policy CS 11 supports making Barnet a safer place and support this policy. The MPA recommend that the following alteration is made to Policy CS3 - We will ensure that development in Barnet respects local context and distinctive local character and creates: - safe and attractive building layouts in line with Secured by Design Principles.
4 1 Graham Saunders English Heritage CS5 Welcome the development of a borough wide Characterisation Study. However we are We consider that the study is None 4 0 Protecting concerned that the Study is not sufficiently comprehensive, in that it excludes the major sufficiently comprehensive 6 and growth areas, green belt and conservation areas. This Study could have a played a key and provides a good enhancing role in pulling existing evidence together and expand upon it to provide a truly borough understanding of Barnet's Barnet wide understanding of the character of the Borough. At present it is not clear whether character therefore meeting (formerly this coordination of evidence will be undertaken as the current approach could be our objective of safeguarding CS3) criticised for being incomplete. We have provided informal comments at the early the suburban nature of the stages of this Study but have not been further engaged (initial comments on the Study borough. We have set a were set out in our email to you dated 28th May 2009). We would welcome the clear spatial strategy through opportunity to provide further advice and encourage you to broaden the coverage of the the Three Strands Approach Study to include those areas currently excluded. which enables the Core Strategy to integrate the needs of places with the priority issues that need to be addressed. Our evidence base needs to be proportionate and our focus has been on those areas that are not protected as Green Belt/MOL, Conservation Areas or identified as growth areas. There is not a one size fits all blanket approach to work on characterisation. 4 1 Graham Saunders English Heritage CS5 It is important to note ’gardens’ can also provide an important contribution towards the The Development None 4 1 Protecting character; appearance and setting of the heritage assets such as listed buildings and Management Policies DPD 6 and conservation areas. In the development of a criteria-based policy for assessing will provide further detail on enhancing proposals involving gardens (paragraph 9.2.5) we would seek to ensure the heritage policy for heritage Barnet value of gardens are considered as part of the criteria. (formerly CS3)
216 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Graham Saunders English Heritage CS5 Support generally Policy CS3 as a policy framework in which to manage the general Further references to the Revise CS5 4 2 Protecting character of the Borough. In particular welcome the commitment to identify areas importance of the historic and 6 and outside conservation areas, which are of special locally distinctive character. Using the environment have been supporting enhancing evidence collected from the Characterisation Study to inform this process is also added to the Core Strategy, text Barnet welcomed. We would also suggest that the Greater London Archaeology Advisor CS5 and supporting text. (formerly Service (GLAAS) could provide useful information to help identify these areas of special The Development CS3) character areas and would encourage their involvement. Management Policies DPD However a fundamental concern of Policy CS3 is that lack of clarity and purpose it has will provide further detail on for protecting and enhancing the historic environment as advised by PPG15 and policies for heritage PPG16. It is not clear whether it was the intention of this Policy to cover this important alongside PPS5. issue, as there appears to be no other policies in the Core Strategy which relates to Policy CS5 has been revised heritage matters. At present the UDP contains a robust range of heritage policies which to set out a framework for do help provide clarity on how the historic environment is protected the management of Barnet's As currently proposed for the Core Strategy there is no policy framework for the historic historic assets. We are environment, which is a major concern that raises the issue of soundness. In particular producing a Tall Buildings we would urge you to either adapt CS3 or introduce a new Core Strategy Policy that Study which will help us to explicitly sets out a framework from the management of the historic environment in assess future proposals for accordance with national guidance. This includes identifying and valuing the breadth of tall buildings.
217 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations all heritage assets the Borough contains (e.g. designated assets such as conservation areas, listed buildings, registered historic parks and gardens, Scheduled Ancient Monuments, Areas of Special Archaeological Significance, and battlefields, and non- designated assets), a commitment to protect and enhance all heritage assets and their settings, support for heritage-led regeneration, and improved access for all to understand and appreciate the historic environment. It is important to ensure that the Policy specifying heritage matters should be supported by robust evidence as advised by PPS1 in terms of up to date evidence on their environmental characteristics and PPG15. An additional concern relates the lack of a policy framework in which to manage tall building proposals. EH/CABE Guidance on Tall Buildings (2007) (EH/CABE Guidance), as endorsed by Government, specifically section 2 of the EH/CABE Guidance, recommends a robust plan-led framework which identifies appropriate, inappropriate and sensitive locations for tall buildings based upon sound evidence such as detailed urban design analysis. Where appropriate or sensitive locations are identified, the EH/CABE Guidance paragraph 2.9, recommends that more detailed work should be undertaken and presented as SPD to support policies in the Core Strategy. We would urge you to include a tall building policy in the Core Strategy on the grounds that tall buildings are a form of development that due to their scale and mass can have an impact upon the qualities of a place, including the historic environment, which is potentially greater in significance than other forms of development. Their impact may be apparent in the immediate area, but could also be more wide ranging. These unique characteristics provide a justifiable basis on which to provide a robust plan-led approach to their location and management. Further we believe that the inclusion of a specific tall building policy will provide the following benefits; • Greater clarity on where tall buildings would be appropriate or not, in advance of specific proposals being submitted; • Enables the spatial, scale and quality of requirements for new tall buildings to be established within the Core Strategy; • Provides an opportunity for public consultation at the plan-making stage for comments upon the fundamental questions of principle and design; • Reduces the potential for speculative applications in inappropriate places; • Provides greater protection to the historic environment and other important townscape characteristics that define and make the Camden special; and • Helps inform an overall vision for the future of a place. At present and based upon the information provided, our concern is that the Core Strategy does not provide sufficient clarity on how the extraordinary characteristics of tall buildings will be managed due to a lack of a robust plan-led framework in which to inform future planning decisions for new tall buildings in the Borough. We would urge you to either adapt CS3 or introduce a new Policy on tall buildings that complies with the EH/CABE Guidance.
218 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 9 Mike Dawson Finchley Society CS5 We propose that suburban houses and gardens should be protected from new-flatted The Development None 5 Protecting developments and conversions and protection given to the houses situated along major Management policies DPD 5 and transport routes. New flats and conversion should be restricted to above business will provide a more detailed enhancing premises within the existing town centre envelopes and in development and policy framework for Barnet regeneration areas where flats already exist. New apartments/conversions in Town protection, conversion and (formerly Centres should have a condition that prohibits the issue of CPZ permits, to ensure redevelopment of suburban CS3) sustainable homes, limit CO2 pollution and additional traffic congestion. housing. We are producing Residential Design Guidance SPD to provide design guidelines for places with a consistent and coherent architectural character. The Residential Design Guidance SPD will address infill development. The approach to the issuing of permits for new development reflects the strategy that was agreed by Cabinet in 2004. 4 1 Mike Dawson Finchley Society CS5 This section is given special emphasis because we fear what is planned for our Town The Development None 5 8 Protecting Centres and their associated main roads. While we wait for Town Centre strategies to Management Policies DPD 5 and be made, uncoordinated planning applications have been made for North Finchley. will provide further policy on enhancing Four aspects in particular concern us regarding Town Centre and their associated main town centres. There is no Barnet roads: support in the Core Strategy (formerly i. Applications for five and six storey flatted developments, if approved, would for retail outside town CS3) ‘canyonise’ the area. Left unchecked this style of building would significantly change centres. We refer to our the character of our Town Centre. We consider the maximum number of storeys earlier response at 455/9 permitted should be four, unless special circumstances allow more. ii. Application for joint retail/flatted development outside of the town centre zones should be refused. If allowed, this would weaken the viability of the retail centre. iii. Applications for flatted development within a Town Centre or CPZ, which do not provide car parking space as required by Barnet’s UDP/LDF, should be prohibited from being issued with CPZ Permits iv. In some roads in Barnet flatted development has been allowed to infill to an excessive level. Melvin Cohen made a strong point about infill at the recent Civic Forum when he presented the Core Strategy, DoT. He commented on the appalling quantity of flats in Hendon Lane, a suburban road close to Finchley Church End town centre, saying this must not be allowed to happen in other parts of the borough. How then can such infill, on historic routes with buildings of character, become proposed policy in DoT? All development on these routes must be in character with the area and limited in height to match surrounding properties. Canyonisation must not be allowed.
219 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Mike Dawson Finchley Society CS5 The Mayor of London has highlighted that in his review of the London Plan he will give The Development None 5 4 Protecting greater protection to back gardens because of the wide-ranging contributions that they Management Policies DPD 5 and make to the city. He proposes to set a general presumption against their loss. will provide further policy on enhancing In order to provide better protection for green spaces at the front and back of houses back gardens development. Barnet the It will be informed by the (formerly Development Management Policies DPD should set policy for gardens in-line with the draft revised London Plan CS3) proposals highlighted by the Mayor of London. and accompanying SPG
4 2 Mike Dawson Finchley Society CS5 In general, commercial development in the suburbs is not required. By definition, they In order for our town centres None 5 5 Protecting are suburbs with family houses. Barnet Council states family houses are a major to function successfully as 5 and reason why families choose to live in Barnet. sustainable places we need enhancing Better protection should be given to maintaining the character of the suburbs. If family to attract commercial Barnet homes in the suburbs continue to be converted/redeveloped as flats, the current investment. (formerly shortage of family homes will worsen. In instances where the residential typology The sub regional Strategic CS3) remains dominant but the character has been undermined by inappropriate flatted Housing Market Assessment development, further flatted development/conversion should be refused. Flatted provides the basis for the development in the suburbs is out of character. To attempt to justify flatted size of units required and development in suburbs by stating that flats are, “…a housing type that is in limited determine the need for supply in the Borough…” family units. “…a housing type that is in limited supply in the Borough…” The sub regional Strategic Is a misrepresentation of new development in the borough over recent years because Housing Market Assessment the majority of new homes in Barnet are flats. provides the basis for the Conservation area status does not necessarily reduce a homeowner’s ability to make size of units required and their homes flexible to changing lifestyle requirements or significantly increase the cost determine the need for of ownership. Even in Hampstead Garden Suburb, which has enhanced protection, family units. homes are extended, adapted and redeveloped. Policy CS 3: Include in this Policy that: We refer to our previous * Flatted development/conversions should not be allowed in the suburbs to maintain the answer at 455/9 falling stock of family homes. Major thoroughfares are no longer identified as having potential for infill housing development
220 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 David Howard Federation of CS5 We want to preserve our suburban houses and gardens from new flatted developments The Development None 6 Residents Protecting and conversions into smaller flats. In particular we feel that the houses along major Management policies DPD 4 Associations in and transport routes should be preserved as they set the character for an area. Local infill will provide a more detailed Barnet (FORAB) enhancing and/or intensification may be acceptable but it should be the exception not the norm policy framework for Barnet protection, conversion and (formerly redevelopment of suburban CS3) housing. We are producing Residential Design Guidance SPD to provide design guidelines for places with a consistent and coherent architectural character. The Residential Design Guidance SPD will address infill development. Major thoroughfares are no longer identified as having potential for infill housing development 4 2 David Howard Federation of CS5 Please save us from further high rise development, improve our failed housing estates This is a borough wide None 6 1 Residents Protecting and otherwise direct new development to designated regeneration and development strategic document which is 4 Associations in and areas. in accordance with CABE on Barnet (FORAB) enhancing Planning for Places - Barnet Delivering Good Design (formerly through Core Strategies. CS3) We are supportive of the Mayors approach to the quality and design of housing including the housing density matrix and the new space standards in the draft London Plan. If the standards pass scrutiny and form part of the final London Plan they will replace the standards set out in the SPD on Sustainable Design and Construction. 4 8 A Reid Mount Anvil Plc CS5 An acknowledgement that tall buildings will be appropriate in some locations. We are producing a Tall None 6 Protecting Buildings Study which will 6 and help us to assess future enhancing proposals for tall buildings Barnet (formerly CS3) 4 9 Pauline McKinnell Cricklewood CS5 All areas should be protected from inappropriate development. Through the Three Strands None 6 Community Protecting Approach the Core Strategy 7 Forum and integrates the needs of enhancing places with the priority that Barnet need to be addressed in (formerly Barnet. Therefore there CS3) should be appropriate development. 221 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Pauline McKinnell Cricklewood CS5 But please don't allow more high rise blocks of flats just because there are already a We will apply the density None 6 1 Community Protecting few built. matrix taking into account 7 Forum and context as well as access. enhancing We are producing a Tall Barnet Buildings Study which will (formerly help us to assess future CS3) proposals for tall buildings 4 1 David Howard New Barnet CS5 4.8.1/2/3 describes the current property types and mix and paras 7.1.1/2/3 describes The approach set out in the None 7 6 Community Protecting why the suburbs are successful. This is what has made the borough successful and a Core Strategy aims to 1 Association and desirable place to live in. Why the obsession of excessive growth which will lead to a ensure that the borough enhancing more transient population and wreck the success story? remains a successful Barnet suburb. The Core Strategy is (formerly required to address the CS3) challenges that we face as a successful London suburb. There are opportunities for targeted growth and it is imperative that we manage this. 4 7 Andrew Newby Barnet Green CS5 the aims are fine except that the third one should specify that all new buildings should We consider that for a new None 7 Party Protecting producing low emissions and where possible be carbon neutral. The residential part of building to be sustainable it 7 and the development should only go ahead if a condition is set that all projects within the should meet the enhancing overall scheme are carbon neutral. New homes and other buildings in the area will exist requirements of our SPD on Barnet for many decades and all new developments of this kind will need to be nearly carbon Sustainable Design and (formerly neutral if the government is to meet its target of reducing CO2 emissions by 80 percent Construction. CS3) by 2050. The enlargement of Brent Cross shopping centre should not go ahead at all because of its impact on congestion and pollution and its damage to nearby community shopping centres. 4 5 Steven Deller CS5 Not the case in Cricklewood where you intend to overwhelm the existing population and The Core Strategy is a None 7 Protecting break up the public spaces into postage stamp size areas. This only applies to areas to borough wide document. 8 and the East of the Hendon Way obviously In Cricklewood you are imposing inappropriate Through the Three Strands enhancing flatted development Approach the Core Strategy Barnet integrates the needs of (formerly places with the priority that CS3) need to be addressed in Barnet. Therefore there should be appropriate development. 4 8 Dorothy Badrick UKOSF CS5 fine words but in reality the development in and around cricklewood has been poor in The Brent Cross – None 8 Protecting all aspects. how about cricklewood which contains huge amounts of local history. no to Cricklewood planning 0 and redevelopment yes to cautious and careful restoration. so why does cricklewood get application was approved enhancing flats the size of rabbit hutches, where's our family housing? please in cricklewood. stop subject to S106 by the Barnet flatted development on the pennine drive estate which should be family housing and council in November 2009. (formerly throw our bxrd plan These issues were CS3) considered as part of this application 4 8 David Dobbs CS5 Agreed in principle, but the wording is too 'flexible' and ambiguous to be meaningful or Please see response at None 8 Protecting to create accountability. The entire borough should be protected from inappropriate 478/5. 1 and development. I don't believe that this is an appropriate proposal enhancing Barnet (formerly CS3) 222 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 Maria Nash Barnet Women's CS5 This policy needs to be written in stone so that no loop hole is there for the council to Each policy in the Core Addition of 8 Design Group Protecting try and balance their bad management of council's funds is offset by selling more Strategy will be monitored monitoring 3 and council land or greedy developers to change the character of Barnet by over building based on specific indicators indicators in enhancing inferior types of buildings which no one checks until it is too late. Local people as well and reported in the Annual Appendix B. Barnet as environmentalist should be consulted backed up by historical data. How will this be Monitoring Report. This will (formerly monitored? What will be put in place to ensure that these family homes will be for provide clear evidence of CS3) families and not for renting rooms out? Only producing design guidelines without policy delivery and a basis penalties means nothing to the developer because they will do what ever they want as for review of the Core the planning dept and the building regs dept do not speak to each other nor are they Strategy properly monitored. The area planning meetings also have to allow residents to have a say not only to sit and listen. Then once there is an objection or a petition it needs to be included in the decision process. 4 8 Robert Shutler Woodside Park CS5 But character is subjective and you need to define what you mean by this. And This is a borough wide None 8 Garden Suburb Protecting presumably you will stifle all contemporary design and creativity - too much control strategic document which is 5 Residents and in accord with CABE advice Association enhancing on Planning for Places - Barnet Delivering Good Design (formerly Through Core Strategies. CS3) We encourage high quality design to create high quality places. 4 5 Michael Storey CS5 I don't believe you. You have encouraged bland, characterless and low-quality Tesco Express was None 8 Protecting developments almost without exception. You granted planning permission to a Tesco approved at appeal by a 7 and Express on Victoria Road, EN4 which does not respect local context or the local Planning Inspector and not enhancing Victorian and Edwardian character of New Barnet. I think that the chair of CABE, Sir the Council. Barnet John Sorrell, summed up the problem when he said: "Our concern is not only the (formerly quality of this kind of development – which is generally very poor – but the way in which In order to ensure that CS3) architecture and places are created in the image of the retailer". He specifically brownfield site opportunities mentioned New Barnet, stating "both Asda and Tesco are pushing weak schemes here in New Barnet are managed against strong local opposition", and that "the Asda scheme fails on every level: its car in the right way a Town focussed and architecturally confused with poor housing tacked on". Centre Framework is being You can't see beyond giving the keys to the village to the supermarkets. Again, they're developed to provide a fine words, but unless I live on Wood Street or Totteridge green, I doubt I'll benefit from strategy for development in them. You are hell-bent on getting at least one more giant supermarket in New Barnet, consultation with the if not more, and something tells me that when you grant planning permission to one or community. This is a both schemes, they're unlikely to be a two-storey red-brick Victorian-style building. You borough wide strategic would see all of this destroyed - http://www.newbarnet.org.uk/issues/demolished.php document which is in accord What does this actually mean? If it means shoving flats in every corner of every street, with CABE advice on no. Planning for Places - Delivering Good Design Through Core Strategies.
223 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Glen Rollings Greater London CS5 The distinctiveness studies and identification of character/typology areas is supported. We consider that the Core None 8 9 Authority Protecting However there is still some ambiguity as to what exactly sets Barnet apart from its Strategy does demonstrate 8 and surrounding boroughs, leading people to know that they are within Barnet. The findings the distinctiveness of Barnet enhancing from the further design studies to be undertaken should be used within future iterations Barnet of this policy. (formerly CS3) P Save our CS5 Save our suburban houses and gardens from new flatted developments and conversion The draft revised London None et suburbs Protecting and protect the houses situated along major transport routes. Plan is clear on the use of iti and the density matrix and states o enhancing that it is not appropriate to n Barnet apply the table (formerly mechanistically. There will CS3) be opportunities for higher density development within the upper range of the matrix in Barnet. The Development Management policies DPD will provide a more detailed policy framework for protection, conversion and redevelopment of suburban housing. We are producing Residential Design Guidance SPD to provide design guidelines for places with a consistent and coherent architectural character. The Residential Design Guidance SPD will address infill development. 2 4 Ian Dubber Workspace CS6 Workspace supports the promotion of Brent Cross / Cricklewood as a new metropolitan We welcome this support. In None 4 Group PLC Promoting town centre and an outer London Development Centre. It is considered that this area ensuring the efficient use of 1 Barnet’s town could act as a catalyst for economic growth throughout the borough. Workspace space in town centres we centres supports the efficient use of land and buildings in town centres and the encouragement encourage a mix of (formerly of a mix of compatible uses including managed affordable and flexible workspace. compatible uses. CS4) Workspace considers that substantial mixed-use development should be promoted in all town centres. These developments should promote workspace for small and medium sized enterprises as these businesses provide the backbone of the Outer London and Barnet economy and is forecast by the GLA Economics Evidence Base to grow in importance over the plan period. 2 1 Peter Storey Friern Village CS6 Each centre should maintain/develop its own character to prevent bland repetitive In order for town centres to None 4 2 Residents Promoting development. survive as vibrant places 2 Association Barnet’s town they will have to redefine centres their roles in response to (formerly their strengths. This should CS4) make them more distinctive. 2 3 Peter Hewitt CS6 As expressed above, if East Barnet is deemed to be a 'local centre' so also should its New Barnet has been None 4 Promoting close neighbour up the East Barnet Road. identified as a district centre 4 Barnet’s town in the London Plan and its centres place within Barnet's (formerly network of town centres is 224 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations CS4) clear.
2 4 Peter Hewitt CS6 I disagree strongly with the implication that New Barnet [together with the Village] has There is no dispute that None 4 Promoting inadequate retail provision. Sainsbury's being the dominant retail outlet, is quite there are brownfield site 4 Barnet’s town capable of satisfying most of the essential day-to-day grocery and general domestic opportunities within and on centres needs of the local community and further afield, and is amply augmented by Tesco the edge of New Barnet town (formerly Express, Budgen and a variety of other smaller outlets further along East Barnet Road. centre. The Town Centre CS4) This is, I would add not to say that there is no potential for additional retail/commercial Framework provides the establishments in either New or East Barnet. Clearly there is. I would emphasise, basis for managing change however, that as far as supermarkets are concerned it would be irresponsible folly and and it is important that result in horrendous traffic flow problems if such were permitted in close proximity to development that comes Sainsbury's - as has been intimated by both TESCO and ASDA. forward includes town centre uses (as defined in PPS 4) and is of an appropriate scale. 3 4 A2 Dominion CS6 Preferred Policy CS 4 seeks to promote Barnet’s town centres. In addition, the Council We refer to our previous None 7 Housing Promoting has recognised, in the Brent Cross Cricklewood Regeneration Area Framework SPG response at 374/2 which 4 Barnet’s town (2005) that there is also benefit in providing smaller retail, restaurant and other uses highlights the policy centres within large-scale residential and mixed use developments, which seek to serve the framework for Brent Cross - (formerly development and bring activity into the area and to key locations. The Brent Cross Cricklewood therefore no CS4) Cricklewood Regeneration Area Framework SPG (2005) has identified the former specific amendment is Parcel force Site on Edgware Road as appropriate for small-scale ground floor retail required of policy CS6. uses. These uses can help to serve local needs and help to add vibrancy to these areas. Preferred Policy CS 4 should be amended to make specific provision for small scale retail facilities as part of mixed use development which will aid the vitality of schemes.
3 3 Asda Stores Ltd CS6 Building on aims to create vibrant town centres, enhance employment opportunities PPS4 states that planning None 7 Promoting and reduce the need to travel the Council should set out as a key ambition the need to authorities should be 9 Barnet’s town provide retail facilities to meet the needs of the community and the importance of "planning for a strong retail centres existing centres in meeting the needs of their respective catchment. mix so that the range and (formerly quality of the comparison CS4) and convenience retail offer meets the requirements of the local catchment area," (EC4.1b). In line with guidance in PPS12 the Core Strategy does not need to repeat this. 3 8 Asda Stores Ltd CS6 The report ‘Creating Vibrant Suburban Town Centres in Barnet’ reviewed the Borough The survey on Creating None 7 Promoting as whole. Consequently, whilst the review concluded that 95% of residents do their Vibrant Suburban Town 9 Barnet’s town main food shopping in Barnet’s town centre, this is a generic statement that does not Centres refers to 'main centres reflect accurately retailing patterns in New Barnet. Asda have carried out detailed shopping' not 'main food (formerly household survey work that suggests that within New Barnet 67% of convenience trade shopping'. The conclusions CS4) is currently lost to rival destinations whilst 99% of comparison expenditure is lost. It is of the Town Centre Needs evident when contrasted with the Council’s wider study that there is a polarisation of Floorspace Assessment and trade to larger centres both in and beyond the Borough. In this context it is important Update are clearly set out that the Council seek to support centres such as New Barnet to ensure they continue to with regards to comparison serve their local catchment. and convenience need.
225 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 9 Asda Stores Ltd CS6 We strongly disagree that there is little quantitative need for further significant The Town Centre Needs None 7 Promoting convenience retailing in the Borough. This conflicts with paragraph 10.6.2 in which the Floorspace Assessment and 9 Barnet’s town Council acknowledge retail capacity, identifying a need for convenience retailing in New Update concurs with PPS4 centres Barnet. Equally it is at odds with NLP’s review of ASDA's planning application, and sets out a qualitative (formerly commission by the Council early this year, where they concluded that there was a need and quantitative assessment CS4) for 2,385m² of convenience retail sales floorspace by 2013 on the Gas Works site. The of Town Centres. It has analysis focuses solely on quantitative need. It is made clear in PPS6 and Draft PPS4 highlighted distinct variations that qualitative factors should be considered and the need to promote choice and between centres in terms of competition are highlighted in draft PPS4 as key considerations. Any assessment of their scale, retail offer and need should consider qualitative deficiencies in existing centres. overall role. This is made clear in the identification of priority town centres. Further work on managing brownfield site opportunities in New Barnet has been developed through the Town Centre Framework 3 9 Asda Stores Ltd CS6 The text needs to acknowledge that need does exists in the Borough, that some The Core Strategy is None 7 Promoting centres are in need to enhanced facilities to enable them to serve their catchment and evidence based and is 9 Barnet’s town in this context applications should be assessed on their respective merits. guided by the Town Centre centres Needs Assessment and (formerly Update CS4) 3 1 Asda Stores Ltd CS6 As highlighted above there is a danger that trade within Barnet is polarised to higher There are 14 district centres, None 7 0 Promoting order centres at the expense of lower order centres in the Borough. It is inappropriate 5 local and one major centre 9 Barnet’s town to plan simply for those centres performing strongly. PPS6 and draft PPS4 seek to in Barnet. They are all centres promote choice and competition and safeguard the vitality and viability of existing promoted in the policy. Our (formerly centres. Accordingly, it should be made clear that comparison retailing will be position on comparison CS4) supported in all centres, especially where it addresses local deficiencies. shopping is based on evidence of need as identified in the Town Centre Needs Assessment and Update 3 1 Asda Stores Ltd CS6 We support the definition of New Barnet as a District Centre in the context of the All centres are promoted in None 7 1 Promoting London Plan. the policy and a clear 9 Barnet’s town Having regard to District Centres in the Borough policy should make clear that hierarchy is set out in the centres development will be supported in these centres to ensure they serve their respective text. CS6 clearly states that (formerly catchments and to help claw back trade lost to larger centres. we will realise development CS4) opportunities in town centres to promote competitive environments and provide consumer choice.
226 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 1 Asda Stores Ltd CS6 We support acknowledgment that there is need for convenience retail in New Barnet In order to ensure that None 7 2 Promoting and that this can be accommodated on the Gas works site as part of a mixed use brownfield site opportunities 9 Barnet’s town development. within and on the edge ofn centres Asda are currently considering amended proposals for the site having withdrawn their New Barnet town centre are (formerly planning application earlier this year. Remediation and infrastructure costs present key managed in the right way a CS4) challenges to bringing forward development on the site which will deliver significant Town Centre Framework has regeneration benefits. Proposals for the site need to raise significant value if they are been developed in order to to be viable. Failure to plan for a viable solution for the site will ensure it remains provide a strategy for underutilised and blight on in the area. development in consultation Policy should support ASDA’s aspirations for the gasworks in order to help facilitate with the community. The regeneration of the site. We recommend that the core strategy actively promote this emerging Town Centre site as the preferable location for convenience retail development in the centre and Framework has informed the make clear that central sites such as this can and should bring forward very high policy direction on New density development in terms of the frameworks generally a rigid timetable needs to be Barnet provided. Having regard to New Barnet the framework is needed to guide development The delivery of the Core in the centre. Given the extensive work Asda have now put into bringing this site Strategy is not dependent on forward we would welcome early engagement on plans for the site and how the Gas the Gas Works site therefore Work site might contribute to these. it is not appropriate. to reference it directly. The gas works site will form part of our Site Allocations DPD therefore it is not appropriate for the CS to promote it. The proposed allocation will reflect the adopted Town Centre Framework for New Barnet. 3 1 Asda Stores Ltd CS6 As a highly accessible centre in need of revitalisation we strongly support aspirations to We refer to our previous None 7 3 Promoting realise development opportunities in New Barnet. It is important that development and response at 379/12 9 Barnet’s town investment in the centre are encouraged thus the town centre frameworks should seek The Core Strategy does centres to embrace development proposals that will revitalise and regenerate New Barnet. provide a strong and realistic (formerly Notwithstanding this, it is important that policy seeks to promote development that message on the role and CS4) compliments existing centres. Development should seek to support and underpin function of town centres existing high streets. Development that has an unacceptable impact on the character of existing centres, visually and economically, should be resisted. It is important that centres within Barnet continue to provide a mixture of national retailers and strong independent provision.
4 4 Matthew Thomas Bride Hall CS6 Bride Hall supports the identification of Edgware as a centre with growth potential and We welcome this support. None 0 Holdings Ltd Promoting looks forward to working with the London Borough of Barnet and its partners on the Consultation on the draft 4 Barnet’s town Town Centre Framework. Town Centre Framework is centres expected by Autumn 2010. (formerly CS4) 4 6 Julia Hines Age Concern CS6 We see access to local shops selling fresh food as an integral part of developing We recognise the None 1 Promoting healthier, integrated communities. importance of such shops to 8 Barnet’s town healthy living and reducing centres the need to travel and (formerly therefore seek to protect and CS4) enhance local neighbourhood centres and parades of shops.
227 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Rose Freeman The Theatres CS6 This policy does not recognize the Borough’s existing cultural facilities for their Theatres are considered a Add section 2 Trust Promoting protection and enhancement nor does it highlight any deficiency that may require future town centre use by PPS4 4.12 on 0 Barnet’s town development. This may have been brought to light in the individual Town Centre which has replaced PPS6. Barnet and centres Frameworks as mentioned in the second sentence of the policy but unless their As noted policy EC4.2 in the arts, (formerly ‘development opportunities’ are reflected in the Core Strategy this policy will not provide PPS4 encourages local culture and CS4) robust guidelines for future development proposals. PPS6 (2005 ¶2.22) states that planning authorities to creative ‘Local planning authorities should encourage diversification of uses in the town centre "encourage a diverse range industry. as a whole, and ensure that tourism, leisure and cultural activities, which appeal to a of complementary evening wide range of age and social groups, are dispersed throughout the centre.’ and night-time uses which Regarding the evening economy PPS6 also states (2005 ¶2.23) ‘ensuring that appeal to a wide range of provision is made where appropriate for a range of leisure, cultural and tourism age and social groups, activities such as cinemas, theatres, restaurants, public houses, bars, nightclubs and making provision, where cafes.’ appropriate, for leisure, A key Government objective for economic development is to promote the vitality and cultural and tourism activities viability of town centres which includes retail, leisure, offices, arts, tourism and cultural such as cinemas, theatres, activities. restaurants, public houses, bars, nightclubs and cafes". Part b of that policy states that we should take account of their potential impact and cumulative impact. Core Strategy reflects that in CS6. 4 2 Rose Freeman The Theatres CS6 Paragraph 10.9.1 states that ‘there is scope for centres to improve their evening We do recognise the Add section 2 Trust Promoting economy’ but we cannot find any guidance on this matter in any policies in the contribution of arts and 15.5 on Arts 0 Barnet’s town document. culture to the distinctiveness and Culture centres There is also no Glossary to provide a description of the term ‘community facilities’. It of Barnet and the value of in supporting (formerly may be that the protection and enhancement of your theatres and performance spaces such facilities as community text to CS10 CS4) are incorporated in this term but this isn’t clear. May we suggest that within the assets. accompanying text of matters regarding community facilities that a definition is added We consider that there is a along the lines of community facilities provide for the health, welfare, social, good description of the educational, spiritual, recreational, leisure and cultural needs of the community. In this range of important way, arts activities and theatre will be incorporated in any policy that mentions the community facilities within enhancement and development of community facilities. the Core Strategy
228 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Tesco Stores CS6 Retail need and capacity – convenience goods We consider that CS6 Revise CS 4 2 Ltd Promoting Paragraph 10.3.1 states that “limited increases in convenience goods capacity are promotes competitive town 7 Barnet’s town forecast (up to 5,028 m2 by 2021) and this can be addressed by stores in the centre environment and centres development pipeline. On the basis of the Assessment analysis there is little provides consumer choice. It (formerly quantitative need to plan further significant convenience goods provision in the lifetime does not restrain proposals CS4) of the Core Strategy”. We appreciate that this is a necessarily broad assessment for for local convenience the borough as a whole. It should be recognised however that more sensitive locally shopping where there is based assessments may well demonstrate a local quantitative need. evidence of need. Moreover, the global borough-wide figures should not in any way act a restraint to proposals within centres that accord with the town centre first approach enshrined in both national policy and the London Plan. PPS4 (Policy EC4) places a clear requirement on local planning authorities to promote competitive town centres and provide consumer choice. To ensure the policy fully accords with national planning policy and the London Plan
4 3 Tesco Stores CS6 Clarification should be provided in respect to the development opportunities identified at Agree to replace Revise CS 6 2 Ltd Promoting paragraph 10.6.5 in respect to District Centre sites. Such opportunities should ‘attractiveness’ with ‘vitality 7 Barnet’s town “enhance the vitality and viability” of the respective centre rather than “attractiveness”. and viability’ centres To ensure the policy fully accords with national planning policy and the London Plan. (formerly CS4) 4 4 Tesco Stores CS6 The policy states the Council will realise development opportunities in the Centres of All centres are promoted in Revise CS 6 2 Ltd Promoting Edgware, North Finchley, Finchley Church End, Chipping Barnet, New Barnet and the policy and a clear and para 7 Barnet’s town Whetstone. Development opportunities are identified in District Centres (Paragraph hierarchy is set out in the 11.7.5 centres 10.6.5) and these should therefore be referred to in the policy as well as these centres text. (formerly play an important role in the retail network and these opportunities accord with the town Reference to known CS4) centre first approach. Such proposals accord with national and regional planning development opportunities in policy, as does the Alternative Option of allowing substantial mixed-use development in other town centres has been all town centres that has not been chosen. To accord with PPS4 it would be helpful to added. distinguish between Town Centres, District Centres and Local Centres – at present the policy refers to just ‘town centres’ but includes both Town and District centres. To ensure the policy fully accords with national planning policy and the London Plan.
4 3 Gaby Kagan Labour Group CS6 Our town centres are important for the communities in and around them, providing a Policy CS 6 promotes the Revise CS6 2 Promoting distinct sense of identity and belonging. Policy CS4 does acknowledge that Brent Cross vitality and viability of all and 9 Barnet’s town may be an important regional shopping centre and will be even more so when the town centres in Barnet. The supporting centres Cricklewood/Brent Cross regeneration is complete. However we have to look after all Core Strategy does provide text (formerly our town centres and, in the interests of sustainability, we must try to make sure a strong and realistic CS4) residents can access the shopping and services they need in their local town centre message on the role and and do not have to travel to Brent Cross or further afield. A failure to sustain our local function of town centres. We Town Centres results in more car trips, more congestion, more pollution and has a agree that there is a need for detrimental impact on our health and the environment. Our Town Centres are not flexibility in letting our town museums and therefore we should not be too prescriptive in our planning policies for centres identify an them, while at the same time ensuring a sensibly strategic approach to ongoing appropriate new role other development of our town centres. than just retail.
229 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Starfield CS6 Paragraph 10.6.2 advises that "…new Barnet offers an opportunity for additional Our evidence base - the None 3 Properties / St Promoting convenience goods floorspace with a mixed use development on the former gas works Town Centre Floorspace 1 James Barnet’s town site. Whetstone offers opportunities for other town centre uses and mixed use Needs Assessment and Investments centres residential development…" Update does not identify a (formerly We object to the inference that "other town centre uses" excludes convenience goods quantitative and qualitative CS4) floorspace which could be provided in Whetstone. We consider the paragraph to be retail need for additional amended to say "…New Barnet offers an opportunity for additional convenience goods retail provision in Whetstone floorspace with a mixed use development on the former gas woks site. Whetstone district centre. offers opportunities for town centre uses, including convenience goods floorspace and The Site Allocations DPD is mixed use residential development…" the appropriate document for Reason: There is a quantitative and qualitative retail need for additional retail provision site specific considerations in Whetstone district centre. There is a qualitative need for main food shopping in in Whetstone. Whetstone to be strengthened, particularly if improvements are made at other centres which influence the centre's market penetration with its catchment area. An analysis of the borough-wide Floorspace Needs Assessment (FNA) highlights that there is substantial retail capacity available in Zones 2, 3 and 4 to support such additional convenience floorspace.
4 2 Starfield CS6 We object to paragraph 10.3.1 on retail need, because the borough-wide position on We consider that CS4 None 3 Properties / St Promoting quantitative need hides the fact that the FNA does identify capacity in some parts promotes competitive town 1 James Barnet’s town (zones 2, 3 and 4) of the borough. The reason for this is set out above (see para. centre environment and Investments centres 10.6.2 reason). The following wording should be added to the end of paragraph 10.3.1 provides consumer choice. It (formerly "…save for where detailed local level analysis of parts of the borough so identifies". does not restrain proposals CS4) for local convenience shopping where there is evidence of need. 4 5 Starfield CS6 We support the realising of development opportunities in the six largest town centres, We consider that Whetstone None 3 Properties / St Promoting particularly Whetstone. no longer merits specific 1 James Barnet’s town identification as a priority Investments centres centre. The appropriate way (formerly forward will be to adopt a CS4) planned approach, probably through a Planning Brief, to any future development opportunities in Whetstone and use the Development Management Policies DPD to consider such proposals 4 6 Starfield CS6 We consider the maximising of the six priority town centres; support a sustainable We have reduced the None 3 Properties / St Promoting pattern of growth whilst protecting the qualities that make Barnet an attractive place to number of priority town 1 James Barnet’s town live, work and trade. centres from six to four but Investments centres they still serve the same (formerly purpose. Our response on CS4) Whetstone is set out at 431/5 and on New Barnet at 471/24
230 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Georgia Wrighton Women's CS6 Outlines the key development areas within Barnet which are identified in the London Development of Brent Cross None 3 3 Design Group Promoting Plan. There is concern within the BWDG regarding the concentration and scale of Cricklewood has been 3 Barnet’s town development and the impact on the sustainability of communities earmarked for growth subject to substantial centres e.g. Cricklewood. BWDG are also concerned about the impact of the development of community involvement. (formerly large supermarkets and their effect on the viability and sustainability of smaller New Barnet has been CS4) shopping centres e.g. New Barnet. Why has New Barnet been designated as a District identified as a district centre Centre? There is concern that this would provide the ‘green light’ for harmful new retail in the London Plan and its development. place within Barnet's network of town centres is clear. 4 5 Robert Newton CS6 Reason: The existing wording of Policy CS4 does not reflect Paragraph 2.3.1 and it The Development None 3 Promoting should. Management DPD will 6 Barnet’s town Under Policy CS4, provide further detail on centres At the end of the first bullet point after the words “office floorspace” add the words policy for Barnet's town (formerly “provided that the development does not detrimentally impact on the surrounding centres and the Site CS4) existing town centre locations” Allocations DPD will bring At the end of the second bullet point after the words “in which it is located” add the forward town centre sites. words “and is located within the existing town centre envelopes that will not be extended to include adjoining suburban houses.” See response to 436/2 on Insert a new third bullet point that reads: “We will ensure that the density of town centre boundaries. development in town centres complies with and does not exceed that proposed in new density matrix detailed in Policy 3.4, Table 3.2 and Paragraphs 3.22 to 3.25 of the See response to 436/4 on London Plan Consultation Draft Replacement Plan (October 2009) and reflects local density matrix. context, public transport accessibility and availability of social and other infrastructure.” Amend the wording of Paragraphs 10.1.1 to 10.10.2 where necessary to reflect these changes to Policy CS4.
4 4 P E Pickering CS6 First bullet point. The Council should rethink its policy on Brent Cross/Cricklewood All these issues have been None 3 Promoting which in its present form will damage established town centres in Barnet and addressed at considerable 7 Barnet’s town neighbouring boroughs, and will generate an unsustainable growth in traffic. length in the consideration of centres the Brent Cross Cricklewood (formerly outline application. CS4) 4 6 Brent Cross CS6 Paragraph 10.3.1 deals with retail need and capacity for convenience goods and states Agree Revise 4 Cricklewood Promoting that there is limited capacity for additional floorspace beyond that in development supporting 0 Development Barnet’s town pipeline. Having reviewed the Town Centre Needs Assessment, which forms the text to CS6 Partners centres evidence base for retail aspects of the LDF, it is clear that the assessment has included (formerly the convenience floorspace component of the BXC development. As such minor CS4) alterations are suggested to the text of paragraph 10.3.1 to specifically acknowledge BXC as an existing commitment. The Town Centres Floorspace Assessment……….. Limited increases in convenience goods capacity are forecast (up to 5,028 m2 by 2021) and this can be addressed by stores in the development pipeline including Brent Cross Cricklewood.
231 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 Brent Cross CS6 Section 10.5 describes the retail elements of the BXC scheme. Minor updates are Progress on proposals for Revise 4 Cricklewood Promoting recommended to ensure consistency with the application and Development Brent Cross - Cricklewood is information 0 Development Barnet’s town Framework. Furthermore, the Development Partners would also seek confirmation of set out in the information box box Partners centres what the ‘150,000sq.m’ retail figure in paragraph 10.5.1 relates to. in Section 7. There is no (formerly Brent Cross - Cricklewood need to duplicate these CS4) Brent Cross is London’s only regional shopping centre and Barnet’s largest shopping proposals in the section on location, but it is not yet designated as a town centre in the London Plan. Plans are Vibrant Town Centres. Resolution to grant planning permission is now in place,including specific development proposals to regenerate Brent Cross - Cricklewood. The application proposals comprise a net addition of 55,000 m2 gross comparison retail floorspace as part of town centre north which is equivalent to the quantum established by the adopted UDP. Comparison floorspace to the North will feature up to 61,545 m2 of new floorspace with 6,545 m2 of existing floorspace within Brent Cross Shopping Centre to be decommissioned. In addition, complementary retail services and facilities, including Class A1 convenience floorspace will also be provided north of the A406. The town centre south of the North Circular Road provides a range of services and facilities to serve the day to day needs of the new resident and working population including a food store.
4 8 Brent Cross CS6 Policy CS4 deals with retailing and Barnet’s town centres and it is suggested that the We have revised the policy Revise CS 6 4 Cricklewood Promoting policy be updated to reflect the details of the application. to reflect the proposals 0 Development Barnet’s town We will realise development opportunities for the town centres of Edgware, North supported by the Partners centres Finchley, Finchley Church End, Chipping Barnet, New Barnet and Whetstone. We will Development Framework. (formerly pursue the individual planning objectives for each centre as set out in their Town CS4) Centre Frameworks through the delivery of environmental, design, transport and community safety measures: o we will promote Brent Cross / Cricklewood as a new metropolitan town centre and an Outer London Development Centre following successful mixed use regeneration which delivers new retail floorspace services and facilities, including a net additional 55,000m2 (net) of comparison floorspace within town centre north and in the region of 370,000 m2 of office floorspace;
4 5 British Library CS6 The BL supports the promotion of successful and vibrant centres throughout Barnet to National planning policy None 4 Promoting serve the needs of residents, workers and visitors and ensure that new development is statement 4 on Planning for 2 Barnet’s town of an appropriate scale and character for the centre in which it is located. The BL Sustainable Economic centres welcomes the protection and enhancement of more ‘local’ neighbourhood centres, and Growth sets the policy (formerly parades of shops, in terms of their potential contribution to sustainable suburbs and framework for considering CS4) shopping. In this context, the BL considers that major new developments, such as the the sequential and impact designated growth areas, should be developed to provide shops and services for these tests of out of centre new developments. The BL notes that within the CAAP a new neighbourhood centre is development. proposed, and a new convenience food store of up to 2500 sqm (as part of 5000 sqm of retail floor space) is proposed.
232 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Metropolitan CS6 Policy CS4 deals with uses in Barnet's town centres. The MPA foresee the introduction We do not require specific None 4 Police Authority Promoting of place shops in town centres as an integral part of their future estate. They will reference to police shops. 3 Barnet’s town increase opportunity for the community to interact with plice officers and will increase Such facilities fit in within the centres accessibility for neighbourhood policing. Preferably these plicie ships will be located in categories outlined in the (formerly town and retail centres where footfall is high and they are therefore easily accessible to policy. CS4) the public. A police shop use will add to the vitality of town centres by providing an increased perception of safety and security. Mindful of the above, it is considered that a planning policy basis to support community facilities such as police shops in town centres in LB Barnet would not prejudice the supply of retail floorspace in town centres or the nature of these town centres in the borough. Further, such a planning policy basis complies with London Plan Policy 3A.18 which states policies in DPDs should assess the need for social infrastructure and community facilities, such as policing, in their area. It further states that policies should seek to ensure that appropriate facilities are provided within easy reach by walking and public transport for the population that use them. The following alterations to Policy CS4 is requested - We will ensure the efficient use of land and buildings in town centres, encouraging a mix of compatible uses including retail, managed affordable and flexible workspace, community facilities such as policing, leisure and residential that add to the vibrancy of the area whilst respecting character
4 1 Cedric Issac CS6 Barnet’s distinctive town centre Edgware town centre needs a radical re-think. A traffic- Please note that public None 4 Promoting free zone from the Edgware bury lane/ hale lane/station road roundabout to the box consultation on the Town 4 Barnet’s town junction entrance to the Broadwalk centre is an ideal entry and exit for buses and other Centre Framework for centres vehicles. Barnet council should consider pedestrianisation of Edgware and other town Edgware will provide the (formerly centres. Many local authorities have opted for traffic-free zones very successfully. I opportunity to discuss such CS4) honestly believe that Barnet council partners are having more influence over its proposals policies than their residents. 4 1 Graham Saunders English Heritage CS6 Generally support the intention of the policy to promote Barnet’s town centres, and in We do recognise the Revise 4 3 Promoting particular the commitment to ensure new development is of appropriate scale and heritage value of our town supporting 6 Barnet’s town character for the centre in which it is located. However we are concerned that neither centres and the contribution text to CS6 centres Policy CS4 nor the supporting text recognises or values the heritage significance of it makes to them as (formerly buildings, spaces and townscape features that define many of these centres. In distinctive places CS4) particular we are concerned that the local character and context of these centres of which the historic environment is a key component, is not promoted as an asset to be understood and used when developing a framework for future change. The current wording of the policy and supporting text provides not guidance or commitment to protecting or enhancing the unique characteristics of these centres, especially their heritage assets. Advise that Policy CS4 and its supporting text is revised by explicitly making a link to the value of the historic environment in defining the local character and context of Barnet’s centres, and in framing proposals for change. The Characterisation Study should help provide evidence on this suggested policy approach. 4 1 Legal and CS6 Delete the words "in order for them to compete with other centres and particularly out- PPS4 clearly states that we None 4 General Promoting of-centre retail parks and shops" from bullet point 5 under policy CS4 on grounds that should proactively plan to 9 Barnet’s town there is no justification or evidence for this and this part of the policy is unsound. promote competitive town centres centre environments and (formerly provide consumer choice. CS4)
233 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Legal and CS6 There is no recognition in the Core Strategy of the role and function of the retail parks PPS4 sets out a clear policy None 4 General Promoting in providing for larger retail store formats selling 'bulky' type goods ranges. There is framework for the 9 Barnet’s town also no policy against which proposals for out of centre development will be assessed. assessment of out of centre centres These are considered key omissions. Paragraph 13.17 of the borough's Town Centres proposals. Through our (formerly Floorspace Assessment (April 2009) states that "Retail warehousing provision in LB Development Management CS4) Barnet also contributes to the comparison shopping offer. The retail parks provide for Policies DPD we will much of shopper's bulky goods needs." the assessment also indicates (at table 10.3) consider setting floorspace that the combined turn-over of non-food out of centre retail provision in the borough is thresholds for requiring in excess of £138m. The retail parks are therefore an important element of the impact assessments of edge borough's retail provision. of centre and out of centre Paragraph 10.11.1 of the Core Strategy indicates that the option of "allowing further development. PPS4 shopping and commercial town centre related development to meet projected demand identifies retail parks as out in existing out of centre retail parks in Barnet" was shown by the Core Strategy of town in the sequential Sustainability Appraisal “to have negative economic, environmental and social impacts. approach. This will form the Retail parks are a focus for car-borne shopping and their promotion as a place for basis for any development growth would impact on congestion. It would also divert investment away from town decisions. centres". No evidence is provided of investment being diverted away from the centres. We consider that a low The Core Strategy is not founded on a credible evidence base and unsound in rejecting density single use format this option. Much of this reasoning in the Sustainability Appraisal which has led to this does not provide consumer option being rejected is predicated on the basis that allowing further retail development choice nor promote changes at the retail parks will reduce the amount of inward investment to the borough, divert to the town centres. investment away from the centres and undermine development opportunities in the However it is open to town centres. developers to respond to Despite "development opportunities" having been identified in the centres in the Town PPS4 and provide more Centres Needs Assessment (and referred to in the Core Strategy) the Needs innovative formats. Assessment document recognises that none of these have come forward (paragraph Policy has been revised 11.26). within the context of PPS 4 The Sustainability Appraisal and its conclusions on this point are poorly founded and and sets our priorities for show a fundamental misunderstanding of the role of retail parks generally in promoting Barnet’s town accommodating large format retail units that cannot be located within physically centres. Retail parks are not constrained town centres. Furthermore, if retail warehouses were forced to be located our priority and applications in centres they would comprise large low-density single uses on sites that would be for such uses will be more efficiently and effectively used for far more socially, economically and considered within the context environmentally beneficial mixed-use regeneration schemes, including new homes. of the Core Strategy, PPS4 This would run contrary to the principles of PPS1 and the London Plan. and the London Plan. Provision of additional retail warehouse floorspace at the existing established retail The Core Strategy is parks is not investment that would otherwise be made in the town centres. The founded on a robust economics of developing retail warehouse units and the rental levels achievable are evidence base and is entirely different to town centre schemes. Allowing appropriately controlled floorspace consistent with national additions to the retail parks would not automatically lead to a diversion of investment planning policy as set out in away from the centres. Furthermore, the retail parks enable substantial levels of PPS4. We consider it expenditure on bulky-type goods such as DIY, decorating goods, furniture and carpets therefore meets the test of to be accommodated within the borough, rather than outside its boundaries. Growth in soundness. non-food spending (incorporating these ranges of goods) in the borough is forecast to be significant. It is more sustainable for this expenditure to be retained within the borough boundaries at established retail locations where there is good opportunity for linked trips that allowing it to go outside the boundaries. The principle of sustainability benefits arising from keeping spending within the borough is accepted by the Sustainability Appraisal (section 11.3.1) New text should be added to the Core Strategy to reflect the role and function of the retail parks in the borough to providing for largely bulky-type retailing (as recognised by the Town Centres Floorspace needs Assessment) that cannot be easily be accommodated within the centres and could undermine regeneration initiatives and 234 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations delivery of identified development opportunities there. In light of this, a positive (or at least neutral) policy approach should be stated under Policy CS5 that sets out the criteria to be addressed in the consideration of proposals for additional floorspace at the borough's retail parks. These should reflect PPS6 (or the new PPS4 when published). Neither of these documents set an embargo against out of centre development in the way that the Core Strategy seeks to. In view of the linked trip opportunities and other sustainability benefits (such as scope to increase floorspace within existing buildings), preference should be given to steering new out of centre development to existing out of centre retail locations (rather than entirely new out of centre locations)
235 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Legal and CS6 Excessive weight and reliance is given to the take up of forecast growth in retail We refer to our previous New policy 4 General Promoting expenditure in the borough to 2016 by the Brent Cross Cricklewood regeneration response at 449/2 on retail CS2 on Brent 9 Barnet’s town scheme. Although it is noted Barnet Council resolved to grant permission for the parks. Cross centres proposal on 19th November 2009 and it has development plan support it must still be A policy framework for Brent Cricklewood (formerly considered by the Mayor and Secretary of State. The grant of permission and subject to Cross Cricklewood as set CS4) this, the timescales for delivery of meaningful provision of new comparison goods out in the 2005 SPG now floorspace remain uncertain. The London Borough of Barnet Town Centres Needs forms part of the Core Assessment (April 2009) identifies 11,356 sqm of comparison goods expenditure Strategy and sets indicators capacity at 2011. This is a very significant amount of floorspace. Paragraph 11.26 of for delivery of key the Assessment identifies no substantive retail-led schemes coming forward in the town infrastructure. Retail is the centres. A significant amount of this expenditure capacity exists now, but there is no catalyst for this indication of how or where it can be accommodated if the Brent Cross Cricklewood infrastructure. Failure to scheme is not approved or implemented. This spending would therefore take place meet these indicators will outside the borough which would necessitate trips largely by car. This is unsustainable trigger a review of the Core and highly undesirable. The Core Strategy is not robust and is unsound in this respect. Strategy Changes need to be made to the strategy to make it more robust in terms of accommodating the forecast growth in comparison goods retail expenditure. One opportunity for this is to identify an element of growth in floorspace at the existing retail parks. The reasons why this is appropriate and would not automatically undermine investment in the centres are outlined in the other representations made by Legal & General.
4 2 HI (Brent Cross) CS6 It is noted that Policy CS4 - promoting Barnet’s town centres - covers albeit loosely, Hotels are identified as a use None 5 Ltd Promoting hotel and tourism uses. HI (Brent Cross) Ltd acknowledge that the council seek to appropriate for town centres 1 Barnet’s town encourage new facilities within town centres, albeit, there is no policy reference seeking in PPS4. The London Plan centres to retain existing sites, such as the Holiday Inn, despite the supporting text stating that also identifies town centres (formerly 'the market largely determines the need for additional facilities such as cinemas, bingo, and opportunity areas as CS4) bowling, health and fitness and hotels'. appropriate. In line with PPS12 it is not considered necessary to repeat.
236 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Mike Dawson Finchley Society CS6 There is a confused policy on the growth of Shopping/Town Centres. Plans for a huge Brent Cross is London's only None 5 Promoting expansion of Brent Cross are in direct conflict with the statement that Town Centres are regional shopping centre and 5 Barnet’s town the most sustainable places for growth. Expansion of Brent Cross will have a significant an area of strategic centres negative impact on major Town Centres in Barnet and create a large increase in traffic importance. Its regeneration (formerly from within and outside the borough. Radial public transport is poor so it is inevitable is highlighted in the London CS4) that the majority of increased traffic will be by car. Plan and it is not a retail Reasoning for rejecting one ‘option’ (Allow further shopping and commercial town park. These issues were centre related development to meet projected demand in existing out of centre retail considered as part of the parks in Barnet) to meet future retail demand suggested at the ‘Issues & Options’ stage Brent Cross application. The conflicts with allowing the major development of the out of town centre Brent Cross: changing role and function of “The Core Strategy Sustainability Appraisal highlighted that this option would have town centres reflects negative economic, environmental and social impacts. Retail parks are a focus for car- national trends. borne shopping and their promotion as a place for growth would impact on congestion. The Core Strategy seeks I t would also divert investment away from town centres.” vibrancy and vitality in the In DoT, item, 10.5.1: Brent Cross is referred to as London’s only regional shopping town centres and provides centre and Barnet’s largest shopping location, but it is not yet designated as a town them with the support to centre in the London Plan. While Barnet’s own reasoning rejects enlarging retail parks manage change and define due to car-borne shopping and the diversion of investment away from town centres, it roles that reflect their sets policy to create the biggest shopping centre in London at Brent Cross. This major strengths. contradiction in policy must weaken the evidence and sustainability of DoT.
4 2 Mike Dawson Finchley Society CS6 This principal, managed with care, is welcomed. Extending this policy on the edge of The policy makes no None 5 2 Promoting town centre locations for mixed retail/flatted development is not welcome, as viability of reference to promoting edge 5 Barnet’s town retail space in the town centre would be threatened. Unless it can be shown that of centre locations. PPS4 centres additional retail space is needed, mixed development on the edge of town centres sets out a clear sequential (formerly should be limited to other uses, such as leisure/office/council services. approach to town centre CS4) development. Policy CS1 has been revised to make it much clearer how it sets the spatial agenda and how the main place shaping policies sit within the Three Strands Approach. Through the Development Management policies we will establish town centre boundaries for major and district town centres. PPS4 makes clear that residential is not a main town centre use. The main town centre uses include retail, offices, cinemas, restaurants, museums and hotels. 237 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Mike Dawson Finchley Society CS6 If the additional 81,024 m2 of comparison goods capacity forecast by 2021 is largely The Town Centre None 5 6 Promoting absorbed by the development of a new town centre at Brent Cross Cricklewood, it will Floorspace Needs 5 Barnet’s town adversely affect the town centres of Edgware, North Finchley and Chipping Barnet. Assessment and Update centres does not identify negative (formerly Instead of proposing comparison goods capacity over and above that planned for Brent impact from the BXC CS4) Cross Cricklewood being absorbed by development opportunities in Edgware, North scheme on the existing town Finchley and Chipping Barnet, it would be more sustainable to limit expansion of Brent centres. Cross Cricklewood and cater for additional capacity at Edgware, North Finchley and Chipping Barnet. We refer to our earlier One of the ‘Alternative options’ not selected is: response at 455/2 “Allow further shopping and commercial town centre related development to meet projected demand in existing out of centre retail parks in Barnet” This option was rejected because: “The Core Strategy Sustainability Appraisal highlighted that this option would have negative economic, environmental and social impacts. Retail parks are a focus for car-borne shopping and their promotion as a place for growth would impact on congestion. It would also divert investment away from town centres.” Brent Cross shopping centre also causes all the negative impacts cited above as the reason for not choosing meeting future retail demand in existing out of centre retail parks. For these reasons, to create vibrant town centres, most future retail demand must be met by Barnet’s major town centres, not Brent Cross.
4 2 Mike Dawson Finchley Society CS6 We agree with most of the policies mentioned in Policy CS 4. Bullet point one should be The Core Strategy is None 5 7 Promoting amended to read: founded on a robust and 5 Barnet’s town • we will promote Brent Cross / Cricklewood as a new metropolitan town centre and an credible evidence base. Our centres Outer London Development Centre following successful mixed use regeneration which approach to promoting town (formerly delivers an additional 35,000m2 (net) of comparison floorspace and 370,000 m2 of centres includes CS4) office floorspace; encouraging larger retail units and a parking regime To these policies we consider that major town centres should include: which encourages turnover. i. larger comparison shops of the type found at Brent Cross shopping centre We also encourage in Policy ii. free short-stay car parking of one hour CS10 the provision of new iii. have a ‘local’ neighbourhood centre community facilities in the iv. have a GP primary care centre town centres, our most accessible locations.
The figure of 35,000m2 is unsubstantiated.
4 2 Fiona Henderson CS6 Specifically, I consider it absolutely necessary that any future planning guidelines The Town Centre None 5 Promoting should impose limits on the amount of retail that would be acceptable in New Barnet, Floorspace Needs 8 Barnet’s town rather than leaving developers with the ‘carte blanche’ of a mixed-use specification. Assessment and Update centres And, in relation to this, I question the methodology of the current retail/floor space assesses future needs for (formerly analysis; I understand that, should we choose to shop in either the Waitrose in High the whole borough at an CS4) Barnet, ASDA's in Southgate, or Tesco's in Potters Bar (or Colney Hatch), we are appropriate level of detail to considered to be shopping outside our area. Indeed, this even applies to the East inform the Core Strategy, Barnet Road Tesco Express! And what does this document therefore conclude? That, following a sound as we are shopping outside our area, we need these (or other retail stores) here in New methodology. Barnet!
238 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations This seems absurd; the majority of supermarket trips are by car and it would not seem A Town Centre Framework unreasonable to travel up to 15 minutes to get to a supermarket, if for reasons of for New Barnet is emerging personal preference, you choose not to shop at the one which is less than 5 minutes which will guide future drive. If we need choice, it, is in the diversity of shops and, more importantly, the range development opportunities of cultural and leisure activities available to residents. Indeed The LDF consultation within and on the edge of the paper clearly states (p8. 3.1.12) that ‘the amount of retail floorspace in Barnet is one of town centre the greatest in London, exceeded only by Westminster and Kensington and Chelsea.’ Any development should respond to a real, not an imagined need. 4 1 Chris Nightingale Friends of CS6 “The former market site in Chipping Barnet provides an opportunity to increase The Core Strategy None 6 Barnet Market Promoting comparison goods provision in that centre.” As a matter of fact, it is not the former recognises the role of 3 Barnet’s town market site. The owners of Barnet Market Ltd (the company that runs the Market) also markets to our town centres. centres own the St Albans Road site. Since the ‘Direction of Travel’ document has been This support would be (formerly published, the owners have moved the market back onto the St Albans Road site from considered as part of any CS4) its temporary site on the Staplton Road car park. The owners have planning decision on the Barnet permission (valid until November 2010) to redevelop the site to provide for the stall Market site market at ground floor level, flats above and an underground car park below. It follows that, if this redevelopment does take place, the market would have to be moved while the construction work is being carried out. We suggest that the statement is reworded as follows: “The market site in Chipping Barnet provides an opportunity for redevelopment leading to the provision of a permanent home for the stall market.”
4 2 Chris Nightingale Friends of CS6 “….. and we will seek to protect existing markets as part of the retail offer of Burnt Oak, The Site Allocations DPD is None 6 Barnet Market Promoting Chipping Barnet and North Finchley town centres and, where appropriate, use S106 the appropriate document for 3 Barnet’s town contributions to ensure the provision of ‘affordable shops’ in new retail development.” site specific considerations. centres We welcome the policy of protecting existing markets and we propose slight rewording We consider that the Core (formerly to emphasise that S106 agreements would be used, where possible, to this end. Strategy highlights the CS4) Thus, we propose “……and we will seek to protect existing markets as part of the importance of markets to the retail offer of Burnt Oak, Chipping Barnet and North Finchley town centres and, where retail sector and seeks to appropriate, use S106 (or its successor) contributions to provide suitable permanent protect them. Therefore sites for these markets and to ensure the provision of ‘affordable shops’ in new retail there is no need to highlight development.” markets as a S106 priority.
4 1 David Howard Federation of CS6 Please protect the Borough’s suburban townscapes, safeguard the variety of local retail Our approach to promoting None 6 0 Residents Promoting and business outlets, limit development to flats above business premises within the town centres includes 4 Associations in Barnet’s town existing town centre envelopes at a height that complements the neighbourhood. To encouraging larger retail Barnet (FORAB) centres encourage local shopping free short stay town centre parking should be provided and units and a parking regime (formerly long stay commuter parking discouraged or sited away from the shopping areas. which encourages turnover. CS4) Getting better public transport and sufficient viable parking is vital to the future of many We also encourage in Policy of the town centres CS10 the provision of new community facilities in the town centres, our most accessible locations. PPS4 makes clear that residential is not a main town centre use.
239 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 David Howard Federation of CS6 Barnet has more town centres than most other London boroughs. It has the second We refer to our previous Revise CS6 6 1 Residents Promoting highest number of shops in London. There are more shops now than demand and response on New Barnet at and 4 Associations in Barnet’s town rationalisation is needed. This must not be imposed from the centre but be addressed 471/24. supporting Barnet (FORAB) centres by local working parties of traders and residents. Local communities must be an The evidence from the Town text (formerly integral part of any rationalisation. The wording for New Barnet for example could be Centre Floorspace Needs CS4) construed as opening the door for a new supermarket which would kill off the rest of Assessment and Update New Barnet, much of East Barnet and have a negative impact on Chipping Barnet. supports a boroughwide Decisions as to whether an existing community is Intensified or enhanced must involve need that should be residents in the community and areas further afield who will be affected. distributed around Barnet and this does not necessarily equate to a large new supermarket. The changing role and function of town centres reflects national trends. The Core Strategy seeks vibrancy and vitality in the town centres and provides them with the support to manage change and define roles that reflect their strengths. Consultation on Town Centre Frameworks or planning briefs for town centre sites will provide opportunities for more local engagement 4 1 David Howard Federation of CS6 We are concerned that there is an emphasis on evening cultures in town centres which We consider that that Core None 6 2 Residents Promoting is likely to mean pubs and binge drinking and anti social behaviour unless much Strategy takes a sensible 4 Associations in Barnet’s town greater emphasis is placed on alternative social and leisure activities especially for approach to food and drink Barnet (FORAB) centres teenagers and the twenties age group plus suitable activities or quality places to eat for and entertainment uses in (formerly the older generations to ensure a balanced mix of users and a safe environment town centres. We will CS4) develop further policy in the DM Policies DPD on the diversification of the night time economy in order to enable activity while ensuring community safety.
240 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 David Howard Federation of CS6 While Brent Cross,/Cricklewood, Colindale, Mill Hill East in particular have been The draft London Plan is None 6 2 Residents Promoting identified as areas for intensification plus the estate regeneration areas of Graham clear on the use of the 4 Associations in Barnet’s town Park, Stonegrove, West Hendon and Dollis Valley we have great concerns at the density matrix and states Barnet (FORAB) centres inappropriate and unsuitable developments that are taking place and that are still being that it is not appropriate to (formerly proposed . The new developments mimic high density high rise inner city apply the table CS4) developments irrespective of where they are in the Borough. The section on Character mechanistically. We have to suggests that developments will have regard to the locality but current experience be realistic and there are shows that one size does fit all and it is large numbers of mediocre to poor quality units. likely to be opportunities for The ability of people to relate to the buildings, the human scale, and character of the higher density development area is what helps to make a community as opposed to a temporary staging post. within the upper range of the While there is a place for modern steel and glass buildings in areas of large scale matrix in Barnet. development such buildings are often out of place in the traditional suburbs. Much of Policy CS 5 emphasises the the opposition is to the appearance of the proposed new buildings and the negative creation of high quality impact they will have on the character of the road. One of the reasons for the failing places and sets out our core 1970s estates was they were alien to the local environment and never accepted. design principles. We are producing Residential Design Guidance SPD to provide design guidelines for places with a consistent and coherent architectural character as well as those locations where further flatted development will not detract from the prevailing character. 4 1 marcus dickinson CS6 Encouraging more pedestrians and cyclists We aim to encourage a None 6 7 Promoting mode shift and make public 5 Barnet’s town transport as well as cycling centres and walking more attractive (formerly travel options. CS4) 4 1 Pauline McKinnell Cricklewood CS6 But should include all town centres. Golders Green and Cricklewood are getting All centres are promoted in None 6 2 Community Promoting rundown. the policy and a clear 7 Forum Barnet’s town All the town centres should be enhanced. All areas should have their distinctive hierarchy is set out in the centres character enhanced e.g. Brent Terrace cottages in NW2. Clitterhouse Farm buildings, text. We are producing (formerly Claremont Rd, NW2 Residential Design Guidance CS4) SPD to provide design guidelines for places with a consistent and coherent architectural character as well as those locations where further flatted development will not detract from the prevailing character. 4 1 Pauline McKinnell Cricklewood CS6 Brent Cross could be developed more on northern and western sides but not as an The designation of Brent None 6 3 Community Promoting outer London development centre. Cross as an outer London 7 Forum Barnet’s town Development Centre is a centres matter for the London Plan. (formerly CS4)
241 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Pauline McKinnell Cricklewood CS6 What planners see as character may not be same as residents who live there. Just The Characterisation Study None 6 4 Community Promoting because people live near the north circular or motorway may not mean they want to be will help inform the 7 Forum Barnet’s town concreted over even more protection of the suburban centres character with further (formerly policies identified in the CS4) Development Management DPD. 4 1 Pauline McKinnell Cricklewood CS6 Would like to see more markets e.g. farmers markets south of the borough Although there is no direct None 6 9 Community Promoting reference to the farmer's 7 Forum Barnet’s town market in the Core Strategy centres the London Plan highlights (formerly their contribution to the CS4) vitality and viability of town centres. 4 8 Government CS6 Policy CS4 (Town Centres) currently suffers from a lack of detail concerning the CS6 has been revised to Revise CS6 7 Office for Promoting quantity, location, timing or means of delivery for retail development. This undermines provide more detail on 0 London Barnet’s town the Core Strategy’s effectiveness as a spatial document. It would be beneficial if quantity, location and timing centres headlines from the Town Centre Needs Assessment evidence could be drawn into this of comparison and (formerly policy both to aid in adding necessary detail to the policy and providing a better link to convenience retail and link CS4) the evidence base. We are pleased to note the town centre hierarchy set out in Table 3. with the Town Centre Needs Assessment and Update 4 9 Government CS6 Policy CS4 (Town Centres) point 7 refers to the use of S106 contributions to ensure the Agree Reference to 7 Office for Promoting provision of ‘affordable shops’ in new retail development. Clarification of what is meant Circular 5/05 0 London Barnet’s town by this policy would be welcomed and sufficiently robust evidence should be referred added to centres to. At the very least, circular 5/05 should be clearly referred to in the policy. supporting (formerly text CS4) 4 1 David Howard New Barnet CS6 NBCA concurs generally with the views set out in the paper by FORAB (attached) in so We refer to our previous Revise CS6 7 Community Promoting far as it relates to New Barnet. We also want to see the Town Centre reclassified to response on New Barnet at and 1 Association Barnet’s town reflect the situation on the ground. It is not a District centre and should be classed as a 471/24. supporting centres local town centre. As evidence I attach a copy of a letter we have sent to the GLA We do not consider that de- text (formerly asking them to redesignate New Barnet. We ask that you also discuss with the GLA the designation is the best way CS4) reclassification of New Barnet to a local town centre. forward for a successful New We wish to register the following comments regarding the LDF Core Strategy Direction Barnet. We will continue to of Travel document and the way in which the proposed policies will have a negative monitor New Barnet’s health impact on the quality of life in New Barnet. as a district town centre.
4 4 David Howard New Barnet CS6 Policy CS4 states that you will realise development opportunities in New Barnet yet it We no longer identify New Revise CS6 7 Community Promoting provides no details of what those development opportunities include. This policy is far Barnet as a priority town and 1 Association Barnet’s town too vague and ambiguous. It should either be made more specific or deleted. centre in CS6 but do supporting centres We therefore wish you to remove the reference to New Barnet in Policy CS4 recognise that there are text on Town (formerly development opportunities. Centre CS4) The Core Strategy does not Frameworks provide a comprehensive list of development opportunities in priority town centres as it is the role of the Town Centre Frameworks to provide that detail.
242 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 David Howard New Barnet CS6 The Mayor has dropped support for four super hubs including Brent Cross and is The Mayor's support for None 7 3 Community Promoting supporting a constellation of local town centres based on small scale improvements. super hubs was in advance 1 Association Barnet’s town This means the excessive proposals for Brent cross should be scaled down and gross of the drafting of the centres overdevelopment of New Barnet town centre be specifically rejected as a policy. Direction of Travel. Brent (formerly Cross is identified in the CS4) replacement London Plan as a Strategic Outer London development centre with a focus on retail. The identification of opportunities in New Barnet is in line with the Mayor's approach for successful town centres. 4 1 David Howard New Barnet CS6 Para 5.1.11, 6.2.1 (pages 136 and 137) New Barnet is having to fight proposals from A Town Centre Framework None 7 9 Community Promoting ASDA and Tesco because there is a gap in planning policy for the past 10 years or is being developed for New 1 Association Barnet’s town more. Even now we are being asked to comment on the LDF when there is no town Barnet which will guide the centres centre strategy for New Barnet. This is cart before the horse syndrome. The proposals future of the town centre. (formerly from both supermarkets are excessive to the point of greed, will overload the The Core Strategy highlights CS4) infrastructure, gridlock the roads, put local traders out of business and severely the role of the Town Centre damage, not improve or enhance New Barnet, East Barnet and Chipping Barnet. Frameworks 4 2 David Howard New Barnet CS6 Page 138 says it will promote Town centres but the council’s present policies and those Our Core Strategy policy None 7 0 Community Promoting advocated in the LDF will destroy New, east and High Barnet aims to promote town 1 Association Barnet’s town centres based on supporting centres their strengths as successful (formerly places. CS4) 4 2 David Howard New Barnet CS6 Para 10.1.1 recognizes that each town centre has its own special character. The These issues are being None 7 5 Community Promoting Tesco proposals for New Barnet would destroy that character and produce nation addressed through the New 1 Association Barnet’s town clonesville. While the ASDA proposals is so alien and of such poor quality as to offend Barnet Town Centre centres any town centre. Framework. The sites and (formerly their preferred uses will form CS4) part of the emerging Site Allocations DPD
243 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 BJ McKenny Whetstone CS6 Naturally, we are particularly interested in the impact on Whetstone, and have The Development Revise CS6 7 Society Promoting examined carefully the comments concerning it as a District Centre. There arises a Management Policies DPD and 3 Barnet’s town contradiction. In 10.2.2 Whetstone is referred to as a clean, safe and pleasant place to will address diversification of supporting centres shop but is then stated to have become more dependant on leisure services and the night time economy in text (formerly evening economy roles - restaurants, cafes, bars and clubs, a situation, if it were true, order to enable a mix of CS4) brought about by unrealistic rent reviews and failure of the planners to uphold the activities for the public realm principles of the old UDP to safeguard the proportion of A1 outlets. Here we would point and to keep town centres out that in the recent application concerning the opening hours of the I-bar on the High safe. The draft London Plan Road, one hundred and eighteen objections were raised and only one in support - has identified Whetstone clearly an indication that local residents wish to retain late night peace and quiet. We town centre as a night time feel that Whetstone should not have been singled out as suitable for late night economy of more than local activities. significance. Perhaps this could be rectified in the final draft of the core-strategy, as any further loss of A1 outlets in favour of restaurants, take-aways, clubs etc would lead to loss of daytime viability and footfall at the expense of local residents, together with increased noise and disturbances to flat dwellers and others on the high Road and adjacent streets (see Policy CS 4). District centres have traditionally provided convenience goods and services for local communities. Developing capacity of district centres for convenience shopping is critical to ensure goods and services at the local level, and with the recession having an impact on restaurants, take-aways etc there are already signs that day-time activity of A1's is at last showing signs of regeneration e.g. Amey's Kitchenware and Household Goods, together with up-market clothing outlets. We now await the outcome of the final stages of the local development framework and trust that local reactions will be fully taken into account.
4 1 Andrew Newby Barnet Green CS6 More should be done to improve the physical attractiveness of these shopping's areas We seek to redefine the None 7 6 Party Promoting and measures taken to make them more comfortable and secure to shop in, e.g. more roles of town centres and our 7 Barnet’s town pedestrian areas, greater separation of cars and pedestrians (e.g. in North Finchley), Core Strategy policy aims to centres design measures to deter anti-social behaviour by gangs or street drinkers. promote town centres based (formerly on supporting their strengths CS4) as successful places. 4 9 Steven Deller CS6 And do nothing for everywhere else. Barnet council has never done anything for Cricklewood is an integral None 7 Promoting Cricklewood and nobody believes you are about to start now. Unless of course it is in part of Barnet and proposals 8 Barnet’s town Cricklewood where you are more than happy to impose inappropriate scale to a for the regeneration of the centres development that will totally dominate existing residents area are well established at (formerly a borough and London level CS4) in the UDP and London Plan. Development of Brent Cross Cricklewood has been subject to substantial community involvement. 4 1 Steven Deller CS6 A pointless exercise. Local shops will continues to close as a direct result of support for Local parades of shops have None 7 5 Promoting preferred town centres as the will not be able to compete. a different role and function 8 Barnet’s town from large town centres. centres Their contribution to (formerly sustainability and community CS4) cohesion is recognised in the Core Strategy.
244 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Sainsbury's CS6 Sainsbury’s supports the continued growth of District Centres, the scale of development It is not our intention to None 7 Supermarkets Promoting should be appropriate to the role and function of that centre. Development within duplicate PPS4 which sets 9 Limited Barnet’s town District Centres should provide access to goods and services at the local level. The out a clear policy framework centres amount of additional retail floorspace should be in accordance with the retail hierarchy. for the assessment of out of (formerly Sainsbury’s supports the reclassification of North Finchley as a Major Town Centre. centre proposals. Through CS4) In accordance with, Planning Policy Statement 4 (PPS4) (December 2009) policy our DM Policies DPD we will should allow under certain circumstances out-of-centre development. Whilst the retail consider setting floorspace needs test is no longer a consideration within PPS4, there may be circumstances thresholds for requiring where out-of-centre development is appropriate subject to: impact; sequential impact assessments of edge approach; and scale. of centre and out of centre development. 4 1 Dorothy Badrick UKOSF CS6 How about a proper plan for Cricklewood? inappropriate overdevelopment which any We refer to our previous None 8 2 Promoting fool can see won’t work. back to cricklewood. why are you trying to foist inappropriate answer at 480/1 0 Barnet’s town overdevelopment on us. if only you would in cricklewood. we get the proposition of centres huge increases in vehicular traffic on already overly congested roads. and how does (formerly this work in relation to the bxrdplan? which will surely kill all shopping areas in a five CS4) mile radius. if only you would protect clitterhouse playing fields.
4 1 David Dobbs CS6 I disagree with the entire proposal for Brent Cross/Cricklewood development. We refer to our previous None 8 3 Promoting answer at 480/1 1 Barnet’s town centres (formerly CS4) 4 1 David Dobbs CS6 Agreed in principle, but inevitably this is highly subjective and the proposal is too Through the Development None 8 4 Promoting 'roomy' to be meaningful. Why not just say town centres will be developed subject to Management policies we will 1 Barnet’s town resource and geographical limits. establish town centre centres boundaries for major and (formerly district town centres. CS4) 4 1 David Dobbs CS6 This wording needs to be strengthened to specifically say what may be considered an PPS4 sets out the main town None 8 6 Promoting inappropriate use or what may be considered subject to full public consultation. centre uses and these are 1 Barnet’s town retail, leisure, entertainment centres facilities, more intensive (formerly sport and recreation uses, CS4) offices and arts, culture and tourism development. 4 1 David Dobbs CS6 I suspect that this will lead to an increasing array of low cost retailers which, whilst We will monitor the impact of None 8 9 Promoting popular, are of limited attractiveness to the majority of residents. any 'affordable shops' that 1 Barnet’s town we deliver. centres (formerly CS4)
245 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Maria Nash Barnet Women's CS6 1) Ensure that the 6 town centres agree to being 'large town centres' 2) Have The town centre frameworks None 8 2 Design Group Promoting meaningful engagement with the local community - the commercial, shop/businesses - are underway and 3 Barnet’s town the users of the centres, women - mothers, single women. Children - teenagers, young incorporate extensive centres adults, vulnerable - elderly and disabled people The framework has to incorporate community engagement in (formerly everyone’s views and needs. Local people want to have their area regenerated for their which people can have their CS4) needs not for the financial rewards for Brent Cross Shopping Centre's private company say on their town centres. Brent Cross has been led by shareholders of a private company to bully and entice The draft London Plan elected members of Barnet to over ride the local residents concerns and issues. The identifies Brent Cross as an Outer London Development Centre should be at Chipping Barnet where there is appropriate location for an enough room to expand and be a link with the counties. Outer London Development All local residents have to be involved in this. Young and old, abled and disabled to be Centre. Part M can only be involved. As long as this is not only lead by a private landlord's greed for personal enforced in new buildings financial reward but a balance that would benefit al mothers with large buggies etc are and when there is an not considered. The best way to support retail use is to make it accessible in everyway extension to a non domestic for the weakest residents or visitor and every other resident and visitor would be able to property such as a shop. use these town centres easily and safely Transport has to be for Barnet resident's needs not what TFL is prepared to offer. It would save the environment if local people had choice in their local neighbourhood but local shops have to be made fully wheelchair accessible through the Building Regulations Department enforcing Part M to all premises. There should be more opportunity for affordable shops or businesses. Social Enterprises should be incorporated and promoted. 4 9 Michael Storey CS6 You'll open the doors to the supermarkets in New Barnet. You claim that there is a Town centres will not survive None 8 Promoting shortage of retail provision in the north and east of the borough, but there simply is no as centres of commercial 7 Barnet’s town evidence for it. Many supermarkets and convenience stores belonging to all the major activity without investment. centres grocery chains are located a short distance from New Barnet, as can be seen on the A Town Centre Framework (formerly linked map (this doesn't include the new Sainsbury's and Tesco's in Chipping Barnet). is being developed for New CS4) http://www.newbarnet.org.uk/issues/howmanysupermarkets.php Barnet which will guide the Listen to local residents. If they don't want it, don't force it on them. future of the town centre. As above, I would agree with the approach. But I think it is hot air and rot. I wouldn't The evidence from the Town trust the current planning department to protect a single stone or brick of Barnet unless Centre Floorspace Needs it was the keystone of an architecturally average private development. You don't Assessment and Update understand the importance of everyday vernacular architecture, such as can be found supports a boroughwide in New Barnet, you just want bland new-build See above. If it means building giant need that should be superstores in the middle of town centres distributed around Barnet The ASDA scheme proposed for New Barnet was described by the chair of CABE as and this does not necessarily "failing on every level: its car focussed and architecturally confused with poor housing equate to a large new tacked on". That scheme was rejected, but given the size of the proposed development supermarket. area, I suspect the revised application won't be too different. So, I'd want to see evidence of you putting these ideas into practise before I believe it.
4 1 Michael Storey CS6 Building huge supermarkets isn't protecting or enhancing New Barnet. Protect our We refer to our previous None 8 5 Promoting neighbourhood centre and shop parades, and give us a framework which will protect us response at 487/9 7 Barnet’s town from gross overdevelopment centres (formerly CS4) 4 1 Michael Storey CS6 You have a wretched record as custodians of Chipping Barnet market. Do better. We consider that the Core None 8 6 Promoting Strategy highlights the 7 Barnet’s town importance of markets to the centres retail sector and seeks to (formerly protect them. CS4) 246 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Glen Rollings Greater London CS6 Although Brent Cross is identified within the draft replacement London Plan as having Table 3 has been updated Revise Table 8 0 Authority Promoting the potential to become a centre of metropolitan significance, there is no similar accordingly. We have 3 8 Barnet’s town mention in the Plan of North Finchley’s potential to become a major centre. removed the reference to centres North Finchley to concur with (formerly the London Plan. CS4) 4 2 Glen Rollings Greater London CS6 The section should refer to the night-time economy role of the centre (noted as being of We have added references Revise 8 1 Authority Promoting “more than local significance” in table A2.1 of the draft replacement London Plan. to Cricklewood and supporting 8 Barnet’s town Whetstone to acknowledge text to CS6 centres their identification in the draft (formerly London Plan. CS4) 4 2 Glen Rollings Greater London CS6 Information on transport capacity and accessibility has been omitted from section 10.5 Section 10.5 is specifically None 8 2 Authority Promoting Brent Cross Cricklewood. TFL would like to see a reference to transport capacity and about shopping and whilst it 8 Barnet’s town accessibility included in this section. is intended that issues of centres transport capacity and (formerly accessibility will be CS4) addressed, it is felt that this is adequately covered in other sections, including the amendments made in light of other TfL comments 4 2 Glen Rollings Greater London CS6 Potential for additional mixed use and employment provision should be encouraged in We consider that Policy CS4 None 8 3 Authority Promoting accordance with the draft replacement London Plan encourages a mix of 8 Barnet’s town compatible uses in town centres centres that add to the (formerly vibrancy of the area. CS4) 4 2 Glen Rollings Greater London CS6 The role of Barnet’s town centres in promoting a healthy night time economy has been We consider that Policy CS4 Revise CS6 8 4 Authority Promoting omitted. covers the main elements of 8 Barnet’s town the night time economy but centres have added a specific (formerly reference to 'a healthy night CS4) time economy'. 5 John Dix CS6 Policy CS4 states that you will realise development opportunities in New Barnet yet it We no longer identify New Revise CS6 Promoting provides no details of what those development opportunities include. This policy is far Barnet as a priority town and Barnet’s town too vague and ambiguous and in so doing presents loophole for potential developers to centre in CS6 but do supporting centres do what they want in the area. This policy should either be made more specific or recognise that there are text on Town (formerly deleted. development opportunities. Centre CS4) I would therefore wish you to remove the reference to New Barnet in Policy CS4. The Core Strategy does not Frameworks provide a comprehensive list of development opportunities in priority town centres as it is the role of the Town Centre Frameworks to provide that detail.
247 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations P New Barnet CS6 Policy CS4 states that you will realise development opportunities in New Barnet yet it We no longer identify New Revise CS6 r Promoting provides no details of what those development opportunities include. This policy is far Barnet as a priority town and of Barnet’s town too vague and ambitious. It should either be made more specific or deleted. centre in CS6 but do supporting o centres Recommendation is that the reference to New Barnet in Policy CS4 should be recognise that there are text on Town r (formerly removed. development opportunities. Centre m CS4) The Core Strategy does not Frameworks a provide a comprehensive list of development opportunities in priority town centres as it is the role of the Town Centre Frameworks to provide that detail. P Save our CS6 Protect the Borough’s suburban townscapes, safeguard the variety of local and retail Our Core Strategy policy None et suburbs Promoting business outlets, limit development to flats above business premises within the existing aims to promote town iti Barnet’s town town centre envelopes and provide free short stay town centre parking centres based on supporting o centres their strengths as successful n (formerly places. CS4) 2 5 Ian Dubber Workspace CS7 Workspace considers that the implementation of biodiversity measures on-site should The Development None 4 Group PLC Enhancing be considered on a site by site basis to take account the site and development Management Policies DPD 1 and characteristics will provide further detail on protecting policy for biodiversity. open space (formerly CS5)
248 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 1 Higgins Homes CS7 Higgins Homes PLC objects to paragraph 11.2.4 because it incorrectly states that: Map 5 (now Map 11) at A4 Introduce 4 PLC Enhancing "Map 5 shows distribution of public open space in the borough". size clearly does not allocate new Map 10 5 and We submit on behalf of Higgins Homes PLC that Map 5 does not correctly identify the new public open space; it on Open protecting distribution of public open space in the borough, and therefore paragraph 11.2.4 is merely illustrates the Space open space erroneous. Map 5 is incorrect as it identifies land to the rear of existing residential distribution of childrens play Deficiency. (formerly properties at Briarfield Avenue as public open space (see attached drawing AMA1). We facilities within Barnet. Revise title CS5) object in the strongest possible terms to the identification by Map 5 of this land in The Site Allocations for Map 11 to green, or annotated in any other way. document is the appropriate Distribution Land to the rear of Briarfield Avenue does not represent public open space. Land to the document to identify any of Play rear of Briarfield Avenue is privately owned, by Higgins Homes PLC, and does not changes to the Proposals Space for provide recognised, well established or unrestricted public access. Land to the rear of Map related to open space. Children. Briarfield Avenue does not appear to be publicly accessible when viewed from Briarfield Avenue, Tangle Tree Close, Rosemary Avenue or Dudley Road. Higgins Homes PLC has not allowed unrestricted public access to land to the rear of Briarfield Avenue. Higgins Homes PLC has placed signs on land at Briarfield Avenue to make clear that the land is privately owned. Considerable attempts have been made by Higgins Homes PLC to secure the site. However, the means of enclosure provided on site have either been damaged repeatedly, or removed by unknown parities. Land to the rear of Briarfield Avenue has historically been used, from time to time, by neighbouring residents. A number of neighbouring residents have accessed the land from the end of their private rear gates. The Proposals Map to the UDP, adopted May 2008, does not identify land to the rear of Briarfield Avenue as public open space. Indeed, the adopted UDP does not identify and site specific policies relating to this land. We submit that nothing has changed since the adoption of the UDP in 2006 that would warrant the specific identification of this land as public open space in the Barnet Core Strategy, or any other Development Plan Document. Our submission that land to the rear of Briarfield Avenue should not be identified by Map 5 as open space is supported by the Barnet Characterisation Study, which forms part of the evidence base to the Core Strategy. The characterisation study identifies land to the rear of Briarfield Avenue as character area D (Suburban Terrace). It is notable that the characterisation study does not identify land to the rear of Briarfield Avenue as 'Green Space' In conclusion we submit that identification by Map 5 of land to the rear of Briarfield Avenue as open space is unjustified and unsound. Map 5 should be amended to exclude identification of land to the rear of Briarfield Avenue as public open space. Land to the rear of Briarfield Avenue should not be identified in any way by Map 5.
249 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 2 Higgins Homes CS7 Higgins Homes PLC objects to the wording of Policy CS5. As drafted, policy CS5 has The protection of open None 4 PLC Enhancing considerable scope for misinterpretation and inappropriate application. The following space does not depend on 5 and text from policy CS5 is likely to lead to major conflicts in interpretation and use in whether it is accessible to protecting decision making: the public. open space 'In order to create a greener Barnet we will enhance and protect Barnet's Open Spaces (formerly by: The Site Allocations CS5) - Protecting designated open spaces, including Green Belt and Metropolitan Open document is the appropriate Land, and other suitable land with the potential to be used as open space.' The wording document to identify any of policy CS5 above is imprecise as it fails to identify which land will be enhanced and changes to the Proposals protected. The 'protected designated open spaces' referenced by policy CS5 are Map related to open space. undefined, and therefore open to wide ranging interpretation. If it is intended that the It still has a contribution to 'protected open spaces' are all the spaces identified by Map 5 and/or Map 6 of the Core make to a greener Barnet. Strategy document then this should be stated specifically. Higgins Homes PLC has submitted representations objecting to Map 5 and paragraph 11.2.4 of the Core Strategy. Specifically, Higgins Homes PLC objects to the identification of land to the rear of Briarfield Avenue, Finchley as open space. The wording of policy CS5 above which refers to 'other suitable land with the potential to be used as open space' is open to wide misinterpretation. It is unclear whether or not policy CS5 is attempting to protect Alternatively, this could mean that private land that has and is inaccessible to the public could be protected by policy CS5 as open space. We submit, in the strongest possible terms, that the wording of policy CS5 is unjustified, inappropriate and unsound. Adoption of policy CS5, as currently drafted, is likely to result in at best substantial confusion for landowners or planning applicants and, at worst, inconsistent and poorly formed planning decisions based on imprecise policy wording. On behalf of Higgins Homes PLC we recommend that the following amendments are made to the Barnet Core Strategy Direction of Travel: 'In order to create a greener Barnet we will enhance and protect Barnet's Open Spaces by: - Protecting [designated] (to be deleted) open spaces [that have unrestricted public access] (in bold), including Green Belt and Metropolitan Open Land [as identified by Map 5 and Map 6 of the Core Strategy] (in bold), [and other suitable land with the potential to be used as open space] (to be deleted).
3 5 A2 Dominion CS7 Preferred Policy CS 5 states that the LPA will look to meet increased demand for open The section on open space None 7 Housing Enhancing space and tackle deficiencies and under provision by securing improvements to open has been amended to 4 and spaces including provision for children’s play, sports facilities and improvements to recognise the multi protecting access arrangements, where opportunities arise, from all developments that create an functionality of open space open space additional demand for open space’. and to recognise that its (formerly When assessing the open space requirements of developments, an assessment of the contribution is dependent on CS5) local context, ignoring administrative boundaries, should be undertaken, and this the local context. should be considered alongside the on-site provision within the development. Open Development will not be space provided within development schemes can often be designed to be multi- required to comply with functional and satisfy the requirements of a variety of users, not just children and young every bullet point in the people. For the above reasons, Preferred Policy CS 5 should be amended to make policy but each scheme will specific allowances for schemes that provide appropriate on-site provision and sit within be judged on its merits in the an area adequately provided for by open space, regardless of whether local context. Further detail on implementation will be contained in the Development Management Policies DPD. 250 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 1 All Souls CS7 Cluttons LLP submitted representations to the Core Strategy Issues and Options stage Appropriate policy will be None 7 College Enhancing on behalf of our clients, All Souls College, Oxford in September 2008. The College contained in the 7 and owns the Edgware Estate located within the Metropolitan Green Belt from the M1 in the Development Management protecting east to land bordering both sides of the A41 in the west. A map highlighting the Policies DPD. Site specific open space ownership of the estate was previously submitted with the September 2008 opportunities can be (formerly representations. We believe that given the growth pressures on the Borough, the identified as part of the Site CS5) Council should include the provision within policy CS5 to permitting sports and leisure Allocation DPD. It is clear use on appropriate parts of the existing open space network, including land in the that we will secure Green Belt and Metropolitan Open Land. Such sites can be appropriately maintained improvements to open space and looked after by responsible land owners in the Borough to help serve both existing borough wide from and projected large future population increases that will occur in the Borough and can developments that create enhance the appearance and ecology in the Green Belt. additional demand. We wish to see Policy CS5 amended by the acknowledgement in the policy wording that allows, in principle, leisure use on open space sites including land in the Metropolitan Green Belt and Metropolitan Open Land, subject to site specific considerations. It is accepted that the third bullet point makes reference to securing improvements to open spaces including provision for children's play, sports facilities and improvements to access arrangements although it is not made clear whether this relates to all forms of existing open space, or only in relation to demand arising from new development in, for example, the identified growth areas. 4 3 Julia Hines Age Concern CS7 However, we do feel that there should be more accessible green spaces within the Our SPD on Sustainable Add new 1 Enhancing development areas than are currently planned. We would also like to emphasise the Design and Construction reference to 8 and importance of green spaces in reducing urban heat islands. In the heat wave of 2003 recognises the contribution urban cooling protecting there were 600 extra deaths, most of which were older people. Designing areas of of green open spaces to in supporting open space green space allows cooling in hot weather. We would refer you to the work on urban cooling. text to CS 7 (formerly London’s Heat Island published by the Greater London Authority. CS5) 4 8 Julia Hines Age Concern CS7 We are concerned that 22 hectares of green space within the development areas is a Delivering new green space None 1 Enhancing relatively small amount given the amount of housing proposed. Access to local green is not just about quantity it 8 and spaces is important for health and recreation. Proximity to people’s homes is an also relates to quality and protecting important factor in encouraging usage. access as well. open space (formerly CS5) 4 1 Julia Hines Age Concern CS7 We support the protection and enhancement of Barnet’s green spaces and recreational We welcome this support None 1 2 Enhancing facilities. 8 and protecting open space (formerly CS5) 4 1 Pam Edwards Barnet Borough CS7 The insertion of the word “and festival” after “sports” in the third point on securing We recognise that parks Revise 2 Arts Council Enhancing improvements. serve as a vital focal point supporting 6 and for informal and informal text to CS7 protecting community activities open space including fairs and festivals. (formerly CS5) 4 4 Gaby Kagan Labour Group CS7 38% of the Borough is in green belt but not all of our green and open spaces are The Development None 2 Enhancing accessible to local residents. The LDF must curb the trend to “privatise” our green and Management DPD will 9 and open spaces so that all residents have access to high quality recreation and open provide policy on the protecting spaces, particularly where building densities are higher. provision of public open open space space and private amenity 251 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations (formerly space. CS5) 4 6 Dennis Pepper Barnet Borough CS7 Section 11: Enhancing and protecting Barnet’s open spaces demonstrates yet again The multi functional role of Revise 3 Group London Enhancing the restricted view of the function of open/green spaces already noted above. It is our open spaces including 12.6.1 0 Wildlife Trust and important that this is corrected in the revised document, and note the following: People the habitat it provides for protecting may well prefer an ‘attractive, clean and green environment’ (11.1.1) but our wildlife wildlife is recognised in the open space requires the conditions in which it can flourish. Core Strategy. We refer to (formerly our earlier response to CS5) 430/2. 4 7 Dennis Pepper Barnet Borough CS7 The ‘network’ of sports and recreational facilities that are apparently ‘vital’ to Barnet’s We do recognise the role of Revise 3 Group London Enhancing success as a place to live (11.1.2) should be located well away from the network of habitat corridors for the 12.6.1 0 Wildlife Trust and SINCs and other sites in which our wildlife can flourish. For example, nature natural migration of species protecting conservation and transmission are essential functions of MOLs and river responding to the changing open space chains/corridors such as Silk Stream and Dollis Brook. Other (human) activities should climate (formerly be directed elsewhere. CS5) 4 8 Dennis Pepper Barnet Borough CS7 It is important that terms such as ‘improvement’ and ‘enhancement’ are carefully We refer to our previous None 3 Group London Enhancing defined in relation to purpose. For example, the ‘enhancement’ of Bittacy Park will response at 430/7. 0 Wildlife Trust and probably threaten the resident wildlife population just as the developments at Mill Hill protecting East have reduced habitats there. It is far from obvious that human enjoyment should open space take precedence. (formerly CS5) 4 9 Dennis Pepper Barnet Borough CS7 We wholeheartedly welcome the support given here to the Mayor of London’s intention We highlight our support for Revise 3 Group London Enhancing to give far greater emphasis to the importance of trees and woodland in his emerging Watling Chase Community supporting 0 Wildlife Trust and London Plan review. We think this further emphasises the importance of Barnet Forest and set out our text and protecting renewing its support for the Watling Chase Community Forest. We think such a policy intention to produce a Green policy CS 7 open space should be about the retention of existing mature trees (even dead ones have an Infrastructure SPD. Our SPD to support (formerly ecological value) as well as new planting. We note also that ornamental trees have on Sustainable Design and the Watling CS5) both a limited environmental value and, near highrise building, a relatively short life. Construction promotes low Chase maintenance indigenous Community landscaping designed with Forest. long term estate management in mind. 4 1 Dennis Pepper Barnet Borough CS7 We note that the second bullet point in Policy CS5 is misleading in that while it The figures are an actual net None 3 0 Group London Enhancing increases the amount of accessible (to people) open space it reduces the overall increase of public open 0 Wildlife Trust and amount of green space in each of these areas. It should be dropped from the policy. space. We consider that the protecting We also think the Policy should incorporate an intention to providing appropriate policy supports biodiversity open space habitats and habitat improvements in areas that are not conservation sites. The policy improvements as a (formerly should also emphasize Barnet’s intention to ensure that wildlife rich sites are linked for consequence of CS5) the benefit of species renewal and development. development
252 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Georgia Wrighton Women's CS7 Informal ‘pocket parks’ and play areas in existing housing areas should be retained, The Development Revise 3 1 Design Group Enhancing alongside larger more formal spaces taken into account as part of the plan assessment. Management Policies DPD supporting 3 and Sufficient new play and open areas should be provided to meet the needs of will set local space text and protecting communities following new development. Allotments are not recognised or encouraged standards for public parks policy CS 7 open space in the relevant policies and should be as they can be an important provision of open and children’s play facilities. to support (formerly space. In light of the increase in housing provision which will be required over the plan We aim to increase the the Mayor’s CS5) period, allotments can provide important space for those living in properties without number of food growing Capital gardens giving opportunities for outdoor leisure and educational pursuits, as well as spaces in Barnet and will Growth providing a cheap, local, sustainable food source. utilise mechanisms such as Initiative capital growth which offer financial and practical support for community farming to identify to identify new opportunities for the development of new spaces. 4 6 Robert Newton CS7 Reason: The existing wording of Policy CS5 does not reflect Paragraph 2.3.1 and it Not necessary to add the Revise LDS 3 Enhancing should. word absolute as designated to set out 6 and Under Policy CS5 open space protected by new SPD on protecting policy. The Site Allocations Green open space Re-write the first Bullet point to read “Giving absolute protection to designated open DPD presents the Infrastructure (formerly spaces including Green Belt and Metropolitan Open Land and additionally designate opportunity to conditionally CS5) further areas for absolute protection such as the proposed open space fronting designate further areas of Revise Granville Road and Bow Lane adjoining the proposed new Finchley Memorial Hospital open space but our policy supporting and other valued open space to include parks, public and private playing fields, public already offers protection for text to CS7 to and private amenity open spaces and the Borough’s allotment sites” other suitable land with highlight Re-write the second bullet point to read: “Securing additional onsite open space and potential to be used as open benefits of recreational provision that meets the national standards of provision within the identified space. community growth area and does not ‘borrow‘ open space from adjoining areas so as to allow an On the basis of evidence in farming increased density of development within the growth area as at Mill Hill East and the open space, sport and Colindale.” recreational facilities needs Under the fourth bullet point, after the words “sports facilities” in the second line insert assessment we will set the words”additional allotment sites,” and after the word “for open space” in the third quantitative standards for line add the words “and leisure and recreational facilities.” open space in the DM Under the fourth bullet point, after the words “green space, trees and hedgerows” add policies DPD. the words “by identifying and scheduling them and safeguarding them through the Provision of leisure and development control, planning enforcement, open space management and other recreation facilities are administrative functions.” addressed in our policy on Under the fifth bullet point, after the words “biodiversity in Barnet” add the words “and Enabling Integrated ensuring compliance with statutory and case law safeguards within the development Community Facilities and control, planning enforcement, open space management and other administrative uses. functions.” Given our significant and Add a seventh bullet point that reads: “Amending to the Local Development Scheme to well used allotment holdings include the production of a ‘Trees and Development Supplementary Planning and extensive former Document’ that it is understood the Council has already drafted.” [Note: See Norwich agricultural land we are keen City Council ‘Trees and Development SPD]. to promote sustainable local Amend the wording of Paragraphs 11.1.1 to 11.7.1 where necessary to reflect these food production. We are changes to Policy CS5. supportive of the capital
253 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations growth initiative to increase the number of food growing spaces in Barnet.
The suggested wording on the fourth and fifth bullet points is unnecessary and unstrategic. The Core Strategy does not have to reiterate our statutory responsibility for biodiversity, trees, hedgerows and green spaces.
We are producing a SPD on Green Infrastructure which will provide guidance on landscaping, trees, biodiversity and sustainable urban drainage systems.
4 5 Zenda Green Mill Hill CS7 Policy CS5 - Enhancing and protecting Barnet’s open spaces (P54) needs greater The Core Strategy is clear in None 3 Preservation Enhancing clarity on what open spaces will actually be protected and enhanced. The Three Strand the principle of protecting 9 Society and Approach commits in Strand 1 to ‘Absolute Protection of the Green Belt, Metropolitan open space. Further policy protecting Open land and other valued open space’ but the policy is not clear on other land that will be contained in the open space will be protected. It is also weak on enhancing the existing stock of spaces, suggesting Development Management (formerly improvements will be made only ‘where opportunities arise’. Map 5 (P55) has been DPD. CS5) prepared in support of this policy but it needs greater clarity on what is protected and Green Belt and MOL are where new provision will be made. identified on the proposals map and have strong policy protection through PPG2. We can only improve open space provision where opportunities arise. This is a realistic approach.
254 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 9 Brent Cross CS7 Policy CS5 suggests that BXC will deliver 11.27ha of open space, which is not We have revised the section Revise CS7 4 Cricklewood Enhancing consistent with the application proposals, in particular Section 2 of the Development to reflect the provision of 0 Development and Specification & Framework. The minor updates are therefore suggested: new open space as part of Partners protecting In order to create a greener Barnet we will enhance and protect Barnet’s Open Spaces the Brent Cross - open space by: Cricklewood proposals. We (formerly protecting, where appropriate, designated open spaces, including Green Belt and consider the wording 'where CS5) Metropolitan Open Land, and other suitable land with the potential to be used as open appropriate' to significantly space…… weaken the policy on securing additional on-site open space or other open space improvements in the protecting open space. identified growth areas including 11.27ha a net additional increase of 8ha of new provision at Brent Cross – Cricklewood, …..
4 1 Graham Saunders English Heritage CS7 Support in general the policy to enhance and protect Barnet’s open spaces. However Agree Revise 4 4 Enhancing neither Policy CS5 not the preceding supporting text (paragraphs 11) recognise the supporting 6 and heritage value of many of Barnet’s open spaces. For example many of the open spaces text to CS 7 protecting identified form part of or are designated assets such as registered historic parks and to highlight open space gardens, or form part of the special character of a conservation area or setting of a heritage (formerly listed building. We would advise that the heritage value of the Borough’s open spaces value of CS5) is recognised, protected and enhanced in the wording of Policy CS5 and its supporting parks and text in order for it to be compliant with national guidance. gardens.
255 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 MR AND LEVENE CS7 As confirmed in representations made to the Issues and Options consultation, the Core The Site Allocation DPD is None 4 MRS Enhancing Strategy should include some provision for the review of MOL designations within the the appropriate document in 8 and Borough to allow sites, where appropriate, to be "Three Strands Approach" seeks the which to consider changes to protecting "Absolute protection of the Green Belt, MOL and other valued open space from the boundary of MOL. open space inappropriate development". Policy CS5 goes onto state that "in order to create a (formerly greener Barnet, we will Enhance and protect Barnet's open spaces by "protecting CS5) designated open spaces, including Green Belt and MOL, and other suitable land with the potential to be used as open space". These objectives are fully supported. Policy CS5 of the Core Strategy, or supporting text to the Policy, should set out how and when a review of MOL will be undertaken in order that there is appropriate opportunity to rigorously assess existing designations and, where appropriate, amend the MOL boundaries and release sites which do not meet the criteria for such designation. Alternatively, in relation to small individual sites within the MOL, the Core Strategy should confirm that individual assessments should be carried out as part of the Site Allocations DPD. Released where they do not meet the requisite criteria as suitable for such designation. Strand 1 of the Council's However, in accordance with representations made to the Core Strategy Issues and Options consultation, serious concerns remain that the Core Strategy fails to include provisions for the review of MOL boundaries. London Plan Policy 3D.10 states that "any alterations to the boundary of MOL should be undertaken by Boroughs through the DPD process". It is appropriate for the Core Strategy or at the very least the LDS, to set out how review of MOL will be undertaken and it is considered important to allow for the opportunity to rigorously assess existing designations and where appropriate release sites which do not meet the criteria for such designations. For example, land at 1 Indigo Walk, located adjacent to Cherry Tree Woods, East Finchley, is currently included within the MOL designation which covers this area of public open space. No.1 Indigo Walk, however, is a private residence which, unlike every other residential property which abuts the Woods, has been included within the MOL designation even though it does not perform any of the functions expected of sites so designated. Accordingly, the Core Strategy should make provision for the review of boundaries as indicated above to ensure that it comprises an effective and robust policy. Policy CS5 of the Core Strategy, or supporting text to the Policy, should set out how and when a review of MOL will be undertaken in order that there is appropriate opportunity to rigorously assess existing designations and, where appropriate, amend the MOL boundaries and release sites which do not meet the criteria for such designation. Alternatively, in relation to small individual sites within the MOL, the Core Strategy should confirm that individual assessments should be carried out as part of the Site Allocations DPD.Accordingly, the Core Strategy should make provision for the review of boundaries as indicated above to ensure that it comprises an effective and robust policy. Policy CS5 of the Core Strategy, or supporting text to the Policy, should set out how and when a review of MOL will be undertaken in order that there is appropriate opportunity to rigorously assess existing designations and, where appropriate, amend the MOL boundaries and release sites which do not meet the criteria for such designation. Alternatively, in relation to small individual sites within the MOL, the Core Strategy should confirm that individual assessments should be carried out as part of the Site Allocations DPD.
256 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Lisa Walduck Natural England CS7 Although we are supportive of protecting and enhancing open spaces in the borough, at We recognise the value of Revise CS 7 5 Enhancing present the Core Strategy appears to view such spaces in isolation. In order to green infrastructure in and 2 and maximise the benefits that open spaces can deliver, it is vital that they are considered Barnet and plan to produce a supporting protecting as a network. We therefore recommend that this policy is revised and expanded to Green Infrastructure SPD.. text Including open space address green infrastructure. new section (formerly Green infrastructure is the network of green spaces, places and features that thread 12.6 on CS5) through and surround urban areas and connect town to country. This includes public Green and private spaces, such as parks, gardens, allotments, cemeteries, trees, green roofs Infrastructure and natural habitats such as woodlands, grasslands and wetlands. and the The benefits of green infrastructure are often described as ‘ecosystem services’. This Green Grid. technical term has emerged internationally to express the many ways in which a Revise LDS functioning natural environment supports life. to introduce Natural England’s London region has developed a paper which sets out four guiding new SPD on principles which should be considered when planning green infrastructure. We Green recommend that you read this paper and revise policy CS5 to better reflect the need to Infrastructure deliver a functioning green infrastructure in the borough. It should be noted that the paper has been produced to provide guidance, and is not a published Natural England statement. 4 2 Lisa Walduck Natural England CS7 Policy CS5 states that Metropolitan Open Land will be protected. However, this may The policy refers to None 5 Enhancing preclude opportunities to enhance areas of MOL which are currently poor and which improving open spaces 2 and could be improved. We would support a policy which aims to improve the quality of which cover all open spaces protecting MOL. including MOL. open space There are small areas of the borough which lie in the GLA’s defined areas of deficiency The Development (formerly in access to nature. In order to address this issue, we recommend that the policy Management Policies DPD CS5) explicitly addresses the need to reduce these areas of deficiency, and that the LDF will provide further detail on provides guidance on how this should be achieved. addressing areas of deficiency in access to nature. 4 1 Katie Arthur Environment CS7 We support Policy CS 5 and are particularly pleased with the second to last bullet point: We welcome this support Revise CS 7 5 Agency Enhancing ‘ensuring that development protects existing site ecology and makes the fullest and have revised policy to 4 and contributions to enhancing biodiversity, both through on-site measures and by add reference to protection protecting contribution to local biodiversity improvements’ and improvement of water open space Suggested Improvements: courses. (formerly The policy could be improved by adding to the above point ‘including the protection and CS5) improvement of watercourses’. This would then help to meet Policy 4C.3 of the London Plan without repeating its content. 4 2 Mike Dawson Finchley Society CS7 We are concerned that the original ‘Three Strands Approach’ to protection of Green Not necessary to add the None 5 8 Enhancing Belt and Metropolitan Open Land is not repeated in Policy CS5 and CS1. word absolute as designated 5 and We wish for absolute protection of Green Belt and Metropolitan Open Land and open space protected by protecting associated spaces as set-out below: policy. For clarification see open space CS 5, first bullet point: PPG 2 Green Belts. (formerly • protecting designated open spaces giving absolute protection, including Green Belt On the basis of evidence in CS5) and Metropolitan Open Land and other suitable land with the potential to be used as the open space, sport and open space. This to include parks, public and private playing fields, public and private playing pitch needs amenity open spaces and the Borough’s allotment sites. assessment we will set Second bullet point: quantitative standards for • Securing additional onsite open space and recreational provision that meets the open space in the national standards of provision within the identified growth area and does not Development Management ‘borrow‘open space from another site. Policies DPD.
257 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations
4 1 P E Pickering hendon and CS7 The comments all relate to matters omitted from, or dealt with much too cursorily in, the We refer to our response at Revise CS5 6 district Enhancing document. We note the references to the character of Barnet and its historic 426/6 on arts and culture and add new 0 archaeological and environment in the document. They are welcome so far as they go, but they do not go The Core Strategy highlights para 4.2.1 society protecting anything like far enough, and should have a chapter to themselves (as the natural its heritage at 4.2.1. Policy open space environment has in Chapter 11) or at least a separate section in Chapter 9. CS 5 refers to protecting and (HADAS) (formerly This chapter or section should, in particular, outline the council’s policy on conservation enhancing Barnet’s heritage CS5) areas (as the UDP did in Policies HC1 and following) and on the ‘local listing’ (as it is including the Battle of Barnet currently termed) of buildings of importance to the borough’s heritage and townscape site. character - as the UDP did in Policies HC14 and 15. It should also mention the wealth Further policy will be of nationally listed buildings which Barnet enjoys - Barnet is, I believe, very high in this included in the Development league table among outer London boroughs. Examples of policies on these matters Management Policies DPD which Barnet could usefully emulate are in Policy 9B of the draft Core Strategy of on heritage and archaeology Islington, and in SP10 of the Tower Hamlets Core Strategy. Archaeology in the but a new chapter in the narrower sense makes even less of an appearance in the ‘Direction of Travel’ Core Strategy is not document - indeed I have found none at all. This must be rectified, and it must be made considered appropriate. clear to the people of Barnet and to developers that the Council will insist on proper archaeological investigations in advance of any development where it seems possible that there are buried remains, and that the results of any investigations will be made public. Including Archaeological Priority Areas in one of the maps would be very helpful. Another omission is of museums. There are two perfunctory mentions, one of Church House Farm Museum in the context of the library estate, and the other of the RAF Museum in the Colindale box in Chapter 7. One would not guess from this that the RAF Museum is a National Museum which the Council should be proud of having within its area. Nor is there even a mention of other museums, such as the Barnet Museum in Wood Street and the Stephens Collection in Avenue House. This contrasts pointedly with the several paragraphs devoted to the various types of open space. Although not really within HADAS’s remit, the document appears to neglect culture and the arts completely (there is not even a mention of the Arts Depot in North Finchley, let alone the various smaller arts centres). Surely they are significant in land use terms, and in making Barnet rather more self-contained, and not a mere dormitory suburb whose inhabitants look to centr
258 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 9 David Howard Federation of CS7 It is essential that there be strong measures to protect our trees and wildlife and save We do recognise the Revise LDS 6 Residents Enhancing our back gardens and back-land from development. We are concerned at the importance of protecting to introduce 4 Associations in and pernicious intrusions into green belt and MOL through sports facilities, schools, golf gardens for biodiversity and new SPD on Barnet (FORAB) protecting ranges and the like, Improved guidance on Front/side garden conversions to car sustainability as well as local Green open space parking is required in order for some planting to be maintained character however without Infrastructure (formerly draconian measures we are CS5) unable to prevent residents exercising their rights through permitted development to make minor alterations to their properties front and back gardens. We are producing a SPD on Green Infrastructure which will provide guidance on landscaping, trees, biodiversity, green roofs and sustainable urban drainage systems. 4 2 Pauline McKinnell Cricklewood CS7 All green spaces should be protected. They are essential to our health. We welcome this support. None 6 0 Community Enhancing We make clear links in the 7 Forum and Core Strategy between protecting health and provision of open open space spaces. (formerly CS5) 4 1 G Jardine Greensquare CS7 Page 54, the map marked 5 should refer to Barnet's Green Spaces and Play Areas The policy provides this None 7 Residents Enhancing being or prime importance. recognition and protection 4 Association and protecting open space (formerly CS5) 4 2 G Jardine Greensquare CS7 Para 11.3, page 53 we suggest the words: It is recognised that children None 7 Residents Enhancing "and informal play spaces" be added the word "formal" as children will often use the will benefit from other 4 Association and areas marked on Plan 5, some of which are natural tree, grass and tree cover as play spaces but provision of protecting facilities. formal play equipment is a open space priority. (formerly CS5) 4 1 Steven Deller CS7 Unless it's Claremont Stadium where you have sought to do the exact opposite by This a specific matter None 7 7 Enhancing overturning this provision in the covenants and taking local residents to court for connected with planning 8 and objecting consent for Hendon FC. protecting open space (formerly CS5) 4 1 Steven Deller CS7 So why break up the existing open spaces in Cricklewood and replace them with These issues were None 7 8 Enhancing smaller areas addressed as part of the 8 and Brent Cross Cricklewood protecting planning application open space considered by committee on (formerly 16 November 2009 259 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations CS5)
4 2 David Dobbs CS7 This needs to be more specifically worded to be meaningful. We consider that the None 8 0 Enhancing approach to protection of 1 and open space is clear. protecting open space (formerly CS5) 4 1 Claire McAlister British CS7 Vision and Objectives The vision and sub ambitions identified here can all help to be We recognise the Revise map 8 1 Waterways Enhancing supported by improved access and facilities at the Brent Reservoir. In February 2009 importance of Welsh Harp / of natural 2 and the Department of Health published the Physical Activity Plan for England “Be active, Brent Reservoir in terms of spaces to protecting be healthy: a plan for getting the nation moving”, which makes reference to the benefit biodiversity, leisure and highlight open space of the waterways and other open space for informal and formal recreation recreation. watercourses (formerly http://www.dh.gov.uk/en/publicationsandstatistics/publications/publicationspolicyandgui and Welsh CS5) dance/dh_094358 Harp / Brent Barnet's Core Objectives We support the final objective that seeks to enhance and The future of Area 10 is an Reservoir protect Barnet's green and natural open spaces, and feel that the Brent Reservoir issue best addressed Add ref to should be mentioned here, so that its potential for leisure and recreation, tourism, through the Site Allocations Reservoir at education, biodiversity etc can be fully utilised. DPD. 4.9.3 11 Enhancing and Protecting Barnet's Open Spaces Map 5 and 6 The Brent Reservoir should be highlighted on these maps as a visitor attraction and local public amenity space, as well as an area where regeneration/restoration would enliven and activate the waterspace, helping to support the Core Strategy Objectives. In addition, we would like to reiterate previous comments submitted as part of the Issues and Options consultation: The sailing club building to the north east of the reservoir, by Cool Oak Lane Bridge, is leased to the Council and currently vacant and falling into disrepair. BW would be pleased to see this reopened and brought back into use, to provide enhanced access to the reservoir as a public resource and increase leisure opportunities. We are aware that the Metropolitan Housing Trust was previously involved in a joint venture with the Council to redevelop/refurbish the West Hendon Estate. BW would support this, to include the refurbishment and reopening of the sailing club building, and the land to the north, which I believe is known as ‘Area 10’. This would help to improve access to this potentially valuable open space and public resource, as well as providing the opportunity to improve biodiversity within this SSSI.
4 2 Maria Nash Barnet Women's CS7 Local people to lead on this issue through Local Agenda 21 groups As part of our Future Shape None 8 0 Design Group Enhancing programme we are 3 and encouraging greater self- protecting help and community open space leadership (formerly CS5) 4 2 Maria Nash Barnet Women's CS7 There should be new allotments created not only the existing allotments protected to We aim to increase the Revise 8 1 Design Group Enhancing encourage more local food produced and better eating habits encouraged by people number of food growing supporting 3 and growing their own food spaces in Barnet and will text to CS7 to protecting utilise mechanisms such as highlight open space capital growth which offer benefits of (formerly financial and practical community CS5) support for community farming 260 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations farming to identify to identify new opportunities for the development of new spaces.
4 1 Robert Shutler Woodside Park CS7 A blanket policy like this is a recipe for non-creative thinking especially as most of the The Core Strategy is clear in None 8 9 Garden Suburb Enhancing green belt is used by an extreme minority of the people. There is more than enough the principle of protecting 5 Residents and open space in Barnet (although much of it is in the wrong areas) and the only areas open space. Further policy Association protecting that need protection are the conservation areas and Woodside Park. There are many will be contained in the open space areas of MOL which should be taken out of MOL status and this land should be brought Development Management (formerly back into some form of proper use. Policies DPD. CS5) 4 2 Glen Rollings Greater London CS7 The policy should refer to the aims of the Mayor’s Blue Ribbon Network in protecting We have identified Barnet's Revise map 8 5 Authority Enhancing and improving the quality of watercourses and their surrounding spaces. The policy rivers in the Blue Ribbon of natural 8 and should also support improved access to open spaces by all residents of the borough. Network and referred to the spaces to protecting policies in the London Plan highlight open space at paragraph 12..5.2. watercourses (formerly and Welsh CS5) Harp / Brent Reservoir P Save our CS7 Give absolute protection for small open spaces and allotments along with Green Belt, Not necessary to add the None et suburbs Enhancing Metropolitan open Land and parks. word absolute as designated iti and open space protected by o protecting policy and our policy already n open space offers protection for other (formerly suitable land with potential to CS5) be used as open space. P Save our CS7 Save our back gardens from backland development We do recognise the None et suburbs Enhancing importance of protecting iti and gardens for biodiversity and o protecting sustainability as well as local n open space character (formerly CS5) 2 2 Universities CS8 A strong USS agrees with this policy as it seeks to promote growth and to provide the We welcome this support. None 4 Superannuation and opportunity for economic advancement. USS are pleased to note that Capitol Park falls CS 8 provides the policy 0 Scheme (USS) prosperous within the Colindale AAP and is designated within the Edgware Road Corridor of basis for supporting Barnet Change which seeks to provide a mix of appropriate uses in the area including businesses and this includes (formerly commercial activity. USS encourages the council to promote Colindale as a growth responding to their needs. CS6) area and support businesses particularly within Finchley and Colindale. USS urges the council to consider maintaining the flexibility of business uses and supporting services within these areas.
261 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 6 Ian Dubber Workspace CS8 A strong Workspace objects to the safeguarding of existing employment sites throughout the PPS4 recognises the role of None 4 Group PLC and borough for Class B uses. Workspace considers that this policy should promote mixed use developments in 1 prosperous economic development as defined by draft PPS4, which includes Class B uses but also facilitating economic Barnet includes developments that: provide employment opportunities; generate wealth; and development however it also (formerly produces or generates an economic output or product. Consequently, the council recommends that we should CS6) should allow for the change of use of sites for non-class B uses that generate economic where necessary safeguard development. This approach is important for long-term economic development of the land from other uses to borough. Indeed, workspace has experienced changes in types of business activities facilitate a broad range of and floorspace demand from the occupants of its property portfolio and has noticed a that economic development. shift away from the requirement for traditional Class B floorspace. There has been a PPS4 retains the long and well established trend of decline in the demand for industrial accommodation requirement for an throughout London. Workspace considers that the protection of existing employment assessment of land and the sites for such uses in Barnet Employment Land Survey Workspace considers the council has not sufficiently considered the redevelopment of provides this to support existing employment sites. Workspace considers that the council should promote the policy CS8. The redevelopment of inefficient employment areas for mixed use developments that Development Management incorporates modern and flexible employment floorspace. New employment floorspace Policies DPD will provide will help sustain existing employment use at such sites and enables sufficient flexibility further detail on policy for and building quality to secure its continued use in the longer term. This will provide existing employment sites in benefit in employment and economic terms through continuing to provide opportunities relation to mixed use. The for a wide variety of small and medium sized businesses. The associated housing Site Allocations DPD is the development as a part of a mixed use development will secure the delivery of this appropriate document for employment floorspace. Without the housing element the redevelopment could be site specific considerations. unviable. We consider that Policy CS8 is responsive to the needs of modern business and therefore promotes economic development in line with PPS4.
262 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 7 Ian Dubber Workspace CS8 A strong Consequently Workspace considers that the council should allow the redevelopment of We clearly state in the Core None 4 Group PLC and employment sites when mixed use development is proposed that incorporates Strategy that Town Centres 1 prosperous residential uses and modern employment use. Workspace supports the encouragement are our preferred location for Barnet of mixed-use developments in the larger town centres that include commercial mixed use development and (formerly floorspace. Workspace considers that the council should promote mixed-use this is supported by PPS4. CS6) development in other locations across the borough including through the Training facilities should be redevelopment of existing under-used sites. Workspace supports the promotion of provided in accessible small and medium sized commercial floorspace. Indeed Workspace actively provides locations in order to reduce affordable and flexible workspaces for these business types. Workspace considers that the need to travel. Barnet's new commercial buildings need to be flexible to meet future business needs and that a Town Centres are range of unit sizes are required including accommodation suitable for small and appropriate locations as we medium sized enterprises. However, Workspace considers that this policy should not seek to redefine their roles restrict the promotion of small and medium sized enterprises throughout the borough based on functions that will Workspace supports the promotion of employment and training schemes. Workspace support vibrancy. However considers that this policy should support the development of employment and training locating such D1 class uses facilities within existing employment sites. Consequently the existing employment sites in employment areas could should not be restricted to Class B uses. Recent government initiatives that seek to lead to future impacts on increase training facilities and raise the workforce’s skills levels have increased existing uses and would not demand for Class D1 floorspace. There is a need for strong linkages between this be appropriate. Class D1 floorspace and existing businesses and can only are achieved by locating these uses in close proximity to each other on existing employment sites. We highlight our close Workspace supports the promotion of employment and training schemes. Workspace working relationship with considers that this policy should support the development of employment and training strategic partners such as facilities within existing employment sites. Consequently the existing employment sites Middlesex University and should not be restricted to Class B uses. Recent government initiatives that seek to Barnet College in helping increase training facilities and raise the workforce’s skills levels have increased residents to access work. demand for Class D1 floorspace. There is a need for strong linkages between this Agreed that planning Class D1 floorspace and existing businesses and can only are achieved by locating obligations should be in these uses in close proximity to each other on existing employment sites. Workspace accordance with Circular considers it important that the provision of student homes and long-term needs of the 05/2005 local colleges and universities are met. It is important that the council support the local universities as they are a major source of employment and are providing the essential skills to the future workforce of the borough. It is also important to promote linkages between existing businesses and the universities to stimulate economic growth. Such an approach would accord with the draft PPS4. Workspace considers that any S106 contributions for employment and training initiatives should be applied on a site by site basis and adhere to the requirements of Circular 05/2005. Planning obligations must only be imposed when it can be demonstrated that they are needed for to mitigate against the impact of the development and should not make a redevelopment scheme unviable.
263 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 6 A2 Dominion CS8 A strong Preferred Policy CS 6 identifies that the Council will ‘safeguard existing employment PPS4 recognises mixed use Introduce 7 Housing and sites that meet the needs of modern businesses. However, mixed use development developments role in new policy 4 prosperous including residential as a replacement for employment uses can improve the viability of facilitating economic CS2 on Brent Barnet a scheme. It should be noted that one of the key themes of PPS4: Planning for development. PPS4 also Cross – (formerly Sustainable Economic Development is to achieve a proper balance between economic recommends at EC2(h) that Cricklewood CS6) opportunities and environmental and social issues, and that the definition of economic we should where necessary development now includes a wide range of development options. With this in mind, the safeguard land from other Council should apply the appropriate flexibility when considering the best use of a site, uses to facilitate a broad and that in the right circumstances, sustainable residential development can make the range of that economic best economic re-use of a site. More specifically, Preferred Policy CS6 should be development. PPS4 retains amended to make specific reference to the fact that the Brent Cross Cricklewood the requirement for an Regeneration Area Framework SPG (2005) in the instance of the former Parcel force assessment of land. Barnet's Depot on Edgware Road, and in other cases other more specific guidance has already Employment Land Survey determined that certain employment sites should be redeveloped for non-employment provides evidence of the uses. Preferred Policy CS 6 also identifies that the Council will support Barnet residents need for employment land. in accessing work through ‘requiring major developments to provide financial The Development contributions and to deliver employment and training initiatives in line with the Skills Management Policies DPD Development Plan’. Whilst our client encourages the improvement of skills in the will provide further detail on Borough, it should be recognised that some developers including A2 Dominion Housing policy for existing already source local labour and provide construction skills as part of their corporate employment sites in relation responsibility. As such, Preferred Policy CS 6 should make specific reference that any to mixed use. The Site financial contribution should not be required or reduced to reflect the benefits that the Allocations DPD is the developer will provide as a matter of course. appropriate document for site specific considerations. The Core Strategy has introduced a new policy on Brent Cross Cricklewood to clearly set out the planning framework for the area. We do recognise that some major developments are making these contributions and this will be factored into negotiations. However this does not merit a change to policy.
3 0 Asda Stores Ltd CS8 A strong We fully support aspirations to promote mixed use commercial floorspace which fully Mixed use commercial None 7 and accord with the aims and objectives of national planning guidance. Policy should be development can comprise a 9 prosperous clear however that mixed use commercial floorspace includes retail development for number of uses with or Barnet the reasons set out above. without retail. (formerly CS6)
264 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 2 Asda Stores Ltd CS8 A strong We support policy aspirations to promote commercial investment in existing town Reference to business Add definition 7 and centres. However, in terms of economic growth throughout the Borough it should be covers retail adequately. We of economic 9 prosperous made clear that retail is considered an important form of economic development. Both have added a new section to development Barnet PPS4 and its emerging replacement (draft PPS4) makes clear that retail should be reflect PPS4 and the at para (formerly considered an important form of economic development. Equally at Section 12 definition of economic 13.1.3 CS6) (Promoting a Strong and Prosperous Barnet) it is acknowledged that Barnet’s economic development. Retail is not growth is increasingly in service-orientated employment and high level knowledge- the only form of economic based jobs and the Council acknowledge that growing numbers of higher skilled development. workers are employed in various sectors, including retail. In line with this, it should be PPS4 provides the following made clear within the vision for the borough as a whole that retail is integral to guidance in relation to when economic development and growth in Barnet. planning authorities are
265 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 1 Asda Stores Ltd CS8 A strong The Council state at paragraph 12.1.2 that: assessing retail need - "in None 7 4 and “Barnet’s future economic growth is projected to be increasingly in service-orientated deprived areas which lack 9 prosperous employment and high level knowledge based jobs with growing numbers of higher access to a range of Barnet skilled workers in financial, retail, business and professional services.” services and facilities, give (formerly We welcome the inferred acknowledgement that retail represents an important form of additional weight to meeting CS6) economic development in the Borough. However, policy needs to make clear that the these qualitative Council recognise retail as an important contributor to the economy and to confirm the deficiencies. However, any importance of retail jobs. benefits in respect of The Governments recognition of both industrial uses and retail as economic regeneration and development in the new PPS4 (issued in May 2009) is the culmination of policy employment should not be evolution that has sought to recognise the employment and economic merits of retail taken into account, although uses. Consequently, national guidance no longer differentiates between industrial uses they may be material or retail uses in seeking to stimulate job creation generally. considerations in the site The objectives in the most recent draft PPS4 stem from guidance previously set out on selection process." the importance of retail led regeneration (Underserved Markets: Retail and (EC1.4b). We have added a Regeneration, DCLG, October 2007). In this report the Government consider that the new section to reflect PPS4 role of the private sector is vital in stimulating growth in disadvantaged neighbourhoods. and the definition of Within this context they consider that “Brand retail can bring economic benefits to economic development. deprived communities including: improved access to quality, low cost products, Retail is not the only form of increased employment and training opportunities”. economic development The guidance makes clear the importance of retail jobs as a catalyst for regeneration. Therefore the employment Retail jobs are considered of significant value since many such jobs require lower initial generating capacity of retail skills or entry level qualifications, offer flexible hours and have a high demand for schemes are not a works. In this context they are considered to represent a ‘stepping stone to wider consideration at a policy opportunities’. level. Jobs provided by operators such as Asda are seen to offer career development opportunities and consequently the Government considers that retail development has an important role to play in local economies and regeneration. Policy needs to make clear that the Council will support retail development and welcome retail jobs. In line with national guidance retail should be considered a form of economic development and the importance of retail jobs recognised. This has added importance where retail proposals may come forward on land previously used for ‘employment uses’ i.e. B1, B2 and B8 uses. In such instances retail proposals should be assessed on their merits. Such proposals will in the majority of cases provide more jobs than previously generated and as such these proposals should not be prejudice on employment grounds because they are for retail uses.
3 1 Asda Stores Ltd CS8 A strong It is noted that 61% of existing employment land is likely to require intervention to Intervention could cover a None 7 5 and remain viable. In this context it is important that the Council’s policy retains flexibility range of solutions from 9 prosperous that allows all proposals on employment land to be assessed on their own merits. improving vehicle access Barnet and parking provision to (formerly greater flexibility on use to CS6) encouraging the subdivision of existing units. Policy CS9 266 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations is clear that we meet the needs of modern businesses and encourages improvements to the quality of existing employment provision.
4 1 Urley Estates CS8 A strong We have the following general observations by way of representations on behalf of The Development None 1 Ltd and Urley Estates Ltd in respect of Barnet House, High Road, Whetstone, N20. Management Policies DPD 5 prosperous Policy should recognise that sites in existing employment use have the potential for will provide further detail on Barnet mixed use development, particularly where they are well located to the town centre and policy for existing (formerly public transport infrastructure. employment sites. The Site CS6) Policy should also embrace sufficient flexibility according to the site specific context, Allocations DPD and where whereby to ensure the overall financial viability of a development scheme a range of appropriate the emerging alternative uses for the site should be considered as acceptable in principle, which Town Centre Frameworks or could include residential use. planning briefs are the Employment Policy should also acknowledge the significant employment return from appropriate documents for non-B class type activities, in both quantitative and qualitative terms, for example in the site specific considerations. retail and leisure sector. The Core Strategy supports mixed use developments in town centres that contributes to their vitality and viability.
4 1 Urley Estates CS8 A strong We are grateful for your consideration and await publication of the Town Centre We consider that Whetstone None 1 Ltd and Framework Document for Whetstone and the LDF Site Allocations Document on which no longer merits specific 5 prosperous we will be submitting further representations. identification as a priority Barnet centre. The appropriate way (formerly forward will be to adopt a CS6) planned approach, probably through a Planning Brief, to any future development opportunities in Whetstone and use the Development Management Policies DPD to consider such proposals 4 5 Gaby Kagan Labour Group CS8 A strong We need to make full use of the Skills Development Group to set up the vocational This relates to S106 policy Revise LDS 2 and training and apprenticeships for the skills that we will need to deliver the essential the priorities for which are to introduce 9 prosperous affordable housing and infrastructure. We should be doing whatever we can to provide clearly set out in the Core new SPD on Barnet local employment here in Barnet. We should have incentives to encourage small firms Strategy policy CS14 and Contributions (formerly and businesses to establish themselves here. includes training. We are to Enterprise, CS6) producing SPD on Employers Contributions to Enterprise, and Training Employers and Training which will aim to ensure that residents have the opportunities to access skills training and new possibilities in Barnet.
267 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Georgia Wrighton Women's CS8 A strong “to promote Barnet as a place of economic growth and prosperity”: BWDG welcome We do recognise this issue Revise LDS 3 Design Group and this objective as women often juggle a variety of different demands on their time and and are preparing a SPD on to introduce 3 prosperous close proximity to work and especially part-time and flexible working opportunities is Contributions and Enterprise new SPD on Barnet often essential for them. Provision of a vibrant local centre and facilities could assist in Employment and Training Contributions (formerly this. However, this objective must also include the retention & provision of sufficient which will help to ensure to Enterprise, CS6) local employment premises, and opportunities for flexible working including home residents have the Employers working in the Borough. It should ensure the provision of flexible work spaces and opportunities to access skills and Training recognise the importance of business support for start up & small businesses. training and new Female employment participation rates are much lower in London than elsewhere in employment provision in the Country and current strategies for growth have failed to benefit women. Much more Barnet. This will also support must be done to ensure that appropriate flexible and part time employment the new provision of opportunities are championed in the Borough and in London generally. affordable workspace.
4 7 Robert Newton CS8 A strong Reasons: Barnet has become a “dormitory” area and many employment sites have This suggested approach will Revise LDS 3 and been redeveloped for housing or mixed housing/employment uses. This should be be considered in the to introduce 6 prosperous halted and reversed particularly given the need to provide opportunities to reduce Development Management new SPD on Barnet journeys to work. Policies DPD and the Contributions (formerly principle set out in the first to Enterprise, CS6) Additionally, whilst there are many businesses conducted from home, there is minimal paragraph will not change. Employers provision of affordable and flexible small business space needed to accommodate We recognise the benefits to and Training these businesses as they expand. A Section 106 fund and construction of small units the vitality and vibrancy of as part of the planning gain contribution of larger schemes will contribute to meeting town centres as well as this need, which is unlikely to be met by the market without assistance and incentives. reducing the need to travel, from the provision of flexible workspaces for smaller businesses. We also recognise the benefits of equipping residents with the skills to access new jobs within Barnet. We do recognise this issue and are preparing a SPD on Contributions and Enterprise, Employment and Training which will help to ensure residents have the opportunities to access skills training and new employment provision in Barnet. This will also support the new provision of affordable workspace. We seek to protect sites with modern business uses that contribute to the prosperity of Barnet.
268 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Additionally, diverting Section 106 funds to training and related initiatives has not The Core Strategy needs to always been the most efficient and productive use of these funds whereas contributions provide clear strategic to “bricks and mortar” have an element of permanency and employment potential. direction, it is not subjective. Re-write first bullet point to read: Meaningful and productive is “Safeguarding existing business use sites so a to retain local employment opportunities subject to a range of that reduce the need to travel and to discourage the run down of employment sites in interpretation the hope of redeveloping for higher value uses such as housing. Encouraging development that improves the quality of existing employment provision and that increases provision generally.” Under the third bullet point, after the word “hubs” add the words “and the Council’s Economic Prosperity SPD will require Section 106 contributions towards workspace provision.” Under the sixth bullet point, add the word “meaningful and productive” between the words “deliver” and “employment”. Amend the wording of Paragraphs 12.1.1 to 12.6.8 where necessary to reflect these changes to Policy CS6. 4 9 Warren Forsyth Middlesex CS8 A strong The University particularly welcomes recognition of the importance of Further and In order to support the plans Revise para 4 University and Higher Education in 12.6 and the explicit references to Middlesex University’s role in of Middlesex University over 13.7.1 1 prosperous paragraph 12.6.1. The paragraph, as worded, implies that the University has the next 15 years (the Barnet completed its relocation and improvement strategy for the Hendon campus, whereas it lifetime of the Core Strategy) (formerly is part of the way through it, and the Core Strategy should provide the policy basis for we require further CS6) successfully completing it. information on their strategy We recognise that further details of Middlesex University’s proposals for the Hendon for the same period in order Campus will be more appropriately dealt with in the Site Allocations DPD and any SPD to help inform the or other site briefing documentation that may be produced and agreed with the Council. Infrastructure Delivery Plan. We suggest that the second sentence beginning “ Middlesex University has relocated its main campus to Hendon…” is replaced by “Middlesex University is relocating its dispersed programmes from other sites to its main campus at Hendon, where new state-of-the-art teaching, learning resource centre and research facility We also suggest that under paragraph 12.6.8, Policy CS 6 – Promoting a strong and prosperous Barnet is slightly expanded to encourage the provision of enhanced further and higher education facilities. We have not found another part of any other policy that does this, although it is implied. The current reference to further and higher education in Policy CS 6 is in supporting businesses by encouraging partnership working with the FHE sector, which is laudable but insufficient. We suggest that there is a further addition to the policy, along the lines “We will support providers of further and higher education by: • encouraging the provision of new and improved facilities within the Borough; • encouraging the provision of further and higher education programmes, skills training and continuing professional development programmes, business support initiatives and applied research.”
269 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 British Library CS8 A strong The BL is supportive of the creation of a strong and prosperous community that We welcome this support None 4 and provides opportunity for economic advancement. In accordance with draft PPS4 the BL 2 prosperous also welcomes appropriate larger mixed use developments and commercial floorspace Barnet in larger centres which will be served by public transport as noted in point 2 of Policy (formerly CS6. CS6)
270 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Metropolitan CS8 A strong Chapter 12 highlights the borough's future strategy for employment land. The MPA are The Core Strategy clearly None 4 Police Authority and content in principle with the approach in Policy CS6 - Promoting a strong and states how it supports 3 prosperous prosperous Barnet, which promotes the protection of employment sites in the borough. business by protecting Barnet However this is on the basis that policing facilities are considered acceptable on such existing employment land. (formerly land. PPS4 recognises mixed use CS6) The MPA have identified the potential of relevant employment sites in helping them developments role in meet goals of their estate strategy. In particular, the provision of patrol bases, custody facilitating economic centres and relevant pan-London policing facilities are vital to the successful development however it also implementation of the MPA's estate strategy. The nature of these uses is similar to that recommends that we should carried out on most employment sites and therefore is ideally suited to employment where necessary safeguard sites and similar locations. land from other uses to Whilst falling outside the 'B' use class definition, these policing uses are employment- facilitate a broad range of generating uses. Generally the policing uses represent no material alteration from an that economic development. Employment (B1) or Warehousing (B8) use as they possess an employment density PPS4 retains the similar to or in excess of 'B' Class uses. Vehicle movement will also be similar to a requirement for an typical employment/industrial use. These facilities do not require continued public assessment of land and the access and therefore have no requirement to be located in town centre areas. Employment Land Survey It is demonstrated above that the policy requirement to provide employment uses within provides this to support designated existing employment sites can be met through the provision of appropriate policy CS6. We consider that policing facilities on such land. Mindful of this, policing uses can be appropriately Policy CS6 is responsive to located within existing employment sites. the needs of modern Furthermore, it is considered that a planning policy basis as suggested below to business and therefore support appropriate policing facilities on employment sites in LB Barnet would not promotes economic prejudice current or future employment land supply across the borough, as such uses development in line with are compatible with the requirement to provide employment opportunity. This is PPS4. The Development supported by a number of London Borough's which have approved policing facilities on Management Policies DPD employment/industrial land, including Enfield (Cambridge Business Park), Haringey will provide further detail on (Quicksilver Place) and Greenwich (Warspite Road). policy for existing This approach is supported by the strategic development plan within Policy 3B.4. employment sites in relation Industrial Locations which states that policies in DPD's 'should develop local policies to mixed use. The Site and criteria to manage industrial sites having regard to helping meet strategic and local Allocations DPD is the requirements for…social infrastructure.' Furthermore, Policy 2.17 Strategic industrial appropriate document for locations of the Emerging London Plan defines interalia 'other industrial related identifying new policing activities' as being acceptable within Preferred Industrial Locations. It is clearly facilities. As noted the demonstrated above that particular policing uses are essentially industrial and that the London Plan also supports emerging Core Strategy should therefore reflect this. It is also further demonstrated that other industrial related certain policing uses will also fulfil the strategic requirement regarding the provision of activities. social infrastructure. In order to comply with strategic policy in this regard the following alterations to Policy CS6 are recommended below. Recommendation: The MPA recommend that Policy CS6 be amended to allow for policing facilities on surplus employment land. - safeguarding existing employment sites that meet the needs of modern business and emergency service providers. Development that improves or maintains the quality of existing employment provision will be encouraged, including that for emergency service providers.
271 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 HI (Brent Cross) CS8 A strong That said, Policy CS6 - promoting a strong and prosperous Barnet - seeks to safeguard The Development None 5 Ltd and existing employment sites. However, neither the policy itself nor its justification provides Management Policies DPD 1 prosperous a clear definition of "existing employment sites or employment uses". The policy should will define existing Barnet be clear that its definition is consistent with the Use Class (amendment) Order 2005, employment sites/uses. (formerly and clarify which uses are considered as employment (which we consider would Policy has been made clear CS6) include C1/D2 Hotel and leisure uses). As the policy is ambiguous, it is inappropriate in safeguarding employment and as such it does not meet the tests of soundness. land.
4 2 Mike Dawson Finchley Society CS8 A strong We agree with most of the policies mentioned in Policy CS 6. We propose the following The policy makes no None 5 9 and amendments (in bold): reference to promoting edge 5 prosperous i. in order to support small to medium enterprises new employment provision will of centre locations. PPS4 Barnet include a range of unit sizes and types and include affordable and flexible workspaces sets out a clear sequential (formerly and home working hubs approach to town centre CS6) ii. encouraging new mixed use commercial floorspace on the edges of our larger town development. Policy CS1 centres (Edgware, North Finchley, Finchley Church End, Chipping Barnet, New Barnet has been revised to make it and Whetstone) where access to public transport is good much clearer how it sets the spatial agenda and how the main place shaping policies sit within the Three Strands Approach. Through the Development Management policies we will establish town centre boundaries for major and district town centres. PPS4 makes clear that residential is not a main town centre use. 4 1 David Howard Federation of CS8 A strong Please provide opportunities for people to work locally and for local small business We recognise the benefits to None 6 3 Residents and expansion by safeguarding employment land and premises. This again requires more the vitality and vibrancy of 4 Associations in prosperous work on joined up public transport and adequate parking facilities in the meantime. town centres as well as Barnet (FORAB) Barnet Barnet has one of the largest numbers of small businesses in London and needs good reducing the need to travel, (formerly quality small offices, serviced offices and small commercial units with potential to join from the provision of flexible CS6) several together or move into larger premises as the business grows. Small industrial workspaces for smaller and commercial parks should be developed in different parts of the Borough to meet businesses. local needs 4 1 Government CS8 A strong Policy CS6 (Promoting a strong and prosperous Barnet) would be improved through the Agree Revise CS 8 7 0 Office for and inclusion of more detail on the proposed quantity, location and timing for business, to show 0 London prosperous commercial and employment development. forecast Barnet growth of (formerly jobs and CS6) demand for business space 4 5 David Howard New Barnet CS8 A strong Policy CS6 states that you will encourage new mixed use commercial floor space in Agree. Revise CS8 7 Community and New Barnet where access to public transport is good. At this time it is unclear as to 1 Association prosperous what will be the outcome of the Town Centre Framework and therefore advocating a Barnet policy of promoting mixed use commercial floor space may preclude other options such (formerly as residential development. CS6) We therefore wish you to remove the reference to New Barnet from Policy CS6
272 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Maria Nash Barnet Women's CS8 A strong Anti ageism needs to come into this grouping. Elderly people should be encouraged to We refer to our response at None 8 2 Design Group and participate by fees being reduced in order that they can access these skills which at 418/14 3 prosperous present they get excluded because of financial restrains as they are on low pensions or Barnet benefits. The elderly should be included in this. (formerly CS6) 4 1 Michael Storey CS8 A strong Again, it's an open door to every Tom, Dick and Tesco to flatten New Barnet and build We refer to our previous None 8 9 and bland supermarkets. response at 471/5 on New 7 prosperous Barnet with respect to this Barnet specific policy on promoting (formerly a strong and prosperous CS6) Barnet. 4 2 Glen Rollings Greater London CS8 A strong Brent Cross/Cricklewood is identified within the London Plan and draft replacement Policy has been revised to Revise CS8 8 6 Authority and London Plan as a strategic office location / location for employment growth. add reference to the 8 prosperous potential of Brent Cross as a Barnet business location (formerly CS6) 6 John Dix CS8 A strong Policy CS6 states that you will encourage new mixed-use commercial floorspace in Agree Revise CS8 and New Barnet where access to public transport is good. At this time it is unclear as to prosperous what will be mixed use commercial floor space may preclude other options such as Barnet residential development. (formerly I therefore wish you to remove the reference to New Barnet from Policy CS6. CS6)
2 Steven Deller CS8 A strong Build in Cricklewood spend the S106 money everywhere else Parts of Barnet where there None 0 and are high levels of prosperous worklessness will benefit Barnet from support to access work. (formerly CS6) P New Barnet CS8 A strong Policy CS6 states that you will encourage new mixed use commercial floorspace in Agree Revise CS8 r and New Barnet where access to public transport is good. At this time it is unclear as to of prosperous what will be the outcome of the Town Centre Framework and therefore advocating a o Barnet policy of promoting mixed use commercial floor space may preclude other options such r (formerly as residential development. Recommendation made to remove the reference to New m CS6) Barnet from Policy CS6 a P Save our CS8 A strong Provide opportunities for people to work locally and for small business expansion by The Development None et suburbs and safeguarding employment land and premises. Management DPD will define iti prosperous existing employment o Barnet sites/uses. Policy has been n (formerly made clear in safeguarding CS6) employment land.
273 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 1 Peter Storey Friern Village CS9 The above policy whilst recognising the current problems of traffic congestion within Policy CS 9 sets out what Publish 4 Residents Providing and around the borough makes no mention of available alternatives to cars, buses and key transport infrastructure is Infrastructure 2 Association effective and trains. With the increased proposed population the traffic problems can only get worse going to be provided to Delivery Plan efficient travel if alternatives are not explored. Getting around the area is central to quality of life in support growth. The (formerly CS Barnet - if alternatives to cars and buses are not found then all in Barnet will suffer a infrastructure delivery plan 8) reduction in their quality of life here. Throughout the developed world towns and cities sets out what, when, where are re-introducing tram systems as a way to beat traffic congestion. Barnet is ideally and how it translates into situated to begin a system which could eventually cover the whole of North London. delivery over the next 15 The system should join existing transport hubs such as railway and tube stations and years including transport, serve all town centres on an east/west basis. community facilities and parks. Regarding tram systems please see response at 416/7 2 2 Peter Storey Friern Village CS9 Consideration must be given to facilitating a new tram system linking all town centres For tram systems please see None 4 7 Residents Providing and major transport hubs. Private car use should be deterred when public transport is response at 416/7 2 Association effective and available. Future development must make provision primarily for new public transport to There may be issues with efficient travel serve it. Car use should be discouraged. How has Barnet influenced behaviour to travelling where any (formerly CS reduce the need to travel? There is nothing wrong with travelling as long as it is by transport system does not 8) excellent fast public transport including a new tram system. have the capacity to meet the demand placed on it, and one way of tackling this is to reduce the need to travel. This is being addressed through mixed use developments and the development management process. Barnet supports the proposed upgrade to the Northern line and the Thameslink Enhancement Scheme which will help provide better public transport services on key existing routes. Extensive public transport improvements are planned as part of the Brent Cross Cricklewood regeneration scheme 2 3 Peter Storey Friern Village CS9 No mention has been made of improving links to the Moorgate - Welwyn Garden City The Borough is supportive of None 4 1 Residents Providing line which runs through the east of Barnet. This is an important link directly into the City reviewing and improving the 2 Association effective and and Kings Cross at weekends. Off street parking facilities are currently non existent at bus network to serve railway efficient travel New Southgate, Oakleigh Park and New Barnet. stations and encourage (formerly CS greater usage of trains and 8) will work with TfL to achieve this. The Borough is not looking to create new car parking facilities at these stations. There are 2 car parks at New Barnet station located off the public highway.
274 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 5 Peter Hewitt CS9 Such reassuring noble sentiments could not be more inconsistent with Barnet Council It is not the role of a None 4 Providing Planning Departments record insofar as the highly controversial and hotly contested Strategic Policy document to 4 effective and JCoSS faith school in Westbrook Crescent, New Barnet, is concerned. If ever there comment on individual efficient travel was a planning permission application that deserved to have been dismissed from the Planning Applications. The (formerly CS outset it was that of JCoSS which so blatantly flaunted much planning criteria and expansion of the school went 8) environmental regulation – especially where travel is concerned e.g. where is the through the Planning mandatory ‘Green Travel Plan’ for the 1,500 students and staff? What will happen in a process which included the few years time when hundreds of cars and coaches daily converge on New Barnet’s submission and approval of already intolerably congested roads from places as far afield as Golders Green, a Transport Assessment and Hendon, Belsize Park, etc. all of which lie within the anticipated student/staff catchment condition 18 which requires area of the new school? the submission of a School Travel Plan which will be reviewed each year. It is nonsensical to assume that students and staff will either walk or cycle to the We recognise the impact of school. And yet, S.14 of the LDF omits any reference whatever to the crucial issue of the School Run and the Core school catchment areas. No mention of any policy that would rigorously impose Strategy is taking a geographical limits on the radius within which students may be enrolled, if that is, the comprehensive approach to Borough genuinely wishes to properly and efficiently address the over-riding tackle this issue through imperatives of reducing its ‘carbon footprint’ or the adverse environmental more effective school travel consequences of traffic-congested highways. plans and traffic Until S.14 is suitably amended to take account of such blatant examples as the management schemes [inexplicably condoned] JCoSSs departure from accepted ‘green travel plan’ policy I outside schools. shall strenuously object, as I’ve no doubt many other concerned ‘Save New Barnet Campaign’ members will. The JCoSSs school travel plan is currently being drawn up, being a new school it was not possible to predict where pupils would come from until the places were offered. Although a Transport Assessment was produced the catchment area and admission criteria were unknown at the time 4 6 Matthew Thomas Bride Hall CS9 In determining the future transport provision across the Borough, Bride Hall support the We welcome this support. None 0 Holdings Ltd Providing approach advocated in draft policy CS8 in accommodating the use of the private car as This is an issue that can be 4 effective and well as enhancing public transport provision. addressed in more detail in efficient travel the Town Centre (formerly CS The vitality and viability of any Town Centre (including Edgware) is largely dependent Framework. 8) upon the number of people that they attract and the ease of travel to a centre forms a large component of how many people will visit. Access by a variety of means should therefore be incorporated to ensure all members of the surrounding communities can access the Centre. Appropriate road infrastructure, parking and public transport provision should therefore form part of a successful centre and in a suburban location such as Barnet a balance should be achieved between trips by all forms of transport.
4 7 Jon Cox London CS9 The LDF planners must be prepared to consider orbital light-rail solutions for such an It would be for TFL as the None 1 Campaign for Providing enormous amount of redevelopment. The Direction of Travel‘s document fails to even London wide strategic 6 Better Transport effective and follow up the subject, even after being raised in consultation. transport authority to review
275 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations efficient travel The borough has also acquiesced in the rejection of light-rail at Brent Cross, even and progress light rail and (formerly CS though public representations were made at the time of the Development Framework orbital schemes since they 8) consultation. It has more recently rejected similar submissions over the two AAPs. cross several London boroughs. There are The global reasons are that, firstly, London-wide planners have failed to acknowledge currently no identified and the once-in-a-lifetime opportunity to leverage planning gain‘out of London‘s financially viable schemes in development areas, mixed with, secondly, Barnet‘s ideological passion to promote road the TFL Business Plan, transport. Our understanding is that (Even the new „Brent Cross Thames link station will probably mean closing the reason for this is due to Cricklewood and possibly Hendon stations, such is the likely pressure from the London- insufficient demand to to-Bedford and the London-to Sheffield railway lobbies, although any „High-Speed provide a convincing Two recommendation in the spring that has a Derby or Nottingham spur, may affect business case to warrant that. The Core Strategy is not fit for purpose, because new orbital transport possibilities further consideration. At in Bar-net have not been seriously considered, despite many representations. Note that present any proposals for says ―considered , because it is accepted that there can be no presumption that a orbital and light rail schemes new off-road light-rail line is financially viable. However, it is not an acceptable position are purely aspirational. for Barnet to claim that it is too late to study the subject. Were such schemes to be Hopefully the Brent Cross planning application will be called in, and the public will have brought forward Barnet the opportunity to cross-examine Barnet officers in excruciating detail about how they would give detailed have handled the borough‘s development areas over the last ten years. In the consideration as we would meantime, the LDF must mention in detail the subject of light-rail and other orbital be consulted and involved as transport. a matter of course.
The CBT proposal was considered by the council as part of the Transport Assessment process leading up to the Planning & Environment committee who considered the BXC scheme in November 2009.
It was noted that the BXC Developers had discussions with the promoters of the BXR and were willing to co- operate with them regarding the BXC area, as long as the remainder of the BXR scheme is viable and funded.
The BXC Transport Assessment clearly demonstrated that the target public transport mode share can be met through a number of major public transport improvements, including a new train station on the midland main line, but 276 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations which did not include a light railway.
4 1 Julia Hines Age Concern CS9 We are concerned about the emphasis on reducing congestion and reliance on car Barnet is looking to tackle None 1 8 Providing travel. congestion and at the same 8 effective and We support traffic calming measures and the provision of frequent safe crossing points, time support key efficient travel including pelican crossings, because older people often lack the confidence to cross improvements to public (formerly CS roads with fast flowing traffic. We strongly disagree with policy CS8. transport. Congestion is one 8) of the most significant issues In addition, car travel is a major factor in climate change, an issue which already does of concern to Barnet and will increasing, have a disproportionately detrimental effect on older people. residents. Given that car travel will continue to be the Walking and cycling are both healthier options for all age groups, and their dominant mode in outer encouragement will promote better health in the next generation of older people. We London, and the fact that do not think that cycle paths should be restricted to off road routes. Barnet is a suburban location with diverse travel patterns that cannot be provided for by non car modes, then appropriate provision for car travel needs to be made. That is not to say that the borough does not have good public transport services and facilities, and in the Regeneration areas in particular there are significant improvements proposed, improving choice and reducing reliance on the car. The Council provides safe crossing facilities where they are deemed to be justified. and traffic calming measures are provided in appropriate circumstances. Road humps are reviewed as part of resurfacing schemes and only removed where evidence justifies this. The Council seeks to ensure that vehicles speeds are appropriate and not excessive, although enforcement is a Police matter. The link between traffic and poor air quality is recognised, and the Council is supportive of the use of 277 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations low emission vehicles to address this. Electric vehicle charging points are now being incorporated into new developments. There is significant walking in Barnet (29% of all trips). Cycling is less common, due in part to the topography of the borough, although there are some good off-road routes, which are safer than on road facilities. It is difficult to provide cycle paths and lanes along the suburban road network in Barnet because of existing physical constraints, although there is a network of routes signed along quieter roads. Safe cycle routes are being planned as part of the Regeneration schemes and incorporated into new developments.
4 2 Julia Hines Age Concern CS9 We support the use of spatial planning to improve health and well-being, but see this as Please see response at None 1 0 Providing being at odds with the emphasis on car travel in CS8. 418/18 above. Barnet’s 8 effective and suburban transport policy efficient travel recognises that car travel is (formerly CS the dominant mode in this 8) part of outer London and will continue to be in the future. New developments and borough Regeneration schemes seek to provide for all modes of travel. 4 6 Gaby Kagan Labour Group CS9 The LDF must have robust policies to encourage a shift to more sustainable modes of The transport policy focus in None 2 Providing transport including public transport, cycling and walking. We should make more secure the LDF is on ensuring more 9 effective and provision for cyclists and cycle parking. There are grants from TFL available which efficient use of the local road efficient travel Barnet should avail itself of. We have not always taken full advantage of these monies network, comprehensively (formerly CS in the past, to the detriment of current and prospective cyclists. We should encourage tackling the school run, 8) home working where it is appropriate. As the largest employer in the borough we delivering high quality should encourage staff that do not need to be in a Council office to work from home in transport systems in the this internet broadband age, while ensuring that they have proper corporate support. Regeneration areas and providing more environmentally friendly transport networks. This includes providing improved public transport in Regeneration areas, as well as supporting significant improvements to the 278 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Northern Line and Thameslink. More cycling and walking to school is being sought through the continued effective implementation of School Travel Plans, which include appropriate cycle parking facilities. A cycle praking space is provided for each new residential unit in Barnet. The Council does provide flexible working were appropriate and practical to the business. School Travel Plans and Green Travel Plans are often not worth the paper they are Our School Travel Plans written on. They need to be taken altogether more seriously. They need to be enforced. have been successful in reducing the number of trips and we will ensure that they are more effectively implemented. The School Run is a major cause of traffic congestion and pollution. Moreover health The School Run is specialists warn that obesity in school children is now a national concern. Green Travel recognised as an issue, and Plans that accompany planning applications are all too often there just to make the our Policy of taking a application more acceptable. It’s crucial that they should be realistic, deliverable and comprehensive approach to fully supported. Too often they are just not enforced and sometimes not enforceable. the school run is aimed at We have good rail services for radial travel but not for orbital or east-west travel. addressing this. The council Bearing in mind the large regeneration developments envisaged at Cricklewood/Brent secures travel plans via Cross, Colindale, Mill Hill, Stonegrove and West Hendon may deliver up to 25,000 new condition and sometimes via homes and 21,000 new jobs we just have to consider the construction of east-west and legal agreement as part of all orbital travel links. The London Campaign for Better Transport group is advocating the relevant planning construction of an orbital light rail service for the Barnet/Brent area, mainly using applications, and is looking existing railway corridors and old disused passenger train routes. to improve their enforceability. Travel plans within some of our regeneration schemes are crucial to their success, are robust and contain a comprehensive range of measures and provisions to ensure that they will be successful. The best example is at Brent Cross Cricklewood where the Framework Travel Plan contains target mode splits that need to be met as the phases of the development roll out.
On Light Rail - Please see response at 416/7
279 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Georgia Wrighton Women's CS9 -“to reduce the need to travel”; this objective is welcomed as it not only reduces the The order of the bullet points Revise policy 3 Design Group Providing adverse environmental and health effects of congestion and pollution it also potentially does not determine their CS9 3 effective and opens up new ways of working with the requirement for facilities to be easily preference. The policy has efficient travel accessible- this is a principle supported and promoted by BWDG. However if the been revised to highlight the (formerly CS Council are serious about achieving this aim, the order of the bullet points should be promotion of mixed use 8) reversed placing the measures to achieve reduced travel as the first bullet point. It development on reducing the should also include reference to how land use policies of location, design and mix will need to travel and the be strengthened to secure this objective. Secondly the bullet point addressing access distribution of growth. to good and affordable transport should place more emphasis on walking, cycling and Please see response at public transport, than the private car, which comes first in the proposed list of transport 429/6 regarding modes of modes. Otherwise in practice the private car will continue to dominate as the mode of transport other than the car. first choice, which will only exacerbate congestion, pollution and act as a barr 4 7 Georgia Wrighton Women's CS9 The provision of step free access tube stations in the Borough should be a priority for Seven of the thirteen tube None 3 Design Group Providing the Council, lobbying Transport for London and working with developers to secure this stations in Barnet are 3 effective and as necessary. A substantial level of growth is proposed at Colindale and a recent accessible and whilst the efficient travel application for a new tube station did not include step free access. Not only will this put Borough supports the (formerly CS up barriers to women and disabled people to accessing this new station, but it will not principle of step free access 8) help in terms of encouraging people out of their cars and onto public transport. Levels its provision would be a of congestion in Colindale are already critical. matter for the relevant station owner and / or operator, and would be subject to individual development negotiations. At Colindale a study into the feasibility and cost of providing step free access has been secured as part of the redevelopment of the former hospital site, and at Brent Cross part of the Regeneration scheme includes delivering step free access. The Council hopes that step free access will also be provided as part of the Mill Hill East regeneration scheme. 4 8 Georgia Wrighton Women's CS9 Public transport for new developments should be brought forward to the earliest Please see response at None 3 Design Group Providing opportunity and light rail/tram options should be considered wherever possible. There is 416/7 for trams, and 242/1 3 effective and concern that the level of development proposed at Brent Cross is not currently for Infrastructure efficient travel accompanied by acceptable proposals for new public transport provision. (formerly CS 8)
280 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 9 Georgia Wrighton Women's CS9 Pedestrian and cycling routes should always be pleasant and convenient to use and Provision of transport and its None 3 Design Group Providing should not play ‘second fiddle’ to the car as has been seen in some recent infrastructure is aimed at all 3 effective and developments proposed. Off road cycle routes should be provided to encourage users, and safety is an efficient travel women to cycle- many women are put off by the dominance of the car on the Borough’s integral part of the design (formerly CS streets and focussed measures need to be put in place to encourage feelings of safety process. Specific issues can 8) when cycling. Many women give up cycling at a young age (when teenagers) and be addressed as part of the promotional activities need to recognise barriers to women and cycling. Only 30% of development control and women have daytime access to a car and the inadequate provision of accessible public consultation process, transport, walking and cycle routes will ensure that barriers to employment and although it should be noted participation in London life remain. Also, improvements to public transport, walking and that there are some good off- cycling provision as we propose is essential if car travel is to reduced in the Borough road cycle routes in Barnet. and pollution and congestion addressed. This is a key plank of environmental justice as it is often women and the poorer groups in society that are worst affected by pollution The Core Strategy has been and poor environmental conditions. subject to an Equalities Impact Assessment 4 9 Robert Newton CS9 Under the ninth bullet point insert a new sentence after the words “to travel by car.” that The priorities for S106 are None 3 Providing reads “We acknowledge that in many CPZ areas there are more parking permits issued clearly set out in the Core 6 effective and than parking spaces available and that new residential developments can exacerbate Strategy efficient travel the situation. Arrangements will therefore be made for residents of new developments (formerly CS not to be eligible for on-street parking permits or contract parking provision in car parks 8) managed by the Council and the Local Development Scheme will provide for the production of a Supplementary Planning Document to reinforce this policy.” Under bullet point 13, after the words “to be fully productive” add the words “and the The Core Strategy supports Council’s Economic Prosperity SPD will require Section 106 contributions towards a parking regime that workspace provision.” balances reducing car use Amend the wording of Paragraphs 14.1.1 to 14.10.2 where necessary to reflect these while recognising that many changes to Policy CS8. residents continue to travel by car. The DM policies DPD will provide more detail on Reason: To inhibit overspill on street parking and to provide opportunities for local car parking standards and employment that reduces the need to travel. policies for Barnet. The approach to the issuing of parking permits for new development reflects the strategy and that was agreed by Cabinet in 2004. 4 6 Zenda Green Mill Hill CS9 Policy CS8- Providing integrated and efficient travel (P72) requires greater detail on In line with national planning Publish 3 Preservation Providing promoting walking and cycling. Barnet is well endowed with green spaces, but greater policy guidance an Infrastructure 9 Society effective and investment is needed to maximise their potential for green travel. There is no map or infrastructure delivery plan Delivery Plan efficient travel plan to support these objectives. There should be grater detail on the improvements to will be produced which will (formerly CS public transport provision, particularly in the key areas of growth. For example to make provide detail on what 8) Mill Hill East AAP work there will need to be more explicit commitment to investment at infrastructure will be Mill Hill East Northern Line, beyond simply improving access. provided and where including open spaces and public transport. For regeneration areas information on walking and cycling proposals and schemes are published in the Brent Cross Cricklewood planning application or included in the relevant Area 281 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Action Plan. 4 8 British Library CS9 The BL is supportive of integrated and efficient travel. The BL notes that Barnet is keen We welcome this support None 4 Providing to see the concentration of growth in accessible locations where there are opportunities 2 effective and for redevelopment. The BL is therefore pleased to note that their earlier comments to efficient travel the Core Strategy Issues and Options Paper have been taken on board and that the (formerly CS new public transport interchange has been recognised in the Core Strategy Direction of 8) Travel Colindale Growth Area section (page 26 and 27). This transport interchange near the Colindale tube station will encourage multi-modal transport links and support a sustainable transport strategy, supporting higher density uses in accordance with PPS1 and PPS3 which notes that growth can be planned and directed to sustainable locations to minimise the need for new infrastructure. The BL is pleased to note that transport choice is a key part of Policy CS8. The BL is pleased to see the delivery of high quality transport provision especially improvements to rail services in the borough including upgrades to the Northern Line, Thames link and bus enhancements. The BL site is located close to the Colindale Northern line station which contributes to the sustainable location of the site and as such the BL support the improvement to the existing tube station together with improvements to additional bus services.
4 2 Cedric Issac CS9 20 miles per hour on all residential areas, starting as a priority in Glendale Avenue. Such a proposal is beyond None 4 Providing the scope of the Core 4 effective and Strategy. Setting borough efficient travel wide speed limits is more of (formerly CS an issue for the Transport 8) LIP. 4 4 Joanne Woodward London CS9 Paragraph 14.3.1 – LB Enfield supports LB Barnet’s comment that improvements are We welcome this support. None 4 Borough of Providing also required on strategic road networks, particularly the A406 (North Circular Road). This can be explored as part 5 Enfield effective and This is consistent with LB Enfield’s Core Strategy and we would like to explore of cross boundary working efficient travel opportunities for cross boundary consideration of transport improvements, particularly on the Infrastructure Delivery (formerly CS the road network. Plan and on Masterplans 8) and Area Action Plans. 4 2 Emma Ford London Fire and CS9 The LFB request that Barnet conduct regular Traffic Management meetings with other This is a detailed highways None 4 Emergency Providing partners and agencies during any regeneration schemes and whilst planning for any issue and not one that can 7 Planning effective and change to the road network. This is to ensure that access for emergency vehicles will be addressed by the Core Authority efficient travel not be compromised by future development to allow the LFB to continue to provide the Strategy. (formerly CS highest class service possible throughout the borough. 8) 4 4 Mike Dawson Finchley Society CS9 Barnet’s Core Strategy should first examine resources in Barnet, where there are Key management corridors None 5 Providing existing problems with infrastructure, then see where it is possible to create sustainable and congestion hotspot road 5 effective and development and how to resolve existing problems. New flatted development in areas junctions have and continue efficient travel with a controlled parking zone should be denied a parking permit. to be examined. (formerly CS Opportunities are and will be 8) taken to address pinchpoints through providing improvements as part of development and regeneration schemes, such as at the M1 / A406 / A5 Staples Corner interchange planned to be improved as part of Brent Cross Cricklewood. Capacity is 282 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations expected to be improved by TfL on the Northern Line and by Network Rail on the Thameslink route. Regarding the parking permit issue please see response at 436/9
4 1 Mike Dawson Finchley Society CS9 Barnet Council acknowledges traffic blockages; particularly around the A.406 and that The regeneration schemes None 5 1 Providing Town Centres are critical to the social, economic and environmental well-being of the are supported by Transport 5 effective and borough. Yet they plan a huge increase in Brent Cross Shopping Centre, which will Assessments which efficient travel threaten the existence other Town Centres, which, demonstrate that adequate (formerly CS “…are critical to the social, economic and environmental well-being of the borough…”. mitigation is proposed in 8) A similar contradiction exists with traffic congestion. Barnet Council acknowledges order to enable the traffic blockages, notably in the area where the majority of regeneration and new development to proceed. At housing is planned (Brent Cross/Cricklewood and A.5 Corridor). Brent Cross Cricklewood a Approximately 50% of working people travel to work by car. With extra non-work related number of junction car use, such as the school run, in such a congested area this is not sustainable improvements along the A5 development. and A406 are included as 'One emphasis is on the need to improve connectivity within outer-London, especially part of the regeneration orbital routes. We do not see planning for this in the Core Strategy, other than ‘seeking scheme. a network of ‘express’ bus services The School Run is recognised as an issue, and our Policy of taking a comprehensive approach to the school run is aimed at addressing this.
In line with national planning policy guidance an infrastructure delivery plan will be produced which will provide detail on what infrastructure will be provided and where. It should be noted that there are a number of new and improved bus services proposed in the regeneration areas, including at Brent Cross Cricklewood where several orbital bus routes will be improved and others created.
283 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Mike Dawson Finchley Society CS9 Radial underground routes are already overloaded and the road network, particularly The current TfL Business Publish 5 2 Providing on orbital routes. A 16% increase in homes is expected by 2026. If dependency on car Plan includes improvements Infrastructure 5 effective and use is to reduce public transport must be dramatically improved to cater for both 16% which are expected to yield a Delivery Plan efficient travel increase in population plus those current car uses that are expected to switch to 20% increase in capacity on (formerly CS public/other modes of transport. We do not see the required increase in provision of the Northern Line in Barnet. 8) public transport in DoT.'The London element of the corridor is currently projected to The TfL Business Plan also deliver approximately 100,000 new jobs to 2026. With Brent Cross - Cricklewood this contains an interim will bring huge increases in demand for both public transport and car use. Public improvement scheme transport and traffic are already congested, particularly traffic. DoT fails to show how proposed for Henlys Corner, these expected increases in congestion will be accommodated. although in the longer term the council is seeking a major improvement at this junction, and at Golders Green Road. Other major improvements to the North Circular Road are proposed as part of the Brent Cross Cricklewood Regeneration scheme. Also, please see response at 456/2 In line with national planning policy guidance an infrastructure delivery plan will be produced which will provide detail on what infrastructure will be provided and where. A detailed Transport Assessment has been produced as part of the Brent Cross Cricklewood regeneration scheme which includes an analysis of existing conditions as well as those predicted as a result of the phased delivery of the scheme, including appropriate levels of transport mitigation thus ensuring that scheme impacts can be accommodated by the transport system.
284 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Mike Dawson Finchley Society CS9 DoT accepts existing transport issues, both public and private and gives its transport Please see response to Publish 5 1 Providing priorities as: 455/12. Infrastructure 5 effective and • reducing the need to travel; Delivery Plan efficient travel • promoting transport choice; The transport analysis work (formerly CS • more environmentally friendly transport networks; undertaken as part of the 8) • ensuring more efficient use of the local road network; development of the • delivery of high quality transport provision approved Mill Hill East Area As priorities they are fine. What is lacking in some of the priorities cited above and Action Plan confirmed that Policy CS 8, is the ability to materially change or improve the situation. Travel plans 2,000 residential units could and ‘managing’ parking schemes will help, but the major traffic generation of Brent be accommodated on the Cross can only increase significantly with the centre’s expansion. site. The council is working Mill Hill East is a growth area designated for some 2,350 new homes. Roads from this with TfL and the developer area do not allow designated priority bus routes to be operated. All buses have to use for the site to plan for a the already congested roads resulting in the inability to significantly improve bus number of bus routes to be services. Northern Line trains have little spare capacity. Some future residents may well diverted so they run through be employed within the growth areas the area. Please see response to 455/12 regarding the Northern Line capacity.
4 1 Patrick Blake Highways CS9 To manage housing growth to meet housing aspirations The key development sites None 5 Agency Providing As stated in our response to the CS Issues and Options consultation, as part of a across Barnet are focused 6 effective and package of measures contributing to a reduction in the need to travel, it is on the west of the borough, efficient travel recommended that the CS should seek to deliver a balanced provision of housing, so there is an inevitable (formerly CS employment and services. As such, the HA are supportive of measures which would imbalance in terms of 8) seek to not only spread housing growth across the borough, but also seek to address housing growth. The any present imbalances. This would ensure that the needs of residents can be met development sites form part locally and in turn limit the need to travel beyond Barnet on already congested sections of the London-Luton corridor, of the SRN. This approach would help to reduce the need to travel, in line with the as acknowledged in recent objectives of PPG13 and will help ensure that the CS is in line with national policy and pan-London Mayoral hence sound by PPS12 (2008). The HA acknowledges that further detail on the strategies. In addition, all boroughs approach to mixed use development will be set out in the Development regeneration schemes and Management DPD while specific sites identified for mixed use will be specified in the associated major Site Allocations DPD. The HA look forward to being consulted join the two documents applications are carefully in due course. investigated, through the development of Area Action Plans and detailed transport assessments for example, to ensure that the impacts are mitigated against as far as possible. The emphasis is on ensuring that development is of mixed usage, thus helping to reduce the number and distance of associated trips by providing everyday service and facilities close to where people live.
285 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Patrick Blake Highways CS9 To reduce the need to travel - the HA notes that the above objective recognises the The transport section of the Revise CS9 5 Agency Providing private car as an important means of travel. We would therefore like to reiterate our LDF Core Strategy has been and 6 effective and previous comments stating that the HA is particularly keen to ensure that LBB's CS will reviewed, and provides a supporting efficient travel not result in a lengthening and greater number of car-based journeys on the SRN. This detailed and strengthened text (formerly CS would directly contradict the principles in PPG13 and DfT Circular 02/2007 (Planning commentary on how the 8) and the Strategic Road Network). Council is seeking to provide In order to ensure that the document is in line with the PPS12 requirement for a sound effective and efficient travel, CS to follow national policy, the HA would recommend that the 'reduce the need to as summarised in Policy travel' core objective is reworded thus: CS9. However, given "To keep Barnet moving in a sustainable way, to provide choice and modal shift by Barnet’s location as an outer encouraging and facilitating the use of convenient and reliable sustainable transport. To London borough, and the promote sustainable travel modes and reduce the need to travel, locating development growth being planned for, it in appropriate locations and promoting home working and new technologies." is inevitable that there will, to an extent, be an increase in traffic levels on the road network, as was acknowledged in the recent work of the Outer London Commission.
286 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Patrick Blake Highways CS9 The HA remains concerned that the emphasis of the CS is focussed on car usage and It is not clear what costly Revise CS9 5 Agency Providing does not have sufficient priority to encouraging sustainable modes of transport. road infrastructure schemes and 6 effective and Although travel by car is likely to remain an important modal choice within the Barnet are being referred to. The supporting efficient travel area, it is important that an emphasis is placed on the provision and improvement of HA have been involved as a text (formerly CS sustainable transport infrastructure and that these modes are considered first, stakeholder in our major 8) particularly where high trip-generating developments such as offices and retail are regeneration schemes, proposed. In line with the DfT's Guidance on Transport Assessment (2007), this including at BXC, and party emphasis will assist in mitigating potential increases in private vehicle trips. As such to both the modelling work sustainable travel measures should be prioritised for localised increases in road that supports BXC and the capacity. The implementation of costly road infrastructure schemes would not be in line outputs. Our position is that with national policy and hence PPS12 (2008). to prioritise other modes The HA is pleased that the CS proposes to improve facilities for walking and cycling over car travel in a blanket across the borough. In particular these should seek to integrate walking and cycling way is unrealistic. We improvements with the sustainable transport network as a whole. This approach would consider that a more help to promote the use of sustainable models in line with PPG13 and hence PPS12 balanced approach that (2008). Additionally the HA welcomes proposals which include improvements to public considers each development transport facilities that will increase the appeal of these sustainable travel options. on its own merits is more appropriate. Notwithstanding this, there are a range of improvements to all modes of transport proposed in the regeneration areas, including substantial public transport improvements at Brent Cross Cricklewood where there is a major regional shopping centre, and nearby at Wembley a national events venue, and the shopping centre in particular needs to be provided with appropriate transport infrastructure across all modes, including as part of a balanced package of transport measures a new and improved M1 junction 1.
287 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Patrick Blake Highways CS9 The HA is pleased that the policy CS8 highlights the need for developers to submit The Development Add footnote 5 Agency Providing travel plans as part of the planning applications process for significant trip generating Management DPD will on Transport 6 effective and developments. Travel plans should include measurable targets and a monitoring provide further policy on Assessment efficient travel strategy to ensure that the objectives of the plan are undertaken effectively once the parking standards and travel (formerly CS development is operational. In addition to the requirement of a Transport Assessment impacts. 8) for such developments, in line with the DfT's Guidance on Transport Assessment (2007). This will ensure that the CS fully aligns with national policy and hence PPS12 (2008). The HA is also pleased that the Policy CS8 gives consideration to the implementation of car sharing schemes for new developments. These schemes should be included in a Travel Plan as part of the planning application process. It is noted that Policy CS8 proposes to manage a parking regime which recognises that many of Barnet's residents will continue to travel by car. As previously stated the HA recommends that maximum parking standards are reduced in areas with good access to public transport, and should not exceed those set out in Annex 4 of the London Plan. This would be consistent with the recommendations of PP13 and would help to ensure that the strategy is in line with PPS12 (2008).
4 5 Patrick Blake Highways CS9 Given the increased emphasis on evidence-based plans in PPS12, it is considered that These comments are noted, None 5 Agency Providing a CS without an evidence base would not be justified and hence could be unsound and there are references 6 effective and based on criteria in PPS12. A recent guidance note by the Planning Inspectorate throughout the transport efficient travel entitled "Examining Development Plan Documents: Learning from Experience section to supporting data. (formerly CS (September 2009)" suggests that the most helpful approach is for evidence bases to be There has also been 8) clearly signposted throughout the DPD text, for example, by the use of footnotes. The extensive work carried out in HA therefore recommends that an evaluation of transport impacts of the local and wider connection with each growth road network is clearly referenced by the borough to demonstrate that the CS is and development area to deliverable in transport terms. support the relevant policy framework, as well as detailed work undertaken in support of each planning application through the transport assessments and travel plans. The LDF process is also being informed by the ongoing work of Transport for London on the Sub-Regional Transport Study, which, is looking at the cumulative impact of growth across the North London sub-region up to 2031
288 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Fiona Henderson CS9 I realise that the details of the core strategy are yet to be finalised. However, from The target for limiting traffic None 5 Providing notes I made on the LDF consultation paper, I would like to highlight the following; growth set in the current 8 effective and In relation to the London Plan (to which this document must comply); London Plan relate to the efficient travel • ‘There are policies relating to the reduction of traffic with a specific aim of reducing period 2001-2011 so is of (formerly CS growth in outer London by a third and zero growth in town centres by 2001-2011. (p3; limited relevance to the LDF 8) 2.1.9) core strategy. The draft Any development that relies on intensive car-use (such as a supermarket), in any town replacement London Plan centre, will have a negative impact on traffic. This does not, in turn, fulfil the objectives sets a target of Zero traffic of the UDP ‘to enhance the quality of the natural and built environment…..to sustain growth in central and inner local communities’ (p8; 2.13), nor is it in line with the aim of the London Plan to make London, and traffic growth in London a healthier place to live in. outer London reduced to no Finally, I would like to add that all this is against the background of the questionable more than 5 per cent. designation of New Barnet as a bona fide ‘town centre’ in the first place, but this is dealt Policies in the core strategy with in the standard letter I have already sent in. Please consider these comments as related to tackling the school additional to rather than separate from this letter. run, delivery of high quality transport systems in regeneration areas and more environmentally friendly transport networks will all contribute to this. Any development with a large scale transport impact will have to be supported by a Transport Assessment and Travel Plan to demonstrate compliance with policy, and to demonstrate that adequate mitigation is proposed prior to consent being given. We refer to our earlier response about New Barnet's designation as a district town centre. It is not a new designation. 4 1 David Howard Federation of CS9 Barnet’s roads will not be able to cope with the projected increase in the number of cars Infrastructure provision is a Publish 6 5 Residents Providing at the present rate of ownership per household. There is a presumption of mode shift key part of our policy on Infrastructure 4 Associations in effective and to public transport but no evidence of where the investment in public transport is effective and efficient travel. Delivery Plan Barnet (FORAB) efficient travel coming from. Without improvements the shift will not take place and Barnet will cease In line with national planning (formerly CS to be an attractive place to live especially with the preponderance of poor quality one policy guidance an 8) and two bed units. infrastructure delivery plan will be produced which will provide detail on what infrastructure will be provided and where. There are extensive proposals for both road and public transport improvements in Barnet that will help accommodate growth and continue to make the borough a successful place where people want to live 289 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations and work.
4 1 David Howard Federation of CS9 There are no plans to upgrade the mainline railways and the Bedford line in the west of The Mayors Transport None 6 6 Residents Providing the Borough is getting worse not better. TFL expressed concern at the Issues and Strategy contains 4 Associations in effective and Options stage about the need to phase growth to match improvements as the present information on which Barnet (FORAB) efficient travel transport infrastructure would not be able to cope. At the Colindale AAP enquiry TFL mainline railways are being (formerly CS officers said there are no proposals for further investment in the Northern Line after the upgraded. MTS includes 8) present works are complete. Phase 2: Northern line Upgrade 2 to deliver a further 20 per cent increase in capacity through the simplification and recasting of service patterns as a funded proposal for delivery in the period 2013-2020 4 1 David Howard Federation of CS9 Both Colindale and the Mill Hill AAPs assumed buses taking up the new demand. Transport Assessments None 6 7 Residents Providing Buses will be using the already overloaded and at peak times now gridlocked roads. have been carried out for the 4 Associations in effective and With more traffic the periods of gridlock will increase. East West public transport is three major growth areas in Barnet (FORAB) efficient travel infrequent, tortuous and totally inadequate actively encouraging car usage the borough, two of which (formerly CS have been adopted as Area 8) Action Plans. The AAPs included proposals to improve road junctions. TfL bus services are regularly reviewed and are considered adequate, and any gaps can be addressed as part of the network review. The Borough is supportive of reviewing and improving the bus network to encourage greater usage and will work with TfL to achieve this. Notwithstanding this, the 3 main existing east-west corridors across the borough – Totteridge Lane, Barnet Road/ Wood Street and Dollis Road are already well served by buses 4 2 Pauline McKinnell Cricklewood CS9 Should plan for less residents travelling by car. Please see responses None 6 9 Community Providing above, particularly 429/6 7 Forum effective and efficient travel (formerly CS 8)
290 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Pauline McKinnell Cricklewood CS9 Agree to some of these but don't want a new station at Staples Corner because this will An infrastructure delivery Publish 6 2 Community Providing detract form Cricklewood Station. Also don't want a bus that only stops at some stops plan setting out the where, Infrastructure 7 Forum effective and e.g.. Rapid transit service. when, what and how of Delivery Plan efficient travel infrastructure delivery will (formerly CS accompany the publication 8) version of the Core Strategy. The location of bus stops and the services using them are a matter of detailed design, although a comprehensive range of bus service improvements are proposed at Brent Cross Cricklewood. The proposed new station on the Midland Mainline at Brent Cross will be designed to be compatible with the new 12 car trains being introduced as part of the Thameslink upgrade. The new station is being designed to work alongside the existing station at Cricklewood, which is also being invested in as part of the Regeneration scheme. Local stopping trains will continue to call at Cricklewood station, with the new longer fast trains stopping at Brent Cross 4 1 Government CS9 Policy CS8 (Transport) identifies key transport infrastructure proposals. The Core Agree Revise CS9 7 2 Office for Providing Strategy or the Infrastructure Delivery Plan will need to demonstrate that any key and publish 0 London effective and infrastructure requirements are deliverable. Highlights of and appropriate references to Infrastructure efficient travel Barnet’s Infrastructure Delivery Plan should be brought into key areas of the Core Delivery Plan (formerly CS Strategy. 8) 4 1 David Howard New Barnet CS9 4.10.1 Makes the point that orbital transport is poor therefore car usage is inevitable. Infrastructure provision is a None 7 7 Community Providing Why therefore is growth still being promoted before the transport issues have been key part of our policy on 1 Association effective and addressed? Why no consideration of a rapid transit or light railway network to link the effective and efficient travel. efficient travel growth areas with existing underground and main line railways across the borough? Transport Assessments for (formerly CS There is no joined up thinking just an obsession with more housing flats, less desirable developments and 8) areas and gridlock. regeneration schemes ensure that the transport issues associated with the proposed growth are fully addressed. We highlight that TFL is a key partner in delivering infrastructure. Please see response at 416/7 on light rail scheme
291 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Andrew Newby Barnet Green CS9 The parking regime should actively discourage people from travelling by car where The Core Strategy supports None 7 7 Party Providing public transport alternatives are satisfactory, e.g. Brent Cross a parking regime that 7 effective and balances reducing car use efficient travel while recognising that many (formerly CS residents continue to travel 8) by car. At Brent Cross Cricklewood the Framework Travel Plan sets out target mode splits, and the parking regime will need to be managed to ensure these are met.
Please also see responses at 429/6 and 456/2 4 3 Andrew Newby Barnet Green CS9 Scrapping of clause (h). Instead of increasing road capacity a congestion charge Please see response at None 7 0 Party Providing should be introduced in any bottleneck areas. New clause: development of a direct light 416/7 on light rail scheme 7 effective and rail link to Brent Cross shopping mall, at the developer's expense efficient travel (formerly CS 8) 4 2 Steven Deller CS9 Transport partners say they have no money for this An infrastructure delivery Publish 7 6 Providing plan setting out the where, Infrastructure 8 effective and when, what and how of Delivery Plan efficient travel infrastructure delivery will (formerly CS accompany the publication 8) version of the Core Strategy. 4 2 Maria Nash Barnet Women's CS9 Double Taxi Card swipes for disabled people Capital Cabs in Barnet Freedom Pass These are specific transport None 8 7 Design Group Providing retained for all Regular West - East & East - West bus network Disabled parking bays issues that should be 3 effective and which have hatching on either side to be available for wheelchair user’s at all public addressed by the review of efficient travel places. Include making all pavements accessible for wheelchairs by having dropped the Transport Local (formerly CS curbs at each corner and enforce fines or towing away vehicles that park across Implementation Plan. 8) dropped curbs. 4 2 Maria Nash Barnet Women's CS9 Ensure that all people with different physical, sensory and neurodiverse conditions are As part of our extensive None 8 9 Design Group Providing consulted on all this engagement on the LDF we 3 effective and seek to ensure that efficient travel representative groups such (formerly CS as Disabled Action Barnet 8) and the Barnet Mental Health Network have the opportunity to participate in the process on behalf of people with such conditions. 4 3 Maria Nash Barnet Women's CS9 This should be rolled out to all areas not only new developments It is through new None 8 0 Design Group Providing development that the 3 effective and planning system can make efficient travel this change happen. (formerly CS 8)
292 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Maria Nash Barnet Women's CS9 Create support groups to assist 'working from home' self employed people to prevent Self employed people are None 8 1 Design Group Providing isolation and depression capable of forming their own 3 effective and support groups without the efficient travel Council's help. (formerly CS 8) 4 3 Maria Nash Barnet Women's CS9 All transport at tube and train stations and bus stops need to be step free and For step free access please None 8 2 Design Group Providing accessible to wheelchair users All pavements to have dropped curbs at all corners see response at 433/7. All 3 effective and Accessible transport of buses across Barnet from West - East and East - West not only buses serving Barnet efficient travel North - South or South - North Make all shops wheelchair accessible everywhere in (including east-west) are (formerly CS Barnet to enable wheelchair users and other physically impaired people to shop locally fully accessible, and any 8) and not have to travel to do their shopping new bus stops must be compliant with the latest accessibility standards. The Council can only influence accessibility through the development control process, not retrospectively impose current standards on existing businesses. 4 4 Maria Nash Barnet Women's CS9 Transport in the past and at present is pathetic in Barnet Local people should have a Engagement with young None 8 9 Design Group Providing voice and not only council officers or elected members Disabled people with all types of people and disabled people 3 effective and impairments are not being included in your consultations Nor are young people who's by the Planning Service is an efficient travel future we are planning have enough input issue best addressed by the (formerly CS review of the Statement of 8) Community Involvement. 4 2 Michael Storey CS9 Stop school runs - run door-to-door school buses instead. We emphasise that tackling None 8 5 Providing the school run through the 7 effective and use of School Travel Plans efficient travel in changing travel behaviour (formerly CS and reducing the number of 8) car trips is one of the key elements of delivering integrated and efficient travel in Barnet.. 4 2 Michael Storey CS9 I don't want you to turn the A110 (Cat Hill) from a residential road into a busy cross- Major thoroughfares are no Revise Key 8 8 Providing borough road. I don't want you to ruin New Barnet. longer promoted as Diagram 7 effective and opportunities for infill efficient travel development The A110 is a (formerly CS key part of the strategic road 8) network (SRN) in Barnet and is therefore of strategic significance and so is expected to accommodate through traffic 4 6 Glen Rollings Greater London CS9 The Core Strategy states that Barnet has high car ownership; TFL asks that this to be Car ownership within Barnet Section 4.10 8 Authority Providing set out as a percentage, and similarly, a percentage for public transport use should also is relatively high, with 73.3% has been 8 effective and be included. of households having access amended efficient travel to a car. accordingly.
293 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations (formerly CS The Core Strategy refers to orbital routes being less well served by public transport Even if demand is low it is 8) thus there is a reliance on private transport. This is accepted although there is no still a contributing factor to evidence to suggest high demand for such trips; TFL is currently looking at such trends there being a reliance on the as part of the North London Model and Transport Study. private car. We are working with TFL on the North London Modal and Transport Study but acknowledge the point, and there is less emphasis on orbital travel in the revised CS9. 4 7 Glen Rollings Greater London CS9 Paragraph 4.10.2 states that 39% in the borough and 42% outside the borough drive to The evidence base is the None 8 Authority Providing work. A further 66% drive into the borough. It is unclear what the evidence base is for 2001 census. 8 effective and these figures. TFL requires an evidence base to support these figures. efficient travel (formerly CS TFL would also encourage the Borough to have an aspiration to reverse these trends in The council is working 8) favour of public transport and mode shift in line with the Draft Transport Strategy towards a mode shift to (5.22.2) to deliver a mode shift to public transport. public transport, in the regeneration areas and through the processing of major planning applications. Barnet supports the current upgrade of the Northern Line and the Thameslink improvements. 4 9 Glen Rollings Greater London CS9 Bullet point 4, under section 6.2.1 states that “to keep Barnet moving in a sustainable Please see above Revise 8 Authority Providing way which provides choice by encouraging the use of convenient, reliable and responses, particularly 429/6 supporting 8 effective and affordable transport including the private car”. Reducing the need to travel and text to CS9 efficient travel encouraging sustainable travel should not include promotion of the private car; (formerly CS emphasis should be put on walking and cycling and the availability of facilities such as 8) work closer to home.
In addition, bullet point 6 should recognise walking and cycling as a way of promoting Walking and cycling are healthy living. widely acknowledged to improve health, but this does not need to be highlighted in this section. Reference is made in the Core Strategy section on Improving Health and Well Being 4 1 Glen Rollings Greater London CS9 Under the Ambitions: ‘Keep Barnet moving’, ‘Clean and green’ and ‘Improving health More walking, cycling and None 8 0 Authority Providing and well-being’ the Core Strategy Objectives should all include the promotion of public public transport use is being 8 effective and transport, walking and cycling in order to promote sustainable and healthy modes of planned for. Please see efficient travel transport. above responses, (formerly CS particularly 429/6 8)
294 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Glen Rollings Greater London CS9 TFL would like to see the inclusion of additional text under Policy CS.4 –Promoting Policy CS6 refers to seeking None 8 2 Authority Providing Barnet’s town centres, to state that the council will “ensure high quality public transport, improvements to the public 8 effective and walking and cycling links and sufficient capacity recognising the needs of all users”. transport network and efficient travel pedestrian/cycling (formerly CS accessibility. This is a 8) borough wide aspiration and not just for town centres. The council is seeking to improve transport capacity in our town centres, where feasible and practicable. 4 3 Glen Rollings Greater London CS9 TFL considers that the Core Strategy has omitted a policy pertaining to integrated and Effective and efficient travel Revise 8 3 Authority Providing efficient travel. TFL recommends there is text on assessing the impact of development is covered throughout supporting 8 effective and through transport assessments, travel plans, cumulative impact of development, the section 14, and the text has text to CS9 efficient travel need for s106 contributions and mitigation of transport impacts as the result of new been updated to incorporate (formerly CS developments in accordance with London Plan policies 3C.1 Integrating transport and TFL's representation 8) development, 3C.2 Matching development to transport capacity and policy 6.3 Assessing transport in the Consolidated draft replacement London Plan (October 2009). 4 3 Glen Rollings Greater London CS9 Paragraph 14.2.1 states that the car will remain the dominant transport mode in outer The car is recognised as Revise 8 4 Authority Providing London. It should be noted that this is inconsistent with the percentage of work based being a dominant mode of supporting 8 effective and journeys in the borough and the need to encourage mode shift to public transport, transport in the Mayor's text to CS9 efficient travel walking and cycling (see also London Travel Report). It is accepted that many parts of transport strategy and the (formerly CS the network are congested; however this should remain at current levels or in some work of the Outer London 8) cases may reduce. TFL would like to see this section changed in order to take into Commission. Growth in account the most up to date research. Barnet’s regeneration areas is being carefully planned, in conjunction with TfL, to help ensure that congestion does not deteriorate. 4 3 Glen Rollings Greater London CS9 Paragraph 14.3.1 refers to a priority to invest in orbital east-west links –TFL would like This paragraph has been None 8 5 Authority Providing clarification on whose priority this is. replaced, and references to 8 effective and 'Anticipated increases in traffic will require investment for access improvements and, as investment in orbital links efficient travel such, TFL recommends that the text should state that “developer contributions and have been removed from the (formerly CS government funding will be a priority”. text. We also highlight that 8) In this section, there is also a reference to the requirement for strategic road network securing all possible external improvements, in particular to the A406 (TLRN). It should be noted that the TFL funding is and will be a Business Plan (2009/10-2017/18) sets out that at Bounds Green works are “scheduled priority. We also clearly state for completion in May 2012; this project involves a number of safety and environmental that the improvements improvements along the A406 Telford Road, Bowes Road and North Circular Road outside of Brent Cross - between Bounds Green Road, Station Road and Chequers Way. A two-lane dual Cricklewood will happen carriageway will be created, pedestrian crossing facilities improved and a dedicated after 2018. cycleway provided”. Anything in addition to this is not currently funded.
295 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Glen Rollings Greater London CS9 Paragraph 14.3.2 sets out that investment is being pursued for A41 (TLRN). It should This paragraph has been Revise 8 6 Authority Providing be noted that there is currently no funding set out for A41 improvements in the TFL replaced, please see also supporting 8 effective and Business Plan (2009/10-2017/18). Any proposed improvements to the A41 will require 488/35 text to CS9 efficient travel justification through the ‘Infrastructure Delivery Plan’. (formerly CS It is accepted that significant assessment work has been undertaken to review the 8) growth areas of Mill Hill East, Colindale and Brent Cross Cricklewood which may impact on the road network.
4 3 Glen Rollings Greater London CS9 TFL welcomes the reference to cycle parking standards and electric vehicle charging Noted. References to the Revise 8 7 Authority Providing points. In addition, TFL would like to see a reference made to the ‘Cycle revised draft parking supporting 8 effective and Superhighways’ which will benefit the Borough via routes 11 and 12. standards have been text to CS9 efficient travel Paragraph 14.3.3 refers to the London Plan “parking regime” which will be introduced. updated. (formerly CS This reference should reflect the published draft “parking standards” in Table 6.1 and Barnet is keeping a watching 8) the “cycle parking standards” in Table 6.2 of the Consolidated draft replacement brief on the new Cycle London Plan (October 2009). Superhighways before deciding whether to support them. 4 3 Glen Rollings Greater London CS9 TFL would like to see the inclusion of additional text under paragraph 14.3.4 to state No addition is considered None 8 8 Authority Providing “car free, reduced car parking ratios and car clubs will be considered in locations with necessary as these are 8 effective and good public transport accessibility, for example town centres and strategic growth implicit in the flexibility of car efficient travel areas”. parking standards (formerly CS 8) 4 3 Glen Rollings Greater London CS9 Paragraph 14.5.1 discusses a realistic approach to infrastructure investment based on The document has been Revise 8 9 Authority Providing sound evidence. TFL would like to see the evidence base cross referenced within the revised to highlight the use supporting 8 effective and document. However, it believes the opposite is true: that town centres and growth of an evidence base text to CS9 efficient travel areas have high accessibility. including the Infrastructure Publish (formerly CS Delivery Plan. Further Infrastructure 8) evidence is being provided Delivery Plan through TFL's North London sub-regional Transport Study. 4 4 Glen Rollings Greater London CS9 TFL would like to see the inclusion of an additional bullet point under paragraph 14.5.3 As a suburban location , None 8 0 Authority Providing to include the transport priorities for “reducing the need to own and travel by car”. where it is acknowledged car 8 effective and travel will continue to efficient travel dominate, reducing car (formerly CS ownership is not a priority 8) that is supported locally, as the ability to move around by non-car modes is limited. Car travel is being addressed through mixed use development and parking policy, particularly in the regeneration areas. Travel plans as part of new developments will also contribute by the provision of electric vehicle charging points and car clubs
296 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Glen Rollings Greater London CS9 TFL would like to see the “emerging evidence base” cross referenced within the The document has been Revise CS9 8 1 Authority Providing document at paragraph 14.5.4. revised to highlight the use supporting 8 effective and of an evidence base text efficient travel including the Infrastructure Publish (formerly CS Delivery Plan. Further Infrastructure 8) evidence is being provided Delivery Plan through TFL's North London sub-regional Transport Study. 4 4 Glen Rollings Greater London CS9 At paragraph 14.6.2, a balance is required in the promotion of e-infrastructure, In the absence of robust Revise CS9 8 2 Authority Providing recognising that the promotion of online retail can also affect economic viability, in evidence on impact of e- supporting 8 effective and particular of local services, and this should be set out. infrastructure and its impact text efficient travel on town centres and flexible (formerly CS working this section has 8) Public transport is provided on a regular level of service and it is more difficult for it to been revised. react to informal travel patterns. In addition, increases in delivery vehicles as a result of Delivery and servicing are the promotion of e-commerce should also be accounted for in the transport assessment matters to be considered as of new developments. part of the development management process. 4 4 Glen Rollings Greater London CS9 TFL welcomes improvements to walking and cycling route set out in paragraph 14.7.1, The quickest routes for Revise CS9 8 3 Authority Providing however, on the main routes these should remain on the carriageway as they are more cyclists are generally along supporting 8 effective and convenient and provide the quicker journeys (e.g. Cycle Superhighways). the main roads in Barnet, text efficient travel which will not be appropriate (formerly CS for some cyclists and 8) therefore the Barnet cycle network includes off-road routes and those along quiet road links. See response 488/37 regarding Cycle Superhighways 4 4 Glen Rollings Greater London CS9 TFL welcomes reference to safety of the transport network set out in paragraph 14.7.3. We welcome this support. Revise CS9 8 4 Authority Providing The relevant section has supporting 8 effective and been updated and text efficient travel strengthened (formerly CS 8) 4 4 Glen Rollings Greater London CS9 TFL welcomes reference to electric vehicles set out in paragraph 14.8.1. We welcome this support None 8 5 Authority Providing 8 effective and efficient travel (formerly CS 8) 4 4 Glen Rollings Greater London CS9 Paragraph 14.10.1 refers to the station improvements that Barnet would like to see at We recognise that Revise CS9 8 6 Authority Providing Mill Hill East, Colindale, and Brent Cross - Cricklewood stations to accompany the congestion on the Northern supporting 8 effective and planned increases in density at these locations. TFL supports this comment, however, line increases towards text efficient travel would like to see further reference to the impact on congestion on the Northern line as central London, hence the (formerly CS well as at the stations. The Northern line is not crowded whilst it is in the borough of tube upgrades being delived 8) Barnet, but the impacts of new developments may lead to further congestion on the by TfL. It should be noted section of line though central London. that impacts on the Northern Line have been modelled and included in the BXC Transport Assessment, 297 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations prepared in full consultation with TfL. Station capacity has also been examined as part of the work on the Colindale AAP
To militate against the future congestion forecast on the Northern line, London Barnet is opposed to any Underground is upgrading the signalling, allowing an increase from 20/22 trains per future downgrading and hour (tph) to 24tph on the High Barnet and Edgware branches. There are further plans splitting of the Northern Line for partial separation of the Northern line (with Bank branch trains terminating at Morden and Charing Cross branch trains terminating at Kennington, and with Edgware and High Barnet trains serving both Bank and Charing Cross
TFL suggest that Barnet support for the Northern line upgrade and partial separation is The Borough does not included in the Core Strategy and that where developments are proposed that will have support the concept of a large impact on demand for Northern line services through central London, developer developer contributions for contributions are sought towards the cost of partial separation. This is particularly true the improvements TFL are for developments from which residents are likely to commute, given that 58% of people progressing. The council’s working outside Barnet travel by public transport. priority is to secure an efficient transport network in Barnet, such as step-free access schemes at the stations, and not to risk development viability by requesting contributions that we believe should be funded through the TFL Business Planning process 4 4 Glen Rollings Greater London CS9 TFL feels the wording of paragraph 14.11.1 should be reconsidered. The wording of the This option was discounted None 8 7 Authority Providing paragraph suggests that Barnet could not consider options that discourage the use of as part of the Direction of 8 effective and the private car without also aiming to discourage walking and cycling. This is Travel efficient travel inconsistent with the Mayor’s Transport Strategy which seeks to ‘Deliver a mode shift to (formerly CS public transport, cycling or walking instead of car use’, and a further mode shift to The Council does not 8) walking and cycling instead of public transport use (Draft Mayor’s Transport Strategy, consider that the use of the section 5.22.2). It is generally noted that Barnet could adopt a more progressive stance private car should be towards discouraging the use of the private car than is adopted in the Core Strategy, as discouraged, rather that has been suggested in the Core Strategies of other London boroughs (including those people should be free to in outer London). An increased focus on the importance of public transport provision in make their own travel Barnet (as opposed to the private car) would provide a stronger steer in planning choices. In the Regeneration decisions towards improving Barnet’s public transport in the future (including London areas there are proposals to Underground). improve all modes of transport. 4 4 Glen Rollings Greater London CS9 The core strategy refers to a review of bus services in the borough at Policy CS.8 and The supporting text for CS9 Revise CS9 8 8 Authority Providing paragraph 14.4.1, TFL feels it important that it is recognised this would be done in has been amended and 8 effective and partnership with TFL. The text “working with Transport for London” should be added accordingly supporting efficient travel here. text
298 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations (formerly CS It should be noted though that London Buses carries out a review of the bus network in We hope that TfL will change 8) London every five years, through a series of ‘tranches’ of routes loosely focused around its stance and be prepared specific areas, in consultation with boroughs, which enable evaluation of service to take a more flexible and changes in the context of the wider local network to take place, and therefore TFL pragmatic approach in the cannot justify additional review. future. As above the text has been re-worded to this effect Similarly under express services, the text ‘working with Transport for London’ should be We are no longer seeking a added network of express bus services 4 4 Glen Rollings Greater London CS9 TFL wishes to see the addition of the following points under Policy CS.8 in promoting Incorporated into CS 9 under Revise CS9 8 9 Authority Providing integrated and efficient travel within the borough: Delivery of high quality 8 effective and • step free access and the promotion of public transport provision that is accessible transport system in efficient travel regeneration areas (formerly CS • work with employers and developers to promote workplace and residential travel Travel plans are produced 8) plans as part of the transportation development control process, and some particularly progressive travel plans are being developed and implemented at Brent Cross Cricklewood and as part of the expansion of the Middlesex University Hendon campus. • use of car clubs and car free development See response to 488/38.
• a new bus station at Brent Cross and step free access at Underground stations e.g. New BXC bus station Mill Hill East, Colindale and Brent Cross incorporated into CS 9. For step free access please see 433/7. 4 5 Glen Rollings Greater London CS9 The initiatives outlined in Policy CS.8 associated with behaviour change initiatives and Notwithstanding the travel None 8 0 Authority Providing smarter choices should be supported by a specific SPD on Travel Plans and Smarter planning work associated 8 effective and Travel initiatives at a later date. with new developments the efficient travel Council is not supportive of a (formerly CS Smarter Travel Initiatives 8) SPD as it believes that people should be left to make up their own minds in terms of travel choices
4 6 Glen Rollings Greater London CS9 TFL would welcome a reference to coach facilities or taxi set down and pick up in the Please see additional text in Revise CS9 8 2 Authority Providing Core Strategy. Provisions for coaches and taxis at developments such as hotels, in section on making more and 8 effective and schools, tourist attractions and leisure venues are key to their operational success. In efficient use of the road supporting efficient travel addition to tourist/private hire coaches the importance of scheduled coach services, network. text (formerly CS providing direct national and airport links from the Golders Green and Brent Cross 8) areas, needs to be recognised. Ticket purchase data suggests that scheduled services are well used by Barnet residents.
299 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations P Save our CS9 Ensure that adequate investment in infrastructure such as public transport, doctors’ In line with national planning Publish et suburbs Providing surgeries and utility provision before approving new development. Stop the issuing of policy guidance an Infrastructure iti effective and on-street parking permits to occupiers of new developments infrastructure delivery plan Delivery Plan o efficient travel will be produced which will n (formerly CS provide detail on what 8) infrastructure will be provided and where. Contributions towards public transport improvements are secured for specific sites as mitigation against the impact of development. Doctors surgeries and utilities are not considered to be part of the Transport Strategy. The Core Strategy supports a parking regime that balances reducing car use while recognising that many residents continue to travel by car. The Development Management policies DPD will provide more detail on car parking standards and policies for Barnet. The approach to the issuing of parking permits for new development reflects the strategy and that was agreed by Cabinet in 2004. 2 9 Ian Dubber Workspace CS10 Workspace supports the development of community facilities and services such as The creative sector is Add new 4 Group PLC Integrated those that provide educational floorspace and leisure, culture and arts facilities. recognised as making a para 13.6.3 1 community Workspace also considers it important that the council recognises the diverse economic significant contribution to on creative facilities assets these facilities provide within the borough. Workspace has experienced an Barnet's economy. We industries (formerly increase in demand for artists and small cultural venues across London. These facilities recognise the demand for CS9) could be provided as part of mixed use developments. performance and exhibition space in the west of the borough. 2 3 Peter Storey Friern Village CS10 Religious schools divide the community not enhance it. Please see response at None 4 4 Residents Integrated 481/34 2 Association community facilities (formerly CS9)
300 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 1 Belsize Square CS10 The Council's existing UDP in Section 9 "Community Services) at 9.1.2 lists some The issue of providing burial None 9 Synagogue, Integrated relevant community facilities; it includes cemeteries. It is recognised by the authority spaces for London and 9 Liberal Judaism, community that the provision of such facilities can have an impact on the quality of people's lives addressing the needs of its West London facilities and can be important for the social and economic well being of the Borough. Further diverse communities is a Synagogue, (formerly into section 9 of the UDP specific reference is made to Cemeteries - paragraph 9.3.4.1 complex one which cannot Spanish and CS9) - 3 and policy CS15. be simply addressed by a Portuguese POLICY CS15 - Cemeteries and Crematoria? The Council will seek to identify borough acting alone. This (Sephardi) appropriate sites for cemeteries or crematoria to meet the needs of the community. was highlighted in Barnet’s UDP. The draft revised In the UDP the council will seek to ensure that adequate provision is made in Barnet to London Plan highlights that meet the burial needs of all sections of the boroughs community. As part of this there has not been an process, the council will liaise with the different religious communities in the borough to assessment of burial space determine their specific requirements and the demand for, and/or the availability of, in London for over 10 years reserved burial spaces. The Council will, in conjunction with other authorities and the and it is clear that the Mayor GLA seek to identify sites to meet those needs. has to work with boroughs and cemetery providers to The need for burial space for the Jewish communities of north London remains and has establish what is the current not been met. The Core Strategy Direction of Travel November draft fails to follow situation with regard to through from the UDP to meet this important need. My clients therefore recommend supply. This assessment that a short introductory paragraph in Section 15 "Enabling Integrated Community should look at barriers to Facilities and Use" be inserted highlighting the need for burial space and the specific supply including the re-use requirements of the Jewish communities (as currently exists in the UDP) and a new and reclamation of burial bullet point is added to Policy CS9 which should read as follows:- space. The LDF is an "The Council accept that there is a need for further burial facilities for local communities evidence based document and will therefore support further provision of such facilities to meet that need" and it is imperative that evidence is up to date. We My clients are currently pursuing a planning application to extend the existing understand that the Mayor Edgwarebury Cemetery. If approved and implemented this will meet the immediate and will commence work on this long term needs of four of the Jewish communities in North London. assessment in Summer 2010 The Core Strategy is not the appropriate document to identify burial sites. We are producing a Site Allocations document and opened two public periods of Site Suggestions in February 2010 and May 2010 for sites to come forward. Despite this information gathering exercise the applicants have not put forward a proposal for the extension to Edgwarebury Cemetery nor evidence to support such a proposal. The Infrastructure Delivery Plan sets out the what, where, when and how much of infrastructure delivery and is a key piece of supporting evidence for the LDF. The IDP highlights that we are 301 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations awaiting work by the Mayor on the provision of cemeteries and crematoria.
302 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 Julia Hines Age Concern CS10 We welcome the integrated use of community facilities, but also feel that older people Access by public transport is None 1 Integrated will benefit from facilities geared particularly for them. Older people have asked for an important consideration 8 community parking permits to allow them to use day centres and community facilities in residential for community facilities and it facilities areas where there are parking restrictions. In addition, these facilities should be easily is important that design of (formerly accessible by public transport. community facilities takes CS9) into account the range of users. 4 1 Julia Hines Age Concern CS10 We are concerned about the apparent lack of inclusion of facilities for older people The policy and supporting None 1 9 Integrated within the community hubs. We would like to see this as policy. text is not intending to 8 community We are concerned that there will be a policy to reduce day centres irrespective of a reduce support for facilities facilities proven demand and increasing elderly population, without any obvious alternatives to for older people. (formerly prevent the “four walls” problem that effects many isolated older people, both with and CS9) without cognitive impairment/ dementia. Reducing day centres may also have a negative impact on carers, many of whom are also older people.
4 2 Pam Edwards Barnet Borough CS10 On the first point, after “pools” change community” to read “community , arts and Multi-purpose community None 2 Arts Council Integrated tourism meeting places” hubs cover a range of 6 community On the third point on the next page “multi-purpose community hubs” should be activities and this could facilities amended to read “multi-purpose community, arts and tourism hubs”. include arts and tourism (formerly 'the insertion of the words “community, arts and tourism” after the words “multi- CS9) purpose” 'the insertion of the words “community, arts and tourism” after the words “demand for” and before “spaces”
4 5 Pam Edwards Barnet Borough CS10 While the Core Strategy comments on leisure centres, these are sports centres run by An additional sub section on New section 2 Arts Council Integrated Greenwich Leisure, each one tailored to the lay-outs for particular sports. We request Arts and Culture is included 15.5 on Arts 6 community that arts centres also be separately defined, as venues that are licensed for public in the Publication version of and Culture facilities performances are each unique and often specialised for particular art forms. While the Core Strategy (formerly there are many rooms suitable for use for clubs, classes, meetings and rehearsals, the CS9) spaces for public performance of theatre, dance, musical theatre and music are limited in number and mainly on the western side of the Borough. There is also a shortage of spaces for exhibitions and, while no licences are needed, open access is required to well lighted wall and floor spaces, and this does not always allow for sharing with other activities.
303 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Pam Edwards Barnet Borough CS10 Arts Centres The council does appreciate Add new 2 Arts Council Integrated The purpose-built arts depot at North Finchley has in its first 5 years established a the submission of this section 4.12 6 community strong programme of professional theatre, music and dance performances together information but considers it – Barnet and facilities with public exhibitions. It is accorded the status of an RFO (a Regularly Funded as too detailed for inclusion the arts, (formerly Organisation) by the Arts Council of England which enables it to then apply and receive in a higher level strategic culture and CS9) support from many trusts and other sources. There is a strong programme of document. Arts and Culture creative educational clubs and classes, and a third programme of professional artists working to do form a feature of this industry offer support and development to many disadvantaged groups across the Borough Core Strategy in recognition Para 11.9.6 through specialised projects. The larger auditorium seating just under 500 has an of the level of participation of supports adjustable floor that may either lie flat for conferences and dances, or be sloped with groups and the level of temporary re- seating, while the smaller studio seats about 150 in stepped tiers. The foyer, café and activity in the creative use of vacant art gallery act as a social centre and meeting place, a drawing room for the Borough. industry retail space Also in the building are Barnet College’s dance and theatre departments and The Core Strategy in town Community Focus offering clubs and classes that include many designed especially for recognises the contribution centres for disabled and elderly people. of groups to arts and cultural performance The whole building has excellent disabled access activities in Barnet and and creative Local music and theatre events requiring a Public Performance Licence highlights the demands for work While arts depot is acting as a regional centre, not only for the Borough but for much of exhibition and performance New section North London, a lively programme of 100 or more semi-professional and amateur space. The temporary re-use 15.5 on Arts groups meet, perform and exhibit in a variety of venues across the Borough. Orchestral of vacant retail space for and Culture and choral performances are mainly in places of worship which have large spaces with such uses is encouraged. facilities upgraded to cater for public performances, including St John the Baptist in We have highlighted the Barnet, Trinity Church in North Finchley, St John’s in Friern Barnet, St Judes and the importance of the schools Free Church in Hampstead Garden Suburb, All Saints in East Finchley, St Michaels in estate for performance Mill Hill and John Keble Church in Mill Hill. Alyth Synagogue and Henrietta Barnett space and cultural events. and Queen Elizabeth Whilst recognising its Amateur theatre performances are held in the specialised Incognito Theatre in Friern importance as a global event Barnet , The Bull Theatre in Barnet, All Saints Arts Centre in Whetstone, John Keble the Core Strategy has a 15 Church in Edgware, Finchley Methodist Church, Hartley Hall in Mill Hill, and Henrietta year life span starting in Barnet School and other venues. Standards are stimulated by BBAC’s annual Drama 2011 looking beyond the Competition where an adjudicator travels to review and assess member societies’ 2012 Olympics. performances, and the societies act as a training resource for young people. Since the professional programme at The Bull moved on into arts depot, The Bull is able to house a succession of weekly hires to amateur groups, as was intended when it was built as a
304 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations community arts centre. The seating for 150 in the air-conditioned upper auditorium is about to be upgraded, while the downstairs dance studio seats about 70. Daytime use is as a full time theatre school. Incognito’s theatre, which also has stepped seating, is completing fundraising to upgrade their building, as is the Phoenix Cinema The only spaces exempt from a licence for public performance are churches, and also schools so long as the event is for pupils & their families – if the pubic are to be admitted to performances then a licence is required. Pubs used to be able to have one or two live musicians performing (the ‘two in a bar rule’) but now have to have a performance licence and as this may involve building work it can be a deterrent. The Government is being lobbied to amend the Licensing Laws to reduce this requirement, as it is felt to be one of the factors leading to closure of so many pubs. Cafes and restaurants also need to be licensed for entertainment. Exhibition spaces Arts depot show mainly professional exhibitions, with some slots and spaces available for local artists. A new gallery will be opened at the rebuilt Barnet College in 2010. Temporary Art & Information Exhibitions are held by BBAC in shopping centres, libraries and at festivals. Local societies have to find venues that are open for a full week or two where no other events are being held (usually holiday weeks) such as Christ Church in Barnet and Hartley Hall in Mill Hill, and also at other times at Trinity Church, North Finchley. Church Farmhouse Museum in Hendon presents historical exhibitions and is not usually able to offer space to local artists. Arts facilities in developing areas There is the need for public performance and exhibition spaces on the western side of the Borough. These should be provided in conjunction with the large new estates being developed at Brent Cross and Colindale including open air venues. This has already been raised with the developers of Brent Cross, who have responded that they expect to provide these facilities in the schools that are to be rebuilt (a secondary and two primary schools) and in the open air squares in the town centre. This, with extended library facilities, would help to serve the social and arts needs of the new community. While the Brent Cross/Cricklewood development plan includes a multiplex cinema, there should however be further provision for live entertainment No doubt there is concern that a theatre would not be a commercial proposition, but given the vast car parks available in the evenings at Brent Cross and the associated restaurants and cafes, either already there or projected in the new development, there should be sufficient infrastructure to support an arts venue. We are advised that a venue seating more than 1100 should provide an income that would ensure it was commercially viable, and would ask that this possibility be explored. Management of multiple-use centres The creation of multiple use centres in schools does require that spaces and timetables are defined in advance and that staff are available to manage each specialised activity. Rather than leaving all these responsibilities to a school which mainly uses spaces in the daytime through term time, the school would then be required to book other evening/weekend/holiday spaces separately, while community events would similarly book space in the daytime with the school. Alternative community/arts/sports centres should be provided if this cannot be agreed Multiple use with libraries should also be considered and would supplement the timetable in schools which often have to provide space for examinations for weeks at a time. The specialised staff should also be responsible for the publicity of events. Design of multi-use performance and exhibition spaces To create spaces that work successfully for performances requires careful planning from the initial stages, as arts requirements need expert advice to incorporate the latest technology and the correct PA and acoustics for the size of the performance space. 305 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations The Building Schools for the Future insists that all Councils appoint a Design Champion to ensure creativity is at the heart of ‘Transformational Change’ in education through this building programme – a senior person within the client organisation advocating and monitoring good design with decision makers and the Project Team throughout the project. The design needs to incorporate facilities such as the ability to black out daylight, to provide comfortable seating (which may be rolled back to stack against walls to allow continued use of the flat floor), air-conditioning, good PA and lighting, stage areas with sprung floors and backstage space, and adjacent rooms suitable for use as foyer, café and dressing rooms. Outer walls should be of heavy materials to contain sound, to prevent complaints from adjoining property. Public performances can then present a high quality performance to an audience that is comfortably seated and will pay a good level of ticket prices to make the project viable and provide a good rental for the venue. While music performances can be for one night only, drama and musical theatre shows require a full week to set up their stage and with enough performances for groups to recover their royalty fees. Music and musical theatre is often best in large spaces, while theatre requires something more intimate. Exhibitions need clear runs of wall and floor space, good lighting and public access at all times, and are best in foyer spaces where staff are able to combine other duties with supervising the exhibition. If facilities are to be grouped in hubs these points have to be settled at the planning stage, including accessible car parking for audiences. Tourism in the borough As tourism can be an important element in the economy of local areas, the Strategy should seek to improve provision, particularly because of the impending impact of the Olympic Games, and arrangements should be made to distribute publicity on tourist attractions in the Borough as part of an ongoing programme. Finance Most arts groups in the Borough are self-financing, including Barnet Borough Arts Council, but have had the opportunity to apply for assistance for special projects to the Borough Council’s Small Grants Scheme (as have all community groups), and this facility should be continued. Separate financial support also should be continued to arts depot, as the Arts Council of England RFO grant and many other grants are dependent on support being provided by the local authority.
306 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 Pam Edwards Barnet Borough CS10 A STRATEGIC PARTNERSHIP has been developed between the Boroughs of Barnet, We refer to our previous Text to be 2 Arts Council Integrated Enfield and Haringey with the encouragement and support of the Arts Council of answer at 426/6. Creative amended as 6 community England, and a recently published Arts Map (enclosed) lists centres and facilities industries are recognised as set out at facilities across North London. a significant part of our local 426/6 (formerly Extracts below are from this comprehensive document which reviews existing facilities economy Add new CS9) and suggests expansion in the Borough of Enfield. See www.barnet.gov.uk We have carried out Core para 13.6.3 Some important POLICIES are listed within the Creative Arts Enfield document , as Strategy consultation at the on creative follows Issues and Options and industries ARTS COUNCIL ENGLAND develops and promotes arts and creative practice across Direction of Travel stage. England, acting as an independent body at arm’s length from Government. Between The Alternative Options were 2008 and 2011 they will invest over one billion pounds of public money from both the removed on the basis of the Government and the National Lottery to support arts organisations, individual artists Sustainability Appraisal and arts infrastructure. ACE believes that the arts have the power to change lives and
307 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations communities, and that active participation in arts activities can. Barnet, Haringey and Enfield Councils have come together in a partnership with financial assistance from the Arts Council of England, to develop marketing of the arts and creative industries in North London as part of the build up to the Olympic. This will help to focus efforts on promoting the arts, to encourage inward investment. Visit London report that there is likely to be an increased visitor market projected over the next few years due to the effects of the current recession and the likelihood that it may deepen over the next 18 months – 2 years. The Arts Council of England is also supporting various development initiatives across London such as “On The Map” which brings together theatres and arts centres in outer London boroughs to coordinate artistic projects and market the arts to Londoners and their visitors. With the 2012 Olympic Games we have an once-in-a-lifetime opportunity to enhance our cultural landscape, encourage even greater participation in arts and sports, and showcase our creativity to the rest of the world. That is why fenders must hold their nerve and keep supporting arts and cultural organisations in the current economic climate. The Cultural Olympiad will provide the build up and platform to reinvest and think more widely about the potential of events across the Borough and every neighbourhood should be encouraged to begin to plan and to celebrate what the Olympics means to them and what they hope to achieve by aiming high through the arts and creative industries. The Olympics will provide a sense of excitement and motivation that will inspire young people to try something new and strive to do their best. The Royal Society of Arts, Manufacture & Commerce (RSA) is doing a lot of work on social policy, community engagement, citizenship, youth engagement and the arts. The Society is developing a strain of work around the EU and social policy from which Enfield could benefit. The Society’s work with young people and social policy could help Enfield to look at our international links and build new partnerships locally to further the development of young areas. Visit London (the tourist agency for London) reports that London has been voted the best European city to visit. Over 15 million overseas visitors come to London each year – 5 million more than go to Paris or New York – together with 10 million domestic visitors and 150 million day trippers. On average 7 out of 10 of these visitors say that London’s cultural offer influenced their decision to visit. The London Development Agency, Visitor London and GLA (Greater London Authority) have reported significant growth in the arts and creative industries in London I raised this point at the public consultation at Chipping Barnet Library and was told that the decision not to include the Alternative Options was taken following a consultation held in the summer, but neither our organisation nor our member societies have been invited to comment on these points and were not included in the consultation.
308 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 Pam Edwards Barnet Borough CS10 We feel that there are bound to be the need at times in the future to adjust the use and The Direction of Travel has Publish 2 Arts Council Integrated location of buildings and their programmes for community and arts use. We entirely set out Barnet's preferred Infrastructure 6 community agree with the sentence that “Community facilities cannot compete financially on the approach and the reasons Delivery Plan facilities open market against higher land use values such as housing or offices.” why alternative options have (formerly For this reason we think that the alternative options should continue to be incorporated been discounted. CS9) in the Core Strategy. In the first option the word “and” should be inserted between “Allow” and “Protect” . The lack of performance The strategies are particularly relevant to buildings used for public performances. space is recognised in the Whereas meetings can be held in a variety of rooms and spaces, performances require Core Strategy and as part of a public licence and can be as specialised for the arts as they are for particular sports. the Infrastructure Delivery Therefore existing assets should be protected by the Borough Council strategies unless Plan. it can be demonstrated that they are no longer required or will be provided elsewhere. While new facilities may be encouraged in hubs there is such a variety of buildings already scattered across the Borough where events are successfully presented, we believe they should be allowed and encouraged to develop where they are. Many of the venues have themselves already evolved into local hubs, particularly places of worship that usually have a hall and sometimes a school attached.
4 9 Pam Edwards Barnet Borough CS10 The possibility of an arts venue at Brent Cross to be explored Provision has been made in None 2 Arts Council Integrated the outline application for 6 community 1,000sqm for multi-use facilities community space in two (formerly locations (2,000 in total). It is CS9) intended that this is co- located with other community space such as education, health or library therefore any venue will be multi-use space. This space is identified for general community use, faith provision, access to information technology and arts and cultural use. There will be scope via a Planning Obligation at the detailed design stage for the public squares and open spaces to consider outdoor performance space and art in the public realm.
309 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Pam Edwards Barnet Borough CS10 There is no reference to local festivals, and it would appear that these are not included We recognise the Add 2 0 Arts Council Integrated in the Open Space, Sport and Recreational Facilities Needs Assessment. Festivals can importance of festivals to the reference to 6 community greatly improve the quality of life in their area, involving many local people and community and the use of festivals in facilities stimulating community cohesion in a neighbourhood. The Borough Council arranges open spaces. An additional open spaces (formerly for annual licensing for public performance in particular parks. The events in green sub section on Arts and in para CS9) spaces can be small and simple or can require a great deal of equipment to arrange Culture will be included in 12.1.6 performances on stage, with marquees and stalls for charities, crafts and community the Publication version of the groups, and also act as a showcase for commercial companies. They would benefit Core Strategy from upgrading of pavilions, toilet facilities and good access. The attendance can be anything up to 20,000 people, and the usual addition of a funfair is popular and helps to finance the events. More festivals in green spaces could be developed in the Borough. The usual annual programme in includes Late June East Finchley Festival in Cherry Tree Park N2 Early July East Barnet Festival in Oak Hill Park, EN4 see www.eastbarnetfetival.org.uk Mid July Finchley Pentland Community Festival, N3 Mid August Friern Barnet Summer Show N10/N11/N12 September Watling Festival in Montrose Park HA8 Grahame Park Festival, NW9 Also on June-August weekends Theatre in the Park in Oak Hill Park EN4 June & July Open air theatre in Little Oak Wood NW11 by Garden Suburb Theatre 1st Sunday December Barnet Christmas High Street Fair 'Please insert the words “and festival” after “sports” in the third point on securing improvements. 'Please add the words “community, arts and tourism” after the word “multi-purpose”. 'Please insert the words “community, arts and tourism” after the words “demand for” and before “spaces”.
4 1 Roger Tichborne CS10 Please amend the first paragraph as follows...The Council will work with our partners to World class is a subjective None 3 Integrated ensure that world class community facilities including schools, libraries, sports centres criteria and not a recognised 5 community and pools, community meeting places and facilities for younger and older people, are standard. facilities provided for Barnet’s communities (formerly CS9)
310 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Roger Tichborne CS10 I believe that the subject of provision of sports facilities is not addressed adequately by The Site Allocations DPD is Publish 3 Integrated this document, warranting a mere 3 paragraphs. That is a scandal for a Borough of the appropriate document for Infrastructure 5 community 330,000 people. I would specifically suggest that the following are written into the plan site specific considerations Delivery Plan facilities :- such as any improvement at (formerly a) Restore Pavilion Road playing fields as a proper sports facility, b) Protect by law all Copthall. CS9) playing fields in the Borough of Barnet c) Upgrade Copthall Swimming pool to have an Olympic standard 50 meter pool, to The Core Strategy is a allow our young swimmers to compete on an even footing with other clubs. Barnet is strategic document which the 9th Largest authority in the Country and there is not a single 50m pool. clearly identifies sport d) Install an Olympic specification diving board at Copthall Pool. It is ridiculous that our facilities as part of the athletes have to travel to Crystal Palace to train. infrastructure requirement to e) Place a legal requirement on the council to maintain all sports pitches to the highest support growth. We are standard. Many youngsters are missing vital exercise due to poorly maintained Council preparing a playing pitch Facilities. strategy which will follow f) Renovate Copthall Stadium sport England's guidance and will guide future provision of and management of such facilities See our response at 432/3 on the Leisure Facilities Strategy
Setting rents for the next 100 years is not realistic and is not a matter within the remit of the LDF. 4 1 Warren Forsyth Middlesex CS10 The University supports Policy CS 9 - Enabling Integrated Community Facilities and Policy CS 10 highlights None 4 1 University Integrated Uses and suggests that a further bullet point be added along the lines: “work in partnership working already 1 community partnership with Middlesex University and other further and higher education providers so an additional reference is facilities to facilitate the improvement of leisure and recreational facilities for joint or shared not merited (formerly educational and community usage.” CS9)
311 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 Metropolitan CS10 This policy deals with the provisions of community facilities. The MPA requested within Both health and safety are None 4 Police Authority Integrated their previous representations that policing facilities should be referred to within this addressed as separate Core 3 community section. Unfortunately this was not taken on board and the MPA would therefore like to Strategy policies and in facilities reiterate the importance of policing facilities being recognised as a community facility these sections we make it (formerly and the need to ensure that double counting of replacement community facilities does clear how we support the CS9) not occur. policies of our partners. A The MPA recommend amendments to this policy to ensure this aspect of the emerging separate reference in CS9 is Development Management Policy document is consistent with Policy 3A.18 of the therefore not required. London Plan. This included police facilities within the definition of 'community facilities' and states that the net loss of community facilities must be resisted. Furthermore, several London Borough's have made amendments to their emerging planning policy to support this approach, these include Policy C2 of Greenwich's UDP (adopted 2006) and Policy CK1 (section c, iii) of the Royal Borough of Kensington and Chelsea (emerging). Recommendation: The MPA suggest that the wording to this paragraph be changed to read - the council will work with our partners to ensure that community facilities including schools, policing facilities, libraries, leisure centres and pllos, community meeting places and facilities for younger and older people are provided for Barnet's communities. We will: - resist any development that would lead to a net loss of community facilities. Replacement community facilities elsewhere in the borough will be acceptable in line with a current strategy for reprovision.
4 1 Her Majesty's CS10 The thrust of this Policy, which is reflected in the Strategic Objectives (page 20), is We seek community facilities None 5 Court Service Integrated generally supported. We support the retention and enhancement of existing community that are capable at being 3 (HMCS). community facilities, as well as the expectation of appropriate contributions from development used efficiently and are facilities towards improving existing provision. However, it is our experience that whilst schools integrated with other uses. (formerly and health care services are typically addressed as part of community and Criminal courts by virtue of CS9) infrastructure needs, the role that the courts play in the community is often overlooked. their explicit function are not We therefore suggest the following amendment to Policy CS9: flexible community facilities. "The Council will work with our partners to ensure that community facilities including schools, libraries, leisure centres and pools, community meeting places, criminal justice facilities, and facilities for younger and older people, are provided for Barnet's communities." For consistency purposes, we also suggest that the following amendment be made to supporting paragraph 15.1.2: "Many community services and facilities are provided by our partners such as Barnet College, Barnet Voluntary Service Council, the Metropolitan Police, and Her Majesty's Court Service." 4 3 Mike Dawson Finchley Society CS10 We support these policies. Community facilities within town centres are particularly We welcome this support None 5 2 Integrated useful, offering a sustainable facility to the surrounding community. 5 community facilities (formerly CS9) 4 1 Robert Goymour CS10 And ask Barnet Council to include some specific targets for developing new leisure The wording proposed is Publish 6 Integrated facilities so that the Council and its partners can then be held to account. inappropriate for a strategic Infrastructure
312 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 1 community The word “adequate” should be added to Policy CS9 first line. It should then read: “The document. Adequate is Delivery Plan facilities Council will work with our partners to ensure that adequate community facilities subjective. In line with (formerly including schools, libraries, leisure centres and pools, community meeting places and national planning policy CS9) facilities for younger and older people, are provided for Barnet’s communities.” guidance an infrastructure delivery plan will be produced which will provide detail on what infrastructure will be provided and where. 4 3 Andrew Newby Barnet Green CS10 The Green Party does not believe that the state should provide funding or other Please see response at None 7 3 Party Integrated assistance to religious schools. 481/34 7 community facilities (formerly CS9) 4 2 Steven Deller CS10 Religious discrimination should no be supported in any aspect of community life Please see response at None 7 9 Integrated 481/34 8 community facilities (formerly CS9) 4 3 Steven Deller CS10 Except in Cricklewood where the council has been actively withdrawing all affordable The Core Strategy is a None 7 0 Integrated services borough wide document. 8 community facilities (formerly CS9) 4 3 David Dobbs CS10 On a personal level I don't consider an expansion of religious schools as desirable. In providing new schools we None 8 4 Integrated aim to address educational 1 community needs and respond to the facilities need for parental choice. (formerly Where there is proven CS9) demand within Barnet and premises can conform with the Department of Education guidance on primary and secondary schools there will be opportunities for such establishments to join the maintained schools sector. This could include faith schools. 4 3 Maria Nash Barnet Women's CS10 All these need to be wheelchair accessible because to date sadly only lip-service has New non domestic facilities None 8 3 Design Group Integrated been in place in Barnet and all community facilities are not accessible for wheelchair or extensions to such 3 community users facilities will be required to facilities meet Building Regulations (formerly Part M. CS9)
313 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Maria Nash Barnet Women's CS10 There should be a Youth Shadow Council for all young people living in Barnet to ensure Youth engagement in the None 8 4 Design Group Integrated all young people's input and not only through the School's system because not all Planning Service is an issue 3 community children that live in Barnet and use Barnet's community facilities go to Barnet Schools best addressed by the facilities because all schools that are engaged with the youth system have children that do not review of the Statement of (formerly live in Barnet because they come from out of borough and are not interested in Barnet's Community Involvement. CS9) facilities There also needs to be inclusion of 'good' children in youth services provision and not the constant manipulation of these services for 'Bad' children. Anti social behaviour can be seen as a reward to getting services. 4 3 Maria Nash Barnet Women's CS10 Segregation creates more problems Equality means everyone in equal all the time not In providing new schools we None 8 5 Design Group Integrated a game that can be chosen by the individual when ever they want to manipulate a aim to address educational 3 community situation Religious schools should be there for those who want to practice their needs and respond to the facilities individual religious choice and not force any other person to share in their beliefs this need for parental choice. (formerly should only be done at University when the youth have reached majority and can make Where there is proven CS9) up their own minds demand within Barnet and premises can conform with the Department of Education guidance on primary and secondary schools there will be opportunities for such establishments to join the maintained schools sector. This could include faith schools. 4 3 Maria Nash Barnet Women's CS10 Involve all communities for this provision not only BMERs but women, elderly and As part of our extensive None 8 6 Design Group Integrated disabled groups engagement on the LDF we 3 community seek to ensure that facilities representative groups such (formerly as Disabled Action Barnet CS9) and the Barnet Mental Health Network have the opportunity to participate in the process on behalf of people with such conditions. 4 3 Maria Nash Barnet Women's CS10 Not 'new and accessible facilities' but new accessible facilities because it should not be New facilities will be required None 8 7 Design Group Integrated either or. All community facilities should be fully wheelchair and sensory/hearing to meet Building Regulations 3 community accessible Part M. facilities (formerly CS9)
314 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Michael Storey CS10 More leisure centres and swimming pools. Provision in the north of the borough is The Core Strategy is a Publish 8 9 Integrated nothing short of a scandal. strategic document which Infrastructure 7 community clearly identifies sport Delivery Plan facilities facilities as part of the (formerly infrastructure requirement to CS9) support growth. We are preparing a playing pitch strategy which will follow sport England's guidance and will guide future provision of and management of such facilities. An infrastructure delivery plan setting out the where, when, what and how of infrastructure delivery will accompany the publication version of the Core Strategy. Please see response at 432/3 on the Leisure Facilities Strategy 4 3 Michael Storey CS10 But that doesn't mean the developments should be granted planning permission in the Infrastructure that supports None 8 1 Integrated first place. growth is a basic tenet of the 7 community planning system. facilities (formerly CS9) 7 John Dix CS10 Section 15.4 deals with Leisure Centres and Swimming Pools. At 15.4.1 the wording is An infrastructure delivery Publish Integrated ambiguous and implies that there are seven swimming pools in Barnet when there are plan setting out the where, Infrastructure community in fact only 3. I would therefore like the wording on paragraph 15.4.1 to be amended to when, what and how of Delivery Plan facilities include the word “three” before the word “pools” on the second line of this paragraph. infrastructure delivery will (formerly The LDF fails to recognise that there is a shortfall in facilities in the Borough, accompany the publication CS9) particularly swimming pools and fails to set any specific targets for the development of version of the Core Strategy. new leisure facilities. Please see response at I would therefore like to see the word “adequate” added to Policy CS9 first line so that it 432/3 on the Leisure reads “…partners to ensure that adequate community facilities…” and to include some Facilities Strategy. specific targets for developing new leisure facilities with which the council can then be Adequate is a subjective held to account. term and should not form part of the Core Strategy 4 1 Robert Newton CS11 Health Add a new bullet point that reads: “Engage with the Government over hospital NHS Barnet has identified None 3 0 and well provision for the Borough that appears to be outside the scope of the London Plan and their needs in delivering 6 being the Borough’s Local Development Framework but is essential for the well being of modern primary care and (formerly existing Borough residents and projected growth in new residents over the plan period.“ this is reflected in the CS10) Infrastructure Delivery Plan. Hospitals are integrated and therefore any proposals for them in the next 15 years are highlighted in the IDP. Any changes in provision will be addressed by the review of the Core Strategy. 315 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 7 Zenda Green Mill Hill CS11 Health In promoting more healthy and active lifestyles, the policy fails to acknowledge the A clear link between open None 3 Preservation and well value or promote investment in Barnet’s open spaces to support healthier space and health is made in 9 Society being neighbourhoods. the supporting text. (formerly CS10) 4 3 Mike Dawson Finchley Society CS11 Health New Primary Care centres should be located in sustainable locations such as town We encourage in Policy CS9 None 5 3 and well centres, which must be easily accessible by public transport. We are concerned that the provision of new 5 being closure of existing GP surgeries in the suburbs will result in access to new alternative community facilities in the (formerly facilities being at unsuitable sites, which are not sited in locations as suggested in town centres, our most CS10) National and Regional guidelines. accessible locations. Include a new bullet point after bullet point one, to read: • new GP surgeries/Primary Care Centres will be built at sustainable locations, to include town centres, which must be easily accessible by public transport;
4 3 Pauline McKinnell Cricklewood CS11 Health Think existing care homes should be retained otherwise people are forced to use Our aim is to help people live None 6 8 Community and well private sector. independently. The provision 7 Forum being of residential care is about (formerly meeting actual needs. For CS10) such care we want to broaden the range of choice for older people’s accommodation. 4 2 Jan Chairman NHS Barnet CS11 Health We strongly welcome reference to the Joint Strategic Needs Assessment (JSNA) in the We have incorporated text Revise 7 and well list of evidence base documents to support the LDF set out in paragraph 4.12. We on health inequalities from supporting 2 being would stress that the baseline health conditions of the borough should be understood the Primary and Community text for CS (formerly and outlined in the LDF. This can be taken from existing documentation such as the Care Strategy of NHS Barnet 11 CS10) JSNA, and confirmed through discussions with the PCT. This should outline the health objectives that the document will seek to address through the planning process. Similarly, health deprivation issues should be addressed though this document. This should be monitored through appropriate indicators to understand improvements in health through the Annual Monitoring Report (AMR). 4 4 Jan Chairman NHS Barnet CS11 Health We support the identification of the wide variety of challenges facing the borough to be We refer to our earlier Revise 7 and well addressed through the LDF, particularly including tackling deprivation, supporting answer on health supporting 2 being growth, social Infrastructure provision and encouraging healthy lifestyles. We would inequalities. In delivering the text for CS (formerly also welcome reference to the need to tackle health inequalities which are closely Core Strategy we highlight 15 CS10) related to deprivation and disadvantage. We would suggest that the Core Strategy our Engagement Agreement refers to and specifies the relationship between health conditions and the determinants with NHS Barnet of health which would underpin a cross-cutting approach to reducing health impacts, encouraging healthier lifestyles and reducing health inequalities. We also support the identification of the likely changing population trends in the borough set out in paragraph 5.1.7 and the need to plan to meet these changing needs. Close working with partners including the PCT will be important in meeting these changing needs.
316 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Jan Chairman NHS Barnet CS11 Health We strongly welcome this chapter. We would stress health and well being is a cross We do recognise health as a Revise 7 and well cutting issue and would ideally be expressed throughout the LDF in addition to Chapter cross-cutting theme. We supporting 2 being 16 and Policy CS 10: Improving health and well being in Barnet. Chapter 16 represents have incorporated text from text for CS (formerly the health and well being issues of the borough moving forward. We particularly the Primary and Community 11 CS10) support reference to the shift in healthcare service provision to a hub and spoke model, Care Strategy of NHS Barnet health provision mechanisms and encouraging healthier lifestyles. It would be useful if this chapter could be linked to others within the Core Strategy where links to health and well being have been identified, such as open space provision, accessibility, air quality, etc. For more information on these links please refer to ‘The health impacts of spatial planning decisions’, The King’s Fund, April 2009 (http://www.healthyurbandevelopment.nhs.uk/documents/news_and_events/20090921 _using_spatial_planning_to_deliver_health_outcomes/Kings_Fund_spatial_planning_re port_April_2009. pdf). We support references within Chapter 16 to key documents and groups, including the JSNA, Health and Well-being Commissioning Framework, Adult Strategy Group and the Older Adult’s Strategy. We may also suggest the Council reviews the Barnet Primary Care Strategy (http://www.barnet.nhs.uk/ec/Folders/PreviewDoc.asp?id=3772), which outlines the vision for community and primary care in Barnet. It focuses on the objective of making a significant shift of services from secondary to primary care to increase the number of local services.
4 7 Jan Chairman NHS Barnet CS11 Health The identification of specific health issues in Barnet in paragraph 16.2.1 is welcome, Improving access to open Add Map on 7 and well alongside confirmation of the commitment to encouraging healthy lifestyles and tackling space and increasing Deprivation 2 being health Inequalities, as set out in the JSNA. It may also be useful to link these issues opportunities for physical in Barnet (formerly with planning interventions to be delivered through the Core Strategy and LDF, such as activity is covered under our CS10) encouraging physical activity through increased access to open space. We would Core Strategy policy on open suggest the inclusion of a map illustrating health deprivation levels across the borough spaces. We have highlighted could be included in the Core Strategy, to help to identify where investment, the links between health and regeneration and other mechanisms should be focussed. deprivation. The Infrastructure Delivery Plan sets out where the health infrastructure is going to be delivered. 4 8 Jan Chairman NHS Barnet CS11 Health Confirmation of Barnet’s healthcare needs is welcome, including the projected The Core Strategy None 7 and well oversupply of residential care homes outlined at section 16.4. Confirmation that this has recognises the ageing 2 being considered the aging population as well as the planned housing growth for the borough population. We do not want (formerly would be welcome. Paragraph 16.4.3 notes the additional costs to the PCT of new care to make reference to S106 CS10) homes in the borough. For clarity, it may also be useful to note that developers will be SPDs until we are certain of required to contribute towards additional healthcare service provision required (both our approach on CIL. revenue and capital funding) until the next funding review. Our model on the ageing population is linked to housing growth. Barnet’s SPD on Contributions to Health from Development sets out when we will seek S106 funding
317 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Andrew Newby Barnet Green CS11 Health Clause (b) is excellent. Clause (a) should be struck out because it is not Barnet NHS Barnet is a strategic None 7 6 Party and well Council's role to give unquestioned support to NHS Barnet's plans, which could partner with whom we work 7 being change. Support should be given only on a case-by-case basis. Clauses (c) and (d) are closely in the development of (formerly purely political aims which have no place in a strategic document of this nature. these plans. The oversupply CS10) of residential care homes are a strategic issue which should be addressed in the Core Strategy. Our aim is to help people live independently and broaden the range of choice for older people’s accommodation. 4 3 Maria Nash Barnet Women's CS11 Health I strongly disagree with d) Any provision should be needs led and with the large elderly Please see response to None 8 8 Design Group and well population of Barnet there will be an increase in the need for additional residential care 477/36 3 being homes who need specialist 24/7 care elderly and disabled people need to be involved (formerly in these policies CS10) 4 3 Linda Morris Edgware CS11 Health Throughout the document you refer to the development of local Primary Care facilities We recognise the provision Revise 8 7 Community and well in line with the NHS Barnet's Polysytem approach. However we believe that this should of community services and supporting 4 Hospital being read Primary and Community Care as local GP surgeries are currently supported in the need to provide care text for CS (formerly their work by a wide range of community services such as district nursing, health closer to the home. 11 CS10) visiting and intermediate care services. These services will increase over time in line with government policy and will be increasingly locally focussed in their approach. It is important therefore that the needs of these services are factored into the development of "hub and spoke" facilities. Provider care closer to or in the home will reduce travelling as well as improving access to services for vulnerable groups. 'We are sure that the use of Primary Care in the document is shorthand for the wider range of services provided in the community but felt it necessary to ensure that this was the case and hopefully to ensure that this is clear in any final documents.
4 5 Glen Rollings Greater London CS11 Health Under sections 16: Improving Health and Well being (Policy CS10) and 18: Ensuring We do not agree that there is None 8 1 Authority and well efficient use of natural resources (Policy CS12), both of these policies should explicitly a need for duplication as we 8 being express the need to target a significant mode shift to walking and cycling, away from have made our approach (formerly use of the motor car. clear in CS 9 on providing CS10) effective and efficient travel. 4 2 Julia Hines Age Concern CS12 A safer We support the policy of making Barnet a safer place We welcome this support None 1 1 place 8 (formerly CS11) 4 8 Zenda Green Mill Hill CS12 A safer Policy CS11- Making Barnet a safer place (P85) With the increased development at Mill The opportunity to None 3 Preservation place Hill East with what we consider to be too higher density especially near the Mill Hill East specifically comment on the 9 Society (formerly Train Station we would expect some new provision for police presence in this area, growth in Mill Hill East was CS11) maybe located in old Officers Mess Building. during the development of the Area Action Plan.
318 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 9 Metropolitan CS12 A safer Paragraph 17.1.6 of this chapter states that the borough will expect development We welcome this support None 4 Police Authority place proposals to reflect guidance in the government publication Safer Places: The Planning 3 (formerly System and Crime Prevention (2004) and the principles of Secured by Design the CS11)) official UK Police flagship initiative for designing out crime. The MPA support this statement. Paragraph 17.1.7 states that greater collaboration with the Metropolitan Police and Barnet Safer Communities Partnerships is desired. The MPA support this statement. Paragraph 17.1.8 outlines the Metropolitan Police Authority's Asset Management Plan. The MPA are currently still developing this strategy, however, support the summary provided.
4 1 Metropolitan CS12 A safer Policy CS11 highlights the borough's strategy to make Barnet a safer place. The MPA We welcome this support None 4 0 Police Authority place support the 6 bullet points within this policy and support the reference to working 3 (formerly alongside the MPA. CS11) 4 1 Graham Saunders English Heritage CS12 A safer Support in general the commitment to making Barnet a safer place, through the use of We will provide a None 4 5 place appropriate security and community safety measures in buildings and spaces. However Development Management 6 (formerly we would seek to ensure that when these measures are being designed that the local Policies DPD and policy CS11) character and context of a place is carefully considered. In particular in sensitive areas framework for the sensitive such as conservation areas and listed buildings we would advise that the heritage value consideration of these of these assets are carefully identified and valued as part of the process of developing issues. security and community measures. It is important to avoid measures being introduced that would have an adverse impact upon the historic environment or the local character and context of an area. The policy and the supporting text should make reference to this issue. Maybe cross reference Policy CS3 and any new heritage Core Strategy policy. 4 2 Her Majesty's CS12 A safer HMCS plays a key role in the delivery of safe and secure neighbourhoods and The Site Allocations DPD is None 5 Court Service place communities, the appropriate document for 3 (HMCS). (formerly Alongside other delivery partners, such as the Metropolitan Police. HMCS provides a site specific considerations CS11) key, front line service in addressing crime reduction and public safety: a service that will and we would expect HMCS be pressurised by the proposed growth in the Borough through the strategic delivery of to put forward proposals as development. part of this process. In order We accordingly support the thrust of this policy; however, it should be amended to for courts to be considered include HMCS explicitly in reference to the delivery of required social infrastructure to as social infrastructure and meet community needs and an integrated part of our to support development and growth in the Borough. We suggest the following be added Infrastructure Delivery Plan to the bullet point list contained within Policy CS11: we would expect HMCS to ·"We will aim to make Barnet a safer place. We will: work with Her Majesty's Court provide further information Service as it reviews its estate to ensure it best meets modern and evolving needs for linking Barnet's growth with court facilities, thus ensuring efficient and effective delivery of its services and improved their needs to accommodate flexibility to allow for future changes in response to new pressures and requirements.' it
4 3 Steven Deller CS12 A safer Building new developments next to disadvantaged communities has been proved to We highlight that community Publish 7 2 place increase crime. Yet you are doing this in Cricklewood cohesion needs to be monitoring 8 (formerly measured across Barnet indicators in CS11) with a focus on growth areas Appendix B such as Cricklewood and the for areas that surround them. measuring community cohesion
319 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Maria Nash Barnet Women's CS12 A safer All sectors of the community should be included in this We have carried out None 8 9 Design Group place extensive consultation on the 3 (formerly Core Strategy which has CS11) generated over 2,100 comments from 334 individual responses. 2 1 Ian Dubber Workspace CS13 Workspace request that caution is taken when considering its carbon reduction The Core Strategy will be None 4 0 Group PLC Efficient use strategy, as such requirements may stifle the regeneration and growth objectives for informed by a heat mapping 1 of natural Barnet. PPS1 states that the local planning authorities should ensure that development exercise which is part of the resources plans address potential impacts upon climate change including through policies which Decentralised Energy (formerly CS seek to reduce energy emissions and promote the development of renewable energy Masterplanning initiative 12) resources. The advice in PPS1 has been clarified and developed further through the being led by the GLA. This publication of 'Planning and climate change' a supplement to PPS1. Under the heading will identify areas of 'Testing local requirements' paragraph 33 of the climate change supplement advises opportunity for decentralised that any policy relating to local requirements for energy supply should ensure what is energy across the borough proposed is evidence based and viable having regard to overall costs of bring sites to which can be prioritised in the market. future. It will set out a route In the case of housing development it is stated that the policy approach should for implementation including demonstrate that the proposed approach is consistent with securing the expected costings which will inform supply and pace of development shown in the housing trajectory required by PPS3 and viability. does not inhibit the provision of affordable housing. Workspace considers that the council should not impose rigid requirements to connect to a decentralised energy network in areas of major mixed use growth including town centres. The site conditions and constraints for each potential redevelopment scheme will undoubtedly differ and it is likely that not all sites could appropriately be connected to the decentralised network.
2 4 Peter Storey Friern Village CS13 Not just additional development but assessments need to be made to existing areas Barnet is now an air quality None 4 5 Residents Efficient use with a view to improvement management area and an 2 Association of natural action plan has been resources developed to improve air (formerly CS quality. 12) 3 8 A2 Dominion CS13 Preferred Policy CS 12 identifies that the LPA will seek to promote the highest Please see response to None 7 Housing Efficient use environmental standards for development and continue working to deliver exemplary 241/10 4 of natural levels of sustainability throughout Barnet and will expect all developments to be energy resources efficient and seek to minimise any wasted heat or power. (formerly CS Whilst as a matter of principle, A2 Dominion encourage the provision of sustainable 12) design and construction, however, these requirements should be balanced against the viability of the development. Explicit reference should be made in the policy so that viability is a specific factor which needs to be considered in determining the appropriate level of the use of natural resources
3 2 Asda Stores Ltd CS13 Development in the Borough should be required to meet the appropriate standards of The issue of heritage assets None 7 0 Efficient use sustainability and design. However policy should not necessarily prejudice and climate change is 9 of natural development in high quality and historic areas, especially those in need for addressed within PPS 5 on resources regeneration and where such development would have a positive effect on the location Planning for the Historic (formerly CS in which they are proposed in terms of economic, physical appearance and social Environment (HE 1.2 and HE 12) inclusion. 1.3)
320 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Julia Hines Age Concern CS13 In considering the characteristics of a lifetime home, we would like to emphasise the The CS seeks to reduce None 1 Efficient use importance of zero emissions homes, which will reduce fuel poverty as well as carbon emissions from the 8 of natural combating climate change. We believe that zero emission developments and the very housing stock and policy resources highest levels of insulation and water saving technology should be part of policy. CS13 supports retrofitting (formerly CS Homes should be built so that in the future older people will not have to choose the existing stock. More 12) between heating and eating. energy efficient dwellings should reduce energy consumption. We are targeting resources as part of our private sector decent homes programme. 4 1 Mark Mathews Thames Water CS13 We welcome the sub-text to the policy which highlights the need to improve the We welcome this support. Publish draft 2 Property Efficient use Borough’s water quality and acknowledges that water is a precious resource, putting an Our SPD on Sustainable LDS 4 Services of natural emphasis on water efficiency. Design and Construction resources We support the references to SUDs in new development in appropriate circumstances. provides further detail on (formerly CS However, it should also be stated that sustainable drainage systems are not SUDs and emphasises the 12) appropriate for use in all areas, for example areas with high ground water levels or clay need for developers to soils which do not allow free drainage. consult Thames Water about A well maintained and managed sustainable drainage system is also required to sewer flooding. The SPD will prevent it becoming ineffective, potentially increasing overland flows, and consequently be subject to revision in having an impact on the sewerage network 2011. We support Policy CS12, particularly bullet point 5 which has an objective of making the Borough water efficient and minimise the potential for flooding. We consider that all new dwellings should meet the water usage targets set out in code for sustainable homes code 3 rating as a minimum. In relation to flooding, Water and sewerage undertakers have limited powers under the Water Industry Act to prevent connection ahead of infrastructure upgrades and sewer flooding can be caused when developers make connections to the existing sewerage network without proper consultation and authorisation from the relevant water company.
4 8 Gaby Kagan Labour Group CS13 Policy CS12: a step-change in reducing carbon emissions in Barnet is required, and the Further evidence is being None 2 Efficient use council should be doing more to promote awareness of the issue and encourage developed to identify areas 9 of natural residents, businesses and partners to reduce their own carbon footprints. The council with the potential to deliver resources must put robust strategies in place to reduce carbon emissions resulting from local decentralised energy. (formerly CS authority operations, including Barnet Homes, and set similar expectation for other local 12) organisations.
4 1 Georgia Wrighton Women's CS13 "to promote efficient use of land and natural resources”- Again the BWDG support the The Development None 3 0 Design Group Efficient use principles of this objective, however, it does not go far enough to specifically require all Management Policies DPD 3 of natural development in the borough to consider good design and layout which ensures easy will provide further detail on resources access by all modes, giving priority for the more sustainable modes and for those with policy for access and design. (formerly CS special mobility requirements. Having these priorities underpinning design can deliver 12) optimum use of the public realm, increase a sense of security and reduce barriers either real or perceived for access by all members of the community. All new major regeneration projects must benefit the Borough’s diverse range of groups and have feelings of safety and community cohesion at their heart.
321 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Robert Newton CS13 Reason: To rectify the deficiencies of the existing Sustainable Design and Construction The Sustainable Design and None 3 1 Efficient use Supplementary Planning Document. Construction SPD is neither 6 of natural Re-write the first bullet point to read:”We acknowledge the weakness of our existing weak nor poor and will be resources Sustainable Design and Construction Supplementary Planning Document and the poor updated to ensure that (formerly CS contribution it makes to sustainability. We acknowledge the importance of sending a requirements reflect changes 12) message to developers that only the highest standards will be accepted in the Borough to generic environmental and also of creating a level playing field for developers who wish to operate in the standards and recent Borough. advances in technology and As a priority we will re-write the SD & CSPD to include examples of best practice from design. across the country and to strengthen the provisions for householder developments as We are supportive of the well as incorporating Policy 3.5, Table 3.3 and Paragraphs 3.26 to 3.33 of the London Mayors approach to the Plan Consultation Draft Replacement Plan (October 2009) with regard to the quality quality and design of and design of housing and space standards.” housing including the Amend the wording of Paragraphs 18.1.1 to 18.6.5 where necessary to reflect these housing density matrix and changes to Policy CS12. the new space standards in the draft London Plan. If the standards pass scrutiny and form part of the final London Plan they will replace the standards set out in the SPD on Sustainable Design and Construction.
4 9 Zenda Green Mill Hill CS13 Policy CS12- Ensuring the efficient use of natural resources (P90) This policy should be We do recognise in the Core Revise 3 Preservation Efficient use explicit on the contribution that Barnet’s open spaces can make to adapt to climate Strategy the contribution of supporting 9 Society of natural change, for example by ameliorating high summer temperatures, managing flood risk such spaces to urban text to CS7 resources and improving air quality. cooling, air quality and (formerly CS reducing flood risk. 12) 4 9 British Library CS13 The BL recognises the increasing pressures on the environment and as such support We welcome this support for None 4 Efficient use the principles of Policy CS12 which seeks to minimise Barnet’s contribution to climate our approach however the 2 of natural change. The BL is pleased to note that its comments to the Core Strategy Issues and policy does not preclude the resources Options version have been taken on board and that part 3 of Policy CS12 states: use of renewable energy. (formerly CS “We will expect all development to be energy-efficient and seek to minimise any wasted 12) heat or power” The BL is pleased to note that the Council’s priority is to utilise high quality design to ensure efficient use of energy rather than seek an inappropriate technological fix and/or renewable energy. The BL considers that the primary focus for new development should be on energy and resource efficiency, rather than renewable energy which may be difficult to deliver on smaller sites.
322 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Graham Saunders English Heritage CS13 Support the need to efficiently use natural resources, and in particular the emphasis We will provide a None 4 6 Efficient use upon retrofitting existing housing stock, promoting high environmental standards, and Development Management 6 of natural introducing local networks to supply energy. However when developing these Policies DPD and policy resources approaches we would advise that careful consideration is given to their application in framework for the sensitive (formerly CS sensitive areas such as conservation areas and listed buildings. It is still possible to consideration of these 12) introduce environmental measures that help improve energy efficiency, and reduce issues. waste as long as the method of application is designed from an understanding of the significance of the heritage assets affected. In addition it should be noted that the appropriate re-use of existing historic buildings and where necessary re-use of fabric does help reduce the need for waste and utilises embodied energy. The policy and supporting text should make reference to the need to consider the character and heritage value of buildings and spaces where this policy will be applied. 4 4 Lisa Walduck Natural England CS13 The supporting text to this policy discusses the need for the Borough to adapt to We refer to the benefits that Revise 5 Efficient use climate change. However, the policy itself only appears to address flooding. There is open space brings to supporting 2 of natural also a need to address other impacts of climate change, including hotter, drier combating climate change in text to CS7 resources summers. Please see the attached paper on the natural value of green infrastructure, the section on enhancing (formerly CS particularly the ‘natural resilience’ section. We recommend that either within this policy and protecting Barnet’s open 12) or within policy CS5 the effects of climate change and the need to adapt to these are spaces addressed more fully. 4 2 Katie Arthur Environment CS13 We support Section 18 “Ensuring the efficient use of natural resources” and in We welcome this support Revise CS 5 Agency Efficient use particular Policy CS 12 which states a commitment to minimising the potential for fluvial and have revised the policy 13 4 of natural and surface water flooding by ensuring development does not cause harm to the water to add reference to reducing resources environment, water quality and drainage systems. surface water run off from (formerly CS The policy also takes into account the requirements of several key documents including new development. The 12) the London Plan and PPS25 and the North London Strategic Flood Risk Assessment. Direction of Travel made This includes a commitment to the application of the sequential test in determining site reference to the Sequential allocations and the use of Sustainable Drainage Systems (SUDS). Test Additionally, the document recognises the effects of climate change on flood risk. Suggested Improvements: The commitment to minimising flood risk should be extended to actively reducing flood risk through policy and development. This should include a commitment to reducing development surface water runoff and the use of SUDS, inline with the requirements of the London Plan. We would expect to see a mention of the reduction of flood risk in paragraph 18.1.2, under the list of issues that the Core Strategy can influence. In order to be considered comprehensive, paragraph 18.4.1 should included a commitment to choosing areas of lowest flood risk when considering site allocations. As previously mentioned, the Sequential Test should also be mentioned within this section of the Core Strategy. If the Sequential Test is not referred to in the Core Strategy we may find the document unsound at the submission stage.
323 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Katie Arthur Environment CS13 Policy CS12 does not make any mention of land as a resource to be managed or We agree that contaminated Revise 5 Agency Efficient use protected. Although I presume this will be addressed through the Site Allocations land is an important resource supporting 4 of natural document, there should be a reference to contaminated land and site remediation in the and have made reference to text to CS13 resources Core Strategy. it (formerly CS Although the deep chalk aquifer is protected by a layer of London clay, there are 12) several gravel and similar permeable formations which may have there own minor aquifers. There are also several surface water rivers and streams that may require protection. Section 18.6.4 mentions the need to protect surface and groundwater from the effects of development but does not recognise the need to investigate and remediate the effects of historic land use. This should be mentioned within this section of the Core Strategy. 4 1 HANA KLEINER CS13 Regarding the statement that 75% of carbon emissions are generated by existing The Development None 5 Efficient use buildings the LDF should include urgent implementation of measures to reduce these. Management Policies DPD 9 of natural Householders will provide further policy on resources should be encouraged to improve insulation, to fit solar panels e.g. when new roofs are climate change. (formerly CS fitted. There should be confirmation that building regulations are to be observed. When Part L of the Building 12) extensions are made with regard to new developments, there is mention of building Regulations 2000 controls regulations both current and future, but no details of existing measures of enforcement. proposed work to existing Does Barnet have an adequate staff and structure for the on site inspection of all dwellings with regard to building taking place? How many buildings are currently being inspected by qualified energy efficiency. inspectors to conform with the existing building regulations, Building Regulations are Not only visually but by physical measurements of energy loss as laid down in the enforced through a building regulations. This issue will assume much greater importance in view of the combination of persuasion, extensive new developments planned. formal letters and court action. Barnet has 14 qualified inspectors to enforce the Building Regulations and has sufficient staff to ensure conformity with the Regulations. 4 4 A Reid Mount Anvil Plc CS13 The phrase "the highest environmental standards" is not qualified. Environmental standards are None. 6 1 Efficient use changing through the 6 of natural Building Regulations and the resources move to zero carbon (formerly CS dwellings. That is our 12) benchmark. 4 4 A Reid Mount Anvil Plc CS13 Requiring Air Quality Assessments and Noise Impact Assessments from development Such assessments None 6 6 Efficient use will not necessarily do anything to improve air or noise quality. This statement should contribute to the sustainable 6 of natural be qualified. quality of development. resources (formerly CS 12) 4 3 Andrew Newby Barnet Green CS13 This clause is too late. The target should be to reduce Barnet's contribution to climate We are working through None 7 8 Party Efficient use change, and to do so at a rate of at least 2.5 percent a year in order to match the Barnet’s LDF towards 7 of natural government's overall target of an 80 percent reduction in greenhouse gas emissions by reducing greenhouse gas resources 2050 emissions and we consider (formerly CS that our approach is 12) consistent with the London Plan and national policy on climate change 324 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Andrew Newby Barnet Green CS13 Barnet Council should support retro-fitting of the housing stock even if some people Impact is important given the None 7 0 Party Efficient use feels it impacts on the character or amenity of an area. Retro-fitting is vital if emission priority we give to protecting 7 of natural reduction targets are to be achieved and climate change is to be avoided. This is at and enhancing Barnet's resources least as important as ensuring that new buildings have low emissions. Impact is usually character to create high (formerly CS subjective in any case. quality places. 12) 4 4 Andrew Newby Barnet Green CS13 This is wishy-washy. The council should be taking steps itself as well as with partners It is unrealistic to expect that None 7 2 Party Efficient use the council has the 7 of natural resources to act alone on resources this. (formerly CS 12) 4 4 Andrew Newby Barnet Green CS13 The strategy pays too little attention to the impact of climate change. Reduction of We refer to our answer at None 7 7 Party Efficient use greenhouse gas emissions should be a key target overall and should be given greater 477/38. 7 of natural importance under various headings, as I have mentioned in those sections. The The Core Strategy supports resources strategy should set a carbon reduction target of 2.5 percent a year to match the the 20 town centres in (formerly CS government's target of an 80 percent reduction in greenhouse gas emissions by 2050. Barnet. Brent Cross is 12) More attention should be given to support for secondary community shopping areas, London's only regional notably Hendon, Temple Fortune, Golders Green and East Finchley. The extension of shopping centre and an area Brent Cross shopping centre should be barred. of strategic importance. Its regeneration is highlighted in the London Plan. 4 3 Steven Deller CS13 All new developments to include solar panels and windmills for self generating We will not seek an None 7 4 Efficient use electricity inappropriate technology fix 8 of natural when high quality design can resources ensure more efficient use of (formerly CS energy. 12) 4 3 Steven Deller CS13 The Claremont stadium plans were proved to increase the risk of flooding but you This a specific matter None 7 7 Efficient use ignored this connected with planning 8 of natural consent for Hendon FC. resources (formerly CS 12) 4 3 Steven Deller CS13 Cricklewood is already one of the most polluted parts of the borough. You intend to These issues were None 7 8 Efficient use make this worse with your development. Further increasing pollution in Cricklewood considered as part of the 8 of natural Brent Cross – Cricklewood resources planning application which (formerly CS the council resolved to 12) approve subject to S106 in November 2009. 4 4 Maria Nash Barnet Women's CS13 All stakeholders and local residents in particular Barnet's Women's Design Group, As part of our Future Shape None 8 0 Design Group Efficient use LA21 groups, disabled groups, elderly groups should be involved. Have Barnet wide programme we are 3 of natural environmental workshops in community centres or schools to train/give information to developing a new resources all people who work or live in Barnet as to how they could make this possible. relationship with citizens and (formerly CS encouraging self help and 12) behaviour change. It is about empowering residents to help one another to access information rather than the council simply running a series of workshops. 325 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Glen Rollings Greater London CS13 The draft replacement London Plan revises the target for renewable energy provision Agree to add reference to Revise 8 2 Authority Efficient use and the document should be updated to reflect these changes. Table 5.1 in Draft Revised supporting 8 of natural London Plan text to CS13 resources (formerly CS 12) 4 1 Zenda Green Mill Hill CS14 Dealing Policy CS13- Dealing with our waste (P92) We support the protection of the This is not a matter for the None 3 0 Preservation with our environment by reducing amounts of waste and increasing recycling. Within the Mill Hill LDF to address. Our 9 Society waste East development, the high density of flats and houses and their close proximity to one household waste storage (formerly another and lack of space will create a situation where, if the current waste process is facilities are sensible and CS13) applied, the streets will be lined with a plethora of refuse bins, green waste bins and practical. They are designed recycling boxes. We feel that this needs to be addressed with new waste practices to provide adequate capacity within the LDF. and divert materials going to landfill. 4 2 David Howard Federation of CS14 Dealing We are concerned at the approach being taken by the Borough as a member of the The NLWP is more than a None 6 0 Residents with our NLWA through the NLWP for managing waste disposal. Although not a key element of waste exercise. It involves 4 Associations in waste the current document we have grave reservations as to whether there is joined up working with six other north Barnet (FORAB) (formerly thinking between the LDF and the waste exercise which will finish up as part of the LDF London boroughs to identify CS13 library of documents sites and policies to manage all waste produced in north London over the plan period. A considerable amount of consultation has been carried out to date with the preferred options published in November 2009. This document highlighted the links with boroughs Core Strategies and the policy framework for dealing with applications for waste management facilities. 4 4 Pauline McKinnell Cricklewood CS14 Dealing Not sure a waste management facility fits in with Brent Cross Cricklewood regeneration The emerging North London None 6 7 Community with our plan. It may have to be relocated elsewhere. Waste Plan will identify 7 Forum waste waste sites. London Plan (formerly policy requires the CS13 replacement of existing waste sites so the Hendon transfer facility needs to be replaced.
326 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 0 Malcolm Carter Bestway CS14 Dealing ii) There is no evidence behind the reasoning of the Council's policy that a waste Safeguarding a waste None 6 (holdings) Ltd with our management facility must be safeguarded within the BXC Regeneration Area. The site management facility ensures 9 waste selection process for waste facilities within Barnet should follow the proposed conformity with the London (formerly sequential test within the NLWP. The NLWP Preferred Options does not state that a Plan with regards to CS13 waste facility must be retained within the BXC Regeneration Area and if the replacement of existing apportionment targets within the NLWP can be met by more suitable sites outside of facilities. the Regeneration Area (e.g. the identified site at Pinkham Way), there would be no The site at Geron Way has Requirement for a waste facility within the Regeneration Area. been identified as a This part of the policy does not sit fully with the NLWP Preferred Options policies and preferred site for waste should consequently be removed from Policy CS13. management in the NLWP. ii) We also object to the part of CS13 which safeguards a Waste Management Facility We clearly state that a waste in the Brent Cross – Cricklewood (BXC) Regeneration Area and believe this element of management facility forms the policy should be removed from Policy CS13. As stated above, we agree that waste part of the proposals for management sites should be designated through the NLWP when it is adopted. Brent Cross - Cricklewood However, the NLWP Preferred Options does not state that there must be a waste as set out in the outline management facility within the BXC Regeneration Area and we consider there are application and the more suitable waste management sites within the wider NLWP boundary (outside of the development framework. Regeneration Area) than our client's site within the Regeneration Area.
4 1 Malcolm Carter Bestway CS14 Dealing i) There was no site selection process or evidence provided within the BXC planning The NLWP is part of the LDF None 6 (holdings) Ltd with our application as to why our client's site has been selected for waste management use and informs and is informed 9 waste and there was no evidence behind whether this was the most suitable site within the by the Core Strategy. (formerly BXC Regeneration Area or the wider area of the NLWP. The BXC application refers to The Geron Way site forms CS13 the fact the site is identified as a Schedule C site within the NLWP Preferred Options part of the proposals for document and this document currently gives a high score for the suitability of our Brent Cross - Cricklewood client's site for waste management use. However, it is premature to rely on the NLWP as set out in the outline Preferred Options document for future waste management sites and we submitted application and the representations to the NLWP Preferred Options Development Framework. Highlighting that the scoring system within this document is flawed and inconsistent between sites. The NLWP document has not undergone an Examination in Public and has not been adopted. Until this time, limited weight should be attached to the sites identified within the current NLWP Preferred Options document. The scoring for sites within the NLWP Preferred Options document could be subject to change by the time the document is formally adopted and/or the document could be found to be 'unsound'. Consequently, limited weight should be provided to the suitability of sites identified within this document until it is formally adopted. We propose the following changes to Policy CS13 – Dealing with our Waste. i) The policy states that waste management sites will be designated through the NLWP and these sites will be the principle locations considered suitable for waste facilities.
327 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Malcolm Carter Bestway CS14 Dealing We agree that the NLWP should be used to identify suitable sites for waste We refer to our response at None 6 (holdings) Ltd with our management facilities. However, consultation on the NLWP Preferred Options has only 469/1 9 waste just ended (10 January 2010) and until this document is formally adopted and (formerly considered sound by an Inspector, limited weight should be attached to the sites CS13 designated within this document. It would be premature for the Council to rely on any sites designated as suitable for waste facilities within this document until it is formally adopted. Notwithstanding the above, we consider the scoring system within the NLWP Preferred Options to be flawed and inconsistent between different sites (we have made similar comments in Bestway's consultation response to the NLWP Preferred Options). This is discussed under question (5) below.
4 3 Malcolm Carter Bestway CS14 Dealing iii) Policy CS13 relies upon designated sites within the NLWP. The sequential approach The NLWP is the appropriate None 6 (holdings) Ltd with our should be included within Policy CS13 for the location of future waste development in place for the sequential 9 waste line with the emerging NLWP Preferred Options policy NLWP1. This would ensure that policy as it forms part of the (formerly existing waste treatment sites and waste transfer sites are assessed for their suitability LDF. There is no need for CS13 for waste facilities before other sites are considered. This would also comply with duplication. The Core Policies 4A.24 and 4A.27 of the London Plan. Strategy highlights the role In the BXC application that the Council has recently resolved to grant permission for, of the NLWP in designating our client's site was identified for a waste handling facility without evidence as to the new sites but this does not Suitability of the site and without a sequential assessment being undertaken. The BXC obscure the identification of application is therefore not compliant with the emerging NLWP policy and the Core a waste management facility Strategy should ensure that future waste development is fully assessed in line with the in Brent Cross Cricklewood emerging policy. as part of the proposals for iii) The sequential approach should be included within Policy CS13 for the location of that area. future waste development in line with national waste policy, the London Plan, and the It is recognised that NLWP is emerging NLWP Preferred Options policy NLWP1. Policy NLWP1 advocates that in an emerging document assessing proposals for waste management facilities, North London Boroughs will whose timetable is behind require that the developers have first considered existing waste treatment sites that of Barnet's Core (Schedule A), followed by existing waste transfer sites (Schedule B), before even Strategy. considering the possibility of proposed new sites for waste management use (Schedule C – our client's site falls within this category). 4 4 Maria Nash Barnet Women's CS14 Dealing Only if local people who work or live in Brent Cross - Cricklewood area agree with This issue was addressed None 8 7 Design Group with our proposals There should be workshops around Barnet to educate the residents and within the Brent Cross 3 waste businesses planning application. The (formerly North London Waste Plan CS13 provides the opportunity to comment on proposed waste sites. Consultation on this document included a drop in consultation event at Hendon Town Hall which was open to all residents and was publicised locally. This was attended by both planning officers and waste officers who were available to answer any questions that people had on waste matters from doorstep recycling to possible new waste sites.
328 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Michael Storey CS14 Dealing Except for point c) which depends on where they are, and point d) which needs further In line with the London Plan None 8 1 with our consultation? existing sites in waste use 7 waste must be safeguarded and (formerly equivalent replacement CS13 provided if they are to be developed. This is the case in the Brent Cross Cricklewood regeneration area. New sites for waste management are required to meet the growth in waste projected across north London; their location is dependent on a series of assessment site criteria that are set out in the emerging North London Waste Plan. 4 5 Glen Rollings Greater London CS14 Dealing Transport accessibility and minimising the impact of waste and construction materials This is a matter for the None 8 3 Authority with our on the highway network should be central to the council’s waste strategy. TFL would emerging North London 8 waste like to see the inclusion of additional text under Policy CS13 to read that “the council Waste Plan which sets the (formerly will promote sustainable transfer of waste by non vehicular modes using multimodal policy framework for waste CS13 and modern technologies. In particular vehicular trips will be minimised outside of peak management. hours particularly in sensitive locations”. 2 1 Ian Dubber Workspace CS15 Workspace considers that a balanced approach should be taken when considering the Agreed that planning None 4 1 Group PLC Delivering the value of the overall planning obligations package, thereby ensuring the viability and obligations should be 1 Core Strategy deliverability of the proposed development to meet strategic objectives. As such, required in line with Circular (formerly Workspace considers that any S106 contributions should be applied on a site by site 05/2005 or its replacement CS14) basis and adheres to the requirements of Circular 05/2005. Planning obligations must only be imposed when it can be demonstrated that they are needed to mitigate against the impact of the development.
329 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Julia Hines Age Concern CS15 We are not convinced that section 106 payments should be used to fund a Business The Business Links Officer None 1 3 Delivering the Links officer as we are not convinced that this is the best use of s.106 funding. Local will help the council to: 8 Core Strategy business is not defined – is it a business with a registered office within the borough, or - understand more about the (formerly where a proportion or a majority of employees live within the borough? The post experience of local CS14) appears to be unduly focussed on construction. businesses in the current economic climate (particularly businesses located in the borough’s town centres) - support local small and medium-sized enterprises and enable them to be more aware of, and bid for, contracts from local developers - act as a conduit for support and advice - understand the skills needs of local businesses - encourage links between business and education - support contractors in the preparation and implementation of their Local Procurement Strategy documents, which will act as a frame of reference for the resulting partnership between the Council, developers and local businesses.
4 1 Julia Hines Age Concern CS15 We are concerned about the emphasis on worklessness amongst younger people and A Skills Development Plan None 1 4 Delivering the NEETs. Whilst we acknowledge this is an important social issue, we would like to (currently under review) is 8 Core Strategy highlight the issue of unemployment, particularly following redundancy, on older people being delivered in the (formerly of working age. Older people are more expensive to employ and so more vulnerable to borough through the Council CS14) being made redundant in an economic downturn. They have less chance of finding and its partners. The Plan new work than any other age group. Being out of work at the end of your career can includes actions to respond result in a failure to build up adequate pension provision, leading to long term poverty to the recession which are following retirement and significant social costs for the community. age neutral (for example partner provision such as Barnet College’s ‘response to redundancy’). A particular target is those who have been out of work for 6 months or more. From April 2010 people aged 50 and over on Jobseeker’s Allowance have benefited from early access to training provision through Jobcentre Plus that would not normally be available until the six 330 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations month stage of their claim.
4 2 Julia Hines Age Concern CS15 We disagree with this policy and believe climate change should be the overriding We are working through None 1 2 Delivering the principle in all new developments, because older people are more vulnerable to its Barnet’s LDF towards 8 Core Strategy impact than any other sector of the population. reducing greenhouse gas (formerly Barnet’s record on CO2 emissions is currently very poor compared with other boroughs emissions and we consider CS14) in London. that our approach is consistent with the London Plan and national policy on climate change 4 2 Mark Mathews Thames Water CS15 We support the references within this section to infrastructure and the requirement that We would welcome Thames Publish 2 Property Delivering the infrastructure is in place to meet the requirements of the Borough. It is important that Waters contribution to our Infrastructure 4 Services Core Strategy infrastructure is brought forward in a timely manner to meet the demands placed upon it Infrastructure Delivery Plan. Delivery Plan (formerly by new development. It is also essential that developers demonstrate that adequate We consider that the policy CS14) capacity exists both on and off the site to serve the development and that it would not wording is clear that lead to problems for existing users. In some circumstances this may make it necessary infrastructure is secured to for developers to carry out appropriate studies to ascertain whether the proposed support growth. The where, development will lead to overloading of existing water & sewerage infrastructure. when, what and how is set Where there is a capacity problem and no improvements are programmed by the water out in the Infrastructure company, then the developer needs to contact the water authority to agree what Delivery Plan. improvements are required and how they will be funded prior to any occupation of the development. Therefore we suggest bullet point 1 of Policy CS14 is amended to state that :- ‘Work with relevant providers and developers to ensure that necessary infrastructure is secured and delivered in time to support Barnet’s growth…….’ In relation to Bullet Point 2 of Policy CS14 it is our understanding that Section 106 Agreements can not be used to secure water and waste water infrastructure upgrades. As Water and sewerage undertakers also have limited powers under the Water Industry act to prevent connection ahead of infrastructure upgrades we therefore rely heavily on the planning system to ensure infrastructure is provided ahead of development either through phasing or the use of Grampian style conditions.
4 1 Georgia Wrighton Women's CS15 Social infrastructure like affordable child care, health, community and education Social infrastructure forms a Publish 3 2 Design Group Delivering the facilities must improve and keep up with the pace of proposed development to ensure key part of our Infrastructure Infrastructure 3 Core Strategy that inequalities are not deepened. The Council should consider enabling the provision Delivery Plan as does the Delivery Plan (formerly of a ‘Centre for Independent Living’ in the Borough. proposal for the Centre for CS14) Independent Living
331 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Robert Newton CS15 Reason: To ensure that development is not completed in advance of infrastructure Each policy in the Core Addition of 3 2 Delivering the provision, that development accords with planning policy and planning consents and Strategy will be monitored monitoring 6 Core Strategy that elected Members have an overview and control over the implementation of based on specific indicators indicators in (formerly planning policy and its review. and reported in the Annual Appendix B. CS14) Add the following bullet points: Monitoring Report. This will We will: “Recognise that developments will have to be delayed, deferred or halted if the provide clear evidence of necessary infrastructure is not provided or delayed.” policy delivery and a basis “Ensure that there is adequate provision for monitoring development work and planning for review of the Core enforcement in the Borough and that within the statutory constraints there is a clear Strategy message that infringements will be pursued by the Council.” “Ensure there is Council Member review of planning decisions in accordance with the July 2005 Audit Commission report so as to check that development proceeds in accordance with the Core Strategy and related policies and that remedial action is taken when this is not the case.” Amend the wording of Paragraphs 20.1.1 to 20.10.2 where necessary to reflect these changes to Policy CS14.
4 1 Zenda Green Mill Hill CS15 Delivering the Core Strategy (P97) should use planning obligations to both improve The priorities for S106 are None 3 1 Preservation Delivering the existing infrastructures (including green infrastructure) along with securing new clearly set out in the Core 9 Society Core Strategy infrastructure for development. In addition section 20.5.3 (P95) funding priorities from Strategy. In increasing (formerly S106 development gain should seek to fund both provision of new open spaces and the access to open space we CS14) improvement of existing spaces. aim to improve the quality as well as the quantity. Therefore it is important to highlight improvements to open space as a S106 priority. 4 1 British Library CS15 The BL is please to note that the Council will use planning obligations in appropriate We welcome this support None 4 0 Delivering the circumstances in accordance with Circular 05/05. The BL recognise that further 2 Core Strategy guidance on the Council’s approach to planning obligations is set out in the Interim (formerly Guidance Note on Section 106 which has been brought forward in response to the CS14) current economic circumstances.
4 1 Metropolitan CS15 Part 20.5 of this section deals with Planning Obligations. A list of proposed items for The Core Strategy None 4 1 Police Authority Delivering the which planning obligations will be sought is outlined in section 20.5.3. The MPA are recognises that the 3 Core Strategy aware that significant additional development is likely to come forward in the borough Metropolitan Police provides (formerly which may increase demands on community facilities such as police facilities. Policy community services and CS14) 3A.18 of the London Plan states that policies in DPD's should assess the need for facilities. The Infrastructure social infrastructure and community facilities (including police facilities) in their area, Delivery Plan set out the and ensure that they are capable of being met wherever possible. provision for infrastructure. Recommendation: In order to ensure the Core Strategy complies with the statutory development plan policy it is requested that an additional point is added to the list within section 20.5.3 to include - policing
332 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Metropolitan CS15 Section 20.6 deals with the Community Infrastructure Levy. As a provider of community We refer to our previous None 4 2 Police Authority Delivering the facilities the MPA are concerned about the blanket use of Community Infrastructure answer at 443/11 on S106. 3 Core Strategy Levy (CIL) model for predicting future police floorspace requirements. Levies tend not There is still uncertainty (formerly to take into account the many factors which affect policing infrastructure need. A variety about the implementation of CS14) of pressures impact upon the level of policing required within the borough. Several CIL. If it does proceed the issues such as demographics and socio-economic factors and significantly different Metropolitan Police will have levels of police officers are needed across the 32 boroughs according t a variety of the opportunity to contribute different factors; the ratio of police officers to population differs greatly between the to Barnet’s charging highest police provision and the lowest within each borough. schedule. The MPA are continually monitoring their needs in the Barnet and across London and they wish to have the flexibility to respond to policing needs if and when they arise. It is believed that the formula based approach is too simplistic and doesn't reflect the MPA's estate strategy. The best way to ensure the delivery of the aims of the Barnet Asset Management Plan is to influence planning policy and development proposals and to secure the delivery of floorspace and other obligations through S106 agreements. This has proven to be the most successful way of delivering the MPA's estate needs and providing police facilities where they are needed. Recommendation: The MPA recommend that the traditional S106 route for the provision for policing should remain alongside any introduction of CIL. Therefore the following alteration is recommended to section 6.2.1 - 'Negotiated planning obligations will still be possible for site specific issues such as policing and to allow for affordable housing to be delivered on site.
4 3 Joanne Woodward London CS15 It is acknowledged that some work has already been commenced regarding The Infrastructure Delivery Publish 4 Borough of Delivering the infrastructure provision as part of the AAP/ master plan preparation for the major Plan incorporates work on Infrastructure 5 Enfield Core Strategy regenerations areas and that Policy CS 14 - Delivering the Core Strategy refers to an the three major regeneration Delivery Plan (formerly Infrastructure Delivery Plan. and development areas. CS14) It is hoped the work already done on the major regeneration areas plus the work to be done to produce the Infrastructure Delivery Plan will be pulled together to ensure services are supplied to the proposed increased population as housing is developed.
4 5 Joanne Woodward London CS15 The Council is please to see a reference to working with neighbouring boroughs in We welcome this support None 4 Borough of Delivering the Section 20.9 and Policy CS 14 – Delivering the Core Strategy. The particular reference and look forward to 5 Enfield Core Strategy to Enfield’s North Circular AAP is also welcomed. LB Enfield looks forward to continue continuing to work with (formerly working with LB Barnet (and LB Haringey) regarding the North Circular AAP which Enfield on the AAP and the CS14) includes the master planning at New Southgate and the works to New Southgate SPD for New Southgate. Station. 4 1 Graham Saunders English Heritage CS15 It is important to highlight the historic environment as a S106 priority. Many We consider that these are None 4 7 Delivering the development proposals can have an adverse impact upon the historic environment in issues that should be 6 Core Strategy terms of affect the character of a conservation area or undermine the setting of a listed resolved through sensitive (formerly building. We would therefore seek to ensure that S106 monies negotiated also design rather than resort to CS14) recognise the need for the historic environment to be appropriately compensated. the S106 route and put Identifying the historic environment as a priority under paragraph 20.5.3 helps ensure further strain on resources that monies obtained are directed appropriately to those assets of the Borough for infrastructure. affected.
333 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Her Majesty's CS15 We support the need to work with relevant providers to ensure that necessary We consider that by None 5 Court Service Delivering the infrastructure is ensuring that developments 3 (HMCS). Core Strategy secured to support growth, and the use of planning obligations to secure such incorporate design principles (formerly infrastructure. which contribute to CS14) Barnet's s106 priorities are listed at Paragraph 20.5.3 on page 95. We request that community safety and court facilities are included within this list, because population and economic growth security we can address this places additional pressure on a range of court services; directly requiring existing issue at an early stage and services to be enhanced or extended. It is appropriate therefore that the cost of such prevent crime. There is additional requirements is met by development in the Borough, in exactly the same way therefore no need to as other community services are supported. highlight as a S106 priority. We would welcome the involvement of HMCS in Barnet’s Infrastructure Delivery Plan. 4 3 Mike Dawson Finchley Society CS15 This policy should be amended as below: Unclear on the benefit of this Publish 5 4 Delivering the We will work with Barnet's Local Strategic Partnership and other partners to deliver the change. The Infrastructure Infrastructure 5 Core Strategy vision, objectives and policies of this Core Strategy. We will: Delivery Plan is required to Delivery Plan (formerly • work with relevant providers to ensure that necessary infrastructure is secured and support growth. CS14) provide the facilities needed for the borough's communities to support Barnet's growth. Securing community support Information on the key infrastructure schemes in Barnet up to 2026 are set out in the for growth is a wider matter Core Strategy Infrastructure Delivery Plan and a key part of the localism agenda
4 1 David Howard Federation of CS15 Please ensure there is adequate investment in infrastructure such as public transport In line with national planning Publish 6 4 Residents Delivering the doctors’ and dentists’ surgeries and utility provision before approving new development. policy guidance an Infrastructure 4 Associations in Core Strategy Stop the issuing of on-street parking permits to occupiers of new developments. Large infrastructure delivery plan Delivery Plan Barnet (FORAB) (formerly numbers of flats are being built with insufficient car parking leading to further will be produced which will CS14) congestion on the streets. The water, electrical gas and sewerage installations are provide detail on what constantly failing in various parts of the Borough and there are forever new holes infrastructure will be appearing as another section of a utility is repaired or renewed. Growth on the scale provided and where. envisaged requires more and faster investment. The Core Strategy supports a parking regime that balances reducing car use while recognising that many residents continue to travel by car. The Development Management policies DPD will provide more detail on car parking standards and policies for Barnet. The approach to the issuing of parking permits for new development reflects the strategy and that was agreed by Cabinet in 2004. 4 1 Government CS15 Monitoring mechanisms should be included in the publication version of the Strategy. Agree Addition of 7 3 Office for Delivering the This is most usefully set out in a single table in the annex. Where possible the monitoring 0 London Core Strategy monitoring mechanisms should be linked to contingency options, particularly for the indicators in (formerly Core Strategy’s critical issues. Appendix B. CS14)
334 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 David Howard New Barnet CS15 Para 2.4.3 refer to the Infrastructure delivery plan. This is a key element to the success We consider that the policy Publish 7 Community Delivering the of any programme of growth. It is not available therefore work on expansion should not wording is clear that Infrastructure 1 Association Core Strategy be permitted until the infrastructure issues are addressed infrastructure is secured to Delivery Plan (formerly support growth. The where, CS14) when, what and how is set out in the Infrastructure Delivery Plan. The Infrastructure Delivery Plan will be published alongside the Publication Version of the Core Strategy. 4 3 Jan Chairman NHS Barnet CS15 We also support reference to the preparation of Barnet’s Infrastructure Delivery Plan in We welcome this support None 7 Delivering the emerging evidence base documents set out in paragraph 4.13, and would encourage and the input of the NHS and 2 Core Strategy thorough discussion with the PCT to ensure healthcare provision is appropriately other strategic partners to (formerly planned. the development of the CS14) Infrastructure Delivery Plan. 4 9 Jan Chairman NHS Barnet CS15 Whilst section 20.10 is welcomed, as it confirms the Council’s commitment to Each policy in the Core Addition of 7 Delivering the monitoring the impacts of the policies, to confirm if the Core Strategy and SCS Strategy will be monitored monitoring 2 Core Strategy objectives are being met, the Direction of Travel consultation document does not based on specific indicators indicators in (formerly include any suggested indicators. We would urge the Council to include a and reported in the Annual Appendix B. CS14) comprehensive set of health and well being indicators, to help to confirm whether Monitoring Report. This will health and well being is improving. Examples could include whether identified health provide clear evidence of issues are being tackled (e.g. levels of cardio vascular disease), if healthy lifestyles are policy delivery and a basis being adopted, if people have access to open space and are taking part in physical for review of the Core activities and if people have adequate access to facilities. Strategy 4 4 Maria Nash Barnet Women's CS15 More local groups should be involved and not only the usual stakeholders & LSP which See response at 472/9 Addition of 8 8 Design Group Delivering the is not local enough to monitor the Core Strategy. As the Core Strategy should be a monitoring 3 Core Strategy living document to enable laws and environment issues like climate change to meet indicators in (formerly these changes then local people should have a voice and monitoring abilities through Appendix B. CS14) LA21 groups 4 4 Michael Storey CS15 Section 106 money should be spent on the community where the development is, to Section 106 money is one None 8 2 Delivering the help soften the impact of a new development. Please remember that Section 106 source of funding for the 7 Core Strategy money is not the be-all and end-all of your aims. critical infrastructure required (formerly to growth. CS14) 4 5 Glen Rollings Greater London CS15 TFL wishes to see a reference to working with ‘Transport for London’ under section Agree Revise 8 4 Authority Delivering the 20.2. supporting 8 Core Strategy text to CS 15 (formerly CS14) 4 5 Glen Rollings Greater London CS15 TFL would like to see the inclusion of additional text under paragraph 20.4 to state We clearly highlight our None 8 5 Authority Delivering the “developers will be expected to fund necessary and relevant transport infrastructure S106 priorities for transport 8 Core Strategy improvements to support development” at 20.5.3 (formerly CS14) 4 5 Glen Rollings Greater London CS15 TFL would like to see the inclusion of additional text under paragraph 20.5.2 to state Agree Revise 8 6 Authority Delivering the that “planning obligations can help to make development acceptable as well as supporting 8 Core Strategy successful and sustainable”. text to CS 15 (formerly CS14)
335 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Glen Rollings Greater London CS15 At paragraph 20.5.3, the bullet point “improvements to public transport infrastructure Agree Revise 8 7 Authority Delivering the and system” has been written twice. supporting 8 Core Strategy text to CS 15 (formerly CS14) 4 5 Glen Rollings Greater London CS15 TFL would like to see the inclusion of additional text under paragraph 20.5.3 to state Our Core Strategy reflects None 8 8 Authority Delivering the that “the priorities for s106 funding will be transport and affordable housing”, as stated the S106 priorities for 8 Core Strategy in the London Plan. Barnet. (formerly CS14) 4 5 Glen Rollings Greater London CS15 TFL welcomes the reference to pooled contributions at paragraph 20.5.4. We welcome this support None 8 9 Authority Delivering the 8 Core Strategy (formerly CS14) 4 6 Glen Rollings Greater London CS15 Where development over TFL land is proposed or where there are significant transport TFL would by definition be None 8 0 Authority Delivering the implications TFL will expect to be party to a Section 106 agreement (paragraph 20.5.5). heavily involved in the 8 Core Strategy application process and (formerly negotiations for the sort of CS14) developments mentioned. This is not considered a necessary addition to the Core Strategy. 4 6 Glen Rollings Greater London CS15 TFL would welcome reference to its Guidance on residential travel planning in London This is not considered a None 8 1 Authority Delivering the and Guidance for workplace travel planning for development and the travel plan necessary addition to the 8 Core Strategy thresholds detailed within them in this section of the Core Strategy. This is required Core Strategy and is better (formerly under Policy 3C.2 of the London Plan. addressed in our emerging CS14) Development Management Policies DPD
336 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 1 Emma Ford London Fire and CS15 The LFB wish to see the inclusion of emergency services as a key priority for S106 Fire safety is an issue for None Emergency Delivering the contributions in paragraph 20.5.3. It is vital to assist the LFB in continuing to provide a Building Control. Planning Core Strategy fast effective and resilient emergency response, which can be achieved through We consider that by Authority (formerly financial contributions towards improving and expanding current fire stations facilities ensuring that developments CS14) and services. incorporate design principles which contribute to Unless opportunities are taken to build safety into any new infrastructure, future growth community safety and within Barnet could create additional risks from fire and other emergencies across the security we can address this borough. The LFB urges the council to ensure that future policies specifically identify issue at an early stage and the links between future development proposals and by new developments in Barnet to reduce the burden on the designing out risks from fire, particularly in residential accommodation. This would emergency services. There include giving consideration to installing hard wired smoke alarms in social housing and is therefore no need to sprinkler systems where the risks justify it. Efforts to try and reduce crime such as highlight as a S106 priority. arson through good design should also be promoted. In addition, the LFB Fire Safety Regulation Team request to work closely with architects and Barnet's housing department, planning department and building control officers to address this issue at an early stage. The LFB believe that the capacity of the key emergency ser ices to improve community safety and maintain a speed of emergency response in line with standards the LFB have set (see London Safety Plan 2009/2012 at www.london-fire.gov.uk) is one issue which should take into account when negotiating Section 106 agreements. This plan should also be taken into account in Section 17 of the plan ('Making Barnet a Safer Place') in order to reduce crime and disorder. As part of the Safety Plan, the LFB undertakes a number of initiatives including working with the Junior Citizen scheme to help young people learn valuable personal safety life skills and in 2009, over 2,500 children from across Barnet attended Junior Citizen events. In the future the LFB request that Barnet work with the LFB to ensure resilient emergency response by improving appropriate financial contributions towards improving and expanding current fire stations facilities and services. The LFB support the negotiation of section 106 planning obligations, or Community Infrastructure Levy if this is brought in as a replacement system, and request the emergency services are always taken into account. 2 1 Jonathan Cornelius TFL Corporate General Overall, TFL CFPD supports the principles set out in the Core Strategy Direction of These sites will be None 3 Finance Travel, in particular paragraph 8.2.2 which encourages housing or mixed development considered as part of the 8 Property within or on the periphery of Barnet's town centres. To help support this aim, TFL Site Allocations DPD. Development CFPD wish to promote a number of sites for residential or mixed use, they are: Colindale Station Car Park, East Finchley Station Car Park, Finchley Central Station Car Park, High Barnet Station Car Park, Mill Hill East Station Car Park, Totteridge and Whetstone Station Car Park, Woodside Station Car Park, Site south of Nether Street.
337 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 2 1 Peter Hewitt General There is a daunting and quite often much arcane detail in Barnet's planning document A good Core Strategy is None 4 'Direction of Travel'. It is my belief that all but the most directly affected residents will written in language that 4 have had neither the time, opportunity nor inclination to study the formidable people can understand. It is assortment of documents/tables/plans/policy statements that compromise the LDF important that the Core dossier. Even the clichéd business jargon of its title is enough to deter the ordinary Strategy is clear and concise man-in-the-street.I myself have to admit therefore to having confined my study of it to so that developers, the S.8, S.10 and S14 - for it is these three categories of the so called. Core Strategy community, the council and Planning that my suburb of the borough is pre-eminently concerned with. Indeed, as its partners understand how has been so vehemently articulated during the past several years by the 'Save New the area will be changing, Barnet Campaign Members' - apropos JCoSS, Tesco and ASDA. when it will change and what their role is. We consider that our priorities for Barnet over the next 15 years avoid the use of jargon wherever possible. Consultation on the Direction of Travel included meetings and presentations to a wide variety of groups and stakeholders explaining what we were doing, why we were doing it and how they could get involved.
338 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 3 1 Asda Stores Ltd General ASDA Stores Ltd is proposing the comprehensive regeneration of East Barnet Gas In order to ensure that None 7 works, to the north of Albert Road, New Barnet for mixed used development. In a known development 9 prominent location to the north of the town centre the site offers an opportunity for opportunities within and on landmark development, able to underpin and enhance the vitality and viability of the the edge of the town centre New Barnet town centre. An application was submitted in January 2009 proposing the are managed in the right way development of the site for mixed use development to comprise residential and retail a Town Centre Framework uses. The proposal sought to remediate the site to enable a contemporary mixed use for New Barnet has been development that would significantly contribute towards the regeneration of New developed to provide a Barnet. Whilst the application was subsequently withdrawn it was acknowledged that strategy for development in the proposal would regenerate the site and the wider area. consultation with the National Planning policy promotes sustainability, central to which is the need for the community. effective use of previously developed sites. Policy encourages investment in previously developed sites that strengthens existing centres and provides a mix of uses that promotes social inclusion. The site represents the principle development opportunity in New Barnet and if it is to be brought back into active use there is a need for significant remediation works. Given the onerous cost of bringing the site forward development on the site needs to generate sufficient value to ensure the deliverability of any future proposal. In this context Barnet Council should seek to plan positively for the development of the site. If no viable solution is planned for the site will continue to blight the area. Detailed local policy promotes both housing and retail development on the Gas Works site and the Council makes clear their intention to support development of a suitable scale and function on the site that will further enhance the adjacent New Barnet town centre. In recent years New Barnet town centre has been in decline. It is important that the Council provide a planning framework that seeks to promote the opportunity at the Gas Work site presents to revitalise the wider centre. Further to our submission to the Core Strategy Issues and Options we welcome additions to the text that support the need to prioritise the development of previously developed Brownfield land and recognise the importance of retail development. We also support promotion of retail and mixed use development in existing centres. The development of Brownfield sites provides important opportunity for the Council to achieve their goal of strengthening and enhancing Barnet’s role as a competitive Borough which offers its inhabitants a high quality environment in which to live, work and play in.
339 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Sarah Burgess CABE General Unfortunately, due to limited resources, we are unable to comment on this document. Although Barnet did not None 1 However we would like to make some general comments which you should consider. benefit from a CABE 3 A good spatial plan is essential to achieving high quality places and good design. workshop we welcome this CABE believes that getting the local development framework core strategies right is advice. one of the most important tasks planners are undertaking. We have run workshops with Section 4 sets out what over 65 local planning authorities to look at how well design is being embedded in core makes Barnet distinctive strategy documents, which form part of the local development framework. The distilling the knowledge workshops offer local authorities independent informal advice from an expert panel and about the place, its allowed us to identify the strengths and weaknesses of current approaches to spatial community and its future. It planning and how design, functionality and space are dealt with in core strategy sets clear priorities for documents. design quality at different Three key messages for local planning authorities have emerged from our workshops. spatial scales in terms of the These are now embedded within a CABE publication called Planning for places: growth areas, town centres delivering good and our high quality suburbs This publication is available to download from the CABE website and historic areas and www.cabe.org.uk/publications/planning-for-places , The three key messages are as makes linkages with AAPs, follows: Town Centre Frameworks, The three key messages are as follows: SPD and other DPDs. Tell the story - A good core strategy needs to tell the story of the place, explain how it There is a clear spatial works and highlight its qualities and distinguishing features. Telling the story helps agenda through the Three everyone understand how the qualities of the place have shaped the strategy and its Strands Approach which priorities for future quality. For more information about telling the story, please refer to enables the Core Strategy to the CABE website: www.cabe.org.uk/planning/core-strategies/tell-the-story integrate the needs of places Set the agenda with the issues that need to Set the agenda: Use the core strategy to say what is wanted for the area, express be addressed. aspirations and be proactive and positive about the future of the place and say how this A good Core Strategy is will be achieved. Set out what is expected in terms of design quality and where written in language that necessary provide links to the relevant development plan documents or supplementary people can understand. It is planning documents. important that the CS is clear For more information about setting the agenda, please refer to the CABE website: and concise so that www.cabe.org.uk/planning/core-strategies/set-the-agenda developers, the community, Say it clearly - Make the core strategy relevant and understandable to a wide audience. the council and its partners Use diagrams to inform the text and communicate the strategy and show what quality understand how the area will of place means. For more information about saying it clearly, please refer to the CABE be changing, when it will website: www.cabe.org.uk/planning/core-strategies/say-it-clearly change a role is. We It is also important that there is a clear priority for design quality and place-making consider that our priorities objectives in the core strategy, setting out the key principles. This needs to be explicit for Barnet over the next 15 so that it cannot be challenged when applications are being determined. years avoid the use of jargon wherever possible.
Consultation on the Direction of Travel included meetings and presentations to a wide variety of groups and stakeholders explaining what we were doing, why we were doing it and how they could get involved
4 1 Jon Cox London General The LDF document is inadequate regarding transport provision, even though the stated The section on transport has None
340 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 1 Campaign for aims of travel reduction, and of cycling and walking, are very welcome. Much of Barnet been revised but the car is 6 Better Transport was built between 1900 and 1939, at low density and with wide roads (following a the dominant transport mode hierarchy of road widths determined by a Royal Commission of 1905). Al-though trains in outer London and is likely and tubes are used for central London commuting, they provide no opportunity for to remain so for the orbital travel. The bus system is used by non-drivers, the environmental aware, and foreseeable future those who cannot afford a car (or at least unrestricted use of fuel). Apart from commuting, car driving is often the only socially acceptable means of travel for the wealthy and essential for others where public transport – such as involving multiple train and bus journeys, or shift work – is unfeasible. The use of a car is considered highly convenient. Even in peak hours, it provides a usual (although deteriorating) near- certainty of travel time. However, there are major planned developments in Barnet and surrounding boroughs as well as a general increase of population in London. 4 2 Jon Cox London General The Outer London Commission (OLC) was established by Mayor Boris Johnson to We have revised the section None 1 Campaign for under-pin his commitment to his political heartland (Barnet was the only borough on the London Plan to refer 6 Better Transport mentioned in his election manifesto) or at least to reverse the perceived over- to the input of the OLC. We concentration on inner London, by the previous administration. As the LDF makes have revised the CS to clear, a final report was expected in ‗autumn 2009‘but as of January 2010 it is still incorporate the draft London awaited. However, the OLC has clearly been kicked into the long grass, and stopped Plan and its policy direction being a proper strategic investigation part-way through its deliberations, when it was on Outer London. retro-fitted with a restrictive: ‗RECOMMENDATIONS MUST BE PRACTICAL, REALISTIC AND TIGHTLY TIMETABLED‘ Please see responses at To meet a new political imperative of being seen to avoid any spending commitment or 416/7 and 418/18 hostage to fortune. In that respect, its credibility has crumbled. Nevertheless, the Great and the Good did start with a remit including how to: “...improve infrastructure, especially the balance between different types of orbital and radial movement, strategically and locally And the ‗Interim report‘ of July 2009 reported that: “Improvements to connectivity and movement within outer London are crucial. There is a strong feeling that improvement to orbital movement is especially important, coupled with realism over the scope for future large scale investment. The focus for investment should be based on a „spoke and hub concept rather than a contiguous high speed link around the city and there is considerable potential in smaller scale improvements.” That last sentence was part of the deliberate down-grading from strategic planning to minor schemes, but it may have been to kill off the long distance West London Orbital tube line, rather than the more local light rail proposals. Quite late on in its proceedings, the OLC turned its attention to ‗quality of life issues (although Barnet‘s public submission had mentioned it, unlike virtually all other boroughs, which concentrated on ‗orbital transport and economic and training issues). Some of this is summarised in the Barnet LDF: “There is scope to enhance [quality of life] while accommodating growth, providing a sensitive approach is taken towards intensification.” Our submission is that this is not being done by Barnet. The borough is attempting to impose giant road improvements‘ at its development sites, without any attempt to consider alternatives that is, to treat the large development sites, within and outside the borough, as providing the opportunity for entirely new orbital transport infrastructure.
341 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Jon Cox London General The LDF says that this study states that “... Improving transport links ALONG the Please see response at None 1 Campaign for corridor will be vital for [the] anticipated growth in employment.” 416/7 on the light rail 6 Better Transport Two points are submitted: Firstly, the study also promotes links ACROSS the corridor proposal (Navin Shah, AM for Brent and Harrow claims credit for that). Any study of a long rectangle, like this corridor, is bound to emphasize the radial routes (Thames link and the A5), but a study of an orbital sector of outer London (never carried out) would be bound to do the same for orbital routes. The ‗North London Strategic Alliance‘ of boroughs, to which Barnet belongs, has never financed any serious orbital transport studies, although it has at least produced a January 2009 ‗Transport Priorities‘ paper, that states: “...Highway congestion and public transport overcrowding is already acute in many areas; there are gaps in connectivity, especially for orbital movements, and the capacity and quality of infrastructure and services often fails to live up to the aspirations of residents, businesses or communities. This is expected to worsen over time.” Secondly, Barnet‘s verbal submission to the OLC asked: What was so great about large-scale long distance commuting anyway? This was in terms of trying to build new ‗local‘ town centres (like Brent Cross) where, as in the ―Lester effect that was mentioned by Barnet, office staff commute in, they work, they go home again. The benefit to the (literally) LOCAL economy is limited, except in terms of lower-grade jobs and lunchtime ‗retail opportunities‘. Barnet would not even benefit from the business rates gained, which go to central government.
4 4 Jon Cox London General Barnet strategic planners will hopefully not be totally unaware of off-road light-rail Please see response at None 1 Campaign for proposals, which would join Brent Cross to Colindale, and maybe Mill Hill East, as part 416/7 on the light rail 6 Better Transport of a wider network involving neighbouring boroughs. Such a concept has been proposal ―supported in principle by Ealing and Harrow full council meetings (and hopefully The Core Strategy clearly Brent and Camden in the future). states why AAPs were It is surprising to read that the Colindale and Mill Hill East Area Action Plans were (in prepared ahead of the order to support early delivery of housing) deliberately allowed to be prepared ahead document. the borough-wide Core Strategy. No wonder the AAP transport assessments were so parochial! Given that the previous Unitary Development Plan for the borough was so inadequate (and car-based) this explains why no serious, borough-wide, strategic transport assessment has ever been fed into the AAPs.
4 5 Jon Cox London General Same again, with knobs on! Please see response at None 1 Campaign for The case of Brent Cross Cricklewood is actually far worse. As the LDF says, the Brent 416/7 on the light rail 6 Better Transport Cross Cricklewood Development Framework was produced to: proposal. ―...guide and inform design and delivery of development. Brent Cross –Cricklewood Unfortunately, the (monopoly) Brent Cross developers have interpreted the including the Development Development Framework as an approved outline planning application. The consultation Framework, London Plan they have held over the last five years has been almost universally condemned as and UDP has been subject arrogant and in-effective. No significant changes to their EDAW land-use plan has been to extensive consultation in tolerated. The local authority has been totally ineffective in promoting the aspirations the past 10 years. and concerns of the public, compared to the private interests of the developers.
342 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Jon Cox London General The Strategic Community Strategy of Barnet includes the theme of growing Transport impacts were None 1 Campaign for successfully. Barnet‘s second of its main strategic Three Strands Approach demands considered using modelling 6 Better Transport the enhancement and protection of the borough. Its third Strand promotes growth that work as part of the evidence is sustainable. Despite all three strategic statements above, Barnet risks being base for the Area Action overwhelmed, or at least greatly harmed, by the transport impacts of its huge Plan. redevelopment sites, and they will also create increased air pollution from traffic (and ―incinerators !) which harms the ―clean, green and safe priority outcome of its ‗2009/10 Corporate Plan‘. 4 2 Julia Hines Age Concern General We support the planned growth in housing and employment, in particular the We welcome this support None 1 commitment to protecting the local environment and green spaces (2.3.3). Exercise has 8 been proven to have a beneficial effect on reducing both morbidity and mortality from many of the most serious and prevalent diseases of old age including coronary heart disease, diabetes mellitus, cancer, depression and dementia. Maintaining mobility is also important in preventing falls. 4 5 Julia Hines Age Concern General We support the sentiments in section 6, but would like to emphasise that accessibility Design consideration will be None 1 and improving health should not just consider buildings. Even pavements, to dealt with in the 8 encourage walking by older people, benches for older people to rest whilst out and Development Management public toilets, or a council run scheme whereby toilets in cafes and restaurants can be DPD. We do recognise that used by the public (with a notice advertising this in the window) in return for a small fee these issues have an impact from the Council for providing this service, as occurs in other boroughs, all have on making places accessible strategic importance in making the borough more accessible and encourage people to and encourage their walk rather than use other forms of transport and to support local shops and provision through design businesses. policies in the DM Policies DPD. We do recognise public toilets as community infrastructure. 4 2 Julia Hines Age Concern General Note that the evidence submitted to the Barnet Characterisation Study is attached to This evidence will be passed None 1 3 their submission. to Urban Practitioners. 8 4 1 Daniel Hope Suburbs General + Too few policies. Wording is opaque and vague. The Core Strategy is meant to be The LDF is a folder of None 2 Foundation Barnet's interpretation of guidance and local need. It is meant to be a Barnet centred documents and the Core 8 document. Our submission is that the Three Strands Approach requires a more detailed Strategy is at its heart. There set of policies. It requires that the Three Strands Approach resolution, adopted by the is a clear spatial agenda Cabinet, drives the Core Strategy. This has not been the case. through the Three Strands Approach which enables the Core Strategy to integrate the needs of places with the priorities that need to be addressed in Barnet. We are required to adopt a positive spatial strategy approach to DPD production and not reintroduce the 183 saved policies of the UDP.
343 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 2 Daniel Hope Suburbs General + Document rushed. Characterisation study that should be lynchpin for core suburban PPS12 states that it is critical None 2 Foundation policies is not yet complete. We participated at length and detail at the Issues and that Core Strategies are 8 Options stage. There has been an unexplained leap from the Issues and Options stage produced in a timely and to the publication of draft policies. The public have been excluded. The major piece of efficient manner. The work to support the Core Strategy, the suburban Characterisation study (curiously Direction of Travel and contracted out to 'urban design' specialists by the Council) is not yet ready. Minutes of Issues and Options form part the Members Steering Group suggest it was due to be ready by mid 2009 but the of the same regulatory stage document is still in draft. We do not see how the Council can proceed from I&O to DoT (Reg 25) of the Development stage until this is complete. Plan regulations. We therefore do not consider it rushed. The Direction of Travel was informed by the draft Characterisation Study and this is clearly stated in the document. We also ensured that a draft version of the Characterisation Study was published as part of the consultation period.
344 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Daniel Hope Suburbs General + Out of kilter with national and regional policy. Does not follow the binding Three Barnet's Core Strategy has None 2 Foundation Strands Approach. Barnet had put forward to the former Mayor of London plans for clearly anticipated the 8 massive growth, centred Mayor's own direction of In the clearly defined growth areas. The old London Plan, soon to be replaced, travel on the London Plan. It encouraged high density development which Barnet Council sought to exceed. The has highlighted the need to new replacement draft London Plan puts the break on such developments and seeks to optimise rather than encourage densities that sit well in the surroundings. Even though Barnet is in on target maximise housing density to meet the growth targets it persuaded Ken Livingstone to accept, the DoT document and to reflect local context, seeks to spread growth out from the specified areas and areas with high public public transport accessibility transport accessibility. Outside of the scope of the Three Strands Approach, policies in and provision of social the DoT encourage intensification outside of formal Town Centres and along infrastructure. The Density unspecified 'major thoroughfares'. Whereas the Three Strands Approach calls for the Matrix in the draft London retention and promotion of houses in suburban areas, the LDF CS DoT calls for houses Plan (table 3.2) is the same to be torn down and replaced with flats as the one in the London Further due to the rush to publish the DoT no account could be made of the Draft Plan 2008. Higher density Replacement London Plan which the Mayor calls on Planning Authorities to treat as a development is therefore not weighty material consideration. Despite this call the Council seeks to hard wire into the discouraged by the draft Core Strategy the Ken Livingston density matrix into Barnet's policy. revised London plan which seeks to optimise the potential of sites. Major thoroughfares are no longer promoted as providing opportunities for infill housing development We have conducted extensive consultation on the Direction of Travel which has involved the Civic Network, Citizens Panel, Residents Forums, the Local Strategic partnership board and nineteen individual meetings with local interest groups or representative bodies. These meetings and presentations explained what we were doing, why we were doing it and how they could get involved. The Council's consultation with the community at both stages can be demonstrated by the level of response we have received.
345 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Daniel Hope Suburbs General + Breach of SCI and PPS12 To ensure that the Core None 2 Foundation The Foundation is concerned at the half hearted engagement with the public, that the Strategy is sound it must be 8 Council has had in relation to the LDF CS. This is most clearly shown in something that justified and built on a robust the Council committed itself in the SCI and is entirely in its control. In the SCI the and credible evidence base. Council committed itself to producing a centre page special insert in Barnet First at This evidence includes the each stage of the process. The Council failed to produced the detailed insert at I&O or views of the local community DoT stage in Barnet First. In fact at the I&O stage Barnet First made no reference to and others who have a stake the LDF CS consultation (something the Council admits in its report). At the DoT stage in the future of the area. This there was a very brief mention inviting people to go to the website. PPS12 and the SCI is set out in the document. require the Council to engage the community in 'continuous engagement, specifically The extent of consultation is those consultations shouldn't be 'one off events. As one of the most significant further set in the Direction of contributors to the I&O stage we expected to be kept informed of progress towards the Travel consultation report. A Council producing draft polices. However a whole series of meetings with Councillors good Core Strategy is written and Officers were held behind closed doors which the public weren't informed of or able in language that people can to contribute too. Had Barnet followed Enfield's example of a formal Cabinet Sub understand. It is important Committee this would have happened. The DoT document was brought before the that the CS is clear and Cabinet in a report at a time before the I&O November 2009 Consultation Report had concise so that developers, been published and before the Draft Characterisation Report was ready. It is our the community, the council contention that the Cabinet should have sent the report back for more work, it was and its partners understand clearly not ready. Further they should not have made a resolution without directly how the area will be seeing the representations. The Consultation Report contained scathing criticism from changing, when it will the citizens' panel and others over the scope of consultation and jargon used. This was change and what their role withheld from the Cabinet. is. We consider that our priorities for Barnet over the next 15 years avoid the use of jargon wherever possible
4 5 Daniel Hope Suburbs General + Cabinet have been disengaged in the process. Needs fresh leadership. It is common The cross party LDF None 2 Foundation for members' of Barnet's Cabinet to publicly admit of the lack of knowledge of Planning members Steering Group is 8 matters. Unlike Planning Committee councillors we are unaware of any training Cabinet considered an appropriate Members have undertaken on Planning Policy matters. Similarly we are unaware of any forum for taking the LDF of the several meetings that have taken place between community representatives and forward and has been the Community where any Cabinet Member has sat in or taken part in. As previously operational since 2007. We mentioned, we believe Enfield Council have the right approach. They have a specialist have carried out training for Sub Committee of Cabinet which, it is clear, drives the strategic approach to the LDF. all Councillors on the LDF The minutes are clear and precise and show resolutions. Compare this to the Barnet and have made 'Members LDF Steering Group' which has vague minutes devoid of decisions and focus presentations on the Core on trivia. Strategy to all political We submit that the Cabinet should attend external Planning training, take control of this groups on Barnet Council. document through a sub committee so that Barnet's needs can come forward in policy - just as has happened in neighbouring Enfield. The Foundation contends that the Council has jumped too far too fast. The Council needs to withdraw these draft policies and return to the results of the I&O stage. A sub committee of Cabinet, under fresh leadership of the Planning Service, needs to look at the results of the I&O stage together with the Three Strands Approach Cabinet resolution and the new draft replacement London Plan, together with Enfield's and Westminster's Core Strategies and produce a Barnet centred document that Puts the Community First.
346 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Gaby Kagan Labour Group General If Barnet’s population does increase over the next 15 years from 331,000 to 384,000 as In line with the need to Revise CS 4 2 GLA projections indicate, then we must have plans to manage and provide for that ensure that the Core and CS9 9 growth. Considering the present problems we face with the dire need for affordable Strategy is deliverable an Publish housing, the pressure on school places, the unsustainable volume of car use and the Infrastructure Delivery Plan Infrastructure lack of good east-west public transport links, it’s unfortunate that the Strategy does not will be provided at the Delivery Plan indicate more clearly how this might be done or even give the impression that these publication stage. Policy in challenges will be seriously addressed. CS9 sets out what key The ‘preservation’ of Barnet as it is and as envisaged in the Three Strands policy transport infrastructure is document is the theme that pervades this Strategy. But the “preservation” of Barnet will going to be provided to not occur if robust and enforced policies on tackling climate change, encouraging a shift support growth. The to more sustainable modes of travel and developing proper orbital public transport links infrastructure delivery plan do not get the required prominence and emphasis within this Strategy. sets out what, when, where The Strategy does not give enough emphasis to housing need, and in particular to the and how it translates into proportion of residents and families in Barnet on average and lower incomes who have delivery over the next 15 household incomes of less than £40,000 per annum and will therefore not even be able years including transport, to afford to take advantage of discounted or shared ownership schemes to buy a home community faculties and in the borough. Barnet has over 17,500 families on the housing waiting list. The parks. council housed just 419 families from the list in 2008/9, so at that rate of re-housing it The Core Strategy clearly will take 40 years to ‘clear’ the list as it is, before even beginning to deal with the issue addresses these issues and of the envisaged population growth to 384,000 by 2026. The need to build affordable the SHMA provides the homes for rent cannot be overstated or emphasised enough and should take more evidence of housing need. prominence in the Strategy if we are to retain a balanced community. On this basis we have set a target for affordable housing and a n appropriate tenure split.
4 1 Dennis Pepper Barnet Borough General Direction of Travel does not confine itself to delivering sustainable development. Quite We do recognise the Revise 3 Group London rightly it ‘addresses other factors’ (1.2.1) too, though in our view these should not be importance of habitats and Section 12.5 0 Wildlife Trust restricted to making places ‘attractive and distinctive.’ The effects of extensive new species and the need to developments go beyond ‘balancing the needs of residents, businesses and future protect and enhance these. generations’.
4 2 Dennis Pepper Barnet Borough General Although the document states (1.1.3) that it is ‘not necessary (our itals) for the Core We do recognise that not Add 3 Group London Strategy to repeat either national or London Plan policy’ it is nevertheless highly only people will be affected references to 0 Wildlife Trust desirable that it should do so: it is important that the links are made here even though it and have added references Blue Ribbon may well be expanded in subsequent DPDs and SPDs. This applies also to policies to Habitat Corridors, Blue network and contained in the current UDP. Such an open procedure would make reference to Ribbon Network and Watling Watling relevant national and regional policies easier for all users. Chase. The map, distribution Chase We note, for instance, that the Direction of Travel makes no reference to Barnet’s of natural space has been Community support for the purposes of Green Belt land, to the Mayor’s ‘Blue Ribbon Network’, or to revised to highlight Barnet's Forest. Barnet’s support for the objectives of the Watling Chase Community Forest. The ways watercourses. in which all of these are incorporated into the ‘direction of travel’ Barnet is engaged on The London Plan forms part are relevant to the quality of life of future generations. It is, of course, not only people of Barnet's development who will be affected. plan and it is therefore not necessary to repeat national or London Plan policy. The Core Strategy provides a list of UDP policies at Appendix C and sets out how they will be replaced by the Core Strategy.
347 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 4 Dennis Pepper Barnet Borough General One core objective is to enhance and protect our green and natural open spaces We refer to our earlier New 3 Group London (p.21), but as ‘places for recreation and biodiversity’ without any indication that response at 430/2 paragraph 0 Wildlife Trust increased human activity may well harm or destroy this ecological diversity (in which 12.5.4 on Barnet has so far shown no practical interest). It is noticeable, for example, that in the habitat AAPs at BX/C, Colindale and Mill Hill East the areas of green space have been corridors significantly reduced (and isolated) and that what left or opened up has been given over recognising to sport and recreation. the need for Barnet is, we are told, ‘rich in green spaces and biodiversity.’ We are not told that both species to are in decline in the borough (house sparrows, skylarks and hedgehogs – to name but move three – are fast disappearing). If the current ‘direction of travel’ is not redirected the between situation will be substantially worse in the vibrant new suburb of 2026. We recommend different that the Planning Authority look again at Barnet’s ecology with the intention of ensuring types of that the primary function of our green spaces is not abandoned to the (understandable) habitats. wish to provide for people’s enjoyment and recreation.
4 1 Dennis Pepper Barnet Borough General On an entirely different matter, we think that Table 1 (pp. 21-24) is both confused and Table 1 clearly shows the None 3 1 Group London confusing as it mixes policies and objectives and, also confusingly, incorporates linkage between the 0 Wildlife Trust ‘ambitions’ as well. We think it important to separate aims (ambitions) and objectives structure of the Sustainable from one another and from the policies devised to achieve them. Community Strategy and the Core Strategy. 4 1 Helen Massey Barnet General We have found many positives in this document. We are particularly pleased with the We welcome this support None 3 Residents departure from the “one size fits all approach”, and that individual solutions will be 2 Association sought for each of the individual town centres. We believe it is only in this way that there is any hope of engendering any sense of civic pride. We look forward to making a constructive contribution to the eventual strategy for High Barnet.
4 2 Helen Massey Barnet General A general concern which we expressed at the “Issues and Options” stage and again Core Strategies should show Publish 3 Residents when you came to talk to FORAB is that so much of your vision and strategic objectives how the vision, objectives Infrastructure 2 Association expressed in sections 1-6 are dependent on the actions of other stakeholders. Whilst and strategy for the area will Delivery Plan the vision might be laudable we are not convinced that the Council’s strategy for the be delivered and by whom next 15 years should be so heavily reliant on something over which they have such little and when. This includes the control. Surely the Council has to set its objectives according to what it can achieve? provision of infrastructure to An objective might be to encourage TFL to deliver integrated transport but TFL not the support the growth Council has to deliver it. highlighted in the Core Strategy. In line with national planning policy guidance an infrastructure delivery plan will be produced which will provide detail on what infrastructure will be provided and where. This IDP must be strong enough to stand up to independent scrutiny.
348 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Helen Massey Barnet General A more specific concern is that section 5 on the challenges to be faced might be seen We consider that Section 5 None 3 Residents as a touch one sided. The positive bullet points at the start need to be balanced by the provides a fair portrayal of 2 Association negatives, which are causing difficulties. The rest of section 5 could then be more Barnet’s challenges clearly focused on how the positives might be enhanced and the negatives tackled. including deprivation. The negative bullet points might be • Shortage of affordable housing • Areas of deprivation Traffic congestion is • Limited entertainment and recreation facilities highlighted as an issue in the • Declining town centres section on providing effective • Traffic congestion and efficient travel. The • Poor east/west public transport facilities. Leisure Facilities Strategy is Most of these points are covered in the later detailed sections of the document. currently modelling unmet However, we don’t believe that traffic congestion receives the attention that it should; it need to facilities and will is a major problem but barely gets a mention. Nor do we think that having lots of green inform the Infrastructure belt and parks is an acceptable substitute for leisure facilities. A misjudged scheme to Delivery Plan. centralise facilities - arts depot – is one that we hope will be avoided in the future.
4 1 Georgia Wrighton Women's General The Core Strategy clearly outlines the social and economic issues faced by the We welcome this support None 3 Design Group borough over the period of the plan (next 15 years) which include challenges to 3 accommodate successfully a growing population. The population growth is anticipated to result in residential community which is more diverse, and with a higher number of both very young and old residents. This in turn will require an appropriate level of community, social, health and education facilities. The Core Strategy also confirms that whilst Barnet is a successful borough, it also has some of the top 10 most deprived areas nationally. 4 2 Georgia Wrighton Women's General The Core Strategy refers often to the need for sustainable development and We have to acknowledge Revise 6.2.1 3 Design Group consideration of climate change, but principles set out in the document, like the that many residents are 3 statement in paragraph 14.8 that the ‘the car is set to remain as the most dominant largely reliant on the car for form of transport in outer London’ conflict with this aim and overall there appear to be necessary journeys. We inadequate policies and measures to tackle this issue given the level of growth therefore highlight the proposed. objective as reducing the need to travel and to keep Barnet moving in a sustainable way which provides choice by widening the travel option available. 4 1 Robert Newton General Reason: The London Plan (February 2008) is being overtaken by events. Barnet’s Core Strategy is Revise 3 Delete wording in Paragraph 2.7.3 and replace with: likely to be adopted before Section 2.8 6 “The London Plan is expected to be significantly revised over the Core Strategy Plan the review of the London on London Period and it is likely that it will be reduced in size and detail for at least some of the Plan is completed. To be in Plan period. Therefore the Core Strategy has been drafted to provide a robust, locally general conformity we have distinctive policy framework for Barnet that does not repeat regional guidance but also to reflect the policy approach minimises risk to delivery from changes to the London Plan.” [See paragraph 2.18 of of the existing London Plan the City of Westminster Core Strategy Publication Draft (November 2009)]. while signposting the changes highlighted in the draft London plan.
4 5 P E Pickering General One drafting point. The document is inconsistent between 'Finchley Church End' and Agree Replace 3 'Finchley Central'. The latter is the name of a tube station, and the former should be references to 7 used. Finchley Central with 349 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations Finchley Church End
4 1 Les Morris National Grid General The Preferred Options report highlights Mill Hill East area as a Growth Area, delivering These are detailed matters None 3 around 2,500 homes and 500 new jobs. National Grid own and operate Mill Hill more appropriate to 8 substation which is located in the vicinity of the Mill Hill East Growth Area. individual proposals and not While National Grid does not object to future redevelopment in this area, we would like to the Core Strategy. to take this opportunity to highlight that substations are vital to the efficient operation of our electricity transmission network for switching circuits or transforming voltage. Mill Hill substation is an essential part of the transmission network and has an important role to play in maintaining the supply of electricity to the local distribution network operator and therefore ultimately to homes and businesses throughout Barnet and the wider area. The site is therefore "Operational Land" and, for the reasons outlined above, there may need to be further essential utility development at the site in the future. In addition, National Grid has high voltage underground electricity transmission cables passing through the following areas identified for development within the Preferred Options document: § Colindale § West Hendon § Cricklewood / Brent Cross § Finchley-Church End Our underground cables are protected by renewable or permanent agreements with landowners or have been laid in the public highway under our licence. These grant us legal rights that enable us to achieve efficient and reliable operation, maintenance, repair and refurbishment of our electricity transmission network. Hence we require that no permanent structures are built over or under cables or within the zone specified in the agreement, materials or soil are not stacked or stored on top of the cable route or its joint bays and that unrestricted and safe access to any of our cable(s) must be maintained at all times The information supplied is given in good faith and only as a guide to the location of our underground cables. The accuracy of this information cannot be guaranteed. The physical presence of such cables may also be evident from physical protection measures such as ducts or concrete protection tiles. The person(s) responsible for planning, supervising and carrying out work in proximity to our cable(s) shall be liable to us, as cable(s) owner, as well as to any third party who may be affected in any way by any loss or damage resulting from their failure to locate and avoid any damage to such a cable(s). The relevant guidance in relation to working safely near to existing underground cables is contained within the Health and Safety Executive’s (www.hse.gov.uk) Guidance HS(G)47 “Avoiding Danger From Underground Services” and all relevant site staff should make sure that they are both aware of and understand this guidance.
350 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Zenda Green Mill Hill General Mill Hill Preservation Society are deeply concerned how Mill Hill can maintain it’s The Core Strategy clearly None 3 Preservation character and identity when Barnet Council propose to build 28,000 new homes in the highlights the contribution of 9 Society Borough of Barnet by 2026 (P19) and project a population of 384,615. With such growth areas such as Mill significant density this will destroy the surrounding suburban character. Barnet Council Hill East to the growth of need to make sure that Mill Hill’s character and identity is fully protected and enhanced Barnet. through the LDF. Section 4 sets out what makes Barnet distinctive distilling the knowledge about the place, its community and its future. It sets clear priorities for design quality at different spatial scales in terms of the growth areas, town centres and our high quality suburbs and historic areas. It makes linkages with AAPs, Town Centre Frameworks, SPD and other DPDs. There is a clear spatial agenda through the Three Strands Approach which enables the Core Strategy to integrate the needs of places with the issues that need to be addressed. 4 1 Zenda Green Mill Hill General Mill Hill Preservation Society seek clarity from Barnet Council because the London Plan The adopted AAP for Mill Hill None 3 2 Preservation sets 3,500 new homes for Mill Hill East by 2026, although the Local Development East is in general conformity 9 Society Framework commits to a total of around 2,660 residential units including 2,000 new with the London Plan. Over units (P26). This needs clarity because we consider the housing density figures in the its 15 year life span the area core strategy to be too high. We feel that the figures should be lower to limit any further is expected to delivery 2,000 increase in density that would have a significantly detrimental impact on Mill Hill’s new homes. Housing density suburban character. It’s good that Barnet Council has a Vision and Objective (P19) but in the Core Strategy reflects it has been forced upon Barnet by the Mayor, who has set very ambitious housing the matrix set out in the targets. London Plan. We would also seek clarity to how the Local Development Framework will promote and The Core Strategy provides police design. This is crucially important if Mill Hill is to retain its character and identity. a hook for more detailed To conclude as previously mentioned, Barnet’s strengths in particular Mill Hill as a policies for the Development successful suburb are underpinned by its historic character, wealth and quality of green Management policies DPD spaces, it’s medium to low housing density, good public transport links and reasonably which will provide a policy good community facilities. Our Green Belt, Open Spaces, Village Greens and framework for protection, Conservation areas including key character areas –The Ridgeway, Mill Hill Village, etc conversion and need absolute protection in order for The Borough of Barnet to remain a thriving and redevelopment of suburban sustainable Borough. Mill Hill has already lost a lot of its suburban appeal and green housing. We are producing space with the growing number of back-garden developments, in-fills, the massive Residential Design Guidance developments at Mill Hill East, Cricklewood and Colindale and we wish to lose no more. SPD to provide design Barnet Council must do more to protect Mill Hill and its unique natural beauty. guidelines for places with a consistent and coherent architectural character. The Residential Design Guidance SPD will address infill development. Design Guidance Note 5 addresses 351 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations extensions to houses and has recently been revised. Our approach to protecting and enhancing Barnet's open spaces is clear in the Core Strategy.
4 1 Brent Cross General In accordance with the London Plan, the Development Partners support the In order to secure a strategic Insert new 4 Cricklewood identification of BXC as a key growth area in the borough. As the Council will be policy framework for the policy CS2 0 Development aware, on the 19th November 2009 the Planning & Environment Committee resolved to future regeneration of Brent Partners grant planning permission, subject to the completion of a Section 106 Agreement, for Cross Cricklewood we have the comprehensive regeneration of the BXC site. Therefore, the thrust of these produced a new policy that representations focus on ensuring that the emerging policy is consistent with the provides a link with the existing Development Framework and the content of the application proposals which 'saved' suite of UDP policies formed the basis of the resolution to grant. on Brent Cross Cricklewood. Any future applications for the area will be determined in accordance with the Core Strategy 'saved' suite of UDP policies on Brent Cross - Cricklewood, the London Plan and the Development Framework Supplementary Planning Guidance (adopted in 2005). 4 2 Brent Cross General Paragraph 1.4.2 identifies that an application for the regeneration of BXC has been This section has been Revise 4 Cricklewood submitted. However, given a resolution to grant has now been secured it is suggested updated to reflect the information 0 Development that the text is updated by adding following sentence: Councils resolution to box Partners The Council has resolved to support the application for the regeneration of Brent Cross approve the outline Cricklewood subject to the completion of a Section 106 Agreement. application subject to a S106. The box on Brent Cross - Cricklewood will be updated to reflect progress on the planning process.
352 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Warren Forsyth Middlesex General As a key stakeholder in the Borough and an active member of the Local Strategic We welcome this support None 4 University Partnership, the University has been involved in all stages of the LDF process to date 1 and has made appropriate representations on the emerging Core Strategy and the options being considered. These have been fairly reported and taken account of in the Council’s reports on consultation, and the University’s aims and aspirations for expansion and consolidation in the Borough have been duly recognised. Overall, the University fully supports the strategic thrust of the Core Strategy Direction of Travel, its Vision and Objectives and Barnet’s place shaping strategy with its balanced Three Strands Approach. The need to keep the document strategic, avoid repetition and attribute matters of greater detail to other Development Plan Documents such as the Colindale AAP and the yet to be produced Site Allocations DPD is recognised and we feel has generally been accomplished in a sound and balanced draft Core Strategy. The more detailed representations set out below are intended to be helpful and constructive, and should be considered in the context of the University’s strong overall support for the Core Strategy Direction of Travel. They indicate elements of the document of particular relevance to the University which are fully supported, and suggestions for alterations or additions to text where these would provide greater clarity or address some ambiguity or unintended error. We also take the opportunity at this stage to identify some of the matters of importance to the University that are to be addressed in other DPD documents.
4 2 Warren Forsyth Middlesex General The intention that the Core Strategy should reflect the strategies and programmes We welcome this support None 4 University resulting from joint working with members of the Barnet Local Strategic Partnership, 1 and the explicit recognition of Middlesex University as a LSP partner are welcomed. The University’s aspirations to expand and consolidate its operations on the Hendon campus and provide new and improved student accommodation in the Colindale AAP area have been supported by the Council and remain in line with the strategic aspirations of the Core Strategy. 4 3 Warren Forsyth Middlesex General It would be helpful if this section acknowledged the importance of the existing Further Agree Revise 4.7.3 4 University and Higher Education sector establishments to the economy of Barnet, as providers of 1 direct and indirect employment, as well as proving educational, training, CPD and business support services to local residents and employers. We suggest adding a new second sentence to paragraph 4.7.3 such as: “The Borough benefits from a strong higher and further education sector, which provides jobs as well as education, training and business support for its residents and employers.”
4 4 Warren Forsyth Middlesex General The need for infrastructure to be developed to support growth is fully supported by the Agree Revise 5.1.8 4 University University, and Middlesex University has a key role to play in providing appropriate 1 facilities and programmes to meet the needs of an increasing population and expanding economy. We suggest that the list of types of infrastructure itemised in paragraph 5.1.8 be slightly expanded to add, after “…schools,” “further and higher education establishments”.
4 6 Warren Forsyth Middlesex General The University supports the Council’s Vision statement in paragraph 6.1.1, the four Agree Revise sub 4 University themes in paragraph 6.1.2 and Barnet’s core objectives in 6.2. We suggest, however, objective on 1 that the amplification of the objective “To meet social infrastructure needs” be social expanded by the addition of another bullet point sub-objective “to support the infrastructure improvement and expansion of further and higher education establishments to meet the needs of a growing population and economy;”
353 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 8 Warren Forsyth Middlesex General The University strongly supports the enhancement and, where feasible, the shared The Site Allocations DPD is None 4 University usage of playing fields and outdoor sports pitches at Copthall where they would be the appropriate document for 1 easily accessible to students and staff at the Hendon campus and where the University site specific considerations could support sports training and education initiatives. We understand that this could such as any improvement at be covered in the forthcoming Site Allocations DPD. Copthall.
4 1 Warren Forsyth Middlesex General The University supports the enhancement and expansion of swimming and indoor The Site Allocations DPD is None 4 0 University sports and leisure facilities at Copthall, where it is keen to work in partnership with the the appropriate document for 1 Council to significantly improve the leisure and recreation facilities for joint community site specific considerations and University usage. This may be a matter for the Site Allocations DPD, although a and we would welcome any meaningful development would require at least the recognition that the existing Copthall discussions with Middlesex Centre and related development is a “Major Developed Site in the Green Belt”. We University on this. would welcome clarification and confirmation that such a designation to enable the leisure facilities to be expanded could be dealt with in the Site Allocations DPD, without a further reference being added to the Core Strategy. 4 2 British Library General The BL supports the LB Barnet Vision and Core Objectives set out in Chapter 6 of the We welcome this support None 4 Core Strategy. The BL note Objective 1 which includes ‘managing housing growth to 2 meet housing aspirations through promoting the development of the identified major growth areas’ in order to provide 25,000 new homes by 2026 to meet local and regional housing needs. The BL supports this Objective and notes that the CAAP, and the BL’s allocation within Colindale, will help LB Barnet meet its housing aspirations.
4 1 Metropolitan General Paragraph 1.2 highlights the MPA as a Local Strategic Partner The MPA support the We welcome this support None 4 Police Authority opportunity to work alongside Barnet and therefore support this reference 3 4 2 Metropolitan General Paragraph 6.2 highlights the core objectives to deliver the borough's vision. Under the Agree Revise sub 4 Police Authority heading 'to meet social infrastructure needs' a number of community facilities are objective on 3 outlined. However policing is not recognised as a community facility, contrary to Policy social 3A.17 of the London Plan. infrastructure the MPA therefore recommend that the wording of the bullet point be amended to including policing (additional wording underlined): - To ensure provision for community needs arising from housing growth including education, policing, health, social care and integrated community facilities;
4 3 Metropolitan General Furthermore, under the heading 'To promote strong and cohesive communities the The provision of policing Revise sub 4 Police Authority MPA previously made representations to include reference to policing facilities, facilities has already been objective on 3 however this was not taken on board. The MPA wish to reiterate the need for increased highlighted as meeting our social policing facilities in the borough to ensure safe and secure communities are created. infrastructure needs infrastructure This reflects the national guidance of PPS1 which states (paragraph 27 (iii)(Delivering Sustainable Development)) that development plans should promote safe and crime free communities. Recommendation: The MPA wish to make the following amendment to this bullet point in order that the emerging core strategy reflects national guidance - To create the conditions for a safer and more secure Barnet by designing out crime and reducing anti-social behaviour, particularly in known 'hotspots', and through supporting enhancements to policing facilities.
354 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Joanne Woodward London General Paragraph 5.1.5 states that over the next 20 years, Barnet will build over 28,000 new Barnet welcomes the Publish 4 Borough of homes. The majority of these dwellings (20,000) will be delivered in three growth areas: opportunity to work jointly on Infrastructure 5 Enfield Brent Cross-Cricklewood, Colindale and Mill Hill East. cross boundary needs. Delivery Plan These areas are also identified in the London Plan as having significant potential for Much of this growth is in Mill accommodating new homes and jobs and area action plans (AAP) or master plans Hill East and Colindale. Both have been prepared for these areas. Along with the proposed housing growth of these areas are subject to approximately 21,000 extra jobs will be created as a result of the regeneration of these adopted AAPs which have major growth areas. demonstrated delivery of This is a considerable growth agenda for the borough and it is crucial that sufficient infrastructure to support supporting infrastructure is planned for and delivered alongside this increase in growth. This work forms part population. of our Infrastructure Delivery The major infrastructure needs such as transport, schools and health services must be Plan matched with the growth to prevent adverse impacts both within the borough and on surrounding boroughs. Some services are already at or near capacity in simply meeting the needs of the existing population. Robust infrastructure planning is needed to ensure the needs of both the existing and new populations. Enfield Council is currently preparing an Infrastructure Delivery Plan to support the delivery of its Core Strategy and would welcome opportunities for a joint approach to infrastructure planning with Barnet and other infrastructure providers particularly for communities living close to the border of our boroughs.
4 2 Joanne Woodward London General This is particularly pressing as according to the housing trajectory on page 30, between Please see response to None 4 Borough of approximately 2,000 and 3,000 dwellings will be provided each year starting 2011/12 445/1 5 Enfield through to 2016/17, with dwelling numbers dropping each year after 2016/17. This means more than half the proposed dwellings (i.e. 17,000) for a 20-year period will be delivered in a 6 year period. This is a short time frame, commencing next financial year in which to supply supporting infrastructure.
355 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Graham Saunders English Heritage General As the Government’s adviser on the historic environment English Heritage is keen to We have addressed the Add new 4 ensure that the protection of the historic environment is fully taken into account at all gaps identified by English section 10.4 6 stages in development of the Core Strategy for Barnet. In general English Heritage is Heritage in the Publication on Barnet’s encouraged by the emphasis upon protecting and enhancing the character of the Stage. heritage. Borough through Policy CS3. However we gravely concerned that there appears to be a lack of a robust policy framework in which to manage the historic environment or We are governed by Add to unique developments such as tall buildings. These are serious omissions which appear statutory requirements for supporting to be contrary to national guidance. Further comments on these points are provided listed buildings and text of CS 5 a below and in our detailed comments. conservation areas. new section On considering the details of the Draft Core Strategy we have the following headline 10.6 on comments to make which we believe will help strengthen the quality of the Plan: PPS12 makes it very clear Barnet’s • Heritage Policy that the Core Strategy skyline and The general approach of protecting and enhancing the character of the Barnet is should not repeat or tall buildings welcomed in that it provides a broad framework in which to manage the Boroughs wider reformulate national policy. environment. However the Core Strategy in its current form does not provide a Revise CS 5 sufficiently robust policy framework in which to protect and enhance the historic on tall environment. This is a fundamental concern which is contrary to advice provided by buildings PPG15 and PPG16. To rectify this current omission a specific Core Strategy policy that recognises and values the historic environment as an asset, a key component of the Borough’s character and potential catalyst for heritage-led regeneration should be included. This should be backed up with robust evidence that defines the Borough’s historic environment as advised by PPS1 and PPG15. • Tall Buildings The lack of a policy framework in which to manage tall buildings is a significant concern. Government endorsed, EH/CABE Guidance on Tall Buildings (2007) (EH/CABE Guidance) clearly recommends that local planning authorities set out a plan- led approach to tall buildings. This omission raises concerns with regard to the robustness of Barnet’s planning policy framework to manage proposals for tall buildings and the potential impact they may have upon the historic environment. To rectify this current situation a specific Core Strategy policy that sets out a plan-led approach to managing tall buildings, based on robust evidence, in accordance with EH/CABE Guidance should be provided. • Characterisation Study We are encouraged by the Borough’s commitment to gain a greater understanding of the character of their area. However there are concerns with regards to the coverage of the study and how it could be used to inform key policy areas such as heritage and tall building issues. English Heritage views were initially. However we have not been involved in the most recent development of this important study. Our continued involvement would be further welcomed as the purpose of this work as evidence base is important for many of the points raised in this letter. • Town Centres and Open Spaces The heritage value of the Borough’s town centres and open spaces needs to be explicitly recognised and incorporated into the appropriate policy and supporting text. English Heritage would strongly advise that the Borough’s own conservation staff are closely involved throughout the preparation of the Core Strategy and associated Sustainability Appraisal, as they are often best placed to advise on: local historic environment issues and priorities, sources of data and consideration of options relating to the historic environment. Finally, we should like to stress that this opinion is based on the information provided by you. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.
356 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations However in the meantime we welcome our continued involvement with staff in the Planning Policy Team on the development of this important planning document. However once you have considered our comments we would welcome a meeting to discuss the issues raised in order to resolve them prior to the completion of the submission version of the Core Strategy.
4 2 Graham Saunders English Heritage General It is noted that we have not been sent a copy of the emerging Proposals Map for The Proposals Map will be None 4 comment at this stage. We would advise that when reviewing the Proposals Map that updated as part of the 6 all up-to-date areas of protection such as conservation areas, archaeological priority consultation on the areas, registered historic parks and gardens and strategic views are included as Development Management stipulated by section 8 ‘Proposals Map’ of Planning Policy Statement 12 – Local spatial DPD and Site Allocations planning (PPS12). When the next stage of the consultation takes place, do send us a DPD. A final Proposals Map copy of the Proposals Map as well. will be published when the LDF is completed 4 3 Graham Saunders English Heritage General Noted that a suite of supplementary planning documents and design guidance notes This matter is addressed in Publish Draft 4 are to be provided. Clarity on their subject matter and whether any of them will relate to the Local Development LDS 6 the historic environment needs to be provided. Scheme (LDS).
4 4 Graham Saunders English Heritage General We note the relationship of the AAPs and Development Frameworks with the Core The AAP evidence base None 4 Strategy in terms of timing and priority. However it is not clear what evidence base has incorporated heritage 6 been used for the AAPs and whether it incorporates heritage matters. Also it is not matters and English Heritage clear whether this evidence base has been used to inform this Core Strategy. were involved in the Clarification on this point would be useful. development of that evidence. English Heritage had the opportunity to express any concerns on the historic environment in the extensive engagement process that took place on both AAPs. An AAP is area specific with more detailed development proposals while a Core Strategy is a borough wide strategic document. It is not a borough action plan. 4 5 Graham Saunders English Heritage General We welcome in general the attempt to summarise the character of Barnet and note that We do recognise our historic Add new 4 a borough wide Characterisation Study is being produced as part of the evidence base environment in the Core section 10.4 6 to the Core Strategy. However, what lacks from the description given in paragraph 4.2 Strategy on Barnet’s is a strong sense of the existing historic environment and the range of heritage assets heritage. Barnet contains. This includes the only Battlefield in London, extensive archaeology, Revise CS 5 and a rich and diverse range of listed buildings and registered parks and gardens. In addition the Borough has a wealth of locally significant buildings, spaces and areas that may not be designated assets, but are still of importance in defining the character of Barnet. Maybe further information from the once completed Characterisation Study could help clarify and strengthen the current description.
357 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 6 Graham Saunders English Heritage General Support in general the inclusion of the core objective to protect and enhance the Agree New sub 4 suburbs. We would suggest that this objective is expanded by including an explicit objective has 6 reference to the promotion of heritage-led regeneration as a priority and improved been added access to understanding and appreciating the Borough history and heritage. on heritage led regeneration 4 9 Graham Saunders English Heritage General Support in general the approach of this section of the Core Strategy. However as It is clear from the evidence Add new 4 demonstrated in this paragraph the focus of the historic environment is the Borough’s of the Characterisation Study section 10.4 6 conservation areas. Registered historic parks and gardens are mentioned, but other that Barnet is not a on Barnet’s heritage assets that also define the Borough and require protection and enhancement homogenous urban form. heritage. are not mentioned, such as listed buildings and archaeology. We have clearly identified Revise CS 5 An additional failing of the current approach which is highlighted in this paragraph development typologies as relates to the typological description given to Barnet. We would agree that overall our framework for protecting Barnet is suburban in character but not exclusively. It contains a variety of density and enhancing Barnet's levels, building and townscape typologies as a reflection of its historic development. It character. This will be taken is not a homogenous urban form as possibly implied in the current text. This variety and forward in the Development diversity of character needs to be carefully understood and reflected in the policy Management Policies DPD framework of the Core Strategy. and SPDs. We have revised the section on Protecting and Enhancing Barnet’s Character to highlight Barnet’s protected heritage 4 3 Emma Ford London Fire and General The LFB has identified the fire station in Finchley to be suitable for redevelopment. The The Site Allocations DPD is None 4 Emergency fire station is now in a poor location following the removal of access to the North the appropriate document for 7 Planning Circular Road some years ago, which affects access throughout the borough, and identifying new fire service Authority increases response time to emergency calls. As a result, the LFB will be seeking new facilities. suitable sites for the station to be relocated, and opportunities to redevelop the existing site. It would be useful for this to be considered in the future, and the LFB would welcome discussions with Barnet. The LFB is not currently represented on Barnet's Local Strategic Partnership (LSP), but The LFB should contact the understand a review will take place this year which should rectify this situation. The Leader of the Council as inclusion of the LFB on this board will allow the LFB to have a greater influence in chair of the LSP relation to the fire safety to prevent issues at a later date. It will also bring greater opportunities on local strategic issues of this nature.
358 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 5 Mike Dawson Finchley Society General Jargon is used all too often within DoT. When discussing various component parts of A good Core Strategy is None 5 the LDF one part, say DoT, refers to another part, say Sustainable Communities written in language that 5 Strategy (Sustainable CS), in justifying a linked strategy. Often these so-called ‘linked people can understand. It is strategies’ are no more than what Barnet Council would like to happen but not a important that the CS is clear strategy. and concise so that 'In reviewing Barnet’s DoT it is noticeable that this document lacks evidence in the text developers, the community, to support claims made in it. This made commenting on the document much more the council and its partners difficult because it was necessary to cross-reference it with other documents. Where understand how the area will evidence shows that claimed sustainable development is actually unsustainable, for be changing, when it will instance, due to increased transport congestion, the solution is to say that solutions: change and what their role “…are beyond the scope of the AAP… is. We consider that our Or indeed, beyond the scope of the Core Strategy, DoT. Residents of Barnet deserve a priorities for Barnet over the Core Strategy that is tailored to their needs, not solely to the dictates of Regional or next 15 years avoid the use National Policy, or profit, as is often the case of jargon wherever possible. iv. Barnet has 20 main town centres. They are critical to the social, economic and environmental well-being of the borough v. research shows that whilst a number of town centres are thriving, others are vulnerable and face significant challenge
4 8 Mike Dawson Finchley Society General A spatial vision is set in Barnet’s Sustainable CS and targets are set in the Local Area Each policy in the Core Addition of 5 Agreement (LAA). However, the four themes and eighteen ambitions of the Sustainable Strategy will be monitored monitoring 5 CS are not a strategy showing how targets will be met. based on specific indicators indicators in and reported in the Annual Appendix B. Monitoring Report. This will provide clear evidence of policy delivery and a basis for review of the Core Strategy 4 1 Mike Dawson Finchley Society General On heritage and the arts, we endorse what Mr Pickering said in his letter of 7th January We refer to our response to None 5 4 on behalf of HADAS. HADAS at 460/1 5 4 1 Fiona Henderson General I would like to point out how difficult this consultation has been for members of the We are concerned that you None 5 public to respond to. I did visit East Barnet library on several occasions and read have had this difficulty and 8 through some of the documentation. However, it was not in a prominent place (it was have written to the Head of upstairs in the study room) and it was in a box labelled incorrectly as ‘historic (or Libraries about documents listed?) buildings.’ Also, the main document appeared to be missing at the start of the being easily available to the consultation period. public during the Why is this so important? Because here in New Barnet we do have a viable consultation period and redevelopment site (the gas works site) and we have two developers waiting in the beyond. wings to make planning applications – one for another site which would involve extensive demolition of the centre of New Barnet. As commented on p.6 of your document (item 3.23), there has been no public meeting in New Barnet even though it has been identified as a town centre. Given that the terminology in this document is not easily accessible, I do not think that this situation is at all satisfactory.
4 1 MWG Scott Garden and General Paragraph 1.2.3 ‘The Core Strategy must also be shown to be viable and flexible so as The Site Allocations DPD is None 6 Plant Centre to allow for future changes in circumstances’. This flexibility is not however apparent in the appropriate document for 2 Developments paragraph 2.3.1, Strand 1 ‘Absolute protection of the Green Belt, Metropolitan Open site specific considerations Ltd Land and other valued open space from inappropriate development.’ It would seem including changes to MOL 359 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations beholden on a rigorous LDF plan making process that all land zonings should be boundaries. examined, in the light of changed circumstances since original Green Belt or MOL zonings were made. This is in the context of an overwhelming need to provide for the increase in housing requirements, particularly for affordable family dwellings. We refer to our response at 462/1 on the Green Belt / MOL 4 2 MWG Scott Garden and General Paragraph 2.1.1 states that there are four sustainable community strategies which Our preferred housing mix is None 6 Plant Centre inform the Core Strategy and these are: supported by the sub 2 Developments • ‘ Growing successfully regional Strategic Housing Ltd • Safer, stronger and cleaner Barnet Market Assessment which • Investing in children and young people helps determine the dwelling • Healthier Barnet (including older people)’ mix for new residential schemes including the Paragraph 2.1.2 goes on to state that the spatial vision is as ‘A successful city suburb’. provision of family Such a concept would imply the inclusion of quality low rise housing. The special accommodation. qualities of suburban development are repeated throughout the Direction of Travel Document. This is in direct contrast to the proposed solution to the requirement to find new housing sites in Barnet which is that of a ‘compact city’. This is interpreted in Policy CS1 as being the redevelopment (and consequent increase in density) of housing at: • Brent Cross - Cricklewood • Colindale • Mill Hill East These developments may be suitable for non-family households but would seem to deny the opportunity for families to access the lifestyle advantages of living in those high quality suburbs which are deemed desirable elsewhere in the Core Strategy. Yet the Themes and Ambitions, Core Strategy Objectives, and Core Strategy Policies, stated in Table 1 on page 21 of the Core Strategy repeatedly make reference to ‘Providing quality homes and housing choice in Barnet’, ‘To promote strong and cohesive communities’, ‘To promote healthy living and well being’. If a more flexible view was taken of matching housing requirements with deliverable sites, including existing Green Belt and MOL Zonings, there would be the opportunity to offer suburban living to more families in need of such housing.
360 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Chris Nightingale Friends of General In order to appreciate why we wish to make the above changes, the background to the The Site Allocations DPD is None 6 Barnet Market current situation regarding our market is given in the following: the appropriate document for 3 Chipping Barnet Market has been in existence for more than 800 years. It is a vitally site specific considerations. important component of the town centre, both in terms of Chipping Barnet's identity and vibrancy and in terms of providing choice and quality at affordable prices. It is currently under threat - not just from the challenging economic climate but, unlike other markets in the Borough, its infrastructure has recently been removed (in order to carry out redevelopment which has not followed) and it has been left highly exposed (literally). The Market has moved back from its temporary home on the Stapylton Road Car Park to an empty site with a temporary hoarding around it, minimal services, no Waco’s or washing facilities and an inadequate and temporary surface. As a result it appears commercially fragile and unattractive to its customers and is in grave danger of ceasing. We welcome the Council's support for the protection and continuation of the Market, but also strongly suggest the Council make special provisions within the forthcoming LDF Core Strategy to 'protect and enhance' this important local facility by committing to the preparation of a specific Planning Brief for the market site (to be adopted by the Council) which states that any redevelopment of this site must re-provide a full stalls market (covered or open) at least equivalent in size to what existed up to the time of the ill-fated move to the Stapylton Road car park. The current planning consent for the site expires in November 2010 and the above will ensure that any subsequent application includes provision of a market (whether or not the present one still exists). 4 1 David Howard Federation of General Our first concern is that the document is too generic and does not sufficiently take into The LDF is a folder of None 6 Residents account the different characteristics of various parts of the Borough. The same documents and the Core 4 Associations in documents prepared by Westminster and Kensington and Chelsea and Enfield Strategy is at its heart. There Barnet (FORAB) Boroughs differentiate between various localities. They actively discourage certain is a clear spatial agenda types of development in one area while encouraging it in another. There is clear through the Three Strands evidence that local councillors and communities have had an active part in drawing up Approach which enables the proposals for each area with the intention of either maintaining the area as it is or Core Strategy to integrate stating what growth would be permitted or encouraged. the needs of places with the priorities that need to be addressed in Barnet. We are required to adopt a positive spatial strategy approach to DPD production and not reintroduce the 183 saved policies of the UDP. 4 3 David Howard Federation of General We are concerned that the language of the consultation document is most unfriendly to A good Core Strategy is None 6 Residents lay people and the consultation documents actively discourage reading and responses written in language that 4 Associations in in the recommended format. people can understand. It is Barnet (FORAB) important that the CS is clear and concise so that developers, the community, the council and its partners understand how the area will be changing, when it will change and what their role is. We consider that our priorities for Barnet over the next 15 years avoid the use of jargon wherever possible. 4 4 David Howard Federation of General While the officers have tried to encourage consultation it has been difficult for the We consider that the None 6 Residents average householder to understand the document as written or what it means for them. Characterisation Study 361 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 Associations in The Characterisation study which would attract more interest was arranged hurriedly for workshop in June 2009 was Barnet (FORAB) a small hand picked group of people and took less than two hours. Most attendees did well organised with the clear not know what to expect or why they had been chosen. aim of drawing on the knowledge of civic groups, such as FORAB. We are concerned that 'most' representatives of such civic groups did not understand what they were doing at the workshop. 4 5 David Howard Federation of General We also have concerns that there are discrepancies between the blue boxes containing The supporting text is more None 6 Residents the policies and the white explanatory text that precedes the boxes. The blue policy expansive because it sets 4 Associations in boxes are weaker than the previous texts. The policies are capable of multiple the context for the policy. Barnet (FORAB) interpretation which will allow developers lawyers to interpret the policies in their favour. The text forms part of the The more robust language of the white text should be used throughout to strengthen development plan and is the policies. therefore a material consideration. 4 6 David Howard Federation of General The document appears to have been based on the existing Zone One centric existing We refer to our response at None 6 Residents London Plan of Mayor Ken and does not appear to have regard to the more suburban 471/7. 4 Associations in orientated draft London Plan of Mayor Boris. The document should be amended to Barnet (FORAB) bring it line with the Mayors new London plan 4 2 David Howard Federation of General This document is an improvement on the Issues and options document but there is a We welcome this None 6 3 Residents considerable amount of further work required before we have a document that with acknowledgement and 4 Associations in implement the original three strands policy in Barnet. We urge you to carry out this recognition that the Core Barnet (FORAB) review before the next version is published. Strategy is an emerging document and reiterate our earlier comments on the Three Strands Approach being an integral part of the place shaping of Barnet. 4 4 A Reid Mount Anvil Plc General 8.2.3 refers to forthcoming Development Management Policies DPD and Site The Site Allocations DPD is None 6 9 Allocations DPD. We await the publication of these documents to assess their content, the appropriate document for 6 however, following the Inspector's comments at appeal in relation to two proposals at site specific considerations. 401-405 Nether Street, Finchley N3 1QG (LPA refs: F/00506/08 & F/00647/08) the site is clearly appropriate for a high-density residential-led mixed-use development and should be allocated as such in the Site Allocations DPD. 4 1 Government General Overall we believe that the document is progressing well. We are pleased with the We welcome this support Introduce 7 Office for brevity of the document and the limited number of policies. The layout of the document from GOL and have added new maps 0 London has much improved from your previous draft, although the document would benefit from new maps for the three and revise an increased use of maps to illustrate policies and where change will occur in focussed growth areas and revised CS1 areas, (particularly Mill Hill East, Colindale and Brent Cross Cricklewood). However, Policy CS1 to better whilst Barnet’s spatial concept is strong, GOL feel that this could still be communicated communicate the spatial better, with more detail in the spatial policies and fewer thematic policies. concept of Three Strands
4 2 Government General Section 5 and Section 6 of the document contain some important information on the We welcome this support None 7 Office for issues facing the borough and set out the vision, objectives and overall spatial strategy from GOL 0 London for the plan period. We are pleased with the progress made on the spatial objectives which are clearer and more focused on Barnet’s most critical issues and in many cases clearly measurable such as the enhancing and protecting of green and natural open spaces objective.
362 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 Government General Clear linkage between evidence base and policy should be apparent throughout the Agree At the end of 7 Office for Core Strategy. Appropriate referencing and listing of all evidence is therefore helpful. each policy 0 London Wherever possible, we urge that the evidence base is complete prior to submission. section we have added a list of references 4 1 Government General If possible, it would be of help if key diagram and other maps showed names of town Agree Revise Map 7 6 Office for centres and locations of key public transport connections. 2 0 London 4 7 David Howard New Barnet General Paras 4.1, 4.3, 9.5, 2.7.3 refer to realigning the LDF to be in line with the new Mayors The publication version of None 7 Community London Plan. This does not appear to have happened and should be done as Mayor the Core Strategy will 1 Association Boris’ Plan is more sympathetic than Mayor Kens Zone one centred document. consider the amendments proposed in the replacement London Plan but until that is adopted the existing London Plan is the document which the Core Strategy has to be in conformity with. Barnet's Core Strategy has clearly anticipated the Mayor's own direction of travel on the London Plan. It has highlighted the need to optimise rather than maximise housing density and to reflect local context, public transport accessibility and provision of social infrastructure. The Density Matrix in the draft London Plan (table 3.2) is the same as the one in the London Plan 2008. Higher density development is therefore not discouraged by the draft London plan which seeks to optimise the potential of sites. The draft London Plan clearly states that higher density provision for smaller households should be focused in areas with good public transport accessibility. 4 8 David Howard New Barnet General Para 4.4 refers to interim visits by the Planning inspector. His comments should be A frontloading visit from the Publish note 7 Community published for all to consider against the draft LDF. Planning Inspectorate took of 1 Association place in October 2009 and frontloading we will publish the note of visit the meeting at publication stage. 4 9 David Howard New Barnet General Para 6.2 the current It systems used to interface between the planning department and We intend to review the Publish Draft 7 Community public is still not working correctly three years after being introduced thus excluding the Statement of Community LDS 1 Association public from finding out about planning applications and other proposals. Involvement and this is an issue that can be addressed 363 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations through that review.
4 1 David Howard New Barnet General Para 9.6, 4.1.2, 4.1.3 reliable versions (and in many cases any version) of the robust We do make it clear what Publish 7 0 Community evidence bases are not available therefore it is unacceptable that the LDF should be our LDF Evidence Base is evidence 1 Association used as a basis for consultation made up of. We are required base to make this publicly and freely available on our website 4 1 David Howard New Barnet General Para 1.3.1. 1.4.1 Where does the word minimum appear in the London Plan in respect Table 5B.1 on page 301 of None 7 1 Community of number of new homes in Colindale and Mill Hill East and 3,500 new homes at Mill the existing London Plan. 1 Association Hill East. Annex 1 on page 213 of the draft London Plan. 4 1 David Howard New Barnet General 1.4.1 The development framework for Brent Cross Cricklewood is primarily the Development of Brent Cross None 7 2 Community developer’s expectations and did not include collaboration with the key stakeholders to Cricklewood has been 1 Association wit the existing residents. The current proposals will not deliver a high quality subject to substantial sustainable development. community involvement.
4 1 David Howard New Barnet General Paras 4.2.2, 4.2.3 these do not acknowledge that areas such as New Barnet and We highlight the Revisions to 7 4 Community Chipping Barnet were self contained separate “villages” out side London and have distinctiveness of Barnet's Key Diagram, 1 Association characters which reflect this. Although there was infill between them in the 20th town centres in the Core CS1, CS3, Century they still maintain separate identities. The proposals for intensification along Strategy and set out a CS6, CS8 all the main roads will kill this identity and when the new retail premises are added will framework for them to and result in Clone town which could be anywhere in the UK. 'Para 4.7.2. Barnet already manage change and perform supporting has too many retail outlets struggling to capture business and there must be some to their strengths. text rationalization if the town centres are to survive. This means fewer shops not more. Major thoroughfares are no longer identified as having potential for residential infill 4 2 David Howard New Barnet General All 14 of the policies in the blue boxes need some rewording to beef them up so they The supporting text is more None 7 3 Community reflect the text in the various preceding white text sections. At present they are woolly expansive because it has to 1 Association and open to multiple interpretations. set the context for the policy.
4 2 David Howard New Barnet General The present document, while an improvement on the first issues and options document, We welcome this Publish 7 6 Community does not meet the needs of New Barnet in particular and will have a major negative acknowledgement and evidence 1 Association impact on the wider community especially East and Chipping Barnet. recognition that the Core base Strategy is an emerging document and reiterate our earlier comments on the New Barnet Town Centre Framework being an integral part of the place shaping of Barnet. All the incomplete and missing evidence bases and supporting documents must be We refer to our response at produced so the whole picture can be seen in the round. 471/10 on the evidence base
364 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 1 Jan Chairman NHS Barnet General We support the overall approach of the Core Strategy, and particularly welcome We welcome the support New para 7 references to joint working with NHS Barnet. The following comments are submitted from NHS Barnet. 20.2.4 on the 2 jointly from NHS Barnet and NHS London Healthy Urban Development Unit (HUDU). Engagement Firstly, we would suggest it may be useful for the Council to review relevant HUDU In terms of engagement we Agreement documentation, including: highlight the publication of • ‘Health and Urban Planning Toolkit’ which sets out a step-by-step approach to the Engagement Agreement improve engagement between Primary Care Trusts and Local Planning Authorities and between NHS Barnet and acts as a Handbook to integrate health into the Local Development Framework and the the council as the local planning application process. planning authority. (http://www.healthyurbandevelopment.nhs.uk/documents/engagement_toolkit/HUDU_H ealth_and_Urban_Planning_Toolkit_Main_Report.pdf) • ‘Watch out for health’ which should be used at an early stage of pre-application discussions, project initiation, area action plan or masterplan stage to provide an overview and identify critical issues related to proposed development and its impact on health. The document outlines potential health benefits, positive and negative effects of proposed development and issues that need to be thought about. (http://www.healthyurbandevelopment.nhs.uk/documents/integrating_health/HUDU_Wa tch_Out_For_Health.pdf) 4 5 Jan Chairman NHS Barnet General We support the comprehensive vision for Barnet set out in paragraph 6.1.1, particularly We consider that tackling None 7 references to encouraging healthy lifestyles, providing high standard public services, health inequalities is 2 high quality of life and tackling multiple disadvantage. Again, reference to the need to addressed by the objective tackle health inequalities would be welcome. We support reference to the four themes of promoting healthy living of the Sustainable Community Strategy (SCS), which include a healthier Barnet. and well-being. An We welcome confirmation of Barnet’s SCS core objectives set out in section 6.2, amendment to the vision is including meeting social infrastructure needs and promoting healthy living and well therefore not required. being, and linking these objectives to the Core Strategy policies in Table 1.
4 1 BJ McKenny Whetstone General Having attended both the Barnet Characterisation Study meeting (10th June 09) and A good Core Strategy is None 7 Society the Civic Network Meeting (11th November 09) I find the whole subject of a long term written in language that 3 vision for Barnet somewhat overwhelming. people can understand. It is As one of the most diverse boroughs in the country, to achieve an overall strategy to important that the Core cover all its requirements, including those of the GLA is no mean task. Strategy is clear and concise so that developers, the community, the council and its partners understand how the area will be changing, when it will change and what their role is. We consider that our priorities for Barnet over the next 15 years avoid the use of jargon wherever possible. 'Consultation on the Direction of Travel included meetings and presentations to a wide variety of groups and stakeholders explaining what we were doing, why we were doing it and how they could get involved.
365 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations 4 3 G Jardine Greensquare General The Residents Association support the Core Strategy draft. We thank the local authority We welcome this support None 7 Residents for providing to us an opportunity to make comment upon the Core Strategy draft and 4 Association for inclusion in discussions relating to the same.
4 2 Dorothy Badrick UKOSF General please consider the quality of life and living conditions and environment in cricklewood The Core Strategy is a None 8 2 and childs hill borough wide document and 0 considers quality of life across Barnet. 4 3 Robert Shutler Woodside Park General Sweeping statements such as the ones stated herein are very grand but will probably Consultation on the Direction None 8 9 Garden Suburb get quoted out of context meaning that all growth will be stifled and that the of Travel included meetings 5 Residents Government and Council will have total control over the population which is presumably and presentations to a wide Association what is behind all of this. This is just one step away from Stalinist Russia which also variety of groups and stifled all creativity and development. stakeholders explaining what we were doing, why we were doing it and how they could get involved. 4 1 Glen Rollings Greater London General It should be noted that the targets for Mill Hill East and Colindale in the Consolidated We have updated paragraph Revise 8 Authority Draft Replacement London Plan (up to 2031) set out updated figures which differ from 1.3.1 and 1.4.1 to highlight Sections 1.3 8 those stated in paragraph 1.3.1. Colindale as an Opportunity Area is set with a figures in the adopted and and 1.4 minimum target of 12,500 homes and 2,000 jobs, whilst for Mill Hill East the figures are draft revised London Plan. 2,100 and 1,800 respectively. 4 2 Glen Rollings Greater London General The target figures within the draft replacement London Plan have not changed, but the See response to 488/1 Revise 8 Authority timeframe of the plan is been extended to 2031 Sections 1.3 8 and 1.4 4 3 Glen Rollings Greater London General At paragraph 2.7.3 no reference is made to the draft replacement London Plan We have updated the Core Revise 8 Authority (October 2009). The Examination in Public is likely to be held later in 2010, after which Strategy to reflect the review section 2.8 8 the replacement plan will gain increased weight in LDF and policy formulation and of the London Plan and have on London decisions. It is important that the most recent and up to date policy is referenced in the highlighted the timetable for Plan Core Strategy to ensure its longevity. its adoption. 4 4 Glen Rollings Greater London General At paragraph 2.8.1, the main report from the Outer London Commission has now been We have amended the Revise 8 Authority received. The document references the ‘spoke and hub’ concept section on the Outer London section 2.8 8 commission following the on London publication of the draft Plan revised London Plan in October 2009. 4 5 Glen Rollings Greater London General Paragraph 2.9.1 sets out that the London Borough of Barnet is involved in co-ordinated Joint working is achieved None 8 Authority working with relevant local authorities (e.g. Brent) and key agencies for the North West through day to day 8 London – Luton Corridor links to Wembley. Transport for London seeks clarity on how interactions and liaison on this is being done in transport terms. specific , schemes, projects and policies, and through the North London Strategic Alliance (NLSA), for example as mentioned in paragraph 14.6.2 3 1 A2 Dominion Vision and Our client notes the Council’s vision and objectives which seek to manage housing Housing has an important None 7 Housing objectives growth and meet housing aspirations; to provide economic growth and prosperity and role to play in kick-starting 4 strong and cohesive communities; and to ensure efficient use of land through the regeneration of our priority promotion of mixed use development on previously developed land. In order to deliver housing estates. However this vision and these objectives, the delivery of housing in general and affordable commercial led regeneration housing in particular must be prioritised. Housing is particularly important to kick start is considered more regeneration and feed the vision of economic prosperity. appropriate to the regeneration of priority town 366 Appendix B - Representations for Core Strategy Direction of Travel and Council’s Response and Recommendations centres and Brent Cross. 4 1 Government Vision and Map 1 – Spatial context for Barnet – suggest including the areas of intensification and Agree Revise Map 7 4 Office for objectives opportunity area as defined in the London Plan for Barnet as well as neighbouring 1 0 London boroughs.
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