PLANNING STATEMENT
363 EDGWARE ROAD, LONDON, NW9 6AF
ON BEHALF OF UTILITY WAREHOUSE LIMITED
TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004
PEGASUS REF: P20-1472
DATE: MARCH 2021
Pegasus Group
10 Albemarle Street | London | W1S 4HH
T 020 3897 1110 | W www.pegasusgroup.co.uk Birmingham | Bracknell | Bristol | Cambridge | Cirencester | East Midlands | Leeds | Liverpool | London | Manchester
©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited
Utility Warehouse Limited 363 Edgware Road, London Planning Statement
CONTENTS:
Page No:
1. INTRODUCTION 1 2. SITE AND SURROUNDINGS 2 3. PLANNING HISTORY 4 4. PRE-APPLICATION CONSULTATION 7 5. DEVELOPMENT PROPOSAL 10 6. PLANING POLICY CONTEXT 14 7. PLANNING CONSIDERATIONS 20 8. CONCLUSION 45
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
1. INTRODUCTION
1.1 This Statement has been prepared by Pegasus Group on behalf of Utility Warehouse Limited (‘the Applicant’), in support of a full planning application for the following proposed development at 363 Edgware Road, London, NW9 6AF (‘the Site’):
“Demolition of existing building and erection of ground plus part 19, 17, 14, 8, 6 and 5 storey building to provide 165 residential units (Class C3) with commercial use (Class E) at ground floors, together with associated parking at basement and landscaping.”
1.2 This planning application follows pre-application discussions with Planning Officers of the London Borough of Brent and the GLA.
1.3 The Statement is structured as follows:
• Section 2 provides a description of the site and the surrounding area;
• Section 3 gives an overview of the relevant planning history;
• Section 4 outlines the pre-application consultation and engagement undertaken;
• Section 5 provides a description of the development proposals;
• Section 6 sets out the planning policy context;
• Section 7 assesses the proposals against the relevant planning considerations; and
• Section 8 summarises and concludes the report.
1.4 This Statement assesses the planning considerations associated with the development in the context of national, strategic and local planning policy and guidance. It should be read in conjunction with several supporting documents which inform the planning application, which are detailed in the cover letter.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
2. SITE AND SURROUNDINGS
The Application Site
2.1 The application site at 363 Edgware Road, London, NW9 6AF (‘the Site’), is situated within the administrative boundary of the London Borough of Brent (LBB), whom act as Local Planning Authority (LPA).
2.2 The site extends to 0.43 ha and is located on the western side of Edgware Road, comprising the north-eastern part of Colindale Retail Park.
2.3 The site is bound by Edgware Road to the east, Windover Avenue to the south, the car park associated with Colindale Retail Park to the west and Beis Yaakov Primary School to the north.
2.4 The site comprises a four storey building accommodating a car show room (sui generis) at ground floor, together with a multi-storey car park above. The site also extends to include forecourt parking to the front of the building, adjacent to Edgware Road.
2.5 The site is identified in Brent’s adopted Policies Map (2016) as falling within the ‘Sarena House / Grove Park / Edgware Road’ Site Allocation (ref. B/C2), and within the Burnt Oak/Colindale Growth Area. The site also falls within the Colindale/Burnt Oak Opportunity Area.
2.6 The site is not in a Conservation Area and the existing building on the Site is not statutory or locally listed.
2.7 The site is located within an Air Quality Management Area (AQMA). The Brent Air Quality Action Plan 2017-2022 identifies measures to manage air pollution in the affected areas. The site is not located in or adjacent to a SSSI, SAC, SPA or Ramsar Site and is not in or adjacent to a Local Nature Reserve.
2.8 The site is located entirely within Flood Zone 1 which indicates a low probability of flooding. The Council’s Surface Water Management Plan (2011) states that the site is located within a Critical Drainage Area.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
Surrounding Area
2.9 The surrounding area is characterised by a variety of uses including commercial, retail and residential uses. Immediately surrounding the site are retail uses which form part of Colindale Retail Park, with offices to the south, a school to the north and commercial uses with residential flats above to the east on the opposite side of Edgware Road. Edgware Road itself is characterised by commercial and retail uses, together with residential and office developments.
2.10 The surrounding area features a mix of building heights and typologies. There are a number of tall buildings in excess of ten storeys along Edgware Road within the surrounding Growth Area. This includes Zenith House (17 storeys) on the opposite side of Edgware Road to the site; Utility Warehouse (13 storeys) at 508 Edgware Road, c290m north of the site; and The Northern Quarter London (19 storeys) at 50 Capitol Way, c470m to the north of the site.
2.11 Brent Council have also resolved to grant planning permission (ref. 17/2284) subject to S106 agreement for redevelopment of Park Parade Mansions and 381- 397 Edgware Road for part 4 part 5 and part 18 storey building comprising retail uses and 110 residential units. This site is located on the corner of Edgware Road and Grove Park, immediately to the north of Beis Yaakov Primary School, c85m to the north of the site.
2.12 Other developments currently being undertaken or recently completed within the Growth Area, including the Silver Works residential development approximately 50m the north-west of the site (behind Beis Yaakov Primary School). The ‘399’ redevelopment at the former Oriental City site along Edgware Road, approximately 150m north of the site, is also nearing completion.
2.13 Beis Yaakov Primary School located immediately to the north of the site and comprises a locally listed building. The nearest statutory listed buildings comprise nos. 3 and 5 Buck Lane (Grade II listed), located approximately 400m to the south- west of the site; and a Grade II listed milestone between the Greenway and Annesley Avenue, located approximately 340m to the north-west of the site. The closest scheduled monument to the site is ‘Manor House moated site, East End Road, Finchley’ is situated 4.5km to the east of the site.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
3. PLANNING HISTORY
3.1 The Council’s online records identify the following planning history relating to the site:
➢ 96/0713 | Alteration to enlarge existing car showroom and to front elevations. Granted 2 July 1996
➢ 97/1848 | Installation of new showroom entrance with new portico canopy and steps. Granted 16 October 1997
➢ 00/1102 | Alterations to remove grass area at the front of the premises and build a concrete slope for display of cars. Refused 12 October 2000
➢ 10/2925 | Change of use from car showroom (Use Class Sui Generis) to retail use (Use Class A1). Refused 15 March 2011
➢ 11/3000 | Refurbishment and extension of an existing vacant motor retail dealership (Alan Day Honda) into a new brand (KIA) automotive retail dealership, installation of windows to ground floor front elevation, installation of external cladding, erection of side canopy extension and associated hard and soft landscaping. Granted 11 January 2012
➢ 12/1969 | Non-material amendment (replacing existing high level cladding on front and side elevations) of Full Planning Permission reference 11/3000 dated 11 January, 2012. Granted 13 September 2012
➢ 12/1820 | Alterations to hard and soft landscaping along site frontage. Appeal allowed.
Surrounding Area
3.2 There are a number of approved developments within the vicinity of the site in the wider Growth Area which are of relevance to the application. This includes schemes incorporating tall buildings along Edgware Road, as highlighted in Section 2.
3.3 Immediately to the north of Beis Yaakov Primary School, c85m to the north of the site, the Council have resolved to grant the following development of up to 18 storeys subject to S106 agreement:
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
13-20 Park Parade Mansion & 381-397 Edgware Road | 17/2284 | Demolition of existing buildings and redevelopment of the site to provide a replacement part 4 part 5 and part 18 storey building comprising 563m2 of retail uses (Class A1, A2 A3), and 110 residential units (56 x 1bed, 30 x 2bed and 24 x 3bed) with associated car parking, cycle storage, plant and shared external amenity space at first and fifth floor level with other ancillary works. | Resolved to grant subject to S106 legal agreement 16 October 2019
3.4 To the north-west of the site and immediately east of the Park Parade Mansion site, the Silver Works development has recently been completed:
Silver Works Development (Sarena House and Allied Manufacture, Grove Park) | Ref. 14/2930 | Demolition of all existing buildings and the erection of 2 to 6-storey buildings providing 227 residential units (10 x 4bed houses, 58 x 1bed, 101 x 2bed, 31 x 3bed and 27 x studio flats), 256 sqm of affordable workspace for research and development (Use class B1(B), proposed vehicular access from Grove Park, provision for car/bike parking on the basement and ground level and associated landscaping and amenity space, subject to a Deed of Agreement dated 29 January 2015 under Section 106 of the Town and Country Planning Act 1990, as amended. | Granted 30 January 2015
3.5 Beyond this, further to the north of the site including along Edgware Road, the following developments have been approved:
‘399’ Development, Oriental Way | 12/2166 | A hybrid planning application, as amended by plans received 1 November 2012, for the demolition of all existing buildings and structures and: full planning permission (Phase 1) for comprehensive mixed-use development comprising full planning permission the erection of a 7,817sqm gross external area (GEA) Class A1 retail foodstore with associated service and delivery yard; 5,207sqm GEA of new Oriental and Far Eastern Floorspace to include shops, financial and professional services, restaurants and cafes, drinking establishments, hot food takeaways and non-residential institutions (Class A1, A2, A3, A4, A5, B1 and D1); podium slab along Airco Close; a site-wide energy centre; associated car parking spaces, motorcycle parking spaces and cycle parking spaces; associated landscaping and public realm works; new vehicular access from Grove Park and vehicular access from Plaza Walk and associated highway works; and outline planning permission (Phases 2 and 3) comprising residential floorspace (Class C3, accompanied by illustrative residential accommodation schedule indicating 183 residential units), associated car parking
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
spaces and cycle parking spaces, associated landscaping and new vehicular access from Airco Close (Phase 2, all matters reserved) and two form of entry primary school and nursery (Class D1, Phase 3, all matters reserved). | Granted 27 June 2013
The Northern Quarter (land at junction of Edgware Road and Capitol Way) | Ref. 08/2823 | Demolition of existing units and erection of replacement 4-storey and 6-storey blocks above two-storey podium decks and a frontage block of 17 storeys above the podium, comprising 460 self-contained flats, 5,360m² of retail (Use Class A1 bulky goods), a 734m² garden centre, 1922m² of floorspace for alternative uses falling within Use Classes A uses (A1, A3) or B1 (a-c), and 649m² for alternative uses falling within Use Classes A uses (A1, A3), Class B1 or Class D1 (community/health centre), 97m² of creche facilities (Use Class D1), 281 residential car-parking spaces, 500 residential cycle-parking spaces, 172 commercial car-parking and 80 commercial cycle-parking spaces, 527m² energy centre, bin stores and associated landscaping, with access from Capitol Way NW9 and Plaza Walk NW9 | Granted 30 September 2009
1-8 Capitol Way | 17/0837 | Demolition of the existing buildings and the redevelopment of the site to provide six buildings ranging between four to nine storeys and eight three storey mews houses, and the erection of a two storey commercial building, providing a total 4,051m of flexible commercial floorspace (B1(a),(b) and (c), B8, D2 and A3) across the site and 414 residential units including a mix of studio, 1, 2 and 3 bedroom units with associated basement car parking, cycle storage, plant and shared external amenity space and landscaped courtyards at ground floor level, and other ancillary works, subject to Deed of Agreement dated 12 November 2018 under Section 106 of Town and Country Planning Act 1990, as amended. | Granted 12 November 2018
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
4. PRE-APPLICATION CONSULTATION
Pre-Application Enquiry
4.1 Pre-application engagement has been undertaken with LBB and the GLA.
4.2 LBB provided pre-application advice on 24th April 2019 following the initial enquiry (ref. 19/0061/PRE) for redevelopment of the site of up to 19 storeys to accommodate up to 208 residential units, with retail/commercial use at ground floor level and basement parking.
4.3 The design evolved following subsequent meetings with LBB in May and August 2019, and the resulting scheme was presented to the GLA on 24th October 2019. The GLA provided their formal response on 19th November 2020, which was overall supportive of the proposed development.
4.4 Following this, a further pre-application meeting was held with LBB in January 2020 seeking feedback on the revised scheme, and LBB’s formal response (ref. 20/0013/PRE) was provided on 10th March 2020. A meeting was also undertaken with LBB’s Urban Design Advisor in Spring 2020 and Brent’s Design Out Crime Officer on 4th August 2020.
4.5 The revised scheme presented to LBB comprised erection of a part 19, 16, 10, 8 and 5 storey building to provide 165 residential units with retail/commercial use at ground floor and parking at the basement.
4.6 Pre-application discussions with LBB identified the following:
➢ Principle of loss of existing car showroom and multi-storey car park (both sui generis) and residential-led redevelopment of the site to include a commercial ground floor frontage is acceptable and supported by the existing and emerging policy context;
➢ The overall bulk and massing of the building would be acceptable in this highly urbanised context, with the taller point block supported at the corner junction;
➢ The horse-shoe perimeter block was considered by LBB to demonstrate a clearly defined and coherent building form, with the tall block on the corner forming a slender and more elegant element complementing Zenith House. The reduction in height from the tower to the perimeter massing of 7
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
storeys, together with the articulation of the slimmer tower, successfully reduces the bulk of the perimeter development and is supported;
➢ Allow set-back of building footprint from boundaries reducing impact and improving the quality of the public realm whilst also optimising extent of active street frontage;
➢ The impact of the proposed development on the locally listed Beis Yaakov Primary School to the north must be assessed and justified as part of a planning application. Careful consideration should be given to the degree of setback and articulation of the façade on the side elevation adjacent to the school;
➢ Consideration to be given to relationship with neighbouring properties, including retaining a 9m distance from habitable rooms to the site boundary with neighbouring school; and submission of a daylight and sunlight assessment in accordance with BRE guidelines;
➢ The proposed development should comply with the London Plan minimum internal space standards, with 10% of homes to meet M4(3) ‘wheelchair accessible homes’ standards and 90% of homes to meet M4(2). Amenity space should be provided in accordance with Policy DMP19, supplemented with communal amenity space where necessary.
4.7 The design evolution of the scheme and how it has been informed by the pre- application engagement with LBB and the GLA is detailed further within the Design & Access Statement.
Engagement and Consultation
4.8 As highlighted within the accompanying Statement of Community Involvement (prepared by Huddle), prior to the submission of this application the Applicant has consulted with the local community, to provide the opportunity to shape and inform the development proposals in advance of the final scheme being submitted for determination.
4.9 Virtual public consultation events were held on Thursday 5th November and Saturday 7th November 2020. A meeting was also held with representatives from Beis Yaakov Primary School on 9th November 2020. A summary of the comments received and how this has informed the design process is provided within the
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accompanying Statement of Community Involvement, with further detail of the design evolution within the Design & Access Statement.
4.10 Overall, the pre-application process has provided an opportunity to highlight and address potential issues at an early stage in the planning process. The development proposals forming this application submission have been refined to address feedback which has been received.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
5. DEVELOPMENT PROPOSAL
5.1 This application seeks full planning permission for the following proposed development:
“Demolition of existing building and erection of ground plus part 19, 17, 14, 8, 6 and 5 storey building to provide 165 residential units (Class C3) with commercial use (Class E) at ground floors, together with associated parking at basement and landscaping.”
5.2 The proposed development will comprise a mix of unit sizes, as set out in Table 1 below.
Number Unit Mix
Studio 9 5.5% 1 Bed 61 37% 2 Bed 53 32% 3 Bed 42 25.5% Total 165 100%
Table 1: Proposed Accommodation Schedule
5.3 All units will accord with the nationally described space standards and have been designed in accordance with Building Regulations, Part M with 10% of the units designed as wheelchair accessible or adaptable.
5.4 All proposed dwellings have access to private amenity space in the form of balconies. Communal roof terraces will also be provided at first, sixth, seventh, ninth and fifteenth floors. The first floor terrace will incorporate play space provision, with additional playspace areas provided at sixth and seventh floors.
Scale and Massing
5.5 The scale and massing of the buildings has been articulated to respond positively to its immediate surrounding context.
5.6 The height of the building extends to ground plus 19 storeys at the south-eastern corner, opposite Zenith House at 17 storeys. The building will step down to 7 storeys to the north, adjacent to the 4 storey locally listed school; and 6 storeys to the south, adjacent to the 6 storey office development at 333 Edgware Road. The
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
stepped approach will ensure the development respects its surrounding context, and the variety in height will break up the massing and provide visual interest.
5.7 The building will be set back from the edge of the site boundary along Edgware Road. This setback will also ensure it does not appear overly dominant in the wider streetscene, allowing greater legibility into the site and enabling the delivery of public realm improvements which will greatly enhance this part of the Growth Area.
Layout
5.8 The proposed layout of the building centres around a ‘horse shoe’ perimeter block arrangement, set around a first floor podium terrace which accommodates a communal garden and children’s play area. The location of the central amenity area ensures it is easily accessible and benefits from natural surveillance from the development, whilst being screened from public views from Edgware Road.
5.9 The commercial floorspace will be located at ground and upper ground levels; providing active frontage along Edgware Road, as well as onto the southern and western elevations fronting Windover Avenue and the wider Colindale Retail Park.
5.10 Car parking will be provided at the basement, which is split over two levels, taking account of the changing site levels, and will be accessed via a ramp from the rear of the building. Cycle storage and waste storage areas will be provided internally within the building, accessed via the rear, and therefore will be screened from view. As such, the development will not appear dominated by hard infrastructure associated with the residential or commercial use.
5.11 Pedestrian access is provided into the site to the residential units from the north- eastern and south-eastern corners along Edgware Road, and from a third access via Windover Avenue. The commercial floorspace is accessed from the relevant frontages along Edgware Road, Windover Avenue and Colindale Retail Park.
5.12 Each residential unit has been designed to the appropriate residential space standards which ensures each unit has a sufficient amount of internal and amenity space. External amenity space has been provided through provision of communal amenity space in the central area to the rear at first floor level, together with private balconies to each unit. Units within the building will be accessible via lifts at ground floor level, and 10% of the flats have been designed to meet Part M4(3) ‘wheelchair accessible homes’ standards; with the remainder of all flats to meet M4(2) ‘accessible and adaptable homes’ standards.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
Landscaping
5.13 The proposed development seeks to deliver greatly enhanced public realm compared to the existing situation, particularly along Edgware Road. Landscaping proposals form an integral part of the proposed development. Landscaping including street trees are proposed to the northern and southern elevations of the building which will provide attractive surrounds to the development, with a lesser amount proposed along the Edgware Road elevation to ensure that circulation and permeability to the development from the street is maximised.
5.14 The landscape proposals have been designed to create an active and engaging private amenity space at first floor podium level, incorporating a children’s play area. This amenity space area will be largely enclosed by the building form which will provide a tranquil and private area when compared with the activity along Edgware Road. Further communal roof terraces are provided at sixth and seventh floor levels, with additional smaller terraces provided at ninth and fifteenth floors.
5.15 Various soft landscaping is to be planted, including to both the communal first floor courtyard area and to the individual private terraces serving each flat facing into this courtyard at first floor level, which will create separation between these two amenity areas. Further landscaping will be incorporated to the sixth, seventh, ninth and fifteenth floor roof terraces.
Parking
5.16 The Proposed Development will provide 59no. car parking spaces; 57 for use by residents, of which 5 will be designated as disabled spaces. There will also be 2no. additional disabled spaces provided to serve the commercial use.
5.17 Of these car parking spaces, 12no. will be electric vehicle charging spaces and all the remaining spaces will incorporate passive provision. The parking spaces will all be located within the split-level basement, accessed via a ramp to the rear of the building, for use of the future occupants of the resulting development.
5.18 The proposals include secure, covered cycle storage, providing parking for 323no. bicycles; 300 for use by the residential properties (294 long stay plus 6 visitor) and 23 for use by the commercial occupiers (9 long stay plus 14 visitor).
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
Servicing, Refuse and Recycling
5.19 Vehicular access will be retained from Edgware Road along Windover Avenue as existing. Servicing and delivery vehicles will continue to enter and exit the site via this point along Windover Avenue to the two dedicated loading areas to the rear of the development, in a similar arrangement to the existing.
5.20 There are 2no. dedicated refuse and recycling stores serving the residents, which are proposed within the building with direct access to the rear to facilitate collection. Refuse and recycling stores are also provided internally within each commercial unit.
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Utility Warehouse Limited 363 Edgware Road, London Planning Statement
6. PLANING POLICY CONTEXT
6.1 In accordance with Section 38(6) of the Planning and Compulsory Purchase Act (2004), planning applications should be determined in accordance with the Development Plan unless material considerations indicate otherwise. Accordingly, national planning policies and the adopted Development Plan are the starting point for determining planning applications.
6.2 The Development Plan for LBB consists of the London Plan (March 2021), the Core Strategy (2010), Development Management Policies (2016) and the Site Specific Allocations (2011).
Development Plan
6.3 The adopted Development Plan identifies the following planning designations of relevance in respect of the application site:
➢ Burnt Oak/Colindale Growth Area
➢ Site Allocation B/C 2: Sarena House / Grove Park / Edgware Road
6.4 The site is also identified by the GLA to fall within:
➢ Colindale/Burnt Oak Opportunity Area
➢ Air Quality Management Area
6.5 The following policies are of relevance to the proposal:
London Plan (2021)
GG1 - Building strong and inclusive communities GG2 - Making the best use of land GG3 - Creating a healthy city GG4 - Delivering the homes Londoners need GG5 - Growing a good economy GG6 - Increasing efficiency and resilience SD1 - Opportunity Areas D1 - London’s form, character and capacity for growth D3 - Optimising site capacity through the design-led approach D4 - Delivering good design D5 - Inclusive design D6 - Housing quality and standards D7 - Accessible housing D8 - Public realm D9 - Tall buildings D14 - Noise H1 - Increasing housing supply
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H4 - Delivering affordable housing H5 - Threshold approach to applications H6 - Affordable housing tenure H10 - Housing size mix S4 - Play and informal recreation E2 - Providing suitable business space HC1 - Heritage conservation and growth G5 - Urban greening SI 1 - Improving air quality SI 2 - Minimising greenhouse gas emissions SI 4 - Managing heat risk SI 5 - Water infrastructure SI 12 - Flood risk management SI 13 - Sustainable drainage T2 - Healthy Streets T4 - Assessing and mitigating transport impacts T5 - Cycling T6 - Car parking T7 - Deliveries, servicing and construction
Brent Local Development Framework Core Strategy (2010)
CP 1 - Spatial Development Strategy CP 2 - Population and Housing Growth CP 5 - Placemaking CP 6 - Design and Density in Place Shaping CP 11 - Burnt Oak/Colindale Growth Area CP 19 - Brent Strategic Climate Change Mitigation and Adaptation Measures CP 21 - A Balanced Housing Stock
Brent Site Specific Allocations (2011)
B/C2 – Sarena House / Grove Park / Edgware Road
Brent Development Management Policies (2016)
DMP 1 - General Development Management Policy DMP 7 - Brent's Heritage Assets DMP 9a - Managing Flood Risk DMP 9b - On Site Water Management and Surface Water Attenuation DMP 12 - Parking DMP 13 - Movement of Goods and Materials DMP 15 - Affordable Housing DMP 18 - Dwelling Size and Residential Outbuildings DMP 19 - Residential Amenity Space
6.6 Policy CP11 (Burnt Oak/Colindale Growth Area) of the Core Strategy states:
“The Burnt Oak/Colindale area is promoted for mixed use regeneration along the axis of Edgware Road. While tall buildings are acceptable in appropriate places along Edgware Road, the council will facilitate a shift in character and use towards a traditional street pattern supporting pedestrian movement, street frontages and
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public spaces and squares. New economic activity will be created in the form of ground floor commercial frontage (including retail, where compliant with the sequential approach). New connections will be created in the form of improved access to local stations and the creation of effective interchanges with new buses. 14.65 hectares of land is promoted for at least 2,500 new homes to 2026, supported by infrastructure identified within the Infrastructure and Investment Framework. Anticipated infrastructure will include:
• A new 2 form of entry primary school • Extensions to a secondary school to provide a further 1 form of entry to 6th form • New nursery places • New health services including space for 3 GPs and 3 dentists • A series of 3 new public open spaces and squares of at least 0.2 hectare each • Improvements to the quality and accessibility of existing local open spaces • A series of play areas within new developments and open space • Indoor and outdoor sports facilities, including contributions towards a new community • swimming pool serving the local area • New bus services to provide interchanges with local rail and underground stations • Multi-use community centre • A minimum of 200 new trees planted
9 hectares of land will be protected for appropriate industrial operations within use classes B1c, B2 and B8 or closely related sui generis uses.”
6.7 The Site Specific Allocations development plan document identifies the ‘Sarena House / Grove Park / Edgware Road’ Site Allocation (ref. B/C2) within which the application site is located, for which it states:
“Allocation: A mixed use development to include residential and workspace, a proportion of which to be managed affordable workspace. The design must have regard to, and not detract from neighbouring uses, including that of the adjacent primary school. The Council will consider the inclusion of the existing school into a comprehensive redevelopment subject to the satisfactory relocation or on-site re- provision. Proposals should include the provision of amenity/open space. Improvements will be sought to public transport as part of any proposal to develop the site.”
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Emerging Planning Policies and Other Material Considerations
6.8 LBB are currently in the process of preparing a new Local Plan, having submitted the draft Brent Local Plan (2019) to the Secretary of State for examination on 17th March 2020. The draft Plan has since been subject to main and minor modifications published in February, August and September 2020.
6.9 In addition to the Burnt Oak/Colindale Growth Area and AQMA designations, the draft Brent Local Plan Policies Map (as modified, September 2020) identifies the site as falling within:
➢ Site Allocation BNSA2: Colindale Retail Park, Multi-Storey Car Park and Southon House; and
➢ ‘Core’ of the Tall Buildings Zone.
6.10 The draft policies of key relevance are:
Draft Brent Local Plan
DMP1 – Development Management General Policy BP3 – North BNGA1 – Burnt Oak/Colindale Growth Area BNSA2 – Colindale Retail Park, Multi-Storey Car Park and Southon House BD1 – Leading the Way in Good Urban Design BD2 – Tall Buildings in Brent BH1 – Increasing Housing Supply BH5 – Affordable Housing BH6 – Housing Size Mix BH13 – Residential Amenity Space BE1 – Economic Growth and Employment Opportunities for All BHC1 – Brent’s Heritage Assets BGI2 – Trees and Woodlands BSU1 – Creating a Resilient and Efficient Brent BSUI2 – Air Quality BSUI3 – Managing Flood Risk BSUI4 – On-site Water Management and Surface Water Attenuation BT1 – Sustainable Travel Choice BT2 – Parking and Car Free Development BT3 – Freight and Servicing
6.11 Draft Policy BNGA1 (Burnt Oak/Colindale Growth Area) states:
“The Burnt Oak/Colindale Growth Area is promoted for mixed use regeneration along the axis of Edgware Road. The primary emphasis in this area will be on creating a sense of place, through well considered quality design that is
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complementary to the remaining adjacent metroland heritage of the area. This will also seek to reduce the traffic dominance of Edgware Road through public realm improvements, including significant urban greening. New economic activity will be created along Edgware Road in the form of ground floor commercial and employment uses. Reduction in car dependency and the greater uptake of active travel should be achieved through the implementation of the London Plan Healthy Streets approach. The inclusion of additional commercial floorspace will help revitalise the area and support the growing population which is set to come forward through redevelopment.
The existing Locally Significant Industrial Sites will be subject to masterplanning with a view to its regeneration to re-provide updated industrial floorspace that meets employers existing and future needs, through co-location with other uses.
Burnt Oak/ Colindale Growth Area will deliver over 2,000 new homes to 2041, supported by social and physical infrastructure to include:
• Improvements to the quality and accessibility of existing local open spaces
• A series of play areas within new developments and open space
• Improved cycle infrastructure along the A5.”
6.12 The emerging Brent Local Plan states that the allocated use for Site Allocation BNSA2: Colindale Retail Park, Multi-Storey Car Park and Southon House is “Mixed use development to include residential, retail and replacement industrial and office space/affordable workspace.”
Other Material Considerations
6.13 Other material considerations that are relevant to the application proposals include the following:
• National Planning Policy Framework (NPPF) (published in February 2019);
• National Planning Policy Guidance (NPPG);
• Adopted London Borough of Brent and Mayoral Supplementary Planning Documents (SPDs) and Supplementary Planning Guidance (SPG), including:
o GLA Affordable Housing and Viability SPG (2017);
o GLA Housing SPG (2016);
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o GLA Play and Informal Recreation SPG (2012);
o GLA Sustainable Design and Construction SPG (2014);
o GLA Social Infrastructure SPG (2015);
o Brent Section 106 Planning Obligations SPD (2013);
o Brent Design Guide SPD1 (2018);
o Brent Basement SPD (2017); and
• Brent Burnt Oak, Colindale and the Hyde Placemaking Plan (2014).
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7. PLANNING CONSIDERATIONS
7.1 Having reviewed the planning position at both national and local level and applied these policies to the application proposal, the key issues in the determination of this application are summarised below.
Principle of Development
7.2 The site comprises a 4 storey building accommodating a multi-storey car park and car showroom with associated forecourt, which is located within the Colindale/Burnt Oak Opportunity Area, the Burnt Oak/Colindale Growth Area and Site Allocation B/C2 ‘Sarena House / Grove Park / Edgware Road.’ The emerging Brent Local Plan indicates the site is located within Site Allocation BNSA2: ‘Colindale Retail Park, Multi-Storey Car Park and Southon House’.
7.3 There are no policies which seek to restrict the loss of the existing car showroom or multi-storey car park uses (both sui generis) at the site.
Residential-led development
7.4 The proposed residential-led development including commercial floorspace at ground and upper ground floor is in accordance with both the adopted and emerging planning policy context, as confirmed in the pre-application advice issued by LBB in June 2020 (ref. 20/0013/PRE).
7.5 The proposed residential-led development seeks to optimise and make efficient use of the site in accordance with Paragraph 118 of the NPPF. The proposal will optimise the development potential of the site when compared to the existing building which is set some way back from Edgware Road owing to the parking forecourt, and will extend further in height to achieve a greater density. The site offers opportunity for optimisation and further development in this respect, in response to its brownfield status, the existing and emerging built context, and the site’s location within a designated Opportunity Area and Growth Area.
7.6 As outlined in the London Plan (2021), London’s overall annualised housing delivery target is 52,287, of which 2,325 new homes are required in Brent. This represents 4.5% of London’s overall housing need. The London Plan states that London Borough’s should seek to achieve and exceed the relevant minimum average housing target and promote the realisation of brownfield housing capacity.
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7.7 At the strategic level, the application site is located within the Colindale/Burnt Oak Opportunity Area. The proposal will accord with the principles of Policy SD1 of the London Plan which seeks to direct housing and employment opportunities to this Opportunity Area, and identifies its capacity for 7,000 homes and 2,000 jobs.
7.8 At the local level, the Site is located within the Burnt Oak/Colindale Growth Area, the designation of which is carried forward in the draft Brent Local Plan (2020). The proposed development will accord with Policy CP11 of the Core Strategy, and draft Policy BNGA1 of the draft Brent Local Plan, which seek to promote mixed use regeneration along the axis of Edgware Road within the Burnt Oak/Colindale Growth Area and incorporate economic activity in the form of ground floor commercial frontage, including retail and employment uses.
7.9 Policy CP2 of the LBB Core Strategy states that the provision of at least 22,000 additional homes will be delivered between 2007 and 2026, including 1,100 in Burnt Oak/Colindale Growth Area in 2017-2026. Draft Policy BNGA1 of the emerging Brent Local Plan (2020) goes further in light of the London Plan to state that the Burnt Oak/ Colindale Growth Area will deliver over 2,000 new homes to 2041. The proposal will contribute towards meeting these ambitious housing targets.
7.10 The site forms part of the wider Site Allocation B/C2 ‘Sarena House / Grove Park / Edgware Road’ under the adopted Brent Local Plan. The proposed mixed use residential-led development will be consistent with the proposed uses the wider site is allocated Specific Site Allocations DPD seeks to allocate this wider site for:
“A mixed use development to include residential and workspace, a proportion of which to be managed affordable workspace. The design must have regard to, and not detract from neighbouring uses, including that of the adjacent primary school. The Council will consider the inclusion of the existing school into a comprehensive redevelopment subject to the satisfactory relocation or on-site re-provision. Proposals should include the provision of amenity/open space. Improvements will be sought to public transport as part of any proposal to develop the site.”
7.11 Under the emerging Brent Local Plan, the draft Policies Map (as modified, September 2020) designates the site as falling within Site Allocation BNSA2: Colindale Retail Park, Multi-Storey Car Park and Southon House. The proposed residential and commercial uses will accord with the relevant draft Policy BNSA2 which allocates the wider site for “mixed use development to include residential, retail and replacement industrial and office space/affordable workspace.”
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7.12 Given the site forms part of wider adopted and emerging site allocations, the development has been designed in order to ‘dovetail’ with any subsequent development which comes forward on its boundaries. An indicative masterplan illustrating this is included within the Design and Access Statement, demonstrating that the proposed development will not prejudice the delivery of the wider site. To the contrary, in light of pre-application advice received, active frontages are proposed to the southern and western elevations in addition to the Edgware Road frontage, which will ensure the development has a positive relationship both to its existing surroundings, and to future development.
7.13 In summary, the principle of residential use on this site is wholly acceptable in accordance with national, strategic and local planning policy and does not prejudice the wider site allocation coming forward.
Commercial Use
7.14 The proposed Class E use will allow flexibility for a variety of uses, including retail and business uses. As set out above, the proposed commercial (Class E) element of the scheme accords with the adopted and emerging site allocations, which are supportive of mixed-use development including office and retail use.
7.15 This is confirmed in the LBB pre-application advice which stated “B1 office use at ground floor level would be acceptable in principle to reflect the adopted and emerging site allocations, and B1(b) or B1(c) light industrial uses could also be suitable.” The response goes on to state “retail uses would be supported in order to serve local retail needs.”
7.16 The proposed commercial element will also assist in the delivery of the wider aims of the Colindale/Burnt Oak Growth Area under both Policy CP11 of the Core Strategy and draft Policy BNGA1 of the draft Brent Local Plan which seek to introduce economic activity in the form of commercial and employment uses along Edgware Road.
7.17 The site will deliver clear socio-economic benefits through the creation of jobs, both in the construction and operation of the proposed development. The existing car showroom comprises approx. 2,080 sqm of floorspace; which compares to 1,262 sqm of proposed commercial floorspace. However the vast majority of the existing commercial floorspace is used for display purposes and the employment output is comparatively low. Indeed, there are circa 10 existing employees in contrast to the
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anticipated 80-90 jobs to be generated from the proposed development once operational.
Layout, Scale and Appearance
7.18 High quality design is promoted throughout national, strategic and regional guidance, as well as the Brent Local Plan. The NPPF (Chapter 12), the London Plan (Chapter 3), and the Core Strategy (Policy CP 6) all place great emphasis on the importance of good design. Policy DMP1 requires the scale, type and design of the development to complement the locality, which is further supported by Brent’s Design Guide SPD1.
7.19 The design has been informed by pre-application consultation with LBB and the GLA, and consultation with LBB’s Urban Design Advisor and Design Out Crime Officer. The proposals have been designed to positively respond to the site’s location within the Burnt Oak/Colindale Growth and Opportunity Areas, whilst having due regard to the surrounding building heights and land uses.
a) Layout
7.20 The site layout features a ‘horseshoe’ shaped perimeter block arrangement comprising 4 blocks centred around a central first floor podium terrace; the principle of which was supported at pre-application stage by LBB and the GLA. Commercial units are proposed at ground and upper ground floor levels, with residential set above.
7.21 A strong and legible building line will be created to Edgware Road. The commercial units at ground floor level will front onto Edgware Road, Windover Avenue and Colindale Retail Park, will provide an active frontage which is further animated by the entrances to the residential cores at the north-eastern and south-eastern corners of the building, and to the south-west on Windover Avenue.
7.22 The building will be setback from all site boundaries in order to deliver improved public realm and to minimise impact to the adjacent school building. The building mass has been setback from Edgware Road in order to provide a significantly improved public realm incorporating landscaping along Edgware Road. The ground floor will be further setback at this north-eastern elevation than the upper levels, with a tall colonnade providing a sense of protection for pedestrians from the busy road at street level. As such, the proposal will accord with Policy CP11 which seeks
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to facilitate a shift in character towards a traditional street pattern which supports pedestrian movement, street frontages and public spaces.
7.23 Pedestrian access is provided to the residential units from the dedicated entrances neatly dispersed throughout the building at the north-eastern and south-eastern corners along Edgware Road and to the south-west on Windover Avenue, which provide legible arrival points. These entrances will provide a continuous active frontage and connectivity with the streetscene.
7.24 Vehicular access to the basement car park will be via a ramp to the rear of the development, in the same location as the existing access to the multi-storey car park. The accommodation of car parking at basement level allows for the creation of landscaping at street level. Refuse storage will be discreetly located to, and accessible via, the rear of the development.
b) Scale and Massing
7.25 Given the highly urbanised character of the site and location within the Burnt Oak/Colindale Growth and Opportunity Areas, together with the number of tall buildings within the immediate vicinity and surrounds, there is significant potential for redevelopment of a scale and mass appropriate to the site’s sustainable location.
7.26 The proposed development comprises a ground plus part 19, 17, 14, 8, 6 and 5 storey building. The tallest element of the proposed scheme will be the south- eastern tower, extending to ground plus 19 storeys in height. This will accommodate residential use across 19 floors, with a rooftop plantroom above.
7.27 Draft Policy BP3 of the emerging Brent Local Plan supports tall buildings of over 30m to the Burnt Oak/Colindale Growth Area. The site is located within the ‘core’ of a designated Tall Buildings Zone in the draft Brent Local Plan, whereby draft Policy BD2 of the Brent Local Plan specifically seeks to direct tall buildings. Feedback from LBB and the GLA throughout pre-application discussions has been supportive of a tall building in this location, and the proposed height is considered acceptable given the site’s existing and emerging context.
7.28 Policy D9 of the London Plan states that consideration should be given to the visual impacts of tall buildings and should reinforce the spatial hierarchy of the local and wider context, aiding legibility and wayfinding.
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7.29 The proposed height responds to the height of numerous tall buildings nearby within the designated Growth Area, including Zenith House to the east which rises to 17 storeys (opposite the site) and The Northern Quarter London (19 storeys) at 50 Capitol Way, further north of the site. Of note, Brent Council have also resolved to grant planning permission (ref. 17/2284) for redevelopment of Park Parade Mansions and 381-397 Edgware Road for residential-led development up to 18 storeys. This site is located on the corner of Edgware Road and Grove Park, to the north of Beis Yaakov Primary School. When viewed in this current and emerging context, the height of the proposed development is considered appropriate and will contribute to enhancing legibility through providing a clear wayfinding feature within the southern extent of the Growth Area, at the crossroads of Edgware Road with Windover Avenue/Colindeep Lane in accordance with London Plan Policy D9.
7.30 Careful consideration has been given to the massing to ensure the proposed building form will respond appropriately to the local context, including topography. The tower element will form the south-eastern point of the development, on the junction between Edgware Road and Windover Avenue and will be sited on the lowest part of the site, complenting the height of Zenith House opposite (17 storeys). The tower element will be relatively slender in appearance; setback from the eighth storey fronting Edgware Road. The remainder of the proposed development will vary in height to respect and conserve the immediately adjacent buildings, breaking up the massing and provide visual interest.
7.31 Indeed, the height of the building along Edgware Road is staggered, stepping down to 7 storeys in height adjacent to the neighbouring 3 storey school building to the north, which will ensure a legible graduation in height and break up the overall form and massing. Similarly the Windover Avenue elevation steps down to 6 storeys, complementing the height of the 6 storey office development at 333 Edgware Road. As such the reduction in height, together with the articulation of the slender setback tower element, will successfully reduce the bulk of the perimeter development as viewed from Edgware Road. The proposal will also relate well to the form and scale of the surrounding buildings, in accordance with Policy D9 of the London Plan which relate to tall buildings.
7.32 In light of the above, and in accordance with adopted planning policy, the proposed height, scale and massing of the proposed development is considered to sit comfortably within the site’s context and provide a positive and sensitive
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intervention, whilst making efficient and sustainable use of this accessible brownfield site.
c) Appearance
7.33 The existing site makes limited contribution to the experience of the townscape with the existing built form and public realm being of mediocre or poor quality. Indeed, the site currently accommodates a low grade, functional multi-storey car park building with car dealership at ground floor level, together with hard surfacing forming a forecourt fronting onto Edgware Road.
7.34 There are only 2 trees to the northern boundary of the site, and one located at the south-eastern corner. The only soft landscaping comprises a small green low hedge separating the parking forecourt from the public highway.
7.35 By contrast, the proposed development will result in a considerable improvement on the appearance of the site; incorporating high quality design, materials and detailed finishes which will respect the character and appearance of the surrounding area; in addition to greatly enhanced public realm incorporating soft landscaping and improved ‘greening’ of the site, including along Edgware Road which will contribute towards wider policy aspirations for this frontage.
7.36 A Townscape and Visual Impact Assessment accompanies this application which considers the visual impacts of the buildings from a variety of viewpoints in accordance with Policy D9 of the London Plan, and concludes that the proposed development will not adversely affect local or strategic views. The assessment concludes that there would be beneficial or neutral effects on townscape character due to the new built form reflecting the character and defined structure of the surrounding townscape, providing enhancements to the public realm and improved quality of the townscape along Edgware Road contributing to a vibrant mixed use corridor.
7.37 Attention has been paid to the detailed design of the proposals to ensure it will make a positive contribution to the townscape, in accordance with Policy CP6 of the Core Strategy. The high quality standard of the design and materiality will ensure that the architectural integrity of the building is maintained in accordance with Policy D9 of the London Plan. The proposed development will incorporate light buff brick with mixed tones to ensure rich variation in the predominant facing material, which subtly contrasts with artificial stone banding at each floor level; further
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highlighted by a band of soldier course brickwork above the head to window openings and recessed balconies.
7.38 The use of traditional and sympathetic brick materiality will ensure a harmonious transition between the new development and the adjacent locally listed building, particularly compared to the existing utilitarian building on site. In this way, the proposed development would improve the setting of the locally listed building through the introduction of high-quality design that offers a contextual response.
7.39 Further details of the materiality is included within the Design and Access Statement.
Heritage and Impact on Locally Listed Building
7.40 The design of the proposed scheme has carefully considered its impact on the relevant heritage assets, in particular the adjacent locally listed Beis Yaakov Primary School to the north, and the conservation areas located in the wider surrounding area.
7.41 A Heritage Impact Assessment, prepared by Turley, has been submitted in support of the application. This provides a detailed assessment of the impact of the proposed development on the relevant heritage assets, and concludes that the particular significance of these assets would be sustained by the proposed development.
7.42 As such the proposed development accords with national policy set out in the NPPF 2019, together with the revised London Plan 2016, Policy CP17 of the Council’s Core Strategy and Policy DMP7 of the Development Management Policies 2016.
Affordable Housing
7.43 The application proposes a total of 165 residential units. The proposed development will include a mixture of dwelling sizes, informed by scheme viability, including studios, 1, 2 and 3 bedroom units.
7.44 A breakdown of the unit mix is detailed below:
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Affordable Intermediate Market Total
Studio 0 0 9 9 (5.5%)
1 bed 0 3 58 61 (37%)
2 bed 10 3 40 53 (32%)
3 bed 10 0 32 42 (25.5%)
Total 20 6 139 165
7.45 London Plan Policies H4 and H5 of the London Plan outline a strategic affordable housing target of 50% and a new affordable housing threshold approach which requires a minimum of 35% affordable on gross residential development to applicable sites, which includes the application site. Where an application does not meet this requirement, it must follow the Viability Tested Route. The London Plan seeks a tenure split to include a minimum of 30% social/affordable rent, 30% intermediate rent and the remainder to be determined by the Borough based on identified need.
7.46 Policy CP2 and Policy DMP15 of the Brent Core Strategy and Development Management Policies outline a Borough-wide target that 50% of housing provision should be affordable. The preferred tenure split of affordable housing is 70% social/affordable rented and 30% intermediate housing.
7.47 Policy DMP15 states the maximum reasonable amount of affordable housing will be sought on individual residential and mixed use developments on sites with the capacity to provide 10 or more homes. Where a reduction to the affordable housing target is sought on viability grounds, applications must be accompanied with a development appraisal to demonstrate that schemes are maximising affordable housing output.
7.48 Draft Policy BH5 of the emerging Brent Local Plan also reinforces the strategic 50% affordable housing target and seeks the same tenure split of 70% Social Rent/London Affordable Rent and 30% Intermediate which meet the definition of
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genuinely affordable housing, including London Living Rent, Affordable Rent within Local Housing Allowance limits and Shared Ownership.
7.49 The supporting text to this policy at para 6.2.47 states that where viability impacts are such that the amount of affordable housing falls below that required for the fast track approach, the Council seeks to pursue the preferred tenure split set out in policy. However it goes on to state “it views the delivery of more affordable tenures that would meet needs (social rent and London Affordable Rent) as a greater priority than achieving a potentially higher percentage of affordable housing on site that places greater emphasis on intermediate tenures”.
7.50 The proposed development will provide 18.6% affordable housing. This scheme seeks to maximise affordable rented accommodation; the proposed tenure split equating to 82.4% affordable rented and 17.6% intermediate. The proposed affordable provision is underpinned by a viability assessment (prepared by DS2) as required by relevant planning policy, which is submitted under separate cover.
Quality of Proposed Accommodation
7.51 The matter of amenity, including residential standards, has been closely considered throughout the evolution of the proposal. The need to support and maintain residential amenity underpins policies from national to local level, with London Plan Policy 7.6 and the Mayor’s Housing SPG seeking to ensure a high standard of amenity for both future residents of the development and existing neighbours.
a) Unit Mix
7.52 Policy CP21 of the Core Strategy states that new housing should contribute towards the wide range of Borough household needs including an appropriate range and mix of self-contained accommodation types and sizes, including family sized accommodation (3 bedrooms or greater). As outlined in the table above, the proposal will provide a mix of unit sizes, including studios, 1 bed, 2 bed and 3 bed homes.
7.53 Policy CP2 seeks to provide 25% family sized accommodation of the target of 22,000 homes to be delivered across the 2007-2026 period. Draft Policy BH6 of the emerging Brent Local Plan reinforces this 25% target on individual sites. The proposal will accord with this policy through the provision of 42 family sized dwellings, equating to 25.5% of the total 165 units proposed.
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b) Floorspace Standards
7.54 Policy D6 of the London Plan states that housing development should be of a high quality design which provide adequately sized rooms with comfortably and functional layouts. Dwellings must provide at least the gross internal floor area as set out in Table 3.1 ‘Minimum Internal Space Standards for New Dwellings’.
7.55 Policy DMP18 of the Brent Development Management Policies also seeks the size of dwellings to be consistent with the London Plan.
7.56 The proposed dwellings provide generous space for future residents which meet or exceed the internal space standards set out in the London Plan, and provide high level of internal amenity in accordance with Brent Development Management Policy DMP1.
c) Amenity and Playspace Provision
7.57 London Plan Policy D6 and Standard 26 of the Mayor’s Housing SPG (2016) seek provision of a minimum of 5sqm of private outdoor space for 1-2 person dwellings and an extra 1sqm to be provided for each occupant, unless higher local standards are applicable. All the proposed flats are served by private balconies which meet or exceed this London Plan requirement.
7.58 Policy DMP19 of the LBB Development Management Plan and draft Policy BH13 of the emerging Brent Local Plan look to exceed the London Plan’s minimum standard and states that all new dwellings will be required to have private amenity space of a sufficient size and type to satisfy its residents’ needs, which “is normally expected to be 20sqm per flat and 50sqm for family housing”. The supporting text to both adopted and emerging policy states that where this cannot be provided individually for each dwelling, the remainder should be supplied in the form of communal amenity space. The justification to the emerging Local Plan also acknowledges that in some locations, “in high density developments the Council understands that meeting the overall minimum might be challenging…As such flexibility could be allowed where it can be shown that all reasonable options for provision have been considered.”
7.59 All proposed residential flats have access to private outdoor amenity space in the form of dedicated private balconies and terraces, which all meet London Plan private outdoor amenity standards. In addition to this, there is also amenity space
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provided in the form of a communal garden proposed at podium level, together with further communal roof terraces.
7.60 The proposed amenity space is considered to provide a good standard given the highly urbanised context, and will meet and exceed London Plan standards. When taking the urban context into account, together with the relatively small footprint and high density of the site which seeks to optimise the development potential in line with the site’s location within designated Growth and Opportunity Areas, and within a Tall Building Zone, the proposed amenity space is considered to be appropriate in accordance with London Plan Policy D3 (Optimising Site Capacity through Design-Led Approach).
7.61 The GLA ‘Shaping Neighbourhood: Play and Informal Recreation SPG’ calculates that 682.5sqm of children’s play space is required to serve the development.
7.62 The proposal comfortably meets this minimum requirement, providing 890sqm of children’s play space. Provision is focused within the first floor podium courtyard, with additional provision at sixth and seventh floor levels.
c) Daylight and Sunlight
7.63 The submitted Daylight and Sunlight Assessment, prepared by BWB Consulting, demonstrates that notwithstanding the urban location, the majority of habitable rooms within the proposed development achieve or exceed the recommended daylight levels. The report concludes that the proposed development is therefore considered to offer acceptable daylight for the enjoyment of future occupants in accordance with London Plan Policy D6, Policy DMP1 of the Brent Development Management Policies and draft Policy DMP1 of the emerging Brent Local Plan.
d) Layout and Outlook
7.64 The building is served by 4 blocks serviced by a dedicated circulation core within each; two to the north of the building and 2 to the south. Each core will serve between 4 and 6 units, with fewer on the upper floors of the tower; and with the exception of a single floor which will serve a total of 7 dwellings. This will accord with the London Plan standard for a maximum of 8 units per core per floor.
7.65 The number of dual aspect units has sought to be maximised in accordance with Policy D6 of the London Plan, with 115 flats (70%) to be dual aspect. The number of single-aspect units, particularly north-facing, has been minimised through the
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design evolution through incorporation of a deck access arrangement for the north and south wings of the building and reducing the tower footprint to ensure a higher proportion of dual-aspect corner units within the tower itself. Further details are provided within the accompanying Design & Access Statement.
7.66 As previously set out, the proposed development seeks to optimise site capacity in accordance with London Plan Policy D3 given its location within a highly urbanised context, which forms part of the Colindale/ Burnt Oak Opportunity and Growth Areas. The proportion of dual aspect units is considered appropriate in this context, and where single aspect units are proposed, these will provide a good standard of accommodation in accordance with London Plan Policy D6.
7.67 The proposed development will be set in from all site boundaries of a sufficient distance which will ensure good outlook for future occupants and maintain privacy of habitable rooms for the future occupants; including across the internal courtyard area.
7.68 Overall, the general arrangement and layout of the proposed units are considered to provide acceptable separation distances and relationships in accordance with London Plan Policies D3, D5, D6, Brent Development Management Policy DMP1 and draft Policy DMP1 of the emerging Brent Local Plan.
e) Accessibility
7.69 Three entrances serving the residents will be provided to the north-eastern and south-eastern corners of the Edgware Road elevation together with a third entrance on Windover Avenue to the south-west.
7.70 The development has been designed to provide convenient and welcoming access in accordance with London Plan Policy D5, with level access from the external environment for residents and visitors through clearly visible and identifiable entrances from the public realm. Each of the units proposed will have access to the lifts located within each core.
7.71 The proposed development has been designed in order that 10% of units have been designed to meet Building Regulation requirement M4(3) ‘wheelchair user dwellings’, with the remaining 90% meeting requirement M4(2) ‘accessible and adaptable dwellings’ in accordance with Policy D7 of the London Plan and in line with pre-application advice received.
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Impact on Neighbouring Amenity
7.72 The development proposals have been carefully designed to ensure that they are cohesive with existing development and do not prejudice the development potential of adjoining sites.
7.73 The closest residential properties are Zenith House (to the east) and Silver Works (to the north east). There is an office block at 333 Edgware Road and retail units located to the south, and the locally listed school to the north.
f) Daylight, sunlight and outlook
7.74 The scale and design of the proposed development has been informed by the supporting Daylight and Sunlight Assessment, which considers the impact of the proposed development on surrounding residential uses.
7.75 It is noted that the site is located within the Colindale/Burnt Oak Opportunity and Growth Areas, in an accessible location where local and regional policy promotes the optimisation of development and concentration of higher densities. At sites within such locations, expectations for daylight and sunlight amenity will, therefore, be lower than at suburban locations.
7.76 The submitted Daylight and Sunlight Assessment considers the impact on neighbouring residential properties within a reasonable proximity to the development, and the adjacent school. The submitted report concludes that whilst the results do not demonstrate full compliance they do achieve an extremely high level of compliance in the context of an urban environment in respect of both daylight and sunlight levels and as such should be considered acceptable.
7.77 In terms of overshadowing, the impact of the proposed development on all assessed surrounding amenity spaces, including the adjacent school playground, will be negligible. The overshadowing assessment concludes that all the amenity spaces will continue to receive good levels of sunlight following the completion of the proposed development without any significant changes to the current situation.
7.78 Overall, the proposed development achieves a high level of compliance in respect of daylight, sunlight and overshadowing, in the context of an urban environment and as such complies with the requirements of London Plan Polices D3 and D9, Policy DMP1 of the Brent Development Management Policies and draft Policy DMP1 of the emerging Brent Local Plan.
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g) Privacy and overlooking
7.79 The site is located in an urban location, within a designated Growth Area, along a main road. Section 5.1 (Privacy and amenity) of SPD1 states that directly facing habitable room windows will require a minimum separation distance of 18m, while a distance of 9m should be kept between gardens and habitable rooms. However, it also acknowledges that in more intense urban areas, some flexibility can be applied.
7.80 The proposed development maintains a separation distance from directly facing habitable room windows at Zenith House of in excess of 23m, comfortably exceeding the 18m requirement. This is considered acceptable to maintain privacy of neighbouring residents.
7.81 Furthermore, the proposed development has been designed to retain a 9m distance between the north-eastern site boundary and proposed habitable room windows in accordance with the Council’s SPD1 and in line with pre-application advice received. The school site, as part of the Colindale/Burnt Oak Growth Area, could come forward for development in the future and the provision of this separation distance will ensure future development will not impact on the amenity of occupiers of the proposed development, ensuring adequate privacy of habitable rooms will be maintained.
7.82 In undertaking pre-application consultation with the local community, the Applicant met with representatives from Beis Yaakov Primary School who raised concern about the potential for overlooking from the north-western elevation; in particular the roof terrace at seventh floor level. In response to this, a 1.5m wide walkway has been introduced along this part of the roof terrace which will be accessible for maintenance only; demarcated by a 1.2m planter incorporating seating orientated towards the communal courtyard, away from the school. The parapet height has also been increased to 1.5m. These measures will ensure no overlooking from the roof terrace. Further details are provided within the Design & Access Statement.
7.83 The proposal will deliver a good standard of residential accommodation which will have a good relationship with surrounding properties with regard to their outlook and privacy, and also safeguards for future redevelopment of neighbouring sites, in accordance with London Plan Policy D3, the Mayor's Housing SPG, Brent Local Plan Development Management Policies DMP1, DMP18 and Brent’s Design Guide SPD1.
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Highways and Transportation
7.84 Chapter 10 of the London Plan sets out the Mayor’s approach to transport matters. Relevant policies include Policies T1, T2, T4, T5, T6 and T7 respectively. Development is encouraged to reduce the need to travel, especially by car, and supporting measures that ensure shifts to more sustainable modes of transport are promoted.
7.85 A Transport Assessment has been submitted in support of this planning application which assesses the transport implications of the proposals in the context of current and emerging policy and guidance. As outlined within the trip generation assessment, the quantum of trips predicted to be generated by the proposed development would be expected to be lower than that of the existing site, resulting in a benefit to the operation of the local highway network. As such the proposed development will be in accordance with the principles of Policy T4 of the London Plan and will contribute towards reducing traffic dominance to the A5 corridor in accordance with draft Policy BT1 of the emerging Brent Local Plan.
Car Parking
7.86 In respect of car parking, the proposal will provide 59 spaces within a split level basement. 57 spaces are proposed for residential occupants (of which 5 will be disabled spaces) and 2no. disabled spaces will be provided for the commercial use. The car parking provision will accord with the standards set out within the London Plan and Policy DM12 of Brent’s Development Management Policies.
7.87 The amount of car parking proposed has evolved through the design process in light of pre-application advice received. The development site is in an accessible location, within walking distance to Colindale Underground Station and multiple bus routes. The PTAL rating is 3 across the majority of the site, with the north-eastern corner incorporating a PTAL rating of 4.
7.88 The GLA pre-application response acknowledges that the sustainable location lends itself to a reduction in car parking provision from that initially proposed, which is subsequently reflected in the proposed scheme. The response states that owing to its proximity to Colindale Station and higher public transport accessibility level to the north, “the site has adequate access to public transport and would sustain travel by public transport rather than dependence on car use,” which is further supported through pre-application discussions with TfL. In turn, the reduced level of car
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parking proposed will minimise vehicle trip generation which accords with the wider aims of the Healthy Streets approach in accordance with Policy T2 of the London Plan.
7.89 In summary, the proposed parking provision accords with the London Plan and Brent’s adopted and emerging planning policy and has given due consideration to the public accessibility and sustainability credentials of the site, which in turn will minimise vehicle movements in accordance with the Mayor of London and TfL’s wider aims.
7.90 The residential units will be provided with 5no. disabled parking spaces, equivalent to 3% of the total number of residential units; with capacity for up to 17no. spaces (10% of the total number of units) should demand arise in the future. This accords with Policy T6.1 of the London Plan, and both the current proposed and future indicative provision is indicated on the Proposed Basement Plan for completeness. Furthermore, 20% of parking bays (12no) will provide active electric vehicle charging points with passive provision for all remaining spaces which will also accord with Policy T6.1.
Cycle Parking
7.91 The cycle parking standards within the London Plan require a minimum of 291no. long-stay cycle spaces for residents of the proposed development and 6no. short- stay spaces for visitors. The Transport Assessment considers a conservative approach in calculating the long-stay requirements for the Class E commercial floorspace, which equates to 9 long-stay spaces and 3 short-stay spaces.
7.92 A secure cycle store is proposed within the building which will provide 294 long- stay spaces to serve the residents, including accessible spaces. Dedicated cycle stores will also be provided within each commercial unit, providing a total of 9 long- stay spaces. All spaces will remain secure and sheltered in accordance with London Plan standards.
7.93 Short-stay provision is proposed in the form of Sheffield stands to be delivered as part of the public realm enhancements fronting Edgware Road, which will accommodate a total of 20 spaces. This will ensure sufficient provision is made should commercial space be used by retail tenants.
Servicing
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7.94 Policy DMP13 of Brent’s Development Management Policies requires development to be satisfactory in terms of means of access for all parking, manoeuvring, servicing and that it does not have an adverse impact on the movement network. This is carried forward to draft Policy DMP1 of the draft Brent Local Plan.
7.95 The proposed development will largely retain the existing servicing arrangements, with all deliveries and servicing taking place to the rear of the development via the existing access from Edgware Road along Windover Avenue. Two dedicated loading areas are proposed to the rear of the development which are capable of accommodating multiple delivery vehicles simultaneously, if required. There will be no deliveries or servicing taking place on-street in accordance with draft Policy BT3 of the draft Brent Local Plan and Policy T7 of the London Plan.
7.96 The supporting Delivery & Servicing Plan provides further detail on the strategy for delivery and servicing activity which is proposed to take place on-site. It is demonstrated that the proposal can accommodate movements of all appropriate delivery and servicing vehicles. Indeed, swept path analyses are included which demonstrate that delivery and servicing vehicles, including waste collection vehicles, can safely access and egress from the site to these loading areas. Dedicated waste stores will be integrated within the building towards the rear at upper ground level, which are easily accessible for collection from the rear loading areas.
7.97 As such the proposed development will accord with Policy DMP13 of Brent’s Development Management Policies, draft Policy DMP1 of the draft Brent Local Plan and Policy T7 of the London Plan.
Travel Plan and Construction Logistics
7.98 The submitted Travel Plan sets out a travel management strategy for the site which aims to encourage use of more sustainable and active modes of transport by users of the proposed development. It identifies key objectives and targets for the Travel Plan, together with a package of measures that will be implemented on site to encourage sustainable travel and relevant monitoring and review mechanisms, in accordance with the aims of London Plan and local planning policy.
7.99 The supporting Construction Logistics Plan outlines key strategies for the management of traffic during construction of the proposed development which
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seeks to minimise disruption to the local community and users of the highways network, and minimise the environmental impact of the construction processes.
7.100 Overall it is concluded that the proposed development will not have an unacceptable impact on highway safety, and the residual cumulative impacts on the road network would not be severe to warrant the refusal of planning permission on highways grounds, as defined by NPPF Paragraph 109.
Environmental Health Considerations
Contaminated Land
7.101 Policy DMP1 of Brent’s Development Management Policies and draft Policy DMP1 of the emerging Local Plan requires development proposals to not unacceptably increase, and where possible reduced, exposure to contamination.
7.102 The application includes a Phase 1 Geo-Environmental Assessment, prepared by BWB Consulting. This identifies that the risk posed by contamination to human health and controlled waters is low. The report recommends ground investigation is undertaken to quantify identified pollutant linkages and assess any mitigation measures required.
Air Quality
7.103 London Plan Policy SI 1 states that development proposals should not lead to further deterioration of existing poor air quality. Development proposals should be at least ‘air quality neutral’. The Borough is located within an Air Quality Management Area, and as such the LBB Core Strategy notes that the Council is working towards meeting National Air Quality Strategy targets as detailed within the Air Quality Action Plan.
7.104 The accompanying Air Quality Assessment prepared by BWB Consulting provides an assessment of the impacts on air quality. The results of the assessment consider the reduction in transport emissions between the existing and proposed use of the site owing to the reduced trip generation.
7.105 Taking this into account, and that the combined building and transport emissions associated with the proposed development will be lower than the combined GLA Benchmarks, the report concludes that the proposed development will be Air
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Quality Neutral overall. As such the proposed development will not lead to further deterioration of air quality in accordance with London Plan Policy SI 1.
Noise
7.106 London Plan Policy D14 requires development to mitigate and minimise the existing and potential adverse impacts of noise and vibration caused through development.
7.107 A Noise Assessment prepared by BWB Consulting has been submitted which considers both the impact of the prevailing noise climate on the proposed noise sensitive receptors associated with the development and the impact of noise generating elements of the development on existing and proposed residential receptors.
7.108 The Noise Assessment concludes that mitigation measures can be used in the design and construction of the development including suitable glazing, ventilators and suitable floor construction between the commercial unit and dwellings above, to ensure acceptable internal noise levels within the proposed residential part of the development in line with national and local policy aims.
Lighting
7.109 Policy D8 of the London Plan states that lighting should be carefully considered and well-designed in order to minimise intrusive lighting infrastructure and reduce light pollution.
7.110 The submitted Lighting Strategy, prepared by BWB Consulting provides an indicative lighting design which can achieve the required minimum lighting levels and distribution to meet the applicable British standards whilst ensuring negligible light trespass to adjoining sites.
7.111 The report concludes that lighting associated with the proposed development is considered to have a negligible impact with respect to residential properties. The most noticeable effect will be a small increase to local area sky glow, however this is anticipated to be less than that created by the existing installation and therefore an overall improvement.
7.112 As such the proposed development will not unacceptably increase exposure to light in accordance with Policy DMP1 of the Development Management Policies, draft
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Policy DMP1 of the draft Brent Local Plan and will reduce light pollution in accordance with Policies D8 and D9 of the London Plan.
Sustainability and Energy
7.113 Policy CP19 of LBB Core Strategy states that all development should contribute towards achieving sustainable development, including climate change mitigation and adaptation.
7.114 The submitted Sustainability Statement, prepared by BWB Consulting, demonstrates how sustainable design and construction measures are used to mitigate and adapt to climate change over the intended lifetime of a development, including the application of the London Plan energy hierarchy and targets in accordance with Policy CP19.
7.115 The site is located in a sustainable urban location, in close proximity to public transport facilities with numerous bus routes operating along Edgware Road and approximately 11m walk to Colindale Undeground Station. Sustainable modes of transport are further encouraged as part of the proposed development through the provision of secure and sheltered cycle parking and the implementation of a Travel Plan.
7.116 Sustainable measures include incorporation of air source heat pumps to contribute to a reduction in carbon dioxide emissions, compared with the target emissions rate. Efficiency measures to limit water consumption to 105 litres per person per day have also been considered through effective design, meeting the requirements of Policy SI 5 of the London Plan.
7.117 Sustainable modes of transport are also encouraged through the provision of secure and sheltered cycle parking and the implementation of a Travel Plan.
7.118 A BREEAM pre-assessment has also been carried out to identify credits and incorporate them into the design and demonstrates that a BREEAM rating of 'Excellent' is expected for the commercial floorspace, in accordance with Policy CP19.
7.119 In respect of energy, Policy SI 2 of the London Plan outlines the ‘Be Lean, Be Clean, Be Green’ energy hierarchy for development proposals. The policy states that major development should be net zero-carbon, and seeks to achieve a minimum on-site reduction of at least 35% beyond Building Regulations for major development.
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Residential development should achieve 10% and non-residential development should achieve 15% through energy efficiency measures. Where the zero-carbon target cannot be fully achieved on-site, any shortfall should be offset through a cash in lieu contribution to the Borough’s carbon offset fund.
7.120 The supporting Energy Statement prepared by BWB Consulting concludes that the total regulated carbon dioxide emissions of the proposed development will be reduced by 83% when compared with the Building Regulations Part L TER Baseline, comfortably exceeding the London Plan requirement of at least 35%. This is a significant improvement upon the existing building which contributes little in terms of sustainability benefits. The shortfall in regulated carbon emissions to meet the requirements of ‘zero carbon’ will be provided through a financial contribution in lieu.
7.121 CO2 savings of approximately 16% (residential) and 35% (non-residential) is also achieved for the proposed development due to energy efficiency measures, which also exceed the minimum reduction target of 10% and 15% respectively in Policy SI2 of the London Plan.
7.122 An overheating assessment also has been undertaken, detailed within the Energy Statement. The report outlines the numerous measures that have been incorporated into the design to reduce the demand for cooling and potential for internal overheating, in accordance with the cooling hierarchy of Policy SI 4 of the London Plan. The assessment demonstrates the residential dwellings with highest risk of overheating demonstrate compliance with the relevant CIBSE TM59 criteria.
Flood Risk and Drainage
7.123 With reference to the Environment Agency Flood Map for Planning, the site is located entirely within Flood Zone 1. The Council’s Surface Water Management Plan (2011) states that the Site is located within a Critical Drainage Area.
7.124 Policy DMP 9A of the LBB Development Management Policies and draft Policy BSUI3 of the emerging Brent Local Plan states that proposals that would fail to make appropriate provision for flood risk mitigation or which would increase the risk or consequences of flooding will be refused.
7.125 The submitted Flood Risk Assessment (FRA) prepared by BWB Consulting noted concludes that the proposed development is not at significant flood risk, subject to the mitigation measures recommended. Furthermore the development will not
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increase flood risk to the wider catchment area subject to suitable management of surface water runoff discharging from the stie.
7.126 Policy SI 13 of the London Plan states that a development should aim to ensure that surface water run-off is managed as close to its source as possible in line with the drainage hierarchy, which includes rainwater attenuation in green infrastructure features.
7.127 Policy DMP9B of the Development Management Policies requires proposals for new development to make provision for the installation and management of measures for the efficient use of mains water and for the control and reduction of surface water run-off. The policy seeks to target mains water consumption of 105 litres or less per person per day and to achieve greenfield runoff rates where possible.
7.128 The design and layout of major development proposals will be required to use appropriate sustainable drainage measures to control the rate and volume of surface water run-off.
7.129 The submitted Sustainable Drainage Statement, also prepared by BWB Consulting, states that green roofs will be proposed and channel drains to the perimeter of the building will be utilised.
7.130 The site is almost entirely impermeable as existing, and green roofs will considerably reduce the impermeable area of the site. The report concludes that in turn, this will significantly reduce surface water run-off rates when compared to the existing situation. Whilst the proposed drainage strategy does not achieve greenfield run off rates, given the urban nature of the site and the significant improvement on the existing situation, this is considered appropriate and acceptable in this site-specific context.
Trees and Landscaping
7.131 The Landscaping Strategy, prepared by OOBE, outlines the design concept for the landscaping scheme. The proposed development incorporates high quality hard and soft landscaping, including the communal garden at first floor podium level, together with the communal roof terraces and sixth, seventh, ninth and fifteenth floors. The palette of soft materials will primarily consist of ornamental planting on each of the roof terraces together with grassed areas at the first, sixth and seventh floors for children’s playspace.
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7.132 At street level, trees and rain garden planting are proposed along Edgware Road and Windover Avenue. This will provide significantly improved public realm along Edgware Road through urban greening which will reduce traffic dominance, in accordance with draft Policy BNGA1 and BNSA2 of the draft Brent Local Plan. Trees and soft landscaping are also proposed to the north-west boundary, providing a green buffer to the adjacent school.
7.133 There are three existing trees located towards the front forecourt of the site which are to be removed as part of the proposal and replaced with the proposed soft landscaping include numerous trees.
7.134 An Arboricultural Survey, prepared by BWB Consulting, has been submitted with the application. The report concludes that the existing trees are considered to be in conflict with the surrounding environment or low quality trees. The report recommends the removal of these trees together with suitable replanting in suitable locations to ensure that the canopy cover along Edgware Road is improved and maintained, which will be achieved through the proposed landscaping scheme.
Ecology
7.135 There are no statutory nature conservation designations within, or adjacent, to the site.
7.136 The nearest nature conservation designation is Brent Reservoir which comprises a Local Nature Reserve and a Site of Special Scientific Interest (SSSI), and is located 1.35km to the south-east of the Site. Masons Field and Fryons Country Park LNRs are both situated 1.4km to the south-east of the Site.
7.137 A Preliminary Ecological Appraisal (PEA), prepared by BWB Consulting, has been submitted which concludes that the site is considered to be of low ecological value with limited areas of green habitats, dominated by non-native species, a lack of connectivity to other habitats in the vicinity and a lack of opportunities for protected or notable species.
7.138 As such the proposed development will not result in an adverse impact to biodiversity within the Borough in accordance with Policies CP18 and DMP1 of the Brent Core Strategy and Development Management Policies and draft Policy DMP1 of the Draft Brent Local Plan. To the contrary, the proposed landscaping scheme will provide opportunity for ecological enhancement when compared to the existing development.
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Wind and Microclimate
7.139 Policy D9 of the London Plan states that the environmental impact of tall buildings, including wind conditions around the building, must be carefully considered and not comprise comfort around the building. Policy D8 of the London Plan also highlights consideration to the local microclimate created by buildings.
7.140 The scheme has been designed with consideration to the existing (and proposed) microclimate, particularly with regards to wind. The submitted Wind Climate Report demonstrates that with incorporation of the proposed mitigation measures and landscaping scheme, wind conditions at the proposed development and surrounding area would be suitable and safe. This remains as such both when assessed in the context of surrounding existing buildings, and cumulative approved schemes.
7.141 The mitigation measures include use of a canopy and balustrade to the terrace at the 18th floor, a balustrade and planters to the terrace at 15th floor, a 2.5m tall deciduous tree and planter at the sixth floor terrace and 7no. trees at ground floor level fronting Edgware Road and to the south-eastern corner. Further details are included in the submitted Wind Microclimate Assessment.
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8. CONCLUSION
8.1 This Planning Statement supports a full planning application for the following development at 363 Edgware Road, London, NW9 6AF:
“Demolition of existing building and erection of ground plus part 19, 17, 14, 8, 6 and 5 storey building to provide 165 residential units (Class C3) with commercial use (Class E) at ground floors, together with associated parking at basement and landscaping.”
8.2 The Applicant has been advised by a multi-disciplinary team of consultants who have devised a suite of documents in support of this application taking into consideration the potential impacts of the proposed development, which have been carefully considered and appropriately addressed alongside relevant planning policies and material considerations. This assessment has clearly demonstrated that the proposal is in accordance with the relevant national, strategic and local planning policies.
8.3 The site is located within the Colindale/Burnt Oak Opportunity Area, Burnt Oak/Colindale Growth Area, and also forms part of Site Allocation B/C 2: Sarena House / Grove Park / Edgware Road and part of the emerging Site Allocation BNSA2: Colindale Retail Park, Multi-Storey Car Park and Southon House in the draft Brent Local Plan.
8.4 The Statement demonstrates that the principle of the residential-led mixed use redevelopment of the site, incorporating Class E use, is acceptable in this location, which is further supported by the pre-application advice received. The proposed development will facilitate mixed use regeneration along the axis of Edgware Road as sought by Policy CP11 of the Core Strategy and draft Policy BNGA1 of the draft Brent Local Plan.
8.5 The proposed development will contribute towards delivering the housing targets of the London Plan and local planning policy, whilst providing high quality design which responds positively to the surrounding context.
8.6 The design of the proposed development has evolved through consultation with LBB, the GLA and the local community. The principle of a tall building is supported in this location within a designated Tall Buildings Zone in the draft Brent Local Plan, and the proposed height is considered acceptable given the site’s existing and emerging context. Careful consideration has been given to the scale, massing and
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detailed design to ensure that the proposed development will integrate appropriately within its surrounds. A strong legible frontage to Edgware Road will be created, incorporating a tall colonnade and public realm improvements including soft landscaping which will create an attractive environment for pedestrians.
8.7 The proposed development will provide a high standard of accommodation for future residents and it has been shown through a number of supporting documents that notwithstanding the urban context, the proposal will not have an adverse impact upon surrounding amenity, including the effect on air quality, noise, daylight and sunlight, and wind conditions.
8.8 The Transport Assessment submitted with the application demonstrates that there will be no material effect on the operation of the highways network arising from the development, taking into consideration the safety of future users and passers- by. The submitted Travel Plan also promotes sustainable transport modes which will reduce trip generation further.
8.9 On the basis of the above, the proposal is considered to be in accordance with national and local planning policy and guidance, including the Development Plan and relevant material considerations, including emerging planning policy, and as such it is respectfully requested that full planning permission is granted
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