Statement of Community Involvement

Lowick

April 2020 1 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Lowick The News Building 3 London Bridge Street London, SE1 9SG [email protected] +44 (0)203 743 6250 2 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Contents

1. Executive Summary ...... 3 2. Introduction ...... 5 2.2. Stakeholder audit ...... 8 3. Consultation Aims ...... 9 4. Consultation activity and outcomes ...... 10 4.1. Demography and approach to consultation ...... 10 4.2. Publicity (July 2019) ...... 13 4.3. Public exhibition (July 2019) ...... 15 4.4. Survey responses (July 2019) ...... 16 4.5. Publicity (November 2019) ...... 23 4.6. Public exhibition (November 2019) ...... 25 4.7. Survey responses (November 2019) ...... 26 4.8. Stakeholder meetings ...... 31 5. Key issues and responses ...... 33 6. Conclusion ...... 37 Appendices ...... 40 Appendix 1: Publicity flyer for July 2019 public exhibition ...... 41 Appendix 2: Advert featured in the 11 July 2019 Harrow Times ...... 43 Appendix 3: Site poster (July 2019) ...... 44 Appendix 4: Public exhibition boards (July 2019) ...... 45 Appendix 5: Survey (July 2019) ...... 54 Appendix 6: Publicity flyer for November 2019 public exhibition ...... 58 Appendix 7: Advert featured in the 7 November 2019 Harrow Times ...... 59 Appendix 8: Site poster (November 2019) ...... 60 Appendix 9: Public exhibition boards (November 2019) ...... 61 Appendix 10: Survey (November 2019) ...... 70 Appendix 11: Map showing approximate location of respondents to surveys .. 74

3 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

1. Executive Summary

1.1.1. This Statement of Community Involvement (SCI) has been prepared by Lowick to accompany an application for full planning permission for Rayners Lane Station Car Park, 5 High Worple, Rayners Lane (“the site”); the re-development of the site to provide 128, 100% affordable homes while retaining 75 commuter car parking spaces., a commuter Cycle Hub, and public realm improvements. The application is submitted by Catalyst Housing Limited (Catalyst) and Transport for London (TfL) (“the applicant”).

1.1.2. The public engagement and consultation for the application was coordinated by Lowick, in conjunction with Catalyst, TfL and the wider project team. Since July 2019 there has been extensive discussions with neighbouring residents, businesses, and commuters, as well as elected members. The applicant has been particularly mindful of the need to engage closely with local residents.

Figure 1: View of the proposed scheme looking west along new street (to update).

1.1.3. Two rounds of public consultation have taken place, with exhibitions held in July 2019 focusing on the principles of development, and in November 2019 on the detailed proposals for the site. 121 people attended the events including local residents, businesses, councillors, and Rayners Lane commuters and car park users. The public 4 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

website has seen significant interest and following the publicity for the scheme it has received 2,056 unique visits and 225 comments.1

1.1.4. Comments from the London Borough of Harrow (LBH) as local planning authority, the Design Review Panel (DRP), stakeholders and the public have all contributed to the submitted scheme and resulted in a number of changes. For example, there has been a reduction in height of the building closest to the station, additional public realm works on High Worple, alterations to the car park layout and revisions to the façade and materials to preserve neighbouring residents’ privacy.

1.1.5. Overall, the majority of comments from members of the public were negative, with views expressed on the reduction of parking, the principle of a car free development and the need for housing. There was some opposition to the principle of development due to the reduction in parking at Rayners Lane Station and a number of respondents seemed concerned about the increase in the local population and impacts on local services in the area. A theme of the feedback we have received has been opposition to the delivery of new housing in the local area (or in some cases affordable housing in particular). In addition, some local residents, particularly those with homes on High Worple, have expressed concern about the height and density of the proposals as ‘not in keeping’ with the suburban nature of the area.

1.1.6. There has been support for the principle of providing affordable housing and the introduction of secure cycle spaces, encouraging commuters to take more active modes of transport. Supportive comments often referenced the housing crisis and climate emergency as key challenges. The architecture has been generally well received, with objections generally to the scale of the buildings rather than the façade design and materials.

1.1.7. The scheme addresses the Mayor of London and the London Borough of Harrow’s (LBH) aim to deliver more affordable housing in the borough, in sustainable, well- connected locations, as set out in detail in the Planning Statement.

1.1.8. The Mayor’s Transport Strategy sets a target of 80% of journeys on foot, by bicycle or by public transport, by 2041. Furthermore, the Intend to Publish version of the London Plan (December 2019) also requires all redevelopment to reduce parking and consider car-free as a starting point, especially when a site is so close to a transport hub. The benefits in terms of reduced vehicle trips, and potential impacts of the reduction in parking are set out in the Transport Statement.

1.1.9. The applicant has undertaken a comprehensive and transparent pre-application consultation with the local community, in line with both guidance and best practice. Where possible, and when not in contravention of the core purpose of the scheme and policy, changes have been made to the scheme to resolve specific concerns.

1.1.10. The applicant has submitted proposals which will directly benefit the borough and local community by providing 128 high-quality 100% affordable homes, in a sustainable location, and fulfilled the requirements of both the Local Plan, the Intend to Publish version of the draft London Plan (December 2019) and relevant aspects of the London Plan (2016, as amended).

1 Visitor and comments statistics to http://www.raynerslane.commonplace.is/ as of 18 February 2020, 11:00. 5 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

2. Introduction

Figure 2: View of proposed entrances to blocks A, B and C

2.1.1. This Statement of Community Involvement (SCI) has been prepared by Lowick to accompany an application for full planning permission for Rayners Lane Station Car Park, 5 High Worple, Rayners Lane, HA2 9SJ (“the site”), the re-development of the site to provide 128, 100% affordable homes while retaining 75 commuter car parking spaces. The application is submitted by Catalyst Housing Limited (Catalyst) and Transport for London (TfL) (“the applicant”).

2.1.2. This development will also include improved access and public realm to the car park from High Worple, new landscaping and a new secure commuter Cycle Hub with 82 spaces and plus secure residential cycling spaces for new residents.

2.1.3. An application for full planning permission is being submitted for the following:

“Redevelopment of existing public car park to provide new residential accommodation (Use Class C3) and Sui Generis floor space at ground floor and a public car park along with associated works.” 6 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Figure 3: Overview of the scheme and site layout (axonometric)

2.1.4. The development includes four buildings of between 5 and 6 storeys on a 1.61 ha site; made up of a standalone building (D) at the western end of the site, and three linked mansion blocks aligned with the railway line (buildings A, B and C). They will offer 128 affordable homes in total, with 95 for London Shared Ownership (68% by habitable room) and 33 for London Affordable Rent (32% by habitable room).

2.1.5. The purpose of this report is to outline the community engagement undertaken by the applicant, and how the application submitted responds to the issues raised. It should be read alongside the following key documents as well as the wider application: 7 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

• Design and Access Statement prepared by Karakusevic Carson Architects (KCA);

• Landscape and Public Realm Strategy prepared by Townshend Landscape Architects;

• Planning Statement prepared by CBRE.

2.1.6. The applicant has held formal pre-application discussions with the London Borough of Harrow (LBH) and other statutory consultees including Historic England and Transport for London (in their strategic planning and transport role). Four rounds of independent design review have also been undertaken with the Harrow Design Review Panel (DRP) and Mayor’s Design Advocate (MDA). Two presentations were given to the Harrow Major Development Panel (MDP).

2.1.7. Our consultation strategy was drafted in accordance with the relevant provisions and recommendations laid out in the LBH Statement of Community Involvement (2012), the Localism Act (2011) and the Revised National Planning Policy Framework (2019) on community involvement in planning. It forms part of the supporting documentation, which informs the planning application.

2.1.8. The applicant acknowledges its responsibility to make sure that people are aware of the proposals and given an opportunity to give their feedback on the plans. The aim has been to deliver a consultation in line with industry best practice. Since July 2019 we have held two rounds of public exhibitions with a combined attendance of 121 people and received a total of 225 comments to our public consultation covering a significant range of issues.

2.1.9. The consultation website for the scheme, hosted by Commonplace, has recorded a significant amount of web traffic, with 2,056 total unique visitors since July 2019. We also received over 59 emails and telephone calls relating to the proposals. Note that many individuals or groups have made multiple comments and enquiries, with 142 unique survey respondents identified through the course of the consultation.2

2 Visitor and comments statistics to http://www.raynerslane.commonplace.is/ as of 18 February 2020, 11:00. 8 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

2.2. Stakeholder audit

2.2.1. Lowick conducted an audit of the relevant political, business and community stakeholders in the local area. The stakeholders were either invited to have individual meetings with members of our project team, offered presentations to their organisation or specifically invited to our public consultation events.

2.2.2. Political stakeholders:

• Cllr Graham Henson, Leader of Harrow Council • Cllr Keith Ferry, Deputy Leader, Cabinet Member for Regeneration, Planning & Employment, Chair of Planning Committee • Cllr Phillip O’Dell, Cabinet Member for Housing • Cllr Paul Osborn, Leader of the Opposition • Cllr Stephen Greek, Shadow Planning & Regeneration Lead • Major Developments Panel • Planning Committee • Navin Shah AM, London Assembly Member for Harrow and Brent • Gareth Thomas, Member of Parliament for Harrow West • Cllr Chloe Smith, Rayners Lane Ward • Cllr Jeff Anderson, Rayners Lane Ward • Cllr Krishna Suresh, Rayners Lane Ward • Cllr Adam Swersky, Cabinet Member for Finance, West Harrow Ward (Neighbouring Ward to the Site)

2.2.3. Local groups and organisations

• Rayners Lane Traders Association • Friends of Roxborne Park • Harrow Nature Conservation Forum • Harrow Heritage Trust • Harrow Public Transport Users Association • Metropolitan Line Users Group • Harrow Cyclists • A group of residents from High Worple that formed in response to the proposals (not a formally constituted residents’ association).

9 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

3. Consultation Aims

3.1.1. The aims of the consultation and community involvement were to:

3.1.2. Allow the local community, station and car-park users to have their say on our proposals. Planning is a matter of public interest and the applicant is committed to best practice in engaging with the local community on proposals for the site. The aim was to proactively involve individuals and groups to ensure that feedback could, where appropriate, be incorporated into the design.

3.1.3. Ensure the consultation was fully accessible, in particular to:

• People with little prior knowledge of the planning system; ensuring that the consultation was accessible and understandable to all, regardless of their level of knowledge of planning or development. We held public exhibition events for all members of the public and uploaded our exhibition materials and a detailed survey onto our bespoke website for the site using the Commonplace consultation platform.

• To those with disabilities, by ensuring that all documents were available in accessible formats upon request and that the public consultation was held at an accessible venue.

• A broad range of people, reflective of the areas demographics while also being mindful of protected characteristics. For those who were willing, basic demographic information has been recorded for consultation responses in an anonymised form.

3.1.4. Support the development of a scheme that meets the needs and aspirations of the local area. We want to ensure that through consultation and engagement with local residents, businesses, organisations, community groups, and councillors, the scheme respects the character of the local area and makes a positive contribution. 10 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4. Consultation activity and outcomes

4.1. Demography and approach to consultation

4.1.1. The applicant was aware that due to Rayners Lane Station’s location on both the Metropolitan and Piccadilly lines, it was an attractive route into central London for commuters from a wide area, and that a key theme would be the reduction in car parking at the station.

4.1.2. As a result, there was a need to conduct a much wider consultation than with just the neighbouring residents and businesses. An online consultation hub was established which included detailed information about the proposals along with an in-depth online survey, facilitated by Commonplace, a specialist online consultation platform. Promotion of the consultation events included not just flyers to local addresses but emails to Oyster card users using the station regularly, as well a local media advertising.

4.1.3. Commonplace is an online platform that helps better understand the needs of different groups. Their websites help make local participation easier by reaching wider audiences and invite them to take part in the consultation process.

4.1.4. Our Commonplace site for Rayners Lane has received 2,056 total unique visitors since July 2019. 57% of those who visited the site did not engage with the material, with 17% exploring the project in depth, 20% viewing between two and four pages, and 5% contributing. 142 unique individual respondents were recorded, with 76 people subscribing to the project news, where they would receive a notification on any new information regarding the scheme.3

4.1.5. We have looked at the demographic breakdown of those who responded to our consultation while also comparing it to the local community as a whole. 22% were commuters and 6% daily car park users while 61% of those surveyed stated that they were local residents4. The map included at Appendix 11 shows the approximate location of respondents and their broad sentiment. The vast majority of recorded postcodes were from the immediate locality, with a small number from further afield such as Stanmore, Watford or Barnet based on their postcode information.

4.1.6. More than a quarter (27%) of those who filled in feedback were aged 60 years old or over, with only 6% below the age of 30. 19% were between 30-44, with 26% between 45- 59. The remainder did not state their age. This is not representative of the age range that live in the Rayners Lane ward where the site is situated, with the younger demographic underrepresented5. There were approximately equal numbers stating their ethnicity was white compared with a Black, Asian or Minority Ethnic (BAME) background. The ward is approximately 70% BAME.

4.1.7. 65% stated they were self-employed, in full- or part-time work (compared to 71.5% in the census data), with 11% retired and 22% did not state an employment status. This is relatively proportional to the residents in the Rayners Lane ward.

3 Visitor and comments statistics to http://www.raynerslane.commonplace.is/ as of 18 February 2020, 11:00. 4 Note, this monitoring question allowed respondents to choose more than one option. 5 ONS Mid-Year (30 June 2019) ward level population estimates indicate Rayners Lane ward has 36% 0-29-year olds, 22% 30-44-year olds, 20% 45-59-year olds, and 22% 60+ year olds. 11 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.1.8. Transport for London Canons Park Station Car Park user survey

4.1.9. In 2017, Transport for London commissioned a survey of car park users, which has formed part of the applicants thinking for the proposals. This was based on a survey of 213 weekday car park users.

Figure 4: Rayners Lane Station Car Park users (origin map with distance isochrones, note blue dots can indicate up to 10 responses)

4.1.10. The surveys identified that 40% of Rayners Lane car park users point of origin is within 2km of the station, 29% is between 2km and 5km and 31% over 5km from the station.

4.1.11. Based on their locations, it would be 2 minutes quicker on average to cycle from within 5km than to drive, and 12 minutes quicker on average to take public transport for users over 5km away.

4.1.12. For those using the car park who’s point of origin is 5km away or more, there may be a number of reasons relating to cost, convenience or journey time. The data indicates many travel from other parts of Harrow, often with either Underground or mainline stations closer to their homes. The availability of parking, the zoning of Rayners Lane (Zone 5) which could reduce cost, more favourable destination for the Metropolitan and Piccadilly Line, and the relatively low daily parking costs are all factors driving this behaviour. Alternative routes are available for many in this group

4.1.13. Station car park users make up approximately 3.4% of the total weekday station users, with sustainable modes serving approximately 7,000 daily users. This is predominantly a station which serves the immediate residential community rather than a wider area.

4.1.14. The car park at Rayners Lane station is also rarely at maximum occupancy. The studies by TfL illustrate that the typical occupancy of the car park is between 35-65%, i.e. between 100-150 spaces occupied of 251 total, and this is acknowledged by local groups 12 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

and residents. A more extensive occupancy study is included in the Transport Assessment.

4.1.15. The data indicates there is significant scope for so called ‘modal shift’ for the majority of car park users, particularly the unusually high proportion (40%) who’s point of origin is within 2km of the station, generally regarded as walking distance for those without mobility problems. The survey formed part of the public consultation materials and was shared with stakeholders to explain the reasoning behind a reduction in commuter car parking.

4.1.16. 32% of car park users would consider cycling if facilities were improved. There is a good opportunity, combined with wider investment in the cycle network, to promote higher rates of cycling and a positive behavioural change for some car park users.

13 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.2. Publicity (July 2019)

4.2.1. Ahead of our first public exhibition in July 2019, the applicant introduced the scheme to the public with a flyer to nearby residents and businesses. 2,066 addresses were sent a flyer via leaflet distributor, London Letterbox (now Lbox Communications).

4.2.2. The distribution area and dates of the event were shared with LBH officers in advance for comment.

4.2.3. The area of distribution is shown below:

Figure 5: July 2019 public consultation flyer distribution area

4.2.4. The flyer described our proposals as follows and is included at Appendix 1:

“We want to hear your thoughts on our plans.

“Catalyst, in partnership with Transport for London, is proposing to build affordable homes at Rayners Lane Station car park. This site provides a fantastic opportunity to provide much-needed high-quality new homes with public transport to the city and local shops and amenities a short walk away.”

4.2.5. The flyer to nearby residents also contained an invitation to our public consultation, with details of the location and timing of the event. Included within the flyer was a map 14 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

showing the site boundary, and the exhibition venue location. Contact details were also provided.

4.2.6. Additional publicity:

• An advert featured in the 11 July 2019 edition of the Harrow Times (Appendix 2).

• Invitation emails were sent to organisations, politicians and local groups.

• Emails were sent by TfL on 10 July 2019 to all those that use an Oyster card and regularly pass through Rayners Lane station. This was sent to 23,300 customers, had an open rate of 41.24% (9,529 of those unique) and a click through rate 3% (701 of those unique).

• Posters were put up at Rayners Lane Station and in the station car park. (Appendix 3).

• Flyers were handed out to commuters at Rayners Lane Station during rush hour.

15 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.3. Public exhibition (July 2019)

4.3.1. The first public exhibition event on the Rayners Lane Station site proposals was held on 16 July 2019 at The Beacon Centre, a short walk from Rayners Lane Station car park. The venue was chosen because of its relative proximity to the site and its disabled access provision.

4.3.2. The focus of the exhibition was to introduce the principles of the scheme, the constraints and opportunities presented by the site, and to seek input from the local community at an early stage about the proposals.

Figure 6: Tuesday 16 July 2019 public exhibition at The Beacon Centre.

4.3.3. The table below summarises the details of the public exhibition:

Venue and time The consultation event was held: • Tuesday 16 July (5pm-8pm)

The public exhibition aimed to attract members of the local community, specifically local residents, car park users and local groups. The event was held at The Beacon Centre, Malcolm Jeffrey Place, South Harrow, London, HA2 0TY

Purpose The purpose of the exhibition was to provide the local community with information about the principles of the proposal and allow them to feed back before the applicant brought back more detailed plans. It also gave local residents and businesses an opportunity to speak to the project team and ask any questions they may have.

Publicity In addition to the flyer distribution covered above, an advert was placed in the Harrow Times and key stakeholders were contacted directly. Posters were also put up in the station, 16 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

and leaflets handed out at rush hour. Oyster card users at Rayners Lane Station were also sent an email by TfL. The publicity materials are included at Appendix 1, Appendix 2, and Appendix 3.

Public exhibition The scheme was presented on 9x A1 Foamex boards, and also content made available on iPads for those with access needs.

These are available at Appendix 4.

Members of the project team were in attendance and guided attendees through the boards, as well as answering any questions they had.

Visitors There were 51 visitors to the public exhibition at the Beacon Centre on 16 July 2019.

Opportunity for For the Harrow Station Sites public consultation, TfL and feedback / Website Catalyst opted to use Commonplace, an online community consultation platform, to record feedback from the consultation.

All attendees were encouraged to leave feedback on the in- depth survey on the website www.raynerslane.commonplace.is.

The website also included all information from the exhibition boards that were on display at the event. iPads were available at the consultation for attendees to fill in their feedback, however there were also flyers with the website address on them, to encourage people to fill in the survey at home. Paper copies of the feedback forms were also made available at the consultation for those who stated that they were not proficient computer users. A copy of the feedback form is included at Appendix 5.

Questionnaires 118 verified responses were received in total to the survey. We completed also received 26 email and telephone enquiries.

4.4. Survey responses (July 2019)

4.4.1. In total, 130 comments were submitted to the survey, either at the consultation itself or on a later date. These were from 70 total respondents of which 65 can be confirmed as linked to an individual and form part of the reported statistics (118 verified comments). This survey was open from 17 July 2019 to 16 October 2019

4.4.2. All comments are publicly visible on the website (www.raynerslane.commonplace.is/).

4.4.3. Overall, 55% of comments were negative about the plans to redevelop the Rayners Lane car park site for affordable housing, and 12% neutral. However, 33% of those surveyed indicated positive views, with the highest support for the design principles.

4.4.4. The largest number of negative comments (31) related to the considerations and opportunities section of the survey, which related to the principle of development and the reduction in commuter car parking. 17 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.4.5. The vast majority of the comments related to the overall principle of developing the site for housing, attitudes towards development in general, and parking. There were relatively few comments which addressed the detail of the proposals or specific aspects of the design, materials, landscaping or public realm. While these elements were not yet developed for the scheme, feedback was sought on various precedent options.

4.4.6. Chart 1: Comment sentiment 0% 20% 40% 60% 80% 100%

Considerations and opportunities 31 7 18

Design principles 9 3 9

Our proposals 25 4 12

TOTAL 65 14 39

Negative Neutral Positive

4.4.7. The survey was divided into three sections: ‘considerations and opportunities’, ‘design principles’, and ‘our proposals’. Each asked a closed question to understand the broad sentiment of the respondent, alongside more detailed questions and open response opportunities.

4.4.8. The framing questions for each section were as follows:

• Considerations and opportunities: How do you feel about the opportunity to provide 100% affordable housing at Rayners Lane Station?

• Design principles: How do you feel about the design principles we have set out?

• Our Proposals: How do you feel about the proposals overall?

4.4.9. Chart 2: What should be our priorities when developing plans for the site?

4.4.10. We asked people to rank priorities (rank 1 being the highest priority) based on a list of options including ‘other’ and an open comments box. The most well supported priority was ‘improving the public realm’. The respondents who rated these issues highly tended to be opposed to the principle of new housing on the site and generally placed ‘more affordable housing’ as their least favoured option. Housing was the most divisive option by far, but there was moderate support for ‘better overlooked commuter car parking.’

4.4.11. The open comments on priorities reflected the data on this question, with comments indicating that existing residents and car park users should be the highest priority, not future residents or those in housing need. A number of comments stated explicit opposition to any new housing in the area, and specifically that they were opposed to affordable housing due to existing congestion and strains on local school places. Users also argued that these proposals were “making it difficult for commuters” or would “inconvenience” existing homeowners. 18 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

0% 20% 40% 60% 80% 100%

Improving the public realm 20 19 10 3

Better overlooked commuter car parking 9 20 11 7 5

Commuter cycle parking 5 4 21 14 7

New affordable homes 9 4 7 15 17

Other 9 5 2 13 23

Rank 1 Rank 2 Rank 3 Rank 4 Rank 5

4.4.12. Chart 3: How do you mainly use Rayners Lane station car park?

7% I don't use the car park 13% I park here as part of my commute 42% I park here occasionally for work 7% I park here to visit friends and family 2% I park here to travel into London for leisure 5% I park here to visit local amenities Other 24%

4.4.13. Just over half (51%) stated they used the car park regularly or occasionally, with 24% commuting. Out of approximately 7,000 people who enter the station daily, only approximately 3.4% use the car park based on full occupancy of every space once per day. The profile of respondents to the survey is therefore likely to very significantly overrepresent regular car park users, who will understandably be the most concerned about any reduction in spaces.

19 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.4.14. Chart 4: Do you support providing secure cycle parking for commuters at the station as part of the development?

15% 23% Strongly support Support Neither support nor oppose Oppose 35% Strongly oppose 23%

4% 4.4.15. Chart 5: Would secure cycle parking at the station make you:

7% 5% Much more likely to cycle instead of drive

More likely to cycle instead of drive

45% 22% It would make no difference I already cycle to the station

My journey would not be possible by bicycle 2% I don't cycle 18%

4.4.16. 27% of consultees were opposed to providing secure cycle parking for commuters as part of the redevelopment. 38% of respondents either supported or strongly supported the provision of a commuter cycle hub at the station.

4.4.17. There were a relatively balanced set of comments regarding cycling. While some did not feel cycling was a reasonable alternative for commuters or for themselves, there was support for the principle of better facilities. A number noted that wider cycling infrastructure improvements were needed in the local area to improve safety and make cycling a more appealing option for a wider demographic.

4.4.18. However, the findings on the possible behavioural impact of improved cycling facilities suggested 12% were more likely to cycle to the station. This is lower than the 2017 TfL survey of car park users which suggested up to 32% would consider shifting to this more sustainable mode of travel. These different results may relate to the disproportionately older demographic who responded to the survey, or local residents who already walked to the station.

20 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.4.19. Chart 6: What are the most important design principles to you? 0% 20% 40% 60% 80% 100%

To design a new green and sustainable 3 8 1 2 1 4 community

To enhance the natural landscape and 3 2 4 5 5 improve public access

To provide high quality and well designed 4 2 6 3 1 3 homes

To provide high quality public and 3 2 3 4 4 1 2 communal spaces

To improve walking and cycling links 3 2 2 1 6 2 1 2

Integrate the new development into 1 2 1 9 5 1 neighbourhood

Contribute to the unique setting and 1 2 1 1 1 3 3 7 ehance the Conservation Area Character

To optimise land to provide housing while 1 2 1 5 6 4 integrating commuter parking

Address the site's complex boundary 1 1 1 1 4 8 3 conditiions

Rank 1 Rank 2 Rank 3 Rank 4 Rank 5 Rank 6 Rank 7 Rank 8 Rank 9

4.4.20. The comments on the design principles predominantly focused on enhancing the natural landscape and public realm and there was substantial support for providing high-quality, easily maintained public and communal space for all ages. The comments reflected the desire to respect the existing character of the area and ‘Art Deco’ façade of the existing Rayners Lane station building.

4.4.21. At the public exhibition events themselves, boards were provided with precedent examples of architecture, landscaping. Stickers and post-it notes were provided for feedback on the options.

4.4.22. However, the majority of comments on these boards did not engage with the detail of the proposals or offer a view on the architecture, materials or landscape design direction the architects should take. Most post-it note comments instead stated opposition to the principle of development or concerns about parking.

4.4.23. What type of housing do you think is most needed in the area?

4.4.24. We also asked ‘what type of housing do you think is most needed in the area’ as part of the survey with a series of option provided. 21 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.4.25. The most popular options amongst respondents for what type of housing was most needed locally were homes for first time buyers (15), social and affordable rented homes (12), family housing (8), and supported housing for older people (6). However, there were also six responses stating that no housing was needed in the area at all. Relatively few respondent chose to engage with this section of the survey in comparison to questions relating to the constraints on development or parking.

4.4.26. However, of those who expressed any preference for housing of any type, their wider attitude to the scheme was significantly more positive. For example, of those who indicated social or affordable rent homes were needed in the area, 58% were positive about the scheme and only 25% negative.

4.4.27. Key issues in written and verbal feedback

4.4.28. As expected, resident’ parking and loss of a proportion of the commuter car-park spaces were the major topics raised. A significant proportion of respondents felt that the car park was at full capacity, and that reducing it will “stop people getting to work”. Many stated that people would not change their mode of transport. The use of the car park to support the local shops and restaurants was also seen as a concern.

4.4.29. A number of respondents disagreed with statistical evidence that car ownership was in decline and said that cars are “not going out of fashion”. Most of this group were also sceptical of the utility of improved cycle parking, one stating cycling was a “luxury”, and either did not cycle or said better provision would make no difference to their behaviour.

4.4.30. Some of the people who answered the survey were concerned about displacement to surrounding residential roads or impact on traffic, and the ramifications for the existing Controlled Parking Zones, which only have very limited hours.

4.4.31. A significant minority agreed that limiting commuter parking would have local benefit of improving safety, congestion and pollution – and would be justified given the provision of 100% affordable housing and wider sustainability goals. For example, an individual on the Rayners Lane website commented that, “do not keep any commuter car parking, as we want people to use other modes of transport (walk and cycle) to reach the station. A cycle hub is good, but people will not cycle without safe, convenient, direct cycle paths to surrounding areas.”

4.4.32. The impact of new homes on wider infrastructure in the area was stated as a concern in a large number of comments, particularly the capacity of GPs surgeries and local schools. There were a number of comments about the area being “overcrowded” or subject to “overdevelopment”, referencing new schemes in the area or wider borough over the last few years.

4.4.33. There was significant opposition to the principle of new homes in the area, regardless of tenure or design, with many stating that “no further housing is required”. A number also raised that new social housing would “degrade the area” and be a “sink estate” as well as “create more crime”.

4.4.34. Those that were in support often mentioned the housing crisis and supported the 100% affordable housing, a number stated they would support fewer parking spaces and higher density. One stated, “there is a housing crisis and we have to get real about solving it. And the only way to do so is build many more homes. Strongly support this development. In fact, I wish it were taller.” 22 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.4.35. The proposed heights of the blocks at around six storeys was raised as a concern by a number of respondents, particularly whether they would ‘overlook’ the properties on High Worple despite significant separation distances. Some of these comments described the buildings as “high rise”.

4.4.36. There were a number of comments about the size of flats generally being too small, although no details of interior layouts were provided at this stage, and all meet relevant space standards.

23 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.5. Publicity (November 2019)

4.5.1. Ahead of the second public exhibition on 20 and 21 November 2019, a flyer was sent to nearby residents and businesses. 2,306 addresses were sent the flyer via our leaflet distributor, London Letterbox.

4.5.2. The second exhibition presented more detailed designs and visualisations of the scheme, and how the applicant had responded to feedback from the first public exhibition. Information as displayed on 10x A1 Foamex boards with a scale architectural model of the proposals and their immediate context.

4.5.3. The proposed distribution area and dates of the public exhibition were shared with LBH planning officers in advance.

4.5.4. The area of distribution is shown below:

Figure 7: Public consultation flyer distribution area

4.5.5. The newsletter described our proposals as follows and is included at Appendix 6:

HAVE YOUR SAY ON NEW AFFORDABLE HOMES FOR RAYNERS LANE

Catalyst, in partnership with Transport for London, invite you to a public exhibition on our updated plans for new homes at Rayners Lane Station car park. We are proposing to build 100% affordable homes on this site, to help meet Harrow’s housing need, while retaining a proportion of commuter car park spaces.

We are holding a drop-in exhibition for local residents and businesses where you can see how plans have developed since our first event in July, meet the project team and let us know your thoughts. 24 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.5.6. The flyer to nearby residents also contained an invitation to our public consultation, with details of the location and timings of the events. Included within the flyer was a map showing the site boundary, and the exhibition venue location. Contact details were also provided.

4.5.7. Additional publicity:

• An advert featured in the 7 November 2019 edition of the Harrow Times (Appendix 7).

• Invitation emails were sent to organisations, politicians and local groups.

• Emails were sent by TfL on 7 November 2019 to all those that use an Oyster card and regularly pass through Rayners Lane station. This was sent to 23,889 customers, had an open rate of 39.89% (9,504 of those unique) and a click through rate 1.38% (329 of those unique).

• Posters were put up at Rayners Lane Station and in the station car park. (Appendix 8).

• Flyers were handed out to commuters at Rayners Lane Station during rush hour.

25 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.6. Public exhibition (November 2019)

4.6.1. Following the feedback from the first public exhibition, the applicant held a second exhibition in November 2019, showing updated plans, including much greater detail on the design of the buildings, CGI’s and an architectural model.

4.6.2. The exhibition was held across two days, in the afternoon and evening of Wednesday 20 November and Thursday 21 November. The consultations were held at Regent Independent College, 167 Imperial Drive, Harrow HA2 7HD.

Figure 8: Photograph of the second public exhibition

4.6.3. The table below summarises the details of the second public exhibition:

Venue and time The event was open to the public on: • Wednesday 20 November (5pm – 8pm) • Thursday 21 November (5pm – 8pm) The public exhibition aimed to attract members of the local community, specifically local residents and those who commute from Rayners Lane Station.

The event was held at Regent Independent College, 167 Imperial Drive, Harrow HA2 7HD.

Purpose The purpose of the exhibition was to provide the local community with further detailed information about our proposals and allow them to feedback on the development before a detailed planning application was submitted. It also gave local residents and commuters an opportunity to speak to the project team and ask any questions they may have. 26 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Publicity In addition to the flyer distribution covered above, an advert was placed in the Harrow Times and on their website. Key stakeholders were also contacted directly.

Posters were put up in the station and car park, and leaflets handed out at rush hour. Oyster card users at Rayners Lane Station were also sent an email by TfL.

The project team also updated the website for the proposals, http://www.raynerslane.commonplace.is/ , which notified all people who had provided feedback after the first consultation. The publicity materials are included at Appendix 6, Appendix 7, and Appendix 8.

Public exhibition The scheme was presented on 10 A1 Foamex boards, with a content scale architectural model and also made available on iPads for those with access needs.

These are available at Appendix 9.

Members of the project team were in attendance and guided attendees through the boards, as well as answering any questions they had.

Visitors There were 70 visitors to the public exhibitions over the two days at Regent Independent College.

Opportunity for TfL and Catalyst opted to use Commonplace, an online feedback community consultation platform, to record feedback from the consultation. All attendees were encouraged to leave feedback on the in-depth survey on the website http://www.raynerslane.commonplace.is/.

The website also contained the exhibition boards that were on display at the event. iPads were available at the consultation for attendees to fill in their feedback, however there were also flyers with the website address on them, to encourage people to fill in the survey at home. Paper copies of the feedback forms were also made available at the consultation for those who stated that they were not proficient computer users.

A copy of the feedback form is included at Appendix 10.

Numbers of 93 comments were received in total on the online survey questionnaires from 27 individuals. We also received 28 email and completed telephone enquiries. Note that some of these are multiple responses from the same individual.

17 people responded in advance to the updated proposals being published on the website, while indicating that they would not be attending the consultations. 4.7. Survey responses (November 2019)

4.7.1. For the November 2019 round of the survey, 95 comments were submitted to the survey, either at the consultation itself or on a later date. These were from 27 unique 27 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

respondents of which 26 can be confirmed as linked to an individual and form part of the reported statistics (93 verified comments). The survey was open from 20 November 2019 to 21 February 2020. All comments are publicly visible on the website (www.raynerslane.commonplace.is/).

4.7.2. Overall, 55% of comments were negative, 31% neutral with 13% positive. The least negative and contentious areas were design and materials, and landscaping, and there was 28% positive feedback for affordable housing.

4.7.3. Chart 7: Comments and sentiment 0% 20% 40% 60% 80% 100%

Introduction (and quick feedback) 21 2 1

New affordable homes 8 5 5

Landscape 5 7 3

Design and materials 6 8 2

Parking and transport 11 7 1

TOTAL 51 29 12

Negative Neutral Positive

4.7.4. Respondents’ feedback on the surveys were analysed and categorised into positive, negative and neutral sentiments around the principle of the proposed plans. The comments were predominantly negative with most directed at the parking and transport proposals in the scheme or the principle of development. Broadly, the pattern and types of issues identified were very similar to the first round of consultation

4.7.5. The survey was divided into five sections. Each asked a closed question to understand the broad sentiment of the respondent, alongside more detailed questions and open response opportunities. The introductory section provided a shortened survey and more general questions.

4.7.6. The framing questions for each section were as follows:

• Introduction (and quick feedback): Broadly speaking, how do you feel about the proposals for 128 new affordable homes at Rayners Lane station?

• New affordable homes: How do you feel about providing 100% affordable homes for London Affordable Rent and shared ownership on this site?

• Landscape: How do you feel about the proposals for landscaping and play space?

• Design and materials: How do you feel about the design and materials proposed? 28 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

• Parking and transport: How do you feel about the proposals to retain 85 commuter car park spaces?

4.7.7. Chart 8: Do you support providing 100% affordable homes for London Affordable Rent (broadly equivalent to social rent) and shared ownership? 21%

17% Strongly support 12% Support Neither support nor oppose 8% Oppose Strongly oppose

42%

4.7.8. 33% of respondents indicated they were supportive of a scheme including 100% affordable housing made up of a mixture of London Affordable Rent and Shared Ownership, 50% stated they were opposed to this and 17% were neutral. Amongst those who opposed, the main reasons included loss of parking, concern that social housing would increase crime and anti-social behaviour, that there was insufficient infrastructure, and a disagreement that there was housing need in the area.

4.7.9. Chart 9: In principle, would you support local residents’ parking having greater protection, through a wider Controlled Parking Zone of longer hours?

41%

Strongly support Support 18% Neither support nor oppose Oppose Strongly oppose 23% 6% 12%

4.7.10. One potential mitigation for reduced commuter car parking could be strengthened controlled parking zones (CPZ) in the area. Whilst the immediate area around the site is already covered by a CPZ, the hours are limited and in the first round of consultation many residents expressed concern that on-street parking would be harder to find if there was a reduction in car park spaces. Responses were supportive of stronger parking controls. However, in the comments many of those who opposed additional controls emphasised the opposition to the reduction in parking or a general opposition to controlled residents’ parking.

29 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.7.11. Chart 10: Do you support the inclusion of a secure cycle hub with around 108 spaces in the proposed development, to encourage people to take a healthier mode of transport to the station?

44%

Strongly support Support 12% Neither support nor oppose Oppose Strongly oppose 19%

19% 6%

4.7.12. As in the first round, more than half supported the principle of a new cycle hub at the station. Nevertheless, many comments indicated they did not feel cycling (or walking) were viable options for travel to the station even for short distances, particularly for older residents.

4.7.13. Key issues in written and verbal feedback

4.7.14. Principle of development: A number of of respondents strongly objected to the principle of the development, which was to reduce the number of car parking spaces and to develop affordable housing on a site which has been allocated as an appropriate site for housing in Harrow Council’s Local Plan. The perceived increase in congestion in and around Rayners Lane, the expected result of increased parking on side streets, including High Worple, as well as potential strain on public services were all mentioned as reasons for this opposition. There was little support amongst this group for increasing housing supply, affordable housing or sustainable travel as policy goals with parking for existing residents and commuters regarded as a higher priorities.

4.7.15. Congestion: An increase in congestion and traffic was raised by a significant number of comments, both due to new residents and commuters seeking a parking space. Respondents referenced the existing traffic concerns around Rayners Lane station and the high street. One respondent claimed that “Rayners Lane is already busy with traffic at all times of day and night, this will bring it to a standstill.” Despite the plans proposing a completely car-free development, some respondents stated that the development would make the “huge parking problem” worse, due to the ”increased number of cars, and the decrease in the number of car parking spaces.”

4.7.16. Parking: Almost all respondents felt that there would not be enough spaces in the car park if the development went ahead. There were concerns that the surrounding streets that are already subject to stress from commuters, and would get worse, specifically in neighbouring High Worple, despite being covered by a CPZ. Stronger CPZ controls had majority support of those surveyed. However, there was concern expressed in the comments that any increase in cyclists in the area may be dangerous and result in more injuries.

4.7.17. Height and density: A number of respondents to survey regard the proposals as too high, and that only 2-4 storeys would be acceptable, if any development was supported at all. One respondent stated that the proposals would “dominate the surrounding houses.” The plans were also viewed as overdevelopment in the area by some. There were a number of concerns about overlooking from High Worple residents. 30 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.7.18. Design: There were a less comments with regard to design, with the sentiment reflecting more of a balanced perspective. There was support for the architecture, the landscaping and the materials, with one respondent commenting that there was an ‘excellent choice of materials that fit the surroundings.’ However, there were a number of comments stating that the proposals were ‘out of character’ within the local area due to their scale.

4.7.19. Infrastructure and overcrowding: A general sentiment at Rayners Lane was the perceived strain on local infrastructure and services, with traffic, health services and local school places being the key topics. Many stated that these were either at capacity or incredibly stretched, and that no additional homes should be allowed without investment.

4.7.20. Step-free access: There were a number of comments stating that the scheme should also deliver step-free access to Rayners Lane station. This is not possible in this scheme. 31 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

4.8. Stakeholder meetings

4.8.1. The applicant has also held a significant number of meetings with local stakeholders, which are summarised below:

Purpose The purpose of the meetings was to give key stakeholders the opportunity to ask questions regarding the development and raise concerns with the project team.

Engagement We began a series of meetings with businesses, local organisations and key stakeholders around Rayners Lane in the summer of 2019. Since then, we have contacted the groups on multiple occasions, and held face to face meetings with two organisations in the local area. The applicant also met with Cllr Chloe Smith, Navin Shah AM, and Member of Parliament Gareth Thomas to discuss Rayners Lane station. The applicant presented to the Major Developments Panel at Harrow Council on 10 July 2019 and 19 November 2019. Organisations we have met with: • Harrow Nature Conservation Forum • Rayners Lane Traders Association These organisations were invited to both the first and second public exhibition, amongst others. The applicant will continue to discuss the proposals with key stakeholders and neighbours following submission.

4.8.2. Notes of meetings

4.8.3. Major Development Panel, 10/07/2019: The three Harrow Station Sites proposals were presented to the Major Development Panel at a relatively early stage in the design process. Conservative members expressed strong opposition to the principle of a reduction in station car parking and car-free development on these sites, stating it was unrealistic to expect car usage to shift to walking, cycling and public transport. There were a number of question about how car-free development could be enforced, and how new residents’ visitors would be accommodated. The height of the proposals was also criticised. There was support expressed by members for the affordable housing on offer and improved cycling facilities.

4.8.4. Cllr Chloe Smith, 06/09/2019: Cllr Smith accepted an offer to meet with the applicant at TfL’s offices in central London. Cllr Smith was broadly supportive of the scheme, adding that she is an advocate of car clubs, however there are issues about the number of people using them. She also wanted the development to be made family-friendly, recognising that the site is in the outer areas of London. Cllr Smith also mentioned that there are issues around services in Rayners Lane, specifically around the local Alexandra Avenue Clinic. Cllr Smith suggested incorporating a drop-off area of the station to reduce the negative impact of the reduction in car parking spaces.

4.8.5. Gareth Thomas MP, 16/09/2019: Gareth Thomas MP met with members of the project team in his constituency office in Harrow West. Mr Thomas expressed hope that local 32 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

people from the Rayners Lane area and wider Harrow would receive preference over the allocation of housing on the site, once completed. In addition, Mr Thomas advocated for the use of local labour to help build the development, if given planning consent. He also asked for the development to be as environmentally friendly as possible, with the inclusion of solar panels.

4.8.6. Harrow Nature Conservation Forum, 20/09/19: The Harrow Nature Conservation Forum suggested possible ideas about increasing the biodiversity of the vacant space in the railway sidings in between the station and the development. The HNCF suggested planting wildflowers in the sidings area, as well as general advice about encouraging bats and bird nesting.

4.8.7. Rayners Lane Traders’ Association, 25/09/2019: The applicant met with RLTA, who expressed concern about the reduction in parking. The Traders Association also discussed the resulting congestion on surrounding roads. RLTA wanted to make sure the private service road opposite the site entrance was protected from displaced commuter parking, an existing issue they felt would worsen. The Traders Association also wanted to have clear and coordinated communications during the construction phase of the development. The applicant agreed to meet with the Traders Association about proposals for the private road at a later date.

4.8.8. Major Development Panel, 19/11/2019: The three Harrow Station Sites proposals were presented to the Major Development Panel just prior to the second round of public exhibitions. Conservative members again expressed strong opposition to the principle of a reduction in station car parking and car-free development on these sites, stating that TfL should encourage parking at stations to prevent driving into central London and car-free would not work in a suburban location. Cllr Keith Ferry, the Regeneration and Planning Portfolio Holder at Harrow Council asked if it would be possible to access the platforms from the car park, therefore providing step-free access. Some councillors criticised the design of the buildings as unattractive.

4.8.9. Rayners Lane Traders’ Association, 08/01/2020: The applicant met once again with the Rayners Lane Traders Association, where the main discussion point was the prevention of unauthorised parking on the service road to the rear of the shops. The option of a gate was explored; however, no consensus was achieved by the traders. Regularly monitored CCTV was also mentioned, however this is not able to be used to enforce parking. Following the meeting, the RLTA sent over a formal proposal for the management of the service road, which is currently being reviewed and discussed. The applicant will continue to liaise with the Traders Association following submission of the application.

4.8.10. Gareth Thomas MP, 26/02/2020: Gareth Thomas MP met with members of the project team in Parliament to get an update on the proposals. He noted that some constituents had expressed concerns to him. He reiterated his desire for local sales prioritisation and for local labour to be used whenever possible if granted consent.

33 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

5. Key issues and responses

5.1.1. For full details of the design development process, and response to comments raised by Harrow Council and other statutory stakeholders please read this section in conjunction with the Design and Access Statement and Planning Statement.

5.1.2. The table below summarises the key issues raised during the course of the public consultation and meetings with stakeholders, alongside the applicant’s response in the submitted scheme:

Key Issue Response of the applicant

Principle of Much of the feedback disputed the need or appropriateness of development the site for housing-led redevelopment. The maintenance of commuter car parking at the current level, and not adding to the local population, were seen as the highest priority by the majority of respondents.

The site has been identified by Harrow Council as a suitable location for housing in their Site Allocations Document in 2013.

Housing There was a significant amount of opposition to new homes of whichever tenure. A number of attendees to the consultations and online stated that the local area was “overdeveloped” or “overpopulated”. This was often liked with comments that local infrastructure could not cope with additional residents, and many referenced general pre- existing concerns about a lack of GP’s or school places.

Those who placed affordable housing delivery as a high priority were significantly more likely to be supportive of the proposals as a whole.

There is a significant need for affordable housing within Harrow. Affordable housing tenures will be in line with the requirements set out by Harrow Council and GLA guidelines. The applicant has included a range of unit sizes and tenures in consultation with Harrow's housing team.

Properties will be marketed to Harrow residents first and it will also not be possible to buy-to-let while still in shared ownership.

A few comments we received indicated that the development would result in an increase in crime and anti-social behaviour in the local area due to the provision of homes at social rent. Catalyst will remain the long-term managers of the housing and has a long-track record as a social landlord. The scheme has been designed to achieve Secure by Design accreditation. 34 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Key Issue Response of the applicant

Reduction in There has been significant opposition to the proposed commuter car reduction in commuter car-parking by local residents and car parking park users on the online survey and at the public consultation events. They believe that there is already existing parking stress in the area, and that the proposals will lead to greater congestion and parking on neighbouring streets from commuters, specifically the adjacent High Worple. Many stated that the car park was “important” to their commute and did not regard alternatives such as walking, cycling or public transport as viable, even when their home was within a short distance of the station. 40% of car park users have a point of origin 2km or less from the station.

The applicant does recognise the need to balance the need for homes with appropriate amounts of car parking for commuters. As a result, 75 out of 251 parking spaces will be retained for station users. The car park does not often operate at capacity, studies by TfL illustrate that the maximum occupancy of the car park is between 35-65%.

As part of the development proposal, a new Station Cycle Hub will be provided with 82 spaces to mitigate the reduction in station car parking. Harrow is also making significant investment in wider cycling infrastructure.

The applicant is retaining an appropriate amount of commuter car parking given current policy. Additional detail is set out in the Transport Statement.

Car-free The majority of comments were sceptical of the viability of car- development and free development in a suburban location and stated that they residents’ parking did not believe new residents would go without a car regardless of the terms of their lease or lack of parking permit. Many local residents felt this would increase the parking stress on local roads, even with a CPZ already in place.

With regard to the proposed residential development, these will be car-free with the exception of disabled parking provision. All new residents, except those with a disabled permit (blue badge), would be unable to obtain an on-street parking permit. Catalyst, who will be managing the development on completion, will enforce this through their leases. A Car Club space (electric vehicle) will be included so that when residents do need a car, they can rent one affordably on their doorstep. Electric charging facilities will be provided for both the commuter and resident parking spaces.

Car-free developments are commonplace in areas of London with good public transport accessibility as a method to improve the built environment and encourage sustainable travel. They are also now the starting point for new development in locations with good connectivity. Rayners 35 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Key Issue Response of the applicant

Lane is served by four bus routes (H10, 396, H9 and H12), the Metropolitan Line and Piccadilly Line.

The proposal will be car-free with 3% active residential blue badge spaces and a retention of 75 commuter car parking spaces including 6 public blue badge spaces.

Parking The applicant has engaged extensively with the Rayners Lane displacement to Traders’ Association, who have concerns about displaced private service parking on a private service road opposite the site entrance. road There is already an existing issue with commuters and visitors unauthorised parking on the road, as well as incidents of fly tipping and other ASB, they feel a reduction in parking and new car-free development may worsen this.

This road cannot be covered by a CPZ as it is not adopted, and enforcement would have to be the responsibility of the freeholders or leaseholders. Discussions are ongoing about potential mitigations and will continue after submission.

Height and The proposed heights of the blocks at up to 6 storeys was Density raised as a concern by a number of respondents, including a newly formed group of High Worple residents, with concerns about overlooking and overshadowing. A detailed assessment of these issues is included in the planning application.

The architects have reduced in height by one storey the building closest to Rayners Lane station. In terms of overlooking the applicant has made sure that any perceived risks of overlooking will be minimised.

The applicant has been working closely with townscape and heritage consultants and believe this is a suitable scale and location. There are a number of key views towards the Listed station accompanying the application.

Design There were significantly fewer comments regarding the facades and materials choice, and those were more balanced or positive about the proposals. There was support for architecture, landscaping and the proposed materiality.

Materials that stand the test of time and have a relationship with the neighbouring context, in particular referencing the Grade II Listed station, have been selected within the proposals.

The architects, KCA, have drawn inspiration from Rayners Lane and the art deco station building, utilising a solid robust masonry materials palette with a dense engineering brick plinth, a warm red brick, complemented with highlighted precast concrete features. Glazed bricks and precast concrete 36 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Key Issue Response of the applicant

highlight communal entrances, while considered brickwork detailing in a variety of styles will add interest to the street facing facades. These proposals will complement the architectural character and history of the area as set out in the Heritage Statement and Design and Access Statement.

Congestion and A number of comments considered new residents and the traffic reduction in car parking would increase traffic and congestion. As part of the planning application, a Transport Assessment has been prepared to identify the travel demand by each mode of travel.

As the proposed residential developments will be car-free, and the level of station car parking will be reduced, the overall level of traffic on the local highway network should reduce substantially as set out in the Transport Statement.

Following comments around the junction off High Worple, being extremely busy and potentially dangerous, a raised table is proposed leading to a widened access to the site, incorporating more space for pedestrians and street trees.

Infrastructure A general sentiment across many of the comments was about the strain on local infrastructure and services, with traffic, health services and schools being key topics.

The applicant is liaising with the Council to identify where there is a shortfall and will continue to discuss this with them as they progress through the determination period.

However, development can only contribute one-off capital not solve long term revenue or recruitment issues.

A 100% affordable housing scheme should be seen as a significant investment in social infrastructure.

Step-free access There were a small number of comments calling for step-free access for Rayners Lane station to be incorporated into the plans. The location of the site does not make this possible to deliver. An indicative masterplan is included in the Design and Access statement for future development which could include step-free access. 37 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

6. Conclusion

Figure 9: Second public exhibition at Regent Independent College

6.1.1. In accordance with local and national guidelines, the applicant has undertaken a pre- application consultation process with local residents, schools, businesses, groups and political representatives. This process has been carried out alongside the formal pre- application meetings between the project team, the London Borough of Harrow and other statutory consultees.

6.1.2. The project team has been available to discuss the proposals with stakeholders, both in person and through various communication channels during the pre-application phase. The community engagement process has helped shape our proposals to ensure it complements the vision for the area and delivers on the wider policy goals of the Local Plan, Intend to Publish version of the draft London Plan (December 2019) and relevant section of the London Plan (2016, as amended).

6.1.3. The proposals for Rayners Lane station car park provide a unique opportunity to deliver 128 affordable homes to directly address the housing crisis in Harrow and London. These plans will also encourage more people to walk, cycle, and take public transport to help solve the challenges of climate change, poor air quality and inactivity.

6.1.4. The applicants’ vision for the site is to:

• Deliver 100% affordable homes to address London’s housing crisis, in a sustainable and well-connected location. This would include a mix of homes for London Affordable Rent and Shared Ownership. • Deliver high quality housing for families, couples, first-time buyers and individuals on low to average incomes who make a huge contribution to our city. 38 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

• Encourage people to use more sustainable and actives modes of transport. This includes walking, cycling and taking public transport to help solve the challenges of climate challenge, poor air quality and inactivity and meet the TfL 80% target for sustainable travel by 2041. • Provide 82 new secure commuter cycle hub spaces to encourage journeys by bike and future-proof the station for anticipated need in decades to come. • Retain 75 commuter car park spaces, an appropriate level in the context of policy and the detailed surveys of car park users. • Invest in high quality design, with architecture which respects and complements the predominant Metro-Land character of the area, the characteristics of the Conservation Area, and the setting of the Listed station building. • Provide landscaping and public realm improvements to make it safe, greener and more attractive for residents and those visiting Rayners Lane. 6.1.5. Two rounds of public consultation have taken place, with exhibitions held in July 2019 focusing on the principles of development, and in November 2019 on the detailed proposals for the site. 121 people attended the events including local residents, Rayners Lane commuters and car park users. The scheme website has seen significant interest and following publicity for the scheme it has seen 2,056 unique visits and 225 comments.

6.1.6. Comments from the London Borough of Harrow (LBH), the Design Review Panel (DRP), stakeholders and the public have all contributed to the submitted scheme and resulted in a number of changes. For example, there has been a reduction in height of the building closest to the station, additional public realm works on High Worple, alterations to the car park layout and revisions to the façade and materials to preserve neighbouring residents’ privacy.

6.1.7. Overall, the majority of comments from respondents were negative, with strongly divided views on parking and housing. There was significant opposition to the principle of development due to the reduction in parking at Rayners Lane Station and a number of respondents seemed concerned about the increase in the local population and a perception of overcrowding in the local area.

6.1.8. The majority of feedback we have received has been opposed the delivery of housing on this site or in some cases affordable housing in particular. In addition, some local residents, particularly in the adjacent High Worple, have expressed concern about the height and density of the plans, as ‘not in keeping’ with the suburban nature of the area.

6.1.9. There has been support for the principle of providing affordable housing and the introduction of secure cycle spaces, encouraging commuters to take more active modes of transport. Supportive comments often referenced the housing crisis and climate emergency as key challenges. The architecture has been generally well received, with objections generally to the scale of the buildings rather than the façade design and materials.

6.1.10. The scheme addresses the Mayor of London and the London Borough of Harrow’s aim to deliver more affordable housing in the borough, in sustainable, well-connected locations, as set out in detail in the Planning Statement.

6.1.11. The Mayor’s Transport Strategy sets a target of 80% of journeys on foot, by bicycle or by public transport, by 2041. Furthermore, the Intend to Publish version of the London 39 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Plan (December 2019) also requires all redevelopment to reduce parking and consider car-free as a starting point, especially when a site is so close to a transport hub.

6.1.12. There is a significant divergence between the majority view expressed in the public consultation and the clear direction of national, London, and borough policy in relation to this scheme. Making the best use of well-connected sites to optimise the delivery of affordable housing is central to the draft London Plan.

Figure 10: View of the proposed Block D, community garden and play space

6.1.13. The applicant has undertaken a comprehensive and transparent pre-application consultation with the local community, in line with both guidance and best practice. Where possible, and when not in contravention of the core purpose of the scheme and policy, changes have been made to the scheme to resolve specific concerns.

6.1.14. The applicant has submitted proposals which will directly benefit the borough and local community by providing 128 high-quality 100% affordable homes, in a sustainable location, and fulfilled the requirements of both the Local Plan, the Intend to Publish version of the draft London Plan (December 2019) and relevant aspects of the adopted London Plan (2016, as amended). Harrow Station Sites. Rayners Lane

APPENDICES 41 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendices

Appendix 1: Publicity flyer for July 2019 public exhibition ...... 41 Appendix 2: Advert featured in the 11 July 2019 Harrow Times ...... 43 Appendix 3: Site poster (July 2019) ...... 44 Appendix 4: Public exhibition boards (July 2019) ...... 45 Appendix 5: Survey (July 2019) ...... 54 Appendix 6: Publicity flyer for November 2019 public exhibition ...... 58 Appendix 7: Advert featured in the 7 November 2019 Harrow Times ...... 59 Appendix 8: Site poster (November 2019) ...... 60 Appendix 9: Public exhibition boards (November 2019) ...... 61 Appendix 10: Survey (November 2019) ...... 70 Appendix 11: Map showing approximate location of respondents to surveys .. 74

42 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 1: Publicity flyer for July 2019 public exhibition

43 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 2: Advert featured in the 11 July Harrow Times

37 July 11, 2019 harrowtimes.co.uk FREETIME

Summer gins to drink right now he world has gone a bit nuts The results of a new social- multitude of new concoctions out for gin. listening survey by Whitley Neill just in time for summer - here are It appeared to reach fever Gin have revealed our favourite some of our favourites... Tpitch a couple of years ago, tipple was tagged 8.4 million times 1. Hendrick’s Midsummer when all manner of gin festivals on Twitter last year. It was more Solstice Gin (limited edition), 70cl, started springing up, new flavours talked about than David Beckham currently reduced to £30 from £35), began appearing on supermarket (mentioned 1.9 million times, in Sainsbury’s shelves everywhere, and no kitchen case you were wondering), The 2. Sipsmith Orange & Cacao Gin, was complete without a couple of Beatles and Wimbledon. 50cl, currently reduced to £22 from balloon glasses for when gin o’clock Sales are continuing to rise, too. £25, Tesco rolled around. According to the Wine And Spirit 3. Hayman’s Gin Liqueur, 70cl, But since then, the spirit has Trade Association, Brits bought £28.95, Master of Malt continued to soar. And now, new almost 60 million bottles of gin in 4. Kokoro Blueberry & research has found that over the 2018, up 38% on the year before. Lemongrass Gin, 20cl, £12.50, last 12 months, gin was mentioned “Gin has officially established kokorogin.com every four seconds on social media. itself in the British consciousness 5. Hyke Gin, 50cl, £24, Tesco We might just be obsessed. and around the world,” says Leanne 6. Stranger & Sons Gin, 70cl, Ware, senior marketing manager at £34.95, Master of Malt Whitley Neill Gin. There’s been a 7. Dingle Original Gin, 70cl, clear shift towards flavoured gins £34.99, ginspiration.uk too, which are creating an 8. Marylebone Orange & incredible amount of conversation Geranium Gin, 50cl, £25, online, she says. Sainsbury’s “The data tells us that ‘gin o’clock’ 9. Kopparberg Premium Gin is now a global movement. There’s a Mixed Fruit, 70cl, £20, Asda dedicated moment in each day 10. City of London Six Bells whereby people enjoy a gin. It shows Lemon Gin, 70cl, £34.95, Master of that in the UK, gin is a firm British Malt icon.” 11. Whitley Neill Pink Grapefruit Stuart Ekins from Gin Mare Gin, 70cl, £20, Asda agrees. “We are clearly in love with 12. Liverpool Rose Petal Gin, 70cl, gin as a nation and the boom doesn’t £40.99, ginspiration.uk seem to be slowing down any time 13. Adnams Limited Edition soon. Be adventurous and bring out Lemon and Tamarind Gin, 70cl, the botanicals you like best by £29.99, adnams.co.uk adding fresh fruit or herbs.” 14. Tanqueray Flor de Sevilla So, what better way to celebrate Distilled Gin & Tonic, £8 for four than with yet another gin? There’s a 275ml bottles, Asda

44 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 3: Site poster (July 2019)

45 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 4: Public exhibition boards (July 2019) 46 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

47 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

48 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

49 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

50 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

51 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

52 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

53 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

54 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 5: Survey (July 2019)

55 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

56 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

57 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

58 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 6: Publicity flyer for November 2019 public exhibition

59 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 7: Advert featured in the 11 July Harrow Times

Web banner:

60 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 8: Site poster (November 2019)

61 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 9: Public exhibition boards (November 2019) 62 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

63 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

64 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

65 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

66 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

67 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

68 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

69 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

70 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 10: Survey (November 2019)

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72 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

73 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

74 | Statement of Community Involvement – Rayners Lane Station Car Park 5 High Worple, Rayners Lane, HA2 9SJ

Appendix 11: Map showing approximate location of respondents to surveys

Harrow Station Sites. Rayners Lane