SCHEDULE OF MAIN MODIFICATIONS OF DRAFT BRENT LOCAL PLAN SUBMITTED FOR EXAMINATION IN MARCH 2020 LONDON BOROUGH OF BRENT This schedule contains all main modifications to Brent Local Plan to submission version for public consultation, which the Inspectors examining the Plan consider necessary for soundness. All proposed modifications and their reference numbers supersede all previous versions proposed by the Council during the examination process. The following format has been used to denote the modifications: Underlined bold text = new text proposed for policy compared to submission version Strikethrough text = text proposed for removal compared to submission version Underline text = new text proposed for justification text compared to submission version Main Modifications Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section MM1 2 Introduction Paras 2.14 – Layout of the Brent Local Plan Amend text to update 2.17 position on London Plan 2.14 As indicated earlier, the London Plan contains many detailed adoption. strategic policies that are also intended for development management purposes. The Greater London Authority considered that this would Additional paragraph to be helpful so that councils can concentrate on locally specific issues clarify the Council’s which differentiate their areas from others. The National Planning approach to making Policy Framework (NPPF) and draft London Plan both emphasise that explicit the strategic and there is no need for Local Plans to repeat their policies. The Local Plan non-strategic policies therefore follows this advice where it is considered national or London within the Local Plan, as policy provides sufficient policy detail. The Brent Local Plan should be required by the seen as complementary to be read in conjunction with the London Framework. Plan, NPPF, National Planning Practice Guidance and London Plan Supplementary Planning Guidance documents. The NPPF (paragraph 21) requires local planning authorities to make explicit which policies are strategic in their Local Plan. Accordingly, the Council has used the criteria provided in the NPPF to assess the policies and site allocations contained within the draft Brent Local Plan. The outcome of this assessment is set out in Table 1 of Appendix 6 of this Plan with the assessment, criteria and conclusions shown within Table 2 of the Appendix. Where a policy was considered to meet at least one of the NPPF criteria, it was determined to be a strategic policy. 2.15 As a result, such the structure of the Brent Local Plan is such that it obviously complements the Good Growth Policies and chapters 2 BRENT LOCAL PLAN PROPOSED MAIN MODIFICATIONS Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section of the London Plan. This is shown in Figure 4. The Plan has a brief overview of Brent’s characteristics, identifying some of the challenges and opportunities. This sets the scene for the following Spatial Vision for Brent, identifying locally specific examples of how the Good Growth Policies will be delivered in Brent either across the borough or through specific areas/ sites. In recognition of the fact that the borough is not homogenous but is made up of a series of smaller places, the Plan splits the borough up and focuses on 7 ‘Places’. The extent of these Places is loosely based on a scale that is likely to be more locally relevant taking account of a mixture of town centres that exert an influence within them, plus their character and clearly defined physical features which might effectively separate them from other identified Places. 2.16 For each of these Places there is an overview of matters such as physical features that define its boundary, a high level analysis of its current attributes, such as town centres, culture and character, transport, employment and education. The challenges and opportunities of the Place are set out. This helps inform a vision for the Place and then the Policy for matters such as culture and character, transport, employment and education, and town centres. In addition, key Site Allocations are set out. 2.17 The Plan then sets out a general position statement in relation to new development in the borough, before using the same chapter headings as the draft London Plan to set out locally specific Brent policies on these matters. 3 BRENT LOCAL PLAN PROPOSED MAIN MODIFICATIONS Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section MM2 3 Brent 3.17, page 20 Amend sentence of para 3.17 to read: To ensure plan Characteristics accurately reflects the However, to support new residential development, current projections planned provision. indicate a new primary school will be required in Wembley Park by 2023. There are however projected shortages of space for secondary pupils which will require provision of the equivalent of two additional secondary schools by 2023/24. 3 Brent 3.19, page 21 Amend latter part of para 3.19 to read: To ensure the plan Characteristics accurately reflects the In terms of indoor sports facilities, the Council's Indoor Sports and evidence base. Leisure Needs Assessment identified provision is significantly below needs. Swimming pools are between ¼-½ of the provision per head of population in adjacent boroughs10. There is also the need for additional sports halls. The Council's Playing Pitch assessment identified that for some sports, additional pitches are required. 3 Brent 3.32, page 25 Amend last part of para 3.32 to read: To provide greater Characteristics clarity on impacts of It however is severely congested at peaks times. It has significant ULEZ on air quality. adverse impacts on communities in terms of severance, pollution and noise. Its will be used as the boundary of the extended Ultra-Low Emissions Zone (ULEZ) to be introduced in 2021 is unclear in terms potential changes on these adverse impacts. Transport for London predict that the ULEZ 2021 will reduce air pollution in Brent by NO2 by 36%, with greater reductions within the ULEZ and lower reductions on and north of the North Circular. 4 BRENT LOCAL PLAN PROPOSED MAIN MODIFICATIONS Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section MM3 4 Development How Will Good Amend to read: Correct numbering to Vision and Growth In Brent allow better referencing. Good Growth in be Delivered?, Brent page 28-29 How will Good Growth in Brent Be Delivered? Relate to the Plan’s 4.1 4.37 The London Plan includes six Good Growth Policies Objectives vision, provide that set out the fundamentals on which development in London consistency with London should deliver. In Brent highlights of how these will be addressed Plan, reflect up-to-date in relation to places and subject chapters in supporting delivering housing trajectory, the development vision and good growth are: provide reference to Policy BH2/ BD2 /BT1 /BGI1 /BSUI1, recognise 1. Strong & Inclusive Communities the importance of a) Reduce spatial inequalities within Brent and incidences indoor and outdoor of areas with high levels of multiple deprivation by sports facilities and promoting mixed and balanced communities improving air quality, particularly around Wembley, Stonebridge, Harlesden, reflect industrial land Neasden and South Kilburn and on council housing evidence base, reflect estates retail and leisure needs b) Building on Brent’s status as London Borough of evidence, reflect the Culture 2020 by supporting inclusive places, where need for affordable ethnic diversity is celebrated and recognised, and space. places where cultural activities are already concentrated, e.g. Wembley, Cricklewood and Kilburn High Road c) Create a more equal and affordable borough, where the opportunities to access good quality housing, employment, education, digital connectivity and culture are maximised 5 BRENT LOCAL PLAN PROPOSED MAIN MODIFICATIONS Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section d) Strengthen the existing sense of community by celebrating Brent’s diversity, heritage and culture, and creating places where Brent’s community can meet e) Ensuring the delivery of a wide range of essential social infrastructures in Growth Areas and across the Brent to support the delivery of sustainable communities 2. Making the best use of land a) Prioritising the majority of residential development in new and more efficiently and intensively developed Growth Areas such including Northwick Park, Staples Corner and Neasden Stations and continuing to deliver in those that have already been started, such as in Alperton, Burnt Oak/ Colindale, Church End, South Kilburn and Wembley to enhance environmental quality, and bring benefits to the community; b) Supporting higher density development in Brent’s town centres, Intensification Corridors and in areas with good accessibility to public transport, c) encouraging greater access, recreational use and also understanding of ecology in Brent’s extensive areas of open spaces, such as the Welsh Harp and Fryent Country Park d) Identifying appropriate areas for tall buildings and change that add quality to and complement Brent’s character and sense of place 3. Creating a Healthy Borough 6 BRENT LOCAL PLAN PROPOSED MAIN MODIFICATIONS Modification Chapter/Policy Paragraph Modification Proposed Reason for Number Number Number or Modification Section a) Using the