Guest blog by Philip Grant, in a personal capacity.
If you have read my guest blogs on Brent Council’s planning application 20/0345, you may have missed two recent comments. I will set these out below, for ease of reference, as well as drawing attention to some interesting flaws in the “public benefits” of the proposals (supposed to justify demolition), that have emerged from recent “consultee comments” I have now seen.
1.The Victorian villa at 1 Morland Gardens, with 2 Morland Gardens beyond, from the top of Hillside.
I have added this comment to my How significant is significance? blog of 25 June:
I have now received a copy of the consultee comments by Brent's Principal Heritage Officer, on the Heritage Impact Assessment and other evidence submitted since his original comments in April 2020.
I can imagine that he was under pressure from those at the Council promoting this application to confirm the HIA assessment that 1 Morland Gardens is a heritage asset of "low significance".
He has resisted reducing the building's score from 8 out of 12 (although from his reference's to the architect, H.E. Kendall Jnr., I suspect he would have liked to increase the architecture score to 3 out of 3, but has also resisted doing that). Despite keeping the same score, he has changed his original significance description from "high" to "medium".
Here are the Principal Heritage Officer's comments of 29 July 2020 on significance:
'1 Morland Gardens is a Locally Listed Building [a non-designated heritage asset] but not in a conservation area nor a statutory listed building. The local list description confirms and sets out its significance. It has a significance score of 8 out of 12. This actually places the building at ‘medium’ significance rather than of high significance as I stated in my initial advice.
National Planning Guidance, Historic environment, paragraph 8 states that an ‘Analysis of relevant information can generate a clear understanding of the affected asset, the heritage interests represented in it, and their relative importance.’ I have therefore considered the Heritage Impact Assessment (HIA) report by Lichfields submitted by the applicants and comments made by other consultees such as the Victorian Society and those with a special interest. I have thus taken into account the available evidence and necessary expertise [National Planning Policy Framework para.190].
The HIA asserts that ‘according to Brent’s local listing criteria the following score is more appropriate to the building: 6/12, due to the authenticity of the building being affected by its 20th century alteration and extension and the lack of its surviving historic context.’ It has been given ‘low significance’. I have looked closely at the reasoning and I do not share the view on the determination that was made.
I am persuaded by Anthony Geraghty MA PhD, Professor of the History of Architecture at the University of York. He rates Henry Edward Kendall Jr. as ‘an architect of considerable importance whose nineteenth century villa characterises work by an architect of genuine and lasting significance.’ This is supported by the Victorian Society who make the point that the Stonebridge Park Estate was a development by a Victorian ‘architect of note’ and a ‘good
surviving example of a key aspect of Kendall's small, domestic works’.
surviving example of a key aspect of Kendall's small, domestic works’.
It is clear to me that 1 Morland Gardens should be considered a local heritage asset of special interest. There are only 2 of this belvedere towered design left in Brent. There are many examples of Italianate origin seen in the Borough (throughout the South Kilburn Conservation Area, for example) but these are by speculative builders and not by a significant architect like Kendall.
With this in mind, I am firmly of the view that the building is of ‘medium’ significance with a score of 8 out of 12 as none of the evidence provided introduces anything much new.'
2.Elevation drawing from the plans submitted in February 2020.
I added this comment to my Why Brent should withdraw its application to demolish 1 Morland Gardens blog of 20 July:
This morning I received (from "The Office of the Leader") a letter from Amar Dave (Strategic Director, Regeneration and Environment), in reply to my open email of 19 July, on behalf of Brent Council as applicant in this case (20/0345). He replied to all the points I had raised, and I will summarise his long letter below.
He said that the architectural and historic significance of the Victorian villa had been understood at an early stage of the planning process, saying: 'The assessment was reviewed by planners following submission and we were informed that it was a very thorough assessment of the condition of the historic building.' - My response to this would be that if their assessment had demonstrated a proper understanding of the building's significance, they would not have been asked to provide one, several months after their original application was submitted!
He did not agree my assertion that 65 homes, a new education centre and affordable workspace was an overdevelopment of this small site, saying: 'Further, the results of our option appraisal and public consultation within the locality showed significant need for these facilities in Stonebridge.'
In response to my assertion that the "low significance" assessment was false, he said: 'This report provided an independent assessment of the significance of the locally listed building.' He also said: 'The validity of the HIA has been confirmed by the Planning Officers.' - My response would be that, despite what the Planning officers might have said, the Council's Principal Heritage Officer has rejected the HIA's claim that the significance score should be reduced from 8 out of 12 to only 6 out of 12.
In response to my question of whether the Officers and councillors proposing this scheme 'really intend to use the HIA, seeking to deceive Brent’s planning committee into approving a planning application which they should really reject?’ Mr Dave has said: 'The HIA is part of the suite of planning documents to be assessed by officers, and considered by the Planning Committee. This will include in the report the assessment of the Council’s own Principal Heritage Officer. The Committee will be able to come to their own judgement on the significance of the building, and will balance this against all other aspects of the scheme.'
He has also said: 'We do not accept your assertion that a decision as either landowner, or as a planning authority, to agree this scheme would put "every other heritage asset in Brent at risk of demolition".'
The Council does not intend to withdraw its planning application.
3.Revised ground floor plan for 1 Morland Gardens, submitted June 2020.
I wrote in my Brent Relents! blog recently that the Council had agreed to change its practice of not making “consultee comments” on planning applications publicly available on its website. Those comments can be really valuable in identifying weaknesses in applications that affect you, and it’s not only the Heritage Officer’s comments that are of interest on this application.
Transport and access: The original plans included a loading bay, for deliveries and refuse collection, as a lay-by on Hillside, but both TfL and the Council’s Transportation Unit said this was unacceptable, because of the danger it would cause to pedestrians. The loading bay has now been moved to the end of Morland Gardens (a cul-de-sac), taking a bite out of the “Arrival Garden” at the entrance to the new adult education college. More of that garden’s paved area has been lost because the GLA objected to the lack of visitor cycle parking.
The loading bay will be the only place where deliveries can be made to the entire proposed development, and is reached along a minor side road with parking spaces on both sides. The latest comments from the Transportation Unit still have concerns about access and servicing of the building. ‘This servicing area will be convenient for the relocated refuse store and the college, but less so for the lower ground floor workspace’. The answer suggested is that: ‘… to ensure the loading area does not become congested, a Delivery and Servicing Management Plan is sought as a condition of any approval.’
That suggested plan (‘to be approved before the building is occupied’) just covers the college and the affordable workspace on the lower floors. What about deliveries to the 65 homes on the upper floors? Given experience during the Covid-19 lockdown, and the growing switch to online shopping, the people living in those homes are likely to need many deliveries as well. It is 50 metres from the loading bay to the entrance door for the tall block of flats, and over 100 metres to the entrance of the homes further down Hillside. Each trip by a delivery driver will take a long time, so where will the other delivery vans or lorries park while waiting for their turn? And can you imagine the nightmare when 65 families are moving into their new homes?
One of the factors causing more deliveries will be that the new homes will be “car free” – no parking spaces (except for disabled) and no permits allowed for street parking. In reality, many residents will have cars (the planning estimate is around 58, based on data for the number and mix of units). What is the answer to this problem? A familiar one to those who have seen previous planning cases – a Section 106 agreement for ‘a financial contribution of £32,500 towards the introduction of a year-round Controlled Parking Zone in the vicinity of the site’!
4.A view of the site - taken from a Google maps 3D satellite image.
Environmental: If you compare the “Google” view with the new ground floor plan above, you will see that the proposed new building comes much closer to Brentfield Road and Hillside than the existing building. The 1994 Harlesden City Challenge garden (which Brent’s application describes as neglected – well, whose fault is that!), and the wide pavement area behind it will be built over, with a much smaller “Arrival Garden” in front of the college entrance instead. In spite of this, the Council’s proposals are claimed to provide ‘improved public realm’.
The latest Stage 1 comments from the GLA point out that the new plans only deliver an “Urban Greening Factor” of 0.2, which falls well short of the target of 0.4, saying: ‘The applicant should therefore seek to improve the quantity and quality of urban greening across the site.’ They also point to the continuing lack of an ecological statement, outlining the impact of the development on different species, and measures to provide a biodiversity gain, in line with London and National planning policies.
Air quality also has a “red flag” against it in the GLA’s comments. 1 Morland Gardens is in an Air Quality Management Area, next to one of the poorest air quality sites in Brent, at the junction of Hillside and Brentfield Road. The ’baseline local air quality’ is poor. The development needs to deliver an Air Quality Neutral assessment for both building and transport emissions, and the GLA are not satisfied that it does. It is already clear from the application’s own assessment that the Nitrogen Dioxide levels would be too high to allow windows to be opened on the ground floor (college) and the next two floors (of homes) above!
Although the plans will provide a one metre wider pavement along Hillside, instead of a low wall then open space, the pavement will be flanked by the building itself (see elevation drawing above). Fumes from the passing traffic will be trapped, and instead of the curving wall and wide pavement turning into Morland Gardens, pedestrians (including students arriving on the No. 18 bus to the Hillside Hub stop) will need to walk up to within 5 metres of the busy junction.
Water: Thames Water have pointed out that the revised plans submitted do nothing to answer objections to the proposals which they made in March. ‘Thames Water has identified an inability of the existing SURFACE WATER infrastructure to accommodate the needs of this development proposal.’ In other words, the increased rainwater run-off would be too much for the local drains, and if no action is taken to address this, a heavy storm (more likely with Climate Change) could cause water to flood down Hillside! They want a condition added that no properties should be occupied until ‘all surface water network upgrades required to accommodate the additional flows from the development have been completed.’ The developer (the Council) would have to pay for those upgrades.
The second objection from March that had still not been dealt with by 6 July was: ‘The proposed development is located within 5m of a strategic water main. Thames Water do NOT permit the building over or construction within 5m, of strategic water mains.’ By taking so much of the site (and adjoining public realm) for the new building, the Council have caused this problem. If they don’t make its “footprint” smaller, the main drinking water supply pipe for this area will have to be moved further out under the highway, at the Council’s expense, before any construction on the site can begin. Imagine the traffic chaos on Hillside / Brentfield Road that will cause!
The Planning Committee on August 12th starts at 6pm (following a pre-meeting at 5pm) and after the preliminaries of declarations of interest and approaches, 1 Morland Gardens is the first item. The proceedings can be viewed live via a link to the Webcast on the Agenda here: http://democracy.brent.gov.uk/ieListDocuments.aspx?CId=115&MId=6107
'Former Victorian building at Craven Park - see Binali's comment below.'
I have just had a first look at the Planning Officer Report for the meeting on 12 August.
At least they admit this in their conclusion:
'Section 38(6) of the Town and Country Planning Act states that the determination of any planning application must be made in accordance with the development plan unless material considerations indicate otherwise. Officers acknowledge that the proposal would involve the loss of a locally listed building, resulting in the total loss of its significance and would therefore be contrary to Policy DMP7 of the Local Plan, and London Plan policy 7.8. It must therefore be concluded that the application does not accord with the
They then go on to say:
'... there would very significant public benefits, most notably the social, economic and environmental public benefits delivered by the proposed scheme,
which include the provision of a much improved adult education facility and the creation of 65 affordable dwellings, including larger family homes, for which there is an acute need in the borough. Those social and economic benefits are in the view of Officers sufficient significantly to outweigh the harm caused by the loss of the heritage asset.'
This really is a test case for Brent v. Heritage!
I have been sent this comment, by a person I know to be a Council employee:
'I do hope you will succeed at the Committee meeting, although given the fact that the applicant is Brent Council, I am not being too optimistic. But as I pass this site every day on my way to work, I am quite fond of the building, and can’t even imagine it would be demolished, even though its historical and architectural value is beyond any doubt.'
This comment was received yesterday, by email from Binali. Hopefully, Martin can add the image she sent at the end of the blog above:
'Thank you Philip for the updates and your work on this.
I remember feeling a sense of loss when this building a few metres down on the island on Craven Park was demolished a decade or so ago. Its position on the island made the building more difficult (and dangerous) for pedestrians to access, so limited its potential uses had it been saved from demolition. I am not sure who owned it or the land. Still disappointing to have seen it go, along with a little bit more of the architectural heritage of the area. I hope 1 Morland Gardens can be saved.'
I would not want "Wembley Matters" readers to think that there is only one side of the argument (in favour of Heritage) in this planning application.
After months of only objection comments (from around 50 different people or organisations), there have been two recently that support the application. This is the most recent (7 August):-
'I am writing to reiterate my support for the Morland Gardens scheme, which I now see as an essential step towards invigorating the local community by providing meaningful opportunities to live, learn and and work sustainably.
The approval of the scheme will also create the space for continued, and much needed community engagement. The recent social and political upheaval (nationally and globally) highlights the need for communities to come together to play an active role in determining positive outcomes for individuals and families (present and future). While the scheme is not a direct response to what is currently happening either nationally, or globally, the context in which the scheme will develop and emerge cannot be denied.
In providing real hope, and genuine opportunities for people to access affordable housing, specialist skills training, and custom-built work spaces, the scheme will undoubtedly play a key role in supporting a community that has shown an incredible resilience for some time, and are equally deserving of the chance to thrive and grow as those who inhabit other areas of the borough.'
The address given for the person submitting this comment is:
2nd Floor, 89-93 High Street, Harlesden, London, NW10 4NX
This appears to be the business address of Bang Edutainment Ltd, which hopes to use the workspace in the proposed new building for some of its activities, and has a representative, Errol Donald, on the Community Stakeholder Steering Group for the Council's 1 Morland Gardens project.
What next? Council officers behind the scheme sending comments in favor from their home address?
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