A guest Post by Philip Grant
I was delighted to see, earlier this month, that the York House car park site could be used for a new youth centre, rather than a primary school. When I read the report to Brent’s Cabinet meeting, alarm bells started ringing. The Department for Education may have cancelled the ill-conceived Ark Somerville Primary Free School project, but the Wembley Park redevelopment area will still need a new primary school, by 2028 on the latest projections. Where would that be built?
NOT the Wembley Park Primary School, but hopefully something like it! (Image from the internet)
It has been known since the early 2000s that the large number of homes Quintain planned to build at Wembley Park meant that a new primary school would be required to serve the area. Brent agreed that the early stages of the development, around the Arena, should be mainly smaller homes, with the majority of the family-sized accommodation provided to the east of Olympic Way in the later phases.
Brent’s land use policy for the North East Lands. (Wembley Masterplan, 2009)
When the Council adopted its Wembley Masterplan in 2009, the “North East Lands” area (ringed in red on the map above) was identified as a primary school location (or one of them, if two smaller primary schools were to be built to meet growing demand for places during the course of the next 20 years, to 2030). This would put the school close to the main residential area, and next to a new park which was to be provided as part of the development.
That choice of location was carried forward into the Wembley Area Action Plan (“WAAP” – yes, that again!), adopted by the Council in 2015, which is still the current planning policy document for this area. The WAAP’s policy on school places emphasised the importance of securing sites for new schools, where large developments meant an increase in population. It also said that primary schools ‘need to be located directly within the area of population growth’, and that ‘nursery facilities … could be combined with other new … primary school facilities.’
The WAAP policy WEM 29, on Community Facilities, stated that ‘the council will … secure at least four forms of entry at primary level, to be secured on development sites within the Wembley area’. It also noted the ‘provision of one site in site proposal W 18.’ This site proposal covered the 4.9 hectare Wembley Retail Park, also known as the North East Lands, and said that ‘a new primary school will be provided’ on that site.
All very good - so what changed? At the end of 2015, Quintain submitted a huge “hybrid” planning application. It included detailed plans for a multi-storey car and coach park to the east of Wembley Stadium, and outline proposals for most of the rest of the land at Wembley Park which it had still to develop. Application 15/5550 has been called the Wembley Park Masterplan, but it was Quintain’s masterplan, not Brent’s.
The application (over 300 documents and plans) was one of a number considered at a Planning Committee meeting on 11 May 2016, just two days after the previous meeting. Most of the objections and discussions were about the car and coach park. The meeting went on for over four hours, and two of the committee members had gone home before it was approved by 4 votes to 1, with one abstention!
Among the outline proposals approved (with little or no discussion) was that the primary school site should be moved to the York House car park. Two sentences from the report by Planning Officers to the committee sum up how this was allowed to happen, despite it going against Brent’s adopted policy for the school’s location:
‘This plot has been identified by the applicant as an appropriate location for a 3 form of entry primary school and nursery.’
‘The proposal delivers the same strategic objective (the provision of nursery and primary school places) and is considered to be acceptable in principle.’
A cynic might suggest that the applicant, Quintain, had identified the York House car park site for commercial reasons, not valid planning reasons, so that it could build tall blocks of flats on the North East plot(s) which would otherwise be used for a primary school site.
But it was only an outline planning consent for the York House site, wasn’t it? When the detailed planning application for the school went before the Committee on 6 June 2018, members were given strict instructions by a Planning Officer. They were not allowed to consider whether the new school to serve the Wembley Park redevelopment should be sited elsewhere, the Officer Report saying:
‘the parameters material submitted with the application [15/5550] specifically identified the subject site (known as Development Zone YH1) for a 3FE Primary School and associated Nursery.’ and:
‘This reserved matters application is considered to be in material compliance with the parameters and principles established under the outline consent.’
Only one committee member voted against the application (here’s a reminder, if you don’t remember what happened to him!). Air pollution had been raised as a major problem with this site for a primary school, with dangerously high NO2 levels along Wembley Hill Road admitted in the application’s Air Quality Assessment. No account was taken of the effect on young children who would be walking to the school. In respect of the school building itself, Officers said that mitigation measures would be included in the conditions for the planning consent. These were having no opening windows on that side of the school below a height of 4.5 metres, and that the air intakes for artificial air circulation must be situated above that height.
Following that decision, the York House car park site was bought from Quintain by the DfE’s Education Funding Agency, for provision of the Ark primary school. Because of the number of increased primary places provided by Brent at other existing schools, and a slight (temporary?) fall in demand for places, the DfE have now dropped the York House school project. Which brings me back to my opening question – where will the Wembley Park primary school that Brent will need, within the next 5 to 10 years, be built?
After the 2016 “Wembley Park Masterplan” decision, Brent’s planning policy, in its emerging Local Plan, has depended on the York House school site. The North East Lands are currently the subject of Quintain’s detailed planning application, 20/2844, which would see tall blocks of flats built around three sides of the northern section of the new park.
Something had to be done, so I have started the ball rolling! I researched the labyrinth of planning application details and planning policy documents involved, and have submitted detailed objection comments on application 20/2844. These set out why the application, which is listed as a variation of conditions under the 15/5550 application, can and should be amended to provide a reserved site for a 3-form entry primary school, and nursery (and should be refused if it does not make that change). I am hoping that Martin can add a copy of my comments document at the end of this article, so that anyone who is interested can read them.
As well as sending my document to Brent’s Planning Officers, I have also sent it with covering emails to the Lead Members and Strategic Directors for Regeneration and for Schools, and to the councillors for Tokyngton Ward, to ensure that Brent is fully aware of its risk of having no site for the new primary school it has a duty to provide by 2028. And as this is a matter which would best be settled by agreement between Brent Council and Quintain, I have also sent a copy to the developer’s Head of Masterplanning and Design, and Head of Planning.
I have done what I can, but this is a matter of concern which present and potential future residents of Brent, and Wembley Park in particular, and those with an interest in education in the borough, need to be aware of. Action needs to be taken on this issue now, but I am just one “voice” (or laptop keyboard, during lockdown). If you agree with me, please make your views known by objecting to planning application 20/2844, or contacting an appropriate councillor or Council Officer. Thank you.
Philip Grant.
Philip's comments - click bottow right corner for full page version
It almost makes you think that the new developments in Wembley Park WON'T be family housing.
ReplyDeleteAs always Mo wil do what Mo wants
ReplyDeleteI would hope that "Mo" will want to ensure that children and their families, in part of what is currently his Tokyngton Ward, will have a good Primary School and Nursery close to their new homes, and next to a small park, when they need them in a few years time. Wouldn't you?
ReplyDeleteIn response to your point on family housing, Martin, I'm afraid that I can't give you any figures on the total number of homes proposed, and what the split between various sizes will be.
ReplyDeleteThe Brent planning pages for application 20/2844 say there are 309 documents, but many of the original September 2020 documents seem to have gone when some revised plans and documents were submitted in December.
All I can say is that what is now proposed will be taller and cover a greater area of the site (by expanding the boundaries of some of the six plots) than the outline proposals which Brent consented to in 2016 under application 15/5550!
The justification given for this in the latest Design & Access Statement is that their 2020 application is: 'a response to the evolving context of the wider Wembley area, and allows the delivery of a greater number of homes, both private and affordable.'
In plain English - because Brent planners have recommended as "acceptable" a string of applications in recent years which allow blocks higher and higher than those set out in adopted planning policies, in order to prioritise the number of new homes, this application should be accepted too!
FOR THE RECORD:-
ReplyDeleteI did not get any feedback from Brent's Children & Young People's Department (or Lead Member for Education) before the North East Lands planning application was listed for the 10 March Planning Committee meeting.
The Planning Officers Report to the committee virtually disregarded my detailed objection comments. I submitted the following objection comment against ref. 20/2844 on 3 March:
'The Officer Report for the Planning Committee meeting on 10 March does not properly deal with the points raised in my detailed comments of 25 to 28 January 2021, over the need for a site for a primary school to be reserved on the North East Lands covered by this application.
The summary of my objection in the Report is just this:
'The new plans should include a new primary school as this is no longer likely to be accommodated on the York House car park site (plot YH1).'
That ignores some of the key points listed in the conclusions to my original comments, particularly the material considerations (which only came to light in January 2021, after application 20/2844 and the amendments to it had been made).
In a report to Brent's Cabinet on 12 January 2021, it was clearly stated, in respect of the proposed primary school on the York House car park site that: 'the DfE has now cancelled the project.'
Just because no new planning application for that site, changing its use from the school plans approved under application 18/0204, does not change the fact that the Primary School required under the Masterplan will not now be built there.
What is likely to make use of that site is another much-needed piece of social infrastructure for the whole Wembley area, a youth centre. The report to the 12 January Cabinet meeting stated:
'It has been confirmed to the DfE that the Council has identified potential options for the use of York House car park as a youth provision for positive educational activities. The DfE confirmed on 19th November that as the York House car park site is no longer required for a primary school in the next four years, the DfE will ask Quintain to vary the Section 106 agreement to withdraw this obligation. They would then seek to dispose of the site (either on the open market or direct to LB Brent) for alternative use.'
Brent, as Local Planning Authority has a duty to ensure that sufficient sites are available for the school places that will be needed, particularly as part of major new developments such as that at Wembley Park.
This is clear from Para. 94 of the National Planning Policy Framework (2019 version), which says that it should: 'give great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications.'
Similar responsibilities are placed on London Boroughs by Policy S3 - Education and Childcare Facilities, of The London Plan 2021.
Brent, as Local Planning Authority, must not walk away from, or turn a blind eye to, its responsibilities, as its Officer Report on application 20/2844 is trying to do.
The points raised over a Wembley Park Primary School by my detailed January 2021 objection comments need to be considered fully by Planning Committee before application 20/2844 is decided, and that consideration needs to be based on current facts, rather than the "planning theory" of the response in the Officer Report to my objection.
That cannot be done through a brief "Supplementary Report" at the last minute. This application should be adjourned from the agenda for the meeting on 10 March, and not put back on the agenda until the issue of the need for a school site to be reserved on the North East Lands has been properly assessed.'
FOR THE RECORD (2):
ReplyDeleteAfter sending a copy of my 3 March objection comments to the Strategic Directors and Lead Members for Education and Regeneration, to try and find out their views on the need for a Wembley Park Primary School site to be reserved, I finally received the following email message from Cllr. Thomas Stephens, Lead Member for Education on 4 March:
'Thanks for getting in touch on these and other issues. As your queries below relate more to wider policy on schools I am briefly writing, as Lead Member, to provide some reassurance here.
I can categorically assure you that the Children and Young People’s Department is appropriately engaged with Regen and Planning on these issues, and there is complete consistency in approaches here. The school place planning strategy projections are very clear on the sufficiency of primary school places across the borough as a whole in the years ahead. Cabinet keeps the analysis of school place demand under annual review and we are confident in the plans we have in place, which will ensure we meet any need for additional places as part of the Wembley Park development.
We continue to respond to meet emerging priority needs for children and young people and other residents across the borough, with the planned youth zone on York House being one of a number of such examples. I would also draw your attention to the pressing need for local SEND provision and the Council’s plans to address this (which can be found in various Schools Forum papers). It also means we can focus on championing the many excellent local primary schools across the borough which unfortunately are projected to be under-subscribed in the years ahead, helping to increase their take-up and in so doing improve their financial situation.
As is your right you may wish to speak at the Committee on 10 March. Should you do so, Officers in attendance will be equipped to respond on these issues as they are closely engaged with CYP. From my perspective, I therefore have every confidence that they will be able to address all of your concerns.'
FOR THE RECORD (3):
ReplyDeleteThis was my reply to Brent's Lead Member for Education [see For the Record (2) above]:
'Dear Councillor Stephens,
Thank you for your email, and your very clear statement of the Children and Young People's Department view of the points I have raised in connection with planning application 20/2844, and the perceived need for a site on the North East Lands for a Wembley Park Primary School.
As a result of your assurances, I will not request to speak at next week's Planning Committee meeting on this matter.
I got involved after seeing from January's Cabinet meeting that the future primary school and nursery for Wembley Park would not be built on the York House car park site. I wanted to make sure that the proper site for that school, as set out in Brent's planning policies, was kept available.
I also wanted to support Brent's Children and Young People's Department in protecting that site for use within the next 5 to 10 years. Now that you no longer believe it will be required, I will not expend further effort in that cause.
I would be interested to know, please, which primary schools CYP believe that the many children who will be living in the new homes in the Wembley Park development (particularly those recently built, or planned for the next few years, to the east of Olympic Way) will be attending, and how they will be able to reach them easily and safely. Best wishes,
Philip Grant.'