Thursday, 13 May 2021

Sudbury Town RA says consultation extension to May 14th over Barham Park development is not good enough as Sudbury councillors object to the development


The Sudbury Town Residents Association has come back to Brent Council after it failed to agree to recognise it as a Statutory Consultee and provide a 21-day consultation period.


The residents’ association had written to Brent Council asking that in the interests of openness, transparency, community engagement and positive working relations that the Council LINK:


1.     Withdraw the Public Consultation immediately

2.     Upload the Statutory Consultee Comments on the Brent Planning Portal

3.     Provide the STRA with the 21-day consultation period as required by statute

The Statutory Consultee Comments have still not been uploaded for the public to consider. Today's screen grab:




Since the publicity about the application two Sudbury ward councillors have made comments on the Council Planning Portal:

Member for Sudbury Ward, Members Room, Brent Civic Centre (Objects)

Comment submitted date: Mon 10 May 2021

Comments of Councillor Mary Daly in response to statuary consultation by Brent Planning Department to application 21/1106

The park keepers Cottages in Barham Park was built to provide accommodation for workers maintaining the unique park with diverse habitat and historic features.
The Park no longer had park keepers the empty cottages were sold The Barham Trust in 2012 to fund maintenance pf the park.
Since that time the new owner has submitted a number planning applications for the redevelopment of the site.
As a local Councillor the majority of my residents have supported sustainable developing of the cottages.
Two applications have been approved '16/1209, 17/5067 but clearly not built out.
Two applications (14/2078), 19/0788) refused because of their detrimental impact on Barham Park
It is concerning and puzzling that the applicant claims the receipt of extensive preapplication advice and that that advise was that 'that the principal of the development is acceptable'
Barham Park is not an asset owned by Brent Council but is a bequest to the people of Wembley (subsequently the London Borough of Brent) to be managed on the people's behalf by Brent Council.
The site in question is within the curtilage of Historic Barham Park. It is not as suggested in a densely built up area. The nearest taller buildings are across the busy Harrow Rd in Barham Village. The Harrow Rd acts as a border between Barham Park and the residential streets.
There are no other tall buildings within the Curtilage of the park and as pointed out less than two years ago in 19/0788 when refusing permission on that occasion ' the an inappropriate height associated with bulk and massing would appear prominent and have a negative impact on the open nature of the park setting'
Application 21/1106
Application 21/1106 is also four stories four stories In addition to being tall it is also sprawling with balconies reaching to and possibly beyond the development boundaries. ( the report is not specific but illustrations suggests it)'
The building extends beyond four stories and is out of character because there appears to be s pergola like structure and a garden on the roof '(again the report is not specific but illustrations suggest it)
The Developer claims to be bringing the character of suburban Sudbury into the park when describing its design. The park however has a different history and purpose with buildings reminding park users of the area's nineteenth/early twentieth century farming past. for example the eighteenth/ nineteenth century buildings, the walled gardens and walkways.
The extensive cover of trees includes as the almost 300 year old mulberry tree. And a very old plane tree. The historic park is a space residents go to walk and contemplate (it is common to see people sitting on the many benches in the park), enjoying the extensive natural life in the park or playing and exercising.

Application 21/110
The new application invites Brent Planning to consider a four story sprawling building with the additional element of a car park within the curtilage of Barham Park on the application site
The Car Park and Parking on the site
It would be unwise to assume that the car park is for the sole benefit of the future residents of the Proposed development. It is common in such developments to seek parking simply to sell it to enhance the profit to be gained from the development. The addition of a six place car park on an historic Barham Park seems even more incoherent when considering the applicant argued for the benefits of the site in terms of its excellent public transport links. The site (4x2 beds, 3x3 beds 2x4 beds) normally warrants 11/12 parking spaces. There is no discussion about the parking needs of all the car owning potential residents (up to 40 people) were the application to be granted.
This will raise demand for on street Parking. The applicant and planners may argue the surrounding streets can absorb the amount of off on street parking generated by the development .
That is not the case because the regeneration of Barham Village where parking was sacrificed to a larger number of housing units the majority of whom are permit free resulting in a very large overspill into neighbouring streets.
The accelerating breakup of family homes in the area into Houses of multiple occupation or flats
Commuter parking
Shopper parking
Further developments already approved 18/3069 is also permit free and 19\1241 (currently being appealed) will rely on onstreet parking if built out.
The applicant has further failed to provide disabled parking as required by policy
It appears the applicant has not considered the incongruity of creating a car park within the curtilage of an historic park.
The Applicant pretty much dismissed the existence of Bats on Barham Park, however the Boroughs own SINC Review 2014. suggests evidence of species of bat was recorded some years earlier. And recommended that 'until further survey work is done the precautionary principal should be used and the site considered as a bat foraging site' it is unclear if that work has ever been done.
Species supported by habitat in Barham Park includes reptiles, birds, invertebrates, foraging as well as possibly roosting bats were reported by the 2014 SINC report .
The bird species observed at the time of the report in the area nearest the proposed development site include Long tailed tits, starlings, ring necked parakeets. A resident a very experienced Ornithologist reported seeing the rarer lesser spotted woodpecker within the last few months.
The tree species sited nearest to the proposed development within the park includes Horse Chestnut, London Plane and 'Willow. the developer makes reference to a mature Cedar of Lebanon to the front of the site whose canopy is acknowledged to be only meter from the balconies of some of the proposed flats.
The applicant also acknowledges that there are nesting birds within the site.
There is no description of the proposed development in relation to the rear perimeter of the proposed development but illustrations seem to show balconies reaching beyond the rear fence. What is clear is that Barham Park with its hundreds of trees is home to a diverse habitat which have not properly been surveyed and the preliminary surveys presented by the developer is not acceptable. The planning department must request more comprehensive independent surveys to establish the impact of such a dense development especially on that very vulnerable section of the park.
The population of the New Development
The development would see for the first time since the park was bequeathed to the people of Brent a population at least forty people living within the parks Curtilage. Driving to and from the site. attracting other vehicular activity on the site such as delivery vehicles etc . those impacts on the park has not been addressed Requiring large industrial sized waste disposal bins within the site.
The area immediately surrounding the proposed development on Barham Park is already degraded because it was used to store heavy materials and machinery to facilitate the regeneration of Barham Estate.
It is also subjected to heavy vehicles and machinery during Irving's Fair several times each year. the upshot is the section in question is compacted and degraded and subject to more flooding as a result. It is the first section of the park a visitor one sees approaching the park from Sudbury Town and one of the most frequently visited.
The prospect of more materials and heavy machinery further degrading the site as a result of further building on the curtilage of the park
The recent and proposed degradation of this section of the park is contrary to the bequest of the park for the enjoyment of the people of Brent. The area needs to be recovered not face another developer onslaught.
The Sudbury Neighbourhood Plan, a Brent Planning Policy is clear in its vision for Barham Park
'recognises the need to restore. Repair and improve existing landscaping in the park'
'Create enhanced eco -habitats for wildlife and educational purposes'
'the park contains a limited amount of play facilities and Play equipment. 'The consultation demonstrates there is a demand for improving and expanding the range and amount of sports and play facilities '
It needs to be recognised that the proposed development site is within the Curtilage of Barham Park and any development of the site needs to adhere to Sudbury Neighbourhood Plan because it echoes the objectives of the original bequest to entrust the Barham Park for the enjoyment of the people of Brent. The present proposal abutting a particularly degraded section of the park, risks further degradation of the ecology of a particularly prominent and used section of the park by introducing a car park onto the Curtilage of the park in an overdevelopment which is not intended to enhance the Park for the people of Brent.
The development
I am not able to comment on the development because there is insufficient information in the
oapplication relating to
The height of the building
The large balconies, their exact overhand,
the relationship of the building to the perimeter of the site,
the relationship of the site to Harrow Rd .
I will this week seek an appointment with Planning officers to view documents not in the application and reserve the right to make further comments if that is required.
Having imagined the building whilst on site it is clearly a dominant and overbearing feature and more inappropriate than 19/0788 because as well as being tall it is also more sprawling and introduces a car park within the Curtilage of Barham Park.
A brown field site
The characterisation of the former parkkeepers cottages as ' brown field land' without the context of its siting within the curtilage of Barham Park has caused particular offence amongst residents. It is recognised that the park keepers cottages have been unused for some years and that sustainable development is welcomed would enhance the Park.
A consistency of approach
Application 17/5067 was approved by Brent Planning. I consulted residents including Sudbury Town Residents Association Representatives during the consultation. It is worth noting there was no objections to the plan because there was unanimity in the community that the proposal was an enhancement of the site. This highlights the pragmatism of the local community who want sustainable development not high density development within the curtilage of Barham Park because it degrades heritage of Barham Park.
(The statement 'the site lies within the setting of the Holt Conservation area' is puzzling, as the Holt Conservation Area appears to be in Wrexham in Wales).
The National Planning Policy Frameworks PPG states that that 'where a proposal would lead to harm' there must be a demonstration of the proposals public benefits
Such demonstrations of public benefit
'should be of a nature or scale to be of benefit to the public at large and should not be a private benefit'
Application 21/1107 is clearly a private benefit to the applicant and any future residents of the site there is no benefit to the park users. For that reason alone it should be rejected
Brent Planners have already rejected a less dense less sprawling fourstory development (19/0788)
'the proposed development would incorporate an inappropriate height and associated bulk and massing that would appear prominent and have a negative impact on the open setting of the park'
Cllr Stevens and I were the only objectors on that occasion but our comments were informed by consultation with residents.
Whilst I appreciate the site is in private ownership and the developer has a right to submit the serious of planning applications the and have them considered by Brent Planning authority has a duty to consider them. Consideration must always be given to the fact it is within the Curtilage of Historic Barham Park a bequest to the People of Brent.
It is worth noting that consideration of the importance of Barham Park as a local heritage asset, its value to the health and wellbeing of the Boroughs peoples, Its fragile ecosystem, Its precious but vulnerable building has not been acknowledged.
The application is presented as the redevelopment of a brownfield site in an urban area inviting high density housing and car parking A readthrough of my comments demonstrates a united community pragmatic about improvement by sustainable development of the site but consistently resistant to dense overdevelopment because of the impact of the park they value so highly.
There is also consistency in the approach of Brent Planning in interpreting policy to the benefit of the park by accepting sustainable applications for the site and rejecting overdevelopment.
I request officers of the council refuse this application please

Member for Sudbury Ward, Members Room, Brent Civic Centre (Objects)

Comment submitted date: Mon 10 May 2021

Objection, Cllr Thomas Stephens, application 21/1106
To whom it may concern,
I am writing to lodge objections for application 21/1106 for consideration of the Planning Committee and Planning Department.
There have been a number of previous applications by the owner of the land on this existing site. Some, for relatively more modest developments, have been approved by the planning department with few-to-no representations from residents (16/1209, 17/5067). Other more intensive proposals for development (14/2078, 19/0788) have been refused by the planning department. Cllr Daly and myself were the only objectors to the latter.
I will now go through each of my concerns in turn. Some of these relate to material planning concerns, but as with many of my planning representations some of these relate to my wider concerns and observations about the particular sensitivities of this development given the area it is situated in, which I believe warrant closer scrutiny and discussion with the developer alongside concerned local residents and the planning department. Some of these could be addressed through securing strict conditions by the planning committee and department, and through assurances over the use of CIL contributions.

Impact on infrastructure and proposals for car parking space
This is perhaps my greatest concern about the development. At present the site serves just two households and there is relatively limited parking space, but this application as it stands proposes to increase this to six parking spaces to the rear of the property. In order to enhance car access the developer proposes to 'adjust kerb lines outside of [the] site ? to improve vehicular access, site lines and landscaping' [my emphasis] (see Design and Access Statement, page 15). The emphasis appears to be on adjusting the markings around the site in order to enhance vehicle access, and have more cars access this from the junction on Harrow Road.
This is not suitable for a proposal on this site, and strikes me as a considerable missed opportunity to secure a more rational use of space, enhance pedestrian access and improve amenity space in Barham Park, in an area which lies within a CPZ and with a high Public Transport Accessibility Level. To understand this, it is worth getting a sensitive and close understanding of what this area is like and the unusual problems pedestrians and road users face in this area at present. These create long-standing public realm issues for the Council which it would be good to resolve:
· To the immediate north-west of this development lies a heavily used bus stop which is a key point of access for residents into and out of Sudbury. The footway near this bus stop is currently far too narrow for these purposes, forcing users to sit around the green space near it (currently on lease from Network Rail), causing damage to nearby plant pots and greenery. Pedestrians passing through those waiting at the stop face a challenge in trying to get through and fight for space.
· The car access point for existing residents on this site lies to the immediate south of this bus stop. Because of the unusual location where it is situated, is currently used jointly by pedestrians passing north-south onto the bus stop and by people walking along the footpath to Barham Park. This always poses challenges and access issues whenever cars in the current site are driving through, but these issues are currently relatively modest because of the small size of the site as it stands (currently just two households). Because of the kerb elevation on this access point, this also creates problems for residents with mobility issues trying to go along the footpath or use Barham Park.
· Cars trying to get in and out of the proposed development have to access Harrow Road at a very unusual angle, turning more than 90 degrees in order to get onto the road. This causes issues with traffic flow for cars and cyclists, in an area of Harrow Road which is already heavily congested and with several heavily used junctions to the immediate south of the site. Again, the current low usage of the site means these problems are currently very modest.
Unfortunately, all of the above issues which will be exacerbated by the proposed development as it stands, and the proposed site plan gets priorities wrong for an area of this nature. I do not agree with proposals for enhanced car parking provision as these will enhance traffic issues for residents on the site going on and off Harrow Road, disrupting traffic flow, causing congestion and limiting access for pedestrians and cyclists.
In addition, the proposed kerb lines as drawn appear to limit rather than enhance pedestrian access, particularly for those with mobility issues, and make it more difficult for residents accessing the bus stop or using Barham Park due to the onflow of cars and other vehicles. Given that the road in the proposed development as it stands appears to be only wide enough to accommodate one car going in and out of the car park at any one time, this development will see an increased use of cars backing off on to Harrow Road (causing congestion) or driving over the proposed kerb lines and getting in the way of people using the footpath.
Overall, I would rather see a development which enhances opportunities for pedestrian access and accessibility of the park and addresses some of the current problems with the footways on this site. Residents living in the flats also need to be prevented from parking on already over-used parking spaces off-site.

The density of the development
The planning history of the site is highly relevant to this second concern. As noted earlier the planning department has previously rejected two developments on the grounds they were over-bearing, whilst two other more modest ones have been accepted. Significantly, proposal 19/0788 was refused because 'the proposed development would incorporate an inappropriate height and associated bulk and massing what would appear prominent and have a negative impact on the open nature of the park setting.'
It is therefore curious that a more intensive development is now being proposed, and the planning committee and department will need to seriously consider this; the material changes from previous applications; and the grounds for refusing the two previous ones. Many of my concerns here relate strongly to the grounds for refusal of previous applications.
The present site consists of two semi-detached, two-storey houses in the north-western end of Barham Park. Unfortunately the current buildings are not of the Victorian design which is in keeping with the historic buildings in the centre of the park (a sad oversight when this was originally built), but the site is surrounded by trees which have a higher height profile than these houses. To the north of the site there is a hill leading up to a railway line, and again this hill dwarfs the existing buildings.
Because of the modesty of the buildings on the existing site, their positioning in the park and the way they interact with their surroundings, this has the very desirable effect of giving visual and physical prominence to the green space on Barham Park. For all intents and purposes residents therefore see this area as very much part of Barham Park, closely intwined with the history of the park itself and with associated covenants and conditions. Proposed developments on this site therefore need to be sensitive to this and in keeping with the surroundings.
The many objections received to this by local residents need to be considered in this context. Objectors see this as part of the park. Every effort needs to be made to secure a development which is in keeping with its surroundings, enhances existing green space and builds on rather than detracts from the rich history and heritage of the park. The surrounding greenery needs to exceed the height profile of the existing buildings and ensure it integrates with the existing site.
The drawings in the planning documents show what the building will look like from various elevation points, and I am concerned that the height profile of the existing trees and surrounding greenery do not integrate well with the development as it stands.

Roof garden and impact on users of the park
I am concerned about the proposal's impact on residents' ability to access green space and amenities around Barham Park. The proposal as it stands includes provision of a roof garden on the top of the fourth floor and for a range of private gardens and amenity space for residents of the flats, but with no clear proposals to enhance green space or biodiversity around Barham or integrate with green space with the park itself. Because there is a car park proposed to the rear of the site, the orientation of the building is towards the park and not towards Harrow Road or the railway line, effectively pushing the building closer to the park itself.
This has the following implications:
· Under this proposal, residents in these new flats will overlook people using amenities in Barham Park itself. Their flat windows and balconies will face onto the park, whereas the orientation of the building they replace was towards Harrow Road and thus away from the park.
· This has caused understandable worries from residents about privacy for users of amenity space on the park and, conversely, for people living in the flats.
· The impact of development on trees in the site needs to be considered carefully. The tree protection plan shows one tree (T4) overlaps with the development and it is not clear to me what steps are being taken to mitigate for this. The impact of large tree roots on the buildings also needs close consideration.
· Building on my earlier concern, the provision of an expanded car park within the site does not strike me as in keeping with Barham Park's status as a green space, and it would be better for more of this space to be used for enhanced green space provision.
· It is not clear to me how far the balconies extend from the existing development boundaries. Any encroachment of the balconies over Barham Park itself will exacerbate residents' concerns about the impact on the park.
· The development proposes private green space and bushes surrounding the site, but the exact nature of this space is not clear to me and it is not clear if the species proposed and the way they are situated would enhance biodiversity and improve green space in Barham. I am concerned they may indeed worsen it by using greenery which makes this development stand out from, rather than integrate with, the park itself.
Overall, this development needs to be considered carefully against Brent's welcome commitments to enhance biodiversity in Barham and across Brent, through wildflower meadows and enhanced greenery. Any conditions and enhancements which could build on this agenda, improve the density of trees and green space and enhance biodiversity would be extremely welcome.
I sincerely hope that the developer and local residents will be able to discuss these issues in greater detail and come to a clearer understanding of the issues with this proposal as it stands. There will be an opportunity to do this in the planning committee should (as I suspect it will be) it satisfies the minimum number of objections to be logged, where I trust it will receive its due scrutiny from colleagues.
Thank you in advance for your consideration. 







1 comment:

Philip Grant said...

This application will go to Planning Committee for a decision, BUT ONLY if Brent's Planning Officers recommend it for approval.

If Officers refuse the application, as they should, there will be no need to trouble the elected councillors.