Site for a future Wembley Park Primary School needs action NOW!

 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

 

 

New youth provision for Wembley at York House car park site now new primary school no longer needed?

 

The York House car park, Empire Way

Next week's Brent Cabinet will consider  moves to establish an Onside Youth Zone centre at the York House car park site in Wembley.

 

The site was earmarked for a new primary school, the Ark Somerville, but the project has been dropped by the Department for Education for the present, due to falling school rolls in the area.

 

The DfE would need to be released from its obligation to Quintain to provide the school under Section 106 and could then sell the site on the open market or directly to Brent Council.

 

The officers report LINK describes what happens at Onside Youth Zones:

 

Youth Zones provide “somewhere to go, something to do and someone to talk to” and aim to be safe, supportive and affordable places where young people can spend their free time constructively. Targeting young people aged 8-19, and up to 25 with additional needs, Youth Zones provide large-scale multi-activity facilities which typically include multi-use 3G pitches, indoor sports hall, climbing wall, gym, music, dance and performing arts facilities and café, along with flexible spaces that can respond to young people’s changing needs and preferences.

 

Given the size of the site some of that provision would not be possible but it would still be a facility that would help make up for some of the youth provision cut by Brent Council. 

 

As Brent Youth Centres  were cut for financial reasons it is worth looking at where the Council  now expect funding to come from:

Running costs

SCIL = Strategic Community Infrastructure Levy

MTFS = Medium Term Financial Strategy

The charity Onside Youth runs a centre in nearby Barnet. You can read about it HERE
 

'A major mistake on public health grounds' but Empire Way primary school approved

Clean Air for Brent sent the following submission to the Planning Committee today but there was little evidence at the meeting that members had taken it into account.[ UPDATE 17.00 June 7th Joe Kwateng has written to CAfB today to say that the document arrived while he was in the pre-meeting with the Committee which was immediately followed by the Planning Committee meeting itself. He could not access his computer and therefore could not bring it to the attention of the committee. He apologised.]

The Committee decided by 7 votes to 1 to approve the application for a 630 pupil primary school on the York House car park on Empire Way. Well done to Cllr Abdi for taking the concerns seriously and voting against. I was surprised that Cllr Colacicco who has fought so hard against the Cricklewood Aggregate Hub on grounds of air and traffic pollution, not only voted for the application but praised it for meeting BREAM standards. A 'green' building in a heavily polluted area is a contradiction.

The Committee were told by officers that as outline permission have already been granted for a much wider area, but one that included the school site, and it had been found 'suitable for a school' that the hearing was really only about planning matters related to design, school travel plans etc.  Design features to mitigate exposure to air pollution included the positioning of classrooms towards the back of the plot with a school hall and non teaching rooms on the ground floor facing Empire Way and the installation of a mechanical ventilation system. Planning Officer told the committee that the Council had Victorian schools in far worse locations- so that's all right then!

The is CAfB's submission:

Objection by Clean Air for Brent

We apologise for the lateness of this objection, but we only became aware of the application on 1 June and have been in dialogue with planning officers since yesterday about the material considered in connection with the outline application 15/5550.

Summary: Clean Air for Brent considers that it would be a major mistake on public health grounds to proceed with the proposal to site the planned Ark Somerville School and associated Day Nursery on the York House site next to the heavily-trafficked Wembley Hill Road. We urge the Council, Quintain and the Ark Academy Chain to consider an alternative site within the development away from the main road.

Outline permission: We appreciate that outline permission was granted in respect of application 15/5550 and that this includes the siting of the school. The implication of the Head of Planning’s email to us of 4^th June is that the question of siting is done and dusted. We agree that this might normally be the case but with respect we regard this as a technicality compared with the risks of damaging the health and development of future nursery and primary school children. So far no development of the critical site has taken place.

Considerations: The UK and London in particular is in serious breach of legal air pollution requirements derived from EU legislation to which the UK is a party. The main pollutant concerned in the legal breach is nitrogen dioxide, NO2. Most of Brent is declared as an Air Quality Management Area because it is in breach of the legal limit for NO2. This includes the site in question.

The legislation is based on World Health Organisation findings on the impact of various air pollutants on human health. In the UK the official Committee on the Medical Effects of Air Pollution (COMEAP) and the Royal College of Physicians among others have published extensive studies on the various adverse health impacts which include respiratory diseases, cancer, stroke, cardiovascular conditions and possibly neurological morbidities. Children are especially vulnerable, possibly because they breathe more rapidly than adults. It is considered that children badly affected by air pollution can have their lung development restricted by up to 10%.

Since road traffic, particularly diesel-powered vehicles, is a major contributor to NO2 pollution The London Mayor, with wide support, has taken a number of initiatives to address the problem of the hundreds of London schools sited for historical reasons on heavily-trafficked roads. An example is the recently published results of a professional air quality audit of 50 of the most-polluted schools, including two in Brent. It is clear that mitigation measures as so far proposed will have no more than a marginal effect on pollution levels affecting children in these schools.

In this situation CAfB believes that it is seriously irresponsible to site any new school on a heavily trafficked road, such as Wembley Hill Road in the present case.

In the short time available CAfB has investigated whether the issue of air quality in relation to the siting of the school was discussed in the papers submitted with the application 15/5550, eventually decided in December 2016. Although the Planning Officer advises that it was we have not found evidence for this in the 77-page Air Quality chapter of the Environmental Statement sent to us yesterday by the Head of Planning. We note that among the documents listed as relevant is the London Plan, but the salient point in the London Plan in relation to the school is in 7.14. This is not discussed but relegated to Appendix 3.3.1. For reference it reads:

“B  Development proposals should:

a  minimise increased exposure to existing poor air quality and make provision to address local problems of air quality (particularly within Air Quality Management Areas (AQMAs) and where development is likely to be used by large numbers of those particularly vulnerable to poor air quality, such as children or older people) such as by design solutions, buffer zones or steps to promote greater use of sustainable transport modes through travel plans (see Policy 6.3)”

The relevant supporting paragraph 7.51 begins:

“Increased exposure to existing poor air quality should be minimised by avoiding introduction of potentially new sensitive receptors in locations where they will be affected by existing sources of air pollution (such as road traffic and industrial processes). Particular attention should be paid to development proposals such as housing, homes for elderly people, schools and nurseries.”

Unfortunately the whole emphasis of the Air Quality chapter is on the effect of the development on the environment and not on the effect of subjecting the school and nursery pupils to the pollution effects of traffic on Wembley Hill Road.

We also note from the Master Plan documents associated with 15/5550, section 5.8 about the school site, that during the early stages three alternative locations for the school were considered but not favoured by Ark Academy or Brent officials. In this section there is no mention of air quality issues arising from siting the school on Wembley Hill Road.

Conclusion: While it would be desirable to install air quality monitoring arrangements close to the site in question and other possible sites before a final decision, this is not really necessary since if the choice is between a busy road and a more local or feeder road within the site the answer is obvious. We therefore urge that this aspect of the overall plan be put on hold for further consideration by the parties in the light of the latest understanding of the effect of air pollution on children’s health and development.

-->

Clean Air for Brent call for thorough air quality assessment for new Empire Way primary school

A gross under-estimate of traffic?

A spokesperson for Clean Air for Brent (CAfB) has commented on the proposed 630 pupil primary school on the site of the York House car park on Empire Way, Wembley:

We know that children in schools on busy roads in Brent are being regularly exposed to illegal levels of air pollution. It’s imperative therefore that Brent Council put air quality at the top of their list of considerations for any new school being proposed in the borough.  A child attending school will have 8 years’ worth of exposure, and it is during these years that children are said to be most vulnerable to the harms of pollution, including asthma, poor lung development etc.

In any case it is hard to see how this proposal aligns with Brent’s current Air Quality Action Plan which states that ‘ The council will review all new planning applications for potential air quality impacts and require all new development have no additional impact on local air pollution as a minimum requirement.’

Given that a superficial air quality assessment was done in 2015, Clean Air for Brent are calling for an up to date Environmental Impact Assessment to be done. 

The Council must do this not just for the children but so that parents can use this information to decide whether they want to send their child to a school that is located on a busy main road, and therefore its air quality environment likely to be highly compromised by passing traffic. 

The decision on whether to grant  planning permission for the school is due at the Planning Committee on Wednesday. LINK

Ark plan new primary school in Wembley but is it needed?

Ark appears to be about to expand its schools empire in Brent adding a new primary free school at Wembley Ark, Ark Elvin and Ark Franklin Primary.

The new school would be on a site at the corner of Empire Way/Wembley Hill Road and the Royal Route with a form entry of 90 (3 classes in each year group) making a total when it is full of 630 pupils with perhaps a 60 place nursery.

The Ark Somerville Primary School would be on a busy main road which is of concern given the impact of air pollution on children and it will be important to see how much open play space will be available to the pupils.

The most important concern though is whether a new school, and such a large one, is actually required. In the immediate vicinity of the proposed school are Elsley Primary which is currently doubling in size to four forms of entry, Park Lane Primary, Oakington Manor Primary and Wembley Primary.

An important factor is the impact of Brexit and the declining value of the pound in the number of European citizens working in Brent.  There is anecdotal evidence of a reduction in numbers which affects the number of  EU pupils in local schools. Alongside this is the continuing issue of families affected by the benefit cap being forced to move out of London.

Quintain is of course building new housing in the area but this is generally not affordable to local people and unlikely to accommodate families. Brent Council will need to provide robust projections of future demand to justify a new school.

I understand that several of the primary schools that have been expanded recently are not attracting sufficient pupils to fill the new places and that some may apply to reduce their form of entry.  I am awaiting the outcome of an FoI request to see the evidence on unfilled vacancies and waiting lists.

If there is not an overall increase in demand a new school would create a 'churn' of pupil movement as parents move their children between schools. Brent Council is committed to supporting 'parent choice' by running schools with some spare capacity but the downside of this is that pupil mobility can be disruptive to the continuity of learning and undermine pupil progress. Schools with high mobility may find it very hard to meet the target thresholds set by the government for Year 6 children when perhaps only 20% of them attended the schoool in Year 2.

Local public transport is already under strain with pupils from Ark Elvin, Wembley Ark, Michaela, Preston Manor and the Lycee converging at home time and the proposed new primary would be on the same routes although one would hope that they lived within walking distance of the school.

Ark's announcement is below.

In September 2014 Ark submitted a free school application to the Department for Education to open a new primary academy in Wembley to help meet the growing demand for school places.

Following the approval of the application, Ark is now consulting on the proposal to open Ark Somerville Primary Academy, serving 2-11 year olds in Brent. It is proposed that Ark Somerville would open in September 2019 and admit 90 Reception age children each year until it reached its full capacity of 630 in September 2025; there is the potential that the school’s 60 FTE nursery might also open at the same time.

Ark Somerville will be located on the corner of Royal Route and Empire Way, next to the London Designer Outlet and will be a newly constructed building completed ready for September 2019 opening. The building is being designed and built by Bowmer and Kirkland, who will lead on a planning consultation later in the summer.

Ark Somerville Primary will be non-denominational, non-selective and mixed, serving local children. The admissions criteria will prioritise those living closest to the school. The school will have particularly strong links with Ark Academy (an all-through school), Ark Elvin Academy (a secondary school) and Ark Franklin Primary, all located in Brent. Ark Somerville will also become part of the wider Brent family of schools.

Please let us know what you think

If you would like to hear more about the schools, please join us at one of our drop-in events which will be held at Ark Academy, Bridge Rd, Wembley, HA9 9JP

There will be two events held on 13th July at:

•  9:30 - 11:00
•  17:30 - 19:00

The consultation period will run from 29 June to 15 September 2017.
If you have any questions or comments, please do get in touch through our feedback form on Somerville S10 Consultation Feedback Form