Alperton Bus Garage development and neighbours 3 years on -

 

Planning permission was granted for the redevelopment of Alperton bus garage in April 2021. The Planning Committee were informed that previous policy had a 14 storey limit on the height of buildings in the area. However, planning officers said that the 'emerging' local plan allowed for tall buildings on the site. Buildings  of 21, 25 and 28 storeys were approved. It is so close to Alperton station that residents are likely to be able to abseil on to the platform!

See 'Your neighbourhood turned upside down. Have your say on local plan'

 Cllr Maurice voted against the application on grounds 'of over-development, height and its destruction of the area's once pleasant suburban character.'

 Alperton councillor Anton Georgiou presented the case against the application quoting the views of local residents.  Many cited over-development, height and density as concerns. See:

Alperton residents' trenchant views on the Alperton Bus Garage planning application fail to stop approval of the development

 

 Above and below are views of the development as it takes shape.

Opposite the site is Minavil House where a low rise commercial site was demolished and replaced with a development that included a 27 storey tower, This development was valued at £64m.

From the Grand Union canal (developer before the bus garage development)

Last week

 

Emerging heights in the tall building zone (Alperton High School bottom right)

There several pipeline developments in the area. One on Ealing Road, wedged between two new developments is a  former  HSBC bank and the Plough public house.

In 2018 plans were approved for two buildings of 9 and 10 storeys on the site with a total of 92 flats. A member of the public asked a question at Full Council after doubts were raised about the application See:

Uproar over Brent's Alperton high rise approval, despite application “failing to meet requirements in 13 different matters”

 Councillor Tatler, Lead Member for Regeneration, Growth, Employment and Skills:, in her response said:

Planning applications of this size raise a number of complex, and often competing issues; in this case, involving the redevelopment of the site to provide two buildings, 9 and 10 storeys, for 92 new flats, a pub and a community use, it raised many issues – the appearance and build of the new buildings, the amount of residential provided, the mix of units, parking arrangements, etc. Officers and Committee members balance all of the different issues, including the planning objections, and make their decision against national, regional and local policies. These issues are often finely balanced, and opinions will often differ as to the merits of a particular case. 

 

Sometimes, one policy objective, (e.g. securing additional housing, or maintaining a public house on the site) might be given more weight than, for example, a reduced level of parking. In this case, the planning merits of the proposal were carefully considered. Officers made some pragmatic judgments around the proposal to achieve, on this allocated site in a housing zone, some 92 new units – a quarter of which are affordable – that works on the site. The committee report makes it clear that whilst some policies are not met, many are, and taking the scheme in its entirety, members felt that the benefits outweighed any harm.

The question does not mention what safety regulations are broken here. However, it is a long established – and correct – principle, that planning does not duplicate requirements set out in other regulations and laws; these will be assessed by other bodies at the appropriate time, whether that be under Building Regulations or Health and Safety rules.

A new application for the site was lodged in August 2024, for two buildings of up to 10 storeys on the site. Planning Officers noted that the previous application had lapsed  because of new fire regulations and the requirement for additional evacuation cores. LINK

In addition to this development  the Boat/Pleasure Boat pub, opposite the bus garage has been demolished and the site is now behind hoardings.

 The last proposal I saw was in a consultation for a 22 storey tower and a replacement pub. Here, as at the Plough site this will probably be re-designated as a 'comunity facility'.

 

 

UPDATE - case taken up by ward councillor. LETTER: A letter to Brent Council regarding my safety in the event of a serious fire in my high-rise block

 Dear Editor, 

How can I get Brent Housing Management to fix the self closing fire doors in my high-rise, William Dunbar House, South Kilburn.

At the Grenfell Inquiry, self closing fire doors that did not self close were identified as the second highest issue after unsafe cladding and as a result I have been emailing the council to fix 2 self closing doors that do not self close and which are part of my only fire escape in my high-rise, one on the 3rd floor & one on the 5th floor but after 3 years, they still have not been fixed and everyone's safety is under threat because of this.

I had a response to one of my emails from a housing officer who said "Fire Safety is not included in my job description" and he failed to pass it on to another officer, who did have Fire Safety in their job description.

After 3 years I decided to ask the London Fire Brigade to solve the issue but I was shocked by their reply, which said they were not responsible for Fire Safety in council blocks and they forwarded my email back to Brent Council who failed to take any action as usual.

Now I am asking Wembley Matters to get a response from Brent Council and get them to fix the 2 self closing door in my block.  However if there are at least 2 damaged doors in my block, I am sure there must be many more damaged doors throughout the rest of Brent's high-rise stock and the council should carry out an urgent inspection of all their high-rises to check to see if there are any other self closing fire doors that do not close.

I realise how important this issue is after the tragic fire in the Bronx that was caused by a non self closing door that stayed open, allowing fire and smoke to escape to the rest of the building, resulting in so many tragic deaths.

My fear is that my block could be next, unless Brent Housing fix all the damaged fire doors across the borough, or we could end up like Grenfell or yesterday's fire in the Bronx..  

Thank you Martin.

John Healy

 

UPDATE: Following publication of this letter on Wembley Matters a ward councillor has got in touch with John to take up the case.

South Kilburn residents object to high rise redevelopment proposal on the Crone, Craik and Zangwill site

 

 

Block A maximum 10 storeys c65metres,  Block B maximum 16 storeys c86metres, Block C maximum 12storeys c72metres.

The proposal:

Phased redevelopment of the site comprising: Demolition of all existing buildings, structures and site clearance, construction of three buildings ranging from 6 to 16 storeys comprising 252 residential units (Use Class C3), and provision of 325 sqm of commercial, business and service floorspace (Use Class E). Hard and soft landscaping works, access and highway alterations, car and cycle parking provision, and associated ancillary works. | 1-75 Crone Court, 1-85 Craik Court and 1-10 Zangwill House, London, NW6 

 

A group of Craik Court residents have objected  to the above demolition and redevelopment on the South Kilburn Estate on the following grounds:

We object to this application because

 

1.   Residents were involved in the three consultations during the spring and summer of 2018. The plans in this application do not resemble what was proposed in the final consultation event in September 2018. In these consultations residents said strongly that they did not want buildings over 10 stories high.  We were given the impression in these meetings that what we were shown in September 2018 would resemble what was built. This is not the case.

 

2.   We do not want high rises in South Kilburn. The application says buildings up to 16 stories will be built. This goes against Brent's Local Plan for the area Craik (p.201) Crone p.202 only mentions up to 14 stories.  Why does this application add 2 extra stories? In the exhibition we were shown the buildings are 8 and 9 stories high. But in this application 16 stories are proposed.   In the Supplementary Planning Document (SPD) for South Kilburn on p48 it says  that the regeneration  plans " will not propose radical divergence from the mansion block typology" 16 Stories is a radical divergence from this . It has a knock-on effect of causing the area to be too densely populated and the loss of light to other blocks in the area.  

 

3.   Loss of parking. At the moment Craik has 22 parking spaces, Crone has 28 parking spaces . These spaces are very much in demand, There seems to be no new spaces in these plans but many more dwellings.  In fact there is a heavy loss of spaces. While we agree that with climate change we should discourage car use, many people living in the area need cars for work or because they are not able to get around without them. Where will they park?

 

The parking on the new plans is only on the road. These roads are now filled with the numbers of people living there. If these buildings are built there will be many more households needing  parking all looking on the same roads for very limited parking.

 

4.   Loss of light - The height and density of these blocks, if allowed  to go ahead, will cast shadows on the homes and open spaces behind them. This is unacceptable.

 

5.   Density -  if the number of new homes asked for in this application  is allowed it will put an enormous strain on the already strained infrastructure in the area.  Services such as doctors are over stretched.  There are no doctors at Kilburn Park Surgery and the other local surgery, Lonsdale Practice is full to the brim.

 

6.   Loss of green spaces. If this plan is accepted there will be a huge loss of green spaces. The area between the two new proposed sites, Canterbury Road, is dark and has 2 huge buildings looming over it in this proposal.

 

7.   Loss of play space.  The application has a huge loss of playspace which is not made up for with the new  park. The new park was built to replace other play spaces that have already been lost. There is a space in the middle of the building on Canterbury Road but that is only for residents of that block. It cannot make up for open accessible play spaces lost.

 

FULL DETAILS OF THE PROPOSAL HERE

Revealed: Brent Council policy designates 'potential' for high rise development In Stonebridge (Conduit Way) and Wembley Central (Dukes Way)

 

Illustration from booklet celebrating the Brentfield Housing Scheme - June 11th 2021 LINK

An obscure Brent Council document LINK on the Council's Local Plan  piublished in June reveals plans for high rise development on part of the Brentfield Estate. I declare an interest as a former teacher at Brentfield Primary School who became familiar with the estate and its families living in low density homes with gardens and a sense of community

Their homes had been built in the wake of the First World War concerns about the poor health of working class recruits stemming from poor housing conditions. In a campaign which became known as 'Homes Fit for Heroes' local councils would build homes for those living in such conditions.

Willesden District Council planned their first Council Estate of homes for heroes and celebrated the handing over of the first homes to their tenants with a grand opening and a booklet written by the Council's Engineer and Surveyor. LINK

 

 Conduit Way now (Instant Street View)

Now 100 years later, almost to the day, those same homes have been described as of 'low quality' by Brent Council and some designated as suitable for high density tall buildings - which will probably comes as a surprise to existing tenants. This comes in the wake of the redevelopment of the Stonebridge Estates on the other side of the Harrow Road which saw high rise blocks demolished.

In a sort of domino effect in reverse, Brent Council justify the building of tall buildings here because of proposed tall buildings on the Bridge Park and Unisys sites. This designation is just part of the Brentfield estate but one can see that the same justification could be deployed at a later date for other areas with the proximity of the redeveloped tall buildings used as a justification. The open space on the other side of the North Circular may also be affected with the proposed tall building at Stonebridge station setting a precedent for the area.

 

For Stonebridge Park an additional area adjacent to the site allocation BSSA7 Bridge Park and Unisys Building has been identified. This incorporates the Conduit Way estate. This extension is justified on the basis that the existing estate is of low density, lower quality homes which has the potential to be intensified to a higher density reflective of its higher public transport accessibility. This is particularly so along and in the areas adjacent to the Brentfield frontage. This will complement the taller buildings proposed on the Unisys and Bridge Park site and reinforce the gateway role from the North Circular of those entering the borough from further afield. 

 

An accompanying map shows the proposed change to the 'tall building' area:

 

Satellite image (Google Earth)

 

 

 

The proximity to other tall buildings is also used to redraw the tall building zones for Wembley Central and Kilburn Square.

 

At Wembley Central the 'Twin Towers' on the site of Chesterfield House provides the justification for the extension of the tall building zone as well as an existing building. In this case the proposal is for additional floors to be added to the existing buildings:

For Wembley Central Area B, an additional area north of Duke’s Way has been included. This is a council housing block. This area has already been developed for a tall building at King Edward Court (11 storeys plus lower ground floor). As such its inclusion is justified in part on this basis to correctly reflect the current situation of a tall building being there. In addition, this block has also been identified as potentially being able to accommodate additional upper floors, in part taking account of the opportunity afforded by the adjacent taller Uncle building.

The new Kilburn Square Zone

The Kilburn Square controversy has already been covered on Wembley Matters LINK but it is worth recording Brent Council's justification here:

Subsequent to the submission of the draft Local Plan more work has been undertaken by the Council as the owner of the estate in testing delivery options. As a result of this a tall building is being proposed adjacent to the Kilburn Square open space. The tenants of the estate have been consulted as have the local neighbourhood forum. As the existing building is not occupied by residents, the scheme will not need a tenants’ ballot to proceed. The initial scheme has been subject to Design Council design review. Recognising the surrounding character, the Design Council regarded the principle of an additional tall building as acceptable in this location, principally due to the existence of a tower on the estate

How many disabled people are living in fear in Brent's high rises after Grenfell?

As the number of high rises proliferate throughout Brent and the cladding issue in many tower blocks unresolved, even as the horrors of Grenfell are relived through the current Inquiry, it is worth thinking about the situation of people with a disability in such buildings.

The London Fire Brigade has said that disabled people should not be placed in any accommodation above the 4th floor. One of the fatalities at Grenfell was a woman who had been told by Kensington and Chelsea Council that she would not be housed above the 4th floor, but tragically, she was.

A disabled pensioner in a Brent Council block has approached Wembley Matters to tell us about his situation. 

Since Grenfell he has asked the council to rehouse him on a lower floor and in response they have asked him why he accepted a flat in a South Kilburn high rise above the 4th floor way back in April, 1993.

They have also lost the record of the PEEP (Personal Emergency Evacuation Plan) that he had sent them and demanded proof that he was disabled despite the council's own OT team assessing him last year and installing a wet room and sit down shower as a result. He thinks that this action, in itself, is proof of his mobility needs.

He remarked that the council had found homes for nearly 900 students but had told him that they had no spare home to offer him. A different case of course, and a private provider,  but it clearly rankles.

The resident could see Grenfell from his tower block his tower block as he wrote his email to Wembley Matters and reflected that there had been two fires in his block during his tenancy and he had not known about them until he smelt the smoke. His neighbours and fire officers had shouted warnings to leave the building but he had not heard them because of the hearing impairment he has on top of his mobility problem.

He asks how many other disabled people are living in fear of fire in Brent's high rises in the shadow of the Grenfell disaster?

A good question, deserving of an answer.

Alperton Bridgewater Road high-rise development approved

Cllr Anton Georgiou (Lib Dem, Alperton ward) told the planning committee that the proposed high-rise development on the Saab showroom site on Bridgewater Road LINK was felt by residents to be 'unneeded, unwanted and unnecessary.'

He said that the 'mini-city' developing around Alperton station was changing the character of the area. The Bridgewater Road proposal was in an area where the majorrity of housing was two storey homes. There were developing problems of traffic levels and the application would contribute to further congestion.  He asked if the £4.4m CIL money raised by the development would actually be spent in the area.

He reported a young resident who had told him,  'Alperton is a place to sleep - not to live.'

Georgiou echoed Paul Lorber's call LINK for the suspension of high-rise development until links with Alperton's high Covid19 rates had been established, including the role of communal areas in high rise blocks in the transmission of the virus.

Cllr Trupti Sangani (Labour, Alperton) said she had seen no improvement in Alperton via CIL spending and called for step free access at Alperton station. The Transport Officer said that this single development was not enough to trigger such a demand as increased footfall following approval would be neglible. Improvements were being sought for nearby bus routes.

It appeared from the developer's response that Alperton School had not been directly consulted about the development which will partially over-shadow the school's site.

There was a discussion regarding how each development on its own would not have an impact but it was the cumulative impact of all the high-rise blocks that was important.  Officers referred to the Alperton Growth Area Policy but it was unclear whether the need for station and train frequency improvements would only happen late in the day, when the new housing was already occupied.

The  Growth Area plans included public spacse, canal improvments new play areas, a new nursery, community spaces and road and junction improvements.

Cllr Sangani referred to problems of anti-social behaviour along the canal side in Alperton and said officers should be raising these issues when they spoke to developers. She was told that things would improve when there was natural surveilliance from the blocks overlooking the can and when the link between all the developments in a wide canal side path had been completed.

The Canals and Rivers Trust could apply to the Council for CIL money to make improvements.

So far the Alperton developments had gained over £14m CIL money for Brent Council, 15% (about £2m) was allocated for Neighbourhood CIL. Chair of Planning Committee, Cllr James Denselow, said that this raised the wider issue of whether CIL money should be spent in the area from which it was raised, or across the borough. This was not a decision for the Planning Commitee nut for the Executive.

The main selling points put forward by the developer was what they claimed was 100% affordable housing and the creation of 120-150 new jobs in the industrial component od the scheme. They stressed their close working relationship with the Council developed through their other schemes in the area.

Councillors were told that their decisions had to be on the merits of the application and they could not make the deision on wider issues and pre-existing local conditions.  Cllr  Denselow, told members of the committee that it was 'tricky' as to an extent they had to take their ward councillor hat off when making decisions.

Officers warned that if they made decisions beyond strictly planning issues they could open the Council to appeals and financial penalties.

Cllr Michael Maurice voted against the application on grounds of his opposition to high rise and was reminde by Cllr Denselow about the danger of pre-determining applications. Maurice was also concerned about the transport implications, Cllr Sangani abstained.

Alperton high rise city's onward march up Bridgewater Road

The emerging high rise city

The former Saab showroom, 2A Bridgewater Road, part of the development site

The site marked with red pin - note the 2 storey suburban housing to the right of image

Wednesday's Planning Committee will be asked to following officers' recommendation and approve a 4-19 storey development to replace the low rise former Saab showroom at 2A Bridgewater Road, Alperton.

The application continues the expansion of high rise in the area as can be seen from the top image take from the application.  The blocks are set back near the Piccadilly underground line, which offers say mitigate their height, with an industrial unit on the street frontage. 

The housing comprises 124 units:

Affordable Housing – comprising 47 affordable rent units at London Affordable Rent levels and 77 shared ownership units in line with the household income cap and eligibility criteria for intermediate products set out in the London Plan and draft London Plan

It has less family housing than guidance suggests but officers say that is offset by its '100% affordability.'

Apart from some disabled parking it will be a car free but officers suggest the case for a local CPZ will be strengthened by the development.

Regarding the development's closeness to traditional 2 storey surburban housing, the report states:

The proposal would respond well to the constraints and opportunities of development in this area of transition between the dense urban fabric around Alperton Station and the more traditional housing to the northwest.

 

High rise leaseholders warned about Advice Notice 14 impact on selling their home

Letter from a Wembley Matters Reader

Dear Martin,

Are you aware of 'Advice Notice 14' resulting from the Grenfell inquiry. It covers owners of all types of homes across Brent but specifically for leaseholders living in high rises.
Until they have a safety certificate issued by the council, all homes are valued at £0.

The council have published a tender (see below) for the work that checks the composition of all wall material in high rises for fire safety.  Once each building is passed as safe, then a certificate is issued but it is likely to take several months, if not years to pass every home across Brent.

It affects 500,000 owners across the whole of England and hardly any of them are aware of it.

They only find out if they try to sell their property, as no buyer can get a mortgage unless the home they are buying has a current safety certificate, covering all the flats within each block.
The problem in Brent and everywhere else is that there are no fully trained inspectors.  So the council tender is trying to find a company to do the work and then pass the buildings by issuing 'a certificate of safety' saying the wall material does not have any Combustible material within it. This material was often used as packing around the steel embedded in the concrete in buildings erected in the 1960's.

But most of the suspect buildings have been built recently and will have to be checked for cladding that is combustible.

I think this is the biggest story to come out of Grenfell so far and hardly anyone in the country is aware of it.

An article in the Guardian on Saturday November 2nd LINK covered the plight of what it called 'mortgage prisoners':

They have all become caught up in the confusion over cladding on tower blocks – specifically, whether or not buildings meet new fire safety standards introduced following the Grenfell disaster, how much it will cost to put any problems right, and who will ultimately foot the bill.

All of this is feeding through to thousands living in “high-rise” (defined as more than 18 metres) apartment blocks, as well as many living in smaller blocks, because property valuers are taking the view that unless they have all the facts at their fingertips – for example, is there any chance the cost might fall on the leaseholder? – they can’t put a valuation on the property. That means these owners can’t sell up or switch to a cheaper mortgage.

This is the decision notice published by Brent Council on October 31st 

This decision seeks approval for the appointment of a building consultancy to complete a data collection exercise to identify external wall materials and insulation used on high rise residential buildings over 18 metres in height within the London Borough of Brent under Contract Standing Orders 88 & 89.

Decision:

To approve:

(1)      Inviting tenders under a mini competition via the NHS SBS Construction Consultancy Services 2 Framework on the basis of the identified pre-tender considerations.

(2)      Officers evaluating the tenders on the basis of the identified evaluation criteria.

Reasons for the decision:

Ministry of Housing, Communities and Local Government (MHCLG) is requesting that Brent Council complete a data collection exercise to identify external wall materials and insulation on all high rise residential buildings over 18 metres.  The Council is therefore seeking suppliers to submit a proposal for carrying out the requirement.

Alternative options considered:

The procurement options for this requirement were either an OJEU procurement or a mini-competition from a framework.  Given the estimated value of the procurement and limited time available to procure a contract in order to commence in December 2019 it was considered that the NHS SBS Framework offered the most appropriate mechanism to procure.

Interests and Nature of Interests Declared:

None
Wards Affected: (All Wards)

You have until Thursday January 3rd 5pm to influence Brent's Local Plan

The consultation  on Brent's new Local Plan ends at 5pm on Thursday January 3rd so there isn't long to get your response in. Full details can be found HERE.

I will be putting aside a certain cynicism about the Local Plan, based on how often planners ignnore the principles set out in the current one,  and hope that many other residents will do the same. The Plan will establish the context of planning decisions and thus the nature of our area for years to come - at the very least we should establish a strong demand for the retention and enhancement of green spaces.

The borough has been split into 7 'Places' and an initial weakness appears to be that Wembley is split rather confusingly between Central Place (Wembley Park) and South West Place (Wembley Central). One would think that the relationship between the two parts of Wembley was crucial in terms of roads, bus and railway transport as well as offices and retail ands thus shold be treated as one place.

Respondents can choose between responding to the details for a particular place (Central Place questionnaire is below as an example) or the overall plan.



This is the East Place questionnaire covering Dollis Hill (including Staples Corner), Neasden and Welsh Harp:

 

The Spring 2018 consultation indicated a split between the general public,  and developers and what were referred to as 'professionals'.  This was particularly evident over high rise flats and the amount of really affordable housing in new developments:

Question 15: Solutions to meeting growth challenges, e.g. tall buildings, lower rise buildings but compromise on standards, or rely on character to inform height/density.

.        2.32  Tall buildings – answers focussed on the need to meet targets with potential to contribute to townscape, those not in favour identified them as eyesores, changing character and perceptions of safety and unlikely to provide affordable housing with criticism of Wembley Park design quality. 


.        2.33  Lower buildings/ compromise standards – there was little support for compromising standards which was considered likely to adversely impact on quality of life/ mental health. 


.        2.34  Take account of existing character – this was supported the most but most people interpreted this as meaning no tall buildings. 


How this is addressed in the Preferred Options Local Plan

2.35    The Plan principally take account of existing character, but recognises that in accordance with London Plan that a positive strategy and sites will have to be identified for taller buildings. The Local Plan focuses on providing ‘clusters’ of tall and increased height, whilst removing opportunity for isolated tall buildings. Lower scale, but taller buildings than exist are identified for intensification corridors and town centres.

Question 16: Where do you consider are the most appropriate or inappropriate areas for tall buildings and why?

2.36    The responses to this part were limited, consistent with the general antipathy towards these types of buildings.

How this is addressed in the Preferred Options Local Plan

2.37    The approach taken forward is to cluster tall buildings in highest Public Transport Accessibility Level (PTAL) areas and those areas where the Tall Buildings Strategy points to such opportunities as part of a positive plan-led strategy.

Question 19: Should higher density housing in suburban areas with greater public transport accessibility be through: conversion/ extensions to existing buildings; infill in spaces between buildings; comprehensive redevelopment of sites, or other?

2.42 Limited number of responses – positive about reuse of buildings and comprehensive redevelopment, but negative about infill.

Question 23: Appropriate affordable housing target.

2.50    From the general public there was more support for the 50% target, although many questioned the affordability of affordable homes provided. The professionals considered 50% too high and pointed to the 35% target set by the Mayor as a recognition of this, as long as viability could still be assessed where lower proposed.

How this is addressed in the Preferred Options Local Plan

2.51    The Plan is consistent with the Mayor’s approach of a strategic 50% target but with a viability threshold of 35% approach. Tenures will be focussed on rented products that even at their maximum are accessible to those on benefits.

Question 24: Greater flexibility in relation to on-site affordable housing provision?

2.52    The general public were against this flexibility as it was likely to polarise communities, developers sought greater flexibility.

Question 25: Affordable Housing Tenure Split?

2.54    The majority of respondents considered that there needed to be a mix, with products genuinely affordable and also those that catered for those working/ wanting to buy. Developers wanted flexibility/ pragmatism on a site by site basis.

How this is addressed in the Preferred Options Local Plan

2.55    Taking account of the needs and viability assessment work a preferred local mix that maximises London affordable/social rent/affordable rented products is prioritised (70%) as a proportion of the affordable housing but also seek a minimum 30% intermediate (shared ownership/ London Living Rent).

Here is the link to the various 'Place' proposals and questionnaires: (see map above to locate your 'Place')

• Central (.docx, 27.0kB)
• East (.docx, 22.3kB)
• North (.docx, 26.9kB)
• North West (.docx, 22.5kB)
• South (.docx, 22.6kB)
• South East (.docx, 22.4kB)
• South West (.docx, 22.8kB)

 

Full details and on-line survey HERE

Alternatively, comments can be submitted by email to planningstrategy@brent.gov.uk or by post to Paul Lewin, Team Leader Planning Policy, Brent Council, Engineers’ Way, Wembley, HA9 0FJ, setting out clearly the page number, paragraph, policy, figure or image the comment relates to.