Newland Court residents' champion reveals Brent Council's potential crime over bat roost within the local vicinity of infill development (Amended)

 

Soprano Pipistrelle (Photo: eurekalert.org.)

Writing on behalf of Newland Court, Wembley Park, residents, Marc Etukudo has submitted an email to Brent Council officers and councillors that raises serious issues of possible environmental law breaking:

 I would like you to accept this email as a formal objection being submitted amongst others submitted against Brent Council’s proposal to build 7 townhouses at Newland Court garages, planning application reference 22/3124. It has been brought to my attention that out of all the ‘infill’ proposals submitted by Brent Council's agent* on behalf of the Council's New Council Homes Team  not a single one has been refused planning permission and every single one has gone to a planning committee meeting and all have been approved. Can you please confirm if this is correct? 

BAT ACTIVITY AND ROOSTING  

I have been informed by the Bats Conservation Trust that if I think a wildlife crime has been or is being committed I should report it to the police. Once I have done that I have to ensure I get a reference number and then let them know about the incident by emailing investigations@bats.org.uk. They will then be able to assist the police, bat workers, members of the public and professionals by giving advice and information about bats, roosts and the legislation. 

So, as I feel that a crime is about to be committed at Newland Court garages by Brent Council in terms of the removal of trees where at least 2 species of bats are active and may roost, I intend to file a report at Wembley Police Station against Brent Council if the proposal is approved in its present form*. The reason being is that although the ecological report from Waterman’s survey does show two species of bats active along the line of trees, their survey is unreliable, because only one surveyor carried it out, at the wrong time and without covering the line of trees properly. 

         

               

The survey was done more than two weeks after it should have been carried out to check whether there was any bat roost in the garage building they identified as a low possibility roost site. Furthermore, carrying out bat surveys when street lightning could influence an inaccurate reading as bats would only normally be seen in dark conditions as they are sensitive to bright lights. Hence the survey reported a sighting of a soprano pipistrelle that was recorded 28 minutes after sunset and 11 passings of the common pipistrelle were recorded 55 minutes after sunset proving that the whole survey wasn’t conducted properly and therefore unreliable.

 

The same can also be said of the survey on birds. The survey reports sightings of starlings, bullfinches, dunnocks, sparrows and song thrushes. I believe that this is an inaccurate survey recorded as it was taken from a reference grid recorded between 2002 and 2018. If a proper survey was conducted then sightings of robins, magpies, pigeons, crows and even parakeets would also have been sighted and recorded because those are the birds we see out our kitchen windows on a daily basis therefore also acknowledging that the bird survey is also flawed and inaccurate.  

 

 

DESIGN GUIDE

 

In the design guide document which was approved by Planning Committee and Brent's Executive (now Cabinet) in 2013, the boundary shown in the Design Guide, which includes the site of the Newland Court garages within the Barn Hill Conservation Area, must be treated as the correct boundary since 17 June 2013. Yet Brent Council’s agent has submitted a different conservation map boundary showing Newland Court garages outside the conservation boundary lines which is yet more evidence they continued to submit misleading information on their planning application to fast track this proposal through at any cost. * 

 

The evidence is there in the Design Guide itself, which states:

 

'This Guide was produced by the London Borough of Brent and adopted by its Executive on 17 June 2013. On 16 January 2013, the Planning Committee agreed to consult publically on a draft Barn Hill Design Guide which had been prepared in discussion with the Barn Hill Residents Association. Letters were sent to all owner/occupiers in the Barn Hill Conservation Area and Ward Councillors on 28 January 2013, giving 28 days to comment on the draft Design Guide. A ‘drop-in session’ for residents was held at Brent Town Hall on 12 February 2013 to give residents an opportunity to discuss the proposals with Officers. On 17 April 2013 the Planning Committee considered the consultation responses and the resulting proposed changes and agreed that the revised Design Guide be reported to the Executive for adoption.  Executive agreed to this on 17 June 2013.' 

 

 

HERITAGE REPORT submitted by the Heritage Officer states that:-

 

Section 72(1) of the Planning (Listed Building and Conservation Area) Act 1990 (as amended) requires that with respect to any buildings or other land in a conservation area, special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area. NPPF. Paragraph 189 recognises that heritage assets are an irreplaceable resource and seeks to conserve them in a manner appropriate to their significance.

 

This statement reveals reasonable doubt from the Heritage officer in regards to whether this proposal will preserve or enhance the character and appearance of the area. This is also taking into consideration that all the officers’ reports (Heritage, Transport, Tree) have been done on the assumption that Newland Court garages do not fall within the conservation boundary. This is yet another misleading application submission by Brent Council planning officers.

 

TRANSPORT OFFICER

The Transport Officer's report also states that ‘At the current time, the application cannot therefore be supported, given the large volume of parking that would be likely to be displaced from the site onto surrounding narrow streets’. This is even probably after he had seen the parking survey which I have already previously noted as being flawed and misleading.

TREE OFFICER

Even Brent council’s own Tree Officer, Julie Hughes has significant concerns relating to the impact that this development will have on protected trees. She also goes on to say that she has some significant concerns regarding the increased pressure that will be placed on the Council to permit lopping, topping or felling the trees within the rear gardens of Grendon Gardens, and the impact that this will have on both the visual amenity of the local area, and specifically the adjacent Barn Hill Conservation Area.

 

Below is a Topographical Survey map sheet of the coverage area from the canopies of the trees that overhang above the Newland Court garages from the gardens of the residents of Grendon Gardens. They show the extent of the tree canopies of the trees in the back gardens of Grendon Gardens much more clearly than the site plans submitted before to Brent Council. I believe this is the reason why the garages at Newland Court are within the boundary of the Barn Hill Conservation area. The diagram below shows that the canopies and roots of the trees cover most of the garages in Newland Court. It would mean that one half of all the trees would have to be chopped off if this proposal were to go ahead. If this doesn’t kill the trees, then the trees would then need constant pruning and lopping every few months as the pruned branches continue to re-grow.    

 

 

With all these mitigating factors:-

 

• The fact that Brent is breaching a lot of their planning guidelines to fast track this proposal.
• The overlooking rule for one in which you and I measured and found Brent's measurements inaccurate.
• Misleading information on the garages being within the boundary line of Barn Hill Conservation Area
• Unclear clarification of the boundary wall between Grendon Gardens and Newland Court. 
• The removal of or damaging protected healthy trees in the Barn Hill conservation area.
• Misleading information supplied by planning officers on the parking survey.
• Misleading information on the ecological report made by Watermans. 
• The systemic discrimination on existing Newland Court residents.
• The reduction in residual bins for existing Newland Court residents.
• The removal of 40 car parking spaces and reducing it to 12.
• The site not being suitable for the proposed development.
• The Heritage Officer having concerns on this proposal.
• The Transport Officer having concerns on this proposal.
• Brent's Tree Officer having concerns on this proposal. 

 

Even MP Barry Gardiner after seeing the facts and not normally one to get involved in planning issues wrote to the Chief Executive voicing his concerns on the way the planning officers were treating the existing residents of Newland Court over this proposal. With all the objections and facts that you have before you regarding this particular proposal, I’m sorry but there is no way that this planning application should be granted. That is, if every single detail in the form of objections and real facts that you and your team now have before you which should form a serious case for refusal. But if it doesn’t then there is something also very seriously wrong. 

 * Note an earlier version of this blog has been edited to remove inaccuracies in the original email to Brent Council for which Marc Etukudo has apologised.

Guest Post: Biodiversity and geological conservation not taken into consideration in Brent Council's Newland Court infill proposal

 Guest post by Marc Etukudo in a personal capacity

I just been made aware that Brent Council have failed to conduct a SPECIES SURVEY for their  proposal at Newland Court, planning application 22/3124  as numerous habitual wildlife are living in the trees in a conservation area where they intend to remove 13 trees. The numerous species of wildlife includes BATS, MAGPIES, PARAKEETS, ROBINS and even SQUIRRELS. BATS are a protected SPECIES under the wildlife and countryside ACT 1981 and regulations ACT 1994.

 

The Royal Town Planning Institute states that ‘PRE-APPLICATION INFORMATION GATHERING 5.3 Chapter 2 deals with the way that planning authorities can develop and maintain any evidence based upon which to plan for biodiversity and geological conservation. This will supplement the further information required to determine a planning application.’

 

SPECIES SURVEYS 5.10 Many individual wildlife species receive statutory protection under a range of legislative provisions and licences may be needed when they are affected by development. The development control process plays a critical part in ensuring that the statutory protection of species is applied and the Circular sets this out in detail. PPS9 also requires that other species identified as requiring conservation action as species of principal importance for the conservation of biodiversity in England are protected from the adverse effects of development, where appropriate, by using planning conditions or obligations.

 

Bats are a protected species under schedule 5 of the Wildlife and Countryside Act 1981 (as amended) and schedule 2 of the Conservation (Natural Habitats, &c.) Regulations 1994. It is illegal to kill, injure or capture a bat, or to recklessly disturb their roosts.

 

SOME OF THE 13 TREES BRENT COUNCIL WANT TO REMOVE

 

Having read through Brent Council’s planning application that they have submitted I have also found that they have answered numerous questions with misleading answers. I have highlighted them in yellow with comments of what should be the right answers in blue below. (PDF Version HERE)

 

 

 

 

 

 

So as you can see, Brent Council have submitted their planning application with lots of misleading answers. I have raised these same misleading answers and the fact that they are also breaching numerous of their own planning guidance rules to the Brent Council’s planning department. With this and other culminating factors, if this was a private planning application submitted, it would have been rejected, shredded and binned straight away. But it’s not, it is Brent Council’s own application so let’s see what happens.

 

Marc Etukudo

 

 

Barry Gardiner intervenes in Newland Court planning application issues

 

Barry Gardiner has written to Brent Council CEO regarding concerns over the Council's planning application for Newland Court in Wembley Park:

Dear Ms Downs,

 

Our Ref: WL / ZA36316

Newland Court Garages, Forty Avenue, Wembley – Planning Application Reference: 22/3124
Alternative Reference: PP-11328951

 

I write on behalf of a number of constituents regarding their concerns for the planning proposals at Newland Court. I would ask that this correspondence be considered as part of the formal consultation.

 

As you are aware, I do not normally intervene in planning matters unless they have major infrastructure implications or where there is a suggestion that there may have been a failure of process.

 

In the case of Newland Court I refer to Brent’s Responsible Growth Strategy and Borough Plan. They set out a number of themes primarily: affordability, equity, sustainability and inclusivity. I am concerned that these themes may not have been sufficiently considered during the consultation process.

 

The proposed reduction of parking spaces from 40 to 12, will certainly affect the existing residents of the 60 flats at Newland Court.

 

I understand there are at least 5 disabled blue badge users living in Newland Court. It is my understanding that there are no plans to provide disabled parking bays. One of the primary benefits of disabled parking is that it ensures disabled residents have ease of access to their property. I am concerned that the accessibility of Newland Court for disabled residents will be severely restricted. This relates to the principle of inclusivity.

 

Many residents in Newland Court are reliant on vehicles for their work, and their salary does not typically permit a sudden increase in monthly outgoings. I am concerned that there may be significant financial implications for these groups should they be forced to seek parking elsewhere, aside from the inconvenience and impact it will have on their employment. This relates to the principle of affordability.

 

Security has been a long-standing issue at Newland Court and Grendon Gardens, particularly in relation to non-residents using communal areas and engaging in anti-social behaviour. I am concerned that the proposals will encourage greater use of the area and lead to increased problems of unauthorised access impacting on the security of vulnerable residents.

 

I am also informed that there have been long-standing issues at Newland Court and Grendon Gardens regarding refuse collection and that the proposal would reduce the number of refuse bins from 14 to 6. Given that the current bins already regularly overflow residents are unhappy with this aspect of the proposal. This relates to the principle of sustainability.

 

Please advise what weight was given to residents’ concerns in this regard when considering this application and how it conforms to the principles set out in the Borough Plan and Brent’s Responsible Growth Strategy.

 

Thank you for your attention to this matter and I look forward to your response.

 

Yours sincerely,

Barry Gardiner

Member of Parliament for Brent North

 

Another blow for Brent Council's Newland Court in-fill scheme as Brent Transportation recommends 'resistance' to the plans

 Brent Transportation has submitted  comments that support the objections of local Newland Court and  Grendon Gardens residents over the effect of the application on parking. These are some key extracts:

'When coupled with future demand from the proposed houses, it is likely that 31-35 cars would seek parking within the estate. With only 12 spaces proposed, a considerable amount of parking would be displaced onto surrounding streets.'

'The only locations with reasonable parking capacity are Barn Rise and Grendon Gardens, but only limited stretches of these roads are within a 200m walk from the development. As such, there is considered to be insufficient spare on-street capacity to accommodate displaced car parking from this development.'

The conclusion is:

'RECOMMENDATIONS:- This proposal should be resisted as it stands, on the grounds that the development would add to on-street parking demand in an area that is unable to safely accommodate a significant amount parking, to the detriment of on-street parking conditions and contrary to Local Plan Policy BT2.'

This follows critical comments LINK by Julie Hughes, Brent Principal  Trees Officer that also

I have significant concerns relating to the impact that this development will have on protected trees…it is my belief that there will still be a significant amount of pressure on the Council to allow works to lop, top and fell trees which are currently protected by virtue of growing within the Conservation Area boundary, if the proposals go ahead as planned. The current spread of the trees is as would be expected for trees of this maturity, although it is likely that the Lime trees forming G4 and G6 will be re-pollarded at intervals. The construction of these dwellings in such close proximity to these trees is likely to lead to future pressure to lop, top or fell these trees due to concerns from the residents for their safety and for other associated general nuisance issues.

 
The scale of the proposed units is such that there is very minimal useable amenity space most of which will be overhung by tree canopies, as will most of the units.

In summary I have some significant concerns regarding the increased pressure that will be placed on the Council to permit lopping, topping or felling the trees within the rear gardens of Grendon Gardens, and the impact that this will have on both the visual amenity of the local area, and specifically the adjacent Barn Hill Conservation Area,

The full Brent Transportion report  is below:

 

 Philip Grant has been campaigning energetically on this blog and in correspondence with Brent Council for planning applications from the Council itself, to its own Planning Committee, should be treated  with probity and subject to the same scrutiny and standards as applications from external developers.

Newland Court – trees are at the root of Brent’s “infill” scheme problems

 Guest post by Philip Grant in a personal capacity

Diagram showing the general proportions of tree roots to canopy. (Image from the internet)

 

When Martin posted a blog about the Newland Court planning application in September, you could see from the aerial view of the site for Brent’s proposed “infill” houses that they would be very close to a line of trees. 

 

Those trees were in the back gardens of homes in Grendon Gardens, inside the Barn Hill Conservation Area. I added a comment, pointing out that those trees were protected, because they are part of the conservation area’s ‘essential character’, and Martin posted that as a separate item of useful information for Grendon Gardens residents. 

 

Residents with trees in their gardens bordering the Newland Court site were advised to contact Brent’s Tree Protection Officer, Julie Hughes. She has submitted her comments on planning application 22/3124, and these begin by saying: ‘I have significant concerns relating to the impact that this development will have on protected trees.’ Her comments, which were only made public three weeks after she’d made them, conclude:

 

Final paragraph of Brent’s Principal Tree Officer on Brent’s Newland Court application.

 

I will ask Martin to attach a full copy of those comments below, along with a document copy of the objection comments which I’ve submitted. These also deal mainly with the harm which the planning application would do to the protected trees in the Barn Hill Conservation Area, if it were to be approved.

 

The Principal Tree Officer’s comments concentrate mainly on the tree canopies, the branches and leaves. Because the site of the existing garages at Newland Court is so narrow, the houses which the Council wants to build there would need most of the overhanging branches of these protected off-site trees to be cut off. The branches would, if such severe lopping did not kill the trees, grow back again, and so would need frequent cutting back, to stop them blocking the light to rear windows. 

 

The extent of existing protected tree canopies, marked on a plan of the proposed new homes.

 

Because there were trees on and adjacent to the site, the planning application had to be supported by an Arboricultural Impact Assessment (“AIA”). This was prepared for Brent Council by Watermans. When I read this document, one short extract about the trees along the southern edge of the conservation area stuck in my mind:

 

‘… it is considered that their roots are unlikely to have extended below the existing retaining wall which forms the northern boundary of the Site. It is therefore considered that they are unaffected by the development proposals.’

 

I don’t claim to be an expert on trees, but you don’t have to be one to know that where a tree has a canopy above ground, it is likely to have roots in the ground below that canopy! [See the diagram above.] It is very convenient for the Council’s plans to assume that there would be no roots from the protected trees where you want to dig foundations and build houses. But how likely is it that a brick wall would prevent all tree roots from growing beyond ‘the northern boundary of the Site’?

 

Luckily, I remembered a similar situation which occurred as part of the Morland Gardens planning application, where there were trees in a next-door garden, just beyond a retaining wall which marked the site boundary. In that case, the AIA included the results of a ground penetrating radar survey. This discovered that tree roots did extend below the wall:

 

‘The scan line results showed that the off-site trees are rooting within the site, but that the physical barrier of the retaining wall and its footings has provided a partial barrier to root encroachment.’

 

That evidence (rather than the “convenient” assumption by the authors of the Newland Court AIA) meant that the building plans at Morland Gardens had to include a two metre wide tree protection strip, inside the site boundary, where no construction was allowed. But the Newland Court site is so narrow that some of the proposed new houses have walls only 50cm from the boundary. These would cut through both the support and feeder roots of protected trees.

 

On the evidence in my objection comments, it would not be possible to build six of the seven houses without seriously harming, or killing off, both the canopies and the roots of protected trees in the Barn Hill Conservation Area. I’ve sent a copy of my comments document to Brent’s Principal Tree Officer, and asked her to consider it and give her response to Brent’s Planning Officers (as well as to me).

 

If I’m correct, then this planning application should be refused (and there are plenty of other reasons put forward by local residents which also justify its refusal). This is a Brent Council application, but that should not make a difference. 

 

Regular readers of “Wembley Matters” will know of my recent battle with the Council over another “infill” scheme at Rokesby Place, and my insistence that Brent’s Planning Officers must be seen to uphold the Local Government Association’s “Probity in Planning” rules:

 

‘Proposals for a Council’s own development should be treated with the same transparency and impartiality as those of private developers.’

 

Would Brent allow an application by a private developer to build houses so close to a conservation area that it damaged or killed protected trees? I doubt it!

Philip Grant.

 Philip Grant's Objection

 

 

Brent Tree Officer's Report 

 

Allegations of misleading information in Newland Court Planning Statement

Following what he sees as unsatisfactory answers to his questions at the Full Meeting of Brent Council, Marc Etukudo has returned to the fray with a comprehensive email to Brent planners citing what he alleges is misinformation in the Planning Statement prepared by Maddox Planning on behalf of Brent Council as the applicant. I have edited the email  to conform with editorial requirements - words in []:

The residents of both Newland Court and Grendon Gardens first found out of Brent Council's proposal to build 7 town houses by demolishing the garages in Newland Court for the very first time in late June 2022 and only gave us until 13th July 2022 to respond to the newsletter. Only because of this proposal has made me investigate the way LABOUR RUN BRENT COUNCIL operates and I am totally appalled with my findings. They tell their own residents across the borough what they think we want to hear and then do what they want to do when it suits them.

 

I have just been reading the Planning Statement from Maddox Planning dated September 2022 and have found out that these plans were first made in 2020 yet we only found out late June 2022.

 

On page 9 Community Engagement 2.6 it states.....

 

'The Community Communications Partnership, acting on behalf of the London Borough of Brent, carried out a communication consultation programme. A newsletter that included details of the proposed development was delivered to neighbours of the site. The newsletter was accompanied by a feedback form for residents to complete if unable to access the internet. Alongside the newsletter an online consultation was created on Brent Council’s Public Participation Platform (https://haveyoursay.brent.gov.uk) that hosted a PDF version of the newsletter that was delivered and the feedback form as a survey to be completed. Additionally, a virtual exhibition video was included on the online consultation that provided residents with a narrated video tour of the site and plans. The consultation has received 42 responses with the majority if residents expressing support for the proposed development'  

 

[Misinformation]. The communication consultation programme was completely flawed. They made sure that not everybody received the newsletters by delivering them to every other flat in Newland Court and to only a few houses in Grendon Gardens. I know this for a fact because a neighbour and I went to every flat continuously to get signatures for a petition and found out that some flats never received the newsletters. We also got signatures for our petition from the affected houses on Grendon Gardens and all the residents there except one were against this proposal. At Newland Court, 4 were not bothered, 1 said they supported it and 5 did not want to know since they were renting and said it was the leaseholders responsibility. We got about 55 valid signatures (since Brent is saying more than one objection from one household counts as one) from Newland Court and Grendon Gardens, so for Brent to say that they

received 42 responses from residents expressing support for this development is [Misinformation]!!!!! 

 

 On page 13, Loss of garages and principle of residential development 4.6 it states.....

 

'With regards to the loss of the garages, the majority of these are all vacant and underutilised. None of these garages are currently being used for car parking. As such, there will be no loss of car parking as a result of the demolition of the existing garages'. 

 

[Misinformation]. 3 garages are still being used for cars and rent is still being paid for them. One is used by a disabled badge holder who is so upset about this proposal and wants to know where she is going to park her car when the garages are pulled down . She claims a council vehicle reversed into her garage a few years ago damaging the door and roof. She had to wait 3 months for the council to repair the damage to  the door and roof and it was when the roof was being replaced that she discovered that all the garage roofs had asbestos. Less than a year later she contracted lung cancer and now only has one lung. She couldn't prove it was the asbestos from her garage so took no action.

 

 On page 14, Quality of Accommodation 4.20 it states that..... 

 

London Plan policy D6 states that housing developments should be of high quality design and provide adequately-sized rooms with comfortable and functional layouts which are fit for purpose. 

 

On page 15, Quality of Accommodation 4.22 it states..... 

 

Policy BH13 requires all new dwellings to have external private amenity space of a sufficient size and type to satisfy its proposed residents’ needs. This is normally expected to be 50sqm per home for family housing (3 bedrooms or more) situated at ground floor level and 20 sqm for all other housing. 

 

House 2 (3B5P) will have an amenity space of 41.6 sqm.

House 5 (3B5P) will have an amenity space of only 32.1 sqm.

House 6 (3B5P) will have an amenity space of 48 sqm.

 

The other houses, 3 and 4 will house up to 7 people. The size of these houses in the tiny plot of land with little amenity space and not fit for purpose.

 

How can Brent Council justify cramming families like tinned sardines in such a crammed site. At least 35+ people in 7 tiny houses.

 

 On page 16 of Neighbouring Amenity 4.29 it states....

 

The guidance states that directly facing habitable room windows will normally require a minimum separation distance of 18m, except where the existing character of the area varies from this. A distance of 9m should be kept between gardens and habitable rooms or balconies. Reduced distances between new frontages may be acceptable subject to consideration of overlooking and privacy as well as high quality design and solutions which can sometimes mitigate impacts and allow for efficient use of land.  

 

It says 'Reduced distances between new frontages may be acceptable subject to consideration of overlooking and privacy'. 

 

No consideration has been taken towards the existing residents of Newland Court as the 18m overlooking rule has been halved, yes halved. Brent Council's new plans states the overlooking distance is 10m but we have measured several times and the 2 angled out buildings that are closest to the new houses measure

8m and 9m from the windows. Do you know how close and imposing the proximity of these new houses are going to be???

 

In my previous emails to you I have highlighted the issues with...

 

PARKING

TREES
BINS 

 

I would now like to raise a point you highlighted in a letter to Mr. T Ghani who was the project manager then dated 31/07/20 where you pointed out....

 

REF: 20/0131/PRE Pre-application Consultation

 

In line with the Council's Statement of Community Involvement, we would encourage you to engage in preapplication consultation with the local community. This is recommended to be in the form of discussing the proposal with neighbours and other nearby occupiers/owners of properties/land / local interest groups. 

 

Equalities

 

In line with the Public Sector Equality Duty, the Council must have due regard to the need to eliminate discrimination and advance equality of opportunity, as set out in section 149 of the Equality Act 2010.

 

The plans for the 'infill' of 7 TINY new houses in Newland Court were made since 2020 yet the first we ever heard about it was the end of June 2022. Brent Council have shown nothing but Systemic discrimination towards the residents of Newland Court over their proposed ‘infill’ plans of building 7 TINY town houses by demolishing the garages at Newland Court. They have shown no empathy, been dismissive and ignored our thoughts and feelings to go ahead with this ‘infill’ contributing to a less favourable outcome for the residents (especially the elderly and disabled) of Newland Court who they are treating like nobodies or a minority group.

 

With all the points I have raised above, the fact that there have been lots of misleading factors from Brent Council and the fact that if they are granted  permission to go ahead with these plans. I am sure they will just keep moving the post to suit them at the detriment of the existing residents of Newland

Court and I plead with you not to approve this planning application.

Yours Sincerely,

Marc Etukudo

Newland Court.

Forty Avenue. HA9 9LZ.