Stonebridge Park tower blocks at Brent Planning tomorrow as flood issues highlighted by current events

 The proposed developments at the corner of Harrow Road/North Circular (Wembley side)

 

Videos of the weekend floods included one of partially submerged uncompleted new homes on a flood site. As readers know there was flooding at Stonebridge Park and Tokyngton Avenue earlier this year when the Wembley Brook was blocked by preparation work on the new Argenta House site. This week an application goes to Planning Committee for two more tower blocks to sit alongside Argenta 26 storeys and Wem Tower (aka Wembley Point, The Wem)  21 storeys. These will be 32 storeys and 20 storeys on a relative small site where the Wembley Brook joins the River Brent, close to the North Circular Road.

The application will be considreed by Brent Planning Committee tomorrow. Watch live from 6pm HERE,

 

 

The Flood Risk Assessment for the site includes illustrations that indicate the level of possible flooding from fluvial (rivers) and surface water.

As the amount of flooding and extreme weather events is accelerating faster than expected it is possible that at some point in the future all these buildings will be surrounded by water for a time.  The buidlings will be designed to be 'floodable' and plans will have to be put in place for evacuation of residents and workers (my highlighting):

 

Flood warning/evacuation plan

 

207. The EA have advised that ideally, applicants should demonstrate a new development

has a safe, dry access/egress route during a 1% annual probability flood event, including an

allowance for climate change, or else a route with a 'very low' hazard rating in accordance with FD2320: Flood Risk Assessment Guidance for New Development. In situations where it's not possible to ensure dry access/egress routes, consideration may be given if it can be demonstrated that proposed 'wet' routes still remain safe for site users.

 

208. The development at Wembley Point does not have a means of dry access/egress during the design flood event. The applicant has submitted a Flood Warning and Evacuation Plan (Pell Frischmann, Ref. 102139-PF-ZZ-ZZ-RP-D-0003, dated 24/04/2023). This highlights that as noted in the SFRA Level 2, under the 1% (1 in 100) AEP plus 35% climate the whole site is submerged. The latest modelling shows that during a 1% AEP flood event plus climate change the depth of flooding across the site is circa 600 mm and the expected velocity is circa 0.98 m/s. The deep, fast flowing water means the post development flood hazard rating for the site is shown to be predominantly "Danger to Most". This means that safe access/egress route cannot be guaranteed during a flood event.

 

209. The Flood Warning and Evacuation Plan has set out that when it is possible to evacuate the site, the evacuation procedure would be signalised via an alarm system for the shared and public areas, and the Flood Warnings Direct service for those in individual properties. The preferred evacuation procedure all residents, workers and visitors would be to leave the site and seek refuge outside on higher ground. The evacuation route would be to exit the site via the north-western access on Point Place and then head north-eastly towards Harrow Road. Higher ground to the north can then be accessed via Harrow Road.

 

210. If the site cannot be fully evacuated or in the case of sudden inundation associated with catastrophic failure of the Brent Reservoir, refuge should be provided on site, The site comprises of multi-story floor levels, where the upper floor levels of the building will count as primary areas of refuge. Following this, they should then wait for the flood waters to recede or until emergency services direct otherwise. The development deploys a water entry strategy, allowing water to enter the majority of the ground floor of the proposed buildings, therefore safe refuge must be sought on the upper floors.

 

211. The proposed evacuation route from the ground floor, through internal stairwells, to the first floor.  Following the instruction to evacuate, there are various locations of refuge that all residents, workers and pedestrians could use in the event of a flood. The site comprises of multi-story floor levels, where the upper floor levels of the building will count as primary areas of refuge, these can be accessed through the internal stairwell. If people are seeking refuge in the upper floors, they should wait for the flood waters to recede or until emergency services direct otherwise.

It does make you wonder about the wisdom of building here at all despite assurances that measures will be put in place. Perhaps the development should be renamed 'Stonebridge-on-Brent'.

Aside from all this the developer has returned with a lower amount of 'affordable' housing than in the initial application. The percentage now with the previous application in brackets:

Of the 515 units:

Private 77.5% (65.8%)

London Shared Ownership 8.3%  (11.1%)

London Affordable Rent 14.2% (23.1%)

Officers support the developer's viability assessment provided for the change.

There are many objections to the scheme on the Brent Planning Portal. many of them coming from occupants of the Wem Tower who claim that they have no prior warning of the massive development that will take place on their doorstep - although it has to be noted that there is one occupant who has submitted a long statement in support of the scheme.

Other objections come from the nearby two storey housing that will by overshadowed to the north of the development in Derek Avenue and Tokyngton Avenue.   

The application includes landscaping and minor play provision on the site opening up the site to the public.

The report considers concerns that the new development will spoil the views of the Brent Railway Stonebridge Viaduct:

The [Heritage] assessment notes that the development will be visible in the background when viewing [The Brent Railway Viaduct], but also noting that the existing Wembley Point building is also within that view. The heritage assessment sets out that while there would be some visual intrusion into the extended setting of the viaduct, that this is considered to cause a low, minor level of harm which would be "less than substantial" to the setting and significance of this heritage asset. Officers agree that the degree of change and harm would be limited, and consider that this would be "less than substantial". It is considered that this harm is significantly outweighed by the benefits of the scheme which include the provision of homes (including Affordable Homes), new publicly accessible space and routes and significant improvements to the local streetscape and environment

One interesting aspect of the proposal is the provision of a 3 storey building to be occupied by Stonebridge Boxing Club, who have popped up in several planning applications.

 

 

 

The application is deficient in several respects as planning officers acknowledge in making their recommendation to councillors that it should nonetheless be approved. The familiar mantra that the 'benefits outweigh the harm' is used again:

The proposal is considered to accord with the development plan when read as a whole. There are some divergences from policy (such as the amount of external amenity and play space), and some impacts that go beyond guidance levels (such as the light received by some properties) and the proposal will result in "less than substantial" harm to one designated heritage asset. However, the benefits of the scheme are considered to significantly outweigh the harm. It is recommended that the planning committee resolve to grant permission subject to the stage 2 referral to the Mayor of London, the completion of a legal agreement as set out above and subject to the conditions listed.

1 Morland Gardens planning application – how significant is “significance”?

Guest blog by Philip Grant, in a personal capacity

Back in February, I first wrote about the 1 Morland Gardens planning application (Housing or Heritage? Or both?), under which Brent Council propose to demolish a locally listed Victorian villa in Stonebridge, to build a new adult education college and 65 affordable homes on the site.

2 Morland Gardens (not No. 1) - this is the "twin" Victorian villa. (Photo by Harry Brown)

Because of some defects in the original application, identified from “consultee comments”, a new batch of plans and documents has recently been submitted. Public consultation is now open again on application 20/0345, until Thursday 16 July. One of the new documents is a Heritage Impact Assessment (“HIA”) [see copy below], and this is what raises the important question in my title.

Locally listed buildings are those which have been identified by a Council as “heritage assets”.  “Significance” for planning purposes is defined as: “The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic.”

Brent’s planning policies (like national ones, and the London Plan), acknowledge the importance of heritage assets, and set out how they should be protected when there are any proposals affecting them. The policy states: ‘The council will resist significant harm to or loss of heritage assets.’ Anyone considering a development should start with ‘an understanding of the architectural or historic significance of the heritage asset and its wider context.’

 

Brent Council is capable of doing this, as the current application for the locally listed Clock Cottage at Kenton Grange shows. Those plans conserve the old cottage, while building assisted-living flats for disabled people around a courtyard (former stables) behind it. Unfortunately, whoever was giving planning advice, to the Council Officers / Lead Member for the 1 Morland Gardens scheme, either did not understand the policies over heritage assets, or thought they could be ignored (because it was a Council scheme, Planning Committee would “rubber stamp” it?).

When the original application was submitted in February, Brent's planning agents claimed that the locally listed Victorian villa had 'minimal significance', without providing much evidence to support that, and ignoring existing evidence (such as Brent's existing local listing assessment, which gave it a significance score of 8 out of 12). Local historians knew this was nonsense, and launched a campaign to save the building (originally known as “Altamira”)’. Their petition, asking the Council not to demolish the building, achieved 368 signatures.

Cutting from the "Brent & Kilburn Times", 5 March 2020.

I submitted my objection comments in early March, explaining in detail why the application’s assessment of heritage significance was false, and recommending that Planning Officers should advise their Council colleagues to withdraw the application. This appeared to have no effect.

In April, a copy of the comments on the application by Brent's Principal Heritage Officer was obtained. He said that 1 Morland Gardens 'should be considered an important local heritage asset of high significance.' He also pointed out that the applicants (Brent Council) had not provided a proper appraisal of the heritage asset, and the impact of their proposals on it, as required by Brent's own planning policies, and said 'the applicants should seek further advice from a heritage specialist to gather further evidence in support of this application.'

The June 2020 HIA is in response to the Principal Heritage Officer’s comments. The document was prepared on the Council's behalf by Messrs Lichfields, who describe themselves as 'the pre-eminent planning and development consultancy in the UK.' Lichfields report was prepared by heritage specialists, but they were aware why their client (planning agents, acting on behalf of Brent Council) needed that report, at such a late stage in the planning process - to support their planned demolition of the building!

In the introduction to their report, Lichfields make clear that: 'The overview of the significance of the heritage assets has been undertaken using a combination of desk-based study and archival research.' They go on to say that: 'Fieldwork was not possible due to the current Covid-19 situation.' In other words, they only looked at a limited number of documents, and did not come to look at the building, its setting or the surrounding area. 

Despite the limited material available to them, they reached the conclusion: 'the building is of low significance’. Explaining how they reached this conclusion, their report says: ‘The methodology for our assessment of significance draws from the NPPF, HE’s Conservation Principles and the DMRB.’ The table they show for the criteria used is taken from the DMRB, and their conclusion is also: ‘In summary and according to DMRB significance criteria (set out in Section 1), the building is of low significance as it is of low historic and architectural importance and of local interest only.’ 

DMRB? No, I hadn’t heard of it either. It is actually the Design Manual for Roads and Bridges, issued by Highways England in 2019, as guidance for designing national infrastructure projects such as trunk roads and motorways. Your guess, as to why the HIA used those criteria, may be similar to mine – to get the “right” result for their client! Why not use Brent’s own significance scoring criteria for locally listed buildings, which was adopted by the Council’s Planning Committee in July 2015?

The HIA does refer to that system, claiming that the significance score for 1 Morland Gardens should be 6 out of 12, rather than the 8 out of 12 given to it for its entry in Brent’s local list. I will explain why I believe they are wrong.

One of the “sources” their desk-based assessment used for considering the historic development of the area was a “Brief History of Stonebridge”, produced by the Grange Museum and Brent Archives. The author of that booklet has already submitted an objection comment, pointing out that a quotation used from it was taken out of context. The HIA had used ‘it was never as grandiose as its planners had originally intended’ to play down the importance of the 1876 Stonebridge Park development. The author had actually compared the smart villas built to the scene originally envisaged in a lithograph by the architect.

H.E. Kendall Junior's lithograph of his proposed estate development, c.1872. (Brent Archives image 1776)

The HIA devotes just eight lines to assessing the historic significance of 1 Morland Gardens, before marking down its score to just 1 out of 3. The author of the booklet, who became an expert on the local history of Brent in his 17 years at our Museum and Archives, has made clear that this assessment is totally flawed. Its key statements are that Stonebridge Park ‘was typical of the late-19th century suburban expansion of London,’ and that ‘1 Morland Gardens is not a rare survival, but typical of the eclectic late-Victorian villas seen across Brent. Therefore, the historic significance of the building is considered to be lower than originally assessed, scoring 1/3.' 

The entrance to Stonebridge Park from Hillside, c.1905. (Brent Archives online image 7914)

 

The 1876 development, was the first housing development in this part of Willesden, and gave its name to the Stonebridge Park area. It was built when Willesden’s population was around 25,000, before the massive late-Victorian influx that saw most of the area’s mainly working-class housing constructed, and the population rise to 114,000 by 1901. Added to this, 1 and 2 Morland Gardens are the only two surviving Italianate-style villas in Brent, so they are rare survivals. Any change to the existing historic significance score should be up to 3/3, not down to 1/3.

 1 and 2 Morland Gardens from Hillside, February 2020.

The other significance criteria that the HIA seeks to mark the building down on is its authenticity.

Because it ceased to be a private house 100 years ago, and has undergone internal alterations several times since then, Lichfields argue that the building is ‘much altered’, and therefore only worth 1/3. But the alterations had already been taken into account when Brent scored it 2 out of 3. It is the authentic Victorian outside appearance of the villa, in its setting with the similarly styled 2 Morland Gardens, which has hardly changed since they were built, which makes them so valuable and significant. Just compare the two views above, taken 115 years apart!

If you agree that the Victorian villa at 1 Morland Gardens has a high significance, not a low one, and that it still has value to this and future generations, then I hope you will help to persuade Brent Council that it should not be demolished. The planning application, 20/0345, is open for public consultation again, and you can submit your comments (hopefully objecting to the plans to demolish “Altamira”) on the planning website . 

Significance is significant. We can try to ensure that the true significance of this building is what decides the planning application, not the false appraisal of it presented in the Heritage Impact Assessment!

Philip Grant.

THE HERITAGE IMPACT ASSESSMENT

Public Square section of £17.8m Pedway deal goes through plus estate 'in-fill' housing

It was the first meeting of the new Planning Committee yesterday evening. Members not only had to cope with hefty agenda papers but a detailed late Supplementary Report on several of the items.  Committee Chair Cllr James Denselow pointed out that most of them were new to the job and it was clear throughout the meeting that he was heavily dependent on planning officer David Glover who sat next to him and the pair were regularly engaged in urgent conversation while the meeting went on around them.

Old hands Cllr Maurice (Conservative) and Cllr Colacicco are still on the committee. Of the newcomers Cllr Abdi, Hylton and Sangani were most vocal and Cllr Johnson as vice chair made some useful interventions.

The most far reaching proposal was left until last when most of the public attending had gone home.  This is the proposal for a new public square with colonnade and canopy beside the Civic Centre that Brent Council sought to gain from using £17.8m of Community Infrastructure Levy for changes to the public realm on Olympic Way.  The overall scheme  includes the replacement of the stadium pedway by steps - a matter barely mentioned last night as it will involve a separate application. The proposal involves modifications of the outline planning permission that had already been granted to Quintain for a building on Plot NW04 and the scheme approved last night is dependent on the removal of the pedway.

It was interesting that in the earlier discussion about the Ark Somerville primary school the impression was given that the granting of outline permission earlier for the wider area, but including the school, was pretty well set in stone and could not be changed.

The public were there for much smaller schemes but ones that directly impacted on their homes  and lives in different neighbourhoods.  The proposals were part of the 'in-fill' of estates to provide more 'affordable homes' and affected Kings Drive in Wembley, Carlyon Close in Alperton and Stonebridge Park.  In each  case residents protested loss of amenity - for Kings Drive, parking spaces; Carlyon Close opening up the quiet close to through pedestrian traffic; and Stonebridge Park the impact on green space.

Denselow throughout the meeting kept emphasising that the Council had to meet the target of building 9,000 new homes by 2028 and it was not surprising that all the applications were approved. The loss of amenity for current residents was out balanced by the provision of new homes.

However it was good to see the definition of 'affordable' questioned and the committee were told that this was 80% of market rent (rather than the Mayor's London Living Rent) though that might be reduced for tenants nominated by the Council.  I hope that committee members will continue to plug away on this when Quintain puts in more applications as the assumption appears to be that the 9,000 will help cut Brent's 4,000 strong waiting list - not at 80% of market rent it won't.

The effectiveness of the planning department's consultation and communication with residents came up several times and this desreves further consideration. Residents' accounts of the consultation process suggested major improvement is needed.

Brent Council closes down Wembley Market's temporary site

The original market (Image: wembley.blogontheblock.com)

Brent Council served a 'stop' notice on Wembley Market yesterday which looks as if it spells the ending of the market for good.

The market had shifted to the Unisys building at Stonebridge Park after losing its Wembley Stadium site because the Council thought it would undermine the London Designer Outlet. There are plans to replace it with a more upmarket 'artisan' market.

Wendy Markets had submitted a planning application to regularise the Stonebridge Park site but the stop notice has been served before that can be heard. Wendy Markets face a £20,000 fine if they don't comply so the market of some 100 stalls will not operate this Sunday. Brent Council claimed there had been complaints about the market according to Get West London LINK