Claimed improvements to original plan
The Sudbury Court Residents Association have added several further submissions to the Brent Council Portal on the Mumbai Junction (formerly John Lyon pub) site planning application.
This morning the total number of comments, mainly objections, stood at 546.
This is a follow up
objection by the SCRA as the documents and reports have altered since the
Consultation Period closed.
The SCRA believe and demand that this application is refused at the next
Planning Committee Meeting and not deferred any longer because of the following
reasons, but not excluding many other valid reasons previously articulated to
the Planning Department:
The current building design, materials and finishes matched the Conservation
Area properties across the road and can be seen from Carlton Avenue West, The
Crescent, Watford Road and Pasture Road, well over twenty properties within the
Conservation Area will be able to plainly see this development from their
homes. For some reason that remains unexplained the Brent Heritage Officer has
changed his view from it damaging the Gateway to the Conservation Area, to not
doing so and not being visible from the Conservation Area which is clearly
untrue. Meanwhile 266 Watford Road's red roof tiles as a replacement for the
original green tiles are being enforced against as it damages the Conservation
Area.
The applicant states in mitigation of the size and massing that the
representations of the proposed building allow for 10 years growth of the
surrounding trees. The surrounding trees are approaching 100 years in age, the
majority having reached maturity and will not increase in size. The out of character
building will not be hidden by trees.
The officers state that the benefit of the building somehow out ways the damage
caused by is height and massing along with it being out of character. This is
the view of some planning officers; however, several hundred residents disagree
with them along with the SCRA who represent circa 3,000 homes. Officers should
reread the Local Plan 6.5.22
Although not a Planning Issue as such there is a large telecom installation in
front of the site. Recently trees in front of the site were substantially
pollarded, the reason used to gain Council approval was that the trees were
affecting the Emergency Telecom signals from the installation. The proposed
building is substantially higher and the top two storeys appear to be clad in
metal which would almost certainly interrupt the Emergency telecom signals.
Page 11 para 5 of the officers committee report attempts to justify the extreme
massing and height because it is near a roundabout, but totally ignores the
surroundings of mainly two store buildings, many now known to be within the
Conservation Area (evidence can be provide on the ground and from Streetview
and Google Earth. The Design Council's workshop with the Developer and Brent
Council stated the building was far too large for the site and would not meet
carbon targets, nor transport emission targets. Interestingly almost all the
objections to the proposal consider the proposal to be too tall and bulky.
The Officers state: The building is of good design quality, relating well to
its context and would enhance the character and appearance of the surrounding
area. Unfortunately the are at complete odds with local residents on this point
as the building is totally out of character and belongs with buildings of a
similar bland design tenet and not in the midst of Metroland.
Officers state that there will be no loss of amenity to surrounding properties;
however, all residents surrounding the site strongly disagree and will have to
provide themselves with forms of shielding to regain their privacy and amenity.
The Met Police were consulted and recommended not using on street parking
because of the friction that would be created with other users of the service
roads and surrounding residential streets. Basically, the officer is saying
that the Design Council and Police are wrong! Additionally, it has not been
proven that there is available parking other than after 2am in the morning.
Page 13 para 1 Highways state that "All servicing arrangements are
acceptable and safe" This statement is completely unfounded as there are
no servicing arrangements on site; all forty two flats will have to be serviced
from the busy and the constantly heavily parked service road as the onsite
service road is now to be a car park. Furthermore, the bin store opens out
across the very narrow pavement in front of the site, itself an illegal
obstacle and in addition it would open onto the designated as the unmanaged
pedestrian crossing, and the proposed Zebra Crossing funded by a S106. One
wonders if officers actually visited the site or fully deciphered the plans
presented to them.
The EMF Report regarding the Sub-station is so porous it should be ignored as
meaningless. SCRA extrapolations show the EMF levels to be outside the SAGE recommended
levels even without being monitored under peak loads which are normally
expected in the mornings and evenings. Variations in EMF reading already
provided to Planning Comments show a 1446% variation in EMF emissions outside
of peak loads.
Ignoring the wildlife corridor running at the rear of Sudbury Court Drive and
Amery Road which joins the SINC of Harrow School and Northwick Park is
unforgivable even if it is not a designated wildlife protected area. No
bat survey has been completed regarding this foraging and commuting route and
therefore the law protecting bats may well be breached if the development is
allowed with its current height and massing along with substantial increase in
light levels. It is the Council's duty to ensure that the bat
foraging/commuting route is protected. There is no doubt that bats utilise the
current restaurant's kitchen warmth as an adhoc and winter roost which would
not have been noticed during the internal inspection.
Sudbury Court Drive and the John Lyon roundabout had been flooding for several
years after and during heavy rainfall a video is available. The manhole cover
near Bengeworth Road is ejected due to the large volumes of water travelling at
speed down the hill of Sudbury Court Drive and Bengeworth Road. It is becoming
obvious that the surface water drain is now overloaded at peak times, possibly
due to all the recent explosion of property extensions and paving of gardens to
provide parking due to the very heavy on street parking demand. The proposed building
would require a flood defence and a substantial SUDS to reduce the flood risk
to the ground floor flats, some of which are deemed accessible.
Page 13 para 3 Of the fire statement states: "All floors are served
by a central protected stair including an evacuation lift. The stair is
accessed by common corridors that do not exceed 15m in length."
Unfortunately the distance from the front doors of flats 1.06, 1.07,
2.06, 2.07, 3.06 and 3.07 are in excess of 18mtrs from the protected stairwell
and therefore the building does not comply with London Plan Policy D5(B5) (7),
BS9991 (6), ADB 2019 (3).
London Fire Brigade Guidance Notes GN29 - should be used to plan for new
premises. As the proposed development site sits behind a narrow heavily parked
service road and a large telecom site it has a very limited access for Fire
Brigade vehicles and therefore does not comply with the GN29 guidance
notes. Furthermore, as the frontage of the building (within its
curtilage) has now been turned from an access/service road into a car park the
Fire Brigade would have to access the building from the external service road
which is, because of the afore mentioned problems, is an impossibility. The
SCRA therefore believe that the proposed building with regards Fire Safety is
unsafe and dangerous.
The Highways Officer's report state that the area is not an accident hotspot
because very little is recorded on Crashmap. Everyone knows that many accidents
are not shown on Crashmap and to utilise its data id just lazy. The Crashmap
data does not mean that the area is not a black spot. In the real world -
during the last twelve months there have been circa 12 single vehicle RTAs
within the locale, with several gardens being entered, bus stops and pedestrian
crossings demolished along with street trees. Utilising Streetmap we have found
evidence of many accidents on the John Lyon Roundabout over the last ten years
including the felling of a substantial tree, a lamp post and several road signs
demolished. On at least two occasions vehicles have been overturned and left
blocking the pavements. Not more than a hundred yards away a lady was killed
performing at right turn at the junction with The Green. The local chemist was
attempting a right turn into their driveway on Watford Road just in front of
the application site and has hit in the rear and pushed across the road and hit
again in the front. The son of the local garage operator was involved in a
collision on the service road at the entrance to the application site, besides
being a dangerous cross road the concrete of the service road offers no grip in
the wet. Without doubt this is not a safe area for motor vehicles
handling as it does 30,000 VPD on the A404 a London Distributor Road and 15,000
VPD on the A4127 a Local Distributor Road, one must not forget that the service
road is used as a rat run to avoid queues at the John Lyon roundabout.
The SCRA are extremely concerned that staff at local businesses have been told
by the owners of Mumbai Junction that they will get Planning Permission is very
concerning, especially as the Developer met with the Leader of the Council and
the Cabinet Member for Regeneration and the Planning Committee privately while
residents were not allowed to approach the Planning Committee themselves.
The SCRA are also concerned at the lack of affordable housing on site nor a
contribution to affordable housing. We suggest if the building were reduced to
say three stories then the margins per unit and viability would increase due to
lower building costs at these lower levels, this would obviously be at the
expense of the overall profit to the Developers.
The Planning Committee Report
dated 12th July Page 9 para 2 states "The refuse storage area would be
sited to the property's frontage"
We would comment as follows:
Having referred to the plans, the refuse store gates open outward across the
narrow pavement (highway) at the site of the current unregulated crossing of
the service road and Watford Road.
Obviously this is totally unacceptable positioning and function and the use of
the gates would block the Highway - The fundamental public right upon a highway
is to pass and re-pass, and the obstruction of a highway can also be a criminal
offence as well as a tort. Highway authorities are under a statutory duty to
prevent, so far as possible, the stopping up or obstruction of highways in
their areas.
This is an additional objection by the SCRA having
reviewed the revised documents published after the end of the Formal
Consultation by the applicant and the planning officer.
The Planning Committee Report dated 12th July and the Daylight Sunlight
Consulting letter.
9. Page 11 para 6 This statement about good levels of outlook and light are at
complete odds with the letter from Daylight Sunlight Consulting Ltd that states
that not all the properties have sufficient light. The Design Council stated
that the health and wellbeing of residents will be harmed by the long corridors
without any natural light or ventilation. Additionally, nearly half the flats
are only single aspect and at least three of the flats will have very little
natural light to the living area windows as the windows are positioned in
corners on the northwest side of the building and have very poor outlooks over
the car park and garage next door.
It is with great disappointment
that we have to yet again point out that the EMF report applies to the current
substation and not the new/replacement one mentioned in the previous officer
report.
Additionally no mention has been made about the emergency telecom signals from
in front of the site which required the pollarding of trees which were half the
hight of the proposed building.
We residents within the SCRA despair at the lack of meaningful consultation
over our valid concerns and the council's total intransigence regarding this
application. Several residents have put their properties up for sale this month
already as the believe this is a done deal.
The current EMF Report
describes the current substation and current usage and emissions from the Sub
Station. Unfortunately, as detailed in the Officer Report to Committee it
transpires that the substation will need upgrading due to the application
property and no doubt for the adjoining site which according to the report will
be subject of a future planning application.
It is therefore true to say that the current EMF report will not apply to the
proposed building and therefore we must be sure that the future substation does
not put residents at a high risk of developing leukaemia from the emissions of
the new substation for which there is NO report.
The current substation apparently has negligible risk, presumably an
enlargement of the substation could well increase the risk to low or medium. We therefore recommend
that this application is not determined until a new report is produced which
includes a substantial increase in power usage. To ignore this request could
potentially and knowingly put people’s lives and well-being at risk well into
the future.
