Wembley Park Station car park – a TALL story

Guest post by Philip Grant. This planning application will be decided by Brent Planning Committee tomorrow, Thursday November 26th. The meeting starts at 6pm and can be viewed HERE

 

Elevation drawing from the planning application with heights added

What is a tall building? For Brent planning purposes it’s one that is more than 30 metres in height (ten storeys), or more than 6 metres above the general prevailing heights of the surrounding area.

The proposed Barratt London / TfL development which Planning Committee will consider tomorrow evening (Thursday 26 November, 6pm) is definitely a tall building (or five of them). You can see more pictures of this planning application in Martin’s 2 November blog.

 

Brent’s Planners, in the Key Issues comments at the start of their Officers Report to the committee accept that ‘the development would exceed the policy expectations in respect of tall buildings’. I think they should have been clearer than that, so let me take you through the tall buildings planning policies which cover the Wembley Park Station car park site. I’ll begin with my “old friend”, the Wembley Area Action Plan (“WAAP”).

 

Foreword to the Wembley Area Action Plan, 2015.

 

When Brent’s then Lead Member for Regeneration (now Deputy Leader) writes to say that this Plan, adopted by the Council after wide consultation with the local community, will determine ‘how Wembley develops over the next 15 years’, you would think you could trust her words. And you can, because the WAAP’s policies still apply, and form part of the Draft Local Plan that is currently being finalised.

 

The WAAP has a tall buildings policy, WEM 5. It’s opening words are: ‘Tall buildings will be acceptable in a limited number of locations within the AAP area.’ The locations where tall buildings are, or may be, appropriate are shown on a map. Wembley Park Station car park is in “the red zone”, labelled ‘Sites inappropriate for Tall Buildings’.

 

The Tall Buildings map from the WAAP.

 

One of the specific sites (W22) identified in the WAAP for particular proposals was called “Wembley Park Station Car Park”. However, that was the western end of the original car park, not the present site with that name. This is where Matthews Close was built, with blocks between 5 and 8 storeys high - a scale identified as suitable for the mainly residential area of Brook Avenue.

 

Brent Council adopted a new comprehensive set of Development Management Policies in November 2016 (as seen in an earlier blog on another planning case in August!). These did not set out any new policies on tall buildings, but it did confirm that ‘policies within the Wembley Area Action Plan will take precedence where there are locally specific policies covering subjects that might also be covered’ by the DMP and the forthcoming Local Plan.

 

Another “supplementary planning document” which will form part of the new Local Plan, when it is finalised, is the Brent Design Guide, SPD1. Its policies were adopted by the Council in November 2018. SPD1 has a section on ‘Density, height and massing’, which includes guidance on sites appropriate for tall buildings. Under Principle 3.1 it states: ‘Tall buildings will only be encouraged in areas identified as appropriate for tall buildings.’ As we have seen above, the Wembley Park Station car park is a site inappropriate for tall buildings!

 

A page from the Brent Design Guide, SPD1, dealing with building heights.

 

As well as this confirmation over tall buildings, SPD1 goes on to set out the rules for heights on all other sites. These include that ‘sensitive design should ensure that new development respects the character of the wider surroundings’, and that ‘new development should positively respond to the height of the adjoining buildings and local area’.

 

I’ve already made mention of Brent’s Draft Local Plan, which has been through several phases of local consultation and is currently undergoing a final review to ensure that it complies with both the National Planning Policy Framework and the London Plan. It should come into force next year, and shape Brent’s planning policies for the next 20 years, so that it’s right that how it would affect the Wembley Park Station car park application is taken into account.

 

The Draft Local Plan does include a site-specific policy for Wembley Park Station (BCSA7), covering two sites. For the southern site, the narrow strip of land between the railway lines and Brook Avenue, it identifies an indicative capacity for 300 new homes.

 

The Wembley Park Station site plan from Brent’s Draft Local Plan (Stage 3).

 

Details for the Wembley Park Station sites from the Draft Local Plan.

 

As shown above, the WAAP tall buildings policy, under which this site is inappropriate for tall buildings, still forms part of the planning policies within the Local Plan. The proposals for the southern site respect that, with just a small adjustment. You will remember that a tall building is one of more than ten storeys, and the design details for this site say: ‘Up to ten storeys will be considered acceptable to the western side of the site, stepping up slightly directly adjacent to the station.’

 

One of the key purposes the Draft Local Plan has been designed to do is to deliver the housing target of providing over 2,000 new homes in the borough every year for the next 20 years. The Wembley Park Station car park site can provide the 300 homes which the Plan requires from it, with buildings no more than ten storeys high, possibly rising to twelve storeys next to the station. Any proposed new development on this site does not need to breach Brent’s tall buildings planning policies.

 

The Barratt London / TfL proposed development offers 454 new homes (152 of which would be “affordable”, but with 79 for sale as “shared ownership” and only 73 for “affordable rent”). But it clearly breaks the Council’s tall buildings planning policies. What does the Officer Report to Planning Committee say about that? This is just one of nine paragraphs on the subject:

 

’47. Whilst the Wembley Area Action Plan (WAAP) forms part of the development plan for the area, as it is the adopted policy, the emerging changes to policy as observed within BD2 of the emerging Local Plan are to be acknowledged and stand testament to the substantial increase in housing targets that have come into relevance since the publishing of the WAAP. Furthermore, emerging London Plan policy can now be afforded substantial weight and the sustainability of this location immediately adjacent to Wembley Park Station would identify it as a preferred site for maximising development opportunities. Wembley Park Station is the only tube station in Brent to be served by more than one London Underground line and its 6a PTAL rating underlines its sustainability.’

 

Heavy going! It’s not easy to follow exactly what the relevant planning policy is. You could easily think that they don’t intend you to, so that you'll just assume that they must know what they’re talking about, and accept their recommendation!

 

Policy BD2, from Brent’s Draft Local Plan.

 

Para. 47 (above) of the Officers Report refers to Policy BD2, as if it supports tall buildings on the station car park site. But BD2 only supports tall buildings in appropriate locations. The online version of the policies map it refers to is difficult to read, because it has so much detail, but this site appears to be within the overall “tall buildings zone”, but not in the Core Zone. This suggests that the site allocation details for BCSA7 above, which allow a slight stepping-up to a tall building at the station end of the site, should prevail.

 

Para. 51 of the Report does provide a couple of lighter moments, even if unintentionally. How about this one? ‘The buildings proposed would serve as a place-marker for the station.’ Imagine the scene:-

 

Visitor: “I need to get to Wembley Park Station. Can you tell me where it is, please?”

Helpful local resident: “Yes. It’s next door to a tall building in Wembley Park.”

 

Or this one – ‘A significant reduction in height from 30 storeys at this scheme’s initial pre-app stage is also acknowledged and has resulted in a building which establishes a reasonable maximum height.’

 

A man walks into Brent’s Planning Office, and says: ‘I want to build a tower block three times higher than your planning policies allow.’

Brent Planner: ‘I’m sorry, sir, we can’t accept that. We can only recommend a building that’s twice as tall.’

 

If a comedian said that, you might well laugh at his joke. But this is not “a tall story” * – it’s exactly what Brent’s Planning Committee is being asked to agree.

 

Philip Grant.

 

* If you are not familiar with the phrase “a tall story”, it’s colloquial English for ‘one that is difficult to believe’ (Oxford Reference Dictionary).

Brook Avenue, Wembley Park: The latest street to fall victim to high rise buildings

Guest post by a Brook Avenue resident

Proposals for the redevelopment of Wembley Park Station car park to build five new buildings between 13 and 21 storeys in height (456 residential units) have been submitted to the council. This is just the latest site highlighted for high rise, excessive density buildings that are slowly changing the face of Wembley as we know it. As a resident of Brook Avenue and having read the various local, London and national plans, I believe that the proposed development contravenes many of the policies set out in the plans and would have a serious adverse impact on the area. The site will be overdeveloped, compromising the quality of the development, character of the street and supporting infrastructure capabilities. If you are a resident of Brook avenue or the surrounding area, or even if you have been left feeling disenfranchised about the emergence of such buildings in Wembley, please read on. Details on how to get involved will be at the bottom of this post.

The 5 blocks will be 13, 13, 14,17 and 21 storeys in height, on a parcel of land that is far too small at 0.67 hectares. 

The site itself has been highlighted in numerous council plans as being “inappropriate” for tall buildings, as per the London plans guidance to grade sites on their “appropriateness” for tall buildings. Based on the council's own policies, the site is clearly not suitable for such buildings and should not be given approval. Given the significant detrimental impact tall buildings can have on local character, it is important that they emerge as part of a planned exercise in placemaking, rather than in an ad hoc, speculative way.

Wembley Area Action Plan

Areas inappropriate for tall buildings are highlighted in red

Historically, Brent is characterised by low to mid rise buildings, with any tall buildings being directed towards town centres. A 21 storey building on a road with mainly two and multi storey buildings would be completely out of keeping with the context and character of the area. The proposed developments will pose both a literal, and metaphorical encroachment on residential suburbia and as the London Plan, Chapter 7.21 states: “The building form and layout should have regard to the density and character of the surrounding development”. I'm sure over the years many of you have noticed a surge in tall buildings in Wembley, often in areas where they do not fit in with the suburban surrounding character. Whilst it is understandable that the push for taller buildings stems from a need for more housing, high density does not always have to mean high rise development. Perhaps efforts should be made for developments that both contribute to the required density and are also in keeping with the character of the area.

 A rendering of what the tallest block will look like as you enter Brook Avenue from Olympic Square

 Rendering of what the buildings would look like from verified view - Barn Rise junction with Eversley Avenue and ...

 ... Kingswood Road at junction with Elmside Road

The increase in density due to the developments would amount to serious ‘cramming’ on what is a quiet, residential, low density road. The buildings adjacent (Matthew's Close) were given an indicative capacity of 100 units in the Wembley Area Action Plan- so how can a site that is on the same street and is in fact 0.2 hectares smaller, be allowed to be built at the indicative capacity of more than quadruple that? The development would also intensify pressure on already burdened infrastructure such as schools and GP’s. The 456 units, which would house more than double that in people, would result in an increased demand for school places within the Borough, without providing any contribution to building new school classrooms. It would mean an increased pressure for the use of existing open space, without contributions to enhance that open space. The development only provides an average of 12.8sqm of private and communal amenity space per unit- this equates to only 64% of the local plan requirements, which would lead to greater pressure on the surrounding open spaces in the area (like what is currently going on with King Edwards Park). Where is the commitment from the council to create open, green spaces to accommodate the growing population of Wembley?

The proposal also makes no provisions for the loss of a car park which accommodates 200 visitors daily.  Brook Avenue is the most heavily parked road in Brent and the loss of the car park, as well as the addition of 456 new homes, will have a serious adverse impact on the street as well as the surrounding areas. Parking will spill onto Brook avenue (a street which already has issues with street parking) as well as the surrounding Barn Hill area. Without mitigation measures, the high levels of population growth anticipated due to the development will place serious pressure on the existing road network, particularly on event days.

The development will not make a significant contribution to Brent's housing needs as it favours one bed and studio flats as opposed to family homes. Brent’s predominant needs are more for larger sized (3 bed or more) family dwellings. Of the 456 dwellings that are proposed to be built, only 10% will be 3 bedroom, as opposed to the 25% that is required by the council. This is a clear lack of consideration for families which should be encouraged to stay and contribute to the establishment of a long term mixed and sustainable community in Wembley. The council's own policy states:

“It is not the intention of the council to build a large transitional location for single people and childless couples who may be forced to move on because there is no choice of family homes available”

The Development would also lead to breaches of the BRE Guidelines (Building Research Establishment) in terms of daylight and sunlight received by the neighbouring properties. It is understandable that existing levels of light cannot be maintained, but this should not be to such a degree that they breach BRE guidelines. The council should ensure that the quality of housing output is not compromised by the need to make the most efficient use of land.

The proposed development will pose both a literal, and metaphorical encroachment on residential suburbia. It seems that this development, like many others emerging all around Wembley, puts quantity over quality. Under the guise of “making the most efficient use of land”, other equally important criteria have been ignored, such as quality, capacity of the street, parking, impact on amenities etc. It should not go remiss to mention that should the council expect it’s policies to be taken seriously, it should lead by example, and not repeatedly contravene it’s own plans through granting permission for development where it would otherwise be unsuitable. If a building that violates so many local and national policies is granted planning permission, what will this mean for the future of Wembley?

Through the strive for the ‘regeneration’ of Wembley, the council has seemingly overlooked the thoughts and opinions of the people who make it what it is: its residents. I urge you all to get involved to help make our voices heard. I will leave you all with a quote from the Emerging Local Plan, Paragraph 4.51:

Meeting indicative capacities should not be used to justify overriding other policies where it would result in creating poor developments.

Get involved:

If you are a resident of Brook avenue or the surrounding area, you can object to this development either by writing your comments on the council website (the application reference number is 20/0967) or emailing your objection to Toby.huntingford@brent.gov.uk .

Resident of Brook Avenue

UPDATED: Wembley Stadium’s vanishing arch – more evidence on Brent Council's failure to protect 'iconic' views

 

View from Bobby Moore Bridge May 2011

 

View from Bobby Moore Bridge September 2018

Last month, I reproduced a letter from Philip Grant which had been published in the “Brent & Kilburn Times” on 6 September LINK . This challenged the Council to explain why it had allowed its own planning rules to be broken, and why it had failed to protect the iconic view of Wembley Stadium, despite its promise to do so.

Philip sent a copy of the letter to Brent’s Chief Executive, Carolyn Downs. Ms Downs replied that she had forwarded it to the Council’s Head of Planning, for attention and action, and that a response would follow. Here is the text of the Council’s response:-

‘Dear Mr Grant

Case 10658297

I write in response to your e-mail to Carolyn Downs within which you seek a response to the matters that you raised within your letter to the Kilburn Time. Within this letter, you have set out that you consider that the Council has failed to protect the view of Wembley Stadium and that you consider that the Council has allowed its ‘own planning rules to be broken’. Within your e-mail, you provide a link to an article that you have published on Wembley Matters which refers to two planning applications for developments within Wembley.

Policy WEM6 of the Wembley Area Action Plan relates to views to Wembley Stadium. This sets out that ‘Regard should be had to the impact of development on the following views … of the National Stadium’ with specific viewpoints referred to within the policy and on a map. The pre-amble to the policy discusses the contribution the Stadium makes and the importance of views to it. It sets out that the Council will protect a range of views to the Stadium.

The potential impact on the views to the stadium are considered within planning applications that could affect those views. This includes the provision of information to demonstrate whether the proposal will affect a protected view to the stadium and the extent of any effect on that view.

The submissions for the two planning applications that you referred to within your internet article do set out the effect of those proposals. As you have highlighted in your e-mail to Carolyn Downs, those reports (and the discussions at the planning committee meeting itself) highlighted that those proposals will result in a small reduction in the view to the arch. This matter was considered by officers and members, and the level of harm associated with this reduction was evaluated. On balance, it was considered that the extent of the reduction was such that it did not warrant the refusal of planning permission.

It is clear from the report and the discussion and debate at the planning committee meeting that regard was had to the potential impact of proposed development on the views to the Stadium. These proposals would result in a slight reduction in the view to the stadium. However, the level of reduction was considered to be small and the level of harm associated with this reduction also small. This is not a matter of rules having been broken. Due regard was had to the policy, with a slight impact occurring should those proposals going ahead. That impact was considered and weighed against the benefits of the proposals, and on balance, planning permission was granted.

Yours faithfully

Development Management Manager’

Philip has decided not to waste his time in trying to argue his point further, but has sent me this comment:

‘This response is typical of the sort of excuse that Brent’s planners come up with. They admit that their planning policy recognises the importance of views of the Stadium, and says that it will protect them. They say that ‘this matter was considered by officers and members’, and then they say that it was only a ‘small / slight reduction’ in the view of the arch, so planning permission was granted. 

Brent must be seen as a “soft touch” by developers. They have planning policies, but it seems they are willing to allow developers to ignore them, as long as they only breach them by a small amount each time! But those breaches are cumulative, and would not happen if Brent stuck to policies the Council had adopted, after public consultation.

The Council’s response does not answer my second question, on why it has failed to protect the iconic view of Wembley Stadium, despite its promise to do so. It HAS failed to protect the view. The evidence is plain to see, from these two photos  above) taken at the same spot on the Bobby Moore Bridge, in May 2011 and September 2018.’

The "protected view" of Wembley Stadium from the White Horse Bridge, on 2 November 2018. If only it was a case of No.13 being an unlucky number for the Stadium views supposedly "protected" by Brent's Planning Policy!

The view from Barn Hill (the road not the open space)

Why has Brent Council failed to protect the iconic view of Wembley Stadium?

'...The council will therefore protect a range of short, middle and long distance views of the National Stadium.' 2015

2018

 I reproduce below Philip Grant's recent letter to the Kilburn Times LINK

Your article “Wembley Arch Vanishing?” (23 August) LINK makes a very important point about Brent Council’s lack of compliance with its own planning policies.

In January 2015, a meeting of Brent’s Full Council adopted the Wembley Area Action Plan, drawn up after public consultation, to be part of the policies which were supposed to be applied in deciding whether planning applications should be accepted. The action plan included a section on “Protection of Stadium Views”, with policy statements such as:

‘Views of the Stadium contribute a significant amount to the perception of Wembley as a whole, performing a range of functions that add a layer of depth to the visual experience of the area.’ and
’The council will therefore protect a range of short, middle and long distance views of the National Stadium.’

In the related section of the action plan on “Protecting the Special Character of Olympic Way”, the protection to be given was spelled out with further policy statements, including:

‘In line with policies WEM5 and WEM6, proposals for tall buildings must demonstrate that they have no adverse visual impacts on views of the stadium from Olympic Way.’ and (in policy WEM7)
’Proposed Development on Olympic Way must be carefully designed and scaled to respect the predominance of Wembley Stadium and its arch.’

Picture 4.39 (above) is an illustration from the 2015 action plan, showing the main view that these policies were supposed to protect. Unfortunately, the reality of what has been allowed to happen can be seen in a photograph which I took, from the same spot, in July 2018. 

Brent has allowed many “minor” bites to be taken out of the view, by approving successive planning applications for tall buildings along Olympic Way over recent years, and there are more to come.

In June 2018, a report to Planning Committee, which approved changes to the plan for a tall block next to the Civic Centre, mentioned some of the earlier concessions made:

‘The top of the new tall building would obscure an additional small part of the stadium arch ....’ and
’Whilst the current proposals would slightly reduce the amount of the arch that is visible at present, this is not significantly more than the degree to which the Barratt and Unite housing schemes on the eastern side of Olympic Way infringe on the view of the arch from Olympic Way ....’

In July 2018, when recommending approval for a development by Network Homes of up to 21 stories, the planners said:

‘...  it is considered that the small reduction in the visibility of the eastern part of the arch is an acceptable consequence of this development and it is noted that the western part of the arch is already obscured to broadly the same extent, helping to bring symmetry to the view of the Stadium along the Olympic Way corridor.’ 


Brent Council should explain why it has allowed its own planning rules to be broken by its planners and Planning Committee, and why it has failed to protect the iconic view of Wembley Stadium, despite its promise to do so.

Philip Grant

Poor public response to Wembley Action Plan consultation

The report on  the consultation on the Wembley Area Action Plan (Issues and Options) has now been published.  The result is very disappointing in terms of public participation with comments seldom getting into double figures for each issue and mainly limited to organisations. The report could have far reaching implications for Wembley's development and the fact that the great majority of people are unaware of this will store up problems for the future.

The document can be found HERE you need to click on the Comments tab on each section to see the responses.