Wednesday 21 August 2019

ASDA & McDonald's need to spill the beans over McDelivery service at ASDA Wembley




Local residents are taking on the big boys over the proposed McDelivery service at Wembley Asda. Despite a request by Brent planners for more information to be provided the only details on the application are for installation of a window!

In my submission to Brent Council I wrote:
There is insufficient information in this application to make an evidence-based comment. It refers only to a sliding window and canopy but behind this is a proposal for a McDelivery service to operate from Asda. We need information on the times the service will operate, any changes in the vehicle lay-out, how pedestrian safety will be ensured if scooters/motorbikes are used to collect food orders and noise controls. Although the Council decided planning permission was not needed for a McDonalds to replace the previous Asda cafe I would suggest that the extension of opening hours and a delivery service operating from the premises DOES require planning permission.
A resident from the flats that overlook the Asda site wrote:
The planning documents made available to residents give little information as to what the application is for, primarily a sliding window. It has now come to my attention and also to the attention of 115 Chalkhill Road residents that a McDonalds restaurant is being built on the Asda site (former Asda cafe) with 24 hrs opening. As residents we have already raised our concerns with the Wembley Matters as well as the Council person Ms Seaton. There is a massive record of noise disturbance record that as residents we have been reporting to the Council on Asda's noise pollution for many years and there has been a noise abatement notice given to Asda few years ago by the Council which has not been really fully acknowledged by Asda hence they have been operating their Home Delivery and Click and Collect business outside of permitted hours for few years and residents have suffered due to this disgraceful behaviour of Asda's management and staff. I would like to mention also about car racing that has been going on at Asda's car park at nights for few years and despite residents reporting this as a health and safety as well as noise issue as well as public safety issue (reported to the Police with number plates of racing cars on multiple occasions) this has never been tackled and resolved. As residents we are extremely concerned that approving night time McDonalds restaurant will certainly generate more noise at nights and more cars at car park causing trouble to the public.

Please kindly look into this objection thoroughly and check previous history of complaints made by 115 Chalkhill Road residents.
Another resident wrote:

The works for McDonalds have already commenced at Asda Forty Lane, with the gutting of the cafe.

I was under the impression no decision was being made until the start of this week?

The planning documents made available to residents gave little information as to what the application was for, primarily a sliding window.

It has now come to light that a McDonalds restaurant is being built on the site of the former cafe with 24hrs opening.

The cafe was not open 24 hours, neither is Asda on a weekend.

You will see from previous correspondence with Brent Council, that the residents of 115 Chalkhill Road have long suffered noise pollution since all the planning applications submitted by Asda have been approved. The car wash directly beneath our homes was moved as it created too much noise pollution, only to be replaced with a skip during the building of the opticians, which then made way for the home delivery and click and collect areas which, even today, are a constant source of noise pollution (although, admittedly, significantly less than before our complaints) The residents facing Asda car park (includes me), faces the most noise pollution. And with this 24 hour operational food joint, it will be a nightmare!!!

There is still an ongoing issue with birds, attracted to the area by the food waste, again, better than it was now both MTVH and Asda have installed netting, but will continue to be a problem until Brent Council address the littering problem we have in this area, which I fear will be exacerbated with the arrival of a 24 hr McDonalds on our doorstep.

We are deeply concerned about the negative impact this will have on our neighbourhood and quality of life.
There are already groups using the staff shelter as a hang out late at night, with loud chatting and car stereos blasting out of open car doors.

The space in front of the car wash is frequently used as a race track, with cars picking up speed from Forty Lane end culminating in 'donuting' in front of the car wash.
What kind of clientele are you expecting at a 24 hour McDonalds? Do you think there will be an increase in trouble? Noise pollution? Littering? This will increase antisocial behaviour. We already find problems near Paddy Power corner.

Not to mention, positioned between to schools, Ark Academy and Lycée International. Is this in line with Brent tackling child obesity? Healthy eating? Why do we need another Mc Donald's, when there are two in close proximity and multiple chicken shops?

Would you please advise, as a matter of urgency, exactly what the plans are for this space and what considerations Brent are taking into account with regard to the issues raised above.

More meetings to be held on South Kilburn ballot while concerns mount over decant options

Perhaps as a result of recent protests by residents Brent Council is offering additional consultation dates regarding the ballot on South Kilburn regeneration. The ballot begins on September 20th.


An issue not addressed in the FAQs is where exactly those residents displaced by regeneration (if the ballot gives the go-ahead) will be decanted to. A Resident Advisor from Communities First who deal with South Kilburn told Wembley Matters:
South Kilburn is a phased scheme currently programmed to complete by 2027. At the time tenants in each phase are required to move there are options of new homes or existing council properties available. I understand that the Landlord Offer will detail the phasing.

The Council's purchase of the new Gloucester and Durham buildings will also generate an additional 160 currently unallocated homes.
Meanwhile there is confusion over the status of the Queen's Park/Cullen House site development, termed a 'site of vital importance' by the Council as it links Queen's Park  to South Kilburn. Planning permission was granted in 2012, amended in 2017 and the go-ahead to appoint a developer given in October 2017. So far no developer has been appointed. 39 of the proposed 137 homes had been earmarked for decanted tenants but around 270 tenants would need to be rehoused from William Dunbar and William Saville House alone.

Tuesday 20 August 2019

Wembley Park Community Fund recipients named

From Wembley Park Community Fund

Quintain and The London Community Foundation announce the recipients of The Wembley Park Community Fund, which provides funding and grants to those in the Brent Community. The Fund aims to make a real difference to Brent residents by encouraging community engagement, participation and place-making through funding a variety of community-led activities.

Grants of between £5,000 and £10,000 have been awarded to charities, community or voluntary organisations. The grants are awarded to three core themes – Better Places – making Brent a great place to live, work and visit; Better Lives – supporting education, employment and good health and Better Locally – ensuring local networks and services work effectively.

The organisations awarded range from The Promise Foundation which mentors disadvantaged young people across Brent; to Hilltop Circle, which delivers football training sessions to young people.
In support of Brent London Borough of Culture 2020, 40% of this round’s funding pot has also been allocated to arts and cultural projects in the borough.  These projects include Intercultural Musicology CIC, which runs free music workshops with instruments from around the world for children aged 0-12 and their parents; and Unique Community Charity which runs youth theatre sessions around the theme of language, and how that connects to identity and meaning.

The Fund is led by Quintain, the developers behind the transformation of Wembley Park, in partnership with their key contractors Wates, McLaren, John Sisk & Son, and McAleer & Rushe. It makes a difference to the lives of local residents in Wembley Park and the surrounding area by encouraging community engagement and participation through funding a variety of community-led activities.

In the past two years, The Wembley Park Community Fund has so far helped fund 20 local projects. The funding has helped children, young people, and the elderly and vulnerable adults.  The funded projects have provided the local community with employment and work training, and wellbeing and sports activities.

James Saunders, Chief Operating Officer of Quintain, the developer behind Wembley Park said:
Community-led initiatives are at the heart of our neighbourhood, making it a vibrant, welcoming and fulfilling place to live, work and visit. It’s been amazing to see the range of projects made possible by The Wembley Park Community Fund and the impact they have in the community. We are particularly pleased to support local arts and culture in support of Brent London Borough of Culture 2020.
Councillor Muhammed Butt, Brent London Borough Council, said:
Initiatives such as The Wembley Park Community Fund build upon the range of new opportunities Wembley Park has bought to the people of Brent.  With 2020 Brent Borough of Culture in mind, it’s great to see a large proportion of the funding going towards cultural and arts projects.
Full list of funded projects:
































Monday 19 August 2019

A list of current and planned housing developments in Brent

People often tell me that they have great difficulty in keeping up with all the regeneration and housing developments in Brent which include Wembley Park, Wembley Central, South Kilburn, Alperton, Northfields and smaller sites.

This document submitted to the Queensbury appeal includes an Appendix listing current and future developments. Click bottom right square for a full-sized copy.




Saturday 17 August 2019

Crunch day for Preston Community Library at Planning Committee on Wednesday 21st August

Ground floor plan showing flat and accommodation entrance and library space
Frontage from Carlton Avenue East
Preston Community Library is at the centre of a planning decision to be made by Brent Planning Committee on Wednesday August 21st LINK. The community library emerged from a fierce campaign against closure and campaigners decided to run a volunteer library to safeguard the site and service until a council run service was reinstated. Recently the library was commended in the Bookseller's Library of the Year Award, the first volunteer library to receive such a commendation.

Campaigners won the status of Asset of Community Value (ACV) for the library and its retention is guaranteed in Brent Council's redevelopment proposal that includes provision of a new building with 12 affordable flats on the site as well as a smaller library space.

Supporters of the library have varying views on the proposal with some supporting the development as a way of ensuring the survival of the library and the replacement of a flimsy building which is not fit for modern purposes. They accept that the  smaller floorspace will be more flexible and adaptable than the current classroom layout. Others oppose the development because the library provision will be smaller than the current floorspace and they wish the library to continue as it is - often without any redevelopment to provide housing.

There are 67 objections in all including that from the South Kenton and Preston Park Residents Association.  Ground include the height and density of the proposed building, its failure to fit in with the local 'metroplitan style' semi-detached houses, traffic impact, overlooking of nearby gardens, lack of play-space for children and danger of surface flooding. Neighbouring Twinstar Car Sales oppose the development partly due to it overlooking their premises but also because it limits their own redevelopment proposals. An earlier submission by them was turned down.

Councillor Kennelly in hs submission recognised the benefits of re-providing the library facility to allow its continued operation in the long term, but highlighted concerns regarding the impact of the proposal upon the privacy of the properties on Longfield Avenue and the need to remove windows/balconies facing onto these properties, that the design of the building is not in keeping with the character of the area and could set a precedent. 

I would expect Cllr Michael Maurice, who is a member of the Planning Committee, to recuse himself from this agenda item as he has expressed strong views on the proposal.

Three supportive comments claimed that the proposal will provide much needed affordable housing within the borough in a decent standard of accommodation, that the site is in a sustainable location close to local amenities, transport links and schools and the proposal will allow the long term operation of the library to take place on the site in a modernised building 

As shown in the plan above the library space will be provided as a shell at this stage and Preston Library will fit it out themselves using the £268,000 they were granted from Neighbourhood Community Infrastructure Levy that was conditional on the redevelopment going ahead. LINK

Below I have reproduced three views from the Council Planning Portal to illustrate the issues:



NEUTRAL

Since this development was first proposed in 2010, I have read and reviewed the many ideas and suggestions from Brent Council. Previous proposals failed to provide adequate provision for a Library or community space. This space has always been and remains an integral part of our community in Preston Ward. Since 2016, I have seen a more engaged approach from Brent Council and a willingness to listen to the community. Although these plans require further alterations, the basic provision for a sustainable community library in the long term is the most important factor in my decision to support this development as a resident and councillor.

The space available to the community will be maintained and modernised. It will allow the Preston Community Library and Hub to build upon their hard work and success by granting long term security both financially and structurally. The current building is approaching the end of its natural life and will require substantial work to maintain the current standards. By supporting this proposal, I believe that the long term future of Preston Community Library and Hub will be secured.

However, I am concerned that the current proposals do not meet the necessary safety concerns for the development to proceed in its current format. Firstly, at every public meeting local residents have expressed their concerns over privacy and child safety. The proposals have continuously failed to meet these concerns. To help protect residents, I propose that all balconies are removed from the final design and no windows overlook the residents on Longfield Avenue. The safety and protection of vulnerable residents should be the first priority for the Planning Committee.

Secondly, the design of the building does not keep with the local architecture. This community has a traditional metropolitan look, which these proposals do not reflect. I am concerned that this will open the floodgates to applications that do not reflect the traditional beauty of the local area. Therefore to maintain the high standards in the local area, these proposals should be reviewed once again.

Finally, I do not believe that adequate planning or consultation has been completed in regards to the impact of increased traffic and reduced pedestrian access whilst work is being completed. I would strongly question any survey that has been completed by the council and ask why they have asked for such little public engagement on this issue. It is my belief that the current proposals will hurt local business and impact upon the lives of both elderly and vulnerable resident. It will lead to an increase in pollution and congestion. The lungs of young residents are most affected by the fumes from parked traffic, I implore the Planning Committee to ask Brent Council to think again about these proposals.

I want to make very clear that my support for this project hinges upon the guarantee of the long term future of the Community Library and Hub. Should the Committee or Brent Council attempt to reverse these plans and commitments that have been made to the community, I would be unable to continue with my support.

FOR

I strongly support this development, because it will provide a new and better laid out and equipped library, rather than it having to make do and mend in a building that has seen better days. I agree with an earlier comment that the library is an important resource for the community which allows people a safe creative environment to interact and encourages diversity, and that it has a positive function in social, health and economic terms.

I also, unlike most of the people opposing the development, positively welcome the development of affordable housing, particularly at a time when across London around 80% of new market housing is affordable to only 20% of working households and there is marked reluctance by private landlords to let to households claiming Housing Benefit.

Brent Council's housing strategy acknowledges that the opportunities for large-scale new development in Brent are constrained by land availability and costs, so smaller developments must play their part in helping to provide homes for those who don't have them or are poorly and insecurely housed.

We in this community should welcome this opportunity to increase the affordable rented housing stock. Too many of the comments opposing the development simply smack of nimybism.

AGAINST

We wish to make you aware of a number of strong objection that we have with regards to the proposed development of  Preston Community Library. As an immediate neighbour to the site of the proposed development, we are of the view that the proposed development will have a serious impact on our standard of Living. Our specific objections are as follows.

1 Detrimental impact upon residential amenities.

We believe that the proposed development is a direct contravention of the policies, it does not respect local context and street pattern or in particular, the scale and proportion of surrounding buildings and would be entirely out of the character of the area, The proposed Development is 4 storey building and is much higher than neighbouring property. The proposed dwelling incorporates an external balcony at front and rear of development unlike any other neighbouring property, so the scale and design of the development will be entirely out of keeping.

The proposal would demonstrably harm the amenities enjoyed by local residents, in particular safe and available on-road parking (see point 6), valuable green space (see point 4), privacy ( see Point 5) and the right to enjoy a quiet and safe residential environment.

2 Need To avoid town cramming

We believe that the proposed development is a direct contravention of the policies. The proposed dwelling would significantly alter the fabric of the area to serious cramming in what is a low density road, The proposed dwelling have very small garden, but the nature and orientation of the plot means that the garden would actually be very small for a four-story dwelling, particularly compared with the large plots typically enjoyed by the surrounding properties. The proposal allows very little space for landscaping and we believe that it would lead to gross over-development of the site. The proposed development would not result in a benefit in environmental and landscape term, to the contrary it would lead to the loss of valuable green space.

3 Communal Play Space Policy S4 (Mayor of London)

We believe there is no Communal Play space for children and Young people in accordance with the requirement of Policy S4 Play and informal recreation as per Mayor of London Plan (Minimum for 10 children)

4 Protection of valuable open space under TPO

We have grave concerns about the adverse effect the proposed development would have on large tree will be removed this will affect wildlife haven for many birds and valuable contribution to the street scene and area and are an amenity for local residents.

5. Loss of privacy and overlooking

The proposed site of development and scale that the primary amenity area of our garden, resulting in a serious invasion of our privacy.

We believe that the proposed development is a direct contravention of policy of the District Wide Local Plan. The design of the proposed development dose not affords adequate privacy for the occupants of the building or of adjacent residential properties. Particularly, with regard to their right to the quite enjoyment of garden amenities. We would urge you to consider the responsibilities of the council under the Human Right Act in particular Protocol 1, Article 1 which states that a person has the right to peaceful enjoyment of all their possessions which includes the home and other land. We believe that the proposed development would have a dominating impact on us and our right to the quite enjoyment of our property. Article 8 of the Human Rights Act stats that person has the substantive right to respect for their private and family life.

6. Inadequate Parking and Access.

We believe that the proposed development does not provide sufficient parking space to meet these requirement ( As specified in transport report this kind of development require 14 space for flat resident plus about 5 space for library users plus disable space for both library user and flat resident) in addition to this , there is already intense on street parking pressure on the road on Carlton Avenue East, Longfield avenue, Fernleigh Court, and we believe the proposed additional parking provision will damage both highway safety and residential amenity.
Also proposed development showing hoarding taking public footpath and parking bay outside library and will create blind spot junction and will increased on road safety and accident.

7. Our other objection are listed below.

1) Nuisance and annoyance obstruction of the view
2) Twinstar similar Development been refused by Brent council reference 08/3173
3) Consultation meeting 76% Neighbours and library user object the development proposal
4) We believe proposed Development will create overshadowing in our property

We would be grateful if the council would take our objection into consideration when deciding this application. We would welcome the opportunity to meet with a representative of planning department to illustrate our objections at first hand.

Friday 16 August 2019

Brent Council issues reassurance on dam safety precautions at the Welsh Harp reservoir

Following the article by Philip Grant LINK on the Welsh Harp dam risk in the light of the Whaly Bridge incident, Brent Council has written to him with the following statement:

The council work with the Environment Agency directly as part of both the Brent Resilience Forum and the London Resilience Forum. To assure you, responses to a breach, or potential breach, of a reservoir form elements of the risk registers for both organisations. The Brent Resilience Forum has a specific multi-agency flood plan in place, including for a breach of Welsh Harp Reservoir. A specific emergency planning training exercise on a flood breach is also hoped to be conducted at some point next year.

As you may be aware, the Canal and River Trust rather than the council is the reservoir operator at the Brent Reservoir and owns the watercourse there. We have recently been in further contact with the Trust since the events at Whaley Bridge and they re-iterated the inspections and procedures that they have in place to ensure the safe management and maintenance of the reservoir. You may wish to contact them directly in relation to this matter for your information.

I am aware that you may place this response in the public domain so I thought it would also be useful to highlight what measures residents can take to prepare for any flood risk:

· There is information available on the council’s website here:
https://www.brent.gov.uk/emergencies/severe-weather/flooding/

· Residents can check the different types of flood risk for your property via the Environment Agency website: here
https://flood-warning-information.service.gov.uk/long-term-flood-risk

· Residents can also use this site to sign up for specific flood warnings: here
https://www.gov.uk/sign-up-for-flood-warnings

I hope this provides re-assurance that the council has multi-agency plans in place for any instances of flooding in the borough, along with a Flood Management Strategy on our website sent to you previously.

Thursday 15 August 2019

Bobby Moore Wembley mural may be shown in the future 'should the Council choose to do this.'

 
Brent Council leader Muhammed Butt

Brent Council Planning Department has responded to a resident’s query about the Bobby Moore Bridge murals stating that the historic murals ‘may be shown in the future should the Council choose to do this.’  The resident was unhappy with Brent Council's decision to allow most of the mural to be covered up by advertising. 

I don’t think I am going to put my money on a reappearance any time soon based on that comment!

Brent Council response:


This relates to the advertising on the side walls of the Bobby Moore Bridge underpass that covers the tile murals that are on those walls.

By way of background, the bridge itself, including the tile murals and the walls upon which the murals are located are owned by the Council.  The Bobby Moore Bridge subway was constructed between 1991 and 1993 as part of the pedestrianisation of Olympic Way by Brent Council. The tile murals were erected at the same time and depict a range of sporting and entertainment events from the history of Wembley Stadium and Wembley Arena.

The Council owns the structure and its walls, but The Council has leased the walls to Quintain for the installation of advertising.  Vinyl adverts have been displayed on these walls for several years.

Following a request to the Council from the Wembley History Society, Quintain engaged with the society to working up the proposals to uncover an element of the murals.  This resulted in the current proposals which included uncovering a portion of the mural which depicts football at the original stadium.  The chair of the society confirmed that they were in support of the proposals.

Applications were submitted by Quintain to change the advertisements and uncover this section of the mural.  Light boxes and advertisements were proposed to be affixed to the bridge in a way that would not damage the tile murals, allowing them to be uncovered in the future.  The application for advertisement consent together with an advertisement for the approval of details pursuant to a planning condition were considered by the Planning Committee on 16 July.  The merits of the proposal were set out in the reports for that committee meeting and were debated at length by Planning Committee members.  The applications were approved at that meeting.

The tiles are not to be ‘obliterated’ as suggested in the e-mail, but rather, the new advertisements are to be fixed in a way that does not damage the mural.  This was a key part of the proposals to put up the light boxes and advertising.  The Council’s heritage officer has checked the works regularly to ensure that they are being undertaken in an appropriate way.  The current proposals result in more of the tile mural being visible within the underpass and ensures that the mural is protected.  Parts of the mural will still remain under advertising, but they will be protected so that they may be shown in the future should the Council choose to do this.
Previous posts on this subject:

Tile murals –Wembley Park’s heritage in the balance

Wembley Park’s tilemurals – now you see them … soon you won’t! 

'Gateway toWembley' mural to be covered by advertising

Wednesday 14 August 2019

Let's build a 24* storey housing block on a flood plain close to Brent's most polluted road...

The proposed 28 storey block with nearby terraced houses and Wembley Point for comparison (revisd image of 24 storeys awaited)
Argenta House on Argenta Way, opposite Stonebridge Park Station where the new block will be built. 
Wembley Point in the background.

Following on from Wembley Central's 'Twin Towers', the tower blocks around Wembley Stadium and those approved in Alperton, a 24 (*the developer's PR agency informs me that 4 storeys have been knocked off the original proposed 28 storeys) storey tower block proposal is going to Brent Planning Committee at its next meeting on Wednesday September 21st.

What is particularly worrying about this proposal is that the 28 storeys (which replace a two storey building) will be built on a flood plain where both Wembley Brook and the River Brent flow and next to the heavily polluted North Circular Road.

Not an ideal site for housing one would think but it is close to Wembley Point which is being converted to accommodation and across the road from he long empty Unisys building which is part of the larger Brent Council supported development which includes Bridge Park complex. Housing and a hotel are planned there as well as a smaller sports centre. Currently Stonebridge residents are in dispute over the plans.

As always Brent planning officers  find reasons to support the plans despite the obvious drawbacks. This is a breakdown of the flats planned for the block. The definition of 'affordable' used is'no more than 80%  of open market rents' (ie unaffordable for the most needy Brent residents):

The wording of a petition and a submission against the development is not available on the Brent Planning Portal. 

Officers argue that the'maximun reasonable amount [of affordable and intermediate housing] has been provided on a near policy compliant tenure split.' It will be subject to further viability assessments as the development proceeds.

While recognising the flood risk and the worsening situation as a result of climate change, and taking into ac count that the first three storeys of the development will not include residential accommodation, the officers state:
At face value on the basis of evidence provided by the applicants it appears, notwithstanding that some of the site is within functional floodplain, from a technical perspective there is the ability to create betterment over the current situation through new development. This is in relation to flood risk onsite and elsewhere (though reducing footprint/obstructions within the channel), improving the aesthetic, recreational and environmental/ bio-diversity performance of the river channel/ environs and also the appearance/ perception of this gateway site whilst meeting the very real issue of meeting housing needs.
 I would hope committee members investigate that statement a little more.

The section on pollution from traffic is even more opaque with officers concentrating on how the new development would add to traffic pollution rather than on existing levels of pollution, but go on to say:



Related to the above, air quality at the lowest levels of the building (levels 6 and below), especially on the eastern elevation closer to the North Circular, would not meet the air quality objections for Nitrogen Oxide, although particulate matter objectives would be met at all levels. This shows that the emissions from the North Circular have a major effect on air quality at the site, albeit that the impact is predicated greatest at the lower elevations and the effect decreases with height. 
However officers assure Planning Committee members that:
Officers have questioned the effectiveness of NOx filtration systems in these flats, since the flats will have opening windows and doors onto balconies. Opening of such doors and windows would result in untreated air entering the internal habitable rooms (depending on air pressure differences). The applicant's air quality consultant has carried out further testing to clarify that the efficiencies of the NOx filters are such that the NO2 levels in the internal air will be 80-90% lower than the incident air, meaning that the affected flats' windows would need to be open for at least 88-89% of the time for internal parts of the flats to exceed the annual mean Air Quality Objective levels that are considered safe. Similarly, it has been confirmed that the use of the balconies on these levels by occupants, even for extended periods, will not result in occupants' air exposure exceeding the annual mean air quality objectives for NO2. As such, it would be necessary for an occupant to live on the balcony (including at night) for such objectives to be exceeded.
Regular readers will not be surprised at the report's conclusion:
Officers consider that the scheme meets planning policy objectives and is in general conformitywith local, regional and national policy. The proposal would make a positive contribution to the area,whilst having an acceptable impact on and relationship with the existing surrounding development.Officers recommend the application for approval subject to the conditions and obligations set out in this report
The full report has much more detail including comments from the owners of Wembley Point regarding a possible bridge between the two buildings which will now occupty the site and potential improvements to Stonebridge Park Station. Available HERE

Residents can apply to the chair of the Planning Committee for leave to make representations at the meeting before a decision is made. Contact the Governance Officer
Email: joe.kwateng@brent.gov.uk; 020 8937 1354