WEMBLEY MATTERS News and views on local politics, the environment, climate change, culture and local history
The theme of Children's Mental Health Week was 'Funding Your Brave' and many Brent children entered poems for a competition. LINK Their many entries are displayed in Wembley Park opposite the Premier Inn, between the LDO and White Horse Bridge, on full size billboards. It is well worth spending some time reading them and appreciating the level of insight and empathy on display.
These are the three winning entries:
The Wembley Park Station car park application is the 5 dark green blocks at the bottom right of the image. Planning Officers claimed that they were part of the overall Wembley Park high-rise area rather than the suburban area in which their own image shows they are clearly situated. The railway line, Bridge Road and Empire Way form a physical enclosure and boundary of the high rise area around the stadium.
Brent Planning Committee tonight approved the planning application for the Wembley Park Station car park which will see the construction of 5 tower blocks on Brook Avenue.
Philip Grant made a powerful presention on the Brook Avenue - Wembley Park station planning application this evening demonstrating how it breached Brent Council's own planning policies. Nevertheless the Planning Committee went ahead and approved the application with only one vote, that of Cllr Maurice, against.
This is what Philip said:
Paragraphs 44 to 52 of the Officers Report give a confused view of Brent’s planning policy on tall buildings for this site. I will explain those policies clearly, using the objectors’ document supplied to you.
The current policy, on page 1, is WEM 5, in the Wembley Area Action Plan, adopted by the Council in 2015. This says that ‘Tall buildings will be acceptable in a limited number of locations within the AAP area.’
At page 2, you can see the locations on the Tall Buildings Strategy map. The station car park is in the red area – ‘Sites inappropriate for Tall Buildings’.
There was a specific site called “Wembley Park Station Car Park” in that Action Plan. This was the site where Matthews Close was built, with blocks between 5 and 8 storeys high - a scale identified as suitable for this mainly residential area.
The Brent Design Guide, SPD1, adopted in November 2018, is another policy covering this application. Under Principle 3.1 it states: ‘Tall buildings will only be encouraged in areas identified as appropriate for tall buildings.’
The Officers Report says that you should be guided by Brent’s emerging Local Plan. The 2015 Wembley AAP policies still take precedence within that Plan, subject to any locally specific details.
The Station Car Park is a specific site, BCSA7, in that Local Plan. If you look at the copy provided on page 4, you’ll see that this application’s southern site has an indicative capacity for 300 homes, and that: ‘Up to ten storeys will be considered acceptable to the western side of the site, stepping up slightly directly adjacent to the station.’
Those are the planning policies on which you should decide this matter.
Committee members, please don’t allow yourselves to be fooled into accepting an application which doesn’t comply with the policies adopted by Brent Council, after consultation with its residents.
This application is a flagrant breach of those policies, and you can, and should, refuse it on those grounds.
Cllr Kennelly, councillor for the relevant ward, Preston, and soon to be on the Planning Committee himself, made a neutral presentation. He thought that the development wasn't in keeping with the local area, it fell outside the designated tall buildings area, the tallest was nearly three times as tall as the existing tallest building in the road, and that the attempt to make up deficiencies in amenity space meant provision of balconies facing each other that would impact on privacy. He welcomes the provision of affordable housing but said that shared ownership would not have been his choice. Answering a question from the Committee he said that a CPZ might alleviate parking issues but would be a long-term cost to local residents, even if initially funded by the developer.
Cllr Liz Dixon, a member of the Commitee said that Philip Grant's presentation had been well articulated but asked what he thought the damage would be to the area. He replsed that the height of the blocks would overshadow neighbouring properties and cut out the light of new homes that were only built a few years ago. It was over-development and breached policy that was the result of public consultation.
Cllr Kansagra said it was wrong that the Council spent so much time on the Wembley Area Action Plan only to ignore it. He said that the developer had bribed Brent Council with flats. He went on to complain more broadly that Brent Council had £126m of CIL and Section 106 money unspent in its coffers. Covid had taught us that space is important - the development was too dense with little amenity space.
Responding, an officer claim that the 'emerging local plan' anticipates that this is a site for tall buildings and that tall buildings should be built around transport hubs, which Wembley Park station on train and bus routes, demonstrably was. Furthermore, both sides of Brook Avenue, beyond its current surburban character, was designated as a site for tall buildings as was part of nearby Forty Avenue thatit leads to. (Forty Avenue is far bottom right - outside the image)
Planning Officer David Glover took me aback when he remarked, 'We are not saying that that 21 storeys is slightly above 10 storeys.' He went on to argue that there would be a loss of viability and thus of affordable homes, if the propsed blocks were lower in height.
Another Planning Officer made my jaw drop when responding to the issue of Covid in high density developments, he said Covid would be gone by the summer and we don't have to worry about it.
There was a very long discussion led by Cllr Maurice on the amount of car parking available in the road that he claimed was already over-parked and would be hit by many of the up to 900 additional residents in a supposedly car-free development seeking a parking space. In addition the 80 or so people who used the station car park would be looking for parking space in the nearby streets. There will some disabled parking in the development and spaces for transport personnel who drive in before the trains start running and drive home after the last trains. There was debate over the extent to which a CPZ would just displace competition for parking to streets further afield. Residents on Twitter testified to how in normal times the station car park was full by 8am, contrary to planners claim that it was underused.
The Planning Committee is not supposed to be political but the only dissent when it came to the vote was the single Conservative councillor, Cllr Maurice. Aside from parking his objection was based on the density of the development in what he considered a suburban area and clear breaches of specific and current Brent policies. He was used to breaches of guidelines but policy was a different matter.
Following labour and machine intensive demolition over the last few days the Pedway is no more!
Thanks to Daniels Estate Agents for the video.
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
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| 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).
Standing Orders were suspended at the Community and Wellbeing Scrutiny Committee this evening to allow for a discussion of the plans to close Wembley Ambulance Station on December 1st - next Tuesday. London Ambulance Service managers attended.
They told the Committee that Wembley was called an ambulance station but was basically a garage from which ambulance were prepared for the road. They claimed it was not fit for purpose and that the site was down for regeneration by NHS Property Services. It was not a health care setting or health care provision as such. 99% of ambulance respones were provided on the road on a 24 hour basis. The closure had made no impact on response times, which were in fact better and comfortably met targets for Grade 1 call-outs.
It had been closed since March under changes due to Covid and formal closure would take place on December 1st.
The LAS spokespeople were challenged on the lack of consultation which councillors claimed was a statutory requirement, the contradiction of saying it was already closed while also stating that it would close next week, the lack of a Equalities Impact Assessment, response times bound to be better because of lack of traffic in lockdown and the closure of Wembley Stadium, closure being nothing to do with improving the service but NHS Property cashing in on an asset, and its impact could not be considered alone as other ambulance stations in North West and West London were also earmarked for closure.
A clearly dissatisified committee recoemmnded that the formal closure should be paused and that London Ambulance Service should embark on proper statutory public engagement and consultation on the proposal.
After the meeting a member of the union told Wembley Matters that although the discussion was brief they thought it went well.
Brent Trades Council will be discussing the closure and possible action at its meeting on Wednesday November 25th.
Good to see Brent Scrutiny doing its job well.
I understand that the suspension of standing orders will be moved at Brent Commmunity and Wellbeing Scrutiny Committee tonight to take an emergency item on the proposed closure of Wembley Ambulance Station on December 1st. The proposal only came to light on Friday without any of the necessary public consultation.
The Scrutiny Commitee can be viewed from 6pm on this link https://brent.public-i.tv/core/portal/webcast_interactive/523448
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The lag in achievement of British Black Caribbean Boys compared with their peers has been a nagging issue in education since at least the 1970s. Historically there have been problems such as disproportionate numbers of Black Caribbean Boys labelled as ESN (Educationally Subnormal) highlighted by Bernard Coard (1971); disproportionate numbers allocated to Disruptive Units, often known as 'sin bins', both on and off school premises (National Association for Multi-racial Education 1979-81); the need and for, and position of black teachers, and the ongoing issue of disportionate numbers permanently excluded from school - often now seen as 'off-rolling': pupils removed from school rolls just before examinations to boost a school's position in the league tables. All addressed as examples of institutionalised racsim.
Throughout these decades there has been a response from the black community which included black parent movements in many areas of the country, supplementary Saturday schools and ongoing campaigns over allocation of black boys to non-examination streams, racist stereotyping, a euro-centric curriculum and much else. The passion that Brent's black community has for education, and concern over under-achievement was very evident at the recent huge public meeting over the future of Bridge Park. The link between that concern and the way the community felt they had been treated was clear.
Brent responded back in 1986 with the Development Programme for Racial Equality (DPRE) which faced a vociferous hostile media campaign about 'race spies' in schools. A further attempt to deal with the issue in 1991 based on a Warwick University Report 'Creating Equity' which recommended a race relations policy to the Council, resulted in a rowdy debate that led to a rebuke to councillors from the then Chief Executive Charles Wood:
Without exception it is fait to say we are stunned by the divisions encouraged and emphasised in the comments made and in particular the repeated attacks on individuals and groups of officers.
The night before I listened to the Brent Schools Music Festival - 450 children from all tehnic groups revelling in the sheer delight of sharing their distinct cultures.
It is difficult to relate the debate that followed to the reality of life in Brent today.
To its credit, given that history, Brent Council decided to again grasp this nettle two years ago with the Back Caribbean Boys Achievement Project which saw 'champions' designated in most Brent schools to seek ways of addressing the under-achievement issues and meet key targets in 'closing the gap' between the boys and their peers. The boys were the only group in Brent schools that had been significantly under-performing over the last three years. There are 1,810 boys of Black Caribbean heritage in Brent schools, 4% of the school population. The project, led by the Brent Schools Partnership, has set up a portal for parents as a resource to support their child and families in this endeavour. Parents who would like access should approach their children's school.
Thankfully in a period when Black Lives Matter has taken centre stage the project has not attracted press hostility.
A report to be discussed at tonight's Community and Wellbeing Scrutiny Committee sets out the overall context of Brent schools and the progress made in closing the gap. You can see the web broadcast of the 6pm meeting HERE.
The diverse nature of Brent’s population poses a range of challenges for schools, the most significant of which include the integration of pupils arriving late to the UK education system, high general mobility, language development needs and deprivation. This diversity is not a fixed picture but rather there are rapid changes to the population. A very high proportion of pupils have English as an Additional Language (65 per cent) and a large proportion of under 16s were born outside the United Kingdom, many starting formal education in England much later than their peers, often with little or no English, and sometimes with no experience of any formal education. The largest spoken first languages other than English are: Gujarati (nine per cent), Arabic (eight per cent), Somali (six per cent), Romanian (five per cent), Urdu (three per cent), Tamil (three per cent), Portuguese (three per cent) and Polish (two per cent).
In addition to new arrivals, socio-economic pressures placed on many of Brent’s families combined with a housing stock which relies heavily on privately rented accommodation, contribute to relatively high levels of pupil turnover in many of our schools. The proportion of Brent pupils who are disadvantaged is 24 per cent. There is a higher proportion of pupils identified as disadvantaged in the secondary phase (28 per cent).
The tables below show that the work of individual schools within the project has had a real impact with British Black Caribbean Boys achieving nearer and sometimes above the national average at the expected level, but the percentage at the higher level lagging. Addressing this is now the focus of the project. Te help you make sense of the tables BBCH stands for Black Boys of Caribbean Heritage. LA is Local Authotiyy (Brent) Figures in green are a positive gap (above the national level) and red a negative gap (below). Key Stage 1 will now be a focus given these statistics. It is important to compare the outcomes of each group both with the national figure for that group and the Brent (LA) and National figures for all pupils.
