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The Rt Hon John Denham MP
The Secretary of State
Department for Communities and Local Government

Dear Sir,

Brent Cross Cricklewood Outline Application, C17559/08
Local Authority: The London Borough of Barnet

I wrote to you in July with my concerns in regard to the consideration of this major strategic application in the London Borough of Barnet. Although the application was seriously flawed and will have a significant impact on proximate areas, the application was passed by Barnet’s Planning and Environment Committee on November 19th 2009.

By means of this submission I am reiterating my request to you to call in this planning application for the following reasons:

1.0 Background:

The outline application for this comprehensive mixed-use redevelopment of the Brent Cross Cricklewood regeneration area was first submitted on 25th March 2008, however the planned regeneration of the area has a much longer history. In 2000 The Secretary of State defined Brent Cross as a regional shopping centre in an out-of-centre location and should therefore be developed after local town centres which are favoured first. Following this, the aim became a new town centre, as defined in Barnet’s UDP as a ‘New High Street’ and the London Plan 2004. However, the outline application and permission for Stage 1 developments that has now been passed amounts to little more than an expansion of out-of-town retail provision, while the rest of the development is postponed to later stages and therefore not guaranteed. I am of the belief there is a significant danger ‘Brent Cross Cricklewood’ will proceed to provide an expansion of out-of-town shopping, contrary to the former Secretary of State’s wishes, and little else.

2.0 Flawed Consultation:

Throughout the process there has been a total lack of meaningful consultation with Brent’s residents west of the site. While I acknowledge that there have been some extensions granted for statutory consultation period very little, if any, of the details of the project have been conveyed by the Applicant and the Local Planning Authority (Barnet Council) to Brent residents through the consultation process. Brent Council’s Planners have had made formal representations to Barnet Council on this matter.

3.0 Waste Handling Facility:

Brent residents have received poor information as to the likely detrimental impact of the development of the proposed Waste Handling Facility. There are genuine and serious concerns about the waste handling facility which is perceived as a proposal for an incineration unit. While the Applicant claims this is not an incinerator, it is most regrettable that even fundamental and critical information such as emission levels and the actual process for waste management proposed by the Applicant are not clearly conveyed to the local residents and traders. Neither the Applicants, the London Borough of Barnet nor the North London Waste Authority have, in my opinion, reasonably addressed confusion over the type of plant technology and as a result its environmental and traffic impact on eastern Brent is not fully known.

4.0 Traffic and Transport:

This is one of the most serious issues which has received universal condemnation. Both Brent and Camden Councils raised serious concerns on the key components and residents are quite rightly worried about detrimental impact from traffic generated from this scheme.

My own comments on this issue are noted in the attached objection letter to Barnet Council.

The London Borough of Brent in its various communications to Barnet also objected to this aspect of the application because an overall assessment of the impact on Brent’s transport system was not forthcoming, neither was there a mitigation strategy from the applicant. In additions to the specific issues covering transport and traffic, ring-fenced Section 106 contributions to the tune of £5 million also need to be addressed by Barnet Council and the applicant.

Like Brent, the London Borough of Camden too has put in strong objections. Camden highlights the flawed transport proposals, which are heavily reliant on private car use and the resultant ‘avoidable and unnecessary increase on Camden’s roads. There’s also severe criticism of ‘undue attention given to increasing the capacity of road junctions’. The Council very justifiably commented that there is a great potential to improve public transport, walking and cycling and like Brent Council it has asked for fundamental review of a proposed transport strategy that does little to improve public and sustainable transport.

5.0 Retail and Regeneration:

I am of the belief the Brent Cross Cricklewood application as it stands presents the threat of out-of-town facility expansion to North West London’s town and district centre. As a Councillor, resident and a member of Harrow Council’s Local Development Framework Panel I am extremely concerned about the serious concerns this development would have on the ailing outdated Harrow’s town centre among other Local District Centres.

I further note that Camden Council has expressed their concerns in that its areas like Kilburn Town Centre (which forms the border between Camden and Brent) would be vulnerable to the significant increase of retail provision at Brent Cross Cricklewood.

6.0 Affordable Housing:

The London Plan in its current form (2004) and the UDPs quite rightly seek and demand a high level, up to 50%, of affordable housing. In addition the Mayor of London is struggling to meet his stated target of 50,000 affordable housing by 2012. The 15% affordable housing target does not meet these justified planning policies. I support Camden Council’s objection in that 15% is woefully short and that the development must aim to increased provision of at least 30% of the total proposed housing with an emphasis on the delivery of large family units of 3 and 4 bedrooms.

Furthermore, there is great concern that the majority of affordable housing will be pushed back into the later stages of the development. Only 795 residential units are planned for Stage 1, while the 2000 decision saw the 2000 residential units as “nebulous”. The Mayor of London has stated (in a public response to my question 3474/2009, Mayor’s Question Time, November 18th 2009) that “all remaining phases will have a 15% minimum level of affordable housing with the opportunity to go above this should viability allow.” I am of the belief this level is woefully inadequate and undermines the pretence and marketing that Brent Cross will provide a viable town centre.

7.0 Conclusion:

The application is flawed and does not conform to major planning policies. Whilst its understandable that the application of such sub-regional significance requires greater length of time for negotiations, amendments and deliberations it has been clear that Barnet Council’s oversight has been a complete shambles.

For the above reasons, I am of the belief that the outline application, flawed and unambitious as it is, wastes the opportunity of a successful, green, long-lasting alternative to the car-orientated Brent Cross plans of the 1960s by merely ameliorating this outdated vision.

I request the Right Honorable Minister ‘calls in’ the above planning application.

Yours sincerely,

Navin Shah AM

Assembly Member for Brent and Harrow

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