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Draft Harlesden Neighbourhood Plan Responses

Name of Respondent

Company Comments

David Walton

Dear Planning Strategy Regarding Harlesden Neighbourhood Plan- I don't believe it. There is a crisis need for Brent decision-makers and major risk-takers to look at the massive social failure of South Kilburn and the needless and ongoing complex injustices state imposed on this specific red lined for exclusion community by the chaotic non- plan for developer profit maximisation approach of the 13 years of 'delivery' endured so far. 13 years of not one new replacement social rent flat built for this community yet and no CIL spent on central park and community infrastructure and oversubscribed schools sites either. No Civic Duty to estate non-people just super prime surplus land of unregistered uses to land power force clear and private contract enclose. Developers only want a build private flats mono culture in Brent and this is OK? Brent shared partnership plans with communities don't hold up legally and CIL is never ring fenced to the neighbourhood densifying as investing CIL in infrastructure would derail the 'movable feast' mono no-plan developers must have. Junk anti-urbanism. Yours, despairing of the state internal colonialism currently cannibalising estate communities and this dangerous private market profit culture of non listening, non engaging, non including, no rights and how this absolutist indifference spreads including to Harlesden. How to de-colonialist mindset developers working in Brent and bring back 'regeneration of people as well as place' public safeguards? A South Kilburn Pilot Project is a good idea for this as we are the pathfinder which lost it path and which other Brent neighbourhoods alarmingly follow.

Environment Agency

Thank you for consulting the Environment Agency on the Draft Neighbourhood Plan for Harlesden. We aim to reduce flood risk, while protecting and enhancing the water environment. We have had to focus our detailed engagement to those areas where the environmental risks are greatest. Based on the environmental constraints within the area, we have no detailed comments to make in relation to your Plan at this stage. However together with Natural England, English Heritage and Forestry Commission we have published joint advice on neighbourhood planning. This sets out sources of environmental information and ideas on incorporating the environment into plans. This is available at: http://publications.environment-agency.gov.uk/PDF/GEHO0212BWAZ-E-E.pdf. The Local Authority will be able to advise if there are areas at risk from surface water flood risk (including groundwater and sewerage flood risk) in your neighbourhood plan area. The Surface Water Management Plan will contain recommendations and actions about how such sites can help reduce the risk of flooding. This may be useful when developing policies or guidance for particular sites.

Danielle Gaynor

To Whom It May Concern, Thank you for providing the above document regarding development in Harlesden. It is a thorough and well thought through document. I do have comments, though, and will present these in order of line items from the document. Section 6.18 - Recommendations One recommendation is that a majority of new housing consist of 2 bed flats. Given the emphasis in section 6.3 on overcrowding, and elsewhere on the growing numbers of people who live alone, I wonder, why mostly 2 bed flats? 25% is not enough. Section 6.21 Proposed locations for housing

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Name of Respondent

Company Comments

I support all of the suggested and potential sights, with the exception of Tubbs Rd/Willesden Jct. I look at that site from the train platform every day and cannot imagine how you will get housing + access to it into that space. What happens when there is a fire? Or an ambulance is needed? How do people even move in? Moreover, the technical problems related to bringing in and removing waste water appear considerable. On the other hand, what would be great in that spot is an allotment, as per Section 8.7. This would also be more compatible of the goal of maintaining a minimum of biodiversity (Section 8.25). Section 6.26 Affordable Housing It is crucial to take this into account in a Ward such as Harlesden. It is also worth acknowledging the increased pressure on social/affordable housing in TFL Zones 2+ due to lack of effort on the part of boroughs such as Chelsea and Westminster, which preferred to accept that developers pay fines rather than renew social housing stock in their projects. Is there any way for Brent to charge Zone 1 boroughs extra for rehousing the residents they “export”? Section 6.28 - what does this mean?

Section 8.11 Children’s play spaces

The road just to the right of Le Junction pub could become such a place, if there weren’t so many men hanging out around the pub at al l hours of the day. Sections 8.16 + Town Square I definitely support underground parking below the proposed square. Getting cars off the streets would help to keep traffic moving, and make the overall environment more pleasant. Regarding the square itself, the proposed drawing is incredibly sterile. Could there even be scope for flower beds around the fountain? Benches? Section 8.21 - I walk past the bus depot every day. This doesn’t particularly bother me, and I never have to wait long to cross the entrance to the depot. The little area just next to it (across Harley Rd from the bookies) is also pleasant, and is a gathering spot for a group of people whose social life revolves around the bookies. They do no harm. For me, all of that is far less of a problem than the anti-social behaviour which is rife in this part of Harlesden. People shooting up behind the postal delivery depot, others openly dealing drugs and drinking alcohol, and throwing their trash all over Bramshill Open Space, these are problems. The parade of shops on Station Rd between Tubbs Rd and Le Junction, these are unattractive and I definitely support improving their appearance. The parade on the other side of Station Rd between the bookies and the Royal Mail Delivery Depot, could likewise use refreshing, so I am glad to see that later on in the proposal. Section 9.10 - please don’t move the Royal Mail Depot! It is a real bonus living where I do to be able to pick up parcels without the use of public transport or lengthy walks. That said, if the little ‘alcove’ in the fence (toward Station Rd) could be closed, it would then not provide a place for people to indulge their crack habit at all hours of the day. Section 9.17 Economy I, too, wonder about the impact of the proposed link between Willesden Jct and the new station at Old Oak Common. The plans that I have seen are for a pedestrian street lined with restaurants/cafes and shops. Moreover, in the development of Station Road and the Town Square, we need to protect space for independent shops and restaurants, rather than let them be taken over by high street chains. Encouraging crafts and trades people to set up business in these premises would have further community building benefits, as well as promoting a diversity of local businesses. On this line, we desperately need a new GP surgery in this part of Harlesden, since the local NHS commissioning group (CCG) closed the surgery on Acton Lane and split it between Central Middlesex Hospital and another practice on the other side of Harlesden. I know this isn’t up to the Neighbourhood Forum, but could links be made with the CCG?

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Name of Respondent

Company Comments

Section 9.20 - I disagree that Station Road retail should be further developed at the expense of Craven Rd, as that would make the South of Harlesden shop heavy while leaving very little between town square and Roundwood Park. Moreover, I wonder if the failure of the businesses in the Acton Lane parade is not further evidence that there is not enough local support for further shops, take aways in this part of the Ward. As it is only about half of the businesses in Station Road seem to be thriving. Section 9.27 - I agree! Too many take aways as it is. Wrappers, bags, cups etc end up strewn all over the streets and my local open space. The litter is disgusting. Section 9.29 I would definitely support using the Acton Lane parade in this way! Good idea. Section 10.3. Isn’t it remarkable that Harlesden has such poor air quality, and simultaneously has lower than average car ownership? It must be a) traffic flow is not well managed and b) most of the traffic is from out of area. In regard to b), how can we reconcile trying to draw people into the area for ‘niche’ shopping, and trying to discourage use of cars? Even for those of us committed to using public transport on principle (re air quality etc), it is a challenge with lots of packages. Also, I applaud the focus on cycling and walking in this document. However, it will also be important to address the terrible and dangerous driving that we see every day - especially around the High Street/Park Parade/Harrow Rd junction. I won’t cycle in Harlesden until we see improvements. 10.5 The busyness and great connectivity of Willesden Junction station make it absolutely insane that HS2 and Crossrail don’t use this site to link to West and Central London, rather than going through Action. No one considered the people travelling when they made this decision. It is a shame that Brent didn’t fight better for this. 10.12 100% support for a road linking Scrubbs Lane and Old Oak Lane. I have wondered a million times why this doesn’t already exist. Section 11 Site allocation 4 - How would this generate 200 jobs? Again, how could you get 600 homes in there? Especially without having a significant impact on the houses on that side of Tubbs Lane, whose gardens would become the view of what must be blocks of flats that are imagined. That is pretty much the comments I have regarding this document. Again, many thanks for the hard work that has gone into drawing it up!

Francesca Leon

Title of e-mail: Plaza

It would be a real boost to the area to ensure there are lots of trees & green areas but also to have a market square option in the plaza & begin a weekly 'farmers market'. This would bring people from all around. Queens Park Farmers' market is popular but not very diverse. Harlesden could champion this.

Highways England

Dear Brent Planning Strategy, Thank you for your letter dated 08 August 2018, inviting Highways England to comment on the above consultation. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and, as such, Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs, as well as in providing effective stewardship of its long-term operation and integrity. We will therefore be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN, in this case, particularly the M1 in the vicinity of junction 1. Having examined the Draft Harlesden Neighbourhood Plan, we are satisfied that its policies will not materially affect the safety, reliability and / or operation of the SRN (the tests set out in DfT C2/13 para 10 and DCLG NPPF para 32). We note, however, that we should be continually consulted as planning applications for individual sites are submitted – particularly regarding the Harlesden Plaza and Willesden Junction Station sites.

Historic England

Dear Sir/Madam

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Name of Respondent

Company Comments

Harlesden Neighbourhood Plan submission draft consultation (May 2018) Historic England is the Government’s adviser on all matters relating to the historic environment and a statutory consultee on a broad range of applications and plans. Accordingly, we have reviewed your document in light of the National Planning Policy Framework (NPPF), with particular regard to the NPPF’s core planning principle that heritage assets be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life and this and future generations. Having done this, and further to our advice in response to the Harlesden Neighbourhood Plan and SEA Screening Opinion consultation on 30th March 2017, and 11th May 2018, Historic England can offer the following advice. We continue to welcome the efforts that the Neighbourhood Forum has made to strengthen the policies within the Draft Plan, particularly around heritage, design and place-making. There are four areas of the Plan that could benefit from clarification in our view before it is adopted. Firstly, in relation to the tall bui ldings policy E9, while we welcome the references to enhancing local character and responding to local architectural and urban design characteristics, we consider that the term ‘unacceptable adverse impacts ‘is unhelpful. This is because it is vague and accepts an unspecified and potentially significant level of adverse impacts (harm) as a matter of course. This is likely to weaken the protections given to heritage assets by national policy and legislation. We encourage the forum to review this wording and replace it with something more robust that promotes high quality buildings only in appropriate locations. Secondly, in relation to policy E6 Gateways, we are unclear what the policy is looking to promote. If it is about improved public realm and reinforcing distinctive local identity we would welcome the aspiration. However, we note that the term ‘gateway’ is often used to justify tall buildings in inappropriate locations that rarely respond to established local character and only have landmark impacts due to their height. As the promotion of tall buildings around the edges of Harlesden does not appear to fit the wider aims of the plan we recommend that a short clarification be added to the policy box and in the accompany paragraphs8.18-8.21 to say more clearly what the Forum wish to see come forwards. We are also concerned about Community Aspiration 5 – Roundwood Park recreation space, which seeks to put sports pitches or other recreational spaces into a statutorily registered park and garden. This is because such facilities often involve significant landscape changes, and potentially intrusive associated facilities like flood lighting. The detailed register entry for this designated heritage asset (equal in significant to a grade II listed building) which retain much of its late Victorian character in line with the architectural character of much of the town centre, can be found on our website (https://historicengland.org.uk/listing/the-list/list-entry/1001556), We note that this is one of the only three registered parks and gardens in Brent, the other to being cemeteries, and therefore are concerned that its significance should be fully understood before proposals are brought forward. We suggest you contact London Parks and Garden Trust who may be able to offer further advice to ensure that sensitive proposals are brought forward. Finally, in appendix A (p.92) the glossary entry for Listed Buildings state that English Heritage are responsible for designating buildings for listing. Historic England has performed the function of managing the National Heritage List for England and advising DDCMS on which assets merit designations since 2015. As such we would respectfully ask you to amend this error. Please note that this advice is based on the information that has been provided to us and does not affect our obligation to advise on, and potentially object to any specific development proposals which may subsequently arise from your Neighbourhood Plan, and which may have adverse effects on the environment. We trust this advice is of assistance in the preparation of your Plan.

Kevin Early Dear Madam/Sir, Having read the Harlesden Neighbourhood plan I can confirm that I am broadly in support of the proposals. While I understand it is a framework to guide future development and change, I do feel it is worth noting that much of this change will inevitably be driven by private investment (while of course ensuring acceptable levels of affordable housing are met). My concern is that all this hard work will be wasted and will amount to nothing unless the area is helped in the short term to irradiate the anti-social behaviour that has increased in Harlesden, (specifically drug dealing, street drinking, drug use, abusive groups congregating, fly tipping, street litter, illegal parking), and generally the feeling that the area is becoming more unsafe, and is a kind of 'wild west' where people can get away with anything. I appreciate that much of this is as a result of a stretched police presence (which simply must be addressed) but I also feel that the councils approach to social housing is not as mixed as it might be, and is in danger of turning Harlesden into a ghetto for want of a better word, rather than the healthy mix of cultures, backgrounds, ages,

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Name of Respondent

Company Comments

incomes, demands, contributors, entrepreneurs, workers etc. etc. that everyone celebrates. In short, I’m simply pointing out that building new buildings will not fix all the issues overnight! On the infrastructural changes suggested, I am fully in support of redeveloping Willesden Junction Station, (which MUST include an improved the link to Harrow Road which is currently unwelcoming and unsafe), I think it will be key to turning the area around, and is a massive opportunity. I’m also mindful of the fact that not all change is good, so I’m also supportive of introducing ‘safer streets’ to the area as I’ve no doubt that traffic through the area wil l increase, and residential streets should be able to protect themselves from the changes around them. I’m also fully supportive of making cycling and cycle routes a priority for the area. In conclusion I’m excited that such a great deal of thought and planning has gone into this document and I hope it will lead to people ‘caring’ for the area and each other more.

National Grid

Dear Sir/Madam Harlesden Neighbourhood Plan Consultation SUBMISSION ON BEHALF OF NATIONAL GRID National Grid has appointed Wood to review and respond to development plan consultations on its behalf. We are instructed by our client to submit the following representation with regards to the above Neighbourhood Plan consultation. About National Grid National Grid owns and operates the high voltage electricity transmission system in England and Wales and operate the Scottish high voltage transmission system. National Grid also owns and operates the gas transmission system. In the UK, gas leaves the transmission system and enters the distribution networks at high pressure. It is then transported through a number of reducing pressure tiers until it is finally delivered to our customers. National Grid own four of the UK’s gas distribution networks and transport gas to 11 million homes, schools and businesses through 81,000 miles of gas pipelines within North West, East of England, West Midlands and North London. To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect our assets. Specific Comments An assessment has been carried out with respect to National Grid’s electricity and gas transmission apparatus which includes high voltage electricity assets and high pressure gas pipelines, and also National Grid Gas Distribution’s Intermediate and High Pressure apparatus. National Grid has identified that it has no record of such apparatus within the Neighbourhood Plan area. Key resources / contacts National Grid has provided information in relation to electricity and transmission assets via the following internet link: http://www2.nationalgrid.com/uk/services/land-and-development/planning-authority/shape-files/ Electricity distribution

The electricity distribution operator in London Borough of Brent Council is UK Power Networks. Information regarding the transmission and distribution network can be found at: www.energynetworks.org.uk Please remember to consult National Grid on any Neighbourhood Plan Documents or site-specific proposals that could affect our infrastructure Hannah Lorna Bevins Consultant Town Planner

Spencer Jefferies Development Liaison Officer, National Grid

n.grid@amecfw.com box.landandacquisitions@nationalgrid.com Wood E&I Solutions UK Ltd Gables House

National Grid House Warwick Technology Park

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Name of Respondent

Company Comments

Kenilworth Road Leamington Spa Warwickshire CV32 6JX

Gallows Hill Warwick CV34 6DA

Canals and River Trust

Dear Sir/Madam Harlesden Neighbourhood Plan Consultation

Thank you for the opportunity to comment on the draft Harlesden Neighbourhood Plan. I can confirm that the Canal & River Trust has no land or waterspace interests within the neighbourhood plan area and therefore has no formal comments to make. We do however acknowledge reference to linking the High Street to other areas, including use of the canal for pedestrian and cycle use.

Natural England

Dear Sir or Madam Harlesden Neighbourhood Plan Publication

Thank you for your consultation on the above dated and received by Natural England on 8th August 2018. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England does not consider that this neighbourhood plan poses any likely risk or opportunity in relation to our statutory purpose, and so does not wish to comment on this consultation.

The lack of comment from Natural England should not be interpreted as a statement that there are no impacts on the natural environment. Other bodies and individuals may wish to make comments that might help the Local Planning Authority (LPA) to fully take account of any environmental risks and opportunities relating to this document. If you disagree with our assessment of this proposal as low risk, or should the proposal be amended in a way which significantly affects its impact on the natural environment, then in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, please consult Natural England again.

Woodland Trust

Re: Consultation on Harlesden Neighbourhood Plan Woodland Trust response Thank you very much for consulting the Woodland Trust on your neighbourhood plan for Harlesden, we very much appreciate the opportunity. Neighbourhood planning is an important mechanism for also embedding trees into local communities, as such we are very supportive of some of the policies set out in your plan. Vision and Objectives

The Woodland Trust is pleased to see that your Neighbourhood Plan identifies the important role that trees play, and that opportunities should be taken to increase tree cover in appropriate locations in Harlesden. Trees are some of the most important features of your area for local people. Already this is being acknowledged with the 2010 adopted Local Plan for Brent which acknowledges the need to improve existing whilst also planting new trees. Therefore, this should also be taken into account with an objective for your Neighbourhood Plan for Harlesden, and should be amended to include the following: Increase the amount of open space locally and improve the street environment, protect and retain any ancient and veteran trees, important views, natural features and biodiversity for the benefit of the local community.

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Company Comments

Environment and Open Space

We are pleased to see that Policy E8 acknowledges the vital contribution of the countryside, which is characterised by numerous native trees, and how these need to be conserved and also enhanced by your Neighbourhood Plan for Stapleford. But this should also recognise the fact that development should not lead to loss or degradation of trees in your parish. Increasing the amount of trees in Harlesden will provide enhanced green infrastructure for your local communities, and also mitigate against the future loss of trees to disease (eg Ash dieback), with a new generation of trees both in woods and also outside woods in streets, hedgerows and amenity sites. Information can be found here: http://www.magic.gov.uk/MagicMap.asp and http://www.ancient-tree-hunt.org.uk/discoveries/interactivemap/ Ancient woodland would benefit from strengthened protection building on the National Planning Policy Forum (NPPF). On 24th July the Ministry of Housing, Communities and Local Government published the revised NPPF which states: development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists The Woodland Trust believe this must be given due weight in the plan making process as it shows a clear direction of travel from central Government to strengthen the protection of irreplaceable ancient woodland and trees. Therefore, we would recommend that Policy E8 (Tree protection and provision) should include the following: ‘There should be no harm to or loss of irreplaceable habitats such as ancient woodland, ancient trees and veteran trees The Woodland Trust would suggest that your Neighbourhood Plan is more specific about ancient tree protection. For example, the introduction and background to the consultation on the Kimbolton Neighbourhood Development Plan (2017), identified the importance of ancient woodland, and how it should be protected and enhanced. Also, we would like to see buffering distances set out. For example, for most types of development (i.e. residential), a planted buffer strip of 50m would be preferred to protect the core of the woodland. Standing Advice from Natural England and the Forestry Commission has some useful information: https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences We would like to see the importance of trees and woodland recognised for providing healthy living and recreation also being taken into account with your Neighbourhood Plan for Harlesden. In an era of ever increasing concern about the nation’s physical and mental health, the Woodland Trust strongly believes that trees and woodland can play a key role in delivering improved health & wellbeing at a local level. Whilst, at the same time, the Health & Social Care Act 2012 has passed much of the responsibility for health & wellbeing to upper-tier and unitary local authorities, and this is reinforced by the Care Act 2014. Also, each new house being built in your parish should require a new street tree, and also car parks must have trees within them. Community Facilities Whilst protecting natural features such as community space is being take into account with the supporting text of Policy CF1 (Community Space Provision), it should also seek to retain and enhance recreational and local green spaces, resist the loss of open space, whilst also ensuring the provision of some more. Therefore, to what extent there is considered to be enough accessible space in your community also needs to be taken into account with new housing proposals. There are Natural England and Forestry Commission standards which can be used with developers on this: The Woodland Access Standard aspires:

That no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size.

That there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round trip) of people ’s homes.

The Woodland Trust also believes that trees and woodlands can deliver a major contribution to resolving a range of water management issues, particularly those resulting from climate change, like flooding and the water quality implications caused by extreme weather events. This is important in the area covered by your Neighbourhood Plan because trees offer opportunities to make positive water use change, whilst also contributing to other objectives, such as biodiversity, timber & green infrastructure - see

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the Woodland Trust publication Stemming the flow – the role of trees and woods in flood protection - https://www.woodlandtrust.org.uk/publications/2014/05/stemming-the-flow/. Woodland Trust Publications

We would like to take this opportunity to draw your attention to the Woodland Trust’s neighbourhood planning microsite: https://www.woodlandtrust.org.uk/campaigning/neighbourhood-planning/ which may give you further ideas for your plan. Also, the Woodland Trust have recently released a planners manual which is a multi-purpose document and is intended for policy planners, such as community groups preparing Neighbourhood Plans. Our guide can be found at: https://www.woodlandtrust.org.uk/mediafile/100820409/planning-for-ancient-woodland-planners-manual-for-ancient-woodland-and-veterandtrees.pdf?cb=8298cbf2eaa34c7da329eee3bd8d48ff In addition other Woodland Trust research which may assist with taking your Neighbourhood Plan foreword is a policy and practice section on our website, which provides lots of more specific evidence on more specific issues such as air quality, pollution and tree disease: https://www.woodlandtrust.org.uk/publications/ Our evidence base is always expanding through vigorous programme of PhDs and partnership working. So please do check back or get in touch if you have a specific query. You may also be interested in our free community tree packs, schools and community groups can claim up to 420 free trees every planting season: http://www.woodlandtrust.org.uk/plant-trees/community-tree-pack/

David Craine

Attn: Brent Council I am writing, having lived in the area for over 30 years and been active in local community groups throughout that time including as a member of the Harlesden Neighbourhood Forum, to give my full support for the Harlesden Neighbourhood Plan. I have participated in many well attended local meetings where the plan has been developed and discussed and efforts made by the Forum to engage with hard to reach parts of the community. The Forum has worked hard to ensure that the Plan is well evidenced - more so than most local plans I have seen - and consistent with relevant planning policy such as the Brent local plan and the London Plan. It has also focused the plan carefully on issues of particular concern to local people including high levels of deprivation, overcrowding, housing and homelessness and the need to improve the use of land in the centre of the town. The Forum has carried out overall the most effective community engagement I have experienced in my 30+ years as a Harlesden resident. It has especially taken into account the likely impacts - both positive and negative - of the Old Oak And Park Royal Development Corporation regeneration work which has the potential to generate significant employment opportunities and potentially homes for Harlesden residents but, if not planned carefully, could create significant congestion problems for Harlesden during both the construction and occupation phases. This makes the existence of a neighbourhood driven Harlesden Plan especially important. walton The plan outlines evidence of serious overcrowding and housing need in the Harlesden and it is important that Brent Council and the OPDC work together with local residents to ensure that new housing is brought forward to meet housing need of a type and in locations which has the broad support of local people. I therefore encourage Brent Council to support the plan going forward to a full referendum.

Transport for London

Bus garage Community Aspiration 7 – Station Road land use Paras. 8.21 and 9.8

TfL notes the Neighbourhood Forum’s aspiration relating to the Willesden Junction bus garage site although TfL does not believe this aspiration can be realised within the Plan period because the site currently accommodates garage facilities which are essential to provide the local bus network. An explicit reference should be added to community aspiration 7 to explain the requirement (which is set out in the Mayor’s Land for Industry and Transport SPG) that any suitable alternative site would need to

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result in no overall loss of garage capacity and be located in the immediately adjacent area. Alternatively TfL would need to formally agree that the particular garage is no longer required which is not currently the case. As a result these conditions are unlikely to be fulfilled. TfL is pleased to note that the bus garage site is no longer included in the list of housing sites in policy H1 or the list of site allocations in chapter 11 and that in response to previous comments the references to removal of the current Strategic Industrial Land (SIL) designation have been deleted. However, there are still a number of negative references to the bus garage site and paragraphs 8.21 and 9.8 continue to seek the redevelopment and relocation of the bus garage on Station Road/Harley Road. The wording of these paragraphs cause serious concerns for Transport for London (TfL) and we would object strongly to any attempt to promote a redevelopment that involved any loss of bus garage capacity in the local area. There are two interrelated issues raised – whether the bus garage site should be improved or redeveloped and whether the Strategic Industrial Land (SIL) designation should be changed. As acknowledged by the amended wording any alterations to SIL could only be progressed through the Local Plan process and could not be promoted by a Neighbourhood Plan. OPDC’s revised draft Local Plan maintains the SIL designation and supports its continued use as a bus garage. The adopted London Plan provides protection for existing land used for transport or transport support functions in policy 6.2 requiring their identification and safeguarding through Development Plan Documents (DPDs). The Mayor’s Land for Industry and Transport SPG provides further detail relevant to bus garages and states that: ‘The loss of any bus garage through redevelopment should be resisted unless a suitable alternative site that results in no overall loss of garage capacity can be found in the immediately adjacent area, or TfL agrees formally that the particular garage is no longer required.‘ Policy T3 in the draft London Plan also states clearly that: ‘Development Plans and development decisions should ensure the provision of sufficient and suitably-located land for the development of the current and expanded public and active transport system to serve London’s needs, including by: 1) safeguarding existing land and buildings used for transport or support functions (unless alternative facilities are provided to the satisfaction of relevant strategic transport authorities and service providers that enable existing transport operations to be maintained and expanded if necessary)’ Although bus garages are mostly owned or leased by individual bus operators, TfL in its role as the strategic transport authority needs to ensure that there are sufficient and appropriately located bus garages to enable services to be provided efficiently. It is important to minimise the need for empty running from distant bus garages which adds to costs, congestion and emissions. The identification and protection provided for bus garages through DPDs, coupled with the designation of land used for a bus garage as SIL provide important safeguards against the loss of bus garages through redevelopment. The closure of any bus garage will have a negative impact on the bus network and competition in that area. Strategically this garage is well located and given its capacity for around 125 vehicles, Metroline operates 6 routes from here. The garage also supports employment in the Harlesden area and directly employs more than 450 staff (with an additional 20-30 contract roles). The garage is also the location of Metroline’s Recruitment & Training Centre, covering their entire operation in London and providing facilities for all staff to gain access to further training and qualifications such as BTECs, NVQs and Driver CPCs. Recruitment of new drivers and supervisors also takes place here, as well as the site providing an Authorised Testing Facility which undertakes MOTs, following the closure of the DVSA testing station at Yeading. The draft Neighbourhood Plan doesn’t identify an alternative location for the garage if it were to be relocated. The statement of consultation suggests that the former Freight Liner terminal (also known as Willesden Euro Liner terminal) which will be used for construction purposes by HS2 Ltd could provide an alternative. However this site would not be released by HS2 Ltd until 2026 at the earliest and its designation as a strategic rail freight facility means that HS2 Ltd would be obliged to promote a future use that maximised the benefits of its direct rail connections. Bus garages are extremely location sensitive, and even a slight relocation of a few hundred metres can significantly increase operating costs and emissions. It is not easy to find suitably located and configured land for bus garages, particularly where there is pressure for higher value development as in Old Oak and Park Royal. TfL will require evidence of early engagement with relevant parties including the operator (Metroline) to explore alternative options for the future improvement or redevelopment of the site. This should include retention of the bus garage as part of an enhancement or intensification of the existing operation rather than its wholesale relocation. It is important to note that the garage is currently leased from a third party rather than being owned by Metroline. If the operator were to consider a future relocation the following criteria for a replacement depot would need to be taken into account:

The replacement garage can operate successfully in order to protect bus operations in this part of London

The replacement garage will need to accommodate the existing fleet and the forecast one required to serve the area

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The location and design of the replacement garage within a fully mixed use development needs careful consideration in terms of the interaction of buses with

pedestrians and cyclists entering the site

The process of exploring options for improvement or redevelopment of the existing site and any consideration of alternative sites will require liaison with all the relevant local planning and transport authorities as well as TfL. Direct bus route Community Aspiration 12 – Direct bus route Para. 10.7

TfL notes the Neighbourhood Forum’s aspiration for a direct bus route from Harlesden through the proposed new High Street to the new (HS2/Elizabeth Line/Great Western) interchange station. This has previously been supported in principle by TfL pending the results of feasibility work. However Policy P2 – OON 14 in the revised draft OPDC Local Plan confirms that ‘infrastructure studies for TfL and OPDC have shown that the delivery of the northern most section of Old Oak Street (the renamed High Street) across Harlesden Place to Willesden Junction is likely to be very challenging to deliver as an all modes route and at the time of the publication of this Local Plan, OPDC would support its delivery as a wide pedestrian and cycle only connection. This would not be capable of carrying buses over the rail tracks and so the OPDC Bus Strategy now proposes to connect Harlesden with the new station by changes to route 228 which would follow Old Oak Common Lane rather than using the High Street. Proposed phased changes to bus routes in the Old Oak area are outlined in detail in the OPDC Bus Strategy developed by TfL which was published alongside the Local Plan. Roads and Traffic Paras. 10.12 and 10.14 It is noted that the Forum favours new links for vehicle traffic from Scrubs Lane to Old Oak Common Lane as part of redevelopment proposals in Old Oak. Whilst it is accepted that new routes could have some short-term beneficial impacts for traffic in Harlesden town centre, traffic modelling undertaken to date by TfL and OPDC has identified that creating new road links which are open as through routes for private vehicles is likely to cause issues elsewhere on the highway network, in particular on Old Oak Common Lane and Scrubs Lane and will draw more traffic into the area as a whole. As a result the new links proposed in OPDC Local Plan are not designed as through routes for private vehicles and will provide access only. Car Parking Policy T2, Policy SA1 Para. 10.17

TfL would support any proposed reduction in the amount of town centre car parking in order to promote access by more sustainable modes. Although justified by reference to current peak usage it is not clear why a minimum level of parking (60 spaces) should still be required after a redevelopment of the Harlesden Plaza site which could be more oriented towards access on foot, cycle or by public transport, consistent with the approach outlined in the Mayor’s Transport Strategy and the draft London Plan General Any specific policies or proposals in the submission version of the Neighbourhood Plan affecting transport assets, infrastructure or services that are owned or provided by TfL should be the subject of prior consultation. In particular any proposals for sites adjacent to or over rail tracks, stations or depots used by London Underground or Overground will need to demonstrate that there will be no adverse impact on transport operations.

Mayor of London

Dear Sir/Madam Planning and Compulsory Purchase Act 2004 (as amended); Greater London Authority Acts 1 999 and 2007;

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Town and Country Planning (Local Development) (England) Regulations 2012 RE: Harlesden Neighbourhood Forum — Submission Draft Neighbourhood Plan Consultation Thank you for consulting the Mayor of London on the draft Harlesden Neighbourhood Plan (NP). As you are aware, all Development Plan Documents in London, including neighbourhood plans must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. Paragraphs 184 and 29 of the National Planning Policy Frameworks (NPPF) 2012 and 2018, respectively also require neighbourhood plans to be consistent with the strategic policies contained in any development plan that covers their area. The Development Plan for the Harlesden Neighbourhood Area includes the London Plan and the Brent Local Plan. It must also give consideration to the Old Oak and Park Royal Opportunity Area Planning Framework and the emerging Old Oak and Park Royal Development Corporation (OPDC) Local Plan. The Mayor has afforded me delegated authority to make detailed comments which are set out below and include representations from Transport for London (TfL), which the Mayor endorses. The draft new London Plan

As you are aware, the Mayor published his Draft London Plan for consultation on 1 December 201 7 and the Minor Suggested Changes (following consultation) on 13 August 2018. The Examination in Public of the Draft London Plan will commence in January 2019 with publication anticipated in Winter 2019/20. Once published, the new London Plan will form part of the OPDC’s, Brent’s and the neighbourhood forum’s Development Plan and contain the most up-to-date policies. The Harlesden Neighbourhood Plan is required to be in general conformity with the current London Plan, however any policies that diverge from the draft new London Plan will become out of date as the draft new London Plan gains more weight as it moves towards publication. In addition, the Draft London Plan and its evidence base are now material considerations. General The Mayor welcomes the overall approach to growth and development in the draft Harlesden Neighbourhood Plan. He considers that in general the plan is positive and clearly set out. However, the Mayor does have some concerns that a few approaches may act to restrict development across the neighbourhood planning area. Neighbourhood planning provides communities the opportunity to set out a positive vision for how they want their community to develop over the next ten, fifteen, twenty years. It is about enabling rather than restricting development and a neighbourhood plan should show how it contributes towards sustainable development. Overly restrictive policies can prevent development and are contrary to the NPPE which has a presumption in favour of sustainable development. The 2012 and 2018 NPPFS make clear that neighbourhood plans should support the strategic development needs set out in Local Plans and plan positively to support local development. The neighbourhood plan area lies, primarily, within the London Borough of Brent, but overlaps with the London Boroughs of both Ealing and Hammersmith and Fulham. For planning purposes, the Harlesden Neighbourhood Area is also partially located within the Old Oak and Park Royal Development Corporation (OPDC) area. This is a significant strategic growth area for London and is recognised by the Mayor as an Opportunity Area in the London Plan and the OPDC Local Plan. The OPDC Local Plan will realise regeneration potential by setting out a clear and comprehensive strategy to optimise economic growth and regeneration potential, create a new town centre and bring many benefits for local and wider communities. Harlesden will capitalise on the benefits provided by this regeneration and the neighbourhood plan could do more to explore these opportunities. Table A1 .1 (Town Centre Network) of the Draft London Plan identifies Harlesden as a strategic area for regeneration. As such this area should support and promote development which will contribute to regeneration by tackling spatial inequalities and the environmental, economic and social barriers that affect the lives of people in the area. Plans and policies should support development that contributes to the renewal of the town centre. Sustainable Development The Mayor welcomes the aspiration of the draft Harlesden Neighbourhood Plan to promote sustainable development. Policy G1 - Sustainable Development, makes reference to Chapter 5 of the current London Plan. However, the neighbourhood plan should make reference to the more recent Draft new London Plan which will soon supersede the current one. This will ensure that the neighbourhood plan does not fall out of date quickly. Sustainable infrastructure is now contained in Chapter 9 of the

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Draft London Plan. With regards to sustainable development, the draft new London Plan designates Harlesden as a District centre with a low potential for commercial growth, but a high potential for residential growth. Housing Policy H1 of the draft neighbourhood plan identifies four sites that are suitable for residential development and a further three potential development sites. However, the neighbourhood plan policy and the supporting site allocation text do not provide further clarity or detail, setting out the quantum and appropriate types of housing. Draft Policy H2 - New housing density, refers to ‘the upper end of the density ranges’. This appears to refer to current London Plan Policy 3.4 which contains the sustainable residential quality (SRQ) density matrix. The new London Plan, once published, will not contain the SRQ density matrix but will seek to optimise density by evaluating an areas capacity (policies Dl and D2). It is therefore advised that any references to the density matrix in the neighbourhood plan be amended to take this into account. This will ensure that the neighbourhood plan does not quickly become out-of-date. Housing Size

The London Plan (policy 3.8) encourages a range of housing choices, With regards to housing mix, the London SHMA 2017 (the latest evidence) identified the following need:

Tenure 1 bed 2 bed 3 bed 4+ bed Total % of total

Market 10,682 2,043 4,101 6,210 23,037 35%

Intermediate 4,334 3,434 2,409 1,693 11,869 18%

Low=cost rent

21,318 5,311 2,462 1,881 30,972 47%

Total 36,335 10,788 8,971 9,783 65,878 100%

% of total 55% 16% 14% 15% 100%

This has informed draft London Plan H12 which states for low cost rent, boroughs should provide guidance on the size of units required (by number of bedrooms) to ensure affordable housing meets identified needs, but boroughs should not set prescriptive dwelling size mix requirements (in terms of number of bedrooms) for market and intermediate homes. Such requirements are inflexible and can fail to meet the intended need, for example, family-sized homes often end up being occupied by sharing adults rather than families, and inflexible requirements can prevent otherwise suitable sites coming forward for residential development. Paragraph 6.35 of the draft neighbourhood plan aligns itself with Brent’s Core Strategy by requiring 25% of new housing to be family sized (3 beds or more). However, this does not reflect the latest strategic evidence and is not in line with the Draft new London Plan (Policy H12). This prescriptive requirement should be amended to adopt a more flexible approach towards the delivery of larger sized dwellings. Draft new London Plan small sites policy H2 seeks to optimise the delivery of housing on small sites in areas with PTALs 3-6 or within 800m of a tube station, rail station or town centre boundary. This policy has implications for the neighbourhood plan which does not take this strategic approach into account. Limiting building heights within the Harlesden Plaza area to four storeys would conflict with Policy 3.4 and 7.7 of the current London Plan and could potentially limit the Draft new London Plan’s presumption in favour of small housing development (Draft London Plan Policy H2) and would therefore restrict the ability of Brent to meeting its proposed housing target of 2,915 per annum including its small sites housing target of 1,023. Furthermore, restriction of development to this extent could stifle the viability of any future proposals and therefore have a negative impact on the neighbourhood plan’s ability to deliver its vision and good growth. Community facilities and space Harlesden Plaza is identified as a location appropriate for the provision of new and enhanced community space. This is set out in proposed Policy CF1. The policy states that CIL funds could be used to finance this endeavour. While the Mayor welcomes the introduction of a diverse range of uses in town centres, in terms of making the best use of land, the co-location of community space with a range of other appropriate uses including commercial and where appropriate, residential should be promoted and supported. At paragraph 7.6 a standard of 370m2 per 1 000 new population for community facilities has been referred to. While such standards can provide a broad benchmark for the provision of new facilities it fails to take into account existing latent provision in the wider local area. Nearby schools, sports facilities and other types of building may

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already have community space which is underused or is not currently accessible to the general public. The neighbourhood plan should investigate if similar opportunities exist in the locality, thereby freeing up space for other uses, including housing within the neighbourhood plan area. Public Houses The Mayor welcomes and supports the neighbourhood plan’s approach to identifying and nominating public houses as assets of community value. Tall Buildings In order that local authorities are able to meet their housing targets taller (ie over four storeys) buildings will need to be considered more frequently as a potential solution in delivering the number of dwellings that London needs. The London Plan seeks to optimise development within town centres and at transport hubs, and in light of this the identification of Willesden Junction Station as an acceptable location for tall buildings is welcomed by the Mayor. However, the neighbourhood plan fails to consider the heights of buildings that will be delivered within the nearby OPDC area and Policy E9 — Tall Buildings, attempts to restrict the heights of buildings within the Harlesden Plaza site to a maximum of four storeys. The restriction of building heights in this area could restrict the viability of development proposals. The policy wording restricting building heights within Harlesden Plaza should be removed from and instead be replaced by a requirement that development proposals be sensitive and responsive to the surrounding environment and local context. Policy D8 Tall Buildings, in the Draft new London Plan and Policy 7.7 of the current London Plan should be followed and reflected in the neighbourhood plan. Local Employment Sites Harlesden, as previously stated, suffers from low job densities and high unemployment. Between 2001 and 2075, 1,300 hectares of industrial land was transferred to other uses across London. This loss of industrial capacity comes at a time when demand for industrial capacity in the capital is increasing, mostly driven by strong demand for logistics to service growth in London’s economy and population. The London Boroughs of Brent, Ealing and OPDC will experience increased demand for industrial capacity up to 2041 and have been identified in the draft new London Plan as boroughs that are required to provide additional industrial capacity. In this respect it is considered that Policy LE1 — Local employment sites, could be strengthened to afford local employment sites greater protection against changes of use. Alternatively, mixed use proposals on these sites may be considered suitable where employment uses can be appropriately co-located with others such as residential in accordance with Policy E7 of the Draft London Plan. While most of the local employment sites are small they can provide much needed smaller, more affordable business spaces for a range of commercial uses and start-up businesses. Draft London Plan Policies E4 and E7 set out the approach to be taken in the release of any type of industrial land, noting that the already significant loss of industrial land in the area has resulted in Brent and the OPDC as being authorities that are to provide additional industrial capacity. In order to ensure conformity with the London Plan, neighbourhood plan Policy LE1 — Local Employment sites should be amended to reflect Policy E4 and E7 of the Draft London Plan. Transport Bus garage Community Aspiration 7 — Station Road land use and Paragraphs 8.21 and 9.8 As stated above, the Mayor notes the Neighbourhood Forum’s aspiration relating to the Willesden Junction bus garage site. He does not believe this aspiration can be realised within the Plan period as the site currently accommodates garage facilities which are essential to provide the local bus network. An explicit reference should be added to community aspiration 7 to explain the requirement (which is set out in the Mayor’s Land for Industry and Transport SPG) that any suitable alternative site would need to result in no overall loss of garage capacity and be located in the immediately adjacent area. Alternatively, TIL would need to formally agree that the particular garage is no longer required which is not currently the case. As a result, these conditions are unlikely to be fulfilled. The Mayor is pleased to note that the bus garage site is no longer included in the list of housing sites in policy Hi or the list of site allocations in chapter 1 1 and that in response to previous comments the references to removal of the current Strategic Industrial Land (SIL) designation have been deleted. However, there are still a number of negative references to the bus garage site and paragraphs 8.21 and 9.8 continue to seek the redevelopment and relocation of the bus garage on Station Road/Harley Road. The wording of these paragraphs are of serious concern to TfL and the Mayor would object strongly to any attempt to promote a redevelopment that involved any loss of bus garage capacity in the local area.

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There are two interrelated issues raised — whether the bus garage site should be improved or redeveloped and whether the Strategic Industrial Land (SIL) designation should be changed. As acknowledged by the amended wording any alterations to SIL could only be progressed through the Local Plan process and could not be promoted by a Neighbourhood Plan. OPDC’s revised draft Local Plan maintains the SIL designation and supports its continued use as a bus garage. The adopted London Plan provides protection for existing land used for transport or transport support functions in policy 6.2 requiring their identification and safeguarding through Development Plan Documents (DPDs). The Mayor’s Land for Industry and Transport SPG provides further detail relevant to bus garages and states that: ‘The loss of any bus garage through redevelopment should be resisted unless a suitable alternative site that results in no overall loss of garage capacity can be found in the immediately adjacent area, or TfL agrees formally that the particular garage is no longer require” Policy T3 in the draft London Plan also states clearly that: ‘Development Plans and development decisions should ensure the provision of sufficient and suitably-located land for the development of the current and expanded public and active transport system to serve London’s needs, including by: 1) safeguarding existing land and buildings used for transport or support functions (unless alternative facilities are provided to the satisfaction of relevant strategic transport authorities and service providers that enable existing transport operations to be maintained and expanded if necessary)’ Although bus garages are mostly owned or leased by individual bus operators, TfL in its role as the strategic transport authority needs to ensure that there are sufficient and appropriately located bus garages to enable services to be provided efficiently. It is important to minimise the need for empty running from distant bus garages which adds to costs, congestion and emissions. The identification and protection provided for bus garages through DPDs, coupled with the designation of land used for a bus garage as SIL provide important safeguards against the loss of bus garages through redevelopment. The closure of any bus garage will have a negative impact on the bus network and competition in that area. Strategically this garage is well located and given its capacity for around 125 vehicles, Metroline operates 6 routes from here. The garage also supports employment in the Harlesden area and directly employs more than 450 staff (with an additional 20-30 contract roles). The garage is also the location of Metroline’s Recruitment & Training Centre, covering their entire operation in London and providing facilities for all staff to gain access to further training and qualifications such as BTECs, NVQs and Driver CPCs. Recruitment of new drivers and supervisors also takes place here, as well as the site providing an Authorised Testing Facility which undertakes MOTs, following the closure of the DVSA testing station at Yeading. The draft Neighbourhood Plan does not identify an alternative location for the garage if it were to be relocated. The statement of consultation suggests that the former Freight Liner terminal (also known as Willesden Euro Liner terminal) which will be used for construction purposes by HS2 Ltd could provide an alternative. However, this site would not be released by HS2 Ltd until 2026 at the earliest, and its designation as a strategic rail freight facility means that HS2 Ltd would be obliged to promote a future use that maximised the benefits of its direct rail connections. Bus garages are extremely location sensitive, and even a slight relocation of a few hundred metres can significantly increase operating costs and emissions. It is not easy to find suitably located and configured land for bus garages, particularly where there is pressure for higher value development as in Old Oak and Park Royal. TfL will require evidence of early engagement with relevant parties including the operator (Metroline) to explore alternative options for the future improvement or redevelopment of the site. This should include retention of the bus garage as part of an enhancement or intensification of the existing operation rather than its wholesale relocation. It is important to note that the garage is currently leased from a third party rather than being owned by Metroline. If the operator were to consider a future relocation the following criteria for a replacement depot would need to be taken into account:

The replacement garage can operate successfully in order to protect bus operations in this part of London

The replacement garage will need to accommodate the existing fleet and the forecast one required to serve the area

The location and design of the replacement garage within a fully mixed use development needs careful consideration in terms of interaction of buses with pedestrians and cyclists entering the site

The process of exploring options for improvement or redevelopment of the existing site and any consideration of alternative sites will require liaison with all the relevant local planning and transport authorities as well as TfL. Direct bus route Community Aspiration 12 — Direct bus route and Paragraph 10.7

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TfL notes the Neighbourhood Forum’s aspiration for a direct bus route from Harlesden through the proposed new High Street to the new (HS2/Elizabeth Line/Great Western) interchange station. This has previously been supported in principle by TfL pending the results of feasibility work. However Policy P2- OON 14 in the revised draft OPDC Local Plan confirms that ‘infrastructure studies for TfL and OPDC have shown that the delivery of the northern most section of Old Oak Street (the renamed High Street) across Harlesden Place to Willesden Junction is likely to be very challenging to deliver as an all modes route and at the time of the publication of this Local Plan, OPDC would support its delivery as a wide pedestrian and cycle only connection. This would not be capable of carrying buses over the rail tracks and so the OPDC Bus Strategy now proposes to connect Harlesden with the new station by changes to route 228 which would follow Old Oak Common Lane rather than using the High Street. Proposed phased changes to bus routes in the Old Oak area are outlined in detail in the OPDC Bus Strategy developed by TfL which was published alongside the Local Plan. Roads and Traffic Paragraphs 10.12 and 10.14 It is noted that the Forum favours new links for vehicle traffic from Scrubs Lane to Old Oak Common Lane as part of redevelopment proposals in Old Oak. Whilst it is accepted that new routes could have some short-term beneficial impacts for traffic in Harlesden town centre, traffic modelling undertaken to date by TfL and OPDC has identified that creating new road links which are open as through routes for private vehicles is likely to cause issues elsewhere on the highway network, in particular on Old Oak Common Lane and Scrubs Lane and will draw more traffic into the area as a whole. As a result, the new links proposed in OPDC Local Plan are not designed as through routes for private vehicles and will provide access only. Car Parking PoIicyT2, Policy SA1 and Paragraph 10.17 The Mayor will support any proposed reduction in the amount of town centre car parking in order to promote access by more sustainable modes. Although justified by reference to current peak usage it is not clear why a minimum level of parking (60 spaces) should still be required after a redevelopment of the Harlesden Plaza site which could be more oriented towards access on foot, cycle or by public transport, consistent with the approach outlined in the Mayor’s Transport Strategy and the draft new London Plan. General Any specific policies or proposals in the submission version of the Neighbourhood Plan affecting transport assets, infrastructure or services that are owned or provided by TfL should be the subject of prior consultation. in particular any proposals for sites adjacent to or over rail tracks, stations or depots used by London Underground or Overground will need to demonstrate that there will be no adverse impact on transport operations. Glossary of Terms The Mayor’s preferred affordable housing tenures are not referred to in the definition of affordable housing in the neighbourhood plan’s glossary. As these tenures will make up the greatest contribution in delivering affordable housing across London in the coming years it is advised that the neighbourhood plan includes these products (London Affordable Rent, London Living Rent and London Shared Ownership) in its definition of affordable housing. See paragraph 4.7.3 of the Draft London Plan and the Mayor’s Homes for Londoners Affordable Homes Programme 201 6-21. Maps/Images A more accurate image illustrating the precise boundary of the neighbourhood plan area would be advisable to avoid any disputes and issues regarding which land lies within and outside the boundary line. A link to Brent’s interactive mapping system, showing the extent of the neighbourhood plan boundary line, should be provided in the neighbourhood plan document. A couple of images illustrating site allocation boundaries could be clearer and more accurate. Location plans for Willesden Junction Station and Former Willesden Ambulance Station, for example, are not as clear as others in the neighbourhood plan. it is advised that these images be improved to avoid boundary issues.

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Thames Water

Dear Sir/Madam, Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for parts of the southwestern area of the district and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. General Comments Thames Water welcome the references to water and wastewater infrastructure issues highlighted within the draft Neighbourhood Plan. It should be noted that the position with regard to the need for infrastructure upgrades can change over time as capacity will depend on development undertaken elsewhere in the catchment. From the 1st April 2018 all network reinforcement work required to support development is now delivered by Thames Water and funded through the Infrastructure Charge applied to each property connected to the water and wastewater networks. The Infrastructure Charge will also cover all modelling and design work required to deliver any necessary upgrades. However, in most circumstances Thames Water will not commit to undertaking detailed modelling and design work until there is certainty of development coming forward. This is because without certainty of development coming forward the modelling and design work may be abortive. In order to assist with planning infrastructure upgrades Thames Water would welcome early engagement from developers to discuss their proposals and programmes. This will assist with avoiding the need for phasing conditions to be sought for planning proposals to ensure that any necessary upgrades are delivered ahead of the occupation of development. As a result we would welcome the inclusion of the following or similar text within the Neighbourhood Plan. “In order to ensure that the water supply and drainage requirements of development proposals are understood and that any upgrade requirements are identified, all developers are encouraged to contact Thames Water Developer Services in advance of the submission of planning applications. Information for Developers on water/wastewater infrastructure can be found on Thames Water’s website at: http://www.thameswater.co.uk/developers/1319.htm. Contact can be made with Thames Water Developer Services by: Post to: Thames Water Developer Services, Clearwater Court, Vastern Road, Reading, RG1 8DB by telephone on: 0800 009 3921 or by Email: developer.services@thameswater.co.uk” Site Specific Comments

Is it appreciated that some of our previous site specific comments have been incorporated into draft Neighbourhood Plan. However, for completeness comments on all of the allocations within the Neighbourhood Plan are appended to this letter.

Site ID Site Name Water Response Waste Response

5070 Car Sales At Junction of High Street and Furness Road

On the information available to date we do not envisage infrastructure concerns regarding Water Supply capability in relation to this site.

On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

55065 Harley Road, NW10

On the information available to date we do not envisage infrastructure concerns regarding Water Supply capability in relation to this site.

On the information available to date we do not envisage infrastructure concerns regarding wastewater networks in relation to this development/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ. On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

55069 Land at Challenge Close and Rear of 50-

On the information available to date we do not envisage infrastructure concerns regarding Water Supply

On the information available to date we do not envisage infrastructure concerns regarding wastewater networks in relation to this development/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email

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Company Comments

70Craven Park Road

capability in relation to this site.

Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

15521 SA1 – Harlesden Plaza Site

The water network capacity in this area may be unable to support the demand anticipated from this development.. Local upgrades to the existing water network infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. The developer is encouraged to work Thames Water early on in the planning process to understand what infrastructure is required, where, when and how it will be delivered.

The wastewater network capacity in this area may be unable to support the demand anticipated from the development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application

119 SA2 Salvation Army Hall and Manor Park Paper Works, Manor Park Road

On the information available to date we do not envisage infrastructure concerns regarding Water Supply capability in relation to this site

On the information available to date we do not envisage infrastructure concerns regarding water supply networks in relation to this development/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

58873 SA3 Former Willesden Ambulance Station, 154 Harlesden Road Site Allocation

On the information available to date we do not envisage infrastructure concerns regarding Water Supply capability in relation to this site.

On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

55071 SA4 Willesden Junction Station

The water network capacity in this area is unlikely to be able to support the demand anticipated from this development. Strategic water supply infrastructure upgrades are likely to be required to ensure sufficient capacity is brought forward ahead of the development. The developer is encouraged to work Thames

The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.

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Water early on in the planning process to understand what water infrastructure is required, where, when and how it will be delivered.

Beckley Group Limited

I write to provide you with comments on the Submission Draft Version of the Harlesden Neighbourhood Plan (May 2018) on behalf of my Client, the Beckley Group Limited. Background The Beckley Group Limited are a Harlesden-based business located on Manor Park Road. The company’s plan is to grow its existing London-based social housing property portfolio. The Beckley Group Limited are a pioneering organisation that combines the expertise of development management, construction and residence services to provide high quality affordable housing for Londoners to live in. Beckley Living, part of the Beckley Group, is also a provider of high-quality affordable workspace for start-ups and established businesses. They are a one-stop shop solution for delivering high quality, well designed and energy efficient affordable homes and places to work in England who combine expertise in affordable housing with private finance to provide well managed, low-cost housing and commercial spaces for people to work and live in. Environment, Social and Governance (ESG) factors are becoming increasingly important considerations across the entire property management landscape, which is why ESG principles are woven into the fabric of the Beckley Group’s Corporate Social Responsibility Strategy. The Beckley Group Limited have been in discussion with Harlesden Neighbourhood Forum in their capacity as a local business and key stakeholder group with interests to deliver much needed affordable homes within Brent. Beckley Group successfully acquired and redeveloped the site at 1 Manor Park Road (Park House) to provide fifteen affordable flats for rent for those in need or less well off by working with local authorities to provide good, high quality homes particularly for people living in temporary accommodation. 9 of the 15 apartments house Brent residents. The company is very keen to deliver similar developments in the Brent area and are currently pursuing a redevelopment proposal for 45 new flats in Harlesden at the Manor Park Works site (Site Allocation Policy SA2 in the Harlesden Neighbourhood Plan). The Beckley Group therefore have a very keen interest in the Harlesden Neighbourhood Plan (HNP) and the Forum’s vision for how Harlesden can develop and grow over the next fifteen years and in particular, how this vision compliments the Beckley Group’s vision to provide 10,000 much needed affordable homes in Brent and throughout London within the next five years. It is on this basis, that the following representations are submitted. The following comments are made specifically in relation to the policies contained in the latest draft of the HNP (May 2018): The revised National Planning Policy Framework (NPPF) (July 2018) The Submission Draft of the HNP was published before the revised NPPF was published in July 2018. It needs to be reviewed to ensure that it aligns with the revised national policy framework. In particular, Section 2 of the HNP needs to be updated to reference the revised NPPF. Draft New London Plan The current 2016 Plan (The London Plan consolidated with alterations since 2011) is still the adopted Plan, but the Draft London Plan is a material consideration in planning decisions. On 13th August 2018, the Mayor published a version of the draft Plan that included his minor suggested changes. These suggested changes have been prepared following a review of consultation responses, and consist of clarifications, corrections and factual updates to the draft Plan that will help inform the Examination in Public. As the HNP needs to be in general conformity with the London Plan, the Submission Draft version should be reviewed to pick up on the new and emerging policy as a result of the Mayor’s August 2018 changes – and Section 2 of the HNP should be updated to reference this.

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Policy G1 (Sustainable Development) This is a new policy in the HNP May 2018 version and it is welcomed. Policy H2 (New Housing Density)

It is noted that this policy still expects new housing development to be delivered at the upper end of the density ranges of Table 3.2 of the London Plan relevant to the location of the proposed housing site and subject to it being acceptable in terms of local context and design. This policy needs to be revised to reflect and be consistent with the new approach to optimising housing density as per paragraph 3.6.1 and Policy D6 in the draft new London Plan. This policy states that development proposals must make the most efficient use of land and be developed at the optimum density which should result from a design-led approach to determine the capacity of the site. The policy requires particular consideration to be given to: 1) the site context; 2) its connectivity and accessibility by walking and cycling, and existing and planned public transport (including PTAL); and 3) the capacity of surrounding infrastructure. Policy D6 specifically states that proposed residential development that does not demonstrably optimise the housing density of the site in accordance with this policy should be refused. Paragraph 3.6.1 in the new draft London Plan specifically states that: “For London to accommodate growth in an inclusive and responsible way, every new development needs to make the most efficient use of land. This will mean developing at densities above those of the surrounding area on most sites. The design of the development must optimise housing density. A design-led approach to optimising density should be based on an evaluation of the site’s attributes, its surrounding context and capacity for growth and the most appropriate development form.”

In light of the limited development land available; the very apparent need for new and affordable homes; the particular demand for smaller dwellings and the highly accessible nature of Harlesden, Policy H2 should be revised to reflect an approach which requires the efficient use of land by optimising density in line with Policy D6 in the draft new London Plan and paragraphs122 and 123 of the revised NPPF (Achieving Appropriate Densities) which specifically state:

Planning policies and decisions should support development that makes efficient use of land;

Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site;

Plans should contain policies to optimise the use of land in their area and meet as much of the identified need for housing as possible. This should include the use of minimum density standards for city and town centres (Harlesden is a district centre) and other locations that are well served by public transport (such as Harlesden which is in a PTAL 6a area) with the aim that these standards should seek a significant uplift in the average density of residential development within these areas, unless it can be shown that there are strong reasons why this would be inappropriate; and

Local planning authorities should refuse applications which they consider fail to make efficient use of land and in this context, and when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight, where they would otherwise inhibit making efficient use of a site (as long as the resulting scheme would provide acceptable living standards).

Policy E9 (Tall Buildings)

The policy wording has changed since the previous version of the HNP. It is considered that the current wording of this policy is too restrictive and not entirely reflective of other strategic policies especially in the adopted and emerging London Plan. The proposed height for a development should be considered in terms of making the most efficient use of the site provided the local character is enhanced and provided there is no unacceptable harmful impacts on the surroundings. Policy E9 should be more reflective of Policy D8 (Tall Buildings) in the draft new London Plan and identify specific locations beyond just land at Willesden Junction station for where tall buildings should be located especially in light of the policy support for making the most efficient us of land in highly accessible areas where there

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are limited opportunities for developing land (such as in Harlesden). The NPPF recognises that tall buildings make a contribution towards providing new homes, economic growth and regeneration – all needs that the Forum identify in the HNP as being required urgently in Harlesden. In line with Policy D8(B) of the new draft London Plan, the NHP should identify the locations beyond simply Willesden Junction where tall buildings will be an appropriate form of development in principle, and should indicate the general building heights that would be appropriate, taking account of:

the visual, functional, environmental and cumulative impacts of tall buildings;

their potential contribution to new homes, economic growth and regeneration; and

the public transport connectivity of different locations.

It is considered that the Salvation Army and Manor Park Works site allocated in Policy SA2 of the HNP is a location which is especially suited to tall buildings given that the site already has taller buildings on it (albeit redundant). Policy DP1 (Design Principles)

This is a newly introduced policy. It is considered to be too restrictive insofar as it states that developments in Harlesden town centre should be no more than 4 standard storeys in height especially given what is said in paragraphs 6.19 and 6.31 of the NHP May 2018 about there being insufficient large sites to deliver housing locally in Harlesden to meet needs and given that recently consented schemes in the town centre including at Park House, Manor Park Road and Willow Yard at the junction of Park Parade and Rucklidge Avenue are five-storey developments which fit in very comfortably and enhance the local area. The character of Harlesden is very likely to change in the future in light of the planned development nearby at Old Oak and Park Royal and it is clear from the latest draft of the HNP that the Harlesden Neighbourhood Forum wants Harlesden to benefit as much as possible from links with that development. The HNP therefore needs to recognise and embrace this development and the opportunities that this will bring to Harlesden. Policies should not be overly restrictive and proposals for development should be judged on their own merits in full recognition of the local context and characteristics which must acknowledge that the area is in transition and is growing. Site Allocation 2 – Salvation Army Hall and Manor Park Works

The draft NHP (May 2018) continues to support residential redevelopment of this site which is welcomed. Rightly so, the housing capacity stated for the site (31 units) is only indicative. Paragraph 11.5 of the May 2018 draft clearly states that the indicative housing capacity “is an estimate of the number of units that can potentially be provided based upon the average of the density ranges set out in Table 3.2 of the London Plan taking account of public transport accessibility and location.” Basing capacity on average density ranges conflicts with what the NHP says at Policy H2. As stated above, Policy H2 expects the density of new housing development to be towards the upper end of the density ranges. Given the limited opportunities for development in Harlesden, adopting average density ranges will not represent making the most efficient use of land. Paragraph 11.5 therefore needs to be amended so that it is consistent with Policy H2. Policy 3.4 (and Table 3.2) of the adopted London Plan and Policy D6(C) in the new draft London Plan continue to refer to a density of 405 units per hectare in areas of PTAL 4 to 6 albeit that higher densities are encouraged. On this basis, and based on the upper end of the London Plan density ranges, the 0.2ha site comprising the Salvation Army Hall and Manor Park Works should deliver 81 units. The indicative 31 units as currently stipulated is far too low and would not optimise the housing density of the site in line with national and regional policy objectives. To further justify this point, it is worth drawing attention to the Harlesden Neighbourhood Plan – Site Assessment Final Report (February 2018) by AECOM - http://docs.wixstatic.com/ugd/7734bf_13884ef3047841b3a580f047942d38a9.pdf which includes a Site Assessment Proforma for the Salvation Army and Manor Park Works site (Pages A6 to A10). This proforma considers the site constraints and makes a recommendation for the potential housing development capacity that could be achieved on the site considering its characteristics and constraints. The recommendation (see Appendix 2) is that the site is capable of providing 30-40 units. Given that Policy H2 of the HNP advocates residential development at a density in the upper ranges, it would seem more appropriate to promote a development of at least 40 units on the site in light of the AECOM assessment. Paragraphs 6.17 to 6.19 – Harlesden Housing Needs Assessment

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The draft HNP refers to the Harlesden Housing Needs Assessment that was prepared by AECOM (April 2016) for the Harlesden Neighbourhood Plan Area which was based on the Brent SHMA and supplemented by local information from the 2011 Census and elsewhere. Paragraph 6.18 of the draft HNP sets out some of the conclusions of this assessment but there are some important conclusions that are not referenced in the draft HNP – and they should be. The Harlesden Housing Needs Assessment is more specific to the needs of the Harlesden area than the Brent borough-wide SHMA because it is underpinned by robust, objectively assessed data providing a picture of housing need at the level of the neighbourhood plan area. Appropriate weight should therefore be afforded to this evidence in drafting the HNP. In particular, and with reference to the 2016 Housing Needs Assessment, the following points should be made more obviously in the draft HNP:

It would be appropriate for the HNP to respond to the local evidence of need by seeking a specific increase in dwellings towards the smaller end of the scale (i.e. of one to five rooms) given that these appear to be in most demand at present (paragraph 37, page 11);

Ensuring support for one and two room units in particular will enable the delivery of new apartments for sale and rent that can meet the needs of the lower-income section of the population not looking for and/or not qualifying for affordable housing (paragraph 38, page 11);

Significant local concerns about affordability, the evidenced need for smaller dwellings, and the local character and context all suggest that the majority of new dwellings to be provided should be flats, which can also make best use of the limited number and size of opportunity sites likely to be available (paragraph 40, page 11);

Patterns and trends in housing tenures underline the need for a range of smaller dwellings to ensure affordability, including smaller houses as well as flats to meet the need from families (paragraph 46, page 12); and

High levels of concealed families and of overcrowding are again indicative of a need to provide new, but smaller, dwellings, to ensure they provide an affordable option for those looking to move out of overcrowded accommodation or who are classed as concealed families (paragraph 50, page 12).

The Harlesden Neighbourhood Forum who authored the HNP specifically state on http://www.harlesdenneighbourhoodforum.com/housing that as a group, that they have identified the challenges specifically faced by Harlesden regarding housing and from feedback they have received, they have identified that a key theme to be addressed in the HNP is the need for “new housing development to include a high number of one and two-bed properties to meet the existing need”. This message needs to be more obviously stated in the HNP. Summary

The Beckley Group is a key stakeholder group in the Harlesden area being a locally-based business and a business that wants to continue work with Brent Council and the Harlesden Neighbourhood Forum to deliver affordable housing solutions for the local community. In this sense, the comments sent out above should be taken into proper consideration in finalising the Harlesden Neighbourhood Plan. The Beckley Group would be very pleased to meet with Brent Council and/or the Harlesden Neighbourhood Forum to discuss matters further, if required

London Borough of Brent

London Borough of Brent’s Response to the draft Harlesden Neighbourhood Plan Pre-Submission Consultation (Regulation 14)

The London Borough of Brent is fully supportive of the Harlesden Neighbourhood Forum’s work in progressing the Harlesden Neighbourhood Plan. It recognises the hard work and commitment that it has taken the Forum to get to this stage and the extensive community engagement that has occurred to date in shaping a vision for the area and policies to help support its delivery. It welcomes the Plan’s focus on increasing affordable housing provision, supporting the high street and local economy and establishing a link with the forthcoming OPDC development. The Council is generally supportive of the policies contained within the draft Plan, but would like to make comments on the following policies/principles: 1. Timing – the new London Plan and the new Brent Local Plan As you will be aware, the new London Plan has been submitted to the Secretary of State for Examination in Public in January to May 2019. In addition, the Council is currently in the process of preparing a new Local Plan, which will supersede the existing Local Plan.

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Within the Plan, there a number of references to policies contained within the currently adopted London Plan and Brent’s Local Plan documents. The Council is concerned that these references could date the Plan significantly and swiftly, as it is likely that the policies referred to will be superseded or removed. Furthermore, Government has adopted an updated version of the National Planning Policy Framework (NPPF). In light of this, paragraphs 2.3 to 2.7 will need to be amended to reflect the update. 2. Policy DP1 – Town Centre Development Principles/ Harlesden Plaza Site Allocation

Policy DP1 places a 4 storey height restriction on development coming forward within Harlesden Town Centre, with Site allocation SA1 – Harlesden Plaza stating that development on this site should be no more than four storeys in height. The Forum has identified a number of elements which are to be incorporated in the Harlesden Plaza scheme, including an area of large public open space, underground car parking, affordable housing and community space. The Council acknowledges the Forum’s desire to ensure that development on the Harlesden Plaza site respects the surrounding context, however considers that the policy and site allocation should allow for flexibility, to ensure that the most appropriate design solution can come forward for the site. This will enable both good design principles and the Forum’s requirements to be achieved. The Council recommends that reference to the four storey height limit within SA1 is replaced with the following text: “Any development should contribute towards Harlesden’s historic character and respond to local level urban design characteristics and established character”. It is also recommended that the following amendments are made to Policy DP1 – Town Centre Development Design Principles. Height: Heights should be reflective of the character of the Neighbourhood Area, and agreed in consultation with the Forum and Design Officer for the relevant Local Planning Authority. 3. Policy H2 – Housing Density

The emerging London Plan has proposed to remove the housing density matrix. The Council considers that applying a generic density range to development sites within the Neighbourhood area could result in its overdevelopment. The density of a site should be determined by the size, shape, proposed use and constraints of the site. The Council would like to highlight that the NPPG, London Plan and SPD1 requires development to make ‘efficient’ and ‘best’ use of land. Therefore it is recommend that the reference to density within Policy H2 is removed. 4. Community Aspiration 4 - Assets of Community Value

The draft Plan identifies an aspiration that the Forum will put forward an application for Challenge House to be an Asset of Community Value (ACV). Challenge House is currently a Children’s Centre, it provides crèche facilities with a secure outdoor play area for children, meeting rooms and office space. As outlined in ‘The Assets of Community Value (England) Regulations 2012’, a community nomination for an ACV must include the following:

a) A description of the nominated land including its proposed boundaries;

b) A statement of all the information which the nominator has with regard to:

i. The names of current occupants of land, and

ii. The names and current or last-known addresses of all those holding a freehold or leasehold estate in the land

c) The nominator’s reasons for thinking that the responsible authority should conclude that the land is of community value; and

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d) Evidence that the nominator is eligible to make a community nomination

Designation of an Asset of Community Value is a separate statutory process outside the planning system, and cannot be determined through the neighbourhood plan. The Council considers its inclusion within the Plan is not appropriate and that the Forum should engage with the Council separately on this matter.

OPDC Old Oak and Park Royal Development Corporation (OPDC) welcomes the opportunity to comment on the submission draft Harlesden Neighbourhood Plan. Unfortunately, OPDC considers that, as currently drafted, the draft Harlesden Neighbourhood Plan does not meet the basic conditions for the content relating to the OPDC area. OPDC intends for the attached comments to be useful in helping to enable the plan to meet the conditions. Additional comments have been made to help inform the content of the plan but these do not have a bearing on whether the plan meets the basic conditions. OPDC would wish to attend any relevant oral hearing should these be held. Should you have any questions please get in touch.

Basic conditions comments

Paragraph Comment Proposed amendment

1 Para 2.28 and Figure 4

Paragraphs 2.28, 2.29 and Figure 4 include outdated OPDC Local Plan information. The OPDC Local Plan continues to be developed with adoption likely to be spring 2019. As such content of the Local Plan may change. Should detailed Local Plan information continue to be included in the Neighbourhood Plan there is a risk it will continue to be outdated.

Paragraphs 2.28 and 2.29 should be replaced with a reference to OPDC Local Plan Place Policies P8 (Old Oak Lane and Old Oak Common Lane) and P11 (Willesden Junction). Figure 4 should be removed or replaced with the Willesden Junction Place Policy Diagram of the second Regulation 19 Revised Draft Local Plan (Figure 4.44).

2 Policy G1 Policy G1 regarding Sustainable Development makes reference to London Plan and LB Brent’s Local Plan policy to deliver sustainable development. However, it does not make reference to OPDC’s Local Plan SP2 which sets out the approach to deliver Good Growth and sustainable development.

Policy G1 should be amended to make reference to OPDC Local Plan Policy SP2.

3 Community Aspiration 1

The plan should not specify that additional homes provided by OPDC will be available for households in housing need in Harlesden. This will be determined through local authority housing allocation policies and through nomination rights policies within the OPDC area.

Nomination rights will be determined at individual planning application stage. London Borough of Brent will have a right to nominate households on the council’s housing register in accordance with the OPDC nominations policy.

4 Para 6.23 and Figure 7

The Draft New London Plan no longer includes a density matrix. To ensure longevity of the Neighbourhood Plan, references to this should be removed.

Remove references to the London Plan density matrix.

5 Policy E1 The policy states that provision of new public open space will be sought within the area deficient in local open space on development sites over 0.5 ha. Some of the areas identified in Fig.14 of the Plan fall within the OPDC area. Where this is the case, the policy should conform with OPDC’s requirements for publicly accessible open space provision as set out in Policies SP8 and EU1.

Include a requirement for development within the OPDC area to conform with Policies SP8 and EU1 of OPDC’s Second Regulation 19 Local Plan.

6 Policy E9 OPDC’s Local Plan Policies SP9 and D5 identifies that a portion of the Willesden Junction area is an area appropriate for the location of tall buildings in principle. Policy SP9 seeks that all development is of the highest design quality. Draft New London Plan D8 provides guidance

Guidance for E9 should replace the first paragraph, recognising that a portion of Willesden Junction is identified as an area appropriate for the location of tall buildings and that any tall building proposal would need to accord with

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for considering tall building proposals in relation to impacts including character and design. OPDC’s Local Plan Policy D6 Amenity provides guidance to protect the amenity of existing land uses.

London Plan and OPDC Local Plan policies to protect amenity of existing uses, deliver the highest standards of design and positively respond to its context.

7 Community Aspiration 7 and paragraph 8.21

Seeking to exclude the Metroline Bus Depot from Park Royal Strategic Industrial Location (SIL) is not in general conformity with London Plan policy 2.17, Draft New London Plan policy E5 and OPDC’s Local Plan (Policies SP5, P8 and E1). The relocation of the depot and the de-designation of SIL to provide residential on the site would conflict with the objectives set earlier in the Plan to protect existing jobs and improve public transport access. The loss of an employment site is also at odds with the evidence (referred to in paragraphs 9.2-9.3) which highlights high levels of local unemployment relative to other nearby areas and the rest of London. Representations made by the Forum to OPDC’s Local Plan seeking the de-designation of the Metroline bus depot have been taken into account. Based on our assessment, it is not considered appropriate for the designation of this site to be changed. OPDC supports the concerns raised by TfL regarding Willesden Junction bus depot.

Text referring to the relocation of the depot and aspirations to remove the designation of SIL should be removed from the plan.

8 Figure 25 Figure 25 provides outdated OPDC Local Plan information. Figure 25 should be removed or replaced with Land Uses map of the second Regulation 19 Revised Draft Local Plan (Figure 3.7).

9 Community Aspiration 8

Welcome support for OPDC Local Plan policy E5. Through this policy, OPDC seeks to work with relevant stakeholders to ensure existing and future residents and businesses benefit from economic opportunities that will come forward in the OPDC area.

Aspiration should reference Policy E5 in OPDC’s Local Plan

10 Community Aspiration 9

While Policy TCC1 of OPDC’s Local Plan does recognise the need to mitigate any risks to the functioning of Harlesden Town Centre, it also notes the significant opportunities for Harlesden to capture trade from the new population at Old Oak. OPDC’s Retail Leisure Needs Study has found that most of the impacts from development at Old Oak on Harlesden town centre are likely to be positive impacts.

Aspiration should also reference the opportunities for Harlesden to capture trade from new development at Old Oak. This approach to secure benefits from new development across Old Oak should be reflected throughout the neighbourhood plan to align with OPDC’s Spatial Vision.

11 Policy LE3 Policy LE3 provides outdated OPDC Local Plan information referring to Old Oak High Street town centre. The title and location of the town centre have changed. Old Oak major town centre is no longer shown to directly connect with Harlesden town centre within OPDC’s Local Plan.

Reference to connecting into Old Oak High street town centre should be removed.

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12 Community Aspiration 12

Community Aspiration 12 refers to outdated OPDC Local Plan information regarding the title and function of Old Oak High Street. Old Oak Street within OPDC’s Local Plan period is no longer envisaged to be delivered as a vehicular route. Guidance for the delivery of this route is set out in OPDC Local Plan policies P2 and P11. Local Plan paragraph OON.14 states that the provision of a vehicular route has been tested and is currently demonstrated to be very challenging to deliver. OPDC’s Bus Strategy shows routes from Harlesden being provided via Park Road from Scrubs Lane and via Old Oak Common Lane.

Reference to providing a direct bus route through the proposed new High Street should be removed.

13 Policies T3 and T4

OPDC Local Plan policies SP7, T2 and T3 seek to deliver new and improved walking and cycling routes from Willesden Junction Station to Station Road along Station Approach and from the Station to Harrow Road along Old Oak Street. They also seek to improve cycling connections to Park Royal. These proposals are supported by OPDC’s Public Realm, Walking and Cycling Strategy, the Old Oak North Development Framework Principles document and the Park Royal Development Framework Principles.

Policies T3 and T4 should reflect OPDC’s Local Plan policies for walking and cycling routes from both sides of the station to Old Oak, along Old Oak Street and routes to Park Royal along Acton Lane.

14 Site Allocation 4

Paragraph 11.18 includes outdated OPDC Local Plan information. The OPDC Local Plan continues to be developed with adoption likely to be spring 2019. As such content of the Local Plan may change. Should detailed Local Plan information continue to be included in the Neighbourhood Plan there is a risk it will continue to be outdated.

Paragraph 11.18 should be replaced with a reference to OPDC Local Plan Place Policy P11 (Willesden Junction).

15 Site Allocation 4 and Policy H1

OPDC’s Local Plan currently identifies that development will take place beyond the Local Plan period of 2018 to 2038 but supports earlier delivery.

Policies SA4 and H1 should identify that development is currently scheduled to take place after 2038 but, in accordance with OPDC’s Local Plan Policy P11, the Neighbourhood Plan would support earlier delivery of development.

16 Policy D1 OPDC’s Local Plan seeks to deliver new and improved walking and cycling routes from Willesden Junction Station to Station Road along Station Approach and from the Station to Harrow Road along Old Oak Street. These proposals are supported by OPDC’s Public Realm, Walking and Cycling Strategy and the Old Oak North Development Framework Principles

Policy D1 should reflect OPDC’s Local Plan policies for walking and cycling routes from both sides of the station to ensure general conformity for the expenditure of Neighbourhood CIL.

Basic conditions statement 1

The Basic Conditions statement should include a copy of OPDC Board Minutes of 26 November 2015 to ensure transparency.

Include OPDC Board Minutes of 26 November 2015 within Appendix A of Basic Conditions Statement.

Basic Conditions statement 2

OPDC will be submitting its Local Plan to the Secretary of State in September 2018 and intends to adopt the plan as part of the development plan in spring 2019. OPDC considers that the Local Plan, having complete 3-rounds of consultation, has significant planning weight. The Harlesden Neighbourhood Plan references the OPDC Local Plan to inform its content. However, section 4 of the Basic Conditions Statement does not include a general conformity assessment of the OPDC Local Plan. OPDC recognises that the statutory requirement is for the strategic policies of the development

Undertake a general conformity assessment of the strategic policies of OPDC’s Second Regulation 19 Local Plan, which OPDC’s Local Plan identifies as being policies in chapters 3, 4 and 11.

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plan; however it considers it useful for transparency and demonstrating robustness of the policies to carry out an assessment in relation to OPDC’s Local Plan.

General Comments

Paragraph/Figure Comment Proposed amendment

G1 All The plan should consider and set out further aspirations and recommendations for how Harlesden can positively benefit from the opportunity of development at Old Oak and the intensification of Park Royal.

General amendments throughout the document. An example could include a Community Aspiration to support businesses to ‘position’ themselves to benefit from potential new customers and footfall created by new connections.

G2 All Consideration should be given to ensuring the structure of the plan supports ease of reading and understanding of policies.

Prioritise policies in document layout and relocate evidence base summaries and London Plan / Local Plan references to a supporting document. This would align with the structure of the London Plan and OPDC Local Plan

G3 Site Allocation 4 Policy SA4 repeats policy E9 Delete existing repetitive text and provide reference to E9