A local resident has kindly consented to share her submission regarding the Willesden Green planning application with readers:
Objection to Planning Applications 12/2925 and 2924,
Willesden Green Library Centre, 95 High Road, London, NW10 2SF Associated application for Conservation Area Consent
I object strongly to the above proposals for a major project to construct 92 flats and a small library building on the above site.
· The replacement library has been misrepresented as a “benefit” to the community when in fact it is diminishing the facilities which are currently available to the public.
· The proposals do not respect the character of the conservation area
· The proposed replacement buildings are not of the highest architectural quality or design - they are an over-scaled and insensitive intrusion which will destroy and dominate the High Road’s sense of place.
· The proposed blocks of flats in the new housing scheme constitute a form of town cramming. On height alone they are unacceptable, breaching SPG17 guidelines that residential development should be no higher than 2-3 stories.
The Council is breaching its own policy commitments, national policy and GLA guidelines; in so doing it is betraying public trust.
BREACH OF BRENT'S PLANNING CODE OF PRACTICE AND DUE PROCESS.
The Council has sought throughout, to misrepresent its role in this matter, trying to pretend that the developer is the sole applicant for this planning permission.
Both the site and the buildings on it are council owned and therefore Brent is a joint "applicant" and an "interested party" in the application.
It is clear that this is a Council project from every statement made by the Council, from the announcement in the 2010 Corporate Strategy that “we will be redeveloping Willesden Green Library”, and all subsequent committee reports.
The Council is, in truth, seeking to grant itself planning permission to develop this land.
Breach of Brent's Planning Code of Practice.
The conduct of both officers and councillors is in breach of Brent's Planning Code of Practice. (see item 12 in respect of officers)
The Planning Code of Practice is also relevant to the conduct of the planning committee: if any member of the Committee has been involved in any way with promoting the scheme for Willesden Library they will be unable to vote on the planning application. As Planning Committee member Cllr. Ann John was clearly involved in promoting this redevelopment scheme; she is therefore partial and should be barred from discussion of the plans, or voting on them.
MISREPRESENTATION of “PUBLIC BENEFIT”
The proposed replacement buildings offer no benefits to the local community that it does not already enjoy. The proposed redevelopment will seriously reduce public benefit.
The Council and its partners have persisted in misleading the public with false statements.
· The proposed scheme represents a net loss in square footage of Publicly owned land and a reduction of amenity in a public amenity building,
· The new public open space will be much worse, hidden away at the back of the building in a shady, steeply terraced passage-way which compromises public safety. The change of ground levels has not been factored in to the design. The scale on the drawings has been misrepresented to imply a larger outdoor amenity.
· Loss of parking
· Detriment to a much-loved historic building.
With the closure of 6 libraries in Brent any replacement of the Willesden library needs to offer a much larger building. This proposal barely offers the same amount of library space as is already there and expects to cram in several other uses, such as increased council offices, onto a smaller site. The proposals are dense, cramped, and over-scaled in relation to neighbouring properties. The proposed architecture is at odds with the surrounding Edwardian neighbourhood.
BREACH OF GOOD PLANNING PRACTICE
The Council has failed to follow due process at every stage of this application:
· to develop an LDF for Willesden Green, although this is an essential part of Town Planning and Spatial Strategy
· to produce a planning brief for the project, despite a written commitment to do so
· to observe government constitutional guidance, Local Gov Act 2000, on “Key decisions”
· to abide by the Willesden Green Conservation Area Character Appraisal/Management Plan 2006,
“There is a need to conserve the best of our built heritage against pressure for redevelopment and unsympathetic alteration”.
· to abide by the Council’s UDP on Conservation-Led Regeneration and preservation of locally listed buildings and conservation areas, policies:
BE24 LOCALLY LISTED BUILDINGS,
BE25 DEVELOPMENT IN CONSERVATION AREAS
· to abide by guidance in the new National Planning Policy Framework
o in creating a strong sense of place
o promotion of design that responds appropriately to local context.
para. 132 'Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification.'
· to abide by London Plan policy 3A.18
o it will not provide equal or enhanced community use floorspace.
o The facilities will not be of equal or better quality to those that are being demolished,
o It will not improve the existing offer to local people.
The Council accepted a planning application without uploading any of the details or drawings onto the Planning Web portal, thus making it impossible for the pubic to inspect the plans, thereby denying the public the right to the statutory period of reply.
The Council has flouted every single possible duty and commitment to properly consult on this scheme, and has attempted to mislead the public at every stage, by misreporting and misrepresenting such consultation as has taken place.
This began with its first public announcement in Brent Council Magazine, issue 107, October 2010, which misrepresented the Corporate Strategy announcement for Willesden as: "improve Willesden Green Library Centre providing more community facilities", when in fact the Corporate Strategy 2010-2014 itself states: “we will be redeveloping Willesden Green Library”
This was fundamentally misleading.
All subsequent consultation has been no more than a box ticking exercise outsourced to private companies.
The most recent in August / September this year was run by a private company calling themselves the Library Lab, thus misleading residents into supposing that they were connected with the Brent Library service.
The people running the meetings tried to control what was said; to stop people from asking questions or expressing their point of view, and even told questioners 'not to be disruptive'.
The numbers attending the meetings were derisory: barely 200 out of a population of potentially 130,000 or so who live in the South of the borough, or 13,000 who live in Willesden; certainly far fewer than the number who wrote letters of objection.
The reports of these meetings put out by this company are a shameful travesty of the truth.
The whole exercise has been in breach of Brent Council Constitution:
“The purpose of the Constitution is to support the active involvement of citizens in the process of local authority decision-making;” and “create a powerful and effective means of holding decision-makers to public account;”
It is not the role of a democratically elected Local Authority to sell public assets cheap to facilitate profits for commercial developers on publicly owned land. A case could be made that Brent will be in breach of its fiduciary duty to the tax-payer in encouraging the developer to shortchange the public with reduced and inferior public facilities in return for large profits at the tax-payers expense. Councillors have endorsed plans that mislead the public.
There is also a question to be answered as to why the current, relatively new building was allowed by the Council to deteriorate to the point where it is claimed it is beyond repair.
For all these reasons these proposals should be rejected.
In by-passing all due process in this matter the Council has tainted the planning process.
There is little point in having any planning policies at all if they can be broken so easily.
The Council should prepare a proper planning brief for the site, which will be properly consulted on, and provide real benefits for the borough, rather than maximum profit for the developer.