A campaign worth fighting

We may have lost last night but it was a campaign worth fighting and no one can doubt the passion and commitment of KWG. KWG did manage to retain some of the Victorian building but most importantly gave notice to the Council/Developers that the community won't be walked over.

I hope that the sense of community and common cause created by the campaign will continue in some form in the future.

Congratulations,

Martin Francis

Crunch time for Willesden Green at Planning Committee tonight

Planners will decide the fate of our library and the construction of 94 flats tonight at Brent Town Hall - over 400 objections have been received and yet the council are still proposing to push it through planning.

The general public are welcome to attend so come along to the Town Hall at 6.30pm (starts 7pm sharp) Willesden Green Library Centre is the only thing on the Agenda  - so there is nothing else to sit through.

If you care what happens in Willesden do come along - this will  affect us all.

Planning Committee will only consider the planning application tomorrow - no powers on conservation consent

Philip Grant writes:

 

Anyone preparing for / attending the WGLC Planning Committee meeting on Thursday evening (21 February, 7pm at the Town Hall) need only concentrate on the planning application, ref. 12/2924, at item 2 on the agenda. No action needs to be taken on the conservation area consent application, ref. 12/2925, which is listed as item 3.

 

Chris Walker, the head of Brent's Planning Service, has now confirmed to me that a revised resolution will be put to the committee, if they decide to grant provisional consent to the planning application. This will simply refer the consent application to the Secretary of State for a decision, and will not claim in any way that Brent's Planning Committee is giving consent to that application, provisional or otherwise.

 

As I have written previously, and Mr Walker accepts, the only person who has authority to grant, or refuse, consent on application 12/2925 is the Secretary of State. Even to present arguments to Brent's Planning Committee against the conservation area consent application would be to suggest that they have a power in that matter which they do not actually have! If the application is referred to the Secretary of State, copies of all online or written comments on  both applications, whether for, or against, or general comments, will be forwarded to the National Planning Casework Unit, so that they can prepare a report for the SofS on which he can base his decision.

Reasons for deferral or even pulling out?

Philip Grant writes:

I have just received the following email, which gives at least one "technical reason" why the two WGLC applications have been deferred from the meeting on Wednesday 13 February, although it suggests that there is still some doubt over whether the new meeting will be on Thursday 21 February.

Dear Mr Grant 

You will hopefully have been notified earlier today that both applications have been deferred for consideration tomorrow and instead will be reported to a future meeting.  The date of the meeting will be notified to all who have expressed views on the application including yourself. 

One of the consequences of deferral will be to allow amendment and updates to the reports including reference to the Secretary of State on the Conservation Consent item.  I will update you once this has been done. 

Kind regards 

Chris WalkerAssistant Director (Planning & Development)

This reply follows exchanges of emails I have had with Mr Walker since the Planning Officer's report on the Conservation Area Consent application (12/2925) appeared on the Planning Committee agenda website.

I had pointed out that the recommendation made in the report, that Planning Committee should resolve to agree the Consent application in principle was unlawful, as only the Secretary of State, not Brent's Planning Committee, has authority to give any decision on this application. This had been agreed by Mr Walker, on behalf of then Chief Executive Gareth Daniel, as far back as May 2012, and Mr Walker had confirmed in November 2012, that this still applied to the new application for consent to partial demolition of the 1894 Library building.

All that is actually needed on this application is a brief report to Planning Committee, advising them that they need to refer it to the Secretary of State, and making provision for Mr Walker to implement the SoS's decision once he has made it.

Although the meeting may only be deferred for a week, it means that the proposed redevelopment of WGLC will not have received planning permission by the first anniversary of the Development Agreement between Brent Council and Galliford Try (signed 15 February 2012). This means that either party can now cancel that agreement, as planning approval within twelve months was a "condition precedent". It does not mean that either of them will pull out, but it may be worth mentioning this to your local councillors as an option they may like to consider, to stop wasting even more money on this ill-considered project.

 

Is the proposed library building big enough?

Residents speak out on unaffordable housing and 'bogus' letters

Brent Planning Committee hear from residents on site visit

Residents gatherered at Willesden Green library this morning to show their concern to members of the Planning Committee who were paying a site visit prior to their decision on the planning application which will be made on Wednesday.

Residents were able to put a number of points and questions to planning officers and the developer. Among issues raised were:

• The decision being made before the outcome of the Town Square Inquiry is known and before the planning consultation period ends on February 14th
• The 'dodgy' support letters (see this week's Kilburn Times) that appear to have been solicited by the developer
• The smaller area of the new centre compared with the old and the erroneous inclusion of access areas in the calculation of the area of the new centre
• The loss of parking space for visitors to the new centre, especially if it is intended to hold major cultural events there
• The loss of natural light to the terraced houses on the roads on either side of the development
• Misleading drawings (see below) which misrepresent the scale of the development
• The aesthetic damage to the conservation area of an out of scale development
• Asset striping of public land by the developer with Council support
• Despite the huge housing list in the borough none of the new housing will be affordable 
• Council action and statements appeared to indicate pre-determination

A true representation of scale?

Delivering our messages

This area will be flats

This house and its neighbours will be over-shadowed by flats

Marking the spot in the present library where the flats will end

 It seemed towards the end of the visit that councillors had still not been given a true idea of the dimensions, particularly the height, of the new housing development and its domination of  the conservation area.

Gather at Willesden Green Library on Saturday to show your concern

Please gather at Willesden Green Library tomorrow (Saturday February 9th) to show your concern when the members of the Planning Committee pay a site visit at 9.45am ahead of the Planning Committee decision on the redevelopment.

 

The Council has recently changed the committee rules in a way that "applications may not be discussed at that time”. However at the end of the visit "the applicant and a representative of the objectors may briefly draw attention to any aspect of the site that is relevant”. It would be good to have a significant number of people present at that, including children, if possible.

 

The non-statutory public inquiry into the application to register the land at the front of the Library as public space will be at the Library on Monday 11th February at 10am.

The planning meeting to decide on the development is still on for Feb 13th. (7pm at Brent Town Hall, items 6 & 7 on the agenda). Rather oddly as the enquiry mentioned above won’t have finished till the day after, and also the ' consultation' period won't be over till 14th February!!! (Happy Valentines Day from Brent Council)

 

Validity of Galliford Try planning application site still an open issue

Wiembley and Willesden Observer February 7th 2013

Philip Grant writes: 

Despite Galliford Try saying that 'this claim is completely misleading', and a Brent Council spokesperson saying 'we regard the application as valid', the issue highlighted in yesterday's "Wembley & Willesden Observer" (above) has not gone away.

 

When Brent Planning Service sent a response (see: "Formal challenge issued on validity of Willesden Green planning application", 23 January, below) earlier this week, they would not even acknowledge that the application which they validated on 2 November 2012 was, in fact, invalid. Although they said that the revised plans which Galliford Try submitted to "correct" the application were now valid, they did not answer the point which was raised, that the site plan includes a larger area than that actually agreed by Brent's Executive and included in the Development Agreement.

 

Dissatisfied with that reply, I referred the matter to Brent's Acting Chief Executive, Christine Gilbert, on Wednesday, as the matter is too important to allow it to be swept under the carpet. As far as I am aware, Brent's Executive has not agreed that the site boundary can be extended. If any Council Officer has agreed it, or has allowed it to be done without raising any objection, what authority do they have for this? It will be interesting to see whether the Executive is asked to approve the larger site, by way of an emergency item at the end of next Monday's already busy agenda, "just to be on the safe side".

 

The extra 1180 square metres added to the Willesden Green Library Centre development site is not a "land grab", in as far as the land will remain in Brent's ownership, but the fact that Galliford Try are now showing a larger site than that agreed by Brent's Executive is there for all to see, in black and red. There needs to be transparency about what is going on here, and whether or not it has been validly authorised. If it has not, then proper procedures need to be followed.

Plan A, Site Plan,Brent Executive Jan 2012        Plan B, Revised Site Plan, Galliford Try Dec 2012

Still time to object to the Willesden Walrus

There will be a visit to the Willesden Green Library by the Planning Committee on 9th February at 9.45am.. There is still time to send in objections to both Planning Applications 12/2924 and 12/2925 in response to the Planning officer's report. See KWG blog spot below

Link for objection https://forms.brent.gov.uk/servlet/ep.ext and then click on the "comment on this application" link to leave comment.

Planning Committee site visit to WGLC on February 9th

Please note that there will be a Planning Committee site visit on Saturday 9th February at 9.45am to Willesden Green Library Centre, Public Square and Car Park. Apparently the Council has just changed the committee rules in a way that "applications may not be discussed at that time". However at the end of the visit " the applicant and a representative of the objectors may briefly draw attention to any aspect of the site that is relevant...

Formal challenge issued on validity of Willesden Green planning application

 This is the text of an email sent by Philip Grant to Chris Walker, Brent's Assistant Director Planning and Development, on 23 January 2013:-

VALIDITY OF WILLESDEN GREEN LIBRARY CENTRE PLANNING APPLICATION
REF. 12/2924

Further to my email yesterday, forwarding a copy of an email I had sent to Andy Bates,  I am writing to formally question the validity of planning application 12/2924 (made in the name of Galliford Try Plc) for the proposed redevelopment of Willesden Green Library Centre.

This application was received by Brent Planning Service on 2 November 2012, and validated on the same day, even though it took until 15 November to load all of the supporting documents onto your website. At some later stage, however, one of your Planning Officers either realised, or had brought to their attention by a comment made in respect of the application, that this application, as it stood, was not a valid one.

Having reviewed the Department of Communities and Local Government document "Guidance on Information Requirements and Validation" via the Planning Portal website, I can see why this application, as submitted, was not valid.

• Paragraph 40 makes clear that among 'the information required to make a valid planning application' is the 'mandatory national information requirements specified in the GDPO.'
• Para. 44 says: 'The GDPO requires applicants to submit “a plan which identifies the land to which the application relates”. This is interpreted as a location plan and a site plan.'
• Para. 46 states: 'The application site should be edged clearly with a red line. It should include all land necessary to carry out the proposed development – for example, land required for access to the site from a public highway, visibility splays, landscaping, car parking and open areas around buildings.'

The site plan originally submitted failed to include all of the land necessary to carry out the proposed development, because it did not, among other things, include land in Grange Road on which development forming an integral part of the application proposals would be carried out.

Having discovered that an application which had been treated as valid was in fact invalid, it appears that the applicant was invited by one of your Planning Officers to "correct" the site plan. As Andy Bates explained to me in his email of 21 January:

'I am happy to confirm that ... the revised plans amended the red line to include all the land that forms the application site. Previously, the northern end of Grange Road was shown as being the subject of future highway works that formed part of the development site, but not within the red line. Planning Officers requested that this site plan be corrected and it was on this basis that the new batch of plans was submitted.'

As a result, revised plans were submitted, including site plans with a new red line site boundary, just before Christmas 2012, with the revised site plans uploaded onto your website on 24 December 2012.  This revised application must therefore be treated as replacing the invalid application of 2 November 2012.

The question now shifts to whether this revised application is valid. On the technical grounds that the revised site plan now 'includes all land necessary to carry out the proposed development', it would appear to be valid, but my email yesterday to Andy Bates highlighted a further point. For ease of reference, I will repeat the main points of my argument on this aspect of the "site plan".

The site plan showing the site available to the proposed development partner for the Willesden Green Library Centre redevelopment was shown as plan A at Appendix 1 of the report by Andrew Donald, Director of Regeneration and Major Projects, to Brent's Executive on 16 January 2012. In that report, Mr Donald made specific reference to the red line site boundary, as follows:

4.18 Following the Executive approval of February 2011 the Council also reviewed the red line site boundary of the site. In order to maximise viability it was decided to incorporate Chambers Lane - the land marked crossed hatched black on plan C at Appendix 1 - within the WGLC site, as shown edged black in the plan A at Appendix 1. In February 2011 the Executive had previously authorised the Assistant Director of Regeneration & Major Projects (Property & Assets) to dispose of the land at Chambers Lane Willesden Green shown crossed edged black on plan C at Appendix 1 with vacant possession by way of auction.

4.19 In June 2011, having defined the site and the Council's requirements for the cultural centre, a tender process was followed in accordance with the HCA DPP Framework procurement procedures, a framework which the HCA has set up already under the EU procurement rules.

This extract confirms that the "defined" site marked by the red line (as edged and cross hatched in black on Plan A) was the redevelopment site on offer to the developer. Brent Executive's decision on this point (from item 5, Willesden Green Redevelopment Project, of the minutes of their meeting on 16 January 2012) is recorded as:

'that the Director of Regeneration and Major Projects in consultation with Director of Legal & Procurement be authorised to award and enter into a Development Agreement with Galliford Try Plc in respect of the Willesden Green Library Centre site as shown crossed hatched black in the plan A at Appendix 1; such agreement to provide for the acquisition of the land as shown edged blue and green in the plan B at Appendix 1 and the development of a new cultural centre within the land as shown edged orange in the plan B at Appendix 1.'

You will note that the Executive only authorised an agreement with Galliford Try Plc 'in respect of the Willesden Green Library Centre site as shown cross hatched black in the plan A at Appendix 1'. The original site plan submitted for this application on 2 November 2012 did show a red line boundary which matched that approved by Brent's Executive.

I am not aware of any further authority given by Brent's Executive to allow the red boundary line to be altered in order to enlarge the site. What appears to have happened is that Galliford Try Plc and Brent's Regeneration Department have failed to fit all of the "Council Works" required by their Development Agreement onto the 2170 square metres of the 7795 sqm Willesden Green Library Centre site which was allocated as the land for those works. In order to "deliver" those works, they have moved some of the proposed facilities onto public highway land at the north end of Grange Road, outside of the site boundary.

Although the "correction" to the red site boundary line contained in the revised plans brings all of the proposed development within the red line on the site plan, that site plan does not show the site boundary as put forward by the Director of Regeneration and Major Projects, agreed by Brent's Executive, and set out in the Development Agreement. I would submit that the revised application of around 24 December 2012, which replaced the invalid application of 2 November 2012, is itself invalid, because it purports to show a site boundary which is not the actual site boundary.

I will forward a copy of this email to Joe Kwateng, at Democratic Services, so that he can consider whether this is a valid application which should go forward to Planning Committee. I will also ask him to consider whether, if it is valid, it can go before that Committee on Wednesday 13 February, as Public Notice of the revised application will not be published in the local press until tomorrow, 24 January 2013, so that the extended Public Consultation Period will not end until 14 February 2013.

Willesden Green Library Centre – some New Year thoughts

Philip Grant has asked me to post this article:-

 

If Brent’s Regeneration Department had got their way, Willesden Green Library Centre would now be an empty building site, and the 10,000 local people who used its former building every week would be making do with small temporary facilities spread across the borough. The thousands of local residents who signed petitions, and the hundreds who have put in a lot of time and effort to fight the proposals, have ensured that this has not happened yet, and that even if the Cultural Centre plans go ahead, the 1894 library building will be retained. 

We can look back on 2012 with some satisfaction, but as we look forward to 2013 the key battles will come in the next few weeks. In order for the Cultural Centre scheme to go ahead, Brent’s Regeneration Department and Galliford Try Plc have three hurdles to overcome. I hope that these notes, and your own ideas and comments resulting from them, will help us to understand what needs to be done in order, hopefully, to see the scheme fall flat on its face.

1. The Town or Village Green application

The Public Inquiry on Martin Redston’s application to have the public square in front of the Library Centre registered as a Town or Village Green will begin on Monday 11 February. In my view, the square could meet all of the legal tests necessary for registration, and current chances of success are around 50/50, but it is up to the Applicant to produce the evidence necessary to prove his case. That is why Martin needs witness statements from as many people living within the Willesden Green area (the “neighbourhood within a locality” on which the application is based) by Monday 14 January at the latest, giving evidence which shows that they have used the square for leisure activities during the period from 1991 until May 2012 (or for whatever part of that period they have done so). It is very important that only genuine information and details are given, and that no one “invents” evidence thinking that this will help. Any statement which the objectors can show to be false, or the Inspector conducting the Public Inquiry considers likely to be false, will undermine Martin’s case by raising doubts about the validity of all his evidence.

Anyone is welcome to attend the Inquiry (from 10am each day in Space 2 on the first floor of the Library Centre – via the lift opposite the BAR Gallery). I hope that any supporters of the application will treat the proceedings with respect, as any placards or noisy demonstration would probably do more harm than good. From what we saw at the preliminary hearing, the Inspector appears likely to handle the Inquiry properly, and to consider the evidence and arguments of both sides fairly before reaching a conclusion. He hopes to produce his report and recommendation by the end of February. If he decides that the case for registration has not been sufficiently proved, I cannot see any point in trying to pursue this application any further. If he recommends that the square should be registered, Brent Council are not obliged to accept his recommendation, and could just sit on his report without taking any action on it. In that case it will be necessary to campaign publicly to shame Brent into registering this open space as a Town or Village Green, because it is only actual registration which protects the land from being built over.

2. Planning Application ref. 12/2924

Brent’s Planning Committee is likely to consider this application at its meeting on Wednesday 13 February at 7pm. The Planning Committee are not “the enemy”. They are independent of Brent’s Executive, and have a duty to decide applications on proper planning grounds and in accordance with Brent’s stated planning policies (unless material considerations indicate otherwise). There is a reasonable chance that they will reject the application, if the defects of the application are put before them.

Many of us will want to be there, and anyone who has commented on the application should receive notification of the meeting from Brent Planning Service. People should attend as individuals, carrying their notification; this is not the occasion for crowd action, placards or anything that could justify officials at the Town Hall barring the public from the meeting. We need to respect the committee proceedings, so that our views as well as those of the applicant and the Planning Officer receive a fair hearing.

The Planning Officer’s report and recommendation will be very important. It should be available to view online, as part of the meeting agenda documents, about a week beforehand. It will be a long and detailed report, and it needs to be studied very carefully. All of the points showing that planning policies have not, or not fully, been complied with need to be noted and referred to in objectors submissions to the committee, and any points where we disagree with the report over whether a planning policy is satisfied also need to be identified and brought to the committee’s attention. I think it would be a good idea if an individual or small team began listing these planning policy points now (from objections and comments already submitted), so that the list is ready to check against the Planning Officer’s report and be available to the KWG representatives who will speak as objectors at the meeting.

It is likely that a maximum of only three members of the public will be allowed to speak at the Planning Committee meeting, and probably for only two minutes each (one may be allowed three minutes). It is probably safe to assume that only two objectors will be allowed to speak, and to identify who would be the best two (with one “in reserve”) to speak clearly, concisely and confidently as to why, on proper planning grounds, the application should be rejected. Those two should notify the committee’s Democratic Services Officer, Joe Kwateng, at: joe.kwateng@brent.gov.uk that they wish to speak as objectors as soon as possible after the date for hearing of the application is confirmed, with the “reserve” sending an application as soon as those two requests to speak have been acknowledged. [I will not be putting myself forward as a speaker, as I think local people from Willesden Green would carry more weight – I will do what I can to ensure that several procedural matters are dealt with properly, including that of Cllr. Ann John as a member of the committee].

As indicated above, the key points to get across are why the application should be rejected on planning grounds. It might be best for one speaker to deal with the housing part of the application, and one to deal with the Cultural Centre points. They will need to work together to see who will have room in their two (or three) minutes to also include the planning policy failures on consultation, the fact that unlike the Civic Centre, WGLC is not in a regeneration area but in a district centre whose suburban character is meant to be protected under Brent’s own policy CP17, and the points arising from part of the site being in a conservation area (with the rest within that area’s “setting”). It will be a tall order to get everything into such a short time, by with careful preparation I think it can be done.

It will not be possible for the Planning Committee to grant full planning permission to this application at their meeting. If they are “minded to accept” the application, it will have to wait while the linked conservation area consent application is referred to the Secretary of State (see below). If the Planning Officer’s report recommends granting planning permission, the committee will not be able to reject the application at their meeting – they will have to record that they are “minded to refuse” the application, set out their grounds for this view, and then adjourn hearing of it to a later meeting. The only way that the application can be refused outright at the meeting is if the Planning Officer recommends refusal and they are satisfied that he is correct to do so. We do not yet know the recommendation will be (or whether, exceptionally in the particular circumstances of this case, there will be no recommendation) but the more proper planning grounds for refusing the application we can draw to the Planning Committee’s attention at the meeting, the better for our case.

3. Conservation Area Consent Application ref. 12/2925

This application cannot be decided by Brent’s Planning Committee, as despite its attempt to hide behind Galliford Try as the “sole applicant”, Brent is legally the joint applicant, at least as far as the proposed Cultural Centre is concerned. The conservation area consent application will only be considered by the Secretary of State for Communities and Local Government (or the planning advisors which recommend what decision he should make) if Brent’s Planning Committee are “minded to accept” the planning application. 

Brent’s Planning Service will have to submit all of the documents in respect of this application, including all of the objections and comments made on it, for consideration. There is nothing further that we can do to influence the outcome, and there will be no public hearing. The usual time for such consideration before a decision is given is, apparently, between 16 and 20 weeks, but can occasionally exceed six months in a complicated case. If the decision is to grant the application, this would then allow Brent’s Planning Committee to grant full planning consent.

Because the two applications have been combined in a single form and set of documents, it is difficult to work out what the conservation area consent application part of it actually consists of. When I managed to do so, in order to submit my detailed comments, I discovered that it is a total mess! The application form seeks permission for the partial demolition of just the southern extension of the 1894 library building, confirming this in its proposed demolition plans and Town Planning Statement, then puts forward plans for work involving the complete demolition of all internal walls and floors within the locally listed building. This and other contradictions in the documents, together with a failure to actually consider the tests which the application needs to pass before it could be accepted, means that the Secretary of State would have little option but to reject it.

Brent’s Regeneration Department are aware of my detailed comments on this conservation area consent application, and if they have any sense, they and Galliford Try will withdraw it and submit a fresh application in place of 12/2925. This would mean another public notice, providing a further 21 days to consider, comment on or object to their consent application. If they press ahead with the existing application, they may well trip over this hurdle, even IF they manage to clear the first two. That is a big “IF”, and something which is far from certain as long as we organise and prepare properly the cases in favour of the Town and Village Green and against the planning application.

Carry on commenting on Willesden Green Planning Application

In response to my query I have received the following from Andy Bates of Brent Planning regarding the Willesden Green applications and whether comments will continue to be accepted up to the date of the Planning Committee Meeting.

Dear Martin, 

Thank you for your email. I can confirm that comments will continue to be accepted. In terms of a Planning Committee date, the first meeting the applications could be considered at is on February 13th 2013. All those who have commented on the proposals will be notified once a date is fixed. 

I hope this updates you. 

Regards, 

Andy Bates
Area Team Manager (South Team)
Brent Planning & Development

Willesden Green consultation process a misleading travesty says local resident

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.

Misrepresentation

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.

CONSULTATION

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;”

FIDUCIARY DUTY

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.

'Remarkable' PR desperately resort to anonymous quotes to undermine Keep Willesden Green campaigners

In their account of the 'community involvement' process they undertook for developers Galliford Try, Remarkable PR make a rather remarkable attack on Keep Willesden Green via an anonymous quote from one resident about what s/he claims a 'few friends' have said. LINK (p24) Public relations has never had a fantastic reputation but this does seem to take the biscuit. The comment is certainly not one that Brent Planning Committee should endow with any credibility.

The quote from Remarkable PR's document

Kate Spence, Joint Chair of the Keep Willesden Green campaign said:

Like most attendees of the Library Lab Consultation, I only attended one meeting.

KWG are a large group of local residents united by their desire to ensure that Willesden Green is regenerated in a way that will benefit the local community. We are the Public who live and use the land at the library site. We want to make sure that the right thing is done and the interests of ALL our community are served. 

Remarkable PR who have made these comments in their consultation are being paid by Galliford Try to consult with us in order to demonstrate that it is appropriate for Brent Council to take Town Centre public land and allocate 70% of it to a property developer for the developer's own private financial gain. The KWG local residents have chosen to campaign to protect the land. It should be retained for much needed infrastructure.

In 2006 Brent Council intended to do things properly. The following can be read in the Willesden Green Conservation Area Appraisal 2006

2.1 The Local Development Framework 

The Planning Service at Brent Council will produce as part of its Local Development Framework a set of core policies for the control of development within Conservation Areas. In particular the core document will address the fundamental principle of “Preserve or Enhance” from the Planning (Listed Building and Conservation Areas) Act 1990 and Planning Policy Guidance Note 15. The core policies will deal with alterations to existing buildings, new development, the built landscape and the natural environment. Policies will also be adopted to respond to the pressures of large scale development in residential historic areas.  

From the core policies a series of guidance documents which will be supplementary to the LDF will be produced. These supplementary documents will expand upon the basic policy principles giving specific guidance regarding materials, construction details and techniques for development in the Conservation Area.  

In addition to the supplementary development guidance documents the LDF will identify and possibly initiate a number of “Area Action Plans” which may include the Conservation Area within its remit. The special requirements of designated Conservation Areas will be a principal consideration in the development of “Area Action Plans”  

2.2 The Community Involvement 

As part of the Development of the LDF the Council has produced a “Statement of Community Involvement” which outlines its strategy for consulting people who live, work and play in the London Borough of Brent. All documents produced as part of the LDF will be consulted upon using the principles and processes described in the document. Hard copies are available from the addresses shown in contact details at the back of this document, or can be viewed on the Council website. The strategies outlined in this document will guide the Councils involvement with the residents of Willesden Green.

Unfortunately none of these intentions have been put in to place.  We are told that the ratio of land allocated at the WGCC has been prescribed by developers as the only viable way of returning a new WGCC with council offices. It seems to me that the opinion of partnered property developers with deeply flawed designs have been given a greater emphasis by Brent Council than a well considered LDF.

How can Remarkable PR expect local residents to sit down and talk about activities inside a diminished library space that has been designed without any Local Development Framework, "Area Action Plan" or a publicly consulted master plan? It is outrageous that Brent residents can be handed such an ill-conceived done-deal and then be criticised when we object as a group. 

If the library is run-down then it is a result of poor maintenance on the part of the council. If Remarkable PR can only find one anonymous resident, who thinks it is wise to sell off Public Asset, then facts speak for themselves. It is time to consider the views of the local residents and to stop trying to consult on the finer details of a done deal.