Site 28 Housing Suitability and Inclusion in LBB Draft Local Plan
Received: 17 November 2024
1.Contradiction in Site Allocation for Deans Brook Nature Reserve (Para 58): In your response, it is noted that 'the Local Plan is not proposing development of the Nature Reserve' and that the plan aims to 'preserve the area of Borough Importance for Nature Conservation, which covers the south eastern part of the site, including the areas around Deans Brook.' However, the allocation of 720 residential units within this area (as outlined in our objections) contradicts this statement(Barnet's responses to o…)(Updated ECA5.3 Ballymor…). If the Deans Brook Nature Reserve is to remain protected, could you clarify why these units are still included in the site's allocation? If development is indeed restricted, we request that the allocation of these 720 units be officially revised or removed to reflect policy compliance. 2.The Environment Agency has highlighted risks associated with building within 8 meters of Deans Brook, including potential destabilization of the riverbank and increased flood risk(Updated ECA5.3 Ballymor…). The proposal to allocate 720 units in this area contradicts Barnet's Policy DM04, which requires developments to preserve natural habitats. We request confirmation that this policy, alongside other relevant environmental standards, will be enforced. If Barnet is not planning to build on top of the river, please remove the land from the allocation for high density housing. 3.Unsuitability of Allocating 839 Units Over TfL Infrastructure: We noted in our objections (Section 2.1 of ECA's updated submission) that 839 units have been allocated directly over the Edgware Underground Station and operational tracks. This allocation is problematic as it contradicts London Plan Policy D13 (Agent of Change) and Policy T3 (Transport Infrastructure Protection). The Environment Agency have raised specific concerns about developments impacting infrastructure, emphasising that 'no balconies or windows should be within 3 meters of the railway' to safeguard operational safety (Updated ECA5.3 Ballymor…)4.Your response (Para 56) states that Site 28 is suitable for development, but it lacks detail on how these policies will be upheld without compromising safety.5.TfL's Objection to the 'High Development' Classification of the London Underground Station (Section 2.1): TfL has expressed concern about the classification of its operational land within Site 28 as a 'high development' opportunity. This land is vital for current and future operational needs, including potential expansions of the Northern Line. The classification poses risks to the continuity of vital transport services, conflicting with Barnet's Long-Term Transport Strategy(Updated ECA5.3 Ballymor…). We seek further clarification on how these concerns were factored into the decision to maintain such a high development allocation.6.Potential Misinterpretation of Transport Infrastructure Policies: Your response (Para 57) mentions the need to protect and re-provide bus operations and Underground infrastructure. However, the current allocation appears to undermine the fundamental requirement of Barnet Policy GSS09, which states that new developments must improve transport infrastructure. Constructing 839 units over live tracks risks operational disruptions and does not align with the policy's intent(Barnet's responses to o…)(Updated ECA5.3 Ballymor…).7.Inclusion of Relocation Language for the Bus Station (Section 2.2): Your plan suggests potential relocation of the bus station, which TfL advises against. Instead, TfL emphasizes developing a 'new or upgraded integrated bus station facility' to ensure continued quality of interchange(Updated ECA5.3 Ballymor…). Would the Council consider revising the language to align with TfL's recommendation
Outcome / Documents
- Response (all information to be supplied) - application/pdf - Download