We objected as follows on 05 October and added to it as below on 14 October.
We strongly object to this planning application. Many of our reasons have already been well expressed by our fellow residents’ associations, our individual members and many others; we won’t repeat them all.
We note that much of the application is speculative, conditional and non-committal (“should be provided”, “should be designed”). It avoids saying that things will be done in accordance with the application, and the only assurances are that the development will be a fine thing for Cricklewood. These assurances are not well-founded and only bolster the impression that this developer is not committed to the project.
The application seeks to justify excessive height, massing and density by claiming the proposal solves trivial or non-existent problems.
Repeatedly, the 25-storey tower is described as an aid to wayfinding and legibility. No evidence is presented that people are having trouble finding their way. Central Cricklewood is highly legible with one main road, the A5, and one significant crossroads leading to Cricklewood Station on one side and Willesden Green Station on the other. Finding the way from Cricklewood Station is helped by Legible London signage and if finding the station were a problem, more signs could be provided. They would be cheaper and far less obtrusive than a 25-storey tower block. All this self-serving justification does is emphasise how starkly visible the development would be from all around.
The application makes much of providing a public pedestrian and cycling route between Depot Approach and Cricklewood Lane.
– It would not serve pedestrians coming to or from the Railway Terraces via Kara Way; that route is already blocked at Kara Way.
– It would not serve cyclists travelling between Cricklewood Lane and the A5 junction with Depot Approach. The concept fails to meet Transport for London’s London Cycling Design Standards. Diverting off straight roads to cycle up and down sharp inclines and in amongst pedestrians fails to satisfy the core outcomes of directness, comfort, coherence and adaptability to increasing volumes, and breaches the principle that bicycles must be treated as vehicles, not pedestrians.
– It would bring pedestrians and cyclists into conflict with each other.
– The traffic and transport sections of the application make no attempt to evaluate likely use or benefits of this feature.
A pedestrian route would have to be provided so residents of the development can move around it, and it cannot reasonably be gated. It’s not a community benefit and declaring it a cycle route only benefits the applicant.
The application criticises Cricklewood for not having a library or a town hall, but does not say it will rectify this or offer any other community facilities, with the exception of public access to the spaces between building plots. It calls one of these spaces a Town Square, though it would sit apart from the roads, and shows it with a brightly lit cinema or advertising screen shining into the windows of the residents across Cricklewood Lane (no assessment of this impact is offered).
The developers have no clear ideas on how the ground-floor commercial spaces would be used, and no strategy for encouraging appropriate uses, let alone allocation to develop the community. There is no policy to ensure they are let and do not remain empty as at nearby Fellows Square.
No social housing is offered and there is only an “aspiration” to provide the minimum of 35% “affordable” units. This fails to meet London’s needs and it fails to meet the needs of our community. The application should be rejected for this reason alone.
The statement of community engagement makes it clear that the developers have not consulted Cricklewood residents so that our views will be taken into account. The statement ends with a brief series of rejections of every criticism, and the plans have not been modified to take any concern into account. That was not engagement.
The open space in the development is not commensurate with the increase in population, which would increase demand on existing and prospective open spaces. The application avoids quantifying this.
The impact of the development on its surroundings would be significant and adverse, as the report from Montague Evans states repeatedly. That report hopes that good design might somewhat mitigate the significant adverse impacts. This does not address the fundamental problem.
Whether 15-storey or 25-storey, these blocks are not appropriate for this area. The tallest buildings around or in process of gaining approval are 9-storey, and they are the exception. Most of the entire neighbourhood is 2-storey or 3-storey. Not even the blocks of Brent Cross South, at some distance, are so high. These blocks would dominate the area. They would be overbearing, far too high and excessively massive. They would be detrimental to the neighbourhood and incoherent with it. Barnet, Brent and Camden still have no joint plan or co-ordinated approach to Cricklewood’s development, but it is clear that there is no prospect of similar development in the Brent and Camden parts of central Cricklewood.
The application states “There will be significant changes to some local views as a result of the regeneration of the Site. These changes and the visibility of the tallest elements on the Site signal the regeneration of the Site and the positive changes brought to the neighbourhood in returning the Site back into active use.” The current residents of Cricklewood and anyone that comes to live on the site would have to live with the permanent changes this development would make and their direct and lasting impact on our lives. These tower blocks cannot be justified by being called a “signal”.
Further objection 14 October
Further to our objection of 5th October, we need to add that the application’s quantitative impact assessments have serious errors and cannot be relied on.
In ES Volume III, Appendix 15-1: Transport Assessment, Table 3.2 says Cricklewood Station has capacity for trains 8-12 carriages long. This is wrong; it can only accept trains 8 carriages long, it and Kentish Town North not having been extended when other stations were.
Table 3.2 also claims that 12 southbound trains an hour stop at Cricklewood trains, in different southbound services 4 times an hour each. This is wrong. For most of the day and especially at peak hours, a total of 4 southbound trains stop at Cricklewood (2 passing one way around the Sutton-Wimbledon loop south of Streatham and 2 the other, and all 4 of those passing through London Blackfriars). This is evident from train timetables and in accord with the 2013 invitation to tender for the Thameslink, Southern and Great Northern Franchise, appendix 2D. It also makes transparent sense that there are the same number of trains each way.
Thus when paragraph 3.29 claims there are 160 carriages stopping at Cricklewood station in 16 trains of 10 carriages, it’s a gross overstatement – there are 64 carriages (8 x 8), of which 32 are southbound.
This means the summary in paragraphs 12.11 and 12.12 are grossly wrong. The estimated 133 passengers in the morning rush hour will not have 16 trains of 10 carriages to choose from; the vast majority will be travelling south towards central London and the various interchanges from West Hampstead onwards on just 4 8-carriage Class 700 trains (capacity 1146 passengers, 427 sitting and 719 standing).
133 passengers is an additional 3% of the capacity of those trains from this one development alone. This should not be minimised or disregarded. The Transport Assessment does not consider let alone report or evaluate the current crowding on these trains, the last stop before many passengers disperse at West Hampstead, so we must point out the repeated statements by objectors that trains are already so crowded at Cricklewood that it’s often impossible to board. Trying to force an extra 3% onto these trains is not feasible.
This of course still ignores the cumulative effects of the other approved or in-process developments in Cricklewood, which the application also understates by half, as follows.
Environmental Statement Volume I, Table 7.3 lists the schemes considered in the Cumulative Effects assessment, purporting (para 7.8.11) to include any within 1 km and over 150 residential units which have a planning application submitted as of May 2020. It omits the development 0.5 km away of the Matalan site on Cricklewood Broadway, opposite the Railway Terraces Conservation Area, with 238 residential units, for which planning application ref 20/0115 was submitted to Brent Council on 13 January 2020, which the public was commenting on from 22 January 2020 onwards, and which we covered repeatedly on our own website. This development would use the same buses and trains, the same roads and shops, the same schools and health facilities, as the proposed B&Q site development. It almost exactly doubles the number of residential units within 1 km of the site that the Cumulative Effects Assessment should consider and thus invalidates that assessment.
On the Barnet planning portal, this application consists of 131 documents. We have not been able to review all the claims. Even where we have as above, the estimate of 133 rail passengers in the morning rush hour is dependent on the TRICS system, to which we do not have access and which is clearly sensitive to the selection of comparable locations (cf the significantly different results for the adjoining 1-13 Cricklewood Lane site in planning application 18/6353/FUL). What we have been able to review shows that this application cannot be accepted as providing an accurate or fair or reasonable assessment of the scheme’s impact and that it significantly understates the impact.