The London Borough of Barnet (Brent Cross Cricklewood) Compulsorv Purchase Order (No. S)2016

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1 Gina Emmanuel 94 Brent Terrace London, Nw2 IBY Sent to: npcu(5)communities.rsi.gov.uk The London Borough of Barnet (Brent Cross Cricklewood) Compulsorv Purchase Order (No. S)2016 Dear Sir/Madam, I wish to register my objection to The London Borough of Barnet (Brent Cross Cricklewood Regeneration Area, BXC) Compulsory Purchase Order (No. 3) 2016, on the basis that the Brent Cross Cricklewood 2010 outline planning permission was obtained without fair consultation, without considering alternatives or options for various aspects of the development & without independent verification for the claims made by Barnet Council & Hammerson. Although I understand that a CPO cannot reopen earlier planning decisions, the unacceptable processes that were used by Barnet Council then are still relevant today. These issues affect CP03, the local community & the wider community as follows. 1. NON-CONSIDERATION OF OPTIONS The Brent Cross Cricklewood Development is sandwiched between 2 major road junctions; the A406/M1/A5 & the A406/Hendon Way junctions. The A406 is a red pollution route & recent tests show that some areas of the BXC site suffer from nearly double the permitted air pollution levels. A reasonable person would assume that the development would do whatever it can to reduce the number of vehicles in this polluted area. However, the developers original consultants estimated that an additional 29,000 cars per day, even with the NEW RAILWAY & BUS STATIONS. Cars will still be a main mode of transport into the shopping centre, since the only mode of public transport will be buses. Both Brent Cross tube station & the new station are too far to be useful. People are more likely to use public transport if it is quick & efficient & gets them to precisely where they want to be (not a mile away from their destination) & not leave them on a bus, stuck in the long traffic jams that regularly occur in the area. As with all the other new large London shopping centres (Stratford, Westfield, Croydon), it is extremely important that more than one mode of PUBLIC transport is used at the redeveloped Brent Cross Shopping Centre. Barnet Council claims that 'No alternative proposals have been put forward by the owners of the land, or any other persons, for its re-use'. However, the options of a new light railway OR the extension of the Dudden Hill line into the shopping centre have existed since before the outline planning permission was granted in It is true that the Council never gave these options serious consideration. The light railway could join the shopping centre to

2 nearby tube & overground stations, making it much more convenient for shoppers. However, the current configuration of the new station plan precludes any light railway or extension of the Dudden Hill line in the future. This failure to act to reduce air pollution as far as possible is not in anyone's Interest & is not in keeping with attempts to reduce pollution by the current & previous London mayors. Barnet Council has reiterated throughout their Statement of Reasons for CP03 that CP03 must contribute significantly towards the achievement of the economic, social & environmental wellbeing for the area. However, failure to reduce air pollution as far as possible is a failure to achieve environmental wellbeing. Finally, it seems that Barnet Council & Hammerson have recognised the flaw in the argument since they have ceased to claim that the new station will help shoppers to get to the redeveloped shopping centre & have concentrated instead on the benefits to the new residents & businesses. 2. PEDESTRIAN/CYCLING ROUTES There is much emphasis in the Statement of Reasons concerning pedestrian & cycling routes in the area of CP03. However, in Phase 1, this emphasis became a series of shared pedestrian/cycling routes with almost no segregation, a solution hated by both pedestrians & cyclists. The Living Bridge, the safest pedestrian/cycling route, has no cycling route to the north, since it ends on the second floor of the shopping centre - cyclists must dismount. There is no way to cross the Hendon Way by bicycle cyclists must dismount. There is no detail regarding the pedestrian/cycling routes around the area of CP03 & over the bridges, but assurances must be obtained that this aspect of the development does not go the way of Phase 1, since this too will be a failure to achieve environmental wellbeing. 3. GREEN SPACE CP03 includes the Spine Road Linear Park to the west of Brent Terrace. Barnet Council & Hammersoh have always claimed that there will be additional green space under the Brent Cross Cricklewood Development. However, this has never been independently verified. This is necessary since there have been a number of significant discrepencies in their assessment of the green space in the BXC area. In some sections of the planning documentation, the green space count is in hectares & in some sections it is in acres. In some sections, the developers have added hectares & acres together. Some large tracts of green space are being lost under the development (Sturgess Park, Brent Terrace Triangles, Cricklewood Town Centre Green, a section of Clitterhouse Playing Fields) & yet there is still a net gain. Barnet Council have included pocket handkerchief sized spaces in their count, whereas large, useful spaces have been lost. Quiet spaces have been lost, to be replaced by areas next to the A406 & the Brent Terrace 4 lane spine road. The poor quality of some of the new spaces (due to air & noise pollution) is surely a failure to achieve environmental & social wellbeing. 4, CONSULTATION

3 On the request of members of the Cricklewood Forum^ there have been 4 meetings where Barnet Council & the developers have agreed to a Q&A session with the public. At one of these meetings, the Hammerson representative admitted that they had not adequately consulted the public. In general, these meetings have resulted in very little new Information and In some cases, continued obfuscatlon of the facts. However, Argent, Soundings & Barnet Council agreed to meet & consult with Brent Terrace residents regarding the removal of the allotment gardens used by many Brent Terrace residents, scheduled under CP03. This consultation resulted in the decision not to take the gardens from the residents during CP03. This has been the ONLY significant change made by the developers In favour of the residents since outline planning permission was granted In 2010 & throughout all the phase 1 & 2 RMAs. However, removing the Brent Terrace allotment gardens from CP03, although welcomed by Brent Terrace residents, may be just a cynical last-minute move to reduce opposition to CP03, & that a CP04 could re-schedule them for removal {see Item 8 below for further expansion of the argument regarding the allotment gardens). Further, Barnet Council's discussion of their public consultation for CP03 (as presented to Barnet Counsellors), includes their public consultation for CPOs 1 & 2, so It appears that more consultation occurred for CP03 than was actually the case. For example, they discuss consultation with the Whitefield Estate.independent advisor, however, the Whitefield Estate has little stake In CP03 so this has no relevance to the current CPO. In addition, the Council claim that they consulted 20,000 people; there are currently only 2-3,000 residents In the BXC area. Finally, how many of these 20,000 people did the Council consult just for CP03? (Consultation Items , CP03 Council Report.) 5. AFFORDABLE HOUSING Barnet Council & Hammerson claim that 'the proposals will provide high quality homes. The Scheme itself will offer more choice by providing a number of different housing options such as shared equity, shared ownership and private homes for sale to residents and those in the wider communlty...ln addition, it will further the strategic objectives in the Council's Housing Strategy which Include: (a) Increasing housing supply, including family sized homes, to Improve the range of housing choices and opportunities available to residents; and (b) promoting mixed communities and maximising opportunities available for those wishing to own their home.' However, available evidence would seem to contradict these claims: Many Whitefieid residents will be forced to leave Cricklewood under CPOs 1 & 2, reducing the diversity of the area; Diversity has been further reduced since the sheltered accommodation provision in the BXC area has been removed & not re-provided under CPOs 1 & 2; Much of the proposed housing Is 1-2 bedroom flats (not family sized homes). There Is much talk of affordable homes UP to 50%...but the Council state that this will depend on the viability studies of the developer & experience of viability studies suggests that the figure is likely to be closer to the lower figure of 15%. In addition, affordable housing Is not affordable to rent or buy for many people on low incomes, so the need Is for SOCIAL housing to obtain true economic diversity in the area.

4 Furthermore, the exact number of new housing units in the BXC area differs across the planning documentation. Finally, it is difficult to argue that the proposed housing would create social improvement in the area, when a whole community has been lost. 6. WASTE TRANSFER SITE According to Barnet Council & Hammerson, Ihe new Waste Handling Facility will provide a modern waste facility capable of handling up to 175,000 tonnes of municipal waste per annum. The new facility will create an improved environment for the local population due to the modern air filtration systems and WASTE DISPOSAL TECHNOLOGY that will be utilised at the new site.' The current waste disposal site has become much more pungent over recent years, so that the rancid smell invades much of Brent Terrace during the summer. There are no guarantees that this will not continue to be the case (although it will affect a different group of residents) when the new waste handling facility is built. In addition, 'waste disposal technology is an incinerator by other terminology. Local residents have consistently made their opposition to this clear; any reasonable person can understand that an incinerator in the middle of a densely populated residential (& commercial) area is ill-judged on the grounds of the detrimental effects it will have on the environment & people's health. In an area that is already highly polluted, additional pollution can only detract from any environmental improvement Barnet Council hopes to achieve with CP NO INDEPENDENT VERIFICATION OF COMMERCIAL FIGURES Barnet Council have made claims regarding both employment figures & the cost for the new station. These have not been independently verified. In particular, the cost of the bridge may result in the taxpayer having to foot a large bill, since only 97m of the required m is being supplied by central government (also the taxpayer). Surely, with such large sums involved, independent verification to ensure that the tax payer will not be left with huge debts, is necessary, otherwise this could hardly be considered as being of economic benefit to the public. 8. DIMENSIONS BETWEEN THE RAILWAY & BRENT TERRACE Although Brent Terrace allotment gardens will not be taken in CP03, Barnet Council have already confirmed that there will be a CP04. In addition, they have stated that 'The land to the rear of Brent Terrace which was previously included within the proposed CP03 boundary has now been removed as this is no longer needed for the construction of the Midland Mainline Bridge or Spine Road'. This does not preclude the gardens being taken at a later date for some other aspect of the BXC development. Furthermore, there has been an on-going argument regarding whether there is enough space between the railway line & Brent Terrace for the proposed blocks of flats, the 4 lane

5 ' i spine road, the linear park & the Brent Terrace allotment gardens. There has never been Independent verification that there will be enough space for everything in the outline planning permission. In SUMMARY, the BXC outline planning permission was granted 7 years ago & at that time the car based scheme incorporating an incinerator & no social housing, was out of date. Things have moved on since then, so the scheme appears even more dated. We should be aiming to produce something fit for the future, not something that is already a dinosaur.