Local Plan Main Modifications: Representor's Q-V

Representations (Representor's name Q - V)

Representations can be viewed below - click the link on the name of the Representor to view our response.

EXAM 400

Main Modification

MM57 - CHW01

MM125 - Site 45

Council’s Response to Inspectors

The Council considers that specific reference to providers is not merited in CHW01H, the wording of which has not been subject to modification. The changes proposed by MM57 makes the policy more effective and consistent with the provisions of the NPPF.

With regards to Site 45 the Council considers that specific reference to Queen Elizabeths School is not merited. Consultation with the school will take place as part of the planning application process. Policy ECC02 – Environmental Considerations covers requirements with regards to demolition and construction. Proposals are required to provide a Demolition and Construction Management Plan to include details on impacts of development and nuisance and how this will be mitigated.

EXAM 401

Radka Wehbe

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The representor expresses their support for any representations made by Save Our Edgware and the Edgware Community Association. They request that Save our Edgware and the Edgware Community Association submission as reflecting their own concerns.

The Council refers to its response to Save our Edgware with regards to Sites 27 and 28, the proposed redevelopment of the Broadwalk Shopping Centre and infrastructure.

The Council carried out the consultation on the MMs on behalf of the Inspector. This consultation was carried out on the same basis as the Reg 19 Local Plan which was published in Summer 2021. The Council has published Consultation Reports which set out what we have done to engage with people prior to submission of the Local Plan in late 2021 for Examination.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 402

Rajeev Shah

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 403

Ralph and Gael Lightstone

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, car parking, including disabled persons car parking, and the bus garage.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 404

Rebecca Grossman

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 405

Regal GNLP Ltd

Main Modification

MM29

MM34

MM41

MM46 – CDH04

MM50

MM53 - TOW01

MM68 (corrected from 67)

MM 69 (corrected from 68)

MM72

MM147 (corrected from 145) – Site 67

Council's Response to Inspectors

he Council welcomes support for MM29, MM34, MM41, MM69, MM50.

The Council responds as follows:

MM 147-Site 67

The Council reiterates that use of the Density Matrix Annex 1 has been accepted by the Inspectors. The Council considers it entirely proper for the Local Plan to signal the Council’s expectations. It expects proposals to respond to the site requirements it sets out in the Local Plan and therefore does not consider that further change is merited.

MM46 –Policy CDH04 –Tall Buildings

This main modification removes ‘major thoroughfares' such as the A1000 as a broad location for where tall buildings may be appropriate. The Inspectors’ letter of 17 August 2023 (EXAM143A) para 58 clarifies that such ‘broad locations’ do not align with the evidence in the Tall Buildings Study Update 2019 (EB_DH_04).

Pre-application advice is advice in response to emerging proposals that in turn are expected to respond to site requirements set out in the Local Plan. Progress on such advice should not be construed as justification for modifications to the Plan.

The only modifications that are relevant are those that have been approved by the Inspectors and the Council subject to public consultation. The Reg19 Local Plan makes no reference to CDH04 or any consideration of a tall building in Proposal Site 67.

The Council acknowledges that EXAM Note 4 (Council’s Proposed Modifications -June 27th 2022) includes references to Site 67 as being potentially suitable for tall buildings. EXAM Note 4 was prepared prior to the EIP. It is also noted that references were made to GNLP being included as a potentially appropriate location for tall buildings in EXAM Note 79 (Tall buildings updated 170323). However, these suggestions have now been superseded by the recommendations made in Inspectors’ letter of 17 August 2023.

The Inspector has not raised any concerns regarding the relevancy of the Tall Buildings Study Update to render the document out of date. The Update continues to be used by the Planning Inspectorate in determining appeals. This is well demonstrated in APP/N5090/W/21/3271077 679 High Road, North Finchley, London N12 0DA a decision issued in 2021. The decision assesses a proposal for the demolition of the existing building and redevelopment of the site to provide 307 homes in a series of buildings up to nine storeys, car parking, cycle parking, hard and soft landscaping, and associated facilities. The Inspector in this appeal discusses the Tall Buildings Study Update in some depth and uses this as evidence to justify his decision. The Inspector dismisses the appeal concluding paragraph 41 of the appeal decision;

'The appeal proposal maximises the potential for densification and in doing so fails to respond appropriately to the Council’s own character assessment or up-to-date guidance in the [Town Centre Framework] TCF and the TBSU [Tall Buildings Study Update]. The detrimental effect on townscape character of the tallest blocks B, C and D would be so great as to significantly and demonstrably outweigh the benefits the scheme would bring.’

The Council concludes that MM47 is sufficiently worded and does not require additional amendment.

MM53- TOW01 Vibrant Town Centres

The Council considers the modifications to Policy TOW01 sufficiently accords with NPPF and London Plan policies. Policy CHW01 seeks to protect community facilities, this covers a range of facilities including leisure centres and swimming pools as noted in Section 8.5. CHW01B only allows the loss of existing community facilities in limited circumstances. This is in line with principles outlined with policy S5 of the London Plan. MM57 - Policy CHW01 Part B clearly states this. The Council does not agree that cross references to Town Centre designations within CWH01 or cross references within Policy TOW01 to CWH01 are required. This follows the London Plan 2021 approach which does not cross reference London Plan Policy S5 within Policies SD6 or SD7

MM68- Policy ECC04 – Barnet’s Parks and Open Spaces

The deletion of ECC04E and the removal of support for potential development of open space that is low quality and low value is a result of the change in strategy arising from the change in administration of the Council in 2022. In the Inspector’s view ECC04E was not justified by existing evidence.

MM72- TRC03-Parking management

The Council does not consider the supporting text in para 11.12.6 (MM73) with regards to CPZs to be contradictory. The supporting text complements the change to TRC03B in allowing for the use of CPZs where there are unacceptable impacts on local highway conditions. The Council notes that this sentence is repeated at the end of para 11.12.6. It therefore proposes to remove this repetition.

EXAM 406

Regal JP - Quod

Main Modification

MM09 - BSS01

MM26 – GSS08

MM11 – Barnet’s Growth Requirements

MM29 - GSS11

MM46 – CDH04

MM138 – Site 58

MM146 - Site 66

Council’s Response to Inspectors

The Council welcomes support for MM09
The Council considers that GSS08 is consistent with the NPPF and the London Plan. It does not consider it unreasonable for a Local Plan to stipulate that any new commercial floorspace relates to the size and the role and function of a town centre and its catchment. The Council considers that through MM26 it demonstrates support for North Finchley regeneration to come forward.
Wording throughout the Local Plan (including para 4.8.5) has been carefully considered by the Council and the Inspectors. Stating that Barnet can deliver and potentially exceed a minimum housing target (in para 4.8.5) is used in the appropriate context.
The Council considers that ‘relates’ is the appropriate word to use.
In revising Policy CDH04 and Map 4 the Council has been guided by the Inspectors letter of August 17th 2023 ensuring that locations that may be appropriate for tall buildings are clearly identified. This ensures alignment with the Tall Buildings Study Update (EB_DH_04).
Development Timeframe relates to the life of the Plan from 2021 to 2036. Therefore the correct timeframe is 6 to 10 years as development is not expected to be delivered before 2026.
Site requirements for site 66, apart from the new opening para, remain relatively unchanged. The Council has not proposed any MM with regard to the Sea Rock façade and therefore considers this particular representation on MM146 to be not duly made.
The use of minimum indicative capacity for some but not all sites is justified in the reasons for the MM.

EXAM 407

Richard Arcos

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 408

Richard Harris

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), the Deans Brook Nature Reserve, Site 27 and Site 28.

EXAM 409

Richard S Weber

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, Major town centre designation, tall buildings, car parking, including disabled persons car parking, and bus garage.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 410

Richard Taylor

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 411

Rikki Borston

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 412

Rishi Shah

Main Modification

MM20 – GSS05

MM59– CHW03

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

EXAM 413

Rita and Ashok Sood

Main Modification

MM20 – GSS05

MM59– CHW03

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28. Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 414

Robert Braham

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 415

Robert Fisher

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and the proposed redevelopment of the Broadwalk Shopping Centre

EXAM 416

Robert Graham

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

Local Plan Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 417

Robert Vertes

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

MM59 – CHW03

MM74 – TRC04

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

Local Plan Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

Local Plan Policy TRC04 highlights that where buildings or other structures taller than 3 storeys are proposed these should not interfere with existing broadcast and electronic communications services, particularly CCTV. Where such interference is unavoidable mitigating measures are required to ensure that the quality of existing signal reception is maintained as a minimum.

EXAM 418

Robyn Deutsch

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

MM59 – CHW03

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, tall buildings and car parking, including disabled persons car parking,.

Local Plan Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 419

Rochelle Kaye

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of Broadwalk Shopping Centre, tall buildings and car parking, including disabled persons car parking,.

Finchley Central and North Finchley Town Centres are not Growth Areas and the sites within these locations are more constrained.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 420

Rochelle Rozasty

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of Broadwalk Shopping Centre, tall buildings, car parking, including disabled persons car parking, and designation as a Major Town Centre.

Finchley Central and North Finchley Town Centres are not Growth Areas and the sites within these locations are more constrained.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 421

Ronit Shakhani

Main Modification

MM20 – GSS05

MM46 – CDH04

MM59 – CHW03

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

Local Plan Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

Local Plan Policy CDH04 states that all new proposals must meet the requirements of the Building Safety Act 2022 with clear lines of responsibility for safety during design, construction, completion and occupation of high-rise buildings. Proposals that involve residential buildings over 18 metres in height will need to provide two staircases to meet Building Regulations standards on Fire Safety”

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 422

Roopam Sharma

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 423

Ropemakers Properties

Main Modification

MM61 – ECY01

MM13 - GSS01

MM27 – GSS09

Council’s Response to Inspectors

MM61 - ECY01- The Council maintains that ECY01B (e) is accurately worded and does not agree that additional amendments are required. London Plan Policy E7 does not require site allocations to be made as to where co location schemes are required. London Plan Policy E7B does state the following;

‘In LSIS (but not in SIL) the scope for co-locating industrial uses with residential and other uses may be considered.

This should also be part of a plan-led or masterplanning process.’

Barnet has adopted a masterplanning approach to co-location in LSIS as detailed in ECY01B(e) and supporting text in para 9.9.4A. This was recommended by para 90 of the Appendix of the Inspectors’ letter of 17 August 2023 (EXAM143A).

The term ‘employment led’ in Policy ECY01Be and supporting text in para 9.9.4 is not subject to comment as part of the main modifications to the local plan. The Council set out the response to this initially in EXAM NO Note 76 (March 2023), and where it was raised again in Council’s Response on Representations from Inspector Led Consultation -June 2023.

Main Modifications in Policy ECY01Be ensures consistency with London Plan Policy E7, helps to provide certainty that proposals for co-location to support delivery of residential or other uses, such as community infrastructure, should only occur as part of intensification of a LSIS with ‘no net loss’ of employment floorspace and should be supported by a coordinated master planning process. Para 9.9.4A also supports this with cross references to London Plan Policy E7 and references to the GLA guidance on Industrial Intensification and Co-Location Through Plan-Led and Masterplan Approaches.

MM 13- GSS01 - The Council refers to the Inspectors August 17th letter (EXAM143A) para 12 which states : ‘The MMs should also remove the indicative capacity for growth associated with the West London Orbital as the location for any associated development beyond the identified Growth Areas in the Plan is not justified by sufficient evidence.’

MM27 – GSS09 – The response above also applies to GSS09.

EXAM 424

Rosalie Segal

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 425

Rosalind Chaplin

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 426

Rosina Abraham

Main Modification

MM109 – Site 28

MM72 – TRC02

MM11 – Table 5

MM20 – GSS05

MM26 – GSS08

MM53- TOW01

Council’s Response to Inspectors

The Council notes the support for the representations from Save Our Edgware and the Edgware Community Association concerning Site 28, protection of Edgware Bus Station, and classifications as a Major Town Centre vs. District Centre, Central Area vs. Suburban Area. We refer to the specific responses to Save our Edgware on these issues.

EXAM 427

Rozmin and Samir Abdul Mohammad

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 428

Rupuk Vekaria

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council welcomes this support for Policy GSS05 as well as the positive comments about the consultation that has been carried out on Barnet’s Local Plan

EXAM 429

Ruth Raebun

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre and tall buildings..

EXAM 430

Sabrina Sherman

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 431

Sagar Shah

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 432

Sally Charin

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to Sites 27 and 28, the proposed redevelopment of the Broadwalk Shopping Centre, tall buildings and infrastructure..

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 433

Sam Shah

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre and tall buildings..

The Council also refers to its response to LB Harrow. The Council’s proposals for Edgware have been subject to extensive engagement with local residents and businesses in both Barnet and Harrow (with the support of LB Harrow).

EXAM 434

Sandra and Cajetan Monteiro

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 435

Sanpine Ltd D9

Main Modification

Site 61 – Tally Ho Triangle

Council’s Response to Inspectors

The Council agrees with the Inspector’s letter of August 17th 2023 Appendix 1 para 132 in respect of Site 61 and that Urban is the correct surrounding context

EXAM 436

Sara Bernstein

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre and car parking, including disabled persons car parking,.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 437

Saryu Bidd

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, tall buildings and character.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 438

Satish Lakhiani

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 439

Save our Edgware and Edgware Community Association

Main Modification

MM20 – GSS05

MM21 – Map 3C

MM70 – ECC06

MM46 – CDH04

MM31 - ECC04

MM51 – CDH08

MM53 - TOW01

MM72 – TRC02

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

Key

Text in bold: new text proposed for addition, compared to submission version

Text within square brackets [ ]: text proposed for removal compared to submission version

The Council considers that it is necessary to address each of these points although the majority of them do not relate to an actual Main Modification. As GSS05 is the strategic policy for the Edgware Growth Area this is the main response by the Council to the comments made by Save our Edgware.

The Inspectors’ task is to consider the soundness and legal compliance of the submitted Plan, based on the criteria set out in the National Planning Policy Framework and associated regulations.

This includes the:

Planning and Compulsory Purchase Act 2004
Localism Act 2011
Town and Country Planning (Local Planning) (England) Regulations 2012.

The Inspectors have taken into account the representations submitted upon the Regulation 19 Draft Plan as far as they relate to soundness considerations. They are unable to consider planning applications or prospective planning applications that will be submitted to the Council.

The requirements and guidelines set out in Policy GSS05 and site proposals 27 and 28 provide the framework, together with other relevant planning policies (subject to adoption of the Local Plan) and guidance contained within the Edgware Growth Area SPD, for assessing any applications that come forward in these locations. Detailed planning applications with more detail on issues such as viability, open space provision, flood risk and biodiversity are assessed as part of the development management process.

The headings associated with each point reflect those of the submitted representation. The Council has added the relevant Local Plan policy or site proposal

Misclassification of Edgware:

Edgware is classified as a Major Town Centre through the London Plan. Annex 1 of the London Plan sets out the Town Centre Network and explains the 5 categories of classification. Any changes to the Town Centre Network have to be made through the London Plan.
The London Plan highlights within Annex 1 - Table A1.1 - Town Centre Network that Edgware has high residential but low commercial potential. The Table shows that Major Town Centres such as Lewisham, Woolwich and Wembley are likely to be upgraded in the next London Plan. Edgware has been classified as a Major Town Centre since the first London Plan in 2004. Of the 201 existing town centres in Table A1.1, none of them are expected to be downgraded in the future. The Council is unaware of any town centre being downgraded in the London Plan. That would be unusual. Given London’s population and employment growth the scale of development in town centres has tended to be for positive growth (for main town centre uses and/or housing).

As set out in the Edgware Growth Area SPD the core functions of Edgware Town Centre will be retained, supported and enhanced. Edgware will be developed as a destination with a diverse retail, commercial, leisure and cultural offering that attracts people from a wide catchment area to support existing local businesses and local economy. The retail/commercial offer will remain focused on Station Road as the main shopping thoroughfare to ensure the traditional shopping parades and small businesses are maintained and enhanced. Edgware’s commercial offering will be supported by new homes, bringing people closer to the activities of the town centre. This coupled with improvements to the public realm and shift towards a greener, cleaner local environment will also improve the Town Centre experience for visitors, existing and new residents alike.

The Central density matrix classification for Sites 27 and 28 in Edgware is consistent with the definition provided by the Density Matrix in Annex 1 of the Local Plan. Sites 27 and 28 have a mix of different uses, large building footprints and typically buildings of 4 to 6 storeys located within 800 metres of a major town centre.
Site 28: Edgware Underground and Bus Station - Unsuitability for Major Development:

Site 28 (as well as other proposals in the Plan) has been subject to a site selection process. This is set out in the Site Selection Background Report. Site capacity has been assessed having regard to the NPPF on seeking the most efficient use of land, the site size and the public transport accessibility level (PTAL) is used to determine the range of appropriate dwelling densities for residential development, and thus an indicative number of dwellings. Site 28 is suitable for development and the Council have set out site requirements and development guidelines within the Local Plan at GSS05 and within the Schedule of Proposals.

This is further supported by the Edgware Growth Area SPD. This includes protecting or re-providing the function of the bus station as well as bus operations, maintaining London Underground infrastructure and operations as well as preserving the SNCI at Deans Brook and providing improved flood risk resilience.
Excessive Housing Density for Site 27

The Council refers to its earlier response at Point 1 on density.
Open Space Deficiency:

ECC04 sets out the standards expected from proposals when new demand for parks and open spaces is generated. The Edgware Growth Area SPD seeks the delivery of new, linked public open spaces within the Growth Area. This coupled with improvements to the public realm and shift towards a greener, cleaner local environment will also improve the Town Centre experience for visitors, existing and new residents alike.
Destruction of Broadwalk Shopping Mall

The Broadwalk lies at the heart of the Town Centre and comprises a major strategic development opportunity for Edgware. It should be noted that the Broadwalk Shopping Centre is not owned by the Council and therefore we have limited influence over its protection. The Council’s role is to ensure that future proposals align with our ambitions for Edgware to become a destination with a diverse retail, commercial, leisure and cultural offering that attracts people from a wide catchment area to support our existing local businesses and local economy. This will help to realise both Barnet’s and Harrow’s ambitions for the town centre.
Edgware's Suburban Character:

The evolution of the Local Plan has long acknowledged Edgware as an important suburban and to some extent urban hub that is a location for opportunities that may bring new investment and revitalisation.

Edgware is a Growth Area because it has good PTAL and (as shown by Sites 27 and 28) a supply of brownfield and underused land and buildings that offer opportunities for inward investment.

The Edgware Growth Area SPD highlights that heritage assets have an important part to play in the growth and renewal of Edgware, providing historical context and supporting local identity.
Misleading "Design-Led Approach" disregard Edgware’s suburban character:

The Edgware Growth Area SPD provides an appropriate area assessment of Edgware. It is supported by a Design Guide which provides a design analysis of Edgware Town Centre and its immediate surroundings and sets out the design approach for key redevelopment sites, and the overall area. Planning applications will be assessed against this.
Contradiction to London Plan's Vision

There is no conflict with the London Plan. The Mayor has issued a Statement of General Conformity and not raised any objections with regards to GSS05. Production of the Growth Area SPD, which will play a key role in assessing submitted applications, was supported by GLA funding.
Unfair selection of Edgware as Tall Buildings site

The existing Local Plan – Core Strategy (adopted 2012) (Core_Gen_14). Policy CS5 identifies Edgware as a specific location for tall buildings. Edgware has therefore been, since 2012, a location where tall buildings may be appropriate. Edgware is also designated as a Growth Area in the Local Plan.
Disregard of Resident/Public Opinion

The Council’s proposals for Edgware have been subject to extensive engagement with local residents and businesses in both Barnet and Harrow (with the support of LB Harrow). Details of the engagement on the SPD are set out in

edgware_spd_public_consultation_statement.pdf (barnet.gov.uk)

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf
Incompatibility with Car Use and Parking Issues affecting viability of Edgware Town Centre:

The Local Plan’s vision seeks good, well-planned growth that has been directed into the most sustainable locations with good transport and active travel choices. This is reflected in policy on Health and Wellbeing CHW02 which supports reducing car dependency as well as promoting active travel and encouraging sustainable modes of transport. The Transport Study that supports the Edgware Growth Area SPD highlights that extensive surface car parking linked to the Broadwalk shopping centre has supported car travel into the town centre. In order to support growth there is a need to significantly improve the provision and support for active travel (walking and cycling) and public transport and combine this with effective management of car parking supply and car usage. The Council really need to make sure that all decisions on parking, the scale of parking given up and likely demand on/for active and sustainable provision are evidence-based. The Growth Area SPD highlights that in managing growth the Edgware town centre experience can be greatly improved for pedestrians and cyclists through improvements to the street environment and dedicated routes. While public transport access is already good, the relationship of the tube and bus facilities with the surrounding town centre can be made much better.
Contradictory Policy on Office Space:

There is no contradiction in the Local Plan’s approach to office space. As set out in Policy ECY01 the Council seeks to safeguard offices as a main town centre use in town centres such as Edgware. Offices have an important role to play as part of Use Class E (Commercial, Business and Services). Offices have not been removed from GSS05. They form part of appropriate location based floorspace provision in Edgware.
No Transport and Connectivity improvements:

Reference to transport improvements in Edgware are set out in the Local Plan, within GSS05 as well as in more detail in the SPD which is supported by a Transport Study. A section of GSS05 sets out expectations of development proposals and infrastructure requirements for Edgware Growth Area.
Infrastructure Requirements:

A section of GSS05 sets out expectations of development proposals and infrastructure requirements for Edgware Growth Area. More detail is set out in the Growth Area SPD. Chapter 12 of the Local Plan sets out how infrastructure can be delivered alongside growth.
Lack of employment opportunities in GSS05 incompatible with Policy BSS01 Spatial Strategy for Barnet:

There is no incompatibility. Principle 7 of the Growth Area SPD sets out that increasing the number of jobs available for local people is a vital element in the renewal of the town centre. It sets out what Edgware needs in terms of jobs and the local economy.
Must adopt Infrastructure first approach instead of design led approach.

A key tenet of the Local Plan is that all development must make the best use of land by following a design-led approach that optimises the capacity of sites, including site proposals, ensuring that it is aligned with London Plan Policy D3 Optimising site capacity means ensuring that development is of the most appropriate form and land use for the site and that it accords with the relevant requirements of the other Policies in this Plan. Chapter 12 of the Local Plan sets out how infrastructure can be delivered alongside growth.
Major concerns on Policy CDH04 Tall Buildings and Site Allocations 27 and 28:

MM46 CDH04 reflects changes to the policy on Tall Buildings, in particular to make it consistent with the London Plan, as requested by the Inspector in the August 17th 2023 letter. The Council refers to its earlier response with regards to Edgware being a location where tall buildings may be appropriate.
Site 28 Edgware Underground and Bus Station is unsuitable for major development:

Refer to specific response on Site 28 to Save our Edgware.
Site 28 - Deans Brook Nature Reserve land is unsuitable for development:

The Local Plan is not proposing development of the Nature Reserve. Policy ECC06 sets out a number of ways that the Council will seek the retention and enhancement, or the creation, of biodiversity in development proposals. One way will be by protecting existing Site of Special Scientific Interest, Sites of Importance for Nature Conservation, and priority habitats and species according to the Natural Environment and Rural Communities Act 2006 and working with partners including the London Wildlife Trust and the Brent Catchment Partnership to improve protection and enhancement of biodiversity in Barnet. The Council refers to its response to the Barnet and Enfield Swifts Group and a proposed modification to ECC06 which refers to opportunities to create other habitats, or features such as artificial nest sites, that are of particular relevance and benefit in an urban context.

Policy TRC01 sets out how the Council will promote and enable active travel requiring developments to address the needs of cyclists and pedestrians. The supporting text states that the Council will ensure, wherever possible, that consideration is given to improving or extending the existing strategic walking network from all development proposals within the Borough. Reference to the proposed Silk Stream Valley Walk is made throughout the Local Plan.

The Council will balance the requirements of ECC06 with those of TRC01 in assessing future planning applications with regards to Site 28. Refer to response on Site 28 with regards to the SINC status.
Non-compliance to Policies regarding protected wildlife such as Bats:

The Council is unclear in terms of how it can be non-compliant with regards to an application which has just been submitted. Reference is made to the Unitary Development Plan (UDP). The UDP ceased to provide the policy framework for Barnet in 2012. The reasons behind the changes shown by MM70 ECC06 to make it align with the NPPF, comply with the Environment Act 2021 and be consistent with the London Plan are set out in the Table of Proposed Modifications.
Site 28’s Flood Risk:

The Local Plan is supported by a Strategic Flood Risk Assessment. Water Management Policy ECC02A is consistent with the NPPF and PPG requirements with regards flood risk, surface water management, water infrastructure, water courses and application of the sequential test to steer new development to areas with the lowest flood risk. Barnet’s approach is supported by the Environment Agency. The policy is supported by the Sequential and Exceptions Test (EB_GI_18) which has been agreed by the Environment Agency. GSS05 and supporting text highlight flood risk issues in Edgware that are to be assessed in terms of planning applications in the Growth Area. Refer to response on Site 28 with regards to that site’s flood risk issues
Site 27 Edgware Town Centre’s Indicative residential capacity should be reduced from 2,379 to 763 dwellings: Site 27

The Central density matrix classification for Sites 27 and 28 in Edgware is consistent with the definition provided by the Density Matrix in Annex 1 of the Local Plan.
Unfair treatment of Edgware - inclusion of Edgware and removal of other towns from tall buildings list: Policy CDH04

The Council does not consider Edgware as being ‘unfairly treated’. It has long been identified a location that may be appropriate for tall buildings since 2012. The existing Local Plan – Core Strategy (adopted 2012) (Core_Gen_14). Policy CS5 identifies Edgware as a specific location for tall buildings. See response to Save our Edgware on CDH04 in terms of the reasons for the changes that the Council made to the policy. There is no conflict between the objectives in MM07 Table 2. If there was a conflict the Inspector would’ve raised this in his letter of August 17th 2023. This table highlights the most relevant policies. Policy GSS01 Delivering Sustainable Growth sets the scene for the Local Plan’s approach to Growth and Spatial Strategy, therefore it appears as the most relevant policy against the majority of the key objectives.
Edgware was wrongly classified as a Major Town Centre in a Central setting:

The Council refers to its previous response with regards to Major Town Centre and the Central density which generated the indicative residential capacities for sites 27 and 28. These sites are not characterised by lower-density developments such as detached and semi-detached houses, small building footprints, and typically buildings of two to three storeys. The Local Plan Density Matrix has been agreed at the EIP as an acceptable approach to inform the densities for the site proposals. It has been applied consistently across the Local Plan site proposals.
Edgware’s Suburban character is indisputable. The box typology of the Broadwalk does not alter the low-density suburban nature of Edgware:

The evolution of the Local Plan has long acknowledged Edgware as an important suburban and to some extent urban hub that is a location for opportunities that may bring new investment and revitalisation. The Edgware Growth Area SPD sets out the character and heritage of the town centre. The SPD reflects that Edgware can draw on its unique character and features while seeking new offerings to enhance the town centre’s appeal and support its businesses. The Broadwalk has a large building footprint which lends itself to a central context.
Contradictions Between Proposed Overdevelopment and Edgware’s Character:

Reference is made to the planning application from Ballymore/TfL. The Council refers to its previous response about the role of this Local Plan EIP which is separate from that of the recently submitted planning application.
Site 27 - Lost of Broadwalk Shopping Mall - Inadequate car parking spaces impact the viability of Edgware as a Town Centre:

The Council refers to its specific response to Save our Edgware on Site 27
A design led approach with the community was not followed to create the Edgware policy

The Council refers to its previous response at Point 10 on the extensive consultation and engagement that has been carried out with regards to the Local Plan and the Growth Area SPD which is supported by a Design Guide.
The proposed design does not fit into the local neighbourhood

This relates to the proposed design in the planning application from Ballymore/TfL. The Council refers to its previous response about the role of this Local Plan EIP which is separate from that of the recently submitted planning application.
Contradict to the sustainability policy of the London Plan

There is no contradiction. The Local Plan policies and site allocations have been subject to Sustainability Appraisal (SA) final_sustainability_appraisal_update_mms.docx (live.com) to ensure that they are the most appropriate. The SA taken as a whole has influenced and informed the Local Plan resulting in a sustainable plan; ensuring environmental, social and economic factors have been integral to decision making both in its preparation and during its examination.
Edgware policy of overdevelopment has not followed many of the regulations for tall buildings:

Clarification that policy DM05 from the 2012 Local Plan (Development Management Policies) (Core_Gen_15). is to be replaced by Policy CDH04 (subject to adoption of the Local Plan). MM46 in relation to Policy CDH04 outlines the reasons why the modifications are necessary to make the policy sound. This includes alignment with London Plan policy D9(C).
High-rise estates will cause loss of privacy and shadowing of neighbourhoods:

As previously stated, proposals will be considered in line with the Local Plan and the Growth Area SPD, which is supported by a Design Guide, along with other relevant material considerations.
Tall buildings are discriminatory to folks observing sabbath:

The Local Plan including Policy CDH04 on Tall Buildings has been subject to an Equalities Impact Assessment.
Open space deficiency in Edgware Town Centre - Must follow Barnet’s own Open Space Policies in the Local Plan:

The Council refers to its previous response at Point 4 on open space deficiency. Applications will be assessed against all the policies including Policy ECC04 in the Local Plan. The Council refers to Policy CHW02 on Promoting Health and Wellbeing. Applications will be assessed against all the policies including Policy CHW02 in the Local Plan. The Growth Area SPD highlights new public open space throughout the town centre as an infrastructure priority. This will be for residents, workers and visitors to enjoy.
Risk to Edgware’s Heritage in Barnet and Harrow:

The Council refers to Policy CDH08 – Barnet’s Heritage which has been subject to a comprehensive redraft as set out in MM51 so that it aligns with NPPF approach to the historic environment. LB Harrow have submitted representations on Barnet’s Local Plan Main Modifications and proposed a further modification to Policy GSS05 which provides clarification on the Growth Area SPD. The Council do not oppose this proposed change. It also proposes further modifications to Sites 27 and 28 to highlight consideration of conservation areas in LB Harrow.
Risk to adjacent Conservation Area:

The Council agrees that Sites 27 and 28 should also make reference to neighbouring conservation areas in LB Harrow. This is consistent with proposal sites 11 and 12 in respect of neighbouring conservation areas in LB Brent. Refer to responses on sites 27 and 28 where proposed modifications are set out
Heritage - Edgware, Edgwarebury and Burnt Oak are in Archaeological Priority Areas (APA):

If a Local Plan proposal site, such as Site 27, is within an APA this is reflected in the existing designation. CDH08F states how archaeological issues will be assessed.
The validity of Edgware Growth Area SPD: Policy GSS05

The Growth Area SPD produced jointly with LB Harrow supports the implementation of Policy GSS05 and the role of this detailed planning framework is reflected in MM20. The Council refers to its response to the representations of LB Harrow with regards to MM20 and MM21. LB Harrow have proposed a modification through a footnote to Policy GSS05 at the end of the 1st sentence of GSS05C :

MM20 GSS05C

"The Edgware Growth Area SPD will remain a material consideration within its geographical scope (including LB Harrow land as shown within mapping in the SPD), but polices within this Local Plan are unable to apply within the LB Harrow administrative area."

The Council also notes the comments from Save our Edgware on the 1st and 2nd sentences of para 4.18.1. Whilst not accepting the proposed changes to text the Council acknowledges that a minor change to the 2nd sentence is required as follows :

"The centre is situated in the north-west corner of Barnet [and] with a small part extending into Harrow."
Site 27 housing target should be reduced from 2,379 to an indicative 763 homes

The Central density matrix classification for Sites 27 and 28 in Edgware is consistent with the definition provided by the Density Matrix in Annex 1 of the Local Plan
Loss of Broadwalk Shopping Mall

The Broadwalk lies at the heart of the Town Centre and comprises a major strategic development opportunity for Edgware. It should be noted that the Broadwalk Shopping Centre is not owned by the Council and therefore we have limited influence over its protection. The Council’s role is to ensure that future proposals align with our ambitions for Edgware to become a destination with a diverse retail, commercial, leisure and cultural offering that attracts people from a wide catchment area to support our existing local businesses and local economy. This will help to realise both Barnet’s and Harrow’s ambitions for the town centre.
Broadwalk as a social hub stated by Barnet Council

An Equalities Impact Assessment (EqIA) is a measure that public authorities often carry out prior to implementing a new policy or service, with a view to ascertaining its potential impact on equality. Such assessments are not required by law; however, they are a way to ensure public authorities are complying with the Public-Sector Equality Duty. Both the Local Plan and the Growth Area SPD have been subject to an EQIA
Inadequate car parking spaces impact the viability of Edgware as a Town Centre:

The Council really need to make sure that all decisions on parking, including disabled persons car parking, the scale of parking given up and likely demand on/for active and sustainable provision are evidence-based. In considering local capacity will seek a Parking Design and Management Plan and may use planning obligations / legal agreements to control the layout and management of the parking spaces, including the nature of the users and the pricing structure. The Parking Design and Management Plan should demonstrate the suitability and arrangements for any retained or proposed parking as well as showing what steps will be taken to ensure minimum disruption to parking in the town centre or local area during construction.
Edgware was wrongly classified as a Major Town Centre in a Central setting

See response for GSS05 with regards to the Town Centre Classification and the use of Central densities for Sites 27 and 28.
Indicative residential capacity should be reduced to 763

The Council refers to its response at point 1.
Edgware's Suburban character is indisputable

See previous response at Point 25 on Edgware’s character
A design led approach with the community was not followed to create the Edgware policy

See previous response at point 10 to Save our Edgware at GSS05 on how Local Plan policy was developed
The proposed design does not fit into the local neighbourhood

The planning application has now been submitted and the Council will assess it against the policies in the Local Plan as well as the guidance set out in the Edgware Growth Area SPD.
The Edgware policy of redevelopment has not followed many of the regulations for tall buildings

See previous response at point 31 to Save our Edgware
High-rise estates will cause loss of privacy and shadowing of neighbourhoods

See previous response at point 32 to Save our Edgware
Tall buildings are discriminatory to folks observing sabbath
See previous response at point 33 to Save our Edgware
Open space deficiency in Edgware Town Centre

See previous response at point 34 to Save our Edgware
Reduced Biodiversity -real threat to protected species living in the Deans Brook Nature Reserve

Deans Brook forms part of Site 28. The Local Plan is supported by a Habitats Regulations Screening Assessment (HRA). 8._final_barnet_main_modifications_hra_screening_report_april_2024_0.docx (live.com)The requirement to undertake HRA of development plans is outlined in the Conservation of Habitats and Species Regulations 2017 (‘the Habitats Regulations’). Site 28 was assessed as part of the HRA and no likely significant effects were identified. Due to the distances involved to any designated site, there are no impact pathways present and in combination effect of recreational pressure and urbanisation do not require consideration. Deans Brook is a Grade 2 Site of Borough Importance for Nature Conservation. ECC06 sets out a number of ways that the Council will seek the retention and enhancement, or the creation, of biodiversity in development proposals. One way will be by protecting existing Site of Special Scientific Interest, Sites of Importance for Nature Conservation, and priority habitats and species according to the Natural Environment and Rural Communities Act 2006 and working with partners including the London Wildlife Trust and the Brent Catchment Partnership to improve protection and enhancement of biodiversity in Barnet.
Risk to Edgware’s Heritage in Barnet and Harrow

The Council refers to Policy CDH08 – Barnet’s Heritage which has been subject to a comprehensive redraft as set out in MM51 so that it aligns with NPPF approach to the historic environment. The Council will assess the heritage implications of the recently submitted application in line with CDH08.The Council proposes further modifications to Sites 27 and 28 to highlight consideration of conservation areas in LB Harrow.
Risk to adjacent Conservation Area

The Council agrees that both Sites 27 and 28 should make reference to neighbouring conservation areas in LB Harrow. This is consistent with proposal sites 11 and 12 in respect of neighbouring conservation areas in LB Brent. Responses to Save our Edgware set out proposed modifications for sites 27 (below) and 28 at point 60

MM108 Site 27
Within site description the Council proposes the following

"The Watling Estate Conservation Area is to the south of the site, while within Harrow, the Canons Park Conservation Area lies to the north west and the Edgware High Street Conservation Area is to the west." Within site requirements and development guidelines the Council proposes the following "In particular, the potential impact of any tall buildings on the setting of the Watling Estate Conservation Area, Canons Park Conservation Area and Edgware High Street Conservation Area must be considered to ensure that the significance of the heritage assets is conserved or enhanced."
Heritage - Edgware, Edgwarebury and Burnt Oak are in Archaeological Priority Areas (APA)

Site 27 is within an APA and this is reflected in the existing designation. CDH08F states how archaeological issues will be assessed.
Site 28 is unsuitability for major development
Site 28 (as well as other proposals in the Plan) has been subject to a site selection process. This is set out in the Site Selection Background Report. Site capacity has been assessed having regard to the NPPF on seeking the most efficient use of land, the site size and the public transport accessibility level (PTAL) is used to determine the range of appropriate dwelling densities for residential development, and thus an indicative number of dwellings. Site 28 is suitable for development and the Council have set out site requirements and development guidelines within the Local Plan at GSS05 and within the Schedule of Proposals. This is further supported by the Edgware Growth Area SPD. This includes protecting or re-providing the function of the bus station as well as bus operations, maintaining London Underground infrastructure and operations as well as preserving the SNCI at Deans Brook and providing improved flood risk resilience.
Edgware tube station and operational Northern Line infrastructure land, Edgware bus station land and Edgware bus garage are unsuitable for development

Proposals to include the Underground and Bus station in the Local Plan as a regeneration opportunity were submitted by the landowner – Transport for London as part of the Call for Sites process. They have been subject to a site assessment process which is set out in the Site Selection Background Document. It is clearly stated in site requirements and development guidelines for Local Plan proposal site 28 that ‘bus operations and the function of the bus station must be protected or re-provided as part of any redevelopment. London Underground infrastructure and operations must also be maintained. This is reinforced by GSS05. Public safety is a priority for making Barnet a safer place to live in, work in and visit. As set out in Policy CHW03 the Local Plan will support proposals that provide safe and secure environments. The Council refers to its earlier response on the central density.

This is a consultation on the Local Plan Main Modifications and the Council therefore is unable to comment on a recently submitted planning application that will be determined on the basis of policies (subject to adoption) in the Local Plan).
Deans Brook Nature Reserve land is unsuitable for development

The Local Plan is not proposing development of the Nature Reserve. The site requirements and development guidelines for Site 28 clearly state that ‘proposals should preserve the area of Borough Importance for Nature Conservation, which covers the south eastern part of the site, including the areas around Deans Brook.’

The Local Plan is supported by a Habitats Regulations Screening Assessment (HRA). The requirement to undertake HRA of development plans is outlined in the Conservation of Habitats and Species Regulations 2017 (‘the Habitats Regulations’). Site 28 was assessed as part of the HRA and no likely significant effects were identified. Due to the distances involved to any designated site, there are no impact pathways present and in com-bination effect of recreational pressure and urbanisation do not require consideration.
Flood risk on site 28

Site 28 was assessed as part of the Flood Risk Sequential and Exceptions Test (EB_GI_18) which found that proposed developments on the site should be located outside of the 8m Main River buffer zone for the Dean's Brook. A detailed FRA must be submitted alongside any planning application which should assess flood risk from all sources and provide details of any mitigation including finished floor levels, floodplain compensation and safe access and egress.
Risk to adjacent Conservation Area

The Council agrees that Site 28 should also make reference to neighbouring conservation areas in LB Harrow. This is consistent with proposal sites 11 and 12 in respect of neighbouring conservation areas in LB Brent.

MM109 Site 28

Within site description the Council proposes the following

"Within Harrow, the Canons Park Conservation Area lies to the north west and the Edgware High Street Conservation Area is to the west."

Within site requirements and development guidelines the Council proposes the following

"Proposals must carefully consider the context of the adjacent Watling Estate Conservation Area, together with the Canons Park Conservation Area and Edgware High Street Conservation Area (within Harrow) , to ensure that the significance of nearby heritage assets are conserved or enhanced, and the relationship with low-rise suburban housing."
Risk to Edgware’s Heritage in Barnet and Harrow

CDH08 has been subject to a comprehensive redraft as set out in MM51 so that it aligns with NPPF approach to the historic environment. The Council will assess the heritage implications of the recently submitted application in line with CDH08.The Council proposes further modifications to Sites 27 and 28 to highlight consideration of conservation areas in LB Harrow.
Risk to adjacent Conservation Area:

The Council proposes further modifications to Sites 27 and 28 to highlight consideration of conservation areas in LB Harrow.
Heritage - Edgware, Edgwarebury and Burnt Oak are in Archaeological Priority Areas

Site 27 is within an APA and this is reflected in the existing designation. CDH08F states how archaeological issues will be assessed.
Concerns Over Replacement Plans

This is a matter for the detailed planning application rather than Policy TRC02 and this EIP. The Council expects TfL to carry out full engagement on its proposals.
Failure to Meet Legal and Policy Standards

Again this appears to be directed towards the detailed planning application and is outside the scope of the EIP. The Local Plan is supported by an Equalities Impact Assessment.
Proposed Requirements for New Bus Station

The Council will expect the new bus station design to meet the very highest safety and inclusive design standards to create a place that is inclusive and accessible and can be enjoyed by everyone including people with disabilities, older people, and carers with young children. The Growth Area SPD highlights that Edgware bus station must :

-Maintain a central location and enable easy interchange;
-Overcome the severance caused by bus access on to Station Road and reduce conflict with pedestrians accessing the station and its immediate surroundings;
-Provide intuitive way finding;
-Offer high quality passenger information and waiting facilities;
-Ensure integration of the station with its surrounding context.
Bus Garage Concerns and Need for Above Ground Bus Garage

Again this appears to be directed towards the detailed planning application and is outside the scope of the EIP.
Accessibility and Consultation

The Council will expect the new bus station design to meet the very highest safety and inclusive design standards to create a place that is inclusive and accessible and can be enjoyed by everyone including people with disabilities, older people, and carers with young children. As part of the planning application there will be opportunity to comment on the proposals for the new bus station.
Building Height and Safety

The reasons for the removal of the Very Tall Buildings category is set out in the Inspectors letter of August 17th (EXAM143A). Application of the criteria in London Plan Policy D9 ensures a consistent approach to proposals for tall buildings across London. Specific reference in CDH04 to the Building Safety Act 2022 and the Building Regulations is merited in order to reflect legislative updates. The Council refers to MM46 para 6.18.5 with regards to the guidance about heights and locations set out in the Tall Buildings Study Update (EB_DH_04). In order to meet a change to the Building Regulations in March 2024 CDH04E will be subject to modification replacing height threshold of 30 metres with 18 metres.
Inclusion of Edgware and Removal of other towns in the Borough

There have been no changes to Edgware’s identification as a location which may be appropriate for tall buildings. Unlike Finchley Central and North Finchley Town Centres, Edgware has been identified as a Growth Area. The definition of a Growth Area is set out in the Glossary of the Local Plan. The locations that have been removed from CDH04A did not have the support from the Tall Buildings Study Update. However as set out in Map 4 town centres such as Finchley Central, North Finchley and Whetstone contain site proposals where tall buildings may be appropriate.
Local Views

The four Locally Important Views identified in the Local Plan are views from places in Barnet. Three of the views extend beyond the Borough. The viewpoint from Stanmore Country Park is from Harrow, therefore the consideration of that as an important view would be a matter for Harrow’s Local Plan. London Plan Policy D9C (to which the Local Plan makes a specific cross-reference) states that development proposals should address visual impacts in terms of long-range views, mid-range views and immediate views.
General watering down of criteria for approval

There has been no watering down. The Council now makes a specific reference to London Plan Policy D9C so that there is no inconsistency in terms of what tall building proposals are expected to address.
Other

Reasons for making the changes are set out in the Table of Modifications which reflects the Inspectors letter of August 17th 2023 (EXAM143A). Finchley Central and North Finchley Town Centres are not Growth Areas and the sites within these locations are more constrained.
Absence of Designing for Density SPD

The SPD, on which work is underway, will help support the implementation of the Plan following its adoption. The Plan does not need the SPD to be in place in order for it to be adopted.
Statement of Common Ground between Council, Ballymore Group and Transport for London

The Statement of Common Ground will be kept up-to-date and will form a key part the Local Plan review and implementation of adopted and emerging policies.

Withdrawal of the Statement would be a matter for the signature bodies.

EXAM 440

Savio Gimmi

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to Deans Brook Nature Reserve, Site 28 and the proposed redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 441

Sawan Shah

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, public transport and character.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 442

Shahnaz Kazi

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 443

Shailen Thakrar

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 444

Sharon Brand

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

Local Plan Policy CHW03 emphasises the importance of addressing crime and fire safety issues early in the design process.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 445

Sharon Coelho

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of Broadwalk Shopping Centre, density and tall buildings.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 446

Sharon Maynard Seath

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 447

Sharon Nassim

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of Broadwalk Shopping Centre, and car parking, including disabled persons car parking,.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 448

Sheida Hartley

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to Sites 27 and 28, the proposed redevelopment of the Broadwalk Shopping Centre and infrastructure.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 449

Shenal Malde

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre and infrastructure

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 450

Sherrie Tillman

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 451

Simon Cohen

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 452

Simon Lewis

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 453

Simona Rotman Shats

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 454

Simone Tanman

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 455

Sinead Butler

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 456

Siva Sai Krishna Vakati

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 457

Solomon Abraham

Main Modification

MM109 – Site 28

MM72 – TRC02

MM11 – Table 5

MM20 – GSS05

MM26 – GSS08

MM53- TOW01

Council’s Response to Inspectors

EXAM 458

Soma Raviraj

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 459

Sonia Thapar

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 460

Souheil Zeidan

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, character and infrastructure

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 461

Sports England

Main Modification

MM31 – GSS13

MM57 – CHW01

MM68 – ECC04

Council’s Response to Inspectors

Key

Text in bold: new text proposed for addition, compared to submission version

Text within square brackets [ ]: text proposed for removal compared to submission version

The Council welcomes this support for MM31 and MM57
The Council does not oppose making reference to the Playing Pitch Strategy Review and Action Plan 2023. It proposes the following modifications to ECC04Ba)

Insert footnote after end of Playing pitches

Refer to Playing Pitch Strategy Review and Action Plan 2023

Para 10.17.4

Playing Pitch Strategy [2017] Review and Action Plan 2023

Para 10.21.1

The Playing Pitch Strategy [2017] Review and Action Plan 2023 highlights that despite good geographical coverage there is demand for additional provision because of issues related to the quality of the existing pitches (mainly due to poor drainage) and accessibility.

EXAM 462

Springboard Two Housing Association

Main Modification

MM24 – GSS07

MM28 – GSS10

MM50 – CDH07

MM81 – List of Sites – Summary

Council’s Response to Inspectors

GSS07 sets out policy for growth in Mill Hill East and names a number of sites that will make a contribution to this growth. Once the Plan is adopted any applications within the Mill Hill East area will be considered against GSS07 and other relevant policies in the Plan. The Mill Hill East AAP remains a material consideration.
GSS10 sets out policy for Estate Renewal and Infill and how such proposals submitted via a planning application will be considered.
The Council does not consider that there is a conflict between CDH07 and supporting text.
The Council considers that Policy GSS01 clearly sets out the approach to growth, and the contribution that Mill Hill East will make to that growth.
At this late stage in the EIP neither the Council nor the Inspector have invited submissions of new sites. The absence of a specific proposal in the Local Plan does not prevent Curry Rise and Bray Road Estate being put forward as a planning application.

EXAM 463

St George (City) limited

Main Modification

MM9 – BSS01

MM33 – HOU01

MM41 – CDH01

MM46 - CDH04

Council’s Response to Inspectors

MM9 – BSS01 – The Council considers that MM9 provides a clear framework and the MM is effective in directing growth to sustainable locations, including those explicitly identified in other policies within the Plan. The modifications were made in order for the policy to be justified and consistent with other policies, and for general conformity with the London Plan. Policy GSS11 address development in Major Thoroughfares. The Council will positively consider proposals on suitable sites which optimise the use of land and site capacity through a design-led approach, in accordance with London Plan Policy D3.

MM33 – HOU01- The Council does not consider there is an inconsistent approach. It is not unsound for the Council to seek the maximum delivery of affordable housing within the policy, whilst also setting out what the minimum requirement for Developers to respond to accordingly. MM33 provides a strong basis for securing much needed affordable housing in Barnet. The modifications to H0U01 have been made for soundness and for general conformity and consistency with the London Plan in relation to the approach to affordable housing delivery as set out in the Inspectors August 17th letter (EXAM143A).

MM41 – CDH01 - The Council considers that there is no inconsistency with the London Plan. Overall, the MM is reflective of London Plan Policy D6(C) in respect of single and dual aspect dwellings. Whilst the London Plan refers to north facing units, it also covers single aspect units more generally. The MM added to Section 6.9 with regard to single aspect dwellings, is in accordance with London Plan para 3.6.5 which states: “Single aspect dwellings are more difficult to ventilate naturally and are more likely to overheat, and therefore should normally be avoided. Single aspect dwellings that are north facing, contain three or more bedrooms or are exposed to noise levels above which significant adverse effects on health and quality of life occur, should be avoided. The design of single aspect dwellings must demonstrate that all habitable rooms and the kitchen are provided with adequate passive ventilation, privacy and daylight, and that the orientation enhances amenity, including views. It must also demonstrate how they will avoid overheating without reliance on energy intensive mechanical cooling systems.”.

It is not considered reasonable or sound to amend the MM to refer to only to north facing units only and remove reference to overheating as suggested by the respondent. These suggestions would not be in accordance with the London Plan and against principles of high-quality design and sustainability.

MM 46 - CDH06 - Historic routes such as Edgware Road (A5) present greater challenges for tall buildings given constrained locations. The Inspectors clearly state in their letter of August 17th (EXAM143A) that Major Thoroughfare locations such as Edgware Road do not fully align with the Tall Buildings Study Update. (EB_DH_04). Map 4 has been updated to include all the locations identified in the Tall Buildings Study Update that may be appropriate for tall buildings. These changes for appropriate locations for tall buildings reflect the current evidence base.

EXAM 464

Standard Life Investments Brent Cross LP and Hammerson (Brent Cross) Limited as partners in the Brent Cross Partnership

Main Modification

MM9 – GSS02

MM10 – Key Diagram

Council’s Response to Inspectors

The Council does not oppose an update to para 3.3.1D of MM9 as follows

"The long-term need for retail and leisure space is not the same as the long-term needs for industrial and office space. A key component of the Local Plan evidence base is the Town Centre Floorspace Needs Assessment. This was completed in 2017 and produced on the basis of the pre 2020 Use Classes Order. There is a broad consensus that expectations of retail and leisure growth from before COVID19 have changed with movement away from traditional retail formats and the way we interact with town centres as the focus of local commercial activity. Within Barnet a key component of future growth is the delivery of a new Metropolitan Town Centre at Brent Cross. This will be delivered through the implementation of the 2014 consent which provides for up to 115,000m2 of new retail space and through future planning applications consistent with Policy GSS02. The Council’s premise is that Brent Cross will be the realisation of any future retail growth in Barnet. If in response to market signals retail growth is not delivered at Brent Cross it is unlikely to be realised elsewhere within the Borough."

The Council considers that for the Key Diagram is sufficiently clear. GSS02B clearly states that the new Metropolitan Town Centre will extend north and south of the North Circular Road. There are no soundness reasons to make this change.

EXAM 465

Stephanie Cook

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 466

Stephen Berlofsky

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 467

Stephen Deutsch

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 468

Stephen Hartley

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 469

Stephen Ufland

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre and infrastructure

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 470

Steven Hesse

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, infrastructure and density

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 471

Stuart Cawthorne

Main Modification

MM20 – GSS05

Council’s Response to Inspectors

As stated in GSS05B proposals will be expected to deliver or contribute to infrastructure. Specific forms of infrastructure are highlighted. This is in addition to requirements through policy such as community infrastructure, public realm, improvements to parks and open spaces.
The leisure options set out in GSS05 remain unchanged from the previous version of the Local Plan. New recreational activities and sports that would benefit local residents and the town centre are fully supported by the Edgware Growth Area SPD was adopted in June 2021.
The Growth Area SPD was produced jointly with LB Harrow and involved extensive engagement with communities and businesses as well as elected members of both councils. This SPD provides a planning framework with more detailed guidance for the Growth Area and the development sites within it.

EXAM 472

Sue Bennett

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 473

Sundeep Gupta

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 474

Surendra Kamath

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28 and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 475

Susyn Northwood

Main Modification

MM85 – Site 3

Council’s Response to Inspectors

The Local Plan seeks to retain community use at Site 3 and does make clear that as part of any consideration of development evidence will be required to justify any loss of community use.

EXAM 476

Suzanne Ellul

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28 and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 477

Suzanne Rubin

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28 and redevelopment of the Broadwalk Shopping Centre.

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 478

Tamar Davis

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28.

EXAM 479

Teresa Cunningham

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, density, public transport and bus garage.

EXAM 480

Terry Gibbs

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28, redevelopment of the Broadwalk Shopping Centre, car parking, including disabled persons car parking, and character. The Council also refers to its response to LB Harrow. The Council’s proposals for Edgware have been subject to extensive engagement with local residents and businesses in both Barnet and Harrow (with the support of LB Harrow)

EXAM 481

Tim Stevenson

Main Modification

MM13 – GSS01

Council’s Response to Inspectors

The Council refers to proposed changes to MM13 GSS01E as set out in response with regards to TfL Spatial Planning

EXAM 482

Tina Son

Main Modification

MM11- Table 5

MM20 – GSS05

MM26 – GSS08

MM53 – TOW01

Council’s Response to Inspectors

The Council notes the support for the representations from Save Our Edgware and the Edgware Community Association concerning the classification of Edgware Town Centre as a Major Centre. We refer to the specific responses to Save our Edgware on this issue.

EXAM 483

Tony Seymour

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 484

Tracey Fraser

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 485

Transport for London - Places for London

Main Modification

MM11- Table 5

MM13 – GSS01

MM20 – GSS05

MM22 – GSS06

MM24 – GSS07

MM26 – GSS08

MM33 – HOU01

MM41 – CDH01

MM46 – CDH04

MM69 – ECC05

MM71 – TRC01

MM73 – TRC03

MM105 – Site 24

MM106 – Site 25

MM108 – Site 27

MM109 – Site 28

MM111 – Site 30

MM112 – Site 31

MM124 – Site 44

MM127 – Site 47

MM130 – Site 50

MM133 – Site 53

MM137 – Site 55

MM136 – Site 56

Council’s Response to Inspectors

Key

Text in bold: new text proposed for addition, compared to submission version

Text within square brackets [ ]: text proposed for removal compared to submission version

The Council welcomes support for MM11, MM20, MM24, MM26, MM27, MM30, MM41, MM69, MM105, MM112, MM133

1. The Council notes response on MM106 and MM136

2. The Council refers to its response with regards to TfL Spatial Planning and proposed changes to MM13-GSS01Bc

3. The Council considers that this minor change to GSS06 Aci as well as para 4.19.8 helps provide further reassurance about residential led development at this site and reflects the Colindale Station SPD adopted in 2019.

"MM20 GSS06 Aci Reconstruction and upgrading of Colindale Underground Station to increase its capacity and provide a step-free access station, along with additional cycle parking and facilitating the residential led redevelopment of adjacent land owned by TfL and others;"

MM20 Para 4.19.8 Colindale Underground Station – “renewal of the station with new ticket hall building with step-free access to the platforms, sufficient gate-capacity and additional cycle parking for the growing population in the area. Together with and intensification to take advantage of the high PTAL, facilitating the residential led redevelopment of adjacent land owned by TfL and others;”

4. MM33 Para 5.4.10B - The Council does not oppose a clarification on the affordable housing threshold in para 5.4.10B using the wording from London Plan Policy H5.

"All development must make the best use of land by following a design-led approach (London Plan Policy D3) that optimises the capacity of sites. Optimising site capacity means ensuring that development is of the most appropriate form and land use for the site. The Council will therefore assess the capacity of sites under the major development proposals threshold set out in London Plan Policy H5 [HOU01] to ensure optimum capacity. In undertaking such an assessment it will also seek to prevent the subdivision of site(s) in the same ownership for the purposes of avoiding the threshold for a contribution to affordable housing."

5. MM46 Para 6.18.5 The Council does not oppose additional reference to the Colindale Station SPD at para 6.18.5

"The Council will also expect proposals for tall buildings to reflect the guidance provided in area planning frameworks such as the Edgware Growth Area SPD, [and] the North Finchley Town Centre Framework SPD and the Colindale Station SPD."

6. MM71 Para 11.4.2 - The Council does not oppose the update on Colindale Station at para 11.4.2 as follows :

"The Government in 2023 announced Levelling Up funding to increase passenger capacity at [for the redevelopment of] the existing Colindale Underground station (including provision of a new, larger ticket hall and step free access). Funding has also been provided for the [new] station upgrade [(which is expected to open in 2024)] by contributions from the Peel Centre development as well as from the Council and TfL. The new station entrance will open in autumn 2025. The redevelopment, which is being taken forward in partnership with TfL, will increase station capacity to meet the needs of the growing population, create step-free access and support sustainable transport choices."

7. The Council does not consider the supporting text in para 11.12.6 (MM73) with regards to CPZs to be contradictory. It complements the change to TRC03B in allowing for the use of CPZs where there are unacceptable impacts on local highway conditions. The Council notes that this sentence is repeated at the end of para 11.12.6. It therefore proposes to remove this repetition. With regards to comments on para 11.12.7 the Council considers that this is a sensible and flexible approach towards phased development which is reflective of the Inspectors August 17th letter (para 123) (EXAM143A).

8.Site 30 – MM111- The Council refers to Map 4 and wording of CDH04 as providing clarification on locations that may be appropriate for tall buildings. It therefore does not consider that further wording about the site proposal being suitable for tall buildings is merited.

9. Site 44. MM124 – Development Timeframe relates to the life of the Plan from 2021 to 2036. Therefore the correct timeframe remains as 6 to 10 years as development is not expected to be delivered before 2026. The Council also considers that further changes to the wording on tall buildings is not merited. The modifications to policy CDH04 “Tall Buildings” reflects the modifications requested for soundness and for general conformity with the London Plan set out in the Inspectors letter. The reference to the pedestrian bridge says it should happen “if possible” and the question of whether it is possible or viable (not the same thing) is a detailed one that should be resolved through the development management process. This also applies to the precise routing of an alternative footway. The Council considers it entirely proper for the Local Plan to signal the Council’s expectations. It expects proposals to respond to the site requirements it sets out in the Local Plan and therefore does not consider that further change is merited. TfL can suggest and justify an alternative through the normal planning application process. This should be dealt with by the accompanying Transport Assessment.

10. Site 47 – MM127 – The Council considers that the existing wording on comprehensive development requires no change and that it is quite clear in terms of site requirements and development guidelines. Mature trees should be preserved. The Council considers retaining the parking reference is entirely appropriate as it signals this as an issue that needs to be addressed and how we want it looked at. The Council really need to make sure that all decisions on parking, the scale of parking given up and likely demand on/for active and sustainable provision are evidence-based. The Council does not oppose a very minor change to :

MM127 – Site requirements and development guidelines:

"The varied surroundings to the site mean that the design and height must be sensitive in terms of intensification; for example, the southern boundary towards the supermarket provides greater scope for building height than towards the low-rise housing to the west."

11. Site 50 – MM130 The Council does not seek any further changes to Site 50. The changes reflect the Inspector’s letter of August 17th 2023 (EXAM143A) which supersedes the Statement of Common Ground with TfL Commercial Development signed off in July 2022. With regards to comments on Site 50 (MM130) the Council would expect transport operations to use the A1 access. Anywhere else it will be getting close to residential properties on Brancaster Drive or Bunns Lane/Rosebery Place. The Council does not consider there are any merits in substituting “amenity” for “living environment”, the latter is much clearer.

12. The Council does not consider the supporting text in para 11.12.6 (MM73) with regards to CPZs to be contradictory. It complements the change to TRC03B in allowing for the use of CPZs where there are unacceptable impacts on local highway conditions. The Council notes that this sentence is repeated at the end of para 11.12.6. It therefore proposes to remove this repetition. With regards to comments on para 11.12.7 the Council considers that this is a sensible and flexible approach towards phased development which is reflective of the Inspectors August 17th letter (para 123) (EXAM143A).

13. Site 55 – MM135 - The Council does not seek any further changes to Site 55..

EXAM 486

Transport for London - Spatial Planning

Main Modification

MM13 – GSS01

MM15 – GSS02

MM16 – GSS03

MM18 - GSS04

MM20 – GSS05

MM22 – GSS06

MM24 – GSS07

MM27 – GSS09

MM29 – GSS11

MM30 – GSS12

MM45 – CDH03

MM58 – CHW02

MM61 – ECY01

MM71 – TRC01

MM72 – TRC02

MM73 – TRC03

MM75 – Chapter 12

MM76 – Chapter 12

MM105 – Site 24

MM108 – Site 27

MM109 – Site 28

MM111 – Site 30

MM114 – Site 33

MM115 – Site 34

MM116 – Site 35

MM119 – Site 39

MM121 – Site 41

MM123 – Site 43

MM124 – Site 44

MM127 – Site 47

MM130 – Site 50

MM133 – Site 53

MM135 – Site 55

MM138 – Site 58

MM141 – Site 61

MM142 – Site 62

MM144 – Site 64

MM147 – Site 67

Council’s Response to Inspectors

Key

Text in bold: new text proposed for addition, compared to submission version

Text within square brackets [ ]: text proposed for removal compared to submission version

The Council welcomes support for MM15, MM16, MM18, MM20, MM22, MM27, MM29, MM30, MM45, MM58, MM61, MM71, MM75, MM76, MM105, MM108, MM109, MM111, MM114, MM115, MM116, MM119, MM121, MM123, MM124, MM127, MM130, MM133, MM135, MM138, MM141, MM142, MM144, MM147.

The Council does not oppose the proposed changes to MM13 GSS01B

"c) An upgraded and enlarged Colindale Underground station providing step free access and enhanced public transport interchange; [New underground station and enhanced public transport interchange at Colindale;]

d) New London Overground passenger rail line - the West London Orbital [Line] together with upgrades to existing stations (Cricklewood and Hendon) and new station at Brent Cross West);

e) New bus stopping and standing arrangements including drivers facilities [in] within and around North Finchley [to allow redevelopment of the] bus station;"
The Council does not oppose the proposed change to MM27 GSS09B and the update to para 4.23.2

"GSS09B - The potential major transport infrastructure upgrades of the West London Orbital (WLO) and Crossrail 2 would provide broad locations for design-led growth in Barnet through developing new stations or upgrading the capacity of existing stations and allowing higher density developments to be achieved or accelerated. Proposals on sites in proximity to these public transport improvements will be expected to deliver a density and quantum of residential units which optimise their potential in accordance with the design-led approach."

"4.23.2 The WLO will deliver a passenger service along existing rail tracks between Hounslow/[Kew Bridge] and Hendon/ West Hampstead Thameslink, passing through Old Oak Common, Neasden, Brent Cross West and Cricklewood. The WLO would have positive impacts through supporting and accelerating [unlocking] housing delivery and [creating] improving access to leisure, community and amenity opportunities along the corridor. Delivery is expected in years 11 to 15 of this Plan"
The Council does not oppose the proposed changes to MM72 TRC02Ac for consistency with GSS01B as follows :

"c) An upgraded and enlarged Colindale Underground station providing step free access and enhanced public transport interchange

d) A new London Overground passenger rail line – the West London Orbital together with upgrades to existing stations (Cricklewood and Hendon) and the new station at Brent Cross West)"
With regards to MM73 (para 11.12.7) the Council considers that this is a sensible and flexible approach towards phased development which is reflective of the Inspectors August 17th letter (para 123) (EXAM143A). The risks highlighted by TfL can be managed through the development management process if/when a s73 application is made – and by appropriate use of conditions and s106 agreements in the original outline application. With regards to comments on MM73 (para 11.12.6) the Council notes the comments from TfL Spatial Planning and the absence of any proposed modification.
With regards to comments on Site 50 (MM130) the Council would expect transport operations to use the A1 access. Anywhere else it will be getting close to residential properties on Brancaster Drive or Bunns Lane/Rosebery Place

EXAM 487

Valda and Mark Pearlman

Main modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 488

Vallabhadas J Sonecha

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 489

Vanita Finn

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

EXAM 490

Varsha Patel

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 491

Vernon Fernandes

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 492

Vivian Ottie

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28 and redevelopment of the Broadwalk Shopping Centre. .

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

EXAM 493

Vivien Lewis

Main Modification

MM20 – GSS05

MM108 - Site 27

MM109 - Site 28

Council’s Response to Inspectors

The Council refers to its response to Save our Edgware with regards to approach to Edgware (Policy GSS05), Site 27 and Site 28 and redevelopment of the Broadwalk Shopping Centre. .

With regards to the Local Plan details of engagement are set out in barnet_draft_local_plan_reg_18_19_consultation_statement_reg_22.pdf

Local Plan Main Modifications: Representor's Q-V

Representations (Representor's name Q - V)

Representations (Representor's name Q)

Representations (Representor's name R)

Representations (Representor's name S - part 1)

Representations (Representor's name S - part 2)

Representations (Representor's name T)

Representations (Representor's name V)

Follow us