A Spectre is Haunting Willesden - More Zombie Planning

 

You may have noticed some big signs springing up which ask "What will Brent look like in the future?" Other than the slightly spooky figures on the poster which might lead you to answer "free-from ghosts, hopefully", there are some important responses needed to this question.

The council is consulting on its new Development Management Plan (DMP) which will guide its planning decisions in the future. This is the first time in over 10 years that the plan is being revised so whatever is decided now is likely to shape Brent planning for some considerable time.

The plan contains a number proposals relating to housing provision and the makeup of our high streets. Of particular interest to us as Willesden Green residents is the section on protection of community facilities. Many of us who have been involved in the Save The Queensbury group have been lobbying for over 18 months for the council to adopt a specific pub protection policy so it is a hugely disappointing blow to see that the council has failed to include this within the draft DMP. Yet again, there has been lip-service which is not backed up by proper action on policies. There is one passing mention of pubs as a part of social infrastructure that should be protected, but given that many other local authorities are recognising the role that pubs play in communities and have adopted very detailed pub protection policies, it seems like a huge missed opportunity that Brent hasn't done the same.

The draft DMP can be be found here http://www.brent.gov.uk/dmp and you are encouraged to respond either by completing the online comment form or by emailing  ldf@brent.gov.uk before 5pm on 31st July.

Points you might like to raise are:

• The purpose of a policy is to give proper consideration where (for example) a developer claims a pub is not viable or not needed. A pub protection policy would have established the value of The Queensbury and its building early on on the planning process, saving the planning department a lot of work and residents of Willesden Green a lot of distress.
  
• Tagging "public houses" on the end of a list of buildings deemed to be community infrastructure  is an ineffective and insufficient substitute for a dedicated pub protection policy. Brent should follow the example of local authorities in Lewisham, Kensington & Chelsea and Cambridge, among others, in adopting a detailed pub protection policy. As part of the policy, these local authorities maintain either a formal register or an informal list of all the pubs within their area.
• Under the new draft DMP, it is highly likely that planning officers would have reached the same conclusion as they did in March 2014, recommending  demolition of The Queensbury.
• The consultation reads that "in keeping with the NPPF, public houses are classed as social infrastructure and proposals which would result in their loss will be subject to this policy and town centre policy DMP 3 ‘Neighbourhood Centres and Isolated Shop Units" However the latter policy makes absolutely no reference to pubs. Hence this will be easily evaded at planning decision and appeal stage.
• The draft DMP does not propose any additional protection for buildings which are listed as Assets of Community Value under the Localism Act. ACV-listed buildings should be protected from applications for Change of Use. The process for an ACV listing already requires a very high bar so the fact of it being worth preservation should not be in question. Although ACV regulations are not primarily planning regulations, it should be noted that 2.20 of the DCLG guidance on ACVs states:
  https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/14880/Community_Right_to_Bid_-_Non-statutory_advice_note_for_local_authorities.pdf  "However the fact that the site is listed may affect planning decisions - it is open to the Local Planning Authority to decide whether listing as an asset of community value is a material consideration if an application for change of use is submitted, considering all the circumstances of the case."  This means that ACV listing can be used as a material planning consideration if desired – it is up to Brent to be bold enough to say that they will give these assets real protection and make the ACV status recognised and valued within the DMP.
• A Pub Protection Policy is not specifically for heritage or rural pubs – CAMRA's model policy covers both rural and urban pubs. Brent has a number of significant historic pubs, some of which are locally listed by Brent for heritage reasons. It has been requested several times that The Queensbury be assessed to be placed on the local list of heritage buildings yet to date this has not happened.
• More weight should be given to the preservation of the characteristics of conservation areas within the DMP. The current policy states that a building in a conservation area cannot be demolished unless it is thought to be actively detracting from the the look of the conservation area. Nobody could argue this is of the current Queensbury building, yet Brent planning officers chose to ignore it when they recommended demolition. The policy should therefore be given more emphasis in order that it is not easily over-ridden.

Aside from the important Queensbury issue the draft DMP is also an opportunity to input on the number of payday lenders/chicken shops/shisha bars on high streets, the height of new developments and the amount of affordable housing that's available. It is an important document, so do be sure to have your say.