Objection to Garrick Industrial Centre planning application
Dear Sir or Madam,
Re Objection to planning application Ref: 17/3350/FUL, North Land of Garrick Estate, Garrick Industrial Centre, Irving Way, London, NW9 6AQ
I am objecting to this application in my capacity as London Assembly Member for Barnet and Camden on a number of grounds relating to Planning, Noise, Air Quality and Light. In addition I have several questions relating to environmental concerns.
Planning concerns
Planning documents show that proposed unit 25 is closest to residential property 178 Colin Gardens, yet the elevation on page 7 shows the closest property to be 2 Colin Drive. This is misleading because 178 will only be 15m from the unit as opposed to the 35m shown in the elevation. The Planning Statement also suggests ‘As set out in the planning committee report to 15/04144/FUL there are sufficient distances between the proposed units and existing residential premises along Colin Drive to ensure that the proposals do not have an adverse impact on existing residential amenity.’ However, the distance between Unit 25 and Colin Gardens is not acceptable.
Design access statement (page 19, 5.1) says ‘Both Unit 25 and 26 are designed so the level of the top does not exceed the roof level of the residential buildings on Colin Drive. This will ensure that the proposed units do not have an overbearing impact on the properties on Colin Drive.’ However, the residential buildings on Colin Gardens are closer to Unit 25 and lower so this proposed unit will be more overbearing for these residents.
The Site Location map suggests that there is room between the two fence lines for parking bays, room for cars to pass, an acoustic barrier and green strip of land. The planning statement adds ‘An acoustic fence is to be incorporated to mitigate against noise disturbance to the residential properties backing on to the site. This will be set approximately 1.6m from the existing fence which is being maintained.’ This cannot all be accurate, as the distances to not add up.
The following wording appears in the design brief on page1 (2.2).
‘The proposed development is partly motivated by Bread’s aspiration to increase their operation further. The Applicant is eager to ensure that The Bread Factory and other existing tenants can grow their business within Garrick Road Industrial Estate rather than needing to relocate further afield. The Applicant and The Bread Factory are in negotiation about leases for the proposed warehouse space.’
Additional support for the idea of the Bread Factory occupancy is found in the Environmental Impact Executive Summary where it says ‘The new development will form the expansion of the existing industrial estate under Use Classes B1/ B2 (food processing) or B8, with associated new car parking and external works.’
The Delivery management plan (Introduction, 1.2) also states ‘It is likely that the two Proposed Units will be occupied by ‘The Bread Factory’ in association with its existing operation on Garrick Road Industrial Estate.’
However the ‘without personal data’ application form states that the ‘activities and processes’ are ‘Unknown at present’ and the operational hours are also ‘Not known’.
If 24 hour or extended hours are going to be proposed in this development it will significantly affect the outcomes for residents and therefore there should be a planning condition attached for no extended hours.
The design access statement (page 11, 2.4) says ‘There is no link between Garrick Road Industrial Estate and the neighbouring residential properties on Colin Drive’; however there are two unsecured gates in the fencing through which people have been observed to be accessing residential properties on Colin Gardens. These gates ought to be secured.
The Environmental statement says ‘The northern part of the Industrial Estate, boarding the specific application site is formed by a landscape strip providing a green buffer for the adjoining residential estate, and made up of a small man made ridge, trees and fences.’ This buffer was a condition of the original application instigated by Barnet Council in January 1980. A decision to reverse this would be totally unacceptable.
Whilst I welcome most of the comments and recommendations provided in the Delivery Management Plan there is no mention of how residents can report concerns and no mention of appropriate sanctions if concerns and issues are not addressed. This could put the burden of responsibility for noise monitoring and reporting with residents rather than management which is unfair and negligent. There is a nominated liaison from The Bread Factory but as the occupants are undecided then it ought to be a nominee from the Garrick Industrial Estate Management.
Noise
The site photographs (page 10, 2.3) show how the current 4m acoustic green barrier helps alleviate residential properties from noise pollution, but the proposal involves removing this barrier (which was guaranteed under a previous Council ruling) and replacing it with a 2.5m high untested barrier. This is unacceptable.
The planning statement (6.12) says ‘In summary this includes the erection of a 2.5m acoustic fence which would be erected along the car park boundary. The acoustic fence would be of a similar height to the existing boundary behind the residential properties and is not considered to be a visually obtrusive feature for residents. However, the current fence is only 2m so this is a 20% increase of ugly solid barrier compared to a green fence with gaps in.
The design access statement (page14, 2.5) says ‘alternative layouts for Unit 26 were tested and it was agreed that the current layout, with direct vehicular access from Wilberforce Road, is preferable. It continues that this proposal will include ‘extending Wilberforce Road to service the proposed units.’ This extension will mean more noise from parked, reversing and moving HGV’s for residents.
Transport
The Delivery Management Plan acknowledges ‘Deliveries associated with both Units will be 24 hours with a large proportion taking place throughout the night.’
The DMP continues to propose that ‘7.1 Staff and drivers of the Bread Factory will not use parking spaces alongside Proposed Unit 25 (as identified in Pink on the enclosed Site Plan) between the hours of 9pm to 7am.’ However, this should also extend to limiting the use of car parking bays along the boundary to the rear of the residential properties from 9pm – 7am. This needs to specifically include Colin Gardens as well as Colin Drive as it affects both. I also don’t believe that the acoustic wall will deliver the reductions in sound from delivery vehicles, service vehicles, staff cars and staff that is suggested when units are within 15m and cars within 5m of neighboring properties.
The transport assessment suggests that: ‘6.2 The unit to be extended at the Estate is currently operational. MB has been advised that the unit employs the following number of staff over the course of a typical weekday: • Morning shift: 15 employees working from 0500 – 1300 hours • Mid shift: 15 employees working 1300 – 2100 hours • Night shift: 15 employees working 1700 – 0100 hours. 6.3 MB has been advised that the extended unit will employ the following additional number of staff over the course of a typical weekday: • Morning shift: 18 employees working from 0600 – 1600 hours • Night shift: 22 employees working 1600 – 0300 hours’
This will mean a total of 85 journeys arriving or leaving during unsocial hours, if every employee were to travel by single occupancy car journeys. This is unreasonable in my opinion. Additionally, this doesn’t include the number of additional journeys completed by delivery trucks which could include ‘articulated lorries up to 16.5 metres long’.
The Full Statement of Conformity (p.5) states that ‘The main sources of noise consisted of road traffic from the surrounding network, and plant from an adjacent site to the west. Considering there are no new developments in the vicinity of the application site that could influence the local noise environment, and as the current operation of the site remains the same, the baseline noise data presented in the previous assessments are considered to remain valid for the Proposed Development.
However, there are now new nearby developments nearby and the increase in traffic (particularly at night-times) will also significantly affect the noise data and implications for new residents.
Air quality
Concerns about disturbing the man-made mound are raised in the Land Contamination report as it may contain ‘A wide range of potential contaminants, depending on the source of material, but may include asbestos, metals, hydrocarbons and polycyclic aromatic hydrocarbons (PAHs). Disturbing this during construction could result in health problems for residents and workers if these materials are present. The report suggest that the dangers of the PRA are assessed as Low-Medium but it also says that the materials are unknown and they have only conducted a ‘walkover’ so it is puzzling how they have come to this rating.
The Planning statement (5.21) says that ‘Policy 7.14 ‘Improving Air Quality’ states that development proposals should include sustainable design and construction measures to reduce emissions from demolition and construction and minimise the increased exposure to existing poor air quality.’ This could be an issue if asbestos or other contaminant materials are found in the landfill of the green mound.
The Planning statement suggests that (6.19) ‘it is relevant to note that as stated within the planning committee report to 15/04144/FUL there are have been no recorded complaints of odour from the existing factories in the GRIE’, but this is known not to be true as I am aware of residents who have done so.
Lighting issues
The Planning Statement recommends that (6.24) ‘Section 4C External Lighting Assessment of Aecom’s Statement of Conformity states that the external lighting assessment remains unchanged from that presented in the 2015 report. Accordingly, the potential impacts of the proposed development are ‘moderate adverse or less’ and could be mitigated through the provision of a Lighting Management Plan which could be secured by way of planning condition’. The planning condition needs to be spelt out in any grant of the application.
Design access statement (page 29, 6.5) says ‘Exterior lighting around the proposed area and car parking areas could be lit to the same level as street lighting except where this would unduly impact on neighbouring residential properties.’ It is not clear which properties the applicants believe will be ‘unduly impacted upon’ or how they propose to alleviate this impact.
Environment
My environmental objections are based on a series of questions:
The green wall proposal (13) for Unit 26 is a fantasy idea being located on a sheltered North facing aspect. There are no details of the type of proposed planting or the maintenance and management proposals. The planning statement (6.29) says ‘The Inspector of Appeals recommends the imposition of a condition that both units should include a green wall for the lifetime of the development the impact of the development would be considerably softened’.
What will happen if the green wall fails or is not managed appropriately?
The Environmental and Sustainability statement quotes Barnet’s Core Strategy (2012) which states that a) ‘Policy CS13 encourages the use of Sustainable Urban Drainage (SUDs) systems (in line with the London Plan drainage hierarchy), reuse and recycling of material resources, living roofs, green spaces and remediation of contaminated land’, and b) ‘Policy CS7: Enhancing and protecting Barnet’s open spaces – the policy aims to ensure that development protects existing site ecology and makes the fullest contributions to enhancing biodiversity, both through on-site measures and by contribution to local biodiversity improvements.’
It appears that this development’s removal of the current green barrier and land strip between residential properties and the new building contradicts these aims.
The Environmental and Sustainability statement (page 17, 3.8) says ‘Based on the above, a number of measures have been recommended by the project ecologist to enhance the site following development. These include:
– Minimal overnight lighting during the construction phase to retain a dark corridor within the Silk Stream for potential otters and foraging bats;
– Remediation and removal of the invasive species close to the site;
– Provision of semi-natural planting, such as new ‘street’ trees;
– Provision of at least three bird boxes specifically designed for species of principal importance and London BAP species;
– Provision of at least five suitably placed bat roosting boxes on or in the new buildings or any retained mature trees.’
It seems unlikely that bats will nest in boxes next to lit, noisy units and the removal of a working natural habitat to be replaced by a substandard, unconnected piecemeal offering appears to be tokenistic at best. Also, the invasive species identified on site have been there for many years and yet the management have shown no interest in tackling them so who should believe that they will coordinate this complex task effectively now?
The Planning statement quotes ‘Policy 7.19 ‘Biodiversity and Access to Nature’ states that proposals directly or indirectly affecting Sites recognised for nature conservation should avoid adverse impact on biodiversity, seek mitigation measures or in exceptional circumstances agree with the Council an appropriate compensation.’ Has appropriate compensation been sought and if so what are the details?
The Tree Survey (page 8) identifies ‘An area of Japanese Knotweed was observed on the site and this is illustrated with red hexagonal hatching in this plan. Japanese Knotweed is a highly invasive weed. If left unchecked, it will rapidly spread across a site displacing native species, and can cause extensive damage to existing and newly built structures. It is essential that any Japanese Knotweed, on and immediately adjacent to a development site, is eradicated before any demolition or construction works take place.’ What are the proposals for delivering on this observation and what is the time frame involved?
Does the planning application recognise the recommended Tree Protection Plan and is it a planning condition as recommended in the Tree Survey (p.32)? The Tree Survey acknowledges ‘The required removal of ‘B’ grade trees can form a substantive reason for an LPA to refuse planning permission for the proposed development because of the loss of public amenity. In order for the removal of these trees to be acceptable to the LPA, the mitigation planting of a number of new trees, of a size, type and location to be agreed with the LPA, will need to be carried out as part of the proposed development’.
What is the agreement that has been reached because the proposed plans appear to show modest trees at best and lack details regarding size and type. The ‘B’ grade trees identified currently on site are tall and provide excellent public amenity as they are.
Conclusion
This application is likely to have a detrimental impact on neighbouring properties in terms of noise, worse environment, light, air quality and transport. In sum, these problems cannot be mitigated against, and therefore I would urge officers to reject this application.
Yours sincerely,
Andrew Dismore
Labour London Assembly Member for Barnet and Camden
City Hall
The Queen’s Walk
London
SE1 2AA
