Response to Local Development Framework consultation (January 2010)

The Council have consulted on their Local Development Framework - Direction of travel document; our response to it follows.

Covering Letter

We have found many positives in this document. We are particularly pleased with the departure from the "one size fits all approach", and that individual solutions will be sought for each of the individual town centres. We believe it is only in this way that there is any hope of engendering any sense of civic pride. We look forward to making a constructive contribution to the eventual strategy for High Barnet.

A general concern which we expressed at the "Issues and Options" stage and again when you came to talk to FORAB is that so much of your vision and strategic objectives expressed in sections 1-6 are dependent on the actions of other stakeholders. Whilst the vision might be laudable we are not convinced that the Council’s strategy for the next 15 years should be so heavily reliant on something over which they have such little control. Surely the Council has to set its objectives according to what it can achieve? An objective might be to encourage TfL to deliver integrated transport but TfL not the Council has to deliver it.

A more specific concern is that section 5 on the challenges to be faced might be seen as a touch one sided. The positive bullet points at the start need to be balanced by the negatives, which are causing difficulties. The rest of section 5 could then be more clearly focused on how the positives might be enhanced and the negatives tackled. The negative bullet points might be

• Shortage of affordable housing
• Areas of deprivation
• Limited entertainment and recreation facilities
• Declining town centres
• Traffic congestion
• Poor east/west public transport facilities.

Most of these points are covered in the later detailed sections of the document. However, we don’t believe that traffic congestion receives the attention that it should; it is a major problem but barely gets a mention. Nor do we think that having lots of green belt and parks is an acceptable substitute for leisure facilities. A misjudged scheme to centralise facilities - artsdepot – is one that we hope will be avoided in the future.

As before we have not sought to comment on every last detail but have expressed a view on those areas which we consider most important We have set out in the enclosed document expressions of support/objection for those core policies and the supporting detail.

Detailed Response

Policy CS1 – Place Shaping Strategy

We are comfortable with the Three Strands approach to the "Place Shaping Strategy" and the principle of major development taking place in the west of the borough where there is so much brownfield land available.

The principle of using development opportunities in the other six nominated District Centres is also not a problem, but we object to New Barnet being one of the chosen six. Five of the chosen six are all clustered together in the north of the borough and they impact on each other. If the available sites in New Barnet are used for major "convenience" shopping it will hit High Barnet, and we would suspect Whetstone, too hard. Waitrose, or whichever supermarket has that shop in The Spires, is our anchor store and we cannot afford to lose it. Grimley’s Floorspace Needs Assessment argued that the capacity for modest "convenience" space in the north end of the borough would all be taken up by either of the current potential developments in New Barnet. If you are to avoid large numbers of residents travelling to a new superstore and deserting their local centres there needs to be modest expansion allowable in each of these nominated centres. New Barnet residents have made very clear that they do not want the superstores. We suggest that the "gasworks site" be reclassified for housing/leisure development. The "Optec" site might still be retail but on a much smaller scale.

CS1 talks of "enhancement" of these six selected centres. We support the notion of enhancement of these centres but looking back at the detail in 7.1.10 it talks about growth without mention of improvement. We would object to these centres just being allowed to grow without improvements to parking, traffic management and the general ambience of the streetscape.

We very much support the notion of enhancement of the historic suburban environment, particularly the areas of special locally distinctive character. You deal with this in more detail in section 9. On page 38 you mention further study of this area. It is not clear whether this will happen before the next draft of this document or some time later. As these are very much local issues we hope there will be further consultation.

Policy CS2 – Distribution of Housing Growth

We support the idea of Chipping Barnet contributing to the 1200 additional homes suggested for the 6 areas in para. 8.1.9. There is capacity around High Barnet for significant infill development. Much of the land behind the shops to the east of the High St is poorly utilised and would benefit from attention.

We object to the wording of para. 8.2.1. This seems to open the way for significant height above commercial premises. If existing RUPs are converted to flats we would be content, but anything higher than 3 storeys will attract strong objections. We have the same concerns about any mixed use new build. The opposition in New Barnet to this sort of scheme demonstrated the strength of public opposition to such schemes. We agree that one or two storeys of commercial or flatted development in limited quantities is acceptable, but high rise flats are out of keeping with the existing low rise environment.

We object to the suggested 544 to594 additional homes suggested for Dollis Valley. This figure can only be achieved by significant high rise. We objected to that when the earlier plans for Dollis Valley were put out for consultation. The north end of Barnet wants family houses not flats, especially not high rise ones. Surely we have to learn from the artsdepot debacle. The flats above artsdepot proved very difficult to sell, and when they were eventually sold to the investor market proved difficult to let. If the New Barnet gasworks site were reclassified to housing/leisure you could offer a planning brief for both that site and DV specifying a large proportion of small houses and still meet the housing target. In para. 4.6.1. you recognise a problem in Underhill with the exceptional number of people who feel unsafe. Might this be to do with the lack of any facilities on the DV estate, so the only people on the streets are young people hanging around with nothing to do? Maybe the eventual revised planning brief needs to specify a leisure element?

Policy CS3 - Protecting and enhancing Barnet’s character

We support your sentiments in para. 9.2.2. about front-garden parking. This detracts from quality streetscapes, and seems to grow like a snowball. When one is approved many more apply. The resulting breaks in available kerb space mean that overall thee is less parking available in the street. Apart from the practicality of reducing overall parking space the visual effect is very unpleasant. Look at the residential streets either side of Golders Green Road.

This policy statement seems to be at odds with the Council’s current practice. Highways recently abandoned the reference to a requirement for landscaping in the guidance notes on crossovers, and we are left in no doubt that Highways actually favours crossovers as they believe that getting cars off the road has positive benefits. Not necessarily so, of course, and there is no sensitivity to the impact on the streetscape. We look forward to the "next level down" documents on the issues raised in this section.

Policy CS4 - Promoting Barnet’s town centres

We support the principles of policy CS4 as articulated on p49, but have problems with some of the earlier detail.

In para 10.1.2 we fear that "intensification" might not just be commercial but flats above The Spires shopping centre higher than two storeys.
Para. 10.2.4 does not include the leakage of shoppers to Potters Bar and London Colney, and we know from our own survey that it happens.
In Table 3 you suggest that North Finchley could become a Major Centre. With that road network to deal with it would probably never happen, but if it did what do you think would happen to all the other district town centres up in the north end of the borough, particularly Finchley Church End and Whetstone? Leave it as a good district centre.
Happy enough with 10.6.3 but think it should include examination of what each town centre might have that is valued/prized by its local community. High Barnet’s example is The Bull theatre. We understand that the Council might not have the sort of money necessary to complete the renovations started by the current tenant, but a long lease would enable the tenant to secure funding from other sources. The evening activities at The Bull are helping to keep teenagers of the street, and we are short of alternative leisure facilities for them.
Pleased that you are addressing the "balance" of parking but very sorry that you seem to have lost the notion of shopper (affordable, short term) parking in the centre with commuters pushed slightly further out. We were very positive about that at the Issues and Options stage.
The commitment to markets at 10.10.1 is valued but 10.6.2 seems to offer the Chipping Barnet market site as an opportunity for comparison shopping. Can the para make clear that this is based on the assumption that the market is rehoused elsewhere within the town centre or within the potential Spires expansion?

Policy CS6 - Promoting a strong and prosperous Barnet

Support this as drafted.

Policy CS7 - Providing quality homes and housing choice in Barnet

We broadly support this as stated in the "blue box" but have difficulty with a lot of the supporting detail.

The policy statement opens with the notion of providing choice, but all the detail militates against this. Young people like to settle in Barnet to raise their families and they make very clear that they want houses with gardens albeit small ones. The figures in 13.2.2 do indicate large numbers of 2 bed units, but people want small terrace houses/cluster homes not flats. Young people without families will drift to flats in inner, more lively, suburbs not Barnet.

There is no indication that the calculation of space requirement takes account of the increasing number of homeworkers who need space to designate as office. For example there are three in our street of just 41 properties. What about single adults who might need to provide space at weekends for children from a previous relationship? We also believe the demand for spacious homes is a fact of life in an affluent area and needs to be recognised rather than ignored or contested. There is space for larger homes on development sites well away from the town centres. We think the model you are using is just too prescriptive.

Policy CS8 - Providing integrated and efficient travel

We support the statement in 14.3.4 that parking provision across the borough will vary according to local circumstances. We also accept that provision might need to be more restrictive as infrastructure develops and maybe people’s needs and habits change.

The notion to link town centres (stations/employment centres too please!) with express buses seems a very positive step towards reducing rush hour congestion and pollution; in High Barnet our two major employers have significant data on where their employees come from and how they travel.

Our concerns are that a prescriptive regime might be implemented before the facilities are there.

It would be great if commuters would all arrive on trains/buses but until the network improves we have to accommodate them. Maybe we will need less space for shoppers when people buy everything online but we are not there yet and must develop a parking regime that supports the existing town centres – hence our disappointment expressed earlier that the notion of shopper parking in the centre with commuter parking on the outskirts seems to have been lost. We believe each town centre strategy should examine the spaces available for these options with a view also to maintaining Council revenue.

The document does not specifically mention integration of bus/tube networks so that transfer is easier. In some areas the long hike from the tube to the nearest bus stop is prohibitive

There is insufficient recognition that the job is not just about cutting back on car travel where possible, but in managing the flow of it. There should be a policy statement here which commits to an examination of traffic flows and destinations so that each town centre strategy addresses the problem.