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Appendix B: Non-technical Summary to the Sustainability Appraisal
London Borough of Brent’s Local Plan
Development Management Policies Development Plan Document
Non-Technical summary
Prepared by London Borough of Brent
November 2016
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1.0 Introduction
1.1 The Brent Local Plan comprises of a suite of Development Plan Documents
(DPDs), which taken together provide the framework and policies for the Borough
in all aspects of land use and spatial planning. The DPDs produced by Brent Council
include a Core Strategy (adopted 2010), Site Specific Allocations (adopted 2011),
Wembley Area Action Plan and Joint West London Waste Plan (both adopted 2015).
The council is now taking forward a Development Management Policies (DMP) DPD,
which sets out detailed decision making policies. Once adopted it will complete
Brent’s Local Plan and will replace remaining saved UDP policies.
1.2 The purpose of Sustainability Appraisal (SA) is to promote sustainable development
through better integration of sustainability considerations into the preparation and
adoption of plans. The SA considers the implications of the DMP, from a social,
economic and environmental perspective, by assessing options and the draft DPD
against available baseline data and sustainability objectives.
1.3 The SA Report is also to ensure compliance with the Planning and Compulsory
Purchase Act 2004, which requires an SA to be undertaken on all DPDs and a
report to be prepared. Furthermore, the SA Report incorporates the requirements for
an Environmental Report under the Strategic Environmental Assessment
Regulations.
2.0 SA Framework
2.1 Part B of the SA Report provides the sustainability context based on a review of
existing baseline data, plans, programmes and sustainability objectives. It establishes
the SA framework to be used in the appraisal process. Table 1 provides a brief
summary of the key baseline issues, whilst table 2 presents the SA framework.
Table 1: Summary of key sustainability issues
Issue Summary and source of evidence
Social
1. Deprivation,
exclusion and
inequalities. Brent
contains some of most
deprived wards in
London.
Brent is now ranked 35th most deprived Local Authority in
England (IMD 2010), declining 18 places since the IMD 2007 were published. Brent now ranks as the 11th most deprived borough in London.
There is a disparity in deprivation across the Borough, with higher levels in central and southern wards.
2. Disparity in social
and economic
conditions both between
wards within Brent and
with other areas.
Average gross weekly earnings for workers within Brent remains lower than the London average.
There is a wide variation in average income within Brent, with lower income level in the south of the borough.
3. Health inequalities The health of people in Brent is varied compared with
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and access to health
facilities.
the England average.
Life expectancy for both men and women is higher than the England average. However, life expectancy is 8.8 years lower for men in the most deprived areas of Brent than in the least deprived areas.
4. Education attainment and projected shortfall of school places.
Whilst primary and secondary school attainment is comparable with national averages, NVQ equivalent qualifications among working age residents remains below national and regional averages.
The Brent Schools Organisational Plan predicts a shortfall in school places in the Borough and in adjacent boroughs.
There are educational attainment inequalities within the Borough.
5. Poor housing conditions, lack of affordable housing and overcrowding, particularly in southern wards.
Brent has one of the highest ratios of house prices to average incomes in the country, and since 1997 average hourly earnings have risen by 12.9% while house prices have increased by 65%. (Brent Regeneration Strategy, 2001-2021).
6. High incidence of crime and fear of crime.
Other than sexual offences, all crime rates are above the national average within Brent. Violent crimes, robbery and burglary are particularly high (Crime Statistics for England and Wales www.crimestatistics.org.uk).
7. Provision of and access to essential services and amenities.
Access to services is a key issue, particularly for those on low incomes or living in deprived areas.
Public transport accessibility is a factor in accessing services. Brent is generally very well connected and has a number of underground, rail and bus links within and beyond its boundaries. However, there are areas of the Borough with poor public transport accessibility, showing that significant areas remain deficient.
Environmental 8. Mixed quality of the built environment and the need for improved architectural design quality.
Townscape quality varies across Brent. Brent has one Grade I listed buildings, six listed Grade II*,and around 200 Grade II. This is lower than many London boroughs, which highlights the importance of protecting such sites.
In contrast there are a number of areas within the Borough considered to be of low townscape quality.
9. Pressure on biodiversity and habitats and lack of
Biodiversity is recognised as a key issue for the Borough through the development of a Local Biodiversity Action Plan, which seeks to protect and enhance both critical
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green space, particularly in southern wards.
habitats and species, as well as create new habitats. Brent should also aim to restore and enhance degraded habitats in the borough.
10. Critical need to minimise waste arisings and deal with waste locally and in a sustainable manner.
Brent’s waste management performance is comparable with the figures for London. However, existing national waste management targets legislation mean managing waste in a sustainable manner is a critical issue for the Borough.
11. Contaminated land and soils present a potentially significant restriction / cost in developing brownfield / derelict sites.
Approximately a quarter of the land of Brent is potentially contaminated, based on historic use. (Brent Contaminated Land Database)
12. Water quality and pollution are key issues for the watercourses running through Brent.
The Water Framework Directive commits all member states to achieving ‘good status’ fro all water bodies. In the Brent Riverside catchment Grand Union Canal, Lower River Brent and Wealdstone Brook are not achieving good status.
The Thames River Basin Management Plan identifies Brent should also aim to restore and enhance degraded habitats in the Borough, including heavily modified water bodies.
13. Availability of water resources to meet current and future demand.
Sufficient water resources to accommodate current and future needs with a growing population and increasing demand is an issue not only for Brent, but for London and the South East as a whole (as identified by the Environment Agency, water companies and the Greater London Authority).This will be an increasingly important issue given the impacts of climate change.
Reducing leakage, managing demand and the possible development of new strategic water resource developments are some of the measures being undertaken to try to address this problem.
14. Flooding and flood risks particularly in relation to the Welsh Harp Reservoir and River Brent.
Localised surface water flooding is an issue in the Borough particular at times of increased run-off.
The LB Brent SFRA identifies four problem areas / issues for river flooding: Welsh Harp, River Brent, Wealdstone.
15. Quality of and access to open spaces and parks, including open air sport grounds.
Approximately 40% of Brent residents live in open space deficient areas.
With competing land pressures, securing significant areas of open space will be challenging. However,
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Brent’s growth areas present an opportunity to secure new open space.
Given levels of open space deficiency private amenity space is of particular importance in the Borough.
16. The need to preserve and enhance built heritage and the historic and archaeological environment against the pressures of redevelopment.
There are 22 Conservation Areas in Brent.
The Borough has a wide range of architectural styles from the simple to the ornate, from Victorian ltalianate and Gothic Revival to Suburban 'Arts & Crafts' and planned "village" settlements. Such a diverse heritage is an essential part of the character of the Borough.
17. Energy use, energy efficiency and renewable energy, and CO2 emissions.
Data sets on domestic energy efficiency in the Borough are not available. However, efficiency is a key element in issues such as fuel poverty and health, and reducing contributions to climate change is a key commitment.
Per capita domestic CO2 emissions are similar to
London and National averages. Road transport is a major source of CO2 emissions in the borough.
18. Poor air quality along major roads and in the south of Brent, with much of southern Brent an AQMA.
For example Neasden Lane is the most polluted area in London for PM10 Particulate.
19. Noise nuisance, both from domestic and industrial sources as well as from noise and vibration from major road routes in the Borough.
London Noise Mapping service shows that all major roads in the Borough are a source of severe localised noise pollution.
Economic
20. Unemployment and job opportunities for local people.
The unemployment rate in Brent is slightly above that of London. The workforce within the borough is slightly less qualified than the London average.
Barriers to work identified include insufficient quantity of jobs, the need for childcare, not enough well paid jobs and lack of skills or qualifications. (Source: MORI)
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21. Poor transport infrastructure and ease of movement particularly given relatively low levels of car ownership.
Although the Borough is generally well served by public transport it is also characterised by issues of poor interchange, particularly in key regeneration areas such as Park Royal, Wembley and Harlesden.
The regeneration of some areas may be hindered unless the public transport infrastructure can be upgraded to cope with planned development and local residents are able to travel to work using alternatives to the private car.
22. The conflict between opposing land uses, in particular balancing housing needs with the protection of employment land and open space.
Land use pressures and conflicts were identified as a key issue by a workshop of council officers and other local stakeholders.
23. The need to manage redevelopment impacts in specific areas. Especially Wembley and Park Royal.
Wembley and Park Royal are two key regeneration areas in the Borough and whilst realising their regeneration objectives it will also be important to ensure the adverse impacts are avoided or at least mitigated.
24. The need to support development in existing centres and ensure the health of town-centres.
The councils ‘Health Check’ and other evidence suggest that Brent’s shopping centres has declined during the recession in terms of vacancy levels, but are now returning to pre-recession levels.
2.2 Whilst Brent does face some key sustainability issues, it also offers some key
opportunities including: very good public transport links, especially with Central
London; its cultural diversity, it is the second most ethnically diverse local authority in
the country and over 120 languages are spoken in the Borough; and several major
regeneration areas.
Table 2: Sustainability objectives and criteria
Objective Criteria
Social
Prosperity and Social Inclusion S1. To reduce poverty and social exclusion
Will it reduce poverty and social exclusion in those
areas most affected? Will it improve affordability of essential services?
Health S2. To improve the health of the population
Will it improve access to high quality health facilities?
Will it encourage healthy lifestyles and provide opportunities for sport and recreation?
Will it reduce health inequalities?
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Will it reduce death rates? Education and Skills
S3. To improve the education and skills of the population
Will it improve qualifications and skills of the population?
Will it improve access to high quality educational facilities?
Will it help fill key skill gaps?
Housing S4. To provide everybody with the opportunity to live in a
decent home
Will it increase access to good quality and affordable
housing? Will it encourage mixed use and range of housing tenure?
Will it reduce the number of unfit homes?
Will it reduce homelessness? Quality of surroundings
S5. To provide everybody with good quality surroundings
Will it improve the satisfaction of people with their neighbourhoods as places to live; encouraging ‘ownership’? Will it improve residential amenity and sense of place?
Will it reduce actual noise levels?
Will it reduce noise concerns? Crime Prevention and & Community Safety
S6. To reduce crime and anti-social activity
Will it reduce actual levels of crime?
Will it reduce the fear of crime?
Community Identity S7. To encourage a sense of community;
identity and welfare
Will it encourage engagement in community activities?
Will it foster a sense of pride in area?
Will it increase the ability of people to influence decisions?
Will it improve ethnic relations?
Will it encourage communications between different communities in order to improve understanding of different
needs and concerns? Will it encourage people to respect and value their contribution to society?
Accessibility Will it improve accessibility to key local services?
S8. To improve accessibility to key services especially for those most in
need
Will it improve the level of investment in key community services?
Will it make access more affordable?
Will it make access easier for those without access to a car? Environmental
Traffic EN1. To reduce the effect of traffic on the environment
Will it reduce traffic volumes?
Will it increase the proportion of journeys using modes other than the car?
Will it encourage walking or cycling? Water Quality & Resources
EN2. To improve water quality; conserve water resources and provide
for sustainable sources of water supply
Will it improve the quality of inland water?
Will it reduce water consumption?
Air Quality EN3. To improve air quality
Will it improve air quality?
Will it help achieve the objectives of the Air Quality
Management Plan? Will it reduce emissions of key pollutants?
Biodiversity EN4. To conserve and enhance
biodiversity
Will it conserve and enhance habitats of borough or local importance and create habitats in areas of deficiency? Will it conserve and enhance species diversity; and in particular avoid harm to protected species?
Will it maintain and enhance sites designated for their nature conservation interest?
Will it maintain and enhance woodland cover and management? Will it encourage protection of and increase number of trees?
Landscape & Townscape Will it improve the landscape and ecological
quality and character of open spaces?
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EN5. To maintain and enhance the character and quality of landscapes and townscapes
Will it enhance the quality of priority areas for townscape and public realm enhancements?
Will it maintain and strengthen local distinctiveness and sense of place?
Will it minimise visual intrusion and protect views?
Will it decrease litter in urban areas and open spaces? Historic Environment & Cultural Assets
EN6. To conserve and, where appropriate, enhance the historic environment and cultural assets
Will it protect and enhance Conservation Areas and other sites, features and areas of historical and cultural value?
Will it protect listed buildings?
Will it help preserve, enhance and record archaeological features and their settings?
Climate Change EN7. To reduce contributions to climate change and reduce
vulnerability to climate change
Will it reduce emissions of greenhouse gases by reducing energy consumption?
Will it lead to an increased proportion of energy needs being met from renewable sources?
Will it reduce emissions of ozone depleting substances?
Will it minimise the risk of flooding from rivers and watercourses to people and property?
Will it reduce the risk of damage to property from storm events? Waste Management
EN8. To minimise the production of waste and use of non-renewable
materials
Will it lead to reduced consumption of materials and resources? Will it reduce household waste?
Will it increase waste recovery and recycling?
Will it reduce hazardous waste?
Will it reduce waste in the construction industry? Land and Soil Will it minimise development on greenfield sites?
EN9. To conserve and enhance land
quality and soil resources
Will it ensure that, where possible, new development
occurs on derelict; vacant and underused previously developed land and buildings? Will it ensure land is remediated as appropriate?
Will it minimise the loss of soils to development?
Will it maintain and enhance soil quality?
Will it reduce the risk of subsidence?
Economic
Growth EC1. To encourage sustainable
economic growth
Will it encourage new business start-ups and opportunities for local people?
Will it improve business development and enhance productivity? Will it improve the resilience of business and the local
economy? Will it promote growth in key sectors?
Will it promote growth in key clusters?
Will it enhance the image of the area as a business location? Employment
EC2. To offer everybody the opportunity for rewarding and satisfying employment
Will it reduce short and long-term local unemployment?
Will it provide job opportunities for those most in need of employment?
Will it help to reduce long hours worked?
Will it help to improve earnings? Regeneration
EC3. To reduce disparities in
economic performance and promote sustainable regeneration
Will it promote regeneration, reducing disparity with surrounding areas?
Investment EC4. To encourage and accommodate both indigenous and inward investment
Will it encourage indigenous business?
Will it encourage inward investment?
Will it make land and property available for business development?
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Efficient Movement EC5. To encourage efficient patterns of movement in support of economic growth
Will it reduce commuting?
Will it improve accessibility to work by public transport; walking and cycling?
Will it reduce journey times between key employment areas and key transport interchanges?
Will it facilitate efficiency in freight distribution?
3.0 Appraisal of the alternative options
3.1 The preparation of the Submission DMP has been informed by an appraisal of
alternative options for a range of policy issues. Alternative assessment findings are
presented in full within the SA. Notable alternatives considered include:
3.2 Housing – not to control the loss of housing. This alternative was not supported from
a sustainability perspective as it would further exacerbate the existing demand/
supply gap, resulting in negative social and economic impacts.
3.3 Housing – not to specifically distinguish between Social/Affordable Rented and
Intermediate housing need. It was considered this approach would fail to properly
address Brent's priority housing needs and would be contrary to London Plan
requirements. The preferred policy to distinguish between the two was considered to
be very positive from a sustainability perspective in seeking to address a critical
sustainability issue in the borough.
3.4 Employment - to allow the redevelopment of Local Employment Areas for residential
development without asking for a demonstration of demand nor requiring the
provision of new workspace that is fit for modern operational standards. The effect of
this approach would be the widespread loss of opportunities to develop small
workspaces for which the Council is satisfied there is demand. This would result in a
loss of local employment opportunities and limit business development. The preferred
option of a managed approach to the release of local employment sites was
supported from a sustainability perspective.
3.5 Town Centres – Alternative options considered included to allow non-retail uses to
occur in town centre locations regardless of the frontage designations. The preferred
policy options presented for these uses are supported from a sustainability
perspective, and are likely to offer protection and promotion to the vitality of existing
centres.
4.0 Appraisal of the preferred approach
4.1 Part B of the SA Report presents an appraisal of the draft Plan under the SA framework. A summary of appraisal findings are presented in table 3 below, with each row covering a specific chapter of the Plan.
Table 3: Summary of appraisal findings
Town Centres
Town centre policies in the plan have a number of positive effects in that they promote
vibrant town centres and employment opportunities. Where local businesses are able to
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thrive and more people are able to work close to home, or in the borough, community
identity, pride and wellbeing can be improved. Crime may also be reduced where
centres become more vibrant, perhaps especially due to the protection of existing retail
space in town centres.
Visitor Accommodation and Attractions policies are particularly predicted to promote
employment opportunities and investment in Brent’s economy. Promoting and protecting
local markets may also lead to the regeneration of certain areas, and can help in the
establishment of new retail businesses.
In addition policy on non-retail uses has potentially positive impacts in terms of promoting
healthy lifestyles, by preventing an overconcentration of hot food takeaways in town
centres, and limiting the proximity of takeaways and shisha cafes to schools.
Built Environment
The key potentially positive effects of the Built Environment policies are enhanced quality of
public realm, townscape and landscapes, together with protection and promotion of
environmental quality and biodiversity in the context of new development. These
enhancements are expected to have beneficial effects on a number of social factors, in
particular aiding the reduction of crime and anti-social activity, and promoting local
community identity and welfare. Minor positive effects are also predicted for improved
health, as design for safer and ‘clearer’ urban spaces can increase physical activity
through walking and cycling, as well as having positive effects on wellbeing.
Policy DMP 7 is expected to have significant positive effects on the protection and
enhancement of the historic environment, by offering a high level of protection for listed
buildings and conservation areas.
The above noted positive effects are predicted to, indirectly create an urban environment
and built fabric which encourages communities in which people will choose to live and
work. This in the medium to long-term is predicted to have positive effects on the economic
health of the borough.
No negative effects are expected arising from the Built Environment policies. This reflects
the nature of these policies, which seek to set specific criteria to help implement the higher
level policies set out in the Core Strategy.
Open Space and Sustainability
The number of sustainability policies has been reduced significantly in the publication
version of the DMP, as many of these policies duplicated Core Strategy policy and policies
contained within the London Plan. As these policies are covered in strategic policy the
deletion will not result in negative sustainability impacts. Open Space policies have also
been consolidated. The key potentially positive effects remain:
Protection of open space within the borough, and the provision of additional
open space. Through this biodiversity and habitat are also offered
protection. Specific positive effects are predicted due to the protection of
the blue ribbon network, requirements for development to provide sufficient
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open space and protect existing, and the control of types of development on
or near open spaces.
Preventing harm to protected areas, such as SINCs, Local Nature
Reserves and SSSIs.
By protecting and enhancing various aspects of open and green-space in the
borough these policies are also expected to have positive social effects. In
particular, beneficial health effects, the provision of good quality
surroundings and promoting community identity and welfare.
Encouragement of renewable energy and energy efficiency measures,
contributing towards reduced contributions to climate change, and the
strengthening of adaptive capacity.
Possible mixed effects are predicted in relation to economic objectives, although these
effects are ‘uncertain’, given the complex trade-offs and interactions. While a good quality
environment, with sufficient open space and healthy habitats and biodiversity will improve
quality of life in the borough and enhance its image as a place to live and work, some could
see environmental protection as having the effect of constraining certain types of growth.
From a sustainability perspective, these trade-offs are important, and the social and
environmental benefits are felt to more than outweigh any perceived constraints to economic
growth.
One minor negative effect is predicted, relating to the possibility of air pollution arising from
some forms of decentralised energy, and on-site micro-generation though it is noted as an
‘uncertain’ effect, given that the effect will be managed by policy elsewhere.
Environmental Protection
Similarly to the Open Space and Sustainability chapter, the Environmental Protection
chapter policy does not duplicate policy at a regional and national level. However, existing
policy is highlighted in the chapter and local validation requirements highlighted. Alongside
existing policy the key potentially positive effects of the Environmental Protection policies
are:
Prevention of negative impacts, providing protection for air and water
quality, and in the case of new developments, enhancement. Control of
internal air quality and natural ventilation are expected to have positive social
effects. Notably improved health, and helping to reduce fuel poverty.
The managed enhancement of soil and land quality, particularly in relation
to existing / historic sites of contaminated land.
Helping to reduce vulnerability to climate change, by planning with
flooding in mind.
The environmental benefits predicted are indirectly expected to have positive
social and economic effects, in particular improving health and providing
good quality, durable surroundings, as well as encouraging long-term
economic viability through helping to provide an attractive living and
working environment and reducing vulnerability to the impacts of climate
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change.
No significant negative effects are expected from the Environmental Protection policies.
Employment
In the Employment policies emphasis on the protection of local employment areas, and the provision of an appropriate mix of flexible work-spaces, such as work-live, is likely to protect local employment and provide additional employment opportunities in the local area.
Where local businesses are able to thrive and more people are able to work close to home, or in the borough, community identity, pride and wellbeing can be improved.
By protecting local employment, and providing facilities for employees near to work, some travel need can be reduced to employment elsewhere, and during the working day. This, in turn may have positive environmental effects, reducing traffic related air-pollution, and helping to mitigate for climate change. Supporting local and new businesses will also bring about economic development benefit for the borough.
There are no potentially negative sustainability effects predicted to arise from the Employment policies, beyond the localised environmental and amenity impacts of the provision of new facilities.
Transportation
The policies perform very well against the sustainability objectives, with a large number of
positive effects predicted, and no negative effects. Many of the positive effects relate to
reducing dependence on the private car by reducing the need to travel and by promoting
walking, cycling and public transport as viable alternative modes. Minor positive scores
have been assigned rather than major positive due to the likely scale of these effects,
reflecting the fact that these policies are somewhat limited by relating to new development
only.
The key potentially positive sustainability effects arising from the Transportation policies are:
Requiring transport assessments seeking to ensure that new developments
provide and support affordable and accessible public transport, as well as
providing sensible and practical walking and cycling routes and infrastructure,
is likely to have positive social effects, particularly improving accessibility,
but also helping to reduce social exclusion, reducing crime (through
passive surveillance) and improving health. Social and community
wellbeing and quality of life are also likely to be improved.
Where higher levels of public transport use, and walking and cycling are
achieved, and car trips reduced environmental benefits are also possible,
notably, improved air quality, noise, and mitigating the effects of climate
change.
Reducing congestion, providing efficient and accessibly public transport and
the improvements to the physical and social environment likely due to
reducing the need to travel are also expected to have positive economic
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effects, improving the long-term viability of the local economy. These
factors are also likely to play an important role in promoting regeneration.
No negative effects are predicted. As a result there are no specific recommendations for
mitigation and enhancement in relation to these policies.
Housing
Broadly, the Housing policies are expected to have positive effects across the social and
economic sustainability objectives, with mixed effects being predicted against some
environmental objectives due to in particular to the probable generation of traffic (and
associated impacts) in specific locations due to new large-scale developments, even where
these effects are limited by policy – hence mixed effects are predicted.
Potential positive effects of the Housing policies are:
Clearly the strongest effect of the Housing policies is to help provide
everyone with the opportunity to live in a decent home . In particular
these policies provide strong protection for existing housing, especially
affordable housing, and seek to meet the borough’s particular needs for both
affordable and family housing, by providing an appropriate mix of tenure and
size.
By helping provide decent homes for all, and ensuring sufficient supply of
affordable homes, these policies are also expected to have other positive
social impacts, such as reducing certain aspects of poverty and social
exclusion, and helping improve health. By imposing controls on the way in
which new housing developments are realised, these policies are also likely
to help to strengthen communities.
By setting out requirements for Accommodation with Shared Facilities,
Specialist and Supported Accommodation to be located in proximity to public
transport and amenities, these policies are likely to have a beneficial effect by
helping to reduce the need to travel, and thus minimising the impact of
traffic on the environment.
A sufficient and appropriate supply of housing is also likely, particularly in the
long-term, to support the local economy by making Brent an attractive
place to live and work, and providing a stable socio-economic basis for local
businesses.
Mixed effects are predicted for the effect of traffic on the environment, air-quality and
possible climate change contributions. Although there is much that is positive in these
policies, and they recognises the potential impacts these sorts of development could have
on the environment, particularly through traffic generation, it seems probable that some
negative impacts will occur even where all effort is made to minimise them.
Social Infrastructure
Potentially positive sustainability effects arising from the Social Infrastructure policies
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include:
Protecting and enhancing community facilities which are a fundamental
support mechanism for those most deprived and excluded access.
Improved community facilities in deprived neighbourhoods are likely to improve
community identity and welfare and may bring other benefits such as
reducing crime and anti-social activity.
Where local facilities are protected and new facilities developed there may be
reduced trips generated to access facilities elsewhere.
Employment generation from new education, health, public houses and other
community facilities.
There are no potentially negative sustainability effects predicted to arise from the Social
Infrastructure policies, beyond the localised environmental and amenity impacts of the
provision of new facilities.
5.0 Appraisal of the Main Modifications
5.1 The SA Report was submitted to the Secretary of State as part of the evidence base
for the Development Management Policies in January 2016. The Secretary of State
appointed an independent Inspector, Katie Child BSc (HONS) MA MRTPI, to conduct
the examination. The Examination Hearing Sessions took place between Tuesday 3
May and Wednesday 4 May 2016. Having taken account of all representations, both
in writing and at the Hearing, the Inspector advised the council to consult on main
modifications resulting in changes to policy wording. In advance of the consultation
an assessment of the main modifications was undertaken.
5.2 In summary, the assessment found no significant negative impacts for any of
the main modifications against the SA objectives. In the main the modifications
provide clarity and consistency, but do not fundamentally alter the overarching
objectives of the policies.
5.3 The Inspector’s report concluded that the DMP are sound subject to main
modifications. Accordingly, the London Borough of Brent adopted the DMP on the
21st November 2016.
6.0 Conclusions and monitoring
6.1 The DMP seek to provide the detailed implementation and control criteria to ensure
that the strategic policies set out in the Core Strategy are delivered effectively, in line
with the Core Strategy objectives. As a result the overall effects of DMP are in the
case of many sustainability objectives less pronounced than was the case with the
draft Core Strategy policies. This reflects the more focussed and specific nature of
the Development Management Policies.
6.2 Overall the policies are predicted to have positive effects. The policies score almost
exclusively positively against the social and economic objectives, however there are
some mixed effects predicted in relation to some environmental objectives.
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6.3 Overall positive social effects are predicted to include improvements to: poverty and
social inclusion, the provision, protection and access to community services and
amenities, the affordability of housing as well as the quality and adaptability of design
in new development and the provision of infrastructure for public transport, walking
and cycling.
6.4 Overall positive environmental effects are expected to include: improvements to the
public realm and the quality of townscapes and landscapes, protection and
enhancement of open spaces, parks and habitats, standards of design for all types of
development (improving visual amenity, as well as functionality), and where
infrastructure is effectively developed, positive effects due to increased walking and
cycling.
6.5 Positive economic effects are predicted to be largely indirect, however they include:
the development of attractive and vibrant communities in which people will chose to
live and work, provision of facilities and amenities for employees as well as for
business which may chose to locate to the borough, flexibility in work-space
availability including facilities for start-ups and work-live development. Improvements
to public transport and walking / cycling infrastructure are also predicted to have
positive economic effects.
6.6 While there are no specific negative effects, some overall effects may be somewhat
mixed due to cumulative effects. Notably, the increase in development implied by the
policies, particularly new housing, cultural and tourist facilities and development to
encourage increased economic activity are likely to produce overall impacts such as:
increased traffic generation and associated air pollution, CO2 emissions and noise,
increased resource use, including energy, water and materials, and the production of
waste.
6.7 Monitoring the significant sustainability effects of implementing the DMP is a
fundamental part of the SA process. It is important to monitor performance against
the sustainability objectives, which form the core of this appraisal, and identify where
they are being achieved and where they are not, so that appropriate remedial action
can be taken.
6.8 Brent has produced Annual Monitoring Reports for each financial year since 2000.
The DMP, as with the Site Specific Allocations DPD and Core Strategy DPD will be
monitored through updates to the AMR each year. The SA of the Core Strategy
proposed a monitoring process in the context of the Core Strategy, but designed to
provide a framework for the Local Plan as a whole. Additional monitoring
requirements are set out in the DMP to reflect the additional requirements of this
DPD.
