Chapter 10 - OPEN SPACE & RECREATION
10.1 INTRODUCTION
10.1.1 This chapter contains policies that aim to address the need to retain open spaces in the Borough, create new green areas, improve recreational facilities, and access to them, and preserve nature conservation sites and wildlife habitats. These policies can be seen as part of a broader approach to preserving and enhancing the environment of the Borough in support of the Council's Environmental Policy and improving sport and recreation through the Borough's Sports Strategy.
10.1.2 Open Space plays an important part in the lives of the Borough's residents. Not only does it meet recreational needs but it also contributes to the landscape and nature conservation value of the Borough. It is essential for everyone's well-being that there should be green 'lungs' in urban areas such as Brent that are densely developed and have no Green Belt land. Although the Borough contains areas of Metropolitan Open Land such as the Welsh Harp, Fryent Country Park and Northwick Park, which provide substantial breaks in the built-up area and are of significance to London, it suffers from a considerable deficiency of local parks and small areas of public open space. According to recognised standards it is the southern part of the Borough that is most deficient in open space and the Borough as a whole is under-provided with built sports facilities. Most of the facilities within Brent's open spaces are in need of improvement.
10.1.3 Nationally there has been a general increase in both leisure time and expenditure on leisure activities. This has been accompanied by increased participation in a wider range of sporting and recreational activities. The Council's aim is to extend the provision and widen the range of leisure, sport and recreation facilities to meet the needs of the Borough, but recognising that the Council's own resources are very limited. The Council's planning strategy towards sport and recreation facilities is informed by the Council's Sports Strategy (1999), the Sports and Leisure Development Framework for Brent (2003) and the Brent Playing Pitch Strategy (2004).
10.1.4 Although Brent is, in general, a densely developed urban area, there are parts of the Borough which have a more natural character and these open spaces and amenity areas, including the various waterways, provide a welcome contrast with the surrounding built up areas. Brent is fortunate in that it contains a number of sites of major metropolitan significance for nature conservation and wildlife with many other areas offering great potential for further creation of wildlife habitats. Natural and wildlife habitats are an important educational, recreational and social resource for the Borough: good sites are a scarce resource in London and deserve protection. Nature conservation is a land use in its own right and must be considered very carefully whenever development and land use change are proposed.
10.2 BACKGROUND
10.2.1 A trend in this and many other London boroughs has been the growing pressure to develop private and education sports grounds which are no longer required by their owners. The loss of such facilities has accelerated over recent years (over 36 hectares (89 acres) of open space in Brent, mostly in the form of sports grounds, has been lost to development since 1993). Their continued loss is not sustainable. The emphasis in this Plan is to conserve remaining sports ground use, in accordance with the Brent Playing Pitch Strategy recommendations. It is a critical resource and now must be protected as such.
10.2.2 As well as a general lack of open space there are also insufficient children's play areas in the Borough, and many of the existing ones are of a very poor quality. There is a need to encourage the provision of new play areas, particularly in those areas most deficient in play space, and the improvement of existing ones.
10.2.3 Demand for allotment space, which had fallen for a number of years, has recently begun to substantially increase and the Council is endeavouring to improve the quality of existing sites that are actively cultivated. When allotments are dis-used, proposals for development will be considered providing other allotment sites or open spaces are improved by way of compensation for their loss.
10.2.4 In addition to the general shortage of open space, certain groups in the community do not have equal access to the sports and leisure facilities in the Borough (notably disabled people, women and members of ethnic minority groups). The Plan needs to consider how to improve access for the community as a whole, especially those groups identified by Sport England as having low participation rates.
10.2.5 It is important to recognise that not all new sports and recreation facilities require open space sites. Some intensive indoor sports and recreation pursuits, such as health and fitness clubs, are best accommodated in town centres where they would meet the sequential approach advocated by the Government as well as assisting in the achievement of the Council's regeneration objectives.
10.3 STRATEGIC CONTEXT
10.3.1 The Government’s overarching strategy for sustainable development recognises the key importance of protecting and enhancing the natural environment, including open space for passive and active recreation, such as sport, and its biodiversity. A fundamental principle of sustainable planning which is endorsed, at national, regional and metropolitan levels as outlined below:
Open Space
National and Regional Policy Context
10.3.2 A Better Quality of Life: a Strategy for Sustainable Development for the UK (1999) emphasises that existing open space should be protected and stresses that “Opportunities should be taken to create more green spaces...” (para. 7.66). The recognition that open space “...can make a difference to the quality of people’s lives in urban settings.” is acknowledged in the Government’s urban renaissance strategy, Our Towns and Cities: the Future (2001).
10.3.3 Detailed planning guidance on protecting and promoting the role of all types of open space is provided in Planning Policy Guidance Note 17 Planning for Open Space, Sport and Recreation (PPG17, 2002) which declares that;
“Open spaces, sport and recreation all underpin people’s quality of life. Well designed and implemented planning policies for open space, sport and recreation are therefore fundamental to delivering broader Government objectives.”
The Government’s objectives include:
• Supporting an urban renaissance;
• Promotion of social inclusion and community cohesion;
• Health and well being; and
• Promoting more sustainable development.
10.3.4 PPG17 recognises that while local authorities should determine the levels and types of amenity space their residents require. They should do so through “...robust assessments of the existing and future needs of their communities for open space, sports and recreational facilities.” (para. 1). Detailed advice to their undertaking is provided in Assessing Needs and Opportunities (ODPM, 2002).
10.3.5 Such assessments should consider locational accessibility in accordance with Planning Policy Guidance Note 13 Transport, which places emphasis on “...open space and recreational facilities in locations likely to be accessible without use of a car.” (PPG13, para. 20).
10.3.6 Planning Policy Guidance Note 2 Green Belts (PPG2, 1995) promotes the protection and the maintenance of the open character of large tracts of Green Belt and Metropolitan Open Land designated primarily to prevent urban sprawl and the merging of urban settlements.
10.3.7 This national planning guidance is reiterated and reinforced at the regional level in Regional Planning Guidance for the South East (RPG9, 2001) which advises that local plans should properly recognise the contribution which “...open spaces can make to urban areas in terms of their recreational, nature conservation and wider environmental and social benefits...” (Policy Q2a).
Metropolitan Policy Context
10.3.8 Strategic Guidance for London Planning Authorities (RPG3, 1996) recognises that “One of London’s greatest assets is its framework of green space and open land.” (para. 7.1). Boroughs are advised to;
“...analyse critically the characteristics and uses of open space, with particular reference to their amenity value, ecological contribution and public access to them. Increasing pressures for active leisure and recreational pursuits need to be considered against the value of the areas for passive enjoyment and nature conservation.” (para. 7.2).
10.3.9 RPG3 advises that open space of strategic value to London should be designated as Metropolitan Open Land (MOL) to which a presumption against inappropriate development applies. RPG3 also urges authorities to consider the valuable role of ‘green chains’, consulting with neighbouring planning authorities as appropriate. Boroughs are also advised to identify and reduce ‘areas of open space deficiencies’.
10.3.10 The draft London Plan identifies the protection of the natural environment as a key constituent element - ‘the city’s breathing spaces’ - in its overarching ‘Compact City’ strategy. The draft Plan’s strategic Policy 2A.10 aims to protect and promote London’s network of open space while draft Policy 2A.11 similarly protects its aquatic counterpart, the Blue Ribbon network. Detailed advice as to their protection and promotion is provided in the Guide to Preparing Open Space Strategies (GLA, June 2003).
Nature Conservation and Wildlife
National and Regional Policy Context
10.3.11 The UK Biodiversity Action Plan (1994) and the more recent biodiversity strategy for England (Working with the Grain of Nature, DEFRA, 2002) detail the national strategy on the implementation of the UN Biodiversity Convention (and similar international commitments).
10.3.12 Planning Policy Guidance Note 9 Nature Conservation (PPG9, 1994) stresses the importance of taking into account nature conservation objectives in urban areas where there is wildlife of local as well as national importance and to ensure that both are protected in UDP's. Plans should be based on adequate information about species and habitats. UDP's should also consider the provision of new habitats.
10.3.13 Planning Policy Guidance Note 12 Development Plans (PPG12, 1999) emphasises the role plans have to play in enhancing biodiversity and protecting soil and land resources. Guidance which is further emphasised in RPG9 Policies E1& 2.
Metropolitan Policy Context
10.3.14 RPG3 advises boroughs to ensure that nature conservation objectives are taken into account where there is a local nature conservation interest. The Guidance recommends the use of the London Ecology Unit's (LEU) sites hierarchy and LEU Ecology Handbooks for each borough to inform the drafting of appropriate policies (para. 7.24).
10.3.15 The Mayor of London has published a statutory Biodiversity Strategy (Connecting with London’s Nature, 2002) which is supported by The draft London Plan, Policy 3D.12 Biodiversity and nature conservation. This requires boroughs to protect Sites of Metropolitan Importance for Nature Conservation and to similarly identify and protect Sites of Borough and Local Importance for Nature Conservation. Detailed implementation advice is provided in Design for Biodiversity (London Development Agency & Partners, 2003).
Sport and Recreation
National and Regional Policy Context.
10.3.16 Planning Policy Guidance Note 17 Planning for Open Space, Sport and Recreation (PPG17, 2002) emphasises the Government’s vision that;
“...sports and recreational facilities have a vital role to play in promoting healthy living and preventing illness, and in the social development of children of all ages through play, sporting activities and interaction with others.” (Page 4).
Hence PPG17 stresses that;
“Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space or the building and land to be surplus to requirements.” (para. 10).
10.3.17 PPG17 advises planning authorities of their responsibilities to take full account of communities existing and future need for recreational space and to resist development pressures where these conflict with the wider public interest. It specifically notes that all types of playing fields are of significance for their recreational and amenity value and for their contribution to green spaces in towns. PPG17 recommends that sports and recreational facilities of high quality or of a particular value to a local community should be afforded protection through appropriate policies in plans.
10.3.18 PPG17 stresses that playing fields should normally be protected to meet the long term needs for sport in the community. The principle exceptions being where:
• The proposed development is ancillary to the sporting or recreational use of the site;
• The proposed development affects land which is incapable of forming a playing pitch (or part thereof);
• The loss of playing fields would be offset through the provision of comparable alternative facilities ideally representing a qualitative improvement; or
• The proposed development is for an outdoor or indoor sports facility of sufficient community benefit to outweigh the loss of the playing field. (Para. 15)
10.3.19 RPG9 Policy E6 further emphasises the need to properly plan for sport and recreational provision to meet diverse community needs.
Metropolitan Policy Context
10.3.20 RPG3, recognising that sport and recreation “...improve the quality of life...” (para. 7.20), emphasises the importance of devising land use policies to take account of sport and recreation facilities including playing fields based on Sport England’s Regional Strategy and Playing Pitch Strategy. Sport England are now statutory consultees on applications involving most forms of sports facility.
10.3.21 The draft London Plan, Policy 3D.6, sets out the Mayor’s strategic objectives for sports which recognise that
“London needs to develop a wide range of high quality but affordable sports facilities, which are accessible to all sections of the community including disabled people. New provision should be focussed in areas with the greatest identified need.” (3D.32).
10.4 BOROUGH POLICY OBJECTIVES
10.4.1 In the face of the trends and pressures outlined above, the main objectives for open space and leisure provision are listed below:
1. Preserve and enhance the open nature of large strategic open spaces and protect other smaller parks and public open spaces from inappropriate development;
2. Protect and enhance those sites which have a nature conserva- tion and wildlife value and to create new ones where appropri- ate. To preserve and enhance habitats to ensure biodiversity;
3. Prevent the further loss of sports grounds, sports pitches and other sporting facilities and reduce the deficit of sports pitches in the Borough;
4. Reduce areas of public open space deficiency and improve overall access to open spaces, notably in the south of the Borough;
5. Improve the quality and coverage of appropriate facilities such as play areas;
6. Increase opportunities for those groups denied access to exist ing sports and recreation facilities such as disabled people, women and ethnic community groups;
7. Extend the dual use of school playing fields, where appropriate; 8. Provide a good coverage of sports centres across the Borough and new facilities in appropriate locations linked to the econom- ic aims of the plan.
10.5 BOROUGH STRATEGY
10.5.1 The overall strategy towards open space and recreation is to set standards for their provision and to protect and enhance the stock of open space in the Borough. It also seeks the provision of new and improved open space through the development process in areas where there are the greatest deficiencies, in areas suffering from social exclusion and in areas in need of regeneration. Protection of existing sports pitch provision is required and improvements in the quality and quantity of such provision will be sought.
POLICIES AND PROPOSALS
10.6 STRATEGIC OPEN SPACE
Metropolitan Open Land
10.6.1 Certain open spaces in the Borough have a strategic importance and a significance (generally because of its size and catchment area) extending beyond the Borough's boundaries. The open character of these areas will be preserved by designating them as Metropolitan Open Land (MOL). The status of MOL was enhanced in RPG3 which conferred on it a similar presumption against development as exists in the Green Belt.
10.6.2 A presumption reiterated and reinforced in The draft London Plan with a commitment to;
“...resist development on Metropolitan Open Land (MOL) unless it is clearly ancillary to the enjoyment of open space. Ancillary uses will only be acceptable where they do not have an adverse impact on the openness of MOL.” (Policy 3D.10).
10.6.3 Both RPG3 and The draft London Plan support LPAC's (now replaced by the GLA) Strategic Advice which contains indicators for the identification of MOL. Metropolitan Open Land is defined as any strategic open land, publicly or privately owned, with or without public access, which fulfils one or more of the following criteria:
OS1 DESIGNATION OF MOL
The following areas are designated and protected as Metropolitan Open Land:
(a) Fryent Country Park, including Barn Hill open space and adjoining sports grounds (part of the former LT sports ground at Old Kenton Lane and Kingsbury Green Primary School playing fields) and allotments at Old Kenton Lane;
(b) Welsh Harp, Silver Jubilee Park and Neasden Recreation Ground;
(c) Northwick Park including the Ducker Pond;
(d) Alperton Cemetery; and
(e) Gladstone Park.
These are defined on the proposals map.
1. It contributes to the physical structure of London, clearly distin- guishable from the built up area;
2. It provides open air facilities for leisure, recreation, sport, arts, cultural activities and tourism which serves the whole or signifi- cant parts of London;
3. It contains features or landscape of historic, recreational, nature conservation or habitat interest of value at a metropolitan or national level.
10.6.4 RPG3 points to PPG2 on Green Belts for a list of appropriate uses on MOL:
OS2 ACCEPTABLE USES ON MOL
The predominantly open character of Metropolitan Open Land will be preserved. Uses which may be acceptable on MOL are restricted to:
• Public and private open space and playing fields;
• Agriculture, woodlands and orchards;
• Rivers, canals, reservoirs, lakes, docks and other open water;
• Golf courses;
• Allotments and nursery gardens;
• Cemeteries; and
• Nature conservation.
10.6.5 The above list is a broad indication of the type of uses acceptable on MOL. However, not all uses are acceptable on all sites. For example, while golf courses are normally an acceptable use, this may not be so if they conflict with other MOL uses such as nature conservation or where they conflict with policies protecting areas of high landscape value (see for example Policy OS16).
10.6.6 Occasionally limited development in the form of buildings may be required to enhance the use of MOL for open space use. For example, changing rooms may be necessary to increase the recreational value of a particular open space. Policy OS3 ensures that building on MOL is limited to such circumstances.
OS3 DEVELOPMENT ON MOL
Within Metropolitan Open Land development will not be permitted unless:
(a) Any proposed building or use is complementary to the land uses listed in Policy OS2; and
(b) Any development is small in scale and is required to preserve or enhance activities associated with the particular open space.
Areas of Open Character
10.6.7 In addition to MOL, there are large open areas which are particularly prominent and visible from the main road network. Although these areas are generally not large enough nor sufficiently widely used to be of strategic importance (and not therefore appropriate for designation as Metropolitan Open Land), they are nevertheless of great significance to the Borough as a whole. For this reason the open character and sense of openness of such areas require special protection, in accordance with RPG3 and The draft London Plan.
OS4 AREAS OF OPEN CHARACTER
The areas of open character identified below and on the proposals map will be protected and enhanced:
• Vale Farm, fronting East Lane;
• Roe Green Park, Kingsbury Road;
• L.T. Sports Ground, Forty Avenue and Bridge Road;
• John Billam Playing Fields, Woodcock Hill;
• Barham Park, Harrow Road; and
• Sports Grounds fronting The Mall.
Green Chains
10.6.8 Green Chains, as recognised in both RPG3 and The draft London Plan, are areas of public and private land which are linked to provide a visual and physical network of open spaces through the Borough and beyond. In Brent, they follow rivers and canals, linking into green spaces in adjoining boroughs. The purpose of designation is to safeguard open land from built development, to maintain and improve access (including access for disabled people) through the chains to provide opportunities for informal recreation, to enhance visual amenity and to safeguard their nature conservation value. The Council will also encourage provision of the missing links in the chains where they are not continuous, as well as linking chains across borough boundaries. The Council will consult and co-ordinate action with adjoining boroughs.
10.6.9 Green Chains are identified on the Proposals Map. They are not confined to the boundaries of the canal and river but also include adjoining open spaces. The Council has a long term objective of providing a series of these linked open spaces along the River Brent. The Council also aims to increase the number and quality of open spaces along the Grand Union Canal (see also Policy BE14) to enhance its value for wildlife and tourism. Both the River Brent and Grand Union Canal will form part of the proposed West London Waterway Walks, as agreed by local authorities and interested bodies, with the aims of improving access, signage, the natural environment and landscape as well as conserving waterside buildings and encouraging waterway improvements. Development along the River Brent is also subject to the Plan’s policy on the prevention of flooding (Policy EP12).
10.6.10 The Council’s implementation strategy for the River Brent, the Grand Union Canal and other Borough waterways will be informed by the Mayor’s Blue Ribbon Network Strategy and, in particular, The draft London Plan, Policies BR2 (Biodiversity), BR3 (Natural Landscape) , BR6 (Flood Defences) and BR20 (Access).
OS5 GREEN CHAINS
The continuity of the following green chains will be maintained and, where practical, extended:
(a) River Brent; and
(b) The Grand Union Canal.
Wherever development proposals are submitted on land adjoining the River Brent and the towpath side of the Grand Union Canal, a landscaped area of public open space will normally be required adjacent to the waterway, incorporating a public footpath with provision for a cycle way and screening of any unsightly features abutting the area. Where the area above cannot be provided in full, the Council will consider contributions to improvements on the Green Chain as a whole.
Development proposals on the off-side of the Grand Union Canal should not erode the open character of the canal where this exists. The extension of open spaces and pedestrian access (including bridging the canal) will be sought on the off-side of the canal where appropriate and subject to operational requirements.
10.6.11 The Council recognises the value of the Grand Union Canal as a recreational feature for the Borough and also as an important wildlife corridor as well as comprising an unbroken Green Chain through the Borough. Conservation objectives are being pursued with the Greater London Authority and the adjacent boroughs, together with organisations such as British Waterways and other interest groups.
10.6.12 The Council aims to improve the appearance, use (especially for leisure purposes), accessibility and wildlife value of the Grand Union Canal and the canal feeder. Regard will be had to the Development Control Guidelines published by the, former, London Canals Committee (1999) for canalside redevelopment and The draft London Plan, Policies BR 19 (Sport and Leisure), and BR23 (Design). The Council's additional landscaping requirements are designed to maintain the character of the canal as well as to promote the gradual improvement of the Canal Green Chain. See also UDP Policy BE14.
10.7 PUBLIC OPEN SPACE
10.7.1 Brent is a highly developed London borough with a considerable overall deficiency of public open space; it has less open space per head of population than some boroughs that adjoin Central London. Guidelines that may be used to determine whether a particular area has satisfactory access to open space were initially set out in the Greater London Development Plan (GLDP) and commended in RPG3 (Table 7.1). These guidelines, which have been recently reiterated in the The draft London Plan, (Table 3D.1), establish a hierarchy of different sized parks providing different facilities, each with minimum access standards.
10.7.2 For example, households that live further than 400 metres (a quarter of a mile) from a park of over 2 hectares (5 acres) are considered to be in a local open space deficiency area. Households that live over 1200 metres (three quarters of a mile) from a park of 20 hectares (50 acres) are considered to be in an area that is deficient in district open space. The Council has accepted these guidelines, set out in Table OS1, as an appropriate measure of open space deficiency and also as a long-term goal for open space provision throughout the Borough, in accordance with RPG3 which advises Boroughs to “...seek to reduce deficiencies in open space...” (para. 7.19).
10.7.3 The draft London Plan endorses and reinforces this approach to identifying areas of open space deficiency (Policy 3D.9 Meeting People’s Needs for Open Space). The draft London Plan, Policy 3D.11, recommends that boroughs should produce open space strategies in accordance with the Guide to Preparing Open Space Strategies (GLA, 2003).
10.7.4 Brent lacks both local open space and district open space. Parts of the Borough south of the North Circular Road, such as Willesden Green, Brondesbury and Kilburn are especially deficient in open space. Given the lack of open space in the Borough and its poor distribution, it is important to protect local open spaces which help to maintain and improve the environmental quality of the Borough and to provide for recreation. The exception to Policy OS6 below is the redevelopment of Kingsbury Swimming Pool (see Policy OS19). The Proposals Map indicates the location of all existing and proposed public open spaces over 1 hectare in the Borough. The policy applies to all public open spaces in the Borough.
OS6 PUBLIC OPEN SPACE
Development of public open space will not be permitted unless it is required to maintain or enhance activities associated with the open space.
Maps OS1 and OS2 show existing public open space deficiencies in residential areas in Brent at Local and District levels respectively. A substantial new residential development could affect the pattern of open space deficiency in the Borough. Measurements are based on actual walking distances taking into account obstructions and not as the crow flies. The maps should therefore be used as a guide as the actual deficiency areas will be larger.
10.7.5 It is recognised that within local public open space deficiency areas it is unlikely that development sites will come forward to remove the deficiency. However, experience has shown that, subject to proper management, small-scale sites make a valuable contribution to help meet the deficiency. Small sites can provide wildlife habitats and so reduce areas of wildlife deficiency. These small sites may also provide a starting point for a larger scheme or, in combination with other small sites, can meet some of the open space needs in high deficiency areas. Public open space will be considered as a key land use should any sites or buildings become available in local public open space deficiency areas. Policy OS7 will be applied in existing predominantly residential areas or where large scale mixed development is proposed. Public open space will be sought in addition to any amenity space required by the development itself.
OS7 PROVISION OF PUBLIC OPEN SPACE
The provision of new or extended public open space (including provision for maintenance) will be sought on appropriate sites in local public open space deficiency areas when redevelopment takes place (including where new development creates a deficiency).
10.8 OUTDOOR SPORTS PITCHES AND SPORTS FACILITIES
10.8.1 The Brent Playing Pitch Survey, undertaken by the Council in 2003 in conjunction with Sport England showed a deficit of sports pitches in all the major pitch sports: soccer, rugby, cricket and hockey using Sports England standards. Brent is significantly below the National Playing Fields Association (NPFA) standards on pitch provision. The Council's experience shows that a shortage of lettable quality pitches exists for all sports with many of the pitches the Council manages being over-used. The diversity of cultures in the Borough means that an appropriate level of provision for Brent would exceed the Sports Council's standards. The Council will have regard to these sports pitch requirement figures which it will calculate for the Borough when applications are made concerning the development of sports grounds.
10.8.2 Between 1980 and 1990, some 17 hectares (41 acres) of private sports grounds were redeveloped, representing 17.5% of the 95 hectares (234 acres) of privately owned or leased sports grounds that existed in 1980. Just over one hectare (of 17 hectares) has been retained as open space within the redeveloped private sports grounds, under planning agreements. During the last decade the loss of private recreational land (primarily in the form of sports pitches) in Brent accelerated. A further 36 hectares (91 acres) of open space, mostly in the form of sports grounds has been developed since the deposit of the first Unitary Development Plan in 1992 and other proposals exist to erode the stock of playing fields further. The pressure on some schools to develop their playing fields remains.
10.8.3 PPG17 advises that playing fields of value or high quality should normally be protected except under limited circumstances. The Council's view is that the historical loss of sports grounds is not sustainable and its assessment is that a strong policy of protection is dictated by Brent's circumstances. Only in this way can it hope to address the shortage of sports pitches to meet its own needs as well as the needs of inner London boroughs looking to outer London to help meet their sports and recreation demands. PPG3 on Housing supports Brent's approach. It notes that clear evidence should be provided that adequate local provision of playing fields remains before development of sports grounds should be considered. Given Brent's current pitch shortages this is not the case and a policy protecting sports grounds is required. The policy also applies to former sports grounds, or parts of sports grounds, which are currently dis-used or under-used.
10.8.4 Where, exceptionally, loss of a small part of a sports ground is necessary to secure the future of the remainder (and is outside a deficiency area), a clear business case must be made, including a demonstration that the enabling element is no more than that financially required, and that the size of the remaining area remains viable in both sporting and financial terms. Any development of sports grounds should not lead to sports pitch or sports provision loss (based on the maximum capacity of the sports ground rather than its current use) unless that loss is compensated for by the provision of pitches and ancillary facilities elsewhere in a suitable location to a comparable quantity and quality. This provision would need to be made prior to commencement of the development.
10.8.5 Alternatively other sports facilities may be provided to compensate for the loss of sports grounds where they are of significant community sporting benefit. In order to compensate for any loss of public amenity from partial loss of open space, programmes to secure free public use at certain times will be secured, particularly for local schools. The policy does not justify the cumulative loss of sports pitches or grounds at any one site.
10.8.6 It is a statutory requirement for the Council to consult Sport England on proposals for development which affects playing fields. Local authorities must also notify the relevant Government department if they are minded to give planning permission for a development on educational playing fields. The Council will also consult with local residents and amenity groups on proposals for the disposal or alternative use of playing fields.
OS8 PROTECTION OF SPORTS GROUNDS
The development of sports grounds (including non-pitch based facilities and ancillary facilities) or open space will not be permitted in areas of local public open space deficiency. Elsewhere the development of sports grounds will only be permitted where the development of a small part (the minimum required) is essential to safeguard or improve the remainder and overall sports provision is not lost, so that either:
(a) The development is ancillary to the principal use of the site as a playing field or playing fields, and does not affect the quantity or quality of pitches or adversely affect their use; or
(b) The development affects only land incapable of forming, or forming part of, a playing pitch, and does not result in the loss of, or inability to make use of any playing pitch (including the maintenance of adequate safety margins), a reduction in the size of the playing area of any playing pitch or the loss of any other sporting / ancillary facility on the site; or
(c) The playing field or playing fields which would be lost as a result of the proposed development would be replaced by a playing field or playing fields of an equivalent or better quality and of equivalent or greater quantity, in a suitable location and subject to equivalent or better management arrangements, prior to the commencement of the development; or
(d) The proposed development is for an indoor (subject to Policy OS19) or outdoor sports facility, the provision of which would be of sufficient benefit to the development of sport as to outweigh the detriment caused by the loss of the playing field or playing fields.
Dual Use Open Space
10.8.7 Some school playing fields and other facilities lend themselves to use by the general public, this extended use of school playing fields and other recreation facilities, such as gymnasia, is known as dual use. In most cases this is confined to passive recreation of school playing fields, such as walking, sitting out, etc. but can include dual use of a wider range of facilities. There is dual use of school facilities at Copland school for example. The Council considers that there is further potential, through dual use, for increased sporting and recreational use of existing school and other facilities. OSP9 sets out a proposal where dual use is integral to the potential development of a new school. Since the main user will always have first call on the facilities, open space deficiencies can only be partially alleviated in this way.
OS9 DUAL USE OPEN SPACE
The dual use of education open space will be promoted, particularly where there is a deficiency of public open space. The dual use of facilities will be sought where schools bring forward significant development proposals.
Improving Access to Sports and Recreation Facilities
10.8.8 As well as the overall shortage of sports facilities, access to indoor and outdoor facilities remains uneven among different groups in the Borough, a feature identified by the Council in its Sports Strategy (1999). Aspects of this inequality can be redressed through planning policies and through sports management practices. The Council will continue, where possible, to adapt its existing facilities to allow full access by disabled people. Making sports facilities accessible to carers of young children, for example by improving changing facilities and providing childcare facilities, will also be considered wherever possible. Other groups in the community have also experienced difficulty in finding sports facilities including pitches. There is a shortage of gaelic football pitches suitable for use by interested schools, for example, and clubs which draw heavily from the African, Caribbean and Asian communities do not always have access to the same level of facilities as many other long established clubs. The Council's commitment to widen access to sport and recreation applies equally to indoor facilities (see also Policy OS20).
OS10 ACCESS TO SPORTS FACILITIES
The Council will, where possible:
(a) Adapt the Council's sport and recreation facilities to help those groups identified in its sports strategy as having low rates of participation in sport;
(b) Provide facilities that meet the needs of all groups in the community;
(c) Adjust provision as new sports develop; and
(d) Encourage other facility providers to take similar action.
10.9 OTHER URBAN GREEN SPACE
10.9.1 PPG17 advises local authorities to take full account of the community's need for recreational space, not solely sports pitches, a position confirmed in RPG3 and reiterated in The draft London Plan, Policy 3D.10. LPAC defined open space to which public access is restricted, or not formally established, but which is capable of meeting recreational and non-recreational needs, as Urban Greenspace. Urban greenspace excludes previously developed urban land. For the purposes of this Plan, Policy OS8 deals with urban greenspace with formal sports use. Policy OS9 considers other Urban Green Space meeting open space needs in Brent. Development of existing Urban Green Space will normally be refused unless it is replaced on site or elsewhere (usually in open space deficiency areas) or it possess no recreational, amenity or nature conservation value.
OS11 URBAN GREENSPACE
Development of Urban Greenspace (not considered in Policy OS8) will be refused unless the following apply:
(a) Urban Greenspace can be replaced on site, nearby or in an area of open space deficiency; and
(b) The site has no recreational, amenity or nature conservation value.
10.10 WILDLIFE AND NATURE CONSERVATION
10.10.1 Several parts of the Borough have significant nature conservation value, with many other areas offering great potential for further creation of wildlife habitats. The Council's nature conservation policies are based on information contained in the Ecology Handbook No 31, Nature Conservation in Brent, 2000. Sites of wildlife conservation value are classified by the, former, London Ecology Unit (LEU, now part of the GLA) as sites of Metropolitan, Borough (Grade I and Grade II) or Local Nature Conservation Importance or sites which form a Wildlife Corridor. Nearly all sites were surveyed. The development process will allow other sites to be surveyed and some of these are likely to be of nature conservation value: new sites will be designated as appropriate. The Council will co-operate with adjoining boroughs to ensure that sites and corridors which cross borough boundaries are maintained.
10.10.2 The various nature conservation sites have a hierarchy of value, the Sites of Special Scientific Interest (SSSI's) as well as sites of Metropolitan and Borough (Grade I) importance contain intrinsically rich habitats and will therefore be protected from development (see Appendix OS1 for a list of sites). In accordance with section 28 of the Wildlife and Countryside Act 1981, the Council will consult English Nature concerning proposed development that affects the SSSI. The Council also consults English Nature on a range of land-use operations that might affect the SSSI.
OS12 DEVELOPMENT ON SSSIs AND SITES OF METROPOLITAN, AND BOROUGH (GRADE I) NATURE CONSERVATION IMPORTANCE
Development will not be permitted on or adjacent to Sites of Special Scientific Interest and Sites of Metropolitan and Borough (Grade I) Nature Conservation Importance shown on the proposals map, unless it is demonstrated, that there will be no adverse effect on nature conservation.
10.10.3 The London Ecology Unit has also identified sites of Borough (Grade II) and local importance in terms of their wildlife and nature conservation value (see Appendix OS1): they may not have such an intrinsically rich habitat but they do have an important local wildlife value. Policy OS13 below ensures that development has no adverse consequences on these sites or that compensatory provision is made.
OS13 DEVELOPMENT ON SITES OF BOROUGH (GRADE II) AND LOCAL NATURE CONSERVATION IMPORTANCE
Development will not be permitted on sites of Borough (Grade II) and Local Nature Conservation Importance shown on the proposals map unless it is demonstrated that there will be no adverse effect on nature conservation or that compensatory provision for wildlife is made.
Wildlife Corridors
10.10.4 Wildlife corridors are areas of land often linking sites of known nature conservation value; typically they run along river corridors, such as Wealdstone Brook, and railway lines as well as linked areas of open space. They need not be made up solely of land of proven wildlife value. It is particularly important to maintain these links so that ecological communities do not suffer the vulnerability that arises from isolation. Wildlife Corridors are often of high amenity value, particularly for train commuters passing through the developed parts of London. Green Chains act as wildlife corridors, but wildlife corridors also include links that are not accessible to the public, for example railway embankments. On wider railway embankments, some sites could be dedicated to nature conservation and a number of these are protected by woodland protection orders. Regard will be had to the operational requirements of the transport undertakers.
10.10.5 The designation of these meets the requirements of PPG9 paragraph 15 which states that “Statutory and non-statutory sites, together with...features which provide wildlife corridors, links or stepping stones from one habitat to another, all help to form a network necessary to ensure the maintenance of the current range and diversity of our flora, fauna, geological and landform features and the survival of important species.”
OS14 WILDLIFE CORRIDORS
Wildlife corridors, as shown on the proposals map, will be protected from developments which sever or otherwise unacceptably harm their importance for wildlife conservation and / or visual amenity, unless, where appropriate, compensatory provision is provided. In the case of the Wealdstone Brook any development which affects its open setting will be resisted.
Species Protection
10.10.6 As well as preserving habitat on which wildlife depends, PPG9 on Nature Conservation also deals with the protection of species and recommends the use of conditions or planning obligations under which the developer would take steps to secure the protection of species. The LEU advises boroughs to ensure that developers also take action to reduce disturbance to a minimum and provide adequate alternative habitats to sustain at least current levels of population when sites with protected or important species are proposed for development.
10.10.7 The LEU also recommended that boroughs should prepare local Biodiversity Action Plans (BAP) which should not only address national priority species listed in the UK Plan, but should also take into account local priorities in order to preserve our familiar wildlife. This advice informed The draft London Plan injunction that development should be resisted where it “...would have a significant adverse impact on the population or conservation status of protected or priority species.” (Policy 3D.12).
10.10.8 The Brent Biodiversity Action Plan (BAP, 2001) recognises the importance of sites and wildlife at a local level and has informed the Mayor’s London-wide Biodiversity Strategy (Connecting with London, 2002) and the London Biodiversity Action Plan (London Biodiversity Partnership, 2001).
OS15 SPECIES PROTECTION
Development which would have an adverse impact on protected species or national or local Biodiversity Action Plan species that are uncommon or under threat in London will be refused, unless steps to secure the protection of the species are implemented.
Major Nature Conservation and Recreation Areas
10.10.9 Brent Reservoir, or the Welsh Harp, is an area of nearly 70 hectares (170 acres) of urban countryside and water. It has matured into a very attractive recreational centre and a valuable habitat for wildlife and plants. Much of the area has been designated as a Site of Special Scientific Interest by English Nature in order to protect its rich variety of plants and other wildlife, and the Council has designated part of the reservoir as a Local Nature Reserve. The Council recognises the unique value of the Welsh Harp Reservoir and its surrounding open land for both recreation and wildlife conservation.
10.10.10 The Welsh Harp has been identified in The draft London Plan as an important element of London’s Blue Ribbon Network (Map BR1). Part of the Welsh Harp is in the London Borough of Barnet and, in order to resolve potential conflicts between recreation and conservation and to consider the future development and protection of the area as a whole, the Welsh Harp Joint Consultative Committee has been established with Barnet Council, British Waterways and other interested parties: initiatives include a joint conservation agreement to protect the area. It is hoped that the co-operation of all of these parties, and the Environment Agency, will ensure a secure future for the reservoir as a nature conservation and recreation area. The Council's general policy in respect of development proposals affecting SSSI's and sites of Metropolitan and Borough Nature Conservation importance (Policy OS12) applies to the Welsh Harp. The special considerations that relate to the Welsh Harp are set out in Policy OS16 below. The Council will continue to interpret and promote the landscape and nature conservation value of both the Welsh Harp and the Fryent Country Park.
10.10.11 Fryent Country Park is one of the best areas for traditionally managed neutral grasslands in Greater London and has a rich grassland flora as well as many ponds, woodland and 11km of hedgerows - many of medieval origin. The wooded area around Barn Hill was laid out by Humphry Repton in 1793 and is a good surviving example of his work: it includes a mature deciduous woodland; wetland meadows; Tudor and older hedgerows following ancient parish boundaries, such as Hell Lane; and a Saxon hedgerow which is the best surviving section of parish boundary hedge in North West London. The Council will protect the Country Park as a Local Nature Reserve under the provisions contained in the National Parks and Access to the Countryside Act, 1949.
OS16 WELSH HARP & FRYENT COUNTRY PARK
On the Welsh Harp and Fryent Country Park, planning decisions should:
(a) Ensure that both areas are protected from any proposals which would affect their integrity as unique environments;
(b) Protect any areas designated as local nature reserves;
(c) Improve access for the local community; and
(d) Protect the areas for predominantly informal recreation.
10.10.12 To help promote nature conservation in the Borough, the Council intends to produce management plans for major public open spaces which have important nature conservation value. These will help resolve conflicts between different uses, for example nature conservation and active recreation. The management plans will examine what kinds of uses are acceptable and what improvements are needed (such as access for disabled people) although they will not deal with day to day maintenance issues. The local community will be involved in the production of these plans and the Council will consult interested parties such as English Nature. The Welsh Harp and Fryent Country Park will be the priorities for the production of these management plans.
Creation of New Wildlife Habitats
10.10.13 Within London good wildlife habitats are a scarce resource and the Council intends to protect and enhance existing sites which have a nature conservation value (see Policy STR36). It is important to ensure that new developments cause the minimum damage and disturbance to landscape, wildlife and wildlife habitats. All new developments should exploit opportunities to improve the environment both from an amenity and wildlife viewpoint. Where land adjacent to nature conservation sites is developed the Council will seek to extend wildlife habitats into the development site (using native species wherever possible). In areas of wildlife deficiency (defined as over 1km from accessible sites of Metropolitan or Borough nature conservation importance) (see Map OS3) the Council will seek part of any development site for the creation and maintenance of wildlife habitat. The development process may create derelict sites which can sometimes lie undeveloped for some time. The Council will seek the temporary use of such sites for nature conservation purposes.
OS17 NEW WILDLIFE HABITATS
The creation of wildlife habitats will be sought as part of the landscaping scheme in major developments in the following locations:
(a) Adjacent to areas of nature conservation importance; and
(b) In areas of wildlife deficiency (see Map OS3).
The temporary use of derelict sites for nature conservation purposes will be encouraged.
10.11 INDOOR SPORTS & RECREATION & OTHER OUTDOOR USES
Children's Play Areas
10.11.1 There is a considerable deficiency in children's play provision in Brent, not only in terms of the land area devoted to play facilities and the quality of provision but, more importantly, in terms of its distribution around the Borough.
10.11.2 Most of the children's play areas in Brent are provided either within public open spaces or on housing estates. Many of the more recent open space acquisitions in the south of the Borough are being used primarily for children's play: they are generally less than half a hectare (one acre) in size and are therefore ideally suited to play provision. Despite the laying out of new play areas and the improvement of many more, a large number of the play areas in Brent are poor, lack modern equipment, safety surfaces and not all are fenced to make them dog free. Some residential areas do not have reasonable access to any play areas at all.
10.11.3 Measured against the National Playing Fields Association (NPFA) standards on children's play space, the Borough is seriously deficient in play space. Meeting the NPFA standards on children's play space is a long term goal for the Borough as a whole, as is a satisfactory distribution within the Borough. The NPFA recommend that pre-school children's play areas should be located within 150 metres of family dwellings and 400 metres for junior play areas. These should be accessible without having to cross main roads. The areas of deficiency are shown on Map OS1.
10.11.4 New housing developments over 15 units (or over 0.5 hectare) and larger scale mixed developments will, where appropriate, be expected to provide children's play areas to the NPFA standards where they are not met or provide contributions to allow such provision to be made within the vicinity or in a deficiency area. Arrangements for their long term maintenance will also be sought through planning obligations. Existing play areas will not be allowed to be redeveloped unless they are replaced within the site or at a more appropriate location.
OS18 CHILDREN'S PLAY AREAS
The provision of suitable play areas for pre-school and junior children to NPFA standards will be sought in residential developments over 15 units (or 0.5 Ha in size) or in large scale mixed developments. Where such provision may not be appropriate, contributions to their provision in a more appropriate location will be acceptable.
Arrangements for the long term maintenance of these play areas will be sought through planning obligations.
Redevelopment of existing play areas will only be considered where they are provided within the development site or at a more appropriate location.
Indoor Sports Centres and Indoor Recreation
10.11.5 There is growing interest in the provision of commercially operated recreation facilities. Previously these were of a reasonably small scale such as snooker clubs, but now schemes of a much larger scale, e.g. indoor cricket and tennis centres, health and fitness clubs are being considered. The location of sports and recreation uses should generally accord with the sequential approach: first consideration being given to town centres, then edge of town centres, district centres and only then out-of-town sites with good public transport access. See also Policies STR2, SH3 and TEA1.
10.11.6 The Council will also seek the provision of childcare facilities in major indoor schemes and a comparable level of access for disabled people, where appropriate, when a new sports facility is created by conversion or extension, where such a change is outside the scope of the Building Regulations. The principles governing proposals for smaller-scale indoor sports and recreation activities, set out in Policy TEA2, apply to small scale indoor sports and recreation proposals.
OS19 LOCATION OF INDOOR SPORTS FACILITIES
Large-scale indoor sports, leisure and recreation facilities should be located in accordance with the sequential approach (Policy SH3 to SH5).
Where reasonable and practicable, in major schemes, the provision of childcare facilities will be sought. The site should be designed to be accessible to disabled people where external works are not covered by the Building Regulations.
Proposals for small-scale sport, leisure and recreation facilities, that do not attract a lot of people, should accord with the principles set out in Policy TEA2.
10.11.7 Brent has comprehensively set out its strategy to develop and enhance a very wide range of sporting and leisure activities in A Sports And Leisure Development Framework For Brent (2003), which identifies the need for new and enhanced facilities and enabling resources in accordance with residents and users priorities. This Strategy complements other surveys which have examined potential locations for indoor facilities requiring extensive site areas, and which need to be co-located with outdoor sports facilities (as they share changing facilities and have indoor and outdoor elements to the same sport), in accordance with the sequential approach, as part of its review of existing sports provision (see Brent's Sports Strategy, 1999). These locations accord with the sequential approach and are therefore included as site specific proposals in Chapter 15 of the Plan or proposals within Policy OS20 below.
OS20 SITE SPECIFIC SPORT PROPOSALS
The Council has set out site specific proposals for the provision of indoor (with some outdoor) facilities at Vale Farm and Kingsbury. It will also bring forward proposals for the re-provision of Willesden Sports Centre and Athletics Stadium. These proposals require extensive site areas. In each case there are no sequentially preferable locations and the proposals are included in the Plan on that basis.
10.12 METROPOLITAN WALKS
10.12.1 PPG 17 advises local authorities to promote and enable walking as a recreational activity. The draft London Plan promotes “...high quality walking routes...” (Policy 3C.18), as identified on its Map 3C.5 London’s network of promoted and proposed walking routes. The Mayor will further detail measures to promote recreational walking in the proposed Walking Plan (Transport for London).
10.12.2 A network of Metropolitan Walks has been formulated by the London Walking Forum. It is intended that Metropolitan Walks such as the Capital Ring (an outer London orbital footpath) will be way-marked and will have information points along them. The Council intends to implement those sections of the Metropolitan route network within the Borough (the River Brent Green Chain and the Capital Ring Metropolitan Walks are set out in the Proposals Map) and ensure that development near the route takes account of the route and, where appropriate, contributes to its implementation by providing way-marking and information, route greening and improving pedestrian safety.
OS21 METROPOLITAN WALKS
The character of paths and other routes which form Brent's Network of Metropolitan Walks will be protected. Development on or near to the route will be expected to take full account of Brent's Metropolitan Walks network (shown on the Proposals Map).
10.13 ALLOTMENTS
10.13.1 Development Plans are statutorily required to make provision for allotments where there is an identified requirement (Allotments Act 1925). PPG17 (para. 14) specifically reiterates the advice of PPG3 (Annex C) that allotments must not be regarded as ‘previously developed land’. The draft London Plan recommends strong protection for allotments (para. 3D.45). The Thorpe Report (1969) recommended national guidelines for allotment provision which have been beyond the ability of the Borough to meet.
10.13.2 The review of the former UDP (1996) took place against a background of accelerating lack of interest in allotment cultivation with consequential rising vacancies and disused plots. An assessment undertaken by the Parks Service showed that the two allotments for which there are site specific proposals (see Chapter 15) were surplus to requirements, and the Council considered what other functions these sites could perform before designating these sites for alternative uses. It should also be noted that Council does not currently rely on Greenfield sites other than those identified in the Plan to meet its housing requirements.
10.13.3 Other allotment sites in the Borough are well occupied and should not be built on unless future assessments show these allotments to be surplus to requirements, in accordance with the advice of PPG17. Particularly, as the historic decline appears to have been reversed with a growing interest in horticulture leading to a significant decline in vacancies and even waiting lists for some allotments. The Council has responded to these changes with a programme to upgrade and improve its allotments where feasible.
10.13.4 Allotments, aside from the site specific proposals will be protected from development. Where they are surplus to requirements, the Council will consider other open space functions that the sites may perform. in accordance with (PPG17). Even where development may be permitted, the allotments open space, recreational and amenity value must be compensated for by means of a planning obligation contributing towards the upgrading of other allotment sites, or by provision of replacement or improvements to other open space.
OS22 ALLOTMENTS
Allotments, other than those identified in Chapter 15, will be protected from development unless:
(a) The Council’s future assessments show allotments to be surplus to requirements
(b) They are extensively disused
(c) A consideration is given to other open space functions the allotment site may perform
Where there is no up to date assessment by the Council, the applicant should demonstrate through an independent assessment that allotment land is surplus to requirements.
The loss of the site’s nature conservation, recreational or visual amenity value is compensated for by means of a planning obligation regarding contributions towards the upgrading of other allotment sites, provision of replacement open space, or some other form of relevant compensatory provision.
10.14 CEMETERIES
10.14.1 RPG3 advises that boroughs should make provision for burial space where possible (para. 7.26). A position reiterated in The draft London Plan, which also emphasises the requirement to consider “...the special needs of certain religious or cultural groups for whom burial is the only option.” (Policy 3A.28). The draft Plan also supports the ‘sustainable cemeteries’ (including reuse of graves) strategy promoted by the, former, LPAC (1997).
10.14.2 Existing capacity has been maintained in Brent's existing cemeteries by using all available areas of them. The Council's main cemetery is at Carpenders Park near Watford. It has space for burials well into the next millennium although access by public transport is poor. There are no crematoria in the Borough: the nearest are located at Hendon, Golders Green, Kensal Green and Ruislip. There are unmet demands from different religious denominations. The Hindu population would like a crematorium more suited to their customs and needs. The Muslim population are served by a separate burial ground at Carpenders Park but not in the Borough.
10.14.3 The Council recognise the practical difficulties in siting cemeteries and crematoria in built up areas such as Brent. The Crematorium Act, 1902 (amended by the Greater London Council (General Powers Act) 1971) set standard distances requiring that new crematoria are normally located 100 yards (91 metres) from any residential property and 50 yards (46 metres) from a highway. As crematoria are not an appropriate use of MOL, then it is difficult to find areas in Brent that would fulfil the standards.
10.14.4 While the existing cemeteries and churchyards in Brent have important historical, architectural, habitat and passive recreational value, the Council are concerned that they are a user of scarce land resources. The Council will, through its own management practices, seek to re-use its burial space. Through the Confederation of Burial Authorities, of which it is a member, the Council will also seek the necessary changes in legislation to facilitate the further re-use of existing burial space before finding further land for burial use.
OS23 CEMETERIES & CREMATORIA
The demand for burial space and cremation will be met inside and outside the Borough without encroaching on sports or open air recreation facilities, or impacting adversely on areas of nature conservation importance, and as far as possible in locations accessible to public transport. Where practicable, all existing cemetery space should be re-used before new burial facilities are approved, provision will be made for recording memorials for historical purposes and protecting those of particular interest. Special consideration will be given to cemetery and cremation facilities meeting unmet needs of religious or ethnic groups in the Borough.
APPENDIX OS1 SCHEDULE OF SITES OF NATURE CONSERVATION IMPORTANCE
Sites of Special Scientific Interest (SSSI)
Welsh Harp
Sites of Metropolitan Nature Conservation Importance
M6 Grand Union Canal
M35 The Welsh Harp
M36 Fryent Country Park
Sites of Borough (Grade I) Nature Conservation Importance
Br.BI 1 Quainton Street Open Space
Br.BI 2 Dollis Hill Rough
Br BI 3 Northwick Park and the Ducker Pool
Br.BI 4 Old St Andrew's Churchyard, Kingsbury
Br.BI 5 Brent Bends
Br.BI 6 Railside Habitats
A.Silverlink Metro between Brondesbury and Willesden Junction.
B. Metropolitan line between Kilburn and Neasden
C. Dudding Hill Loop between Cricklewood and Harlesden
D. Harlesden to Wembley Central, including the Wembley Brook
E. Piccadilly Line between River Brent and Sudbury Hill
F. Chiltern Line between River Brent and Sudbury Hill Harrow
G. Jubilee lineside from Stanmore Junction northwards to Queensbury
H. Northwick Park and Kenton railsides
Sites of Borough (Grade II) Nature Conservation Importance
Br.BII 1 The Canal Feeder and River Slade
Br.BII 2 Paddington Cemetery
Br.BII 3 Gladstone Park
Br.BII 4 Roundwood Park and Willesden New Cemetery
Br.BII 5 Tokyngton wildflower area and the Brent
Br.BII 6 Harp Island
Br.BII 7 Abbey Road Mounds
Br.BII 8 Coronation Road Pastures and Guinness Siding
Br.BII 9 Grange Roundabout Nature Area
Br.BII 10 St John's Old Burial Ground
Br.BII 11 Wealdstone Brook from Kenton to the Jubilee Line
Br.BII 12 St Mary's Churchyard, Willesden
Br.BII 13 One Tree Hill
Br.BII 14 Roe Green Park
Br.BII 15 Willesden Reservoir
Sites of Local Nature Conservation Importance
Br.L 1 River Brent west of Stonebridge
Br.L 2 Meadow Way Copse
Br.L 3 Kingsbury Hospital Wood
Br.L 4 Wealdstone Brook (Wembley Park section)
Br.L 5 Brentfield Open Space and Leicester Road
Br.L 6 Grove Park and Tramway Brook
Br.L 7 The Pimple
Br.L 8 Queens Park
Br.L 9 The Old Orchard
Br.L 10 Elmwood Park
Br.L 11 Alperton Cemetery
Br.L 12 Barham Park
Br.L 13 Wembley Park Sports Field
Br.L 14 Brett Crescent Backland
Br.L 15 Barham Primary School Wildlife Area
Br.L 16 Byron Court Primary School Nature Reserve
Br.L 17 The Orchard - Malorees Infants and Junior School
