Chapter 3 - BUILT ENVIRONMENT

3.1 Introduction
3.2 Background
3.3 Strategic Context
3.4 Policy Objectives
3.5 Borough Strategy

POLICIES & PROPOSALS

3.6 - DESIGN SUBMISSIONS
BE1 - URBAN DESIGN STATEMENTS

3.7 - URBAN DESIGN PRINCIPLES
BE2 - TOWNSCAPE: LOCAL CONTEXT & CHARACTER
BE3 - URBAN STRUCTURE: SPACE & MOVEMENT
BE4 - ACCESS FOR DISABLED PEOPLE
BE5 - URBAN CLARITY & SAFETY
BE6 - PUBLIC REALM: LANDSCAPE DESIGN
BE7 - PUBLIC REALM: STREETSCAPE
BE8 - LIGHTING & LIGHT POLLUTION
BE9 - ARCHITECTURAL QUALITY
BE10 - HIGH BUILDINGS
BE11 - INTENSIVE & MIXED-USE DEVELOPMENTS
BE12 - ENVIRONMENTAL DESIGN PRINCIPLES

3.8 - PRIORITY AREAS FOR TOWNSCAPE & PUBLIC REALM ENHANCEMENT
BE13 - AREAS OF LOW TOWNSCAPE QUALITY
BE14 - GRAND UNION CANAL CORRIDOR
BE15 - TRANSPORT CORRIDORS & GATEWAYS
BE16 - OTHER PUBLIC REALM INITIATIVES

3.9 - OTHER STRUCTURES
BE17 - BUILDING-SERVICES EQUIPMENT
BE18 - SATELLITE DISHES
BE19 - OTHER FORMS OF TELECOMMUNICATIONS DEVELOPMENT
BE20 - ADVERTISEMENTS ON BUILDINGS
BE21 - ADVERTISEMENT HOARDINGS

3.10 - URBAN CONSERVATION
BE22 - PROTECTION OF STATUTORY LISTED BUILDINGS
BE23 - SETTING OF LISTED BUILDINGS
BE24 - LOCALLY LISTED BUILDINGS
BE25 - DEVELOPMENT IN CONSERVATION AREAS
BE26 - ALTERATIONS & EXTENSIONS TO BUILDINGS IN CONSERVATION AREAS
BE27 - DEMOLITION & GAP SITES IN CONSERVATION AREAS
BE28 - OPEN SPACE IN CONSERVATION AREAS
BE29 - AREAS OF DISTINCTIVE RESIDENTIAL CHARACTER
BE30 - ENABLING DEVELOPMENT & HERITAGE ASSET CONSERVATION
BE31 - SITES OF ARCHAEOLOGICAL INTEREST
BE32 - MONUMENTS AND EARTHWORKS
BE33 - TREE PRESERVATION ORDERS
BE34 - VIEWS & LANDMARKS

APPENDIX BE1 - SCHEDULE OF PROPERTIES IN CONSERVATION AREAS
APPENDIX BE2 - SCHEDULE OF PROPERTIES IN GRAND UNION CANAL POLICY AREA
APPENDIX BE3 - SCHEDULE OF PROPERTIES IN AREAS OF DISTINCTIVE RESIDENTIAL CHARACTER
APPENDIX BE4 - SCHEDULE OF LISTED BUILDINGS
APPENDIX BE5 - SITES OF ARCHAEOLOGICAL IMPORTANCE AND ARCHAEOLOGICAL PRIORITY AREAS
APPENDIX BE6 - VIEWS AND VIEWPOINTS

MAP BE1 - AREAS OF LOW TOWNSCAPE QUALITY
MAP BE2 - TRANSPORT CORRIDORS AND GATEWAYS
MAP BE3 - CONSERVATION AREAS AND ARTICLE 4 DIRECTIONS
MAP BE4 - VIEWS, LANDMARKS AND VIEWPOINTS

3.1 INTRODUCTION

3.1.1 This chapter is concerned with the design quality of Brent's built environment and its setting. It relates to the overall 'form' of developments and their use, i.e. their layout, scale, density, accessibility, landscape, appearance and the way in which areas function. The policies cover not just the design of individual sites and buildings, but also the spaces in between them, the linkages and relationships between the various built-environment components and public space, in order to create or maintain places that people want to work and/or live in. The quality of the urban environment affects everyone, and good design is necessary for positive change to occur.

3.1.2 The design policies apply to all types of development throughout the borough. In some parts of the borough, the condition of the environment is so poor, that special design policies apply, to secure enhancement of their townscape and public realm.

3.1.3 The Chapter also includes policies for the preservation of our built heritage and its settings. Again, the concern is not just for individual historic buildings, but also includes the conservation of areas of special architectural or historic character. Specific policies on environmental protection are covered in Chapter 4, while the natural environment, notably wildlife and nature conservation, are addressed in Chapter 10 on Open Space & Recreation. Special design policies apply within the Wembley Regeneration Area chapter (Chapter 14).

3.2 BACKGROUND

3.2.1 The built-environment is made up of many elements: buildings; transport infrastructure, streets; open land and the spaces around them; trees and other landscape features. It is the result of the collective efforts of countless people; developers, architects, planners, engineers and builders, who conceive, fund, design, plan, and construct our buildings, streets and public spaces. Collectively, these elements determine the character, appearance and quality of the local environment in which people live, work, play and travel, often also providing urban habitats for wildlife.

3.2.2 The environment affects people in social, economic, psychological as well as physical ways, and in recent times there has been much concern expressed about the alienating nature of the modern built environment, in addition to its production and maintenance - its wasteful use of energy and resources and detrimental impact on the eco-system. The quality of much modern building is often seen as poor, using expensive, non-renewable materials, some of which adversely affect our health. Consequently, a 'good quality' environment is one that supports healthy lifestyles and encourages within us a feeling of well being, safety and confidence. Sustainability is thus an important dimension of urban design, which has emerged as one way of bringing architects, engineers and planners together with the community, to find more user-friendly solutions to poor environmental conditions.

3.2.3 Urban design has been defined in various ways, but is essentially the practice of shaping the complex interactions between urban form and movement, between places and people, and between the built-environment and nature. It aims to influence the different aspects of the development process to deliver successful villages, towns and cities that work well. The planning system has a key role in facilitating the urban design process, especially as increasing attention is also being paid towards environmental 'sustainability'. The design of buildings and land use patterns have a crucial impact upon natural resources and ecological processes. The planning system, by encouraging designs that integrate with natural processes, can play an important part in countering such global problems as the greenhouse effect.

PICTURE

Brent's Urban Character

3.2.4 The built-environment within the borough is of relatively recent history; from the 19th to 20th centuries. As is typical of much of London, there is a multi-centred structure from amalgamated villages. Main roads well-defined by densely developed frontages, link the main town centre districts to each other and the wider north/west London area. The North Circular Road, however, is a significant barrier between the more affluent north/west of the borough and the poorer south/east area, and also has less frontage-definition.

3.2.5 Brent's development has tended to reflect its accessibility from London. The British Rail lines and the Metropolitan Railway enabled suburban 'Metroland' development boosted by the British Empire Exhibition in Wembley Park in 1924/25. Much of the architecture of Brent reflects the styles of these times. As a result, buildings in Brent display a wide variety of local design characteristics. This variety has been added to by new cultural groups who have introduced new architectural styles. A recent example would be the Swaminarayan temple in Neasden. The wide range of environmental conditions within the Borough, includes:

- Well-planned leafy suburbs;
- Dense 19th-century inner city housing;
- 1960's & early 1970's high-rise residential estates and office blocks;
- Two of London's largest industrial estates; Wembley Stadium & Park Royal;
- A large number of district and local shopping centres of varying quality.

3.2.6 A common problem with the design of many of the high-rise housing estates was their use of standardised building forms with little or no regard to local character and architectural styles, often resulting in an unattractive visual appearance. They lacked defined street frontages leading to inadequate natural surveillance of street activity. In addition, the grounds were often dominated by asphalt, with an excessive proportion of sites covered by roads and parking areas with a consequent lack of space for effective landscaping and amenity. The resulting environment did little to promote a sense of community and shared space and often contributed to an atmosphere of insecurity and alienation in some parts of the borough. The overall standard of building (including interiors) and of urban design, was often very poor, and many of these properties have short life spans.

3.2.7 Brent is not a borough of uniform character, but one of striking contrasts; between suburban areas in the north (with a reasonable range of facilities and a strong sense of community), and southern inner-city areas (with a limited range of cultural and recreational facilities and fear of crime). Much of Brent lacks the higher environmental quality evidenced in neighbouring boroughs. There is now widespread recognition within the borough of an urgent need for substantial improvements to the quality of the urban environment.

3.2.8 Such improvements to the environment cannot be achieved by the Council's actions alone. Co-operation between the Council, local communities and local businesses is essential and the Council has launched its Local Agenda 21 Action Plan, bringing together these different sections of the community in partnership. The policies and proposals in the UDP have been designed to ensure that the land-use planning system contributes to the objectives of the Action Plan. The Council will encourage community participation at all stages of the planning and design process and will seek to raise awareness of design-quality issues in the community.

3.3 STRATEGIC CONTEXT

3.3.1 The Town and Country Planning Act 1990 requires that development plans include policies in respect of, '..the conservation of the natural beauty and amenity of the land', as well as 'the improvement of the physical environment'.

3.3.2 Government policy is set out in Planning Policy Guidance Notes (PPGs). General Policy and Principles (PPG1) revised in 1997, gives particular advice in the field of design control, stating that; 'The appearance of proposed development and its relationships to its surroundings are material considerations'. PPG1 continues: 'Development plans..... should provide applicants with clear indications of planning authorities' design expectations. Such advice should avoid excessive prescription and detail and concentrate plan policies on broad matters of scale, density, height, massing, layout, landscaping and access'. However, local distinctiveness is to be maintained and planning authorities may concern themselves with detailed design where this may have a significant effect on the character or quality of an area. Overall it stresses that the 'aim should be for any development to result in a benefit in environmental and landscape terms'. Guidance in PPG3 (Housing) goes further: Local planning authorities should adopt policies which:

- Create places and spaces with the needs of people in mind, which are attractive, have their own distinct identity, but respect and enhance local character;
- Promote designs and layouts which are safe and take account of public health, crime prevention and community safety considerations; and
- Place the needs of people before ease of traffic movement in designing the layout of residential development.

3.3.3 'Development Plans' (PPG12) stresses that environmental issues be taken comprehensively and consistently into account, including, development plans having:

- Policies and proposals for the improvement of the physical and natural environment in urban areas, including sustaining the character and vitality of town centres, making provision for tree planting and the general revitalisation of urban areas;
- Policies which stress the need for better urban design including the appearance of proposed development and relationship to its surroundings;
- Policies which help preserve the built and archaeological heritage.

3.3.4 Government advice on Conservation Areas is to be found in PPG 15 on 'Planning and the Historic Environment'. 'The physical survivals of our past are valued and protected for their own sake, as a central part of our cultural heritage...Their presence adds to the quality of our lives, by enhancing our familiar and cherished local scene and sustaining the sense of local distinctiveness'. In relation to the demolition of buildings in Conservation Areas, It states that 'The general presumption should be in favour of retaining buildings which make a positive contribution to the character or appearance of a Conservation Area'. PPG16 'Archaeology and Planning', provides advice on archeological remains.

3.3.5 Regional Planning Guidance for the South East (RPG9) prioritises improving the quality of life in urban areas to make them attractive places to live, work, spend leisure time and invest. Within the context of the UK Sustainable Development Strategy, it emphasises the need to maximise the re-use and redevelopment of land and buildings without the loss of valued parts of the built environment and within the capacity of areas to absorb more development while maintaining and enhancing urban quality.

3.3.6 Government guidance on planning London's environment is principally provided through Strategic Planning Guidance for London (RPG3, May 1996). It identifies 14 core components contributing to the quality of London's built-environment, suggests a number of urban quality goals to be incorporated in boroughs' strategic policies. It also suggests that boroughs should, in addition to identifying buildings and areas of special quality and promoting policies for their conservation and enhancement, also acknowledge the role of conservation in regeneration initiatives.

3.3.7 The Government published 'By Design - Urban design in the Planning System: Towards Better Practice', (June 2000). It states that good urban design depends upon:

- A clear framework provided by development plans and supplementary guidance delivered consistently, including through development control;
- A sensitive response to the local context;
- Judgements of what is feasible in terms of economic and market conditions; and
- An imaginative and appropriate design approach by those who design development and the people who manage the planning process. It sets out the key objectives of urban design as:

- Character - A place with its own identity;
- Continuity and enclosure- A place where public and private spaces are clearly distinguished;
- Quality of the public realm- A place with attractive and successful outdoor areas;
- Ease of movement - A place that is easy to get to and move through;
- Legibility - A place that has a clear image and is easy to understand;
- Adaptability - A place that can change easily; and
- Diversity - A place with variety and choice.

It stated that effective policy and guidance should focus on how development form (aspects such as layout, scale and appearance) can be brought together in a particular local content to achieve the urban design objectives.
Development plans should set out general design policies implementing the overall urban design principles, and criteria against the achievement of these objectives can be judged. A UDP could also include design policies relating to specific areas, specific sites or recurrent design issues. The plan could also explain how design issues are to be managed in the planning process, such as when and how supplementary planning guidance will be prepared. The plan should also explain in what context, appraisals have been carried out, in developing policy.

3.3.8 The Urban Task Force report 'Towards An Urban Renaissance' highlighted the importance of urban design for achieving high quality dwellings at higher densities on previously developed land. Its recommendations included:

- Introducing a national urban design framework, the key princi-ples of which should be disseminated through planning and funding guidance, and supported by best practice guidelines;
- Adopting an integrated design-led approach to regeneration through pilot projects funded by Government;
- Requiring planning authorities to produce unified public realm & open space strategies, covering provision, design, management, maintenance and funding.

The DETR's White Paper, 'Our Towns and Cities: The Future - Delivering an Urban Renaissance', (Nov. 2000) set out the visions, planning policy and programmes to be pursued. A key policy is to secure better planning and design which is sustainable, to improve the quality of people's lives.

3.3.9 Other relevant Best Practice guidance includes the 'Urban Design Compendium' by English Partnerships and the Housing Corporation, which outlined key aspects of urban design focus to be considered in regenerative development projects. They are:

- Appreciating the context - Places for people: Interpreting and using character resources and local aspirations;
- Creating the Urban structure - Enrich the existing: Working with the landscape and enhancing interrelations between urban elements at every scale (city, town, neighbourhood);
- Making Connections - Sustainable movement systems: Putting foot, cycle and public transport infrastructure before cars. Also mixing uses and forms ensuring visual integration;
- Detailing the Place - Buildings and the public realm interface, and their design for change.
- Implementation - Managing the investment: Issues of viability and delivery mechanisms to ensure lasting quality.

3.3.10 The Mayor of London's Draft London Plan (DLP) June 2002, set out urban design principles for London's development as a sustainable, compact city. These include maximising the potential of sites, enhancing the quality of the public realm, promoting world class architecture and design, the sustainable use of resources, and sensitive management of London's historic assets.

3.4 POLICY OBJECTIVES

3.4.1 In accordance with the overall aim of making the Borough a more attractive place in which to live and work, the policies in this Chapter, contribute towards achieving the following objectives:

1. Reinforcing the attractive qualities of Brent's built-environment, to establish positive images and identities, and enhance the quality of life for all its inhabitants;
2. Securing a higher standard of architectural and urban design for all development, ensuring sympathetic integration within their context and respecting principal views across the Borough;
3. Promoting high quality development and investment in Brent's built-environment, particularly for areas identified as most needing improvement, to improve the sustainability and effectiveness of urban areas within the Borough;
4. Preserving, managing and enhancing the Borough's built heritage;
5. Working, in partnership with the community, to promote a sustainable, fully accessible and safe environment;
6. Raising local awareness about urban design issues, and promoting appreciation of the built environment in Brent.

3.5 BOROUGH STRATEGY

3.5.1 In line with increasing 'quality of life' expectations, the Council considers that the improvement of the Borough's environment is a very high priority. Poor environmental conditions make the Borough an unattractive place in which to live, work and play, affecting how people feel about their area, their safety and economic prospects. A poor quality environment also acts as a serious disincentive to commercial investment. A high quality environment is essential for attracting high quality investment. For this reason, the need is to focus more attention on raising the quality of urban and building design, in order to secure the long-term environmental and economic regeneration of the Borough.

3.5.2 It is also recognised that achieving this objective requires clearer design advice, and a borough-wide Urban Quality Survey was therefore carried out to inform the strategy and policies in this chapter. The Council's 'Urban Quality Survey' involved carrying-out a qualitative audit of Brent's built-environment on a thematic, representative basis (i.e. conservation, town centre, residential, open space, industrial and opportunity areas). These were assessed against a range of urban design criteria, providing a baseline of information about the conditions of various places within the Borough, and the effects of the previous policy approach.

3.5.3 The Borough strategy aims to substantially raise design standards and thereby, the quality of the urban environment in Brent. It is recognised that as development is an incremental process, higher design standards will need to be rigorously applied to all proposals for development within the borough. The strategy for achieving these policy objectives is both comprehensive and hierarchical, comprising the following key elements:

1. Promoting awareness of design issues amongst applicants, their agents (predominantly non-architects), developers and within the Council;
2. Setting a higher standard for submissions of supporting material with planning applications;
3. Providing an overall UDP policy framework for assessing the design quality of development schemes, consisting of:
- General, Borough-wide urban design policies;
- Use & topic-specific policies such as mixed-uses, etc.;
- Context-specific policies for corridors and gateways needing public realm enhancement;
- Area-specific policies such as for Conservation Areas and Areas of Distinctive Residential Character.

4. Preparing Supplementary Design Guidance to support UDP policy implementation:
- Design Strategies and Frameworks for areas in need of townscape and public realm enhancement;
- Design & Landscape Guidance for specific design issues, distinct quarters and/or character areas within the borough;
- Planning, Design & Development briefs for key sites.

5. Pursuing a higher standard of design in all new buildings and alterations to existing buildings, through development control and negotiation.



POLICIES AND PROPOSALS

3.6 DESIGN SUBMISSIONS

3.6.1 Proposals for development are put forward by a range of applicants such as; developers, design professionals, businesses and lay people, not all of whom have a detailed knowledge of the development process. To raise design standards, it is important to explicitly state what the Council's expectations are.

Design Guidance

3.6.2 The Council will from time to time, in consultation with the public and other interested bodies, issue supplementary guidance to elaborate on various aspects of urban, building and landscape design. The purpose of such guidance is to amplify policies and proposals of the Plan including detailed matters of design and layout, such as any technical standards that may be appropriate. Such guidance contributes to raising public awareness of design issues, and encouraging applicants to consider the effect of their proposed development on the quality of the local environment. The Planning Authority will use this guidance as a basis for assessing the design quality of development proposals. Proposals will be expected to have regard to this guidance, which will be a material consideration in determining planning applications.

Design Briefing

3.6.3 Effective briefing is a prerequisite for good design. Briefing is the method by which the client or developer can instruct their designers on their requirements and can realise, with professional feedback, what precise benefits are possible from a development. Proposals that are discussed early on with the Planning Authority provide an opportunity to inform the briefing stage long before designs have been formalised. Time spent on briefing can help eliminate late changes of mind and save expensive delays.

Design Presentation

3.6.4 In order to properly assess proposals for development, it is important for adequate information to be produced to a professional standard. The scope of information required to demonstrate design quality will depend on the complexity of the proposal and whether it is at outline, full or detailed stage. All proposals for development must be accompanied by the appropriate, scaled and annotated drawings of the proposed development shown in its context, as detailed in Guidance note on making a Planning Application. Significant, major or complex proposals should also be accompanied by three-dimensional (3D) representations such as an axonometric or perspective drawing, a CAD presentation and/or a portable scaled model.

3.6.5 Applicants should be aware that separate permission from the Council's Building Control unit may also be required under the Building Regulations. It is therefore important at the outset, to seek the advice of qualified architects, designers and engineers who are experienced in dealing with design and structural work.

Design Statements

3.6.6 The process of designing a development for a particular site should start with an assessment of its physical nature and local conditions. It should be followed by a rational explanation of how the development relates to the site's contextual features and contributes towards sustainability objectives. 'Off the shelf' designs and corporate styles, whether of commercial buildings or housing, which do not reflect the specific context of a place, will not be acceptable. The Council will expect applicants to have made an effort to ensure an appropriate design quality. Government guidance in PPG1 recommends the preparation of urban design statements to demonstrate that a range of design issues have been adequately considered by appropriately qualified and/or experienced designers, and that due account is taken of urban sustainability goals. The Council produced new Supplementary Design Guidance Note 4 (SPG4) to guide applicants on how to prepare full and brief Design Statements.

3.6.7 The term 'new' within the policy is intended to encompass redevelopment schemes as well as wholly new development. It does not include small domestic extensions, changes of use/conversions or refurbishment, as the built structure in these instances would either not change at all or would not change sufficiently to exert any appreciable impact.

External space steps away from gardens to reduce overlooking. Source: Pound Lane redevelopment, Design Statement, HTA.


BE1 URBAN DESIGN STATEMENTS
An 'Urban Design Statement' should be submitted for all new development proposals. On all sites of 0.3 hectare or more, and sites likely to have a significant impact on the public realm, in conservation areas, and sites affecting the setting of listed buildings or major new regeneration projects, this statement should include matters relevant to the scheme, such as:
(a) Important features (trees, hedgerows, buildings, etc) within and/or forming the edges of the site;
(b) The location and nature of existing & potential links to and through the site, to facilities outside it (Policy BE3);
(c) Important views within and out of the site, and landmarks visible outside the site;
(d) The relationship of the site to surrounding area (levels, etc);
(e) How the design relates to and enhances its urban context (Policies BE2, BE4, BE5 and BE7) as well as the concept and principles behind the architectural & landscape design (Policies BE6 and BE9); and
(f) How the development contributes to urban sustainability & regeneration (Policies BE11 and BE12).
On smaller and/or uncontroversial proposals, a brief statement of the design approach should be provided.



3.7 URBAN DESIGN PRINCIPLES

3.7.1 The plan's urban design policies do not seek to restrict design creativity. They are intended to discourage the submission of poorly considered schemes, safeguard basic amenity standards, and promote better, more sensitive design, striking a balance such that the existing character of areas is respected (where this is attractive and worth preserving), while architects and developers have the freedom to originate new design solutions where appropriate. Generally, good design will be encouraged, while obviously poor designs will be resisted. The following policies, outline the general design criteria that will be used to assess the design-quality of all applications.

3.7.2 Development proposals will be assessed with regard to their overall effect on urban quality, and should demonstrate that all the following urban design objectives have been adequately addressed:

1. Townscape: Local Context & Character (Policy BE2);
2. Urban Structure: Space & Movement (BE3 & BE4);
3. Urban Clarity & Safety (BE5);
4. The Public Realm: Landscape & Streetscape (BE6, BE7 & BE8);
5. Architectural Quality (BE9 & BE10);
6. Sustainability: Intensity, Mixed-Uses & Sustainable Design (BE11 & BE12).

1. Townscape: Local Context & Character

3.7.3 A knowledge and understanding of local context (topographical, functional and visual characteristics of an area) is necessary in order to successfully integrate new development into the built-environment. The Borough is made up of areas of distinct identities and varying quality. In an established urban area such as Brent, development proposals on most sites should examine and respond to local design and landscape characteristics derived from the landforms and natural features, colours, materials and texture, as well as the uses, heights, scale, bulk and design of buildings. The important contextual cues depend on the scale of the proposed development. More extensive proposals need to consider a wider range of general characteristics, while single infill schemes and extensions need to respond to more detailed characteristics on the particular street on which they are located.

3.7.4 Buildings in Brent express a wide variety of local design characteristics, many of which are worthy of protection, and this variety of design has been added to by new cultural groups who have introduced fresh architectural styles. Modern buildings that selectively adopt some of the characteristics of existing buildings can happily fit into many settings where the environment has been built up over many generations. In addition, good architecture is often architecture that surprises, and the Council's desire to see selective adoption of local design characteristics need not preclude the introduction of innovative designs that relate well to their surroundings.


BE2 TOWNSCAPE: LOCAL CONTEXT & CHARACTER
Proposals should be designed with regard to their local context, making a positive contribution to the character of the area. Account should be taken of:
(a) The existing landforms and natural features;
(b) The need to respect or improve the quality of existing urban spaces, materials, townscape or historical features which contribute favourably to the character of an area; and
(c) The opportunity for improvement or variety within an area of poor or uniform character, by creating a new area of distinctive quality on suitable sites.
Proposals should not cause harm to the character and/or appearance of an area, or have an unacceptable visual impact on Conservation Areas, Areas of Distinctive Residential Character, Listed Buildings, Views, Landmarks, Green Chains or Metropolitan Open Land.
Application of these criteria need not preclude the sensitive introduction of renewable technologies, innovative contemporary designs and designs which reflect the cultural diversity of the area.



2. Urban Structure: Space & Movement

Spatial Organisation

3.7.5 One of the basic principles underlying the design of urban areas is the enclosure of space by built structures, primarily buildings. Enclosed urban spaces can be visually pleasing by increasing variety and visual interest, and are experienced as being more 'comfortable' at the pedestrian scale, often contributing to a sense of 'belonging' or community, which can foster a safer, more secure environment. They can also contribute to road safety by influencing drivers' perception of speed in residential areas.

3.7.6 In order to provide an interesting and stimulating urban environment, development should create streets and spaces of varied character. The degree of enclosure achieved in public spaces within a development should be designed according to the types of spaces provided, and variation in their scale, form, treatment and edges can be used to achieve individual identity and character. Townscape features such as gateways, landmarks, level-changes, and focal points such as; prominent corner sites, can also be used to provide drama and interest, while visual linkages can be established between streets and spaces, using vistas and framed views.

3.7.7 Continuity, in terms of having regard to established building lines, is important for reinforcing the edge of spaces within the urban environment. In order to maintain enclosure, the built frontage of the street should be as continuous as possible, without large gaps between buildings or deep setbacks from the public footpaths. Variations to the building line should only be used where they can denote important or public buildings, create well-defined spaces that are both useable and pedestrian friendly, or where they serve a townscape function such as marking a junction or helping to frame a particular view.

Movement: Permeability & Accessibility

3.7.8 The first major design consideration for access to any new development, concerns the network of public routes and spaces on the edges or within the site. An important aspect of a good urban environment is its 'permeability', that is, the availability of convenient and safe, non-vehicular public routes linked to streets, facilities and amenities. The location of public spaces should help people find their way around the borough by reinforcing intersections of traffic and pedestrian routes. The permeability of the surrounding area needs to be assessed, taking account of desirable public routes through or around the site and creating opportunities to contribute to wider aspirations of cycleways or footpath networks. Any proposal which would result in the complete loss of a public route will only be acceptable if a satisfactory alternative, linked to existing facilities and adjoining public spaces, is provided, as new routes which are separated from their surroundings are more likely to be unsafe and vandal-prone.


3.7.9 It is recommended in the 1998 'Places, Streets and Movement' publication by DETR, that a Movement Framework be designed for new development, to ensure that travel on foot, by bicycle and public transport have priority, and are properly integrated within a scheme. The advantage of such a comprehensive strategy at the outset, is the safeguarding of routes for the different forms of movement, which it would be difficult or impossible to fit into the design later on.


BE3 URBAN STRUCTURE: SPACE & MOVEMENT
Proposals should have regard for the existing urban grain, development patterns and density in the layout of development sites, and should be designed to ensure that:
(a) Spaces are satisfactorily enclosed by built-form. All spaces between and around buildings should be created to be functional, and attractive for their intended users;
(b) Its layout is defined by pedestrian circulation, taking the form of urban blocks;
(c) Particular emphasis is placed on prominent corner sites, entrance points, and creating vistas and public areas; and
(d) It respects the form of the street of which it is a part, by building, or responding to the established line of frontages, unless there is a clear urban design or planning justification;
(e) Connections are established where appropriate, to open space and regard given to the potential for green landscaping.
Development layouts should also make explicit, an overall movement framework, which should:
(i) Prioritise movement by foot, cycle and public transport;
(ii) Encourage convenient pedestrian access to important civic areas by retaining existing, or providing new, routes and linkages which contribute to the permeability of an area;
(iii) Minimise traffic conflicts between vehicles, pedestrians and cyclists by ensuring a clear delineation of routes and unencumbered entrances and circulation; and
(iv) Integrate the proposed development with public transport and car parking facilities.


Access for Disabled People

3.7.10 The second major design consideration related to movement, concerns the equitable access to the development for disabled people. Equity is an important dimension of sustainability, and access is a major problem for large sections of the community, for whom parts of the environment can be unusable. The most acute disadvantage can be faced by disabled people and a significant proportion of the community (risen overall from 11.4% in 1991 to 15.6% in the 2001 census) suffer from some form of mobility disability, whether through a limiting long-term illness, age or injury. This section of the community has a basic right to use the parts of the environment that everyone else takes for granted.

3.7.11 There are a wide range of disabilities; in addition to those who are wheelchair-bound, there are the 'ambulant disabled', with impaired sight, hearing, speech or a combination of these. There are also those with disabling health problems, such as heart or respiratory conditions, rheumatism and arthritis. The elderly, pregnant women and parents with young children and pushchairs also tend to find access to the built-environment challenging. The various needs of all of these groups need to be taken into account in design decisions, as inconsiderate urban and building design has a considerable effect on the quality of life of these significant sections of the community.

3.7.12 The Disability Discrimination Act 1995, requires that buildings to which the general public are admitted, including places of employment and education, are accessible to disabled people and have suitable parking and toilet facilities. The Planning Acts, as modified by the Disability Discrimination Act 1995, requires that planning authorities draw the attention of developers to the provisions of the 1995 Act and to the British Standard BS8300: 2001 for disabled access. BS8300 and the Building Regulations 2000, Approved Document M (2004 edition) also set out minimum standards with which access provision should comply. The Disability Discrimination Act 1995 requires all providers of goods, facilities and services to take reasonable measures to ensure that they are not discriminating against disabled people. The Office of the Deputy Prime Minister has published a good practice guide for the planning system, 'Planning and Access for Disabled People'. Strategic developments should also have regard to the specific policy on inclusive design in the draft London Plan, which is supported by a draft best practise guide, 'Accessible London'

3.7.13 The standard design guidance for access for disabled people; 'Designing for Accessibility' 2004 edition, is a joint publication by CAE (Centre for Accessible Environments) and the Royal Institute of British Architects (RIBA). The Council will expect all developments and refurbishment schemes requiring planning permission to have regard to those standards which are incorporated in the Council's draft Supplementary Planning Guidance (SPG 12), but it will not impose more onerous requirements than those set by 'Part M' of the Building Regulations. This should enable disabled people to visit and use buildings and their surroundings. The Council will endeavour to improve access and facilities for disabled people and will make particular efforts to ensure that all buildings and land under its control have adequate facilities and access. Other chapters of the Plan contain specific policies on access for disabled people.

3.7.14 In addition to making the built environment accessible to disabled people, and the consequent increased opportunities this brings, good physical access benefits everyone, particularly the elderly and families with young children. Good access is good design and planning.


BE4 ACCESS FOR DISABLED PEOPLE
Developments open to the general public or used for employment or educational purposes shall include suitable access and facilities for disabled people , which should also be provided in schemes for changes of use, extensions and alterations unless practical considerations dictate otherwise.
The policy does not apply where there are separate requirements under the Building Regulations.


3. Urban Clarity & Safety

Understandable Places

3.7.15 The 'ability of users to understand a place' and find their way around it, is very important in two ways. In order to benefit fully from the choices and qualities within a townscape, people, especially visitors, need to be able to quickly understand both the layout of a place and what goes on there. Legible layouts and activities make it possible for people to form a clear mental picture of the main physical features in a place, and of the main patterns of use of buildings and spaces. Therefore, a 'legibility analysis' of a site's context is an important part of good design. This involves considering the significance and clarity of existing physical aspects such as:
- Paths (movement channels e.g: streets);
- Edges (boundaries and barriers);
- Nodes (movement junctions and meeting places);
- Districts (distinct areas, quarters);
- Landmarks (visible points of reference).
The design of a new development may integrate with or reinforce these existing features, and/or form new features, to enhance or improve an area's identity.


Well-Used Spaces

3.7.16 In order for a place to be understandable, it is also important for the function and ownership of spaces to be clear. The three main space-types are; public, private and semi-private, of which public spaces, such as streets, footpaths, squares and parks are the most important in urban design terms, because they can be used for civic activities by everyone. Private spaces, such as rear gardens by contrast, serve only the occupants of the related houses or flats for their private outdoor activities. Semi-private spaces include residents' parking areas, courtyards, driveways and/or front gardens, which usually form a privacy-maintaining buffer or transition zone between the public realm and buildings marking the beginning of the private domains.

3.7.17 The means of distinguishing between these spaces need not always involve a barrier such as a wall or fence and can often be very subtle, using changes in level or surface textures, building edges and soft landscaping to define each area. If public, private and semi-private spaces are to function effectively, these differences must be clearly discernible to their users, because unclear or ambiguous spaces lack defined ownership and often do not operate as intended, leading to problems with loss of privacy, inadequate maintenance, and inappropriate behaviour. The location of public spaces should also help people find their way around the borough by reinforcing intersections of traffic and pedestrian routes.

Community Safety & Designing-Out Crime

3.7.18 The fear and reality of crime is a major factor preventing the full enjoyment and use of the environment. A reputation for high levels of crime can also be a factor in hindering the economic regeneration of an area. Safety and the perception of safety is therefore an important issue. The Council, in cooperation with the police and the local community, is carrying out a Community Safety Programme designed to improve the safety of streets and Council premises, to minimise opportunities for crime and to raise awareness of the ways in which crime may be prevented.

3.7.19 Successful crime prevention often depends on a wide range of measures in which the planning process can assist in 'designing-out' crime at the outset of the design process. Circular 5/94 'Planning Out Crime', states that crime prevention is capable of being a material consideration in considering planning applications. It is the intention of the Council and Police Service to reduce the impact of crime within the Borough by ensuring that all development proposals have satisfactorily sought to design-out crime in line with the advice contained in Circular 5/94 and having regard to the principles of the police 'Secured by Design' initiative. Brent and the Police will seek to incorporate these measures as early as possible in the design process.


3.7.20 The large majority of all crime is committed only when the opportunity presents itself and design can play a part in deterring such crime through improved layout, lighting and more secure barriers. There is plenty of evidence that a combination of good design, management and community involvement, is a much more effective way of making the Borough safer, than the negativity of shutters, barbed wire and other physical crime prevention devices, which may provide well-fortified private spaces, but result in very hostile public spaces. The informal surveillance of public and semi-private spaces is an important community safety concept recognised by the 'Secured By Design' Police initiative, and is best achieved when buildings front onto these spaces, and when these front elevations also contain the main entrances. In order to further crime prevention and to enhance personal security,

3.7.21 The Council will assess development proposals according to the criteria set out in policy BE5 and having regard to its Supplementary Planning Guidance (SPG10) Community Safety. Where appropriate, conditions will be attached to permissions, requiring the residential and/or commercial elements within a development to comply with the relevant British Standards and with the aims and objectives of 'Designing-Out Crime' and/or 'Secured by Design' principles.


BE5 URBAN CLARITY & SAFETY
Development should be designed to be understandable to users, free from physical hazards and to reduce the opportunities for crime, incorporating the aims and objectives of both 'Secured By Design' and 'Designing-Out Crime' concepts, such that:
(a) Clear relationships are created between existing and proposed urban features outside and within a site, so that users know how to move into and through the development;
(b) Public, private and semi-private spaces are clearly defined in terms of their use and control;
(c) The informal surveillance of public and semi-private spaces around buildings is maximised through the positioning of fenestration, entrances and other forms of overlooking;
(d) Front elevations should address the principal adjoining streets containing, where possible, habitable rooms and actively-used main entrances, with private areas to the rear of the property. Significant areas of blank walls and parking should be avoided on back-of-pavement locations.;
(e) Entrances are overlooked by development, provided with good lighting and are visible from the street;
(f) Rear gardens do not adjoin public space, or if not possible, should have a secure barrier;
(g) Parking spaces are provided within view of properties, and if not possible are made safe in other ways, and are not normally accessible via the rear gardens of residential properties; and
(h) Public spaces and accessways through or adjoining a site are overlooked by development, provided with good lighting, set away from cover and provide clear sight lines, and should not run next to rear gardens.



4. The Public Realm: Landscape & Streetscape

3.7.22 The 'public realm', as distinct from the private domain, refers to all the physically and visually-accessible space such as; forecourts, streets, pavements, squares, parks, open spaces and the facades of the buildings, or other structures, that define them. It is, as the main setting for human interaction, arguably, the most important part of the built-environment. However, as evidenced from Brent's Urban Quality Survey 1999, the quality of the public realm in some locations within the Borough has continued to decline; from the proliferation of fly-posting, graffiti, advertisement & signage clutter, mediocre and poorly maintained buildings, desolate public spaces, traffic congested streets and lack of pedestrian vitality particularly at night. This has led to perceptions of insecurity and an increasing tendency towards 'gated' developments in the private realm. In order to reverse these trends, special attention needs to be paid to the design and maintenance of the landscape and streetscape.

Landscape

3.7.23 The quality of the built environment is greatly enhanced by considering site planning and the integrated use of hard landscape (e.g. paving, street furniture) and soft landscape (trees, shrubs, grasses) treatments at an early stage in the design process. These need to be designed in relation to the arrangement of spaces, their usage, access, circulation and safety criteria, bearing in mind the overall location of a scheme. Applicants are advised to seek professional advice from a qualified landscape architect, regardless of the scale of the development.

3.7.24 The landscape of a site and the street frontage provide the setting for buildings and make an essential contribution to what constitutes the character of an area. Soft landscaping is at a premium within the town centres and other urban parts of the Borough. In addition to the ecological, aesthetic and micro-climatic benefits, established vegetation helps integrate architecture with the urban landscape, adding to development value.

3.7.25 The Council is committed to retaining and preserving the best of the Borough's landscape which has taken years to reach maturity, and will ensure that all new developments make a positive and continuing contribution to the Borough's landscape character and that as many existing landscape features as possible are retained. Ensuring adequate maintenance and management schemes for landscape is of particular importance (Circular 11/95). Existing vegetation usually needs less maintenance and management than new planting, and the species contribute to the existing character of the area. Through the use of conditions and legal agreements the Council will seek to protect and retain trees, shrubs, and hedgerows (see also policy BE32). Where trees and other landscape features are identified for retention, it is very important for appropriate contracting and site supervision procedures to be in place to protect them from damage during and after construction. This is an integral aspect of the design and implementation of the development. The Planning Authority will expect the details of such arrangements to be provided in a Landscape Method Statement.
3.7.26 The quality and suitability of new planting is also crucial to ensuring the ongoing sustainability of the Borough's landscape. Use of semi-mature or advanced nursery stock will be particularly important for screening and boundary treatments. Care will be needed with security fencing which should not create an oppressive effect and should be softened by planting. The Council will adopt Supplementary 'Landscape Design Guidance', during the Plan period.



BE6 PUBLIC REALM: LANDSCAPE DESIGN
A high standard of landscape design is required as an integral element of development schemes. This will be expected to include:
(a) A design which reflects the way in which the area will be used and the character of the locality and surrounding buildings;
(b) An adequately landscaped frontage (including trees and shrubs) on commercial developments outside town centres;
(c) Retention of existing mature trees, shrubs and hedges, particularly where these form part of the character of an area;
(d) New planting of an appropriate specification (species, size, density of planting) with semi-mature or advanced nursery stock;
(e) New, integrally-designed, structural landscaping on appropriate larger sites ;
(f) Boundary treatments such as: fencing, railings, etc. which complement the development and enhance the streetscene;
(g) Screening of access roads and obtrusive development from neighbouring residential properties; and
(h) Approval of any landscape scheme and implementation, management and/or maintenance programmes, before work on site commences.


The Street Environment

3.7.27 The frontage and setting of buildings forms an essential part of the street scene, being also important environmentally particularly through the absorption of runoff and dust particles. Although the Council seeks to ensure a safe, accessible and informative street environment for all residents, visitors and tourists, in terms of suitable surfaces, adequate signage and sufficient facilities, it does not have control over parts of the street and trunk roads managed by statutory undertakers and the Highways Agency.

3.7.28 Lamposts, seats, traffic signs and other items of 'street furniture' are necessary and useful, but increasing numbers and poor design and siting can create clutter, detracting from the appearance of the street scene. In recognising that street furniture can add interest, provide information and make a positive contribution to the quality of the physical surroundings, the Council has made considerable efforts to eliminate clutter from the streets by reducing the number of signs and posts. The Council also tries to ensure that all such items are well designed and located. Where street furniture is the responsibility of statutory undertakers then the Council will use its influence in this regard. In sensitive areas, such as Conservation Areas, the design of lamp posts and of seating can greatly assist in preserving and enhancing local character. Regard will be had to 'Streets for All', a guide to the Management of London's Streets' prepared by English Heritage with the active involvement of the London Boroughs. It gives best practice guidance on street management issues. In the siting of street furniture the access requirements of the utility providers will be taken into account.

Residential Street Frontages

3.7.29 Many residential parts of the Borough have an open suburban character, which is deserving of protection. Random extensions and developments which fill in the spaces between buildings can gradually erode this character. In order to retain the open character of streets and street junctions and to retain an adequate space for landscaping, the flank and rear walls of properties should be set in by 2m from the edge of the property where this adjoins a street, unless the wall would follow the building line of an adjoining property. (The normal 2m set-in may be reduced to 1m in certain densely developed parts of the Borough).

3.7.30 Maintaining adequate green space between a building and the road is important but there is great pressure to use this space for other purposes: hard-standings and crossovers, road widening and so on. Forecourt parking is a particular problem: the pressure to avoid on-street parking must be balanced against a number of other factors, especially the need to preserve adequate front green space. Where Permitted Parking Areas are introduced, the Council will consider the use of Article 4 Directions (see Glossary) to protect the contribution of forecourts to the street scene (see also policy TRN15 on forming an access to a road).

3.7.31 As well as protecting the existing streetscape, the Council will endeavour to enhance street planting. This will be particularly important in the case of major developments where it is not possible to provide landscaping on site.



BE7 PUBLIC REALM: STREETSCAPE
A high quality of design and materials will be required for the street environment. The design and provision of all important street elements and furniture (including public art) will be coordinated, wherever possible, to make a positive contribution, avoid unnecessary clutter, and ensure a safe, informative and attractive environment.
Public realm improvements, including street furniture, public art and the planting of new street greenery will be promoted and encouraged. Where appropriate, through Planning Obligations, the enhancement of the public realm that forms the setting for significant and major developments, will be sought, particularly in areas requiring improvement to the public realm or with low tree coverage.
Within residential areas, the following will be resisted (both for existing and new developments) where they would detract from the character of the area and where planning permission is required:-
(a) The excessive infilling of space between buildings and between buildings and the road;
(b) The loss of paving, front walls, railings or hedges of character and common to the street, which should be restored or reproduced where practical;
(c) Hardsurfacing occupying more than half of a front garden area; and
(d) Forecourt parking, where this would cause (b) or
(c) And where such parking would detract from the streetscape or setting of the property, or create a road/pedestrian safety problem.
In Conservation Areas and in Areas Of Distinctive Residential Character, a high quality of street furniture will be required to preserve or enhance the character of these areas.


Lighting & Light Pollution
3.7.32 The imaginative use of lighting can be a powerful way of showcasing buildings, landscape and topographical features, defining routes and boundaries as well as emphasising views and landmark features. It can thus make a significant contribution towards the Council's objective of improving the overall experience of major areas within the Borough, beyond the daylight hours. This will require considering the lighting within Wembley, and other centres such as Kilburn, Harlesden and Cricklewood, taking account of their night time economy, safety, security, desired image, residential amenity, energy use and light pollution, as a whole.

3.7.33 Lighting is essential in many instances for security reasons as well as for traffic and pedestrian safety, and is just as important for enhancing buildings of architectural and historic significance. Poor or insensitively designed schemes can, however, lead to 'light pollution' where excessive amounts of lighting diminish the integrity of the night-time sky, and result in unnecessarily high energy consumption. Where there is a danger of this, lighting should be designed to minimise glare and spillage, and kept to the minimum required for security and operational uses. Applicants are referred to the Institute of Lighting Engineers' Guidance Notes for the Reduction of Light Pollution. It may also be desirable to screen lighting installations from neighbouring residential areas and roads, and consider minimising the visual impact of lighting apparatus on daytime views through the height, width, design, location and surface treatment.


BE8 LIGHTING & LIGHT POLLUTION
Sensitively designed proposals which create and improve lighting are encouraged where it contributes to the overall spectacle and image of major areas such as Wembley and enhances the experience of town centres with significant night time uses, such as Kilburn, Harlesden and Cricklewood.
Development proposals should however, conserve energy through the use of low energy or renewable lighting systems where appropriate, and should preserve the darkness of the night time sky, particularly near Metropolitan Open Land and Public Open Spaces. and Lighting should be controlled to avoid nuisance to road users, harm to residential amenity and/or detriment to local distinctiveness.
Where appropriate, conditions will be used in controlling the intensity of lighting to avoid nuisance to road users, harm to residential amenity and/or detriment to local distinctiveness.


5. Architectural Quality

3.7.34 The Council is keen to promote high quality architectural design, in order to improve living and working conditions and raise the profile of Brent. This section covers aspects of architectural design which can impact significantly on the quality and vitality of the spaces in between them. Although it is not appropriate for design policies to prescribe particular styles of architecture, it is still necessary to provide guidance on the main principles to be observed, for instance, in the form and elevational treatment of buildings, to ensure a good quality and harmonious composition in various locations. A surprisingly high number of buildings do not benefit from the design skills of architects, and creativity can often be stifled by clients' preferences for standard pattern book or corporate solutions. Design policies which require the exercise of architectural skill, innovation, and artistic creativity and expression, can therefore serve as a useful tool for securing more innovative, site-specific design solutions.

3.7.35 The Council wishes to promote respect for local character in the design of new buildings by ensuring that they are in harmony with their settings and surroundings, particularly where these affect open spaces that contribute strongly to the character of the Borough. Amongst those local design characteristics which should be assessed are the: siting, orientation, plot width, footprint, major proportions, detailing, roofscape, fenestration scale, emphasis and rhythm of adjoining development. However, respect for local design characteristics need not mean slavish replicas with no element of originality, or the use of characteristic traditional features unrelated to any overall design concept. In particular locations, including industrial and commercial areas and some main road frontages, a bold, innovative design which does not clash with the surrounding area, may serve to add visual interest. In areas with poor character and environments, the introduction of fresh architectural styles can be beneficial, and the introduction of high quality innovative designs will be encouraged where these can positively contribute to the appearance of the Borough.

Use, Civic Function & Location

3.7.36 Most new buildings should not dominate the townscape of established urban areas, but blend carefully into them. Notable exceptions in which the use or function of a particular building may justify a greater significance in the townscape, include important public buildings, such as town halls, libraries, theatres, religious buildings & sports centres. The size and scale of new buildings should therefore be related to their public importance and location. This does not preclude changes in scale or massing for a design purpose, such as closing a vista or corner-site treatments to provide a local landmark building.

Materials

3.7.37 The use of appropriate materials is also important for integrating a new building with its surroundings. The choice of facing materials should include proper consideration of their quality, fixing methods, colour, texture and profile. In all cases, durability, water run-off, and the ability to withstand weathering, must be considered, in addition to their aesthetic suitability. The Council is concerned to ensure that buildings do not deteriorate in appearance because of inadequate materials and detailing, and will favour the use of durable materials wherever possible. Some finishes and elevational treatments, e.g. highly reflective glass, may therefore not be appropriate in sensitive locations such as within Conservation Areas and Areas of Distinctive Residential Character.

Extensions & Alterations to Buildings

3.7.38 The design of extensions and alterations should start with an appraisal of the existing building, in order to produce a complementary and harmonious addition. The Council will need to be satisfied that matters of detail have been fully considered from the start. Extensions are covered by Policy H24 in chapter 5 and SPG5: Extending Your Home. Detailed design advice on conversions and amenity considerations in new residential development is provided in SPG17: Residential Design Standards.


BE9 ARCHITECTURAL QUALITY
New buildings, extensions and alterations to existing buildings, should embody a creative and appropriate design solution, specific to their site's shape, size, location and development opportunities, and should be designed to:
(a) Be of a scale, massing and height that is appropriate to their setting, civic function and/or townscape location;
(b) Respect, whilst not necessarily replicating, the positive local design and landscape characteristics of adjoining development, and satisfactorily relate them;
(c) Exhibit a consistent and well-considered application of the principles of any chosen style;
(d) Have attractive front elevations which have a direct relationship with the street at ground level, with well-proportioned windows, and habitable rooms and entrances on the frontage, wherever possible;
(e) Be laid out to ensure that buildings and spaces are of a scale, design and relationship to each other, which promotes the amenity of users, providing a satisfactory level of sunlighting, daylighting, privacy and outlook for existing and proposed residents; and
(f) Employ materials of high quality and durability, that are of compatible or complementary colour and texture, to the surrounding area.
Particular attention will be given to these matters in Areas Of Medium-High Townscape and Public Realm Quality (See paragraph 3.8.3), in areas abutting Green Chains and Metropolitan Open Land, and for proposals affecting Conservation Areas, and Areas Of Distinctive Residential Character.


High Buildings

3.7.39 Although it is recognised that high buildings can act as landmarks and focal points, and can play an important economic role, the Council considers that new development should generally respect, though not necessarily replicate, the traditional scale and character of the existing surroundings. High buildings are considered appropriate only in a few locations in the Borough where their impact can be contained and where they would contribute towards overall regeneration. In sensitive areas, the likely effect of high buildings on Listed Buildings and Conservation Areas for instance, will determine their appropriateness. Policy BE10 sets out the framework for considering building heights.

3.7.40 There is no formal definition of a High Building, but they are generally taken to be more than 25m high (82 feet or 9 storeys) or of any height which significantly exceeds that of the surrounding development. Different parts of the Borough are sensitive to different building heights and this is reflected in Policy BE10. The Council will consult other London boroughs on proposals for buildings over 40m (133 feet) in the Wembley Regeneration Area and on proposals for buildings of over 30m (100 feet) elsewhere in the Borough. The Council will also consult the GLA, the Commission for Architecture and the Built Environment (CABE), and English Heritage on proposals for high buildings in general; the Ministry of Defence for buildings covered by the Town and Country Planning (Aerodromes and Technical Sites) Direction 1992, and British Waterways for buildings in or visible from the Grand Union Canal Corridor. In the event of the Council receiving a planning application for an exceptionally high structure or building (over 91m or 300 feet), the Council will consult the Civil Aviation Authority. By virtue of the Town and Country Planning (Mayor for London) Order, the Mayor of London will need to be notified of buildings in the Borough over 30m in height.

3.7.41 The combined effect of a concern to restrict high buildings to locations where their impact can be contained and of other policies in the Plan, particularly that on major purpose built offices (EMP15), is to restrict tall office buildings to the Wembley Regeneration Area which has very good public transport access appropriate to such development and can accommodate the visual impact of such buildings. The design of modern industrial plant may also create the need for high buildings, for this purpose Park Royal is identified as an appropriate area. Other areas where high buildings might be acceptable in environmental quality terms, such as the low lying areas around the North Circular Road, are not identified in the Plan as appropriate locations for high density uses.


BE10 high buildings
High Buildings (over 25m) are most appropriate where their visual and other impact can be accommodated. Preferred locations are the Wembley Regeneration Area & the Park Royal Area (inset plans). Such proposals should:

(a) Be of outstanding architectural and urban design quality, with a distinct profile and roofscape, preferably emphasising a point of civic or visual significance, or a centre of urban activity, transport interchange or regeneration;
(b) Be set in the context of, and be carefully related to, its surroundings, both existing and proposed, and to any other high buildings in the locality and to open space;
(c) Secure a complete and well designed setting of lower buildings and/or landscaped open space, so that it interacts in a positive manner with, and contributes to, its surroundings at street level;
(d) Avoid marring the skyline or intruding to the detriment of local, medium and long-distance views of important landmarks (see Policy BE34);
(e) Avoid a significantly harmful effect on the microclimate, and amenities of the area, through matters such as turbulence, noise reflection or overshadowing;
(f) Demonstrate how the design contributes to sustainability objectives (see Policy BE12);
(g) Avoid blocking important telecommunications channels, without mitigating measures;
(h) Take into account, in their design and location, relationship to airports and air routes, drainage and water channels, communication and transport links, and industrial plant and chimneys;
(i) Have regard, in their location, height and design on their impact on the character (including setting) of Listed Buildings and Conservation Areas; and
(j) Provide, where appropriate, a design statement (See Policy BE1) and a visual impact study including photomontages and maps of areas from which the building would be visible.


3.7.42 High buildings can be an asset if well designed and properly located. They should preferably be located where they mark a gateway or transport interchange, terminate a key view or emphasise a location of civic importance. They should be distinctive and memorable enough to act as orientation features within the townscape, and clearly distinguishing and articulating their roofscapes and street level podiums to visually break up their overall height into 3 recognisable sections. For religious buildings, a flexible approach will be taken to the inclusion of spires, minarets, domes, etc. which can provide a visual focus to a development and reflect its function and the visual diversity of the Borough.

6. Sustainability: Intensity, Mixed Uses & Sustainable Design

Higher-Intensity Development

3.7.43 Until recently, high density urban development has been associated with poor quality environments and the numerous social problems of the high-rise residential blocks. Increasingly however, the positive features of urban density and concentration of uses has begun to be recognised as essential to successful urban areas. Indeed, providing the design is of sufficient quality, higher-intensity development produces some of the most sustainable of human habitats. Intensive urban uses allow people to live and work in close proximity, reducing car trips. In addition, they encourage economic and social interactions leading to widespread regeneration benefits. Environmentally, many of the most attractive and sought after urban areas in London, and more widely, are well-managed high-density neighbourhoods. In appropriate locations, therefore, it is important to use the intensity, or density, of development as a positive planning tool to reinforce the economic and social potential possessed by individual areas. This approach is also encouraged by more recent government policy guidance, and well-designed schemes will be welcomed.

Location & Types of Mixed Uses

3.7.44 Mixed-use developments enhance the quality of urban areas by ensuring a vital mix of uses, which enhance the richness of experience for those living or working there. Mixed uses can also aid community safety and contribute to other planning objectives such as the provision of housing and the achievement of vital and viable town centres, as well as a reduction in car use through increased pedestrian activity. In fact, reducing the need to travel is another key benefit of developing a mix of land uses. The benefits of having a mix of land uses at the neighbourhood scale are that it enables people to walk or cycle to local facilities and may even encourage people to live and work locally. In a neighbourhood with a mix of uses not every building will have more than one use: quiet, single use residential streets still have a key role.

3.7.45 This section indicates where and in what circumstances sites should be developed with a mix of land uses, what additional uses (e.g. 'secondary uses') should co-exist with the primary use, and the main design considerations. The sites most suitable for development with a mix of uses in Brent are those where an existing mixed-use character can be built upon, as in town centres, or where opportunities mean that they can be newly established. Selectivity is crucial because, as RPG3 notes, where a development involving a mix of uses is located where it encourages cross-commuting trips by car, the benefits of a mix are lost. The policies only apply where the plan does not already stipulate a particular use or range of uses on a site. It therefore, does not normally apply in Strategic & Borough Employment Areas (SEA/BEAs), nor in Hospital and Higher/Further Education (HFE) zones (which in any event are often partially self-contained developments with a mix of uses). The preferred locations are within Areas of Very Good & Good Public Transport Accessibility (as defined in the Transport chapter, section 6.7).

3.7.46 The primary use will depend on design considerations, such as the prominence of a use within the site, just as much as floorspace. Where public transport improvements in the form of significant additional facilities (such as additional access points or enlarged station facilities) are provided, these will also be considered as a secondary use meeting the aims of the policy. Also where large developments of a public or institutional nature contain within them significant ancillary activities which reduce the need to travel (e.g. gift shops and cafes) these can also be said to satisfy the policy, providing the development as a whole complements the mix of uses in the area.

3.7.47 It is recognised that the exact mix and proportion of uses will vary in different locations and that, in some circumstances, addition of secondary uses(s) will not be practical; such as where it cannot be physically achieved on the site because of the operational needs of the primary user. The nature of a development, including the sub-categories within a use class, can also be considered as to whether a secondary use is required. The secondary use should be appropriate to the site's location e.g. a town centre use open to visiting members of the public, in or adjoining shopping centres; or a priority use (Policy STR1). Occasionally, an innovative secondary use may be proposed which complements the site and area so well that those uses listed above may not be required. The Council will use phasing or other conditions to ensure secondary uses are implemented.

Design of Higher-Intensity & Mixed-Uses

3.7.48 Careful design is necessary in higher-intensity and mixed-use developments, to preserve the quality and amenity of individual units/users and because some combinations of uses are not as compatible as others. The careful juxtaposition of uses will be crucial to the success of mixed-use schemes. Where the vertical 'stacking' of uses is the most appropriate way of achieving a mix, the issue of the design and arrangement of uses is particularly important. The relationship between food and drink (A3) uses and residential uses requires special attention (See Policy SH10). Some uses require separate ground floor access to achieve the benefits of mixed use in terms of variety and pedestrian access.



BE11 INTENSIVE AND MIXED-USE DEVELOPMENTS
Proposals for higher densities than that prevalent in the surrounding area will be encouraged in appropriate locations, which will include town centre locations in Areas of Very Good & Good Public Transport Accessibility (as defined in the Transport Chapter section 6.7), and transport interchanges (Policy TRN6). Proposals in these areas are encouraged to include a mix of compatible land uses.
Proposals in the above locations, or for a change of use, that fail to incorporate an appropriate element of secondary use(s), where single uses would undermine the existing character or prejudice the regeneration prospects of an area, will be resisted, taking into account:
(a) The scale and nature of the proposed development relative to the mix of land uses in the surrounding area, and
(b) The feasibility of incorporating secondary use(s) given the nature of the primary use and the site characteristics.
Particular attention will be paid to the design of intensive and mixed-use developments, which should achieve a satisfactory relationship between individual units and uses in terms of their layout, stacking, the adjoining area(s) between them, and protection of the amenity of adjoining and proposed residents.
Uses open to visiting members of the public (such as shops and food and drink uses) should be located to have a significant ground floor window display and entrance.
Residential accommodation (other than live-work) should be functionally independent of commercial or business uses and should be separately accessed at street level.


Sustainable Design & Construction

3.7.49 Urban sustainability depends on the way towns and buildings are built, maintained and used. The DETR's 'Building a Better Quality of Life: A Strategy for More Sustainable Construction' (2000) recognised that buildings contribute directly and indirectly to the consumption of energy and resources and to environmental pollution, affecting our activities, health and well being. Buildings designed and constructed sustainably are now recognised as likely to provide healthier and more comfortable conditions. However, although Sustainability Appraisals were required of Development Plans, this was not applied to development proposals, beyond Environmental Impact Assessments (EIA) for the largest, most important schemes. Regional Planning Guidance for the South East (RPG 9) 2001, also recognises that: 'The design of individual developments will be a major influence on the extent to which they are sustainable...' (Para. 5.9).

3.7.50 The environmental and social effects at each stage of modern building and development processes can include for example:

- Energy consumed from heating, lighting and ventilation of buildings;
- Detrimental effects of winning raw materials (mining/quarrying) on the environment;
- Adverse effects of many modern building materials and ser-vice systems on people's health (e.g. sick building syndrome);
- Pollution from air-conditioning and heating systems used in buildings;
- Waste generated during the demolition (90 million tonnes in 1998), construction and operation of buildings.

3.7.51 The Council therefore expects applicants to consider sustainability issues from the early site-analysis and concept-design stages of their proposals, as well as throughout the detailed design and specification process. Attention from an early stage is crucial, as schemes cannot be redeemed at the latter stages if the conceptual design has not addressed sustainability issues. This is not always a straight-forward process and nearly always involves some kind of environmental trade-off.

3.7.52 The layout of new development can do much to promote energy conservation and hence reduce the emissions of greenhouse gases by, for example, orientating buildings so that principal habitable rooms face south, thus maximising passive solar gain. Further information can be found in the DETR/DTI design guide 'Planning for Passive Solar Gain'. It is also important that servicing, refuse storage arrangements and landscaping are duly considered.

3.7.53 Buildings can also be orientated so as to minimise heat loss from prevailing winds. It is also important that new buildings do not disrupt local movement patterns or cause air turbulence problems, and applicants should demonstrate how it is intended to minimise or mitigate any adverse conditions. High buildings deserve special attention, as it is now widely acknowledged that they exert significant impacts (e.g. concentration of pollutants, sunlight reduction, wind deflection, energy consumption), making sustainability an important consideration in assessing their acceptability at the local level.

3.7.54 Developments involving passive or active solar installations may have Building Regulations implications, so advice should be sought from Building Control. They may also require planning consent. Where proposed on listed buildings, in conservation areas or other sensitive settings, care should be taken to ensure no harm is caused to the character of such buildings or areas.

3.7.55 Even at the local level, urban design interventions can help reduce the impact of air pollutants, and positively affect micro-climatic conditions. When locating particular uses and features (play areas, sports fields, sitting areas used often or for long periods by elderly and the sick, outdoor cafes, bus stops, building entrances, windows, intake-vents), attention should be given to their sensitivity to air pollution. Preventative or ameliorative measures should be adopted when these uses are to be located near places liable to suffer from high emissions (heavily trafficked streets and busy intersections, taxi stands, bus depots, tunnel or garage entrances, exhaust vents and locations upwind of polluting industries), as well as in designated Air Quality Management Areas (see also Policy EP3 in chapter 4).

3.7.56 Developers should pay special attention to sound insulation between converted dwellings (party walls and floors) and within mixed-use developments, as much higher insulation levels will be needed at the boundaries between commercial and residential units.

3.7.57 In the long term, improving built environment sustainability could bring social and economic as well as environmental benefits for example, potentially providing employment for many people through large-scale insulation, renovation and de-construction programmes.

3.7.58 The Council has published Supplementary Planning Guidance on 'Sustainable Design, Construction & Pollution Control', (SPG19) covering design for sustainable use of energy, water, building materials, site practices and pollution control measures (noise, land contamination and air quality). This is accompanied by a development control Checklist for developments meeting specific thresholds. A best practice Householders guide has also been published. These will assist residents, designers and builders to save energy and water, to reuse materials or choose sustainable materials for refurbishment, extension and new build projects in the Borough, and to minimise nuisance and pollution during and after construction.

3.7.58 Applicants for strategic developments referable to the Mayor of London, should also address the sustainable design, energy and other relevant policies set out in the draft London Plan, and its proposed strategic best practice guide.


BE12 SUSTAINABLE DESIGN PRINCIPLES
Proposals should embody sustainable design principles, commensurate with the scale and type of development, including taking account of:
Sustainable Design
(a) Incorporating built forms, technologies, orienta-tion and layout that will contribute to reduced energy consumption (e.g. ventilation, heating/ cooling, lighting) and associated emissions;
(b) Avoiding negative micro-climatic effects (e.g. wind turbulence, noise reflection);
(c) The potential for the re-use of existing buildings and materials and environmental effect of building materials used;
(d) Making adequate, integrally-designed provision for the storage and recycling of waste;
(e) The potential for the management or recycling of water;
Sustainable Construction
(f) Methods to protect important flora, fauna and/or topographical features during construction and to minimise disturbance to local amenity;
(g) Methods to maximise recycling and re-use, as well as minimising waste during demolition and construction;
Pollution Control
(h) Sustainable remediation of brownfield sites redeveloped for sensitive uses, will be sought, and where contamination remains in-situ, a monitoring regime will need to be agreed;
(i) Measures to minimise the impact of poor air quality on sensitive users in Air Quality Management Areas (See Policy EP3); and
(j) Noise levels from traffic, trains (near railway lines) or other significant noise-generators.
In assessing the sustainability of schemes under these headings, regard will be had to the supplementary planning guidance.



3.8 Priority AREAS for Townscape & Public Realm Enhancement

Urban Quality in Brent

3.8.1 In recent years, planning in Brent as in many other Boroughs, has tended, to focus more attention and resources, on conserving the best of its built heritage. Whilst these efforts have not had a uniform effect in all of Brent's designated conservation areas (in terms of preventing the erosion of some historical or architectural features), there has undoubtedly been a significant level of success in maintaining, and in some areas even enhancing, the quality of their townscape and public realm.
3.8.2 The Council's 'Urban Quality Survey' 1999, has revealed the very considerable discrepancy that now exists between the quality of buildings and spaces within designated heritage areas, and the predominantly poor environment in the other areas of the borough. This serves as a clear indication of the importance and success of design and planning controls in securing a quality environment.

Areas Of Low Townscape or Public Realm Quality

3.8.3 Beyond the designated heritage areas, there are contexts of varying quality, which require a comparable level of positive design policy and development control in order to effect a higher standard of urban and building design. Priority design areas are therefore being designated to facilitate targeted policy attention. The first of these are Areas of Low Townscape or Public Realm Quality indicated on Map BE1. Areas identified as being of low quality will be prioritised for townscape and public realm enhancements and innovative contemporary building design. Within these areas, in order to encourage their environmental regeneration, planning standards (density, parking, etc.) may be more flexibly applied, provided developments are of the highest design quality. Other areas not identified on the map, are Areas of Medium-High Townscape and Public Realm Quality and, for proposals within them, the contextual criteria in Policies BE2 & BE9 will be more strictly applied.


BE13 AREAS OF LOW TOWNSCAPE OR PUBLIC REALM QUALITY
Particular regard will be had to the design and attractiveness of all development proposals in Areas of Low Townscape or Public Realm Quality (See Map BE1). Development proposals within these areas will be expected to:
(a) Have an independence of form and design, make a positive design statement and show creative use of materials;
(b) Create, where appropriate, new compositions and points of interest, being disciplined, however, by the existing building lines and the overall scale of the area; and
(c) Have regard to any approved Enhancement Strategy for the area and make a contribution towards its implementation (in terms of external works and landscaping), public realm enhancement commensurate with the scale of the proposed development.
The Council will produce Townscape & Public Realm Enhancement Strategies for Areas of Low Townscape or Public Realm Quality.


Transport Corridors & Gateways

Grand Union Canal Corridor

3.8.4 The Grand Union Canal runs for approximately two miles through Brent. Throughout its length it represents an important recreational and ecological resource. Although the character of the canalside environment can be poor, it offers great potential for quality waterside developments and the Council is intending to conduct a canal corridor study in conjunction with British Waterways to explore this potential further. Policy OS5 in Chapter 5 considers development of the canal in relation to its function as a green chain. Policy PR4 covers the canal in Park Royal. The policy below also sets out the Council's requirements regarding the provision of moorings on the canal. Opportunities to create moorings may arise through the development process, particularly in the major canalside redevelopment areas covered in the Park Royal Chapter (Chapter 13). Non-residential moorings do not require planning permission but they can be regulated through planning obligations associated with canalside developments.



BE14 GRAND UNION CANAL CORRIDOR
Developments adjoining or visible from the Grand Union Canal Policy Area (as shown on the proposals map) should wherever possible:
(a) Be designed to benefit from and complement canalside settings through, where appropriate, development 'facing' the canal;
(b) Enhance or create views through and from the development, from and towards the canal;
(c) Provide landscaping and pedestrian routes to parts of the development site adjoining the waterside;
(d) Conserve structures and features associated with the working life of the canal.
Development should not reduce the navigable area of the canal nor cantilever or bridge over the towing path or canal except for road, railway or footbridges.
Residential moorings will be permitted on the non-towpath side or in new basins or marinas and should not interfere with navigation or other uses of the bank. Non-obtrusive servicing and infrastructure should be provided.


Road & Rail Corridors

3.8.5 The continual upgrading of the Borough's image for visitors (including potential investors) and residents is an important prerequisite for regenerating the local economy. For many visitors the lasting impression of places in Brent is gleaned as they travel into and through the Borough. These corridors and gateways also affect the quality of life of residents who use them on a daily basis. Major transport corridors link places in Brent to the rest of London and also divide the Borough into sectors. They therefore, often serve as important paths and districts in their own right. It is important to define a 'beginning' and 'end' to corridors, in order to establish or enhance local character and identity, and create a good impression.

3.8.6 Public realm enhancements in designated corridors will be achieved through a combination of design and planning control (negotiating improvements to proposals) and Council initiatives (planning and highway powers or other direct actions). The Council will prepare urban design frameworks for these corridors and development briefs for key sites along them, in order to:
- Provide a better experience and first impression for visitors;
- Guide, orientate and inform visitors about areas, attractions and facilities both along the route and in the main town centres before arrival;
- Improve and/or reinforce the character and identity of parts of, or entire, corridor areas;
- Ensure co-ordinated enhancement of their public realm; and
- Promote the provision and use of public transport.
Transport corridors are indicated on Map BE2. The enhancement of Olympic Way within the stadium precinct, is covered by policies within the Wembley Regeneration Area Inset (Chapter 14).

Main Gateways

3.8.7 Gateways can help provide an identifiable definition of these qualities. In order to develop these gateways, a collaborative and co-ordinated urban design approach will be required for the purposes of:
- Creating an enhanced sense of arrival and welcome;
- Creating a series of structures to serve as landmarks;
- Identifying suitable levels of signage;
- Reflecting the enhancement strategies for individual corridors;
- Responding to development opportunities on adjacent sites;
- Enhancing the quality of the public realm.
The main gateways are at major road junctions and are also shown on Map BE2. The Park Royal North-Western Gateway is covered by policy PR6 within the Park Royal Inset (Chapter 13).


BE15 TRANSPORT CORRIDORS & GATEWAYS
Particular regard will be had to the design and attractiveness of all development proposals in the vicinity of, and visible from Transport Corridors.
The following road and rail corridors (See Map BE2) are priorities for Townscape and Public Realm enhancement during the Plan Period and where opportunities arise, attractive views and important local landmarks should be opened up from these corridors:
1. North Circular Road;
2. Harrow Road;
3. Kilburn High Road;
4. The Stadium Access Corridor;
5. From Fryent Way, Dudden Hill Lane & Willesden High Road to Willesden Lane;
6. The Chiltern Line (between Sudbury & Willesden Green stations);
7. The Jubilee & Metropolitan line (between Wembley Park & Willesden Green stations); and
8. The Euston West Coast Line (between Willesden Junction & Wembley Central).
Urban Design Frameworks will be produced for each Corridor and for the Main Borough Gateways, to guide the form of development and ensure a co-ordinated enhancement strategy.


3.8.8 Certain special policies for protecting and/or enhancing the public realm in specific areas (e.g. Olympic Way) are set out in the Inset Plan chapters. The Council is also undertaking, in partnership with other bodies, enhancement schemes in industrial estates, town centres and housing estates. These are covered in more detail in the relevant chapters of the plan.


BE16 OTHER PUBLIC REALM INITIATIVES
Public realm enhancements will be supported in the parts of the borough with rundown and/or unattractive environments. Within these areas the following will be undertaken or supported:
(a) Schemes to introduce new, or improve existing, greenspace;
(b) Traffic calming and traffic management schemes to reduce conflicts between motor vehicles and pedestrians;
(c) Improvements to street furniture and street lighting;
(d) Measures to improve industrial and commercial servicing; and
(e) schemes of townscape improvement, particularly in the main shopping areas.
Priorities for small scale improvement schemes will be those which:
1) Will provide or improve greenspace in deficient areas; or
2) Address severe localised pockets with poor environments outside the areas chosen for comprehensive public realm improvement; or
3) Promote improvements suggested by the local community.


3.9 OTHER STRUCTURES

Plant, Ventilation & Air-Handling Equipment

3.9.1 This includes all building services equipment likely to have an impact on the external environment. Generally, every effort should be made to accommodate all plant, equipment and ducting within existing buildings and structures, making use of all internal voids and spaces, before considering external options. All new buildings such as shops, restaurants, offices and industrial premises should include appropriately designed service ducts to provide unobtrusive ventilation, servicing and cabling. Where external ducting and pipework is unavoidable, flank or rear wall locations are preferable, depending on their visibility and provided such equipment does not obscure windows, are not inserted within visually sensitive windows, or result in loss of daylight or outlook to neighbouring properties. Roof level equipment should not cause unacceptable damage to the character and appearance of the proposed building, or those in the locality. Where acceptable, it should be located in the least conspicuous position, include adequate screening and should be designed as an integral part of the overall form and appearance of the building. Thought should also be given to servicing and access requirements for all plant.


BE17 BUILDING-SERVICES EQUIPMENT
All air-cooling, heating, ventilation, extraction and conditional systems, as well as any ancillary plant, ducting and equipment likely to be visually intrusive, should in the first instance, be accommodated within the internal envelope of proposed buildings.
Where this is not practicable they should be located in visually inconspicuous positions, with a minimal effect on the use, character & appearance of proposed and nearby buildings, and local amenity.
Where building services equipment cannot be satisfactorily relocated or 'designed-out' through the use of passive systems, then it should be considered as part of an overall integrated architectural design.


Telecommunications Equipment

3.9.2 Telecommunications are a rapidly growing and increasingly essential component of modern economic infrastructure. London's future will be increasingly dependent upon it being a hub of a world wide information network. Government advice on Telecommunications is given in PPG8 revised in 2001; this seeks to balance the need to foster the growth of telecommunications with the protection of amenity. It requires development plans to be alive to the growth and characteristics of modern telecommunications.

3.9.3 Most satellite dishes and other minor telecommunications developments do not require planning permission, being permitted under the Town and Country Planning General Development Order (GPDO) 1995. Planning permission is required in Conservation Areas that are subject to Article 4 directions. The Government proposed changes to the GPDO for satellite (not mobile phone) and other antennas in 2003, but these have yet to be finalised.


BE18 SATELLITE DISHES
Applications for satellite dishes should satisfy the following criteria, being:
(a) As small in size and as few in number as possible;
(b) Shared by as many users as is feasible;
(c) Located as unobtrusively as possible, usually on the rear elevation of buildings, and not visible above the apex of the roof;
(d) Located so as not to interfere with doors or windows of neighbouring properties; and
(e) Removed as soon as they become obsolete.
Satellite dishes will only be permitted on Listed Buildings, if it can be demonstrated that they would not harm any features of special architectural or historic interest which it possesses.
In view of the need to preserve or enhance the character or appearance of conservation areas, they are unlikely to be acceptable on the front elevations of buildings within Conservation Areas.


3.9.4 Quite different considerations apply to proposals by licensed telecommunications operators. These run a national public service network with many systems operating on a line of sight basis requiring frequent base stations and relays. Preferably, such equipment should be located on existing tall buildings but, when masts are to be used, the Council will expect the potential for mast sharing to be explored fully in order to avoid their proliferation. Part 24 of the General Permitted Development Order 1995, dealing with telecommunications was amended in 1998 (SI 2001). The amendments are explained in 'Circular 4/99: Planning for Telecommunications' (July 1999). Advice on the siting of satellite dishes is available as part of the Council's Supplementary Planning Guidance. Where satellite dishes require planning consent the Council will seek to minimise their often considerable visual impact.

3.9.5 The Council will, with information from the Radio-communications Agency and Radio Sites Databank, draw up a register of existing masts and other structures (such as roof sited base stations), to which new telecommunication apparatus could be attached. It is also recognised that the location of such equipment on residential tower blocks can give rise to radio and television interference. PPG8 makes it clear that such interference is a material planning consideration when not covered by other legislation. Regard will be had to the potential impact of development on those sites. Site-sharing, rather than mast sharing, may be more appropriate in some cases for environmental or planning reasons. Technical or design factors may, in other instances, also indicate a new site entirely. Particular attention will be given to screening and planting, and sites will need to be large enough to accommodate such landscaping.

3.9.6 To protect visual amenity in sensitive areas, where it is deemed preferable for mast development to be confined to one site, the Council may, where practicable, encourage operators to enter into a planning obligation with the relevant landowner to ensure the site remains available for sharing. Where a ground-based mast is to be erected within Brent's Conservation Areas or Sites of Special Scientific Interest, the amendments to the regulations have now introduced a requirement for operators to make 'An application for the Planning Authority's determination concerning prior approval of siting and appearance'. This is also required before the installation of certain apparatus under permitted development rights. The Authority has a fixed 56-day period in which to determine whether or not 'prior approval' is required, and notify the operator of its decision.

3.9.7 It is a condition of the prior approval procedures that equipment should be sited so as to minimise its effect on the external appearance of any building on which it is installed. This will particularly apply in those sensitive areas listed in Policy BE19. If, in the view of the Council, the equipment has not been so sited then it may require its re-siting. The installation of such apparatus on listed buildings will require listed building consent which, if this damages the character of the building, will not be given. Factors to be considered concerning the appearance of the mast and ancillary apparatus include materials, colour and design. The use of appropriate materials and colour may help make a mast less obtrusive, and the planning authority will also consider the overall shape of the apparatus and effect of either a solid or open framework construction.

3.9.8 The Government-commissioned Stewart Report (May 2000) from the Independent Expert Group on Mobile Phones, considered effects from their use and from associated technology. It concluded "the balance of evidence indicates that there is no general risk to the health of people living near to base stations on the basis that exposures are expected to be a small fraction of the guidelines." It recommended a precautionary approach on the basis of gaps in current scientific knowledge. The Government accepted this and requires all new facilities to meet guidelines by the International Commission on Non-Ironising Radiation Protection (ICNIRP) set in accordance with the precautionary approach. Local authorities may not set their own unilateral moratoriums or limits on such development.


BE19 OTHER FORMS OF TELECOMMUNICATIONS DEVELOPMENT
In considering applications for other forms of telecommunications apparatus, the following will be taken into account, in so far as is technically and legally feasible, whether:
(a) The operator has explored the possibility of erecting antenna on existing buildings or other structures;
(b) The operator has explored the possibility of sharing an existing mast,replacing it with one suitable for joint use, or of erecting one suitable for joint use;
(c) So far as practicable, any mast and/or equipment is sited and designed so as to minimise their visual impact on the skyline and setting;
(d) Reasonable steps have been taken to ensure that the minimum number of pieces of apparatus are erected;
(e) Technologies to miniaturise and or camouflage equipment have been fully explored;
(f) The proposal includes a statement stipulating that the facility when operational will not exceed INCIRP guidelines for public exposure; and
(g) There is clear evidence that significant electromagnetic interference will arise, or will probably arise, and that no practical remedy is available.
The visual impact of telecommunications apparatus will be minimised upon Listed Buildings, Areas Of Distinctive Residential Character and Metropolitan Open Land.
Proposals to locate ground-based masts within Conservation Areas or Sites Of Special Scientific Interest, or in close proximity to schools or hospitals, must be accompanied by adequate information for assessment and special justification for such a location demonstrating that there are no alternative sites.


Advertisements

3.9.9 As PPG19 (Outdoor Advertisement Control) emphasises, outdoor advertising is essential to commercial activity, but advertisements tend by their nature to be prominent and can be unsuitable in some locations. They can, however, enliven drab surroundings, screen eyesores and sometimes may offer an opportunity to improve the environment, for example by including landscaping on the site. The Council will assess advertisement schemes solely by the statutory criteria of amenity and public safety. The policies below give an indication of the key amenity and safety issues relevant in the Supplementary Planning Guidance on Advertisements published by the Council.


BE20 ADVERTISEMENT ON BUILDINGS
Advertisements (including awnings) on buildings will only be approved when designed to be in keeping with the scale and character of the building, and surrounding area, and limited to avoid an excessive display. Large signs on flank walls at a high level will not be approved.
Shop signs should be confined to fascia level and no more than one small projecting box sign per frontage will normally be allowed (see also Policy SH21).



3.9.10 Poorly located advertisement hoardings can be particularly obtrusive and may in some cases pose a danger to traffic. It is therefore necessary to restrict the types of location where such hoardings will be permitted. Supplementary guidance (SPG7) Shop-fronts & Shopsigns deals with shop advertisements & security features.

3.9.11 As explained in Supplementary Guidance (SPG8): Advertise- ments other than Shops, advertisement hoardings are only likely to be acceptable if they enhance the appearance of an area. Freestanding hoardings and hoardings on buildings must therefore satisfy the criteria within Policy BE21 and SPG8. The acceptability of other types of advertisement (on street furniture, pole signs, etc) also depends on their ability to make a positive contribution to the local environment and criteria are set out in the guidance document.


BE21 ADVERTISEMENT HOARDINGS
Advertisement hoardings and other freestanding advertisements will only be approved where they enhance the appearance of an area. Public realm enhancements, such as landscaping or public art, will be sought by a planning obligation, as part of advertisement hoarding schemes. They will not be approved in the following areas:
(a) Predominantly residential areas;
(b) On or adjacent to conservation areas and listed buildings;
(c) On open space, or where they would block important views across it, or where they would obscure other important views, landscaping or groups of trees;
(d) Where it would lead to advertisement clutter, detract from public realm enhancements within the area and/or prejudice regeneration initiatives;
(e) On railway embankments; and
(f) On major roads and road junctions where distraction to drivers could be prejudicial to highway safety.

continue to next part of Chapter 3

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