PART 2 - 3. ENVIRONMENTAL PROTECTION AND OPEN SPACE
   
PART 2 POLICIES
EP7 Renewable Energy (date of deletion 28th September 2007)
EP8 Energy Conservation and Efficiency (date of deletion 28th September 2007)
EP9 Water Quality, Supply and Disposal (date of deletion 28th September 2007)
EP10 Sustainable Urban Drainage (date of deletion 28th September 2007)
EP11 Development within Floodplains
EP12 Control of Surface Water Run-Off
EP13 Culverting and Deculverting
EP14 Development Within Areas at Risk from Sewerage Flooding
EP15 Water Conservation
EP16 Waste Management, Disposal and Recycling Facilities
EP17 Waste Generating Activities (date of deletion 28th September 2007)
EP18 Landfilling (date of deletion 28th September 2007)
EP19 Aggregates (date of deletion 28th September 2007)
EP20 Use of Previously-Developed Land
EP21 Vacant and Disused Land and Buildings
EP22 Contaminated Land
EP23 Dangerous Substance Establishments and Major Accident Hazard Pipelines
EP24 Air Quality (date of deletion 28th September 2007)
EP25 Noise
EP26 Habitat Creation and Enhancement
EP27 Species Protection
EP28 Conserving and Enhancing Biodiversity
EP29 Tree Masses and Spines
EP30 Tree Preservation Orders and New Planting
EP31 Areas of Special Character
EP32 Green Belt-Acceptable Land Uses
EP33 Development in the Green Belt (date of deletion 28th September 2007)
EP34 Extension to Buildings in the Green Belt
EP35 Major Developed Sites in the Green Belt
EP36 Agriculture
EP37 Re-Use of Existing Buildings in the Green Belt
EP38 Recreational Uses in the Green Belt
EP39 Land for Recreation in the Green Belt
EP40 Buildings for Indoor Recreation Use in the Green Belt
EP41 Green Belt Management Strategy
EP42 Watling Chase Community Forest
EP43 Green Belt and Metropolitan Open Land Fringes
EP44 Metropolitan Open Land
EP45 Additional Building on Metropolitan Open Land
EP46 Green Chains
EP47 Open Space
EP48 Public Open Space
EP49 Allotments
EP50 Informal Areas of Open Space
 
  INTRODUCTION
3.1 Over millennia human activities, most of which relate to land use in some form, have interrupted and at times come into conflict with natural processes. In recent years the scale of disruption and potential consequences have become increasingly apparent: climate change, habitat loss leading to an increasing number of species becoming endangered or extinct, resource shortages, and pollution. These global impacts have local consequences. There is a need to ensure that development does not cause the environment, on which we depend for resources such as air, water and land, to deteriorate further. All development has some environmental impact. To protect global and local ecosystems from irreversible damage adverse impacts must be kept at levels that do not disrupt natural processes to the extent whereby they can no longer function, or function properly, and are unable to recover. This requires closer consideration to be given to the relationship between development, infrastructure and resources than has been given in the past and, in particular, the implications of proposals for water and energy supply and use, waste, pollution, land and wildlife. At the most basic level sustainable development is concerned with safeguarding natural resources, and maintaining or improving air, land and water quality.
   
  NATIONAL & STRATEGIC CONTEXT
3.2 Policies in this Chapter aim to provide a development framework that contributes to achieving the UK Government's objectives and targets for sustainable development, as set out in 'A Better Quality of Life', the UK Strategy for Sustainable Development'. Realising these objectives will bring significant social and economic, as well as environmental benefits. For example, energy efficient buildings can help address fuel poverty, by providing affordable warmth; reduce costs of heating, ventilation and lighting to businesses; and use less fuel for a given area of space. Recycling has the potential to create jobs at many skill levels: in collection, sorting, reprocessing and reuse of materials. PPG1 states that a sustainable planning framework should conserve cultural and natural resources, including 'wildlife, landscape, water, soil and air quality'.
3.3 Government policy acknowledges the growing contribution renewable energy has to make in providing secure, diverse and sustainable energy supplies and to reducing greenhouse gas emissions and pollution (PPG22: Renewable Energy, 1994). The South-East region, of which Harrow forms a part, imports much of its energy from elsewhere, and lacks sufficient generating capacity to meet its own supply requirements; this is likely to continue for the foreseeable future (RPG9: Regional Planning Guidance for the South East, 2001). Boroughs are advised that development plans should include proposals for renewable energy resources; promote energy efficient measures as part of the design and form of development; and encourage energy efficient technology, such as combined heat and power to form part of major new build or development proposals.
3.4 Links between development and water supply, quality and availability have long been recognised. Planning has an important role to play in safeguarding water resources by providing a framework that ensures development does not have adverse impacts on watercourses, water quality or lead to flooding and secures a more sustainable approach to water supply, quality, use and drainage. Flooding can endanger lives and cause damage to property. PPG25: Development and Flood Risk (2001) emphasises the positive role of land use planning in reducing flood risk, by guiding, regulating and controlling development so that it does not increase flood risk. Authorities are advised to apply the precautionary principle to decision making and to consider how climate change may affect flood risk over the lifetime of developments. It is also acknowledged that watercourses perform important roles in nature conservation, including acting as Green Chains and Green Corridors, as well as being wildlife habitats in their own right.
3.5 Watercourses, river corridors and their associated floodplains provide important habitats to both people and wildlife alike. As landscape features they perform an essential function in both conveying water during normal flows and accommodating and attenuating flood waters.
3.6 The Waste Strategy 2000, for England and Wales, provides the statutory framework for waste management decisions and emphasises the importance of managing waste according to the best practicable environmental option. PPG10 Planning and Waste Management (1999) - describes the role of the planning system in achieving sustainable waste management as being to provide a planning framework that enables adequate provision to be made for waste management facilities to meet society's needs for waste re-use, recovery and disposal, taking account of the potential for waste minimisation and particular needs with regard to special waste. Land use planning should complement, but not duplicate the licensing system. A Municipal Waste Strategy for London will form part of the Mayor's Spatial Development Strategy. As a statutory document, future decisions regarding waste management proposals will need to take account of this.
3.7 Securing the effective use of land, including remediation of contaminated land, and appropriate use of vacant and derelict land, has long been a key aim of planning. Government policy places increasing emphasis on the importance of ensuring development takes place on previously developed land, in order to protect the quality of urban and rural environments (PPG1 and PPG3: Housing).
3.8 The Pollution Prevention and Control Act 1999 introduced a new system of pollution prevention and control with the aim of implementing EC Directive 96/91 to achieve integrated pollution control across Europe. Planning and pollution control regimes are intended as separate but complementary regimes. The role of planning is to consider the potential for pollution to affect land use, for example, for development or agriculture. Matters affecting a planning permission may also be relevant to a pollution control authorisation or licence. PPG23: Planning and Pollution Control (1993) indicates how, by determining the location of potentially polluting development and restricting development in proximity to sources of pollution, public health and sensitive environments can be protected, while ensuring industry does not face unnecessary constraints.
3.9 Biodiversity is not restricted to sites with recognised nature conservation status but occurs all around us. Back gardens, grass verges, river and railway embankments and vacant sites may all contain a rich variety of habitats and species. While national policy instruments and action are important, it is largely through action at a local level that biodiversity is lost or conserved.
3.10 As PPG9: Nature Conservation (1994) points out, 'attractive environments, where attention is given to nature conservation, are essential to social and economic well-being. With careful planning and control, conservation and development can be compatible.' Despite having a rich diversity, many species and habitats in the South East are threatened or declining ('The Biodiversity of South East England: An Audit and Assessment, 1998). To protect biodiversity it is necessary to go beyond protecting what is already there: losses must be reversed and habitats restored or created. A London-wide Biodiversity Action Plan, co-ordinated by the London Biodiversity Partnership includes audits of species against criteria which include threat, decline, local distinctiveness and appeal. The Mayor of London has produced a Biodiversity Strategy for London (Connecting with London's Nature, July 2002), which local authorities are required to pay due regard to.
3.11 Trees and woodlands conserve and enhance biodiversity, help maintain or improve air quality, provide opportunities for recreation and enhance the landscape and cultural heritage. PPG2: Green Belts (1995) acknowledges the role of community forests in providing opportunities for recreation and supporting wildlife.
3.12 PPG2 outlines the role of Green Belts, in contributing towards more sustainable patterns of urban development, by protecting the countryside and uses such as agriculture and forestry, and restricting urban sprawl. Highly valued by successive Governments, as essential elements in planning policy, Green Belts have contributed many other benefits helping to safeguard attractive landscapes, recreational opportunities, and nature conservation sites. The Countryside and Rights of Way Act 2000 establishes a statutory right of access to open country and registered common land and contains important provisions relating to nature conservation. The Act increases the protection given to Sites of Special Scientific Interest (SSSIs), strengthens wildlife enforcement legislation, introducing tougher penalties and stronger powers for enforcement agencies and provides a statutory basis for biodiversity conservation.
3.13 Areas of open space perform essential roles within, and on the edge of, urban areas and encompass small informal spaces, cemeteries and allotments as well as parks and playing fields and larger areas of land designated Green Belt and Metropolitan Open Land. PPG17: Sport and Recreation (1991) indicates that the Government does not consider an open space use of land as less important than any other land use. Open space contributes to quality of life in urban areas, regardless of whether or not it has public access. In recent years many urban parks have suffered neglect the London Plan calls for a positive approach to open spaces in order to enhance their characteristics and value. Nationally, and London-wide there is considerable variation in the level and quality of open space. Much of inner London lacks sufficient provision to meet local residents' needs. Due to a shortage of certain types of open space, such as allotments and playing fields, residents may rely on provision in outer London Boroughs to gain access to these facilities. (PPG17 : Planning for Open Space, Sport and Recreation, July 2002).
3.14 An Environmental Impact Assessment (EIA) enables the environmental effects of developments to be systematically assessed and for certain types of development is a statutory requirement. All proposals listed in Schedule 1 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations (1999) require an EIA. In addition, Schedule 2 proposals which meet certain criteria or thresholds or which the local authority considers likely to give rise to significant environmental effects also require an EIA. Schedule 2 proposals include shopping centres and car parks, leisure centres, multiplex cinemas, railways, roads, groundwater abstraction and installations for waste disposal. Developers may request a 'screening opinion' from the planning authority on whether an EIA is needed prior to submitting a planning application. This should be accompanied by a plan identifying the site of the proposed development; a brief description of the nature and purpose of the development and its possible effects on the environment; and any other information the person making the request may wish to provide.
3.15 There may be concern regarding the impact of proposals which, while they might not require an EIA, due to their nature, scale and local circumstances, would require the local planning authority to be provided with information on the nature of such impacts in order to determine whether a proposal is acceptable. Such impacts might relate to air, land and water quality, flood risk, transport and ecological impact or other matters. Details are given elsewhere in this Chapter and in the Transport Chapter (T6). Regardless of whether or not an EIA is required, proposals will be expected to demonstrate compliance with all relevant policies.
  3.16 The regional strategic planning context is provided by the spatial development strategy for London, the Mayor's London Plan (February 2004). The policies in this chapter have been drafted in the light of the vision, objectives and strategic policy content of the Plan.
   
  ENVIRONMENTAL PROTECTION AND OPEN SPACE OBJECTIVES
3.17 I) To promote a pattern of development that is energy and resource efficient, reduces reliance on fossil fuels and other non renewable resources, and maintains or enhances air, land and water quality to a standard that is beneficial to human health and wildlife;
  2) To conserve and enhance biodiversity and natural heritage in the Borough and ensure residents have opportunities to enjoy nature, close to where they live where this does not conflict with nature conservation aims;
  3) To protect and enhance areas and features of structural importance to the Borough; and
  4) To maintain and improve the distribution, quality, use and accessibility of public and private open spaces in the Borough.
   
  PART 1 POLICIES
3.18 Strategic policies for Environmental Protection and Open Space (SEP1 to SEP6), and reasoned justifications, are set out in Chapter 2 of the Plan. They cover the following matters:-
  SEP1 - Energy Use and Conservation
SEP2 - Water
SEP3 - Waste - General Principles
SEP4 - Biodiversity and Natural Heritage
SEP5 - Structural Features
SEP6 - Areas of Special Character, Green Belt and Metropolitan Open Land.
   
  PART 2 POLICIES
  ENERGY
  Renewable Energy (Date of deletion 28th September 2007)
  EP7 THE COUNCIL WILL REQUIRE NEW DEVELOPMENTS TO BE SO DESIGNED AS TO MAXIMISE THE POTENTIAL, TO THE EXTENT THAT THIS IS PRACTICABLE, VIABLE AND CAUSE NO UNDUE HARM TO THE ENVIRONMENT OR RESIDENTIAL AMENITIES, OF RENEWABLE ENERGY SCHEMES SUCH AS MAKE USE OF SOLAR ENERGY, PHOTOVOLTAICS AND NATURAL VENTILATION.
   
3.19 Buildings account for more than half of all energy used in the UK and travelling between them a further quarter. Extraction and quarrying of building materials also use significant amounts of energy. Design, layout, and location of development impact significantly on energy use and can constrain or create opportunities for using renewable energy sources.
3.20 Renewable energy has a significant part to play in meeting UK targets for reducing greenhouse gas emissions. National targets are to generate 10% of electricity from renewable sources by 2010 and 10,000 MWe (megawatt equivalent) Combined Heat and Power generating capacity installed by 2010. To ensure the Borough contributes its share of the UK target the Council will require new developments to incorporate renewable energy features where practicable and cost effective.
3.21 Passive solar design is a proven technology that need cost no more than conventional designs. It makes the most of the sun's natural heat and light, a building's orientation and available shade to ensure the optimal environment for occupants. Design costs may be slightly higher, but construction costs may be lower as savings may be made in other areas (e.g. less extensive or no air conditioning required). Energy bills in passive buildings are considerably lower. Grants are often available which cover or contribute to the cost of passive solar design. Electricity supplied from renewable sources will, in most cases, be exempt from the Climate Change Levy.
3.22 The Government's focus on renewable energy has increased, and has been reflected in the Energy White Paper (February 2003), and the Mayor's draft Energy Strategy (January 2003) and other sustainable energy strategies. The Council encourages and emphasises the need for much greater energy efficiency and a growing reliance/progression on renewable energy sources such as solar energy, wind power and bio energy to meet the UK target for carbon reduction. The Council will facilitate and promote energy installations in the borough to:
A) promote sustainable energy from these beacon installations; and
B) raise awareness of renewable energy within the broad community.
3.23 Active systems, such as photovoltaics, are cost competitive for certain types of development: for example, where used instead of decorative cladding around office buildings, capital costs are similar, or in the case of prestige cladding, less. Running costs of such buildings are much less. Costs of active systems are falling rapidly. Therefore new developments should be designed, as far as practicable, to enable these to be installed sometime in future. Renewable energy and energy conservation should be seen as complementary. To realise the full benefit of renewable systems installed or planned for it is essential that developments are specified to a high standard of energy efficiency. Photovoltaics are capable of meeting most of or even exceeding the power (electricity) requirements of a building that is designed to a high level of energy efficiency and where energy efficient appliances and practices are subsequently used and adopted.
3.24 Technologies are being developed that allow electricity to be generated from windpower without requiring large structures to be prominently sited on hill tops and, due to their low visual impact, are particularly suited to urban and suburban situations. These utilise building envelopes and a concentrator system and comprise an array of small turbines which remain largely (or completely) hidden and can be combined with other renewable energy technologies, such as photovoltaics, to meet most of a building's energy needs. As technological constraints are overcome, other types of renewable energy, such as fuel cells and geo-thermal energy will offer increasingly viable alternatives. Although modest in terms of individual energy output, small scale renewable energy schemes have an important contribution to make in reducing reliance on fossil fuels and in fostering diversity of supply. Their cumulative impact over the long term could be significant.
3.25 PPG22: Renewable Energy (1993) indicates that when determining planning applications for renewable energy, local planning authorities should consider the impact on the local environment and the wider contribution to reducing greenhouse gas emissions. In addition, each authority is to consider the contribution their areas can make to meeting need on a local, regional and national basis.
3.26 Developers will be referred to Supplementary Planning Guidance for examples of designing for passive and active solar and natural ventilation, and renewable energy schemes. In applying this policy, the Council will take into consideration site characteristics, which in some circumstances may limit options available. Developers for their part will be expected to show how they have utilised layout, design and orientation and any other appropriate measures, in their proposals, as far as practicable, to meet the requirements of the policy. These are not intended to be prescriptive, but to demonstrate what is possible, and developers may wish to look elsewhere for examples of good practice to draw upon. Advice on grants will also be published.
  Energy Conservation and Efficiency (Date of deletion 28th September 2007)
  EP8 DEVELOPMENT PROPOSALS SHOULD MINIMISE ENERGY USE THROUGH APPROPRIATE DESIGN, LAYOUT, ORIENTATION, DENSITY AND LOCATION.
   
3.27 Planning has an important role to play in securing more energy efficient development. Design, layout, orientation, density and location of development can have a significant impact on energy use. Trees can act as wind barriers or provide shade from the sun. Energy efficient design is partly, but not wholly, covered by Part L of the Building Regulations. It is important that all parties consult one another early in the development process. For example, passive and active solar buildings may have particular infrastructure requirements that need to be considered at an early stage in the design process by appropriate specialists, e.g. service engineers. Energy efficiency measures can be achieved in development of all kinds, ranging from domestic extensions to major commercial or residential schemes.
3.28 Well-insulated buildings, designed to maximise natural light and ventilation, use less fuel and offer superior comfort to occupants at lower cost than their artificially controlled counterparts. Where developments require an Environmental Impact Assessment, a life cycle assessment or whole life costing should be submitted as part of this, taking into account energy used in materials (embodied energy), construction, maintenance and subsequent use and include energy from transport associated with these activities. A range of good practice guides and case studies covering most aspects of energy efficiency are available free from the Building Research Establishment (BRE). These include:-"Briefing the Design Team for Energy Efficiency in New Buildings" (GPG21), "Energy Efficiency in New Housing" (GPG96 and GPG79), (GPG 173), "Environmentally Smart Buildings - A Quantity Surveyor's Guide" (GPG 274), "Passive Solar Estate Layout (GIR27), "Passive Solar House Design" (GIL22), "Energy Efficient Design in New School Buildings and Extensions-for Schools and Colleges" and "Using Solar Energy in Schools" (GIL16).
   
  WATER
  Water Quality, Supply and Disposal (Date of deletion 28th September 2007)
  EP9 THE COUNCIL WILL NOT PERMIT DEVELOPMENT WHICH IT CONSIDERS LIKELY TO HAVE AN ADVERSE EFFECT ON:
    A) RIVER CORRIDORS, OR
    B) THE WATER OR ECOLOGICAL QUALITY OF RIVERS, LAKES, GROUNDWATER OR OTHER WATER AREAS,
    WHETHER BY SURFACE OR WASTE WATER DISCHARGE, DISTURBANCE OF CONTAMINATED LAND, OR OTHER ACTIVITY (INCLUDING ABSTRACTION)
   
3.29 Maintaining or enhancing the water quality of rivers, lakes and ponds is essential to human health, to the health of the environment and a wide range of activities. Poor or deteriorating water quality can affect water supply for domestic, industrial and agricultural uses, general amenity, opportunities for water-based recreation, fisheries and nature conservation. The chemical quality of watercourses in Harrow ranges from poor to fair and improvements are needed. Sewer/drain misconnections, whereby foul water discharges into and pollutes watercourses, have been identified as a major cause of poor water quality in the Borough. Improved development practices need to occur alongside other changes, including greater public awareness of the need to conserve and avoid polluting water; identifying and rectifying misconnections between sewers and drains and reducing the amount of water lost through leaks.
3.30 The Council will encourage proposals that enhance and protect the water environment for the purposes of conservation, recreation and habitat improvement. Developers will be expected to ensure their proposals do not harm the water quality of rivers, lakes and other water areas and to take any steps necessary to prevent this. The river corridor must be retained and where possible restored such that no development will be permitted within 8 metres of top of bank of main rivers, or within 5 metres of ordinary watercourses.
3.31 Water environments are important wildlife habitats and make a valuable contribution to biodiversity. The Council will need to be satisfied that proposed development will not harm the aquatic environment before granting permission and may, by condition or agreement, require measures to be taken to protect or improve water quality through better management or sensitive planting, to protect and enhance ecological quality and biodiversity. The Council, in conjunction with the Environment Agency, will seek to restrict development that would have a detrimental impact upon habitat value and biodiversity, both of which are dependent on good water quality. Every opportunity will be taken to environmentally enhance the value of the river corridors whether in relation to development proposals through the planning process or through other Borough initiatives.
3.32 Groundwater provides an invaluable source of water for public supply and industry and sustains the base flows of streams and rivers, but can become polluted as a result of activities such as the disposal of effluent in soakaways, landfilling of unsealed sites over permeable bedrock or inappropriate chemical storage. Large underground structures constructed below the water table should include drainage systems capable of allowing groundwater to by-pass the structure without any unacceptable change in groundwater levels, or flow to groundwater-fed streams, ditches or springs. Since cleaning up contaminated groundwater is difficult and expensive, the Council, after consulting with the Environment Agency and North Surrey Water/Three Valleys Water will aim to prevent or reduce the risk of groundwater pollution by ensuring measures taken are adequate and, if necessary, withholding consent for developments that would pose an unacceptable risk to groundwater quality.
3.33 Proposals should make adequate provision for water supply and waste water treatment, ensuring an adequate supply to serve the development without detriment to existing water abstractions, groundwater levels or surface water flows, ground and water quality, fisheries amenity and nature conservation; and should be consistent with the long term management of water and wastewater services.
  Sustainable Urban Drainage (Date of deletion 28th September 2007)
  EP10 NEW DEVELOPMENT AND REDEVELOPMENTS WILL BE EXPECTED TO INCORPORATE SUSTAINABLE URBAN DRAINAGE SYSTEMS WHERE PRACTICABLE.
   
3.34 The Borough's surface water drainage infrastructure is generally considered to be under-capacity and liable to frequent surcharge. Conventional drainage systems, designed to carry surplus water away as quickly as possible, can result in poor run-off quality and overflow where drains feed into sewers with insufficient capacity. This results in an uncontrolled discharge to the receiving watercourse. During times of high rainfall the response to the watercourse is rapid, which increases the risk of flooding. Sustainable Urban Drainage Systems (SUDS) provide a way to drain without causing flooding (or with less risk of flooding) or polluting watercourses. Their widespread introduction would lead to significant improvements in water quality, amenity and biodiversity. SUDS can reduce costs by reducing the need to invest in additional surface drainage and sewerage infrastructure and, during times of heavy rainfall, for pumping stormwater - which is expensive and uses a considerable amount of energy. Types of sustainable urban drainage range from the relatively simple water butt to more complex arrangements involving porous surfaces, infiltration devices, swales, basins and ponds. SUDS can take the form of, or be integrated with, water and landscape features, such as ponds, reedbeds and wetlands, providing habitats for plants and wildlife and enhancing the amenity and nature conservation value of developments.
3.35 RPG3 pointed out the need for development to be planned so that it does not run ahead of the necessary provision of water supply and infrastructure. SUDS control the volume, speed and quality of run-off at source or before it reaches watercourses, are closer to natural drainage patterns and can include rainwater harvesting and grey water recycling, which reduces water demand. SUDS can help recharge groundwater, which in turn helps sustain river flows. Where existing infrastructure, for sewerage, drainage and water supply, is close to capacity, SUDS may enable development to be built to a higher density than would otherwise be the case. SUDS should be considered in the first instance for all sites over and above traditional piped systems. There are many types of SUDS and which is appropriate will depend on factors such as site characteristics and the nature, scale, and location of development proposed. However the Council recognises that there may be occasions when SUDS is not an appropriate system for the drainage of surface water from the site. The Council will consult with the Environment Agency, sewerage undertakers and water authorities, including seeking ecological advice, regarding the implementation of SUDS.
3.36 The presence of natural water features, such as ponds and rivers can improve amenity and provide plant and wildlife habitats and thus have an important contribution to make towards environmental quality. There is likely to be considerable potential for creating and restoring water features, through, for example, deculverting, creating wetlands and ponds including as part of regeneration and development proposals.
3.37 PPG25 points out that consideration of SUDS at all levels of the planning process can lead to opportunities for imaginative and attractive developments. Consideration needs to be given, at an early stage in the design and planning process, to integrating sustainable drainage systems into the overall site concept and layout; the need for investigation and remediation of contaminated land; and maintenance, operation and monitoring over the long term. Further guidance on SUDS is set out in the Environment Agency's publication "Sustainable Urban Drainage - An Introduction" (1999), also in "Sustainable Urban Drainage-Design Manual for England and Wales" and "Sustainable Urban Drainage-Best Practice Handbook" both published by Ciria in 1999. Developers are advised to consult the Environment Agency, highways authorities and water undertakers for advice on suitable techniques for particular development proposals and locations.
   
  FLOOD RISK
3.38 Primary responsibility for safeguarding land and property against natural hazards, such as flooding, lies with the owner. Operating authorities are empowered to carry out flood defence works in the public interest. In Harrow, operating authorities are the Environment Agency, for the main rivers, and the local authority responsible for ordinary watercourses and highways drainage.
3.39 Government policy as set out in "The Strategy for Flood and Coastal Defence" aims to provide a framework to reduce risks to people and the developed and natural environment from flooding by encouraging adequate flood warning systems, economically sound and sustainable flood defence measures and discouraging inappropriate development in areas at risk of flooding. The Government considers developing in high risk areas unsustainable, indicating that no public funds are available for flood defence measures in anticipation of future development as public subsidy is allocated to reduce the risk to existing developments.
3.40 Where material considerations outweigh flood risk, any flood defence measures necessary would have to be provided as part of the development, including arrangements for their long-term maintenance. High level targets set by the Ministry of Agriculture, Fisheries and Food (MAFF) for flood operating authorities (local authorities, internal Drainage Boards) and Environment Agency regions include the requirement for authorities to prepare policy statements showing how they intend to respond to flood risk and meet Government objectives regarding flood and defence.
3.41 Planning authorities are advised to consider circumstances where changes of use or managed retreat of flood defences, to allow floodplains to flood naturally in order to store and gradually release water, would be appropriate. Restoring natural floodplains is likely to play an important part in the sustainable management of flood risk over the long term.
3.42 The Environment Agency has published proposals for a flood alleviation scheme within the catchment of the Silk Stream, which includes the Edgware Brook tributary. The scheme covers a wide area in the north east of the Borough and in the adjoining London Borough of Barnet which, historically, has been subject to significant flooding, most recently in 1992. Flood alleviation schemes, such as along the Silk Stream, can offer opportunities to secure ecological improvements and greater public access to watercourses. Flood alleviation schemes do not eliminate the risk of flooding, but protect properties to a certain level. Properties will still be at risk from floods of greater magnitude.
  Development within Floodplains
  EP11 DEVELOPMENT WITHIN FLOODPLAINS WILL NOT NORMALLY BE PERMITTED. SHOULD CIRCUMSTANCES ARISE WHERE OTHER MATERIAL CONSIDERATIONS OUTWEIGH THE NEED TO PROTECT THE NATURAL FUNCTION OF THE FLOODPLAIN, DEVELOPERS WILL BE REQUIRED TO INCORPORATE ADEQUATE MEASURES TO ENSURE THAT THEIR PROPOSAL WOULD NOT LEAD TO OR INCREASE THE RISK OF FLOODING ON-SITE OR ELSEWHERE.
   
3.43 Floodplains are generally areas of low-lying land adjacent to watercourses liable to flooding. They perform a number of functions: protecting areas upstream and downstream from flooding and providing wildlife habitats and environmentally attractive areas. Functional floodplains are unobstructed or active areas where water flows regularly in time of flood. In Harrow, these are effectively undeveloped areas within the floodplain. New development or intensification of existing development in the floodplain is at risk of flooding. Reducing the water storage capacity of the available floodplain and restricting flood flow routes, increases the risk of flooding elsewhere.
3.44 In assessing proposals the sequential approach will be applied, as set out in PPG25. This indicates that in already built up areas, at high risk of flooding (as defined in paragraph 30, PPG25), development may be permitted provided appropriate minimum standards of flood defence can be maintained for the lifetime of the development. Any necessary flood defence works should be fully funded and provide for long term maintenance as part of the development proposed. Built development will not be permitted in functional floodplains, or on undeveloped sites or locations at risk of flooding, apart from essential transport and utilities infrastructure that has to be there and which remains operational at times of flood, causes no net loss of floodplain storage and does not impede water flows or increase flood risk elsewhere. In assessing the level of flood risk on a particular site, account will be taken of potential flooding from other sources apart from rivers.
3.45 The Council aims to maintain, and where appropriate restore, the natural function of floodplains, in recognition of their role in reducing flood risk and enhancing biodiversity. Artificially engineered flood defence measures can have adverse impacts on the natural and built environment, as consultation draft PPG25 acknowledges. Continued construction of hard engineered flood defences to protect development exposed to frequent flooding, is unlikely to be sustainable in the long term. Where measures are needed, soft engineering techniques, such as natural flood meadows should be used instead, although avoiding such areas in the first place is preferable and consistent with the precautionary principle. This recognises that while damage from flooding may be uncertain and unpredictable, it can be significant (PPG25 : Development and Flood Risk, July 2001). In determining planning applications, and identifying areas within main river floodplains where built development should be avoided, the Council will use the Indicative Flood Plain Maps produced by the Environment Agency, which show the extent of main rivers and their floodplains in Harrow. Site specific guidance will be sought from the Environment Agency regarding main river floodplains.
3.46 Land uses suitable on floodplains include sports fields or open space for outdoor recreation (where there would be no danger posed to humans or damage to receiving watercourses) and nature conservation, wetlands or woodland. Where a development site lies partly within a floodplain, there may be scope for using this area to provide a natural/open space/amenity area as part of or serving the development, whose built elements would lie outside the floodplain. However, there should be no ground raising or obstructions to flood flow within the floodplain. Buildings on stilts are not considered to be acceptable within the floodplain. Risk to life is of primary concern in relation to any development in areas at risk of flooding and, ideally, people should not be placed in the floodplain in the first place.
  Control of Surface Water Run-Off
  EP12 APPROPRIATE ATTENUATION MEASURES SHOULD BE INCORPORATED IN ALL DEVELOPMENT GENERATING SURFACE WATER RUN-OFF. DEVELOPMENT LIKELY TO RESULT IN ADVERSE IMPACTS, SUCH AS INCREASED RISK OF FLOODING, RIVER CHANNEL INSTABILITY OR DAMAGE TO HABITATS, WILL BE RESISTED.
   
3.47 Susceptibility of land to flooding is a material planning consideration. Given the uncertainty inherent in estimating flood risk and increased risk arising from climate change, PPG25 : Development and Flood Risk, July 2001 advises local planning authorities to apply the precautionary principle to the issue of flood risk, avoiding risk where possible and managing it elsewhere. The precautionary principle enables prudent action to be taken in advance of scientific certainty. It is concerned with taking action now to avoid possible environmental damage when scientific evidence for acting is inconclusive but potential damage could be significant. The Council is to produce maps showing areas at risk of flooding throughout the Borough.
3.48 New development normally increases surface water run-off, where permeable surfaces are replaced by impermeable surfaces such as roofs and paving, and through compaction from vehicular movement. Increasing the risk of flooding, pollution and silt deposition, untreated run-off damages habitats and leads to river instability. Effects can occur at a distance remote from the development. Flood risk management needs to be applied to the whole river catchment and not be restricted to floodplains. Developers are advised to give careful consideration to the role that trees, open land, including where appropriate, rough grassland and scrub, and vegetation play in slowing down the flow of rainwater into the drainage system, offsetting some of the adverse effects of surface water run off. In areas susceptible to flooding or where significant surface water run off can be expected to result from new development, the Council may require trees to be retained, additional trees to be planted, and soft landscaping/open land to be retained for these purposes. The Council, where appropriate in consultation with the Environment Agency, will assess the surface run-off implications of new development proposals and the environmental impact of such proposals. New developments will only be permitted where the Council is satisfied that suitable measures designed to mitigate the adverse impact of surface water run-off into non-main rivers and watercourses are included as an integral part of the development. Where appropriate the development should include provision for the long-term management of these measures. Consideration should be given to the use of SUDS, retention of vegetation and role of tree planting in reducing surface water run off and hence reducing flood risk. The Council seeks to sustain the natural drainage processes within catchments and will normally require new development and redevelopments to incorporate sustainable urban drainage systems such that the 1 in 100 year critical storm is attenuated on site. Policy EP10 gives further guidance on sustainable drainage systems.
3.49 The developer is responsible for determining whether a development will be affected by flooding, or will increase flood risk elsewhere and for satisfying the local planning authority that any flood risk can be successfully managed with minimum environmental effect to ensure the safe development and secure occupancy of the site (PPG25). Where there is a lack of knowledge regarding flood risk it is the developer's responsibility to obtain this knowledge. To determine whether development is appropriate and the minimum level of flood protection acceptable, regard will be given to the sequential approach set out in PPG25, Table 1. Consultation will also be carried out with the Environment Agency, sewerage undertakers and water authorities regarding particular sites and locations and specific measures that may be needed, including the standard of flood defence required, taking into account prevailing circumstances. Developers are advised to consult the Environment Agency, or other appropriate authority, at the earliest opportunity on the potential flood risk of their proposal.
  Culverting and Deculverting
  EP13 DEVELOPERS WILL BE ENCOURAGED TO ENHANCE AND OPEN UP (DE-CULVERT) WATERCOURSES FOR THE BENEFIT OF WILDLIFE, TO IMPROVE AMENITY AND ACCESS FOR MAINTENANCE. CULVERTING WILL NOT NORMALLY BE PERMITTED. WHERE APPROPRIATE, THE COUNCIL MAY REQUIRE WATERCOURSES TO BE ENHANCED AND/OR DECULVERTED AS PART OF PROPOSALS.
   
3.50 Watercourses, such as rivers and streams, provide valuable habitats for many species, as ecological corridors provide important links between habitats, and contribute to an attractive, interesting environment. Such benefits are lost through culverting, (putting watercourses in pipes) which breaks the continuity of the river corridor and may have serious implications for safety, maintenance, flooding and nature conservation. Developers will be encouraged to restore and enhance watercourses where opportunities arise as part of their proposals. Where a culvert runs beneath a site on which new or re-development is proposed, developers should examine the scope for deculverting and/or enhancing watercourses, where possible using site layout to facilitate this. Where opportunities arise in conjunction with major development proposals, and/or in identified locations where deculverting or watercourse enhance is sought, deculverting and enhancement of watercourses may be required. Consideration will be given to the contribution open watercourses can make to regeneration and redevelopment proposals. Planning permission for developments which preclude the potential for a watercourse to be naturalised/enhanced in future will not normally be granted. All development proposals close to culverted watercourses should facilitate their continued effective maintenance and replacement.
  Development Within Areas at Risk from Sewerage Flooding
  EP14 PLANNING PERMISSION WILL NOT BE GRANTED FOR NEW DEVELOPMENT THAT WOULD INCREASE THE RISK OF FOUL OR SURFACE WATER FLOODING ON THE SITE OR ELSEWHERE UNLESS MEASURES TO CONTROL DISCHARGE TO THE SEWERAGE SYSTEM ARE PROVIDED BY THE DEVELOPER.
   
3.51 In areas at risk from sewerage flooding, foul and surface water sewers can be heavily surcharged during periods of heavy rainfall. Increased discharge of surface water or foul sewage from new development can increase the risk of flooding on-site or elsewhere. In many instances, flooding from manholes/gullies in the public highway or within domestic and other premises occurs, leading to the risk of flooding within dwellings, commercial and other buildings. In such areas, new development, infilling or major extensions should not proceed unless measures to control the discharge to the public sewerage system are provided by the developer. Risks can be attenuated by on-site storage and/or controlled discharge to surface/foul sewerage systems.
3.52 The Council will consult the Environment Agency and water undertakers in considering development proposals. Developers are advised to consult the Environment Agency and Thames Water before submitting planning applications.
  Water Conservation
  EP15 DEVELOPMENT PROPOSALS SHOULD INCLUDE APPROPRIATE MEASURES TO CONSERVE WATER, SUCH AS PROVISION FOR COLLECTING RAINWATER AND RECYCLING GREY WATER AND WATER EFFICIENT DEVICES. DEVELOPERS OF MAJOR SCHEMES WILL BE REQUIRED TO DEMONSTRATE HOW THEY HAVE TAKEN INTO ACCOUNT THE NEED TO CONSERVE WATER IN THEIR PROPOSALS.
   
3.53 Water supply is a material planning consideration (PPG12). There is a growing imbalance between supply and demand in London and the South East as demand is forecast to increase. Water abstraction reduces flows in watercourses and can reduce water quality and availability, rendering habitats unfit for aquatic life and posing a risk to human health.
3.54 Conserving water will be essential to ensuring adequate supplies continue to be available in future. In view of the pressures that water supply in the South East faces, possible water shortages and a reduction in water quality due to increased abstractions, the Council will expect all new development proposals and major refurbishments to include measures to conserve water. Other types of development will be encouraged to include measures where appropriate. Depending on the scale and nature of the proposal and availability of water supply and infrastructure, specific measures may be sought, by agreement, or as a condition of granting planning permission.
3.55 Water conservation measures include metering, water efficient toilets, grey water recycling, rainwater utilisation systems (water butts), and tap flow regulators. Early consideration, within the planning and development process, of the scope for incorporating grey water recycling or rainwater utilisation systems into developments is likely to enable the most practical and effective options/solutions/opportunities to be identified. Grey water recycling may have particular infrastructure, design and drainage requirements that need to be considered at an earlier stage than would be the case with conventional water supply and drainage systems. Further guidance on grey water recycling and sources of advice will be given in Supplementary Planning Guidance.
   
  WASTE
  Waste Management, Disposal and Recycling Facilities
  EP16 THE COUNCIL WILL ACTIVELY ENCOURAGE RECYCLING AND WASTE MINIMISATION BY ENSURING THAT APPROPRIATE FACILITIES ARE PROVIDED, AND BY RESPONDING FAVOURABLY TO PROPOSALS WHICH ARE CONSISTENT WITH THESE AIMS. THE COUNCIL WILL MAINTAIN A SITE FOR THE COLLECTION AND TRANSFER OF WASTE AND THE REDISTRIBUTION OF RECYCLABLE MATERIALS IN THE BOROUGH.
   
3.56 Each year, the Council collects around 75,000 tonnes of household and commercial waste; a further 30,000 tonnes is delivered to the Civic Amenity Site. However, this accounts for less than half the waste arising in the Borough. Much of the Borough's waste is non-household waste, and includes construction, demolition, industrial and commercial wastes whose disposal is managed by the private sector. Household waste is projected to grow 2-3% a year. During 1998/9 household waste grew by 6% across the West London Waste Authority catchment area. If waste continues to grow at 3% a year the volume of waste produced would double in twenty years time at 6 percent growth waste would double in about 12 years.
3.57 The Council recognises that to encourage people to recycle, adequate recycling facilities must be provided. Minimising waste from construction can be integral to the design and construction of new development and is closely linked to resource efficiency. Considerable scope exists within the construction industry to reduce waste, for example, by recycling demolition and construction wastes, where possible on site, and using recycled materials (see policy EP20) and resource efficient construction methods. Opportunities for incorporating recycled/re-used materials in new development and hence to minimise waste arisings should always be considered. Where appropriate, recycling facilities and/or provision for storing separated waste will be sought as part of new development (see policy D8).
3.58 Proposals for waste management facilities should accord with the principles of sustainable waste management set out in policy SEP3 and should be acceptable in terms of their impact on the local environment and residential amenity. Preference will be given to proposals that promote options at the top of the waste hierarchy, namely, waste reduction, re-use, recycling and composting. Waste to energy facilities may have a role to play in reducing the need to landfill waste, with the added benefit of recovering some value from waste in the form of heat or heat and electricity (via Combined Heat and Power). However, such facilities should be small-scale and burn residual waste (waste left over from recycling) in order not to compete with recycling or undermine efforts to minimise waste by removing the incentive to reduce waste. The Council recognises the need to co-operate with and work alongside the community, businesses and other sectors to secure suitable and appropriately located facilities and work towards achieving more sustainable waste management practices and attitudes towards waste in the Borough.
3.59 To comply with the EU Landfill Directive, which came into force July 2001, the Government has set targets to recover value from 40% of municipal waste by 2005, 45% by 2010 and 67% by 2015. Recovery includes recycling, composting and energy from waste. Targets have been set to recycle or compost 25% of household waste by 2005, rising to 30% by 2010 and 33% by 2015 and reduce the amount of industrial and commercial waste landfilled to 85% of 1998 levels. The introduction of the landfill tax and more stringent controls to minimise environmental impact have added to the cost of dealing with waste. As the cost of landfill rises, other options are likely to become more attractive, both economically and in terms of their environmental impact.
3.60 Responsibility for waste management in Harrow is shared between the Council, as Waste Collection Authority, and West London Waste Authority, the disposal authority. The catchment area for waste disposal extends beyond the Borough boundary. The Council will work with neighbouring Boroughs, West London Waste Authority and others to identify suitable sites for waste treatment and disposal, including composting facilities.
3.61 Improvements to the Civic Amenity Site in Wealdstone are sought, in view of the large and increasing volumes of waste passing through it. A much higher proportion of the site's waste could be recycled than at present; but facilities are close to capacity, making it difficult to expand activity. Much of the household waste delivered to the site by the public comprises furniture and grass cuttings (around a third of all household waste) and is not recycled, but could be. Extension of the site will be considered or, alternatively, transfer of facilities to a suitable site elsewhere in the Borough.
  Waste Generating Activities (Date of deletion 28th September 2007)
  EP17 THE COUNCIL WILL CONSIDER THE IMPLICATIONS FOR LOCAL WASTE MANAGEMENT OF MAJOR DEVELOPMENT PROPOSALS, SUCH AS HOUSING AND COMMERCIAL DEVELOPMENT, AND SEEK LOCAL WASTE MANAGEMENT SOLUTIONS IN RESPECT OF ALL NEW MAJOR DEVELOPMENTS.
   
3.62 The Government's Waste Strategy 2000: England and Wales has indicated the need for development plans to consider the broader context of how waste might be collected efficiently and effectively and dealt with, as far as possible, nearby. While there has been considerable focus on waste streams, and the land use planning implications of these, insufficient attention has been given to the implications for waste management of major development proposals.
3.63 Major development proposals often present significant opportunities for re-use, recycling, composting or energy recovery. Identifying opportunities early in the design and planning process makes it more likely that they will be fully taken advantage of and all stages (including wastes arising through construction, use, maintenance and demolition) considered. It is acknowledged that for certain wastes, for example, some special or hazardous wastes, disposal nearby may not be possible or desirable (on health and safety grounds or because specialised treatment facilities may be required).
  Landfilling (Date of deletion 28th September 2007)
  EP18 THE COUNCIL SUPPORTS A SHIFT AWAY FROM LANDFILL TOWARDS MORE SUSTAINABLE FORMS OF WASTE MANAGEMENT THAT EMPHASISE WASTE REDUCTION AT SOURCE AND RECYCLING. LANDFILLING WILL NOT BE PERMITTED UNLESS THE COUNCIL IS SATISFIED THAT:-
    A) THE PROPOSAL REPRESENTS THE BEST PRACTICABLE ENVIRONMENTAL OPTION FOR THAT PARTICULAR TYPE OF WASTE; AND
    B) THE EFFECTS OF THE PROPOSAL ON THE APPEARANCE AND QUALITY OF THE LAND INVOLVED AND SURROUNDING AREA, INCLUDING IMPACT ON RESIDENTIAL AMENITY AND ECOLOGICAL IMPACT, ARE ACCEPTABLE.
   
3.64 Landfilling causes air and water pollution, contaminates land and contributes to global warming through the release of methane, a greenhouse gas several times more powerful than carbon dioxide. The European Landfill Directive requires a reduction in the amount of biodegradable waste sent to landfill. In Harrow, disposal by landfill does not fulfil the proximity principle, because of a lack of sites in or near the Borough. At the same time it is recognised that for certain wastes, after taking into account factors such as transport and location, landfill outside the Borough may be the best practicable environmental option. Landfill represents an inefficient use of land, particularly in a Borough like Harrow, where sites are scarce and required for other activities.
3.65 The Council intends to pursue a range of options, such as waste reduction, recycling, composting and energy recovery, as set out in the 'Waste Management and Recycling Plan: 1999 - 2005', to reduce the need to send waste to landfill. Which option is appropriate will depend on the waste stream and opportunities available. For example, the Borough's street tree and parks waste is reused or recycled (as mulch and to make products), averting the need for landfill. The Council intends to build upon this good practice and encourages proposals that contribute to sustainable waste management in the Borough.
  Aggregates (Date of deletion 28th September 2007)
  EP19 THE COUNCIL WILL ENCOURAGE AGGREGATES RECYCLING AND THE USE OF RECYCLED AND SECONDARY AGGREGATES, CONSTRUCTION MATERIALS AND DEMOLITION WASTES AS SUBSTITUTES FOR PRIMARY MATERIALS WHERE FEASIBLE. THE COUNCIL MAY USE PLANNING OBLIGATIONS OR AGREEMENTS OR CONDITIONS TO SECURE RECYCLING OF MATERIALS ON SITE AND/OR USE OF RECYCLED AGGREGATES IN MAJOR SCHEMES.
   
3.66 There are significant environmental and social costs associated with using primary aggregates: extracting, processing, transporting and disposing of materials use up considerable amounts of energy and land, create dust and pollution and blight landscapes. Land may be degraded, temporarily or permanently, or is simply unavailable for other uses. Recycling and re-using aggregates and construction materials, including timber, saves resources and energy (provided materials are not transported for long distances) and reduces pollution.
3.67 MPG6: Minerals Planning Guidance includes targets to increase the use of construction and demolition wastes and secondary aggregate materials with the aim of nearly doubling the use of recycled aggregates from 30 million tonnes a year in 1989 to 55 million tonnes by 2006. The UK Waste Strategy advises that 'aggregates should be recycled wherever possible and where technically, economically and environmentally acceptable construction and demolition wastes should be used instead of primary materials.' Improving the efficiency of the construction industry is a key objective in the Government's 'Strategy for Sustainable Construction,' published in April 2000.
3.68 The London Plan recommends that local authorities should assess opportunities for facilities for aggregates recycling and where possible, identify sites suitable for it to take place, taking into account the source of materials and means of transport.
3.69 There is considerable potential to recycle construction and highways waste in Harrow, of which 6,000 tonnes passed through the Civic Amenity Site last year. With the introduction of an aggregates levy in 2002 the financial cost of using primary aggregates will increase. The amount of secondary/recycled aggregates used compared with virgin aggregates is an indicator in the UK Strategy for Sustainable Development.
   
  LAND QUALITY, USE & ENVIRONMENTAL IMPACT
  Use of Previously-Developed Land
  EP20 THE COUNCIL WILL SEEK TO SECURE ALL NEW BUILD DEVELOPMENT TO TAKE PLACE ON PREVIOUSLY-DEVELOPED LAND, WITH THE EXCEPTION OF ANCILLARY DEVELOPMENT NECESSARY TO SUPPORT APPROPRIATE OPEN SPACE, METROPOLITAN OPEN LAND AND GREEN BELT USES.
   
3.70 The full and effective use of urban land and protection of areas of open space are essential prerequisites of a more sustainable Harrow. To achieve this objective, more intensive use must be made of previously-developed land (brownfield sites). In particular the Council seeks to ensure that all new housing development takes place on previously-developed land. To further relieve development pressures on greenfield sites, other policies in the Plan aim to secure the effective use of vacant and/or under-used land and property in the Borough.
3.71 The Council recognises that, in addition to pressures for housing, there will be a need to accommodate other types of development within the Plan period. This must take into account residents' needs for access to a variety of open spaces for recreational purposes. There is very little scope for increasing the amount of open land in the Borough. Open land will also still be needed for agricultural, nature conservation and amenity purposes. Brownfield sites can support a variety of plants and wildlife and as amenity/open space may provide opportunities for informal recreation and contact with nature in an urban setting. Their potential contribution towards meeting open space targets in areas of open space deficiency will be taken into account in assessing proposals for their redevelopment as will their nature conservation value. Only by protecting such areas will a more sustainable balance of land uses, which is fundamentally important to the quality of life and environment of the Borough, be achieved. The Council therefore considers it appropriate to protect greenfield sites from all land uses which can satisfactorily be accommodated on other previously-developed sites within the urban area. However, it acknowledges that should the sequential approach need to be applied consideration of greenfield sites would have to take place.
  Vacant and Disused Land and Buildings
  EP21 THE COUNCIL WILL KEEP UNDER REVIEW ALL LAND BROUGHT FORWARD FOR DEVELOPMENT TOGETHER WITH ALL VACANT LAND AND BUILDINGS TO ENSURE THEY ARE PUT TO APPROPRIATE AND BENEFICIAL USE, AND WILL RELEASE LAND AND BUILDINGS SURPLUS TO ITS REQUIREMENTS, WHILE ENCOURAGING OTHER LANDOWNERS TO DO LIKEWISE. IN REACHING A DECISION ABOUT THE FUTURE OF LAND AND BUILDINGS IDENTIFIED AS SURPLUS TO COUNCIL REQUIREMENTS THE LIKELY BENEFIT TO THE COMMUNITY AND ENVIRONMENT OF REDEVELOPMENT PROPOSALS AND USE OF LAND WILL BE TAKEN INTO ACCOUNT.
   
3.72 As part of the process of securing full, effective use of land and building resources, it is important that vacant and underused land are brought forward for development as quickly as possible. In particular, appropriate levels of new housing provision need to be secured. Although the supply of vacant sites continues to diminish and the average size of sites tends to be smaller, redevelopment and refurbishment proposals will continue to play an important role in achieving the Plan's objectives.
3.73 Consideration needs to be given to the long-term impact of releasing land and buildings and any subsequent redevelopment or use and indirect costs and benefits (financial and other) associated with these, if the environment and resources are to be safeguarded for future generations. In addition to ensuring that Council owned buildings and land serve the needs of the community and meet high environmental standards, the Council, as landowner, is in a position to negotiate the best possible outcome for the community when releasing land or buildings it no longer requires. The best outcome will not necessarily result from a proposal with the highest financial return but may require consideration to be given to proposals that offer significant social and environmental benefits but which have a lower financial return.
3.74 Land and buildings will be required for development by Council service departments and other agencies with whom the Council is a partner, as well as the private sector, during the Plan period. The Council will monitor overall land availability and use of buildings and identify suitable sites to ensure statutory needs can be met. In exceptional circumstances, the Council will consider the use of compulsory purchase powers to encourage development. Where appropriate, financial contributions received in lieu of on-site provision of affordable housing may also be used to secure such provision. In addition, the Council will maintain and update records on housing development activity; this will also assist in evaluating future use of land and buildings in the Borough.
  Contaminated Land
  EP22 THE COUNCIL, IN DETERMINING A PLANNING APPLICATION FOR THE DEVELOPMENT OF CONTAMINATED LAND, OR LAND SUSPECTED OF BEING CONTAMINATED, OR LAND ADJACENT TO SUCH SITES, WILL REQUIRE AN INVESTIGATION OF THE HAZARDS POSED AND APPROPRIATE REMEDIAL MEASURES. SUCH MEASURES MUST ENSURE THAT THE SITE IS DEVELOPED SAFELY, IN A MANNER THAT ENSURES THE SAFETY OF THE OCCUPIERS AND/OR USERS, AND DOES NOT HAVE ANY ADVERSE ENVIRONMENTAL IMPACT. PLANNING PERMISSION WILL BE CONDITIONAL UPON SUCH MEASURES BEING IMPLEMENTED IN ACCORDANCE WITH THE APPROVED SCHEME OF REMEDIATION.
   
3.75 Section 57 of the Environment Act 1995 requires local authorities to identify and take appropriate action with regard to contaminated land in their area. The planning system is expected to be the primary regime for securing the amelioration of land contamination, preferably via voluntary action by landowners and developers when submitting development proposals. The Council's Contaminated Land Strategy provides a framework for identifying and addressing issues relating to contaminated land in the Borough. In applying this policy, regard will be given to this Strategy and to the Memorandum of Understanding between the Environment Agency and the local planning authority. PPG23 sets out the Government's approach for dealing with land contamination through the planning system. It indicates that under the "suitable for use" approach risks should be assessed, and remediation requirements set, on the basis of both the current use and circumstances of the land and its proposed new use.
3.76 The regimes for dealing with contaminated land clearly lay responsibility for dealing with contamination with the developer. The Local Planning Authority must be advised by the developer of the ways in which issues of contamination have been taken into account in the formulation of development proposals. For this to take place, a detailed investigation of the nature and extent of contamination on-site will be necessary. A full investigation of any re-development on contaminated land or potentially contaminated land should consider both surface soils and underlying groundwaters and adjacent surface waters. The Council will seek advice from the Environment Agency on remedial measures and piling issues if appropriate. Whilst the Council acknowledges that there may be differing degrees of contamination on specific sites, there may be circumstances where, because of the nature of the contamination, investigation of adjacent sites will also be required.
3.77 It is important that remedial measures are undertaken safely and ensure the health and safety of future occupiers of any new development. Consideration should be given to the possible ecological value of sites, as vacant or derelict sites may support a diversity of habitats and wildlife, even where contamination is present. Remedial processes should be carried out in a way that does not undermine this. Where necessary, appropriate monitoring procedures will be agreed between the developer and the Council. Unless the developer can demonstrate otherwise, there will be a presumption in favour of on-site treatment. All stages of the development should be undertaken without any adverse environmental impact.
3.78 On site treatment of contaminated land is likely to require permits/and or licences authorised by the Environment Agency with whom early consultation is advised. Where appropriate, the Council will consult the Environment Agency regarding requirements for monitoring groundwater and/or surface waters.
  Dangerous Substance Establishments and Major Accident Hazard Pipelines
  EP23 THE COUNCIL WILL ENSURE THAT SAFE DISTANCES ARE MAINTAINED BETWEEN DANGEROUS SUBSTANCE ESTABLISHMENTS OR MAJOR ACCIDENT HAZARD PIPELINES AND PROPOSED DEVELOPMENT.
   
3.79 A small number of existing sites and pipelines in the Borough are classified as Dangerous Substance Establishments (DSEs) and Major Accident Hazard Pipelines (MAHPs) by the Health and Safety Executive. This is because significant quantities of hazardous substances are stored or used in them or transported through them. These DSEs and MAHPs are: the Transco site at Marsh Lane, Stanmore, together with a number of Transco High Pressure Transmission Pipelines. Plans showing the exact location of these installations can be viewed at the Civic Centre. Whilst these installations are subject to stringent controls under existing Health and Safety legislation, the Council considers that it is also prudent to control the kinds of development permitted in the vicinity of installations through planning control. The Council has been advised by the Health and Safety Executive of Consultation Distances for each of these installations. In determining whether or not to grant consent for a proposed development on land within these Consultation Distances, the Council will take account of the advice it receives from the Health and Safety Executive about risks to the proposed development from the DSEs and MAHPs. Developers should pay due regard to Consultation Distances from existing DSEs and MAHPs when developing land for other uses nearby, e.g. housing.
  Air Quality (Date of deletion 28th September 2007)
  EP24 THE COUNCIL WILL TAKE INTO ACCOUNT THE EFFECT OF DEVELOPMENT AND CHANGES OF USE ON LOCAL AIR QUALITY IN DETERMINING PLANNING APPLICATIONS. PROPOSALS LIKELY TO HAVE AN UNACCEPTABLE IMPACT ON LOCAL AIR QUALITY WILL NOT BE PERMITTED. THE COUNCIL MAY REQUIRE THE DEVELOPER TO CARRY OUT AN ASSESSMENT OF THE IMPACT OF THEIR DEVELOPMENT ON LOCAL AIR QUALITY.
   
3.80 To assess the impact of development and changes of use on air quality both direct effects arising from the development and indirect effects, namely pollution from additional traffic, need to be taken into account. Other factors to consider include the characteristics and sensitivity of particular locations to potentially polluting development (see also Policy T6).
3.81 Traffic is the main, although not the only, cause of air pollution in Harrow. Emissions from traffic serving, or generated by, new development can worsen local air quality still further. Even where the impact of a single proposal is minimal, the cumulative impact of several proposals may be significant, and therefore should be considered. Land use planning can improve air quality over the long term by ensuring development reduces the need to travel, is less polluting and easily reached by non-polluting forms of transport.
3.82 The National Air Quality Strategy provides a framework for reducing air pollution at national and local level and includes health based standards for the following pollutants of concern: benzene, 1,3-Butadiene, carbon monoxide, lead, nitrogen dioxide (NO2), particulates (PM10) and sulphur dioxide (SO2). From these standards the Government has derived objectives, taking into account costs, benefits, feasibility and practicality, which are given statutory force under the National Air Quality Regulations 2000. The regulations specify deadlines by when objectives must be met (which vary from 2003 to 2008, depending on the pollutant). The Mayor of London's Draft Air Quality Strategy (2001) sets out policies and proposals to work towards achieving national objectives and targets for reducing pollution in London. The Council intends that future development and use of land in the Borough should contribute towards achieving the national targets and will have regard to the policies and proposals set out in the Mayor's air quality strategy, and expects developers to do the same. Developers are advised that other policies in the UDP, in particular on energy conservation and efficiency (EP8), renewable energy (EP7), and transport (T6), provide guidance regarding the type of development sought that may also assist in meeting the requirements of this Policy.
3.83 Part IV of the Environment Act 1995 requires local authorities to assess and review air quality; to designate areas unlikely to meet National Air Quality objectives as Air Quality Management Areas (AQMAs); and draw up action plans to enable National Air Quality Objective limits to be met in these areas. A review and assessment of air quality by the Council and consultants indicates that parts of the Borough, in particular along main roads and some background locations, exceed National Air Quality Strategy limits. The Council has declared the whole Borough as an AQMA because of the difficulties of identifying the precise boundaries where the Air Quality objective levels are no longer breached. Unless action is taken at a local level to improve air quality, objectives are unlikely to be met for particulates and NO2.
3.84 "Local Air Quality Management: Air Quality and Land Use Planning" (2000) guidance LAQM.G4(00) states that development plans 'should identify where further development is constrained by the cumulative effect of existing and future polluting uses of land.' Air quality in Harrow is monitored regularly to identify the extent, nature and location of pollution. Development proposals within or likely to affect an AQMA will be expected to be consistent with pollution reduction aims set out in action plans for these areas. Proposals that contribute towards action plan aims will be positively encouraged. The Council may use conditions or seek agreements to ensure development does not undermine air quality or to secure specific measures required to implement Air Quality Management action plans. In circumstances where the Council is concerned about the potential impact on air quality, developers may be asked to include a statement assessing the likely impact their proposed development would have on air quality and any mitigation measures proposed. Where a proposal is likely to exacerbate existing pollution or interfere with achieving air quality strategy targets, the Council will aim to identify measures that could be taken to address these concerns and may use conditions or seek agreements to ensure these are implemented. Where this is not possible, to safeguard public health and environmental quality, permission would be refused.
3.85 Air pollution is the concern of more than one agency and the subject of more than one statutory instrument. The Local Planning Authority will work closely with the Environment Agency and other enforcement authorities, including the Council's Environmental Health division, and neighbouring authorities, when considering the effect of proposals on air quality. Consideration will be given to local, London-wide and national air quality strategies in existence or that come into existence during the course of this Plan in implementing this policy.
  Noise
  EP25 IN ASSESSING PLANNING APPLICATIONS THE COUNCIL WILL TAKE INTO ACCOUNT NOISE AND VIBRATION LEVELS LIKELY TO RESULT FROM OR AFFECT A PROPOSAL AND WILL REQUIRE NOISE, VIBRATION AND DISTURBANCE TO BE MINIMISED THROUGH:-
    A) DESIGN, LAYOUT & ORIENTATION OF BUILDINGS;
    B) PLANTING AND LANDSCAPING;
    C) USE OF NOISE SCREENS;
    D) INSULATION;
    E) ENCLOSING OR SCREENING PLANT AND EQUIPMENT;
    F) CONTROLLING TIMES OF OPERATION;
    G) VIBRATION SUPPRESSION; AND
    H) OTHER APPROPRIATE MEASURES.
    DEVELOPMENT PROPOSALS THAT WOULD LEAD TO UNACCEPTABLE LEVELS OF NOISE, VIBRATION OR DISTURBANCE WILL BE REFUSED.
   
3.86 Noise has a major impact on the environment, health and quality of life generally. Noise nuisance is a growing problem, particularly in urban areas, although many suburban and rural areas are affected as well, largely through increased traffic. Developments should be designed to minimise domestic noise, through sensitive layout, good sound insulation, landscaping etc.
3.87 So that people and sensitive environments are not subjected to excessive noise levels from new development or changes of use, noise-generating development will not be permitted in noise-sensitive areas, unless developers can demonstrate that it would not have an adverse impact on neighbouring land uses. Noise-generating development includes industrial, commercial, catering, leisure and entertainment uses. The preferred location for noise-sensitive development, which includes residential development, schools, hospitals and community facilities, will be away from loud noise sources. Noise sensitive areas occur in the vicinity of these uses, to a greater or lesser degree, or where these uses predominate and also include areas relatively undisturbed by noise nuisance valued for nature conservation, quiet recreation or amenity purposes. Where it is not desirable or practical to separate noisy and noise-sensitive uses, (for example, town centres may include catering, entertainment, commercial and residential uses in close proximity), consideration will need to be given to ensuring residents are protected from excessive noise, particularly at night. Developers will be expected to ensure that noise arising from their proposals, including noise generated by people and vehicles arriving and leaving the premises, does not cause excessive disturbance to adjacent land uses and where necessary the Council will impose conditions to ensure that noise is kept to within acceptable limits.
3.88 In assessing the level of disturbance likely to arise from or affect a proposed development the Council will refer to PPG24: Planning And Noise (1994). This recommends noise exposure categories (NECs) for new residential development. NECs relate to noise from air, rail and road traffic and mixed sources and take into account night and daytime noise levels, but do not cover industrial noise, where it is the main noise source, which needs to be assessed separately. In making an assessment, the Council will be sympathetic towards the needs of public transport operators and providers.
3.89 Where necessary, the Council will use conditions requiring developers to take measures, such as glazing, insulation, screening and landscaping to ensure adequate levels of noise protection. Only where an acceptable quality of environment (inside and outside) for the uses proposed is likely to be achieved will permission be granted for noise-sensitive development close to noise sources.
3.90 Noise-generating development will be permitted only where the impact on neighbouring land uses is considered likely to remain within acceptable levels. Disturbance from noise generating development may also be minimised through restricting hours of operation or use.
3.91 Regard will be given to the Mayor's Noise Strategy, when published, in implementing this policy. Noise levels may be mapped in Harrow in future and this will help guide decisions regarding the location of noisy or noise sensitive development as well as suggesting suitable mitigation measures. The Council operates a Considerate Contractor Scheme whereby contractors are encouraged to follow a Code of Practice to minimise noise nuisance during construction. It will make full use of its statutory powers to monitor and control noise from commercial and industrial operations and other sources. Enforcement action will be taken under environment health and other legislation requiring noisy activity to cease or noise abatement measures to be undertaken.
   
  NATURE CONSERVATION
3.92 Harrow has a varied environment with a wide diversity of wild plants, birds and animals. This diversity occurs throughout the Borough and is not confined to open spaces and nature reserves. The Harrow Nature Conservation Strategy and Biodiversity Action Plan (BAP) will provide a framework for the protection, enhancement and management of nature conservation features throughout the Borough. A survey of habitats and sites of importance for nature conservation was carried out in 1989 by the London Ecology Unit (Nature Conservation in Harrow, Ecology Handbook 13) and the Harrow BAP will build upon this work. Further research has also been undertaken since the original survey was published. Increased attention will be paid to small habitat fragments. These can be particularly valuable to wildlife and enrich local amenity, but are in danger of being overlooked. Monitoring of nature conservation sites in London has been carried out by LPAC and results published in their 'State of the Environment Report' (1996). This report looked at losses, gains and quality of Sites of National, International, Metropolitan or Borough Importance for Nature Conservation and records that since 1994 the nature conservation value of over 10 % of land in Harrow designated for nature conservation (87 hectares) has been improved.
3.93 The Harrow Nature Conservation Strategy and Biodiversity Action Plan (BAP) aim to involve, via partnerships, all those whose activities may affect the biodiversity of Harrow. This in turn will help to ensure a systematic approach to the identification, protection and management of sites, habitats and species throughout the Borough. All sites included in the London Ecology Unit's Handbook are indicated on the Proposals Map.
  Habitat Creation and Enhancement
  EP26 THE COUNCIL WILL ENCOURAGE CONSERVATION OF WILDLIFE THROUGH THE PROTECTION OF EXISTING, AND CREATION OF NEW, HABITATS AND WILL ENDEAVOUR TO TAKE ADVANTAGE OF OPPORTUNITIES PRESENTED VIA THE DEVELOPMENT CONTROL PROCESS TO CREATE AND ENHANCE LANDSCAPE AND NATURE CONSERVATION FEATURES, AND IMPROVE PUBLIC ACCESS WHERE APPROPRIATE. WHERE DEVELOPMENT PROPOSALS WOULD ADVERSELY AFFECT FEATURES OF NATURE CONSERVATION VALUE, THE COUNCIL WILL REQUIRE THE PROTECTION OR REPLACEMENT OF SUCH FEATURES.
   
3.94 The Council wishes to extend opportunities to enjoy the natural environment to all the Borough's residents and will encourage the creation of locally appropriate new habitats where possible. Under the European Habitats Directive, member states are required to encourage the management of features of the landscape which are of major importance for wild flora and fauna. Plans should be concerned not only with designated areas, but also with other land of conservation value and the possible provision of new habitats. A variety of habitats exist within the Borough, including a number of National Priority Habitats such as Lowland Heathland, Ancient/Species-rich Hedgerow and Wet Woodland. In addition, there is a range of woodland types, including ancient woodland, as well as wetland and grassland. Whilst habitats can decline as a result of natural processes (succession) or neglect, through positive and appropriate management they can be protected, enhanced and in some instances created.
3.95 Not all sites with ecological potential have been identified and further sites may come to light at a later date. Sites lying vacant for long periods can develop habitats of importance ecologically. In some instances, the ecological interest of identified sites may have diminished due to poor management, suggesting the need for ecological monitoring of sites and a positive approach to enhance and maintain their nature conservation value.
3.96 The impact of proposals on habitats, including small habitat fragments, will be taken into account when determining planning applications. Developers will be encouraged to create and enhance landscape and nature conservation features in an ecologically sensitive manner. For the purposes of implementing policies in this plan, the Nature Conservation Strategy (and Harrow BAP when it is produced) will be regarded as Supplementary Planning Guidance. Opportunities will also arise to secure habitat protection and enhancement through the development control process.
   
  Species Protection
  EP27 DEVELOPMENT THAT IS LIKELY TO CAUSE HARM TO PROTECTED SPECIES OR THEIR HABITATS WILL NOT BE PERMITTED UNLESS THERE ARE OVERRIDING MATERIAL CONSIDERATIONS WHICH OUTWEIGH THE NEED TO MAINTAIN HABITATS OF AFFECTED SPECIES IN AN UNALTERED AND UNDISTURBED STATE. WHERE AN ADVERSE IMPACT IS LIKELY TO OCCUR, APPROPRIATE COMPENSATORY AND/OR MITIGATING MEASURES WILL BE REQUIRED.
   
3.97 Certain species of flora and fauna are protected by national and international legislation and Local Planning Authorities are required to have regard to these when determining planning applications. In addition, 'protected species' in Harrow include priority species in national, London and local biodiversity action plans. Planning permission will not be granted for development or land use changes which would have an adverse impact on species protected by Schedules 1, 5 or 8 of the Wildlife and Countryside Act 1981, as amended, or priority species or habitats in national, London or local biodiversity plans (including species in neighbouring boroughs' plans where habitats overlap). Where development is likely to affect species listed in the Act, English Nature should be contacted. Some examples of animals receiving protection under the Act include nesting birds, all bat species and their roosts; kingfisher, fieldfare, redwing, hobby; water vole and great crested newt. Measures should be taken to protect habitats before, during and after any development that may have an adverse impact. Badgers are protected under the 1992 Protection of Badgers Act and a licence from English Nature is required to permit interference with a sett. A list of protected species in London is set out in the London Ecology Unit booklet 'Protected Species in London' and in the London Biodiversity Audit (2000).
3.98 Where development is permitted that is likely to affect protected species or their habitats, the Council may use conditions or seek to enter into an agreement to: facilitate the survival of individual members of the species; minimise disturbance; provide alternative habitats to sustain at least the current levels of population.
  Conserving and Enhancing Biodiversity
  EP28 THE COUNCIL WILL CONSERVE AND ENHANCE BIODIVERSITY BY:-
    A) RESISTING DEVELOPMENT THAT WOULD HAVE A DIRECT OR INDIRECT ADVERSE IMPACT ON SITES OF SPECIAL SCIENTIFIC INTEREST, STATUTORY LOCAL NATURE RESERVES, OTHER SITES OF IMPORTANCE FOR NATURE CONSERVATION, COUNTRYSIDE CONSERVATION AREA AND GREEN CORRIDORS;
    B) ENSURING THAT ALL DEVELOPMENT PROPOSALS TAKE ACCOUNT OF NATURE CONSERVATION WHERE RELEVANT AND ENSURING THAT ALL DEVELOPMENT PROPOSALS CONSIDERED LIKELY TO MATERIALLY AFFECT SITES OF NATURE CONSERVATION IMPORTANCE TAKE INTO ACCOUNT THEIR IMPACT ON WILDLIFE AND THE ECOLOGY OF THE SITE;
    C) ENCOURAGING DEVELOPERS TO RETAIN HABITATS AND FEATURES OF VALUE TO ENHANCE THE NATURE CONSERVATION INTEREST OF SITES AND MAKE PROVISION, WHERE APPROPRIATE, FOR PEOPLE TO ENJOY THESE FEATURES;
    D) IDENTIFYING SITES FOR STATUTORILY AND LOCALLY DESIGNATED NATURE RESERVES IN CONSULTATION WITH ENGLISH NATURE AND REGIONAL AND LOCAL NATURE CONSERVATION GROUPS;
    E) WHERE THE COUNCIL CONSIDERS IT APPROPRIATE, REQUIRING DEVELOPERS TO DEMONSTRATE HOW THEIR PROPOSAL WILL IMPACT UPON WILDLIFE AND NATURAL FEATURES AND CONTRIBUTE TO CONSERVING AND ENHANCING BIODIVERSITY IN THE BOROUGH; AND
    F) ENSURING THAT ANY LOSS OF HABITAT E.G. WOODLAND, WETLAND ETC., IS COMPENSATED FOR BY PROVISION OF AT LEAST AN EQUIVALENT AREA OF LAND OF EQUIVALENT HABITAT QUALITY UNDER THE TERMS OF A PLANNING OBLIGATION.
   
3.99 Harrow's environment supports a wide diversity of wild plants, birds and animals. In recent years certain species have declined or come under threat as a result of human activities, including development. The Council wishes to retain and enhance this diversity in recognition of the many benefits this brings - social, educational, economic - to the Borough's residents and will promote awareness and enjoyment of the natural environment. Key to maintaining diversity is the protection, appropriate management and enhancement of habitats throughout the Borough. Identification of nature reserves and protection of Sites of Special Scientific Interest (SSSIs) is an important element, but it is also important to consider existing or potential habitats within open spaces, housing areas, gardens, playing fields, industry and public utilities (space around buildings, vacant land), along road verges and railway land. Such sites may be worthy of protection ecologically and may be enhanced by appropriate management.
3.100 Several sites in the Borough have been identified as important ecologically and as potential nature conservation sites. Some already have planning protection, for example, Green Belt, SSSIs. Outside these areas, sites may be vulnerable to development which could damage or destroy their ecological integrity. Where sites are vulnerable despite designated protection, for example SSSIs lost to development or damaged by Permitted Development rights, Article 4 Directions may be used to remove Permitted Development rights, but can only be implemented where there is evidence of a threat. The Countryside and Rights of Way Act 2000 contains provisions regarding the notification, protection and management of Sites of Special Scientific Interest (SSSIs), and places local authorities and other public bodies under a statutory duty to further the conservation and enhancement of SSSIs, both in carrying out their operations and exercising their decision-making functions.
3.101 Sites of importance for nature conservation in Harrow are organised according to a hierarchy based on criteria developed by the London Ecology Unit. Criteria are set out in the Ecology Handbook No 3 - Nature Conservation Guidelines for London and make it possible to compare and identify sites of Metropolitan, Borough or Local Importance.
3.102 Not all sites of importance have statutory protection and some have yet to be identified. The Council will seek the advice and assistance of English Nature, London Wildlife Trust, Herts and Middlesex Wildlife Trust, the Greater London Authority and local groups on conservation matters in the designation of sites and their value as a visual and wildlife amenity to local residents and to the Borough. Developers will be encouraged to include features that are wildlife-friendly in their proposals and should avoid unnecessary or excessive hardsurfacing. The Council will endeavour to ensure that its own schemes, proposals and practices exemplify good practice and are sensitive to nature conservation interests. Where necessary, the Council will use conditions or seek to enter into an agreement to retain features of nature conservation value and secure the long term management of designated sites. The Countryside Conservation Area, as defined in the London Ecology Unit Handbook 'Nature Conservation in Harrow', is shown on Text Map 5.
3.103 In assessing the relative weight to be attached to the benefits of a proposal that is likely to have an adverse ecological impact, consideration will be given as to whether the site or proposal is of local, Borough or strategic benefit. Permission will only be granted where it can be shown that the resulting benefit(s) significantly outweighs the nature conservation value of the site. It is not envisaged that this would be so for designated sites such as SSSIs, Sites of Nature Conservation Importance or statutory Local Nature Reserves. In such circumstances, any loss of habitat should be compensated by provision of at least an equivalent area of land. On this land a habitat should be created which is of equal or greater nature conservation value than that lost. The retention of extensive tree cover, shrubs, hedgerows and other natural habitats, such as lakes, is an essential element in the Council's Nature Conservation Strategy. New planting will be desirable and normally appropriate native species, preferably from native stock, should be planted. Only in more formal settings will foreign or exotic species be recommended. Advice on wildlife friendly planting is to be produced as Supplementary Planning Guidance.
3.104 Bentley Priory Open Space (a Local Nature Reserve) and land adjacent to Harrow Weald Common contain important habitats and geological features respectively. These are nationally important sites and have been designated by English Nature as SSSIs. Visitors can, by their numbers, have an adverse impact on these areas. The Council will control access by maintaining footpaths, hedges, fences and signposts which encourage people to visit less sensitive habitats and avoid areas where human access would conflict with nature conservation aims. The Council will seek the opinion of English Nature and Harrow Nature Conservation Forum before designating new nature reserves.
3.105 Where the primary function of a Green Corridor is to act as a transport corridor, the Council will pay due regard to the operational requirements of the public transport operators, and at the same time aim to work with operators to protect and enhance visual amenity and nature conservation interests (see Text Map 3).
   
  TREES
3.106 Globally, trees play an important role in the sustainable environment of the planet. Their role in removing carbon dioxide and other pollutants from the atmosphere and replacing them with oxygen is now acknowledged as being vitally important. To secure more sustainable development will require that the stock of trees is not only maintained but ideally increased. Whilst it is thought that nationally most progress can be achieved by increased afforestation, trees in urban areas make a small contribution. Trees provide habitats for a variety of flora and fauna, and contribute greatly to the biodiversity of the Borough. They also slow the rate of water run-off and thereby may contribute to reduced risks of, or levels of, flooding. They also impact on the water table. Overall, it is important that as many trees as possible are retained, and that tree removal is kept to a minimum by proper tree management. Locally, trees also make an important contribution to the attractiveness of the Borough as a place to live and work. It is also acknowledged that structural problems in buildings and structures, and damage to infrastructure (such as drains), can arise from their proximity to trees.
  Tree Masses and Spines
  EP29 THE COUNCIL WILL PROTECT AND ENHANCE TREE MASSES AND SPINES OF STRUCTURAL IMPORTANCE TO THE BOROUGH'S BIODIVERSITY AND CHARACTER BY:-
    A) RESISTING APPLICATIONS FOR DEVELOPMENT WHICH WOULD IMPAIR THE INTEGRITY OF PART OF ANY TREE MASS OR SPINE, OR ITS VISUAL IMPACT;
    B) MAKING TREE PRESERVATION ORDERS; AND
    C) REQUIRING RE-PLANTING AND THE RETENTION OF TREES AND NEW PLANTING IN CONJUNCTION WITH DEVELOPMENT OR WHERE APPROPRIATE.
   
3.107 The landscape infrastructure of the Borough needs sensitive and careful management in order to contribute fully to the biodiversity in the Borough and to remain a valuable asset in the overall character. Tree cover in the form of masses and spines is of major significance for the Borough's biodiversity and character as a whole, not just for the residential areas, and so is of structural importance. Rear gardens frequently support identifiable tree masses. Whilst there are many small groups or individual trees of importance to particular sites or localities which require protection, there are a large number of tree masses and spines which form the nucleus of the treescape in the Borough. Because of this structural importance to the biodiversity and overall character they should be afforded a high level of protection. Large parts of the Areas of Special Character, Green Belt and Metropolitan Open Land derive their special character from the quality and extent of their tree cover. Equally important are the masses and spines relating to areas of open space or land within the built up area, and also to main transport corridors, such as railway lines and watercourses. Groups of trees within a Green Chain are of importance and must be kept free from damage, protected and enhanced in order that the full ecological and/or recreational potential of such areas can be realised.
3.108 The Council will continue to make appropriate Tree Preservation Orders (TPOs) on trees that are considered to be of special or outstanding amenity value, in order to prohibit the felling, lopping or topping of trees without Council approval. However, the Council recognises that it does not always have the powers or jurisdiction to make Tree Preservation Orders, and in these situations the Council will seek the co-operation of landowners to secure the retention of trees.
3.109 In order to supplement the stock of trees which have been lost through natural causes, including such factors as disease and storm damage, the Council will encourage the undertaking of adequate new planting. The need to maintain and improve the landscape will result in the planting of trees and shrubs which are particularly suitable to the locality in which they are located, and will need to take into account nature conservation and ecological considerations.
3.110 Where development is proposed in proximity to a tree mass or spine, including those in rear gardens, the Council will resist the loss of trees in order to retain their value to the biodiversity and landscape character and to avoid the piecemeal erosion of such a tree mass or spine. In considering proposals, an assessment will be made as to whether the location of any new buildings would be likely to lead to a future request for the pruning or felling of trees. In addition, prior removal of trees will not create any presumption in favour of development in the position in which they were located. Where a tree or trees have been removed, the Council will seek replacement by appropriate planting, which in the case of replacement of a mature tree or trees will involve semi-mature stock or a group of trees being provided.
  Tree Preservation Orders and New Planting
  EP30 THE COUNCIL WILL:-
    A) MAKE TREE PRESERVATION ORDERS AND RE-EXAMINE EXISTING TREE PRESERVATION ORDERS TO PRESERVE IMPORTANT INDIVIDUAL TREES OR GROUPS OF TREES;
    B) SEEK TO ACHIEVE NEW TREE PLANTING THROUGHOUT THE BOROUGH, PARTICULARLY WHERE THE EXISTING TREE COVER IS UNSATISFACTORY, BY ENCOURAGING PRIVATE OWNERS, LOCAL GROUPS AND DEVELOPERS TO UNDERTAKE ADDITIONAL PLANTING; AND
    C) ENCOURAGE THE PLANTING OF INDIGENOUS SPECIES.
   
3.111 The importance of trees to the sustainable environment of the Borough has been outlined in the preamble above. As part of the process of protecting the tree stock of the Borough, the Council has powers to make Tree Preservation Orders. These prohibit the felling, lopping or topping of trees without Council approval. All trees in Conservation Areas are also protected whether or not they are covered by a Tree Preservation Order.
3.112 There are very few locations in the built-up part of the Borough where natural regeneration can take place, and new planting and maintenance are necessary to counteract factors such as disease and old age. In some areas, e.g. parts of Wealdstone and South Harrow, existing tree cover is inadequate and judicious new planting would greatly enhance the visual attraction of those areas. There are often site constraints which need to be considered e.g. pavement widths, proximity to buildings, highway regulations and the existence of underground cables and structures, although there are few locations where some form of tree planting could not be undertaken.
3.113 The special character of large areas of the Green Belt and Metropolitan Open Land is, to a large degree, determined by the quality of the tree cover. It is important therefore, that appropriate trees are retained and new ones planted in areas where this would improve the landscape. Forest-type trees are particularly suitable in these locations. There are management plans for key sites in the Green Belt. Tree management forms part of those plans. Large scale tree planting is expensive, and the Council will make use of the various forms of grant aid and advice which are available from organisations such as the Department for the Environment, Food and Rural Affairs and English Nature. Any additional planting must be located so as not to compromise the structural integrity of the public sewer or associated ancillary equipment.
3.114 Trees die from natural causes, and damage and tree loss is exacerbated by heavy storms. Trees are also vulnerable to pollution. There is therefore an on-going need to protect existing trees and plant new ones (see also policy D10). As part of the Council's policy for the planting of new trees, consideration will need to be given to appropriate replacement of trees which have been lost. Trees may be of value as individual trees or as a group, for their intrinsic interest, amenity value, or value to the overall landscape of the Borough, and the Council wishes to protect existing trees for this reason. Similarly, new trees may also fulfil any one of these functions. The Council will seek the planting of new trees by a number of agencies and individuals, in order that the biodiversity, landscape and environmental quality of the Borough are maintained and/or enhanced. The Council will undertake additional tree planting, including of street trees, during the Plan period, as resources permit. Tree planting will not be encouraged in places where it could be detrimental to the current or potential nature conservation value of open habitats, such as grassland, heathland or wetlands. It may be necessary to control natural colonisation of trees in these habitats. In individual private gardens, the Council will encourage owners to replace trees lost, or developers to implement landscaping schemes in new developments, which will enhance the biodiversity and environment of a locality.
3.115 Local residents, the business community, amenity and natural history societies and development agencies can play a significant role in maintaining and improving the Borough's biodiversity and environment by retaining trees and shrubs in the gardens or grounds of properties in their ownership and by new planting, either in gardens or along streets. Residents and amenity societies are encouraged to participate in the Council's Tree Purchasing Scheme. The Council will also continue to improve general awareness of the benefits of trees and the value of nature conservation in the environment by, for example, publishing booklets and involving local schools in tree planting schemes, etc. The Council hopes that such action may reduce vandalism or the unnecessary removal of existing trees.
   
  OPEN SPACES
  Areas of Special Character
  EP31 WITHIN THE AREAS OF SPECIAL CHARACTER, AS SHOWN ON THE PROPOSALS MAP, THE COUNCIL WILL:-
    A) RESIST THE LOSS OF, OR DAMAGE TO, FEATURES WHICH CONTRIBUTE TO THE AREA OF SPECIAL CHARACTER;
    B) PRESERVE ARCHITECTURAL AND HISTORIC FEATURES WHICH CONTRIBUTE TO THE CHARACTER OF THE AREA;
    C) PROTECT SKYLINES AND VIEWS FROM INTRUSIVE DEVELOPMENT; AND
    D) ENSURE THAT REDEVELOPMENT SCHEMES PRESERVE OR IMPROVE THE CHARACTER AND APPEARANCE OF THE AREA.
   
3.116 There are two Areas of Special Character in the Borough: Harrow-on-the Hill and the Harrow Weald Ridge. The features which Areas of Special Character are intended to preserve are vulnerable to destruction or irreparable damage by development or some changes of use and this policy is an attempt to resist the loss of, or damage to, such features. A wide range of features such as ponds, meadows, hedges, ancient field patterns, copses, dykes, ditches, individual or groups of historically interesting or attractive buildings and important views and skylines all combine to establish the particular quality of the Areas of Special Character. The Areas of Special Character designated in Harrow largely consist of sloping ground, and therefore much built development is likely to be visible and possibly intrusive from over a wide area. Within the Green Belt Area of Special Character, cemeteries will only be considered when no alternative site outside the Area of Special Character can be identified. The special character of the areas is also recognised by the designation of parts of them as conservation areas containing many listed buildings (refer to Chapter 4 for further details).
3.117 The original strategic policy aims of the Areas of Special Character are still endorsed by this Council. These areas are important strategically for their architectural or historic interest, their high landscape value and townscape quality. They are essential to the retention of London's character. The Area of Special Character in the Harrow Weald area substantially coincides with the Countryside Commission's Heritage Land designation and has similar aims and objectives. Any Heritage Land not already included within the Area of Special Character will be considered for inclusion.
   
  GREEN BELT
  Acceptable Land Uses
  EP32 LAND IN THE GREEN BELT AS SHOWN ON THE PROPOSALS MAP WILL BE KEPT PRIMARILY OPEN IN CHARACTER AND FREE FROM BUILDING DEVELOPMENT. THE CONSTRUCTION OF NEW BUILDINGS FOR THE FOLLOWING USES IS ACCEPTABLE IN PRINCIPLE:-
    A) AGRICULTURE, FORESTRY, NATURE CONSERVATION AND CEMETERIES;
    B) OPEN-AIR RECREATIONAL FACILITIES WHICH MAINTAIN THE CHARACTER AND OPEN NATURE OF THE GREEN BELT, HAVE NO SIGNIFICANT ADVERSE ENVIRONMENTAL EFFECTS, AND DO NOT DAMAGE SITES OF NATURE CONSERVATION IMPORTANCE;
    C) LIMITED EXTENSION, ALTERATION OR REPLACEMENT OF EXISTING DWELLINGS (SUBJECT TO POLICY EP34 ); AND
    D) LIMITED INFILLING OR REDEVELOPMENT OF IDENTIFIED MAJOR DEVELOPED SITES (SUBJECT TO POLICY EP35).
   
3.118 PPG2: Green Belts (1995), indicates a general presumption against inappropriate development which is, by definition, harmful to the Green Belt since this is likely to affect adversely its character and openness and should, therefore, not be permitted. In considering applications for development in the Green Belt, the Council will attach substantial weight to the provisions of PPG2. Of particular concern will be the appropriateness of the proposed development and any demonstrable harm arising from it.
3.119 The Council does not regard the extension or alteration of dwellings, as well as the replacement of existing dwellings, as inappropriate, providing this does not result in disproportionate additions over and above the size of the original building. Limited infilling or redevelopment at Major Developed Sites would be subject to the criteria set out in PPG2 (Annex C3 and C4) and should have no greater impact than the existing development on the purposes of including land in the Green Belt, should not exceed the height of the existing buildings, or lead to a major increase in the developed proportion of the site. Policies EP33 and EP34 set out the general criteria which will be used to determine planning applications. However, recreational activities which require visually intrusive facilities such as stadia, pitches and courts will not be permitted.
3.120 The London Plan gives recognition to the need to safeguard the integrity of the Green Belt and requires UDPs to include land use policies which discourage their development for inappropriate uses. A variety of land uses is acceptable in the Green Belt, but such development should not compromise its integrity and environmental character. Although cemeteries could be accommodated subject to safeguards, crematoria would not be acceptable.
  Development in the Green Belt (Date of deletion 28th September 2007)
  EP33 PLANNING APPLICATIONS FOR DEVELOPMENT IN THE GREEN BELT WILL BE ASSESSED IN RELATION TO WHETHER:-
    A) THE PROPOSAL IS APPROPRIATE TO ITS GREEN BELT LOCATION;
    B) THE PROPOSAL IS WELL DESIGNED IN RELATION TO THE SIZE AND SHAPE OF THE SITE AND IN PARTICULAR, WHETHER SUFFICIENT SPACE EXISTS WITHIN THE SITE AND ITS SURROUNDINGS;
    C) THE PROPOSAL RETAINS THE OPENNESS AND CHARACTER OF THE GREEN BELT;
    D) EXISTING TREES AND NATURAL FEATURES ARE RETAINED, AND A HIGH STANDARD OF LANDSCAPING COULD BE ACHIEVED;
    E) ANY PROPOSED STRUCTURE WOULD CONFLICT WITH THE PURPOSES AND THE PROPER FUNCTIONING OF THE GREEN BELT;
    F) ANY ASPECT OF THE PROPOSAL WOULD HAVE AN ADVERSE VISUAL IMPACT ON THE SKYLINE AND ADJACENT AREAS; AND
    G) IN THE CASE OF REPLACEMENT DWELLINGS THERE WOULD BE ANY MATERIAL INCREASE IN SITE COVERAGE, BULK AND HEIGHT OF BUILDINGS.
   
3.121 Development and changes of use will be strictly controlled within the Green Belt to ensure that such land remains primarily open and existing environmental character is maintained or enhanced. Limited building development will be considered where it is necessary to support or maintain the functional viability of appropriate Green Belt uses. The Council recognises that existing residential properties will remain and will allow replacement dwellings, subject to the above requirements. New residential development will not be permitted, to prevent the coalescence of urban areas. In the case of major developed sites or land being declared redundant in the Green Belt, regard will be had to the provision of PPG2 Annex C, alongside the policies of this Plan. The visual amenities of the Green Belt should not be injured by development which, although of a type acceptable in the Green Belt, might be inappropriate by reason of its siting, materials or design.
3.122 With regard to replacement dwellings in the Green Belt, where these involve relocation, the original site should be properly reinstated with appropriate planting and landscaping before the replacement dwellings are occupied. The Council considers it important to protect the character of the Green Belt by ensuring that ancillary facilities, such as car parking, do not have an adverse impact, and will take these into account in considering whether a proposal is acceptable. Intensification of uses in the Green Belt will be considered in the same light. The replacement of existing dwellings need not be inappropriate development providing the new dwellings are not materially larger than those being replaced.
  Extension to Buildings in the Green Belt
  EP34 PROPOSALS TO EXTEND BUILDINGS, INCLUDING RESIDENTIAL UNITS, IN THE GREEN BELT SHOULD:-
    A) MINIMISE ADVERSE ENVIRONMENTAL IMPACT ON THE GREEN BELT CHARACTER AND BE APPROPRIATE IN TERMS OF BULK, HEIGHT AND SITE COVERAGE IN RELATION TO TOTAL SITE AREA;
    B) IN THE CASE OF EXTENSIONS TO DWELLINGS, NOT RESULT IN DISPROPORTIONATE ADDITIONS OVER AND ABOVE THE SIZE OF THE ORIGINAL DWELLING; AND
    C) CONTRIBUTE TO THE REDUCTION OF ANY EXISTING ENVIRONMENTAL PROBLEMS ON THE SITE.
       
3.123 This policy provides criteria by which an appropriate size of extension can be determined for each particular site, without resorting to a maximum allowable size which inevitably could become a minimum for most developments. As well as being used to assess the impact on the specific site, these criteria should also be considered in relation to the effect on the character of the surrounding area. The Council's objective is to strictly control the size of any extension in order to minimise the impact on the Green Belt. Extensions will also need to satisfy Policy D4. In addition, the Council regards the size of the original building (see Schedule 1 - Glossary of Terms) and the amount of space around the building as two important factors to be considered when dealing with proposals for extensions in the Green Belt. Criterion B) reflects specific advice in PPG2 and should not be taken to imply that disproportionate additions would be acceptable for buildings other than dwellings.
  Major Developed Sites in the Green Belt
  EP35 IN HARROW'S GREEN BELT THE FOLLOWING SITES ARE SPECIFICALLY IDENTIFIED AS MAJOR DEVELOPED SITES:
    1) BAE SYSTEMS LIMITED;
    2) HARROW COLLEGE, WEALD CAMPUS;
    3) ROYAL NATIONAL ORTHOPAEDIC HOSPITAL;
    4) RAF BENTLEY PRIORY; AND
    5) GOVERNMENT OFFICES, BROCKLEY HILL.
    THE COUNCIL WILL PREPARE DEVELOPMENT BRIEFS FOR THE SITES WHERE THERE IS PRESSURE FOR DEVELOPMENT.
   
3.124 PPG2 (Annex C) recognises the presence of some major developed sites in the Green Belt which may be in continuing use or redundant. In dealing with such sites, the Council will consider the extent of the development and any development brief for the site. In addition, any future development proposals would need to conform to the criteria set out in paragraph C3 and C4 as well as paragraphs C15-C17 of PPG2 Annex C, in association with the policies of this Plan. The development envelope for Harrow College (Weald Campus), indicating substantially the existing extent of development, is shown on the Proposals Map.
  Agriculture
  EP36 THE COUNCIL WILL ENCOURAGE THE RETENTION OF EXISTING FARM LAND IN THE GREEN BELT IN ORDER TO PROTECT THE RURAL CHARACTER AND FEATURES WHICH HAVE EVOLVED OVER A NUMBER OF YEARS. DEVELOPMENT WILL ONLY BE ALLOWED IF IT CAN BE SHOWN TO THE SATISFACTION OF THE COUNCIL THAT:-
    A) OTHER SIGNIFICANT GREEN BELT ADVANTAGES SUCH AS IMPROVED LANDSCAPING AND FACILITIES FOR PUBLIC ACCESS WILL RESULT;
    B) IT WILL BE DEVELOPED IN CONJUNCTION WITH AN APPROPRIATE GREEN BELT USE; AND
    C) IT WILL NOT RESULT IN THE LOSS OF GOOD QUALITY AGRICULTURAL LAND.
    D) OTHER CRITERIA FOR DEVELOPMENT IN THE GREEN BELT AS SET OUT IN POLICIES EP32 AND EP33 ARE MET.
    THE COUNCIL WILL SEEK TO ENSURE THAT IMPROVEMENTS TO THE APPEARANCE AND CHARACTER OF THE LAND, AND ITS VALUE FOR NATURE CONSERVATION, WILL BE SECURED BY THE IMPLEMENTATION OF APPROPRIATE LAND MANAGEMENT.
   
3.125 Farmland in the Green Belt is under continuing pressure to change, particularly on the inner edge of the Metropolitan Green Belt. The Green Belt area of Harrow is distinctive because of its high quality visual character. It is recognised that agricultural land uses are a major element of this distinctive character (e.g. because of field patterns, hedges, ponds etc.) and therefore agricultural land warrants protection and retention wherever possible and practicable. Whilst there is currently the need to bring food production and demand into balance through the EU Common Agricultural Policy reform measures, this does not detract from the continuing need to protect the best and most versatile land as an important national resource for the future. With the continuing downward pressure on farm incomes it is also recognised that there is a need to enable farmers to diversify their businesses, which in turn helps to facilitate a healthy rural economy and ensure continued management of the countryside. Agricultural land should be retained in such a way that the visual quality and character of the land is not diminished and the distinctive rural character is retained even if a change to another acceptable Green Belt use is proposed. Any redundant farm buildings should be put to an appropriate new use.
  Re-Use of Existing Buildings in the Green Belt
  EP37 THE COUNCIL WILL CONSIDER APPLICATIONS FOR PLANNING PERMISSION FOR THE RE-USE OF EXISTING BUILDINGS IN THE GREEN BELT BY REFERENCE TO THE CRITERIA SET OUT UNDER POLICY EP34 AND THE FOLLOWING ADDITIONAL CRITERIA:-
    A) WHETHER ANY OF THE BUILDINGS HAVE BEEN ERECTED UNDER THE GENERAL PERMITTED DEVELOPMENT ORDER WITHIN FOUR YEARS PRIOR TO THE APPLICATION;
    B) WHETHER THE PROPOSED USE HAS A MATERIALLY GREATER IMPACT THAN THE PRESENT USE ON THE OPENNESS OF THE GREEN BELT AND THE PURPOSES OF INCLUDING LAND IN IT;
    C) WHETHER THE BUILDINGS ARE OF PERMANENT AND SUBSTANTIAL CONSTRUCTION AND ARE CAPABLE OF CONVERSION WITHOUT MAJOR OR COMPLETE RECONSTRUCTION; AND
    D) WHETHER THERE IS A NEED TO WITHDRAW PERMITTED DEVELOPMENT RIGHTS FOR ANY SUBSEQUENT DEVELOPMENT.
   
3.126 PPG2 stresses the importance of the need to discourage abuse of Permitted Development rights. The Council therefore acknowledges the desirability of re-using existing buildings in the Green Belt, subject to the normal criteria controlling any development, but with the necessary safeguards to prevent abuse of Permitted Development rights and detrimental effect on the openness of the Green Belt.
3.127 In order to discourage abuse of Permitted Development rights, particular attention would need to be paid to applications for re-use made within 4 years of the completion of agricultural buildings erected under the General Permitted Development Order. The Council will need to consider among other things whether the re-use of farm buildings constructed under Permitted Development rights could have a serious detrimental effect on the openness of the Green Belt.
  Recreational Uses in the Green Belt
  EP38 THE COUNCIL WILL PROMOTE OPEN AIR RECREATION IN THE GREEN BELT WHICH MAINTAINS THE OPEN NATURE AND CHARACTER OF THE GREEN BELT, HAS NO SIGNIFICANT ADVERSE ENVIRONMENTAL EFFECTS, AND DOES NOT DAMAGE SITES OF NATURE CONSERVATION IMPORTANCE, BY:-
    A) PRESERVING EXISTING RECREATIONAL OPEN SPACE; AND
    B) INCREASING THE AMOUNT OF RECREATIONAL LAND AND FACILITIES AVAILABLE TO THE PUBLIC.
       
3.128 Large areas of open land within Harrow's Green Belt are used for informal recreation. In view of the growing demand for recreational opportunities, the Council will strictly protect existing recreational open space in the Green Belt and increase the amount available to the public, provided this does not undermine the character of the Green Belt and is sensitive to ecological interests. Examples of recreation facilities likely to be acceptable include facilities for picnicking, nature study, walking, jogging or other activities that do not require formal facilities such as pitches or courts.
  Land for Recreation in the Green Belt
  EP39 THE COUNCIL WILL ENDEAVOUR TO BRING ADDITIONAL LAND INTO PUBLIC USE IN THE GREEN BELT AT GLENTHORNE, COMMON ROAD AND HARROW WEALD PARK, BROOKSHILL, TO THE EXTENT THAT THIS IS CONSISTENT WITH THE INTERESTS OF NATURE CONSERVATION.
   
3.129 Proposals for increasing informal recreation primarily involve sites in the Green Belt, where land is more readily available and can be brought into public use. Bringing further sites into public use will help reduce constraints on recreation in the Green Belt, e.g. lack of car parking space and picnic sites, an inadequate footpath and bridleway network and conflicts between different recreation uses and landowners. A rich variety of flora and fauna are to be found at Glenthorne and Harrow Weald Park, including some uncommon species and valuable habitats. Access may need to be restricted to protect habitats and wildlife from undue disturbance, thereby ensuring their continued survival, and that future generations are afforded the opportunity to enjoy them. The Green Belt Management Strategy provides an overall context for improvement. Priorities include improving new sites, such as Glenthorne and Harrow Weald Park, and continuing to improve picnicking facilities and car parking at existing sites such as Old Redding.
  Buildings for Indoor Recreation Use in the Green Belt
  EP40 THE COUNCIL WILL RESIST THE CONSTRUCTION OF BUILDINGS FOR INDOOR RECREATIONAL PURPOSES IN THE GREEN BELT.
   
3.130 The Council does not favour the construction of buildings for indoor recreational purposes because of their possible visual impact on the Green Belt. However, the Council wishes to increase the amount of recreational land and facilities available to the public. In order to maintain the integrity and openness of the Green Belt only essential small-scale ancillary recreational buildings, which support the acceptable recreational uses, will be permitted. Appropriate landscaping will be required to minimise the visual impact of such ancillary buildings on the character of the Green Belt.
  Green Belt Management Strategy
  EP41 IN CONSIDERING PLANNING APPLICATIONS IN THE GREEN BELT, THE COUNCIL WILL TAKE THE MANAGEMENT PLANS OF INDIVIDUAL SITES OR AREAS INTO ACCOUNT.
   
3.131 The Council has approved a Management Strategy which states the Council's main aims for the future of the Harrow Green Belt. Decisions on planning applications should conform to these aims. In particular, development on sites for which a management plan has been prepared within the context of the strategy should fully accord with the requirements of that management plan. The Strategy sets out a broad framework for the proper management of land, recreation, access, information and nature conservation in the Green Belt, and sets priorities for the preparation of management plans. It forms Supplementary Planning Guidance to the Plan, and copies may be obtained from the Local Planning Authority.
3.132 Within the framework of the Strategy, management plans will contain proposals for the implementation of countryside management. In particular, access to the Green Belt will be enhanced through the provision and improvement of footpath networks. The Bentley Priory Circular Walk was the first example of this kind followed by the Pinner-Grimsdyke Circular Walk in the west of Harrow's Green Belt, linking with the Bentley Priory Circular Walk.
  Watling Chase Community Forest
  EP42 THE COUNCIL SUPPORTS THE AIMS OF THE WATLING CHASE COMMUNITY FOREST AND WILL ENCOURAGE PROPOSALS THAT SECURE ITS EFFECTIVE IMPLEMENTATION, PROVIDED THEY ARE CONSISTENT WITH GREEN BELT OBJECTIVES AND AREA OF SPECIAL CHARACTER.
   
3.133 The Watling Chase Community Forest covers an extensive area in Hertfordshire stretching down to the northern edge of London. The intention is to create a large 'forest' landscape for wildlife, work, recreation and education. Although only a small part of the Forest lies within the Borough (see Text Map 5), the Council wishes to support the principles behind its creation as set out in the Community Forest Plan, and appropriate proposals which contribute to its development. Where appropriate, the Council will support proposals which facilitate improved access to the countryside and provide appropriate outdoor leisure and recreation facilities. All proposals within the Forest should include landscaping proposals that are compatible with their location within this part of the Forest. This will usually involve tree planting and/or landscaping that enhances the current landscape. The Council will consider the need to produce Supplementary Planning Guidance where this will assist the development of the Forest.
  Green Belt and Metropolitan Open Land Fringes
  EP43 THE COUNCIL WILL RESIST DEVELOPMENT PROPOSALS ADJACENT OR CLOSE TO GREEN BELT OR METROPOLITAN OPEN LAND WHICH WOULD HAVE A DETRIMENTAL VISUAL IMPACT ON THE OPEN CHARACTER OF THAT LAND OR AN ADVERSE ECOLOGICAL IMPACT. WHERE NEW DEVELOPMENT IS PROPOSED ON LAND ADJACENT TO THE GREEN BELT OR METROPOLITAN OPEN LAND, OR ON SITES IDENTIFIED AS IMPORTANT FOR NATURE CONSERVATION, THE COUNCIL WILL HAVE REGARD TO THE OPPORTUNITIES FOR:-
    A) THE RETENTION OF EXISTING TREES AND NATURAL FEATURES SUCH AS PONDS AND AREAS VALUABLE TO WILDLIFE AND NATURE CONSERVATION;
    B) THE RETENTION OF THE EXISTING LANDSCAPE CHARACTER; AND
    C) SYMPATHETIC AND COMPLEMENTARY LANDSCAPE SCHEMES AND THE CREATION OF FEATURES, USING INDIGENOUS PLANT SPECIES, WHICH ATTRACT WILDLIFE.
   
3.134 Land adjacent to the Green Belt, including sites of nature conservation importance, is important because it forms part of the distinctive character and natural habitat of the Green Belt. It is also important for enhancing views from the Green Belt and the openness of such areas. The London Plan states that Metropolitan Open Land should have protection equal to that of Green Belt. Therefore this policy is equally applicable to Green Belt and Metropolitan Open Land. PPG2 supports the argument for controlling the visual impact of proposals which are conspicuous from the Green Belt, although outside it, and there is a logical need to exercise similar control over development adjacent to Metropolitan Open Land, or in some cases, close to (but not abutting) Metropolitan Open Land. Development in such an area that detract from the open character of Metropolitan Open Land, should be resisted. This can include an impact which is detrimental to buildings, landscapes, views, natural features, and ecological aspects, which have been recognised because of their strategic importance to the whole or part of London. Therefore, the protection and enhancement of this land must be a priority to ensure that the aims of Green Belt, Metropolitan Open Land and nature conservation policies are successfully achieved.
3.135 Land adjacent to the boundary should be carefully considered in relation to its effect on the ecology of the Green Belt and also for its own ecological value. Where planning applications are being considered, their impact on ecology can be regulated through retention of ecological features, planting of native species attractive to wildlife, etc. The Council is able to give advice on these aspects. Ecological factors should be important considerations in land adjacent to identified sites of nature conservation importance. In these areas, preserving all trees as well as much of the natural vegetation, in new development schemes, should ensure a continuous wildlife habitat up to and beyond the boundaries of identified sites. Appropriate new planting and landscaping is of particular importance here.
  Metropolitan Open Land
  EP44 METROPOLITAN OPEN LAND AS SHOWN ON THE PROPOSALS MAP WILL BE KEPT PRIMARILY OPEN IN CHARACTER AND FREE FROM BUILDING DEVELOPMENT. THE FOLLOWING LAND USES ARE APPROPRIATE:-
    A) PUBLIC AND PRIVATE OPEN SPACE AND PLAYING FIELDS;
    B) AGRICULTURE, ORCHARDS AND WOODLANDS;
    C) GOLF COURSES;
    D) NATURE CONSERVATION; AND
    E) ALLOTMENTS.
    WHERE AREAS OF METROPOLITAN OPEN LAND COINCIDE WITH AREAS OF SPECIAL CHARACTER, ALLOTMENTS WILL NOT BE ALLOWED AS THEY HAVE A DETRIMENTAL IMPACT IN THE CHARACTER OF THESE AREAS.
   
3.136 Within Greater London, there are a number of extensive areas of open land which provide useful and attractive breaks in the built up area and are of strategic significance. The London Plan recommends that Metropolitan Open Land be accorded the same level of protection as Green Belt. It also requires UDPs to have land use policies on nature conservation, a use which is desirable in Metropolitan Open Land and Areas of Special Character, and to include this in the list of acceptable uses in Metropolitan Open Land. In accordance with national guidance, and given that such uses do not destroy the open and often attractive character of Metropolitan Open Land, these uses can be permitted. Playing fields are acceptable, as, unlike Green Belt, Metropolitan Open Land is located within urban fabric, near centres of demand for recreational facilities, and is not necessarily protected for its countryside character, but rather for its open character and provision for community needs.
  Additional Building on Metropolitan Open Land
  EP45 ADDITIONAL BUILDING (INCLUDING EXTENSIONS) WILL ONLY BE PERMITTED ON METROPOLITAN OPEN LAND WHERE IT CAN BE DEMONSTRATED THAT IT IS ESSENTIAL FOR THE PROPER FUNCTIONING OF THE PERMITTED LAND USE. SUCH DEVELOPMENT SHOULD NOT HAVE AN ADVERSE IMPACT ON THE CHARACTER OF THE AREA. IT WILL BE ASSESSED IN RELATION TO SIZE, DESIGN AND SITING. THE COUNCIL WILL REQUIRE LANDSCAPING DESIGNED TO ENHANCE NATURE CONSERVATION (E.G. THROUGH THE PLANTING OF INDIGENOUS SPECIES), WHERE APPROPRIATE.
   
3.137 The Council wishes to limit the amount of additional building and hardsurfacing on Metropolitan Open Land to a minimum in order to protect its open character. Therefore, rather than supporting applications for ancillary development, the Council requires that the need be adequately demonstrated before planning permission can be granted.
3.138 The Council accepts that ancillary development may be necessary to sustain open land uses, but will carefully consider each planning application to ensure that the open character and views to and from Metropolitan Open Land are minimally affected. The character of these areas should be sustained and enhanced through landscaping, bearing in mind that the openness of Metropolitan Open Land is a particular feature which should be protected.
3.139 Redundant educational or institutional buildings within Metropolitan Open Land are considered suitable for recreational uses if the remainder of the site is retained as open space. The Council wishes to encourage the provision of outdoor recreational open space which is not detrimental to the aims of Metropolitan Open Land protection, and which contributes to the general amenity of the area. Replacement buildings should not encroach on the openness of the Metropolitan Open Land, therefore no increase in site coverage, bulk or height will be permitted.
  Green Chains
  EP46 THE COUNCIL WILL SAFEGUARD THE BOROUGH'S GREEN CHAINS AND WHERE POSSIBLE IMPROVE THEIR CONTINUITY BY RESISTING DEVELOPMENT THAT WOULD IMPAIR THEIR OPEN CHARACTER AND CREATING, EXTENDING OR ENHANCING GREEN CHAINS WHERE OPPORTUNITIES ARISE THROUGH THE DEVELOPMENT PROCESS AND OTHER MECHANISMS. GREEN CHAINS WILL BE MANAGED FOR NATURE CONSERVATION, PUBLIC ACCESS (INCLUDING FOOTPATHS AND CYCLEWAYS WHERE APPROPRIATE) AND OPEN AIR RECREATION. THE FOLLOWING GREEN CHAINS ARE SHOWN ON THE PROPOSALS MAP:-
    A) RIVER PINN FROM CANNON LANE TO BOROUGH BOUNDARY;
    B) YEADING BROOK FROM NORTHUMBERLAND AVENUE TO BOROUGH BOUNDARY;
    C) FORMER BELMONT RAILWAY LINE, MONTROSE WALK AND LAND AT STANMORE PARK.
       
3.140 Green Chains are linked open spaces, which normally follow a river or other linear feature such a former railway line. Green Chains can take the form of narrow linear spaces or pedestrian/ cycle routes linking a series of open spaces or wider areas of interlinked open space designated as Metropolitan Open Land. Serving a number of functions, including nature conservation, recreation and breaks in the urban fabric, Green Chains can incorporate or connect with Metropolitan Open Land, parks and open spaces and can link to Green Belt areas and other Boroughs.
3.141 As pressure for development in built-up areas increases, opportunities for walking and cycling in peaceful, natural surroundings away from traffic are likely to become increasingly important to maintaining quality of life in urban areas. As part of the Council's commitment to improving public access to open areas and protecting the Borough's open and pleasant character consideration will be given to finding ways to enhance, extend or create Green Chains and to working with neighbouring Boroughs and other organisations, such as the London Walking Forum, to achieve this.
3.142 Green Chains should be distinguished from Green Corridors whose purpose is to serve as a wildlife corridor and enhance visual amenity and which may not have public access (railway embankments do not, for example), although in practice designations can overlap. Green Chains can be of strategic significance, for example, where Borough boundaries are crossed or links to Metropolitan Open Land provided. Uses appropriate to Green Chains are those that retain and enhance their open character, do not require built facilities and enable public access, such as nature conservation and outdoor recreation. Green Chains will be accorded the same level of protection as Metropolitan Open Land in policy terms.
  Open Space
  EP47 THE COUNCIL WILL PROTECT AND WHERE APPROPRIATE ENHANCE THE BOROUGH'S OPEN SPACES, PARKS, PLAYING FIELDS AND RECREATION GROUNDS, REGARDLESS OF OWNERSHIP. DEVELOPMENT, APART FROM SMALL SCALE ANCILLARY FACILITIES NEEDED TO SUPPORT OR ENHANCE THE PROPER FUNCTIONING OF THE OPEN SPACE, WILL NOT BE PERMITTED ON OPEN SPACES IDENTIFIED ON THE PROPOSALS MAP AND ON OTHER OPEN SPACES WITH RECREATIONAL, NATURE CONSERVATION OR AMENITY VALUE OR LOCATED IN AREAS LACKING SUCH SITES UNLESS THE SITE IS SURPLUS TO REQUIREMENTS OR SUITABLE ALTERNATIVE PROVISION IS MADE AVAILABLE.
       
3.143 Types of open space in need of protection include: Public Open Space, Private Open Space, Educational Open Space, Informal Open Space, Allotments and Cemeteries.
3.144 Protecting open space as a resource is important because once an open space is lost to built development it is difficult to replace. In protecting open spaces, due regard will be given to enhancing both the quality and quantity of open spaces and their distribution across the Borough. Planning permission will only be granted for non-recreational development of open spaces and playing fields where it has been demonstrated that the open space is surplus to requirements and consideration to all alternative open space and recreational functions have been explored in accordance with PPG17 para10.
3.145 The quality and function of open space can be adversely affected by insensitive development. In assessing proposals for the use of open space consideration will be given to the appropriateness of the use. To maintain the character and openness of the Borough's green spaces, ancillary buildings will be permitted only if necessary to the functioning of the open space. These should be small in scale, sensitively sited and should not compromise the open character of the space. Built development will be assessed in terms of bulk, size, design and location to ensure that it is sensitive to its surroundings. Re-use of buildings for community or leisure use, where appropriate, will be encouraged. Appropriate landscaping around new ancillary buildings will be required. Landscaping which is attractive to wildlife will be encouraged.
3.146 Alternative open space functions will also be considered for unused sites to prevent their unnecessary loss to inappropriate development. The Council will seek the views of communities as to how opportunities for recreation and open spaces can be delivered and apply the proposals stated in Policy SR1 and para 2.107 to development pressures likely to endanger the loss of open space and recreational facilities in the Borough. In the event that replacement open space or other open recreational facilities are brought forward, they should be at least as accessible to current and potential new users, and at least equivalent in terms of size, usefulness, attractiveness and quality.
3.144 Protecting open space as a resource is important because once an open space is lost to built development it is difficult to replace. In protecting open spaces, due regard will be given to enhancing both the quality and quantity of open spaces and their distribution across the Borough. Planning permission will only be granted for non-recreational development of open spaces and playing fields where it has been demonstrated that the open space is surplus to requirements and consideration to all alternative open space and recreational functions have been explored in accordance with PPG17 para10.
3.145 The quality and function of open space can be adversely affected by insensitive development. In assessing proposals for the use of open space consideration will be given to the appropriateness of the use. To maintain the character and openness of the Borough's green spaces, ancillary buildings will be permitted only if necessary to the functioning of the open space. These should be small in scale, sensitively sited and should not compromise the open character of the space. Built development will be assessed in terms of bulk, size, design and location to ensure that it is sensitive to its surroundings. Re-use of buildings for community or leisure use, where appropriate, will be encouraged. Appropriate landscaping around new ancillary buildings will be required. Landscaping which is attractive to wildlife will be encouraged.
3.146 Alternative open space functions will also be considered for unused sites to prevent their unnecessary loss to inappropriate development. The Council will seek the views of communities as to how opportunities for recreation and open spaces can be delivered and apply the proposals stated in Policy SR1 and para 2.107 to development pressures likely to endanger the loss of open space and recreational facilities in the Borough. In the event that replacement open space or other open recreational facilities are brought forward, they should be at least as accessible to current and potential new users, and at least equivalent in terms of size, usefulness, attractiveness and quality.
3.147 Private open space makes a vital contribution to recreational and sporting opportunities, especially in built up areas of the Borough. Educational open space also covers an extensive area, although many of the Council's schools have insufficient on-site space. Much of this is playing fields, and is therefore vital for students who wish to play outdoor sports. Where appropriate, and especially where there is a lack of local community sports facilities, arrangements will be sought to facilitate dual use by the public. In areas of public open space deficiency private open space can have increased amenity value for the community.
3.148 There is considerable inter-borough use of playing fields in London. Harrow's pitches are used by residents of other Boroughs, while Harrow residents travel outside the Borough to use pitches elsewhere. Harrow's playing fields, therefore, should be viewed in the context of regional provision and demand for pitches. Considering demand solely within the Borough, provision of playing fields is marginally above the minimum standard of 1.2 hectares (3 acres) per 1000 population recommended by the Sports Council and the National Playing Fields Association in the Playing Pitch Strategy (1991). Despite much use being made of the Council's soccer and cricket pitches, there is a demand for better quality facilities that the Borough is unable to meet. Better use might be made of existing facilities by, for example, floodlighting where appropriate, and improving drainage, access and changing facilities. Where floodlighting is to be used, measures, such as cut-off lighting can minimise adverse impacts. Such proposals should comply with policy D21. There is concern that future generations may not have facilities to play pitch sports since replacing playing fields that have been developed is almost, if not completely, impossible.
3.149 The Department for Education and Employment advises that future demand for educational playing fields should be taken into account, in terms of school numbers and in terms of whether an educational open space can contribute towards meeting local community needs for open space when considering the future of playing fields. To ensure future generations have opportunities to play pitch sports, there will be a presumption against the development of playing fields except where suitable alternative provision is made. This should be accessible, convenient, and of at least equivalent quality and quantity. At the same time, the Council recognises that open space needs can change over time and will be sympathetic to proposals where a change of use from one open space type to another is the best way of meeting these. Types of publicly accessible open space are shown in Schedule 2.
3.150 Parks, open spaces and playing fields play an important role as soak areas for groundwater. The Council acknowledges that building on such undeveloped land should be minimised to ensure that drainage problems do not arise.
3.151 Car parking on open space that is unrelated to the open space use, whether temporary or permanent, will not be permitted. Parking on a temporary basis to serve a related open space use may be permitted where the Council considers appropriate.
  Public Open Space
  EP48 THE COUNCIL WILL SEEK TO IMPROVE THE AMOUNT AND DISTRIBUTION OF PUBLIC OPEN SPACE WITHIN THE BOROUGH AND WILL DEVELOP AND EXTEND LOCAL PARKS AND PUBLIC OPEN SPACES AT RAF STANMORE PARK, AND ROXETH ALLOTMENT SITE, SOUTH HARROW. PRIORITY WILL BE GIVEN TO THE USE OF SITES WHICH CAN REDUCE LOCAL PARK DEFICIENCY.
   
3.152 Certain areas of the Borough are more generously provided with public open space than others: in some more densely built up areas residents may have to travel unacceptably long distances to their nearest park, disadvantaging those with mobility difficulties, small children or those without a car. However, there are a number of constraints in securing additional public open space, such as competition from other land uses, high land values and available finance.
3.153 Areas lacking public open space have been identified using the local open space accessibility standards set out in The London Plan (see also Schedule 2). Deficiencies of public open space can only be addressed at local park level because of the lack of sites in the Borough of sufficient size to provide district parks (see Text Map 6). Scope for increasing the amount and distribution of public open spaces in the Borough is therefore limited, nevertheless the Council will investigate ways in which this can be achieved. Local parks should be accessible, encourage casual use by the public and be located close to residential areas, to make them convenient for local residents.
3.154 Proposals to increase provision of public open space are shown above. Of these, land at Roxeth Allotments will help offset local park deficiency. Sites identified in this Policy are shown on the Proposals Map. Further opportunities may arise over the duration of this Plan. The Council will encourage similar provision by neighbouring authorities where this would be to mutual advantage to address local park deficiencies near the Borough boundary.
  Allotments
  EP49 THE COUNCIL WILL ENDEAVOUR TO RETAIN ALLOTMENT SITES IN THEIR CURRENT USE. ON SITES IDENTIFIED AS SURPLUS TO REQUIREMENTS PREFERENCE WILL BE GIVEN TO ANOTHER OPEN SPACE USE. BUILT DEVELOPMENT, ON PART OR ALL OF A SITE, WILL ONLY BE PERMITTED WHERE:-
    A) THERE IS NO DEFICIENCY IN PUBLIC OPEN SPACE OR DEMAND FOR RECREATIONAL FACILITIES THAT COULD BE REMEDIED BY ALLOCATING THE SITE FOR THAT PURPOSE;
    B) CONSIDERATION HAS BEEN GIVEN TO AN ALTERNATIVE OPEN SPACE USE AND NONE IS FOUND TO BE SUITABLE FOR THE SITE; AND
    C) THE SITE MAKES NO SIGNIFICANT CONTRIBUTION TO THE ENVIRONMENTAL CHARACTER OF THE AREA.
       
3.155 The Council aims to ensure that adequate allotment land continues to be available to meet the needs of the Borough's residents. Allotments combine opportunities for leisure, exercise and social contact with the practical benefits of growing cheap, healthy food. They are thus a valuable community resource. The benefits of food growing in urban areas are increasingly recognised. Several factors suggest that, nationally, demand for allotments may increase: public concern over health and the environment; increasing numbers of elderly people who are fit and active; and, in the context of higher housing densities, the need to provide a range of alternatives to private gardens. Demand in Harrow has remained fairly constant over the past 10 years. However, demand is affected by many factors, including condition and security of sites, facilities, accessibility, publicity and promotion. Assessment of provision should take into account current and future demand, including demand from other Boroughs, and demographic change.
3.156 Use of allotments close to where people live will be particularly encouraged, to reduce the need to travel and improve access for people without cars. There may be scope to broaden the role of allotments on underused sites to encompass some public open space where this would best meet local community needs. The Council will consider taking all or part of under-used allotments into temporary open space use where appropriate.
3.157 The Council recognises the contribution allotments make to the open character of the Borough and environmental quality. As an allotment once built on is difficult to replace, there will be a presumption against built development on such sites. Where allotments are underused, consideration will be given as to whether they have been properly marketed, are in poor condition or lack facilities, before allowing a change of use. Built development will be permitted only where an open space use is not needed or suitable and there is no detrimental impact on the environment. Alternative open space uses can include community garden, leisure garden, park or nature reserve. Provision should be made for displaced allotment holders of at least equivalent quality, quantity and terms of tenure within reasonable distance.
3.158 The Council will be sympathetic to the needs of plot holders who wish to garden organically and will investigate ways to encourage community gardening and food growing schemes.
  Informal Areas of Open Space
  EP50 IN CONSIDERING PROPOSALS AFFECTING AN INFORMAL AREA OF OPEN SPACE THE COUNCIL WILL TAKE INTO ACCOUNT:-
    A) THE CURRENT USES OF THE OPEN SPACE;
    B) WHETHER THE SPACE PROVIDES A FOCAL POINT IN THE LOCAL TOWNSCAPE;
    C) WHETHER THE SPACE PROVIDES AN ATTRACTIVE SETTING FOR A D) BUILDING (OR A GROUP OF BUILDINGS);
    D) WHETHER THE SPACE PROVIDES SIGNIFICANT VISUAL RELIEF WITHIN THE BUILT-UP AREA;
    E) THE EXISTING OR POTENTIAL NATURE CONSERVATION VALUE OF THE SITE; AND
    F) WHETHER THE SPACE IS IN AN AREA OF OPEN SPACE OR NATURE CONSERVATION DEFICIENCY.
   
3.159 Besides more extensive areas of open space, within the Borough there is a diverse range of smaller areas including "informal open space", such as grassed areas on housing estates. These areas contribute in a significant way to the townscape, and thereby to the character of the Borough.
3.160 Open areas can provide a visual focal point in a locality, and can give short or long distance views of interest. Similarly, within built up areas the existence of informal open space can provide a contrast to buildings particularly where they provide an attractive landscaped feature. Such areas, if they are derelict or in an unkempt state, may be improved through sympathetic landscaping to enhance the quality of a locality. Policy D9 highlights the Council's commitment to achieve a high quality of forecourt greenness and street greenery in the Borough, securing enhancements to small informal areas of open space and is a logical extension to this approach. Improvements to all three types of greenery combine to enhance the overall environmental quality of the locality. With regard to the biodiversity of the Borough, such areas are likely to have an increasing ecological and/or landscape and amenity value, particularly as more effective and intensive use is made of urban land.
3.161 Small open spaces have a vital role to play in creating an attractive urban environment and can support a variety of plants and wildlife, thereby providing opportunities for people to enjoy nature close to where they live. Informal and incidental open spaces can contribute to Biodiversity Action Plan objectives. The Council encourages sustainable ecological projects in partnership with the local community and others. The development of agreed management plans will enable the local community to play an active role in securing ecologically sound nature conservation management of appropriate sites on informal and incidental open spaces. A network of inter-linked open spaces will create conditions for a wider range of species to thrive than would be possible with isolated spaces. Consideration will also be given to identifying, creating and enhancing links between smaller open spaces and larger open spaces or areas of nature conservation interest, where resources permit. Only in exceptional circumstances, where sites are devoid of nature conservation and amenity value (existing or potential) and serve no other useful purpose (such as breaks in the urban fabric, play areas), will their use for off-street parking or extensions to gardens or houses be permitted.
   
   
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