2. Reputational and Legal Risks to the Council
Approval of this development exposes the Council to liabilities for flood-related loss of life or property, as well as reputational damage for failing to act responsibly in safeguarding public safety.

3. Failure to Follow a ‘Design-led’ Approach has led to Flawed Designs which Fail to Meet Community Needs
Proposals are supposed to be ‘design-led’, which means that the most appropriate form of development should be preferred over simply ‘maximising density’.  This approach should:

• Engage in meaningful upfront engagement with local communities to capitalise on their insight and knowledge;
• Respond to the existing character and distinctiveness of an area; and for residential applications
• Determine an appropriate indicative site capacity.

• at the time the developers were engaged, the number of indicative units for the site in emerging Local Plan was 160 not 300 to 350; so
• Tall residential buildings were inevitably designed which is an inappropriate response to a distinctly low-rise residential area; and therefore
• By the time presentations to residents were made, it was too late for meaningful engagement.

The result is a set of proposals that:

• completely ignores residents’ legitimate and stated concerns that the Environment Agency believed the main site to be unsafe for a residential development;
• defies garden suburb principles;
• ignores the local housing need for family-sized homes; and
• transforms the library site from its intentional public realm setting into a private-use setting (albeit publicly owned).

4.  Marked Departure from Building Heights Currently Proposed in Similar Circumstances Elsewhere
The number of storeys on Site 1 is six to thirteen.  Yet the maximum height proposed for a car park site in a neighbouring ward is as low as six.  There does not appear to be a valid reason for the approach to Site 1 especially since it is in a low-rise Conservation Area (and the neighbouring proposal is not).  Furthermore, the Site 1 is not in an Opportunity Area, nor on the A5, so it should not be considered a candidate for Tall Buildings.

5. Watling Estate Conservation Area Character Undermined
The height, mass, and scale of the proposed residential buildings are excessively tall, fail to protect or enhance the character of the Watling Estate, disregarding and undermining its garden-suburb heritage. This approach is contrary to national policy.

6. Regeneration Goals are not Achieved
The development fails to deliver on the expected remit of a regeneration, introducing:

• A significant overcrowding risk given that the large population increase will be in a ward with one of the highest population density figures in the borough;
• Single-aspect flats which are known to be unsuitable for post-pandemic living; and
• High insurance costs unfairly transferred to residents due to increased flood risks.

7. Overstretched Local Infrastructure
No additional healthcare provision is proposed, leaving services unable to cope with the population increase. Public transport will be overburdened.   The enlarged built footprint will increase surface water runoff, overwhelm local sewers, which in turn increases flood risks.

8. Environmentally Unsustainable Library Redevelopment and Ecologically Unsuccessful
Demolishing and rebuilding the library unnecessarily increases environmental impacts. Retrofitting the existing structure would be more sustainable as well as practical because:

• It would be consistent with the Council’s ‘BarNet Zero’ aspiration and its ‘Climate Change and Biodiversity Emergency’ declaration; and
• Would free up Site 3 for regeneration.

Overall, the proposals do not succeed in achieving the statutory requirement for 10% Biodiversity Net Gains.  This means that biodiversity improvements will have to be relocated and maintained for 30 years elsewhere (which will have to be paid for).

9. Loss of Car Park Threatens Burnt Oak trade
The loss of 156 public parking spaces will negatively impact Burnt Oak commercial interest, reducing current footfall and threatening the livelihood of local traders. 

An alternative would be to:

• Reduce the number of spaces less drastically (by the estimated number of commuters who simply drive in from afar to catch the tube, but who otherwise do not engage with the town); and
• Partially regain floodplain capacity by joining the eliminated area of car park to the existing, and preferably, restored scrubland (which would increase the amount of blue-green space which would provide vital ecosystem services).

10. Flawed Public Consultation Process
The consultation process was compromised by:

• An incorrect end date in the Council’s notification;
• A single notification which was too far from the three separate development sites;
• Missing documentation at commencement.

All of this limited public awareness and engagement.