26/0418

The proposal would result in the unjustified loss of commercial floorspace within a designated town centre, Insufficient evidence has been submitted to demonstrate that the basement is no longer required, is unviable, or that its loss would not undermine the operation, viability and servicing of the existing retail unit or the wider vitality and function of the town centre. As such, the principle of the development is contrary to Policy BE4 of the Brent Local Plan.

The proposed development, by reason of inadequate levels of natural daylight, outlook and ventilation, including to the kitchen and internalised living/sleeping areas, and inadequate floor to ceiling heights to significant parts of the accommodation, would result in a substandard residential accommodation and oppressive living environment, contrary to Policy D6 of the London Plan and Policy DMP1 of the Brent Local Plan.

The proposed due to the removal of basement access would compromise the servicing arrangements of the ground floor retail unit. Furthermore, the proposed access via a narrow, unlit rear service road would provide an unsafe and poor-quality pedestrian environment, giving rise to personal safety concerns. The proposal is therefore contrary to Policies DMP1, BT1 and BT3 of the Brent Local Plan (2019-2041).

Due to insufficient information provided to demonstrate how refuse would be collected, and as the distance to the nearest collection point would exceed recommended carrying distances, the proposal would result in poor waste management arrangements, to the detriment of residential amenity and the functioning of the public highway, contrary to Policy DMP1 of the Brent Local Plan (2019-2041).

In the absence of a site-specific Flood Risk Assessment, the application has failed to demonstrate that the development would be safe for its lifetime, incorporate appropriate mitigation measures, or avoid increasing flood risk elsewhere. The proposal also involves the creation of a basement dwelling in a high flood risk area. As such, the development is contrary to Policy BSUI3 of the Brent Local Plan (2019-2041) and Policy SI12 of the London Plan (2021).

The application has failed to demonstrate that adequate fire safety measures would be incorporated into the design, contrary to Policy D12 of the London Plan. The proposed basement unit would rely on a single means of escape, and no Fire Safety Strategy or supporting information has been submitted to confirm safe evacuation, fire separation, or smoke ventilation. This gives rise to significant concerns regarding the safety of future occupants. DocFDN Ref: 26/0418 Page 2 of 4

Due to the absence of information, it has not been demonstrated that the use of the adjoining properties would be acceptable in terms of their impact on the amenity of future occupiers, contrary to Policy D13 of the London Plan (2021). The introduction of a noise-sensitive residential use in close proximity to established commercial premises would risk prejudicing their continued operation and future optimisation.