Objection
Barnet Planning Department
Barnet Planning Department
Barnet Council
2 Bristol Avenue,
Colindale,
London
NW9 4EW
By post & online 27th August 2025
Ref: 25/2671/FUL High Barnet Underground Station Station Approach Barnet EN5 5RP
Right to Object
A1 Self Storage has operated for over 30 years in Whetstone and many of its customers and staff are impacted by this proposal.
We agree with many of the objections already raise by many others, including the absence of parking provisions, inappropriate location for tall buildings and demonstrably poorly-arranged inter-connectivity and servicing arrangements as well as lack of amenities and/or amenity space for the residential proposal.
The purpose of this objection letter is to focus on matters that are either not fully addressed or have not been raised to our knowledge this far, so that the Officer responding to these objections can dealt with them separately and address them specifically.
The current proposal celebrates the lack of parking provision in its transport document forcing people to use public transport as if this were an achievement! Relishing the idea that the residents of Barnet living within a 2.5 km of the station should have travel to travel on foot to reach a bus stop and engage in public transportation.
This shows either a complete lack of awareness or callus disregard for the more vulnerable members of society, including:
disabled and less able bodied;
those with diminished mental capacity;
the younger and older members of the public who will be vulnerable to criminals during long walks and pushed aside at peak times;
those who have experienced crime and fear walking the streets especially when dark;
those who have not embraced the cashless society; and
those who have to meet time deadlines.
To meet the disabled need requirements of the development itself would require 28 parking spaces or 10% of the residential units. 90% of new homes must be accessible and adaptable, adhering to Building Regulations M4(2). Furthermore, 10% of major new developments must be provided as wheelchair user dwellings (M4(3)). Such residences cannot solely rely on public transport. They need point to point transport. The scheme would effectively prevent them working and exploring the wider area in an economic way. The 3% proposed in the scheme is woefully inadequate as is the 6% the developer claims can be achieved.
Policies that collectively aim to encourage people to use public transport and bicycles are predicated on the assumption that both are safe but the empirical evidence does not actually support the case
according to the following Tfl freedom of information request (FOI-3753-2425).
01A Violence 6801
01B Weapons 247
02A Sex 1808
03A Criminal Damage N/A
03B Graffiti N/A
04A Line of Route (Serious) (e.g. placing obstructions on the route) 53
05A Theft of Passenger Property 24180
06A Motor Vehicle 862
06B Pedal Cycle 414
07A Robbery 1443
08A Burglary & Theft Railway N/A
08B Theft Cable & Plant N/A
09A Public Order (Serious) 5983
10A Fraud (Serious) 92
11A Drugs 1162
12A Other (Serious) 285
Between January 23 and June 24, Tfl confirmed a total of 47,456 recoded crimes, including 14,851 which were classed as serious, violent, robbery or used weapons, ie 31.2 % of the crimes committed during this period.
The crime rate for London generally is 106.4 per 1000 people for 2024/2025, or put another way there is a 10% chance of Londoners experiencing a crime this year.
If you bicycle you are 15 times more likely to be injured per mile travelled than by car with 9 cyclists killed and 261 serious injured in 2024.
Clearly, the more vulnerable people described above are more susceptible to becoming victims of crime and injured while travelling without the protection of a car they, with their essential needs being disregarded by this proposal.
1. Car Journeys
As of 2023, High Barnet tube station saw 3.26 million annual entries and exits pre-covid. This number was 4.05 million 9,863-11,095 cars journeys per day on average. However, the planning statement says only 8% arrive by car, which equates to between 789-887 car arrivals per day. Presumably, a fair % or these actually park at the station (23% see below).
Of these 42% (or between 4,142-4,660) are made locally within a 2.5 km catchment area serving as a park and ride location outside of the congestion charge zone entirely in keeping with policy. Therefore 68% travel further. A 15-minute car journey from High Barnet Station covers a radius of roughly 4.8- 8 km in typical London traffic, depending on the specific route, time of day, and road conditions.
Which is why the station currently has 193 car parking spaces including 6 disabled bays. The google earth image taken on 18/3/2025 (a typical Tuesday) shows the car park 97% full, as do many others.
This indicates that 187/789 or 23% arriving by car actually park at the station before making their journey onwards.
Tfl currently charges £10 per day during the week and £6 per day during the weekend for car park alone.
This also indicates the parking is well-used and paid for, adding considerably to the cost of transport. Therefore, to infer there is no car parking demand is completely false.
2. Failure of POLICY T4 & Policy TRC01 of the London Plan
Assessing And Mitigating Transport impacts
It is not enough to address this development in the same way one would address development on private land, ie in a way which is unconnected to the operational requirements of Tfl. By its very nature, this land (a proportion of which is currently used as a car park for High Barnet Tube station) will ultimately impact transport across the entire service area for the station.
This is not properly addressed in the current proposal since it does not address nor mitigate the 23% of car arrivals that currently enjoy parking at the Station, pay for a car parking at the station, and are more than likely to also pay via Government to subsidise Tfl to the tune of around £485m.
By removal of these parking places, likely used by people by the more vulnerable who are unable to take buses, this development is the antithesis of Policies T4 & TRC01. It will prevent car users from accessing the Tube network in High Barnet, forcing them to make longer journeys by cars and costly taxi journeys, and preventing them taking an onward journey by underground train.
It should also be noted they already pay on a daily rate basis £2,600 a year for the privilege of parking their car, a practice that used to be free prior to 2003 when Tfl endorsed the park and ride concept.
3. Questionable Development Practice
The Acts of Parliament enabling the foundational companies of the railway network did so on the basis that those companies would provide transport services Tfl appears to remain a private entity but with heavy subsidies by the Government. It's unclear why this should be the case or who or what ultimately owns the GLA and its controlling body.
The entity where the High Barnet Proposal appears to have been placed is Places for London (formerly TTL Properties Ltd). It says it has investment property valued at £1.5 bn and managed to make a loss of £130m last year.
It's not clear why a company should be receiving land worth millions of pounds from Tfl operations which are subsidised by the UK tax payers to the tune of £250m-£500m annually only to then have the amenity provided for those same tax payer removed in a for-profit development, nor why Places for London is only providing 50 % social housing when its clearly subsidised by the tax payer and should be 100% social housing.
Why is this the case and what public consultation and scrutiny has occurred on this subject, if any?
4. Sequential Test
The LPA & Tfl have put forward at least two sties locally on the Northern Line for proposed development:
Site 37 which relates to the current proposal and the ultimate stop; and
Site 45 (the penultimate stop on the North Line in which we are tenanted * (see transparency disclosure at the end of this document).
Places for London and Tfl in general are in a unique position in that it owns and control large amounts of land within London, several of which it has put forward for development.
Therefore, the sequential test should be applied on the basis of its effect on the transport infrastructure of the entire borough. It should not be confined to the local centre where a planning proposal originates.
Failure to properly address the Sequential Test
The Planning Statement considers the test at paras 9.67- 9.72. In short, it asserts that as the "floorspace cannot be disaggregated from the 283 homes that are proposed [and] must be provided on the Site as part of the Proposed Development [in order to] achieve the objective of the site allocation", the sequential test is met.
The Court of Appeal has recently considered the lawful approach to the sequential test in R (on the application of Tesco Stores Limited) v Stockport Metropolitan Borough Council [2025] EWCA Civ 610.
In Tesco, the Court reviewed the relevant paragraphs in the NPPF and the applicable policies in the Council's Local Plan. The Court explained as follows.
1. The purpose of the sequential test is to steer development to town centres, or edge-of-centre, in preference to out-of-centre locations.
2. The sequential test sets a clear order of preference, with the first preference being town centres.
3. The words used in para 91 of the NPPF (ie "suitable" and "available" are ordinary English words and should be interpreted as such.
4. A sequentially preferable site does not need to be "exactly suitable" for the developer's needs. Paragraph 91 "does not say that if the developer happens to own a sequentially preferable site, which it does not want to bring forward for retail development or some other main town centre use, that site must be ignored" [para 43].
5. A site may be suitable but not be available, and vice versa. This is a matter of planning judgement. A site's availability is also a question of fact.
6. Sites may be available and then cease to be available during the course of an application. The NPPF test should accordingly be applied flexibly.
7. The application of the sequential test does not depend on there being a need for the proposed development. However, the requirement still exists for developers to demonstrate that their development will not causes significant adverse impact either to investment in town centres or the vitality and viability of the town centre.
In the application, the Planning Statement does no more than assert the test has been met. It does not show how it has been met through an analysis of "available" and "suitable" sites within town centres which could better meet the purpose of the sequential test.
The argument in the Planning Statement, namely, that the main town centre uses cannot be disaggregated from the development and are necessary for the allocation is not an answer to the need for the developer to have undertaken the sequential test, particularly when the developer owns land nearby which is within a town centre or edge of town centre that is more suitable. This purpose of the sequential test is not negated by a site's allocation, as the requirements for the sequential test having been undertaken and satisfied are necessary development control mechanisms which inform planning judgement when considering an application for planning permission on an allocated site.
The sequential test has not been satisfied in the application.
5. Safeguarding
It is noted that in the March 2025 adopted LDP site 45 has notes concerning safeguarding and increases in train stabling and Northern Line infrastructure.
What is not clear from the LDP document is why this applies to Site 45 but the same is not apparent for Site 37 which makes no mention of such a requirement as to the increased capacity requirements of the Northern Line or additional train stabling.
It appears that site 37 is more appropriately located and physically orientated to accommodate increased train stabling and capacity requirements on the Northern Line, as it is the terminus stop where trains are already injected in to the Northern Line to carry passengers at every stop to their destinations.
As well, by reason of the land's shape, orientation and topography with respect to the existing track at High Barnet Tube station, it appears that train stabling would be more suitable here than the penultimate stop at Totteridge and Whetstone which forms part of site 45
Agent of change principle (NPPF)
The party responsible for introducing the change of land use should be responsible for the management and mitigation measures flowing from the change of use. Therefore, until Tfl identifies the Northern Line future upgrade requirements and provides feasibility studies for all the available sites (including Site 37 & Site 45), no planning permission should be granted. This is of fundamental importance in order to safeguard the future transport needs of the Northern Line, given that populations densities in London will continue to grow and further restrictions will be placed on car use such as:
emissions restrictions;
Congestion Charges;
reduction in car Vehicular Lanes;
CPZ (controlled Parking Zones; and
speed limit reductions.
There will be an ever-increasing need for Tube trains journeys. To safeguard this vital transport infrastructure and need, Tfl must be transparent and open about its future tube projections.
No such information is available online at Tfl, nor on the LPA websites detailing any such feasibility studies or future requirements.
It should be noted that economic prosperity is directly related to transit times and the ability to move goods and people from one location to another.
In conclusion, this planning application should not be permitted to proceed until such time as Tfl has demonstrated through and open and transparent process each of the following:
why Site 37 should be given preference over Site 45;
that there is no need to provide for future train stabling on the Northern Line; and
why Site 45 should be preferred for this rather than Site 37 or any other Tfl site on the line, either stand alone or in combination.
We cannot see why Site 37 would sequentially be preferential nor why with the desperate need for housing and the higher residential delivery capacity Site 45 located on the edge of Whetstone Town Centre would not be brought forward preferentially as a priority.
6. Town Centre Character
High Barnet has a definitive character and a low-rise nature.
Unlike High Barnet, the Planning Inspectorate determined in its appeal decision (APP/N5O9O/A/09/2100884)for the Travelodge that here was no discernable character to the High Road in Whetstone. The proposal does not adhere to the character of the area
7. Design Amenity
A1SS submitted a pre-application to the LPA, more details of which can be viewed at WWW.A1SS.UK.
In stark contrast to the current proposal by Tfl, the A1SS development could have delivered:
• 600 residential units
• 40,000 sq ft of food retail
• 20,000 sq ft cinema
• 100 bedroom hotel
• 20,000 sq ft of other leisure uses
• 10,000 sq ft gym and other medical/health related amenities
• High levels of car parking to service residents, guests and visitors of the commercial elements
• 60,000sq ft of green amenity space including 60 new trees, to improve air quality. Can be partially used to accommodate local events or similar and open spaces at high-level
• Area available for Farmers Market and localised events
• A public rooftop restaurant providing views across Dollis Valley
• Renew 11,000 sq ft offices on site.
• Dedicated receiving centre & community Hub to enhance community cohesion.
1 New tree per 10 Residential units
In contrast the proposal in 2017 provided for over 250 sq ft of amenity space per resident unit or 1250% more area. This should be contrasted against just 20 sqft of amenity space per residential unit in the TfL proposal.
At the time of writing this proposal this proposal had 157 objections and 19 supporting comments (13 of which were consecutive on the same day indicating they are not genuine support but contrived, otherwise you might reasonable expect them to be interspersed with the 8 times the number of objections). This leaves 6 actually supporting the proposal ie it has a 96% disapproval rating amongst the residents it serves.
The 2017 pre-app garnered support from the We Love Whetstone society and others and we believe would have delivered what the residents of Barnet actually want, ie high quality development.
Yours sincererly
Peter Gerson
Director
*Disclosure purposes the Author has an interest in Land included within site 45 but has not had contact with the LPA or Tfl for at least years on this subject.
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