BRAG Comments on Brentford High Street Plans

Redevelopment of Brentford High Street – Ref:  P/2012/2735 00607/BA/P2

As you may know, BRAG (Brentford Recycling Action Group) is a voluntary, non-political community waste action group made up of Brentford residents. Our main aim is to raise awareness of waste and environmental issues, promoting activities and facilities to improve the local environment for the benefit of local people.

With this in mind, we have looked at the proposals for the south side of Brentford High Street which have been presented by developers Ballymore.  There is much to be commended (for example a CHP system that could be connected to Brentford Dock/a town wide district heating system).  However improvement is needed in the following areas:

  • Carbon neutrality – Locally we are very proud that Lord Stern of Brentford published the Report on the Economics of Climate Change in 2006. This is internationally recognised as a milestone report on the economics of climate change and shifted the global debate.  Ballymore’s Economic study (pg 41) suggests that the developer picks up on the Council’s desire: “To ensure that all new developments within Brentford contribute to the Community Plan goal of a ‘carbon-neutral’ borough and address key environmental issues that exist within the area.” At present the scheme’s environmental proposals are not yet ambitious enough in their contribution to this goal in a town that should be leading the way.
  • Code for sustainable homes targets / sustainability of materials
  • Table 3.1 on page 8 of the Environmental Strategy shows how standards will improve in the year ahead. The Local Authority should make sure that through an escalator agreement, the higher standards are locked in as the development could take ten years to build out.
  • At present a very low Code for Sustainable Homes rating has been achieved in the area of materials use (Only 11 of 24 points achieved). “Material specification – Opportunities for the reclamation and reuse of aggregates on site will be investigated. A target of 10% of materials by value will be from recycled or reclaimed sources. The Waste and Resources Action Programme (WRAP) states that by adopting the available opportunities to increase recycled content through the use of cost competitive, readily available products (i.e. good practice products), levels of over 15% recycled content by value are common.” (see pg 26 of Sustainability statement)
  • Is there an opportunity to aim for Code level 5 (rather than 4) if selection of materials was carefully managed in detailed design/ contractor commissioning phase? Can Ballymore make any commitments in this regard or this be required through planning conditions?
  • Energy efficiency
    • Can higher standards of air tightness to Passivhaus standards be achieved? This appears weak in the Sustainability Statement. (See
  • Energy sources
    • As well as the CHP plant for the site, are ground source heat pumps (building scale) not possible part of the energy mix? See pg 30 of the Energy strategy.
    • Pg 18 of the Energy Strategy advises “Were gas-fired CHP implemented, photovoltaic panels would be a more appropriate use of available roof space than solar thermal.” Could Solar PV not feature on a small scale on the refurbed old buildings pitched roofs?
    • Can canal be used for heating/ cooling as at GSK House?
    • Can educational access/ visibility of the CHP energy centre (incl live information displays on generating capacity) be incorporated into the scheme?
  • Water – There is a soft commitment to rainwater harvesting, but only for external use. Could toilet recycling of water be demonstrated in some of the older buildings that are being refurbed?
  • Rooftop allotments – It would be good to see these extended across all the roof-tops, rather than the tokenistic intervention currently proposed. A management scheme should also be considered. Allotments would offer “opportunities for physical activity” and “access to healthy food” – highlighted in pg 20 of Ballymore’s Health Impact Assessment.
  • Ecology – We note that a bat licence will be required from Natural England to ensure the value of the site to bats is retained/ enhanced. We would like to be kept informed as to how this retained value/ enhancement will be achieved.
  • Demolition – “Prior to demolition Site Waste Management Plans will be produced. These will include an estimate of all the waste produced throughout the demolition and construction of the proposed masterplan. Opportunities will be highlighted to minimise and re-use demolition waste and also to divert waste streams from landfill. “ (See pg 26 of Sustainability statement) Will Ballymore invite residents/ Council officers on site through the demolition phase to see this being implemented? Can Ballymore be conditioned to sign the Demolition Protocol?
  • Recycling in the home – Code for sustainable homes compliant bins are insufficient for the storage realities that Hounslow’s sophisticated recyclates separation system demands. We would welcome planning conditions to ensure additional storage/separation space into all homes to maximise resident’s ability to recycle 100% of their waste. Five containers of appropriate size are needed in each home for: kitchen waste/compost; paper & card; plastics; tins/bottles; and general.

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