651.-london-borough-of-brent-and-its-boundaries-with-barnet,-camden,-ealing,-hammersmith-and-fulham,-harrow,-knc-and-westminster

LOCAL GOVERNMENTBOUNDARY COMMISSIONFOR ENGLANDREPORT NO 651

LOCAL GOVERNMENT BOUNDARY COMMISSION FOR ENGLANDCHAIRMANMR K F J ENNALS CBMEMBERSMR G R PRENTICEMRS H R V SARKANYMR C W SMITHPROFESSOR K YOUNG

; . CONTENTSParagraphsIntroduction 1-6Our approach to the review of Greater 7-9LondonOur consultations and the representationsmade to usSuggestions for change and ourconclusions:Generalio-13The Partition or Abolition of Brent 14-44Wider implications of our draft 45-48proposalsBrent's boundary with BarnetWest Hendon 49-55Brent's boundary with HarrowLarger scale proposals 56-61Greenford Road and Sudbury CourtDrive 62-72Area east of Honeypot Lane 73-85Northwick Park Hospital and HarrowCollege of Technology 86-100Brent / s boundary with BalingBarham ward 102-108Alperton 109-118West Twyford/Park Royal 119-139Brent's boundaries with Hammersmith and Fulham and Kensingtonand ChelseaSuggestion for major change 140-141Brent's boundary with Hammersmith and FulhamCollege Park 142-152

Brent's boundary with Kensington and ChelseaKensal Green Tunnels 153-155Brent's boundary with WestminsterKensal Triangle/South Kilburn 156-173Brent's boundary with CamdenKilbum High Road . 174-175Electoral consequences 176Our conclusions 177Publication 178

THE RT HON MICHAEL HOWARD QC, HPSECRETARY OF STATE FOR THE ENVIRONMENTREVIEW OF GREATER LONDON, THE LONDON BOROUGHS AND THE CITY OFLONDONLONDON BOROUGH OF BRENT AND ITS BOUNDARIES WITH THE LONDONBOROUGHS OF BARNET, CAMDEN, BALING, HAMMERSMITH AND FULHAM,HARROW, THE ROYAL BOROUGH OF KENSINGTON AND CHELSEA AND THE CITYOF WESTMINSTERCOMMISSION'S FINAL REPORT AND PROPOSALSINTRODUCTION1. This report contains our final proposals for the LondonBorough of Brent's boundaries with the London Boroughs of Barnet,Camden, Ealing, Hammersmith and Fulham, Harrow, the Royal Boroughof Kensington and Chelsea and the City of Westminster. We haveconsidered, but not proposed, the partition or abolition ofBrent. We have also considered but are not proposing the transferof certain major areas to other boroughs. However, we arerecommending that several residential areas, together with HarrowCollege of Technology and Northwick Park Hospital, be transferredfrom Brent to adjoining boroughs. We also recommend that CollegePark and the Willesden Freightliner Terminal be transferred toBrent from Hammersmith and Fulham and Ealing respectively. Inaddition, we are making some proposals to remove minor anomalies,for example where properties are divided by boundaries. Ourreport explains how we arrived at our proposals.2. We consider it important to record the fact that our currentreview of Greater London has been, and is being, conducted underthe remit set for us by the Local Government Act 1972 and ourguidelines from the Secretary of State (contained in Departmentof the Environment Circular 20/86). This review is not affectedby the provisions of the Local Government Act 1992.3. On 1 April 1987 we announced the start of a review of GreaterLondon, the London boroughs and the City of London as part of theprogramme of reviews we are required to undertake by virtue of

section 48(1) of the Local Government Act 1972. We wrote to eachof the local authorities concerned.4. Copies of our- letter were sent to the adjoining Londonboroughs; the appropriate county, district and parish councilsbordering Greater London; the local authority .associations;Members of Parliament with constituency interests; and theheadquarters of the main political parties. In addition, copieswere sent to the Metropolitan Police and to those governmentdepartments, regional health authorities, electricity, gas andwater undertakings which might have an interest, as well as tolocal television and radio stations serving the Greater Londonarea, and to a number of other interested persons andorganisations.5. The London boroughs and the City of London were requested toassist us in publicising the start of the review by inserting anotice for two successive weeks in local newspapers so as to givea wide coverage in the areas concerned.6. A period of seven months from the date of our letter wasallowed for all local authorities and any person or bodyinterested in the review to send us their views on whetherchanges to the boundaries of Greater London authorities weredesirable and, if so, what those changes should be and how theywould serve the interests of effective and convenient localgovernment, the criterion laid down in the 1972 Act.OUR APPROACH TO THE REVIEW OF GREATER LONDON7. We took the opportunity in our Report No 550, "People andPlaces", to explain in some detail the approach we take to ourwork and the factors which we take into consideration whenconducting reviews, including the guidelines given to us by theSecretary of State (set out in Department of the EnvironmentCircular 20/86 in the case of the reviews of London).8. Subsequently, in July 1988, we issued a press notice, copiesof which were sent to London boroughs, explaining the manner inwhich we proposed to conduct the review of London boundaries.

.In the notice we said that, from the evidence seen so far, thiswas unlikely to be the right time to advocate comprehensivechange in the pattern of London government - although the noticelisted a number of submissions for major changes to particularboundaries which had been made to the Commission, some of whichthe Commission had itself foreseen in "People and Places". Theseand other major changes to particular boundaries are beingconsidered by the Commission as it makes proposals for changesto the boundaries of London boroughs.9. More recently, we have felt it appropriate to explain ourapproach to this, the first major review of London since Londongovernment reorganisation in 1965 and to offer our thoughts onthe issues which have been raised by the representations made tous, and by our consideration of them. We have therefore publisheda general report, entitled "The Boundaries of Greater London andthe London Boroughs" (Report No. 627), which discusses a numberof the wider London issues which have arisen during the courseof this review.THE INITIAL SUBMISSIONS HADE TO US10. In response to our letter of 1 April 1987, we receivedsubmissions from the London Boroughs of Brent, Barnet, Harrow,Ealing, Hammersmith and Fulham, the Royal Borough of Kensingtonand Chelsea and the City of Westminster. The London Borough ofCamden did not make any submission in respect of its boundarywith Brent. We also received representations from two localMembers of Parliament, 14 interested organisations and 563members of the public. Six petitions were also received.OUR DRAFT PROPOSALS AND THE RESPONSES TO THEM11. In addition to our letter of 1 April 1987, we published afurther consultation letter in connection with this review ofBrent's boundaries. This announced our draft proposals andinterim decisions to make no proposals, and was published on 31July 1991. Copies were sent to all the local authoritiesconcerned and to all those who had submitted representations tous. We arranged the publication of a notice advertising our draft

proposals and interim decisions. In addition, the localauthorities were requested to post copies of the notice at placeswhere public notices are customarily displayed. They were alsoasked to place copies-of our letter on deposit for inspection at.their main offices for .a period of twelve weeks. Comments wereinvited by 23 October 1991.12. We received a total of 531 individual representations inresponse to our draft proposals and interim decisions. Theyincluded comments from all the affected local authorities, theRt Hon Sir Rhodes Boyson MP, Mr Harry Greenway MP, Mr PaulBoateng MP, Mr Ken Livingstone MP and Mr Michael Elliott MEP. Theremainder were from local councillors, residents andorganisations. We also received 197 pro-forma letters and sixpetitions, containing 758 signatures.13. In addition to Brent Council's formal response, we receivedcopies of a draft response prepared by Brent's Central PolicyUnit. This was considered by the Council, and several importantchanges were made which were incorporated in its formalsubmission to us. However, the draft response (hereafter referredto as the *Central Policy Unit Report 1 ) was forwarded to us bythe following persons and organisations, as their formal responseto our draft proposals: Mr Ken Livingstone MP; the Rt HonReginald Freeson; the Liberal Democrat and Labour Groups on BrentCouncil; and Brent North Labour Party. For this reason, we referin this report both to Brent's representations to us and toarguments contained in the Central Policy Unit Report, which, itshould be understood, does not represent the views of theCouncil.SUGGESTIONS FOR CHANGE AND OUR CONCLUSIONSTHE PARTITION OR ABOLITION OF BRENT14. The submissions received in response to our initialconsultation letter of 1 April 1987 included suggestions forradical change to Brent's boundaries. These involved thepartition of Brent and/or the amalgamation of parts of theBorough with adjoining authorities. Our interim decisions in

espect of these radical suggestions are set out in the followingparagraphs, prior to our final proposals for changes toindividual boundaries.1 5. Brent made no suggestions for major change to its boundaries.However, the London Borough of Harrow suggested that its boundarywith Brent should be realigned to encompass Wembley andKingsbury, the effect of which would have been to transfer alarge part of north Brent to Harrow, together wi th the WestHendon area of Baraet and a small part of Baling. Harrowconsidered that the communities covered by these areas weresimilar in character to those in its own area and, if amalgamatedwith Harrow, would readily form a cohesive local government unit.The Council also argued that its total population was below theaverage for outer London boroughs and that there would beadvantages, in terms of the overall efficiency of serviceprovision, if both its area and its population were substantiallyincreased.16. At the time Harrow submitted its suggestions for change,Harrow District Health Authority had applied to the Departmentof Health for an extension to its area, to incorporate within itthe northern part of the Brent Health Authority. Harrow claimedthat there would be substantial advantages, in terms of providingefficient and convenient local government services, if theBorough were to be enlarged in line with the proposed extensionof the District Health Authority. However, we were laterinformed that the District Health Authority's application had notbeen supported by the North West Thames Regional HealthAuthority, and had been refused by the Department of Health.17. Harrow 1 s suggestion for radical change was supported byrepresentations from 37 members of the public. It was opposedby the London Boroughs of Barnet and Baling, the Labour Group ofHarrow Councillors and five members of the public. The Brent andHarrow Family Practitioner Committee (now Family Health ServicesAuthority) and Brent Petty Sessions Area Magistrates' CourtsCommittee also opposed any change to Brent's boundary withHarrow.

18. The Brent North Conservative Association suggested that Brentshould be partitioned by the creation of a boundary along theA406 North Circular Road, to restore the pre-1965 boroughs ofWembley and Willesden. The Association claimed that the effectof the merging of Wembley with Willesden, at the time of Londongovernment re-organisation in 1965, had been severely detrimentalto Wembley. Accordingly, it requested the restoration of Wembleyas a separate authority. In support of its submission, theAssociation argued that Wembley and Willesden were distinctlyseparate communities and that, because of both geographical andsocial factors, it was impossible to create a central "heart* forBrent. It considered that, taken together, the North CircularRoad and the Welsh Harp Lake formed a continuous barrier betweenthe two areas, which, being different in character, had differentproblems and aspirations. The Association claimed that this hadresulted in education, finance, race relations and other aspectsof local government in Wembley suffering severely since themerger. The Association also stated that Harrow's suggestion,for its boundary to be extended to the limits of the Wembley andKingsbury Health Care areas, would be acceptable to many Wembleyresidents as an alternative to an independent Wembley, providedit included the whole of north Brent.19. The Brent North Conservative Association's submission wassupported by a petition bearing 10,400 signatures calling for therestoration of the borough of Wembley, and by 174 letters frommembers of the public. The Member of Parliament for Brent North,the Rt. Hon. Sir Rhodes Boyson, also submitted a representationto us in support of the restoration of the former borough ofWembley.20. The Sudbury Court and the Preston and Mall Residents'Associations both supported the restoration of the former boroughof Wembley. Similarly, the Barn Hill Residents' Associationsuggested that Brent should be divided along the lines of thepre-1965 boundaries. The Barham Park Residents' Associationsuggested adopting the River Brent as a boundary, to achieve asimilar partition of Brent. This last suggestion was supportedby a petition containing 144 signatures.

21. Two members of the public submitted a joint suggestion forthe dissolution of Brent by the amalgamation with Harrow of thatpart of the Borough north of the A406 North Circular Road, andthe division of the southern part between Kensington and Chelsea,Hammersmith and Fulham, Westminster and Ealing. They recommendedthe abolition of Brent on the grounds that the present Boroughwas split by the North Circular Road into two distinct areas, onesuburban and the other with urban environmental problems. Theyclaimed that the existing inner city/suburban authority wasunmanageable because of these environmental and structuraldifferences. They also referred to the social differences betweenthe two areas.22. The Preston Amenities Protection Association suggested thata new, separate borough should be created by amalgamating theParliamentary constituency of Brent North with the adjacentcommunities of Kenton and south Wembley. The Association claimedthat this would reflect the socio-economic differences betweenthese areas and south Brent. The effect of the suggestion waspractically the same as that proposed by the Brent NorthConservative Association, to restore the borough of Wembley.23. In addition to the letters from members of the public whichwere sent to us in support of the above suggestions, we received88 representations from local residents requesting that the areaof Brent to the north of the A406 should be transferred out ofthe Borough by means of either suggestion. Almost all therepresentations received were from residents of the northern partof Brent.24. The representations from members of the public generallyexpanded on the reasons for change given by Harrow and theConservative Association in their submissions for radical change.Many asserted that Brent covered a large area which was dividedby what the respondents regarded as the major barrier of theA406. They emphasised that the north of the Borough was suburbanin character, and that its sense of identity was separate fromthat of the urban south. Additionally, they considered themselvesto be di sadvantaged in terms of service provis ion, wi theducation, public health and refuse collection being the services

most .frequently mentioned. In many cases, they suggested thatthe northern part of Brent had a greater affinity of interestwith Harrow, which was regarded as a more efficient localauthority. Those representations which requested the restorationof Wembley recalled a well-managed borough which providedeconomical and satisfactory services.25. A further view frequently expressed was that Brent was nottenable as an administrative area. Many perceived it as anauthority with high revenue expenditure and poor serviceprovision.Our Conclusions26. We have a duty to make recommendations to the Secretary ofState for such boundary changes as appear to us desirable in theinterests of effective and convenient local government. We havereceived guidelines from the Secretary of State (contained inDepartment of the Environment Circulars 33/78 and 20/86), whichadvise us that, in conducting boundary reviews, we should haveregard to three criteria: "whether or not an area or boundaryaccords to the wishes of the people, reflects the pattern ofcommunity life, and is conducive to the effective operation oflocal government and associated services". In the conduct ofthis review, we have had particular regard to the constraints ofparagraph 7 of Circular 20/86, that "...the abolition or creationof a principal area would be appropriate only where theCommission consider that the present arrangements clearly failto provide effective and convenient local government...".27. In order to consider whether the abolition or partition ofBrent would be conducive to effective and convenient localgovernment, we considered that a number of questions had to beaddressed. These included the effectiveness and convenience oflocal government in Brent at present; whether it was so poor thatradical change was required; if problems did exist, whether theywould be resolved by radical change; and, if a case had been madefor radical change, what effect it would have on north and southBrent and on the structure and pattern of local government in8

esidents of north Brent for radical change. The extent to whichthese difficulties might have resulted from the policies andpriorities of Brent Council since its formation was a matter onwhich it would have been improper for us to express a view. Inany event, they did not appear to us, on the evidence available,to have been a consequence of the size, shape or preciseboundaries of the Borough.31. Nevertheless, it was clear to us that a significant body ofopinion in north Brent sought radical change. The wishes of thepeople are an important consideration in our reviews, and we feltwe could not ignore this expression of public opinion.Accordingly, we considered whether any of the suggestionssubmitted to us for major change would meet the wishes of thoseseeking transfer from the Borough. We recognised that theadoption of a proposal for radical change could not be taken inisolation; we would need to be satisfied that there would be noadverse effect on the provision of effective and convenient localgovernment in this part of North West London generally. Inparticular, we would need to be satisfied that adequatearrangements could be made for what remained of Brent, and thatresidents in that area would not be disadvantaged as a result ofthe transfer of the northern part of the Borough.32. We identified two main options arising from the suggestionsto partition Brent along the length of the A406 North CircularRoad:(a) the creation of two new, separate boroughs of Wembleyand Willesden; and(b) the amalgamation of the northern and southern parts ofthe Borough with their neighbouring authorities.33. We considered these two options, both of which had receivedconsiderable support from local residents. However, complicationscaused by Brent's geography applied to both. Brent is an areatraversed by a number of radial transport routes, both road andrail, with significant blocks of industry and a number ofextensive railway goods yards. This suggested to us that the10

North Circular Road was not the only barrier to movement withinthe Borough and that, were abolition or partition to becontemplated, it might be achieved by means other than thoseproposed by Harrow and the Brent North Conservative Association.34. The creation of two new, separate boroughs of Wembley andWillesden would result in administrative units of approximately129,000 and 126,000 population respectively. We were aware that,in purely numerical terms, units of such a size were comparablewith certain other London boroughs - for example, the RoyalBoroughs of Kensington and Chelsea and Kingston upon Thames.However, we did not consider that there were any overall benefitsto be gained from increasing the number of London boroughs aspart of this review of Greater London. Indeed, our general, view,taking account of our guidance from the Secretary of State, wasthat, where current arrangements clearly failed to provideeffective and convenient local government and major change wasrequired, this should, where possible, be achieved by mergingrather than dividing authorities. More specifically, in the caseof Brent, splitting the authority into two smaller boroughs couldexacerbate the problems of providing effective services inWillesden. Certainly, it seemed unlikely that the increasedburden on resources would lead to more effective and convenientlocal government in Willesden.35. The alternative would have been to amalgamate the two halvesof Brent with their neighbouring authorities. Uniting thenorthern part of Brent with Harrow would have brought togetherareas of generally similar characteristics, and an enlargedHarrow would not be over-large in relation to other outer Londonboroughs. However, there would be difficulties in uniting southBrent with any of its neighbouring authorities, or apportioningit amongst them.36. The five London boroughs adjoining south Brent are, from westto east, Ealing, Hammersmith and Fulham, Kensington and Chelsea,Westminster and Camden. To have united the southern part of Brentwith Ealing might, perhaps, have been be the most obvioussolution in terms of shape. However, the two areas are dividedby the industrial estates around Park Royal and North Acton, and11

y the radial routes traversing this part of London, such as theA40, the Grand Union Canal and railway lines.• . •. ••37. We considered the possibility of uniting south Brent withHammersmith and Fulhara, or Kensington and Chelsea, orWestminster;'or dividing it between all three. ..However, such acourse of action would have resulted in major upheaval for thoseauthorities in terms of finance and the provision of services,and would have had significant repercussions on the structure oflocal government in this part of London generally. Moreover,other than in the immediate vicinity of the existing boundary,little evidence of links or similarities between south Brent andthese boroughs could be identified. In our view, any boroughencompassing areas as diverse and unrelated as Neasden andFulham,- or Stonebridge and Soho, would have no obvious centre,and would be unlikely to form a unit of local government any morecohesive than the currently structured London Borough of Brent.While an amalgamation of Willesden with. Camden would have thebenefit of uniting the Kilburn shopping centre in a singleauthority, there would be difficulties in establishing ameaningful boundary between an augmented Camden and the remainderof Brent.38. We concluded that the arguments advanced for the abolitionor partition of Brent were not sufficient, in the context ofeffective and convenient local government, to warrant the majordisruption which would result from such a course of action. Suchrestructuring should, in our view, be considered only in thecontext of a comprehensive reappraisal of the pattern of unitaryauthorities within London as a whole.39. Accordingly, mindful of our guidelines from the Secretary ofState, we took an interim decision to make no proposals for theabolition of Brent, or for its partition into two new boroughs.40. Our interim decision was supported by Brent and by twomembers of the public. We received 93 representations .and threepetitions containing a total of 140 signatures in opposition toour interim decision. Brent argued that the quality of serviceprovision in the Borough had undergone a recent improvement, and12

that the continued existence of the authority was in theinterests of effective and convenient local government. Indeed,on this second round of consultation, substantially fewer localresidents wrote to us to seek the restoration of Wembley as anindependent authority; we reflected whether this lower level ofresponse might have resulted from the different policies andpriorities now being pursued by Brent Council.41. The South Kenton and Preston Park Residents' Associationcommented on what they considered to be the divisive effects ofthe North Circular Road and adjoining industrial estates. Severalother respondents, including the Preston Amenities ProtectionAssociation, complained that effective and convenient localgovernment in Wembley was being impaired by its forcedassociation with Willesden. A Brent councillor suggested that theBorough was an artificial creation which had failed to engage theloyalty of its inhabitants. He argued that both Wembley andWillesden could function effectively as separate and independentauthorities.42. The Rt Hon Sir Rhodes Boyson MP and the Brent NorthConservative Association suggested that, in rejecting calls forthe abolition or partition of Brent, we had given insufficientweight to public opinion. Sir Rhodes considered that the recreationof smaller local government units in London would accordboth with the wishes of the people and with the spirit of theGovernment's Consultation Paper on the Structure of LocalGovernment, which was published in 1991.43. We gave careful consideration to all these points, but didnot feel that the reasoning behind our interim decision had beenundermined. In taking account of the representations we receivedfrom the residents of north Brent, we had to bear in mind thatthe wishes of the people are only one of the factors to which weare enjoined to have regard by the Secretary of State. Weacknowledged the strength and sincerity of the feelings expressedin those representations, but nevertheless we doubted whethersufficient account had been taken of the need to make suitableand effective provision for Willesden, in the event of a formalseparation from Wembley. It seemed likely that any proposal to13

divide Willesden between the Boroughs adjoining Brent's southernboundary would meet with strong opposition from, the potentialrecipients; in this context we noted Westminster's objection toour draft proposal-to transfer the Carlton Ward of Brent to itsarea.44. We reaffirmed our view that major restructuring, involvingeither the abolition or partition of Brent, would causesignificant disruption to local government services in north-westLondon, and would therefore run contrary to the purpose of thecurrent review. Accordingly. we have decided to confirm ourinterim decision as final. - . • -WIDER IMPLICATIONS OF OUR DRAFT PROPOSALS45. While we had concluded that radical change to Brent would beinappropriate in the context of this review, we felt there wereseveral areas where the Borough's boundaries were unsatisfactory,and where some intermediate change was necessary in order torectify anomalies and reflect communities of interest. Ourproposals for change were published in our draft proposals letterof 31 July 1991.46. In responding to our draft proposals, Brent, together withother respondents, commented on their cumulative effect on theBorough as a whole. We took full account of these broaderobjections when reviewing each individual draft proposal. •47. In particular. Brent objected to the possible loss both ofindustrial land (particularly at Park Royal) and of two districthospitals. The Council estimated that 47% of its PrimaryEmployment Areas, as defined in the public consultation draft ofits Unitary Development Plan, would be transferred toneighbouring Boroughs if our draft proposals were implemented infull. The Council argued that this would seriously erode Brent'sindustrial base. In particular, it stressed the strategicimportance to the Borough of the commercial premises at ParkRoyal and Honeypot Lane, situated on its boundaries with Ealingand Harrow respectively. We acknowledged that the retention of14

these industrial areas in Brent might be important in communityterms, and in the realm of service provision and developmentplanning.48. We felt that the objection to the loss of the Borough's mainhospitals (Central Middlesex and Northwick Park) was lesscompelling. Accessibility is generally more important to patientsthan is the particular local authority in which a hospital islocated. However, we recognise the need for close liaison betweenhealth authorities and local authorities over the provision ofservices, and accept that, as *care in the community 1 policiesdevelop, it will be increasingly important for social servicesto have effective links with health services.BRENT'S BOUNDARY WITH BARNETWest Hendon -49. In response to our letter of 1 April 1987 announcing thecommencement of this review. Brent suggested that the existingboundary should be realigned along the Edgware Road in thevicinity of West Hendon, in order to rectify an anomalous stretchof boundary and unite the Welsh Harp area in Brent. The effectof this suggestion would have been to transfer the site of theformer West Hendon Hospital, several roads and an area of mainlyopen land from Barnet to Brent. Harrow's radical suggestion, tounite the Wembley and Kingsbury Health Care areas within Harrow,discussed in paragraphs 15 and 16 above, also utilised theEdgware Road for the suggested realignment and would, ifimplemented, have had the effect of transferring the same areafrom Barnet to Harrow.50. Barnet acknowledged that the Welsh Harp area is currentlydivided by the existing boundary, but opposed the suggestions ofboth Brent and Harrow on the grounds that the Welsh HarpConsultative Committee brought together the various interests inthe area, with the result that the division was not an obstacleto efficient management. Additionally, Barnet expressed the viewthat the Edgware Road would not provide the most satisfactory15

oundary between authorities_as, in other parts of its length,it severed community centres. It accordingly took the view thatthe adoption of the Edgware Road as a boundary in the area ofWest Hendon would be divisive. In Barnet's opinion, a virtue ofthe existing boundary at West Hendon was that it contained thewhole of that community in one authority.51 . The suggestions to adopt the Edgware Road as the boundary inthis - area were also opposed by a Barnet councillor, the WestHendon Ward of the Labour Party and 12 members of the public. Twopetitions, totalling 80 signatures, were also received from WestHendon residents opposed to the suggestions.52. We also received representations, specifically opposingBrent's proposal, from Mr John Marshall MP, the West Hendon, Hydeand Verulam Court Residents' Associations and 140 members of thepublic. Two petitions were also received, totalling 981signatures, opposing the transfer of the West Hendon area toBrent. The Hendon South Conservative Association informed us thata substantial number of West Hendon residents opposed thesuggestion that part of their ward should be "arbitrarily"transferred to Brent.53. We concluded that the northern residential part of the WelshHarp area of Barnet was dissimilar in character to the adjoiningarea of Brent. We also took the view that the eastern residentialarea, being cut off from Brent by the reservoir, shared acommunity'of interest with Hendon, to the east, which would besevered by the suggested realignment. Accordingly, we took aninterim decision to make no proposals for this area.54. We received five representations in response to our interimdecision. Barnet, and the Brent North Conservative Association,supported our interim decision. However, Brent maintained thatthe Edgware Road acted as the Borough's "natural easternboundary', and was supported in this view by one member of thepublic. Another local resident suggested realigning the boundaryto the Edgware Road between Kingsbury Road and Silk Bridge, andthen to the high water mark on the eastern edge of the Welsh Harpreservoir, rejoining the Edgware Road at Brent Bridge. He argued16

that * Brent was deficient in open space, and would be betterplaced than Barnet to develop the reservoir as a recreationalresource.55. We acknowledged that there was an element of arbitrarinessin the existing boundary, in that it bore no relation to presentdaygeographical features. However, the division of the reservoirbetween two authorities did not appear to us, on the evidenceavailable, to be an impediment to the area's effectivemanagement. Moreover, we saw no reason to amend our view that acommunity of interest extended across the Edgware Road in thisarea. The use of the road as a boundary between Kingsbury Roadand Brent Bridge would therefore, in our judgement, beinappropriate. Accordingly, we have decided to confirm ourinterim decision as final.BRENT'S BOUNDARY WITH HARROWa) Larger Scale Proposals56. Two suggestions were received from members of the public forthe transfer of part of north Brent to Harrow, in the event ofour deciding against partitioning Brent along the North CircularRoad. Both suggestions were submitted on the grounds that theresidents of Preston and North Wembley enjoyed a community ofinterest with Harrow, and looked to that Borough for shopping,leisure facilities and other services. Both representationssuggested that these areas had been neglected as a result oftheir geographical isolation at the northern part of Brent.57. The first suggestion (transferring approximately 20,000electors) recommended that the boundary should reflect the postaldistricts in Preston and North Wembley, by a realignment fromKingsbury Circle westwards along the Mall to Preston Road, southto East Lane, west to Watford Road, north to Sudbury Court Drivethen south-west along Sudbury Court Drive to rejoin the existingboundary. The second suggestion (transferring approximately17

35,000 electors) was for the boundary to be realigned westwardsfrom Stag Lane along Beverley Drive and south down Honeypot Laneto Kingsbury Circle. From this point the suggested boundary wouldpass south down Fryent Way and King's Drive, and west along thesouthern curtilages of Forty Avenue, East Lane, Sudbury CourtRoad and Sudbury Court Drive. It would then follow the easterncurtilage of Greenford Road as far as its junction with WhittonAvenues East and West.58. We considered that both suggested realignments would, ifadopted, divide local community centres and areas of continuousurban development. Nor were we convinced that ei ther of themreflected the pattern of community life in north Brent, or wouldenhance effective and convenient local government in the area.We therefore took an interim decision not to propose major changein this area.59. Five members of the public commented on our interim decision.One suggested a realignment along The Mall, Preston Road and EastLane, arguing that this would reflect the social and historicalties between north-west Brent and neighbouring areas in Harrow.Three other local residents sought a realignment along East Lane,in order to transfer the Sudbury Court Estate to Harrow. Afurther member of the public favoured the transfer of Sudbury andSudbury Court Wards to Harrow, on the grounds that many residentsof these wards shopped in Harrow, and made frequent use offacilities provided by that Borough.60. We considered all of these suggestions, and noted thatalthough they were submitted as alternatives to partitioningBrent, they would still have far-reaching effects on theprovision of local government services in North-West London. Thesuggested realignments appeared to us to cut arbitrarily throughresidential development, and to divide communities in Wembley.We therefore reaffirmed our earlier view that major change inthis area would cause considerable upheaval, and be detrimentalto effective and convenient local government. Accordingly. wehave decided to confirm our interim decision as final.18

61. Having rejected major change, we.considered the suggestionsreceived for minor changes to this boundary. Our interimdecisions and final proposals are set out in the followingparagraphs.b) Greenford Road and Sudburv Court Drive62. Brent submitted suggestions for change in the areas ofGreenford Road and Sudbury Court Drive. Harrow submitted similarsuggestions, prior to the submission of its radical proposal torealign this boundary further to the south. Both Brent andHarrow suggested realigning the boundary along Greenford Road,between its junction with Sudbury Hill and the existingBrent/Baling boundary, thereby transferring a number ofproperties on the eastern side of Greenford Road from Harrow toBrent. Brent did not specify the exact line of the realignment.Harrow suggested using the eastern side of the highway.63. These suggestions were supported by Harrow East ConservativeAssociation but opposed by a petition containing 270 signaturesfrom the Sudbury Hill (Harrow) Residents' Association, andrepresentations from seven members of the public.64. Linked with its suggestions for Greenford Road, Brentsuggested a boundary change in the area of Sudbury Court Drive.The effect would have been to realign the boundary from thenorthern end of Greenford Road, north up Sudbury Hill to thenorth-western curtilage of No. 5 Sudbury Hill and then along therear curtilages of properties on the north-western side ofSudbury Court Drive, to join the existing boundary at the rearof 36 Littleton Road. Such a realignment would have transferredproperties on the eastern side of Sudbury Hill and the northernside of Sudbury Court Drive, together with one property inHermitage View, from Harrow to Brent. In the event of our notadopting this realignment, Brent suggested that Nos. 20-24Sudbury Court Drive be transferred from Harrow to Brent. Boththese suggestions were opposed by four members of the public.19

65. Harrow suggested that the boundary in this area be realignedalong the length of Sudbury Court Drive and north-east alongWat ford Road to the south-east corner of the rugby footbal1ground at Northwick Park. The effect would have been to transferfive roads north of Sudbury Court Drive, known as the PebworthEstate, from Brent to Harrow. This suggestion was supported bythe Harrow East Conservative Association and by eight members ofthe public, one of whom proposed that it be extended to followthe natural feature of high ground south of Sudbury Court Road.66. The present boundary in this area is well defined andundefaced. Accordingly, as we had received no evidence that thesuggestions from Brent and Harrow would result in any significantbenefits in terms of improvements to effective and convenientlocal government, we took an interim decision to make noproposals.67. Brent did not comment on our interim decision. However,Harrow restated its view that the Pebworth Estate looked to thenorth, and should be transferred to its area. A local residentsuggested that only the northern side of Pebworth Road should betransferred to Harrow.68. Harrow, the Wembley division of the Metropolitan Police anda member of the public all disputed our view that the boundaryis well-defined in Sudbury Court Drive. They pointed out that theroad is split between two authorities, with three properties(Nos. 20-24) being in Harrow. The Metropolitan Police informedus that this division had led to properties at the western endof Sudbury Court Drive being excluded from the localneighbourhood watch scheme. All these respondents suggested thatthe boundary be realigned to the centre of Sudbury Court Drive,between Hermitage View and the junction with Sudbury Court Road.69. The Metropolitan Police also suggested two other minoramendments: first, to transfer Nos. 1025-1027 Harrow Road toHarrow; and second, to align the boundary to the easterncurtilage of Watford Road b.etween Pebworth Road and Harrow SchoolFarm. The police argued that, for operational purposes, it would20

e simpler if Watford Road were in . the same authority as theproperties fronting it.70. Our interims-decision, was supported by the Brent NorthConservative Association.71 . We reaffirmed our view that the Pebworth Estate should remainin Brent: it is separated from Harrow by extensive playingfields, and appears to us to be linked to Wembley. In ourjudgement, the existing boundary along the southern perimeter ofthe playing fields is well-defined and does not detract fromeffective service provision. A realignment along the centre ofPebworth Road, as suggested by a local resident, would serve onlyto split the Pebworth Estate.72. We acknowledged.the concern of the Metropolitan Police overthe division of Sudbury Court Drive. However, the existingboundary - does not split properties, and we observed that arealignment to the centre of Sudbury Court Drive would not unitethe road in one authority. Similarly, we doubted the necessityof the other minor changes suggested by the Metropolitan Police.The boundary in the vicinity of Nos. 1025-1027 Harrow Roadfollows property curtilages and is not defaced. The secondsuggestion, affecting a short stretch of Watford Road betweenPebworth Road and Harrow School Farm, was contingent on ourconfirming as final our draft proposal for Northwick Park (seeparagraphs 86-100 below). Nevertheless, we did not consider thatan alignment to the eastern side of Watford Road in this areawould result in any significant benefits in terms of effectiveand convenient local government. Accordingly, we have decided toconfirm as final our interim decision to make no proposals forGreenford Road and Sudbury Court Drive.c) Area east of Honevpot Lane Mao 1Draft Proposal73. Brent suggested a realignment to rectify a defaced and illdefinedlength of boundary between Honeypot Lane and Burnt Oak21

Broadway (A5), by realigning the boundary north from the existingboundary at Turner Road and along the rear curtilages ofproperties in Mollison Way and the Highlands, to rejoin theboundary with Barnet at the A5. An identical suggestion wasreceived from the Labour Group of Harrow Councillors.74. Harrow also suggested a realignment in this area, followinga line east from Honeypot Lane, along Cumberland Road, theeastern part of Beverley Drive, Holyrood Gardens and Stag Laneto meet the boundary with Barnet at the AS. Its suggestion wassupported by the Harrow East Conservative Association and by onemember of the public, but was opposed by the Labour Group ofHarrow Councillors. A member of the public suggested arealignment identical to the western part of Harrow's suggestionbut, to the east, adhering to the entire length of BeverleyDrive/ and thence along Holmstall Avenue to meet the existingboundary farther south on the A5 '75. We considered -that the - current boundary, by dividingproperties and roads, was unsatisfactory and caused confusion.We agreed that, in the interests of effective and convenientlocal government, a more clearly identifiable boundary wasrequired. However, we noted that this is an extensivelydeveloped area of similar character, without any features orbreaks in development offering natural boundaries.76. We considered the suggestions submitted to us for boundarychanges in the area, together with other possible alternatives.We decided to adopt as our draft proposal a line from HoneypotLane, along the northern curtilage of Kingsbury Hospital, northalong the Jubilee Line railway and then east along the rearcurtilages of properties on the southern side of Beverley Driveand Holmstall Avenue, to meet the existing boundary with Barnetat the A5. We considered that such an alignment had the meritof offering the best defined boundary, without dividing focalpoints of community or shopping centres in this residential area.22

Final Proposal77. We received eight representations in support of our draftproposal, and thirteen objections. Brent raised three separateobjections. It believed that our draft proposal would, firstly,split a community focussed on Queensbury Station Parade, whichit described as the v natural hub* of the local community. Second,it would divide the J; Laing Estate, which is listed as an "areaof special residential character 1 in the public consultationdraft of Brent's unitary development plan. Third, our draftproposal would remove from Brent a *primary employment area'stretching across Cumberland Road. Brent pointed out that thesouthern part of this industrial estate was due forredevelopment, and the Council was concerned that any investmentshould be maximised for the benefit of Brent residents. TheCouncil also pointed out that it owned housing stock off MollisonWay, and had earmarked part of the Brixton Estate in De Havi 11 andRoad for redevelopment. . .78. Education was a further issue raised by respondents. We wereinformed by the Department of Education and Science that Brentoperated a two-tier education system, and Harrow a three-tiersystem. Kingsbury High School argued that this was significant,in that children living in the area affected by our draftproposal would have to travel to a tertiary college in the farnorth of Harrow if they wished to continue with in-borougheducation after the age of sixteen. A local resident argued thatHarrow had insufficient spare capacity in its schools to absorbpupils from the area proposed for transfer.79. Harrow itself supported our draft proposal, which itconsidered had been well-received by residents. Support was alsoforthcoming from a Brent councillor and from the Wembley Divisionof the Metropolitan Police, which expressed the view that ourdraft proposal would improve links between the the local policedivision and residents of Queensbury. Two members of the publiccommented that the area between Beverley Drive and the existingboundary had been poorly managed by Brent; they cited as evidenceof this the recent closure of a branch library in Mollison Way.However, Brent pointed out that it was proposing to reopen this23

library, and had delayed doing so only because of the uncertaintyover a possible boundary change. Another member of the publicargued that residents of Queensbury naturally gravitate towardsthe shops and community facilities in Harrow, as those in Brentare distant and difficult to reach.80. There appeared to be a general acceptance that the existingboundary east of Honeypot Lane is unsatisfactory, being defacedin several areas. However, some respondents had reservationsabout the precise alignment of our draft proposal, and suggestedalternatives. Brent suggested that the boundary be continuedalong Honeypot Lane as far as Taunton Way, before followingTaunton Way and Camrose Avenue east to the AS, on the groundsthat these roads. delimit communities. The Brent Labour Party'Local Government 'Committee suggested an alignment along theHighlands and the rear curtilages of properties in Mollison Way,due west across Turner Road and then south along the railway lineto the existing boundary. Three members of the public separatelysuggested alignments along Mollison Way, in conjunction withalignments either along the Highlands or Stag Lane. Anothersuggested that the boundary should follow the rear curtilages ofproperties in The Highlands and the eastern half of Mollison Way,before following Waltham Drive southwards, and the rearcurtilages of properties in Calder Gardens westwards, as far asthe existing boundary.81 . The Brent North Conservative Association, which sharedBrent' s concern over the possible division" of the J. LaingEstate, suggested an alignment along Stag Lane, De Havilland Roadand the rear curtilages of properties in Lawrence Crescent andCalder Gardens. A local resident suggested that Beverley Drivewould provide the most suitable boundary in the area.82. We gave careful consideration to all these, and other,possible alternatives. Our draft proposal had attracted somecriticism on the grounds that it cut through an homogeneouscommunity. .However, we felt that in an area such as Queensbury,which lacks obvious delineating features, any realignment wouldinevitably run through neighbourhoods which were architecturallyand socially similar;. We questioned whether alignments along24

major thoroughfares, such as Camrose Avenue, Mollison Way orBeverley Drive, would improve on our draft proposal, as theseroads appeared to us to act as foci for local communities, ratherthan as clear dividing lines.83. We also recognised the concerns of Kingsbury High School overtertiary education provision. However, we considered that itsreservations had been substantially met by recent Court of Appealrulings, which have reinforced parents' rights to choose a schoolregardless of local authority boundaries.84. We felt that our draft proposal had the advantage of usingtwo clear breaks in residential development - first along therear of properties in Holms tall Avenue, and secondly to the northof Kingsbury Hospital. However, we recognised the force of someof Brent's arguments against our draft proposal: in particular,we were persuaded that the industrial/commercial area situatedto the north of Kingsbury Hospital should be retained within theBorough, and that the Laing Estate should remain united in oneauthority. Accordingly, we have decided to withdraw part of ourdraft proposal, so retaining the existing boundary west of theJubilee Line railway.85. East of the railway, we considered that the alignmentsuggested by the Brent North Conservative Association - alongStag Lane, De Havilland Road and the rear curtilages ofproperties in Lawrence Crescent and Calder Gardens - had themerit of providing an identifiable boundary which utilised abreak in residential development in De Havilland Road. We havetherefore decided to adopt the Conservative Association * ssuggestion as our final proposal in this area.d) Northwick Park Hospital and Harrow College of TechnologyMap 2Draft Proposal86. Harrow suggested a realignment eastwards from the WatfordRoad along the rear curtilages of properties in Norval Road, then25

north along the Bakerloo railway line to meet the existingboundary at Kenton Road. The effect of this suggestion would havebeen to transfer Northwick Park, Northwick Park Hospital, HarrowCollege of Technology, three residential roads and the south sideof part of Kenton Road from Brent to Harrow. Harrow submittedthis suggestion on the grounds that it would be more costeffectiveif the hospital were located within the area of itscontrolling District Health Authority, and that the adjacentresidential area was close to Harrow town centre, to which itlooks for services.87. The suggestion was supported by the Harrow East ConservativeAssociation and by two members of the public. The Labour Groupof Harrow Councillors supported the suggestion to transfer theHospital and College but opposed the transfer of the residentialarea; it considered that Kenton Road provides a natural boundarywhich should be retained. Brent did not comment on Harrow'ssuggestion.88. We considered that Northwick Park Hospital, the residentialroads to the north and, particularly, Harrow College ofTechnology look towards Harrow, in respect both of administrationand service provision. We took the view that it would be in theinterests of effective and convenient local government for thisarea to be located within Harrow. We therefore adopted Harrow'ssuggestion as our draft proposal.Final Proposal89. Brent opposed our draft proposal. It pointed out thatNorthwick Park Hospital had applied for National Health ServiceTrust status, which, i f granted, would have weakened thehospital's links with Harrow Health Authority. (In the event, theapplication was refused). It also informed us that Harrow Collegehad become an annexe of the Polytechnic of Central London, withHarrow itself having no role in its management. Brent commentedthat students were increasingly drawn from areas outside NorthwestLondon.26

90. Brent also objected to the transfer of Northwick Park toHarrow. It regarded the Park as being of particular importanceto Brent, which in its view is deficient in public space. TheCouncil commented that .it organises sports events in the Park,and said that the sports facilities are used mainly by residentsof Brent. It believed that our draft proposal would diminishlocal authority accountability to these users, particularly inrelation to planning matters. Brent also pointed out that thereis no vehicular or pedestrian access to the park from Harrow.91. The Rt Hon S ir Rhodes Boy son MP and Mr Paul Boateng MP,together with 46 other respondents, also objected to our draftproposal insofar as it affected Northwick Park. In general, theserepresentations reiterated the points made by Brent. However,concern was also expressed over the possibility of developmentin the park, and resultant traffic congestion. A Brent councillorand the Sudbury Court Residents' Association feared that Harrowwould take a more positive .view of development schemes thanBrent. The St. Cuthbert's Church Parochial Church Councilcommented that Brent has taken effective measures to controlsocial and leisure activities in the park, such as the flying ofmodel aircraft, which disturb local residents; it considered itimportant that the local authority responsible for Northwick Parkshould be answerable to those residents.92. A local resident pointed out that five electors resident inNorthwick Park Pavilion would be transferred to Harrow under ourdraft proposal, even though access to the pavilion was via theFairway, in Brent. A second member of the public considered itunreasonable that Harrow residents should be required tocontribute to the upkeep of a park which they rarely use, whilea third felt that our draft proposal would make it more difficultto police the area effectively.93. Harrow, and nine other respondents - including a Brentcouncillor, Harrow East Conservative Association and the Jubileeand Bakerloo Lines Users' Committee - supported our draftproposal insofar as it affected the Park, the college and thehospital. One local resident believed that Harrow would be morelikely than Brent to protect Northwick Park from development. The27

proposal to transfer the college and hospital was described as* soundly based' by the North-West Thames Regional HealthAuthority, which commented that the hospital is serviced byHarrow, and draws most of its patients from that Borough.94. We received 14 representations, and 197 pro-forma letters,supporting that part of our draft proposal affecting theresidential area west of Kenton Station. A further fourrespondents objected to this part of our draft proposal. Brent,together with a Brent councillor, argued that Churchill Avenue,Rushout Avenue and Northwick Avenue - collectively known as theNorthwick Park Triangle - form an integral part of the SpencerChurchill Estate, which straddles the Bakerloo Line railway.Brent argued that the shopping zone alongside Kenton Stationforms the focal point of the estate, and suggested that plans fora new supermarket, on land immediately to the east of theStation, would strengthen the ties between the Triangle andBrent. The Brent North Conservative Association commented on thehistoric connections between the triangle and Wembley. It feltthat the Kenton Road provides the clearest and most logicalboundary in this area.95. Harrow, the Metropolitan Police and a large number of localresidents supported this part of our draft proposal. TheNorthwick Park Residents' Association suggested that thene i ghbourhood looks to Harrow for service prov i s ion, withschools, shops and leisure facilities all being convenientlylocated north of the Kenton Road. The Association forwardeddetails of a survey which it had conducted in the locality: 73%of affected households were recorded as having supported ourdraft proposal, with just over 1% expressing opposition. A publicconsultation exercise conducted by Harrow showed similar results.Those residents who commented to us directly mentioned theTriangle's proximity to Harrow town centre, and its comparativeremoteness from administrative facilities in Brent.96. In assessing the response to our draft proposal, we noted thedistinction drawn by respondents between .the park, college andhospital on the one hand, and the residential triangle on the28

other. We recognised that the main opposition had been to thetransfer of Northwick Park to Harrow.97. The argument over which local authority would be the bettercustodian of Northwick Park seemed to us to be inconclusive andof limited relevance. The Park is designated as Metropolitan OpenLand, within the terms of the Department of the Environment'sRegional Planning Guidance for London, and the presumptionagainst development will remain regardless of which planningauthority has responsibility. We accepted, however, that Brenttakes an active interest in the park's management, organisingsporting events and activities for the Borough's schoolchildren.In view of this, and the fact that the Park is accessible onlyfrom Brent, we concluded that it would be inappropriate toconfirm this part of our draft proposal.98. Brent's arguments on the question of the college and hospitalseemed to us to be less persuasive. Neither the college nor thePolytechnic of North London opposed our draft proposal, and wewere informed that Harrow has retained a role in theadministration of the college. Additionally, the hospital remainsunder the control of Harrow Health Authority, and receivesservices from Harrow. Taking this into account, we reaffirmed ourview that the transfer of the college and hospital to Harrowwould be in the interests of effective and convenient localgovernment.99. The Northwick Triangle is separated from Brent by twointersecting railway lines, and its proximity to Harrow towncentre suggests a community of interest with that area. This wasborne out by residents' comments. The Spencer Churchill Estateis already divided by the Bakerloo Line, which appears to us toconstitute a significant barrier between communities.100. Accordingly, we have decided to confirm as final only thatpart of our draft proposal from Kenton Road south to theMetropolitan line. Thereafter, we have decided to adopt as ourfinal proposal an alignment along the southern embankment of theMetropolitan Line as far as Northwick Park Station, and thensouth and west along the perimeter of the hospi tal grounds,29

ejoining the existing boundary at Watford Road. This would keepNorthwick Park in Brent, but transfer the college, the hospitaland the Northwick Triangle to Harrow.THE BOUNDARY BETWEEN BRENT AND BALING101. In response to our letter of 1 April 1987, we receivedsuggestions for major realignments along the entire length ofthis boundary, as well as several suggestions for minor changes.In the interests of clarity, we have addressed the issues alongthe boundary in three sections.a) Barham war-fl (Boundary with Ha-rrrw to Bridoewater Road)Maps 3 and 4Draft Proposal -102. Neither Brent nor Ealing suggested changes to this stretchof boundary. However, the Ealing Social Democratic Partysuggested a realignment from Sudbury Hill Station east along thePiccadilly Line to the point at which it is crossed byBridgewater Road, then south down Bridgewater Road to theexisting boundary. We agreed that the existing boundary is illdefined,particularly in the area of Northwood Gardens, and tookthe view that a realignment along the Piccadilly Line wouldprovide a clear, identifiable and durable boundary. Accordingly,we adopted the Ealing Social Democratic Party's suggestion as ourdraft proposal.Final Proposal103. Our draft proposal was supported by Brent, Ealing and by twomembers of the public. Brent considered the Piccadilly Line inthis area to be a major natural barrier.104. We received twelve representations opposing our draftproposal. The Central Policy Unit Report argued that the areaimmediately south of the Piccadilly Line had close historicallinks with Sudbury, to the north. Mr Harry Greenway MP alsoexpressed the view that this area had stronger connections withSudbury and Wembley than with Ealing. He accepted, however, that30

'the existing boundary was unsatisfactory. As an alternative toour draft proposal, he suggested a realignment along the rear ofproperties in Whitton Avenue East between Greenford Road andAllendale Road, the centre of Allendale Road as far as theunderground line, and then along the underground line eastwards,and Bridgewater Road southwards, to the existing boundary.105. Mr Michael Elliott MEP and the Baling Labour Party contestedthe view that the underground line acts as a dividing linebetween communities. They believed that our draft proposal wouldcause unnecessary disruption to established patterns of communitylife. Brent North Conservative Association objected to our draftproposal on the grounds that it altered Wembley's historicboundaries, and might .reduce the likelihood of Wembley beingrestored as a separate borough as part of a future review.106. A Brent councillor considered the Piccadilly Line to be nobetter-a boundary.-, in this area than Whit ton Avenue East, or theGrand.Union Canal. Three respondents drew our attention to thebreak in development provided by Horsenden Hill, although onlyone suggested its adoption as a boundary. A member of the publicsuggested that, if change were considered necessary, the bestoption would be to transfer Polling District SEE of Brent'sBarham Ward to Ealing, by a realignment north along BridgewaterRoad from the existing boundary, west along Roundtree Road andsouth along the path linking Roundtree Road with Whitton AvenueEast.107. We gave careful consideration to the various comments andsuggestions made by respondents. Although we acknowledged thatHorsenden Hill does provide a clear break in development, we hadno evidence to suggest that the residential area south of WhittonAvenue East would be more effectively administered if transferredfrom Ealing to Brent. We also considered that minor realignmentsto the boundary would be unsuitable, as Whitton Avenue Eastappears to form the centre of a community.108. We remained of the view that a realignment along thePiccadilly Line would create a clear, identifiable boundary, andunite the community centred on Whitton Avenue East. We have31

therefore decided to confirm as final our draft proposal betweenGreenford Road and Bridgewater Road.b) Alperton (Bridgewater Road to North Circular Road) Map 5Draft Proposal109. Brent and Baling did . not suggest any changes to thisstretch of boundary. The Baling Social Democratic Party suggesteda realignment along the Grand Union Canal from the Clifford Roadallotment gardens to Manor Farm Road, and then south along ManorFarm Road and Alperton Lane as far as the existing boundary. Thiswould have had the effect of transferring the Lily GardensEstate, adjoining Manor Farm Road, from Brent to Baling, and ofuniting light industrial premises south of the Grand Union Canalin Ealing. A member of the public suggested a realignment alongthe Piccadilly Line from Bridgewater Road east to the point atwhich the railway crosses the Grand Union Canal, and theneastwards along the canal to the North Circular Road. Thissuggestion was intended to simplify the boundary in the Alpertonarea.110. We took the view that a realignment along the PiccadillyLine and the Grand Union Canal would take advantage of structuralbreaks and therefore provide a clearly defined boundary. We alsoconsidered that it would reflect community ties, by unitingPerivale in one authority. We therefore decided to adopt thesuggestion from a member of the public as our draft proposal.Final Proposal111. Brent supported our proposed realignment along thePiccadilly Line, but considered that the boundary should continuealong the railway as far south as Twyford Abbey Road, instead ofdiverting to the Grand Union Canal. It argued that the railwaywas an effective barrier both north and south of the canal.Ealing supported our draft proposal in full, as did two membersof the public, who believed that our proposed alignment would beeasier to identify on the ground than the existing boundary, and32

therefore less confusing to local residents. The Wembley Divisionof the Metropolitan Police suggested, as a slight modificationto our draft proposal, that the-boundary should be aligned to thenorthern, rather than the southern, bank of the Grand Union Canalbetween the Piccadilly Line and the North Circular Road. This wasintended to ensure that the whole length of the canal in thisarea would be in one authority.112. We received 15 objections to our draft proposal. The CentralPolicy Unit Report provided a detailed list of facilities whichwould be transferred out of Brent if our proposal wereimplemented. These included council housing; two primaryemployment areas; a workshop for disabled people; the AlpertonSports Ground; and Brent's central works depot in Marsh Road,which houses the Borough's Contract Services Department. Thereport argued that relocation of the depot would be expensive,and disrupt service provision in Brent. It also noted that ourdraft proposal divided the Baling Road, which it suggested wasa focal point for the surrounding Gujerati community.113. The loss of facilities, and the question of community ties,were also mentioned by a Brent councillor and the Birchen GroveResidents' Association. Ealing Labour Party claimed that VicarsGreen Primary School, in Lily Gardens, has close connections withAlperton High School, and that residents of the Lily GardensEstate look to Alperton for services. A second Brent councilloralso objected to the proposed transfer to Ealing of the primaryschool in Lily Gardens, although he acknowledged that residentsin the near neighbourhood might have affinities with Ealing. Hesuggested that, if we decided to opt for more minimal change, weshould consider the possibility of continuing the boundary alongManor Farm Road between Pleasant Way and the Central Line. Thesame suggestion was put forward by a member of the public.114. The councillor also questioned whether the Grand Union Canaldelimited communities, and pointed out that the Abbey Estate,located between the canal and the River Brent, was linked to thearea north of the canal by a footbridge. In addition, he saw nobenefit, in terms of effective and convenient local government,in transferring to Ealing the narrow strip of development in33

Bridgewater Road, to the west of One Tree Hill recreation ground.He pointed out that this area was cut off from Peri vale, inEaling, by Sudbury Gol f Course and Alperton Cemetery. Fourmembers of the public specifically objected to the transfer ofthis cemetery, which, they said, had traditionally catered forresidents of Wembley.115. Mr Harry Greenway MP commented that the Abbey Estate isdependent on Alperton for shopping facilities, and suggested thatthe recent opening of a supermarket in the Ealing Road wouldserve only to increase these links. His views were supported bytwo residents of the Abbey Estate, who considered the River Brentto be a more significant barrier in this area than the GrandUnion Canal. Mr Greenway suggested that the boundary should becontinued along the Grand Union Canal between Clifford Road andEaling Road, and then follow Ealing Road south to the existingboundary by Riverside Gardens. The Ealing Labour Party consideredthe Abbey Estate to be isolated from all surrounding areas, butfelt that, on balance, its affinities of interest were withBrent, rather than with Ealing.116. We accepted the force of the argument against the transferto Ealing of the various local authority properties situatedsouth of the canal. We acknowledged that the transfer of theseproperties to Ealing would, in the short term at least, causedislocation to services in Brent, and that the interests ofeffective local government would be better served by retainingthem in that Borough.117. Although only two residents of the Abbey Estate commenteddirectly to us, we felt we had sufficient information to concludethat the Estate looks mainly north to Alperton. We acknowledgedthat the River Brent and the North Circular Road are significantphysical features which tend to limit north-south movement inthis locality.118. We concluded that the existing boundary could besubstantially retained from the point in the west whereBridgewater Road crosses the Piccadilly Line to the point in theeast where it leaves the River Brent. However, we felt that the34

Lily Gardens Estate, to the west of Manor Farm Road, was closelyconnected to contiguous residential development in Baling, andcould be more effectively and conveniently administered from thatBorough. Accordingly, we have decided to modify our draftproposal, and to adopt as our final proposal a suggestion froma Brent councillor, for a realignment along Manor Farm Road andAlperton Lane between Pleasant Way and the existing boundary,together with a minor realignment along the Grand Union and ManorFarm Road south of Clifford Road, in order to unite industrialpremises in Baling.c) West Twvford/Park Roval (North Circular Road east to Boundarywith Hammersmith and Fulham) Maps 5.6 and 7Draft Proposal119. Brent and Baling suggested only minor realignments in thisarea. Brent suggested a centre-of-road realignment alongCoronation Road, to rectify an area of undefined and defacedboundary at the site of the former British Rail freight depot.In the .adjacent area at Acton Lane, Baling suggested arealignment along the southern frontage of the Central MiddlesexHospital, on the grounds that this would reflect the existingarrangements for highway maintenance. Baling also submitted aminor suggestion to realign the boundary from the centre to thesouthern side of Harley Road, to facilitate road maintenance inthe area.120. In the vicinity of Iveagh Avenue, Baling suggested that amore logical boundary could be formed by extending the existingboundary along the River Brent to meet the Grand Union Canal,passing south-east along the canal and then returning to thepresent boundary westwards along Twyford Abbey Road. The WestTwyford Residents' Association suggested that the Brent/Balingboundary should be extended to the Grand Union Canal, in orderto transfer Blveden Road, Elvedon Place and the Abbeyfieldsdevelopment to Baling. The Association did not, however,delineate a boundary to achieve this.35

121. The Baling Conservative Associations (Ealing Acton, BalingNorth and Ealing Southall) considered this stretch of theboundary between Brent and Ealing to be in need of radicalchange. They suggested that the boundary should be realigned tofollow the River Brent to its junction with the Grand Union Canaland then follow the canal eastwards to Old Oak Lane. This wouldhave had the effect of transferring part of Park Royal from Brentto Ealing, and three residential streets, some industrial landand the Willesden Freightliner terminal from Ealing to Brent. TheAssociations considered that their suggestion, if adopted, wouldhave had the advantage of uniting West Twyford in Ealing, onwhich authority, they said, this community depended for primaryschools and civic amenities.122. The Ealing Social Democratic Party also considered thatradical change to the boundary was necessary, on the grounds thatit did not satisfactorily relate to the pattern of communitiesand transport linkages in this highly urbanised area. Itsuggested a realignment along the Central Line eastwards fromAlper ton Lane to Old Oak Common Lane, in order to uni tecommunities and place the main body of the Park Royal industrialestate under the control of a single planning authority. A memberof the public submitted an identical suggestion.123. Another member of the public suggested a realignmentfollowing the Grand Union Canal, from the point at which itcrosses the River Brent eastwards to Old Oak Lane. Thissuggestion was intended to overcome the claimed divisive effectof the main British Rail line and sidings between Wembley Centraland Willesden Junction.124. The existing boundary between Brent and Ealing is generallyill-defined, dividing not only roads and properties but also thecommunity of West Twyford and the industrial area of Park Royal,all of which appeared to us (on the information then available)to look to Ealing for amenities and services. West of the NorthCircular Road, we decided to adopt as our draft proposal a linenorthwards along the eastern curtilage of the North Circular tomeet the British Rail line, and then eastwards along the southern36

edge of the railway and the Freightliner Terminal at WillesdenJunction, to the existing boundary with Hammersmith and Fulham.In our view, such a realignment had the advantages of providinga clearly identifiable boundary which would unite West Twyfordand Park Royal in Ealing.Final Proposal125. Brent opposed our draft proposal, on several grounds. Itpointed out that the portion of the Park Royal industrial estatecurrently in Brent accounted for 30% of the Borough's "primaryemployment land 1 and contained several major employers who drewlabour from communities in Brent, such as Stonebridge andHarlesden. It argued that, as Park Royal had strategic andregional significance, planning matters should not be thepreserve of a single borough; any possible negative effects ofdivision had, in Brent's view, been overcome by the creation ofinter-borough management and planning agencies, such as the ParkRoyal Partnership. The Council commented that close links hadbeen forged between employers based in Park Royal and localcolleges in Brent, leading to work placement schemes and trainingprogrammes.126. The Council expressed the view that Park Royal would bedisadvantaged if it were united in Ealing. It pointed out thatBrent was eligible to apply for Government funding under theUrban Programme and the City Challenge initiative, and thatconsideration was being given to making Park Royal the focus ofa City Challenge bid to the Department of the Environment. SinceEaling was not eligible to apply for such funding, Brent feltthat our draft proposal could have a detrimental effect on theredevelopment of Park Royal.127. We received a further 18 objections to our draft proposal.The North-West London Training and Enterprise Council believedthat uniting Park Royal in Ealing would hinder the area'sregeneration, as Brent had been heavily involved in framingschemes for renewal. In addition, it suggested that the currentdivision of Park Royal was beneficial in that it provided for anelement of competition between the three boroughs responsible for37

the area. Brent Trades Union Council was concerned that our draftproposal could endanger a major consortium-led developmentproject known as Park Royal International. We understood,however, that work on this project had been suspended, pendinga revival of the property market.128. A number of Park Royal respondents argued that our draftproposal would sever relationships built up between privatecompanies and local authorities. Guinness pic informed us thatit was represented on Brent's Urban Regeneration Agency, andcommented appreciatively on the co-operation it had received fromthe Council. It suggested that a small area of land betweenCoronation Road and the Western Avenue, which formed part of itsproperty holdings, should be transferred to Brent. McVitie's Ltdalso indicated that it would prefer its premises, off Acton Lane,to remain in Brent.129. The Metropolitan Police suggested that Park Royal had bettertransport links with Brent than with Baling, and Brent commentedthat these links with its area would be further improved when theroad connecting Abbey Road to the North Circular was completedin 1994. The Wembley Rifle Club, located on land adjacent to thislink road, said that it had strong ties with Brent; it mentionedthat the Mayors of Wembley - and, latterly, those of Brent - hadtraditionally been ex-officio presidents of the club. The RifleClub suggested that the line of our draft proposal be modifiedslightly in the area of the link road, in order to retain itspremises in Brent. Other respondents, including Mr Harry GreenwayMP, suggested that the boundary be aligned to the River Brentbetween the Grand Union Canal and the railway embankment, to takeaccount of the barrier effect of the river and to avoiddefacement when the Abbey link road was completed.130. The proposed transfer of the Central Middlesex Hospital toEaling was an additional source of concern to respondents. Brentcommented that patients were drawn overwhelmingly from its area,and that Brent Social Services Department co-operated closelywith Parkside Health Authority in providing social work supportat the hospital. The North West Thames Regional Health Authorityalso opposed the transfer of the hospital to Ealing. Neither the38

Central Middlesex Hospital Trust nor.Parkside Health Authoritycommented directly to us. However, the latter was quoted by Brentas questioning whether the hospital's interests would be servedby having Baling as the sole planning authority, Mr Paul BoatengMP expressed concern that provision of care for the elderly wouldsuffer if our draft proposal were implemented.131. Ealing supported the proposed unification of Park Royal inits area, as did nine other respondents. Ealing Labour Party andMr Michael Elliott MEP believed that our draft proposal wouldfacilitate the regeneration of Park Royal, while agents for HeinzLtd. suggested that uniting the area in one authority would leadto greater efficiency and simplicity in the planning process. MrHarry Greenway MP. expressed doubts over the strength of theconnection between the Central Middlesex Hospital and surroundingneighbourhoods in Brent, and supported the hospital's transferto Ealing. A Brent councillor suggested a realignment along theGrand Union Canal between the North Circular Road and theexisting boundary at Willesden Power Station, so transferring thehospital and the larger part of Park Royal to Ealing.132. Both Ealing and the Ealing Labour Party objected to theproposed transfer to Brent of the Freightliner Terminal atWillesden Junction. The Council commented that it had beeninvolved in developing part of the site as a depot for ChannelTunnel traffic. The Ealing Labour Party commented that vehicularaccess to the terminal site was from.Ealing. The transfer of theterminal was, however, supported by the Jubilee and BakerlooLines Users' Committee.133. The West Twyford Residents 1 Association supported our draftproposal, on the grounds that it would unite West Twyford inEaling. Several other respondents, including the Ealing LabourParty, also considered that this community should be united inone authority. The Brent Labour Party Local Government Committeesuggested that this could best be achieved by transferringAbbeyfields Close and Moyne Place to Ealing. A member of thepublic suggested a realignment north along the River Brent as faras the Grand Union Canal, south-east along the canal to a pointdue north of Rainsford Road, and then south and west along the39

ear" curtilages of properties in Moyne Place and Abbeyf ieldsClose, to rejoin the existing boundary in Twyford Abbey Road.134. Having considered the response to our draft proposal, weremained doubtful that the current three-way split of Park Royalwas in the long-term best interests of the industrial estate; weconsidered that, in purely planning terms, there was a case foruniting the estate within one authority. Nevertheless, it wasclear to us that Brent has close, and mutually beneficial,contact with business and industrial concerns in Park Royal.These contacts extend into the education and training spheres,and appear to be of particular value to an area such as southBrent; which has suffered from high unemployment. Moreover, Brentargued persuasively that the current multi-agency and multiboroughapproach to planning matters functions effectively, andthat to disrupt existing arrangements would set backredevelopment. • .135. We accepted that the Central Middlesex Hospital, in spiteof its N.H.S. Trust status, had close links with the ParksideHealth Authority and Brent's Social Services Department, and thatits transfer to Ealing might have a detrimental effect on healthcare provision in Brent.136. The information received in response to our draft proposalsletter suggested, on balance, that major change in the Park Royalarea would be inappropriate at this time. We have thereforedecided not to confirm our draft proposal 'in full, but toconsider instead the options for more limited changes which wouldunite communities and rectify defacements in the existingboundary.137. We took the view that West Twyford should be united inEaling, on the grounds that this area has close community tieswith Ealing, and has better access from that Borough.Accordingly, we have decided to adopt as our final proposal asuggestion from a member of the public, to transfer ElvedonPlace, Elvedon Road, Moyne Place and Abbey fields Close from Brentto Ealing, by a realignment along the River Brent, the centre of40

the Grand Union Canal and part of the northern perimeter of theGuinness estate.138. We considered Guinness' suggestion that an area of landbetween Coronation Road and the Western Avenue should be unitedwith the major part of its estate in Brent. However, we notedthat this land - although owned by Guinness - was covered largelyin railway tracks, and we could see no justification in terms ofeffective and convenient local government for transferring it toBrent.139. In order to rectify anomalies in Coronation Road and ActonLane, we have decided to adopt as part of our final proposal arealignment along the rear curtilage of the former British Railfreight depot in Coronation Road, and along the northerncurtilage of Acton Lane as far as the line of our draft proposalat the Watford-Euston railway. East of this point, we consideredthat, as the Freightliner Terminal at Willesden Junction wasoperationally linked to the railway system, it should be in thesame authority - Brent - as the sidings to the north.Accordingly, we have decided to confirm as final that part of ourdraft proposal running east from Acton Lane to the boundarybetween Ealing and Hammersmith and Fulham.BRENT'S BOUNDARIES WITH HAMMERSMITH AND FULHAM AND THE ROYALBOROUGH OF KENSINGTON AND CHELSEA140. In response to our letter of 31 July, Westminster CouncilConservative Group submitted a new suggestion to realign Brent'ssouthern boundary to the Grand Union Canal, between the Old Oakrailway sidings and Ladbroke Grove. It described the Grand Unionas a natural boundary. The effect of the suggestion would havebeen to transfer to Brent an industrial estate, two cemeteriesand residential areas at College Park and Kensal Rise.141 . Whilst acknowledging that the canal was one of a numbersignificant physical features running east-west through thisarea, we had no evidence to suggest that its use as a boundaryin this area would result in more effective and convenient local41

government. We have . therefore decided not to pursue theConservative Group's suggestion.BRENT'S BOUNDARY WITH HAMMERSMITH AND FULHAMCollege Park Maps 7 and 8Draft Proposal .142. Brent suggested the transfer to its area of some residentialand industrial property located south of the Harrow Road.Hammersmith and Fulham suggested using a side of road realignmentin Harrow Road. It also submitted a minor suggestion to clarifythe boundary in the vicinity of Willesden Junction.143. We doubted whether these minor realignments would addressthe essential arbitrariness of the existing boundary, which didnot appear to reflect patterns of communities in this area. Weobserved that College Park is separated from other residentialareas in Hammersmith and Fulham by a number of divisive features,including the Watford to Euston and Baling to Paddington railwaylines, St. Mary's Cemetery, the Grand Union Canal and WormwoodScrubs. This contrasted with College Park's proximity toresidential and shopping areas in Brent, such as Harlesden. Wefelt that, in view of its geographical position, College Parkcould be more effectively and conveniently administered fromBrent. Accordingly, we decided to adopt as our draft proposal arealignment along the Watford to Euston railway line, therebytransferring College Park to Brent.Final Proposal144. Brent supported our draft proposal, as did a Brentcouncillor and a member of the public. However, it was stronglyopposed by Hammersmith and Fulham. We also received 77representations from College Park residents, a petitioncontaining 554 signatures, and 21 letters from pupils of KenmontPrimary School, all opposing our draft proposal,145. Although many respondents acknowledged that College Park isphysically separate from other residential areas in Hammersmithand Fulham, they denied that this had caused problems in terms42

of service provision. Some suggested that Hammersmith and FulhamCouncil had gone to considerable lengths to integrate the areainto the Borough, in order to compensate for its apparent^isolation 1146. Hammersmith and Fulham was widely perceived as an efficientauthority. The regularity and efficiency of refuse collectionsand highway maintenance appeared to be especially appreciated bylocal residents, many of whom feared that services woulddeteriorate under Brent. The College Park Action Committeementioned that Hammersmith and Fulham had provided a mobilelibrary and a community centre; in addition, traffic calmingmeasures had been instituted, and funding made available for asummer festival. A number of local businesses also commentedfavourably on Hammersmith and Fulham*s record as a provider ofservices.147. Several respondents claimed that College Park is wellconnectedto Hammersmith and Fulham. They pointed out thatadministrative facilities in Hammersmith are more easilyaccessible than those in Wembley, while Hammersmith and Fulhamnoted that the A219 Scrubs Lane provides a fast link betweenCollege Park and centres to the south. A view commonly expressedwas that the Harrow Road, to the north of College Park, is a farmore effective impediment to movement than the railway lines, theGrand Union Canal or Wormwood Scrubs. The Hammersmith LabourParty and a local firm suggested that the boundary should followthe Harrow Road and the rear of properties in Tubbs Road, as faras the existing boundary at Old Oak Lane.148. Nearly all respondents claimed to identify strongly withHammersmith and Fulham, and to have few connections with areasnorth of the Harrow Road. Several feared that our draft proposalwould sever long-standing community links. The Governors ofKenmont Primary School were concerned about possible disruptionto education services, and pointed out that pupils used sportsand educational facilities in White City and Hammersmith. TheCollege Park Action Committee commented that some residents ofCollege Park were employed on the industrial estate to the southof the Watford-Euston railway line.43

149. Hammersmith and Fulham, having conducted an opinion surveyof local residents, concluded that these residents valued theirlinks with Hammersmith, and believed that a transfer to Brentwould bring disadvantages in terms of effective and convenientlocal government. The College Park Action Committee noted thatour draft proposal .would leave within Hammersmith and Fulham arow of terraced cottages adjoining St. Nary's cemetery; itquestioned whether the interests of effective and convenientlocal government would be served by dividing these few propertiesfrom College Park.150. We acknowledged the strength of local residents' oppositionto our draft proposal; approximately 50% of residents signed thepetition opposing our draft proposal, and Hammersmith Council'ssurvey appeared to show a similarly high proportion of householdsto be against major change. We accepted that College Park wasunusually self-contained for an inner London community, and thatit could be said to have a distinct identity. However, it seemedto us that its case for remaining separate from Brent derived inpart from the apparent barrier effect of the Harrow Road. Wedoubted whether the Harrow Road was in practice such asignificant barrier. Although the road is a through-route, it isonly single-lane at College Park, and a pelican crossing has beeninstalled.151. We addressed the question of the terraced cottages in ScrubsLane, which would remain in Hammersmith and Fulham if our finalproposal' were implemented. We noted that the cottages wereadjacent to a trading estate which would continue to requireservicing by Hammersmith and Fulham. Although the cottages wouldbe isolated from other residential development, there were nogrounds for supposing that they would suffer, in terms of serviceprovision, if College Park were transferred to Brent. We alsoconsidered a suggestion from a member of the public that St.Mary's Roman Catholic Cemetery be transferred to Brent along withCollege Park. It was argued in favour of this suggestion that thechurch to which the cemetery was linked was situated in Brent,and that that Borough would be more committed to the upkeep ofthe cemetery. We doubted the validity of this last point, notingthat Hammersmith and Fulham had designated the cemetery a44

conservation area..Moreover, the change would not in our viewenhance the provision of local government services.152. In reviewing our draft proposal, we were conscious of thepoints raised in paragraph 26 above - in particular, we bore in.mind that the wishes of the people are only one of the factorswhich we must consider. He acknowledged the strength of feelingexpressed by the considerable number of College Park residentswho made their views known to us, but we had also to consider thepattern of community life and the effective operation of localauthority services. Notwithstanding the views of local residents,we concluded that College Park has natural affinities with Brent.We realise that most local authorities are resourceful inovercoming problems caused by boundary anomalies, and we acceptthat Hammersmith and Fulham may not in practice be experiencingdifficulties in providing services to College Park. Nevertheless,the distance between College Park and the nearest centres inHammersmith and Fulham is considerable; and .there is a range ofprominent physical features - most notably the Grand Union Canal,two mainline railway lines, a cemetery and a sizeable area ofopen land - which.isolate the neighbourhood from communities tothe south. Taken together, these facts argue strongly that localauthority services could in the long run be more effectively andconveniently provided by Brent. Accordingly, we have decided toconfirm our draft proposal as final.BRENT'S BOUNDARY WITH KENSINGTON AND CHELSEA Map 8Draft Proposal153. Brent made no suggestions for change to this boundary.However, Kensington and Chelsea suggested realigning the boundaryalong the Grand Union Canal, thereby transferring Kensal GreenCemetery to Brent. We considered that the Watford-Euston railwayline would generally provide a more suitable boundary alongBrent's southern boundary. However, in the area of the KensalGreen Tunnels, where adherence to the railway line was notviable, we decided to adopt a line which would unite all theproperties in Alma Place, and those on the southern side ofHarrow Road, in Brent. We considered that these properties could45

e' more effectively and conveniently, administered by thatBorough.Final Proposal154. Brent supported our draft proposal. However, it was opposedby Kensington and Chelsea, on the grounds that it would loseplanning control over land bordering Kensal Green Cemetery. Amember of the public suggested the transfer of Kensal GreenCemetery to Westminster, partly in order to eliminate the threeboroughsplit at the junction of the Harrow Road and LadbrokeGrove. In his judgement, this had been largely to blame for suchproblems as traffic congestion and inadequate road maintenance.He believed that unified responsibility for the junction and thesurrounding residential area would benefit the local environment.155. We reaffirmed our view that the properties fronting theHarrow Road look to Brent, and appear to have no community ofinterest with other commercial and residential areas inKensington and Chelsea. We had no reason to suppose that thesetting of the cemetery would be damaged by possible developmentalong the Harrow Road, as Kensington and Chelsea had suggested.As regards the Harrow Road/Ladbroke Grove junction, we took theview that only minor realignments were necessary in this area.(We have consulted on these realignments in the context of ourreview of the City of Westminster's boundary with Kensington andChelsea). Accordingly, we have decided to confirm as final ourdraft proposal for the boundary between Brent and Kensington andChelsea.BRENT'S BOUNDARY WITH WESTMINSTERKensal Triangle/South Kilburn Map 9Draft Proposal156. Brent suggested a side of road realignment along a shortstretch of Shirland Road, in order to resolve the problem ofdivided properties. The City of Westminster also suggested aminor change at Shirland Road, the effect of which would have46

een to transfer seven properties from Brent to Westminster.The Westminster Labour Party suggested that the entire boundarybetween Brent and Westminster should be realigned along theWatford to Euston railway, on the grounds that the residentialareas that would be transferred have restricted access from Brentand look to. Westminster for amenities and services. TheWestminster Labour Party considered that the existing boundarywas not conducive to the effective delivery of local governmentservices. ' - - * ... :157. We considered that the existing boundary between Brent andWestminster divides communities around Kensal Green and West andSouth Kilburn, and warrants realignment in order more accuratelyto reflect the pattern of community and service links in thearea. We noted that residential communities are isolated betweenthe Watford-Euston line and the boundary with Westminster, andconcluded that local government services to these areas could bemore.effectively provided from Westminster. . ... •158. Accordingly, in order to provide a clearly identifiableboundary which reflected the pattern of communities in the area,we decided to adopt the Watford-Euston line between WillesdenJunction and the Edgware Road as our draft proposal for theboundary between Brent and the City of Westminster, as suggestedby the Westminster Labour Party.Final Proposal159. We received 21 representations in support of our draftproposal, and 22 objections. A petition of 13 signatures wassubmitted in opposition to our draft proposal and another,containing 51 signatures, supported the unification inWestminster of the Tollgate Gardens Estate, to the south ofOxford Road.160. Brent supported a realignment along the Watford-Eustonrailway line, which it regarded as a major structural barrier.Our draft proposal was also supported by the Brent EastConservative Association and by a Brent councillor, who agreedthat our alignment reflected the pattern of communities in the47

South-Kilburn area. . Ten residents of the Kensal "/Triangle (i.e.the area bounded by the Harrow Road, Chamberlayne Road and therailway) argued that the quality and level of service provision -in particular refuse collection - would improve if the Trianglewere transferred to Westminster/They added that, in their view,.the Kensal.Triangle had strong links with Westminster. Severalresidents of Oxford Road, and the adjoining Tollgate GardensEstate, expressed the view that their neighbourhood looked toWestminster, and provided details of their dependence on servicesand facilities provided by that Borough. They commented that thepattern of public transport provision reinforced these links tot h e south. : " . - - • - - . - . . -161. Another member of the public, while supporting our draft-proposal,' made the point that South Kilburn and the KensalTriangle are distinct neighbourhoods, with the latter being moreclosely connected to Westminster. Accordingly, he put forward analternative, intermediate alignment, which followed the Watford-Euston railway only as far as Salusbury Road, and then followedSalusbury Road south to the existing boundary.162. Westminster City Council, Mr Ken Livingstone HP, the Rt HonReginald Free son, the Liberal Democrat and Labour Groups on BrentCounci1, a Brent counci1lor and Brent North Labour Party allopposed our draft proposal, and included the Central Policy UnitReport as part of their submissions. One of the Report's mainreservations was that our draft proposal paid too littleattention to community ties; it argued that the shops and otherfacilities located north of the railway line exert a considerablepull on South Kilburn, so that the railway itself cannot be saidto delimit communities. It also drew attention to the presencein South Kilburn of a Council-owned annexe of the College ofNorth West London, which caters largely for students living inBrent.163. The Report also pointed out that South Kilburn contains thelargest municipal housing estate in Brent, and that the majorityof those living in South Kilburn are council tenants. These factswere noted by Westminster City Council, in support of its48

argument that the draft proposal would cause needless disruption,and harm Brent by depleting its in-Borough housing stock.164. In addition, the Report listed the services and facilitiesin South Kilburn which are organised or funded by Brent. Theseranged from an Afro-Caribbean centre to a Home Care Service,which provides assistance to residents with physical disabilitiesor learning difficulties. Lastly, the Report mentioned theefforts being made by Brent to counter deprivation in SouthKilburn, which has the Borough's highest unemployment rate. Thesesocio-economic problems would, it argued, be compounded by ourdraft proposal, as Westminster is ineligible for Urban Programmefunding. The Report pointed out that Brent has been able to usesuch funding to build premises for small businesses.165. Brent Community Law Centre suggested that South Kilburn hasstrong historical links with areas north of the railway line.Westminster Council Conservative Group and Westminster NorthConservative Association considered South Kilburn to be^suburban' - in other words, different in character from areasof inner London, such as Westminster; in their view the KensalTriangle also looks outwards, towards Harlesden.166. Several respondents (including Westminster itself) doubtedwhether local government services could be more effectivelyprovided from Westminster. They observed that Brent was heavilyinvolved in South Kilburn, principally as a landlord. TheCommunity Law Centre pointed out that if Brent continued to ownand manage the South Kilburn Estate, tenants would pay rent toone local authority while receiving housing benefit from another.It regarded this as a recipe for confusion and inefficiency. Ona broader point, the Community Law Centre also expressed concernthat our draft proposal would divide reponsibility for KilburnHigh Road between three authorities.167. Our proposal to remove the Kensal Triangle from Brent alsoattracted opposition. The Kensal Green Residents' Associationreported that its members had no desire for change. A companybased in this area was anxious to remain within the area coveredby the North West London Training and Enterprise Council, from49

which it received part of its funding. Another localorganisation, the Neighbourhood Six Council, felt that the KensalTriangle looked north to Kensal Green. This view was shared byWestminster and by the Westminster North ConservativeAssociation; both commented that access to the Kensal Trianglefrom Westminster was limited, now that traffic calming deviceshad been installed.168. Westminster disputed the need for anything more than minorrealignments, to eliminate anomalies at Shirland Road. However,it suggested that if major change was deemed necessary, thenparts of Westminster should be transferred to Brent.Specifically, it recommended an alignment along Walterton Roadand the Grand Union Canal, which would have united West Kilburnand South Kilburn in Brent. This suggestion was supported byWestminster North Conservative Association, a member of thepublic and by Westminster Council Conservative Group, which alsosuggested an alignment along Kilburn Park Road as far as theboundary between Westminster and Camden. The Conservative Groupargued that West Kilburn is essentially "inner suburban' and, insocio-economic terms, has more in common with Kilburn proper thanwith areas to the south in Westminster.169. The Leader of the Opposition on Westminster Council and theSaltram Area Residents 1 Association opposed this suggestion, asdid Walterton and Elgin Community Homes Ltd, which pointed outthat a realignment along Walterton Road would split a housingestate.170. We reassessed our draft proposal in the light of all theinformation presented to us by respondents. We agreed that thearea affected by our draft proposal covered two distinct areas.South Kilburn, to the east, is comprised largely of municipalhousing, and contains numerous social services and communityfacilities which receive funding from Brent. By contrast, thearea west of Salusbury Road appears to share the socio-economiccharacteristics of West Kilburn, and the response from localresidents suggests that it has close community ties withWestminster.50

171. By .far the larger part of the Central Policy Unit Report wasconcerned with South Kilburn: all the facilities and servicesmentioned in the Report are located in this area, and thedeprivation which Brent is seeking to remedy through UrbanProgramme funding is concentrated in the South Kilburn Estate.We were concerned that the loss of this sizeable housing estatemight affect Brent Council's ability to discharge its statutoryresponsibilities towards the homeless. It seemed to us, onreconsideration, that South Kilburn has strong community tieswith Brent, and that to transfer the area to Westminster wouldcause significant disruption, which would not be in the interestsof effective and convenient local government.172. Accordingly, we considered alternatives to our draftproposal,''which would remedy defacements in the area of MalvernRoad and Oxford Road and eliminate anomalies in the area ofKilburn Lane. We took the view that the minor suggestion putforward by Westminster, for a realignment at Shirland Road, wouldnot address the fundamental defects of the existing boundary; norcould its major suggestion, involving the transfer of WestKilburn to Brent, be justified in terms of effective andconvenient local government.173. In order more accurately to reflect the differences betweenthe Kensal Triangle and South Kilburn, we have decided to confirmas final that part of our draft proposal between the Kensal GreenTunnels and Salusbury Road, and to modify the remainder byrealigning the boundary south along the centres of SalusburyRoad, Malvern Road and Chippenham Gardens, rejoining the existingboundary in Kilburn Park Road. Further east, we have decided torealign the boundary to the centre of Oxford Road betweenCambridge Gardens and the existing boundary between Brent andCamden, in order to unite the Tollgate Gardens Estate inWestminster. We consider that these alignments - the effect ofwhich would be to retain South Kilburn in Brent but transfer theKilburn Triangle to Westminster - would best reflect localcommunities of interest, and would accord with the expressedwishes of residents.51

BRENT'S BOUNDARY WITH CAMDENKilburn High Road174. We noted that the existing boundary between Brent and Camdenfollows, in its entirety, the Edgware Road (A5). Mo suggestionswere submitted to us for change in this area. The presentboundary divides the shopping centre at Kilburn, but it has themer i t of following a clearly defined and well-establi shedfeature. Accordingly, in the absence of any other more suitablealignment in this area, we took an interim decision to make noproposals for this boundary.175. Neither Camden nor Brent expressed a view on our interimdecision. The Jubilee and Bakerloo Lines Users' Committeesupported our interim decision; it argued that the division ofKilburn High Road caused no problems in practice, as interboroughmaintenance agreements were in place. We have thereforedecided to confirm our interim decision as final.ELECTORAL CONSEQUENCES176. When publishing our draft proposals, we invited suggestionsfor possible changes to electoral boundaries as a consequence ofour proposed administrative boundary changes. We were concernedat that stage to avoid premature discussion of electoralconsequences when it was already evident that the proposalsthemselves would be the subject of considerable further comment,which we would want to consider before formulating our finalproposals. As yet, therefore, no proposals to deal with electoralconsequences have been published. Having now formulated our finalproposals for boundary changes, we have concluded that, in viewof the nature and extent of the consequential changes toelectoral arrangements which will be required, these ought to beadvertised separately in order to give local authorities andresidents affected by them a full opportunity to comment. We haveaccordingly decided that we should report to you now only on ourfinal proposals for administrative boundary changes, as provided52

for in section 51(1) of the 1972 Act. Our final proposals forconsequential changes to electoral arrangements will be thesubject of a separate report, which will be submitted to you indue course.CONCLUSIONS177. We believe that our final proposals, which are summarisedin Annexes B and C to this report, are in the interests ofeffective and convenient local government and we commend them toyou accordingly.PUBLICATION178. A separate letter is being sent to the London Boroughs ofBrent, Barnet, Camden, Baling, Hammersmith and Fulham, Harrow,the Royal Borough of Kensington and Chelsea and the City ofWestminster, asking them to deposit copies of this report attheir main offices for inspection for a period of six months.They are also being asked to put notices to that effect on publicnotice boards. Arrangements have been made for similar noticesto be inserted in the local press. The text of the notice willexplain that the Commission has fulfilled its statutory role inthis matter and that it now falls to you to make an Orderimplementing the proposals, if you think fit, though not earlierthan six weeks from the date on which our final proposals aresubmitted to you. Copies of this report, with the maps attachedat Annex A illustrating the proposed changes, are being sent toall those who received our draft proposals letter of 31 July1991, and to those who made written representations to us.53

Signed K F J ENNALS (Chairman)G R PRENTICEHELEN SARKANYC W SMITHK YOUNGR D COMPTONSecretary7 May 1992

LOCAL GOVERNMENT BOUNDARY COMMISSION FOR ENGLANDREVIEWS OF GREATER LONDON. THE LONDON BOROUGHSAND THE CITY OF LONDONBRENT LBAFFECTING HARROW, EALING, HAMMERSMITH AND FULHAM,KENSINGTON AND CHELSEA and CITY OF WESTMINSTER LBsFINAL PROPOSALSExisting BoundaryProposed BoundaryProduced by Ordnance Survey for theLocal Government Boundary Commission for England

LOCATION DIA«AMIHARROW LBBARNET LBBRENT LBCAMDEN LBIEALING LBHAMMERSMTHAND FULHAMLBKENSINGTON ANDCHELSEA LB

IHARROW LB

HARROW LB

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HARROW LBEALNG LB

BRENT LBNAL PK/EALING LB

BRENT LBALING LBC) Crown Copyright 1992 ftO•DO)

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KENSINGTONAND CHELSEA LB

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MAPNO.CONSEQUENTIAL CHANGESAREAREF.FROMTOABBrent LBHarrow LB2A3A4A5ABCBrent LBEaling LB6ACBEaling LBBrent LBABrent LBEaling LB7BEaling LBBrent LBCHammersmith & FulhamLBBrent LBAKensington & Chelsea LBBrent LB8BBrent LBCity of Westminster LBCHammersmith & FulhamLBBrent LBABBrent LBCity of Westminster LBCtHammersmith & FulhamLBBrent LB

ANNEX CSUMMARY OF PROPOSED BOUNDARY CHANGESBrent's boundary with HarrowArea east ofHoneypot LaneNorthwick ParkHospital andHarrow Collegeof TechnologyBrent / s boundary with EalinqBarham WardAlpertonWest Twyford/Park RoyalRealignment to stag Lane,De Havilland Road and rearcurtilages of propertiesin Lawrence Crescentand Reynolds DriveRealignment to transferNorthwick Park Triangle,Northwick Park Hospitaland Harrow College ofTechnology to HarrowRealignment to PiccadillyLine as far as BridgewaterRoadRealignment to Manor FarmRoadRealignment to transferAbbeyfields development,works in Elvedon Road andsite of goods depot inCoronation Road to Ealing.Realignment to northerncurtilage of Acton Lane.Realignment to transferfreightliner terminal toBrent.Brent'& boundary with Hammersmith and FulhamCollege ParkRealignment toWatford-Euston railwayBrent / s boundary with Kensington and ChelseaKensal GreenTunnelsRealignment to rear ofproperties on south sideof Harrow RoadBrent's boundary with WestminsterKensal Triangle/South KilburnRealignment to transferKensal Triangle andadjoining residentialarea to Westminster, andto eliminate defacementsin area of Malvern Road/Oxford Roadparas 73-85,map 1paras 86-100,map 2paras 102-108,maps 3-4paras 109-118,map 5paras 119-139,maps 5-7paras 142-152,maps 7-8paras 153-155,map 8paras 156-173,map 9