Does Brent's Development Management Plan adequately address residents' concerns?

Thusday's Planning Committee LINK is rather different than usual because it addresses the context within which planning decisions are made and reflects members' concerns over some of the wider issues to do with regeneration, development and provision of affordable housing and making reference to such matters as the proliferation of betting shops and takeaways and the protection of pubs. This is the first in a number of blogs on the issues addressed.

The first item on the agenda is the Brent Development Management Policies Local Plan LINK which summarises reponses to the consultation. The Draft Plan dated August 2015 can be found HERE :

.        Summary of Issues Raised 


.         

.        3.8  Length of the document: A number of respondents identified that the document was too long. This has been addressed through significant amendment, removing that which is dealt with sufficiently in NPPF, NPPG and London Plan and its associated SPGs 


.        3.9  Town centres: Policies to prevent an overconcentration of takeaways, pay day loan shops, betting shop and Shish Cafes and takeaways and shisha cafes in proximity to schools received significant support from residents. However, Planware objected to the proposal to limit the number and location of takeaways on the basis they do not feel there is adequate justification for this policy. These policies have essentially been retained largely unchanged as it is considered evidence supports their retention. 




.        3.10  Built environment: tall buildings, heritage policies and general comment about development trends within Brent affecting the built environment quality, e.g. loss of front gardens. Tall buildings are considered to have effective policy in the London Plan. The heritage policies have been rationalised to make them more focused and address issues raised by English Heritage. Brent specific policies, e.g. retention of 50% of front gardens has been retained, with an emphasis on providing additional locally specific guidance, e.g. conservation area appraisals and design guides to identify more clearly features of heritage significance and appropriate development responses. 


.        3.11  Open Space: Comments related to the consistency of the policy with the NPPF. The Environment Agency highlighted reference to several Plans related to river catchments and their improvement. The Canal and Rivers Trust sought a policy on supporting residential moorings. The policies on open space essentially duplicated NPPF and London Plan and have been removed. Reference to the Environment Agency recommended documents has been made. Given the likely limited applications for residential moorings, it is felt that this is best addressed through other policies in the Plan. 


.                 3.12  Environmental Protection: The Environment Agency sought additional reference to Preliminary Risk Assessments in relation to contaminated land. Thames Water sought a policy on water and sewage infrastructure capacity. Most of the policy in this section added nothing locally distinctive for  Brent being adequately addressed in NPPF and London Plan. Consequently the policies have been removed, whilst reference to material required to support applications and locally specific studies to assist applicants in tailoring their responses to sites have been identified.

.        3.13  Sustainability: the Home Builders Federation questioned the approach on appropriateness of local allowable solutions. SEGRO, Shurgard, Macaire Enterprises, Home Builders Federation and Quintain raised concerns in relation to the impact of the policy Renewables and Decentralised Energy could have on scheme viability and how this will be considered. Greater London Authority (GLA) considered little emphasis had been given to energy efficiency. London Plan policy has evolved significantly in this area in relation to allowable solutions and with the publication of the Mayor’s Sustainability SPG. It is considered that policies in the London Plan and associated SPGs are appropriate to address the policies that were in this section. Reference to appropriate local documents that assist developers in making Brent specific solutions have been made. 


.        3.14  Transport: Brent Cyclists supported parts of the cycling policy, but wanted greater commitment to segregation of cycle routes. GLA wanted greater reference to cycling infrastructure such as the superhighways. GLA questioned the Council’s approach to the North Circular. GLA and Quintain raised questions about the Council’s parking standards and servicing requirements. Wembley wanted greater acknowledgement of event days traffic management in developments. In relation to freight GLA wanted greater reference to Transport for London (TfL) documents. Walking and cycling is considered to be sufficiently covered in the London Plan and as such policy has been refined to address the Brent specific part of the London Ring. Parking and servicing standards have been amended in relation to comments made. Reference has been made to TfL freight and construction management documents. Wembley issues are essentially covered in the Wembley Area Action Plan. 


.        3.15  Employment: Costco, Segro and Shurgard objected to policy seeking 10% of floorspace in new commercial schemes on strategic employment sites to be affordable workspace for SMEs. The policy has been deleted. Affordable workspace will be sought through the redevelopment of Local Employment Sites, where the provision of uses such as residential can help subsidise the provision of affordable workspace. A significant amendment to policy is that the Council is seeking to allow release some SIL and LSIS where the site is poor quality employment land and the development would meet strategic needs, e.g. minimum 50% affordable housing or significant social infrastructure needs such as additional secondary schools. 


.        3.16  Housing: With regards to Affordable Housing local people and groups raised concerns about amount and price, marketing of housing and house prices in general. GLA suggested wording for the policy around seeking the maximum provision. They questioned the 70/30 rented/intermediate split and rent setting for affordable rents. McCaire Enterprises questioned consistency with national policy on viability reassessment. The Council’s property section wanted a flexible approach to on-site provision. Quintain wanted evidence  that the 50% had been viability tested. In relation to Maximising Housing Supply McCaire Developments considered that the policy did not go far enough to ensure Brent’s new target would be met. On Conversions greater clarity was sought on the 130 sq.m. size requirement. On Housing Quality and Standards Quintain and McCaire Developments thought the on-site amenity standards were unjustified. Hostels and HiMOs there were concerns that a separate policy was required. Unite raised concerns about the perceived negative approach to provision of student accommodation, whilst the GLA pointed out need for greater consistency with London Plan. Dr Maguire raised concerns with the Council’s approach to provision of Travellers.

.        3.17  The 50% target is already set out in the Core Strategy. There is sufficient evidence to justify the 70/30 mix from a needs and viability perspective. Reference to rent setting has been removed. On viability assessment, given rapid price changes and a desire to get sites developed the Council has amended its position. It will seek reviews for significant developments of 200 dwellings that will take more than 18 months to start, or where a phased approach to delivery will be undertaken. On site provision of affordable housing is preferred but a flexible approach for strategic landowners on a site by site basis can be taken forward if there is clarity at the beginning about what affordable housing will be achieved and where and this is consistent with other policies, e.g. mixed and balanced communities. 


.        3.18  DMP38 has been removed, this is sufficiently covered in London Plan policy and Housing SPG prior to a Brent Core Strategy/Site Allocations review. The conversions policy has been amended to deal with potential loss of family housing where that accommodation can be shown to be unlikely to ever be to a standard to accommodate a family. The size criteria for conversion is considered justified based on London Plan housing sizes. The amenity standards are considered justified as Brent has been following this policy through for more than 10 years. The policies on the variety of shared/institutional residential accommodation have been amalgamated. The policy justification has been amended to more fully address the issues raised by the GLA and gives greater emphasis to the needs student housing can meet and its regeneration benefits in creating mixed and balanced communities. The approach to travellers is considered proportionate as national policy provides a presumption in favour due to the lack of a 5 year supply of pitches to meet needs. 


.        3.19  Social Infrastructure: A significant number of comments on this chapter related to the need for a specific pub protection policy. Mayor’s Office for Police And Crime commented that policy DMP44 is not consistent with London Plan. A pub protection policy has been introduced into the DMP, whilst general social infrastructure is addressed sufficiently well in the London Plan. In relation to the Mayor’s office, the supporting text makes reference to loss of community facilities being acceptable where providers have an agreed programme of alternative social infrastructure .