Guest post by Philip Grant in a personal capacity
Extract from the Affordable Housing Update Report to Brent’s Cabinet, 14 November 2022.
In a guest post last week, Kilburn Square – Brent must come clean on affordable housing!, I let “Wembley Matters” readers know about the Council’s failure to update Brent’s Planners about the change from London Affordable Rent (“LAR”) homes to shared ownership in its Kilburn Square planning application, 22/3669.
It appeared that they were trying to get their application approved (probably at Planning Committee on 15 March) on the basis that all 99 of the proposed “general needs” homes would be for LAR. A Brent Cabinet decision on 14 November 2022 made it likely that around 40 of those homes would be “converted” to shared ownership. On those “true” figures, the application would be likely to fail Brent’s Local Plan affordable housing policy BH5.
In comments below that article, I kept readers up to date with correspondence between myself and Head of Affordable Housing and Brent’s Lead Member for Housing. However, Martin has agreed that the latest exchange of emails is sufficiently important to deserve a guest post of its own.
I have previously drawn the attention of Ms Baines and Cllr. Knight to a letter I had published in the “Brent & Kilburn Times” on 19 January, calling on the Council for honesty over its Kilburn Square affordable housing proposals:
My letter published in the “Brent & Kilburn Times” on 19 January 2023,
On 9 February, after several brief exchanges of emails, I had written to Brent’s Head of Affordable Housing (with copy to the Cabinet Lead Member for Housing) saying:
‘Please confirm that you have now instructed JLL to submit a revised Affordable Housing Statement for Kilburn Square (application 22/3669), giving the actual and updated tenure split for the proposed 139 homes, including those you intend to "convert" from LAR to shared ownership.
If you cannot give that confirmation, please explain why, and what you intend to do over the tenure split on this scheme. Thank you.’
This is the full text of the reply I received on 10 February:
I have previously confirmed we are still in a live procurement, this means we have not confirmed the market costs of this build and do therefore not know if a change in tenure would even be required.
I can assure you as head of affordable housing and partnerships my role is to deliver as many social homes as possible.
I have to admit that I found the claim at the end of the first paragraph difficult to believe! If I had replied straight away, I’d probably have used words I might later regret. So I waited several days, and this is the full text of the reply I sent to Brent’s Head of Affordable Housing on 14 February:
‘This is an Open Email
Dear Ms Baines,
Thank you for your email of 10 February.
I was pleased to read of your determination 'to deliver as many social homes as possible.' I hope that by 'social homes' you mean homes at Social Rent level, as strongly recommended by the Brent Poverty Commission report in 2020, or at least the other form of "genuinely affordable" Council homes, at London Affordable Rent ("LAR") level.
I was surprised to read that you 'do not know if a change in tenure would even be required', for the 99 "general needs" homes proposed for Kilburn Square in your planning application 22/3669.
That is entirely the opposite of what was set out in the "Update on the supply of New Affordable Homes" report ("the Report") to the 14 November 2022 Cabinet meeting, for which you were the first named Contact Officer.
At para. 1.1 of the Report it stated:
'This report specifically outlines viability gaps across 10 schemes, which are not yet in contract and sets out options for cross subsidisation where possible for the Council’s consideration.'
Paragraphs 4.17 to 4.30 of the Report dealt with 10 New Council Homes Programme ("NCHP") schemes which were not yet in contract, with para. 4.18 stating:
'To better understand the Council’s options, officers have reviewed all 10 of these schemes to explore possible options for making schemes viable. This in real terms means the conversion of some social rented homes to shared ownership or other tenures in order to cross subsidise the scheme.'
Four of the ten schemes were identified from this review as being suitable for "conversion", and Kilburn Square was one of the four. From the information supplied in the Report, it appears that details of the review's evidence and conclusions, from its assessment of the ten schemes, were set out in an "exempt" appendix to the Report, which was made available to Cabinet members and some Officers, but not to the public.
Para. 4.19 of the Report gives that information, as follows:
'Appendix 2 sets out a summary table of this assessment and overall, there are four schemes which allow for conversion of some homes (50% or under in keeping with planning requirements) and result in a positive net present value which mean they are financially viable.
These schemes are:
· Kilburn Square
· Windmill Court
· Seymour Court
· Rokesby Place '
Specific details of the number of homes involved in those four schemes, and the total number to be "converted", were stated in para. 4.20:
'Across these four schemes, there were 204 affordable homes due for delivery either at Social Rent or London Affordable Rent. This conversion would see this number reduce to 145 homes for London Affordable Rent and 59 homes for Shared Ownership.'
Paragraphs 4.22 and 4.23 appear to make clear that only two homes from the small schemes at Seymour Court and Rokesby Place could be "converted" from LAR to shared ownership. That would leave 57 of the LAR homes proposed for Kilburn Square and Windmill Court to be converted to shared ownership, according to the November 2022 Report.
Given that detailed information, from just three months ago, it is difficult to understand how you can now claim that Officers involved in the NCHP 'do not know if a change in tenure would even be required' for Kilburn Square (which has roughly twice the number of proposed LAR homes than those approved for Windmill Court).
As the Report was signed off by the Corporate Director, Resident Services, and recommended (and received) greater delegated powers for him in respect of the tenure split for NCHP schemes, I am copying this email to him, and to the Council Leader (as well as to the Cabinet Member for Housing).
Mr Gadsdon may wish to explain to the Council Leader (and Cllr. Muhammed Butt may wish to receive that explanation) what has changed so much in the past three months to make the previously unviable Kilburn Square scheme, where perhaps around 40 LAR homes would need to be "converted" to shared ownership, now potentially viable, so that no such "conversion" might be needed.
I am sure that a number of other councillors, and interested local residents, would like that explanation to be made public.
As things currently stand, the apparent difference in the situation over the affordable housing tenure split at Kilburn Square, between that set out in the Report in November 2022 and that suggested in your email of 10 February, could be seen as an exaggeration of the viability problem last November, in order to mislead elected councillors into transferring some of their powers to Senior Officers. Some clarification is surely needed!
Has there genuinely been a massive change in the viability of Brent’s proposed Kilburn Square housing scheme in the past three months? Was the “viability gap” on New Council Homes schemes overstated by Council Officers in their report to Cabinet in November 2022?
Or has the true position over the tenure split of the proposed homes at Kilburn Square not been disclosed in the email sent to me on 10 February, in an attempt to maintain an unfair advantage over affordable housing when the Council’s planning application is considered? You can decide which version you believe!