Sunday 12 November 2023

KILBURN SQUARE: Decision time (Chapter One) is finally here this Wednesday!


A guest post from the Chair of Kilburn Village Residents’ Association


WM reported three weeks ago  (  on the reaction of our local community to the (thankfully aborted) attempt to deal with this large and controversial scheme late in the evening, when the Committee clock was already into Overtime.  


This time, KS is the first Application on the Agenda (  ). A 6pm start is a bit early for many of our supporters to be there… but we’re pleased the Committee members will be fresh, and able to concentrate on the merits – and drawbacks – of the model in the Application as filed.


They will not be short of material to prompt questions:


·         They have the Officers’ original 61-page October 10 report, and a Supplementary report from the day before the October 18 meeting

·         But we found both of those to be less than balanced and objective

·         So we’ve provided them all with two detailed Response documents giving the very different perspective of the local community – on and off the estate

·         Both of those responses have now been posted as formal Objections on the Planning Portal (ref 22/3669)


The second one was linked in the last WM piece; but Martin has kindly embedded our more substantial initial response here: 



 Read it at your leisure – but here’s the message in a nutshell:


  • We’d support a scheme just replacing two daytime-use buildings (such as Blocks A and B in the version now proposed), in line with the Local Plan Site Allocation and the April 2020 Cabinet report approving a development partnership with Network Homes
  • But encroaching on the actual estate, removing valued green space and mature trees while adding more households (60% more vs 2019) to share the reduced communal space (like Blocks C and E) … is a Bridge Too Far


And here’s the Exec Summary

1.       This scheme is still too big, there are significant other policy breaches, and not all claims for flexibility are justified

2.       After a totally ineffective pre-engagement programme, the applicant is seeking to impose this version of the scheme despite the local community’s overwhelming call for a smaller, fairer model 

3.       The public interest benefit is tempered by affordability issues and the proposed tenure mix is unlikely to be deliverable

4.       Conclusion: we do not believe this scheme represents a fair balance, and urge the committee to decline approval


Two particular topics we feel are unacceptably dismissed by the Officers are the pre-engagement process and the Sandwood overshadowing by too-close-for comfort Block E 


The Officers dismissively say pre-engagement is not a statutory requirement, that there’s “a difference of opinion” about the effectiveness of what was done, and the Committee must determine the Application purely “on its merits”. If that were true, what was the point of mounting a superficially thorough pre-engagement effort? 


·         Brent regularly acknowledges the importance of consultation beyond legal requirements, and “taking the community with us”

·         We’ve often quoted senior Brent figures saying they “will not force homes on anyone” and want “a scheme that can work for everyone”

·         Brent has a detailed 2017 policy document spelling out the required process (NOT followed in the second stage consultation here)

·         The London Mayor specifically reminded the Applicant’s project team in 2021 he requires a process that is “…responsive and meaningful” – which we have demonstrated this was not

·         The project team told residents in 2021 that the engagement process was “one of three pillars” of the project evaluation

·         A senior Brent Officer was (with no irony) one of the judges for Best Community Engagement in the industry-wide “Pineapple” Awards


Overshadowing by Block E should be an Open and Shut case. 


The consultant’s report clearly says if BRE 209 guidance is strictly followed, it could be no more than 1-2 storeys.  The Officers’ report acknowledges that – and then tries to accept a series of the Applicant’s excuses for building it (five storeys) anyway


·         Irrelevant hypotheses about modelling the result without the Sandwood balconies, or if E were a mirror image of Sandwood’s East face (12 flats affected) – PURE SOPHISTRY!

·         Claims that living conditions in the rest of the Sandwood flats will still be fine (WRONG – residents already need lights switched on in the daytime)

·         Claims that the amount of acknowledged overshadowing across the whole scheme is modest – and acceptable given the “public interest” delivered; how is that fair to Sandwood residents?

·         Unsubstantiated statements that the guidance is largely intended for rural locations


The consultant’s report in the Application also talks of “site constraints” as a possible basis for lenience; but Block E is totally standalone – and removing it would not have any bearing on the rest of the scheme


To our minds, the Case against Block E is a sufficient valid Planning Objection to require that the Application be declined


Chapter Two


And then, if Permission is granted on Wednesday, there will have at some stage to be a Chapter Two – once a viable funding model is found and a modified tenure mix, with perhaps 30% of units for outright market sale, will need to be re-submitted to the Committee…   


If only the Applicant had had the moral courage to make that adjustment NOW – while the scheme is getting the fullest possible scrutiny!


Keith Anderson


Philip Grant said...

As the Chair of KVRA says, the case against the proposed Block E (which would be built on the main green open space on the Kilburn Square estate) should be sufficient to get this application refused, on good planning grounds.

It is such a pity that Brent's New Council Homes team, and the Cabinet members responsible for them, did not listen to the residents at least two years ago. They could have had a scheme with slightly fewer homes, that could have got planning consent unopposed, and have started construction in time to get around £10m in GLA funding from its 2016 - 2023 Affordable Homes Programme.

Anonymous said...

These words are very true as Brent missed out on additional funding because of pushing for the infill element of the proposals.
It’s actually Block C that is most detrimental for existing residents in removing their green space. Block E is quite small but squeezed into a space where infill had already taken place and will cause existing residents to lose their daylight and sunlight.

According to the upcoming budget the five priorities in Brent are:
Prosperity, Pride and Belonging
A Cleaner, Greener Future
Respect and Renewal in Brent
The Best Start In Life
A Healthier Brent

None of these apply to the existing Brent residents who live in Kilburn Square and will be greatly affected by the infill blocks C and E.

Where is the pride and sense of belonging when when you are overshadowed and have a road placed in front of your home and to the rear of your home to cater for new build properties that will be sold or passed over to the developers.

Where is the cleaner greener future when the Urban Greening Factor is being reduced to below the minimum required for a residential development and would only qualify as a commercial development.

Where is the Respect and Renewal when in order to reduce to cater for the two infill blocks all existing residents will be required to use the undercroft to park their vehicles. The undercroft has been disused for decades due to crime, drug taking and antisocial behaviour. It is not safe to use as a car park. Above it on the podium is a children’s nursery with play area and it’s not safe to have vehicles parked beneath it. There is also fire safety reasons for keeping it closed that include one fire exit with 21 steps that leads out to the standing area for the LFB and Dry Riser for the 17 storey tower, none of which has been put before the regulator/ HSE.

As for the best start in life the existing children’s play area is in the greenest and least polluted part of the estate. The children’s area will be moved over towards the corner with Brondesbury Road which can have levels of NO69. It’s also a diminished quality of space for the children in an area where there is a high road traffic accident rate including fatalities.

And finally a Healthier Brent which doesn’t seem to matter when part of Kilburn Square is in AQFA 30 and also high on the GLA map for Urban Heat Islands. This is not even being properly considered as under Constraints on the planning proposal it has been listed as Alperton. So nobody at planning needs to think about how what is already a densely populated residential estate beside Kilburn Town Centre AQFA can be stripped of all greenery to below the minimum requirement, having their light and sunlight removed, having roads placed outside their windows, and be forced into an undercroft that the police are against reopening. This will cause problems for existing residents and the surrounding neighbourhood in the long term and cause crime to increase and return to areas that the community has worked hard over the years to reduce and improve the neighbourhood.

Philip Grant said...

Anonymous (15 November at 12:11) is correct. I should have said that it was block C which the Council wants to build on the Kilburn Square estate green space.

My excuse for getting it wrong is that my mind was working alphabetically round the proposed new blocks, while Brent has labelled them in this order: A, B, E, C.

(What about D, you may ask? At one stage Brent proposed two small blocks of flats, C and D, on the green space. Then they changed it to one big block C.)

Anonymous said...

Yes you are correct Philip about blocks C and D being merged. This is probably because if you spent some time there looking at the proposal it was obvious that at least one if not both of those infill blocks should be dropped. So the answer was to merge them into one and hope that with a lot of spin they can get it past the Members. Here because one of the daytime use buildings (former mental health services) is to become an extra care facility this will help to get the infill part waived through. This extra care facility is actually in the AQFA so if you could send your elderly relatives there. If this was the Tokington AQFA there would have been more scrutiny and the residents might have been heard and the Air Quality Focus Area would have been addressed under Constraints and Policies complied with.