BE AWARE: Brent Local Plan Review coming up - this will affect your community, your area and perhaps even your home

 

Image from the 2019-2041 Brent Local Plan

Admittedly a consultation about the Brent Local Plan isn't likely to cause a huge amount of excitement but lack of engagement with an upcoming Review that will be discussed at next Tuesday's Resources and Public Realm Scrutiny Committee could cost residents dear.

The 2019-2041 Plan, spearheaded by Cllr Shama Tatler, shaped planning decisions based on support for tall buildings, densification, intensification corridors and the designation of eight Growth Areas. This is transforming our borough. 

The proposal is for a Full Review covering all areas of the Plan rather than a few areas as some other councils are undertaking. LINK  Bold emphasis is mine.

The current Plan is immense and contains proposals for sites across the borough but current conditions and changes in planning laws mean a review is necessary:

     The principal rationale for review is to embrace the need to plan longer term to meet the needs of a growing population to at least 2046 and possibly beyond. The largest priority is to ensure housing delivery can be sustained at high levels in the future. This requires identifying sites well in advance of when they are needed. Due to the complicated nature of future opportunities (the need to parcel up sites that currently include individual homes) this could well be longer than was needed in the past. Large single ownership sites such as Grand Union in Alperton are getting rarer. Sites are more likely to be like 1-22 Brook Avenue allocated in 2011, having publicly been identified 3 years earlier in the draft plan; this only had a comprehensive planning application submitted in 2023 (15 years after first being identified) and it is understood that full site ownership has still not yet been achieved by the applicant. 

Brook Avenue is the road next to Wembley Park station where the developer pressured owners of the suburban houses to sell up to enable a developer to build tower blocks. If they failed to agree the Council would consider compulsory purchase to enable the development to go ahead – it was in the Local Plan. It appears one at east owner is holding out.

 

The paper going to the Committee implies predicts there may be more such proposals:

 

To date much of the population of Brent has accepted the ambitious levels of development that the last Local Plan promoted. The next Local Plan may wellhave to deal with accommodating more development amongst suburban housing, most of which will be in good condition and privately owner occupied.

As well as potentially affecting more people’s homes, it could more likely to result in more areas having more substantial changes in character compared to currently. This may well increase the amount of objection and challenge to the plan from Brent residents or community groups. This could again slow down the plan’s delivery, requiring further levels of engagement and revision to plancontent or policy direction.

 

You have been warned. Look up your area/address on the current Local Plan and you may well be surprised/shocked by what you find. LINK

 

Another reason for review is that the Council has been unable to meet its targets due to the current economic and labour supply situation, and new safety regulations:

 

Brent’s delivery [of housing] prior to 23/24 was excellent. In the 3 financial years to 22/23 Brent delivered the equivalent of 8136 net additional dwellings Ministry of Housing, Communities and Local Government (MHCLG) official figures. This represented 131% of its target against the Housing Delivery Test (HDT). Delivery in 23/24 was however very weak at 656 net dwellings. This is not yet reflected in the latest MHCLG HDT figures but represents only 28% of the 2,325 annual minimum target. Completions for 24/25 have not been finalised but are likely to be well below the target. Lack of planning permissions are not what is holding back delivery. The latest GLA datahub information indicates that as of 31st March 2024, 16,985 dwellings had permission but had not been completed. It is other factors including viability, construction capacity, the contraction of the private sales market, investor caution and building safety regulator sign-off (for buildings 6 or more storeys) that are having the biggest slowdown impact.

  

We know that a higher proportion of private housing is likely on South Kilburn due to these factors and that there is a slowdown in the already limited building of new council homes – the only truly affordable option for most Brent residents. Remember that the definition of ‘affordable’ is often 80% of the market rate and these targets are not being met:

 

In respect of other Local Plan housing objectives, the amount/ percentage of affordable housing, when compared to overall housing delivery, is below the 35% London Plan fast track route target and significantly below the 50% strategic Local Plan target. In 23/24 19.7% of the homes that were completed in the borough were affordable, and 26.7% of the homes that were approved that year were affordable. For 23/24 homes delivered which were subject to an affordable housing S106 obligation, the percentage delivered was 44%.

 

Given the number of families on the Council list, and the Council’s policy to persuade them to move into private accommodation outside of the borough, the policy for more family-sized homes has also failed:

 

The Local Plan has a target of 1 in every new 4 (25%) homes requiring permission being 3 or more bedrooms. In 23/24 delivery was below this at 12.2%. Delivery of this target is impacted by small scale schemes that might be for three of less dwellings, thus not required to provide a three-bed home; on larger schemes, there is often a trade-off reflecting the viability considerations. 3+ bedroom schemes do not attain the same values (per square metre) as properties with 1 or 2 bedrooms, thus requiring the 25% affects development viability and can reduce the number of affordable homes that can be delivered. 

 

If there are to be more smaller developments in future these also have their drawbacks:

 

For minor developments, the range of policies that apply are fewer, in part reflective of the Government’s position that to support the small builders’ sector there should be lower costs/ simpler processes. In addition, many of the homes in this sector in Brent are delivered via conversions of existing homes (e.g. conversions of houses to flats). These factors can bring compromises that might not be applicable in larger schemes, e.g. no lifts, inability to provide outdoor amenity space for upper floor dwellings, encouragement to attain higher energy efficiency/ renewables, rather than requirement, etc.

Although officers try to reassure, there are also issues when builders try to reduce costs:

 

The Council ensures that the quality of the affordable homes is consistent with that delivered for private homes. Applicants know that the Council will not accept obvious lower standards or development that is not tenure blind particularly in terms of outward appearance and location. There however, may be subtle differences, (e.g. communal facilities such as size of lobbies, corridor finishes, incorporation of soft furnishings, gym facilities) as registered providers seek to reduce on-going service charges to occupants.

 

Officers outline other areas of the Local Plan where it is likely that changes will be needed;

In respect of the topic area policies sections changes are likely to be required to reflect recent and proposed trends, e.g. during and post Covid the move towards on-line trading will mean some retail uses are diminishing, meaning town centres are at greater risk of contraction, whilst hospitality uses are also struggling, with existing numbers of pubs proving difficult to maintain as viable. The Council will need to review its viability tests/ periods of vacancy that are acceptable to ensure its not unnecessarily maintaining property vacancies. Review of the borough’s green spaces indicates an inconsistency in categorisation and levels of protection provided for those not identified. These will need a detailed review and amended policy. The affordable workspace policy will need review to apply it to a lower size threshold of development. It was subject to change during the last examination by the Inspectors as it received objections, which the Council was not allowed to address properly due to submission of additional viability being inadmissible. The amount and concentration of student housing has also become a more pronounced concern for councillors and the Plan will consider how to best address this, balancing up London’s strategic student housing needs against Brent’s housing priorities including very high affordable housing needs.