Sudbury Labour on its blog has given an account of theor contribution to tonight's Planning Committee decision LINK.
After strong objections from Sudbury Councillors, Brent Council’s planning committee today voted 4-3 against the Pocket Living application. A vote to refer this back to Council Officers and the applicants was then passed by a vote of 5-2. This follows strong objections from local residents and Sudbury Councillors.
For over a year, Sudbury Cllrs Tom Stephens and Mary Daly have provided consistent opposition this proposal, submitting several written objections to the development (all of which are noted in the Committee Report) and supporting residents to carry out their own survey of car park usage. We also spoke out against the application at today’s meeting. You can watch our speeches on the Brent Council website, and a note of our speeches is also copied below (check against delivery).
Councillor Saqib Butt, as a Member of the Planning Committee, remained neutral and objective throughout, but after a fair hearing of the concerns raised decided to vote against both the application and the decision to refer it back to Officers and the developer.
The main reason Councillors gave in voting against the proposal was because it was contrary to the planning policy of both the Local Plan and the London Plan, both of which stress the need for genuinely affordable family housing units to meet the severe need for housing in London. The provision of 52 1-bedroom units, which only just meet the technical definition of “affordability” without being genuinely affordable, will simply not meet this severe need.
We too felt this was by far the strongest grounds for objection, and gave Councillors a clear material reason to reject this proposal – hence why this featured very strongly in our objections. But it was by no means the only concern we had. Between us, we also covered a range of other issues such as the severe lack of disabled parking space, the lack of amenity space for residents and the impact the developement could have on parking pressures for residents. All of these were highlighted in our objections.
We were glad to see that after a fair hearing, the majority of Councillors in the Planning Committee shared these concerns, and declined to offer the application their approval. We will continue, as we have always done, to fight for Sudbury residents on this issue and to closely scrutinise any future applications which come forward.
There are others and I can talk about these in response to questions.
It is simply this: the affordability and housing mix in this proposal is a direct contravention of our Local Plan and the London Plan. None of the grounds the Committee have been given to accept the proposal in spite of this hold water, as I will explain later.
***
I wish to acknowledge at the outset the acute housing crisis facing this country, with Brent the least affordable borough. All of us see this clearly in our surgeries. People who need stable, genuinely affordable homes for themselves, their families, and their children.
But it is exactly these needs which I want to emphasise here in my objection: the needs of families, with children, without a stable home.
***
As Policy CP21 of our own borough’s local plan acknowledges, this acute need can only be addressed through the provision of genuinely affordable family housing units. It requires that new housing provides, and I quote:[1]
“[F]amily sized accommodation … capable of providing three or more bedrooms … [on] sites providing 10 or more homes.”
Planning policy also contains similarly clear provisions on affordability, with the London Plan (Policy H6A) requiring 30% of affordable homes to be either London Affordable Rent or Social Rent.[2]
This need cannot be met through 52 one-bedroom units which only just meet the technical definition of affordability. Indeed this is expressly acknowledged in numerous parts of the committee report you will have all read:
In all good conscience, I cannot accept the grounds that have been proposed for passing this application, in spite of this direct contravention of our Planning Policy…
***
I accept that if no viable alternative in keeping with our Planning Policy was available, that could offer grounds to accept. But paragraphs 15 and 16 of the committee report clearly state that a viable alternative, in keeping with our planning policy, could be provided on this site.[6]
***
The committee report notes the unmet need for 1-bedroom intermediate housing in our borough.
But this isn’t grounds for ignoring our own Local Plan, Paragraph 5.94 of which expressly argues against the then-Mayor changing the social / intermediate housing ratio.[7]
If we do not think it is addressed in our Local Plan, the proper process would be to address this as a policy in our new Local Plan – and not by simply deciding on the hoof to contravene our own planning policy.
But even more fundamentally than this, the demand for intermediate housing can also be met by freeing-up existing overcrowded smaller housing in a way which is entirely in keeping with our Local Plan: providing suitable, new build family units, at genuinely affordable rates.
***
In conclusion, I wish to stress that there are many other grounds for the Committee to challenge the developers on this application. And I’m sure these will be addressed by other speakers:
When I first objected to this development almost a year ago, I assumed that the developer would take steps to address this. I’m disappointed to see that this hasn’t happened.
In the absence of clear reasons to accept such a contravention, and with the grounds for doing this discounted, the Committee is left with just one option: to reject the proposal put forward today.
[1] Brent Council, Local Plan: Core Strategy, Policy CP21, page 78. NB Objective 7 (p21) also sets a goal of “ensuring that at least 25% of all new homes built in the borough are family sized (3 bed or more) and 50% (approx.) are affordable.”
[2] Brent Council, Committee Report 19/1241, 6 May 2020, page 14
[3] Brent Council, Committee Report 19/1241, 6 May 2020, page 1
[4] Brent Council, Committee Report 19/1241, 6 May 2020, page 6
[5] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 14, page 15
[6] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 15 and 16, page 16
[7] Brent Council, Local Plan: Core Strategy, Policy CP21, paragraph 5.94, page 78.
[8] This is because TfL asks that “a parking design and management plan to be submitted for approval prior to occupation of any units, in order to ensure at least one disabled space is secured for occupiers of the flats.” See Brent Council, Committee Report 19/1241, 6 May 2020, page 11
[9] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 92, page 24
[10] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 89, page 24
Para 1 of the report speaks of getting rid of an 84 space underused car park car park and replacing it with two residential blocks
This statement is factually incorrect in the summer of 2019 TFL fenced off the rear end of the site and reduced the size of the car park to 66 spaces this is important because the very sketchy information the developer provided is as a consequence is incorrect.
Para 87 describes a survey undertaken by the applicant claiming that there was a 30% use of the park based on the incorrect number of spaces.
A survey undertaken by members and residents found a different pattern of use. This was reported to the council but not included im the report to members of the planning committee. Over three weeks during the morning and afternoon members found a consistent 54% occupancy of the 66 space car park. Members observed use was predominantly by commuters. Morning users were different from afternoon users so the car park is not as described underused.
There is no evidence that the statuary bodies TFL or Brent Council undertook any activity to establish use of the car park in contravention of legal equalities obligation.
Parking
Para 97 advises that DPM 12 requires that all overspill be safely accommodated on street
Policy BT2 that developments will be supported where it does not add to on street parking
Policy 90 acknowledges that the nearest Brent streets are heavily parked but claims that Ealing streets can absorb some on street parking.
As stated above policy is in place to prevent this level of pressure on existing communities.
Amenity
Para 77 advises the policy DMP19 and emerging policy BH 13 that all new dwelling be required to have external private amenity space this is expected to be 20 sqm of private outdoor space for 1d-2 person dwellings. Based on the policy 1050sqm of space is required Only 11 of the 52 proposed units have outdoor amenity space falling short by 913 sqm.
Para 79 suggests that this cam be mitigated by communal amenity space 476 sqm of amenity space in the communal courtyard. However this space appears to have two uses it is also intended to be a turning space for large vehicles there are two descriptions of this space para 80 “ a communal amenity space” and “ a turning space for servicing buildings
Para 102 describes the same space as “a turning facility has been incorporated into the lauout between the two proposed blocks to allow refuse vehicles emergency vehicles so that they are not required to reverse long distances”
In Para there are contrary statements about the courtyard/turning point “ para 80 states “ the communal courtyard has been improved it would be usable” whereas Para 102 states “ officers recommend a condition of the surfacing of the turning point” it is clear is that the development is marginally short of private or even communal amenity space requirements it is so unacceptably short as to warrant refusal.
After strong objections from Sudbury Councillors, Brent Council’s planning committee today voted 4-3 against the Pocket Living application. A vote to refer this back to Council Officers and the applicants was then passed by a vote of 5-2. This follows strong objections from local residents and Sudbury Councillors.
For over a year, Sudbury Cllrs Tom Stephens and Mary Daly have provided consistent opposition this proposal, submitting several written objections to the development (all of which are noted in the Committee Report) and supporting residents to carry out their own survey of car park usage. We also spoke out against the application at today’s meeting. You can watch our speeches on the Brent Council website, and a note of our speeches is also copied below (check against delivery).
Councillor Saqib Butt, as a Member of the Planning Committee, remained neutral and objective throughout, but after a fair hearing of the concerns raised decided to vote against both the application and the decision to refer it back to Officers and the developer.
The main reason Councillors gave in voting against the proposal was because it was contrary to the planning policy of both the Local Plan and the London Plan, both of which stress the need for genuinely affordable family housing units to meet the severe need for housing in London. The provision of 52 1-bedroom units, which only just meet the technical definition of “affordability” without being genuinely affordable, will simply not meet this severe need.
We too felt this was by far the strongest grounds for objection, and gave Councillors a clear material reason to reject this proposal – hence why this featured very strongly in our objections. But it was by no means the only concern we had. Between us, we also covered a range of other issues such as the severe lack of disabled parking space, the lack of amenity space for residents and the impact the developement could have on parking pressures for residents. All of these were highlighted in our objections.
We were glad to see that after a fair hearing, the majority of Councillors in the Planning Committee shared these concerns, and declined to offer the application their approval. We will continue, as we have always done, to fight for Sudbury residents on this issue and to closely scrutinise any future applications which come forward.
Speech opposing the development from Cllr Thomas Stephens
Many other objectors speaking today have already given powerful reasons for rejecting this proposal. But in my representation, I wish to focus on the one issue in particular, which I feel which the Committee by far the strongest grounds for refusal.There are others and I can talk about these in response to questions.
It is simply this: the affordability and housing mix in this proposal is a direct contravention of our Local Plan and the London Plan. None of the grounds the Committee have been given to accept the proposal in spite of this hold water, as I will explain later.
***
I wish to acknowledge at the outset the acute housing crisis facing this country, with Brent the least affordable borough. All of us see this clearly in our surgeries. People who need stable, genuinely affordable homes for themselves, their families, and their children.
But it is exactly these needs which I want to emphasise here in my objection: the needs of families, with children, without a stable home.
***
As Policy CP21 of our own borough’s local plan acknowledges, this acute need can only be addressed through the provision of genuinely affordable family housing units. It requires that new housing provides, and I quote:[1]
“[F]amily sized accommodation … capable of providing three or more bedrooms … [on] sites providing 10 or more homes.”
Planning policy also contains similarly clear provisions on affordability, with the London Plan (Policy H6A) requiring 30% of affordable homes to be either London Affordable Rent or Social Rent.[2]
This need cannot be met through 52 one-bedroom units which only just meet the technical definition of affordability. Indeed this is expressly acknowledged in numerous parts of the committee report you will have all read:
- It is acknowledged on the front cover, where it states the development is a “departure from policy CP21 of Brent’s local plan.”[3]
- It is acknowledged on page 6, where it states that the housing mix, “does not fully accord with Brent and London Plan policy targets.”[4]
- And it is acknowledged in paragraph 14, page 15, where it states “the scheme would be contrary to Policy DMP15(b) of the Local Plan, and both Policy 3.11 and emerging Policy H6 of the London Plan as no flats would be offered at a social or affordable rate.”[5]
In all good conscience, I cannot accept the grounds that have been proposed for passing this application, in spite of this direct contravention of our Planning Policy…
***
I accept that if no viable alternative in keeping with our Planning Policy was available, that could offer grounds to accept. But paragraphs 15 and 16 of the committee report clearly state that a viable alternative, in keeping with our planning policy, could be provided on this site.[6]
***
The committee report notes the unmet need for 1-bedroom intermediate housing in our borough.
But this isn’t grounds for ignoring our own Local Plan, Paragraph 5.94 of which expressly argues against the then-Mayor changing the social / intermediate housing ratio.[7]
If we do not think it is addressed in our Local Plan, the proper process would be to address this as a policy in our new Local Plan – and not by simply deciding on the hoof to contravene our own planning policy.
But even more fundamentally than this, the demand for intermediate housing can also be met by freeing-up existing overcrowded smaller housing in a way which is entirely in keeping with our Local Plan: providing suitable, new build family units, at genuinely affordable rates.
***
In conclusion, I wish to stress that there are many other grounds for the Committee to challenge the developers on this application. And I’m sure these will be addressed by other speakers:
- The issue of disabled parking space for commuters still isn’t resolved in this proposal. In fact TfL’s planning condition could mean there are just two disabled spaces for general public use, and not three as stated.[8]
- The availability of parking remains a concern. And there is even an admission in paragraphs 89 and 92 of the report that 38 cars and many blue badge holders could be displaced to residential streets – including streets already in a CPZ outside of CPZ hours.[9] [10]
- There is a serious lack of amenity space, to the tune of 913 square metres
- And concerns have been raised about running this Committee online, I’ve asked for further info on this and I’d be happy to discuss in questions
When I first objected to this development almost a year ago, I assumed that the developer would take steps to address this. I’m disappointed to see that this hasn’t happened.
In the absence of clear reasons to accept such a contravention, and with the grounds for doing this discounted, the Committee is left with just one option: to reject the proposal put forward today.
[1] Brent Council, Local Plan: Core Strategy, Policy CP21, page 78. NB Objective 7 (p21) also sets a goal of “ensuring that at least 25% of all new homes built in the borough are family sized (3 bed or more) and 50% (approx.) are affordable.”
[2] Brent Council, Committee Report 19/1241, 6 May 2020, page 14
[3] Brent Council, Committee Report 19/1241, 6 May 2020, page 1
[4] Brent Council, Committee Report 19/1241, 6 May 2020, page 6
[5] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 14, page 15
[6] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 15 and 16, page 16
[7] Brent Council, Local Plan: Core Strategy, Policy CP21, paragraph 5.94, page 78.
[8] This is because TfL asks that “a parking design and management plan to be submitted for approval prior to occupation of any units, in order to ensure at least one disabled space is secured for occupiers of the flats.” See Brent Council, Committee Report 19/1241, 6 May 2020, page 11
[9] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 92, page 24
[10] Brent Council, Committee Report 19/1241, 6 May 2020, paragraph 89, page 24
Speech opposing the development from Cllr Mary Daly
Para 1 of the report speaks of getting rid of an 84 space underused car park car park and replacing it with two residential blocks
This statement is factually incorrect in the summer of 2019 TFL fenced off the rear end of the site and reduced the size of the car park to 66 spaces this is important because the very sketchy information the developer provided is as a consequence is incorrect.
Para 87 describes a survey undertaken by the applicant claiming that there was a 30% use of the park based on the incorrect number of spaces.
A survey undertaken by members and residents found a different pattern of use. This was reported to the council but not included im the report to members of the planning committee. Over three weeks during the morning and afternoon members found a consistent 54% occupancy of the 66 space car park. Members observed use was predominantly by commuters. Morning users were different from afternoon users so the car park is not as described underused.
There is no evidence that the statuary bodies TFL or Brent Council undertook any activity to establish use of the car park in contravention of legal equalities obligation.
Parking
Para 97 advises that DPM 12 requires that all overspill be safely accommodated on street
Policy BT2 that developments will be supported where it does not add to on street parking
Policy 90 acknowledges that the nearest Brent streets are heavily parked but claims that Ealing streets can absorb some on street parking.
- With this in mind it is worth looking at that they will absorb.
- The site is so tight that even the one disabled space a policy requirement for disabled future disabled residents is proposed to be put on the highway.
- If future disabled commuters need additional spaces it is proposed they are put on the highway
- The report advises that Para 96 that the parking allowance for such a development is 39 spaces. Because they cannot be provided it is permit free but not future vehicle owner free. It has nto been estimated how many future professional higher income residents will own a vehicle clearly they will compete with local residents for parking when CPZ are not in operation.
- Because there has been no comprehensive survey of commuter parking at the car park it is impossible to know how many commuters use the car park for sure certainly it is considerably more than that suggested by the applicant.
- Service vehicles for the proposed development including online deliveries, maintenance vehicles, displaced TFL staff TFL staff using the yard to the back of the site.
As stated above policy is in place to prevent this level of pressure on existing communities.
Amenity
Para 77 advises the policy DMP19 and emerging policy BH 13 that all new dwelling be required to have external private amenity space this is expected to be 20 sqm of private outdoor space for 1d-2 person dwellings. Based on the policy 1050sqm of space is required Only 11 of the 52 proposed units have outdoor amenity space falling short by 913 sqm.
Para 79 suggests that this cam be mitigated by communal amenity space 476 sqm of amenity space in the communal courtyard. However this space appears to have two uses it is also intended to be a turning space for large vehicles there are two descriptions of this space para 80 “ a communal amenity space” and “ a turning space for servicing buildings
Para 102 describes the same space as “a turning facility has been incorporated into the lauout between the two proposed blocks to allow refuse vehicles emergency vehicles so that they are not required to reverse long distances”
In Para there are contrary statements about the courtyard/turning point “ para 80 states “ the communal courtyard has been improved it would be usable” whereas Para 102 states “ officers recommend a condition of the surfacing of the turning point” it is clear is that the development is marginally short of private or even communal amenity space requirements it is so unacceptably short as to warrant refusal.
