GLA statement regarding fire safety and tall buildings - second staircases

 This statement will have an impact on high-rise developments in the pipeline across London.

You will no doubt be aware that the government have published their consultation document shortly before the Christmas holiday on proposed changes to the Building Regulations, which includes mandatory second staircases in buildings over 30 metres in height. LINK

The Mayor has consistently expressed concerns that the fire safety requirements in the national Building Regulations are not fit for purpose, so the proposed strengthened requirements and clear direction at the national level are strongly supported. This consultation envisages a very short transition period with new developments being encouraged to prepare for this change now. In light of this – and given the requirements of London Plan policy D12 that all developments should achieve the highest standards of fire safety – we are clear that, with immediate effect, all planning applications which involve residential buildings over 30 metres in height will need to be designed to provide two staircases before they are referred to us at Stage 2 for the Mayor’s decision. We recognise that the earlier statement by the NFCC referenced over 18 metres but, to be clear, our requirement for two staircases applies to residential buildings over 30m in line with the national position.

 

The GLA’s Planning team is working with the Boroughs to progress schemes which are currently in the pipeline to ensure they include two staircases where necessary before any Stage 2 referral. We are all working hard to look at feasible options to secure this and try to meet key timescales, particularly given the impact planning delays may have on affordable housing grant funding. The GLA Housing and Land team are working alongside us with applicants and providers to achieve delivery of the current 16-23 Affordable Housing Programme. Investment partners should contact their Head of Area within Housing and Land to discuss the impact on AHP projects. The position of our Housing and Land colleagues is that any projects which were eligible for their funding, taking account of all criteria, and had full planning consents at all stages prior to the 23rd of December 2022 (when the government consultation was released) would remain eligible for funding subject to all other eligibility criteria still being met; but as mentioned, we still urge you to contact your relevant Heads of Area.

 

The Planning team would be happy to discuss specific applications you have that are affected by this so please get in touch via the relevant case officer. We are keen to work with you and partners to look at how we can progress these cases through to decision in a co-ordinated and pragmatic way.

 

Jules Pipe

Deputy Mayor, Planning, Regeneration and Skills

 

Tom Copley

Deputy Mayor, Housing and Residential Development

 

IMPORTANT: DON'T LOSE YOUR RIGHT TO VOTE! INFORMATION ON VOTER ID

 

The GLA has launched a non-party campaign to raise public knowledge on the VoterID now needed to vote in elections. There is concern that some residents, especially young people, may not have the necessary ID to vote, thus undermining democracy.

The GLA helped by other organisations have launched a Voter Registration Hub with much useful information including resources for teachers in high schools and colleges. I have included some of the resources here.  Go to  https://registertovote.london/home/voter-registration-landing-page/

 

British Sign Language Video 

 

Never take your right to vote for granted 

 

From the Chartists to the Suffragettes, the history of voting rights is littered with examples of people taking extremely brave actions to secure the vote.

 

From a group of Barons tracking down a king in a muddy marshland and forcing him to sign a piece of paper in 1215, to the eventual universal suffrage of all adults in the United Kingdom 713 years late, we must remember that the right to vote in this country wasn't always guaranteed, and gaining it never came easy.

 

The 1819 Peterloo Massacre saw 17 people killed for demanding the right to vote after cavalry charged into a crowd of 60,000-80,000 protesters.

 

Chartism was a working class movement in Britain 1838-1857 that acted nationally, protesting and petitioning to demand voter suffrage.

 

The Suffragettes were a militant movement of women demanding the right to vote. They used radical action to secure this right, which led to members of the movement being imprisoned and even dying in the struggle.

 

Twyford Abbey development approved by Ealing Plannng Committee despite overwhelming opposition from residents, and from the nearby primary school, local councillors, the GLA and Rupa Huq MP

 

 

The recording of the Twyford Abbey development application representations and discussion at Ealing Planning Committee can be viewed above.  The application to develop on Metropolitan Open Land, currently in private hands, was approved despite overwhelming opposition from residents, and opposition from two ward councillors, the GLA and Rupa Haq MP.  It involves the loss of 157 mature trees and 7 acres of protected woodland.

 

Brent borders the site and some Brent residents registered objections. However, Brent Council was consulted and had no objections.The planning committee's  decision will now go to the GLA.

 

 Twyford Abbey and the South Lawn

 

The GLA had commented on strategic issues:

 

Land Use Principles
The proposal does not meet the exceptions of paragraph 149 of the NPPF and constitutes inappropriate development on MOL which is, by definition, harmful. A full public benefits package is required to determine whether ‘very special circumstances’ exist to outweigh the harm to MOL and any other harm. Confirmation is also required as to whether the loss of the extant school permission is considered acceptable in terms of being in a borough of identified
need, or other social infrastructure.

Urban Design/Heritage
The proposal would result in harm to the grade II listed Abbey, with a degree of harm to the walled garden and St Marys Church which will need to be weighed against the public benefits including those related to the restoration of the historic buildings. This exercise will be undertaken at Stage II referral once the additional information is provided (including views) and a full public benefits package is
available.

Other Matters
Also required are a London Plan (2021) compliant fire statement and consideration of pedestrian access to the North Circular as well as further information/revisions in relation to housing, affordable housing, transport and sustainable development.

Planning Officer Response: Noted, and all above matters will need to be discussed with the GLA during the Stage II process and are included in this report.

 

 These are the 'Very Special Circumstances' put forward in support of the application. 

 

Rupa Huq MP wrote:

 

I am writing to register my concerns with the above application in relation to the repurposing of Twyford Abbey for residential accommodation and formally object.

 

I was pleased to get a look at Twyford Abbey recently courtesy of the developer. Whilst I grew up locally this was the first time I’d seen the historic Abbey buildings and got behind the gates. The setting is hugely impressive and I agree that something better should be done with it other than lying dormant.

 

However, I am very concerned about the impact that such a monster development proposal will have, both on the site itself, and on local residents in surrounding streets. The provision of some 326 new homes on a relatively small site represents a very dense development of unnecessary height including seven new blocks of flats, along with a terrace and other stand- alone homes, represents a significant increase in the built footprint of this primarily greenfield site.

 

This proposal is completely incompatible with the nature of the site and the surrounding two storey residential roads; and will adversely affect the outlook of existing homes and longstanding residents on Iveagh Avenue and Brentmead Gardens forever. Significantly this is also metropolitan open land i.e. quasi green belt. Under the London Plan, metropolitan open land is afforded the same status and protection as green belt and is expected to be protected from inappropriate development.

 

Current government policy dictates that nature should be left in a better state at the end of development processes than at the start and that we should be aware of carbon footprint. It is not clear to me that this is proven here when the application proposes the removal of some 100 mature trees, including trees subject to a Tree Preservation Order – at a time when people talk of offsetting by planting trees to contribute to the urban ecosystem. As well as an immediate loss of habitat and biodiversity locally, the value of the trees in offsetting air pollution from the adjacent A406 dual carriageway is significant to local residents. Furthermore, the loss of the trees as part of the outlook from existing properties would represent a loss of amenity for local residents.

 

Existing residents here anyway feel stuck in a no man’s land between Brent and Ealing with e.g. no doctor’s surgery. Such a substantial residential development and concomitant population growth in this area will place local services – which are generally limited in this area – under significant strain. There is insufficient parking proposed which I foresee difficulties with.

 

Some elements of the proposal are indeed eye-catching. I agree that the grounds should be opened up and the Abbey deserves better than to rot away. However, the explanation I sought on my site visit of balancing resident privacy requirements of what are being presented as exclusive residences and allowing the public to roam the green spaces is not clear in my mind. My worry is this will ultimately be a gated community. The proposed provision of barely one-third of units as genuinely affordable housing will mean that this development does little to assist with the affordable housing shortage in Ealing, and falls below the expectations of genuinely affordable housing provision of both Ealing Council and the Mayor.

 

Whilst obviously the developer is sensing pound signs in their eyes, I feel that there are better uses for this great site. I understand that there is for example extant planning permission in perpetuity for a school. This - with the public able to use the greenspace of the grounds at weekends - feels a more acceptable solution. There is precedent for this in Ealing e.g. with the very successful Ada Lovelace school. I know of at least one local independent school which is seeking to expand and there may be others.

 

In conclusion, while I feel there is a better use for Twyford Abbey than lying dormant I remain unconvinced that this proposal represents the best possible long-term, sustainable and sensitive solution for the future of the Twyford Abbey site that would safeguard the heritage and biodiversity of the site and provide real benefits to the Abbey’s neighbours.

 

Yours sincerely,

 

Dr Rupa Huq
Member of Parliament for Ealing Central and Acton

 

 

Brent’s Affordable Council Housing – the promises and the reality

Guest post by Philip Grant in a personal capacity.

This image is a screenshot from a video featuring Cllr. Promise Knight, Brent’s Cabinet Lead Member for Housing, Homelessness and Renters’ Security, which was produced by a PR company to promote the Council’s “infill” housing scheme for Clement Close. The video was shared in Martin’s blog about residents’ opposition to Brent’s plans, in July 2022.

 

My use of images from that video in this guest post is not intended as a personal attack on Cllr. Knight. Her words in the video are official Brent Council housing policy, which she may have been reading from an autocue, and I don’t doubt that she believes them to be true.

 

I’m writing this blog as a follow-up to one last month, “Scrutiny – What Scrutiny?”, after my expectation that concerns over Brent’s Cecil Avenue housing scheme (raised in a deputation on 9 March 2022) would be considered at the Resources and Public Realm Scrutiny Committee meeting on 6 September were dashed in a single sentence from the Chair, Cllr. Rita Conneely:

 

‘I’ve received information which reassures us about the accuracy and the quality of the information that was presented to the Scrutiny Committee.’

 

The only information I was aware of which had been presented to the Committee was a written response, sent from a Council Officer two months after my deputation, which made no reference to the Cecil Avenue housing scheme part of it. Cllr. Conneely’s sentence referred to two lots of ‘information’, so I submitted a Freedom of Information Act request for both of those, and have now received two documents in response to it.

 

I will ask Martin to attach these. The first includes the “Housing” section of the original “Poverty Commission Update” report, my deputation and the Council’s response to it, and then refers to information about the Cecil Avenue scheme which the Council had sent to me, and had not previously provided to the Committee. There is no indication of when this was supplied to them, and whether this was to all members, or just to the Chair.

 

  

Information reassuring the Committee that Brent had provide information to me!

 

After that brief “note”, it sets out the text of an email which Cllr. Promise Knight sent to me on 13 July 2022. I must apologise to Cllr. Knight, and to “Wembley Matters” readers, as I’d said I would share her reply with you. I thought I had done, but I’ve now found my “possible guest blog” document, unfinished and never submitted to Martin! Here is what she wrote:

 

‘Thank you for your email regarding the proposed development of the Cecil Avenue site. It is my understanding that you asked similar questions at Full Council of November 2021 and received a written response.

 

In summary, the Cabinet report of August 2021 that considered proposed developments in Wembley Housing Zone set out the position. 

 

Brent Council signed funding agreements with the GLA in 2016 and 2018, securing £8m grant to deliver 215 affordable homes across six sites within the WHZ by 2025, through a rolling programme of acquisition and development, and used £4.8m grant to acquire Ujima House. 

 

Heads of terms were subsequently agreed with the GLA to amend the existing WHZ funding agreement to refocus the £8m grant to deliver 152 affordable homes solely on the two council-owned Cecil Avenue and Ujima House sites. 50% affordable housing is proposed across the two sites, with London Affordable Rent homes, increasing the amount and affordability of affordable housing above minimum levels secured at planning. The development will also include workspace to support job creation and economic growth, community space, highway and public realm improvements and new publicly accessible open space. Reviewing the WHZ financial viability, the GLA also agreed in principle an additional £5.5m grant to deliver the scheme.

 

The council can also use its own capital, secured via ‘prudential borrowing’ in order to deliver additional affordable housing. Each opportunity to deliver housing is considered on its individual merits via development appraisals that assess a number of variables per site that ultimately evaluate viability. The intention of the council is to maximise the availability of affordable housing across the borough while ensuring that the proposals represent good value for the council and that borrowing is sustainable. The Council needs to ensure the entire programme is financially viable within the GLA grant available hence the requirement for a mixed tenure development in order to subsidise the delivery of the affordable elements.’

 

Although Cllr. Knight’s email gave more financial details than had previously been supplied to me, it does contain errors. The 50% affordable housing (which is what private developers are meant to provide) is not proposed to be all at London Affordable Rent. Sixty-one of the 98 “affordable” homes the Council intends to retain at Cecil Avenue (after transferring 152 other homes to a developer, for private sale) are to be for shared ownership or “Intermediate Rent”.

 

And my 9 March deputation to R&PR Scrutiny Committee (and follow-up emails to the Chair) urged the Committee to challenge the viability (they could get the details of this, while I’m not allowed to see them because of “confidentiality”), and to question Cabinet Members and Senior Officers as to why they cannot provide more genuinely affordable homes on the former Copland School site.

 

 

I’ll go back to what Cllr. Knight said in her Clement Close video, using images from it (with several lines of text edited into a single picture, for ease of reading). One of the main arguments used by the Council for why it needs to build so many new homes is:-

 

 

They make much of their “Brent Labour” promise of 1,000 new Council homes by 2024 (although a September 2021 “Life in Kilburn” blog showed that many of these would not be for households in temporary accommodation, or on the Council’s housing waiting list):-

 

 

And now the key point, used to justify the many “infill” schemes on existing Council estates:-

 

 

The former Copland School site at Cecil Avenue is a large piece of vacant Brent Council-owned, brownfield land in Wembley. The Council has had planning permission to build 250 homes there since February 2021. What an opportunity to make the most of that, and deliver a quarter of the entire 1,000 new Council homes target, in just one project! 

 

Work could already be underway (they currently don’t expect to “start on site” until next year) to deliver those homes, yet the Cabinet and Council Officers seem fixated on pushing through lots of smaller “infill” projects, against the wishes of many existing residents.

 

The second document which the Chair of R&PR Scrutiny Committee had received, headed ‘Mr Grant Clarification’, is unsigned and undated. It sets out ‘the current position’, and there has been a significant change from the written response sent to me last May. My deputation pointed out that the Report on progress in meeting the Poverty Commission recommendations (which Cabinet had accepted in September 2020) made no mention of social rented homes.

 

The Brent Poverty Commission recommendation for ‘more social rented homes’.

 

In May I was told:

 

‘In 2021, following discussions with the GLA the council received £111m of GLA grant, this falls within the 2021 – 2028 programme and will allow the council to build 701 Social rented homes, which are currently in development and feasibility stages. Delivering social rented homes remains a major priority of the council.’

 

This is in line with what both Brent and the GLA were saying last year:

 

 

The “Clarification” document now says:

 

‘The Poverty Commission report stated that the council is on track to deliver more than 1000 council homes by 2024 and a further 701 council homes by 2028. These are intended to be provided at London Affordable Rent levels.’

 

Although both Social Rent and London Affordable Rent (“LAR”) are classed as “genuinely affordable”, they are different, as I pointed out in a guest post in July. Even if Brent Council were to charge the maximum “rent capped” amount for Social Rent (which it does not have to), this is still cheaper than LAR. My ongoing dispute with the Council over the rents for two new Council homes at Rokesby Place, which were wrongly changed from Social Rent to LAR (by Planning Officers!), showed that the tenant of each four-bedroom home would have to pay £772.20 a year more (on 2022/23 figures) if the tenure was LAR.

 

The second document also suggests that Brent is likely to include more ‘intermediate housing (for example shared ownership)’ as part of the so-called “affordable” housing that it builds. It is already going down that road, both at Watling Gardens, where Cabinet approved a change of 24 homes from LAR to shared ownership in June, and in its Cecil Avenue proposals.

 

A placard from a demonstration against Shared Ownership.

 

But the Advertising Standards Authority has recently ruled that shared ownership cannot be described as “part rent, part buy”. Legally it is just an “assured tenancy”, which has been dressed-up as home ownership for political purposes. The rent rises each year are not “capped” (as Social Rent and LAR levels are). If the “owner” of a “share” defaults on their rent (or service charges) their home could be repossessed, and they would lose all the money they have paid for their “share” of the property.

 

And, shared ownership is NOT affordable to most Brent households living in temporary accommodation, or on the Council’s housing waiting list!

 

The direction that Brent Council is travelling over its provision of New Council Homes is moving away from what the 2020 Brent Poverty Commission Report showed was needed. It found:

 

‘More than 90% of couples or lone parents with two children cannot afford LB Brent social rents, and no family with two children (whether couple or lone parent) can afford any rent that is more expensive than LB Brent social rents.’

 

If that is true, then why is Brent not building affordable homes for Social Rent?

 

Philip Grant.

 

GLA Consultation on Design Guidance (London Plan)

 From the Greater London Authority (GLA)

Consultation Opportunity – Design guidance: Characterisation and growth strategies, Optimising site capacity, a design led approach; Small site design codes; and Housing design standards London Plan Guidance

We are consulting on four new pieces of London Plan Guidance (LPG) relating to design and housing quality. This is the second consultation on this guidance, which builds on the Good Quality Homes for All Londoners Guidance that was consulted on between 13 October 2020 and 15 January 2021. 

We are consulting again because we have made quite significant changes to the guidance including making it into four separate LPG. 

1. Characterisation and growth strategy LPG

This relates to the following policies in the London Plan and is used for plan-making: 

Policy D1 London’s form, character and capacity for growth Policy D2 Infrastructure requirements for sustainable densities Policy D3 Optimising site capacity through the design-led approach Policy D9 Tall buildings Policy HC1 Policy HC1 Heritage conservation and growth, and Policy SD9 (Part B) Town centres: Local partnerships and implementation

It sets out a three-stage process to survey and analyse the characteristics of areas and uses this to identify the character of different areas and define tall buildings. This is then used to support growth strategies that take account of areas’ capacity for change and capacity for growth, including areas where tall buildings might be appropriate and the heights in these locations. 

2. Optimising site capacity: a design led approach LPG

This relates to the following policies in the London Plan and is used for plan-making and directly informing planning applications: 

Policy D1 London’s form, character and capacity for growth Policy D3 Optimising site capacity through the design-led approach, and Policy D4 Delivering good design

It sets out a five-stage process for implementing the design-led approach to plan-making and the site assessments that inform specific planning applications. 

3. Small site design codes LPG

This relates to London Plan Policy H2 Small sites, parts B2 – 4, setting out a process to analyse the opportunities for small site development and prepare and implement design codes. It will be used for plan-making and directly informing planning applications. It covers relevant aspects of the National Model Design Code published in 2021 by national government. 

4. Housing design standards LPG

This relates to London Plan Policy D6 Housing quality and standards and provides a checklist of London Plan policy requirements for new build, change of use and housing conversions in one place, with appropriate cross references back to the relevant policy in the London Plan and guidance about the type of development different standards apply to. 

The new guidance will be of interest to architects, designers, planners, developers, boroughs, neighbourhood planning groups, community groups and others. 

The consultation closes on 27 March 2022. 

Online Events

We’re running the following events (all online): 

Friday 4 March – 10am – 11:30am
This event is a general briefing for the general public to find out more about the new London Plan Guidance documents that relate to design and characterisation. It is open to all and is suitable for planning agents, architects and developers to ask questions and find out more about the guidance.
Register on this link: https://www.eventbrite.co.uk/e/261016205497

Friday 11 March – 10.00am – 11.30am
This session introduces the four new London Plan Guidance documents that provide guidance on design and characterisation. It is aimed at the borough officers in London, interested in design and characterisation.
Register on this link: https://www.eventbrite.co.uk/e/261071370497

We are also attending three Urban Design London events on the 8th, 9th and 16th March where we will present and set out the guidance documents that are out for consultation. To sign up to these events, please sign up on the UDL website. https://www.urbandesignlondon.com/events/2021-2022/london/

Useful Links

View details on the consultation and submit your response:
https://consult.london.gov.uk/designandcharacterisationguidance

Sign up to attend our online events:
http://londonplanguidance.eventbrite.com

The London Plan 2021 can be viewed on our website:
https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/london-plan-2021

Any queries can be emailed to QualityHomesLPG@london.gov.uk. You can post responses to: The Planning Team, Greater London Authority, City Hall, Kamal Chunchie Way, LONDON, E16 1ZE. 

Kind regards 

The London Plan and Growth Strategies Team