Brent Council writes to tenants on implications of the Building Safety Act ahead of Saturday's deadline

Wembley Matters has written about the implications of the Building Safety Act on a number of occasions as well as putting questions to the Brent Cabinet lead member for housing.

Now Brent Council has written to tenants and leaseholders of all the blocks owned by the Council affected by the Act with the actions they and tenants have to take to comply.  I have embedded the letter below in order to keep the QR codes intact.

As usual click on bottom right to enlarge the image. 

 

These are the Brent Council blocks affected. In addition blocks owned by private companies and housing associations will come under the Act if they meet the criteria.

 Asked by Wembley Matters to comment on the Brent Council letter a local tenant said:

I wonder if any of those receiving a letter are aware of all the other statutory obligations that the council has to send to the building regulator by Saturday.

1) Registration ---Completed

2) KBI's (Key Building information)

3) Following Registration the council have to publish their Resident Engagement Strategy, along with a Complaints Policy in order to apply for a Building Safety Certificate for each building.

4) Publish a safety case for each building, including Resident Profiles.

However the Regulator will only wish to see a safety case if there has been a recent incident, so that means the council have to send a safety case for Kilburn Square which shows the regulator what fire safety measures were in situ at the time of the fire.

All the above have to be with the regulator by Saturday the 30th September 2023.

In the letters, the council  only refers to Safety Case Reports which are summaries of safety cases but they are not the same.

Safety Case Reports are not needed to be sent to the Regulator until the deadline which is the 6th April 2024.

Kilburn tower block fire shows the necessity for Brent Council to engage with tenants - contribute to the engagement strategy and make it REAL!

 

 

Yesterday I asked a supplementary question on the Building Safety Act following the written answers provided prior to the meeting LINK. I will leave readers to judge whether the question was answered. 

Coincidentally, a fire broke out on the 13th floor of the tower block in Kilburn Square as the Council Meeting went on and Kilburn councillors left the meeting to go to the scene.

Life in Kilburn tweeted that there had been previous warnings about fires in that particular flat and these had gone unheeded by Brent Council.

 

The Daily Mirror followed this up and published a full piece HERE.

Three people have now been arrested in connection with the fire.

 

 

 

In 2017 I wrote an article on Wembley Matters about how the Kensington and Chelsea Council tried to silence a local blog, the Grenfell Action Group that had written about their concerns over the risks at Grenfell LINK prior to the fire and deaths. If one major lesson has emerged it is that residents who actually live in the blocks should be listened to and councils should engage with them.

 

That is being implemented six years on through a Resident Engagement Strategy. The council have a legal duty to set up a Resident Engagement strategy for each of the 41 Brent high-rises, including Kilburn Square.

 

Each strategy will allow anyone living in each building to engage with the council in making any decisions on both fire safety and structural issues in each high-rise.

 

These Resident Engagement strategies come within The Building Safety Act with most of it coming into force on the 1st October 2023.

 

The council are currently holding a consultation into what each strategy should include and they want to hear from anyone who lives in any of the 41 buildings in scope.

 

The Consultation can be found HERE. Brent Council explains:

 

The Building Safety Act (2022) introduced new requirements for building owners to demonstrate their ability to identify and manage safety risks in the properties they have responsibility for.

The Act specifically requires landlords to establish an engagement strategy for 'higher risk buildings' (18m in height OR seven storeys or more and containing at least 2 flats) and the document attached is a proposed engagement strategy for the 41 'higher risk buildings' owned and managed by Brent Housing Management.

 

The strategy details:

• What information will be provided to residents
• What decisions they will be consulted on
• How residents views will be taken into account; and
  

How the appropriateness of consultation undertaken will be measured

 

The draft strategy is embedded below:

 

 

Relief that no injuries at Kilburn Square tower block fire

From X (formerly Twitter) @IvorRBFCosta 

 

From London Fire Briagde

Eight fire engines and around 60 firefighters were called to a flat fire on Kilburn Square in Kilburn.

Half of a flat on the 13th floor of a 15 storey building was alight. Thankfully, no injuries are reported.

It was a very visible fire and the Brigade's 999 Control room received 78 calls alerting them to the fire.

The Brigade was called at 1843 and was under control by 2009. Fire crews from Kentish Town, Kensington, Park Royal, Hendon, Chelsea, Euston and Soho fire stations were in attendance.

The cause of the fire is under investigation. 

Kilburn Square development paused. All scheme options to be reviewed but Brent Council will still seek planning approval for the designed scheme.

The saga of the controversial Kilburn Square development continues with a letter distributed to residents today. The Council's plans have encountered much opposition,

Search 'Kilburn Square' on this blog for the previous posts.

As Life in Kilburn (highly recommended) pointed out on Twitter, this is the second site paused as Windmill Court was also paused. The two sites were allocated GLA money with a strict on-site start deadline of March 31st 2023. 

Newland Court in Wembley Park is also putting up resistance to infill proposals on their estate.

 The Planning Committee due to be held on March 15th, where the contested Planning Application may have been presented, has been cancelled. 

 

Kilburn Square – Would you believe it?

 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:

 

‘Hello Phillip,

 

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. 

 

Best wishes

 

Emily-Rae’

 

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!

 

 

Best wishes,

 

Philip Grant.’

 

 

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!

 

Philip Grant.

 

Kilburn Square – Brent must come clean on affordable housing!

 Guest post by Philip Grant in a personal capacity

 

From JLL’s Affordable Housing Statement for Kilburn Square, published 28 November 2022.

 

There are many reasons for objecting to Brent’s “infill” housing application (22/3669) for the Kilburn Square estate, but when I submitted my objection at the weekend, it was just about affordable housing.

 

Why would I object, when an updated and “Final” Affordable Housing Statement submitted by the Council’s planning agent, JLL, in late November clearly promised that for the 99 proposed “general needs” units ‘all proposed homes will be let at London Affordable Rent by Brent Council’? My reasons are set out in detail in an illustrated objection comments document, which I hope can be attached at the end of this post, for anyone to read if they wish to.

 

Two weeks before that Affordable Housing Statement was published, Brent’s Cabinet had approved a Report which proposed the conversion of homes, originally promised to be for rent at the genuinely affordable London Affordable Rent (“LAR”) level, to shared ownership (or even open market sale). Kilburn Square and Windmill Court were among the schemes where this would happen, but the actual numbers of LAR homes to be converted at each site were hidden away in an “exempt” Appendix.

 

Paragraphs about Kilburn Square from the Report to the 14 November 2022 Cabinet meeting.

 

Despite Brent’s New Council Homes team having known for at least three months now that they would not be delivering all 99 of their proposed “general needs” homes at Kilburn Square at LAR, no updated information on this has been supplied to Brent’s Planning Department. That information could make a difference between the application meeting Brent’s Local Plan affordable housing policy, BH5, or not meeting it.

 

The policy states that the “tenure split” for affordable housing should be 70% Social Rent or LAR and 30% ‘intermediate products’. Forty of the proposed 139 homes at Kilburn Square are for extra care accommodation, charged at Local Housing Allowance rent level, which is an ‘intermediate product’. This means that the split shown by the application (by unit) is 71.2% LAR and 28.8% intermediate, which would comply with Brent’s planning policy.

However, if the homes converted from LAR to shared ownership (which is also an ‘intermediate product’) were to be split proportionately between Kilburn Square and Windmill Court (the other two schemes would only involve two “conversions”), the split by unit for Kilburn Square would become 43.9% LAR and 56.1% intermediate. This would fail the BH5 policy test, and make it difficult for Planning Officers to recommend the Kilburn Square application for approval on the basis of its “public benefits”.

 

Conclusions from the Officer Report to Planning Committee on Windmill Court, March 2022.

 

When Brent’s Windmill Court planning application (21/4690) went to Planning Committee in March 2022, the fact that all of the proposed new homes would be for Social Rent (for existing tenants re-housed) or LAR was cited as a ‘substantial benefit’. This was used to justify several failures to comply with planning policy, which were 'considered acceptable' after taking into account that benefit.

 

Now some of those LAR homes will be converted to shared ownership (as has already happened at Watling Gardens). But that was because problems with viability only arose (or so it was claimed) after planning consent had been given. The situation over the proposed conversion of LAR homes to shared ownership at Kilburn Square is very different!

 

I will end this “introduction” to my objection comments with two paragraphs from them, setting out my views on the Kilburn Square position to Brent’s Planning Officers:

 

4.4 It currently appears that the applicant is knowingly withholding important information from the Local Planning Authority, in the hope that it can get its application approved on the basis that all of the 99 “general needs” homes proposed will be for rent at LAR level. It would then submit an application to vary the affordable housing condition in the consent given on that basis.

It would undermine the integrity of Brent’s Planning System, and reflect badly on the integrity of Brent’s Planning Officers and Planning Committee members, if such a blatant abuse of that system were allowed to occur.

4.5 I would argue strongly that, having been made fully aware of this situation, Brent’s Planning Case Officer should advise JLL that its client, the applicant, must submit its revised proposals for the tenure split of the proposed 139 homes at Kilburn Square, and that no decision on application 22/3669 can be made until that has been done.

 

We will have to wait and see whether any notice is taken of my affordable housing objection comments!

 

Philip Grant.

 

 

LETTER: Kilburn Square - Decision Time Approaches!

  'Save Kilburn Square' demonstration

 

 

A Letter from the Chair of Kilburn Village Residents’ Association

 

Dear Editor

 

Wembley Matters has faithfully reported on the laborious journey of the controversial Kilburn Square housing expansion project through the “pre-engagement” process for the last two (!) years. This plea from a KS resident was the most recent: (LINK) But decision time is almost here. 

 

In late October, Brent finally filed its Planning Application; 140 documents and counting if anyone is stuck for some light reading. Go to pa.brent.gov.uk and search for reference 22/3669. The Planning Statement is a good overview – but check out the Affordability statement too. 

 

That says 99 of the 139 units will be at London Affordable Rent. But since the PA was filed, the report to the November 14 Cabinet has made clear that the scheme as filed is not financially viable; and many of the new flats will have to be changed to Shared Ownership, or even outright Sale. How will the Planning Committee deal with that…?

 

Viability aside, the local community – KS residents and neighbours alike - has the same complaint it has had since February, when Brent announced it was freezing the scale and shape; it fails to address two of the three main objections we had to the rejected original scheme (180 units): loss of green space and mature trees, and excessive density of residents.

 

Comments on the Planning Portal are building steadily. All are Objections – with one exception: the submission from our MP Tulip Siddiq. That is officially classed as neutral; but we know that in reality she is urging Brent to listen to, and take account of, our concerns. A supportive Comment has also been submitted by the CPRE, reinforcing our concerns about the loss of mature trees and green space (which the Application has the gall to claim is “under-utilised” and therefore ideal for hosting a 37-unit new Block). CPRE is extremely concerned at the problem of Council Infills on green space across London: https://www.cprelondon.org.uk/news/londons-housing-estates-infill-and-green-space/

 

Read the comments for yourself; search Kilburn Square on WM and browse the sad history of this protracted saga; visit https://save-our-square and email us at savekilburnsquare@gmail.com to join our campaign. And then feel free to post a comment for yourself.

 

Registering and posting on the portal is ideal since we all get to be inspired by what you’ve said. Or the simpler route is to email planning.comments@brent.gov.uk (including 22/3669 and “Objection” in the subject line); and bcc us at that gmail address if you can

 

To whet your appetite, I’ve copied three rather different Objections already posted

 

1.This from a Victoria Road resident:

 

I have been a resident of Brent for 40+ years and have lived in the same house in Victoria Road, which will be directly opposite the new block C of the Kilburn Square development.

 

Direct impact – light and privacy

 

I am worried about the impact on light and privacy as they have admitted that this overshadowing will fall below accepted daylight standards. 

 

More broadly I am disappointed that the Council’s process of engaging with Brent residents not actually living on the Square but as directly affected neighbours has been poor and tokenistic and I do not feel there has been an enlightened approach to co-creation and coordination with the views of the whole local community. I want to stress that I am not objecting to the entire scheme; my concerns are about the scale and densification of the current proposal with the imposition of a huge block (C) removing green space and mature trees and impacting on our outlook through the canyoning effect of a multi-level block right up against the Victoria Road boundary.

 

Loss of green space

 

Brent West has been rated E (an area most deprived of green space). Those of us living next to Kilburn Square and in close proximity to the Kilburn High Road are both most deprived of green space and most exposed to the traffic pollution hotspot of one of the main transport arteries into and out of London. Trees and green space are essential for health, wellbeing and for helping to reduce the impacts of pollution and carbon. Kilburn Square is not a public park, but its lawns are not ‘underutilised brownfield’ as claimed by the application. It provides a vital environmental and visual asset for the wider neighbourhood. 

 

Kilburn Square is a much-needed green lung for estate and local residents; the latter will not benefit from the promised landscaping; instead of open green space and trees we are faced by a fortress-like apartment block. The green space also plays a part in flood risk mitigation as it can absorb excess water when it runs off concrete and overwhelms sewers. This is an increasing risk as we are already getting street flooding, especially in Brondesbury Road and backed-up drains and this will only increase as extreme weather events become more frequent. Brent’s Climate Strategy seeks to increase green space – this proposal is in direct contravention by concreting it over. 

 

Viability of landscaping proposals

 

The landscaping proposal is impressive but new trees take years to mature; there is no guarantee that any new vegetation will be properly maintained, and I am worried about the safety of our street plane trees with the amount of soil and root disturbance so close to them caused by months of heavy construction.

 

There have been concerns expressed about the financial viability of the scheme with rising costs; it would be likely – if completely unacceptable for both residents and neighbours - for the ambitious and sustainable landscaping plans which slightly mitigate the loss of green space to be the first things to be cut when budgets are stretched.

 

Pressure on local services and parking

 

I also object to the densification of this scheme as I have seen no reference to the overall impact on the provision of local GP, health, leisure services, schools and other youth and community facilities.

 

We have been given reassurance that no additional parking will be provided for new estate residents and that research has shown that on-street parking is adequate and available. I do not know when such a survey was carried out, but I can say confidently that that is not my experience living near the High Road at various time during both weekdays and at weekends and that no research has been done on the impact of visitor and delivery parking on surrounding streets.

 

Quality of life

 

I have been very happy living in Victoria Road for 40+ years and consider the Kilburn Square estate as near neighbours. It is a well-run, well managed estate – greatly improved in terms of safety, amenity value, visual impact, and overall garden maintenance since the early 1980s. It has a great sense of place, and its open outlook has kept it from ever feeling like a closed (or gated) community. I welcome some new build but don’t want to feel that a big increase in overcrowding radically changes the atmosphere and sense of security that I currently feel living as a single person directly opposite the Square.

 

A reduced scheme

 

Brent Cabinet has publicly admitted the scheme in the Application (with 40 Extra Care Flats and 99 homes at London Affordable Rent), is NOT financially viable and many flats will have to be moved to Shared Ownership or outright sale; this would move the tenure mix further away from the reach of the neediest families on the waiting list - undermining Brent’s justification for overriding proper concern for the mental and physical wellbeing of existing residents by considering a smaller scheme.

I would urge the planning committee to think about the bigger picture rather than seeking to maximise all available space for new build – the existing footprint of redundant buildings and the plan for the tower already provide a substantial number of new homes. I feel that a compromise that removes Block C and E would be acceptable and would avoid concreting over all our precious and valued green space, undermining the benefits it brings us all.

 

 

2.This from the Committee of the Kilburn Forum:

 

I am submitting these objections on behalf of the Kilburn Neighbourhood Plan Forum Committee. While the committee recognises the urgent need for affordable housing in Brent to accommodate residents who are in temporary accommodation or homeless and appreciates Brent has a target to meet 1000 new homes by 2025, this plan to infill 139 new homes on a settled housing estate is over-development. The plan is in breach of the Brent Local Plan which proposes some additional housing (100 units in two phases) over the next 10 years. The Local Plan sets out a vision for Kilburn Square to be developed as the Kilburn Town Centre, linking the square with the market and shopping precinct. The sheer volume of housing in the plan makes this vision impractical as understandably the residents expect the enhanced housing estate to be fenced and secured from outsiders moving around, experiencing a wider 'square'.  The additional housing blocks inevitably reduce the amount of green space that is vital to the current residents. The corner of Algernon and Victoria roads is especially cherished by families and much of this is lost to new blocks. It appears that the reduced shared outdoor space is compensated for by the provision of balconies for individual flats. While this may comply with regulations for outdoor space allowances per person/flat and important for renters, it does not compensate for quality of life or achieve a reduction of carbon emissions. Although the plan is detailing elaborate landscaping and some of this is to be welcomed, the site is not suited to the concentration of housing proposed, especially because it is located on one of the most polluted high roads in the borough.  The Pollutants assessment currently show the location is below Air Quality objectives and although the plan suggests that construction emissions will add to the pollution, it is also assumed that construction management solutions will mitigate the high risk over the development period. The reality of dense development on this housing estate conflicts with Brent's policies on clean air and biodiversity. The plan proposes the demolition of two facilities which provide community and health services. While it is recognised that the services' needs have changed and the NHS facility has moved elsewhere, the community facilities must be re-provided. The Former Clinic was granted 'a change of use' for an Arts charity, albeit as a temporary measure as the building is being demolished. However, the need for community facilities for social interaction, youth, education, arts, and other community activities remains, even more so with the increased number of housing units. We are given to understand that all the housing units will be at London Affordable Rent, and this is set out in the planning brief. Providing 139 including the 40 extra care homes for residents in urgent need of housing is the justification given for the excessive infill proposed. This cannot then not be converted to some homes being partially sold for shared ownership or private flats for outright sale as this contradicts the whole basis of the proposal. The Neighbourhood Forum is very aware and concerned that residents are dissatisfied with the quality of consultation. Although the plan has been amended to reduce even more housing on the site, there has been little opportunity for co-design and improvements we would expect from a more co-ordinated and consultative approach.  The Forum had one consultation session with the planners and architects some time ago but there has been a lack of communication with the wider neighbourhood and stakeholders, including those on the Camden side of the High Road. We make this point because of the strategic importance of Kilburn Square to the many and varied Kilburn High Road stakeholders. Finally we should point out that the refurbishment of the Tower block is outstanding and, although it may not be a planning application matter, the residents in this block must be treated equally with others coming into the estate, in terms of the quality of their flats. We recognise that current residents have put effort into creating a harmonious and safe environment and that it is essential to maintain balance, fairness, and goodwill to sustain social cohesion. We ask for a full revision of the plan to address these points.     3.This from Kilburn Village RA:    Who we are Kilburn Village RA is the long-established Residents’ Association covering the quadrant in Kilburn Ward NW6 bounded by Kilburn High Road, Victoria Road, Donaldson Road and Brondesbury Villas. Our territory comprises the Kilburn Square Co-op Estate and six surrounding roads.   We work closely with our neighbouring Residents’ Associations and the Kilburn Neighbourhood Plan Forum. We will be submitting a comprehensive consolidated response to this Planning Application, but this document outlines our overall conclusions   Introduction and Summary  The tension between the acute need for new, especially affordable, housing and the wellbeing of potential host communities is currently the subject of intense national debate. And it’s at the heart of our response on behalf of our local community, residents, and neighbours, to this Application.   1.    The estate urgently needs the existing tower refurbished, and could benefit from some improved landscaping; but it’s a mature, stable well-balanced estate and any extra building will be disruptive and affect its “Sense of Place”   2.    But recognising the acute social housing shortage, most residents and neighbours would accept Blocks A and B, replacing daytime-use buildings, whose scale (80-100 homes) aligns with what Brent Cabinet envisaged in a March 2020 Network Homes agreement   3.    Promoting the ill-conceived, over-ambitious Mini Master Plan (180 homes) seriously increased the duration and cost of pre-engagement, and alienated the local community; after a near-unanimous rejection in Summer 2021, Brent Council agreed to reduce the scale   4.    But the scheme now adopted (only 21% smaller) has addressed only one of the three key concerns Brent acknowledged: it has cut down the proposed tower, but would still increase resident density unacceptably (by 60% vs 2019), and breach various policies, notably Amenity Space and Brent’s Climate Strategy, with Block C removing green space and trees   5.    The expected partial move to Shared Ownership will move the tenure mix further away from the reach of the neediest families on the waiting list, and undermine Brent’s justification for overriding proper concern for the mental and physical wellbeing of existing residents   6.    The superficially thorough pre-engagement process has in reality been tokenistic and ineffective - in particular since the re-set, with the residents’ Independent Advisor’s role reduced and neighbours’ views not welcomed   7.    We therefore oppose the scheme as filed; if it is approved and implemented, it will be without the support of the local community – residents and neighbours – which the Council has always insisted it will secure; but the Approval should include a Condition precluding “Value Engineering” of the design and materials specified in the Application