30 Brondesbury Park: 'Incremental intensification' is the name of the game

 

30 Brondesbury Park, NW6

The border wall on Aylestone Avenue

The proposed new building and terraced housing

Brent's Local Plan was formally adopted with barely a murmer of opposition in February and along with other guidelines with influence the work of Brent Council's Planning Committee henceforth.

 

We are familiar with 'intensification corridors', 'town centre density', and 'tall building zones', all destined to change the face of Brent and increase its population.

 

Small residential sites are also ear-marked for development via 'incremental intensification' and the planning proposal for 30 Brondesbury Park, NW6, is an early example of what we are likely to see in the future. 

 

The proposal is to demolish the existing building and construct a three-storey building containing six flats in its place (three x 2-bedroom and three x 3-bedroom), together with a terrace of three x 3-bedroom houses addressing the Aylestone Avenue frontage.

 

Planning officers support the application as contributing to increasing the stock of housing in the borough and especially welcome the family sized accommodation. They accept the viability assessment that says the arithmetic means that the developer cannot make a contribution towards affordable housing.

 

The application has some elements in common with that in Queens Walk, Kingsbury  LINK where a block of flats replaced a family sized house on the corner with Salmon Street. Wembley Matters has since found evidence that rather than residential flats the development operates as holiday lets.

 

30 Brondesbury Park, like Queens Walk, is a corner site with garden space, and similar arguments are marshalled to support the development.

 

Planners state that Brent Policy BH4 supports development within the curtilage of a dwelling and that Policy H2 and the Local Plan recognises that the 'use of  small residential sites can make a valuable contribution to the delivery of new housing and some incremental change to local character could be acceptable on this basis.'

 

In short building a larger development utilising garden space is acceptable and sits alongside the 'fill-in' housing that is taking place on Brent's council estates.

 

Furthermore, 'the intensification of smaller sites is expected to form an important part of the delivery of housing to meet Brent's housing need during the [Local] plan period' and this is supported by the NPPF that expects the planning system, to meet the need for homes.

 

As we know corner houses such as 30 Brondesbury Park with a garden often has a long garden wall or fence along the adjacent road. Brent planners seemingly see that as dead space:

 

Neighbours have also raised concerns that the proposal would result in development of garden land, or ‘garden grabbing’. However, corner sites are considered to offer some scope for infilling in this way, in comparison to development of rear gardens that are enclosed by other rear gardens. In this case the extent of 2m high boundary wall along Aylestone Avenue creates an extensive dead frontage that adds nothing positive to the street scene. The proposal would break up this frontage by providing a building which would have a clear visual relationship to the main building but would remain clearly subservient to it. This would activate the street scene more effectively than the existing blank wall.

 

The London Plan is quoted by officers in support of the application: 

London Plan Policy D3 sets out a design-led approach to new development that responds positively to local context and optimises the site’s capacity for growth by seeking development of the most appropriate form and land use. It encourages incremental densification in areas that are not considered suitable for higher density development.

 

We have become familiar with claims that what neighbours often see as out of character developments are justified by Brent planners as 'landmark' or 'destination' buildings; in this case:

 

The site layout and building lines are considered appropriate for this prominent corner site, and to act as a gateway signalling the transition to the more domestic scale of the side street. [Aylestone Avenue]

 

There is little comfort for those concerned about the environmental impact of building on gardens, already suffering from the paving over of front, and increasingly, back gardens:

 

Residential gardens are generally considered to have low ecological value due to their small size, the nature of the use and, in this case in particular, proximity to disturbance from road traffic.

 

Officers note the 21 objections 'raising concerns regarding over-development and the impact on the character of the area, including the overall scale and mass of the proposal, front building line on Aylestone Avenue and loss of trees and green space, impacts on neighbouring properties in terms of daylight and privacy, increased pressure on on-street parking' and these are dealt with in the officers' report LINK with the Planning Committee recommended to approve the application. 

 

 

Wembley Park Station car park – a TALL story

Guest post by Philip Grant. This planning application will be decided by Brent Planning Committee tomorrow, Thursday November 26th. The meeting starts at 6pm and can be viewed HERE

 

Elevation drawing from the planning application with heights added

What is a tall building? For Brent planning purposes it’s one that is more than 30 metres in height (ten storeys), or more than 6 metres above the general prevailing heights of the surrounding area.

The proposed Barratt London / TfL development which Planning Committee will consider tomorrow evening (Thursday 26 November, 6pm) is definitely a tall building (or five of them). You can see more pictures of this planning application in Martin’s 2 November blog.

 

Brent’s Planners, in the Key Issues comments at the start of their Officers Report to the committee accept that ‘the development would exceed the policy expectations in respect of tall buildings’. I think they should have been clearer than that, so let me take you through the tall buildings planning policies which cover the Wembley Park Station car park site. I’ll begin with my “old friend”, the Wembley Area Action Plan (“WAAP”).

 

Foreword to the Wembley Area Action Plan, 2015.

 

When Brent’s then Lead Member for Regeneration (now Deputy Leader) writes to say that this Plan, adopted by the Council after wide consultation with the local community, will determine ‘how Wembley develops over the next 15 years’, you would think you could trust her words. And you can, because the WAAP’s policies still apply, and form part of the Draft Local Plan that is currently being finalised.

 

The WAAP has a tall buildings policy, WEM 5. It’s opening words are: ‘Tall buildings will be acceptable in a limited number of locations within the AAP area.’ The locations where tall buildings are, or may be, appropriate are shown on a map. Wembley Park Station car park is in “the red zone”, labelled ‘Sites inappropriate for Tall Buildings’.

 

The Tall Buildings map from the WAAP.

 

One of the specific sites (W22) identified in the WAAP for particular proposals was called “Wembley Park Station Car Park”. However, that was the western end of the original car park, not the present site with that name. This is where Matthews Close was built, with blocks between 5 and 8 storeys high - a scale identified as suitable for the mainly residential area of Brook Avenue.

 

Brent Council adopted a new comprehensive set of Development Management Policies in November 2016 (as seen in an earlier blog on another planning case in August!). These did not set out any new policies on tall buildings, but it did confirm that ‘policies within the Wembley Area Action Plan will take precedence where there are locally specific policies covering subjects that might also be covered’ by the DMP and the forthcoming Local Plan.

 

Another “supplementary planning document” which will form part of the new Local Plan, when it is finalised, is the Brent Design Guide, SPD1. Its policies were adopted by the Council in November 2018. SPD1 has a section on ‘Density, height and massing’, which includes guidance on sites appropriate for tall buildings. Under Principle 3.1 it states: ‘Tall buildings will only be encouraged in areas identified as appropriate for tall buildings.’ As we have seen above, the Wembley Park Station car park is a site inappropriate for tall buildings!

 

A page from the Brent Design Guide, SPD1, dealing with building heights.

 

As well as this confirmation over tall buildings, SPD1 goes on to set out the rules for heights on all other sites. These include that ‘sensitive design should ensure that new development respects the character of the wider surroundings’, and that ‘new development should positively respond to the height of the adjoining buildings and local area’.

 

I’ve already made mention of Brent’s Draft Local Plan, which has been through several phases of local consultation and is currently undergoing a final review to ensure that it complies with both the National Planning Policy Framework and the London Plan. It should come into force next year, and shape Brent’s planning policies for the next 20 years, so that it’s right that how it would affect the Wembley Park Station car park application is taken into account.

 

The Draft Local Plan does include a site-specific policy for Wembley Park Station (BCSA7), covering two sites. For the southern site, the narrow strip of land between the railway lines and Brook Avenue, it identifies an indicative capacity for 300 new homes.

 

The Wembley Park Station site plan from Brent’s Draft Local Plan (Stage 3).

 

Details for the Wembley Park Station sites from the Draft Local Plan.

 

As shown above, the WAAP tall buildings policy, under which this site is inappropriate for tall buildings, still forms part of the planning policies within the Local Plan. The proposals for the southern site respect that, with just a small adjustment. You will remember that a tall building is one of more than ten storeys, and the design details for this site say: ‘Up to ten storeys will be considered acceptable to the western side of the site, stepping up slightly directly adjacent to the station.’

 

One of the key purposes the Draft Local Plan has been designed to do is to deliver the housing target of providing over 2,000 new homes in the borough every year for the next 20 years. The Wembley Park Station car park site can provide the 300 homes which the Plan requires from it, with buildings no more than ten storeys high, possibly rising to twelve storeys next to the station. Any proposed new development on this site does not need to breach Brent’s tall buildings planning policies.

 

The Barratt London / TfL proposed development offers 454 new homes (152 of which would be “affordable”, but with 79 for sale as “shared ownership” and only 73 for “affordable rent”). But it clearly breaks the Council’s tall buildings planning policies. What does the Officer Report to Planning Committee say about that? This is just one of nine paragraphs on the subject:

 

’47. Whilst the Wembley Area Action Plan (WAAP) forms part of the development plan for the area, as it is the adopted policy, the emerging changes to policy as observed within BD2 of the emerging Local Plan are to be acknowledged and stand testament to the substantial increase in housing targets that have come into relevance since the publishing of the WAAP. Furthermore, emerging London Plan policy can now be afforded substantial weight and the sustainability of this location immediately adjacent to Wembley Park Station would identify it as a preferred site for maximising development opportunities. Wembley Park Station is the only tube station in Brent to be served by more than one London Underground line and its 6a PTAL rating underlines its sustainability.’

 

Heavy going! It’s not easy to follow exactly what the relevant planning policy is. You could easily think that they don’t intend you to, so that you'll just assume that they must know what they’re talking about, and accept their recommendation!

 

Policy BD2, from Brent’s Draft Local Plan.

 

Para. 47 (above) of the Officers Report refers to Policy BD2, as if it supports tall buildings on the station car park site. But BD2 only supports tall buildings in appropriate locations. The online version of the policies map it refers to is difficult to read, because it has so much detail, but this site appears to be within the overall “tall buildings zone”, but not in the Core Zone. This suggests that the site allocation details for BCSA7 above, which allow a slight stepping-up to a tall building at the station end of the site, should prevail.

 

Para. 51 of the Report does provide a couple of lighter moments, even if unintentionally. How about this one? ‘The buildings proposed would serve as a place-marker for the station.’ Imagine the scene:-

 

Visitor: “I need to get to Wembley Park Station. Can you tell me where it is, please?”

Helpful local resident: “Yes. It’s next door to a tall building in Wembley Park.”

 

Or this one – ‘A significant reduction in height from 30 storeys at this scheme’s initial pre-app stage is also acknowledged and has resulted in a building which establishes a reasonable maximum height.’

 

A man walks into Brent’s Planning Office, and says: ‘I want to build a tower block three times higher than your planning policies allow.’

Brent Planner: ‘I’m sorry, sir, we can’t accept that. We can only recommend a building that’s twice as tall.’

 

If a comedian said that, you might well laugh at his joke. But this is not “a tall story” * – it’s exactly what Brent’s Planning Committee is being asked to agree.

 

Philip Grant.

 

* If you are not familiar with the phrase “a tall story”, it’s colloquial English for ‘one that is difficult to believe’ (Oxford Reference Dictionary).

Affordable Housing Task Group Report's recommendations to be considered by Brent Cabinet on Monday

A report to Monday's Cabinet will be of much interest to local people on the housing waiting list as well as those struggling with expensive but poor private rented housing. Cabinet will, rather belatedly  consider the report from the Affordable Housing Scrutiny Task Group that went to the Resources and Public Realm Scrutiny Committee in January.

Cabinet is asked to:

a.Note the Resources & Public Realm Scrutiny Committee’s endorsement of the report, and its recommendations

b.Note and consider the committee’s additional proposal: that plans for new housing developments take into account the known needs of people with disabilities awaiting housing provision.

 Recommendations (Link to report)

 

Affordable housing targets and viability 

1.     In the new Local Plan for Brent the strategic target of 50 per cent for affordable housing in new developments should be retained, with an expected tenure split of 70 per cent social rent / London Affordable Rent to 30 per cent intermediate affordable housing. 

2.    Brent Council should adopt the Mayor of London’s 35 per cent “fast-track” threshold approach to viability (with 50 per cent on publicly owned land and for industrial sites). Through this the council would forgo the requirement for a financial viability assessment and/or a late stage viability review in the event that a developer guarantees delivery of the requisite percentage of affordable housing across the entire development (with the 70 per cent social rent / London Affordable Rent to 30 per cent intermediate tenure split applicable). The policy should be subject to review. 

3.    To help meet the need for larger affordable homes in the borough, Brent should continue to require a minimum of 25 per cent of new affordable rented homes to be three bedrooms or larger, accommodating at least a household of six (2 people per bedroom). However, this approach must be combined with a clear and effective under- occupation strategy, enabling and incentivising down-sizing in order to release more existing larger homes for re-let. 

4.    The council should continue to use the “Existing Use Value Plus” (EUV+) method for determining benchmark land values. Any other uplift in value should be captured for the public. 

Corporate approach to affordable housing delivery 

5.    Future council policy with regard to the setting of rents for affordable housing should continue to be based on the traditional social rented model (like the mayor’s London Affordable Rent model) and should not be linked to volatile and irrational market rents rather than incomes. 

6.    Brent Council should create a cross-departmental Board of officers, reporting directly into the Corporate Management Team (CMT), to ensure a ‘one council’, joined-up, sustainable approach to the delivery of Affordable Housing. The board should have high level responsibility for programme management and monitoring of an Affordable Housing Action Plan and associated suite of Key Performance Indicators. The Board should include senior officers from Brent’s Planning, Housing, Regeneration, Property, Finance and Legal teams. 

7.     Brent should consider adopting a land assembly, master planner approach, working with key partners and designating Land Assembly Zones in its Local Plan. Where attempts to encourage and incentivise voluntary land assembly do not succeed, Brent should commit to extend its use of compulsory purchase powers in these zones, where the law allows. 

8.    Brent Council should maximise resources available through the mayor’s fund, RTB receipts and borrowing to support direct delivery within its own capital development programme with a primary focus on rented homes at social rent levels and on larger homes (3 bedrooms or larger). 

9.    Brent must adopt a clear policy on access to shared ownership in the borough, making the product accessible to people on incomes that are as low as possible and ensuring the policy is designed to enable keyworkers to take advantage of it. 

10. All new homes in Brent should be marketed locally first, as per the Mayor of London’s planned “first dibs” policy. Brent should investigate how such a requirement could be implemented. 

11.  Brent Council should explore all the options highlighted in this report for innovative partnering arrangements and delivery models with Registered Providers. 

Estate regeneration

12.Future estate regeneration projects in Brent should use the South Kilburn Regeneration Programme as a model of good practice and make a clear commitment to ensuring there is no loss (in quantum terms) of social rented affordable housing and to resident ballots. 

Land owned by public authorities  

 13. Brent should actively promote partnership working on publicly owned land with other public bodies, as promoted by the Naylor Review (One Public Estate), e.g. Network Rail/TfL sites such as potential over station and over rail land developments, as part of the Local Plan. 

Industrial/employment sites

14. Brent must adopt a proactive approach to identifying opportunities where surplus commercial space, underused retail sites and car parks may have significant potential for housing development, both strategic industrial land sites and smaller commercial land sites, and in particular where sites have potential for mixed-use developments.

Small sites

15. The council and its agents should proactively explore partnerships with developers and RPs on small sites to maximise the amount of affordable housing across the borough. Brent should identify potential opportunities and funding mechanisms for increasing development of small sites, including any further opportunities for infill development. It should be prepared to invest the necessary resources. 

16. Developers of small sites with capacity for 10 or fewer units should be expected to pay a commuted sum, wherever possible, based on a consistent tariff, to Brent as a contribution to the fund for affordable housing to be built elsewhere in the borough. All affordable housing in small developments should be included in Brent’s periodic performance stats. 

Community led housing

17.Brent should investigate and promote opportunities for community led housing projects, such as “Community Land Trusts” and “Self-Build” projects, which will protect homes and assets at affordable levels in line with local incomes for future generations. 

18. Brent should explore setting up of a CLT model on publicly owned land and encourage developers to do the same.

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