Wembley Housing Zone – is this an answer to Brent’s affordable housing needs?

  Guest Post by Philip Grant (in a personal capacity)

One year ago, the Brent Poverty Commission report by Lord Richard Best was published. The Commission reported that: ‘1 in 6 households (17%) live below the poverty line, doubling (to 33%) after housing costs are taken into account. More than 1 in 5 (22%) of children live in poverty, doubling to a startling 43% after housing costs.’ The report identified: ‘an acute shortage of social housing which has forced people into the private rented sector where rents are two or even three times higher.’

 

 

The following month, Brent’s Cabinet gave its full backing to the report’s recommendations, including those based on the key point that the Council needed to put ‘more investment in social housing’, and ‘build even more affordable homes.’

 

 

Next Monday (16 August), Brent’s Cabinet has the opportunity to put those recommendations into action, when they consider a report on implementing the Council’s proposals for the Wembley Housing Zone. I will set out briefly what is proposed, and why Cabinet members may wish to question how what Council Officers are proposing might be improved, to take better account of the Poverty Commission’s findings.

 

The Wembley Housing Zone (“WHZ”) was set up in partnership with the Greater London Authority, to speed-up the delivery of new homes. £8m of GLA funding was received, and part of this (£4.8m) was used by the Council to buy Ujima House in Wembley High Road. The other site (already Council-owned) which now forms part of the WHZ is across the road, where Copland School used to stand (whose buildings were demolished after Ark Elvin Academy moved into its new school further down the slope).

 

 

A detailed planning application for the site on the corner of the High Road and Cecil Avenue, and an outline application for Ujima House, were made towards the end of 2019. Although these were approved by Planning Committee in March and June 2020 respectively, the formal consents were not signed off until February 2021. 

 

It had been decided that the two WHZ schemes would be treated as one for “affordable housing” purposes, and Cabinet is now being asked to ‘approve the preferred delivery option for the regeneration of the sites’. The two sites between them will provide 304 homes, and it is proposed that 50% of these should be affordable homes. I will give a short outline of what is proposed for each site.

 

The planning approval for Ujima House (19/3092) would demolish the existing building and replace it with a ten-storey block. There would be workspace and a café on the ground floor, with 54 residential flats on the floors above. The 28 1-bed, 18 2-bed and 8 3-bed (only 15% of the total) homes would all be for rent by Brent Council at London Affordable Rent levels (not social rents - see below). 

 

 

The more detailed application for the cleared site at the corner of Cecil Avenue and the High Road (19/2891) would build blocks, between five and nine storeys high, containing 250 flats and maisonettes. 64 of these homes would be either 3-bed or 4-bed (26%). However, only 39% of the homes in this development would be “affordable”, and only 52 of the 250 are proposed to be for rental, at London Affordable Rent levels.

 

 

[These blocks would not be as grim as they look in the elevation drawings, as the plans include a courtyard in the middle!]

 

The affordable element for this larger site was set out in an “Approved Plan”, which was made a condition of the February 2021 planning consent. More than half of the London Affordable Rent homes (28) would be 3 or 4-bed. The plan also set out that the other 36 “affordable” homes (21 of which would be 2-bed) should be either Shared Ownership or Intermediate Rent (which would be cheaper than private rents, but not within the means of those on the housing waiting list).

 

 

There appears to be a discrepancy. The 52 + 36 affordable homes for the Cecil Avenue / High Road site in the planning consent make a total of 88. However, the WHZ report to Monday’s Cabinet meeting says that 152 affordable homes will be delivered (50% of 304), and to reach that figure 98 of the homes from the larger site would need to be affordable, not 88.

 

Fifty percent of affordable homes may sound good. But if only 106 of the 304 new units are to be for rent, and all of those at London Affordable Rents, how does that meet the Cabinet’s commitment to the recommendations of the Brent Poverty Commission?

 

London Affordable Rent levels are set by the GLA. They use a formula based on rent figures decided in 2017/18, which are then increased each year by the previous September’s Consumer Prices Index increase plus 1%. The 2017/18 figures used were around 50% of open market rents at the time, but were between 30% and 50% higher than the average “social rent” levels for the same sized homes charged by housing associations and London boroughs. 

 

An analysis available on the GLA website makes clear that London Affordable Rent should not be confused with social rent levels, and says: ‘social rent is the only housing type really affordable to lower income Londoners.’ That is why the Poverty Commission report said that Brent should seek to make more of its new “affordable” housing genuinely affordable, at social rent levels.

 

It appears that the Council Officers making these WHZ proposals to Cabinet are either unaware of, or have chosen to ignore, the recommendations on housing in the Brent Poverty Commission report. Their proposals would ‘bring the Cecil Avenue and Ujima House sites to the market together’, through the Council undertaking the construction on both sites, but “procuring” ‘a developer partner to share private housing sales risk.’

 

The Officer report to Cabinet says that their proposal is a “medium risk” strategy:

 

‘The Council takes and manages construction risk, which it has experience of doing through its housing and schools capital programmes, but a developer partner is sought to take and dispose the private sales housing, of which the Council has no experience. By financing construction, the Council can use lower public sector borrowing rates and reduce finance costs.’

 

One of the “risks” of following this route would be:

 

‘A developer may seek to influence the final scheme, compromising the overall place making vision and regeneration benefits for the area.’

 

If the Council is going to undertake and manage the construction on the two sites, why not make ALL of the homes it builds “affordable housing”, providing 304 Council homes for people (especially families) on its waiting list? Ideally, these should all be for social rent, for those most in need, as recommended in Lord Best’s report. If that is not financially viable, an alternative could be 50% let at social rent levels, with the other 50% (presumably the better ones on the Cecil Avenue site, which a developer would have wanted for “private sale”) at London Affordable Rent.

 

I can’t make any detailed suggestions on the finance side, as six of the seven Appendices to the Officer report are secret, because they contain “Information relating to the financial or business affairs of any particular person (including the authority holding that information)". It appears that the press and public may also be excluded from Monday’s Cabinet meeting while these matters are discussed!

 

 

However, it is clear from the report which is available that there are ongoing discussions with the GLA over funding for the scheme, about ‘increasing the amount and affordability of affordable housing’:

 

‘Reviewing WHZ financial viability, the GLA have also agreed in principle an additional £5.5m grant to deliver the scheme, but which is subject to confirmation.’

 

If the Council would go back to the GLA, and its 2021-2026 Affordable Housing Programme, with proposals for the Wembley Housing Zone to provide 100% affordable housing, that could provide the answer.

 

I believe that this suggestion is worth serious consideration, so I am sending a copy of the text of this article to all of Brent’s Cabinet members (sent Friday 13 August at 4:23pm). I hope that at least some of them will raise questions based on it, especially about the need for social rent homes to be considered, at the meeting on Monday.

 

I will also send a copy to the Council Officers involved, and to the Chief Executive, for their consideration, and so that they can either provide answers, or at least agree to go away and look at this matter again. 

 

The Wembley Housing Zone provides a major opportunity to meet some of the housing need identified by the Brent Poverty Commission. That opportunity should not be wasted!

 

Philip Grant.

Sudbury Town Station planning application rejected, Ujima House and North Brent School approved

After a lengthy discussion Brent Planning Committee again rejected the TfL application for a development of 'pocket homes' on the car park at Sudbury Town Station. Despite a £600k offer by the developer towards the build costs of 6 three bedroomed homes outside the area, the committee stuck to their original objection on grounds of lack of family homes for the site itself,  the loss of the car park and its impact on acessiblity for people with protected characteristics; and the applications lack of compliance with Local and London plans. Three members of the public and two councillors made very persuasive presentations opposing the application.

Cllr Denselow abstained. Cllrs Hylton and Chappel voted for the application and the four other committee members against.

The Ujima House discussion was a real mish mash.  The owner of Lanmore House and Jaine Lunn occupant of a neighbouring house on Ecclestone Place, were represented and it emerged that a 'letter before claim' against the Council, who are the developer, had been issued. The committee were told by the Council legal officer that the Council had complied with all regulations and that appeared to be the end of that.

Inaccuracies in the officers' report were highlighted concerning the height of the building and the number of windows in adjoining buildings affected, and the committee were told that the architect had failed to get back to the Council about a query, but all this was deftly passed over.  The issue of a weight restriction of 15 tons on the entrance to Ecclestone Place was brushed aside with an assurance that if necessary lorries could access the site from Wembley High Road (traffic jams!)

The committee were told that this was just an outline application and detailed issues could be dealt with at a later date.

The application was approved.

The Executive Headteacher of the Wembley Multi-Academy Trust after initial zoom problems gave a confident presentation on its plans for a new school on Neasden Lane, currently called North Brent School, although it is on the south side of the North Circular.

However, after she had left the meeting some confusion arose over the catchment area of the school as it emerged that pupils would be travelling to the site from North Wembley as the school is currently housed on the Wembley High School site.  The new site would open at the end of 2021 so the children on the current site would have to travel down. One officer muttered something about issue of the school  catchment should have come up earlier and councillors seemed unsure if the new school when fully open would serve the local area or continue to be populated by pupils from the North Wembley area.   Clearly it would be better in terms of Green School Travel Plans if the catchment was local and the area does lack its own non-denominational school.

The new school will be 6 forms of entry so will generate a lot of trips and transport was the main issue discussed. An earlier plan to have 4 coaches travel down to the school from North Wembley had been opposed by TfL and was reduced to one, so pupils will have to travel by public transport either  on the tube, by bus or by cycle. The 297 route would be beefed up in consultation with TfL and the 245 was also mentioned but that only goes as far as Neasden shopping centre before turning off towards Staples Corner. One councillor raised concerns about children from different schools milling around at the Neasden interchange where there were already problems.

It appears that on one side of the borough we will have children travelling north from Harlesden and Stonebridge to Ark Elvin and on the other children travelling south from North Wembley to Neasden Lane!

The one decision made (apart from  approving the application) was to  call for 172 cycle parking places to be provided in the initial phase of the building. No one queried whether cycling to the school would be safe.

Recording of Committee HERE

UPDATED: Controversial deferred planning applications return to next week's Brent Planning Committee

While most Brent Council committee meetings have been cancelled or postponed, as well as the Council's AGM which was due to be held this week, the Planning Committee continues via the internet.

Nex Wednesday's meeting considers a number of heavy-weight planning applications, worth millions, including two that were deferred at the May 6th meeting.

The application for Ujima House, on Wembley High Road, was deferred after a late objection was received from the landowner of neighbouring Lanmor House. His email objecting is not available on the Planning Portal (it is just noted) and of course as usual the 'Consultee' comments are linked but not actually published.

The email's contents can only be gleaned from the Planning Officers' summary LINK:

Additional objection 

Objections have been received on behalf of the owner of the adjoining site at Lanmor House (370 to 386 High Road) and part owner of 26-29 Ecclestone Place. 

A summary of the concerns are set out below: 

1. Consultation

The objector considers that there was a lack of consultation with the adjoining land owner during both pre-application and application stages. 

With regards to consultation requirements for the planning application itself, the Council did post site notices outside the application site and the application was advertised in the local press. In addition, consultation letters were sent to all nearby occupiers. This included the commercial space and all flats within Lanmor House, and 26 to 29 Ecclestone Place. 

The Council therefore exceeded its statutory duty for consulting on the planning application.

Further details of the comments received (including an objection received from 27 Ecclestone Place) are discussed within the “consultation” section below. 

The NPPF paragraph 40 states that local planning authorities should encourage applicants to engage with the local community before submitting their applications, and Brent's adopted Statement of Community Involvement reinforces this by setting out recommended pre-application engagement for planning applications. For an application of this scale, discussions with neighbours and public meetings and exhibitions are recommended. However pre-application engagement is not a statutory requirement. In this case, local residents were invited to attend two public exhibitions and give feedback on the proposals, although non-resident property owners were not explicitly invited. 

2. Accuracy of reporting

The objector considers that there was a lack of consideration of the proposal upon Lanmor House, taking into account the recent planning history and works carried out to Lanmor House. They also raised concern about the scale of surrounding buildings not being accurately reported and inaccurate reference to the building line being in line with adjoining sites where in fact it projects forward, and the resulting impact of the forward projection upon neighbouring amenity. 

The above matters are discussed within the "remarks" section below. 

3. Building scale and mass of envelope parameters

The objector has expressed concern about the footprint and resulting depth of the building and the impact on neighbouring occupiers, specifying that there would be an overdevelopment of the site. 

4. Separation distances, privacy and outlook

The objector is concerned about the potential for overlooking and a loss of privacy and outlook to Lanmor House and 26 to 29 Ecclestone Place. 

Once again, this is expanded upon within the "remarks" section below.

5. Daylight and Sunlight

The objector considers that there are inaccuracies within the daylight and sunlight report in terms of the reporting of the windows within Lanmor House and no consideration of the impact upon the communal roof top garden in Lanmor House. 

This is expanded upon within the "remarks" section below.

6. Right of Light

The objector has highlighted that whilst outside of the remit of planning, the Council should be aware of its legal position regarding rights of light. As highlighted by the objector, this is outside the remit of planning. 

7. Highway matters

Matters have been raised with regards to construction traffic, servicing and delivery traffic, and access to the proposed building.

This has been discussed within the remarks section below. 

8. Streetscene

The objector considers that the assessment of the impact on the streetscape does not consider the curve in this part of the High Road and the potential for a “canyoning” effect along this part of the High Road with the nine storey building on the opposite side. Concerns are raised with the impact on the micro-climate wind tunnelling effect. They also believe that the Design and Access Statement misrepresents the building when viewed from the east as it is only shown as nine storeys.

These matters are discussed within the "remarks" section below. 

The  officers find reasons to reject the objection (see report linked above) and recommend approval of outline planning permission but it appears likely that the owner of Lanmor House will take things further.

The second deferred item is the development at Sudbury Town Station. This was initially rejected outright by the Planning Committee but officers' quickly proposed that it be deferred so that they could talk with the developer, Transport for London and this was, controversially, accepted by Committee members. LINK

These discussions have resulted in an offer by the developer  to contribute £600,000 to 'enable the provision of six 3 bedroomed houses' off-site. Committee members may wish to explore the mathematics involved.

The developer has also offered one additional blue badge parking space and confirmed that the offer of contributing to the cost of a CPZ would be available for 10 years.

The officers report LINK  gives a blurb for the Committee to adopt if they are minded to still refuse the application.

Residents reaction:

Defer these vital planning applications until residents can participate

There are still no clear instructions on the Brent Council Democracy web page (above) on how residents can make representations on planning applications that are tabled for Wednesday's virtual meeting.

Given this blog's long-standing campaign for transparency and accountability in local government I can only echo Paul Lorber's call to Cllr Denselow, the chair of the Planning Committee and its members, that the weighty planning applications be deferred until such time as site visits can take place and residents without internet access can make representations for or against applications.

These are the applications tabled for Wednesday:

0. APPLICATIONS FOR DECISION 
   
   
1. 18/4919 1-26A, coachworks & storage areas, Abbey Manufacturing Estate, all units Edwards Yard, Mount Pleasant, Wembley, HA0 
2.   Demolition and erection of a mixed use development of buildings ranging between 3 and 14 storeys in height comprising residential units (use class C3), flexible commercial floorspace falling within use classes A1, A2, A3, A4, B1(a), B1(c), D1 or D2, associated car parking, landscaping and ancillary facilities (Phased Development)
   
   
   
3. 19/1241 Car Park next to Sudbury Town Station, Station Approach, Wembley, HA0 2LA 
4.   Re-development of existing car park for the erection of two blocks of residential dwellings, with associated residential amenity space, refuse storage, cycle parking, landscaping and other ancillary works, together with re-provision of disabled car parking bays nearest to Station Approach to serve Sudbury Town Underground Station (DEPARTURE FROM POLICY CP21 OF BRENT'S LOCAL PLAN).
   
   
   
5. 19/3092 Ujima House, 388 High Road, Wembley, HA9 6AR 
6.   Demolition of the existing building and erection of a new building up to a maximum height of 39.6m comprising up to 5,000sqm residential floorspace (Use Class C3), up to 600sqm of flexible workspace (Use Class B1A, B and C), with ancillary cafe (Use Class A3) up to 600sqm ancillary floorspace, associated hard and soft landscaping, wheelchair car and cycle parking.
   
   
   
7. 19/3259 1-7 and 15-33 Peel Precinct and garages, 97-112 Carlton House, Canterbury Terrace, 8-14 Neville Close, 2 Canterbury Road, London, NW6 
8.  
9. Full planning application for a phased development for the demolition of 2 Canterbury Road, 1-7 and 15-33 Peel Precinct and 8-14 Neville Close, and erection of seven buildings (A to G) ranging between 5 and 16 storeys, plus part basement, comprising private sale residential units (Use Class C3), shared ownership residential units (Use Class C3), social rented residential units (Use Class C3); new health centre (Use Class D1), new gym (Use Class D2), flexible use class within retail and commercial units (Use Class A1/A3/B1) at ground floor, associated landscaping, highways and public realm improvements (including new public space and market square), private open space, associated car parking, cycle parking and servicing provision
10.  
11. FULL DETAILS HERE 

Former Brent Council Leader issues Official Complaint over lockdown Planning Committee decision making

The proposed buildings on Sudbury Town Station Car Park

The Brent Planning Committee on Wednesday May 6th (6pm) will be a virtual meeting. The Agenda on the Council website states:

Note: Please note the press and public will be welcome to attend this as an online virtual meeting. The link to attend and view proceedings will be available via the Live Stream page on the Democracy in Brent website. 

The Agenda does not state how members of the public may make representations at the meeting, a normal Planning Committee provision, which ensure the public's voice is heard.

However,in correspondence with former Council Leader and Liberal Democrat General Election Candidate, Paul Lorber, the Council has stated:

It is possible to speak at the Committee Meeting (online or via the telephone) subject to the restrictions set out in the Council's Standing Order. These provide for one objector and/or one supporter of the application to speak. The Chair has the discretion to increase this to two people from each side. In doing this, the Chair will give priority to occupiers nearest to the application site or representing a group of people. 

To address the committee you must speak to Democratic Services at least one clear day before the meeting. Please telephone the Democratic Services Officer, Mr Joe Kwateng, on 020 8937 1354 during office hours or email committee@brent.gov.uk

Apart from the Sudbury Town Station proposal that Lorber was concerned about (see image above)  there are also applications for a mixed used development at the Abbey Manufacturing Estate/Edwards Yard site in Wembley  for 3-14 storey buildings, an 11 storey building on the site of Ujima House in Wembley High Road, and Peel Precinct and neighbouring sites  in South Kilburn for 7 buildings of 5-16 storeys.

A pretty heavy agenda by any measure and issues on which the public may well want to make representations.

Paul Lorber wrote to Brent Council CEO outlining his concerns over the absence of site meetings as well as the rights of residents witout internet access:

As you know I raised with you concerns about dealing with Planning Applications during this crisis. As in most cases applicants will not be able to pursue or implement any approved applications there seems no great urgency to rush applications through and deny members of the public an opportunity for a proper say.

It is normal for many residents to attend Planning Committee when they are concerned about an application. Determining applications on line denies them this opportunity. Any resident not on the internet or not familiar with the new technology faces an even greater disadvantage and unfairness.

It has been a long standing practice in Brent for many decades for planning applications which are either controversial or subject to great concern or opposition from residents to be subject to a site visit. Site visit were an important opportunity tfor members of the Planning Committee to better understand the concerns being raised and to see things on site. The reasons for this are obvious - explanations and information on paper only do not tell the full story.

The planning site meetings are also an opportunity for residents to point out the their concerns directly to Councillors.

I am concerned that going ahead with planning applications subject to Planning Committee Meetings, because of the nature of the application or the large level of opposition,in the way proposed undermines the normal Brent Council approach of meaning full public involvement and Brent Council's commitment to Open Government. All the advantage is handed over to the Applicants who have had the opportunity of direct access to Council Officers denied to the members of public. It is those officers who then advise Councillors in Planning pre meetings or in other ways outside of public scrutiny.

The lack of site meetings as a major change to the way planning meetings have been dealt with in the past which also undermines the whole process.

In my view Brent Council should suspend dealing with any applications which are subject to material number of objections and only deal with applications which fall into the category dealt with under delegated powers or those where no materail number of objections have been received.

Besides the risk of extra challenges to decisions were made there is a much more serious issue of public confidence in the whole planning process in Brent.

I trust that you will consider my concerns seriously and suspend the process of dealing with Planning Applications in the proposed way.

Lorber has now issued a formal complaint as a result of his dissatisfaction with the Council's response to his letter:

The Brent Council decision to proceed with planning applications in the way proposed in your letter has a number of implications:

1.     It denies members of the public (or even Councillors) to request a site meeting.

2.     It denies any member of the public without the internet or ability to join the online meeting of the right to participate.

In view of this any consideration of this application should be deferred until such time as things return to normal, site meetings are possible and all memebers of the public are free to attend a normal Planning Committee Meeting in Brent.

See Copland/Ujima proposals on Saturday 10-2 at SEIDs Hub. Wembley

From Your Shout agency

As a reminder we will be at the Social Innovation and Enterprise Hub (SEIDs) on Empire Way, Wembley HA9 0RJ on Saturday 16th February, 10.00 – 14.00. Drop in to see how the proposals for the former Copland School and Ujima House sites on Wembley High Road have progressed since our last event.

Once you arrive at SEIDs please follow the signs to find us (see picture attached).

We hope to see you on Saturday!