Report Finds that “Affordable” Housing Increases Rents for Low-income Londoners

 

 

As the Labour Party Conference meets in Liverpool and Brent's lead member for Regeneration also takes on a leading role in the national Labour Yimby (Yes in May Backyard) Group a well-researched report has been published that raises doubts about the strategy.

The YIMBY Group seeks to label any opposition to massive housing developments as NIMBYs (Not in My Backyard) - self-interested communities interested only in maintaining their own privilege - the Public Interest Law Centre report shows that the issue is more nuanced.

Although Cllr Tatler has argued that any increase in housing supply in Brent will lower rents through market mechanisms, according to My London Office of National Statistic data shows that Brent has seen the steepest rise in rents over the past 12 months of any local area in England or Wales.

The average rent is now £2,121 per month - a rise of 33.6% since 2023. This compares with a London average rise of 9.6%. 

 From the Public Interest Law Centre website

 

“Immediate action is needed to adopt policies aligned with UN standards of affordability. Time is running out, and the impact on children in temporary accommodation is especially urgent.”

 

PILC has launched a report that has found that estate regeneration projects that feature demolition routinely underproduce truly affordable housing for low-income Londoners and increase rents of council and social housing by an average of more than £80 per week. 

 

We commissioned Dr Joe Penny of UCL’s Urban Laboratory to analyse six of the ‘best’ and ‘worst’ regeneration projects across three London Boroughs including The Aylesbury Estate and The Heygate Estate.  

 

The report has found that the word “affordable” is used with no consideration for what is truly affordable for people who need these housing options the most and there will be a net loss of 2,151 truly affordable council homes. 

 

What is cross-subsidy estate regeneration? 

 

The cross-subsidy approach to estate regeneration has been the dominant model of estate regeneration for the past two decades and looks set to continue under the Labour government. 

It is when council estates are demolished to make way for expensive properties which are put on the market or rented privately. In theory, the new private homes fund the construction of “affordable” homes on the sites. 

 

“As legal aid lawyers, we witness daily injustices stemming from the housing crisis. This research, for the first time, clearly demonstrates the damage caused by current “affordable” housing policies and the push for demolition, which disproportionately affects many of our brave, working-class clients” said PILC’s legal caseworker and community legal organiser Saskia O’Hara.  

 

Challenging the narrative 

 

The new Labour government and the Greater London Authority maintain that cross-subsidy models are the answer to the housing crisis. However this report shows that it is making it worse. 

 

“The findings from this report evidence the urgent need for a fundamental rethink of estate regeneration in London” said Dr Joe Penny who wrote the report.  

 

“The current cross-subsidy model is badly failing council and social housing tenants, as well as those on housing waiting lists. Truly affordable homes – that is, homes that cost no more than 30% of net household incomes – are not being replaced in sufficient quantities; social and affordable rents are increasing beyond what those on the lowest incomes can afford; and structurally sound buildings are being wasted amid a deepening housing emergency.” 

 

Using the evidence in the fight for affordable housing 

 

To make the evidence as accessible as possible, PILC have created a short illustrated guide to the report and a video highlighting the top 5 things you need to know about council house building in London.  

 

These resources are designed to empower residents facing displacement from demolition of their housing estate and communities facing gentrification because of regeneration plans to challenge the plans with hard facts. 

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We’ve been active in supporting local residents and grassroots campaigns to challenge injustice from gentrification for many years. |We use the law as a tool to assist, support and empower communities at the frontline of gentrification. 

We work to support local residents and campaigns to shift the power balance away from demolition and cross-subsidy regeneration back to the people who live there. 

As movement lawyers, we seek to be on the ground with campaigners, offering legal services as just one tool or tactic amongst others in a campaign. 

 

Download What Golden Era: A guide to help challenge estate demolition plans with hard facts. 

 

Download The promise of cross-subsidy: Why estate demolition cannot solve London’s housing emergency. 

 

Watch What Golden Era? 5 things you need to know about council house building in London. 

 

Tonight's Brent Council motion on housing fails to commit to council housing

 Labour Chancellor Rachel Reeves today announced the reinstatement of mandatory housing targets on local authorities and changes in planning laws in favour of development, including a review of  land designated as green belt as well as  use brownfield and grey belt sites.

She indicated that local communities will only have a limited say (my emphasis):

It will still be in the first instance up to local communities and local authorities to decide where housing is built, but we will bring back those mandatory housing targets..it will be up to local communities where housing is built but it has to be built.

Clearly in areas like Brent, where available land is at a premium, there is likely to be pressure on some of our green spaces. Readers will remember plans to build on the Garden Centre land at the Welsh Harp at Birchen Grove, and the glass house land in Cool Oak Lane. The plans were defeated by a local campaign.

There was no mention in accounts of Reeves' statement that I have read, about the building of council homes. Similarly, a motion put by Brent Planning Committee member Cllr Liz Dixon to tonight's Council Meeting, written before the result of the General Election was known, but reflecting the Labour Manifesto, mentions 'affordable housing' without defining it, and does not mention council housing.

This reflects Cllr Shama Tatler's emphasis on building a range of home types, many of which would not be affordable for local people. Whether taking on the Building New Council Homes remit from Cllr Promise Knight, who is on maternity leave, will change her stance remains to be seen. Certainly her belief in the market: that more homes of any type will increase supply and lower prices, is challenged by some of her fellow councillors, who point to the distortions in the market caused by land banking and foreign investors' acquisition of new homes.

Tonight's meeting will also note the answers to questions to the Cabinet which includes Cllr Butt's advice to to evicted Brent tenants to move out of Brent to areas where rent is lower.

This is Cllr Dixon's Motion:

Declaration of a Housing Emergency

 

This Council notes:

 

* London is the epicentre of the country’s housing crisis, with a quarter of Londoners living in poverty after paying for their homes.

* In one of the wealthiest cities in the world, more than one child in every classroom is homeless and living in temporary accommodation, while rough sleeping is up 50% over this decade.

* Councils in London are spending £90m per month on temporary accommodation for homeless people - up almost 40% on last year.

*The dream of homeownership is out of reach for young people. The government have failed to act despite the housing crisis acting as one of the country’s biggest barriers to growth.

*The government has spent billions of pounds on housing benefit every year, which goes into the pockets of private landlords without creating any new assets.

*Without intervention, the number of new affordable homes built will fall sharply in  coming years thanks to high interest rates and runaway construction cost inflation.

 

This Council further notes:

 

*The Housing Needs Service in Brent has seen a 12% increase in homelessness approaches in 2023/-24 (7,300) compared to 2022/-23 (6,529). The total number of homeless families living in B&B and Annexe accommodation has risen to 485.

*Many Councils are being forced to book rooms in commercial hotels to meet statutory duties. In Brent this has driven a £13.4m overspend. These issues are not unique to Brent and have impacted the whole of the country – but especially London.

* There are 5,688 households in A-C banding on the waiting list. At Band C, the average waiting time for a 2-bed home is 8 years, with a 4-bed home rising to 24 years.

*GLA grant funding per unit of affordable housing is approx. £195k, with typical build costs per average unit in the region of £450k. Brent Council has planning permission ready or has submitted applications for 423 more affordable units, but many face a significant funding gap, and will not be viable without an increase in available subsidy.

 

This Council welcomes:

 

Pledges made during the current election campaign:

 

*To update the National Policy Planning Framework, including restoring mandatory housing targets.

*To get Britain building again, creating jobs across England with 1.5 million new homes over the next parliament.

*To work with local authorities to reform Local Plans and strengthen the planning presumption in favour of sustainable development, supported by additional planning officers.

 

This Council resolves to:

 

(1) Work with other local authorities in London that have declared a housing emergency to calling on the incoming government to unlock the funding needed to deliver the affordable homes Brent desperately needs.

 

(2) Write to the Secretary of State to recommend the following steps:

 

*The suspension of the right-to-buy discount.

*A new Housing Revenue Account funding settlement to increase the supply of housing, improve standards and support retrofitting.

*Financial support to immediately purchase more homes from private landlords.

*To review the Local Housing Allowance available for Temporary Accommodation.

 

Cllr Liz Dixon

Dollis Hill Ward

It is important to note the reference to viability as the remaining elements of the South Kilburn regeneration looks increasingly in doubt and the St Raphaels plans have been much reduced.

Leasehold reform, Shared Ownership issues, a rent cap, builders' responsiblity to fund fire safety work, including cladding remediation are issues still to be addressed in the ear;y days of this government.

Cllr Tatler taken to task on regeneration issues

 Tuesday's Resources and Public Realm Committee was the swan song of the Committee as it was the last one of the municipal year and it may well have new members and chair after the Council AGM.

I may put the kibosh on the present committee if I say that in my opinion this would be a pity as it has developed its skills over the last year and Cllr Rita Conneely has proved a formidable chair. It takes time for councillors to undergo training and increase their confidence at holding lead members to account.

Cllr Shama Tatler, with the regeneration and planning brief, was in the hot seat on Tuesday and faced some tough questions.

The issue of the viability of both private and public developments was a major theme in the light of the post-Truss financial situation with its high interest rates and reduction in confidence, inflation, shortage of labour post-Brexit and supply-chain problems. In addition the post-Grenfell need (rightly) for second staircases in tall buildings has meant that developments have had to be reviewed.

Cllr Tatler explained how as a result the amount of units for sale might have to be increased and affordable housing reduced, tenure cmay be hanged to include more 'intermediate# housing (often shared ownership) or alternative sources of funding sought.

A note of realism was introduced early in the meeting when Pete Firmin, a South Kilburn resident, spoke about the problems with the regeneration of the South Kilburn estate including poor quality new housing, scaffolding up around relatively new blocks and problems of incursions into blocks where tenants had been decanted. His contribution and Cllr Tatler's response can be seen in the video at the top of the page along with some of the other exchanges reported here.

Cllr Anton Georgiou brought up tenure on the new South Kilburn blocks. saying that he had been told that they were not at social rent as Cllr Tatler claimed but at the higher London Affordable Rent. He promised to produce evidence to this effect.

Improvements in infrastructure was an issue in Alperton regeneration as it lagged behind the building of new blocks. He gave the example of improvements to Alperton Station needed by the new residents in car-free developments.

Cllr Tatler said it was often difficult to get the improvements in place because of the need to work with partners such as TfL, regarding the station and the NHS regarding the promised medical centre on South Kilburn, and things moved slowly.

She pointed out that it was pivate housing that yielded Strategic Community Infrastructure levy in regeneration areas - Council housing did not qualify.

The need for more affordable social housing was another major themes. Committee chair Cllr Rita Conneely said, 'That is what we want as a committee, what backbenchers want and what residents want.'

She urged Cllr Tatler and the Regeneration Department to challenge developers more ('Let's say no, let's start saying no!' ) and for London councils to get together a common front to stop developers' divide and rule. 'Whatever you bring back to use, we will want more.'

 Cllr Tatler had said, 'We can't say no to developers', but Gerry Ansell who earlier had said, 'we can't walk away from  developers' pointed out that the Planning Committee could say no and reject applications. That as we know happens seldom and Planning Committee members are reminded of the need for housing at the start of each meeting and are also warned that an Appeal by a developer would cost the council money.

Shama Tatler pointed out that there was already a London-wide body in the form of the GLA and that as Local Plans began to more closely mirror the London Plan there would be more consistency across London.

She went on:

It is wrong to say we don't challenge developers. Mo (Cllr Muhammed Butt, leader of Brent Council) and I have conversations day in, day out, with developers about what our red lines are. This is why we get criticised for having too many high blocks. I will have high blocks if it means we are getting as much affordable housing in a scheme as possible.

The committee, following a point raised by Pete Firmin, said that community spaces in regeneration areas needed to be publicly owned rather than belong to the developer.

The meeting finished with Cllr Tatler agreeing to meet with concerned residents in regeneration areas.

 Note: It was a very long meeting. The full webcast is HERE

Following comments on this article here is a link to the latest ONS (Office of National Statistics) data on rent levels and house prices in Brent. Main findings in the image. For links to each go to: 

 https://www.ons.gov.uk/visualisations/housingpriceslocal/E09000005/

 

Wembley Housing Zone – Brent’s Cecil Avenue development downsized!

 Guest post by Philip Grant in a personal capacity

 

Revised East and South elevation drawings for Brent’s Cecil Avenue development.

 

It may not look any smaller, but as disclosed in the Affordable Housing Supply Update report to December’s Brent Cabinet meeting, the number of homes to be built on the Council’s Cecil Avenue development has been reduced. The reason is the need for second staircases, because of new fire regulations introduced as a result of the Grenfell Tower tragedy.

 

I mentioned this in a guest post last month, Brent’s Affordable Council Housing – open and transparent?, when I wrote: ‘the report does not say how many of the new figure of 237 homes will be for private sale, and how many of those left for the Council will now be for “genuinely affordable” rent, rather than shared ownership. A lack of openness, which I will try to remedy!’ 

 

I’ve now received a reply to a Freedom of Information request, and can provide the answer. Cecil Avenue is part of a wider Wembley Housing Zone (“WHZ”) project, together with Ujima House, on the opposite side of the High Road. Brent Council’s contract with Wates in March 2023, said each would have half (152 out of 304) of the WHZ homes. However, all of the Wates homes, for private sale, would be on the more desirable Cecil Avenue site. 

 

The revised split of the Cecil Avenue homes, from Brent’s 8 January FoI response.

 

These figures show that although there will now be thirteen fewer homes on the Cecil Avenue development, those going to Wates will only be 2 less, while Brent Council loses 11. This is partly compensated for by the revised proportion of family-sized homes going in Brent’s favour. The Council will now have 71.4% of the family-sized homes, rather than 68.75%, but the total number of family-sized homes at Cecil Avenue has been reduced from 64 to 42, as part of rearranging the unit sizes to fit in the staircases.

 

Surely these changes would need planning permission? They did! An application was submitted on 21 August 2023, but Brent’s planners treated it as “non-material” amendments to the original consent given in February 2021, so that it was not publicised or consulted on. The application was approved by the Delegated Team Manager on 30 October 2023.

 

The heading to the Delegated Planning report, October 2023.

 

The report on this application (23/2774) makes clear that despite the WHZ involving two sites and a combined building contract, for planning purposes the Cecil Avenue application must be looked at on its own. Brent’s planning policies require that large housing schemes, such as this one, should provide 50% affordable housing. These revised proposals only provide 36.7% (and only 48.5% if the whole WHZ scheme is taken together). If it had been 50% at Cecil Avenue, there should have been at least 118 affordable homes on the site, not just 87 out of 237.

 

Brent’s affordable housing planning policies require a tenure split of at least 70% of the affordable housing to be “genuinely affordable”. The 56 homes at London Affordable Rent (“LAR”) out of 87 “affordable” Council homes is only 64.4% (62.4% over the WHZ scheme as a whole). Despite not meeting either of Brent’s planning policy percentages for affordable homes, the amended application was accepted. 

 

The only “good news” this time is that 21 of the 28 family-sized homes for Council tenants at LAR (down from 35 family-sized, on the figures supplied to me last July) will be 4-bedroom homes, with private gardens. There is currently a desperate need for these large family homes for affordable rent in the borough. It is unfortunate that, because of more than two years delay by Brent Council, in going down the “developer partner” route, it will be nearly three years before these homes are actually available! And LAR rent figures exclude service charges, which could bring the total bill up to as much as 80% of local open market rent level.

 

Extract from the approved documents for the amended application 23/2774.

 

35.6% of the “affordable” Council homes at Cecil Avenue will be what is known as Intermediate homes. This is a summary of what these 31 homes comprise:

 

Extract from the approved documents for the amended application 23/2774.

 

As shown in the information provided to me above, 28 of these homes will be for shared ownership (despite there being a surplus of these in the borough, it not being affordable to most people in housing need – a household income of £60k a year required to afford a 1-bedroom flat - and shared ownership being a “scam”!). What about the 3 “other affordable” homes? The planning application documents show that these Brent Council homes are intended to be sold, by Wates, as Discount Market Sale (”DMS”) homes.

 

The DMS homes must be ‘offered to Eligible Purchasers for sale at a price that is no more than 80 (eighty) per cent of Open Market Value, with the Council retaining and holding the remaining equity under an equitable charge’. To be an eligible purchaser for one of these 1 or 2-bedroom flats you would (on current figures) need to have an annual household income of no more than £90k. Affordable?

 

It is not just the number of homes (and affordable homes) which has been downsized in the amended plans for the Cecil Avenue development. In his reply to an email I had sent him about the Council’s Cecil Avenue development in February 2022 (that’s nearly 2 years ago!), Cllr. Muhammed Butt spoke proudly of ‘a new publicly accessible open space during this latest development. A positive outcome for the residents of Brent.’

 

My guest post including his reply did concede that: ‘The approved plans for the Cecil Avenue site include a courtyard garden square. This would mainly be for the benefit of residents, but there would be public access to it, through an archway from Wembley High Road.’ All of the tower block developments, existing and planned, along this stretch of the High Road, will bring thousands of extra residents within a short walk of this ‘publicly accessible open space.’ However, that too has been downsized:

 

Paragraph from the Delegated Planning Report on application 23/2774.

 

The amended external amenity space may just ‘exceed the minimum requirement’ for play space needed by the reduced number of future occupants at Cecil Avenue, but there will be little to spare for the other ‘residents of Brent’. 

 

Delay and downsizing. What more can go wrong for a Brent Council housing scheme, on Council-owned land, which received full planning consent on 5 February 2021? If only Brent had got on and borrowed the funds to build it, at the very low interest rates at then, and hired a contractor straight away, they could have had 250 (or at least 237) affordable Council homes at Cecil Avenue available in 2024, rather than 87 in late 2026.

 

Philip Grant.

Brent’s Affordable Council Housing – open and transparent?

Guest post by Philip Grant in a personal capacity

 

I’ve already written about the Morland Gardens parts of the Affordable Housing Supply Update report to next week’s (11 December 2023) Cabinet meeting, and Martin has also posted a blog about the temporary accommodation proposals in its South Kilburn section. In this article I will cover some of the other points that caught my eye from that report.

 

I am not seeking to underestimate the “challenges” which the Council faces over meeting current housing needs, particularly over the shortage of Central Government funding, rising construction costs and higher interest rates since the disastrous mini-budget during the short-lived Truss premiership. Brent has aimed to do more over housing than many other London Councils, and the recommendations in this report include to ‘approve the use of usable Capital reserves to fund’ the New Council Homes Programme (“NCHP”), and to provide extra resources to tackle the current temporary accommodation crisis. 

 

A recent feature of such reports is a “Cabinet Member Foreword” (though whether these are written by the Lead Members, or for them by a Council Officer, is unclear). I was struck by these words from this Foreword’s para. 3.5: ‘this report emphasises the importance of being open and transparent with all ….’ I agree that openness and transparency are very important, but does this report deliver on those words?

 

In the report, are the Council being honest about what they have achieved so far? The Cabinet Member for Housing says: ‘we are on track to meet our target of 5,000 homes by 2028’. When the NCHP target was first launched five years ago, the aim was 5,000 affordable homes built in the borough between April 2019 and March 2024 inclusive. As part of that aim, the Council set itself ‘a strategic target of delivering 1,000 new council homes at genuinely affordable rent by 31 March 2024.’ So, they’ve missed that target, and replaced it with another!

 

 

Table 1 in the report (above), which should be accurate because the “numbers” have been “cleansed”, shows that 3,901 affordable homes will have been finished in the borough in the five years to March 2024 (although the “by tenure” column totals 3,943! - see my corrections in red). 812 of those are shown as delivered by Brent Council. But only 560 (those described as “General Needs”) of the new Council homes will be “genuinely affordable”, and of those 235 were for existing Council tenants being moved from older blocks due to be demolished. 

 

The affordable homes provided by RPs (Registered Providers of social housing, such as Housing Associations) make up 3,089 of the 3,901 total, but only 940 of those homes appear to be “genuinely affordable”. That is just over 30% of the total, with the rest being “intermediate” homes, such as shared ownership. Although most of these will have received planning consent before Brent’s Local Plan came into force in February 2022, that is the opposite of the tenure split for affordable housing which is now supposed to apply: 70% genuinely affordable and no more than 30% “intermediate” affordable housing.

 

More details about the types of “affordable housing” can be found in an article, Brent’s Affordable Council Housing – figuring out Cllr. Butt’s reply, which I wrote after a previous Cabinet update in November 2022.

 

The report has a section headed “Schemes on site and in main works contract”, and there are two schemes in particular from this that I would draw attention to. The first of these is Watling Gardens, the Council’s positive publicity over the start of work on which was mentioned in another article on Brent’s Council housing in October.

 

 

While the report says that this scheme ‘is currently on track’, it would cost more than the £38.5m which Brent’s Cabinet approved as the contract award price in June 2022. Brent’s answer is to issue an instruction that the project must be “value engineered”. What does that mean? It means that it will still have to built as planned, but using some materials which are less expensive than those originally intended. Previous examples of “value engineering” which come to mind are the use of reinforced autoclaved aerated concrete (RAAC) in some public buildings during cost saving measures in the 1960s to 1980s, and the £300k “saved” by using cheaper cladding when Grenfell Tower was being refurbished!

 

The stage and TV drama, where all the words were taken directly from Inquiry transcripts!

 

I’m not trying to suggest that the cost saving at Watling Gardens would result in anything as life-threatening as Grenfell Tower, but in the interests of transparency the public, and particularly future residents of the development (including those whose homes were demolished with the promise of a replacement there), deserve to be told what cheaper materials will be used as part of this “value engineering”.

 

I have written about Brent’s Wembley Housing Zone project on a number of occasions, including about the extra GLA funding it received, and about the 152 out of 250 homes on the former Copland School site at Cecil Avenue which Brent’s “developer partner” will get for private sale, rather than being Council homes for Brent people in housing need. The report now says there will be less than 250 homes, because of the need for extra staircases, as a result of fire safety changes following the Grenfell Tower Inquiry.

 

 

I’m pleased to see that Brent appears to have learned one lesson from Morland Gardens (the need to begin work before planning consent expires), but why has it taken nearly three years to get to this stage? However, the report does not say how many of the new figure of 237 homes will be for private sale, and how many of those left for the Council will now be for “genuinely affordable” rent, rather than shared ownership. A lack of openness, which I will try to remedy!

 

You need to read to the end of the report, on page 21, to find out what it means by ‘the importance of being open and transparent’, which I quoted near the start of this article. It appears that, to Brent Council and its Cabinet, this is more to do with the messages it gives out, rather than a commitment to being genuinely open and transparent about everything:

 

 

In other words, it is the usual “spin” that Brent Council puts out, either only sharing “good news” stories (usually with the Leader and/or one of his Cabinet colleagues getting the credit for something positive) or giving the reasons (excuses?) for why they can’t do what they had originally promised to deliver.

Philip Grant

 

Kilburn Square – Brent planners seek to reduce Affordable Housing by stealth

 Guest post by Philip Grant in a personal capacity

The recent guest post by the Chair of Kilburn Village Residents’ Association, Kilburn Square – Decision time (Chapter One) is finally here this Wednesday, ends with a reference to a future decision which will have to be made if planning permission for Brent Council’s proposed scheme is approved. But if Planning Officers get their way, there will be no Chapter Two.

 

Martin’s earlier blog about the various Brent infill housing applications on the agenda for Wednesday evening’s Planning Committee meeting, Say after me, 'The benefits of the scheme outweigh the harm/impact/conflict with policy', showed how Brent’s Planning Officers are using claimed “public benefits” to justify ignoring any objection points against the applications they are recommending should be accepted.

 

The main “public benefit” which they say would ‘far outweigh any harm’ on the Kilburn Square application (despite the many valid objection points set out in the KVRA Chair’s recent article) is that the proposed 139 new homes would all be affordable housing. That is what the application’s Affordable Housing Statement (Final) says, despite Brent’s Cabinet giving the green light to some of them being "converted" to shared ownership or even outright sale at its meeting in November 2022.

 

The rent details from the application’s Affordable Housing Statement (Final)

 

The affordable housing proposed in the Kilburn Square application is 99 "general needs" homes at the genuinely affordable London Affordable Rent ("LAR") level, and 40 New Accommodation for Independent Living ("NAIL") flats at the "intermediate" Local Housing Allowance rent level.

 

Other local Brent housing estate applications (Watling Gardens and Windmill Court) approved in 2022, under the current Brent Local Plan policies, also showed that all of their new homes would be for genuinely affordable housing (LAR, or Social Rent level for returning existing tenants). The affordable housing condition (Condition 3) in their planning consent letters made clear that 100% of the homes would be affordable housing, as set out in those applications. The reason given for this condition was: 'In the interests of proper planning.'

 

There have been no changes in planning policy or law since those consents were issued in April 2022, so the position should be the same for Kilburn Square.

 

However, if you look closely at the proposed Condition 3 in the draft decision notice, tucked away at the end of the Planning Officers’ Committee Report for Kilburn Square, it says:

 

'The development hereby approved shall contain 139 residential dwellings. A minimum of 50 % of those dwellings (measured by habitable room or number of homes) shall be provided as Affordable housing ....'

 

I submitted an objection to this proposed condition, and I will ask Martin to attach a copy of the pdf version of it (which I submitted online, and emailed to the three key Planning Officers - Head of Planning, Development Management Manager and Case Officer – on Sunday evening) at the foot of this article, for anyone to read if they are interested. 

 

I also objected to a weird Condition 4 in the draft decision notice, also concerning affordable housing, for which there was no mention or explanation of in the body of the Committee Report:

 

The opening part of the proposed Condition 4 from the draft decision notice.

 

If the application is approved on Wednesday, as recommended by Planning Officers, allowing affordable housing Condition 3 to stand would totally undermine the "public benefits" which the application is meant to provide. 

 

A minimum of 50% of the proposed new homes would be 70, leaving 69 which Brent's New Council Homes team could "convert" away from genuinely affordable LAR rent to local people in housing need. They could even be “converted” from affordable housing to private sale, leaving as few as 30 of the 99 “general needs” homes at LAR rent level, promised by the application, actually delivered by Brent Council’s Kilburn Square project.

 

What is equally as bad is that Planning Officers are trying to do this "by the back door". When Brent wanted to "convert" some of the Watling Gardens LAR homes to shared ownership, they had to make a fresh planning application to change Condition 3 in the 100% affordable housing consent they'd received for the scheme.

 

My objection is seeking to have Condition 3 of the planning consent, if Planning Committee approve the plans, require that 100% of the 139 homes should be affordable housing, as set out in the application itself. 

 

I am also seeking that the Condition(s) should include a requirement that any change the applicant (Brent Council!) wishes to make to that affordable housing condition should be made by way of a “material change” application under Section 73, Town and Country Planning Act 1990. That type of application requires public consultation (so the chance to object), and detailed consideration of the reasons and evidence given for seeking a change.

 

I had drawn attention to the discrepancy between what the Kilburn Square application promised for affordable housing and the November 2022 Cabinet decision on “conversion” of units from LAR last February (Kilburn Square – Brent must come clean on affordable housing!). When Brent’s planning agent did not submit revised affordable housing details, Brent’s Head of Planning promised that the application would be ‘considered as submitted’. 

 

This should have meant that the affordable housing condition would specify 100% affordable housing. To change that, by stealth, to ‘a minimum of 50% affordable housing’ feels like a dirty trick, which Brent’s Planning Officers should be ashamed of!

 

Philip Grant