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.

 

 

Difficulties with South Kilburn redevelopment?

We know that rising costs of regeneration schemes in the pipeline have led to proposals for changes in tenure. There is a clue to possible similar problems in South Kilburn in the last paragraph of the Finance Report going to Cabinet on Monday morning that follows information on slippages totalling £16.2m.

South Kilburn

South Kilburn has a budget variance of £16.2m, owing to slippage.

There is a £5.2m slippage due to acquisitions being forecast in future years primarily on Austen House and Blake Court. A £4.9m SCIL contribution from the NWCC projects will not be used within the financial year. There is a £4m slippage on the Carlton and Granville project, the project has moved into the construction phase after procurement and the forecast now reflects a more realistic schedule. There is slippage of £1m on the District Energy Network
project which will be used in future years due to the concept design being reworked to meet the amended requirements of the London Plan. There is also a £1.1m slippage on the infrastructure works at Peel and Carlton Vale Boulevard.

Risk and Uncertainties

The mixed-use nature of the scheme relies on developers making the schemes viable and providing the affordable housing alongside the private units. Possible difficulties with high inflation could make this more difficult, so the programme is reviewed regularly to ascertain the potential impact on future phases.

SHARED OWNERSHIP – Let’s have a debate!

Guest post by Philip Grant in a personal capacity

 

 

By the time you read this, item 13 on Monday evening’s Full Council meeting will probably have happened. Martin has already shared a copy of the motion on “Building the Homes our Community Needs”, put forward by Lib Dem councillor Anton Georgiou, which deals with affordable housing, and whether Brent Council should make some of its New Council Homes shared ownership properties, rather than for letting at genuinely affordable rents. 

 

It is certainly ‘an issue of relevance to Brent’, but the chances are that it won’t get a proper debate on the actual issues the motion raises. Although this is a meeting of all the councillors, who are supposed to represent the views of the residents in their Wards, across the borough, what will be played out is a game of party politics.

 

A small extract from the Labour Group amendment to Cllr. Georgiou’s motion.

 

When the agenda for the meeting was updated on Monday, it included an amendment to the motion by the Labour Group. The word ‘amendment’ is perhaps an understatement (see extract where red = Labour). Although I suspect that few Labour Group members were consulted over it (perhaps just the Leader and a couple of Cabinet members?), it is likely they will be “whipped” to support the many amendments, then to vote for the amended motion.

 

The amendments have been proposed to change the motion completely, so that it promotes the policies which the Cabinet adopted on 14 November. I set out many of these in a guest blog on 11 November, “Brent’s New Affordable Council Homes promises shredded!”, and Martin’s blog on 14 November, and comments on it, give a flavour of what happened when the Cabinet approved the recommendations of the “Update on the supply of New Affordable Homes” report, without any noticeable discussion of it.

 

 

One of the key issues in all this is whether Brent Council should “convert” some of the affordable housing it plans to build from the “genuinely affordable” London Affordable Rent to shared ownership homes. That is something which does need a proper debate, which it won’t get at a Brent Council meeting, so I’m offering this opportunity for you to have your say. Here are the two versions of the shared ownership issue, from the motion and the proposed amendment to it. 

 

Proposal 1:

 

This Council believes: Shared Ownership schemes are not a ‘genuinely affordable’ housing model and are not something that should be promoted by Brent.

 

This Council resolves to: Ensure all new developments taking place on existing estates within our borough must be seeking to provide more Social Housing and not Shared Ownership or Market Sale units.

 

Proposal 2:

 

This Council believes: Shared Ownership schemes are not a top priority for Brent Council, but do form a valuable part of an overall housing mix, as they allow some people to get onto the housing ladder when they otherwise would not be able to afford a full deposit.

 

This Council resolves to: Continue to work with the GLA and DLUHC to secure the funding needed to ensure all new developments must seek to provide as much social housing as is financially viable.

 

If you have a view on whether Brent should provide some shared ownership homes, rather than those homes being for affordable rent to Council tenants, please share it in the comments below. Even if you are a member of a political party, please just give your personal views. 

 

You can just “vote”, for Proposal 1 or Proposal 2, if you wish. You don’t have to give your reasons, although it would help to properly understand how Brent residents feel about this subject if you do.

 

You can comment as “Anonymous”, although if you do, it would help if you can give some indication of what angle your view is coming from. But please comment honestly, so that we can have a proper debate on ‘an issue of relevance to Brent.’ Thank you.

 

The Labour Group amendment was submitted by Cllr Shama Tatler, Kingsbury ward.

 

The full Labour Amendment in red and black is HERE, 

Philip Grant.

 

Call for Brent Council to deliver more council homes for social tenants and end confusion over their use of the term 'affordable'

 

Wembley Matters has consistently raised the issue of Brent Council's obfuscation of the term 'affordable housing' and the need for clarity in the use of the term was highlighted recently by Cllr Rita Conneely, Chair of Scrutiny.

The issue has become more prominent as a result of the Council's intention to change the tenure of many of its planned infill housing on the council's own estates  to shared ownership and open market sale.  Brent Council's CEO, when denying that the council was building any shared ownership homes, has recently confirmed that shared ownership is not affordable for most Brent residents in need of housing.

Cllr Anton Georgiou (Alperton)  has tabled a motion for debate at Monday's Full Council Council meeting that seeks clarity on the use of terminology, but much more importantly a commitment that projects on estates should be  seeking to provide genuinely affordable social housing and not shared ownership or open market sale.

The Motion

Building the Homes our Community Needs

This Council notes:

The pressures on Council Housing stock are immense and will not ease in the coming months and years, rather they will grow even more.

The Cost of Living Crisis, coupled with the disastrous macroeconomic situation in the UK, means it is increasingly likely that more local residents will turn to the Council to assume responsibility for their housing needs. As an authority, we need to be prepared for this.

Whilst we are grateful that Brent has made progress in seeking to supply Council Homes we need to see greater, more urgent resolve to deliver more Council Homes for Social tenants.

The latest report to Cabinet, entitled, ‘Update on the supply of New Affordable Homes’, sets out where Brent is when it comes to the delivery of the New Council Homes Programme (NCHP).

On the 14th November, the Cabinet was asked to formalise a change of approach that would allow Brent Council to deliver only 50% of new stock at Council Rent and London Affordable Rent level in its own developments. While this approach will deliver some Social Housing on Council owned land, this will be at the expense of current Estate residents, reduction of amenity space, and will not achieve our overriding ambition to reduce the ever-growing housing waiting list in a meaningful way. Council Land will be de-facto used to build housing out of reach for most Brent residents.

There are also a growing number of local people in our area, who have been life-long residents of Brent and who are now being priced out of the borough, because housing is too expensive.

Developers, who are granted consent for their private schemes by Brent’s Planning Committee, are not providing our area with the type of housing our community desperately needs.

This Council believes:

 

1.    There needs to be greater clarity on terminology around housing, particularly what constitutes being ‘genuinely affordable housing’.

2. Targets and policy around house building, must be focused on seeking to reduce the housing waiting list and reduce the number of local people currently in temporary accommodation

3. Shared Ownership schemes are not a ‘genuinely affordable’ housing model and are not something that should be promoted by Brent

4. We need to be holding developers accountable and ensuring that a greater proportion of new stock built in our borough is genuinely affordable for local people

This Council resolves to:

1. Guarantee that the banner term ‘affordable housing’ is not used in communications, and instead council communications only refer to “genuinely affordable housing”.

2. Amend the Local Plan to ensure Affordable Housing is defined as being purely Council Rent, London Affordable Rent, London Living Rent, which would exclude Shared Ownership and Affordable Rent (below or equal to 80% of market value rent).

3. Ensure all new developments taking place on existing estates within our borough must be seeking to provide more Social Housing and not Shared Ownership or Market Sale units.

4. Increase the target of affordable units within private developments to match neighbouring Camden at 50%, with a split of 40% social rent and 60% others, in order to ensure we are building the homes our community really needs.

Loss of green space and tenure change are issues in Rokesby Place application that Planning Committee must discuss

 

Two 4-bedroom houses are planned for this site (Site A)

Many issues have arisen over Brent Council's plans for infill housing in its council estates but the two main ones have been loss of green space and trees to the detriment of existing residents and the proposed tenure of the new developments.  

The Brent Planning Committee will consider the Brent Council planning application on Wednesday August 17th at 6pm. I understand that are likely to be representations from residents and a local councillor. The webcast can be viewed live HERE.

Both issues are involved in the proposal for infill  at Rokesbury Place in Harrow where two four-bedroom houses are proposed on the site above at the end of a dead-end street. The tenure of the houses has been changed from the Social Rent originally proposed to London Affordable Rent.

The proposal would remove three mature trees and reduce the green space, used for leisure, and parking.

These trees are to be removed:

Birch

Cherry

 

 

Lime

 

Planning Officers have recommended approval of the proposal and say: 

Whilst it is noted that there is a part loss of the existing grassed space, (next to 34 Rokesby Place) the scheme would provide a new communal amenity space next to the new homes and enhancement to the remaining space within site B (next to 31 Rokesby Place) including new drying facilities. The benefits of the scheme to provide two new affordable family sized homes would be considered to outweigh the harm of any loss of existing green space as discussed within para 67-69 below (see report)

 

An area of approximately 160 sqm of green space is proposed to be changed to hard surfacing to accommodate the enhanced turning head and the parking spaces within site B. Site A has landscaped areas at either end of the car park, with a total area of approximately 145 sqm. These will be removed, but a new communal landscaped area of approximately 80 sqm will be re-provided. It is acknowledged that it is possible that some residents may be currently using some of the grassed area for recreational functions, and that this may have some local value despite not falling within the boundaries of a designated public open space. (My emphasis)

 

Policy DMP1 seeks to retain existing green infrastructure including open space, high amenity trees and landscape features, and providing appropriate additional or enhancements where possible. Where the loss of open space is proposed, this would be required to be balanced against the benefits of the proposal. While the loss of the green space is acknowledged, the scheme would deliver the provision of two affordable family sized homes within the Borough for which there is an identified need. This is considered to outweigh the harm, particularly given the proximity to Barham Park which provides a large area of open space in very close proximity and access to this park would remain unrestricted for nearby residents. On balance, the loss of this green space is outweighed by the benefits of the scheme as a whole, including the delivery of two affordable family sized homes.

  A objector from Copland Avenue points out:

On the previous application in 2015, the Tree Officer appraised the two trees to the rear of the site (Bird Cherry T2 and Lime T3) and provided root protection recommendations (in fact the cherry is a prunus lusitanica, a tree with an Award of Garden Merit which produces food for pollinators and berries for birds). That report stated ..." the retention of trees identified as T2 and T3 is recommended as this will enhance the screening between the new houses and the adjacent gardens. The retention of existing groups of trees will be beneficial in maintaining the character and appearance of the site and locality as well". Additionally, in the final report of the 2015 application it stated, "One tree would be lost as a result of the proposal, however, a Bird Cherry and Lime which provide a valuable food source and attract various wildlife would remain on site". There doesn't appear to be a tree officer's report for this application, just a report by the developer which is not going to be impartial. These two valuable trees, plus a nice silver birch, are all to be sacrificed, it seems - heartbreaking! We strongly object to this. Surely Brent should adhere to its previous recommendation to retain these trees. We would also request a BAT survey has they are in our garden every summer.

 This is the overall plan for the Rokesby Place:

 

The applicant claims that when surveyed only one car was using the car park which appears to be disproved by this photograph from a resident:

Incidentally the building behind the car park, an extension to a Crawford Avenue house, is not shown in the application plans.

 

Work will also go on at the green space adjacent to 31 Rokesby Place. This is currently a green space with a washing drying area where residents have carried out planting. Cars are morked next to it but the council say this is a turning area. They claim 5 'new' car parking spaces are provided in the new design but this does not take account of the loss of spaces on the northern site or the spaces needed by the new houses. Objectors dismiss claims that residents could park on nearby streets.

 

 

Visiting this morning it was clear that this small, peaceful community really care for their estate as can be seen from the planting that has taken place outside the terrace of houses:

The second issue, previously high-lighted on Wembley Matters, and of particular significance to Watling Gardens, is the never-ending ambiguity around Brent Council's definition (or lack of it) of 'affordable housing.

The Brent Poverty Commission in the report adopted by Brent Council was clear:

The application form clearly stated that the tenure for these 4 bedroom  houses would be for Social Rent. LINK.

 

But Scedule B of the Officers' Report going to Planning Committee as the Letter of Approval states that tenure is London Affordable Rent  LINK :

 

However, the Planning Statement, prepared by Maddox Planning for Brent Council as the applicant, clearly states a proposed Social Rent LINK:
 

 

The justification for the harm this application will do to the existing residents of Rokesby Place is the benefit that two new four-bedroom Council homes will provide.

On the application form it was said that these new large family homes would be for Social Rent.

Social Rent was identified by the 2020 Brent Poverty Commission Report as the only genuinely affordable housing which the majority of families in housing need could afford, and the rent level which Brent Council should be aiming to provide its Council housing programme at.

But the proposed Condition 3, which the Officer Report recommends the Planning Committee should approve, has changed the tenure of these two homes to London Affordable Rent, which  is not what the application offered, and would not be affordable to most families on the Council's waiting list.

By making these two homes for London Affordable Rent, rather than Social Rent, it undermines the benefit which is supposed to justify this application. If Planning Committee is minded to accept the application, it should insist that Condition 3 be changed, so that the affordable housing is delivered as two Social Rent units, as originally set out in application 22/1400.

This is particularly important as these 4-bedroom houses are clearl meant for large families so rent level wil be particularly important for them - as the Poverty Commission recognised. 

Back in 2018 the Scrutiny New Developments Task Group on Affordable Housing LINK said:

Brent’s future housing strategy should be explicit about the need for social rent. It is not acceptable for the viability process to lead to a lack of social rented accommodation, but significant proportions of “affordable rent” and intermediate products such as shared ownership, when we know these simply are not genuinely affordable options for residents of the borough in housing need.

That is even truer today.