Granville and Carlton submission on the South Kilburn Masterplan

The following submission on the SDP Masterplan for South Kilburn has been made to Brent Council by the users of The Granville Plus Centre and The Carlton Centre who live, work and study in South Kilburn: (please  click at the end for the full article which is well worth reading)

Brent Council launched a consultation on its review of the South Kilburn Masterplan Supplementary Planning Document (SPD) in February 2017 which ends on the 30 March 2017. For this consultation the Council released a document over 180 pages long over 3 sections. The people from South Kilburn were given 6 weeks to comment on this document which lays out the plans for their homes, parks, health, education,small businesses, and community services in the area for the next 10 -15 years.

Each site is given 2 A4 pages in the document. The first half of the page gives the details about where the property is with the second half of the same page incorporating a short paragraph about each of these three issues: 'Description', 'Justification' and 'Design Principles'. The second page gives a vague shadow drawing of a huge block or blocks in the place of the current buildings.

There are repeated justifications for redevelopment; that the buildings are poorly built, internal design problems, or poor design and construction. Some of the justifications to tear down buildings are absurd such as "there is a lack of clarity about what is the front or the back of the property" (Crone and Zangwill) or the property "is currently in a prominent gateway position and the current development does not capitalise on this" (William Dunbar and William Saville Houses). Any idea of refurbishment is brushed aside as not viable. On the basis of this paltry and inadequate information people are expected to agree to a massive reconstruction of their lives. The end result is unclear. Certainly this document gives very little information about it. Further, much of the detail about the buildings in the document is inaccurate calling into question the accuracy of the whole document and its legal status.

We, the people of South Kilburn, reject this document for 2 reasons. Firstly, the bad process and secondly, loss of trust in what the Council are doing and why. With regard to the process, the length of the consultation coupled with the importance makes it unable to be agreed in the time period. To read the plans and think what they mean in this the time period is far too short. The vagueness of the document along with the inaccuracies make it virtually meaningless and allow the Council to do anything in South Kilburn, making any idea of a consultation farcical. Most important the vision is not the vision of the people of South Kilburn. It is an imposed vision whose prime purpose is to maximize housing.

South Kilburn Masterplan review ordered as project falls 12 months behind schedule and viability questioned

"The South Kilburn Regeneration programme has slipped behind schedule in 2015/16. There is a masterplan review of South Kilburn Regeneration; this means it is being fundamentally reviewed to determine how best to deliver the programme and realise benefits of regeneration for South Kilburn and for its businesses and residents. This review will reconsider the fundamental approach, including whether it is better for the council to retain the South Kilburn Housing Assets, or continue to dispose of them."

The above statement was included in the papers for the Full Council meeting last month and was a surprise for South Kilburn residents causing cconsiderable disquiet. 

As a result an information request was made to Brent Council to try and find out exactly what was going on. I would welcome comments from SK residents  on whether they feel any the wiser as a consequence of Richard Barrett's response. It would be interesting to know the additional costs that will be incurred by the review.

I am writing on behalf of the Kilburn branch of the Labour Party to request information relating to the regeneration programme in South Kilburn. Last year, I put in an FoI request about other aspects of the programme, and you kindly provided me with useful responses. I hope you will be able to do so on this occasion too.

The basis for my questions is a point in the budget report that was discussed at the full Council meeting on Monday. This is covered in section 14.5 (first bullet) of the report, as follows:

“The South Kilburn Regeneration programme has slipped behind schedule in 2015/16. There is a masterplan review of South Kilburn Regeneration; this means it is being fundamentally reviewed to determine how best to deliver the programme and realise benefits of regeneration for South Kilburn and for its businesses and residents. This review will reconsider the fundamental approach, including whether it is better for the council to retain the South Kilburn Housing Assets, or continue to dispose of them.”

I have searched through the Brent website, and have not found the information that I am seeking. I should therefore appreciate responses to the following:

·         What are the terms of reference of the masterplan review referred to in the above extract?

The intention is to appoint a Design Team to assist the Council review the adopted Master-plan and the current proposals for the remainder of the programme. It will seek to understand whether the principles established in the original Master-plan need to be altered or not given the passage of time and taking into account the schemes already delivered. The review will also look at the scope of the Master-plan and factoring in any relevant new legislation and guidance ensure the programme remains viable; as such it will also look at all sites within the South Kilburn area to consider inclusion or exclusion within the overall Master-Plan. The brief is currently being worked up by officers but when it is ready to go out to market it will be made available to the public via the London Tender Portal 

·         What is the timescale of the review?

It is hoped to go out to market to seek expressions of interest from Architectural Practices in March, appoint, subject to Cabinet approval, by May with a likely consultation process and report back to Cabinet toward the end of 2016 or early 2017 at the latest. This indicative timescale is subject to Cabinet Timetable availability and it is also likely that the Master-Plan will be placed before Planning Committee alongside a proposed SPD for the area.

·         Will there be a consultation of local residents and other interested parties as part of the review? If so, what form will this take?

Absolutely. It is intended there will be a series of consultation events/workshops with local residents, tenants and stakeholders. The most likely format will be drop-in meetings but may also include questionnaires. The final form of consultations will be agreed with the appointed Practice but it will be a specific requirement of any bid to conduct consultation.

·         How far behind schedule has the regeneration programme slipped? What are the implications for the remaining phases of the programme?

The programme has slipped due to external factors such as the safeguarding of Salusbury Road site by HS2 since 2012 and other factors, such as specific project delays on site. This, in turn, has pushed the programme out of kilter by having a knock-on effect on future phases. Some individual projects remain on target but overall the programme has extended by at least twelve months. The intention is that the Master-plan Review will seek to see whether there is any ability to recover this time by reconfiguring the remaining programme. The Master-Plan review will also incorporate a refresh of the financial viability of the scheme. No implications have been identified apart from the obvious prolongation of the programme and the resultant delay in tenants moving into new accommodation.

·         What criteria and methodology will the review use to decide whether to retain the South Kilburn Housing assets?

I note the extract provided by this FoI from the Budget Report but would advise that the Master-Plan Review will not be the vehicle for determining whether the Council disposes or retains assets as they are developed. I am sure the Review will be used to assist in the consideration of this query but it is more likely something that will be considered by the Council’s Investment Board and reported back to Cabinet for decision as appropriate.

·         Whether and how does the review relate to the information that the Council will provide following the Scrutiny Committee’s consideration of its report on South Kilburn regeneration, at its meeting of 2 December 2015 (see LINK)  

The Master-Plan review and the questions arising from the Scrutiny Committee consideration are separate matters. The points made by the Scrutiny Committee will and has assisted in the development of the Brief..
 

THE WEMBLEY MASTERPLAN AND THE RECESSION

“The Masterplan is a long term plan that should reach far further than the current economic down turn. A wide range of studies have been conducted that provide confidence that the proposals within the document can be delivered.”
Brent Council response to concerns about the Wembley Masterplan, December 2008

Brent Green Party and other objectors to the Wembley Masterplan called for Brent Council to put the Plan on hold until a full analysis of the impact of the recession on the local economy had been carried out and the Council’s Climate Change Strategy was in place.

A report entitled ‘The Local Impact of the Recession’ was tabled at the Council Executive on 16th March 2009. The Climate Strategy is long overdue and there appear to be concerns over the adequacy of the Consultant’s report. It is essential that a long-term project should be based on such a strategy. Despite this vital missing ingredient the Executive is due to make a a decision on the Masterplan at its meeting on Monday April 6th.

RECESSION OVERVIEW
The Recession Report resists engaging in detailed economic forecasting but states, “In short we face possible deflation, continuing low interest rates, a continued lull in property and housing markets and unemployment rising and possibly peaking in 2011-12…….At the same time, the government borrowing to defend the economy and provide fiscal stimulus will put huge pressure on public finances.” (4.5)

The Council faced with challenges on the financial viability of the Masterplan had earlier said that funds would be available from the government or the GLA in the event that Section 106 funding was not available.

RETAIL
The Wembley Masterplan envisages 47,000m2 of retail, restaurants and bars and a ribbon of retail running from Wembley High Road to Wembley Park. The Recession Report reveals that employment in wholesale and retail in Brent stands at 22%, a greater proportion than the British average (5.5.2) which ‘therefore may be an area of concern’. Brent has a greater proportion of firms involved in wholesale and retail than the British average: “This may be an area of concern, as the retail-related industry is predicted to be one of the sectors most severely hit by the recession.” (6.1.2)

So retail is already disproportionate, is likely to be hit most severely by the recession, but forms the backbone of the Wembley Masterplan. The Masterplan stated that further retail development was dependent on the successful completion of Quintain’s Phase 1 Wembley Boulevard development. A ‘success’ that looks unlikely in the present economic climate and the competing attractions of Westfield and a refurbished Brent Cross.

HOUSING
The Report suggests that with the fall in house prices and sales at a 30-year low, there may be an increase in demand for temporary and social accommodation. “A consequence of this could be that more people will turn to renting or seeking council housing. Brent already has one of the highest levels of demand for housing in the country, where we are unable to meet even a small proportion of the existing demand.” (8.2.1)

The Wembley Masterplan envisaged the provision of 3,727 new homes of which 1,400 were to be affordable. Much of this would be financed by Section 106 receipts (money paid by developers to the local authority towards infrastructure improvements). However the Recession report notes, “A quarter of the local authorities surveyed by the Audit Commission state that they have seen falls in Section 106 receipts of more than 5%, which is of particular concern because about half of the affordable housing supply in recent years has been provided under Section 106 agreements.” After noting that school building improvement plans will also be affected the Report states, “Opportunities to generate improvements in public sector infrastructure through regeneration projects will also be affected. (10.5.4)

The Report notes that the current forecast is that, “Brent will struggle to achieve the LAA target to deliver 458 affordable homes annually between 2008 and 2011 by 17.4% due to delays or terminations of development schemes. Wembley regeneration schemes were also expected to contribute to the supply targets, but some of these sites will be delayed, as developers such as Quintain concentrate on the non-housing part of their development.” The Report expects new starts to “drastically slow” and “in some cases where construction has commenced developers are delaying internal fit outs that allow new homes to be habitable in the hope that the market will improve”.

So housing, and particularly affordable housing, is essential and a major part of the Masterplan but unlikely to be completed in the short or medium-term, and some, already largely completed, will not be coming on the market. The Report pins its hope on government action to stimulate the housing market despite the constraints imposed by the huge long-term debts incurred by the government’s recent interventions to stabilise the economy.

REGENERATION AND DEVELOPMENT
It is worth quoting the first paragraph of this section in some detail:
“The construction industry has been severely hit by the squeeze on credit, and delays in development schemes have had a negative effect on the pace of Brent’s major projects, for example timetables have been put back for Wembley development….The lack of credit and economic recession may well both stop and delay private development, which may adversely affect our regeneration ambitions in Brent.” (11.1)

This throws the whole rationale of the Masterplan into doubt. The argument that the Plan is a long-term vision beyond the current crisis cuts both ways. If it is long-term there is no need to approve it at present when the Report recognises that the extent, depth and longevity of the economic downturn is unclear. The argument that, “…the council use this as a period of opportunity in terms of the regeneration agenda through undertaking detailed planning work and establishing clarity of vision, so that development projects can be kick started when the upturn occurs” (11.2), seems to be based on an assumption that things will soon be back to normal – an assumption as we have seen that is not well supported by other statements in the Report.

QUINTAIN ESTATES
Despite the council’s claim to the contrary when Quintain Estates criticised the Wembley Masterplan for unaffordability, they remain the council’s main developer partner.

Quintain have themselves been badly affected by the economic situation and their strictures need to be taken seriously in the context of their ability to provide Section 106 funding for the Masterplan proposals.

Quintain has recently negotiated a three-year deal with its lenders to manage its debts of £620,000,000. This involved increasing the firm’s maximum gearing ratio (the ratio of debt to net worth) from 110% to 150%, allowing for expected further falls in the value of its UK properties. This stabilised the firm’s stock, which has fallen 58% this year. However the arrangement provides protection only for a 20% fall in property valuation from September 2008 levels and the decline in property values has accelerated since then. Quintain is likely to seek further investment to help stabilise its finances.

CONCLUSION
The council’s own report, ‘The Local Impact of the Recession’, reinforces objectors’ criticisms of the Wembley Masterplan. The Plan based as it is on expansion of retail, housing, hotel and office space at a time of economic recession and long-term economic uncertainty is irrelevant in its present form. As a long-term Plan it should also take into account the council’s yet to be published Climate Change Strategy.

The Wembley Community Association will be attended the Executive on Monday April 6th to press their case for a realistic and sustainable Masterplan.

IS CONSULTATION A CON?

‘Consultation’ has become a buzz word – the government consults about the third runway, the post office consults about post office closures, the health service consults about ‘super surgeries’ or ‘polyclinics’, the local authority consults about graffiti, climate change, care charges for elders, planning including the Wembley Masterplan and the Wembley Academy.

Too often, consultation seems to offer us a way of affecting decisions but leaves us feeling disgruntled and rather cheated. What starts as an extension and deepening of democracy leaves us cynical about decision makers and politicians. Despite a fight post offices closed, despite a fight Heathrow expansion is going ahead.

“It doesn’t make a difference. They’ve already decided anyway.”

For Brent Council I suggest the questions should be:

1. What do we consult about? When do we decide a consultation is necessary? How do we justify not consulting on some issues? It sometimes seems that the most controversial issues are not directly consulted about. We had no consultation about whether the people of Brent were in favour of City Academies as a form of semi-private provision (publicly funded but private controlled), little about where it should be – but were asked about its name and catchment area. We weren’t asked if we wanted a Civic Centre and the subsequent loss of the Town Hall, but were asked (rather glossily and expensively) about graffiti. A new contract has been awarded for play-services but the clubs and clients were not consulted during the bidding process. The new provider, ‘Kids’ has an odd trio of patrons (David Cameron, Cherie Blair and Elton John) and its inadequacies have been exposed by Private Eye – Kensington and Chelsea have already thrown it out.
2. How do we consult? It is not just a question of Area Forums, questionnaires in Brent Magazine, meetings with the Youth Parliament, on line forms, focus groups etc but what information is made available, how and when. There are major questions of accessibility. Having to down-load tens of multi-paged documents is not an option for all, working out from cryptic list of documents on the planning site which are relevant is a full-time job, trying to get hold of documents at libraries and one stop shops can be a marathon under-taking. Timing is crucial major increases in care charges were consulted about over the Christmas holidays when day centres and voluntary organisations were closed. The most telling recent case has been the Wembley Masterplan when local residents and businesses (small and large) were forced to form the Wembley Community Association because they were so enraged by the Council’s failure to reach the people most affected. They managed to force an extension of the consultation process so that they could put their case against the opening up of North End Road and for a more realistic project to be completed sooner. An approach reinforced by Quintian’s comment that the Masterplan was ‘unrealistic, undeliverable and unaffordable and the Govt Office for London demanding more convincing evidence of ‘realism and deliverability’.
3. How good is the quality of information we use for consultation? This includes the quality of questionnaires and whether they enable credible, useful information to be gained (e.g. school places question on school size gave no opportunity to state a preferred size – only to agree/disagree with Council policy); the quality of the often expensive reports carried out by consultants; whether reports actually do the job they are supposed to (the traffic survey for Wembley Academy assume Wembley Primary and Preston Manor pattern of trips to school when children will be travelling from South Brent, flood report says no evidence of local watercourses from street names when Brook Avenue and Kenbrook are nearby - duh!)

4. How fair are our consultation procedures? This relates to accessibility of information as above but also who is consulted and to what lengths we go to reach everyone. The Climate Change Strategy, Wembley Masterplan consultation, and the Care Charges consultation have all had to be extended to give people more time to respond – and it is to Brent Council’s credit that it has bowed to public clamour and done that. But there have also been complaints about the geographical limits of consultation and the need to write to more people and involve the ‘hard to reach’. A colleague has also raised the question of payment for attendance at Focus Group meetings, whether such payments are just known to those ‘in the know’, and how such payments stand ethically. How do you get on a focus group and how are they constructed to give a fair representation?

Perhaps more important is the question:
Does consultation raise unrealistic expectations about changing or reversing decisions? If consultation is really only about small, often cosmetic changes, perhaps it is best to say that at the outset rather than mislead people into thinking they can make any substantial impact on a decision and alienate them by seeming to ignore their well-thought out arguments. After all the ultimate consultation is at election time but if people are fed up with consultations, and thus also with politicians by then, they probably won’t vote.

What we (the people) should be demanding:

Don’t be humbly grateful to be granted a small say – instead:

Demand Council learn from recent problems:

· Widen consultation
· Ensure accessible and high quality documentation
· Ensure procedures are fair with adequate time lines

To strengthen democracy and accountability