Council agrees to consider campaigners' suggested improvements to Pub Protection Policy

Queensbury Pub campaigners

Queensbury Pub campaigners Ian Elliott and Sujata Aurora spoke at yesterday's Planning Committee on the proposed Pub Protection Policy written into the Brent Development Management Local plan.

While welcoming the Council's decision to have such a policy after their long campaign they also called for improvements based on CAMRA's suggestions and the policy adopted by Waltham Forest. The campaigners had circulated the CAMRA letter to members of the Committee and Sarah Marquis, the chair commented that it had raised some important points.  The Committee were asked if the accepted CAMRA's points and they murmured assent.

Waltham Forest policy included an audit of what would be lost to the community if a pub was to close. It was important to be aware of developer strategies to undermine the viability of a pub by for example raising prices or letting the building run down.

Campaigners argued that if the Council made the suggested policy changes it would have a excellent policy whereby viable pubs would be protected.

Paul Lewin, Brent Planning and Projects Manager, said that there was 'merit' in CAMRA's comments but that officers would need time to explore them and any legal or planning issues they raised. It was agreed that the Plan could be revised to accommodate changes but it appeared unlikely that this would be in time for the August Cabinet.  The comments and changes  could be made as part of the 6 week publication process.

The Waltham Forest policy can be found HERE and CAMRA's letter below:

Brent Planning Committee attempts to push the affordable housing agenda forward

Steve Weeks,  Brent Council's Head of Area Planning, was refreshingly straight talking at last night's Planning Committee when he stated that the Government's aim was to push the housing market rather than the amount of affordable housing.

Speaking about the Vacant Building Credit, which enables developers to escape affordable housing requirements under somewhat vague criteria, Weeks remarked, 'There has been much discussion in planning circles about how much of a gift this is to the development industry.'

He said that the  purpose was to incentivise development and that the  Council were stuck with the policy but were trying to be interpret it in a reasonable way. The Committee (with one abstention) agreed a definition of that the Vacant Building Credit would be applicable only to 'builsings that have been in lawful use for a continuous period of less than six months in the three years before which planning permission first permits the chargeable development.'

In the ensuing discussion officers made it clear that they would check on whether developers had made genuine efforts to market such properties at realistic prices in a reasonable way or had deliberately left them empty or abandoned.  However, they also pointed out that they had limited resources.

The vexed question of Viability Assessment, whereby developers try and reduce the amount of affordable properties they have to provide in developments, often once planning permission has been granted and work started, on the grounds of getting a 'reasonable return' on their investment, was discussed at some length.

Officers were working with other London boroughs on a Protocol to address the issue and the aim was to have some guidance on the Council website for developers  which would address the issue of viability from the pre-application stages.  The Protocol should be available by the end of the year. Sarah Marquis, Chair of the Committee had circulated to member a very full document from Islington Council and suggested something similar for Brent.

Steve Weeks said that much of the Islington Policy was lifted from the London Plan, and thus repeated existing policy.  Brent Council could produce a shorter version but that would take some time and it was important that guidance should be available to developers sooner.

The Committee agreed recommendations that a position statement be posted on the Council website  requiring affordable housing viability assessment to be provided in a form that is open to public and members' scrutiny with more comprehensive affordable housing related advice. They also agreed in principle to closer work with London boroughs on an affordable housing protocol and joint procurement of a consultants' panel.

The Council's target of 50% affordable housing in new developments would be retained with a 70/30 social or affordable rent/intermediate split rather than the Mayor's 60/40.  The Council is commissioning a Strategic Housing Market Assessment (SHMA) which should demonstrate the housing needs in the borough to update the Council's housing strategy. It is likely to show a large increase in the need for 'intermediate products'. House price rises mean that households with incomes between £58,000 and £73,000 should be eligible for 25% shared ownership properties.

Earlier in discussions of the  Brent Development Management Policies Local Plan officers said that there was a possibility of releasing some industrial (employment) sites for housing that would need to meet the minimum affordable housing targets and that these might also be released for the provision of new secondary schools that would be needed in the future.

Sarah Marquis asked officers to look at the potential of adopting a code for developers that would require them to sell to Londoners in the first instace rather than overseas buyers.

There was a fairly short discussion due to time constraints on the issue of 'Poor Doors' (separate entrances for private and social tenants in mixed developments).  Officers said that the entrances should look the same from the outside, although they would be different once you stepped inside. Private tenants would have services such as concierge and social teneants would not be able to afford the service charges involved.

When it was suggested that there should be a single entrance, committee members were told that there was a limit on how many flats should be accessible from a single court. This meant that there had to be several entrances.

Brent Council finds request for information on the Stonebridge Playground betrayal 'extremely burdensome'

As we have heard this week the Government wants to get rid of the Freedom of Information Act, although they haven't quite said it so bluntly.

As far as Brent Council is concerned is seems they have already adopted their own Obfuscation of Information Act.

Glynis Lee, puzzled over the sudden change of policy by Brent Council in Summer 2014 - at a first meeting Brent Council officers informed the Brent Play Association that the Stonebridge Adventure Playground was to be rebuilt, with a new building and perhaps slightly less land but then, at the next meeting, told them they would be closed.  An excited architect named Fred Eastman of South Stuio Architects had shown them his plans for the Playground at the first meeting.

At the same time Brent Council decided to end funding for the Playground.  Their own consultation report later admitted that 80% of consultation respondents wanted to keep the playground, but this was followed by Cllr Ruth Moher stating at a Cabinet meeting that 'you can get anyone to sign a petition'.

Wanting to unravel all this Glynis had put in a Freedom of Information request that the Council refused to answer. She then asked for a review and this was the response.

Note the promised reply by  12th May 2015.  In fact it did not come until July 8th and had been apparently arbitrarily changed from an FoI request to an Environmental Information Regulations request.

This is Fiona Alderman's reply:

--> Dear Ms. Lee

Thank you for your request for a review received on 13 April 2015.

Your information request
Environmental Information Regulations 2004

I refer to your request received on 13 April 2015 for a review of the
council’s decision to refuse your request for information relating, in
broad terms, to the Stonebridge Park redevelopment from 16 September 2013
to date. Please accept my apologises for the delay in conducting the
review.

As part of my review I have considered your original request for
information received on 9 March 2015 which was in the following terms:

“All correspondence, reports, minutes, letters and proposals which relate
to the redevelopment of Stonebridge, the expansion of Stonebridge primary
school, the removal of the Welsh School and the closure of Stonebridge
Adventure Playground. This information would be with specific reference to
all of the above between the Brent’s Asset management department, Children
and Young people department, and department of Regeneration and growth.
Information including reports and plans from South Studio Architects to
also be included, and all communication between council officers, and
councillors which pertains to any or all of the above”.

I have also considered the council’s response to your request dated 8
April 2015.

The response stated that your request is being handled under the Freedom
of Information Act 2000 (FOIA) and the Environmental Information
Regulations 2004 (EIR) and that with one exception your request was
refused because it exceeded the statutory cost limit of £450 (or 18 hours)
as set out in section 12 of FOIA.

The response referred to the diffuse nature of your request, its breadth,
the shear volume of the potential information that might be in scope, the
hundreds of officers across the council and other individuals who may hold
the information you have requested, the difficulties in determining with a
reasonable degree of certainty the information the council actually holds
and the council officers and other individuals who actually hold it (i.e.
the difficulty in locating the information) and the inordinate amount of
time and the excessive and wholly disproportionate amount of resource and
money complying with your request (including retrieving and extracting the
relevant information) would demand.

I also note that you were invited to narrow or refine the scope of your
request.

A link, however, was included in the response for ease of accessing the
report to Cabinet on the council’s re-development proposals for
Stonebridge Park which is a public document and was already published on
the council’s website.

Against that background, I now set out the outcome of my review.

As your request was for information relating to redevelopment proposals,
it constituted ‘environmental information’ for the purposes of EIR.
According to EIR, environmental information includes any information on,
amongst other things, the state of land and plans and activities affecting
or likely to affect the state of land. Your request therefore should have
been considered under EIR and not FOIA and, as a consequence, the refusal
of your request did not comply with the requirements of EIR.

Under EIR, the council can refuse to disclose environmental information if
an exception applies and, in all the circumstances of the case, the public
interest in maintaining the exception outweighs the public interest in
disclosing the information. There is, however, a presumption in favour of
disclosure. Although, unlike FOIA, EIR do not contain an express
cost-limit, the council can refuse to disclose information to the extent
that the request is “manifestly unreasonable”. Further, according to FOI
case law, the costs of compliance can be taken into account under both
regimes.

In all the circumstances, I am satisfied that it is necessary to refuse
your request to protect the resources of the council from being squandered
on disproportionate use of EIR. I am also satisfied that there is no
adequate or proper justification for your request and that it is not aimed
at the disclosure of important information which ought to be made publicly
available.

In this regard, I note in particular that key decisions about the
Stonebridge Park redevelopment proposals have been made by councillors in
open and public meetings and that important information, such as Cabinet
reports and associated documents, are already freely available. Also of
particular note is the extensive and widely advertised consultation that
was undertaken to seek the views of residents and other local stakeholders
about the redevelopment proposals which included creating a website
setting out consultation information with an on-line response portal and
face to face consultation events. The consultation also received
considerable local press coverage.

Finally, as the redevelopment proposals have education, planning and
procurement implications, the attendant statutory controls bearing upon
the council ensure that its decision making is open and transparent and
that there are opportunities for public participation and for the council
to be held to account.

As the availability of the manifestly unreasonable exception is subject to
the public interest test, I have also considered the benefits of
disclosure. The disclosure of yet further information would be in the
interests of openness and transparency. Providing access to information
can assist in holding public authorities to account and encourage greater
public participation in the exercise by public authorities of their public
functions.

On the facts of this case, however, I have no doubt that for the reasons
given in the previous refusal of your request and the reasons I have
given, the public interest in disclosing the information you have
requested is outweighed by the public interest in withholding the
information. In deciding how much value there would be in attempting to
comply with your request I have also had regard to the fact that at least
some (if not most) of the information is likely to fall within available
exceptions under EIR which the council could and would rely upon to
justify a refusal of your request.

Thus, for all the reasons I have summarised in this decision notice, as
your request is extremely burdensome and costly, would require an
unreasonable diversion of finite resources from the provision of valuable
services and is of no public value, it is in my opinion manifestly
unreasonable.

Hence, although your request should have been dealt with under EIR, and
not FOIA, to all intents and purposes, very similar considerations apply
and the outcome is the same.




In conclusion, therefore, I have upheld your complaint in part because it
was dealt with under FOIA, and refused under section 14 of that Act, and
not under EIR. Ultimately, however, I have upheld the decision to refuse
your request because it is manifestly unreasonable and the public interest
favours withholding the disclosure of the information.

If you are not content with the outcome of my review, you have the right
to complain directly to the Information Commissioner. The Information
Commissioner can be contacted at:

The Information Commissioner's Office, Wycliffe House, Water Lane,
Wilmslow,



Glynis would appreciate a translation of the above into English so that she can inform the children of Stonebridge, badly missing their playground as the summer holidays begin, of the Council's position. Can anyone help?

Incidentally the School expansion document going before the Cabinet on Monday notes (regarding the Stonebridge Day Centre currently hosuing Stonebridge Primary classes) and the Preston Library site:

It should be noted that of the above sites, the former Preston Road Library and the former Stonebridge Day Centre are both included in the Capital Disposals Programme for 2016/17 with forecast receipts of £700k and £1.5m respectively estimated for Quarter 4.

 

'A Bigger Picture of Brent' evokes nostalgia & animated conversation at Preston Library Community Hub

Preston Community Library Hub was crowded this afternoon for a showing of 'London: A Bigger Pictures Comes to Brent'.

London: A Bigger Picture is a three year project from the London Screen Archives that is digitising archive film, often family moves, of life in outer London. It captures ordinary daily life as well as special events.

Today's screening included a 'Healthy Baby' contest filmed during the 1920 miners' strike, Sports Day at Willesden grammar and a School trip to Paris in 1936-7, Coranation Celebrations in 1953 and came right up to date with the 1993 Festival of Brent at the old Brent Town Hall.  We saw breathtaking footage of the first cup final at Wembley when huge crowds swept into the stadium and over the pitch. This was the famous 'White Horse' event, when police horses were used to calm the crowds and now commemorated in the Whit Horse Bridge near Wembley Stadium station.

When Kingsbury Open Air Swimming Baths (Roe Green) was shown there were murmers of recognition and appreciation from the audience. The colour footage showed a crowded baths and despite one mutter that 'it was very cold' there was general agreement when someone said, 'if only we had that now'. None of the audience could confirm my memory that Dobbin, the Express Dairy cart horse, had bolted one day in the 50s and ended up in the pool: 'It's your imagination, Martin' , 'It's an urban myth.'  Can anyone help?

Coincidentally tonight's Planning Committee has an item on Brwnt's historical heritage. There is a proposal that seeks to provide a consistent and transparent approach to the identification and protection of the Borough’s Locally Listed Buildings The process would involve consultation with residents about which buildings and sites should be listed. These are the suggested criteria LINK :

Any site or structure provided it is not already statutory listed and meets the designation criteria, can be added to the Local List, particularly if it can be shown that it contributes to the character of an area and is valued by local people. The following are the criteria for including buildings, structures or features on the Local List:

1)         Architectural significance

a) an example of a style of building that is particular to the local area, or a good surviving example of a historic architectural style;

b) designed by notable local, or national architects, engineers or designers; or

c)  an example of a particular technical innovation in building type, material or technique.

2)         Historical significance

.        d)  associated with an important historic figure, local or national; 


.        e)  have strong community or socio-economic development significance, such as 
schools, institutions or any important part of Brent’s industrial and military 
history; or 


                    f) is associated with any important local historic events.

3)         Townscape significance

.        g)  building groups, structures or features, including groups or terraces of buildings, which help form an attractive local character; 


.        h)  good examples of town planning/layout; or 


.        i)  notable buildings or structures, on important routes into the area, or key 
landmark buildings which create a vista or contribute to the skyline. 


Unfortunately some uncertainty has emerged over the Preston Library and Community Hub as the building, which until recently housed some overflow classes from Preston Park Primary School, has been earmarked again by Brent Council. although some joint use is envisaged..

A report going before the Cabinet on Monday states LINK :

This building was originally used as an annexe by Preston Park Primary whilst the new permanent school building was completed. That use is no longer required however the former Preston Road Library is proposed to accommodate 60 reception places to compensate for the loss of 2 Reception classes from the delay to the proposed expansion at Byron Court Primary School. Cabinet is requested to approve an extension until the end of the 2016/17 academic year. Further, Cabinet is requested to delegate authority to the Operational Director of Property and Projects to enter into a licence with an identified school until 31 July 2017. 

It is noted that at the time of drafting this report, a licence to occupy the building exists granting the Friends of Preston Road Library use of the building for the operation of a pop up community library. This expires on 31 July 2015. Proposed future school use will take account of the local aspiration for this community library to continue in some way. 

This property is currently included in the Council’s Capital Disposals programme for 2016/17 and forecast capital receipts arising from disposal are assumed to fund the Capital Programme for that year. Approval of the proposal to extend use until July 2017 will impact on the completion of a disposal and receipt of an associated capital receipt will be delayed until 2017/18.

 The 'London: A Bigger Picture' project can be found HERE

To volunteer, donate film or find out more contact screenheritage@filmlondon.org.uk

Weekend closures on Jubilee and Metropolitan lines

Jubilee line On Saturday, there will be no service between Willesden Green and Stanmore, and on Sunday there will be no service between West Hampstead and Stanmore. This is while we renew points and replace track at Neasden.

Metropolitan line Trains will not run between Aldgate and Harrow-on-the-Hill while we renew points and replace track at Neasden.

Weathering the Storm: GLA report calls for promotion of low carbon economy and climate change adaption strategy

From the London Assembly Economy Committee 

London’s status as a global city makes its economy increasingly vulnerable to climate change.
Not only do we face higher risk of flooding, drought and heatwaves at home, but we also ‘import’ risk through the insurance sector, overseas investments and our supply chains.

However we have found that the adaptation economy is strong and growing. And London is well placed to take advantage of further opportunities for growth in a sector in which it has internationally recognised strengths. The time is right for responsible investment in, and promotion of, the green economy as an alternative to coal and other fossil fuels.
The London Assembly Economy Committee has investigated the impact of climate change on London’s economy in terms of risks and opportunities.

During the investigation, the Committee held two public meetings with representatives for a number of organisations, including Lloyd’s of London, PwC, LSE and Siemens. Written submissions were also received from the Mayor of London, the Federation of Small Businesses and the City of London Corporation amongst others.

Recommendations

The report makes a number of recommendations, including:

• The London Climate Change Partnership should map the major supply chain vulnerabilities of London’s economy.
• The Mayor should commit to the principle of a transition away from investment in certain fossil fuels, namely coal and towards reinvestment in responsible funds.
• The Mayor should launch an award for climate change adaptation to reward innovative initiatives by London businesses. 
• The Mayor should drive forward a resilient low carbon economy for London by promoting skills in this area and encourage innovation in the green economy.
• Climate change adaptation should be integrated into the Mayor’s Economic Development Strategy, as currently it doesn’t feature.

Related documents	Size
Weathering the Storm: The Impact of Climate Change on London's Economy	1.42 MB
Written submissions	3.69 MB
Submissions to initial call for evidence	3.12 MB
Transcript of 24 June meeting	218.26 KB
Transcript of 23 October meeting	206.53 KB
Impact of Climate Change on London's Economy - Summary of Views and Information (interim report)	887.63 KB

Shahrar Ali, Green Deputy Leader calls for greater scrutiny of police on de Menezes anniversary

 

Shahrar Ali, Deputy Leader of the Green Party attended the event to mark the tenth anniversary of Jean Charles de Menezes' death at Stockwell station this morning. Speaking before the event he said

“I shall be paying my deepest respects to the family of Jean Charles de Menezes on the tenth anniversary of his fatal shooting. Their grief has been compounded by the failure of the IPCC and of our judiciary to hold any operational commander or firearms officer to account, despite the admission that mistakes had occurred.”

Baroness Jenny Jones, London Assembly member, said:

“The killing of Jean Charles de Menezes was not just a tragic error by the Met Police, but also an example of their trying to hide evidence, cover their tracks, and avoid justifiable scrutiny. I'd like to think that it couldn't happen again, but quite honestly, I think it could.”

Ali continued:

“Whilst the family seeks justice in the European Court, we also insist upon greater scrutiny of the police rules of engagement and racial profiling that allowed this to happen. We cannot abide by a scenario where a man or woman gets shot dead, out of misidentification and tactical error, simply for being in the wrong place at the wrong time."

Shahrar Ali, Deputy Leader of the Green Party who will attend the event to mark the tenth anniversary of Jean Charles de Menezes' death at Stockwell station tomorrow morning (1), said:
“I shall be paying my deepest respects to the family of Jean Charles de Menezes on the tenth anniversary of his fatal shooting. Their grief has been compounded by the failure of the IPCC and of our judiciary to hold any operational commander or firearms officer to account, despite the admission that mistakes had occurred.”
Baroness Jenny Jones, London Assembly member, said:
“The killing of Jean Charles de Menezes was not just a tragic error by the Met Police, but also an example of their trying to hide evidence, cover their tracks, and avoid justifiable scrutiny. I'd like to think that it couldn't happen again, but quite honestly, I think it could.”
Ali continued:
“Whilst the family seeks justice in the European Court, we also insist upon greater scrutiny of the police rules of engagement and racial profiling that allowed this to happen. We cannot abide by a scenario where a man or woman gets shot dead, out of misidentification and tactical error, simply for being in the wrong place at the wrong time."
- See more at: https://www.greenparty.org.uk/news/2015/07/21/de-menezes-shooting-greens-call-for-police-accountability-and-warn-of-risk-of-repeat-fatality-ten-years-on/#sthash.Q27r2hry.dpuf

Affordable Housing, Viability, Vacant Building Credit and Poor Doors vital issues at Brent Planning Committee

The issue of 'viability assessments' where developers attempt to reduce the amount of affordable housing in developments that have already started has been well documented recently. This article from last year sets out the issues with passion LINK

Brent's Planning Committee on Thursday will receive a report which, between the lines, sets out how the Government and London Mayor are seeking to tie the hands of councils wanting to build affordable housing.

London councils have been trying to work together to develop a Protocol over  the issue and are considering employing consultants to respond to the developers' claims.

The report LINK states baldly:

 Government still wants to be seen to be encouraging additional housing development. Recent policy announcements such as the Starter Homes Initiative and the Vacant Buildings Credit both see normal affordable housing planning requirements as an expendable component in the delivery of this aim.

  The Vacant Building Credit was introduced by Ministerial Decree in November 2014:

The basic premise is that in order to support brownfield regeneration, development of empty or redundant buildings should be further incentivised. This is through reducing or potentially removing affordable housing contributions normally sought from qualifying housing developments. The Practice Guidance gives no flexibility on the application of the Credit related to a development’s viability. Consequently even if the development could in any case afford to provide policy compliant affordable housing amounts the Credit still applies.

The officers comment that details of the policy are inadequate and it is unclear to what extent it will affect Brent LINK but propose:

Vacant Building Credit will only be applicable to:

i) the Gross Internal Area of buildings (buildings as defined in the Community Infrastructure Regulations)

ii) buildings that have been in lawful use for a continuous period of less than six months in the three years before which planning permission first permits the chargeable development

What will certainly affect residents and those seeking affordable housing is the issues around developer profits and viability assessments that reduce the amount of affordable housing in developments, as well as the requirement to increase social rents to market levels. It is worth quoting the report LINK in detail here:

.    Notwithstanding the increases in values and delivery rates within the housing market and the viability of housing developments, Government still wants to be seen to be encouraging additional housing development. Recent policy announcements such as the Starter Homes Initiative and the Vacant Buildings Credit both see normal affordable housing planning requirements as an expendable component in the delivery of this aim. In addition developers can still appeal agreed Section 106 affordable housing levels on the basis of viability direct to the Secretary of State through changes introduced by the Growth and Infrastructure Act 2013. The adoption by the Council of the Community Infrastructure Levy (CIL) reduces the element of discretion that the Council has in relation to infrastructure matters that previously would have been captured through S.106 obligations. This means that when viability is raised as an issue, affordable housing represents a larger cost within what is a smaller contributions ‘pot’ around which there is flexibility to negotiate. 


.    Local authorities’ ability to control rents in S.106 obligations, following the move away from social rent as the preferred rented product, have been hindered by a judgement supporting the Mayor’s London Plan policy position of restricting such an approach. (LB Islington & Others v Mayor of London & Another - CO/16997/2013). The general assumption at national level (and followed through by the Mayor) is that affordable tenants should be paying higher amounts of rent more reflective of market levels. Where tenants find this unaffordable, they are initially supported by benefits. When benefits become insufficient, tenants should move on to options that they find affordable. Whatever the merits of this approach Planning has to work within these parameters.

.    3.12  Notwithstanding the potential progression of the protocol it is recommended to Committee that Brent in the mean time issues a position statement/guidance that seeks to ensure that as much of the information contained in viability assessments and ideally all can be viewed by the public. Where the developer is adamant that commercially sensitive information is contained within that they do not want to be disclosed, the Council will require an document that provides as much information as possible in the public domain. An easily understandable Executive Summary document should also be provided to be made available so that the opportunity for greater transparency exists.

Islington Council has set out its requirements on viability assessments fully with a detailed process that begins at the pre-application stage and is a document that Panning Committee members should study in detail. LINK

 Another controversial issue which Planning Committee has encountered is that of 'poor doors', separate entrances in mixed developments for 'market' and 'social residents. This is what officers say on the issue:

Tenure Blind development

.    3.18  There have been concerns and media coverage about ‘poor doors’ and highlighting differences in tenure related to design. The current Mayor’s Housing SPG in paragraph 1.3.18 is clear: “Schemes should be designed to maximise tenure integration and all affordable housing units should have the same external appearance and entrance arrangements as the private housing.” The Draft Interim Housing SPG recently issued for consultation has a slightly different approach to entrances. It states: “In some higher density schemes, separate provision of entrance and circulation spaces for different tenures may enable affordable housing provision which might otherwise be made unviable given high service charges and management arrangements. All entrances will need to be well integrated with the rest of the development...” 


.    3.19  Both documents are clear about the design being the same but reflect the real practicalities of dealing with management charges in particular. Case law has clarified that cross-subsidisation between tenures for management charges are not legal. Many private occupiers/tenants expect the prices they are paying for properties to reflect additional levels of service/standard related to the communal areas. Unsurprisingly Registered Providers are not keen for management charges to be higher than they need to be for their tenants/leaseholders. They want to control the charges as much as possible. They are also reluctant to be reliant on a third party freeholder/managing agent in managing those costs.

.    3.20 Compared to some rents, service charges can provide significant additional cost. For the purposes of benefits they are also regarded as part of the affordable rent charged. This increases risk to the Registered Provider of having to meet the cost out of other funds, thus impacting on overall affordable housing delivery. If there are risks of high charges, it will also affect the interest of Registered Providers in purchasing the affordable dwellings. Officers will seek to ensure that wherever possible tenure blind development occurs, however there may well be practical reasons why there may need to be differentiation in approach or physical separation between tenure types.

 This appears to leave wide open the potential for the continuation of at least some 'poor doors' developments in Brent.