Image from the 2019-2041 Brent Local Plan
Admittedly a consultation about the Brent
Local Plan isn't likely to cause a huge amount of excitement but lack of
engagement with an upcoming Review that will be discussed at next Tuesday's
Resources and Public Realm Scrutiny Committee could cost residents dear.
The 2019-2041 Plan, spearheaded by Cllr
Shama Tatler, shaped planning decisions based on support for tall buildings, densification,
intensification corridors and the designation of eight Growth Areas. This is
transforming our borough.
The proposal is for a Full Review covering
all areas of the Plan rather than a few areas as some other councils are
undertaking. LINK Bold emphasis is mine.
The current Plan is immense and contains
proposals for sites across the borough but current conditions and changes in
planning laws mean a review is necessary:
The principal rationale for review is to embrace the
need to plan longer term to meet the needs of a growing population to at least
2046 and possibly beyond. The largest priority is to ensure housing delivery
can be sustained at high levels in the future. This requires identifying sites
well in advance of when they are needed. Due to the complicated nature of
future opportunities (the need to parcel up sites that currently include
individual homes) this could well be longer than was needed in the past. Large
single ownership sites such as Grand Union in Alperton are getting rarer. Sites
are more likely to be like 1-22 Brook Avenue allocated in 2011, having publicly
been identified 3 years earlier in the draft plan; this only had a
comprehensive planning application submitted in 2023 (15 years after first
being identified) and it is understood that full site ownership has still not
yet been achieved by the applicant.
Brook Avenue is the road
next to Wembley Park station where the developer pressured owners of the
suburban houses to sell up to enable a developer to build tower blocks. If they
failed to agree the Council would consider compulsory purchase to enable the
development to go ahead – it was in the Local Plan. It appears one at east owner is
holding out.
The paper going to the
Committee implies predicts there may be more such proposals:
To
date much of the population of Brent has accepted the ambitious levels of development
that the last Local Plan promoted. The next Local Plan may wellhave
to deal with accommodating more development amongst suburban housing,
most of which will be in good condition and privately owner occupied.
As
well as potentially affecting more people’s homes, it could more likely to result
in more areas having more substantial changes in character compared to
currently. This may well increase the amount of objection and challenge to the
plan from Brent residents or community groups. This could again slow down the
plan’s delivery, requiring further levels of engagement and revision to plancontent
or policy direction.
You have been warned. Look
up your area/address on the current Local Plan and you may well be surprised/shocked
by what you find. LINK
Another reason for review is
that the Council has been unable to meet its targets due to the current
economic and labour supply situation, and new safety regulations:
Brent’s delivery [of housing] prior to 23/24 was
excellent. In the 3 financial years to 22/23 Brent delivered the equivalent of
8136 net additional dwellings Ministry of Housing, Communities and Local
Government (MHCLG) official figures. This represented 131% of its target
against the Housing Delivery Test (HDT). Delivery in 23/24 was however very
weak at 656 net dwellings. This is not yet reflected in the latest MHCLG HDT
figures but represents only 28% of the 2,325 annual minimum target. Completions
for 24/25 have not been finalised but are likely to be well below the target.
Lack of planning permissions are not what is holding back delivery. The latest GLA datahub information indicates that as of 31st March 2024,
16,985 dwellings had permission but had not been completed. It is other factors
including viability, construction capacity, the contraction of the private
sales market, investor caution and building safety regulator sign-off (for
buildings 6 or more storeys) that are having the biggest slowdown impact.
We know that a higher
proportion of private housing is likely on South Kilburn due to these factors
and that there is a slowdown in the already limited building of new council
homes – the only truly affordable option for most Brent residents. Remember
that the definition of ‘affordable’ is often 80% of the market rate and these targets
are not being met:
In
respect of other Local Plan housing objectives, the amount/ percentage of
affordable housing, when compared to overall housing delivery, is below the 35%
London Plan fast track route target and significantly below the 50% strategic
Local Plan target. In 23/24 19.7% of the homes that were completed in the
borough were affordable, and 26.7% of the homes that were approved that year
were affordable. For 23/24 homes delivered which were subject to an affordable
housing S106 obligation, the percentage delivered was 44%.
Given the number of families on
the Council list, and the Council’s policy to persuade them to move into private
accommodation outside of the borough, the policy for more family-sized homes has
also failed:
The
Local Plan has a target of 1 in every new 4 (25%) homes requiring permission
being 3 or more bedrooms. In 23/24 delivery was below this at 12.2%. Delivery
of this target is impacted by small scale schemes that might be for three of
less dwellings, thus not required to provide a three-bed home; on larger
schemes, there is often a trade-off reflecting the viability considerations. 3+
bedroom schemes do not attain the same values (per square metre) as properties
with 1 or 2 bedrooms, thus requiring the 25% affects development viability and
can reduce the number of affordable homes that can be delivered.
If there are to be more smaller
developments in future these also have their drawbacks:
For
minor developments, the range of policies that apply are fewer, in part
reflective of the Government’s position that to support the small builders’ sector
there should be lower costs/ simpler processes. In addition, many of the homes
in this sector in Brent are delivered via conversions of existing homes (e.g.
conversions of houses to flats). These factors can bring compromises that might
not be applicable in larger schemes, e.g. no lifts, inability to provide
outdoor amenity space for upper floor dwellings, encouragement to attain higher
energy efficiency/ renewables, rather than requirement, etc.
Although officers try to reassure,
there are also issues when builders try to reduce costs:
The
Council ensures that the quality of the affordable homes is consistent with
that delivered for private homes. Applicants know that the Council will not
accept obvious lower standards or development that is not tenure blind
particularly in terms of outward appearance and location. There however, may be
subtle differences, (e.g. communal facilities such as size of lobbies, corridor
finishes, incorporation of soft furnishings, gym facilities) as registered
providers seek to reduce on-going service charges to occupants.
Officers outline other areas of
the Local Plan where it is likely that changes will be needed;
In respect of the topic area policies sections changes are likely to be
required to reflect recent and proposed trends, e.g. during and post Covid the
move towards on-line trading will mean some retail uses are diminishing,
meaning town centres are at greater risk of contraction, whilst hospitality
uses are also struggling, with existing numbers of pubs proving difficult to
maintain as viable. The Council will need to review its viability tests/
periods of vacancy that are acceptable to ensure its not unnecessarily
maintaining property vacancies. Review of the borough’s green spaces indicates
an inconsistency in categorisation and levels of protection provided for those
not identified. These will need a detailed review and amended policy. The
affordable workspace policy will need review to apply it to a lower size
threshold of development. It was subject to change during the last examination
by the Inspectors as it received objections, which the Council was not allowed
to address properly due to submission of additional viability being
inadmissible. The amount and concentration of student housing has also become a
more pronounced concern for councillors and the Plan will consider how to best
address this, balancing up London’s strategic student housing needs against
Brent’s housing priorities including very high affordable housing needs.
