Philip Grant has asked to have the following two comments he has submitted to Brent’s Planning Service on the Willesden Green application (12/2924) posted on the blog. This is for the information of other people interested, and to make these comments easier to read, as the Council’s system packs the text together, and inserts upside-down question marks where quotation marks have been used, which will make the points more difficult to follow when they do appear on the Brent Planning website. The comment on affordable housing also had to be edited slightly in the version submitted, as that shown below contained too many characters.
DEPARTURE FROM BRENT’S CORE POLICY CP17
The Town Planning Statement submitted by URS on behalf of Galliford Try Plc makes much of the fact that the proposed building is designed to be Brent Council’s southern hub (at para.1 – Introduction):
‘The proposed new Cultural Centre represents a flagship scheme for Brent Council, to act as a southern counterpoint to the new Civic Centre in Wembley to the north.’
This approach appears to have blinded both Brent’s Regeneration Department and the developer to an important difference between the Wembley and Willesden Green sites.
Under the Brent’s LDF Core Strategy for planning, Wembley is the main growth area (of five such areas) in the borough, and the site of the major Wembley City redevelopment within which the new Civic Centre is under construction. Willesden Green is not one of the Core Strategy’s growth areas, but a District Centre, where Brent’s ‘Protection and Conservation’ policy applies. At para.5.12 the Core Strategy says:
‘As well as areas where growth and change can be focused and encouraged, there are also extensive parts of the borough that need to be protected and conserved, especially the suburban character. This relates largely to the character of particular built areas, such as the borough's 22 designated conservation areas ....’
The Core Policy which sets out to maintain ‘the local character of Brent’ is CP17. In particular, this states:
‘The distinctive suburban character of Brent will be protected from inappropriate development.’
Policy CP17 is not referred to in section 5.3 of the URS Town Planning Statement among ‘Those Core Strategy policies which are considered relevant to the development proposals’. Given the care which URS appear to have taken to mention any core policies which might possibly appear to support their client’s proposed development, this suggests a desire not to bring this particular relevant policy to the attention of the Planning Committee.
One of the important points which must be put to Brent’s Planning Committee for them to consider and decide is whether the proposals in this planning application amount to ‘inappropriate development’. It is difficult to justify the proposed building of 95 new homes, in blocks up to 5 storeys high, on a site of only around half an acre, as protecting the ‘distinctive suburban character’ of Willesden Green.
FAILURE TO PROVIDE AFFORDABLE OR FAMILY HOUSING
Brent Council’s Core Strategy for planning includes Part 5 “Planning for More and Better Housing”. At para.5.72 this states: ‘Maintaining and providing a balanced housing stock is a key Core Strategy housing objective’, which is set out in Core Policy CP21 as including:
‘An appropriate range and mix of self contained accommodation types and sizes, including family sized accommodation (capable of providing three or more bedrooms) on suitable sites providing ten or more homes’.
Part 5 of the Core Strategy goes on to look at affordable housing, showing that affordable housing is much needed in the borough, and that:
‘Brent has a particular need for larger family affordable housing, particularly for social rental, as the Brent Housing Needs Survey 2004 indicated that 43% of the affordable housing requirement is for 3-4 bedrooms.’
Brent’s Core Strategy acknowledges that targets for affordable housing come under the Mayor of London’s London Plan. It notes that:
‘The Examination in Public of the London Plan concluded that the expectation that all sites in London with a capacity for 10 or more homes should contribute to the overall strategic objective that 50% of London's new housing should be affordable was a robust policy assumption applicable to all boroughs.’
Section 3 of The London Plan (2011) deals with housing, and at para.3.9 it sets out a strategic target that 50% of new housing in developments of 10 or more homes should be affordable, and that 70% of affordable housing should be social housing.
Galliford Try’s original planning application (ref.12/1190) in May 2012 included 92 new homes, none of them affordable homes, comprising 40 x 1-bed, 48 x 2-bed and 4 x 3-bed units. This revised application is even further away from both Brent’s own housing and planning policies, and from the London Plan, because as well as again proposing no affordable housing it includes 95 new homes with none of them family sized ( 46 x 1-bed and 49 x 2-bed).
The reasons put forward as to why the planning application (ref.12/2924) should be accepted despite failing to meet planning policies on both affordable housing and providing family sized homes are claimed to be given in the Town Planning Statement submitted by URS (Galliford Try’s planning agents) in support of the application.
At para.6.1, on affordable housing, this says:
‘In this particular case, the objective is to deliver significant public benefits that consist principally of a new cultural centre in a building of a design that will make a substantial improvement to the local townscape and surrounding public realm, all at no cost to the taxpayer. In these circumstances it will not be possible to provide affordable housing within the scheme. A Viability Assessment, demonstrating as much will be submitted in support of the application in due course.’
On the family sized accommodation point, para.6.1 says:
‘The proposed development seeks to provide 95 dwellings within attractive blocks comprising 1 and 2 bed apartments. As the Cultural Centre is to be funded entirely by the sale of the residential units, no 3 bed apartments are provided within the scheme due to viability issues’.
Before Brent’s Planning Committee could consider approving proposals which so clearly breach planning policies, they would need to see in full, and be satisfied by, an independent Viability Assessment which URS promised to submit. What they have actually received is a Viability Statement dated 13 November 2012 prepared by URS themselves (see “WGCC-ViabliityExecSummaryNov2012” near the bottom of the online document menu). This states that:
‘A Financial Viability Assessment has been carried out by specialist assessors BNP Paribas Real Estate, at the request of the Greater London Authority. The financial results are confidential and, therefore, cannot be circulated publicly.’
URS then go on to give a brief summary of what they claim the assessment contains, saying that:
‘The report concludes that the development cannot provide both the cultural centre as well as affordable housing, as this would render the scheme unviable.’
What has been supplied is not an independent assessment, and not even a statement made by the specialist firm who are said to have made that assessment. Brent’s planners and Planning Committee should not accept the assurances of URS on this matter. In the absence of clear and convincing justification, the application fails to meet key planning policies on housing, and should be rejected.