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.
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