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Quintain submit bumper bundle to next Brent Planning Committee

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Quintain's developments from Barn Hill
Brent Planning Committee must be having difficulty in keeping up with the speed and complexity of Quintain's planning applications. The April 26th meeting will hear two pre-applications from Quintain and decide two applications. These items of interest in the context of my previous posting on Brent;s definition of affordable housing.

The first pre-planning application will be for the 'Green car park' where 500 'affordable' (see posting below) and private housing units are proposed above a 77 coach park and 212 car park.

On affordable housing officers' comment:

The submission documents have not included details on the proposed provision of affordable housing within the scheme, officers understand that this is still under consideration by the application team and will be included within any submission. London Plan policy 3.12 requires borough’s to seek the maximum reasonable amount of affordable housing, taking account of a range of factors including local and regional requirements, the need to encourage rather than restrain development and viability. The policy requires borough’s to take account of economic viability when negotiating on affordable housing. 

The applicant will be required to demonstrate that the maximum reasonable amount of affordable housing is being provided in this scheme unless the proposal achieves the Council’s target of 50 % Affordable Housing with a 70:30 split of Affordable Rent to Intermediate housing. This would need to be tested through the submission of a financial appraisal submitted with any future planning application which would be subject to scrutiny by or on behalf of your Officers. 

The application is proposing build to rent units within Plot E05. This will be the first purpose designed PRS block within the Wembley Masterplan and is proposed to improve marketability and absorption rates thereby allowing more units to be delivered more quickly. 

Quintain have stated they will provide affordable housing at a level to be agreed, having regard to viability testing, which has not yet been concluded. 

Units would be designed to meet the noise criteria set out within the outline consent and thus will be appropriately designed to mitigate against stadium and road noise.
The proposed mix of units does not accord with the housing mix specified within the Wembley Area Action Plan, which a considerably higher proportion of studio and one-bedroom units proposed. The applicant has specified that they would look to balance the mix of units through the delivery of additional larger units within subsequent phases of the masterplan. Officers consider this approach to be acceptable in principle as it would look to establish a balanced mix of housing in the area and are working through the implications of this with the applicant. However, given the predominance of smaller units, officers consider it necessary to secure a convent (covenant?) which requires the units to be owned and managed by a single organisation as Private Rented Section accommodation for a reasonable period of time.
The second pre-planning presention is on what Quintain are calling the Fulton Quarter (Wembley Retail Park and Fountain Studios). Quintain are holding a public consultation on this next weekend LINK.

In this case the Brent officers do make a passing reference to the new London Mayor's Supplementary Planning Guidance LINK but note also that the application does not include the units with more bedrooms needed by Brent residents:

The Wembley Area Action Plan specifies that mixed use development with predominantly commercial uses is acceptable in this location. Appropriate uses include retail, office, leisure, student accommodation, hotel and community use with a limited amount of residential. Additionally, the site lies within the Strategic Cultural Area where leisure, tourism and cultural uses are encouraged. The Area Action Plan specifies that at least one of the buildings should be in education use. 
A key element of the proposals is the potential to deliver a new higher education facility for Wembley. Whilst these discussions with potential institutions and the Council are still at a relatively early stage, the Fulton Quarter Masterplan has been designed with flexible buildings which can be used to accommodate an educational use should the discussions progress further over the coming months. The preferred location for this use would be fronting on to Olympic Way and adjacent to the College of North West London. 
The variety of proposed uses for the site are considered to be acceptable by officers and will ensure an appropriate environment is created in line with the Area Action Plan.

Affordable Housing
The proposed provision of affordable housing within the scheme is still under consideration by the application team and will be included within any submission. London Plan policy 3.12 requires borough’s to seek the maximum reasonable amount of affordable housing, taking account of a range of factors including local and regional requirements, the need to encourage rather than restrain development and viability. The policy requires borough’s to take account of economic viability when negotiating on affordable housing. 
The applicant will be required to demonstrate that the maximum reasonable amount of affordable housing is being provided in this scheme, and this would need to be tested through the submission of 
a financial appraisal submitted with any future planning application which would be subject to scrutiny by or on behalf of your Officers. 

The applicant is proposing a broad mix of units with final number yet to be agreed. The housing mix does not fully accord with the mix set out within the Wembley Area Action Plan with a greater proportion of Studio and 1-bedroom units proposed.

In the intermediate/discounted market rent and sale tenures, Quintain will look to provide the predominance of units in these tenures as studio, one and two bedroomed units.
It is expected that the units will be provided across the rented and sale tenures and so will be designed and brought forward having regard to the Housing SPG 2012 and the further evolving guidance on PRS from the Mayor. 

 The first planning application (17/0328) is for a slab of land described as:
Olympic Way and land between Fulton Road and South Way including Green Car Park, Wembley Retail Park, 1-11 Rutherford Way, 20-28 Fulton Road, Land south of Fulton Road opposite Stadium Retail Park, land opposite Wembley Hilton, land opposite London Design 

 In this case the application covers a change in the proposed layout of Plot W06:

The proposed changes to the parameters of Plot W06 are as follows:

The re-orientation of the massing of the building to create two distinct buildings, with no proposed change in height;  

Splitting of the approved B1 and C3 uses into the two separate buildings; and  

A change in the form and location of the open space as a consequence of the amendment to the buildings.
It is worth noting that the housing component of the scheme has 115 for private rent and 35 London Housing Bank units which at 80% of market rents are not affordable to most Brent residents
  35 units are provided as London Housing Bank units. This is a time limited affordable housing product, supported by the GLA, with rents set at 80% of the market level for a minimum period of seven years. In accordance with the GLA guidance, after seven years these units can be sold to the market or to tenants as individual homes, retained as affordable housing or transferred into the company’s housing portfolio. A decision will not be made until much nearer the time but the potential for tenants to either remain or relocate to other units (private or Discount Market Rent) within the wider Masterplan scheme will be a key consideration so as to maintain a strong sense of community and to ensure that Wembley continues to develop as a vibrant, balanced and sustainable neighbourhood. This is to be comprised as follows:  9 studio, 15 1 bedroom, 11 2 bedrooms 0 3 bedrooms
The second application for the 'Land North East of Wembley Stadium' (17/0462) is likely to be most controversial with Wembley National Stadium Limited making representations.
The proposal for Plot E01 E02 comprises of four buildings splayed radially, providing 3 distinct landscaped gardens. The proposed development provides 633 residential apartments and 3,376sqm GEA of non-residential floorsapce together with cycle parking for residents, all associated external amenity space, hard and soft landscaping and ancillary areas including a basement.  

Residential Accommodation
• The ground floors will accommodate residential entrances and lobbies, concierge facilities, commercial spaces, residential amenity, circulation and primary access to upper floors.
• Building 1 provides 195 residential apartments across 15 levels above podium floor.
• Building 2 provides 186 residential apartments across 12 levels above podium floor.
• Building 3 provides 153 residential apartments across 12 levels and upper ground floor. • Building 4 provides 99 residential apartments across 12 levels and upper ground floor. • Each apartment has access to a private balcony or terrace. 

Non-Residential Space
The proposal as submitted proposed the provision of 3,376sqm GEA of non-residential floorspace within the ground and lower ground levels that would be used for purposes within Use Classes A1-A2, D1-D2 and/or B1 on its Northern, Western and Southern facades within Block 1, 2 and 3. However, this does not fully accord with the parameter plans approved through the outline consent which only allow uses within Use Class D1 (community) and C3 (residential dwellings) within these plots. As such, a condition has been recommended restricting the use of these units to Uses Class D1.
 Wembley National Stadium say:
Wembley National Stadium Limited (WNSL) 
WNSL supports the principle of high quality development within Wembley Park that will improve the surrounding environment of the stadium. The close relation of plots E01/E02 to the stadium and the scope for impact on existing operations means these proposals are of particular importance to WNSL and we raise the following key points. 
 
1.         Introduction of non-residential uses WNSL does not necessarily oppose the principle of ground floor A2, B1 or D2 uses in Plot E01/E02, however, it can only support this inclusion if it satisfied the potential uses would not impact event day operations. Of particular concern is the proposed A1 use and the impact this could have on the flow of spectators through the area, including Perimeter Way East. Retail uses would introduce the possibility of crowd flow pinch points which could cause safety and security issues and impact the access and egress times. WNSL would only consider A1 use acceptable in E01/E02 if appropriate measures were put in place to mitigate any event day impact.
2.         Active frontages on Perimeter Way East The reserved matters application is inconsistent with the approved parameters in terms of the extent of the defined active ground floor frontage and pedestrian entrances for the E01/E02 scheme. In principle, WNSL do not object to pedestrian entrances from Perimeter Way East; however, for stadium event day safety it cannot support the use of commercial frontages on Perimeter Way East during event operations.
3.         Servicing and Residential Movement WNSL consider a condition should be attached to any permission that clears and restricts all movement on Perimeter Way East on event days unless for required emergency services.
WNSL request further information in relation to ‘resident movement on event day’ to demonstrate how this will be suitably managed and controlled
4.         Noise The application does not seek to discharge Condition 34 which relates to residential units affected by externally generated noise. WNSL look to forward to future confirmation that the noise levels set out in the condition are adhered to.
5.         Design The application material does not provide an elevation from Olympic Way that shows both plots E01/E02 and plot W03 and how they relate to the stadium. An additional drawing is requested so that this key view can be appropriately reviewed.
6.         Car Parking The proposed car park access for Plot E01/E02 is indicated to be made from the adjacent E05 car park. This may be an acceptable solution but cannot be confirmed until a scheme is approved. Accordingly a condition is required that prevents any use of the car parking spaces as shown on the submitted drawings until a satisfactory access arrangements have been approved.
Brent Officers note the points raised by WNSL and have the following observations to make:
1.  The flexible use of the non-residential uses for purposes within a number of Use Classes (A1, A2, D1, D2 or B1) is proposed within the submission. However, this is not considered to materially accord with the parameter plans which only allow Use Class C3 and D1 within this plot. As such, a condition has been recommended restricting the use of these units to Use Class D1.
2.  The introduction of active frontages on perimeter way is supported by officers. It is considered that this is a good design approach based on sound principles and will activate the southern side of the building as well as providing surveillance on what may otherwise become and under-used service road. It also contributes to the relationship between the proposed development and stadium and will provide an appropriate environment on non event days for future residents of the building and locality. In relation to event day safety, the measures referred to above are considered sufficient to ensure the subject site is appropriately managed and therefore reduce their event day impact. Active frontages for two small non-residential units are proposed outside of the “Areas for Active Frontages” shown on “Parameter plan 08 - Proposed Uses” which was approved through the outline consent. However, this is not considered to materially change the scheme, given the scale and nature of the proposals within the outline consent and the material planning considerations associated with this element of the proposal. The outline consent allows non-residential uses at ground floor level and the parameter plan identies parts of these plots facing both Olympic Way and Perimeter Way East as being area for active frontages. Whilst the Reserved Matters proposals look to provide activity in areas slightly outside of those identified on the Uses parameter plan, they do not introduce them within streets where active frontages were not previously approved.
3.  Details on servicing and deliveries will need to be submitted under condition 26 of the Masterplan planning
permission which is required to be discharged prior to occupation. This will ensure appropriate measures are in place so as not to affect the stadium or crowd flow on event days.
4.  The reserved matters application does not seek to discharge condition 34 relating to the internal noise environment at this time. Details of this will need to be submitted under condition 34 of the Masterplan planning permission which is required to be discharged prior to occupation.
5.  The applicant has submitted an image of Plots E01/2 together with Plot W03. These show that the designs are not duplicates but have a similar language and officers consider they compliment each other when viewed together. The overall design approach and finished appearance of the development is supported by officers.
6.  The plans do not include access to the car park and therefore it cannot be accessed by vehicles. Condition 11 of the Masterplan consent restricts any vehicular access to this area unless details of access that do not conflict with stadium vehicular or crowd flows have been submitted to and approved in writing by the Local Planning Authority. Until such time the car park cannot be used. This is in compliance with the requirements of the masterplan and ensures that an appropriate approach will be secured before any vehicular movements to this plot take place.
 
39.8% (252 flats) of the residential units is provided as 'affordable' housing. 39.2% (248 flats) are to be delivered as private market rent. The remaining 21% (133 flats) are to be London Housing Bank dwellings. (See above) The mix comprises 123 x studios, 219 x 1bed units, 229 x 2bed units, 55 x 3bed units and 7 x 4bed units.  

I hope councillors will probe further into what is meant by affordable here. 





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