“Curiouser and curiouser!” Cried Alice (she was so much surprised, that for the moment she quite forgot how to speak good English). [Alice in Wonderland]
Despite recent publicity about planners ignoring the stipulations of Brent's own planning policies, as well as the London plan, convoluted arguments are used to justify ignoring them once again.
Brent had a 20% cap for the proportion of student accommodation in the Wembley area in terms of the total population. It had ruled that the cap had now been reached. However two applications are on the agenda for Parkwood House Albion Way and Unit 1-5 Cannon Trading Estate, in First Avenue for 283 and 678 beds respectively. The latter as part of a new campus for the University College of Football Business (UCFB) which includes educational facilities.
Planners use projected population growth to rule that the number of units in a 20% cap is actually higher than they had previously said:
The research carried out by officers took into consideration the actual consents (rather than an average 12% increase as argued by the applicants) and concluded that the projected population growth of the WAAP (Wembley Area Action Plan) area would have been 27,377 if considered solely on the site allocations, however when taking into consideration the site allocations, and deliverable planning permissions granted to date (both implemented and extant) the current WAAP area population increase as of October 2017 stands at 32,842. Based on this, it is considered that when considered against the 5444 student bedrooms granted to date, this would mean that the current percentage of student accommodation against residential population stands at 16.6%, which would allow for an additional 1,123 rooms before the 20% cap is reached.
The researched carried out by applicants and officers in relation to the Parkwood House application (17/2782) has significant bearing on this application. Given that Parkwood House (283 beds) and UCFB (678 beds) together propose an additional 961 student beds within the WAAP area, both schemes can be accommodated within the revised 20% student cap of 1,123 beds.The UCFB application has received 46 supporting comments and none against. Look a little further and you find that 39 of the 46 come from existing student accommodation in Victoria Halls, Felda House and Unite Students.
The Parkway development has not yet got a student accommodation provider to run the site. It consists of a part 13 and part 17 storey development. The height restrictions of the WAAP (Wembley Area Action Plan) are casually circumvented:
- The approach to the height, massing and material palette is supported as it will provide a high architectural quality that is appropriate for a building of this height. The site is designated within the Wembley Area Action Plan as "Inappropriate for tall buildings". However, the proposed building relates well to the other tall buildings within the immediate vicinity, forming a logical cluster of tall buildings that also achieves an appropriate relationship with the nearby lower mansion blocks to the north.
Further to the proportion of student accommodation and the height of buildings another long-running sore is Brent's attitude towards affordable housing. Too often planners do not state exactly what is meant by 'affordable' skating over the details but the report on the Quintain application for 'Land East of Wembley Stadium' has to respond to representations from the London Mayor's Office.
Affordable housing: 23% offered as DMR (Discounted Market Rent) at up to 80% of market rate is wholly unacceptable and must be significantly increased, noting the introduction of high density residential on this Opportunity Area and Housing Zone site. The affordability of the affordable housing must also be addressed. GLA officers will robustly scrutinise the viability assessment to maximise affordable housing provision. Once secured, any on-site affordable housing must remain affordable in perpetuity, and appropriate covenants and clawbacks secured in accordance with the Mayor’s Affordable Housing and Viability SPG
An initial offer of 23% affordable housing by the developer was reduced to 7% when Brent tried to make it truly affordable for Brent residents, but they find this proportion 'acceptable'.
For reference the London Living Rent is set by the London Mayor's Office based on median household income per ward. These are the Brent figures:In order to deliver affordable units at London Living Rent levels, more planning gain subsidy is required, and this change has a consequential negative impact on the quantum of affordable housing the scheme can provide when compared to the applicants’ original offer. The Council's consultants have advised the Council that at London Living Rent levels the maximum reasonable level of affordable housing provision that the scheme can currently viably provide is 28 units, representing 6.6% by unit (7% by habitable room). The applicants have offered 32 units, representing a minimum 7% by unit (8% by habitable room). It is accepted that the reduction in the affordable housing quantum from 23% to a minimum of 7% is a notable change, however after considering local housing needs and affordability and the wider Wembley Park affordable housing provision discussed above, officers take the view that this is outweighed by the important benefits associated with London Living Rent, including the significant increase in affordability that this tenure provides for Brent residents.
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The full details and basis for calculation can be found HERE
It should be noted that viability reviews usually reduce the amount of affordable housing rather than increase it.
This buildings will be 10-21 storeys high affecting views of the stadium so a curious feature of this application is the statement by Wembley National Stadium Limited which quotes its arrangement with Quintain as a reason for not opposing this scheme, although they appear to be really against it:
The scale, size and occupancy of the development is different to that previously approved for this plot, and the introduction of residential use has led to a significantly different form, massing and height for E05. This effects (sic) the view of the Stadium from Great Central Way, which is a key route into the Stadium for spectators, teams, officials and dignitaries. Ordinarily, this increase in scale and change in view may give cause for The FA to wish to object. Ordinarily, this increase in scale and impact may give cause for The FA to wish to object. (sic) In this instance however, we have a close working relationship and contractual arrangements in place with the applicant (which include provision of facilities, tenant management arrangements, anti-ambush protection and other measures to protect Stadium operations on both event days and non-event days). We do wish to put on record that any future developments of similar scale and size where we do not enjoy the same arrangements with the applicant will lead to an objection.