Why the Growth Areas Were Chosen
1.0Summary
1.1This paper sets out the reasons for the choice of the council’s Core Strategy Housing Growth Areas. As the Core Strategy has to be succinct, there is not an opportunity to explain fully the options considered in selecting growth areas and the other possible options that were rejected and the reasons that such choices were rejected. This document sets out the reasons for the choice of the Growth Areas.
1.2When going through the Options and Preferred Options stages it may be that in appraising the individual policies of the Core Strategy, the individual parts of the overall growth strategy were better appraised than the sum of the parts. This has led some, including the Inspector to the withdrawn Core Strategy, to note that there appears to be confusion over where the growth strategy is focused and what were the reasonable alternatives that were considered in arriving at the choice in the Core Strategy.
2.0What are the realistic choices?
2.1Housing Growth is set in the form of targets in the London Plan. This target to be exceeded followed a study of Housing Capacity; that is the number of likely sites that can be identified, with a small contribution from bringing empty homes back into use.
2.2The target for Brent is 11,200 from 2007/8 to 2016/17, an annual monitoring target of 1120 homes.
2.3In Brent, there is very little vacant land and housing development has to come from other,mostly brown-field,sites.
2.4To be in conformity with the London Plan the borough has to find ways to accommodate housing growth to exceed its London Plan targets.
3.0Main Issues
Main Choices Spatially
3.1The council considered the following possible choices;
Option 1-spread growth around all of its existing town centres and key public transport infrastructure nodes
Option 2-disperse growth across all areas of the borough
Option 3-concentrate growth on areas of opportunity that have good public transport access, are in need of regeneration and that can deliver jobs and infrastructure.
Option 4- centre main housing growth on the Wembley area only
Option 5-allow development on specific land use types (e.g.industrial land or on areas of poor quality public housing) to achieve the target
3.2Before looking at the options it is worth considering other useful objectives that new housing development may achieve:
What other objectives might Housing Development achieve?
3.3Aside from meeting the high level of housing need in the borough any strategy for housing growth has to consider other benefits:
- New housing can regenerate run down parts of the borough
- New housing on large scale can create a new sense of place
- New housing can generate the provision of new services when a critical service threshold is reached
- New housing can help provide jobs when, as a significant part of mixed use development, helps to deliver employment uses that may be otherwise unviable.
- Where located near to public transport, it can result in a reduction in the proportion of car trips made
- Higher density housing near good public transport services makes sustainable use of scarce land resources
- Provides new stock that has better energy and other resource use standards
- There is a need to consider the disbenefits also. These are:
- New housing in the wrong location can lead to rising levels of road and public transport congestion as well as increasing pressure on other infrastructure
- New housing can increase pollution and resource consumption
- New housing can displace employment uses with a consequent loss of jobs
What are the key tests to assess growth options?
3.5The key tests in order to assess the benefits and drawbacks of each option are set out below:
- Opportunities of bring forward land for housing
- Sustainable Transport Location
- Regeneration benefits
- Employment Benefits
- Infrastructure Provision
- Compatibility with other plans and programms
- Environmental and social sustainability
- Viability
- Deliverability
- The test set out above attempt to measure the success of each option:
- Test one assesses whether land is available which can bring forward housing in a timely way.
- Test 2 assesses whether the options are in locations with good public transport access(as measured by PTAL score) so that high densities can be supported and car journeys reduced as the location offers choice of transport modes.
- Test 3 is to assess whether or not there is physical regeneration in an area that is run-down which includes derelict land or where significant vacant sites exist
- Test 4 looks at whether the development of land will also deliver development providing new jobs such as with mixed use schemes
- Test 5 is concerned with whether existing infrastructure or proposed new infrastructure is capable of meeting demand and is suitably located
- Test 6 assesses whether housing growth is compatible with the Council’s or the Mayor of London’s other plans and programmes, e.g. the Brent Community Strategy or the London Plan
- Test 7 deals with whether or not the locational option would unduly impact upon the local environment and on use of resources or whether it would result in an imbalance or strain on the provision of social infrastructure.
- Test 8 considers the viability of various options
- Test 9 assesses the prospects for delivery of the various options
What are the benefits and drawbacks of each potential option?
Option 1
Concentrating housing growth in town centres and on key transport nodes
3.7The option of focusing growth in all of Brent’s town centres and main transport interchanges takes advantage of good public transport access (shown by high PTAL levels) and good access to shops and services, whilst achieving higher densities and lower car parking. With 16 town centres and a number of other interchanges, the impact on any one centre or interchange could be limited. It may be that these levels of growth could be absorbed into the existing infrastructure capacity. In terms of policy such an option of higher density mixed use town centre development would be encouraged as a matter of policy.
3.8The main drawback to option 1 is that there are few readily available sites in most of Brent’s highly developed town centres. Intervention by the council would be needed to acquire and amalgamate sites that in town centres will largely be comprised of shops with residential uses over them. Not only would such intervention be disruptive for businesses, as well as socially, neither the council nor its partners have the resources or the financial capacity to progress the inevitable CPO action that would be needed to progress a town centre development option. The council can point to the difficulties experienced in securing fairly modest acquisitionsin town centres and around stations in Wembley (e.g. West End site), in Church End and adjacent to Queens Park station. In terms of development on and around station interchanges many of the stations have been developed (Wembley Central) or have other reasons for them not coming forward (e.g. Kilburn Park is listed and Network Rail does not support development over Queens Park as it would negatively affect much needed track capacity).
3.9Option 1 is not, therefore, considered to be a deliverable solution and would be delivered only at significant financial and social cost. It would not appear to bring forward the equivalent economic benefits of option 3.
Option 2
Dispersing Housing Growth evenly over the whole borough
3.10The option of housing growth dispersal more evenly over the whole borough may have the benefit of reducing the impact of growth so that it may be better absorbed into each area. However, sites would need to be available across the borough when they are clearly not, as shown by successive London-wide housing capacity studies. Such a strategy is likely to increase car use because many locations would have poor public transport accessibility. In all probability development would need to be within established residential area and would encourage building at higher densities and using back gardens, thus affecting the character of such established residential areas. Providing housing development in existing residential areas would not bring forward the employment and regeneration benefits that other options will.
3.11To summarise, because of a lack of available sites across suburban residential areas, dispersal of housing growth would require the development of sites that cause harm to the character of established areas over sites for which development provides a more positive benefit. For this reason option 2 is not supported by the council.
Option 3
Proposed Growth Strategy- FiveGrowth Areas
3.12Option 3 is the one selected by the council as it mixes a deliverable strategy with the most desirable planning outcomes and for which there are fewest planning policy constraints. This option will benefit areas in need of regeneration on a scale that will allow not just the development of individual sites but the creation of new neighbourhoods with much improved public realm, that creates a sense of place− development and public realm are delivered in tandem. The sense of place is further enhanced by bringing forward a sufficient scale of development to deliver social and other infrastructure. It will also focus development where public transport access is generally good, or will deliver sufficient development in a single location which will be capable of funding significant transport improvements.
3.13The counter argument to Option 3 is that some of the growth areas are too large and will over concentrate housing growth, thus creating environmental and traffic related problems. Also that it will overload social and other facilities and not provide sufficient open space to meet all the new communities’ needs. It will also reduce the chances of other town centres being regenerated as it concentrates growth to a limited number of centres. However, although there may be some local environmental and traffic impacts associated with the strategy of concentrating housing growth, the strategy delivers a more sustainable approach long term by, for example, promoting greater use of public transport rather than use of the private car and by negating the environmental impact on substantial parts of the borough that dispersal of growth would have.
3.14The combination of a practical approach to deliver housing growth in sustainable locations with positive regenerative benefits and new infrastructure is the main reason for the council supporting this option.
Option 4
Concentrate Growth in the Wembley Area
3.15Growth could be concentrated almost entirely within the Wembley area because it has the capacity to deliver housing targets. The benefits of this option are that it would cement Wembley’s place as the key economic driver for the borough, while reducing pressure on the other areas of the borough that may not be so well placed to accommodate growth. Promoting housing development on a large scale would help bring forward sites in an area that has very good transport accessibility and good prospects for delivering social and other infrastructure.
3.16The main problem of concentrating growth in a single location is that there will potentially be a burden on existing infrastructure in the local area. For example, it would require that most, if not all, of the additional school capacity needed to meet growth to be located locally. This would not be possible without there being a significant reduction in the level of growth that can be brought forward. It is better to have a strategy that can result in certain of the infrastructure requirements being spread. For example, schools which can be expanded in other parts of the borough can also contribute to the need that is generated. Also, such a strategy does not help spread the regenerative effects of new housing development to other areas that may need it. There is also a risk that the development of the strategy is concentrated in an area with one major land owner: this could be an advantage in delivering development but a risk that only one landowner could implement the whole strategy.
3.17In conclusion, the risk of concentrating growth would raise delivery issues and potential congestion problems while not spreading the benefits of housing growth. It may also mean that sites that can potentially contribute to meeting housing need in other areas would remain undeveloped. For these reasons the option is not supported.
Option 5
Development on either industrial land or on poor quality council estates
3.18A possible option for accommodating housing growth could be targeting particular types of land use such as industrial land or redeveloping the poorer housing stock as higher density housing. A benefit of both of these options is that land values are likely to be significantly lower than residential development value and thus allow viable development to come forward with necessary infrastructure support. In terms of industrial land, this change in value would encourage land owners to bring land forward for development and thus provide a deliverable strategy. Both land use based options would help regenerate some of the areas of poorest quality in the borough.
3.19In considering industrial land there is insufficient unprotected industrial land supply (local sites and borough sites) and such a strategy would require the development of StrategicEmploymentLand, currently protected by the Mayor’s London Plan. The industrial land option may renew some industrial units as part of the development but it would result in the loss of a significant number of jobs. This option would concentrate housing development in areas of poorer public transport access and in areas that have a poorly developed social infrastructure and a poor public realm. Much of the ownership in industrial areas is fragmented and land assembly would be challenging.
3.20The redevelopment of poorer quality housing stock is an option that could provide significant new dwelling stock. The problem is that most of Brent’s large estates, such as Stonebridge, Chalkhill and Church End have been redeveloped and Barham and South Kilburn are the next priorities but they do not provide significant additional housing potential. Most other estates have a high level of private ownership as a result of ‘right-to-buy’, making acquisition and development difficult. Also, some areas are not suitable to be redeveloped at higher densities. This is not considered, therefore, to be a practicable option.
3.21In conclusion option 5 has real problems in practice in terms of policy (industrial land) or land assembly (housing estates). Neither of the land uses neither are particularly well located nor bring forward employment benefits. They are not therefore options supported by the council.
Conclusions
3.22Five options have been considered in bringing forward housing growth in the best and most sustainable locations and in order to secure other planning objectives such as employment growth, physical and social regeneration and to minimise the negative impact of such housing growth. Each option has been assessed against a number of key tests that reflect the Core Strategy Objectives and also assess the deliverability of each option.
3.23In making that assessment against a wide range of factors rather than individual policies, Option 3 remains the council’s preferred option in terms of approach to growth area spatial strategy.
L B Brent Planning Service
November 2008
Appendix 1 Summary of Options
Note that numbers in the table relate to the key tests set out above
Option 1- Spread Growth around all existing town centres and public transport nodes.Benefits / Drawbacks
1. Spreads growth in up to 16 main centres-needs only 700 homes per centre
2. Development in areas with good PTAL scores
3.Helps small scale regeneration of local centres, gradual improvements in town centres
4.Maintains employment in all centres
5.Reduces transport impact on one centremay allow expansion of existing infrastructure
6. Mixed use development compatible with London Plan and current borough policy
7.Reduces environmental impact on any one centre
8. Requires range of smaller sites
9. Risk is spread over a number of smaller sites / 1.Opportunities to develop in available sites are limited so will need to acquire and build on well used town centre sites.
2.Many transport interchanges/stations are not available to locate development-e.g. Queen’s Park , Kilburn Park (listed) or have been built over (Wembley Central)
3.Misses opportunities from large scale regeneration
4.Unlikely to get employment benefits with retail expansion such as at Wembley
5.Cost of new infrastructure will be high if needed as lack of nearby development sites
6.Some town centres, e.g. Willesden, Harlesden have conserved cores which we wish to preserve
7. May be economically disruptive and affect social cohesion as existing retail/residential high street frontage is redeveloped at higher density.
8.Acquisition in centres that have residential development above shops likely to be costly and time consuming