Agenda item

This paper addresses points that the Scrutiny Committee has indicated that it wishes to focus on in respect of the Brent Local Plan review. These are an overview of the Local Plan’s performance to date, along with the key priorities, proposed scope, approach, and governance arrangements for the upcoming review.

Councillor Benea (Cabinet Member for Regeneration, Planning and Property) was invited to introduce the report relating to the Brent Local Plan Review, which addressed points that the Scrutiny Committee had indicated that it wished to focus on in respect of the Brent Local Plan review. These were an overview of the Local Plan’s performance to date, along with the key priorities, proposed scope, approach, and governance arrangements for the upcoming review. The Local Plan had a key role in balancing social, economic and environmental challenges and opportunities. It was noted that London was distinctive in having a mayor responsible for a regional plan, enabling a more strategic approach across issues such as infrastructure, housing and employment, and ensured consistent policy application, such as minimum affordable housing requirements. It was further stated that London's economic strength also made it an attractive area for investment, leading to some of the highest standards of development, quality and environmental performance in the UK.

 

In continuing the response, Alice Lester (Corporate Director for Neighbourhoods and Regeneration) provided further context regarding the strategic challenges currently facing the delivery of development projects. It was acknowledged that, while economic cycles were often described as cyclical, a number of industry professionals had expressed the view that the present difficulties were more structural in nature. A range of approaches were being explored to address the prevailing challenges, with particular focus on establishing a framework to facilitate the effective delivery of projects on site.

 

Having thanked Councillor Benea and Alice Lester for introducing the report, the Chair then moved on to invite questions and comments from the Committee in relation to the Brent Local Plan Review report, with the following comments and issues discussed:

 

• As an initial query, views were sought around the principal objective or focus that Brent’s Local Plan should aim to deliver for residents. In response, Councillor Benea (Cabinet Member for Regeneration, Planning and Property) emphasised the importance of delivering affordable housing that met the needs of Brent’s diverse communities. It was noted that a mixed tenure approach, with particular attention to family homes, was essential. Reference was made to previous work undertaken to assess the concentration of student accommodation in Wembley Park and it was confirmed that future planning would prioritise family housing. It was further stated that housing targets must be realistic and achievable within Brent’s context, while also aligning with the requirements of the London Plan. It was acknowledged that the current paper represented an early stage in the review process and that securing funding for the review remained a critical consideration. The Chair further clarified that the Local Plan document under consideration did not constitute a draft plan, but rather an early opportunity for scrutiny. The purpose of the discussion was to explore emerging ideas and provide constructive feedback to inform future iterations of the Brent Local Plan.

 

• The Chair then invited officers to reflect on the performance of the existing Local Plan, identifying both areas of success and underperformance, and to outline key lessons that would inform the Brent’s Local Plan review. In response, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) comprehensively explained that viability remained a significant factor in the delivery of development and would continue to be a central consideration in future planning efforts. While the current plan had successfully identified growth areas and facilitated considerable delivery, challenges persisted in achieving the appropriate mix of housing, particularly in relation to the affordable housing provision. David Glover (Head of Planning and Development Services) additionally reported that housing delivery had been strong until approximately 18 months prior, at which point a marked decline had been observed across the sector. It was noted that this trend was not unique to Brent but represented a broader issue affecting a number of Boroughs. The success of the Council’s master planning approach was highlighted, particularly in designated growth areas, where comprehensive frameworks had been established. However, it was acknowledged that current market conditions had rendered many developments unviable, with limited activity outside of student accommodation and co-living schemes.

 

• Members queried the implications of post-Grenfell fire safety regulations on the viability of high-rise versus low-rise developments. In response, David Glover (Head of Planning and Development Services) explained that the requirement for dual staircases in buildings exceeding 18 metres had significantly affected development costs. It was further stated that this regulation reduced the amount of usable space per floor, thereby decreasing the number of homes or commercial units that could be accommodated. Consequently, construction costs had increased, impacting both private and public sector schemes. The necessity of the regulation from a fire safety perspective was acknowledged but it was noted that its implementation had compounded existing pressures, including rising construction, labour, and finance costs. It was reiterated that the Council’s role was to enable development by providing clarity and certainty to investors, thereby encouraging investment and delivery within the Borough. Alice Lester (Corporate Director for Neighbourhoods and Regeneration) additionally noted that Brent had established a strong reputation within the development sector and attributed this to the collaborative efforts of officers, members, and senior leadership, with it being highlighted that the Council was regarded as a reliable and proactive partner. It was stated that, despite the challenges ahead, Brent remained a Borough in which developers were willing to invest, in contrast to other areas where there had been disengagement with investing.

 

• Members raised questions regarding the Council’s approach to renovation and the utilisation of existing buildings, particularly in light of escalating build costs. In response, David Glover (Head of Planning and Development Services) informed that the Brent Local Plan encompassed all forms of development, including renovation, extensions, and changes of use. It was noted that in many cases, renovation did not require planning permission and would instead be subject to building regulations. As such, while renovation was supported, it was not always captured within the scope of the Local Plan. It was confirmed that substantial change was occurring in Brent, and that the Council remained responsive to opportunities for adaptive reuse and redevelopment of existing buildings.

 

• The Chair posed questions regarding the scope of the Local Plan in supporting alternative methods of suitable housing delivery, with a specific focus on whether the Local Plan could outline targets related to renovation and other non-new build approaches. David Glover (Head of Planning and Development Services) responded by stating that flexibility in delivery mechanisms was essential to achieving meaningful outcomes. It was explained that the existing Local Plan had already identified intensification corridors and town centres as areas suitable for increased development. However, the form that such development might take would vary significantly depending on site-specific conditions. It was emphasised that the most effective approach was to establish clear parameters for each site, including expected building heights, land use composition, and the balance between residential and commercial uses. It was noted that flexibility should be maintained to allow for renovation, extension, or new build, depending on viability and context. Jehan Weerasinghe (New Corporate Director for Neighbourhoods and Regeneration) referenced the current policy context and noted recent national announcements, including the allocation of £39 billion to the Affordable Housing Programme and the introduction of a ten-year rent settlement, which had provided long-term financial certainty to the sector and created a buoyant environment within which Registered Providers (RPs) could effectively work. The potential for cladding costs to be reclaimed through the Building Safety Fund was additionally noted, which had further increased delivery capacity. The importance of the Council engaging proactively with delivery partners to translate this positive policy context into tangible housing outcomes was stressed. Brent’s strong reputation within the development sector was highlighted, with it being noted that Brent was currently among the top-performing boroughs in building social housing in London. In concluding the response, Jehan Weerasinghe highlighted the successful completion of the procurement process for a single delivery partner in South Kilburn, and extended gratitude to the officers involved in that work. The Chair noted for the public record that Registered Providers (RPs) would be responsible for delivering the social housing referenced.

 

• Details were sought around whether the Local Plan would strike an appropriate balance between promoting new development and investing in existing housing stock and infrastructure. Members expressed concern that infrastructure delivery often lagged behind housing development and asked whether the Local Plan would ensure that infrastructure readiness was embedded from the outset. In response, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) confirmed that an Infrastructure Delivery Plan would be produced alongside the Local Plan, which would set out the facilities required to support housing growth and include a structured approach to phasing and timing. Paul Lewin (Spatial Planning Manager) further added that development generated significant income for the Council through mechanisms such as the Community Infrastructure Levy (CIL), Section 106 obligations, the New Homes Bonus, and increased council tax revenues. It was noted that while many of these funding streams were realised post-development, the Council had now accumulated sufficient infrastructure levy funds to begin allocating substantial resources to infrastructure projects, some of which would be delivered in advance of housing schemes. The balance between renovation and new development was further addressed, with it being explained that planning policy primarily governed new developments requiring planning permission, whereas renovation often fell outside the scope of the Local Plan. Nonetheless, the reuse of buildings was encouraged under the London Plan hierarchy in respect of carbon embodiment, and Brent’s Local Plan would reflect this principle. The disparity between the Borough’s housing targets and the capacity of small-scale schemes to meet those targets was highlighted. The Committee heard that the current Local Plan set a minimum target of 2,325 dwellings per annum, of which approximately 440 were expected to be delivered through small scale conversions, extensions, and changes of use. It was noted that the majority of housing delivery would therefore need to occur in designated growth areas through higher-density development.

 

• The Chair raised questions specifically regarding whether the Brent Local Plan was solely focused on growth areas and future development, or whether it could also address retrospective investment in areas where development had already occurred but where infrastructure gaps had since been identified. In response, David Glover (Head of Planning and Development Services) clarified that the Brent Local Plan was a statutory planning document concerned with development, including the construction of new buildings and changes in land use. It was explained that the Local Plan did not cover the maintenance or upkeep of existing buildings, as such activities typically did not require planning permission and therefore fell outside the remit of the Local Plan. It was further explained that the Council received Community Infrastructure Levy (CIL) contributions from new developments, which were required by legislation to be spent on infrastructure that supported development. While the funds were not tied to the specific developments from which they originated, they were required to demonstrate a link to development activity. This provided the Council with a degree of flexibility in determining how best to allocate infrastructure funding across the Borough, provided that the expenditure supported development in a general sense. However, infrastructure projects that were unrelated to development could not be funded through CIL, regardless of their merit, due to legislative limitations.

 

• Members sought clarification on earlier comments regarding the shift from cyclical to structural challenges in the development sector, questioning what specific structural issues were currently affecting delivery. In response, Alice Lester (Corporate Director for Neighbourhoods and Regeneration) explained that the challenges were multifaceted and cited a significant increase in construction costs, estimated at approximately 40% over the past 5 years. Although the rate of increase had slowed, costs had not decreased, resulting in a sustained elevation in development expenses. Restricted access to finance and the withdrawal of industry investors from the market were also highlighted as key structural issues currently hindering development.

 

• Members questioned the appropriateness of the term ‘Local Plan’, expressing concern that the process lacked meaningful local input from both councillors and residents. It was queried whether the term ‘local’ referred to the geographical location of development or to the decision-making process itself. In response, Alice Lester (Corporate Director for Neighbourhoods and Regeneration) informed that the Local Plan was indeed a local document, serving as the spatial development strategy for the London Borough of Brent. It was acknowledged that the Brent Local Plan was developed within the framework of regional and national policy. It was further noted that Brent had received recognition for its community engagement efforts during the preparation of the previous Local Plan, including an award from the Royal Town Planning Institute. David Glover (Head of Planning and Development Services) further mentioned that housing targets were based on evidence of need. It was explained that targets were also set for employment space, industrial capacity, and other land uses, based on analysis of what was required to support the Borough’s growth. It was acknowledged that the scale of housing need was significant and that there was ongoing debate about how best to meet that need, such as suburban intensification, increased building heights in well-connected areas, potential expansion into the Green Belt or a combination of strategies. In concluding the response, it was highlighted that the Brent Local Plan was evidence-based and designed to meet the Borough’s long-term housing and employment needs.

 

• Members expressed concern that the Local Plan placed insufficient emphasis on the quality of life for both existing and new residents and cited a recently constructed residential block in Alperton that remained largely unoccupied and was currently covered in plastic sheeting due to unresolved cladding issues. The living conditions were described as unacceptable, and it was questioned how such developments had been permitted. Concerns were also raised around the mismatch between local housing needs and the types of housing being delivered. It was noted that there was a clear demand for larger family units, yet a disproportionate amount of student accommodation had been approved. It was felt that this approach may have assisted in meeting financial targets but failed to address the actual needs of Brent residents. Members concluded by referencing a 1934 planning document for Wembley, which had prioritised quality design, open space, and liveability, and expressed regret that such principles appeared to have been lost in current planning practices.

 

• Further information was sought by members regarding the continued emphasis on tall buildings within the Local Plan, noting that the cost of construction increased proportionately with height and therefore flats located on higher storeys tended to be more expensive to build than those on lower levels, thereby impacting overall viability. It was queried whether financial experts could be engaged to assess what constituted a sensible and financially viable building height in the current climate. In response, David Glover (Head of Planning and Development Services) acknowledged the validity of the concern and affirmed that the Brent Local Plan was not solely focused on financial targets, but rather on delivering high-quality homes for residents. It was stated that while housing need calculations were essential, the priority remained the provision of suitable and liveable accommodation. Reference was made to international examples of high-density living, and it was noted that Brent had developed Supplementary Planning Documents (SPD), including the Residential Amenity and Place Quality SPD, to guide the delivery of well-designed, high-density developments. It was further explained that student accommodation had become more prevalent due to its increased viability but acknowledged that it did not necessarily align with the Borough’s most pressing housing needs, which included affordable housing and family homes. In relation to building heights, it was confirmed that viability assessments were conducted during the preparation of the Brent Local Plan, as well as during the development of supplementary planning documents (SPD) and masterplans. These assessments considered the cost implications of different building types and identified thresholds at which construction became significantly more expensive. It was noted that given the Borough’s limited land availability and the scale of housing need, it would not be feasible to meet targets solely through low-rise development. As part of the Local Plan review, residents would be consulted on their preferences, for example in relation to suburban intensification, increased height in growth areas, or a combination of both approaches.

 

• The Chair questioned whether the financial modelling undertaken as part of the Local Plan review could be shared with councillors, particularly through a working group similar to that established during the previous review. The Chair expressed interest in ensuring that councillors had the opportunity to engage with viability testing and contributions to the financial modelling. In response, Paul Lewin (Spatial Planning Manager) confirmed that such engagement would be possible and explained that the Council’s viability modelling involved testing a range of development scenarios, including small-scale schemes such as the replacement of single dwellings with multiple flats. It was noted that while the number of scenarios tested was typically limited due to cost considerations, councillor priorities could be incorporated into the modelling process to ensure that the analysis reflected local concerns and aspirations. The Chair reiterated that, in addition to shaping the content of the Local Plan, members were keen to contribute to the consultation process itself, particularly given the early stage of the review.

 

• Queries were raised regarding the integration of neighbourhood plans into the Local Plan, with specific reference to the Kilburn Neighbourhood Plan. Members highlighted the extensive community engagement undertaken in the development of the plan and expressed hope that its findings would be reflected in the borough-wide strategy. Paul Lewin (Spatial Planning Manager responded by confirming that the Council had maintained close engagement with neighbourhood planning groups, including those in Kilburn. It was stated that the Kilburn Neighbourhood Plan was regarded as a complementary plan to the Local Plan, with no duplication of plans. The Council had supported the neighbourhood planning process and had not raised any fundamental objections to the contents of the Kilburn Plan, which was currently at the examination stage. It was affirmed that the insights and community feedback gathered through the neighbourhood planning process would be considered in the development of borough-wide policies. It was also noted that the Council would seek to incorporate elements that neighbourhood groups had found challenging to address independently, and it was recognised that the two planning documents evolved on different timelines.

 

• Members thanked Councillor Benea (Cabinet Member for Regeneration, Planning and Property) for reaffirming the Council’s commitment to affordable housing and acknowledged that this priority was widely shared across the local authority. Members observed the ongoing challenges in meeting affordable housing targets and questioned what targeted policy interventions or incentive mechanisms were being considered to increase the delivery of genuinely affordable homes. In response, David Glover (Head of Planning and Development Services) referred to the London Plan review currently underway and noted that the Council had not yet received the first draft of the revised London Plan, and that the initial consultation had been limited in detail. One of the key areas under review was the threshold approach to affordable housing delivery, which had been introduced by the Mayor of London to incentivise developers to meet minimum affordable housing levels without the need for detailed viability assessments. It was explained that under the current framework, schemes providing at least 35% affordable housing, or 50% on public sector land, were exempt from viability testing. This approach was intended to expedite the planning process by removing a significant source of delay and negotiation. It was stated that the Mayor was expected to review whether the current thresholds were set at appropriate levels and whether adjustments could further encourage affordable housing delivery. It was emphasised that if the threshold was set too high, it could render schemes unviable, whereas a threshold close to the viable point could incentivise developers to accept slightly reduced profit margins in exchange for greater certainty and faster planning consent. The importance of reviewing intermediate housing products was also highlighted, with concerns being noted about the affordability of shared ownership units. A growing demand for intermediate rented homes was identified, which could serve residents who were not eligible for social housing but could not afford private rented homes. It was felt that broadening the definition and scope of affordable housing would help address the needs of a wider range of residents in Brent.

 

• Following up, members questioned whether there were any specific policy interventions or incentives that Brent could implement at this stage of the Local Plan review, acknowledging the need to remain aligned with the Mayor’s policy framework. In response, David Glover (Head of Planning and Development Services) advised that it was difficult to determine the scope for local interventions until the revised London Plan had been published. It was reiterated that Brent’s Local Plan must operate within the parameters set by the regional strategy and that the Council’s ability to introduce independent measures would depend on the content of the Mayor’s policies. It was further mentioned that the Council’s focus remained on ensuring the viability of development proposals and maximising the delivery of affordable housing within those constraints. Alice Lester (Corporate Director for Neighbourhoods and Regeneration) additionally highlighted that while the Local Plan review would involve policy choices, the Council would engage with a wide range of stakeholders during the review process, including councillors, residents, community groups, businesses, and developers. There were also opportunities to pursue complementary actions outside of the Local Plan review. It noted that Jehan Weerasinghe, the newly appointed Corporate Director for Neighbourhoods and Regeneration, would be leading this work, which would include discussions with development partners, actively reviewing its own assets, considering a portfolio approach for development, or disposal of some sites to reinvest capital into affordable housing delivery. Engagement with public sector partners was also underway to identify collaborative opportunities.

 

• The Chair sought details on whether the Council’s recent property review would be reflected in the Local Plan. In response, Alice Lester (Corporate Director for Neighbourhoods and Regeneration) advised that the Local Plan would only incorporate specific site allocations where appropriate, such as Kilburn Square. It was clarified that planning policies were thematic and focused on land use rather than ownership. However, it was confirmed that the Plan would include provisions aimed at maximising the use of public assets to support development objectives.

 

• In addressing the balance between Brent’s local housing needs and the wider London housing needs, particularly in relation to student accommodation, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) stated that Brent would be a formal consultee in the London Plan review and would use that opportunity to advocate for its own housing priorities. Concerns about the concentration of student housing in areas such as Wembley were acknowledged and it was confirmed that this issue would be examined closely during the Local Plan review. It was noted that viability remained a persistent challenge, and in recent years, student housing had often been the only form of development progressing due to its viability. While investment of any kind was welcomed during periods of market stagnation, the need to strike a balance between viability and meeting local housing needs was stressed. It was added that where the Council lacked grounds to refuse a student housing proposal, it could consider securing financial contributions in lieu of on-site affordable housing, which could then be redirected to support Brent’s affordable housing objectives.

 

• The Chair expressed concern regarding the exploitative nature of much of the student accommodation being delivered. It was noted that such developments were often unaffordable for students and were sustained by a market underpinned by student loans. The Chair highlighted that students were frequently tied into inflexible contracts, even in cases where they withdrew from their studies, and that the cost of such accommodation often exceeded that of traditional shared housing. The Chair urged the Committee to challenge the assumption that student housing was inherently viable, given its reliance on a vulnerable demographic with limited housing choice.

 

• As an additional query, the Chair questioned whether there was a formal process for explaining instances where housing targets had not been met, particularly in cases where under delivery was the result of policy choices rather than market conditions. In response, Paul Lewin (Spatial Planning Manager) advised that no such formal mechanism currently existed. The Chair suggested that such qualitative feedback should be incorporated into Brent’s response to the London Plan. The Chair emphasised the importance of contextualising housing targets with explanations, particularly in relation to student housing, to ensure that Brent’s strategic position was clearly understood.

 

• The Chair stressed the importance of understanding the financial implications of planning decisions. It was noted that the Council’s temporary accommodation crisis had significant budgetary consequences and that the approval of certain housing types, or the inability to resist them, could exacerbate financial pressures. The need for the Local Plan review to include detailed discussions on the risks and consequences of planning decisions, particularly in relation to housing delivery and financial sustainability, was emphasised.

 

• With reference to paragraph 3.2.6 of the committee report (which highlighted a decline in new housing completions over the past 2 years), members questioned how lessons from delayed development sites, particularly those affected by viability issues, construction capacity, or regulatory delays, would inform future policy and delivery strategies. In response, Alice Lester (Corporate Director for Neighbourhoods and Regeneration) reported that the Council was still in the process of engaging with developers to understand the barriers to delivery. It was noted that many of the challenges were structural and beyond the Council’s direct control. Nonetheless, the Council would continue to explore ways to facilitate development and support delivery partners. Paul Lewin (Spatial Planning Manager) further added that the policies in the current Local Plan were designed to support development across the full cycle but acknowledged that there was inflexibility in some areas. For example, while the Brent Local Plan set affordable housing targets, these were subject to viability assessments on a case-by-case basis.

 

• Details were sought regarding how the Brent Local Plan review would address the delivery of a balanced housing mix, particularly the provision of 3 bedroom and larger family homes, while also managing the challenges of viability and affordable housing targets. It was noted that the current delivery rate of such homes stood at less than 12.2%. In response, Paul Lewin (Spatial Planning Manager) informed that the current Local Plan policy already represented a compromise between identified housing need and viability considerations. It was explained that while the Borough’s needs assessment indicated a higher requirement for larger homes, the policy target had been set at 25% due to the outcomes of viability testing. It was acknowledged that if viability conditions worsened, further prioritisation would be required, with some policy objectives potentially needing to be treated with greater flexibility, while others would remain non-negotiable. David Glover (Head of Planning and Development Services) further added that the Local Plan set out targets for a range of housing types, including family sized homes. However, at the planning application stage, decisions were made based on the specific circumstances of each scheme. It was additionally mentioned that in many cases, the target of 25% family homes was not met, particularly where the delivery of social rented housing was prioritised. It was also stated that the complex decision-making process was unlikely to change under the new Local Plan, as viability challenges associated with private 3 bedroom homes were expected to persist. It was confirmed that the review would include a reassessment of the need for larger homes and the appropriate targets, but that each scheme would continue to be assessed on its individual merits, with decisions made on the basis of what would deliver the most benefit in each case.

 

• Clarification was sought on what consideration was being given to the impact of Houses in Multiple Occupation (HMOs) on the availability of family homes, particularly those with 3 or more bedrooms. In response, Paul Lewin (Spatial Planning Manager) explained that the Council had adopted a policy setting out the circumstances under which HMOs would be considered acceptable. It was highlighted that Brent had gone further than many other London boroughs by introducing an Article 4 Direction, which removed permitted development rights for HMOs. This meant that planning permission was now required for the conversion of a dwelling into an HMO, even where the number of occupants was fewer than 6. It was confirmed that the Council had refused a number of HMO applications, primarily on the grounds of quality and, in some cases, location, including access to public transport and local services. It was acknowledged that while HMOs were not classified as affordable housing, they did provide an important housing option for single individuals and couples with limited means. It was emphasised that the Council continued to balance the need for such accommodation with the need to protect family housing stock.

 

• The Chair was keen to seek details around the alternative approaches, powers or ideas that were being explored as part of the Brent Local Plan review, particularly in light of the persistent challenges in delivering affordable housing. In response, Paul Lewin (Spatial Planning Manager) conveyed that the Council was actively exploring all available options to increase affordable housing delivery. It was reported that significant efforts had been made to identify and bring forward Council-owned sites, many of which had progressed to the point of securing or nearing planning permission. However, it was emphasised that the fundamental issue remained the lack of sufficient subsidy for affordable housing, a challenge that had persisted since the 1980s.

 

• Enquires were made by the Chair as to what elements of the Brent Local Plan might be strengthened to effect meaningful change, with interest being expressed in understanding the initial thinking around what could be done differently in the development of a revised Local Plan. In response, Paul Lewin (Spatial Planning Manager) advised that the key differences in a new Local Plan would likely relate to the intensity of development and the further optimisation of sites beyond current levels. It was explained that a wide range of options had not been presented at this stage, as many of the strategic choices had already been made in the previous Local Plan and were now being addressed through individual planning applications. It was noted that the existing policy framework allowed for a degree of flexibility, enabling the Planning Committee to prioritise on a site-by-site basis rather than applying a uniform approach across all developments. It was further stated that, from a policy perspective, the principal means of increasing affordable housing delivery would be to raise the overall volume of housing delivered within the Borough. The constraints posed by limited land availability and the need to consider the Borough’s character was acknowledged. It was highlighted that designated tall building zones had been introduced, with indicative height limits set for developments within those areas. However, due to ongoing viability considerations, these were subject to continual review to assess their appropriateness. Alice Lester (Corporate Director for Neighbourhoods and Regeneration) additionally noted that while it was possible to explore a wide range of options, such choices must be grounded in practical realities. It was recalled that the previous Local Plan had presented residents with a number of choices. It was acknowledged that there had been limited availability of suitable housing sites. The Council’s commitment to doing everything possible to foster confidence among developers and to simplify the planning process was reiterated. Planned workstreams were outlined, including the potential consolidation and expansion of the Neasden and Church End growth areas, and the exploration of suburban densification. It was also noted that Brent was among the few local authorities with an affordable housing policy applicable to small sites below the threshold of 10 units, which would contribute to affordable housing delivery.

 

• The Chair then queried the realism of the Borough’s affordable housing targets, noting the disparity between Brent’s stated target of 50%, the London Plan’s target of 35%, and the Borough’s actual delivery rate of 19%. The Chair questioned whether the targets were achievable or merely aspirational. In response, Paul Lewin (Spatial Planning Manager) acknowledged the importance of maintaining ambition within the policy framework. It was explained that the Council was bound by legislative requirements and viability assessments, and that each site presented unique challenges, particularly in relation to development costs. It was also emphasised that overall housing supply had a direct impact on affordability, and that failure to deliver private housing could also negatively affect housing affordability across the Borough. David Glover (Head of Planning and Development Services) further commented that the Council had been successful in securing new infrastructure, including parks, schools, and medical centres, as a result of clearly articulating its needs within the Local Plan. It was explained that these provisions were based on robust evidence and population projections and had been developed in collaboration with strategic partners such as the NHS and the Department for Education (DfE). The importance of monitoring changes within existing town centres was also highlighted, noting that the Local Plan provided a framework for managing such changes in a way that could positively or negatively impact residents, depending on how planning policies were applied.

 

• Members sought clarification on whether the Council’s target of 50% affordable housing strengthened its negotiating position with developers. It was also queried whether the target served to communicate the Council’s ambition and standards, and if it provided any tangible advantage during negotiations. In response, Paul Lewin (Spatial Planning Manager) confirmed that the target did assist in negotiations. It was explained that while national policy guidance imposed constraints, particularly in relation to viability assessments, the presence of a clear and ambitious target helped to set expectations. The example of the Mayor of London’s affordable housing policy was referenced, with it being noted that initial refusals of non-compliant applications that had not achieved the required targets had a significant impact on developers’ understanding that their planning permission would be refused. This, in turn, influenced more realistic negotiations with landowners regarding land values. It was further elaborated that if the Council’s targets were set at a level that rendered land sales unviable, landowners might be disincentivised from releasing land for development, thereby limiting opportunities for housing delivery. The importance of maintaining a balance between ambition and viability was emphasised, with it being noted that development would not proceed unless it remained financially worthwhile for landowners and developers. Reference was also made to national policy developments concerning Green Belt land, where the expectation was that such sites, previously undevelopable, would be valued at agricultural rates, thereby enabling the delivery of up to 50% affordable housing. However, it was noted that in Brent, much of the land had existing uses with value for other purposes, and therefore, to create additional development value, it was necessary to make those sites more viable and valuable for the landowners to release the land. Jehan Weerasinghe (New Corporate Director for Neighbourhoods and Regeneration) provided assurance to the Committee, stating that the team would undertake a comprehensive review of all relevant assumptions and return to the Committee at a future date to present their findings. The importance of revisiting previous assumptions and policy boundaries was emphasised to determine which elements were essential and which could be reconsidered in light of the Borough’s housing needs. The need to assess the implications of various policy choices on the overall delivery of homes, including considerations around tenure mix, asset utilisation, and alternative development options, such as conversions and refurbishments, was also highlighted. The commitment of the team to delivering increased numbers of affordable homes for the residents of Brent was reaffirmed.

 

• Members raised a further point regarding the Council’s ambition in relation to building standards and climate change and noted that while the current Local Plan required a 35% carbon reduction from new buildings, other local authorities, such as Islington and Hackney, had adopted more ambitious targets, including net-zero carbon standards. Members suggested that Brent could consider not only encouraging but requiring the inclusion of features such as solar panels and heat pumps. Additionally, it was suggested that carbon offset payments could be made by developers, where they could not meet carbon reduction targets and could limit the use of carbon offset funds to a last-resort measure. Member also raised the potential to strengthen requirements around BREEAM standards. Members then enquired whether the Brent Local Plan review would include discussions on enhancing the Council’s climate-related ambitions and building performance standards. In response, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) confirmed that these matters were central to the rationale for undertaking a review of the Local Plan. The Committee were advised that the Council was currently updating its Climate Action and Resilience Plan, and that the work of the climate team would inform the development of this piece of work. The importance of progressing in areas such as sustainable design, shading, flood resilience, drought mitigation, and energy efficiency. It was confirmed that the Council was already addressing some of these issues through planning decisions but recognised the need to go further in ensuring that homes were designed to remain comfortable and sustainable in the face of climate change.

 

• Members raised a question regarding the potential financial implications for developers arising from the Council’s ambition to enhance environmental and building standards. Members expressed concern that increased requirements, while necessary to address climate change, could result in higher development costs, and emphasised the importance of maintaining Brent’s attractiveness as a Borough for investment, while ensuring that climate change remained a central consideration in policy discussions. In response, David Glover (Head of Planning and Development Services) acknowledged that enhanced environmental standards did incur additional costs for developers. However, it was noted that the industry had made significant progress in improving the quality of construction, particularly in areas such as building fabric, insulation, air tightness, photovoltaic panels, and heat pump technology. It was explained that as these technologies became more widely adopted, their costs had decreased, and their implementation had become more routine. It was reported that some developments were already achieving carbon dioxide emission reductions of 60-70% beyond current building regulations. It was stated that the planning system had played a key role in driving these improvements and confirmed that the Council would continue to raise expectations in this area. Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) further mentioned that the Council was mindful of the potential impact of environmental requirements on residents, particularly in relation to the cost of living. The importance of ensuring that measures such as heat networks were implemented in a manner that delivered tangible benefits to residents was emphasised. Jehan Weerasinghe (New Corporate Director for Neighbourhoods and Regeneration) provided further assurance that the Council would engage with peer authorities, including Islington and Hackney, to learn from their experiences in delivering carbon-neutral developments. The Council’s commitment to a comprehensive and inclusive approach was reaffirmed, ensuring that all relevant considerations were explored and that the Committee would be kept informed throughout the process.

 

• The Chair raised a further question regarding the Council’s historical reliance on carbon offset payments and queried whether there was scope to adopt a firmer stance by requiring higher on-site carbon standards rather than accepting financial contributions in lieu. The Chair questioned whether the Council could push back against developers who sought to rely on offset payments. In response, Paul Lewin (Spatial Planning Manager) advised that the Council was currently undertaking a review of its carbon offset payment framework, supported by a viability study. Reference was made to the approach taken by Westminster City Council and, to a lesser extent, the London Borough of Hammersmith and Fulham, where a tiered system was in place. Under such systems, the level of offset payment decreased as developments achieved higher levels of carbon reduction. It was noted that while viability remained a key consideration, post-construction reviews of current schemes had shown encouraging performance. It was highlighted that the transition away from gas central heating, particularly in flatted developments, had contributed significantly to progress towards zero carbon outcomes. It was acknowledged that while some developers continued to meet only the minimum requirements, there was a clear trend towards greater ambition in this area.

 

• Members referred to the work of the Kerbside Task Group and the importance of incorporating its recommendations into the Local Plan. Assurance was sought that the findings of the task group, particularly in relation to greening and climate resilience, would be considered and reflected in future policy development. In response, David Glover (Head of Planning and Development Services) confirmed that he had participated in the task group sessions and was aware of the recommendations. It was stated that the Planning Service worked closely with colleagues across departments, including Sandor Fazekas (Head of Healthy Streets and Parking) to ensure that such information intelligence and recommendations were taken into account in the policy.

 

• Members raised a point regarding the need to address conflicting policies within the Local Plan. An example was cited where a resident had sought to install external cladding to improve energy efficiency but had been deterred by the requirement to submit professionally produced technical drawings, which incurred a prohibitive cost. Members expressed concern that such requirements undermined the Council’s stated support for retrofitting and energy-saving measures. In response, David Glover (Head of Planning and Development Services) advised that planning permission was not generally required for the installation of external cladding and offered to review the specific case outside of the meeting. It was acknowledged that while the Local Plan covered a wide range of policy areas, efforts were made to ensure alignment wherever possible.

 

• Members enquired whether there was an appetite, as part of the Local Plan review, to consider how communities could be more actively involved in the use of local green spaces, referencing examples such as community gardens and shared green spaces within new developments. In response, Paul Lewin (Spatial Planning Manager) informed that the Council had developed a significant body of guidance, including the Amenity Supplementary Planning Document (SPD), which addressed the acceptability and design of open spaces within developments. It was explained that part of this guidance related to the future management of such spaces. The Council sought to encourage a sense of ownership among residents, particularly in relation to decision-making about how these spaces were used. However, it was noted that the long-term maintenance of these areas remained a key consideration. It was observed that while community interest in managing green spaces could be strong at the outset, it often diminished over time, leading to challenges in sustaining upkeep. This issue applied both to spaces within private developments and to areas of public realm owned by the Council. It was confirmed that members of the team had supported community garden initiatives in the past, some of which had been successful, while others had struggled to maintain long-term engagement.

 

• As a further issue highlighted, members questioned whether the Local Plan would be the appropriate place to set out expectations regarding the ongoing maintenance of community-led spaces, including proposals such as community parklets, which were being considered by the Kerbside Management Task Group. In response, Paul Lewin (Spatial Planning Manager) confirmed that maintenance expectations were typically secured through planning conditions within development proposals. It was conveyed that when a landscaping plan was submitted, it was generally accompanied by a requirement for ongoing maintenance in accordance with that plan. The guidance aimed to ensure that appropriate long-term management arrangements were in place.

 

• Concerns were highlighted regarding the usability of green spaces that were either protected or created through development. The example of a wildflower meadow introduced in Wembley Park was cited, with it being noted that while safeguarding such spaces was important, it was equally essential to ensure that they remained functional and accessible, particularly in the context of rising temperatures and increasing population density. Members urged that usability be considered alongside aesthetics in the design of green spaces. In response, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) confirmed that the Local Plan included policies to protect open spaces and to incorporate it within new developments. It was stated that community engagement would also be addressed as part of the review. Reference was made to the Council’s tree strategy and the importance of integrating environmental protection, climate resilience, and maintenance considerations was noted.

 

 

• As a separate issue, members questioned how the Local Plan review would address the issue of overconcentration of gambling establishments in town centres. In response, Paul Lewin (Spatial Planning Manager) acknowledged the concern and confirmed that the Council already had a policy in place to manage gambling premises, which placed it ahead of some other local authorities. However, it was recognised that in certain centres, the policy had not been effective in limiting the proliferation of adult gaming centres. It was advised that the policy would be reviewed, and that one likely change would be to adopt a broader definition of gambling to encompass emerging forms of activity not currently captured by the existing policy. It was noted that while the number of gambling premises in the Borough had declined overall in the past decade, there had been an increase in adult gaming centres. It was explained that in some town centres, such as Wembley and Harlesden, the existing policy allowed up to 3% of the frontage length to be occupied by gambling establishments, which was deemed a considerable length. It was reported that the policy had been more effective in other centres, such as Neasden, where the Council had recently won an appeal on the basis of overconcentration. It was highlighted that the policy would likely be revised to provide greater clarity and less flexibility, thereby offering stronger grounds for refusal where appropriate. Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) further added that the Council intended to take a more robust approach to managing gambling establishments. The importance of supporting investment in town centres and ensuring that planning policies contributed to positive outcomes for local communities was reiterated. Alice Lester (Corporate Director for Neighbourhoods and Regeneration) further noted that any revised policy would be subject to examination as part of the Local Plan review process. It was acknowledged that strengthening the policy would be challenging but confirmed that officers would explore options for a more stringent approach, subject to acceptance by the Planning Inspectorate.

 

• The Chair sought clarification on how the Council’s commitment to delivering community spaces through the Local Plan would be addressed in the review. In response, Paul Lewin (Spatial Planning Manager) confirmed that the current Local Plan already contained policies addressing this matter. It was explained that where there was a loss of a commercial unit within a parade or town centre, the Council’s preference was for the unit to be repurposed for other commercial uses, social infrastructure, or local employment opportunities, before considering residential use. The challenges posed by permitted development rights was acknowledged, which allowed for the conversion of retail units into residential dwellings without the need for planning permission. The Council had sought to mitigate this through the use of Article 4 Directions in town centres, although these had not been extended to neighbourhood parades or individual shop units. It was additionally stated that the Local Plan included policies to support the provision of additional social infrastructure. Where such infrastructure was proposed, it was subject to a set of criteria to ensure its appropriateness. It was emphasised that the loss of existing social infrastructure would not be permitted without a robust assessment of alternative options. The Local Plan also sought to promote the diversification of town centres while protecting facilities deemed essential to community wellbeing.

 

• Members highlighted the proliferation of fried chicken outlets on Wembley High Road and Ealing Road, noting that these developments, alongside gambling establishments, were having a detrimental impact on the character and health of local communities. Members urged the Council to adopt a holistic approach to high street planning, taking into account mental, physical, financial, social, and environmental wellbeing. While acknowledging the influence of central government legislation, members stressed the importance of clearly identifying what could be controlled at the local level to avoid repeating past mistakes. In response, Gerry Ansell (Director of Inclusive Regeneration and Climate Resilience) agreed that town centres required a comprehensive and integrated approach. It was noted that Paul Lewin (Spatial Planning Manager) managed the town centres team and confirmed that opportunities existed to strengthen partnerships with local businesses and communities. It was emphasised that while planning policy could provide a framework, its effectiveness depended on collaboration and investment. Reference was made to small-scale interventions which had significantly improved the performance of town centres. Paul Lewin (Spatial Planning Manager) further stated that the Use Classes Order provided a high degree of flexibility, which complicated enforcement. It was explained that Class E permitted a wide range of uses, including retail, financial services, restaurants, cafés, and gyms. The distinction between a restaurant and a takeaway was often blurred, particularly when establishments included seating areas. It was noted that while standalone takeaways required planning permission and were subject to specific policies, it was often difficult to determine whether a premises fell within the takeaway use class or was operating as a restaurant with ancillary takeaway services. This ambiguity posed challenges for monitoring and enforcement.

 

• Members observed that officers had previously been unable to provide data on the number and type of businesses operating in town centres and suggested that the Council begin collecting such data to better understand what constituted a successful and holistic town centre.

 

• As a more general issue, members enquired about how the Local Plan review would strengthen policies to ensure that development continued to deliver well-paid employment and apprenticeship opportunities for Brent residents, particularly those from disadvantaged backgrounds. In response, David Glover (Head of Planning and Development Services) stated that the Council performed strongly in this area and explained that through existing policies and guidance, the Council secured targets for the employment of Brent residents as apprentices on development sites, as well as broader targets for local employment. Funding was also secured to support the Council’s Employment and Skills Team, which was responsible for identifying, placing, and training apprentices. It was noted that where a development did not include employment space, such as in residential-only schemes, the Council still secured commitments for construction-related employment. In developments that included commercial premises, the Council also sought to secure ongoing employment opportunities following completion. It was confirmed that officers would explore whether further measures could be introduced to strengthen these provisions.

 

• Members were keen to seek details on how the Council intended to capture and respond to objections and concerns raised by residents, particularly in relation to issues such as gambling, as part of the Local Plan review process. In response, Paul Lewin (Spatial Planning Manager) stated that the report outlined the extent of consultation and engagement undertaken during the previous Local Plan review. It was confirmed that a similar approach would be adopted for the review, with improvements where possible. The Council’s intention to enhance its digital engagement strategy was emphasised, noting that during the last review, the Council had utilised a platform called Commonplace. This tool enabled residents to identify specific locations on a map, express what they valued about those areas and highlight issues. Contributions were visible to others, fostering a forum-like environment for community dialogue. It was explained that this approach had supported the Council’s place-shaping work by helping to identify local characteristics and opportunities. It was added that should funding be allocated within the Local Plan review budget, digital engagement tools would be further developed, not only to improve consultation but also to enhance the accessibility and interactivity of the Plan itself.

 

• The Chair asked which communities had been identified as priorities for engagement in the Brent Local Plan review, particularly those with whom the Council had not historically engaged effectively. In response, Paul Lewin (Spatial Planning Manager) advised that the Council had made efforts to engage with all communities during the previous review. Where response rates had been low, targeted follow-up engagement had been undertaken. It was explained that the level of engagement was proportionate to the potential impact those communities could have on the content of the Plan. The Council had attempted to collect data on protected characteristics to better understand the demographics of respondents, although this had proven challenging due to low response rates. It was acknowledged that engagement with young people had initially been limited, but this had been addressed through collaboration with the Youth Parliament, which had provided valuable and distinct insights. It was also noted that local councillors had been encouraged to promote participation within their communities.

 

• The Chair then sought clarification on the funding arrangements for the Local Plan review and asked about the potential risks and implications, should funding not be secured. In response, David Glover (Head of Planning and Development Services) confirmed that there was no dedicated funding pot or external income source currently allocated for the Brent Local Plan review. The Committee was informed that officers would be submitting a request to Cabinet for the necessary funding. While alternative funding sources had been explored, none had been identified. It was stated that, as with previous reviews, it was likely that funding would need to be drawn from the Council’s central budget, which was under significant pressure. It was emphasised that without adequate funding, the Council would be unable to proceed with the review. It was noted that the process required not only officer time but also the commissioning of evidence-based studies, public consultation, and examination, all of which incurred substantial costs.

 

• The Chair referred to paragraph 3.2.61 of the committee report, which estimated the cost of the Local Plan review to be between £500,000 and £1.6 million. The Chair also referenced the inclusion of a commitment to deliver pitches for Gypsy and Traveller communities. While agreeing that this was a core element of the Local Plan, the Chair questioned why it had been included within a paragraph on funding and sought clarification on the connection between the two. In response, Paul Lewin (Spatial Planning Manager) explained that the cost range reflected a number of assumptions. It was noted that the Council was aware of internal efforts to address issues at the Lynton Close site, which were progressing well. Should these efforts succeed, it might negate the need for the Local Plan to identify additional sites for the Gypsy and Traveller community. However, if the Council were required to allocate new sites, the process would be significantly more complex than in the previous Plan, where a criteria-based policy had been deemed sufficient. Under current requirements, the Council would need to identify and allocate specific sites to meet identified needs. Members were advised that this process was often contentious and would likely require multiple rounds of consultation before a final proposal could be submitted for examination. It was explained that this introduced additional risk and cost, including the need for site assessments and extended examination time. While not all of the estimated cost was attributable to this issue, it represented a significant potential cost pressure and had therefore been included in the funding considerations.

 

• As a final query, the Chair sought clarification regarding the extent to which underrepresented groups had been engaged in previous Local Plan consultations, asking specifically whether there was any evidence that the Gypsy and Traveller community had been consulted during earlier Local Plan processes, and whether such engagement had been used as an opportunity to understand and reflect their concerns, particularly in relation to the historical lack of planning for site provision. In response, Paul Lewin (Spatial Planning Manager) confirmed that a Gypsy and Traveller Needs Assessment had been undertaken as part of the previous Local Plan review. This assessment had been conducted on a West London-wide basis, with each participating Borough, including Brent, receiving its own set of data and findings. As part of this process, the Council had engaged directly with the Gypsy and Traveller community. All households residing at the Lynton Close site had been invited to participate in interviews to assess their housing needs. It was explained that, at the time, the national planning policy framework included a specific definition of who qualified as a Gypsy or Traveller for the purposes of planning policy. This definition had since been subject to challenge and reinterpretation. Under the previous framework, despite the expressed needs of the Gypsy and Traveller community, the national policy position had concluded that there was no requirement for Brent to allocate additional pitches. This created a complex and challenging situation for the Council, as it was unable to fully address the needs of its residents within the constraints of national policy.

 

In seeking to bring consideration of the item to a close, the Chair thanked officers and members for their contributions towards scrutiny of the Brent Local Plan Review Report. As a result of the outcome of the discussion, the following suggestions for improvement identified were AGREED:

 

SUGGESTION FOR IMPROVEMENT

 

1)    Include land value mapping in the evidence base supporting the upcoming Local Plan.

 

2)    Set targets for Local Plan priorities that are realistic, achievable, and clearly deliverable to support effective implementation and buy-in.

 

3)    Strengthen consultation and engagement with local neighbourhood groups throughout the Local Plan development process, drawing on lessons from previous efforts to ensure their input meaningfully informs the revised plan and supports ongoing, transparent dialogue.

 

4)    Enhance outreach with underrepresented groups throughout the upcoming Local Plan development process, applying lessons learned from prior communications and engagement efforts.

 

5)    Ensure that the Committee is regularly updated on delegated decisions made by Cabinet members and corporate directors throughout the Local Plan development process.

 

6)    Ensure that councillors, via the Brent Local Plan Working Group, are actively involved in reviewing the findings of viability assessments, financial modelling, and policy options throughout the Local Plan review and the development of the updated Local Plan.

 

7)    Explore, through the Local Plan review, opportunities to strengthen policy mechanisms that ensure all parts of Brent, not only designated Growth Areas, benefit equitably from development.

 

8)    Explore innovative approaches through the Local Plan review to further strengthen the delivery of genuine affordable housing, climate resilience, sustainability, social infrastructure (such as community facilities), and green spaces across Brent, while addressing issues such as gambling overconcentration and other uses associated with social harm.

 

9)    Consider strategies within the Local Plan review to support a balanced mix of green spaces across all areas of the borough, meeting community needs equitably.

 

10)Enhance developer requirements through the Local Plan review process by introducing higher standards for sustainability, climate adaptation and resilience, and build quality.

 

11)Leverage the Local Plan review process to limit the use of the carbon offset fund to a last resort for developers.

 

Please note that the specific wording of the suggestions for improvement was subject to refinement following the meeting, with the agreement of the Chair.