Chapter 5 - HOUSING continued

Definition of Affordable Housing: a dwelling is defined as affordable housing where it has the smallest number of rooms appropriate to alleviate the needs of a household in unsuitable accommodation, which cannot afford to pay an amount on that property equivalent to:- one third of gross household income on a mortgage or renting taking up 35% of net household income. This should equate to a periodic outgoing for the household on rent, lease or mortgage equivalent to that for similar accommodation provided by registered social landlord in the Borough for accommodation of similar size and quality (as listed in the annual housing strategy).

The Proportion of Affordable Housing Sought

5.7.19 Because of this scale of need for affordable housing there is a strong case that the maximum reasonable proportion of the total UDP housing provision (as stipulated in The draft London Plan Policy 3A.7) should be allocated as being for affordable purposes, having regard to the Boroughwide target (Policy STR18). The policy below sets out the criteria listed in national, regional and metropolitan policy. In carrying out its housing provision survey the Borough has analysed sites with regard to their suitability for affordable housing by the factors listed in this policy. The Council has also increased certainty; by specifically identifying large housing and mixed-use sites on the proposals map where this would not prejudice other planning objectives, and indicative affordable housing targets are set in the site specific proposals chapter, for sites not solely allocated for affordable housing. Major town centre opportunity sites (where the priority is for town centre uses such as retail and leisure) have not had targets set. Moreover, policy guidance in Circular 06/98 and RPG3 now require that where affordable housing polices have been included in development plans, local authorities should develop both plan area wide targets and indicative site specific targets for affordable housing provision.

5.7.20 In order to arrive at Boroughwide and site specific targets however it is necessary to set a target percentage based on the range of typical site conditions - as well as for a basis for negotiation on future windfall sites. The level has been set based on what has been achieved through operation of the previous interim policy, and is therefore considered reasonable, having regard to the
exceptional level of housing need, and relative shortage of large sites (referred to in section 5.5). The dwelling mix of the affordable proportion would need to meet the requirements of those in priority need following consultation with registered social landlords operating in the Borough. Units should also meet Housing Corporation Scheme Development Standards.

5.7.21 Affordable housing can sometimes be more difficult to secure as part of conversions from other land-uses (e.g. offices) than for new-build sites, for example because of management problems of affordable and general market housing within the same building. A similar situation may apply to work-live schemes, where the residential element may generate an affordable housing liability. Therefore, when such housing is provided regard will be had to the special opportunities or constraints of the site in considering whether or how much affordable housing should be provided on-site (there may instead be opportunities for provision-in-lieu where on-site provision is impractical). This flexible approach would recognise that these potential constraints may not apply and the building can be easily convertible to affordable housing.

5.7.22 The RPG3 definition of affordable housing includes both low cost market housing and subsidised housing. However the housing needs study shows the disproportion between Brent's low incomes and high house prices meant that low-cost discounted general market new-build (as well as work-live proposals) would be unlikely to meet the affordability criteria of any of those in housing need. This being more expensive than the cheapest general market converted accommodation. Such housing would be less unaffordable, but it would not meet the definition of affordable; this reality has been recently recognised by the proposed revision of PPG3. The policy set out below recognises the supplementary role that such housing plays to affordable housing. It is also inappropriate to use the proposed lower car parking standard for low-cost general market housing as they have higher car ownership.

5.7.23 The Brent Housing Survey 2003 estimated that about 32% of households requiring affordable housing could potentially avail of intermediate housing. However, this was largely restricted to those needing only one and two bedroom units and even in this category was mainly confined to the cost bands just above social rental levels and very much below market rental and purchase prices. This situation has therefore been reflected in the Council’s draft Supplementary Planning Guidance on Affordable Housing (2003) which normally specifies a ratio of 70% rental and 30% intermediate units in accordance with The draft London Plan Policy 3A.8.

5.7.24 Particular considerations apply to sheltered housing, a very specific segment of the housing market, and where their relative low cost is a significant selling point. However, as Circular 6/98 states “...local assessments of needs for affordable housing may show that there are elderly households who cannot afford sheltered housing provided by the market.” (footnote 2). This is the case in Brent where the Council’s draft Older Persons Housing Strategy (2003) has estimated that Brent has a very substantial need for additional affordable, primarily social rental, sheltered accommodation.

5.7.25 In order to meet the housing needs of Borough residents, affordable housing not available to Borough residents (through being on the housing register of another borough, for example) would not count towards the Boroughwide or any site specific target. However this is acceptable providing that the affordable housing component normally required is available to Borough residents elsewhere in the development.

5.7.26 Policy H3 will be used to assess proposals for ‘key-worker’ housing (e.g. nurses, teachers etc. see glossary.). The tests are the same as for all affordable housing, is it affordable? how will this be secured? would it be for Brent’s needs e.g. an institution in Brent? Such proposals need to demonstrate that it would not occupy a site suitable for those in priority need (i.e. family housing), which could increase overall homelessness.

5.7.27 Affordable housing will generally be secured by the means set out in Appendix H2.

H3 PROPORTION OF AFFORDABLE HOUSING SOUGHT

In assessing the scale of affordable housing required of sites above the size threshold (Policy H1), the maximum reasonable proportion of affordable housing will be sought and secured (generally 30%-50% of units on suitable sites) having regard to the Boroughwide target (Policy STR18), & to the following factors:

(a) Any exceptional costs associated with the site above those normally encountered;
(b) The physical suitability of the site for affordable housing;
(c) The walking distance of the site to a shopping centre & local services;
(d) The public transport accessibility of the site; (sites with good or very good accessibility are considered particularly suitable);
(e) The housing needs of the local area and the need to secure a mix of housing types, sizes and levels of affordability in the locality;
(f) Any site-specific indicative target (set out in site specific proposals) assessed by these criteria; and
(g) The costs associated with the achievement of other planning objectives.

For developments involving conversions of buildings from other land-uses, where the site is suitable for redevelopment, the special opportunities or constraints of the building will be considered.

For developments involving conversions of buildings from other land-uses, where the site is suitable for redevelopment, the special opportunities or constraints of the building will be considered.


Off Site Provision-In-Lieu

5.7.28 Brent only accepts cash-in-lieu provision of affordable housing, in very limited circumstances as:

• They mitigate against mixed communities and socially balanced development;
• They usually result in less affordable housing being provided;
• The calculation of the cash payments can be more complex to calculate and administer than on-site provision; and
• In Brent and other areas the shortage of sites for affordable housing can be more pronounced than a shortage of housing finance.

5.7.29 On most housing sites, there will be no reason why affordable housing could not be provided. Circular 6/98, PPG3 and the draft London Plan all state a presumption in favour of providing affordable housing as part of the development. Failure to do so could justify refusal of planning permission. It will only be where, for example, a flatted development cannot reasonably be divided into affordable housing units or where service charges for the scheme make units unaffordable that cash-in-lieu payments may be considered (The Council may seek justification of the service charge need and level).

H4 OFF-SITE AFFORDABLE HOUSING - 'PROVISION IN LIEU'
Where affordable housing is appropriate this should be provided 'in-situ' other than in exceptional circumstances.


5.7.30 The Council will set out in more detail how it calculates cash-in-lieu payments in supplementary planning guidance on affordable housing.

Key Worker Housing

5.7.31 Key worker housing usually refers to housing for key service workers, essential to the economic functioning of a city (e.g. transport workers, health workers, teachers etc) but whose income may be insufficient for them to rent or buy on the open market. Brent will support the provision of this housing where at least a proportion is affordable (in this context meeting the housing needs of workers or households who earn between £12-25,000 (at 2001 salary levels) and is delivered on sites that would not otherwise provide affordable housing for those in greatest housing need (set out in Policy H2). An appropriate proportion of key worker housing is also acceptable as part of the affordable housing requirements under Policies H2 and H3 where there is a recognised local need for such housing.

5.7.32 Priority should be given to workers in Brent (a more sustainable approach) and schemes should provide a range of unit sizes. Key worker housing will be particularly appropriate in areas where 'high-need family-sized' housing is inappropriate on the scale envisaged under Policy H2 (see particularly Wembley Inset Plan). It may also be appropriate to ensure the delivery of affordable housing on small housing development sites where affordable housing is required.

5.7.33 The Brent Housing Needs Survey 2003 specifically investigated the particular housing requirements of the Borough’s key worker residents (employed in the health, social services, education, local government, public transport and the emergency services).The Survey revealed that 57% of the key worker households who need / are likely to move cannot afford market housing and 26% will be dependent on social rental housing. Most of the 31% who can potentially afford intermediate housing can only do so at the lower end of the cost spectrum. The Survey estimated a keyworker affordable housing need for 356 homes per year of whom 137 require three or more bedrooms, indicating the need to ensure that key worker housing provision satisfies the full range of household demographic requirements.

H5 KEY WORKER HOUSING

Key Worker Housing should include a proportion (30-50%) of units affordable to those employees on low incomes. Key worker housing should not replace affordable housing for those in greatest housing need as set out in Policies H1 and H2 except where it:

(i) May be developed on sites where a high proportion of housing for those in greatest housing need is unsuitable (for example some sites in the Wembley Regeneration Area); and
(ii) May assist in the economic viability of providing affordable housing on small sites.
Key Worker Housing should also:
(a) Give priority to employees working in Brent;
(b) Support a range of tenures; and
(c) Provide a range of dwelling sizes (except where a Brent employer has a specified need for a particular size of accommodation).


Protection of Existing Affordable Housing (including HMOs)

5.7.34 The following policy prevents this loss of existing affordable housing, in accordance with RPG3 (para 4.29), unless the loss is the only means of securing essential improvements to the quality of affordable housing remaining / rebuilt on-site. In some cases there may be a need for a smaller number of larger units. Affordable housing is wider than that just within the C3 (dwelling) use class. It can include student and nurse hostels and houses in multiple occupancy (HMO) and the policy covers all of these. Where affordable housing, such as hostels, is linked to an existing institution which is being relocated the affordable housing can be replaced by housing at the new institution.

5.7.35 The Council recognises that some residential accommodation that is not self-contained, including Houses-in-Multiple Occupation (HMOs), meets an identified need for relatively affordable accommodation and facilitates mobility of labour. The upgrading of such properties is a major priority of the Council. In some cases the self containment of a small proportion of units within an HMO may be permitted where it results in the upgrading of the remainder of units or facilitates management, unless the property is incapable of meeting modern standards.

H6 PROTECTION OF EXISTING AFFORDABLE HOUSING (INCLUDING HMOS)

The net loss of affordable housing units (including purpose built hostels and houses in multiple occupancy), or land part of affordable housing sites to non-affordable housing use, will be resisted unless this is the only means of securing essential improvements to the quality of affordable housing remaining / rebuilt on-site, or its suitability for residents in priority need, or the property is incapable of being brought up to Housing Act or Building Regulations standards.


5.8 ESTATE REGENERATION

5.8.1 The Government’s overarching ‘social inclusiveness’ strategy, recognises the need to physically and socially regenerate poorly designed and badly constructed, mono-tenurial, housing estates through multi agency programmes such as New Deals For Communities. A strategy supported by PPG3, RPG9, RPG3 and The draft London Plan.
5.8.2 A number of major Council estates count as amongst the most deprived areas in the Borough as judged by housing need,
environmental, health, social and economic indicators. Most were built in the 1960s and 1970s, when there was a heavy reliance on Bison and Resiform system building methods. These methods have since proved to be problematic and to produce poor quality housing. By the 1990's many of the estates in Brent were in need of some form of redevelopment or
refurbishment, in total over 9,800 dwellings were affected. To respond to this the Council has formulated its Estates Regeneration Strategy. The two principal aims of this are:

• The transformation of the housing stock on these estates into high quality affordable housing through either refurbishment or redevelopment; and
• To achieve the renewal of local communities and improve the quality of individual lives by associated social and economic development programmes.

5.8.3 There can be no doubting the Council’s commitment to estate regeneration: the redevelopment of the Chalkhill estate in Wembley Park is underway, as is that of the Stonebridge and Church End estates. Proposals have been recently prepared for the Barham Park estate.

5.8.4 Because of the different status of each regeneration programme the UDP as a whole reflects:

• That those schemes that have been granted permission set precedents for the planning of the Borough as a whole - in particular on overall dwelling provision targets;
• That because of uncertainty over funding regimes and future regeneration strategies the Plan needs to have a 'loose fit' approach to the form of redevelopment - if any - that takes place in future projects;
• That though conventionally described as 'estates' many are actually widely varying in character and the solutions of some may arise through thinking beyond their boundaries and beyond focusing on problems of the public stock alone; and that
• The needs of existing residents needs to come first - in that they already suffer from a poor environment.

5.8.5 One of the key aims in each project has been to reduce their perception as 'estates' to break them into a series of smaller dwelling groups each better related in layout and form to adjoining streets and housing. This may require thinking outside the traditional role of the Council as landlord of public stock. The securing of
balanced and mixed communities may require increased general market / shared ownership housing - which may also provide gap funding.

5.8.6 Most of the estates were developed in a predominantly flatted form. Resident consultation has previously found a strong
preference for more traditional forms of housing with gardens. On some estates this has led to a lowering of densities. The
anticipated scale of loss is fully accounted for in the Borough's
provision study. The result of these programmes has also meant the loss of units (much of it unusable) but its replacement by new high quality affordable stock - surely a real gain in housing terms. On estates programmes that might come forward - such as Brentfield and St Raphaels - there may be scope for raising
densities.

5.8.7 In the case of South Kilburn, the whole of the former Carlton Ward (now split between the Queens Park and Kilburn wards) was selected as a New Deals for Communities Area in May 2001, and Policy H7 applies to the whole area. Alternative regeneration strategies for redevelopment and / or refurbishment are being developed by the New Deals for Communities in partnership with the Council and local residents as part of a Master Planning process. The Master Plan process will examine opportunities to introduce a range of housing types and tenures, improved community facilities and new leisure and health facilities. The South Kilburn Master Plan will form the basis for supplementary planning guidance and once agreed will guide future development in the area.

5.8.8 On some estates it may be necessary to decant residents to housing outside the designated regeneration areas, as shown on the Proposals Map. This is to enable the initial phase of demolition and redevelopment, or refurbishment, to proceed.

H7 MAJOR ESTATE REGENERATION AREAS

In the Major Estate Regeneration Areas (MERAs), as shown on the proposals map, refurbishment and / or redevelopment is sought and supported, and should:

(a) Demonstrate the full involvement of local residents in planning and design;
(b) Be according to a masterplan demonstrating how different phases of development / different designers are co-ordinated;
(c) Involve the minimum loss of existing affordable housing consistent with providing quality new stock of the form wanted by residents - and where off-site provision is needed demonstrate that this is feasible;
(d) Include a mix of house types/tenures, land uses, and community, facilities to help secure mixed and balanced communities;
(e) Ensure through an overall landscape design framework a proper balance between private and public open space with sufficient provision for children's play space and formal and informal public open space;
(f) Be exemplars in terms of their approach towards design, telecommunications, energy / renewables and water use, re-use of materials and measures to reduce the use of the car; and
(g) Provide appropriate community, health, leisure and training facilities.


5.9 LOSS OF HOUSING

5.9.1 The already noted Government guidance and The draft London Plan’s emphasis on the need to increase housing provision clearly infers a general presumption against loss of the existing dwelling stock unless there are justifiable reasons. It is a statutory requirement that ‘Notice of Intent’ to demolish residential buildings must be given to the Council in advance of demolition.

5.9.2 The Brent Housing Needs Survey 2003 illustrates that the Borough cannot afford to lose housing. Where a development proposal entails demolition or change of use of residential accommodation, the Council will seek replacement dwellings comparable with the standard and the amount of accommodation lost. This is in order to maintain the overall amount and quality of the dwelling stock and to ensure that the dwelling target in Policy STR18 is not jeopardised. The only exceptions are for a strictly defined range of community facilities. The policy also prevents loss to short-term leased accommodation, which requires permission in London.

H8 RESISTING LOSS OF HOUSING

Development should not result in the net loss of residential accommodation where such accommodation can still be used, with or without adaptation, for permanent residential purposes; or loss of land within the boundary of sites in housing use to non-housing uses. Where a development entails demolition or other loss of dwellings, comparable replacement will be required. Specific exceptions to this policy are set out in the Community Facilities chapter.


5.10 Self Contained HOUSING

National and Regional Policy Context

5.10.1 PPG3 advises that “Local authorities should take account of assessments of local need in determining the type and size of additional housing for which they should plan.” (para 11). The proposed redraft of PPG3 goes significantly further in advising that “where there are appropriate local plan policies in place, local authorities should reject developments that conflict with the objective of widening housing choice” (para 15).

5.10.2 RPG9 states that “A range of dwelling types and sizes should be provided...” in local plans which should “...set out clearly the mix of dwelling types and sizes that would reasonably be expected...” (Policy H4).
Metropolitan Policy Context

5.10.3 RPG3 encourages “...a mix of housing types...” based upon the “...assessment of local needs...” (paragraph 4.20). The draft London Plan requires boroughs to ensure that “...new developments offer a range of housing choices in terms of the mix of housing sizes and types...” (Policy 3A.4).

Borough Policy Objective

5.10.4 The size of new dwellings cannot be solely left to the market as the Council has an obligation to ensure that its Plan adequately provides for the demographic housing needs of the Borough’s residents whose average household size (2.6 persons) is one of the highest in the country, indicating the need to ensure an adequate proportion of family size housing in new developments. Family housing is defined for the purpose of this Plan as providing two or more bedrooms.

5.10.5 The Plan also recognises that the amenity benefits of new housing should be available to a variety of household types and sizes throughout society - not just the largest households and / or those with the highest incomes. And that a 'planned under-occupancy' of large homes occupied by small households is a wasteful use of land. Finally, there are good planning reasons for ensuring that child densities do not vary too widely between neighbourhoods - to ensure mixed and balanced communities and to avoid the social problems that can result from very high child densities.

5.10.6 There may be scope for additional housing, both to meet the demands for larger homes, to accommodate priority needs, and smaller dwellings for single person households, to avoid under occupancy. This assists the Plan in securing mixed and balanced communities in larger new housing developments between all household types and between market and affordable housing. The Council will therefore seek to achieve a mixture of family and non-family units in all large developments wherever practicable to ensure mixed and balanced communities. Examples of sites unsuited to family occupation, where non-family units may be more suitable, could include sites where there is no, or limited, scope for external amenity areas, or not having the appropriate quality of environment for families.

H9 DWELLING MIX

On developments capable of 15 or more dwellings, or residential sites of 0.5 ha or more, irrespective of the number of dwellings, a mix of family and non-family units will be required, having regard to local circumstances and site characteristics. Exceptions may be made for developments of sheltered or supported housing, housing in or adjoining town centres or where the site is unsuited to family occupation. Special regard will be had to affordable housing developments designed to meet the needs of a particular priority group.


5.10.7 Most new dwellings created through new-build or conversion will be self-contained in terms of facilities. In the future, developments of 'Co-Housing' or similar, where some facilities are shared may become as popular as they are elsewhere in the world. There may also be a requirement for ‘cluster housing units’, particularly for specific types of key workers, such as nurses. However, it is essential that any innovative types of non-self contained accommodation should provide an overall high standard of accommodation, suitable for its residents’ needs, otherwise they will be treated as hostel or house in multiple occupation accommodation as appropriate. Similarly retention of some shared facilities may well be for the benefit of existing tenants where houses in multiple occupancy are upgraded.

H10 CONTAINMENT OF DWELLINGS

New residential accommodation should be self-contained unless it is designed to meet the known needs of a named institution and suitable management arrangements are secured as part of the planning application. Such accommodation should be provided to the same standards as self-contained units, and will only be acceptable where the site is not suitable for family accommodation, and does not result in the loss of existing self-contained accommodation. Non self contained accommodation should be located within an area with good or very good public transport accessibility.


5.11 NEW RESIDENTIAL DEVELOPMENT

5.11.1 The Government’s overarching national, regional and metropolitan housing and planning strategies emphasise the need to maximise, high quality, well designed, new housing development, with the necessary complementary open space amenities, and other community facilities provision, on ‘brownfield land’ (previously developed sites). This strategic approach is further endorsed in The draft London Plan.

The Location of New Residential Development

5.11.2 Policy STR19 governs acceptable locations for residential
development. Housing will be promoted on previously developed urban land which the Plan does not protect for other land uses. Sites should provide acceptable residential amenity for existing and proposed residents, be accessible by means other than the private car and provide necessary infrastructure. This policy has been used to assess housing sites identified within the Plan and will also be used to assess windfall sites.

Community Facilities in New Residential Development

5.11.3 New residential development may also have to comply with Policies OS7 and OS18 on new open space and children's play facilities respectively; Policy BE7 on retention of existing trees and landscape features and Policy CF5 on community facilities in large scale development, in accordance with the relevant advice and criteria of PPG3, RPG9, RPG3 and The draft London Plan.

Maximising Housing on Previously Developed Land

5.11.4 The strategy of the Plan (Policy STR3) is to maximise housing on previously developed urban land, commonly referred to as 'brownfield' land. This has a specific technical definition, see the Glossary. The Borough is using the results of the National Land Use Database to identify and prioritise the more difficult sites in order to work with bodies such as English Partnerships and the London Development Agency to bring them into productive use.

H11 HOUSING ON BROWNFIELD SITES

Housing will be promoted on previously developed urban land which the Plan does not protect for other land uses.

Previously developed sites which do not come forward for development in the short / medium term will be prioritised through:

(a) Preparing development briefs;
(b) Improving the access to and / or environment around sites,where feasible and necessary;
(c) Assembling sites where necessary;
(d) Undertaking land restoration and / or remediation where required; and
(e) Working in partnership with other bodies.


5.11.5 The Government's sequential approach as set out in PPG3 is designed to restrict development of 'greenfield' sites whilst appropriate 'brownfield' housing opportunities remain unrealised. The Plan sets a brownfield target of 95% of additional housing from 2000-2010. In the light of the housing provision survey this is considered achievable as many more brownfield sites are now allocated in the Plan and those few greenfield sites identified for housing are solely to secure a wider planning purpose (such as a better arrangement of private and public open space on major estates).

5.11.6 The GLA Housing Capacity Study (London’s Housing Capacity, 2000) demonstrates that Brent is able to meet most of its housing requirements on brownfield land. Very few greenfield sites are allocated for housing in the Plan, contributing a very small proportion of the housing requirement over the Plan period. It is therefore not proposed to bring forward anymore greenfield sites for development other than those set out in this Plan, and the ad-hoc release of greenfield sites would not therefore be appropriate unless strategic housing requirements are not being met. Housing supply will be monitored throughout the life of the Plan (see Appendix 1).

5.11.7 Circular 1/2000 gives specific advice to London boroughs and indicates how the agreed annual rate of housing provision will be met. The draft London Plan also proposes to closely monitor annual housing provision. The Council will monitor the contribution from the various elements of supply, including site specific proposals set out in Chapter 15 of the Plan.

Urban Design Quality in New Residential Development

5.11.8 The Council is firmly committed to securing quality at every stage of the development process. By quality, the Council means the extent to which development meets the needs of all those who use and view development. As well as the general policies in the Built Environment chapter, the Housing chapter contains special policies tailored to the issues that arise in new residential development. A guiding shared objective of Government strategy, as evidenced in By Design: Better Places to Live (2001), the draft London Plan, and the UDP is to tackle this through emphasising the role of urban design in securing the characteristics that create interesting places. These techniques have been increasingly used in Brent, including on a number of major schemes, and are leading to a notable improvement in residential quality.

5.11.9 Urban design emphasises how people use, move around and experience places. A responsive people-centred design approach leads to a shift away from designing residential layouts around the needs of the car, towards pedestrian friendly development designed around the needs of people. Secondly, it emphasises the importance of context, the setting of developments and the characteristics of sites, in designing an appropriate solution.

5.11.10 The policies below are not intended to limit the creative freedom of architects and designers and should not preclude the use of innovative approaches provided that it can be demonstrated that the approach will be as effective as more traditional ones. Nor do they dictate any particular style or elevational treatment, although they do caution against the over-use of standard house 'patterns' used without discrimination, or over-dependency on ‘cul-de-sac’ layouts.

5.11.11 Rather, the policy is predictated upon an urban design framework being set for individual sites. The context of a site should define the sense of place that an urban design framework is setting out to create. This means that pedestrian circulation should be put at the heart of site layout and built form. For this reason a ‘roads first’ approach to layout design, including outline applications for layout without siting details, is not acceptable. All sites with, or large enough to require, internal roads / footways, will be required to submit an 'Urban Design Statement' with the application (Policy BE1). This will show how pedestrian movement within the site links to adjoining sites (taking into account community safety and other considerations) and will shape the means of access and layout of the scheme .

Housing Standards & Quality

5.11.12 The Borough is keen to encourage a much more 'design-led' approach to the density of housing development where the design is tailored to the context of the site. However, it is still necessary to give designers and housing developers a clear understanding of the level of expected amenity that residents should enjoy as a result of proposed development. The Borough has replaced conventional arithmetical housing 'standards' with a new approach. The policy sets down those amenities that both existing and proposed residents should be entitled to expect, i.e. a minimum acceptable standard of privacy, daylighting etc. The onus will then be on the designer to demonstrate how these will be met. In those cases where the 'back-to-back' distances between habitable room facing windows is less than 20m, the Council will expect particularly skilled design to ensure acceptable quality. The Council has amended its highway and parking standards to encourage more traditional interconnected street layouts with on-street parking.

H12 RESIDENTIAL QUALITY - LAYOUT CONSIDERATIONS

The layout and urban design of residential development should comply with policies in the Built Environment chapter, and in addition they should:

(a) Have a site layout which reinforces or creates an attractive and distinctive identity, appropriate to its locality, creating a clear sense of place;
(b) Have housing facing onto streets and defining roads;
(c) Have access and internal layout which achieves traffic safety where cars are subsidiary to cyclists and pedestrians, normally preventing vehicles from travelling greater than 32 Kph (20 mph). Cul-de-sacs should only be used in parts of development sites that cannot be serviced in any other way. Gated communities will not be permitted;
(d) Have an appropriate level of car-parking, and cycle parking, where dedicated on-street car parking is maximised as opposed to in-curtilage parking; and
(e) Avoid an excessive coverage of tarmac or hard landscaping and have an amount and quality of open landscaped areas appropriate to the character of the area, and local availability of open space, and the needs of prospective residents.


5.11.13 A key aspect of quality will be ensuing that areas are designed in a comprehensive and compatible way over time.

5.12 RESIDENTIAL DENSITY

5.12.1 Density is a measure of the intensity of development of a residential plot. It is conventionally measured in habitable rooms per hectare (hrh), see Appendix H3.

National and Regional Policy Context

5.12.2 PPG3 and PPG13 promote increasing densities at locations with good public transport accessibility such as at or around town and district centres.

5.12.3 RPG9 specifically supports raising densities (Policy Q3) and maximising housing opportunities through the ‘Sustainable Residential Quality’ or design led approach (first advocated by LPAC, 1998). More recently, Circular 1/2002 (Town and country planning (residential density) (London and South East England)) has stipulated minimum densities.
Metropolitan Policy Context

5.12.4 RPG3 states “The Secretary of State considers that the next review of UDPs should be the occasion for each Borough to examine the scope for raising densities.” (para 8.12) and that ‘town cramming’ can be avoided through better design and “...clear straightforward policies on standards and layout.” (para 8.13). The Secretary of State did not consider that it would be helpful to set out a Londonwide density guideline (para 8.11). It does list however a range of factors which should be considered in the re-assessment of density policy (paras 8.11-8.14).

5.12.5 These and additional factors together with a more design led approach have been employed in The draft London Plan Table 4B.1 Density location and parking matrix to indicate an appropriate range of densities from suburban to central London new housing development. The Mayor emphasises that increasing housing densities is a key requirement to implement the Compact City strategy.
Density and Sustainability
5.12.6 The sustainability argument in favour of increasing densities is that:

• It increases the viability of public transport through increasing it's potential clientele;
• It increases the potential local market for local shops and services,
• It compensates for lower population in a neighbourhood resulting from smaller household sizes, - thereby reducing the need to travel; and
• Higher density housing is more energy efficient and is required to make Combined Heat and Power / District Heating schemes economic.

5.12.7 Higher density developments do not have an intrinsically lower energy consumption - this depends just as much on a supporting infrastructure, transport and parking policies, and urban design and pattern of land-uses throughout the urban area. In short density must be carefully planned.

The 'Design-Led' Approach to Density

5.12.8 The density of the Borough varies between its inner-urban Victorian / Edwardian core and outer Brent which has a more open 'Metroland' suburban character. Adopting a 'design-led' approach to density means that full regard is paid to the context of building heights, development patterns etc. Whilst high quality residential development is possible at almost any density this does not mean that this would be compatible with local character, or with providing appropriate levels of amenity. SPG17 sets out the standards, particularly in terms of noise insulation, day and sun-lighting for higher densities. The Council’s more flexible approach to development standards (such as lower parking and road standards) makes this possible.

5.12.9 Whilst there may be areas of a high quality suburban character that are unsuitable for significantly higher densities, the areas where there is the best case for moderately higher densities (in terms of sustainability, vitality and access to services) are areas with good or better public transport, as well as town and district centres with good public transport accessibility. The main factors which affect the suitable density for a site are listed in Policy H13 and are explained in more detail in the checklist below. Once the parking standard for a residential development is defined, space set around and between buildings, and building heights agreed, then density should follow from these urban design considerations. Further guidance on the importance of these factors in generating appropriate design related densities, will be provided during the Plan period, within SPG17.

The Factors Likely to affect density in more detail

• The size and shape of the site. Larger and more regularly shaped sites are able to take higher densities than smaller and more irregularly shaped ones, however larger sites should also have a range of densities including (on appropriate sites) a substantial proportion of units with gardens;
• Whether the site is within a town or district centre. These are appropriate for higher densities where they have good public transport accessibility.
• The density and character of housing in the surrounding area. Densities will be higher in areas of an urban character, than those of a suburban character. In Conservation Areas this should be the primary consideration;
• The type of development. Appropriate densities will vary by the type of accommodation proposed. Certain higher density building forms may appeal to some types of households in more central locations.
• The amenity and needs of potential residents. This includes the need to ensure adequate privacy, daylighting and sunlighting and protection from noise. Family accommodation will require more spacious development than that for non-families. Where areas are proposed for clearance and re-development, the expressed preference of future residents will be particularly important;
• The constraints of adjoining land uses and the amenity of adjoining residents. Matters such as overshadowing, overlooking etc.;
• The constraints and opportunities of the site;
• Whether the development is proposed as a car-free housing development. An increased density may be appropriate;
• Whether the development is for affordable or supported housing. The lower parking standards appropriate for such development permit increased densities;
• Child Density. Developments with high child densities (number of children per site area) are not suitable for high residential densities. There will also be space requirements for children's play areas;
• The opportunities the site presents for passive solar gain and / or district heating. Sites suitable for passive solar gain (e.g. south facing) may require, depending on layout, densities below a certain level, whilst district heating, to be economic, requires a minimum density;
• The public transport accessibility of the site. Sites with good or better public transport accessibility are more suitable for increased densities, sites with very poor public transport accessibility have very limited scope for additional housing;
• The capacity and level of use of the road access to the site. Sites accessed via a quiet and narrow residential cul-de-sac may require decreased densities or traffic reduction measures to prevent unacceptable noise from traffic;
• Whether the development is proposed to be mixed use. Density calculations may be less meaningful and other factors need to be considered;
• Whether the development is infill, frontage redevelopment or backland development. The relationship of the development to adjoining housing is an important consideration for such sites;
• Existing landscape features on the site. Where these are required to be retained then a lower density may result.

H13 RESIDENTIAL DENSITY

The primary consideration in determining the appropriate density of new residential development will be achieving an appropriate urban design which makes efficient use of land (particularly on previously used sites) and meets the amenity needs of potential residents. The most dense developments will be appropriate in those parts of the Borough with good or very good public transport accessibility. Surrounding densities should be at least matched unless this would harm residential amenity.

The density of a site should also have regard to the context and nature of the proposal, the constraints and opportunities of the site and the type of housing proposed.


5.12.10 In order to meet the Boroughwide housing target in Policy STR18 it is important that full and effective use is made of all suitable sites for housing. If fewer dwellings are built on these than sites are capable of then there will be additional pressure to build on unsuitable sites.

H14 MINIMUM RESIDENTIAL DENSITY

Planning permission will be refused where development would under-utilise a site, where there are no pressing considerations to protect the character of an area. Outline permissions will be the subject of a condition specifying a minimum number of dwellings at reserved matters stage.

continue to last part of Chapter 5

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