Part 2 - West London Alliance

Request for an exemption to the permitted development rights for change of
use from commercial to residential
1.0
Introduction
1.1
Brent is a borough in West London which covers an area of 4,325 hectares (17 square
miles). It extends from Burnt Oak, Kenton and Kingsbury in the North, to Harlesden,
Queen's Park and Kilburn in the South. Brent contains some unique assets and performs a
number of functions within the capital. It is a strategic location for a major visitor attraction
in the form of the national stadium at Wembley, and contains part of the largest
manufacturing area in London, Park Royal industrial estate. Park Royal is one of the
largest manufacturing estates in Europe, and its central location makes it unique in
London.
1.2
The purpose of this report is to request an exemption to the proposed permitted
development rights on the basis of criteria B, that the rights will have a substantial adverse
economic consequence at the local authority level, for the following:


Strategic Industrial Locations (SIL)
Locally Significant Industrial Sites (LSIS)
Opportunity Areas which encompasses Wembley town centre.
1.3
This report provides evidence that introducing the proposed permitted development rights
in these specific locations will have significant adverse economic impacts, which would not
be outweighed by the benefits. The Greater London Authority will also be submitting
evidence to support the exemption of SIL.
1.4
In addition the council would like to raise concerns regarding the conversion of offices to
residential within areas with severe air quality problems, and would strongly recommend
air quality is considered as part of the prior approval process.
2.0
Background to Brent’s Economy
2.1
The Local Economic Assessment (2011) found Brent provides workplace employment for
approximately 113,000 people (employed and self employed) accounting for 13.9% of
West London’s employment; and 2% of total employment in London. According to the
London Office Policy Review (2012) 15,677 people are employed in Brent’s 267,000 sq m
of office stock.
2.2
The largest private sector employment in Brent is in wholesale and retail (21,800
employees) accounting for almost a fifth (19.3%) of employment. This is followed by
business services (16,800), manufacturing (10,600) – in particular within the manufacturing
of food and drink sector (5,000) - transport and communications (10,600), and the
construction sector (9,500). The borough also provides a significant number of jobs in the
public sector; including administration (5,000), education (6,500), and health (13,700).
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2.3
The Brent Local Economic Assessment (2011) found evidence of an entrepreneurial
culture with high levels of self employment. Brent has an estimated total of 12,000
enterprises; accounting for almost a fifth of workplaces in West London and nearly 1 in 20
workplaces in London. Nine out of 10 are micro enterprises (with less than 10 employees);
higher than the average for West London, London and nationally. Comparison with
national benchmarks suggests there is a healthy enterprise culture in Brent, with national
indices ranking the borough 52nd in Britain.
2.4
Employment within Brent tends to cluster around key town centres, primarily Wembley and
also within Park Royal, both identified in the London Plan as Opportunity Areas for their
potential to accommodate further growth and prosperity. Park Royal is Europe’s largest
industrial estate and the principal industrial area in West London. Together with Willesden
Junction, Park Royal extends to 700 hectares across Brent, Ealing and Hammersmith &
Fulham boroughs.
2.5
Despite this the relative position of the borough in terms of employment deprivation is
worsening. There is a relatively low employment rate and high levels of worklessness
particularly among ethnic minorities, young people and women. In 2009 128,000 residents
in Brent were in employment, representing 67.7% of the working age population. This
figure is slightly below the London average (68%) and lags considerably behind the
national average (70.2%).
2.6
The Future of Brent’s Economy
2.7
Projections suggest there will be a net increase in jobs in Brent and that many of these
jobs will be office based. The forecasts used in the Local Economic Assessment (2011)
suggest that there will be a net increase of 5,000 jobs up to 2020 within the borough.
Business services are expected to create the majority of additional economic output, with a
net increase of £347m in Brent’s economy between 2010 and 2020. The forecasts in the
Employment Land Study (2009) set out that there is net demand to 2026 for approximately
10 to 13 ha of land for B1 uses, whilst the London Office Policy Review (2012) projects
22,331 will be employed in offices in Brent by 2036.
2.8
The Local Economic Assessment (2011) highlights growth in each of these sectors will be
affected by the availability of suitable accommodation. This is reflected in Brent’s Core
Strategy which highlights the challenge to maintain sufficient employment land to meet
future needs whilst releasing the least well located land for alternative uses. Given the
importance of micro-enterprises to the borough’s economy it will also be crucial to maintain
an adequate supply of affordable workspaces.
3.0
Strategic Industrial Locations & Locally Significant Industrial Sites
3.1
London Plan policy 2.17 seeks to protect and manage SIL as London’s main reservoir of
industrial and related capacity, comprising approximately 40% of London’s total supply.
SILs comprise Preferred Industrial Location (PILs) or Industrial Business Parks (IBPs).
These designations are intended to meet the needs of different types of industry by
providing a range of premises and environments. IBPs are intended for businesses
requiring a high quality environment while PILs are for businesses with less demanding
requirements. West London contains a large share of London’s industrial capacity (27%)
including sixteen SILs. SIL within Brent is listed in table 1.
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Table 1: Employment Land in SIL by Area
SIL
Total Land Area (ha)
Category of SIL
Park Royal
120
PIL/IBP
Staples Corner
36
PIL
Wembley/Neasden
62
PIL
East Lane
18
PIL
Total SIL
236
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London Borough of Brent Employment Land Study (2009), URS
3.2
A plan outlining the extent of each area is included in appendix 1.
3.3
In total Brent contains 236 ha of land designated as SIL. Each SIL contain a mix of
employment uses including storage and distribution (B8), general industrial (B2), research
and development (B1b), light industry (B1c) and offices (B1a). Office uses form a
significant proportion of each SIL. For example in 2012 Wembley/Neasden SIL contained
2.88 ha of offices which equates to nearly 5% of its total land area. (Wembley Area Action
Plan Economic Development and Employment Land in Wembley, 2012)
3.4
In addition Brent contains 64 ha of LSIS. These sites, designated in Core Strategy policy
CP 20 due to their importance to Brent’s economy, are generally larger sites providing a
range of plot sizes and premises for a variety of business activities, including those with
potential ‘bad neighbour’ uses. LSIS are considered well suited to retention for industrial.
These sites do not have the same level of strategic accessibility as SIL but still have good
access to main roads and transport links, and are a source of affordable workspace. LSIS
designated in the Core Strategy are shown in Table 2.
Table 2: Employment Land in LSIS by Area
LSIS
Total land Area (ha)
Alperton
29
Brentfield Road
4
Church End
9
Colindale
7
Cricklewood
1
Honeypot Lane
5
Kingsbury
6
Neasden Lane
3
3
Total LSIS
64
London Borough of Brent Employment Land Study (2009), URS
3.5
A plan outlining the extent of each area is included in appendix 2.
3.6
The council is concerned conversion of office buildings to residential within SIL and LSIS
could compromise the distinct industrial character of these locations, and prejudice their
future development for employment uses. Planning policy, specifically Brent’s UDP policy
H22, seeks to protect residential amenity and minimise and mitigate any impact from
development upon surrounding uses. The unmanaged conversion of offices to residential
could prejudice the future development of adjacent plots for employment uses, as in
compliance with planning policy employment uses considered ‘bad neighbour uses’ would
not be granted permission adjacent to residential development. This could ultimately
prejudice not only B1a uses within the SIL and LSIS but the 300 ha of employment land
within their boundary.
3.7
In addition as the present Use Class Order allows for conversion of B8, B2, B1c and B1b
uses to B1a without the need for planning permission there is a risk developers will convert
these uses firstly to offices, then to residential.
3.8
The loss of SIL and LSIS is of particular concern in Brent as 9 out of 10 enterprises are
micro-enterprises employing less than 10 people, meaning the availability of affordable
workspace which SIL and LSIS provide is of particular importance to the local economy.
(Local Economic Assessment, 2011)
3.9
The council feels London Plan policy 2.17 already provides an appropriate degree of
flexibility to allow for consolidation of SIL where appropriate. To give a local example of
how this has been applied, through an employment land review which informed the
Wembley Area Action Plan (WAAP) it was identified a proportion of the Wembley SIL
should be de-designated. This was informed by an assessment of vacancy levels,
implications for adjacent uses, and the impact this would have on the SIL and wider
economy. A revised boundary has been subject to public consultation through the AAP
process. The council believes this managed and considered process is the most effective
method to manage employment land within the SIL and LSIS.
4.0
Opportunity Areas
4.1
London Plan policy 2.13 identifies Opportunity Areas and Intensification Areas as the
capital’s major reservoir of brownfield land with significant capacity to accommodate new
housing, commercial and other development.
4.2
Brent has three opportunity areas:


4.3
Wembley (encompassing Wembley/Neasden SIL)
Park Royal/Willesden– part of which falls within Brent. The remainder is in Ealing,
Hammersmith & Fulham. (encompassing Park Royal SIL)
Colindale/Burnt Oak
A plan outlining the extent of each area is included in appendix 3. The Wembley/Neasden
and park Royal SIL are encompassed by the Opportunity Area boundary.
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4.4
Wembley
4.5
Wembley Opportunity Area comprises 239 ha, with an indicative employment capacity
established in the London Plan (2011) of 11,000. Together with its near neighbour Park
Royal, Wembley aims to become a key driver in the West London economy, providing a
sustainable source of jobs for local people. The Local Economic Assessment (2011)
highlights the importance of Wembley to the local economy and states concentrating and
coordinating office development within Wembley capitalising on key assets, infrastructure,
accessibility and branding remains the main way Brent can bring in additional investment
and prosperity to the borough. The site is well located to provide local job opportunities and
access to other facilities for some of London’s most deprived neighbourhoods nearby. The
London Office Policy Review (2009) noted that, other than Park Royal, Wembley was by
far the best new opportunity for office provision as evidenced by Quintain's Wembley City –
largely retail and leisure led – which includes consent for 100,000 sq m of office provision.
4.6
The emerging WAAP has been informed by an Employment Land Study undertaken in
2012. The WAAP sets the vision for Wembley to be a modern service based economy
comprising hotels, restaurants, offices, shops, leisure uses and creative industries. A small
but important element in the AAP for Wembley is the creation of workspace for the creative
industries (the arts, media, music, publishing etc). Nurturing creativity and enabling
creative people to live and work in this area will assist in the diversification of local jobs.
Research by Brent Council as part of the Local Employment Assessment (2011) has also
identified considerable unmet local demand for small scale employment spaces suitable for
occupation by creative industries.
4.7
In addition it is an objective in both the London Plan (2011) and emerging WAAP for
development within Wembley to aid the regeneration, vitality and viability of Wembley as a
town centre. The Wembley area currently includes two town centres; Wembley town centre
to the south west and Wembley Park to the north. The WAAP proposes to link the two
town centres through the eastward expansion of Wembley town centre. The purpose of
this policy is to ensure Wembley remains the main focus of new retail and town centre
uses. In addition there are concerns that conversion of office to residential within Wembley
will lead to a loss of, as well as undermining the ability to introduce, active frontage in the
town centre. This could prejudice its viability and the potential to expand Wembley town
centre eastwards creating a link to the Stadium area. This will have a particular impact on
the east of Wembley town centre, a key link to Wembley Park which has a concentration of
office uses.
4.8
Introducing permitted development rights within Wembley Opportunity Area could lead to
the loss of not only existing office uses, but 100,000 sq m of office provision in the pipeline
as part of Quintain’s Wembley City development. Loss of this office development will
impact on the ability of Wembley to achieve the target in the London Plan of 11,000
additional jobs. The council feels policy in the emerging WAAP allows for an appropriate
degree of flexibility in allowing conversion of office buildings. Policy WEM 10 allows for the
re-use of redundant office buildings for appropriate alternative use, where office uses are
no longer viable. The council already adopts a flexible approach which has allowed for a
managed reduction in office space over the last 20 years whilst protecting the viability of
Wembley town centre.
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4.9
Park Royal/Willesden Junction
4.10
As set out in the Local Economic Assessment (2011) Park Royal is Europe’s largest
industrial estate and the principal industrial area in West London. Together with Willesden
Junction, Park Royal extends to 700 ha across Brent, Ealing and Hammersmith & Fulham
boroughs. The Park Royal Opportunity Area currently accommodates some 2,000
businesses employing around 40,000 along with some small scale residential
development. It is estimated that the Opportunity Area could accommodate a further
425,000 sq m of commercial and industrial floorspace. Land use studies suggest 5% of the
Opportunity Area is used for business, 14% for industrial and 38% for storage and
distribution. The London Plan (2011) sets a target for the Opportunity Area to
accommodate 14,000 additional jobs.
4.11
The vision for Park Royal set out in the Park Royal Opportunity Area Planning Framework
(2008) is to protect and intensify employment on the Park Royal Industrial Estate by
supporting sustainable business growth and environmental industries, creating an
attractive working environment through improvements to public transport and the public
realm and the development of a new heart offering a range of amenities. The council’s Site
Specific Allocations Development Plan Document (SSADPD) plans for the development or
redevelopment of 50 ha of land within the Opportunity Area for employment uses between
2007 and 2017, which will create 4,400 new jobs.
4.12
The aim is for Park Royal to remain a strategic employment location, exploiting its potential
to meet modern logistics and waste management requirements, making good use of its
access to Heathrow and the West End, strategic road and rail connections and seeking to
develop its potential for water freight. It is also a key hub for the future location of waste
management facilities to help meet West London's needs.
4.13
Economic and land use research which informed the Local Economic Assessment (2011)
shows that while there is pressure for residential development and conversion to other
higher value non-industrial uses, demand for industrial land is constant and land will
continue to be required for employment use. Local businesses have expressed the view
that improving access to public transport, providing more amenities and upgrading the
environment (including transport access and physical appearance of the sites gateways)
would benefit their operations and attract more investment and employment to the estate.
Park Royal Partnership supported the council’s ambitions for Park Royal to continue
deliver local employment. 50% of jobs in Park Royal are taken by local residents living in
the surrounding area – including some of the most deprived wards in England: Alperton,
Harlesden and Stonebridge in Brent, East Acton and Hanger Hill in Ealing, and College
Park and Old Oak in Hammersmith & Fulham. The estate has provided, and continues to
provide local employment for some of Brent’s residents in the most disadvantaged wards.
4.14
As with SIL the council is concerned the conversion of office buildings to residential within
Park Royal could prejudice not only office development, but the character of Park Royal as
a principal industrial area which employs a significant number of Brent residents. This
could impact not only on the existing 40,000 jobs within the Opportunity Area, but the
potential to meet the London Plan (2011) target of 14,000 additional jobs.
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4.15
Colindale/Burnt oak
4.16
Colindale and Burnt Oak Opportunity Area comprises a 262 ha site with an indicative
employment capacity of 2,000 and potential for a minimum of 12,500 new homes as set
out in the London Plan (2011). The area includes major development sites in Brent along
the Edgware Road at Oriental City, Zenith House and Capital Way. The SSADPD (2011)
protects 9 ha of land within the Opportunity Area for industrial operations including B1, B2
and B8 or closely related uses. A proportion of the site has been identified for managed
affordable workspace.
4.17
The allocations in the SSADPD (2011) contribute to the delivery of the council’s growth
strategy whilst allowing for an efficient use of land which mitigates between possible
conflicting uses. This includes an appropriate buffer development between new
development and existing employment uses. Should offices within the Opportunity Area be
allowed to be converted to residential in an unmanaged way this could threaten the
balance of uses and the character of employment land. This will ultimately threaten the
council’s ability to achieve the target for the area to provide 2,000 new jobs as set out in
the London Plan (2011).
5.0
Additional Concerns
5.1
In addition to seeking exemptions the council would like to take this opportunity to raise a
number of concerns.
5.2
Air Quality
5.3
The potential for housing to be developed in areas which suffer below acceptable levels of
air quality is of particular concern in Brent as the A406 North Circular Road (NCR)
intersects the borough. The NCR is designated as both a Trunk Road, Greater London
Authority Road and a Priority (Red) Route and the forms a key element in the London
Road Network in channelling essential traffic, especially freight, away from Inner London.
As such the NCR presents special air quality problems and has been identified as one of
the most polluted locations within the borough in Brent’s Air Quality Action Plan (20052010). Notwithstanding improved fuel emission standards, the sheer volume of traffic on
this road, even if significantly reduced, would present severe air quality problems for the
foreseeable future. There will continue to be unacceptably high-permanent concentrations
of certain pollutants for areas close to the road.
5.4
The council currently has a policy to manage air quality sensitive development within
restricted areas in close proximity to the NCR, such as housing, hospitals and schools.
Due to the accessibility of the NCR it is an attractive location for employment uses. The
two main office locations adjacent NCR are Wembley Point (which contains 15,108 sq m of
office accommodation) and the former Unisys Offices in Stonebridge Park. In addition
there are numerous smaller offices in the vicinity of NCR. The council is concerned under
the permitted development rights these offices could be converted to residential uses
without having to demonstrate there would be no adverse health impacts on future
occupiers.
5.5
The Chief Planner’s letter dated 24 January 2013 makes reference to a prior approval
process covering significant transport and highway impacts, and development in areas of
high flood risk, land contamination and safety hazard zones. The council would urge the
7
DCLG to include an assessment of air quality as part of the prior approval process to
ensure the health and quality of life of future residents is protected.
5.6
Developer Contributions
5.7
There appears to be no provision for the council to seek Section 106 contributions for open
space, education and health care. This will result in pressure on existing schools, open
space and infrastructure, especially in areas of the borough where an increase in
residential accommodation was not envisaged. It is also unclear how the provision of
affordable housing will be dealt with through the permitted development rights. If no
affordable housing is required as a result of change of use then this will have a dramatic
effect on the supply of affordable housing in the borough.
5.8
Housing Standards
5.9
It is unclear to what extent the new homes provided through office to residential
conversions will be expected to comply with design guidance such as the Mayor’s Housing
Supplementary Planning Guidance (SPG) and Brent Council’s Design Guide for New
Development SPG. Guidance encourages high quality design, specifies minimum space
standards and levels of amenity space. It is unclear how design and spacing standards will
be maintained. The same point applies to other planning requirements including renewable
energy, parking levels, secured by design, Lifetime Homes, and provision of wheelchair
accommodation.
5.10
Resources
5.11
Permitted development rights will be subject to a prior approval process covering
significant transport and highway impacts, development in safety hazard zones, areas of
high flood risk and land contamination. It is currently unclear who will manage the prior
approval process and how this will be resourced given current pressures on council
resources and budgets.
6.0
Conclusion
6.1
To summarise the introduction of the proposed permitted development rights to SIL, LSIS
and Opportunity Areas will have substantial adverse economic consequences for Brent.
Whilst housing development creates employment opportunities through the initial
construction work this is not a long term gain and will result in a permanent loss of
employment land with potential to create long term growth and jobs. The permitted
development rights threaten not only the existing 267,000 sq m of office stock, which
provides employment for 15,677 people (London Office Policy Review, 2012), but could
also compromise the distinct industrial character of SIL and LSIS, and prejudice their future
development for employment uses. This is of particular concern in Brent due to the number
of micro-enterprises employing less than 10 people, meaning the availability of affordable
workspace which SIL and LSIS contain is of particular importance to the local economy.
6.2
There is also concern the permitted development will lead to a loss of office development
with extant planning permission. The most significant of which is 10,000 sq m within
Wembley as part of Quintain’s Wembley City development. Loss of schemes such as this
to residential will severely damage Brent’s ability to meet employment targets in the
8
London Plan for Opportunity Areas and achieve the projection in the London Office Policy
review (2012) of a 22,331 increase in office employment by 2036.
6.3
In addition there are concerns that conversion of office to residential within Wembley will
lead to a loss of, as well as undermining the ability to introduce, active frontage in the town
centre. This could prejudice its viability and the potential to expand Wembley town centre
eastwards into the Stadium area as set out the WAAP.
6.4
Exempting the proposed areas from the permitted development rights would still leave
scope for a considerable amount of office space to be converted to residential, including
the conversion of offices within a Major Centre at Kilburn, 10 District Centres and 4 Local
Centres.
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References
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Brent Air Quality Action Plan (2005-2010), London Borough of Brent
Brent Core Strategy (2010), London Borough of Brent
Brent Local Economic Assessment (2011), Centre for Local Economic Strategies
London Borough of Brent Employment Land Study (2009), URS
London Plan (2011), Greater London Authority
London Policy Office Review (2009), Greater London Authority
London Policy Office Review (2012), Greater London Authority
Park Royal Opportunity Area Planning Framework (2008), Greater London Authority
Site Specific Allocations Development Plan Document (2011), London Borough of Brent
Wembley Area Action Plan Economic Development and Employment Land in Wembley
(2012), London Borough of Brent
10
Appendix 1: SIL Boundaries
11
Park Royal
12
Staples Corner
13
Wembley/Neasden
14
East Lane
15
Appendix 2: LSIS Boundaries
16
Alperton
17
Church End, Brentfield Road & Neasden Lane
18
Cricklewood
19
Colindale & Honey Pot Lane
20
Kingsbury
21
Appendix 3: Opportunity Area Boundaries
22
Wembley
N.B. Print at A3.
23
Park Royal/Willesden
N.B. Print at A3.
24
Colindale/Burnt Oak
25