[not long] to comment on “affordable housing” draft

Comments must be submitted by 28 February on the Mayor’s draft SPG on affordable housing and viability tests.  All Just Space groups are urged to submit their views direct to the Mayor’s office in good time and copy them to JustSpace so we can share them and formulate our collective response more effectively. 

An SPG (Supplementary Planning Guidance) is not permitted to make “new policy”: it has to stay within the policies set out in the adopted London Plan. The Mayor is thus hemmed in: he can only propose things which fit the policies inherited from Boris Johnson (and fit the policies of the national government).

Among the issues which Just Space groups may want to comment on are:

1.  There are no provisions to increase the supply of new housing at social rent, or to protect existing stocks. Indeed the social housing requirement on private development projects is reduced. Just Space has always argued that social rent is the ONLY rent regime which meets the needs  of those in the greatest housing need and of Londoners on normal incomes. The evidence for this is even stronger now and homelessness is growing.

2.  The relatively new idea of developments built from the outset for renting  by private developers —called Build to Rent (BtR)— is being promoted without adequate preparation or research. It is proposed to grant various privileges for developments of this sort and the whole concept represents such a change of policy that it should be withdrawn and re-considered as part of the next London Plan. The Mayor may be hoping for a lot of these homes to be built to help meet targets for total output (though they will not contribute to social housing output) but if there is really as much “investor interest” as claimed, then this output will probably be forthcoming without any new privileges.

3.  Pending the new London Plan there is merit in the idea that developments which meet (or exceed) a minimum threshold of (genuinely) affordable housing provision should be exempt from the need to present viability assessments.  But the threshold should be set at 50% “affordable” (the Mayor’s manifesto commitment), not at 35%. And within the required “affordable” housing the requirement for 60% to be social rent should be enforced.  One aim of all this is to lower developers’ profit expectations and thus gradually lower the amounts they pay for land, and the sooner the Mayor starts to push these expectations down the better. Developers whose schemes meet the existing London Plan target of 35-40% “affordable” could still apply and still get permission but would simply not benefit from the fast track handling.  The Mayor is surely free to reward those whose projects exceed the plan’s requirements.

4.  All developments taking place on public land or by housing associations should be required to deliver at least 50% “affordable” housing.

The Mayor’s draft SPG is here.

Submit your observations to housingspg@london.gov.uk by 28 February and please copy to Just Space – m.edwards@ucl.ac.uk who is coordinating replies.

Compare with the housing section in the Just Space document  Towards a community-led plan for London here

More detail (added 23 February). One of the Just Space groups, the 35% Campaign in Southwark, has prepared detailed comments and proposals and thay have agreed that we can post that here to help other groups prepare their submissions. A short summary in 10 points follows, and the full 16-page text is a download here: affordable-hsg-spg-35-response-draft

1              We’re dismayed the Mayor has done nothing to promote social rented housing; indeed the opposite, by reducing the amount required in the affordable housing tenure split.

2              The cumulative effect of some of the changes proposed in the SPG eg changes in tenure split, excluding social rent from Build to Rent (BtR), amount to a change in the London Plan and should not be made without the consultation that requires.

3              There is a lack of research and assessment behind the SPG for BtR.  This should be produced before the Mayor gives it  further support.

4              The viability threshold should be raised to 50%.  It’s important to note that this is not a target and does not place any obligation for a/h delivery on the developer, for better or worse.

5              All developments by registered providers and/or on public land should deliver at least 50% affordable housing.

6              The Mayor should be prepared to exercise his call-in powers more readily.

7              The affordable housing tenure split should remain at 60:40 social /affordable rent and intermediate rent.

8              The Mayor should reconsider his support for BtR.  It will be afforded numerous planning concessions (laxer density, space, design standards); it is likely to deliver less affordable housing in total; it excludes social rented housing; its viability assessments will be treated more leniently.

9              BtR’s affordable housing, discounted market rent (DMR) is inferior to social/affordable rent/intermediate rent on one or several counts –  it provides shorter tenancies;  it will probably charge higher rents; it’s long term ‘affordable’ status looks doubtful.

10           Notwithstanding our objections to BtR we’ve made various suggestions that might improve it – longer tenancies and covenants, more comprehensible ‘clawback’ arrangements.