About Ed

staff in the Bartlett School of Planning and cooperating with others in UCL and with the Just Space Network to support London citizens' inpu

Just days 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privileges for developments of this sort and the whole concept represents such a change of policy that it should be withdrawn and re-considered as part of the next London Plan.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.

#LDNworkspace – an innovation

Later (21 Feb) This experiment generated a mass of tweets which the London Assembly Economy Committee staff consolidated in a Storify here.  We’ll add updates from the meeting when we have them.

15 Feb: This is an innovation in democracy: Just Space in discussion with the Chair of the London Assembly Economy Committee is experimenting with tweets as a way for us to inform the committee’s debate on Tuesday morning 21st February on small enterprises: access to workspace, impact of the business rates increase and what support is needed from the Mayor of London. The briefing for the panel debate is here and the debate should be webcast.

The following guests have been invited to attend

  • Simon Pitkeathley, Chief Executive, Camden Town Unlimited; 
  • Natalie Campbell, Co-founder and CEO, A Very Good Company; 
  • Dr Patria Roman, Chair of Trustees, Latin Elephant and member of Just Space;
  • Ben Johnson, Senior Advisor, Business and Digital Policy, Greater London Authority;
  • David Fletcher, Chief Executive, Wimbletech Community Interest Company.

The Committee is keen to hear from a wide range of business and community interests and have arranged to gather views, concerns and suggestions through Twitter, under #LDNworkspace on three main questions:
•       Does your business find it difficult to access workspace in London?
•       How will business rate increases affect you?
•       What further support could the Mayor of London give you and your SME?

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Housing trumps everything

The severity of London’s housing crisis is being used as grounds to displace other activities on which London depends: office, workshop, industrial, retail and social enterprises. Even more of an own goal is the way London sacrifices its remaining social housing to achieve extra total housing numbers, but less affordable. Just Space is challenging the way this is done partly through what looks like a technical/professional exercise of listing sites but is really policy-making in disguise. Continue reading

Mayor’s plans need toughening up

12 December 2016 London Community groups today welcome the new Mayor’s ambitions to make this a city “for all” but his proposals need a lot of sharpening if they are to turn the tide of developer-domination of London’s growth.

Responses to the Mayor’s first document, A city for all Londoners, closed last night and the Just Space network response is here just-space-response-to-a-city-for-all-londoners The Mayor’s report, together with reports and slide shows from the various consultation events held in November 2916 are all here https://www.london.gov.uk/get-involved/have-your-say/all-consultations/city-all-londoners

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Lobbying City Hall

Just Space, after publishing the ground-breaking document Towards a community-led plan for London: policy directions and proposals, is following up by working with various parts of City Hall.

We met with Nicky Gavron, Vice-Chair of the London Assembly Planning Committee and have written in June and October to the Chair, Tony Devenish and to her – most recently sending our critique of the London Infrastructure Plan 2050 which their Committee is discussing.  Just Space plans to contribute to future meetings of the committee, especially on the formative ideas for the next London Plan.

Just Space takes part in the Strategic Housing Market Partnership [a re-naming of the former Strategic Housing Land Availability (SHLA) Methodology Panel ] whose October meeting heard a summary by Elliot Kemp of some of the 6 research projects on housing density which the Mayor’s office had commissioned.  These 6 reports are expected to be published later in October.  Meanwhile the slideshow from the meeting is here.

As the London Enterprise Panel is currently going through a review of its purpose and membership, Just Space has asked to meet with the Mayor of London to discuss the opportunity to be represented on the LEP, to give voice to a wider range of interests and concerns and bring in the diverse expertise of the network’s members.

Just Space Economy and Planning has also recently written to the Mayor of London and the London Enterprise Panel regarding the bid to the Government’s Local Growth Fund, expressing concerns that the proposed funding allocations would not meet the real priorities of London’s diverse enterprises.

The LEP bid would direct £173m at supporting housing development in the Royal Docks, Housing Zones and on small sites. JSEP emphasised that one of the key pressures facing London’s economy is the severe lack of low-cost accommodation for a wide range of activities, caused by the loss of essential workspace on industrial land and high streets to housing development. JSEP suggested that this funding, together with the £110m proposed for high-street regeneration should be used for retaining and increasing workspace capacity to support London’s diverse economic sectors. This would strengthen manufacturing, repair, reuse, recycling, servicing, storage and distribution activities, all of which contribute to local employment and local supply chains, reducing emissions caused by travel to work and deliveries. JSEP argued that supporting these sectors should be one of the key priorities in spending the £30m proposed budget for improving air quality. Continue reading

Londoners’ own plan for London

Just Space Network launches Community-led Plan for London and calls for Sadiq Khan to encourage fair involvement in planning.

Just Space, an informal network of voluntary and community groups, has published a draft Community-led Plan for London to establish the need for public participation and new initiatives in planning the city.

Towards July thumb

Frustrated by the few gains resulting from community participation in successive Examinations in Public (EiPs) of the London Plan, and at too late a stage in the process, Just Space decided to use its combined knowledge and evidence built up over many years and write a set of London Plan policies from a community perspective. Eighty-five different organizations have contributed to the draft, from local community campaigns to pan-London interest groups.

Just Space calls for the new Mayor to analyse the current planning model and its detrimental impact on the majority of Londoners. They say there is an urgent need to re-balance a system in which developer-led planning dominates large areas of the city, for example across the ‘Opportunity Areas’. Just Space challenged Boris Johnson’s London Plan, saying it would increase the polarisation of London’s communities, continue to encourage inequality and not solve the housing crisis. They were also critical of the narrowness of his ‘World City’ focus.

Richard Lee, Just Space co-ordinator, said:
“Londoners need to be involved in strategic thinking about what kind of a city we want to live in and how policy can reflect that, rather than being just ‘end users’ of the planning system. We have a wealth of knowledge to bring to the table and are looking to Mayor Khan and his team to open the door at this formative stage.

“Our view is that people are alarmed at the social and economic impact of recent development and that as a result different planning priorities need to be established. Our policies focus on London’s well-being, for example through a more localized, fair and green economy; the refurbishment of existing homes; functional blue and green spaces; the importance of social infrastructure and community assets. The proposals come about through ground-level knowledge and the principle that London should be a city for all.”


  1. Download Towards a Community-led Plan for London – policies and proposals Sent to GLA Assembly Members, Mayoral advisers and planning team on 10 August 2016.
  2. The Just Space Network was founded to bring a large number of community voices together to participate in the Examinations in Public of the London Plan, a formal process usually dominated by town planners and developers and where participation is rare from those most affected by the policy on the ground. The Network brings together an impressively wide range of groups, some with a London-wide remit such as the London Forum of Civic and Amenity Societies and Friends of the Earth, others locally-based community groups such as the Earl’s Court Tenants Association and special interest local campaigns like Friends of Queen’s Market.
  3. The Network also has close links with London Universities (e.g. UCL and King’s College) whose staff and students provide research that the network can use to support grass roots evidence, while students gain from working in direct contact with communities.
  4. The Mayor of London normally produces an outline of his draft ideas for the new London Plan early in his term. The last Mayor’s document was called “Planning for a better London”. https://www.brent.gov.uk/media/323950/SD67%20plan-better-london.pdf Sadiq Khan’s is expected in September or October 2016.
  5. www.justspace.org.uk

Supporting documents

Long version of Chapter 3, Economy, with notes and sources: Download: Just Space Community led Plan – Economy long June