Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

Tuesday 12 March afternoon: extra session for matters not discussed on Feb 27
M29. Build to Rent
M33. Large Scale Shared Living Development
M30. Supported and Specialised Housing

Build to rent: the panel’s questions
M29. Would Policy H13 provide a justified and effective approach to build to rent housing to meet housing need? In particular:
a)  Would the criteria to define build for rent set out in Policy H13B be justified and would they be effective in supporting delivery?
b)  Would the approach to affordable housing requirements be justified and effective? Would it be effective in meeting local needs? Would the approach to discounted market rent homes be effective? Should the discount level be defined locally to take account of local circumstances?
c)  Are there specific design requirements of this type of housing and would the policy be effective in delivering them?
d)  Overall, would it meet the objective of Policy GG4 to delivering the homes Londoners need?

GLA James Clark and Robert Wacher: providers of BtR are not discontented by this policy.
Answering questions from the Panel:
Why not use NPPF definition? A: we wrote the definition before the NPPF 2018 came out, and we think it’s good.
Criteria in NPPF and SPG, defining BtR, accepted by the industry
What about the “distinct economy” of this form of provision? A: BtR and BtS have different attributes. Some positive, some negative from a profitability point of view (lists them) justifying a distinct planning regime.

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

This is a rough draft posting with many corrections still to come (1 March)

London Plan EiP Other housing matters. 01/03/2019

Size mix M28.

Panel questions:  Would Policy H12 provide a justified and effective approach to achieving the dwelling size mix to meet London wide and local needs? In particular:
a)  Does the dwelling size and mix identified in the 2017 SHMA provide a robust and realistic assessment of London wide needs?
b)  Would policy H12 provide an effective and justified strategic framework to deliver the mix of homes needed? What is the justification for preventing boroughs from setting prescriptive dwelling size mix requirements for market and intermediate homes and would this approach be effective? Would it provide sufficient flexibility to meet local needs? In light of this and the need to optimise density would it make a sufficient contribution towards family homes?
c)  Overall, would it meet the objective of Policy GG4 to deliver the homes Londoners need?

 Assembly Planning Committee  SHMAA. Table 1 is based on an entirely hypothetical scenario. This is contrary to paragraph 3. Table 1 means that all rooms are occupied. That means that if someone has a spare room, it means there is someone else lacking a room. Table 1 is a scenario that is not going to happen. You can’t direct people to scenario in table 1.

You have many scenarios and you need to have a single scenario that is evidence-based. The plan needs to provide this scenario.

Assembly Conservative Group Shortage of family size properties. The Mayor can take different approaches to address that. The planning system, the housing strategy. There are no incentives in the planning system nor in the housing strategy to build family size housing. There should be funding for this.

Problem overcrowding. Even if you address the issue of under-occupation, you will still have a problem of overcrowding.

London Tenants Federation (LTF) If you don’t have a degree of prescription, properties of 3 and 4 bedrooms will be squeezed out.

A low provision of market family size housing will put even more pressure into social family size housing.

The bias should be towards more family-size social housing.

 

Assembly Planning Committee   Importance of London Living Rent for nurses, teachers, junior doctors, etc. Many of these need to go out of London to find anywhere they can afford.

Family housing is the most flexible form of housing and it suits London’s need.

Inspector to GLA: What evidence you have on size mix?

Mayor’s team We are not presenting a criteria based policy.

Inspector What evidence you have for those policies.

Mayor’s team (?) She is talking about the referable applications ??

Inspector

Disadvantages of small units and advantages of family homes.

Does this policy ensure that enough family homes are built?

Mayor’s team

Developers will build what is more profitable.

Many of the family homes are not occupied by families, they are occupied by sharers. The need is an affordability issue here. We say that these family homes should be build where they are more affordable.

Inspector

Concern: there are 3 scenarios embodied in the three versions of the table. The last one is the only one that is evidence based.

Removing the table from the London Plan seems to be welcomed, but it needs to be replaced by one scenario.

Mayor’s team

We have tried to be as transparent as possible on how we have arrived to each of these scenarios.

The problem with the local evidence is that is not that transparent.

There is a need for better guidance from the government on this.

They suggest an SPG that will bring the evidence to the area-wise size mix target.

Inspector

Anything else you would like to respond to?

Mayor’s team

There is an issue about very large units being delivered.  Paragraph 3.4.3 to resist those too large dwellings.

If there is a requirement to build homes that are not highly demanded by the market, this will slow development. This is why we believe there should be no prescriptions.

London Forum

? missing bt

Just Space

Horrified by the push to build smaller and smaller units.  People cannot have children and it’s being assumed that they won’t.

Planning needs to accord to the reality that many people do have children.

Inspector:  Request for a more positive policy that sets criteria for the local authorities.

Mayor’s team:  We feel we have that criteria in policy H12.

 

LA Planning Committee

SPG: It is important that it is evidence-based.

LTF

It is not acceptable to say we cannot provide family size housing because it costs a lot if this is what people need.

Levitt Bernstein

Requirements for particular ethnicities should be taken into account. 

Vacant Building Credit

Panel Question: M25. Would Policy H9 be consistent with national policy? Is the approach taken justified?

Inspector;  What evidence do you have that brownfield land will come for development anyway?

 

Mayor’s team:  This is what we have seen.

 

Clarify the circumstances in which the credit should be used (Vacant building credit). The purpose of this clarification is that it will be difficult to falsify vacancy to benefit from the credit.

Inspector:  Expand on the point that it is in accordance with government policy

 

Mayor’s team:  (didn’t get what she said)

 

Inspector:  Some people say it should be a matter for London boroughs to expand. Respond to that.

 

Mayor’s team:  There is a huge need on affordable housing across London. The London Plan needs to tackle that. Leaving it to local authorities would be to risky since the affordable housing needed might not be delivered.

Home Builders  Federation

We haven’t heard about the incentive to deliver more homes. So more sites come forward.

NHS property:Benefits to the VBC that has been overlooked. It might incentivise building in brownfield land rather than on green belt.

NHS have a number of vacant buildings that could benefit from VBC. Many of them listed building. Listed buildings should be prioritised through additional text.

The proposed 50% affordable housing puts a lot of burden on the NHS sites. If VBC is brought forward, NHS property should be exempt if they can demonstrate strategic enabling…

 

Inspector

Asks the Mayor about whether a reverse policy would have been more effective.

 

Mayor’s team

They don’t agree that overall housing need and affordable housing need are two separate things.

VBC is very rarely if at all applied in London. That is because the viability tested route does its job.

 

Redevelopment of Housing and Estate Regeneration
Panel questions: M26. Would Policy H10 provide a justified and effective approach to the redevelopment of existing housing and estate regeneration? In particular, would the approach to affordable housing be justified? In light of Policy H5, would the requirements be clear? In the context of local need and objectives for redevelopment or estate renewal, would it be effective? What is the justification for provision of affordable housing floorspace rather than units? Would it provide sufficient flexibility to reflect local circumstances and support housing and estate regeneration? Overall, would the approach taken meet the objective of Policy GG4 in delivering the homes Londoners need?

 Inspector

What happens when there is a potential loss of housing.

It says that it should be replaced with at least the same floor space overall.

All should go through the viability tested route.

 

I would like to ask on something on what LA Green Group (Sian Berry) said.

 

 

Mayor’s team

4.6.14 Estate regeneration is not covered by the policy.

And it is reiterated saying it does not going through viability route.

It is controversial in London and it is best that it is out in the public.

Incompatibility with delivering the number of new affordable housing.

 

Still Mayor’s team?It should be replaced with the same quality, with the same floor space of low cost rent.

When social rent with tenants’ right to return, it should be replaced with social rent. When there is no right to return, it could be replaced with either social rent or London affordable rent.

 

Floor space is the best way to keep mixture of unit sizes and ensure the floor space

 

Inspector

Why not number of units.

 

Mayors team

With number of units you could lose floor space as small units replace larger ones.

 

London Property Alliance

Small scale schemes. It does not distinguish between small schemes and estate regeneration. Particularly in inner London, where it is far more mixed. Some of these buildings might be available for redevelopment. The fact that all of them have to go through the viability tested route is a disincentive for redevelopment. (He seems to be proposing the 35% fast track route)

 

London Assembly Planning Committee

Estate regeneration is not clearly stated in policy H10.

They believe that policy H10C should be reinstated.

All estate regeneration should provide at least the same tenure and floor space.

Improvement of existing housing, new affordable homes, and improvement of…

A cross reference to the Mayor’s guidance on estate regeneration would be helpful here.

 

LTF

Refurbishment rather than demolition should be the norm. The presumption in H10 is demolition and they reject that. A new H10C should be instated that prioritise refurbishment vs demolition.

Keep the existing, refurbishment, and add new social housing.

When a block is earmarked for demolition, while its wait its demolition, it goes through a state of under maintenance and disrepair that is not good for the residents.

They don’t want social rent replaced by London Affordable Rent. The rent is much higher.

Ballots: we’d rather not to be in a position where we have to ballot the demolition of a estate, because it is a lot of stress and a lot of work.

We think that ballot should be a planning requirement, not a condition to GLA funding.

 

Inspector

Go back to the Mayor. Is this policit about redevelopment of existing housing or about estate regeneration?

 

Mayor’s team

It is attempting to do both.

 

Inspector

About the plan prioritising demolition

 

Mayor’s team

We would say it is the opposite compare to the previous plan, which identified estates as sites for more housing.

We just say that when demolition is going to happen, it should follow this policy.

 

Just Space

Council rent can be replaced by higher rents and this has never been said before.

I am also worried that this policy has already been implemented by the GLA through the planning system. Provides examples of Lewisham and Merton where policy H10 has been implemented and they justify the replacement of social rent with London Affordable Rent. This plan should not be implemented because it is still being examined in public.

From 105 to 152 pounds week (SR to LAR).

Vital issues should be not in the footnotes and reword it: replaced with no increase in the rent and no increase in service charge.

“Regeneration” has been misused for many years.

Health and wellbeing: we propose an additional paragraph about the mayor making an assessment on the health and wellbeing of people living in the estate before these schemes. Brings a report on the impact of displacement of residents: health, death. It is quantified in cost.

Not mitigate. Does it need to be make at all.

 

Footwork Architects Ltd

We cannot consider an existent estate as silos detached from its context.

A lot of discussion around the definition of the term regeneration, for the reasons just stated by Just Space. There should be a definition of it.

Policy H10 for such a contentious issue, it is incredible sparse. There is nothing here about the need for engagement with exisiting communities. There is nothing here to protect from displacement. There is nothing about the need for an initial assessment to know about the exisiting communities.

If it is not here, where are we going to do it?

 

LB Barnet

Floor space rather than units: we support the policy. (added some point but did not get it)

 

London Forum

We think this is a very bad policy. It is going to cause harm and it does not address the subject matter. Redevelopment of existing housing is different from redevelopment of estates.

To make this a policy that would work for estates. We need to have boroughs to make clear what they want to achieve. Appraisals consider. Social and environmental issues should be taken into account into these appraisals.

Leaseholders offered like for like replacement.

The policy is going to continue things that have gone wrong in the past.

The policy need to tell residents what is going to happen to their estates.

 

Assembly Planning Committee

There might be a case to separate policies from housing redevelopment from estate regeneration.

The policy is about demolition. It does not mention refurbishment. Is there goingto be a policy on refurbishment.

SPG on estate regeneration?

 

Inspector

Estate regeneration is a contentions issue. Comment on the point of separating housing redevelopment from estate regeneration.

 

Mayor’s team

We believe it is right to have that one policy.

We do not suggest this is a form of supply that boroughs should follow, but if it happens, how it should happen.

 

Inspector

Footnote 50a. Comment on that.

 

Mayor’s team

If you compare it to previous plan, this policy goes much further (the previous was talking just about replacing affordable, not specifying tenure).

We think we have gone considerably further.

About rent being identical. This is to the negotiations between landlord and tenants.

About making ballots part of the policy: we cannot oblige developers to do what the ballot result says, so we have done it through our funding.

 

LTF

We would like the GLA to reconsider what we are proposing: H10C edited. Refurbishment needs to be considered.

The preference is always demolition. The policy should say about considering refurbishment.

Rent to be negotiated between landlord and tenants? This is not realistic. These people need to be protected and it should be in the policy. Maintaining the same rent should be in the policy.

If you don’t consider all the options before demolishing, we are going to end up with many demolitions.

Public funding should all be spent on additional social housing units, NOT on demolishing and replacing units which are perfectly sound structurally.

 

Just Space

Comes back to the point on rents going up by 44-45 pounds a week.

Equality Impact Assessment: Impact of raising the rents on particular disadvantages groups such as Black & Ethnic Minority groups.

Suggest additions to the policy: a robust equality impact assessment that looks at whether these groups can afford to buy or rent housing on the new development.

 

Footwork Architects Ltd

Tenure mix and social infrastructure. How are we going to address this concerns.

On a process of community engagement. Regeneration schemes should put these aspects in discussion.

Policy needs to be rephrased.

 

London Forum

About GLA referring to the estate regeneration guidance: Guidance is how to implement policy, and we do not have any policy. The policy does not say anything about how renewal of estates should be approached.

 

Mayor’s team

In terms of planning process. We do have the guidance.

Suggestions for different clauses: This should not be seen in isolation as the only policy that applies to estate regeneration. She refers to other policies discussed in previous weeks. She says this policy refers to replacement of tenure.

 

They have incorporated security for those residents that have right to return, while previously C didn’t do that.

 

We have done some of these things in the good practice guide, but it is just a good practice guide, which shows different ways of doing things, which can not be put in policies.

 

Footwork Architect Ltd

Displacement: in order to avoid the lack of trust that exists around this issues. There needs to be some wording on how to avoid unnecessary displacement. She has written some wording.

The comment she heard in a half regeneration estate is: This is social cleansing!

These things do need to be in this policy. They need to be stated where they need to be applied.

 

Just Space

Footnote 50a. Right to return. It is a pity that this policy is not stated in a more positive way. There should be a right to REMAIN, so people do not have to leave and then come back.

A lot of pressure are put of people to leave their homes so the council has vacant property.

Point about ballots and residents making decisions.

All comes from the top down. It should be about residents making decisions.

We have to extend the ballot to using the planning power to oblige all boroughs to implement ballots.

 

Inspector

About including more details to the policy and all are claiming

 

Mayor’s team

They think it provide enough details. She refers to the guidance and that these things on the guidance should not be on the London plan.

 

Footwork Architect Ltd

What are we doing here if after a session like this, the Mayor’s team says after all this that they believe nothing should be included in the policy.

She would like to see the Mayor’s team acknowledging this.

 

Inspector

Yes, the panel does have a role on this.

 

Mayor’s team

Yes, we are going to assess these suggestions.

Notes thanks to Dr Pablo Sendra

Back to the EiP narrative page

 

 

 

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

Overview of week 4 – Monday 11 and Wednesday 13

Week 4 of the Examination in Public aimed to complete the review of the New London Plan’s (NLP’s) strategy in relation to housing supply and targets (started on Friday 8^th& concluding Feb 11^th) . This short summary of discussions aims to highlight a couple of issues with the approach used in the NLP, particularly with regards to the delivery of housing targets and the focus on small sites to unlock additional housing provision (Feb 13^th). This overview was written before the examination of monitoring and gypsy and traveller accommodation (Feb 15^th).

More detailed write-ups are:
Friday 8 and Monday 11 Feb M19 Housing supply and targets
Wednesday 13 Feb M20 Housing on Small Sites

The credibility of housing targets set out in the plan has been a running concern from community groups, London Boroughs (particularly Outer Boroughs), Wider South East Local Authorities and some representatives of the real estate/house building industry since the beginning of the examination. In previous weeks, various stakeholders have indicated these targets were very unlikely to be met and might encourage unaffordable, and very dense housing developments, thus threatening local communities and the preservation of local heritage across London. Just Space indicated that the EiP has repeatedly shown that this draft plan would not succeed in meeting its own estimation of London’s housing needs, let alone catching up with the unmet backlog of need for social rented/ low rent housing.

 

Furthermore, we highlighted that this situation was not new. We have been here before, and if the panel recommends the adoption of a deficient plan, subject to an early review of the market demand, social need, capacity and policy situations a few years down the line, we know what is going to happen. London will keep staggering from Plan to Plan, and it is the situation not only of low- and medium-income Londoners but of almost everyone across and beyond Greater London, that will deteriorate. We thus urged the panel to advise for a complete new approach to target setting and housing delivery. This requires new thinking and new models of land markets, in order to consider policies that do not contribute to, benefit from and incentivize land price escalation and that take seriously the role of non-market housing sectors and of the stock of homes. This will also require to reconsider how development viability is estimated and framed. This will imply engaging more closely and frequently with London’s communities, community organizations and universities as well as local governments. We observed this had been fruitful in the last weeks and we are even more hopeful that this can lead to more just results, especially as we have seen a renewal of the GLA team, coming up with fresh ideas and willing to invent the future.

 

The introduction of the Small Housing Sites (policy H2) in the NLP represents one such innovation, and was discussed on Wednesday Feb 13^th. The GLA team emphasized the novelty of this policy, which radically differs from previous London Plans focusing on densification and provision through large scale redevelopments. The team also stressed that this strategy aims to incentivize SMEs to enter the housing market and has the potential to create more mixed communities and to encourage the provision of affordable housing. To them, barriers to the widespread use of small sites are not economic or technological but deliberate policy choices.

Whilst the policy itself was broadly encouraged – particularly by community organizations, several issues were raised in relation to its design and implementation. The Examiner first highlighted recurring concerns, notably from the Boroughs, on the modelling of small sites capacity. The assumption and evidence behind the 1% growth target was questioned by community groups and the Boroughs – with the exception of the London Borough of Islington. The GLA team responded they thought the 1% assumption was realistic given the availability of stock and the appetite of small builders in terms of growth of their business, and the rate of growth to serve the population to fill those homes. The London Tenants Federation pointed out that its was unclear how this policy would benefit low-income households. A representative of the Federation flagged that there is a backlog of needs for social rented homes which has gone unmentioned in this strategy of endless subdivision of units. It is unclear how the strategy contributes to the actual needs of Londoners.

More generally, barriers to the delivery of small sites were highlighted by the Boroughs and London First. South London boroughs argued that the policy was simply replicating existing tools which were already being used (meaning a step change in delivery was unrealistic). Furthermore, concerns were raised on a number of points threatening the delivery of this policy:residents might oppose intensification; landowners might be unwilling to bring forward properties; it takes a large amount of planning time to bring applications forward as small developers are not necessarily experienced; boroughs do not have the resources to undertake detailed design code work and do not have the capacity for additional planning application work. London Forum expressed concern regarding whether boroughs had the necessary skills and resources to deliver; they felt this policy weakened the role of Neighbourhood Plans. London Tenants Federation made a strong statement regarding how community led developments on small sites have successfully brought forward social rented housing with genuine community benefits. They proposed specific wording to increase policy support for community, social rent and self-build. Both they and Just Space pressed for social housing contributions to be required from small sites of 0-9 dwellings as well as larger schemes, as practiced sucessfully by a number of Boroughs already. Islington council spoke up in strong suppport based on their experience.

In addition, it was flagged that even when housing provision increases as a result of small sites development, problems emerge in relation to transport and service provision. A representative of the NHS worried about how small sites intensification would impact access to social infrastructures. Just Space added that the spirit of small sites policy should be linked with lifetime neighbourhoods, including investments in local social infrastructure. The London Forum indicated that social infrastructure provision needs to inform decisions about developments and a mapping of these facilities should be undertaken to guide where there is capacity for development. Several organizations indicated that PTAL estimates needed to be taken with care when assessing the accessibility of small sites. For instance, the West London Alliance highlighted that PTAL should be a starting point for a more nuanced approach which considers development levels beyond London wide modelling to look at specific differences.

The Inspector raised at the end the possibility of adopting different ways of setting targets: SHLAA, trend based (as boroughs argued for more realistic setting of targets based on what had been achieved historically), policy-led approach based on identifying sites and local feasibility. It was noted that so many Minor Suggested Changes had now been made to the policy it had become opaque and hard to read!

This post by Enora Robin

More detailed write-ups are:
Friday 8 and Monday 11 Feb M19 Housing supply and targets
Wednesday 13 Feb M20 Housing on Small Sites

Back to the EiP narrative page

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

M20 Housing on small sites, policy H2

Key points from the morning:

1. Minor changes issued by GLA yesterday meant participants didn’t have enough time to formulate responses
2. Small sites are a key part of GLA new housing policy, with a 1% growth target which is based from no empirical research but partly judgement and partly choice.
3. In relation to M20, question a, participants raised concerns about this 1% growth target:
   1. 1% based on an assumption that 1 in 5 properties sold will increase their units, this is based on no evidence and is unrealistic
   2. 1% is a subjective choice by the GLA, whereas paragraph 48 of the national planning policy says evidence must be proportionate and compelling
   3. GLA say 1% is reasonable but it has a profound effect on output. In many boroughs this output increase in unachievable considering current rates of development.
   4. Therefore, the London wide modelling does not work in this instance as the targets are unachievable in many places
   5. Citizens have experienced the results of small-scale intensification without adequate service provision as negative
4. In discussion of the PTAL, participants raised concerns at its lack of engagement with communities:
   1. General agreement that the PTAL is a good starting off point to identify areas which lack accessibility but needs a more nuanced approach which examines specific differences and development levels

The following notes from the morning session follow a chronological order, and have tried to be comprehensive, however, some comments have been excluded to aid in representing how the flow of discussion took place. The numberings therefore follow how discussions played out.

Preliminary proceedings:

1. The panel welcomed early comments from participants
2. Generally, participants commented on the minor changes that were received yesterday (12/02/19), stating that participants have not had enough time to adequately read and formulate comments on these changes to policy H2.
3. GLA: a lengthy discussion of policy H2, responding to some of the written responses from participants. London has a housing crisis so more homes are needed, but must ensure good growth.
   1. Whilst the previous London plan focused on large sites the focus is now on the important role small sites must play. Push on small sites represents fundamentally different approach to previous plans.
   2. Need more SME builders to deliver small site goals
   3. This approach will deliver more mixed communities. For example, older people can downsize and stay in local community. Opens up more opportunities to open up affordable housing.
   4. People’s concerns include:
      1. accessibility of these sites? However, we’re talking about planning in a big city that is already well connected
      2. Character concerns? The character of London has always evolved, and will continue to do so

• Modelling concerns. Modelled approach provides spatial logic and unbiased approach.

1. In summary, small sites development is a new way of working, encouraging development in areas that haven’t experienced development in recent years. Barriers to widespread use of small sites are not economic or technological but deliberate policy choices and lack of focus on this form of supply in the past.

4. Panel: Please discuss recent minor changes made
5. GLA: the changes involved conservation area changes, and a removed of more detailed points relating to other policies in the London plan being removed.

 

a) Is modelling of delivery from small sites in the SHLAA justified, including reliance on PTALS?

The first part of this discussion was focused on modelling, not PTALs.

Discussion between the panel and the GLA only:

1. Panel: In terms of the modelling I am aware of concerns by boroughs on the way the methodology came about, as far as I’m concerned, I’ve got enough information to reach a view on that. However, paragraph 48 talks about the need to have a windfall allowance, what is your view about what you’ve done in relation to paragraph 48 and the windfall allowance?
2. GLA: the modelling was based on projected future trends, and historic delivery. What we are unable to rely on is the historic delivery rate is because we will be going forward on the new policy. So it was a combination.
3. Panel: So because of what happened in the past, and what will happen in the future, there is compelling evidence for paragraph 48?
4. GLA: Yes
5. Panel: Have there been case studies to test it?
6. GLA: No, we based it on our general understanding.
7. Panel: Small sites have been set as schemes of less than 25 units or under 0.25 hectares. Why have these numbers been chosen? The national policy is less than 10 homes,
8. GLA: the SHLAA has used 0.25 hectares for a while. For the 25 – we did consider a number of different thresholds. We thought that 10 would act as a ceiling to development, and larger than 25 we thought there would start being greater impacts on the areas than a small site should.
9. Panel: You didn’t include a source on the allowance on the intensification of flats. Why?
10. GLA: The intensification of flats would usually come under large sites. We have already removed houses that have already been converted into flats from the modelling. But, we considered that flats are much more complicated for the modelling. We would support intensification of flats, and if that capacity exists that would help boroughs to reach their targets.
11. Panel: So intensification of flats wasn’t included but that doesn’t mean its precluded from developments?
12. GLA: yes.
13. Panel: Where does the 1% growth assumption used generally (not in conservation areas) come from? In SHLAA it says it’s a reasonable estimate, but I’ve seen others saying it should be lower.
14. GLA: When determining the rate of growth we were careful that it shouldn’t be so high as to disrupt the character of the neighbourhood, but couldn’t rely on an unrealistic housing growth. So, we thought the 1% was realistic given the availability of stock and the appetite of small builders in terms of growth of their business, and the rate of growth to serve the population to fill those homes. We thought that 1% represents a fairly modest rate of growth. We were aware of the undesirability of having a low growth rate, that would hinder London’s ability to meet London’s growth needs.
15. Panel: So, the 1% figure was partly a policy choice, partly a judgement, not based on empirical evidence?
16. GLA: Yes.
17. Panel: Some criticisms say that the 1% growth rate doesn’t make allowances for boroughs, for example that it shouldn’t include garden land. What do you say to this?
18. GLA: we would say the intensification figures are robust, based on a pan London sample to increase sample size. I would argue we haven’t included garden land in the intensification factor.

The panel then opened up the discussion to the floor, regarding concerns about modelling.

1. Panel: Any other questions about modelling?
2. London Forum: General deep concerns about these policies. But on the question of the assumption of the 1%, you justify that on the basis that 5% of properties are sold each year. But the 1% suggests that 1 in 5 properties sold involves an increase in the number of units. Sounds reasonable, but there is no evidence of that. Most sales involve adjustment of the property, or an extension of the property, but not necessarily an increase in units.
3. CPRE: In relation to open space and modelling, clarification in relation to general public open space and how this has been taken into account in the modelling process.
4. London Borough of Islington: Generally in support of the policy. Significant delivery of small sites is deliverable even when there are seemingly lots of constraints. We wanted to come along and provide support. Linking delivery to past trends isn’t going to cut it anymore to meet future needs, so in my mind this is a good approach that enforces a proactive mindset in other boroughs.
5. SW London: It was heard the 1% was a subjective judgement of the GLA, we think it should be formed by evidence not judgement. This same argument applies to conservation areas, why 0.25%? The GLA say that 1% is reasonable but it has a profound effect on the output, we think it should be justified by robust evidence. Additionally, terraced and semi-detached houses should not be modelled in the same category; a more nuanced approach was required to deliver the notional capacity and it would’ve given a more realistic output. Moreover, we have a large social housing estate, totally unsuitable to deliver what policy H2 expects. We are not anti-growth, we accept the responsibility, but when a new housing target is released, we must objectively assess it, and it is not possible to reach this.
6. Havering: We have got to question if the 1% growth assumption is realistic. It’s too large. No evidence that 1% will happen. When the numbers are actually crunched, the outputs are undeliverable
7. Bexley: Must reflect on what a ‘modest’ target actually means. Across London it would mean a 6-fold increase would be required. In Bexley, a 5-fold. If you look at applications for small sites we would need to more than double the small sites applications, and then approve them all. Our policies are permissive currently. We have done an analysis on our policies, to show that our policies are permissive in relation to what the draft London Plan sets out as permissive local policies. In terms of the 1%, it would be interesting to know what the historic growth rate is. In Bexley, it is 0.2% currently, so we would need a 5-fold increase in our small sites almost immediately. Additionally, the methodology emerged after the large sites figure was found. The 1% figure covers the gap to meet building need, that’s not evidence, that’s reverse engineering
8. West London Alliance: it is important to look at the scale of change these numbers envisage. A 238% increase on historic delivery. Paragraph 48 of national planning policy says evidence needs to be proportionate and compelling. The evidence here is not, therefore this is not sound.
9. London Tennants Association: Whilst Islington council may see their small site development strategies as successful, citizens have seen the results of intensification as negative. There is a backlog of needs for social rented homes which has gone unmentioned in this strategy of endless subdivision of units. How does this contribute to the actual needs of Londoners?

GLA: We overstated the 5% churn in relation to 1% growth. Inner London figures haven’t changed as much as outer London as much of the intensification has already happened/is happening. We need to meet the needs of overcrowding and homelessness. The policy approach is based on robust evidence base.

1. West London Alliance: Lack of evidence on change in relation to new planning environment. No evidence or engagement with homeowners.
2. Bexley: Agree- householders do not directly engage with policy.
3. London Forum: 1 in 5 homeowners are not going to divide their unit. This is something developers do, not normal homeowners. To intensify/build additional units into your home you need to have somewhere else to live through the building process and most homeowners do not have that

The Panel then moved on to discuss PTAL parameters directly.

1. TFL: 800m from transport is conservative, in an analysis of London residents and use of transport most 800m is walked. Acknowledge that PTAL has limitations, and are trying to work with these limitations as alternatives would also be limited. PTAL in practice will vary between and within areas.
2. NHS: Worried about access to social infrastructure
3. Pettswood: PTAL assumes you use the transport you live near to and this is unrealistic; many will drive
4. London Forum: PTAL is good at scoping the areas where development couldtake place, by looking at average accessibility, but needs more engagement.
5. West London Alliance: PTAL should be a starting point for a more nuanced approach which considers development levels by go beyond London wide modelling to look at specific differences
6. Just Space: Spirit of small sites policy should be linked with lifetime neighbourhoods. Investment in local social infrastructure as well as just housing supply brings a number of benefits whilst coping with increasing pressure.
7. Hadley wood: PTAL needs to consider differences between inner and outer London – different consequences of lack of accessibility

Morning notes  above from Zoe Rasbash and Lily Downes. Afternoon session below from Jenny Robinson.

During the session, the Inspector raised a number of questions of the GLA directly, and other topics attracted attention from London Borough representatives, who were there in force.

Is there nothing new in this policy?

GLA argued the policy is needed to encourage boroughs to proactively identify and bring forward new sites. Certainty, with design codes and an SPG on design will bring forward more development. South London argued that the policy was simply replicating existing tools which were already being used (meaning a step change in delivery was unrealistic). Evidence concerning how current borough policies impede small site development was cited but contested that it had not been made available (except in a press release).

 

Difficulties of bringing forward small siteswas an issue raised at length by London Boroughs and London First. Concern that residents might oppose intensification, landowners might be unwilling to bring forward properties, that it takes a disproportionately large amount of planning time to bring applications forward (small developers not necessarily experienced or working with experienced architects); that boroughs do not have the resources to undertake detailed design code work, and do not have the capacity for additional planning application work (GLA noted that the policy could yield 30 applications per year for Sutton, for example). Outer boroughs felt their circumstances were very different from that of eg Islington where this strategy has yielded considerable proportion of the targets (50% delivery 2005-18). Islington noted that outer boroughs²should accommodate change and take the communities on journey with them. Proper design codes should mean development did not disturb local conservation areas. Concern was expressed that undeliverable targets could have an adverse effect on the boroughs and the GLA through the anticipated Housing Delivery test and its consequences. The example of Croydon was noted where considerable effort had already been undertaken on design codes and small sites, but the increased targets from what has been delivered (592) to 1500 are unrealistic to achieve. The GLA observed on this that the new policies there had not yet had time to have an impact.

 

Viability of development and in relation to affordable housing: The GLA has an addendum which tests viability which they suggest exists on most sites (less viable on low value sites), and talking to small and medium developers have identified an appetite for development. A study put forward by some of the boroughs (undertaken by JLL) which shows challenges on viability was contested by GLA as assuming relatively high profits for developers (12% on affordable, 18% on private as well as assuming a 60/40 social rent -Intermediate split, which could be adjusted to have less social rent to increase viability. JLL speaker used the telling phrase “…market prices paid for land do not leave space for affordable units.” Enfield argued that small sites overrule market forces in terms of expected land value – sites are not currently at the £7000/m²level, more like 4-5000. Debate on land value and viability, importance of developing close to transport nodes where values will be higher. Enfield noted there was no principle of CPO for this policy, to resolve issues of multiple landownership. Islington stated that they took 50-60k per unit in affordable contributions on sites of 1-9 houses. Viability evidence could justify lower payment in exceptional cases. Would like discretion on when to accept payment (commencement or completion).

 

Availability of sites and feasibility of the step-change in delivery required. The GLA said they were going to monitor this very closely. A lot would be windfall not allocated sites. GLA felt that with clearer signalling they can incentivise the boroughs.

 

London First expressed support for the strategy, but were concerned about deliverability because the housing target relied overly on targets for small sites. They spoke on behalf of their members (being small and large developers, housing associations) and pointed out that small applications are time intensive, with many neighbourly issues, impact on neighbours, only 50% of land?home-owners want housing in their area – they saw the need to support London Boroughs to resist the social and cultural issues behind this opposition. Overall they felt that relying on small sites for this level of delivery was too risky and that a Plan B was needed. They later expressed support for contributions to affordable housing from sites less than ten units, but observed there was less opportunity to cross-subsidise at this scale for Housing associations and raised viability issues and the need for more grant.

 

Community Voices: London Forum expressed concern regarding whether boroughs had the necessary skills and resources to deliver; they felt this policy weakened the role of Neighbourhood Plans, and had an issue with the removal of constraints on what London Boroughs had to consider (presumption in favour of developing small sites?). Affordable housing delivery was supported but this was not (and should be) focussed on low cost rent which is at least 47% of housing need. The Further minor suggested changes have weakened the framework for this. London Tenants Federation made a strong statement regarding how community led developments on small sites have successfully brought forward social rented housing with genuine community benefits. They noted the generous green spaces of some social housing estates and that there were TMOs who were interested in bringing forward community led developments, as well as CLTs such as Peach, Russ, Phoenix? They proposed specific wording to increase policy support for community, social rent and self-build. LTF also stated that they support policy H2(h) requiring contributions from all developers to affordable housing – this could be off-site contributions. Not seeking affordable housing from these sites when they will make a large contribution to future housing supply would be to lose out on a lot of affordable. Pat argued that there was no direct correlation between viability and the size of the development. Michael Bach of London Forum suggested London was always ahead of the national policy on requiring affordable from smaller developments. Just Space wished to make a comment on the Interim Period, but the Inspector refused this. Striking out policy H2 (h) JS argued would lose 1000s of homes for social rent, and a number of boroughs already take contributions from developments less than 10 houses, inclding Islington LB who were there and testified. In the concluding discussion London Forum (Bach) made the point that the London Plan’s Good growth ambitions, and the need to create communities, means that what is needed is the right development in the right places – areas or locations. Social infrastructure provision needs to inform decisions about developments and a mapping of these facilities should be undertaken to guide where there is capacity for development.

 

London Assembly planning committee: felt the targets were more likely to be met if there was flexibility not to meet a certain proportion on small sites, which they acknowledged were difficult to bring forward.

 

The relationship between causing unacceptable harm and the benefit from building housing [what kind of housing constitutes such a public benefit?] was raised at length by LB Bromley, who had done a study on appeals against refusing planning approval – those they had successfully contested approved recognition of harms such as overbearing impact on gardens, reduced light, discordant features. The presumption being introduced would muddy the waters on making judgements about harm vs public benefit. The GLA argued that the design codes would assist with making this decision.

 

The Inspector raised at the end the possibility of adopting different ways of setting targets: SHLAA, trend based (as boroughs argued for more realistic setting of targets based on what had been achieved historically), policy-led approach based on identifying sites and local feasibility.

 

Inspector asked about concern that was expressed regarding issues of net loss of green cover, and need to reprovide – could inhibit delivery of housing? GLA stated that major developments had to conform to LP policy, for small sites no net loss could be accommodated through measures like trees and green roofs, or offset in area through greening in area eg tree planting. An SPG is planned on this.

 

It was noted that so many MSCs had now been made to the policy it had become opaque and hard to read!

 

Was the presumption of development on small sites necessary or justified? The GLA is seeking to make best use of land. The MSCs have adjusted the policy to mimic PD rights eg not develop on more than 50% of garden, design codes to ensure overlooking can be accommodated. Some boroughs have policies to protect gardens – these might be out of kilter with London Plan, and the presumption of development will prevail. The Inspector refused to hear any discussion of this as he had written comments from participants. He also suggested he did not want to hear any further discussion on affordable housing.

 

House Builders Federation: The Mayor’s approach to assessing capacity is novel – normally this needs to be based on identifying specific sites – unusual to adjust policy to expect a greater trend in windfall supply, which has not been identified. The NPPF expects boroughs to identify more small sites, but can you rely on the high level assessment in the London Plan to bring forward this increase? HBF support the policy but need specific sites to be identified for development.

Morning notes from Zoe Rasbash and Lily Downes. Afternoon session from Jenny Robinson.

Back to the EiP narrative page

Short overview of matters 19 and 20

On to the next blog post

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

Housing strategy M19 (policy H1)  The overall size of the “need”/requirement target had been debated on Tuesday (matter 17) including the adequacy of the needs assessment (SHMA – Strategic Housing Market Assessment). The compatibility of all that with the overall aims of the Plan (Good Growth policies) was debated yesterday Wednesday (matter 18).  Today was the first half of matter 19 Housing strategy: supply and targets which includes the capacity study SHLAA (Strategic Housing Land Availability Assessment). The panel had lots of sub-questions, a-f covered today; g onwards on Monday.

The Panel asked: Are the overall 10 year housing target for London and the targets for the individual Boroughs and Corporations set out in Policy H1 A and in Table 4.1 justified and deliverable? In particular:
a) Are the assumptions and analysis regarding site suitability, availability and 
achievability and development capacity for large sites in the Strategic Housing and Employment Land Availability Assessment (SHLAA) reasonable and realistic?
b) Have the environmental and social implications of the proposed increase in housing targets been fully and properly assessed?
c) Policy H1 B 2) a)-f) identifies various sources of capacity. Will these be sufficient to meet the ten years targets and what proportion of housing is expected to be delivered by means of the different types? How much is expected to be delivered on existing industrial land in the context of Policies E4-E7?
d) Will the focus on existing built up areas rather than urban extensions using GB/MOL provide sufficient variety of house types and tenure?
e) Is the emphasis on development in outer London consistent with the intention in Policy GG2 that seeks to proactively explore the potential to intensify the use of land on well-connected sites?
f) Does the Plan adequately consider the cumulative impacts of other policies on the deliverability and viability of housing?

[This blog mostly pieced together from tweets; if you have better notes please let us have them. It’s lop-sided because we include a full text of Mark Brearley’s intervention. The blog is not structured to follow the sequence of the panel’s questions above.]

There was a lot of general critique of the SHLAA process and criteria including Just Space explaining how they had, from the outset, challenged the continued attrition of industrial and employment land, the inclusion of council estate ‘regeneration’ not yet 
approved by ballots or proper planning processes and the application of much higher densities to all sites than normal. Strong statements from Highbury Group, especially on how the study had embedded the densities observed in (mainly) non-compliant schemes.

About 40,000 dwellings per year were expected from ’large’ and 25,000 from ‘small’ sites.  Some of the large sites (only 1% of dwellings) were regarded as ‘low probability’ of being developed for a variety of reasons.

Ian Gordon (LSE) points out that almost all the extra capacity compared with 2013 SHLAA is from increased density assumptions; otherwise only about 3k dw/year added.

London Tenants Federation LTF stress that the targets are (wrongly) just for TOTAL housing (mostly market) when we know that the need is massively for social housing.  Need a table broken down by affordability/tenure in place of Table 4.1.

GLA Jennifer Peters insists only a “tiny” proportion of identified sites involve demolition of occupied housing. Some numbers were read out and will be communicated to us by James (and we’ll insert here).

Christine Whitehead (LSE) reported LSE research for GLA which had examined new London housing purchased by foreign buyers, concluding that very few held the dwellings vacant; the vast majority rented them out or used them for family etc purposes.  Michael Bach (London Forum) responded that international buyers may not keep flats empty (cf LSE research findings) but they don’t house people off housing lists! Putting it another way, Peter Eversden insisted that meeting 137% of the requirement for market housing in London year after year while under-achieving low-rent housing can’t go on. It takes up land essential for meeting real needs.

On the continued attrition of industrial floorspace, yardspace and workspace, manufacturer Mark Brearley for Just Space said [his text]:On behalf of Just Space I am Mark Brearley, proprietor of Kaymet, tray and trolley manufacturer since 1947, whose factory in Peckham near the Old Kent Road is proposed for erasure by our local authority who did not ask us. Our Vital OKR business association, with over 300 members, speaks up for the threatened industrial and high street economy of our area.

Delivery of a significant quantity of housing on industrial land has been built into GLA figures. This is a threat to London’s substantial industrial economy, and how it serves London, and the approximately 450,000 people employed, in the context of escalating accommodation shortages.

Some housing delivery will, of course, come from industrial land release already in progress, with permissions, in adopted plans. But estimates going beyond that, assuming the exercise of Policies E4 – E7 as currently drafted, are incompatible with the intention to retain sufficient industrial accommodation capacity. The further loss of industrial capacity that Policies H1 B 2) d) and f) imply would run counter to the conclusions of the GLA’s own careful research evidencing a trajectory towards industrial land shortfall of some 585 ha.

I highlight that justification for Policies E4 – E7 points to the need to halt loss of industrial accommodation across London, and Policy E4 states that retention and provision of industrial capacity should be planned monitored and managed having regard to Table 6.2, a table showing 32 boroughs in either Retain or Provide Capacity categories.

Policy H1 B 2) d) and f), that assume redevelopment of anachronistically labeled ‘surplus’ industrial sites, with additional mention of utilities sites, in ways that would deliver housing, depend on Policies E4 – E7. [refers to Vital OKR submission.] Housing delivery assumptions should be revised accordingly, as should the wording of Policy H1 B 2). Much less delivery of housing on industrial sites should be assumed. This source should be tapering away. We already have an industrial accommodation crisis causing large scale loss of enterprise. We must now stop looking there for significant further housing capacity.

Policy H1 B 2) d) that refers to the redevelopment of surplus utilities and public sector owned sites should be deleted. Who owns land is not a relevant matter, and to additionally highlight utilities (and to extend this to transport functions also as later in the draft plan at 6.4.5) is not consistent with the studies that are the key evidence base, in which predicted changes to demand from a range of sectors (including utilities and transport) were considered, and nil net loss was the conclusion.

Policy H1 B 2)f), that refers to ongoing releases of industrial land, or shifting it into LSIS designation thus allowing co-location with housing, should be amended to make clear that such release should not be ongoing. In order to be consistent with the powerfully evidenced London-wide no net loss policy this source of housing capacity should be presented as finite, only relating to what has already been allowed through planning permissions and adopted development plans.

Finally to chime in with concerns about the targeting of big format retail, as well expressed by Halfords already yesterday. Policy H1 B 2) b) is also in need of amendment. The strip-out of bigger format retail capacity is a concern. An example: In my own Old Kent Road a major application just in for a site where a B&Q store now is. The developers claimed that B&Q do to not want to stay, but now B&Q say they do & have not had their needs considered.

Just two miles away from where we are now in City Hall, around the Old Kent Road, hundreds of businesses are being forced out, their premises listed as housing capacity based on scenarios that do not give us a future. We need a London Plan that helps the likes of us, across this city, and allows for the growth of appropriately located industrial activity. [end]

Caroline Shah (Just Space, Kingston) stressed the damage posed to biodiversity and environment by the densities being imposed on many parts of London, together with the damage to heritage, urban qualities and social infrastructure capacities. The use of Opportunity Area designations to enforce these measures —often by-passing any local democracy or even consultations— is especially alarming and the Kingston case represents a whole new scale of damage: using OA status as a surreptitious blanket coverage for an entire borough. She went on to insist that most of the plan policies designed to regulate development were worded in such soft, imprecise and purely qualitative terms that they would have little or no impact on the outturn: terms like “Emerging Skyline”, “Evolving Context”

Christine Whitehead LSE on deliverability of the housing targets said “We need to be very cautious.” London First has apparently done a rival ’viability assessment’ which casts doubt on the financial viability of some/many of the proposals. John Wacher of the GLA viability unit said that they had tested 35 housing development typologies. Found development should be viable everywhere but different forms likely in diff places. Difference with London First was that GLA had taken care to use baseline land values which had been through scrutiny and were thought to reflect full impact of planning policies, whereas LF had used market transactions, often higher. (John previously at LB Islington and had led on the famous Parkhurst Road territorial army hall case.)

Foreshadowing the session on “small sites” Andrew Barrie Purcell (head of London Plan in the Johnson period), acting for West London Alliance of boroughs, mounted a critique and called for a much more nuanced approach to suburban densification. Echoed by Just Space which called for a rescue of the “lifetime neighbourhood” concept as embodying a bottom-up approach with reduction of the need to travel by getting people closer to services. 800m from town centre boundary or from ‘a station’ not an adequate basis for defining densification zones. GLA must do something better or ensure that boroughs do.

Note edited by Michael Edwards from own notes and various people’s tweets. Please suggest corrections and additions in box below.

End of Friday.  Session resumed on Monday 11th. No notes here (yet) on Monday morning.

Afternoon:

Just Space: Thank you for letting us have a few minutes for final reflections on the Housing Strategy and capacity debates of the last few days.

Many of us have been saying in the café that the emperor has no clothes, or words to that effect. So much of the evidence has been to the effect that this draft plan cannot succeed in meeting its own estimation of London’s housing needs, let alone catching up with the unmet backlog fof need for social rented/ low rent housing (which makes up 78% of total need estimated in the SHMA).

We have been here before.  The risk is that you (the panel) recommend the adoption of a deficient plan, subject to an early review of the market demand, social need, capacity and policy situations a few years down the line.

Thus London staggers from Plan to Plan, each of which sees the aggravation of the housing crisis affecting low- and medium-income Londoners (and almost everyone else in various ways). This serial process is simply not acceptable and Just Space urges you to recommend some completely fresh thinking.

That thinking will differ from the past, particularly by including analysis, understanding (and even modelling) of the land market. The land market has never had adequate attention from City Hall but is one of the main roots of our problems and the Mayor will have to consider how to avoid policies which contribute to land price escalation, link this with his lobbying on property taxation and local government finance, and take seriously the role of non-market housing sectors and of the stock of homes. The appointment of Mr Wacher and his viability unit give us hope but they have a lot to do besides ‘viability’.

The UK economy is now generally understood to be dangerously a ‘rentier’ economy and there are national as well as regional moves to re-think the dominance of the property sector over our lives.

Another key feature of the next plan must be a closer and more frequent collaboration between the Mayor, his professionals, London’s communities, communty organisations and universities as well as local governments. We have seen how fruitful this can be in the last weeks. Imagine if it were a continuous process of co-production of the plan.

Finally we should say that we have some sympathy for the GLA teams, despite our criticisms. They are a new and young team, as they say, and have been asked to innovate in squaring the circle (which they do not quite say). They have this big new idea of the small sites policy which in many ways we support as a progressive move.  But they are being heavily criticised because it is a departure from trend which they can’t demonstrate will come true.  Our view is that the future MUST be different from the past, for reasons of equality and dealing with the climate emergency. We must invent the future between us.

[Final comments were also made by Christine Whitehead (LSE), Sharon Hayward [LTF] and Michael Bach (London Forum). To follow, we hope.

Back to the EiP narrative page

On to the next day: Small Sites

Overview of these 2 matters

 

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk
For this day we had no note-taker so would especially value corrections and comments from those who were present.

These were the panel’s questions:  M18  Will the housing policies achieve the good growth objectives in Policies GG1, GG2, GG3 and GG4 relating to building strong and healthy communities, making the best use of land, creating a healthy city and delivering the homes Londoners need? In particular how will the provisions of GG4E regarding ambitious and achievable build-out rates be put into effect? Will the provisions of Policy H1 B-F provide an effective strategic context for the preparation of local plans and neighbourhood plans?

(pieced together from tweets and emails)

London Tenants Federation LTF: seven things the London Mayor should do about the need for social rented homes The Mayor’s office said at the #LondonPlan  examination 06.02.19 that lack of funding prevents delivery of the SR homes needed in London. Of course, we encourage him to lobby Government on this, but …..

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by postgraduate students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk
For this day we had no note-taker so would especially value corrections and comments from those who were present.

Housing need & overall target

The Panel asked: M17. Is the need for 66,000 additional homes per year identified by the Strategic Housing Market Assessment (SHMA) justified and has it been properly calculated for market and affordable housing having regard to national policy and guidance? In particular:
a) What weight, if any, should be given to the revised household projections published in September 2018?
b) What weight, if any, should be given to the potential impact of Brexit?
c) Has the Mayor adequately considered increasing the total housing figures in order to help deliver the required number of affordable homes in accordance with the PPG (ID 2a-029-20140306)?

James Gleeson (@geographyJim) is defending the Strategic Housing Market Assessment (SHMA)

Why is London method different from national model?  GLA defends backlog approach in which the demographic growth forecast then has extra ‘need’ added to represent catching up the accumulated backlog of under-provision (within which 78% is need for social rent). This differs from the NPPF which instead makes an arbitrary uplift for “market signals”. Various views expressed. Just Space supports the London backlog approach but notes that the phasing over 25 years is outrageous (and probably means the backlog would grow). More important still the social housing numbers & percent in the targets disregard the findings of the SHMA. 

Highbury expert group (Duncan Bowie) eloquent in support of this position, as is LTF.

Christine Whitehead LSE: the London approach better than national.  suppressed demand should be met.

James Stephens (HBF) strongly supports use of a standard national method of estimation. Consistency most important. GLA method is rather a black box.  Stephens:  “market signals” approach more focused on exclusion from owner-occupation, a key concern of government. Bowie: yes and that’s irrelevant for Londoners in housing need for whom owner-occupation is out of sight.

Some discussion of household formation rates and migration.

LTF argues migration misleading because so much of London’s need is exported through forced moves of hh displaced by LAs. Some discussion on this. GLA says that hh accepted by LAs as statutory homeless are included in the “backlog” whether they are housed in London or elsewhere.

CW/LSE  Stresses that hh formation needs to be approached carefully, taking account of turnover. Rapid churn has fewer households; new migrants take 10 years to adopt settled habits and form smaller households..

Bowie. We need more knowledge of migrations…  constrained choice, choice, compulsion.  Contradiction that compact city is supposed to meet London needs, but actually exporting so many people, with environmental and cost problems for people having to travel back to work. Understanding of migration motives etc has implications for bedroom size mix. If we assume that people who can afford it will all move out of London for adequate rooms. .  It’s a policy issue embedded in a technical process.

James Stephens:  latest projections of population/hh so much a reflection of policy failure, so would be a dereliction of duty to base the Plan on a projection of those trends.

Main outcome of the discussion on migration, brexit and household sizes is that the uncertainties are huge, alternatives should be explored, and the situation closely watched. Next SHMA envisaged by GLA to start in a couple of years. Govt submission today seeks a review of the #LondonPlan right away !! https://www.london.gov.uk/sites/default/files/m17_mhclg_2631.pdf … {note that they write this and then fail to show up and use their seat.)å

Inspector Smith asks why such a shift up in need for 1 and 2 bedroom flats since the previous SHMA and plan? Doesn’t get a good answer. 

New option now presented in GLA submission for table 13/5,  with different assumptions about under-occupation. Gleeson unwilling to choose, though original table 13  probably most likely. Strong support for the new alternative table to be the basis for the plan – expressed by Assembly Planning Committee (Nicky Gavron), JS, LTF, Highbury…

Paul Burnham (Just Space) urges need for housing need surveys- to establish income, savings, debt, ethnicity etc of those in housing need.Very evident in Tottenham, for example, that many (including  disproportionate BME, disabled, women-only hh) can’t possibly access the kinds of ‘affordable” housing requiring advance deposits or part-buy.

GLA responds that they have used data from English Housing Survey: 7-8000 London hh over the 3 years they have used.

Backlog:  Inspector says representations have stressed 25 years far too long.  Duncan Bowie (Highbury Group) stresses former MHLG guidance was to catch up in 5 years; first London Plan 2004 spread it over 10 years (the range of the housing targets) and then the Boris Johnson Plan spread it to 20 years. JS and LTF in strong support.

CW/LSE: we would all agree that 100% of the output should be “affordable” (what does this mean?  Out of context)

CPRE stresses political character of the backlog issue.

Should the #LondonPlan target be increased to get more “affordable” housing? Just Space and LTF arguing quite the reverse: the super-high housing targets drive all the damaging aspects of the whole Plan including estate demolitions which reduce social housing. Widespread agreement that building more housing in total does not produce more affordable housing. LTF has charts in their submission.  CW/LSE however argues that the two statistics move broadly up and down together.

This note pieced together afterwards by M Edwards. Corrections & amplifications specially welcome, either below or by email.

Back to main EiP narrative page

On to next day’s blog post M18 Housing strategy