Category: Housing

  • Housing

    Housing

    INTRODUCTION

    Most Londoners can’t afford to live here. Market rents are far too high. “Affordable rents” are not affordable. The supply of council housing has been deliberately run down for forty years. The price of buying a home is prohibitive. The financialisation of the housing market means that London properties are worth more as financial assets than they are as homes. Some investment properties are kept empty. Social housing is not being built. Reductions in temporary accommodation fail to meet ever-increasing homelessness, including 74,000 children. People who need a council home are forced into expensive, insecure, and poorly-regulated private rented housing. Far more is spent subsidising overpriced rents than on building social housing.

    The housebuilding model is predicated on property values forever rising, plus an imperfect market and a cartel of housebuilders who control the supply. Developers over-pay for land and then, due to the ‘flexible’ planning system, claim they cannot afford to provide social housing. 300,000 council homes have been lost to Right To Buy across London. Estate regeneration has proved a painful delusion, resulting in the needless demolition of council homes and the destruction of communities. Shared ownership homes are a dreadful trap. London’s development is distorted, as housing has been built on a quarter of our industrial land rather than being integrated into coherent communities, harming economic activity. Huge amounts of public land have been lost.

    Local government is not fit for purpose (accountability, transparency and finance) and starved of funds. The relationship and priorities between government departments, the Mayor and local authorities is muddled.

    Solutions in our MANIFESTO

    • A major programme of public investment in public housebuilding in co-production with communities who will be living in them, prioritising family-sized housing
    • Public land should be used for not-for-profit rented homes (including community forms of housing), provided for free as a community asset transfer or long lease. This means land owned by public bodies including Local Authorities, government departments, NHS, Transport for London and Network Rail
    • Abolition of Right to Buy. Support the buy-back of ex-council stock
    • Tenancy reform: the Mayor of London must be granted the necessary powers to effect the Blueprint for Reforming Private Renting including the control/regulation of rents; the basic standards should apply equally to temporary accommodation; and the rights of council tenants should apply to housing association tenants
    • A presumption against estate redevelopment schemes unless they significantly benefit the health and well-being of existing residents, and communities are kept together throughout; and where refurbishment – the circular economy – takes priority
    • A presumption in favour of retrofitting and upgrading all rented housing and the training of architects, engineers, developers; a dedicated core of trained construction specialists in local authorities working with residents in situ, and planners in low-carbon technology and materials
    • Abolish viability testing and the flexibile approach, which encourage hope value and land value inflation. Viability mustn’t trump planning policy: land value must reflect planning policy
    • Establish a transparent register of residential property ownership and usage, eg identification of second homes, to help ensure that property is used and taxed appropriately, including the introduction of a Vacancy Tax
    • Councils and the Mayor must take effective, timely action on London’s empty homes, with new powers to requisition homes and commercial properties that are empty for more than six months, making use of Empty Dwellings Management Orders, CPOs, tighter regulation of Airbnb
    • Reinstate community participation in the identification of housing need and available sites, for the Strategic Housing Land Availability Assessment (SHLAA) and Strategic Housing Market Assessment (SHMA)

    LINKS, GROUPS CAMPAIGNING ON THIS ISSUE

    Action Plan for the Housing Crisis

    Homes 4 All

    Refurbish don’t demolish

    London Tenants Federation (web site under repair)

    ACORN

    HACKNEY RENTERS – DIGS

    Islington Private Tenants  @IslingtonPRS

    Radical Housing Network

    Architects for Social Housing @ASH_housing

    London Federation of Housing Co-ops

    London Tenants Federation – mainly council tenants, though includes some Housing Association tenants and some leaseholders on Council estates

    Generation Rent – see their Renters manifesto

    Advice4renters

    ARCHIVE POSTS 

  • 3 key demands on housing

    3 key demands on housing

    JustSpace and CPRE_London have today written to the Secretary of State, Angela Rayner and the Mayor of London, Sadiq Khan, pressing for urgent action on 3 fronts as the new government’s housing policies are shaped:

    1. The Mayor of London has fewer powers than any other leader of a major city in the Western world. There is a range of devolved powers which the strategic authority needs to address its unique problems, including the regulation of the rapidly growing private rented sector in terms of rents, conditions and evictions. The Mayor also needs the flexibility to direct government housing grant towards the highest need, which is for genuinely affordable housing in the form of social rented homes. The particular conditions specific to London also need the Mayor to have power to suspend or end the Right to Buy, which continues to erode the social stock and discourage councils from adding new council homes. The necessary devolution of powers could be enacted relatively speedily, while we await provisions in the proposed Housing Bill coming into force.

    2. The proposed Housing and Infrastructure Bill needs to address urgently the ongoing scandal of s21 ‘no fault’ evictions as well as provide other basic renters’ rights, standards and controls. It also needs provisions to address the growing abuse of homes being kept deliberately vacant, which currently stands at over one million across the UK . It needs powers to address over one million housing permissions which have not been built out (particularly those where implementation has been technically triggered through the expedient of digging a trench): a so-called ‘Use it or Lose it’ approach to planning permissions. And, as part of resolving the crisis in local government finance, the Bill needs to address the absurdity of the average householder in Oldham paying more in council tax than the residents of Buckingham Palace.

    3. We understand that the Mayor is likely to instigate a full review of the London Plan later this year, and would strongly urge that communities traditionally excluded from the process of developing the strategic housing needs assessment and strategic housing land assessment are fully engaged from the outset.

    We look forward to working together to resolve the housing crisis

    Download the full letter (PDF)

    checked M E July 2025

  • Housing is the central election issue

    Housing is the central election issue

    Just Space takes the lead in building support for this Housing Charter with CPRE London and further support from Renters’ Rights London, Action on Empty Homes…. More organisations have been invited to sign up and if your organisation would like to join in, please make contact

    Our online session with speakers Sem Moema AM and Josh Ryan-Collins was a great success and the video is now online at https://www.youtube.com/watch?v=ukwrGXSPJ28

    Download a PDF version – best for printing

    The Centre for London held a housing conference (“summit”) which we attended. It was almost entirely dominated by speakers for the status quo. A report by our coordinator is here.

    checked M E 26 July 2025

  • Woodberry Down: we can help rescue the later phases

    Woodberry Down: we can help rescue the later phases

    Submission by Pat Turnbull to Hackney Council consultation – urgent

    The Consultation Masterplan from Berkeley Homes for Woodberry Down Phases 5 to 8 is under consultation till 5 December 2023 with a view to an ‘outline planning application’ being submitted in Spring 2024.  [Editor: there are various dates mentioned as closing dates and it is always worth sending comments even after the formal close. Go to https://hackney.gov.uk/woodberry-down/  Email planning@hackney.gov.uk ]

    The document is drawn up in a misleading way.  Many pages are devoted to landscaping, infrastructure etc and only right at the end do we come to the crux of the matter – the housing.  In consultations people quoted in the document have asked for more desperately needed affordable housing – I’m sure what they really meant was social rented housing, the only kind that is actually affordable to most Londoners, especially those in greatest need.  But that’s not what we are getting.

    Several times the regeneration is referred to as lasting twenty years.  Nevertheless as the document says itself ‘The regeneration of Woodberry Down was first planned in the 1990s’.  That means it has been going on in one form or another for over twenty years already and we are only on Phase 3 of 8.  This has built a terrible uncertainty into the lives of everyone living on Woodberry Down.  It is already 18 years since plans were approved in 2005, to then be altered in 2014.  Building work began in 2009.  So for much of this time residents have been living on a building site, with all the noise, vibrations, dust and mess connected with it.

    The regeneration has had other effects.  A Freedom of Information request submitted by Vice News revealed that in 2002, there were 1,722 homes occupied at social rent on the Woodberry Down estate.  In 2020 when the FoI request was submitted, there were 1,269, a 26 per cent fall.  (‘It’s an exercise in profit – the 20-year “regeneration” plan forcing people from their homes’, Vice News, 15.9.20).   More recently, Geoff Bell, longstanding Woodberry Down resident, said this: ‘During Phase 3, more social homes were demolished than built.  There is no indication this will change in phases 5 to 8.’ (‘Campaigners speak out over loss of council homes in major rebuild of Woodberry Down estate’, Hackney Citizen, 17.11.23)

    The Consultation Masterplan says: ‘Every permanent council tenant on the estate can move into a brand new social rent home on the estate that meets their household needs.’  There are however many people on Woodberry Down with temporary tenancies because of the protracted nature of the regeneration.  What happens to them?  Even for the permanent tenants this can mean losing a family home which they would expect to stay in for life and getting a one-bedroom flat in exchange.  That’s apart from the fact that a lot of the social rented housing is on the less pleasant parts of the estate, overlooking Seven Sisters Road, leaving the Woodberry Wetlands and other views as selling points for Berkeley’s market housing. 

    What compensation have Woodberry Down residents and other Hackney people in desperate need of a permanent home, had for this tension and upheaval?  The estate originally had nearly 2000 council social rented homes. The 2014 revision projected 5,557 homes in all with only 1200 of them social rented.  Not one of these will be a council home.  Such social rented homes as are provided will be Notting Hill Genesis housing association;  housing associations are private bodies, so there will no longer be any public housing on this 64-acre site.

    The ’benefits to date’ consist of 2,901 homes of which only 654 are social rented.  In phases 5 to 8 Berkeley Homes is proposing to provide only 41.7 per cent ‘affordable’ housing, of which only 43 per cent will be social rent, the remainder being unaffordable shared ownership, aimed at households earning up to £90,000 a year.

    We are told that in the 1990s ‘structural surveys showed the estate with 2000 homes was too costly and complex to refurbish.’  Much of this housing is still standing in 2023.  So how accurate was this assessment and how much of the decision was instead driven by the desire prevalent at the time to get rid of council estates and replace them with what was described as ‘mixed and balanced’ developments?  How ‘mixed and balanced’ is Woodberry Down today?

    According to an article in the Hackney Citizen of 20.8.19 (‘Handful of leaseholders resist council plans for Woodberry Down development’), Hackney Council agreed to give Berkeley the Woodberry Down land on a 999-year lease.  In the context of the housing crisis today, this seems an unforgivable decision.   In 2021 there were 13,400 on the Hackney Council waiting list, which had already been arbitrarily slashed some seven years previously, and was now again slashed to around 8,500.  This was no indication of the need for council housing but simply an expedient decision because there was no council housing to give them.  Apparently people were to be offered ‘personalised support to explore other options to find a home’ a process which actually redirected households into insecure, expensive, poorly regulated private rented housing.  In October 2019 the median market asking rent as a proportion of median income for two people in Hackney was 38 per cent; in October 2023 it had gone up to 44 per cent. (Guardian from TwentiCi, annual survey of hours and earnings.)  There are 3,000 Hackney residents in temporary accommodation.

    Berkeley has had this gift from the council and it has certainly made the most of it. Nobody will ever be able to find how much profit Berkeley has already made out of what was once a council estate.  Woodberry Down was one of the bases on which Berkeley has expanded into a widespread developer.  Isn’t it time the council demanded something back from Berkeley – not Woodberry Wetlands but social rented housing?    

    Since the 1990s there has also been increasing consciousness of the environmental impact of unnecessary demolition and construction.  Ought we not also therefore to re-examine the 1990s decision to demolish the whole estate?  At different times residents have called for refurbishment rather than demolition, for example resident Klaus Graichen who in 2011 had lived on the estate for 15 years (‘Hackney Council scrambles to plug £60 million hole in Woodberry Down scheme’, Hackney Citizen, 11.1.11).  Ought the council not to take another look at the possibility of refurbishing parts of the estate, particularly the more recently built parts on Green Lanes north of Manor House (Rowley Gardens)?

    It should never be too late to reconsider ill thought out decisions that have had such severe effects on Hackney citizens in desperate need of social rented homes.   

    Tom Cordell kindly lets us link to a clip he filmed of (the late) Tony Pidgley, head of Berkeley Homes, in exchanges with Sadiq Khan in Croydon

  • GLA, planning and housing update

    GLA, planning and housing update

    14 July 2023: there is news from City Hall which is important for Just Space members.

    Draft guidance on ‘Affordable’ housing and on Viability Assessment: consultations close on 24th July.

    The Mayor produced two new London Plan Guidance (LPG) documents in draft and seeks comments before they are finalised. These documents cannot, by law, change the policies which are embedded in the London Plan but they can and do elaborate them and toughen them up through the details of implementation.

    The London Tenants Federation (LTF) has submitted their very careful and detailed commentary on both LPGs and has kindly agreed that we can share it with other members of Just Space who may be preparing their own submissions, or who may want to write to the GLA supporting the LTF.

    The LTF makes a refreshed and powerful case for focusing planning policy as much as possible on maximising the production of social housing at council rents and not the other, more expensive, forms of so-called “affordable” housing. It refers back to the latest GLA study of London’s housing needs in 2017 which showed how overwhelming was the need even then for secure, low rent, housing which only social/council housing can provide and it points to the extremely low levels of actual production which have been achieved since then, suggesting many ways in which more could be done.

    The response welcomes some of the GLA proposals to tighten up loopholes which enable developers to avoid or minimise their obligations and pushes for a bolder insistence on delivery of at least 50% ‘affordable’ housing on land previously in public ownership.

    The Viability analysis LPG is all about the details of a rotten system which the LTF and Just Space have always criticised – establishing developer profitability as the dominant criterion governing what gets built and for whom. But for the moment the provision of most social housing depends on private developers and housing associations being forced to provide it as a condition for getting planning permission. The rules and procedures for testing what developers can afford are the subject of this LPG and the Tenants Federation is very shrewdly pointing out further ways in which developers’ manipulation of the figures could be limited and the whole process be made more transparent.

    The LTF response to the two LPGs is here and will also be on their own site LondonTenants.org (now under repair)

    The GLA’s draft LPGs are at Affordable Housing and at Viability along with means to comment.

    Remember: 24 July 2023 is the closing date for comments.

    Planning For London programme

    Just Space and many community groups consider that the last London Plan was a bad plan and it’s is now very old. Drafted in 2016, it would have been adopted in 2020 (though it was pushed into 2021 by the Secretary of State) and has in many ways become even more irrelevant to London’s real needs as a result of the pandemic, the fresh round of austerity, now a recession and the accelerating reality of climate and biological breakdown.

    We argued that the City Hall planners could and should have got down to some urgent work to get a new plan under way but the Mayor apparently decided that no start should be made until after the next mayoral election in May 2024. So instead City Hall has devised this Planning for London programme in which they are gathering the views of citizens and organisations while declaring that this is not part of making the next plan.

    They have just held the first two events at which they met with citizens and organisations (we are called “stakeholders’) and they promise to publish what that have gleaned from listening to the many round-table discussions they orchestrated. They are also going to publish their learnings from an earlier series of focus-group-type (‘deliberative’) events to which they invited a statistically representative selection of Londoners. The whole programme is set out on the City Hall web site here. There will be a stage where they invite our inputs on how they should do impact analysis. That’s a process which they made a serious mess of last time and had to try to make good in the middle of the public Examination so it is very important that we all help.

    Just Space told its member organisations about these two recent public events so quite a few of us took part and we are gradually comparing notes about what happened. We’ll post our summary here. Meanwhile one of our members wrote a personal blog post here which you might want to look at.

    If you have comments or observations or took part in these events and want to offer your reactions, please get in touch or use the comments below.

    checked by M E. July27 2025

  • ESTATE Watch

    ESTATE Watch

    Demolition or neglect: Are the Mayor of London’s ballots offering tenants a fair choice?

    WEDNESDAY 17th JUNE 2020

    Over 35,000 homes across more than 100 London estates are earmarked for or undergoing demolition according to Estate Watch, a new resource for affected communities.

    This despite the Mayor of London’s Estate Regeneration Guidance (2018), which was supposed to give council tenants and leaseholders a better deal.

    Launching today, the Estate Watch website has been produced by community organisations Just Space and London Tenants Federation (LTF) to provide tenants and residents with independent facts and resources about the realities of demolition and possible alternatives. Our Alternative Guide to Estate Regeneration is available here.

    Since 2018, councils and housing associations seeking Mayoral funding for large housing schemes involving demolition of existing homes must obtain majority resident support through a ballot. 

    “We’re hearing worrying reports that balloted communities are being offered a false choice: demolition or neglect,” said LTF and Just Space in a joint statement.

    “Tenants must be fully informed and have meaningful choices before we get to a ballot. We’ve established Estate Watch in part because of concerns that that is not happening.”

    Luise, a leaseholder on Camden’s West Kentish Town estate, which voted in favour of demolition earlier this year, described seeing council officers visiting residents in their homes while the ballot was taking place to ‘help’ them fill in the form. 

    “They were upfront that they were pushing for it to be knocked down,” said Luise. “There was nothing impartial about the consultation. They’ve been deliberately and continuously neglecting the estate. We were basically told that if we voted against demolition the estate would be run down even further.” 

    According to the Mayor’s Guidance, “when considering the option of demolishing and rebuilding homes, councils, housing associations and their partners should always consider alternative options to demolition first”.

    “In our case we had to work really hard over a very long period of time to get the best that we could out of a demolition and rebuild scheme, but there was only ever one option on the table. Refurbishment was simply dismissed.” said Harry, an LTF rep from a Kingston estate, where residents have recently voted for demolition.

    The new website provides tenants with key facts, tools and case studies to fight their corner and to try to engage on more equal terms in discussion about the future of their homes and communities. 

    This includes research by academics at University of Leicester (UOL) and Kings College London (KCL) showing that long term uncertainty, depression and displacement were common experiences among both tenants and leaseholders undergoing demolition.

    “Just Space and LTF have set up Estate Watch because the realities of ‘regeneration’ for resident communities are very different to what’s depicted on council websites and brochures,” said Loretta Lees, Professor of Human Geography at the University of Leicester. 

    “It comes on the back of my 3-year ESRC research project into gentrification and displacement of council estate tenants and residents. 

    “My research identified that 55,000 council homes had been demolished in estate renewal schemes since 1997 and as a rough estimate, about 131,000 tenants and leaseholders were displaced.”

    Over the last 3 years, Just Space and The London Tenants Federation have worked with the University of Leicester and King’s College London on a research project that has provided detailed evidence since 1997 of the displacement of London council tenants and leaseholders through regeneration schemes.

    As part of this research, 120 in-depth interviews were carried out with tenants and residents on 6 different council estates undergoing regeneration: Aylesbury (Southwark), Gascoigne (Barking and Dagenham), Ocean (Tower Hamlets), Love Lane (Haringey), Pepys (Lewisham) and Carpenters estate (Newham). The interviews showed that many residents were forced out of their neighbourhoods leaving behind that precious network of friends, relatives and neighbours. The research has also shed light on the conditions many residents have been forced to live in – with essential repairs often neglected by the Council for years – and the uncertainty about the future, which created high level of anxiety and stress.

    As the research project draws to a close, the EstateWatch website has been developed as a resource for communities on estates facing regeneration, to know their rights and to ensure that tenants’ and residents’ choices will be respected. We want to monitor each scheme as it progresses and make space for residents to add updated information about their estate in real time. This can be a precious tool to hold Councils across London and the Mayor to account and make sure that future regeneration schemes benefit existing local communities.

    Find out more

    We have more info at estatewatch.London

  • M29, 30, 33 Build-to-Rent… 12 March

    M29, 30, 33 Build-to-Rent… 12 March

    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.

    The appeal of this form to developers is reflected in a growing pipeline.  43,000 units recorded by Molior (and more data in the Mayor’s submission for today). The gap between BtR and BtS has been narrowing since the SPG appeared.
    Low cost rent could be justified by LAs where evidence supports it and this is reflected in a proposed further alteration.
    James Clark; The mix of tenures within BtR reflect partly our view that it’s good to have unified management, which wouldn’t happen with normal mix, where management of affordable part of a scheme is normally done by an RSL.
    Viability testing was done assuming LLR levels and 50% of market level
    Fast track added along with the threshold.
    (“NPPF has a 20 20 provision”: what does this mean?)
    BPF are  very discontented with the change now proposed by GLA – to enable some social rent…  This is what the GLA has proposed in its submission of 12 February: add as 4.13.9A

    Where justified in a Development Plan, boroughs can require a proportion of affordable housing as low cost rent (social rent or London Affordable Rent see 4.7.4) on Build to Rent schemes in accordance with Policy H7 A. Low cost rent homes must be managed by a registered provider. The low cost rent affordable housing would contribute towards the relevant threshold required to meet the fast track route, as set out in paragraph 4.13.6. DMR is an intermediate product and is managed and allocated as such, therefore it is not appropriate to seek DMR at or close to social rent levels.

    Get Living London (owners/operators of the Olympic Village). capitalised rental value of BtR is always less than market sale. We spend more on building cost: shared space, better public realm, spec of homes normally higher because we repair it!  So we build on bigger sites, and thus get special problems,  3.15-4.25 % yield on costs.  Operational efficiency. IRR is about half what the BfS model gives. Doesn’t like having to build separate passages, entrances etc for social tenants. Better to have a tenure-blind approach.
    Greystar: unified management is crucial.  Resisting the social housing dimension. Social housing would normally mean putting it in a separate building, mainly for management reasons. Another problem: at what stage would the social housing requirement be imposed? Only in  S106 stage?
    London First is very supportive of the new sector. Disappointed that social rent amendment was not part of the fine consultations we had in the period leading up to the consultation draft.
    Fast Track is OK but the 35% figure is premature. Not enough evidence yet. Would create expectations among councils in cases where 35% can’t be viable (yet).
    Opposes double management regime. Scrap the social housing option, or as a compromise limit it to large multi-block schemes.
    Michael Ball (Southwark CDG) for Just Space supports main thrust.  But why is the covenant only for 15 years? 30 years covenant has been agreed agreed at Elephant & Castle. We don’t understand why the split is different from policy H7. Elephant scheme was agreed on a basis much closer to Policy H7.
    This 35% setting will have a deeply undermining effect on the mayor’s 50% target.
    London Tenants Federation. We see no reason why resources should be diverted to this sort of housing.  The more of this you do, the less we have of social rent which is what London needs.  Median equivalised incomes in London make LLR unaffordable in almost every ward in London.
    GLA James Clark: on the social rent suggested change: Given the needs shown by SHMA and needs in boroughs.
    No need for separate management. some private developers have become registered providers; some RPs do BtR; Where there are really no options there’s always cash in lieu.
    M33.  On the separate matter of Large scale shared living development – a tiny but potentially growing kind of housing.  [comment by note-taker Main interest is that GLA proposes that contribution for affordable housing should be  split 50:50 between a lump sum and a perpectual payment related to the rents.  A kind of equity sharing.]
    M30. On separate “supported housing” policy. Richard Lee says where is the evidence? JS asked a question at the technical seminar on why no evidence was being collected on the specific housing needs of minority groups. We were told the work had been done in various parts of GLA…and we expected now to see it collected from other parts of the GLA.  But the mayor’s statement now has NO reference to the needs of any specific group. No footnotes. No studies or documents cited.  Delivery:  how could it be delivered? Totally missing. A policy without a policy. The list in the draft Plan is simply a descriptive list of things boroughs might want to do. The reference to needs assessments is the nearest we get to a proper policy. The audit of existing provisions (incl refurbishment needs).  The policy should have included health and care services + the smaller specialised housing associations in partnerships.
    No reference either to user groups, most of whom are vulnerable groups: users need to be fully involved. Some needs are so small that unlikely to be met on a borough level and may need multi-borough or pan-London level.  LGBT for example very keen to be active on a pan-london basis.   Inadequate guidance to boroughs on how to engage with the various groups.  Who is missing?  completely missing BAME and LGBT+
    Hostels and temp accom: some discussion of where people can go AFTER hostels, but nothing on temp acomm and hostels for homeless, esp rough sleepers. HLG stats emphasise the particular vulnerability of LGBT BAME and young people to homelessness.
    Specialist accom which includes service provision – advice and service as part of housing service very important indeed and that’s another omission.
    We want the policy to be fit for purpose and would like to help the mayor achieve what he aims to do.
    GLA response: essentially saying this policy is not on the needs of particular groups but more a reminder to boroughs of what they should consider doing…

    Notes by Michael Edwards

  • M24 affordable housing 26 Feb

    M24 affordable housing 26 Feb

    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

    M24. Would policies H5 to H8 provide a justified and effective approach to delivering affordable housing to meet the good growth objectives set out in Policy GG4?

    Policy H5 Delivering Affordable Housing

    Panel (P):

    • There will be another session on viability at another point [Matters 92/3 on 17 May]. The basis of the discussion today is affordable housing.

    Highbury Group (HG):

    • Odd to defer viability conversation considering that the viability head of the GLA is present. Will be hard to talk about Policy H6 without talking about viability

    P:

    • H5 sets out strategic target of 50% affordable housing.
    • Threshold approach allows schemes to go through a fast track if development has over 35% affordable housing.
    • All of that is in the SPG.
    • Within the fast track route there is a provision for minor developments
    • Viability tested route is only required if threshold is not met
    • Threshold approach needs to be measured in habitable rooms with existing value +
    • Need to link all the policies (H5-H8). Take policies as a whole.
    • H7 is about tenure
    • In relation to H5 there’s the new target of 50% delivery of affordable housing – surely it will fall short of that
    • The delivery of [market?] housing would be higher than needed

    Greater London Authority (GLA):

    • Need to consider aspirations and be realistic; evidence tempered by realism
    • Try to strive for a number that is deliverable and constantly changing

    P:

    • Assumption of 50% is without grant. Then there’s an investment programme which could boost %.
    • Opportunity to marry planning system with Mayor’s approach?

    GLA:

    • Several examples in Plan where this marriage is happening
    • Whereas before the tradition was to keep these things separate

    P:

    • Will the shortfall be made up? What are the strategies to make up 50%

    GLA:

    • On balance, if 35% of the Plan is secured, along with investment programmes, the 50% will be challenging but achievable.

    P:

    • Overall need is 65%, need for low-cost rent is 45%.

    GLA:

    • Pushing it as much with tenure need but not enough funding.
    • Have tenure targets

    P:

    • Industrial Land and Public Land is 50% threshold because it should provide more community benefits.
    • This higher requirement needs justification

    GLA:

    • Danger of industrial land becoming scarce; London needs more of it. That’s why we’ve done this approach – to avoid net loss.
    • Necessary and possible to deliver housing on public land as it is a finite resource – opportunity to raise value for public land.
    • Not a blanket approach – these schemes can go down through viability route

    P:

    • Will this incentivise developments on these lands?

    GLA:

    • Accept that tension – but seeking to balance conflicting priorities.
    • Expectation for public land should be higher
    • Not all public land is owned by GLA but have work with land owned by NHS (I.e. St. Ann’s development in Haringey (StART) to achieve affordable housing)

    H:

    • Any questions of questions a-c?

    Elephant Amenity Network (EAN):

    • Why not 35% on low cost housing rather than 30%?

    Just Space (JS):

    • What the GLA has not talked about is the need for social rental housing
    • Does not comply with the Equality Act 2010
    • The housing policy disproportionately affects the most vulnerable communities
    • Social rent housing needs to go back in if GLA is to comply with legal duties
    • These policies clearly do not deal with public equality duty – in fact, they discriminate against these communities further but actually paint it as progressive
    • These policies do not deliver the homes Londoners needs
    • Decimating the most marginalised
    • This plan creates a city for the rich and a city for the poor

    London Forum (LFo):

    • The 35% is too low – Mayor needs to increase it
    • Affordable housing is spoken of in too much general terms – need to speak about each type
    • How can the plan allocate housing without deciding which types are needed?
    • Grants given by the GLA are too ring-fenced (not sure about this note)
    • Failure of providing affordable homes for London’s real needs
    • Over-delivering market homes continuously but not delivering affordable housing
    • If the situation continues we will fail completely to meet need
    • Need to make definition absolutely clear for each type of home
    • Evidence from last year that targets were not met

    London Tenants Federation (LTF):

    • There should be 60% social housing target
    • All affordable housing grants should go to social rented housing, none to higher-rent / intermediate categories
    • Disagree with term affordable housing – affordable for whom?
    • Shared ownership is “affordable” but its for households with incomes of 90k a year – that’s not affordable for median incomes
    • All London public land should be used for social rented homes
    • Strongly in favour of on-site provision because developers put social rented homes off-site because they think it lowers land/house price
    • Poor people forced out of city by this approach

    HG:

    • Re-introduce policy of 2004 plan so London boroughs have a framework – not each borough working independently
    • Need a specific affordable housing policy for each borough

    NHS Property Service (NHSPS):

    • NHS supports delivery of affordable homes for NHS workers
    • Tension between 35% and 50% policy, given HNS need for money for health
    • Sees bureaucracy as a complicating factor

    London Assembly Planning Committee (LA PC):

    • Percentages do not meet the needs stated in the SHLAA
    • Should be based on need
    • Propose to review 50% target in 2021 to look at success and state of funding
    • Will get less funding from government if 50% is all we say we want to meet
    • Estate regeneration has been removed from needing to through viability route
    • Want to see more monitoring and review of policy
    • Wording seems to reduce industrial site to provide affordable housing – need to be careful with that

    CPRE London (CPRE):

    • Support everything that has been said about raising the target
    • Pressure on green spaces that conflicts with other policies in the plan
    • Huge disparity on delivery across London – need to have a city-wide framework

    JS:

    • Only 310 social rented homes were completed in the 9 months before December 2018
    • People from vulnerable communities have not been consulted
    • The GLA talked about StART – plan is for “affordable” homes, no social rented homes, no target demand

    P:

    • Strategic target is too general, inflexible, there’s variation among London boroughs, general policies aren’t enough?

    GLA:

    • We think the plan is a strong approach to improve conditions
    • Policies are very clear in terms of what we expect boroughs to do
    • We believe that the threshold is enough
    • We need to also think about the need for intermediate products
    • Need to think of a good approach to all groups
    • Look into reviewing it in 2021 through the SPG

    LFo:

    • On b – low aim for public sector land, because it includes TFL land, which is quite considerable

    NHSPS:

    • Support the delivery of key-worker houses

    EAN:

    • Question on whether more funding may be available for low cost rent?

    JS:

    • Language and definitions obscure what’s really necessary
    • “Affordable” does not mean anything
    • What’s the tenure split? How much is the actual rent?
    • Need a social house building programme – the Mayor is saying nothing about that

    LTF:

    • Refer again to question of affordable housing targets – and failing to provide social housing
    • Example of Waltham Forest

    P:

    • Strategy too reliant on government funding

    GLA:

    • Committed to 10,000 council home target
    • 30% target is low-cost housing

     

    Policy H6 Threshold Approach to Applications

    GLA:

    • Threshold approach makes process clearer
    • Speeds up planning system
    • Makes it easier for council
    • Increasing rate of building affordable housing

    P:

    • Many people say it should be higher

    GLA:

    • Understand that it should be higher but it is based also on viability
    • Balance between maximising delivery and production
    • Encourage boroughs to adopt the approach to save time through process
    • Want to keep door open for development
    • There are various criteria that have to be met to enter fast track route

    EAN:

    • 40% is too high on boroughs (?)

    JS:

    • Wholly opposed to viability tests in housing provision
    • Threshold should be based on needs (50% or higher)
    • Push for a higher threshold level
    • Still challenge the whole concept of “affordable”
    • Opposed to the inclusion of shared ownership as part of the affordable rent category
    • Accept that it’s a good idea to have a threshold to escape viability route
    • Objective to get land value down – escalation is the route of our problems
    • Great that the GLA is discouraging inflation by providing certainty to developers about what they are going to be allowed to build
    • Thresholds are crucial for setting developer expectations but need to set it higher and developers and landowners will have to adapt
    • Question of what happened to the things that need to be reviewed, i.e. infrastructure if the development skips the viability assessment

    LFo:

    • Threshold approach not being as challenging as it could be
    • More could be delivered
    • Does not indicate which types of affordable housing should be sought
    • The grant system is not working – not secured into the future
    • Need a plan B without them

    London School of Economics (LSE):

    • Protracted planning negotiations are a significant issue
    • Threshold approach provides more clarity and that’s a good thing
    • Policy won’t be effective on its own in achieving the 50% target
    • Not possible only through planning policies
    • Effect on increasing reliance on small sites – which are not subject to affordable housing (not viable)

    LTF:

    • Not convinced that this approach will deliver more that 35% affordable housing
    • Developers will continue to choose building shared ownerships
    • Propose a 50% target for social rented homes
    • Need the mayor to carry out further analysis
    • 35% is better but it’s not enough
    • Want every variation and proposition to be made public for everyone to see
    • Review mechanism cannot result in less affordable housing – need monitoring on this
    • Worry about developers not caring about fast track route and sill engage in very carefully carried out viability assessments that benefit them

    HG:

    • Doesn’t make sense to have separate logics – should be 50% for all land
    • GLA paints this measure as progressive but in 2004 plan all schemes were subject to a viability assessment
    • Although the principle is right, the mechanism of a fast route does not give enough scrutiny and it’s not strong enough
    • It’s very easy for developers to achieve 35% – should be challenged to provide more

    Home Builders Federation (HBF):

    • Support elements and theory behind it but concerned on whether it is going to be effective and whether the targets will be met
    • Whether it’ll be effective in delivering 65000 housing units a year
    • Need to keep in mind that other types of housing need to be delivered – including the aspiration to buy rather than rent
    • GLA claims that 45000 net additions were reached in 16-17 – disagree, believe it was 39000 (HCLG data differs from GLA)
    • Lagging behind target
    • Tests the effectiveness of London Plan
    • Important that mayor monitors this policy closely
    • Need to take into account where policy flexes in other areas
    • Generally, affordable housing has flexed to accommodate other priorities
    • But affordable housing is a prime priority right now
    • Suggest that part c3 should be deleted because it won’t be an option anymore

    London First (LF):

    • H6b no time scale placed in relation to the public land 50% target
    • 6.5 should be amended to include time frame
    • H6Ca clarify point?
    • Believe that more leeway should be given to opportunity areas in terms of meeting such ambitious targets
    • Issue of scheme amendment (G,H) need to go further

    NHSPS:

    • Welcomes the simplification of fast track route
    • Don’t understand why public and industrial are treated differently from private land
    • Leads to think that viability assessments will be inevitable, which complicates process
    • Would like to see a scheme that helps the process for public land, not complicate it

    London Borough of Brent (Brent):

    • Very supportive of policy
    • Concern with relation of tenure mix
    • Developers seek fast track approach, but their tenure mix does not comply
    • Concern about the target becoming more important than the tenure
    • Old Oak & Park Royal (Mayoral) Development Corp’s draft Local Plan sets a 50% affordable housing target split 30% London Affordable Rent & 70% intermediate. It’s assessment of need shows only 14% are able to afford Intermediate.

    LA PC:

    • The objective should be to achieve alterations in land value [decrease it]
    • Suggestion to increase threshold in stages [35% now but increasing it upward progressively]
    • Fact that govt grant has to be used for so much intermediate housing should further increase the social housing content delivered by private development
    • Will speed up delivery and will help to achieve targets
    • Can be done throughout reviews
    • Will increase transparency by getting rid of secret calculations
    • The fast track approach does not allow us to see whether developments could do better than 35%
    • 6ac change
    • Concerned about change in B [on gross residential development]

    GLA:

    • If we set it to 50% all developments will want to go through viability route – which won’t decrease the length of the process and would provide less
    • Think 35% is the right approach at the moment
    • Understand that there are difficulties, especially the uncertainty of value and cost assumptions
    • This will improve conditions, considering that there are very low levels of affordable housing being provided
    • The danger of tenure would be true (?), but we have quite strong tenure policies
    • Depends on what the borough wants to do
    • Argues that it is a simple financial calculation to find viability
    • Can make it clearer in the plan that meeting the 35% does not mean that you can get away with other requirements

    JS:

    • Question about late stage reviews – could they lead to a reduction of affordable housing?
    • Risk of a downwards revision, which would be very damaging
    • If that’s not the case, it should be clearer on the wording

    LFo:

    • C3 [meeting obligations]

    HBF:

    • London boroughs will have to rapidly update local plans to meet requirements of London Plan
    • Is the purpose to catch a value or provide delivery?
    • Thinks the fast track approach does meet the requirements but question on compliance on all areas
    • That’s why it needs strong monitoring from the mayor

    HG:

    • H6c3 change of wording – compliance with other policies to ensure that scheme is not just used to push small sites that are not viable to build affordable housing

    LF:

    • Want to make contributions on review mechanisms
    • Review mechanisms should not apply for affordable housing in industrial sites because it does not promote development

    notes mainly from Blanca Yanez Serrano

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    On to next blog page

     

     

     

     

     

     

     

     

  • M34-5 Design 5 March

    M34-5 Design 5 March

    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

    Delivering good design

    Note: Un-rehearsed alliance between Just Space, Footwork architects and NHS.

    GLA:

    • GLA: Policy D1 sets out extensive criteria; focused mainly on physical attributes of design. Physical as well as experience; safe, inclusive —what design leads to in terms of what you experience in environment. Drawing on work of Jan Gehl— how you experience urban environment – how does the human interact with the city. Number of factors that combine to make experience. Physical leads to experience.
    • Defend that policy is London-shaping.

     

    London Tenants Federation

    • Question/concern in references of ‘character’… it’s not just about design, its about social content, what kind of communities live there, what is their economic status. Has huge impact.
    • Expressed concern of Harlesden residents with huge development coming to Old Oak Park Royal opportunity area. How does this design policy shape or form to protect that kind of existing community?

     

    London Forum

    • D1/2: These aren’t policies they are process/procedures better dealt with in guidance, however problem with that as they then aren’t scrutinized.
    • Very worried about democratic deficit, lack of openness/transparency and community engagement as negotiated in private between LAs and developers etc – community only get to see the output of this, don’t get to see input.
    • Community want greater transparency and say over future of development
    • In a city for all Londoners, Mayor wants communities to feel comfortable with nature and scale of development…however there is a MISMATCH of mayor’s aspirations with what we have here —which is a technician document!
    • Worried that D1/D2 cut people out process.

     

    CPRE:

    • Welcome changes made to draft on local distinctiveness and welcome given comments regarding human-centred approach outlined by GLA of Jan Gehl approach..… however they ARE NOT FOLLOWED THROUGH IN D1/D2. There is huge gap between that spirit and way which policy is expressed here.
    • Particular concern way in which plan as a whole is silent around NIEGHBOURHOOD planning approaches to resolving tensions. In order to understand local distinctiveness, would Like to see communities encouraged to go down neighbourhood planning route.
    • London is made up from a number of villages… we don’t want London Plan to lead us down road to change/development in London that is uniform, ‘anywhere places’ which leech distinctiveness away from London. This can be overcome by engaging communities more proactively.

     

    Just Space

    • D1B needs to demonstrate the community engagement process undertaken at appropriate time and how it influences the design.
    • Instead of using social indices of multiple deprivation as a headline, our idea is to have this mechanism of social impact assessmentto find out which of these assets are important to people, which directly relates to what is designed and planned there.

     

    Footwork architects:

    • Define good design in policy?
    • Agree with Just Space and others that emphasis on this policy informing area planning is important in that it’s an understanding of the social contextof places before a red line appears around a site that then informs quality of development proposals put forward.
    • In the mayor’s introduction, he defines good growth and acknowledges that there is social process to design.
    • Design can’t claim to be good If doesn’t acknowledge local context or people’s needs, wishes and what people value in a place. Then can act on this in how an area can be protected and enhanced.
    • Need to define mechanisms for understanding local character and social context prior to development, need a proper assessment and early intervention and a requirement to act on this information
    • Need to show an understanding of likely social impact of development
    • Promoting inclusivity requires an understanding of existing social makeup and what well-integrated communities are in order to avoid displacement of existing communities and businesses.
    • To avoid formless places? Acknowledge SOCIAL HERITAGE alongside built heritage, reference to local identity as to what makes each place unique.

     

    HBF:

    • GLA has said LP is a different type of document from local plans and therefore NPPF 2012 doesn’t necessarily apply, which we take issue with! As it has been our understanding throughout that the soundness of LP is assessed against NPPF…
    • GLA shouldn’t get away with ‘cherry picking’s what it gets away with
    • D2 We have an issue with as it is wordy and difficult for applicants to interpret and navigate and comply with. REMOVE D2 as we think design matters are better addressed at local levels

     

    London NHS

    • What is missing is what contribution design makes to social interactions, well-being and health.
    • no mention of impact on people’s lives and communities’ health and wellbeing in policy design.

     

    City of London Corporation:

    • Good design is not always about aesthetics
    • It’s how people feel welcomed irrespective of economic position
    • Way designs are translated to public and we welcome concept of 3D virtual reality – to engage Londoners in understanding design proposals

     

    Inclusion London:

    • D1: need fully funded access panel with people who understand things for large development and local developments – inclusive expertise. Access and inclusion panels and forums to check over development again and again;
    • Need to challenge assumptions and habits. Rethink and revisit
    • Inclusion actions aren’t referenced throughout

     

    Friends of the Earth

    • Agree with above that D1: missing crucial elements such as environmental sustainability
    • Need to acknowledge that London characteristics is not just about heritage features but of public spaces/squares and green cover.

     

     

    GLA response:

    • Feel that exclusion of communities from process/democratic deficit is dealt with in D2. Also view that issue of local distinctiveness and requirement for London boroughs to do something with initial evaluation and use this to inform policy is dealt with in D2.
    • Plan must be read as a whole!

     

    RESPONSE TO GLA

    • Impact on mental health is major failing!! (NHS London)
    • Need to have further clause specifically relating to engagement and collaboration (footwork architects)
    • The (profit) numbers are going to continually trump everything else (in reference to HBF), and public participation will be seen as block not benefit. We need to put something in plan where we stop just using the numbers. Where is the limit? (Just space)
    • Plan needs direct reference to how community engagement can be useful in process, (CPRE)
    • D1/2 are NOT London specific. We Agree with HBF that these aren’t policies. Tokenistic additions are not going to solve fundamental problem. (London Forum).
    • Concern over capacity of LBs to undertake the work, with lack of resources and skills in place making. Since 2014 mayor undertaken surveys to see what place-shaping capacity they have; results are revealing over 1/3rdlack confidence in place-making skills and large % difficulty in retaining their place-making staff (London Assembly Planning Committee)

     

    **BREAK**

     

     

     

    NHS:

    • Concerned by the focus on appearance OVER impact and outcome on community using it
    • In reference to analytical tools, which are visual and environmental, we propose including HEALTH IMPACT ASSESSMENT IN THERE.

     

    London First:

    • Support use of master plan, design code and review where appropriate

     

    Footwork architects:

    • THERE’S a WIDESPREAD VIEW that retaining the initial design team is important
    • Protection of design integrity is something that has been compromised particularly on major schemes.
    • Design review is important process as it ensures development proposals deliver on their promises. Communities often feel disenfranchised and that their power to influence schemes is limited. Good design review according to guideline can ensure that these social requirements are adhered to or at least respected in process

     

    Just Space:

    • Local input is important. Going outside borough in this policy, there isn’t place for the local consultation results.
    • Best way this can work: if applicant brings consultation results that have already happened to the design review so people know what the local feeling is.
    • Local consultation comments should be introduced to benefit design review

     

    London Forum:

    • Securing initial design team involvement could be required
    • “Design code” – needs explanation

     

    Just Space:

    • Master planning ought to have consultation component in it
    • Do not agree with 150 M policy over there in City of London – far too high – more City of London buildings should come to the mayor

     

     

    POLICY D3: INCLUSIVE APPROACH

    GLA:

    • Is it necessary? Principles are embedded in plan to remove barriers to inclusion, it is necessary to ensure that focus continues. Include as many Londoners as possible.

     

    Design council:

    • Inclusive approach positive
    • Well expressed

     

    HBF:

    • High standards of inclusive design is vague – applicant wouldn’t know or decision maker know how to respond to that. ‘highest standards’ is too vague.

     

    Footwork:

    • Inclusive design is defined in such a narrow way!!!
    • Only reference to physical barriers NOT SOCIAL BARRIERS !!!
    • Social accessibility needs to be cleared up

     

    Just space:

    • Build on/ amplify what Footwork Architects said (without prior collaboration).
    • Create inclusive communities; Age friendly cities/communities.
    • Design for aging population is a life course approach. To support aging population you need social cohesion to avoid inter-generational conflict and to facilitate downward and upward transfer of resources and knowledge between people in different age groups.
    • Needs of young, excluded groups, families – all need to be included.
    • If just talking about physical barriers – when we think about the lifts in A3: those also with cognitive and sensory impairment – who could have issue exiting in emergency
    • Community engagement: resourcing issue. Find it hard to reach groups with valuable voices such as; LGBT, older generation and minority groups. Reaching those has to be done through voluntary organisations who often have the capacity, contacts and knowledge but can’t respond effectively without resources.

     

    London Forum:

    • Support policy but seek changes
    • British standards institution 2005: define inclusive design with regard to access to services and in design policies there is not enough emphasis on this. There are barriers to access to services as well as points that people want to meet!
    • Proposed that more emphasis on walkable communities and maintenanceof those walkable neighbourhood.

     

    NHS London:

    • Inclusive design in terms of social aspects addressed
    • As GLA say it’s focused on physical barriers
    • Suggestion: inclusive design statements and the fact that there’s no requirement of master plans and design codes to embed and document inclusive design at policy level
    • reference to British standards by London Forum: they’re broader then physical aspects , also touch on neuro-diverse individuals and their experience. Broader aspect bringing the social is important!!
    • Glossary importance: no mis match between this and policies.

     

    Friend of the Earth

    • Policy doesn’t fully reflect the internal access of buildings. Often, buildings call themselves accessible but internally have no accessible toilets etc
    • Reference to refurbishment – existing buildings are often hopeless – so many places that doesn’t bother with physical access anymore – how we can make London more accessible in the physical sense? Policy needs to refer to refurbishment as well as new building, especially for shopps and town centre uses – and even where planning permission not required.

     

    Assembly planning committee:

    • Support need for broader definition in policy, not just access issues.

     

    GLA:

    • Mis match between inclusive design between glossary and use in policy.
    • D3: DOESN’T touch on social and attitudes to design.
    • DESIGN FOR THE MIND********* should COVER PEOPLE NEuRO-DIVERSE CONDITIONS
    • Moved on from lifetime neighbourhoods to inclusive neighbourhoods

    notes from Gabi Abadi

    Back to EiP narrative page

     

     

     

     

     

  • M23-8 Housing 1 March

    M23-8 Housing 1 March

    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

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