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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 ??
Disadvantages of small units and advantages of family homes.
Does this policy ensure that enough family homes are built?
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.
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.
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.
Anything else you would like to respond to?
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.
? missing bt
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.
It is not acceptable to say we cannot provide family size housing because it costs a lot if this is what people need.
Requirements for particular ethnicities should be taken into account.
Vacant Building Credit
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…
Asks the Mayor about whether a reverse policy would have been more effective.
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?
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.
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
Why not number of units.
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.
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.
Go back to the Mayor. Is this policit about redevelopment of existing housing or about estate regeneration?
It is attempting to do both.
About the plan prioritising demolition
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.
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?
Floor space rather than units: we support the policy. (added some point but did not get it)
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?
Estate regeneration is a contentions issue. Comment on the point of separating housing redevelopment from estate regeneration.
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.
Footnote 50a. Comment on that.
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.
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.
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.
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.
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.
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.
About including more details to the policy and all are claiming
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.
Yes, the panel does have a role on this.
Yes, we are going to assess these suggestions.
Notes thanks to Dr Pablo Sendra