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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