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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
- 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
- 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
- Assumption of 50% is without grant. Then there’s an investment programme which could boost %.
- Opportunity to marry planning system with Mayor’s approach?
- Several examples in Plan where this marriage is happening
- Whereas before the tradition was to keep these things separate
- Will the shortfall be made up? What are the strategies to make up 50%
- On balance, if 35% of the Plan is secured, along with investment programmes, the 50% will be challenging but achievable.
- Overall need is 65%, need for low-cost rent is 45%.
- Pushing it as much with tenure need but not enough funding.
- Have tenure targets
- Industrial Land and Public Land is 50% threshold because it should provide more community benefits.
- This higher requirement needs justification
- 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
- Will this incentivise developments on these lands?
- 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)
- 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
- 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
- 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
- Strategic target is too general, inflexible, there’s variation among London boroughs, general policies aren’t enough?
- 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
- On b – low aim for public sector land, because it includes TFL land, which is quite considerable
- Support the delivery of key-worker houses
- Question on whether more funding may be available for low cost rent?
- 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
- Refer again to question of affordable housing targets – and failing to provide social housing
- Example of Waltham Forest
- Strategy too reliant on government funding
- Committed to 10,000 council home target
- 30% target is low-cost housing
Policy H6 Threshold Approach to Applications
- Threshold approach makes process clearer
- Speeds up planning system
- Makes it easier for council
- Increasing rate of building affordable housing
- Many people say it should be higher
- 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
- 40% is too high on boroughs (?)
- 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
- 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)
- 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
- 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
- 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.
- 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]
- 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
- 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
- C3 [meeting obligations]
- 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
- 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
- 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