Housing: revised guidance

The GLA can produce Supplementary Planning Guidance (SPG) to elaborate on policies contained in the London Plan and especially to advise on implementation. The GLA planning team has prepared a revision of the 2012 SPG on housing and published a revised draft for consultation in May, just after the General Election. Just Space was among those invited to a February meeting to discuss the proposed content. No draft was circulated before or during the meeting but the team’s thinking was outlined in a slide show and talk by Jennifer Peters. Housing SPG GLA presentation 23.02.15

Following the meeting, Just Space submitted comments which are below.

The consultation draft then appeared and can be downloaded here on the Greater London Authority website: https://www.london.gov.uk/priorities/planning/consultations

Just Space responses have been made in August 2015:
Just Space – Draft Interim Housing SPG August 2015
member groups have also submitted responses, as follows:
Draft Interim Housing SPG comments by Hayes Community Development Forum

Housing SPG revision: earlier Just Space comment  3 March 2015


  1. Just Space was invited to a meeting on 23 Feb 2015 of the GLA Strategic Housing Market Partnership (a.k.a. SHLAA steering group). This group had originally been set up for the purpose of discussing the methodology of the SHLAA, and had been told in no uncertain terms that it was not for discussing housing need. Its membership—of Borough officers plus a very few private sector interests plus just 3 community organisations—in no way represented significant other groups, such as travellers, PRS tenants, the elderly and other need categories and is thus not an appropriate sounding board for major policy debate. GLA officers advised that they recognised this as a problem, but were eager to discuss the issues with this group, but only as part of an on-going and wider consultation.
  1. Just Space is in difficulty commenting because an SPG is supposed to elaborate policies already established in the London Plan, not make or modify policy. Since many of the housing policies contained in the London Plan have been fiercely and consistently opposed by Just Space and its member organisations, commenting is almost impossible. One member describes it as ‘embroidering the emperor’s new clothes’ and there is mention of deckchairs on the titanic. All we can do is to welcome the positive elements and seek to mitigate the worst impacts of the Mayor’s policies.
  1. Just Space looks forward to commenting in detail on the Draft SPG, publication of which is expected on 11 May, just after the General Election (when the next round of draft Alterations to the London Plan are also expected).

Comments of substance (on the talk by Jennifer Peters, illustrated with slides).

  1. Discussing whether or not the annual target should be 42,000 (the Mayor) or 49,000 (the inspector), or figures above 60,000 favoured by others, is of academic interest in a situation where actual delivery hovers around 50% of that number. In addition, even those (unachieved) targets lacked ambition in an environment where we could expect the London’s population to grow by 20% in the next 20 or so years.
  1. Just Space remains convinced that the Mayor’s focus on aggregate housing output, with some attention to “affordable” output, is almost meaningless and deflects attention and resources from meeting Londoners’ most urgent need for more social and genuinely affordable housing.
  1. The FALP is no great document, and the inspector seems to have been in two minds as to whether to approve the plans or not, although it is of interest that even he seems to believe that to meet need over the next ten years, London should be building 62000 homes per annum over the next ten years, to meet need. However, in the end he seems to have been persuaded to agree a figure of 49,000pa over the next 20 years, to 2036 and sign off the plan.
  1. We remain deeply concerned about the losses of employment and services throughout suburban London (within Town Centres, other High Streets and on employment/industrial land). The SPG’s proposals for minimising these losses, enabling these economies to prosper and minimising the need to travel to jobs and services will be scrutinised closely. Containing and mitigating Permitted Development Rights is just part of this set of problems.
  1. The proposed new section on accelerating housing completions appears deeply illogical. Because it is now recognised that developers on large sites will build out their permissions for market-sale units at the slow pace which best maintains their profitability, the Mayor is squirming to avoid the logical solution—to establish a large-scale public-sector strand of production which could go at full speed. He is thus advising boroughs to maximise the number of big sites so that they have more separate developers, each of whom will trickle their completions. More tenure forms are to be encouraged—mainly as a way of avoiding the trickle problem—but not to the point of re-negotiating S106 on approved schemes. It is not clear exactly how this is to be achieved. The developers had nothing to say at the February meeting, and the council reps said it was out of their hands.
  1. Public land surplus to requirements owned by the GLA and its agencies: Mayor is ‘very proactive’. The GLA hopes that the new Land Commission announced on Friday will help. But no suggestion that Mayor will develop himself. The talk is very positive, however, since we know that land availability is not really the main problem at the moment (there is enough land with planning permission in the country to meet need nationally, if not in Central London) the problem is the lack of will/incentive to build.
  1. Tony Mulhall of RICS asked whether PRS could be a substitute for affordable housing. Just Space would be wholly opposed to this if it were to be proposed.
  1. Just Space remains deeply concerned by the problem of developers coming back to reduce delivery of affordable/socially rented homes on the grounds of secret viability re-assessments. As long as councils and developers kept such assessments secret, they will never be trusted. Interestingly, one of the council reps at the February meeting described the viability assessments he saw as ‘fanciful’. We argue that such documents must be open and public, if any faith in the planning system and developers is to be achieved.
  1. It appears that the density matrix is to be reviewed in the new London Plan but not before. Meanwhile Just Space continues to stress that the adequacy of social infrastructure should be a factor influencing permitted densities, in the spirit of “Lifetime Neighbourhoods”. The density ‘flexibility’ that developers currently enjoy seems to result in them effectively ignoring the matrix when it conflicts with their commercial objectives and could be inflating land values as developers over-bid for sites, knowing they can secure density increments in planning negotiations. As we said at the February meeting, London’s practices are greeted with astonishment and derision by planners from countries in Europe and North America where densities are regulated.
  1. Just Space is pleased to hear that space standards are to be detailed in the SPG and looks forward to examining how the London proposals are meshed with government standards for England.
  1. We give a provisional welcome to the proposal that GLA will insist boroughs do own SHMA/need assessments within the framework of its own London-wide ones..
  1. The DCLG has commented on the plans, with the minister, Brandon Lewis, becoming exercised over the standards for parking provision, where he is keen on making more parking spaces available. This is very important to us, since any increase in parking provision means an increase in land costs per dwelling, which in turn impacts on the viability of a development; something which would adversely affect the provision of affordable/social rent housing. Just Space is also very concerned that relaxation of parking control would contribute to car ownership and use, slow the growth of car clubs and undermine London’s proud achievements in modal switch.
  1. Just Space continues to urge that the concept of protecting private garden land should be extended to cover also the green space on housing estates which have current and potential roles just as important as private ones (§1.2.18 of the 2012 SPG).
  1. We hope that the GLA will preserve the good material in the 2012 SPG on sustaining communities, including those in which households are large and/or include disabled people.
  1. We note the absence of the 2012 “social mix” policies from the talk at the February meeting and hope that this means the section has been dropped. The allegation that poorer people somehow benefit from an admixture of richer people in their neighbourhoods has been so widely discredited that it has no place in London plans, especially since it is used only to legitimise the expulsion of poorer people from their communities, never to support social housing in middle-class suburbs. [Later: see below for elaboration.]


The GLA planning officer replied immediately: “Thanks for sending this through  – a quick question about para 18 of your comments about social mix policies; we are not amending that element of the SPG which is why we didn’t raise it. Just to understand your comment a bit more (more out of personal interest / potential issues for the full review, than for the SPG) –   but does your comment mean that you are not supportive of onsite affordable housing? Or that you are just unsupportive of what the promotion of mixed communities is sometimes used to justify?”

We replied as follows: “We are grateful to you for querying para 18 of our very compressed comments. The following is a slight expansion.

Just Space has always been supportive of on-site “affordable” and (even more of) on-site social housing. Off-site provision should be only in the most exceptional cases.
You are right that our repeated objections to the broader discourse of “social mix” is because this fine-sounding apple-pie sentiment has so often been used as part of the legitimation for clearing social housing estates, dispersing communities and replacing them with “mixed” developments.  We consider this unacceptable infringement of people’s rights to stay put and makes nonsense of aspirations for “sustainable communities”.
We would also note that in London so many estates originating as social housing now actually contain mixed tenures (with leaseholding and freeholding former tenants, plus owners following resale plus private tenants).  This further diversifies the population of estates which, in London, have long contained quite a strong occupational and income mix.
We note also that research by Paul Cheshire at the LSE – coming at it from a very market-economic perspective – has failed to find any evidence anywhere that poor people benefit from the insertion of richer people among them. We are sure you know the paper: Cheshire, P. (2009). “Policies for Mixed Communities: Faith-Based Displacement Activity?” International Regional Science Review 32: 343.
We would be more than happy to contribute further on this to the full review. It is so important.”  3 March 2015