Response: Homes for London, the London Housing Strategy

Transcription

1 February 2014 Response: Homes for London, the London Housing Strategy Draft for consultation November 2013.

2 1. Introduction and Background The National Housing Federation is the voice of affordable housing in England. We believe that everyone should have the home they need at a price they can afford. That s why we represent the work of housing associations and campaign for better housing. Our members provide two and a half million homes for more than five million people. And each year they invest in a diverse range of neighbourhood projects that help create strong, vibrant communities. In November 2013 the Mayor published Homes for London, the London Housing Strategy in draft for consultation. The Federation has consulted widely with members including the G15, G320 and our member practitioner groups to produce a response reflecting the views and recommendations of the housing association sector in London. 1.1 Summary of the National Housing Federation s response The National Housing Federation welcomes Homes for London and supports the Mayor s ambitious targets for increasing the numbers of much-needed homes of all types and tenures across London. Housing associations own and manage over 430,000 homes for Londoners from all walks of life, and are also key partners in the delivery of new homes. Key recommendations The GLA should: Maintain a flexible and open dialogue on the new investment programme which will help our members to deliver the maximum new affordable homes for London. Continue to pursue positive discussions with the boroughs on nominations to ensure the system is fit for purpose. Commit to supporting affordable housing requirements in the planning system. Recognise the housing needs of young people and vulnerable groups in London. Hold a focussed discussion of how best to deliver unprecedented levels of house-building via the London Housing Bank, housing zones and other innovative forms of development finance.

3 2. Identifying the challenge London s housing need The National Housing Federation supports the Mayor s ambition to increase housing delivery to at least 42,000 new homes annually in London. We also recognise, as the Strategy does that this target will not in itself meet housing need in the capital. The Mayor s own Strategic Housing Market Assessment (SHMA) suggests the target should be around 49,000 homes. Consideration needs to be given to how the Mayor will work with boroughs and the sector to deliver all the homes London needs. The Housing Strategy sets out various options outside the investment programme that the Mayor will explore to meet this additional demand, which we look forward to hearing more detail on. House building is vital to London s economy, both in terms of the Capital s continued global competitiveness and in terms of the economic benefit to GDP and employment rates. A recent study by the National Housing Federation shows that more than 80% of London businesses surveyed warn a lack of affordable housing would stall local economic growth, while 75% said it would affect their ability to attract and keep workers. 1 In addition we estimate that for every home built in London 117,645 of GVA is pumped back into the Capital s economy, and almost two full time equivalent jobs are created. 2 We are encouraged that the Mayor has recognised that housing is essential infrastructure. We see this as a big step forward and would welcome his support in ensuring that this is nationally recognised. 2.1 Setting the ambition Planning: In this section the Mayor makes a commitment to use the full range of powers at his disposal to remove barriers to delivery, particularly with regard to stalled sites and planning processes. As a consultee on major applications, we believe the Mayor has the power to do much more to 1 Survey for the National Housing Federation 2 Economic impact database, Centre for Economics and Business Research (CEBR)for National Housing Federation, 2013.

4 increase delivery and we welcome his willingness to address this. On strategic schemes the Mayor has the power to directly refuse or to call in applications, taking them over and determining them himself. There must be stronger scrutiny of developers claims that affordable housing requirements are negatively impacting viability. Without planning gain from Section 106 it is difficult to see how the Mayor will achieve his 15,000 annual affordable home target. Many of our members have similar concerns about the interaction between S106 and CIL. CIL is an important tool for local authorities to deliver key infrastructure, but the danger remains that affordable housing delivery via Section 106 will be squeezed out as developers claim that being asked to contribute twice make sites unviable. Clause 6 of the Growth and Infrastructure Act 2013 further adds legitimacy to the renegotiation of affordable housing commitments on grounds of viability. The Federation opposed this Clause and lobbied successfully for it to time out in We strongly encourage the Mayor not to accept the reduction of affordable housing provision on sites over which he has control, and to scrutinise developers viability claims We are calling on the Mayor to take a more active role in resolving difficulties in major schemes, but always with the proviso that affordable housing quotas must not be reduced unnecessarily, especially on high value developments. Private rented sector provision: We recognise the positive role a strong PRS can play in London s housing market, and support the Mayor s ambitions to extend provision of this tenure. We also recognise there are significant problems in London s existing PRS. There is a need to increase the quality and quantity of PRS provision as well as encourage a more professional, accountable sector that better meets the needs of tenants. Housing associations have a pivotal role to play in the delivery and on-going management of good quality private rented sector homes. The sector is committed to establishing a quality PRS, and we very much support the Mayor s agenda with regard to addressing standards. The Federation supports the principles and ambitions behind the London Rental Standard. We welcome efforts to drive up standards in the private rental market, as do our members. As a sector we very much support the Mayor s emphasis on encouraging new entrants into the large-scale purpose-built PRS market. At present with a few exceptions housing associations are leading the way with developments such as Genesis Stratford Halo, and TVHA s Fizzy Living

5 schemes. These large scale schemes have multiple benefits for tenants including higher quality, stable rent increases, a choice of longer tenancies, and greater flexibility. Increasing market rental completions to 5,000 per year is a worthy ambition. We look forward to more detail on how the Mayor plans to encourage other players such as institutional investors to enter the market. Although we are keen to support the delivery of new PRS, market rents remain unaffordable to a many Londoners and this type of housing should not be prioritised above affordable housing or prejudice its delivery affordable housing programme: We very much support the Mayor s ambition to provide an affordable housing programme which is more tailored to the needs of London. In particular we welcome the recognition that in London there is an acute need for genuinely affordable rented housing. The Federation and our London members have made this case for many years and we welcome the fact that the Mayor is acting. We support the delivery of an appropriate mix of rented homes at different levels. However, the discounted rent product is likely to be opposed by many boroughs. The GLA have subsequently clarified that in fact a more blended approach to that outlined in the strategy will be acceptable. Where a local authority wishes to put in additional resource such as New Homes Bonus or discounted land in order to make the provision of lower rent homes more viable, the GLA has clarified it will be acceptable to deliver homes at discounted rents below 80% of market via the programme. This is a positive development. There are pre-existing issues with nominations that make providers nervous about homes for higher rents. Many local authorities continue to nominate tenants to homes where they will struggle to pay the higher rents, partly because of a lack of more affordable options. In many parts of London, 80% of market rent is not affordable to those in employment, and is contradictory to the objective of making affordable homes accessible to low and middle income households. This issue with nominations risks holding up delivery and affecting the viability of the programme. If providers do not have certainty that local authorities will nominate tenants to properties they can afford, it could affect associations confidence when bidding and undermine the programme. The division of larger and smaller homes between these differentiated rent products is also of concern to Federation members. The requirement to provide 36% of the higher rented homes as three beds and above could pose serious problems. In many parts of London local

6 authorities will struggle to nominate tenants, even those in work, who can afford the rent on a larger home at 80% of market rent. Discussions with the GLA subsequent to the publication of both the Strategy and the investment prospectus have made it clear that the GLA understands these issues. GLA Area Heads are in discussions with their boroughs to produce framework agreements around nominations to homes delivered under the programme. It is clear that these agreements will not be fully in place by the close of the bidding deadline in March, although a statement of principles may be in some cases. The GLA have indicated that there will be scope for negotiation on bids past the deadline to compensate for this. The GLA should recognise that many providers will be submitting bids without knowledge of the success of the framework agreement negotiations, and must offer sufficient flexibility in recognition of this. The GLA must keep the sector informed of progress with boroughs throughout this process to help give confidence to bids, and maximise responses to the prospectus Cross subsidy The GLA should recognise that housing associations must make decisions about cross subsidy based on their individual business priorities. Housing associations vary hugely and not all forms of cross subsidy are appropriate for all providers. Clarifications from the GLA are very welcome that bids which offer other forms of cross subsidy than market rent or sale will still be considered. It is also positive that the GLA are not insisting on re-lets and conversions to higher rents. It is positive that the GLA has stated that providers with fewer than 1000 homes will not be required to do market rent or sale to cross subsidise, but we would appreciate it if this flexibility could be extended. Many associations who have not traditionally delivered these types of products may struggle to convince their boards of the desirability of such a venture. In addition the regulator is taking a keen interest in housing association activity in this area which does not tally with the GLA s enthusiasm for this type of delivery. With regard to high value disposals, many associations are subject to restrictions contained within their stock transfer agreements with local authorities that may prevent them from undertaking these kinds of disposals. The GLA should maintain a flexible approach on the issue of cross subsidy and maintain a broad definition of what constitutes value for money, which takes into account the differing circumstances of associations.

7 2.3. Improving design The Mayor should be recognised for setting robust housing standards and taking a proactive approach to housing quality. However, in the long-term we think it is important that London standards sync with those that are applied nationally as part of the Housing Standards Review. In that way, the full benefits of the Review will be realised, allowing the rationalisation and standardisation that will aid delivery, particularly for our members that operate inside and outside of London. There are a number of schemes which were granted planning permission prior to the introduction of the Design Guide standards, which may now run into difficulties if they are not compliant Improving existing homes and estates Retrofitting and improving energy efficiency, and upgrading existing stock Housing associations are committed to improving the environmental performance of their stock and have already invested significantly in such improvements, particularly to provide affordable warmth. While it is appropriate to make environmental improvement a condition of the additional Decent Homes funding, we would like some further information on what exactly will be expected from housing associations. Housing association stock in London varies hugely in age and type and it is important that this is recognised in any proposal for retrofit. The GLA has suggested that they would like to assess what housing associations would need in order to carry out a full retrofit by We would like to explore this with the GLA and ensure a position is reached that is practicable for housing associations, whilst meeting the Mayor s objectives. We look forward to further clarity as to how these proposals will impact on housing associations from the Mayor We believe that SAP rating would be a more appropriate way of measuring energy efficiency performance of housing stock rather than Energy Performance Certificate, as it is in many ways a more precise and useful measure. Empty homes We welcome recognition that action on empty homes can contribute to reducing the shortfall of affordable housing. We encourage the Mayor to work proactively with boroughs to facilitate action on this. Different approaches are needed in different parts of London. Some boroughs

8 could be encouraged to use their existing powers to tackle blight and impose council tax penalties on long-term empties to act as an incentive to address this problem. Other boroughs need to adopt a more flexible approach to such penalties to ensure that only long-term empties are being penalised, and not short term voids. We think that the Mayor should also explore the use of his compulsory purchase powers to facilitate acquisition of long-term empty homes for the public good. 3. Fulfilling the covenant 3.1. Supporting working Londoners Supporting home ownership and the intermediate market Housing associations have been the driving force behind the delivery of shared ownership and other low cost home ownership (LCHO) options for decades. Therefore as a sector we strongly support the Mayor s ambition to increase access to this important tenure. It is very positive that the Mayor has recognised some of the obstacles to intermediate delivery and has committed to using his influence to address them. We especially welcome his promised work with mortgage lenders to encourage them to treat shared ownership mortgages in the same way as any other mortgage application. We welcome the improvements to First Steps that have been made and our members have engaged positively with the 100m fund for new LCHO products via the Homes for Working Londoners section of the housing covenant. The ambition to increase the number of shared ownership homes to ensure 250,000 Londoners can access shared ownership by 2025 is also very welcome. We are keen to see more detail on how the GLA will encourage other entrants to this market, and other means of delivering shared ownership outside of the new investment programme. Right to part-buy We very much support the principles of Right to Buy, in particular the desire to increase social mobility and to help those social tenants transition into home ownership who wish to do so.

9 However, there are substantial problems with the way the current system operates, which we believe would extend to a right to part-buy programme. The Government s introduction of more substantial discounts has undermined the Preserved Right to Buy (PRtB) policy that applies to housing associations with transferred stock and their tenants. There is no plan from Government to replace the affordable homes lost through PRtB, nor is the policy s impact on affordable housing supply being monitored. We believe the considerably reduced receipts resulting from Right to Buy discounts are at least partly responsible for the slow rate of replacement, something that would only be exacerbated by a right to part-buy where the local authority would receive an even smaller initial receipt. In addition there is only likely to be a very small market for this product, as experience with Social Homebuy indicates, so the GLA may put time and energy into something that can only have limited impact. It is also not clear how the Mayor would fund housing associations to offer these schemes to their tenants. The Mayor should focus his resources on increasing new supply of shared ownership as a means of increasing access to this tenure. Facilitating mobility We approve of the Mayor s plans to retain a percentage of nominations for pan London lettings. This should help to ease some current issues where the difficulties of letting properties to tenants across borough boundaries can hinder mobility. Our members are also content for the sub regional nominations system to be replaced by a wider pan London nominations system. Nominations and allocations The changing operating and policy environment means that allocations and nominations agreements made between local authorities and housing associations in the past may no longer be enable housing associations to effectively manage their stock and maximise the capacity in their business. This will impact on their ability to maximise the supply of new homes. Local authorities, in the discharge of their duties, have normally nominated the household at the top of their waiting list to the housing association when a tenancy is available. Often this household is dependent on benefits. In the case of homes let at an affordable rent of up to 80% of the market rate, this means that the benefit dependency of the household in question is increased and the distance to labour market can become unbridgeable.

10 Many housing associations are in active discussions with local authorities to ensure agreements can be made in the best interests of the local authority, housing association and tenants. This may mean operating a more flexible allocations policy around the numbers of tenancies allocated to those households who are mainly dependent on benefits to pay their rent. We appreciate the further intervention of the GLA on this issue. Many of these pressures, particularly welfare reform, are also faced by local authorities. However, not all local authorities are willing to revisit allocation and nomination agreements, and this may mean in future that some associations will need to review their operations in certain areas to ensure the integrity of their business. Whilst we welcome the Strategy s reference to permitting associations to retain nominations, we would like to clarify that the percentage of nominations granted is a matter for each association to decide independently. High earners contribution A version of a high-earners contribution has been explored by some of our members from time to time. However the numbers of social housing tenants who earn more than 60,000 p.a. are estimated to be very low. The burden of collecting the relevant information and implementing the relevant rent increases would in the majority of cases outweigh the value of the exercise. The Federation would strongly counsel against any compulsory introduction of such a measure. 3.2 Meeting a range of housing need Housing for older Londoners Increasing the quantity and quality of homes for older people in London is crucial to achieving a wide range of the Mayor s objectives. We are pleased to see the inclusion of older peoples housing in the Mayor s strategy, but feel it does not go far enough in setting out how the Mayor will deliver the right kinds of development in the right places. We understand the impetus behind designating the percentage of wheelchair accessible homes, and we welcome the introduction of a single wheelchair standard for London. However, the blanket 10% requirement for wheelchair-accessible homes is too inflexible and our preferred approach is to ensure homes are adaptable to be able to meet the occupants changing needs over their lifetime.

11 Similarly the Federation has been pleased to note the introduction of the care and support specialised housing fund, to which our members have responded positively. However we do not feel that the Strategy offers a sufficiently comprehensive and wide-ranging vision for delivering the high quality older peoples developments London desperately needs. The Mayor should do more to protect and promote older people s housing by offering guidance to boroughs on planning for such developments. It is critical for older people s ability to live independently that supported housing developments should be located close to amenities, mixed in with other types of housing and that developments should be designed as community hubs which will attract local people of all age groups. Focus should be on making sure that the right kinds of housing are being developed in the right places, as well as numbers and types of homes. The Mayor should enter into a dialogue with the boroughs to ascertain how older people s housing is being developed across London, and if current plans reflect best practice. Tackling overcrowding We remain concerned that the Mayor s commitment to tackling overcrowding is coming into increasing conflict with the wider Government agenda to address under occupation and benefit dependency in the social rented sector. The risks to housing associations revenue streams from the bedroom tax, coupled with affordability concerns and the overall benefit cap mean that it is harder for associations to develop larger family homes. In addition our members are more wary about the types of tenants they can accept into larger homes, due to concerns about nominations. Housing associations and local authorities alike have stepped up their efforts to help tenants move and/or downsize, albeit with limited success, which will free up some larger homes. However the question of which households can take advantage of those homes will come into persistent conflict with the Mayor s ambition to reduce severe overcrowding. We welcome the opportunity to contribute to this ambition through our role on the Overcrowding Board, but we are sceptical of the ability to make substantial progress on this issue in the current welfare climate.

12 Addressing statutory homelessness and rough sleeping We remain concerned at homelessness trends in London. Rough sleeping is on the increase, homelessness acceptances are up by 8.2% in the last year and over 42,000 households are living in in temporary accommodation. 3. Our members who provide temporary accommodation in London are finding the model for providing this vital service is becoming increasingly precarious. Welfare reforms such as direct payments of housing benefit to tenants and the inclusion of the temporary accommodation management fee in the household benefit cap make it extremely difficult to predict the future of the temporary accommodation model. Local authorities are now able to discharge their homelessness duty into the private rented sector, but evidence from the London boroughs suggests it is increasingly difficult to attract private landlords to house clients in receipt of benefit. This means there is an ongoing need to provide secure temporary accommodation for those homeless and at-risk households for whom a suitable home cannot be found in the social or private rented sector. At the same time it is more difficult to attract private landlords even to participate in a fully managed, rent guaranteed temporary accommodation scheme due to the high rents they can command on the open market. Guaranteeing the rents on these properties and ensuring they are not affected by the benefit cap is essential to the future of the service. We would welcome support from the Mayor in urging DWP to make an announcement on this issue as soon as possible that will guarantee continued provision and allow our member to continue providing this essential part of London s homelessness safety net. Other types of housing-related support We are pleased to note the inclusion of rough sleepers and older people in the Mayor s strategy. However we are disappointed to note the lack of reference to the wide range of other groups for whom quality specialist and supported housing is vital to independent living. Our members provide care, housing-related support and specialist homes for Londoners with diverse needs, from people who need help with drug and alcohol dependency; to young people leaving care; to people with complex physical and mental health requirements. The Federation s publication Providing an Alternative Pathway explains the importance of housing 3 CLG homelessness live tables

13 as part of an effective care system, helping to achieve the dual ambitions of improved quality of life for individuals and delivering long-term savings to the NHS. 4 Meetings with GLA representatives have made it clear that bids from providers of specialist and supported housing will be welcomed in the new investment programme. However the drafting of the Strategy and the prospectus, which focused on the desire to deliver shared ownership, capped and discounted rent products, and wheelchair accessible properties did not make that plain. Inevitably many bids for specialist care and support homes will require higher levels of public subsidy than general needs developments. We welcome the assurances from the GLA that such schemes will be considered on an individual basis and will not be allowed to skew the overall value-for-money assessment of a bid. There have also been suggestions from the GLA that a second bidding round may be made available in late 2014 to allocate whatever portion of the programme is not allocated in the current bidding round. It has been suggested that this may be a good opportunity to involve smaller and specialist providers who may struggle to put together an appropriate bid before the March 2014 deadline. We very much welcome this positive response to our members concerns that has led to consideration of a second bid round. We urge the Mayor to lobby for a repeat of the care and support specialised housing fund when it runs out in Young people The National Housing Federation s members provide a wide range of services for young people, whether that be supporting young parents, helping young people into the workplace or delivering specialist young people s services on behalf of local authorities. We were disappointed that the Strategy did not contain reference to the particular challenges faced by young people in London s housing market. Federation members such as Family Mosaic, Shepherds Bush Housing Group and the YMCA network all provide innovative support to young people wishing to enter education, training or the workplace as a means to independent living. In the final version of the Housing Strategy we would like to see the Mayor make more reference to how he plans to support London s young people to access appropriate housing, with particular reference to those who are vulnerable. 4 National Housing Federation, Providing an Alternative Pathway, the value of integrating housing, care and support, January 2013

14 Young people from all backgrounds are priced out of independent living, and many of them are unable to simply return home. The Federation would like the Mayor to make a commitment to addressing the housing needs of the capital s vital young people. 4 Delivering the vision 4.1 Financing housing delivery A long term financial settlement for housing The Federation and our members look forward to working with the Mayor to develop his thinking on alternative sources of funding such as a London Housing Bank. Many of our members have provided homes using similar models to Affordable Rent to Buy in the past with varying degrees of success. An important consideration for Federation members would be that, providing the public subsidy from the original loan is returned, housing associations should be at liberty to dispose of properties or otherwise as they see fit after the initial loan period expires. We also support lifting the local authority borrowing caps to increase prudential borrowing to fund localised housing delivery. We also welcome the substantial grant settlement for London the Mayor has secured for the investment programme Capital investment in affordable housing is the most efficient form of subsidy in the long-term. In terms of future programmes we believe the Mayor should have even more discretion to spend the capital settlement on London-specific priorities in order to use it more effectively. The Mayor should advocate for an ongoing commitment from central government to a much bigger national capital programme, of which London would be the primary regional stakeholder. We support calls for a rebalancing from revenue to capital investment in the provision of affordable housing. We welcome signs that the Mayor recognises the value of affordable rented homes at lower rents, both in terms of the benefits to low income Londoners and in terms of a reduced housing benefit bill. Despite these proposed finance options and the increased capital grant provisions we remain concerned as to how the Mayor will successfully fund his ambitious house building targets. We would like to be involved in discussions, particularly around the London Housing Bank as ideas progress to help create workable proposals for increasing development capacity.

15 We support the Mayor s ambition for a secure, long-term funding stream for housing in London and look forward to exploring his ideas with the GLA. Making affordable housing assets work harder We understand that at times of reduced public subsidy it is important that housing associations should sweat their assets to aid delivery. However, given that London housing associations have been operating in an environment of declining subsidy and increasing land values and build costs for many years, this is already a given for any developing housing association. Our members are committed to making the most of their capacity. Larger housing associations in London have led the way in self-funded development and accessing non-traditional forms of finance, such as bond issuance. Whilst many more are exploring these avenues and we will continue to see innovative approaches from the sector, it is fundamental that housing associations ability to attract development finance rests on their secure asset base and the financial health of the sector. The emphasis on supporting smaller housing associations to develop and make best use of latent capacity in the sector is very welcome. Many smaller associations are interested in exploring potential development opportunities and the GLA s offer to match-make with larger associations could be helpful to those providers. Many smaller associations such as Soho Housing and Innisfree are already exploring partnerships with larger providers and support for such moves is welcome. Many smaller housing associations are also exploring innovative ways of self-financing development, such as taking advantage of high land values. We welcome further details on the GLA s match-making proposals as a matter of urgency to help smaller providers prepare their bids. We welcome the softening in the GLA s attitude to on RCGF to make it clear that providers who are not developing will not be asked to hand back RCGF. 4.2 Bringing forward land for development Garden suburbs and public land release Getting access to suitable land is a vital ingredient to delivering new homes. For this reason we support the GLA using the London Development Panel to accelerate delivery of sites for housing in a coordinated and timely manner. The Panel s focus should be comprehensive and include all surplus land suitable for housing in order to maximise impact on delivery. It would therefore be a missed opportunity not to extend the Panel to all public sector land including

16 boroughs. The Mayor should work pro-actively with the boroughs to encourage them to participate in the scheme and bring forward their own land. There also needs to be more coordination in the way land is released in order to make the most of potential opportunities for combining sites to unlock additional capacity. As well as facilitating the release of land, the Mayor should look at alternative disposal models and work with boroughs on innovative approaches that support housing delivery. Public land which is either discounted, free or paid for at a later date, provides housing associations with a game-changing opportunity to deliver the homes London needs. For example, rather than traditional approaches which seek to maximise a one-off capital receipt, the GLA could support revenue-based models where land is made available to developer at low or nil cost and leased back for a certain term. The GLA and the boroughs should consider models where the public sector shares in the increase in value generated by the development. We would welcome the opportunity to work with the Mayor and other partners on developing such alternative approaches to land disposal. In setting the price for public land, best value should be defined much more broadly and give consideration to the long-term benefits and savings of delivering affordable housing, as opposed to focusing on the most significant up-front receipt. For example, affordable housing will deliver real savings to local authorities housing residents in temporary accommodation as well as additional council tax revenue. Housing associations could also deliver affordable housing alongside employment and independent living initiatives, reducing demand on local authority services. This would also serve as an important way of facilitating new entrants into the market and increasing competition. The Strategy contains little detail of the Mayor s planned approach to other public sector bodies who are not part of the GLA family. We hope the final version will have more detail on how the Mayor plans to work with central government departments and boroughs to achieve London s housing ambitions. Housing Zones We look forward to more details about how the proposed Housing Zones may work. Federation members, such as Home Group, are already exploring proposals of their own for how affordable delivery could be incentivised and would like to usefully contribute to the GLA s discussions on this issue. Proposals for housing zones should be focussed on increasing affordable housing delivery, rather than luxury developments to the exclusion of homes for ordinary Londoners. We welcome the consideration this proposal demonstrates as to how barriers to delivery can be overcome.

17 5 Conclusion The GLA is warmly supportive of the Mayor s ambitious Housing Strategy. The National Housing Federation look forward to working closely with the GLA over the coming months to flesh out many of the details of these proposals. Key recommendations The GLA should: Maintain a flexible and open dialogue on the new investment programme which will help our members to deliver the maximum new affordable homes for London. Continue to pursue positive discussions with the boroughs on nominations to ensure the system is fit for purpose. Commit to supporting affordable housing requirements in the planning system. Recognise the housing needs of young people and vulnerable groups in London. Hold a focussed discussion of how best to deliver unprecedented levels of house-building via the London Housing Bank, housing zones and other innovative forms of development finance.