TEE FABIKUN. Document Ref: REP.LP Matter 3 Housing

Size: px

Start display at page:

Download "TEE FABIKUN. Document Ref: REP.LP Matter 3 Housing"

Joel Bailey
5 years ago
Views:

1 TEE FABIKUN Document Ref: REP.LP Matter 3 Housing 1. Bearing in mind the recent Inspector s report following the Further Alterations to the London Plan (FALP) examination (see paragraphs of that report), is there a case for the LLDC to have carried out its own strategic housing market assessment and calculated its own objectively assessed need for housing? The FALP Inspector was referring only to the overall target for housing and not that of market trends and needs of different groups in the community (such as families with children, older people, people with disabilities, service families and people wishing to build their own homes) or of size, type and tenure required in particular locations reflecting local demand. Local need and demand for a range of housing types is likely to be very different in East London than in other parts of London. Newham for example has the highest average household sizes in London and also has the highest number of households with incomes of below 15,000 per annum. There seem to be some contradictions between the LLDC s apparent dependence upon the boroughs SHMA s and yet setting affordable housing targets at a 15% lower than any of the boroughs. Hackney, Newham, Tower Hamlets and Waltham Forest all have 50% affordable housing targets presumably based on objectively assessed need, while the LLDC sets 35% of its total target (1471) -171 (of non-self-contained housing). The LLDC should carry out a SHMA and set a date in the Local Plan of when that will be done. 3. Some representors refer to a loss of homes to accommodate the Olympic and Paralympic Games facilities. Is there a case or a boost in the FALP housing numbers because of the area s recent history? Or does the need to avoid the loss of employment land and secure balanced, sustainable development maximising the legacy of the Games count against the suggested approach? Most of the homes lost were social-rented and were a range of sizes of homes some accommodating 10 single people. It is unlikely that

2 genuinely affordable homes, like for like, would have been delivered to address this loss. If they were not, the loss there would likely have been some accounting for this in a reduction in net delivery figures for social rented homes in Newham. This loss of social rented homes would be addressed through higher targets for social rented homes within the overall target for homes. There is no case for taking more industrial land to deliver three times the number of homes lost with two thirds of them being market rather than social rented homes. 12. Are policies H1 to H7 a mix of housing types, affordable housing and housing for different population groups in general conformity with policies 3.8 and 3.9? No. (i) They don t address the accommodation of service families and custom build (Poicy 3.8 (j)) In addition the LLDC has the opportunity to be more innovative in the way that it addresses housing choice including providing encouragement for community based housing such as cooperatives and community land trusts. The development of St Clements Community Land Trust was supposed to be a pilot for a future CLT as part of the Olympic Legacy. CLTs are based on the idea of provision of housing that is affordable in perpetuity and since they also put back benefit into the wider community, there is a strong possibility that community infrastructure would also be delivered. These are choices that should not be overlooked in terms of grass root contributions to achieving positive outcomes from the Olympic Games Legacy. In the past the London Mayor made a number of positive comments on a CLT being delivered in Chobham Manor. What happened to this innovative idea? To be sound the LLDC Local Plan must include the choice of wider community based housing at least in policy H1 to include support for self-build, co-operative housing and community land trusts. (ii) They don t consider the need for supported housing. (iii) They don t adequately address provision of family housing as a strategic priority (see also response to q13)

3 Policy H1 provides for more than 50% of homes provided being two, three and more bedroom sizes. The London Plan defines family housing as three bedrooms or more. Policy H1 would be more effective and in conformity with the London Plan through specifying a target for family sized homes. The danger of the current emphasis on more than 50% of homes being two, three and more is that a greater number of two bedroom homes than is required would be delivered and delivery of family sized homes are not properly addressed. (iv) H2 target for affordable homes is inadequate. (v) Re Policy H3: The LLDC should adequately assess the need for older peoples housing and set targets through producing a SHMA. Until it has done this the Local Plan should include a proportionate figure of that assessed by the boroughs or the London Mayor. (vi) Policy H4 should seek to deliver an element of student accommodation that is affordable for students in the context of average incomes and rents for broadly comparable accommodation provided by London universities (para 3.53b London Pan (where there is not an undertaking with a specific HEI). Policy H4 or supporting text should specify what it means by negative impact in terms of balance of tenure and income in the locality and adverse amenity impacts. (vii) Policy H5 should acknowledge the full extent of Gypsy and Traveller accommodation needs and should identify specific sites. (viii) H.6 and H.7 both refer to affordable housing. Affordable housing is a specific planning term and should not be used in the context of private rented housing. The FALP set a specific definition of private housing which should be included in the LLDC Local Plan glossary. Bullet point 1 of Policy H.6 and H.7 should be removed and possibly replaced with maximising shared housing to accommodate needs of under 35 s who are unable to claim LHA for single person s accommodation (which is presumably what this bullet point is aimed at). How will local need for HMOs by identified? Perhaps this should be assessed in a LLDC SHMA?

4 13 and 14. In terms of choice of housing, these policies should also conform to London Plan policy 3.14 which support the maintenance and enhancement of the condition of London s existing homes and that it should promote efficient use of the existing stock by reducing the number of unfit and unsatisfactory dwellings. The LLDC s Local Plan does make some reference to this is paragraph 5.5 but there could either be an additional housing policy on existing housing or a policy on retrofitting as required by London Plan 5.4. The NPPF also says in paragraph 51 that local planning authorities should identity and bring back empty homes into residential use - in line with local housing and empty homes strategies. Is policy H1 consistent with the policies for constituent London Boroughs (eg LB Newham target for 39% family housing)? Does it adequately reflect the diversity of needs in East London identified in the SHMAs? Should policy H1 include more specific targets for different types of dwelling? The LLDC should carry out a SHMA to objectively assess need within its boundaries and should set a target date for doing this. A target should be set for family sized dwellings. In the absence of an LLDC SHMA it would seem that a target of at least 39% for family sized homes, as Newham suggests, would not be unreasonable. The E London SHMA assessed a need for 44% of homes to be family sized dwellings, Hackneys 2010 assessment was for few larger sized home (principally it seems in the market sector); Newham s 2010 assessment found need for 38% family sized homes, Tower Hamlets % family sized homes and Waltham Forest s 2011/12 assessment found need for 40% family sized homes. Targets should also be set according to tenure to take into account the greater need for affordable family sized homes. The need for affordable four-bedroom homes is high in this area and so targets should also address this. 17. There is a potential conflict between boosting housing supply to secure a maximum number of new units and achieving the optimum dwelling mix which will secure lifetime neighbourhoods? Does the Local Plan address this matter adequately? No. The following would help

5 Setting a higher target for affordable homes Including a policy on existing homes or retrofitting Setting targets for family sized homes and older peoples dwellings Having a policy on Lifetime Neighbourhoods or making adequate reference to policy 7.1 of the London Plan 18. Does Policy H2 conform to Policy 3.11 of the London Plan on affordable housing? No see The FALP sets a new target of 17,000 affordable homes which is 40% of the total London Plan target. An appropriate LLDC proportion of this would be 588 affordable homes per annum. The LLDC s 455 is only 31% of the total homes delivered. Their justification for suggesting this is 35% is inappropriate. The target should be at least 608 affordable homes per annum 588 (40% of the total London Plan target) + 25 additional per annum to make up for homes demolished to make way for the Olympic stadium. 19. The Housing Background Paper, TBP/04 explains the links between policy SP2 seeking a minimum of 455 affordable units pa, policy H2 which will maximise affordable housing provision on sites of 10 dwellings or more, and paragraph 5.13 which describes a minimum target of 35%. Should Policy H2 be more positive in seeking a specified level or percentage of affordable housing or is its wording justified by the need for some flexibility? Given the enormous backlog of need for housing in London particularly for affordable housing - 60,893 social-rented and 45,705 intermediate (Greater London SHMA 2013) there is a need to positively seek as much affordable housing as possible. This should be set out numerically as a proportionate London Plan figure and in percentages in policy H2 and SP2 (which should be amended). 20. Is there any evidence that affordable housing policy is no supported by robust and up-to-date evidence of viability? Is the reference to using 35% as a minimum to commence discussions justified? LB Tower Hamlets comments on this are interesting. Developers are consistently pushing down levels of affordable housing in schemes apparently on the basis of viability assessments; encouraged by the NPPF and NPPF guidance, when incredibly analysis carried out by the Bureau of Investigative Journalism showed in December 2014 that the country s biggest builders made 2.1 billion profits in 2014 a 34% jump over the year before.

6 Over the last year there have been various reports on East Wick and Sweetwater (1,500) homes of which 40% was to be affordable but, according Neale Coleman, is now likely to be around 30%. There has been a consistent drop in the total number of homes promised on thee the Olympic site as well as levels of affordable housing. The LDA s housing target in the 2004 outline permission was for 10,000 new homes. In a report to the London Assembly in 2005 it was said that 9,076 new homes were expected to be delivered 1 At that time the London Plan target for 50% affordable homes with a 70/30 split of social rented and intermediate homes. The 2010 masterplan proposed 8,000 homes. The Legacy Community Scheme outline approval in June 2012 was for five neighbourhoods totalling 6,800 homes with an affordable housing target of only 35%. East Village has 2,818 new homes, 1379 affordable (49%); Chobham Manor will provide 828 new homes of which only 28% of which will be affordable and social rented homes are no longer being delivered. There is a key problem in negotiations between developers and planning authorities are carried out in secret with no public scrutiny. Boroughs tend to argue that they don t have the expertise to carry out individual viability assessments or can t afford to employ someone to do this. Proposals: The LLDC is more likely, than any of the boroughs, to be able to (and should) employ someone to carry out individual viability assessments of sites and ensure that at above 40% affordable housing is delivered on all sites within the LLDC boundaries. There should be a strategic policy in the LLDC Local Plan on disposal of land. There should be serious considerations of engaging various community based organisations in conversations around delivering homes on sites where developers say they are unable to deliver (at a minimum) 40% affordable homes. The LLDC could hold onto the freehold of the land or hand it over to community based organisations to ensure homes affordable homes and delivered and remain affordable in 1 Report to the London Assembly %2Fwww.london.gov.uk%2Fmoderngov%2FData%2FLondon%2520Assembly%2520%2528Plenary%2529%2F %2FMinutes%2FWritten%2520answers%2520RTF.rtf&ei=1VHYVNaKIMfXaruFgrgK&usg=AFQjCNE5QMI WSgOynoYagf4JeSqnx_l_EA&bvm=bv ,d.d2s

7 perpetuity. Surely this is a once in a lifetime opportunity to be innovative in ensuring a legacy is delivered to the community rather than to developers. 21. Is there some inconsistently between the LLDC approach with 35% affordable housing, and a 60/40 split between affordable /social rent and intermediate housing, and that of the LB Tower Hamlets which seeks 50% affordable housing and 70/30 tenure split? What are the likely consequences of the differences? Will there be flexibility in the split between affordable types on individual sites? Hackney, Newham, Tower Hamlets and Waltham Forest all set 50% affordable housing targets. It is incredible that given the LLDC s dependence upon the borough s SHMAs that its target is 15% less that the four boroughs and indeed less than the London-wide target of 40%. 24. Should the Local Plan indicate that the provision of affordable workspace should offset the provision of affordable housing, as suggested by some representors? No. The London Plan gives clear direction and targets for delivering affordable housing which the LLDC should play its part in delivering this. 25. Is policy H3 in conformity with Policy 2.8 of the London Plan and the text which follows that policy? In allowing provision of new specialist older persons accommodation, is Policy H3 positive enough? Should there be more specific targets for positive planning and to aid monitoring? See written submission to q12 (v) 27. Is policy H4 in conformity with paragraphs 3.52 onwards of the London Plan and FALP? Could the policy give rise to over-provision of student accommodation with over-concentration resulting in adverse impacts on existing communities? See written response to q12 (vi). 28. Should the policy be more specific as to what over-concentration means, what adverse amenity impacts would be unacceptable and what amounts to affordable student provision? See written response to q12 (vi). 29. Is policy H5 consistent with Planning policy for traveller sites, March 201, DCLG? Has the Legacy Corporation: Carried out early and effective community engagement with settled and traveller communities in assembling the evidence base (Policy A);

8 Set pitch targets and identified a supply of specific sites deliverable for the first five years, and developable or as broad locations thereafter (Policy B); Set criteria which are fair and facilitate the traditional, nomadic life of travellers while respecting the interests of the settled community? If not, how can the deficiencies be remedied? The LLDC has not consulted with Gypsy and Traveller communities from all four growth Boroughs in conducting their accommodation needs assessment and only the needs of Hackney Travellers have been taken into account in the Plan. This approach is unsound because it fails to recognise the needs of communities which were in the LLDC area prior to the Games and were consequently displaced and the impact of the Games on Traveller communities in close proximity. A pitch target should be clearly included in the text of Policy H5 and as a monitoring indicator in the Delivery and Implementation section of the Plan. Policy H5 should clearly commit to the delivery of Bartrip Street South as a Travellers site in the next 5 years. The policy should include additional wording on how the LLDC will ensure the needs of Gypsies and Travellers in the area will be met beyond the first five years of the Plan. 31. Is policy H6, Houses in Multiple Occupation (HMO), out of line with LB Newham s policy which resists the conversion of family housing to HMO unless exceptional circumstances prevail? Does paragraph 5.28 imply a more restrictive approach to HMOs than Policy H6, amounting to a new policy rather than reasoned justification? Given the emphasis in policy 3.8 on the provision of family housing (as a strategic priority) the LB Newham policy around resisting the conversion of family housing to HMOs except in exceptional circumstances, should be supported. Policy H.6 is weaker. 33. Should the justification for seeking affordable housing when HMOs or private rented housing are provided be explained more fully or is paragraph 5.31 sufficient? 5.31 is not sufficient. The use of the term affordable housing as set out in the London Plan and glossary of the LLDC Local Plan is used inappropriately in policies H6 and H7 and text of See proposed word changes in response to q12 (vii) The LLDC might also include the FALP definition of the private rented sector which is quite specific around not including forms of affordable housing.

Examination - London Legacy Development Corporation Local Plan 2015 to 2031

Examination - London Legacy Development Corporation Local Plan 2015 to 2031 Inspector s Matters, Issues and Questions Matter 3: Housing Issues: Whether the Local Plan, notably section 5, is consistent