Lewisham Green Party Response to Draft Lewisham Housing Strategy Lewisham Green Party welcomes the opportunity to comment on Homes for London: Draft Lewisham Housing Strategy 2015-2020. We feel that the Housing Strategy could be far more ambitious, and contain a sharper focus on how to tackle the challenging housing problems in Lewisham. The Green Party believes that providing genuinely affordable homes for everyone should be a key priority nationally, in London and in Lewisham. Sadly recent governments have neglected this, with policies that have resulted in housing being used too often as an investment opportunity. Rises in house prices and rents, reduced tenant rights and a lack of investment in publicly owned low rent housing has created insecurity, anxiety and homelessness for many ordinary Londoners. The Green Party wants to see clearer local and national policies to: increase public investment in building more not-for-profit and council housing, at rents that people can genuinely afford; introduce rent stabilization and greater security of tenure in the private rented sector, ending retaliatory evictions; replace the right to buy (which encourages financial exploitation of housing at the expense of those in need) with a right to rent, to help struggling home owners; make the tax system fairer, and better able to serve the common good, by discouraging speculative investment in housing; minimise the environmental impacts of new and existing housing. A Housing Strategy for Lewisham Lewisham Green Party supports some elements of the draft Housing Strategy, but believes the Council should be taking a much bolder approach, to rebalance Lewisham s housing market for the common good.
The introduction to the Strategy recognises the urgency of the crisis, and its root causes, but its objectives lack ambition in tackling these causes. The Strategy needs to place far greater emphasis on regulating and reducing the dominance of the Private Rented Sector, and making better use of existing Local Authority powers to support new social and not-for-profit housing models, to meet the long term housing needs of local people. While we support the thrust of the objectives and many of the subsidiary priorities in the strategy, its delivery requires more specific commitments to action. We consider the following to be the main priorities: 1. Introduction of a licensing scheme for the whole private rented sector, similar to that operating in Newham, as soon as possible to make sure landlords comply with current legislation. 2. Maximising the funds available (through planning agreements and borrowing) to build more council homes at affordable rents. The Council should use arms-length companies and other legal structures so that these homes are excluded from the right to buy. 3. Ensuring all new homes are carbon neutral, and built to high design standards. 4. Actively promoting and facilitating installation of solar panels in all existing housing properties (public and private) where roofs are suitable, particularly in housing whose construction (eg solid brick walls) limits cost effective wall insulation. 5. Making sure all new housing developments include adequate local public open space and private garden areas for childrens play and to support health, urban drainage and quality of life. 6. Actively identifying council and publicly owned land that that can be used for new council or other low rent non-profit making housing. 7. The Council should use their land to actively support alternative models to diversify the sources of housing supply in Lewisham, including through models like custom build and community land trusts. These can keep rents down and prevent the loss of low rent property through the right to buy. 8. Resources should be devoted to identifying empty properties and bringing them back into use (including through change of use) using compulsory purchase if
necessary to secure renovations. This should include more support and funds to community-led groups to do this, as Phases have done in Brockley, for example. But it should ensure that the GLA funded programme to bring empty flats above shops into use should not subsidise profitable well financed companies (as we understand has happened in the past). 9. Lewisham Homes should cease to be an arms length management organisation and the council housing brought back under direct democratic control. We would like to see more specific actions and defined measures throughout the Strategy, explaining how its objectives will be achieved. We give some suggestions about each Objective below. Objective 1: Helping residents at times of severe and urgent housing need Priorities 1, 2, 3, 6, and 9 in this section all appear to largely relate to the provision of advisory services, rather than addressing the real reasons why so many residents are in severe and urgent housing need. Housing advisory services are currently poor, and can do little to address needs if affordable accommodation does not exist. We welcome priorities 4 and 5, and agree that the Council should urgently invest in new and more appropriate models of temporary accommodation, instead of using costly and unsuitable Bed and Breakfast to house those in urgent need. However, we believe new models of temporary accommodation should be not-for-profit and Council-led, and not remain in the private rented sector (as is suggested on page 10 para 7). New models of temporary accommodation must also be linked to the development of more secure tenancies and long term social housing, as part of Objective 2. Priority 8, to offer options for supported housing to vulnerable households, is welcome - but weakly worded. We would like to see a clearer commitment to increasing the overall levels of supported housing for residents with specific health, care and support needs. This should be reinforced through relevant planning policies, partnership working with charitable and care organisations, and better negotiation of developers section 106 contributions linked to commitments in Objective 2. We welcome priority 10, to reduce rough sleeping to a minimum, but again we feel there need to be clearer commitments to working with homelessness charities and increasing social housing provision, to ensure long term solutions which tackle the root causes of homelessness. We understand the spending pressures the Council is currently under, but would like to see local funding levels for homeless charities and partnerships reinstated.
Page 11 paragraph 3 mentions the need to reduce overcrowding, but offers few solutions. The Trading Places scheme alone will be insufficient to address this growing problem. We would like to see the numbers of HMOs better controlled through local planning policy and all existing HMOs far more strictly licensed and regulated, to improve quality and reduce overcrowding. There could be far stronger use of planning policy to dis-incentivise further private landlords from endless subdivision of decent sized homes into HMOs, or the loss of gardens to rental extensions and beds in sheds. These create inhuman over-crowding, sub-standard living conditions, and the degradation of existing family housing stock with long term implications for health and quality of life for future residents. Page 11 paragraph 4 notes the massive reduction in available social rented properties in Lewisham since 2010, yet the Strategy makes no firm commitments to reversing this decline. We would like to see a Strategy which is more specific about targets to increase the number of social rented units, either through Lewisham Homes and Council-led new-build programmes, or by working with not-for-profit providers, residents and community land trusts to develop suitable land to fill this urgent gap. Key Objective 2: Building the homes our residents need We welcome this objective, and agree that the priorities are broadly right, but we believe these should be far more ambitious about the provision of higher proportions of genuinely affordable and social housing. Priorities 1 and 4 could include a far higher target figure for affordable housing delivery. The proposed 2,000 affordable homes represents less than a third of the projected new housing to be built in the next four years. This would mean that at least 4,400 new homes would be unaffordable. The introduction to the Strategy also evidences how the London definition of affordable housing is not actually affordable to the vast majority of Lewishams residents. Priority 4 could commit to introduce new measures to ensure a good proportion of new homes built for purchase or rent in Lewisham are genuinely affordable, and made available to households or individuals on salaries lower than 30,000. Priority 2 and 7 could be more ambitious about the number of new council houses to be built, and the speed at which these will be completed. Until a London-wide or national suspension of right to buy is in place (which risks new council houses being sold to private investors) we would like to see Lewisham Council explore setting up a new arms-length housing company to build and rent affordable homes without this risk. Other Councils have already demonstrated how this can provide an interim solution.
Priority 5 would benefit from specific commitments and targets to increase the provision of supported housing to meet the growing demand from those with care and support needs. Priority 8 relates to bringing empty properties into use. However, it is not explicit about how this will be achieved. We would like to see Lewisham being more proactive in using its existing powers and new discretions to maximize the collection of empty property tax, and discourage private landlords from allowing property to be left unoccupied. Priority 9 commits to driving up the quality of housing design and energy efficiency. This is welcome, but will require better implementation through Lewisham s planning policy and decision making if it is to be achieved. Greater emphasis needs placing on Lewisham s Residential Development Standards alongside energy efficiency standards like BREEAM and Code for Sustainable Homes before planning applications are approved. Priority 10 to pilot re-deployable housing is welcome, but should not delay the delivery of permanent solutions for vacant sites. Priorities 4 and 11, to make better use of the planning system, and support residents to commission or build their own affordable homes, is a key part of the solution to the current crisis. We would like to see the Council taking a far more active approach to supporting resident-led housing solutions, including the establishment of new Community Land Trusts on suitable publicly owned land to deliver at least 1,000 genuinely affordable, resident-designed housing units within the next four years. This model enables homes to remain truly affordable and resident owned/managed, in perpetuity. Priority 12 is unclear in its intention. Regeneration of town centres cannot be led by housing alone. Care should be taken to ensure that town centre and employment zones retain an appropriate focus on retail, employment, cultural and social facilities without which the economic regeneration of the whole area will be placed at risk. Key Objective 3: Greater security and quality for private renters Priorities 1, 2, 3, 4, 6 and 7 all relate to problems created by an unregulated and rapidly growing private rented sector, with increasing numbers of rogue landlords. Lewisham s regulation of this sector is currently weak compared with some other boroughs. There are currently relatively few fines or enforcement actions against poor landlords, and only a limited proportion of privately rented accommodation is being subjected to adequate checks. We strongly recommend that Lewisham speeds up its work to establish a compulsory registration scheme for all private landlords, and that the Council plays a
more active role in driving up quality and preventing overcrowding and dangerous conditions. Priorites 1-4, 6-7 could all be achieved more effectively through a universal and compulsory registration scheme for all private sector landlords. Newham Council has successfully introduced such a scheme, for example. The Council might also work more closely with HMRC to ensure private landlords are not avoiding paying income tax, and lobby government to make buy to rent less lucrative through urgent reforms of income tax offset rules and loopholes for landlords. Priority 5 references the Council s existing powers to set up its own housing company to deliver affordable housing and avoid right to buy risks. We have previously suggested this, and would welcome quicker action to take advantage of this option. Such a model offers far better value for money for the tax payer, and it the most effective way of maximizing the cross-subsidy options referenced in paragraph 1 on Page 17. Priority 9 refers to Lewisham Council s Private Sector Housing Agency which is able to lease homes from private landlords to meet urgent housing need. We believe this model is inadequate, and means taxpayers are still subsidising landlords profits unnecessarily. The establishment of a new not-for-profit housing company would be a more cost effective solution, as it would allow the outright purchase of private rented property, bringing this back into not-for-profit ownership to make up for the loss of so many Council homes. The PSHA also has a limited accreditation role at present. A local private landlord registration scheme offers options for far more consistent accreditation scheme, and enforcement of basic housing standards across all privately rented provision, instead of in a piecemeal fashion. We welcome the emphasis on improving tenants rights, and transparency around letting fees etc. A universal and compulsory registration scheme would be a more effective way of achieving this aim, and could also provide routes for tenants to report poor conditions or practices by private landlords with a degree of anonymity, and some possibility of enforcement action being taken. Lewisham Green Party would prefer to see clearer outcomes and aims associated with this objective, such as an overall reduction in the size and proportion of the Private Rented Sector in Lewisham, and an overall increase in the length and security of tenancies, and their affordability. Key objective 4: Promoting health and wellbeing by improving our residents homes We support this objective, but believe the proposed solutions could be more ambitious, and include greater detail about how the objective will be achieved.
For example, paragraph 3 on page 19 references the importance to health and well-being of improving the external space around housing. We welcome this, but would like to see a far more rigorous implementation of planning policy to achieve this objective. The current Residential Development Standards could be more consistently enforced to ensure all homes offer adequate light, privacy and green spaces between them. There is a well-documented trend in Lewisham for developers to cram new homes onto ever smaller plots, leading to the loss of gardens, good street layouts, outlook, drainage and light for future residents, with associated long term health and environmental impacts. Priority 2 proposes to extend the ALMO management agreement with Lewisham Homes to anticipate further improvements to housing quality. We believe the Council would achieve better value for money and more democratic control over its housing stock by bringing its management back under direct Council control, and budgeting for these improvements itself. Priority 4 commits to re-provide social or supported homes on other sites. This priority suggests that sites will be sold for profit where existing homes require significant investment. However, this approach risks the irreversible loss of publicly owned land in order to meet the immediate costs of re-provision elsewhere. This short-term approach will limit the Council s options to increase social and supported housing provision to meet growing demand in future. Priority 5 could include closer working with the energy companies to ensure Lewisham residents benefit from the Energy Company Obligation. We welcome the commitment in priority 6 and 7 to provide loans and grants for improvements to owner-occupied and private rented sectors, and to adapt properties to reduce risks, and ensure older residents can stay safely in their homes for longer. Many pensioners are owner-occupiers, but struggle to afford the cost of essential home improvements. This group must not be forgotten. ----------------------------- Finally, we wish to encourage Lewisham to work with other Councils to lobby and influence Government to address the root causes of the current housing affordability crisis. National reforms and legislative change are essential if we are to rebalance our housing market, and make housing affordable to Londoners again. For instance, Lewisham Council could support proposals by Generation Rent and other groups to improve rents and security in the private rented sector. The Council could also put pressure on the Government to abolish benefit sanctions which limit people's ability to pay for housing, in
addition to food and bills. We would also like to see more collective action to abolish the highly damaging Right to Buy introduced under Margaret Thatcher, but not reversed under subsequent governments.