This post is a quick paste-up of material I prepared for yesterday when I was invited to participate as a guest in the Committee’s first consideration of the Further Alterations to the London Plan FALP. It is not exactly what I said because I wasn’t able to get all the points made, but there will be a webcast and perhaps a transcript later . Michael Bach from the London Forum was also a guest and he made many very strong and some overlapping points. I hope he’ll agree to his text going online too. Comprehensive summary in the Twitter stream of Myfanwy Taylor.
The Committee had prepared some questions (shown in bold).
Question to John Lett and Alan Benson. Other guests to be invited to comment.
1. Can you explain how the SHMA and SHLAA have been used to inform the evidence base for the proposed revisions to the London Plan?
The Plan (FALP) is fundamentally NOT based on the appropriate evidence so it is not compliant with the NPPF or good for London.
It’s as though we learned nothing from the credit crunch and are sleepwalking back into a house price bubble.
The reality is that the overwhelming need of most Londoners and of the London economy is for an end to escalating prices and rents, and the most serious crisis affects those with household incomes below the median of about £33k. The Plan and the SHMA disregards copious evidence from London Councils and independent bodies on what has happened since the 2011 base-date for the analysis. Furthermore—despite our argument in the Steering Group—the SHMA does not adequately separate out the affordability issues throughout the income distribution.
The emphasis should, on the evidence, be on using public money to maximise the stock and output of social rented housing. which – alone- can meet many people’s needs. The Mayor should also facilitate lower cost market output but not divert public money to this end.
There is a sleight of hand in the Mayor’s SHMA when it uses the term “social” to cover both housing at target / “capped” rents and the newly defined “affordable rents” and assumes that housing supplied at “affordable rents” will meet all the social housing needs. It won’t. Assembly was right to reject FALP and its should reject this.
Questions to John Lett and Alan Benson. Other guests to be invited to comment.
3. Can you explain why there is a 20,000 annual shortfall between projected housing need and the targets for new housing in the period 2015 to 2025?
– _How is this consistent with the NPPF requirement to use the evidence to ensure that the Plan meets the full, objectively assessed needs for market and affordable housing in the area?
4. Can you explain the significant variation in borough minimum housing targets between the existing Plan and the proposed Plan?
– _Why do some boroughs see an increase in excess of 70 per cent while others have allocations increased by only single digit percentages?
5. The targets are minima and boroughs are encouraged to augment these benchmarks through a variety of means where possible. If the Plan accepts there is scope for increased housing capacity, why is it not overtly forceful in setting more challenging targets? – Does this approach allow boroughs to evade their obligation to meet London’s housing need?
This is the wrong target (total dwellings): the important target is those dwellings which meet London’s most severe needs.
Much of what gets produced is, in effect, being “exported” or meeting low-priority needs. Re-phasing of backlog over 20 instead of 10 years further swings output towards market and prolongs misery for many.
Given the Mayor’s underspend last year and the falling levels of starts for affordable housing we can have little confidence…
Borough targets: many outer boroughs still being allowed to get away with low outputs; “mixed and balanced communities” does not apply to them.
The Mayor needs to take over large sites on which completions are disappointing and bring them to a rapid completion. Market will never do this. Greenwich Penninsula and many other slow sites.
Peter Eversden writes in his commentary for London Forum:
The FALP identifies (para 3.44) a requirement of 25,600 affordable homes a year. In paragraph 3.64 it is stated that “Affordable housing funding over the full term of this Plan is not known. Based on the funding that was available and the record of delivery of affordable homes over recent years, the housing need requirement and taking into account the housing supply target, an average of 17,000 additional affordable homes per annum has been set as the strategic target for the term of the Plan.”
That planned annual shortfall against need of social rented housing will be added to the earlier nine years’ shortfall of over 160,000 such homes. There are now fewer social rented homes in London than ten years ago yet the altered London Plan states that “There is significant clear priority need for affordable family homes.” and “There is a particular need for social/affordable rented family homes.”
Question to John Lett and Will McKee. Other guests to be invited to comment.
6. The Plan increases the potential for new jobs and homes in London’s opportunity areas by 16 per cent and 28 per cent respectively. How can you make sure these are provided with the full range of supporting infrastructure to make them sustainable places to live and work?
7. The Plan says that London’s expanding population is likely to give rise to significant demand for modern, more efficient forms of retailing. What would this retailing look like and how should planning encourage this?
Full engagement of surrounding communities in OAPFs is essential, with completions phased with social infrastructure. Local communities are best informed on the needs of their localities in the OAPF (planning) phase and need to be centrally involved throughout implementation to ensure that infrastructure and services do appear at the right times, that S106 agreements are implemented and so on.
Ensure no net loss of social rented housing in OAs as recommended by Panel 2011 REMA
Slippery words “modern and more efficient” cf Ward’s Corner, Queen’s Market, Peckham. The plan should build upon, not erase, the economies which have been developed in poor and mixed districts. (see also below)
Questions to Will McKee, Michael Edwards and Michael Bach.
8. How could the Plan be stronger in backing essential civic and community based services in town centres?
9. Given the moves toward providing more housing in some town centres, and managing the retail decline of others, how should the Plan be more protective of employment uses in outer London in order to make them more sustainable?
– _What is the position on Strategic Industrial Land, and how vulnerable is it in terms of the priority for higher density housing?
– _How might the Plan be more proactive in resisting loss of offices and retail to residential that the Government’s reforms to permitted development rights may precipitate?
Plan should give more emphasis to the independent retail and to the non-retail employment which predominates in and around town centres, to the non-sexy, low-GVA/worker. Laura Vaughan and Jessica Ferm at UCL Suzi Hall at LSE are doing excellent work on this; build regeneration on the diverse economies we have, not sweep these economies aside for new-build space which these businesses can’t afford.
Plans for comprehensive redevelopment of town centres with higher density has 3 snags:
(i) protecting/replacing affordable workspace in order to grow the local economy and in order to ensure services available locally (supporting Lifetime Neighbourhoods etc) and in order to reduce the need to travel;
(ii) failing to cap density, which can inflate land price expectations of buyers and sellers. The density matrix should be tightened up (with no exceptions) to ensure that densities are predictable. (Some debate on this and I agreed to write a memorandum about it.)
(iii) GLA Planners at presentations on the draft FALP explained that an important element of the high density, mixed-use, town centre renewal approach is dependent on delivery mechanisms yet to be drafted or tested. Strategy should not be based on assessments and mechanisms that are not available, scrutinised or proven.