Partial Review of the Local Plan
The Battersea Society supports the three aims set out for the Partial Review of the Local Plan in relation to affordable housing, and we recognise the urgency that has led to the Review. But we would welcome the opportunity to discuss key aspects of all three aims together with the exploration of some topics not covered in this review. Our concerns cover:
50% affordable homes: Given government policy (reviewed at Appendix), we would welcome the opportunity to discuss with the Council the mechanisms it might use to fulfil its requirement. We should also welcome clarification on whether the requirement includes provision of affordable supported housing.
Housing Needs Assessment (HNA): this, which underpinned the policies in the current Wandsworth Local Plan, was itself based on evidence now many years out-of-date (notably the 2011 census). We should like to know what plans the Council has to update the HNA.
London Affordable Rent (LAR): We would welcome clarification on whether LAR would be included in the proposed social rent requirement. We would also welcome clarification on what intermediate products the Council might aim at, particularly in light of the Government’s requirement set in Planning Practice Guidance in 2021, that 25% of affordable homes delivered by developers should be First Homes for sale to first-time buyers at a discount of 30%. We believe that neither that scheme nor Discounted Market Rent can meet the needs of current and potential residents in Wandsworth; and that the requirement should therefore specify genuinely affordable housing such as London Living Rent.
Reducing the 10 homes threshold: we would welcome discussion with the Council on whether the sliding scale of contributions from developments on sites below the threshold of ‘capable of ten or more units’ adopted in the Local Plan for Richmond, or some other mechanism, might be the best approach in Wandsworth. This is set against the background of the small sites’ assumption in the Housing Needs Assessment in 2021 to provide 10% of new housing which the Local Plan increased to 20%. The London Plan allows boroughs to require affordable housing on such sites and we recognise the importance of so doing when such a high proportion of all new housing is expected to be on small sites.
Housing Mix, LP24: While we recognise that the scope of the Review is limited essentially to policy LP23 in the Local Plan approved in July, we regret that the opportunity has not been taken to review policy LP 24 on housing mix and we should like to discuss this. Housing Needs Assessments are highly sensitive to the assumptions made, not least those about the occupancy of housing stock. They also focus on a one-way relationship between demand and supply, failing to acknowledge that the relationship in fact works both ways: supply almost invariably has an impact on demand. The result is that the demand for small units, rather than housing for growing families, is significantly over-stated. Over-provision of small units has played a significant part in stimulating the high levels of inward and outward migration, especially by young adults, and this is incompatible with the Council’s aim to establish stable neighbourhoods and balanced, cohesive communities. We believe that the policy of focusing new housing provision, especially for the affordable housing sector, on one-bedroom and two-bedroom units is perverse.
Other issues: The information provided so far does not cover important issues covering:
• allowable levels of service charges for both social rent and other tenures;
• how the policies might apply to Build to Rent schemes, or more specialist developments such as Co-Living;
• the implications for estate redevelopments.
We would welcome clarification and further discussion on all these issues.
APPENDIX
Government and Local Plan Policies
We are aware of constraints arising both from Government policy and policies H2, H4, H5, H6 and H7 in the London Plan. We are also aware, however, that some LPAs have been able to produce evidence that has led both inspectors and the Secretary of State to approve Local Plans that include figures relating to affordable housing that go beyond those set in the NPPF, in Planning Practice Guidance, and in the London Plan.
Requirement for 50% affordable homes on-site
While the NPPF requires at least 10% of new homes to be affordable, the London Plan approved by the Secretary of State in 2021 sets a much higher target of 50%, to be met mainly by three mechanisms:
• The threshold approach, under which applications which provide a minimum of 35% affordable housing (50% on public or on industrial land) are not required to provide a viability assessment at application stage.
• Applications that do not meet the 35% threshold must follow a full viability assessment route under which an assessment must be provided at application stage, followed by one or more reviews.
• The provision of grants under the Affordable Homes Programme.
We are well aware of the difficulties in meeting any of the targets set to date. The most recent HNA showed affordable housing completions typically at around 300 a year, as against annual need of over 2,300. Completions have risen since the average of around 300 a year for 2011-2019 shown in the HNA, to around 500-600; this largely through the Council’s own Homes for Wandsworth programme. But this would therefore not nearly touch the need for over 2,300 affordable homes reported in the HNA; and we believe that the continuing cost-of-living and housing crises have increased the need since then. It is clear that the deficit in meeting the need for affordable housing is much higher in Wandsworth than in Richmond, which, alongside Islington, has set a minimum of 50% affordable housing in its Local Plan.
Both the Islington and Richmond Plans acknowledge the complications associated with viability assessments, and also the role of public subsidy (mainly via the Mayor’s Affordable Homes Programme) in meeting their expectations. We are also aware of the recent London Plan Guidance (LPG) on Affordable Housing and Viability, and of the importance of toolkits such as that associated with the LPG on Optimising Site Capacity.
A 70/30 split in favour of social rent
Policy H6 in the London Plan sets a minimum of 30% low-cost rent (including London Affordable Rent (LAR)), and 30% intermediate products, with the remaining 40% can be determined by the borough. We note also that under Policy H5, applications that do not meet the tenure split specified are subject to a full viability assessment.