The London Plan 2011 is subject to proposed alterations. “Early” proposals and our response to them are the subject of this page. Later “Revised Early Minor Alterations” (REMA) are the subject of our later response – see our HOME page. Both sets of changes will be the subject of an Examination in Public in November 20102.
The Mayor has published proposed “Early minor alterations” which would re-define “affordable housing”. In December 2011 these were put out for consultation with the London Assembly, and there was a further ‘public’ consultation. The Just Space Network took the opportunity of making a submission at the first (December) stage because it is so important. The Mayor’s proposed changes are at http://www.london.gov.uk/publication/early-minor-alterations-london-plan
This is the submission Just Space made:
Just Space Network submission to the Early Minor Alterations to the London Plan (December 2011)
1. Just Space is a Pan-London network of tenants groups, amenity societies, equality groups, environmental campaigns and voluntary sector infrastructure organisations.
2. We object to the proposed alterations to affordable housing in Policies 3.8, 3.10 and 3.11 of the London Plan.
3. We object to the alterations to paragraphs 3.44, 3.61 and 3.66 which state that the new affordable rent product is aimed at the same target group as social rented housing. Affordable rented homes have rents up to 80% of market rents which is significantly higher than the target rents that apply to social rented housing.
4. We object to the alteration in Policy 3.11A, 3.11B and paragraphs 3.65 and 3.66 that combine social rent and affordable rent. The alteration undermines London Plan definitions of affordability that that explicitly relate to low income households.
5. Affordable rent could be treated as contributing to meeting the demand for intermediate housing, since affordable rent fits much more readily with the criteria for intermediate housing that housing costs are at 40% of net household income. Affordable rent does not meet the criteria for social rented housing for which housing costs should be no greater than 30% of net household income.
6. We also object to the alteration in Policy 3.11A and B since it sets a combined target for social rent and affordable rent without any assessment of housing need undertaken through a Strategic Market Housing Assessment (SHMA).
7. The most recent SHMA found evidence that 63% of new homes needed to be social rented and that a significant amount of this need could be met by living in private rented homes covered by housing benefit. This assumption has been undermined by the housing benefit changes and at the London Plan EiP 2010 it was acknowledged that a new study of housing need was required. Furthermore, the existing SHMA provides no information on how many households currently assessed as in need of social rented housing will be able to afford affordable rents.
8. We would argue that a case needs to be made for the uniqueness of London’s housing crisis. Simply inserting national policy into the London housing context, where market rents are almost double the national figure, will not address the needs of households who are in the bottom half of the population by income.
9. The change we are seeking is for the London Plan to set separate targets for social rented, intermediate and affordable rent and to monitor the delivery of each separately.