Camden Federation of Tenants and Residents Associations
CFTRA Response to the Draft replacement London Plan 12 jan 2010
We represent council tenant and leaseholders in Camden.
How planning and development policy is carried out on major sites in Camden including the Kings Cross and Euston railway lands, and on MRC land behind the British Library and National Temperance Hospital. will make a big difference to tenants in Camden, to our children and our future. There are already over 18,000 households on housing waiting lists, and rising overcrowding and other housing need.
We believe that future redevelopment in London must
a) place a higher value on the quality of life for all (including social and environmental impacts) rather than simply the economics of building and development
b) Help create more economic diversity and less reliance on the financial and business services sector
c) Ensure less waste and more careful and carbon-considered use of resources
d) Insist on meaningful community consultation and involvement in decisions on redevelopment.
Affordable housing: Camden’s record
Total net affordable new affordable housing as % of total (all conventional completions: tenures)
2005/6 81 13%
06/7 228 46%
07/8 75 (of which 46 ‘intermediate’;
29 ‘social’) 20%
3 yr total = 384 25%
(from London Plan Monitoring Report http://www.london.gov.uk/mayor/publications/2009/docs/monitoring_report5-2.pdf
To deliver an improved standard of living the London Plan must implement binding targets for the delivery of genuinely affordable and secure housing that addresses the needs of the growing numbers on London council housing waiting lists, the majority of whom cannot afford or don’t want to buy and for whom ‘intermediate’ housing (shared ownership or higher-rent) is too costly and does not offer security.
The housing market is failing to meet the housing need of Londoners, with rising numbers of repossessions and vacant private homes, a failure to build genuinely affordable and family sized homes, and the dire lack of security for private renting tenants in particular. In these circumstances we oppose the 20% reduction in targets for ‘affordable’ homes and believe this must be challenged. Boroughs must not be allowed to set lower targets for ‘affordable’ housing.
More council housing is needed in inner and outer London. The GLA must use clear targets and quotas for developers and boroughs, to urgently deliver the genuinely affordable housing for rent for those who need it most. Boroughs must match housing delivery (totals, tenure and size) to local need. The Plan should remove the get-out clause that allows developers to plead financial distress as a reason not to provide the housing that is needed. Boroughs should not exceed maximum housing density targets. Minimum space standards for new housing development are welcomed.
Housing Tenure mixing:
Council housing is historically concentrated in some areas, but remains in desperately short supply. The remaining supply is under continuing pressure from the right to buy, from stock transfer and (in some cases) from demolition to make way for new building in other tenures. Even worse, it is sometimes argued that less social rented housing should be included in new building in such areas on the grounds that this tenure is somehow ‘over-represented’ in the area. Exactly this argument was used by Camden Council and developers Argent in the recent Triangle Site public inquiry.
In Camden the situation is made worse by the current practise of direct sale at auction of much-needed council homes to property developers, at less than their value. This creates nothing less than gentrification of certain areas; the opposite of what is needed. It is even more bizarre when one considers that many of these homes were acquired by the Council in the late 1960s and ‘70s and helped create mixed communities – these properties provided homes to generations of families, but are now being sold despite an 18,000 waiting list. We are aware that this is happening in other parts of London. This loss of genuinely affordable, democratically accountable and secure rented housing is therefore becoming a London-wide issue which the London Plan needs to address. Monitoring should record the loss of council and RSL homes for rent, and policies should discourage or prevent this when it mitigates against meeting local housing need.
There may be some merit in the introduction of some social rental housing in solidly owner-occupied areas (though the London Plan sees no need to plan for this). Until better means can be found, it remains essential to oblige developers of private housing schemes to build homes for council or RSL renting. But in areas like ours the call for the insertion of other tenures threatens the supply of much-needed genuinely-affordable rented housing and as condescending. It is often based on stereotypes in which it is assumed that council tenants are idle folk who need role models, weak organisers who would benefit from more educated community leaders and so on. It is an insult. There is no evidence base to support it.
We propose that at least [Policy 3.10] subsection B [A more balanced mix of tenures should be sought particularly in neighbourhoods where social renting predominates] be simply deleted. We further propose that the entire policy should be deleted pending research which might form the basis for an evidence-based replacement. Many consequential adjustments would be needed in other parts of the Plan.
Other issues of concern:
Reducing carbon emissions
.All new developments need to meet higher environmental targets. More interim targets between now and 2025 are needed to ensure London is on track to reducing its carbon emissions. ‘Retro-fitting’ our homes would make a significant impact on energy use and should be prioritized; London Housing budgets should be directed to retro-fitting council, housing association and private rented homes, with landlords providing match funding.
Housing and Employment Targets
Housing and employment targets should be subject to local consultation and critical analysis. Targets for areas not yet finalised (including Euston) should be the subject of full local consultation before they are embodied in the London Plan.’
“Regeneration” should be defined to mean that local communities can sustain and reproduce themselves. Our experience of large and small scale ‘regeneration’ schemes in Camden, including to the Kings Cross Railway Lands, is that much regeneration has failed by this definition. The London Plan needs to ensure that publicly-subsidised redevelopment on sites including publicly owned or purchased land, is regulated to ensure primary benefits to the majority of Londoners, and in particular to those originally living and working in or adjacent to these areas.
In our experience the “regeneration” practiced in London produces few benefits and often adverse effects for the majority of Londoners, and in particular for those living on or below the average income (£24,000). We object to the policies as currently phrased and propose changes as follows:
‘Policy 2.13 A (add new sub-section c) [The Mayor will..] Consent to development only when it has been shown that established populations living in and around the areas will benefit and will not be subject to displacement or displacement pressures except where there is full mitigation.
The Plan states the location of tall buildings is permissible within Opportunity Areas, Regeneration Areas, the Central Area Zone, Areas of Intensification and Town Centres. The negative social and economic impacts, or again the so-called ‘regeneration’ aspect of these buildings, and the environments they create around them, also needs to be considered.
FUNDING AND DECISION-MAKING IN LONDON
For the improvement of London for all, the GLA / the London Plan must
a) recognise the need for more power for local communities to make decisions
b) hold borough councils to democratically and locally-agreed targets.
Camden Federation of Tenants and Residents Associations