I have to apologise for the length of this blog I thought it might be helpful to those engaged in providing evidence to the London Housing commission (before 12 October 2015). The Commission might find this evidence less than helpful to the particular questions being put by the IPPR; how to double the supply of housing, improve the balance between owning and renting and to raise the quality in the private rental sector. However, it can be seen from these submissions that, due to the systemic nature of housing provision, other factors have to be taken into account even while concentrating on the important questions for which the Commission was primarily set up to address.
London Housing Commission – Call for Evidence
1. Introduction
1.01
These comments are based on representations made on the
Mayor’s Draft Interim Housing Supplementary Planning Guidance. To some extent the Draft SPG appeared to be
leaving the same gaps as the introduction to this ‘call for evidence’.
1.02
This paper relates mainly to the specific areas of energy
efficiency and housing choice, matters that are not referred to in the briefing
but which are important components in the housing system. The Commission must
never lose sight of the fact that the provision of housing is a complex system. It would be futile and wasteful to introduce
changes into a system that cause friction or rebound effects. The Commission
should be looking for ways to create coherence out of confusion and to identify
measures that take advantage of the potential within the system to create
virtuous circles. The severity of the
housing crisis in London (and the South East) is such that effective
improvements are only likely to be achieved through locking in the cumulative
benefits or knock-on effects identified through this systemic approach.
1.03 It may be that the Commission finds the housing
system too complex and conflicted for
interventions to have any useful or lasting influence. In these circumstances the Commission could
and should identify relatively discrete sub-systems where some limited but real
progress could be made. Alternatively
there might be scope for creating new sub-systems, an example, as discussed in
this paper, could be a step change in the self/custom/group –
building/finishing – to include an element of co-housing.
2. Energy efficiency
2.01
The Government seems finally to have disposed with the Code
for Sustainable Homes – without devising any replacement. The Chancellor and Business Secretary have
now decided to also abandon the 2016 Zero Carbon Homes target. So long as sustainable development benefits
from the presumption in the NPPF, zero carbon housing should remain a part of
planning policy applicable to London through the boroughs or GLA/Mayorial
office. All housing proposals should be considered against NPPF para 94, the
Climate Change Act 2008 and the 4th Carbon Budget that requires a
50% reduction on carbon emissions by 2025 interpreted at of between 6% (by the
CCC) and 10% (Tyndall Inst) annual reductions.
Zero carbon housing implies terraced housing and apartments, taking
account of the southern aspect and potential for solar gain and PV generated
electricity. Developments should be expected
to fit into ta 6%-10% carbon reduction trajectory and in the words of an appeal
inspector seeking to apply the UN/Bruntdland definition (also in the NPPF) must
‘consume their own smoke’ (Ref 22169598).
Incidentally, in that case, the inspector logically found that CHS4 (that is a
higher standard than current Building Regulations) would have been inadequate,
and that orientation would be critical (ie maximising solar gain potential) to
a scheme before it could benefiit from the presumption in the NPPF.
2.02
The Commission could also support a preference for the use
of terraced housing or apartments on grounds of energy efficiency/affordable
living and restrictions on house extensions (ie conditions removing PD on new
housing) and possibly, “consequential improvements” which would relate to the
upgrade of existing housing if/when they are extended or even
re-furbished. “Allowable solutions” on
top of zero carbon houses could be required when the need for carbon negative
buildings becomes apparent ie when contributions from agriculture, transport, industry
and power generation to carbon reductions fall behind budget.
3. Housing Choice and under-occupation
3.01
There is a debate about the relative merits between “senior co-housing” and inter-generational
co-housing” that is academic in a country and city where neither is available. The
Commission should investigate the contributions that senior (in fact all forms
of) co-housing would make to sustainable development (esp addressing spiralling
health/care costs). The Older Women’s Co-housing Group took from 2000 to 2015
for the first resident to move on-site which is clearly unacceptable and could
be explained by the failure of the planning system to provide positive support.
Being neutral is not enough. Senior and inter-generational co-housing could be fundamental to providing attractive choices
for potential downsizers; what should be a major theme throughout the work of
the Commission. Eg see the work of HAPPI.
On this point it might be helpful for the Commission to include figures of the
scale of under-occupation from the 2011 Census. In round numbers there are about 2.5m spare
bedrooms and a shortage of 800k within the London area.
3.02
All the LPAs should now be keeping registers of potential
self/custom/group –builders/finishing (and co-housers would be simple but
useful bolt-on). These need some greater definition as some of these categories
should qualify as “affordable housing” and – until included as such in the
NPPF- could be offset in any negotiations on the affordable housing
contributions from particular sites. This would be consistent with the national
relaxation of 106/CIL liability for social housing.
3.03
Self/group - building would also be consistent with the
support for intermediate housing and equity share. The value of the building could be held by
the builder/finisher, while the land could be owned/shared by a Registered
Provider.
3.04
With the support of the Commission self/group – building and
the expectation that this could make a meaningful contribution to the required scale
of new dwellings but would also need a much more positive approach to the
supply of sites. This should be through a principle of the “reservation” of
part of sites for these purposes (ie 20% of any site of 5 or more
dwellings). Anything less than 20% would
not represent the increased scale of contribution wanted by central Government
or the 50% being achieved in other countries.
This approach would be the equivalent of plots being sold “off-plan” (a
well established concept understood and accepted by developers) and the area
reserved could also be serviced by the developer, the operation that
self/group-builders would find most difficult and would be sub-contracted in
most cases. The developer could provide
some other skills and materials as might be required. The principle of “reserving” parts of
allocated and permitted sites could also apply to co-housing so that those on
(and not yet on) registers could rely on a supply of sites in all areas (and
potentially give some real meaning to Lifetime Neighbourhoods).
3.05
The “reservation” would come with a time limit depending on
the size of the site – the development of larger sites normally having greater
flexibility. In fact co-housing schemes might not follow designs very different
from existing layouts, being predominantly of smaller dwellings with common-house
and guest accommodation that could be designed (and even built) to designs that
allowed sub-division into individual dwellings if no demand for co-housing
manifests within a reasonable period.
3.06
The current scale of provision of opportunities for self/group
– building/finishing and co-housing, requires
support from the LPAs under NPPF para 50.
3.07
Incidentally, co-housing is entirely compatible with the
provision of fewer parking spaces due to the intrinsic level of cooperation
between residents who would set up or join car-clubs.
3.08
The size/mix of housing should be controlled not just at the
original development but also through conditions in respect of extensions. Any larger dwelling should be designed to
minimise the cost of any subsequent sub-division in accordance with the
projected reductions in household size.
4. Summary
4.01
The Commission is being established to address the
challenges being faced by London in the near and longer term. The need to
reduce carbon reductions by over 6% per year is unprecedented and has only
occurred in war time or, briefly, in times of severe economic recession.
Neither provide helpful precedents or lessons for how this could be achieved in
a period of economic growth expected by the Government and GLA. A similar
discrepancy applies to the extreme problems of affordability, the lack numbers
being supplied and the lack of choice being delivered.
4.02
The Commission should include the measures of how all be
development would be made sustainable/resilient and also contribute to the
sustainability of the existing city housing stock and city/community
living. It is in this context that the terms
of reference seem to be lacking.
4.03
The Commission should liaise with the GLA and its review of
the housing SPG and ensure that both are compatible and strong enough to ensure
that the scale and affordability of new housing would be achieved (accounting
for the double whammy of accelerated rights to buy financed by council house
sales) and insufficient numbers of new dwellings. Affordable living (ie taking into account
heating and travel costs) is more important than affordable housing, and both
would be reduced by examples of self/group/building and co-housing.
