Introduction
Engagement with the Draft Alterations to the London Plan (Housing
Provision Targets) has been motivated by, firstly, housing
co-operatives' need to build permanent housing for the single
homeless and tenants of their short-life properties (a need borne
out by the findings of the GLA/Resource Information Service
report Silting up? A survey of London hostels about move-on
accommodation and support, April 2003); and, secondly, a need to
sustain access to short-life stock in the face of RSL and private
sector competition and the sale of local authority and RSL
properties at boom-inflated prices. In particular we point to the
barriers thrown up by the marketisation of the social and
intermediate housing sectors, and the prejudicial Housing
Corporation classifications which deny many smaller
co-operatives access to preferential finance available to their
competitors in the empty property and social/intermediate housing
markets.
MACE Housing Co-operative was founded in 1974 and became 'fully
mutual' in 1986. It is registered as a Friendly Society under the
Industrial and Provident Societies Act 1965. MACE now manages 102
properties and houses 218 people in eight London boroughs.
The co-operative is run on principles of self-determination
(non-intrusion) and self-management (autogestion), and
employs eight members of staff aided by a Management Committee
and issue-discussion fora drawn from its membership.
Co-operative (tenant-managed) housing needs more than affirmative
policy statements in the London Plan to maximise its potential.
In policy and provision of social housing, the single homeless
are routinely marginalised as low priority despite demographic
trends, while single persons are categorised as 'high risk' by
corporate finance institutions. 'Affordable' housing association
rents and options for shared ownership are too costly for those
on low or precarious incomes. There is no 'trickle down'.
On average, some 60 single 'non-priority' individuals contact
MACE to access accommodation every week. The Empty Homes Agency
states that there are 99,781 empty dwellings in the city, 43,000
of these in private hands (Mayor of London report Empty Homes in
London 2004). It is clear that, outside of the restrictive terms
of the London Plan's housing targets, there is extensive capacity
for the needs of the single homeless and other marginalised
persons to be met.
Matter 1 - Derivation of targets for additional
homes
Is there sufficient clarity and robustness in respect of the
derivation of the housing provision targets in Policy 3A1 and
Table 3A1?
(A) How much reliance can be placed on figures deriving from
the methodology of the 2004 Housing Capacity Study?
Draft Housing Alterations 3.15 In setting the monitoring
target to 2016/17, the Mayor has taken account of the
relationship between London and the rest of the south east, and
the Barker report on housing supply. [...]
- On March 15, 2006, The Guardian
newspaper published projections from the Department of
Communities and Local Government, (DCLG) of a significant rise in
single households by 2026 (Ashley Seager, Homes crisis feared as
households projected to rise by nearly a quarter). While the DCLG
expects the total number of households to rise by almost a
quarter over the next 20 years (from 20.9 million nationally in
2006 to a total of 25.7 million), a rise in single households is
expected to be the main driver in this expansion, accounting for
72% of annual housing growth. Out of an anticipated expansion of
209,000 households per year, 150,000 will comprise single
persons. The DCLG (echoing Shelter) put this acceleration down to
a rise in divorced persons and older persons living alone after
the death of a spouse. However, The Guardian article notes that
the vast majority (up to two thirds) of new single person
households will be among the over-35s. Sixty percent of the
expected rise is predicted to occur in London, the south east,
the south west and the east of England.
These figures were not available when aggregates in the London
Plan, the Draft Alterations, or its associate documents the 2004
Housing Capacity Study and the Housing, London Plan Supplementary
Planning Guidance, published November 2005, were being
calculated; MACE feels that there is a need for a reconsideration
of ratios and priorities in the housing sections of the London
Plan and in any future documents on housing capacity and
demand.
At a rough calculation, out of every 100 dwellings built, by the
DCLG figures, 36 should be affordable one bedroom units; by LDA
ratios itemised in Section 11.2 of the Supplementary Planning
Guidance, only 16.5 affordable dwellings out of 100 would have
one bedroom, 45% of that suggested by the DCLG projection. Again,
looking at dwellings built for market sale, by the DCLG figures,
out of every 100, 36 should be one bedroom units, whereas the LDA
targets stipulate only 12.5 (just over one third [34.7%] of that
implied by the DCLG). Total shortfall of one bedroom units within
the LDA's housing requirements amounts to 43%, a deficit of 6,046
units per annum of affordable housing, and of 7,306 units per
annum of single person units for market sale.
- Figures itemised in Table 18 of the
2004 London Housing Capacity Study are of limited value for
independent calculations as several of the boroughs listed
(especially those in East London which have a prominent
short-life stock) do not have the numbers of vacant dwellings
factored in. Also, figures quoted in Table 3A.1 of the Draft
Alterations to the London Plan
do not tally with those in Table 18 of the 2004 Housing Capacity
Study. Therefore we find your statement in item 3.9 of the Draft
Alterations, that "The GLA's new Housing Capacity Study
(published in July 2005) is the most comprehensive study of
London's housing capacity" rather puzzling.
- There is something inherently
dangerous in deriving targets from capacity rather than demand;
in any other circumstances, such a manoeuvre would produce a
formality of performance target achievement. A further problem is
that assessment of local housing need is referred by local
authority planning departments to their colleagues in housing who
reflex
to central government floor targets biased towards family and key
worker provision. RSLs also marginalise co-operatives and the
single person in their drive to meet government targets for
family and key worker housing.
- As the derivation of targets relies on
a suppression of demand, it is perhaps worth considering where
the tensions lie in single person provision. The DCLG News
Release 2006/0044, March 14 2006, 'More single households and
growth in the Midlands and North increase housing demand', refers
solely to home ownership when considering necessary aggregate
expansion to meet the rise in single households. We draw your
attention to our initial submission to the EIP process which
explores in some depth the structural pressures combining with
individual crisis that indicate a vast need for open-access
social and
rented-intermediate tenures. Such turbulence impacts heavily on
persons in the equality categories orienting the London Plan and
its supplementary documents.
In particular, polarisation of the labour market, around contract
(in)security (i.e. deregulation)
-- described as a 'southafricanisation' of society by Joachim
Hirsch -- indicates a marked trend towards underemployment and
casual or freelance working. Flexibilisation (or 'precarious
labour') afflicts particularly women, those in their 20s and 30s,
and those working in such sectors as diverse as creative and
media, business services and leisure, retail and entertainment,
all slated for growth in the London economy. This volatility will
intensify as 'flexisecurity' policies are unfurled across the
European Union (Gray, 2004).
Floor targets for the housing of key workers and larger families
may also work to marginalise the provision of single person
dwellings for the low-income tenant, as councils commandeer nomination rights to renovated
and new build space to meet their priority quotas. Co-operatives
now also face the negotiation of commercial lease fees with all
sections of the housing industry as private landlords and RSL
business plans demand immediate and profitable incomes.
The off-loading of fiscal crisis onto the tenant manifests in
high rents, bad housing,
waiting list discrimination, exclusion from emergency provision
and street homelessness, prospects reaching right through to old
age. New build discriminates against the poorer applicant, for
example, when intermediate rather than social housing rents are
offered, when only key workers may be housed, or with the
official promotion of part-mortgaged tenures. The market paradigm
restructuring affordable housing provision operates as a
differential mechanism with a pronounced centrifugal effect on
the single and those on low incomes. We have to ask: who will
house the single elderly person in 2025 with a lifetime
of precarious or underemployment, no secondary or private pension
and without
property capital?
Draft Housing Alterations 3.12 These targets are for
net additional homes, including additional dwellings provided
through development and redevelopment, and conversions from
residential and non-residential properties, together with long
term vacant properties brought back into use and household spaces
in new non self-contained accommodation. [...]
- The Mayor of London's report Empty
Homes in London 2004 states that as of April 2003 there were
99,781 empty residential properties in London, with an estimated
43,000 in private hands. This represents a
tremendous potential resource for short-life
co-operatives to sustain and expand their stock, particularly at
a time when housing associations are recalling property for sale
(this a response currently to the imperative of meeting Decent
Homes Standards in other properties by 2010).
However, despite the concerted efforts of the Empty Property
Agency, significant grant aid for private sector renewal schemes
by the London Housing Board, and central government intentions to
amend the legislative framework, few of these empty dwellings are
finding their way to short-life co-operatives.
Alex Savine, Group Leader (Policy & Research), for Newham
Council, reports that "In the past, the Council has sought to
work with short-life housing co-operatives. Recently, however,
owners anticipated rental income has undermined the viability of
short-life housing arrangements" (personal communication,
June 2, 2006).
Savine's comment provides an instance of a more general trend
raising MACE rents across the board -- a demand by landowners
(including RSL and local authorities) to provide an immediate and
profitable income from leased property through the negotiation of
commercial lease fees which capitalise on investment of public
funds by the co-operative. Private lease fees have risen by as
much as 400% since 1992 (compared to 4-5% of local authority
short-life agreements). The authors feel that local authority
support of landowner prerogative is based on a misinterpetation
of the Human Rights Act. We call for legislative controls to
limit the amount a landlord can charge for formerly empty
property to be put in place.
Supply chains implied by Jonathan Ellis, chief executive of the
Empty Property Agency, who writes in support of RSLs managing
empty home schemes for local authorities and promotes private
sector interest in refurbishing empty dwellings for rent,
escalate further this central block to the housing of those on
low incomes. One might also note that subsidy and preferential
loan arrangements are reserved to RSLs and the private sector
themselves, monies to which co-operatives generally have no
access.
The authors feel that Mayoral actions are also effecting a
marginalisation of housing
co-operatives from access to the capital's vacant stock. We
request that representatives of London's co-operatives are
invited to the annual Empty Homes event, and are invited to
discussion on barriers to co-operative housing with the Empty
Homes Agency. It would be
a savage irony if short-life housing co-operatives, long the
primary users of empty space, are forced out of action by local
and London government empty property work which, notably, seeks
to replicate their operations.
(B) How sound are the judgements that have led to targets
higher or lower than the capacity identified in the Housing
Capacity Study?
- The authors feel that the capacity for
single person dwellings -- especially short-life and private
sector lease -- is far greater than the London Plan targets allow
for, although we acknowledge that many of the empty dwellings,
particularly those held by the private sector, will be more
suitable for shared housing and family accommodation on account
of the size and original layout of the properties. The boundary
between family accommodation and shared non self-contained
dwellings has been left open, and we are concerned that the
single person will be forgotten in the process of local
authorities scrambling to meet targets for family and key worker
housing.
- Landlord prerogative (the maximisation
of commercial income) will inflict financial barriers for lower
income families and deny them access to these appropriate (albeit
temporary) dwellings. The authors feel that the Empty Property
Agency and the Mayor of London need to bear this in mind when
lobbying the DCLG and Housing Corporation. Without a counter to
the maximisation of income on empty property, this significant
'addition' to residential stock will, as usual in housing policy,
benefit the more wealthy.
- A 'familist' discourse (the
propagation of politically pro-family ideas and the notional
strengthening of families themselves, Barrett & McIntosh, 1982, p
26) obscures the differing needs of diverse family households,
including disparities of wealth, and the extended relations of
some minority ethnic households. Popular rhetoric around housing
targets and urban form suffer from an acute 'familialisation'
(ibid), that is, a recourse to ideologies modelled on values
perceived to be those of the family.
MACE itself notes a bias in housing association thinking toward
servicing the needs of families housed within their stock, not
realising that, for instance, crisis within the family often
rests on the lack of housing provision for adult children or
elderly relatives, something particularly prominent in Asian and
African households (but with wider import), and something that
co-operatives are well placed to help sort out.
Matter 3 - The impact of the proposed targets for housing
provision on other policy areas
In the identification of housing targets has sufficient
attention been given to the impact on other housing policies and
on the availability of land for other uses?
(A) How should the Draft Alterations have regard to the
implications of revised housing targets for the provision of
affordable housing and for the delivery of an appropriate mix of
housing types and sizes?
- The Spatial Development Strategy
provides a highly sympathetic environment for housing
co-operatives, but there is a radical disjuncture between the
statement of objectives in the London Plan and conditions that
London's housing co-operatives face in accessing finance and
prospective stock, despite fulfilling London Plan sustainability
criteria and several of the Mayor's personal objectives set out
at the start of the document. Two other documents elide the
institutional barriers inhibiting non-profit (but non-RSL)
co-operative participation; these documents discuss both empty
property and mutual housing models in a framework that might be
described as 'hegemony of the market plus coercion'. One
document, Community Land Trusts & Mutual Housing Models, laced
with communitarian justifications and with an emphasis on mutual
ownership and equity stakes, makes no attempt to engage in
dialogue with London's short-life or even permanent
co-operatives. The report Empty Homes in London 2004 is addressed
in some detail under Matter 1. However, this document too
provides little hope for non-RSL providers.
- The Mayor and his staff at the London
Development Agency should pay due regard to the funding of new
build and empty property refurbishment. Many housing
co-operatives, particularly in east London, are not registered
with the Housing Corporation and thus unable to access finance on
the capital market without an RSL partner, and are neither
eligible for RSL-earmarked grants, the significant central
government subsidy available to RSLs, nor preferential loan
agreements. This is a major factor preventing co-operatives from
embarking on new build permanent accommodation or renovation
programmes of empty property.
- MACE feels that there is institutional
discrimination against co-operatives within the Housing
Corporation, and against the single person with no capital in the
social and intermediate housing sectors. Social housing providers
appear to regard the single homeless as morally reprehensible (a
reflection of housing priority categories which cater for those
using drugs or suffering alcohol problems). There appears also to
be an assumption within the Housing Corporation that somehow
co-operatives are not well managed. Institutions right through to
local authorities lack a knowledge of how co-operatives work and
the calibre of individuals (especially professional housing
management staff) that they can draw on. Tenant-only management
committees are regarded as an anomaly and, paradoxically, as lacking
transparency.
Caps on housing benefit discriminate against non-RSL non-profit
providers and their tenants (RSLs can charge what rents they
want) and shortfalls squeeze tenants to an extreme of existence.
Local authority rent officer determinations have not kept pace
with the commercial turn of the empty property industry. In March
2008, tenants will face the imposition of the Local Housing
Allowance (LHA) as a replacement for Housing Benefit. The LHA has
been piloted already in nine local authority areas on those with
private tenancies. The September 2005 issue of Roof magazine
quotes one 'pathfinder' area, Conwy, where the average proportion
of properties affordable at LHA rates was below 10%. While
short-life housing (leased from local authorities and housing associations) is still relatively cheap, properties sourced
under private-sector lease agreements compel near market rent
levels. We are deeply worried about the restrictive effects of
the LHA on the
long-term ability of our members to be able to afford their
(already minimal) accommodation. MACE urges the Mayor of London
to lobby the DCLG for a complete cancellation of the Local
Housing Allowance.
- Leah Watkins' report Silting up? A
survey of London hostels about move-on accommodation and support,
April 2003, indicates a significant shortage of independent
permanent accommodation (i.e. with no or low support) to relocate
those in hostels or other temporary housing. The 136 projects
contacted during the survey (with a total of 6,382 bed spaces)
reported a current shortage of 1,930 move-on bed spaces. The
report calculates that this means that 30% of people currently in
temporary accommodation are simply waiting for
a suitable transfer to become available. 84% of the shortage is
for permanent accommodation, 75.3% are persons waiting for
permanent accommodation with low or no support.
Boroughs have different resources to draw on and varying
procedures of dealing with the single homeless. Testimony of at
least one MACE tenant, however, has revealed that
non-priority persons in Camden Council temporary accommodation
may face the continual prospect of an imminent return to street
homelessness when in contact with the local rota of night
shelters and when staying in temporary hostels. In the latter,
the homeless person faced a bailiff eviction after a one month
stay (deemed after this month to be 'ordinarily homeless' and
therefore no longer the council's responsibility) if he was
unable himself to access suitable move-on provision, and this
after a lengthy period of rough sleeping and night shelter
habitation. Experience in Hackney notes a refusal of emergency
housing to non-British nationals and the institutionalisation of
rough sleeping into emergency housing procedures (an individual
must be spotted three times on the street to gain access to a
shelter, this criteria is being applied even to young women).
Other shelters across London charge the homeless exorbitant
rates.
The Watkins report notes that refugees and asylum seekers are
deemed to be the hardest to house from temporary accommodation;
most move-on provision is earmarked for persons specifically with
drug or alcohol dependencies.
Such a deficit is compounded by local authority lettings
policies. These include the
ring-fencing of one bedroom flats for couples (single persons
reduced to studio accommodation, very restricted) and the
exclusionary grading of priority, which works to marginalise
single persons, including those with psychiatric illness (in
Hackney, applicants
in the 'Reserve' category are told that they will never be
housed).
Silting up? estimates that there will be a future move-on
accommodation requirement of 73% (of all those in temporary
housing) with no or low support (demand was 69% in 2002).
With a cap on commercial lease fees demanded by speculative empty
property owners, and access to RSL preferential funding, the vast
reserves of empty dwellings in London could be brought into play
to help meet this urgent demand. Co-operatives with experience of
managing short-life and other lease agreements on formerly empty
property have the expertise that could make such an operation
viable. MACE cautions against the institutionalisation of supply
chains via RSLs or private sector companies as this would push
rent levels up beyond the local authority thresholds of housing
benefit payment and push accommodation further out of reach of
those on low incomes.
MACE's comments on floor targets can be found in item
1.A.4.
(B) Has sufficient regard been paid to the impact of the
housing targets on urban character?
The principle of self-determination in
co-operative housing, and high density space requirements of the
single person, fit well into the compact city model proposed in
the London Plan.
(C) To what extent could delivery of the housing targets
impact on the resolution of the competing demands for land,
including employment uses and waste facilities?
- The commercialisation of the empty
property industry is partially addressed in item 1.A.5.
In a climate of increasing competition and higher prices accorded
to empty space, non-profit housing co-operatives are forced to
operate at a disadvantage in competition for land and dwellings
with both RSLs and the private sector, or suffer the escalating
costs of supply chain management and commercial leasing.
Allocation of land is via the market mechanism. What is needed
are local land and property banks valued outside of a market
paradigm for social and intermediate housing providers to draw
on. The GLA commissioned a report on this very issue (Community
Land Trusts and Mutual Housing Models, November 2004). However,
quite the opposite appears to be happening on the ground. The
writers of the Community Land Trust report seem in any case more
interested in what they term Mutual Home Ownership, i.e.
part-mortgaged tenures in
a co-operative management context, with gifted or discounted land
held outside of private ownership. The report appears largely
ideological. The writers exhibit no interest in housing
co-operatives that do not conform to a US model, and do not
engage in dialogue with London
co-operatives on contemporary or projected circumstance, as one
might expect in a strategic document.
The millennial building boom has produced tight competition for
infil sites (local authority land coming up for public auction
locally to much speculative interest) and escalating land
inflation in London's inner boroughs. As mentioned above, private
sector operators and RSLs are being encouraged by the GLAs Empty
Homes Agency to work closely with local authorities to get a
slice of the empty property cake; co-operatives meanwhile are
being marginalised by landlord 'expected income'.
The market determines who builds, but even here the playing field
is skewed against
co-operative developments as both RSLs and the private sector are
eligible for London Housing Board grants to refurbish empty
property, while RSLs receive majority subsidy
(85-95%) from central government funds and preferential finance
terms on the capital market.
The GLA's Spatial Development Strategy and Economic Development
Strategy both provide a sympathetic regulatory context for
housing co-operatives, but assert that "Approaches which work
with the grain of the market are most likely to be
successful". Put baldly, this will force out both
co-operatives and the single person.
- Regarding the release of employment
land for residential use, the authors feel that the scale of
vacant dwellings reported in Empty Homes in London 2004 proves
that there is little need to encroach on marginal space set aside
for small and micro firms, or for non-residential space in
shopping centres.
(D) Do the Draft Alterations raise issues that need to be
considered in the full Review of the
London Plan?
Draft Housing Alterations 3.14a The delivery of these
targets is dependent on adequate funding for transport
infrastructure, social infrastructure and affordable housing.
This funding should ensure that development is sustainable and
provides an appropriate mix of provision in terms of type and
affordability. [...] Delivery will also be affected by market
factors. [...]
Rather than iterate an assumed
consensus, perhaps the London Plan could address the barriers
that prohibit housing meeting the needs of those on precarious or
low incomes and benefits, and the procedural closures of local
authority rough sleeping services (see 3.A.4). While there are
certain measures the London Plan might promote, the authors of
the MACE submission call for political action to circumvent the
market paradigm which raises prices beyond the threshold that
housing co-operatives can reasonably charge for rent (and tenants
on benefit pay), and the regulatory enclosures that marginalise
housing co-operatives from development finance.
- We urge the Mayor to accord a higher priority in
social housing ratios of the London Plan to London's single
residents, and to provide for the diverse emergencies that bring
people within the reach of social housing and crisis
institutions.
- Possible measures to aid co-operatives utilise the
vast stock of vacant dwellings to refurbish and provide move-on
accommodation for those in temporary hostels, and for those on
low incomes or benefits, include (i) ring-fencing quotas of empty
property for the non-profit sector, (ii) legislative controls to
curb lease fee maximisation by owners of empty property (to take
the profit motive out of negotiations), and (iii) an equalisation
of financial arrangements for renovation as well as loans to buy
land for development and finance construction.
- We would ask the Mayor of London to lobby councils
and housing associations for more favourable rates to housing
co-operatives in both statutory lease negotiations and market
sale, and for the inclusion of co-operatives in housing
association development plans and local authority empty property
work. We would also request the invitation of representatives
from London's housing co-operatives to the GLA's own empty
property events.
- We request that the Mayor lobby the Housing
Corporation to register housing
co-operatives as social landlords, and to lobby local authorities
to support such applications. RSL status will enable us to level
the playing field in access to development finance and government
subsidy for permanent housing for the single
homeless.
- We would also request that the Mayor lobby the
Treasury to guarantee any loan provided by financiers to housing
co-operatives for the development of permanent homes for the
single person (a principle defined during the Thatcher
administration to aid small businesses with no collateral). We
would also welcome support in approaching pension funds and
ethical fund managers for investment in social housing, and for a
Treasury mandate of a quota percentage of pension fund investment
for co-operative social housing, including that of the single
person. Properties developed would become collateral investment
for pension funds, sub-leased to housing co-operatives who would
then manage them.
- We request investigation of the viability of local
land and property banks (or a Londonwide variant) for non-profit
housing providers, outside of the market paradigm.
- We would welcome coordination by the LDA of a
Londonwide consortium to tackle single person housing (a
modification of your proposal in the East London Sub Regional
Development Framework).
- We request special action from the Mayor of London
to ensure that if a housing
co-operative builds dwellings for its members' long-term benefit,
that they retain the right to allocate this space to their
existing tenants or from their own waiting lists, without
intrusion from the local authority. This should also apply to any
short-life, private sector lease or emergency accommodation that
co-operatives seek to provide.
- Local authority deposit guarantee schemes should
be available on a wider basis to aid anyone on the edge of crisis
and to rescue those institutionalised as homeless (or 'receiving
housing advice', an institutional euphemism for the new rough
sleeper) by local authority procedures designed to discharge
responsibility for the single homeless rather than house
them.
- MACE also urges the Mayor of London to lobby the
DCLG for a complete cancellation of the proposed Local Housing
Allowance.
Rowland Ekperi and Carolyn Smith, June 8, 2006
Bibliography
Barrett, M. and M. McIntosh (1982) The Anti-social Family
(London) Verso
DCLG News release 2006/0044 More single households and growth in
the Midlands and North increase housing demand,
Dear, M. and A. J. Scott (eds)(1981) Urbanization and Urban
Planning in Capitalist Society (London) Methuen
Gray, A. (2004) Unsocial Europe, Social Protection or
Flexploitation? (London) Pluto Press
Hirsch, J. (1981) 'The apparatus of the State, the reproduction
of capital and urban conflicts' in M. Dear and A. J. Scott (eds)
Urbanisation and Urban Planning in Capitalist Society
(London) Methuen
Mayor of London (2005) 2004 London Housing Capacity Study
(London) GLA
------- (2004) Community Land Trusts & Mutual Housing Models
(London) GLA
------- (2005) Draft Alterations to the London Plan (Spatial
Development Strategy for Greater London) Housing Provision
Targets Waste and Minerals (London) GLA
------- (undated, presumed 2004 or 2005) Sustaining success.
Developing London's Economy, Economic Development Strategy
(London) LDA
------- (2004) Empty Homes in London 2005 (London)
GLA
------- (2005) Housing. The London Plan Supplementary Planning
Guidance (London) GLA
------- (2005) The London Plan, DRAFT Sub Regional Development
Framework East London (London) GLA
------- (2004) The London Plan. Spatial Development Strategy
for Greater London (London) GLA
Roof magazine, September/October 2005
Seager, A. (2006) Homes crisis feared as households projected to
rise by nearly a quarter, The Guardian, March 15
Watkins, L. (2003) Silting up? A survey of London hostels
about move-on accommodation and support (London) GLA &
Resource Information Service
|