Response by the Southwark Group of Tenants Organisations (SGTO)
1. About the SGTO
The Southwark Group of Tenants’ Organisations is an independent tenants’ federation that supports and campaigns for council tenants and leaseholders in the London Borough of Southwark.
As an organisation, we welcome the Mayor’s aspiration to increase the supply of all types of housing, particularly genuinely affordable housing for those whose needs are not met by the private market. We also welcome attempts to give small and medium builders the support they need to take a bigger role in delivering homes in London, and agree that much more needs to be done to protect and enhance the rights of those in the private rented sector.
However, we have deep concerns around the Strategy’s ability to deliver truly affordable housing for those on lower incomes and receiving benefits, and believe that there needs to be a greater focus on the part social rented housing has to play in meeting the capital’s housing needs. We comment on some of the specific points and policies below.
Another concern is the fact that this draft Housing Strategy has been published for consultation without having the Strategic Housing Market Assessment (SHMA), the Strategic Land Availability Assessment (SHLAA) and the Good Practice Guide to Estate Regeneration available until a week before the submission deadline. We believe that these documents are essential to prepare a proper response to the draft Strategy and feel that they should have been produced earlier in the process. The consultation period for this strategy should be extended to reflect this.
3. Building Homes for Londoners
Policy 3.1: Increasing the Supply of Land for New Homes
We agree that the more land should be provided for housing, but are worried that the draft Strategy risks paving the way for the loss of much-needed employment and industrial space in the capital, especially outside of the Central Activities Zone (CAZ). We are concerned that the draft strategy will lead to more public land being sold off to private developers, and used to deliver homes that are unaffordable to buy or rent for the vast majority of Londoners.
We also believe that any public land that is brought forward for housebuilding should be used to provide 100% public housing – that is, council or other social-rented housing. We think that this a reasonable aspiration, to ensure that public assets are utilised for the public good.
We recognise that private investment is necessary to deliver new homes at the scale London needs. However, we think that it is a much more prudent use of public money to invest in genuinely affordable and social rented housing, rather than to support access to finance and help ‘de-risk’ sites for private developers.
Policy 3.3: Diversifying the Homebuilding Industry
The Mayor is right to say that the housing market in London is too dependent on large developers whose model relies on homes for private sale. However, we are concerned that this strategy does not indicate any real movement away from this approach. We also notice that the Mayor’s London Development Panel features representatives of some of the country’s biggest homebuilders and developers, such as LendLease and Taylor Wimpey.
We do not share the same enthusiasm as the Mayor towards the Build to Rent sector. Whilst this product may provide housing for those on middle to high incomes, it offers little to people in the most acute housing need and we are concerned that developers will use Build to Rent as a way of getting out of their planning obligations to deliver affordable housing. The main beneficiaries of these schemes are investors, (many of whom offshore their profits and avoid paying any tax in the UK) and not local communities.
In our own borough, the design and construction flaws of system-built large panel buildings from the 1960s and ‘70s are still causing problems for residents today. The Mayor must ensure that any offsite homes are built to the highest design and safety standards and that no corners are cut in the rush to build homes.
4. Delivering Genuinely Affordable Homes
Policy 4.1: Genuinely Affordable Homes
The Mayor is right to say that rents up to 80% of market value are simply not affordable, and we welcome the attempt to provide a definition of ‘genuinely affordable’ that more closely corresponds to what different Londoners can afford. We also welcome the Mayor’s intention to refuse to authorise the conversion of social rented into higher rented ‘affordable’ homes – and think that social landlords who continue to do so should be penalised in their ability to access GLA funding.
However, we are deeply concerned that the needs of households with less than median incomes will not be met through the draft strategy. The Mayor’s new rent products, London Living Rent and London Affordable Rent, whilst an improvement on existing so-called ‘affordable’ rent products, still offer little to those on households with incomes of under £20,000 a year. According to Southwark Council’s own data, over 35,000 households in the borough would be unable to access London Affordable Rent.
We are concerned that the introduction of even more ‘affordable’ housing products further muddies the waters and further diverts resources from providing clearly and desperately needed social rented housing.
We support the aspiration of homeownership and recognise that a dysfunctional and inaccessible housing market puts this aspiration out of reach of people across London. However, the Mayor should be focussing public resources on supporting those people in the greatest housing need rather than subsidising homeownership and rents for Londoners on above-median incomes. The Mayor should also spearhead campaigning to have the national definition of ‘affordable’ scrapped and replaced with a more appropriate term.
We also feel that this ambition to secure genuinely affordable housing is undermined by the inclusion of ‘other discounted/ intermediate market rent (DMR/IMR) homes’ in the Mayor’s definition. This could allow developers to provide properties adhering to the government definition of ‘affordable’ (up to 80% of market rates) and still satisfy the Mayor’s policies. We want to see a clearer ‘maximum’ figure, based on local incomes, as to what constitutes genuinely affordable housing. This would provide clarity for both developers and for local communities.
Policy 4.2: Increasing Delivery of Affordable Homes
The Mayor’s deal to secure £3.15bn of central government funding for affordable housing is greatly welcomed. However, we are concerned that not enough of this funding is targeted at those in the greatest housing need. Again, we would wish to see a greater proportion targeted at delivering new social rented housing as opposed to delivering intermediate products and funding subsidies for home ownership.
Policy 4.3: Protecting London’s Affordable Homes
Social rented housing is the only affordable option for many Londoners, and with the cumulative impact of high rents, living costs and welfare reforms it remains the only way those on low incomes and on benefits can live in the capital. The Mayor should be taking a lead role in protecting and expanding this form of tenure and is right to be arguing the case to government for increased investment into quality public housing.
The requirement for like-for-like replacement of any affordable homes is a welcome and necessary aspiration. However, the lack of clarity in what constitutes ‘like-for-like’ leaves this requirement open to manipulation and we are concerned that this could result in the further loss of social rented housing. We would wish to see the sentence in paragraph 4.68 ‘This means that homes for social rent must be replaced with homes at similar levels’ with ‘This means that homes for social rent must be replaced with homes for social rent’.
We welcome the Mayor’s call for greater control by Councils over their right-to-buy receipts. With over a third of right-to-buy properties in the capital now being let in the private rental market, it is clear the policy has both decimated desperately needed affordable stock and has led to more and more families pushed into the unaffordability and insecurity of the private rented sector, pushing up housing benefit expenditure. We would wish to see the Mayor going further, and calling for a comprehensive review of right-to-buy in line with national Labour Party policy.
5. High Quality Homes and Inclusive Neighbourhoods
Policy 5.2: Meeting London’s Diverse Housing Needs
We are disappointed to see so little focus on meeting the housing needs of young Londoners. Young people across the capital are locked out of accessing sustainable housing on two fronts: both due to affordability and to policy restrictions which limit their access social housing and financial support through the benefits system. The Mayor should be exploring ways to help young people, especially those who are unable to afford to rent privately, access affordable and sustainable housing.
We also think more focus should be given to the delivery of family-sized homes and how the strategy can be used to tackle overcrowding. We would also like to see the Mayor work with boroughs and housing associations to develop local voids strategies and provide any necessary support and resources to bring empty social rented properties back into use.
We believe that the proposal to make housing provision a key part of the Mayor’s strategy for settling Syrian refugees should be reworded to include all refugees.
Policy 5.3: Community Support for Homebuilding
The Mayor’s recognition that residents’ voices must be at the heart of decision-making by councils and housing associations is also much welcomed. Too often it feels that decisions are made which affect the lives of tenants and residents but those affected have little to no say. We welcome any attempts to streamline access to the Housing Ombudsman, and to increase the effectiveness of the social housing regulator. We are happy with the idea of a Social Housing Commissioner and would be keen to support the Mayor’s lobbying efforts on this front.
However, one way in which the Mayor could really demonstrate support for resident involvement would be to give them a real say via legally binding ballots of all existing tenants and leaseholders who will be affected on any estate regeneration scheme. This would give residents real power over the future of their communities and is again is in line with national Labour Party policy.
We want to repeat what was said in our response to the draft Good Practice Guide to Estate Regeneration earlier this year – that any regeneration schemes must only go ahead with the support of the local community. We are concerned that the Good Practice Guide to Estate Regeneration has not yet been published, almost a year after consultation on the document closed.
It is good that the Mayor is considering ‘buy-to-leave’ investments and empty homes. However, we would want to see more clarity on what kind of changes to planning and taxation policy he thinks would be effective in reducing the number of properties left empty in the capital, particularly in central London. It is clear that current arrangements act as no disincentive to leaving properties empty.
We also believe that the Mayor should be looking at ways to resource and support borough tenants’ federations, in council, housing association and private housing as a way of promoting community engagement and giving tenants a greater voice.
6. A Fairer Deal for Private Renters and Leaseholders
Policy 6.1: Improving Standards for Private Renters
We welcome the Mayor’s attempts to better regulate the sector through licensing schemes and ‘naming and shaming’ rogue landlords. We also support the Mayor’s calls for greater assistance with upfront costs and support at local levels for private tenants.
6.2: Improving Affordability and Security for Private Renters
In Southwark, like all London boroughs, the gulf between private rents and the support available through the Local Housing Allowance means that the private rented sector is all but inaccessible for individuals and families on the lowest incomes. We welcome the sentiments to improve affordability and to work with boroughs to improve standards in the private rented sector.
However, we feel that the Mayor should be taking an approach in line with other city authorities such as Berlin and New York and lobbying for greater interventions to ensure affordability and security and to control rents in the private sector. Policy 6.2 says that the Mayor ‘supports measures that would limit unacceptable rent increases without limiting housing supply’ but the strategy offers little clarity on what those may be. The Mayor should be calling for more radical measures on rents and security of tenure to make what is an increasingly mainstream and long-term tenure work better for renters.
Policy 6.3: Reforming and Improving Leasehold
We support the Mayor’s aims to improve leasehold terms and to provide better information and support for leaseholders. We would wish to see local leaseholder organisations such as LAS2000 in Southwark involved in any work to improve and expand the provision of support and advice.