Wandsworth Local Plan Partial Review

The Battersea broadly welcomes the proposed changes to the Local Plan set out in the consultation draft, particularly those that aim to increase the amount of affordable housing. But we have reservations about some aspects of the proposals, especially those relating to housing mix.

Policy LP23 Affordable Housing

LP23 A. We welcome the proposal to maximise the delivery of affordable housing within the London Plan strategic target of 50% for all new homes. We also support the policy that 70% of affordable homes should be for social rent (thus not including the London Affordable Rent allowed for in the London Plan); and that for the remaining 30%, priority should be given to London Living Rent rather than shared ownership or other products, including Discounted Market Rents. We suggest that this priority should be stated in the policy itself, rather than being relegated to the supporting text.

We also support the tightening of the requirements for on-site, rather than off-site provision of affordable housing; and for developments to be tenure-blind (though Policy LP 23 A3 may need to include a reference to Policy LP 30 with its preference for a separate core for affordable housing).

While we support the new guard in policy LP23 A4 against the loss of affordable housing, we have reservations about the wording at the end of the first sentence. We suggest that it should read “the uplift in the number of social rented dwellings”.

LP23 C. We have reservations about the proposed charge of £50k per unit for developments on small sites of from one to nine units. We support the measures proposed in paragraph 17.13 to guard against any attempts to evade the threshold for major developments; but we are concerned that, combined with liabilities for CIL, this additional charge may risk failure to build housing on otherwise viable small sites.

LP23 D. We support the introduction of a Fast Track Route at an enhanced threshold (as compared with the London Plan) for developments providing 45% affordable housing and meeting the requirements of all relevant parts of LP 23. We have reservations, however, about the requirements for both early and late-stage reviews for those developments that provide between 45% and 50% affordable housing (where no such reviews are required for the latter).

LP23 E. We support the proposed use of the Viability Tested Route, but we believe that the final sentence concedes too much. We suggest it should read “to maximise the level of social rented housing to the level suggested by the viability testing”.

Policy LP24 Housing Mix

We are disappointed by the very minor changes to the indicative proportions of dwelling sizes, which we believe require much more significant change. To suggest that up to 30% of market housing, and 40-45% of affordable housing should be provided as one-bed units flies in the face of all evidence. The recent Housing Needs Assessment (HNA) indicates that more than 4,000 households are currently overcrowded in affordable housing, and many have been waiting several years for moves to larger dwellings. It also shows that both in the private rented and in the owner-occupied sectors, the largest increases in prices arise when residents move from two-bedroom to larger flats and houses. This indicates high demand for larger dwellings. And a core conclusion of the HNA is that “the highest need is for 2 and 3 bedrooms; approaching 70% of the overall affordable need is for 2 and 3-bedroom properties”.

Nothing in the HNA suggests that anything remotely approaching the minimum range proposed for one-bedroom dwellings - 20% for market housing and 30-35 for affordable housing - is required as a response to housing need. We must therefore urge that the indicative ranges for such dwellings be reduced to match the evidence presented in the HNA.

Moreover, we have strong reservations about both the HNA’s methodology and some of its conclusions, especially its focus on two-bedroom dwellings. This seems to derive from its finding that half of the increase in projected households between now and 2038 will derive from couples without children; but nearly half of that increase derives from couples over the age of 65, not from inward migration or household formation. Most couples in that age group will thus already be resident in dwellings in Wandsworth, rather than in need of new housing, unless they decide to downsize; and the evidence shows they have a marked reluctance to do so. Since the HNA suggests that fewer of them are leaving the borough than in the past, the overall supply of larger houses depends increasingly on their demise.

But the biggest problem with the HNA is its sole focus on need and demand (with a marked tendency to present the two as equivalent). It fails, like previous exercises, to acknowledge that supply and demand are inextricably linked. The result has been over many years policies promoting an over-supply of one-bedroom and two-bedroom dwellings, which attract the young adults who, as the HNA and much other data shows, come to the borough from elsewhere to live in such dwellings; but then move out when they need the larger dwellings with three or more bedrooms of which there is a restricted supply in the borough. This militates against creating and sustaining the mixed and balanced communities that are repeatedly claimed to be core aims for the Council. It is not easy to understand why the Council wishes to continue with policies on housing mix that contradict those aims. To repeat, the indicative proportions must be changed radically, away from any significant supply of one-bedroom dwellings, and towards more larger dwellings. If not, the revised Plan will fail the soundness test set out in the NPPF paragraph 36.

Policy LP 28. Purpose-Built Student Accommodation

We support the Council’s aim to restrict the provision of new student accommodation, for the reasons set out in in paragraph 17.42. We are concerned, however, that the requirement that new student accommodation should be provided only on sites that are not suitable for conventional housing may be too restrictive. The number of sites that might in principle be available for new student accommodation, but not suitable for conventional housing, must be very small indeed beyond the Roehampton University campus (see paragraph 17.45). We presume that for the purposes of this proposed requirement, ‘conventional housing’ means housing that meets the UN definition: rooms in a ‘permanent building or structurally- separated part thereof which, by the way it has been built, rebuilt or converted, is intended for habitation by one household’. We also suggest that the policy set out in the supporting text paragraph 17.44 should be included in the main policy statement.

We strongly support, however, the requirement in Policy LP28 A6, that priority should be given to the needs of first, recognised HEPs in Wandsworth, and then those in neighbouring authorities or within a practical travelling distance from Wandsworth.

Policy LP 29. Housing with Shared Facilities

We welcome the continued restrictions on new developments of large-scale purpose-built shared living accommodation; and we support the increase – as compared to London Plan Policy H16 A10 – in the cash contribution towards the provision of conventional housing. But the wording of the first sentence of Policy LP 29 D3 is obscure at best. We fail to understand what it might mean.

Policy LP 30. Build to Rent

We support the new requirements to make this policy consonant with Policy LP23. We also support the suggestion in paragraph 17.64 that the Council should resist the inclusion of Discounted Market Rent products among the affordable housing to be provided. We suggest that this should be included within the policy itself, rather than being relegated to the supporting text.

Policy LP 31. Housing for Vulnerable and Older People

We support the changes to the existing policy to make it compatible with Policy LP 23. We suggest, however, that the policy should make clear that the Council will support redevelopment of existing housing for vulnerable and older people that will provide enhanced and/or additional dwellings.