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Consultation response to Mayor of London's draft housing strategy

Author: Susie Dye

High housing costs are one of the biggest drivers of poverty in the capital. We therefore welcome the Mayor’s draft London Housing Strategy, and particularly the recognition of the need for genuinely affordable, high-quality, rented homes for Londoners on low incomes.

Among other points, we expressly support:

  • The introduction of the 50% target for Section 106 contributions on public land and at least 35% elsewhere, and discouraging ‘cash in lieu’ payments;
  • Public funding for genuinely affordable, rented homes in perpetuity;
  • The Mayor’s commitment to ensuring accessible homes, to ‘like for like’ replacement of social housing on refurbished estates, as well as to involving residents in estate regeneration;
  • The Mayor’s plans to drive out rogue landlords in the Private Rented Sector, notably through the new Landlord and Agent Checker, and coordinated enforcement across London boroughs;
  • The Strategy’s recognition of the needs of particular vulnerable groups in London, notably homeless people in Temporary Accommodation, women fleeing domestic violence, and LGBT communities.

We believe, however, that the following areas need further work:

  • People are being led to believe that ‘London Affordable Rent’ is equivalent to social rent. However it is actually 42% higher on average than typical social rents, and takes up 45% of the average household income of those in social housing.[1] This is a concern, and risks people distrusting that new policies will lead to ‘genuinely affordable’ housing. The Mayor should deal transparently with his constituents in language about affordability and what is feasible.
  • London Living Rent (LLR) is now exclusively a middle-income rent product. For those on median incomes of £39,000, LLR is £1,083 per week, which restricts them geographically (see map on next page), and makes LLR homes out of reach for many Londoners. We encourage the Mayor to support LLR properties in places where they mean rent becomes genuinely affordable.[2]
  • The original Living Rent proposals had a Living Rent linked to people working on the minimum wage. We would like to see that ‘real’ Living Rent proposal revived, to help make London genuinely affordable for the people on low incomes on whom the city depends.  

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  • While the PRS policy has many strengths, it neglects to mention the role of letting agents. Agents manage around two thirds of rented properties, and mediate many relationships between landlords and tenants. This oversight should be remedied.
  • We also warmly encourage the Mayor to commit to an independent evaluation of the Landlord and Agent Checker, to increase understanding of the impact on tenants and the supply of rented properties.
  • At present, demolitions mean that the affordable and social rented housing stock is either stagnant or falling in some boroughs, while others complete hundreds of affordable and social rented homes per year. The Mayor must be proactive in calling in developments that lead to a net loss of affordable housing, as well as holding developers who reduce affordable housing after planning permission is granted to account.

Top and Bottom London Boroughs for ‘Affordable’ Homes Delivery (2012-6)[3]

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Top and Bottom London Boroughs for Social Rented Housing Delivery (2015/6)[4]

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  • We value tenant voice, and therefore note the idea of a Commissioner for Social Housing Residents. However this could further entrench divisions between those with assured tenancies, and their private renting or homeless neighbours. Private renters and those in Temporary Accommodation have few rights to consultation and are often wary to speak up; instead what is needed is rights (and maybe a Commissioner) for all estate residents. We also encourage the use of ballots, representative voice, and independent tenant advocates, including private renters and licensees, on individual estates.
  • We encourage the Mayor to indicate his support for Karen Buck’s “Fitness for Human Habitation” Bill, which would grant rights to enforce the law to both private and social tenants, and create legal options for social tenants experiencing neglected repairs.
  • As noted in the Strategy’s Impact Assessment, there are significant equalities issues in housing: while homelessness among White households has risen 9% since 2012, it increased by 48% among BAME households. Disabled and LGBT Londoners and those fleeing domestic violence experience greater housing need and a lack of appropriate provision. We ask the Mayor to fund pan-equalities research into the needs of such groups and to model the impact of his policies in more depth, to ensure that London offers equitable access to the right to a home for all. 
  • We also ask him to promote the involvement of diverse voices in the housing debate.

Finally: Trust for London is a landowner, one of a number in the capital with endowments and social purposes. Our Chief Executive is offering to convene a group of such landowners, to discuss how we can play a role in delivering affordable housing in the capital while retaining our freehold and making an acceptable financial return. We have also begun exploratory work for two sites in the hope of creating an exemplar for others to copy. We invite the Mayor or Deputy Mayor or their representatives to follow up on this offer. 

Contact: Susie Dye, Grants Manager, info@trustforlondon.org.uk 020 7606 6145

[1] London Tenants Federation (LTF), “’Genuinely affordable’ housing, or more of the affordable housing con?” July 2017

[2] LTF’s paper on affordability (above) alerted us to this issue..Shelter Policy Blog, “London Living Rent – one piece of the Housing Crisis Puzzle.” http://blog.shelter.org.uk/2016/10/london-living-rent-one-piece-of-the-housing-crisis-puzzle/ October 2016, plus the original JRF/Savills and Citizens UK Living Rent proposals. 

[3] Trust for London “London Poverty Profile: New Housing Completions” https://www.trustforlondon.org.uk/data/new-housing-completions/;

[4] London Tenants Federation, “Analysis of Targets and Delivery of Housing in London (2015/6)”