R19.0106 Freepost RTXU-ETKU-KECB Planning Policy Islington Council Town Hall Upper Street London N1 2UD 17 October 2019 [email protected] ISLINGTON COUNCIL LOCAL PLAN: REGULATION 19 CONSULTATION Thank you for consulting the Home Builders Federation (HBF) on the draft Islington Local Plan Regulation 19 consultation version. James Stevens, the HBF’s Director for Cities, has prepared this response and he is the lead contact for all things in relation to the Islington Local Plan. The Home Builders Federation (HBF) is the principal representative body of the house building industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational plc’s, through regional developers to small, local builders. Our members account for over 80% of all new housing built in England and Wales in any one year. Recent research by the Government has estimated that housebuilders have made a significant contribution to the nation’s infrastructure, providing some £21 billion towards infrastructure of all types including affordable housing since 2005. We would like to submit the following comments on the draft Plan and we would like to be involved in the examination-in-public on those matters relevant to these representations. 1. What is the role of the local plan The plan period Para. 1.2 states that the Local Plan will cover the period 2020/21 to 2035/36. Policy H2: New and Existing Conventional Housing provides a housing target that runs only to 2028/29. We acknowledge that the Draft London Plan is only able to identify a housing land supply up to 2028/29 (thereafter London’s capacity is more uncertain and will need to be reassessed) and we acknowledge that footnote 8 to the Draft Islington Local Plan (DILP) refers to the annual target that is set by the DLP being rolled forward for the period post 2028/29. However, if the DILP is unable to identify a land supply that last beyond 2028/29 then the Plan should terminate then. Conversely, if the Council is able to identify a land supply to sustain output beyond 2028/29 then it should reflect this in its targets. Home Builders Federation HBF House, 27 Broadwall, London SE1 9PL Tel: 0207 960 1600 Email: [email protected] Website: www.hbf.co.uk Twitter: @HomeBuildersFed Secondly, the DLP applies from the year 2019/20 – a year earlier than the commencement of the DILP. This indicates that the Mayor has assessed that there is capacity in Islington to begin delivering 775dpa for at least ten years. Therefore, the DILP should be extended by at least another year to carry the plan period up to 2029/30. Policy PLAN1: Site appraisal, design principles and process The policy is unsound because it is unjustified. We question whether it is justified to require schemes of all sizes to comply with the requirements of Part C in view of other policy objectives set by the Draft London Plan (DLP). While the HBF acknowledges the importance attached to good residential design by national and regional policy. The industry recognises that it needs to do more to improve the design of residential schemes. However, in line with national policy (NPPF, para. 68) and the DLP (Policy H2), Islington needs to encourage the construction of more homes on small sites of 0.25 hectares in size or lower. At the moment, according to the DLP, this requires a total of 484 homes a year on small sites, or about two thirds of its overall annual need (775dpa). The DLP, however, has not identified these sites, so Policy H2 of the DLP is drafted in a way that is meant to incentivise small site delivery. While we agree that design quality should not be compromised in small schemes, we do think that Part C of the policy needs to acknowledge the resource constraints that confront many small developers. While many established housebuilding companies have the resources and staff that allows them to comply with policy, most small builders do not. Few small housebuilders operate within London owing to the complex planning policy environment. The HBF has nearly one hundred small house builder members (SMEs) but none operate within London. This is something that Government and the Mayor of London is keen to change. The Mayor wishes to significantly increase the contribution of small sites to help meet London’s housing needs (Policy H2, Part A 1)). Paragraph 4.2.1 of the DLP observes that achieving this change will require positive and proactive planning by boroughs through plan-making a decision-taking. It would be helpful if the policy acknowledged the challenge of encouraging more housing through small site delivery. We are not seeking a dilution of design expectations for small developers, more a recognition in the policy that it may be difficult for all scheme to comply with every consideration listed in Part C. There are many other policies in the DILP that will place demands on the developers of small sites (such as the 50% affordable housing requirement), therefore it would be helpful if the Council provided more support in other areas, such as compliance with its design requirements. For example, a small infill scheme involving the construction of one-to- five new dwellings will probably have a negligible impact on traffic (item xiv), trees (item v), visual context (item vi), entertainment and community activities (item ix) etc. Therefore, we request that Part C is amended to read (additional text in italics): “All development proposals must submit a site appraisal comprising the information below, commensurate with the scale, location and potential impact of the proposal. Mayor development proposals and smaller developments on sites in prominent or sensitive locations will likely be required to address many, if not all, of the criteria. Developers of small schemes that are not in prominent of sensitive locations should agree with the council, through pre-application discussion, those elements of the list below that it is necessary and feasible to address through the site appraisal.” Policy H1: Thriving Communities Parts of the policy are unsound because it conflicts with national policy. Part E Part E seeks 50% of all new housing to be ‘genuinely affordable’. We will consider this policy in more detail under Policy H3. However, the term ‘genuinely affordable’ could provide misleading to the general public as many might think this refers to affordable home ownership. It would be better if this policy was recast to reflect the detailed requirements of policy H3, part H, which specifies a tenure split of 70% social rent and 30% intermediate housing. The extent to which this is viable and deliverable we will address further under policy H3. Notwithstanding this, we consider that the policy should be re-drafted allow for the full range of affordable housing types to be provided in line with those specified in annex 2 of the NPPF. National planning policy at paragraph 64 now encourages the supply of homes for home ownership. It specifies that at least 10% of the affordable housing component to be provided as affordable home ownership. Therefore, to discount these other types of affordable homes would be contrary to national policy and would prevent more affordable routes to home ownership. Recent research by the Affordable Housing Commission has revealed that, when surveyed, most people consider that the term affordable housing refers to affordable housing for ownership, rather than renting. The Council’s own survey of housing preferences (Islington SHMA Household Survey Results, July 2017) reveals that 67% of respondents would rather own than rent. The next question in the survey shows that 66% of respondents expected their next residence to be either owned with a mortgage or loan and another 7% expected to access homeownership through intermediate products (see pages 37-38). Question C5 then explores the realism of this being achieved. In answer to this, 6% expected to own outright, 32% of respondents expected to purchase with a mortgage or a loan, and 4% expected to acquire through an intermediate product (part rent/part buy). Further survey questions explore the ability of households to access home ownership. Question D9 asks whether respondents consider that they could afford the payments associated with home ownership and 16% thought they could do it comfortably, 24% thought the costs were manageable, and 41% considered the costs just about manageable. The remainder of respondents indicated that it would be strain. These results do indicate that there is an appetite for home ownership and an ability to afford low-cost home ownership products. We should also consider the work of the Affordable Housing Commission, led by Lord Best, on this question. The Commission, looking at surveys, recognises that many people currently renting want to become owner-occupiers but are thwarted from doing so. As an early report to the work of the Commission concluded (AHC Chair’s summary: Measuring housing affordability in England – an alternative approach (April 2019) concluded. Meanwhile, as our focus groups have expressed so clearly, many people are very frustrated at their inability to move into home ownership. Our calculations suggest 1.6m renting households have the means to buy. This suggests that for hundreds of thousands of households currently renting – the vast majority in the PRS – the aspiration of home ownership need not be thwarted simply by the problem of affordability. Later reports to the AHC have explored options to assist households into home- ownership such as deposit schemes, restrictions on buy-to-let, taxes imposed on existing owners but ring-fenced to support home-ownership products for first-time buyers etc.