Draft London Plan: Our response to the GLA's open consultation

The National Housing Federation (NHF) is responding to the Greater London Authority's (GLA) consultation on the Draft London Plan.

Our response focuses on Chapter 3: Delivering the homes and neighbourhoods Londoners need, and is now available to read below. If you are not an NHF member, but would like to read our response, please email Tanya Bass.

The key points in our full response, which you can access below, highlight how the London Plan could go further to safeguard on-site delivery and ensure that affordable housing thresholds increase with viability.

Affordable thresholds:

• We welcome the return to the pre-emergency affordable housing threshold for larger schemes in Location Band A and ultimately want to see a full return to the previous threshold approach across London, when viability conditions allow.

• We are calling on the GLA to establish a clear expectation in clause 3.40 that affordable thresholds must increase where evidence demonstrates improved viability. Rather than simply allow local planning authorities to “explore” higher thresholds, the current wording should go further to ensure that thresholds are increased in line with improved economic conditions.

In-lieu payments:

• We support the expectation for affordable housing to be provided on site, except in genuinely exceptional circumstances. However, any proposals for off-site provision or payment in-lieu should be subject to the viability-tested route. This would encourage developers to work with housing associations to deliver affordable homes directly, rather than relying on cash contributions.
• Alternatively, where seeking fast-track approval, the contribution should provide at least 25% more affordable housing than the equivalent on-site requirement.
• Any payment-in-lieu contributions must be ringfenced for the delivery of affordable housing and prevented from being returned to developers. Where funds are not spent within a reasonable timeframe, they should be transferred to the GLA or an affordable housing provider for delivery.

Smaller Section 106 sites still matter:

• The exception allowing developments of 10-35 homes to provide a payment in-lieu without following the viability-tested route should be removed. All developments should either be subject to the same viability requirements or, where payment in-lieu is proposed through the fast-track route, be required to deliver a higher affordable housing contribution than would be required through on-site provision.
• Medium-sized housing associations rely on these opportunities and have strong capacity to purchase and manage homes on developments of 10-35 units. The focus should instead be on improving early engagement, design and long-term management arrangements so that affordable homes can be successfully delivered on site.