Memorandum by Birmingham City Council
1. INITIAL REMARKS
As a result of the timing of this Inquiry, when
both Planning and Housing Departments both have a number of intensive
commitments, such as the review of the Unitary Development Plan
(UDP), the review of Regional Planning Guidance for the West Midlands
and the production of the annual Housing Investment Programme
(HIP) submission, it has been difficult to amalgamate an extensive
response. Therefore, the following written evidence is to be considered
by the Urban Affairs Sub-Committee with reference to the enclosed
relevant documents (or parts of), which are:
current Housing Strategy Statement;
recently completed citywide Birmingham
recently completed City Living Study;
relevant extracts from the current
draft of Unitary Development Plan (UDP);
supplementary Planning Guidance on
Affordable Housing (SPG);
a copy of the City Council's submission
to the Regional Planning Guidance (RPG) Public Examination, which
includes the results of a region-wide surveycarried out
by the City Councilon the application of affordable housing
places for livingthe City
Council's Residential Design Guidelines.
Birmingham City Council Planning and Housing
Departments have worked jointly in producing this written evidence
to the DTLR Inquiry into affordable housing.
Birmingham City Council considers that this
is a very important inquiry, and not only to the South East of
England where the problems of high demand and ever-increasing
house prices are widespread, but also across the rest of the UK,
where local markets are often radically different within the same
local authority boundary.
This written evidence follows the format of
the inquiry's request for comments on a number of issues, but
is preceded by a short section on the strategic direction of Birmingham
with regard to affordable housing.
The Council's UDP adopts the regionally agreed
two-part definition of affordable housing as:
"A: Housing provided by an organisationsuch
as a registered social landlord or local authoritywhich
is allocated on the basis of need. While such dwellings will normally
be made available for rent, they may also include subsidised low-cost
home ownership, where a registered social landlord or local authority
retains a continuing interest."
"B: Low-cost market housing, which may help
to meet the needs of first-time buyers, single people, the elderly
and other low income households, who cannot afford to rent or
buy houses generally available on the open market."
In brief, Birmingham is not considered to have
a "wholesale" affordability problem, although the current
Housing Strategy does recognise that there are polarised markets
within the City boundary. This means that there are pockets of
low demand with low house prices (under £50,000), with neighbourhoods
close by experiencing surging demand for traditional properties
with average house prices in excess of £130,000.
The Housing Strategy recognises the longstanding
problem of out-migration of affluent households from Birmingham
to areas such as Worcester, Lichfield and Solihull, and is keen
to develop methods of intervention, which encourage them to remain
in Birmingham. The issues to be tackled, therefore, are increasing
the supply of attractive, aspirational housing for younger middle-income
households in the owner occupation sector, whilst also providing
adequate is this the right word? "affordable" housing
for lower income households in need.
In the light of recent research conducted on
behalf of Birmingham City Council, a series of nine Housing Market
Areas (HMAs) have been identified across Birmingham. These are
areas within which broadly similar characteristics can be found
(eg demand, tenure, weaknesses, function of area, residential
stability). Cross-tenure housing strategies are in the process
of being developed for each of the nine HMAs.
When developing strategies at a more local level
than local authority boundary, it then becomes apparent that the
scale and location of demand for affordable housing should be
considered at a more local level to truly understand the nature
of the problem where it exists. For instance, whilst it may be
correct to say that Birmingham has a ready supply of housing affordable
to those on average incomes, the choices available at the lower
end of the market may be in areas experiencing declining/low demand,
dwellings in poor condition, or obsolete housing types.
4.1 The definition of affordable
For the definitions used by Birmingham City
Council, please see the enclosed references from the Supplementary
Planning Guidance on Affordable Housing and Unitary Development
Plan documents (which are also stated above). The region-wide
definition was developed by the West Midlands Local Government
Association to give individual local authorities the scope to
define the levels of affordable housing it wished to see on qualifying
private sector developments within its area. In the City Council's
case these are set at 25 per cent under Part A of the definition
and a minimum of 10 per cent under Part B, an approach that has
been backed up by the results of the Birmingham Housing Study.
4.2 The scale and location of the demand for
Firstly, the big question, "is there a
demand?" must be addressed, but this can only be done with
an effective definition of affordability.
In Birmingham, there is a considerable scale
of demand for affordable, driven both by poverty in some areas,
but also by high house prices in others. Following the Birmingham
Housing Study, the Council has developedin accordance with
government guidancea long-term housing model, which assesses
and projects year-by-year demand for social and affordable housing
in Birmingham. This will help the Council to assess, monitor and
review as well as respond to demand for affordable housing. Factors
affecting the scale and location of demand for affordable housing
are varied, and include large scale clearance proposals, social
landlord management policies, and the size, design, quality and
popularity of new build housing, particularly where social and
homeownership are built on the same site, but are distinguishable
by sight. Other factors such as interest rates can affect the
demand for affordable housing and tenure issues.
4.3 The quality of affordable housing
Quality is generally believed to be poor, reflecting
design and construction methods coupled with years of under-investment.
This has resulted in the very poor state of social housing. This
exists alongside widespread problems of low demand and stigma.
In social housing areas with these problems, the knock-on effect
on interspersed and neighbouring private housing areas can be
There is a clear need to ensure that social
housing reflects twenty first century aspirations and therefore
needs to be desirable, in terms of being indistinguishable from
owner occupation, and also having good space standards. Ironically,
space standards in private housing are often more of a contentious
issue, as social housing regulations need not be followed.
4.4 The adequacy of the existing supply and
the amount of resources
It is also important to recognise that quality
is more of an issue than quantity. Whilst affordable housing provision
may meet the numerical requirement, on a more local level, there
are likely to be unmet hidden demands, for example, the need for
family housing and "Difficult-to-let" accommodation,
which does not meet present-day expectations.
In terms of the existing supply of affordable
housing, it is not only a lack of resources that has led to the
inadequacy in the quality of social housing, but also policies
such as the Right to Buy which has stripped much of the better
quality stock from the social housing sector.
4.5 The extent to which planning gain can
fund the level of affordable housing required
Planning gain should be seen as a top up. In
Birmingham, the PPG3 threshold of one hectare is used, and therefore
only on larger sites, which form a relatively small proportion
of total supply. There are numerous and conflicting demands on
section 106 monies and the strength of the property market precludes
all of the demandsdesirable though they may befrom
being met. The City Council's approach in considering planning
applications, where the full provision of affordable housing is
not being made, is to require an "open-book" assessment
by Valuers to assess viability. The current environment, however,
seems to suggest that the Housing Corporation may be willing to
put grant into section 106 schemes.
Since 1996 the record in negotiating S106 affordable
housing in Birmingham is as follows:
|Year||Units secured in negotiations
||Commuted sums for off-site provision
To give an idea of the contribution, the level of dwelling
completions per annum averaged c1,800 dwellings of which about
700 completions per annum were by RSL/Housing Associations.
4.6 How resources should be balanced between social housing
and options for owner-occupation for those who cannot afford to
buy (including shared ownership), and whether any additional mechanisms
are required to bring forward shared ownership-type schemes
The current balance of resources between rent/sale in Birmingham
is 80/20. Options for affordable owner occupation in Birmingham
need to be extended to meet the needs of lower income households,
especially those who could potentially lose their current homes
under redevelopment proposals, and also the needs of middle-income
households. In particular, the Council would be keen to see further
use of initiatives such as the resale covenant. There may also
be a market for shared ownership in the City Centre and the City
Council is keen to test this through S106 negotiations.
4.7 Whether targets in Regional Planning Guidance are appropriate
The Council believes that there should be indicative regional
and sub-regional affordable housing targets set out in RPG. This
would help ensure that the housing that gets built is more closely
related to the needs arising and in the event of significant under-provision
of affordable housing compared to the requirement of a strong
pointer to the need for government intervention. Possible benefits
of having a sub-regional target would be for the relevant authorities
to "share" the target. This would be particularly useful
in the Birmingham and Black Country sub-region, where certain
areas, eg parts of Sandwell, have much greater capacity for new
housing than within Birmingham's boundary. This also opens up
the possibility of affordable housing needs being provided across
boundaries, which must surely be desirable to open up greater
flexibility in the labour market. At present residents of social
housing are at a serious disadvantage in securing employment outside
their "home" district.
4.8 Whether targets on decent and affordable housing will
be met by central and local government
Birmingham is unlikely to meet the Government's decent homes
target by 2010 (or the interim 2004 target). Following a negative
LSVT ballot result, the issue of the decent homes target has become
even more challenging for Birmingham to meet.
4.9 Whether current policies and practices are leading
to the creation of mixed communities
Birmingham City Council's policies are aiming to create mixed
communities in the wider theme of sustainability. This is both
at a corporate level with the Community Strategy and the Local
Neighbourhood Renewal Strategy, but also more specifically within
individual Departmental strategies, such as Housing.
There are some good practice examples of where proactive
management on new estates can help to create sustainable communities.
However, the design of new estates needs to be at the forefront
of any aim to create mixed and balanced communities. Other good
examples of where mixed communities have been created through
estate redevelopment are in Pype Hayes and Castle Vale, where
mixed dwelling type and tenure have been developed following the
breaking up of monolithic council estates.
Whilst policies and practices can assist in the development
of mixed communities, market forces work against it. In some cases,
the market operates entirely in contradiction, for example where
there are a multitude of social and private rented landlords operating
in a local area. Market forces also encourage more affluent households
to live alongside each other, whilst leaving social housing residents
in "ghettos". On individual development sites, this
problem is compounded through the segregation of the affordable
allocation from the owner occupied section.
Perhaps mixed communities can only be created where there
are real opportunities for change because, in reality, where affluent
families continue to move out, polarisation will develop.
4.10 Whether more Greenfield development is needed to meet
Some Greenfield development is inevitable, but there is also
tremendous scope to reverse longstanding trends for decentralisation
through more balanced redevelopment following clearance and demolition.
The review of RPG in the West Midlands is seeking to increase
house building within the Major Urban Areas. This strategy is
aimed at tackling decentralisation and it is important that a
tight grip is kept on Greenfield developments within and beyond
the City's boundary if the aspirations for urban renaissance are
to be achieved. Evidence from the success of "City Living"
within Birmingham City Centre suggests that the private sector
is more than willing to invest within the urban area when there
is a clear vision, strong leadership and certainty.
In seeking to increase housing capacity within the urban
area it is very important that very great emphasis is placed on
the quality of design. To this end the City Council has recently
produced new residential design guidelines (Places for Living)
to assist developers. An obvious further point, perhaps, is that
the Council resists development on Public Open Space for playing
fields and generally considers that relaxation on this point would,
in the longer run, work against the achievement of urban renaissance.
4.11 The cost to individuals, businesses and the economy
resulting from any shortfall in the provision of decent, affordable
There may well be an impact on the economy of undesirable
social housing. A shortfall in the provision of affordable housing
can cost individuals in restricting their housing choices and
ability to meet their aspirations. This is also the case, most
notably in London and the South East, with regard to key workers
who cannot afford to freely purchase homes on the open market
but arguably need to be close to their place of work. Whilst Birmingham
has an abundance of "affordable" housing, local area
demand and popularity are key factors. Particularly, in the City
Centre, prices are too high for most to afford and this is a specific
issue that the City Council intends to pursue through the application
of the PPG3 affordable housing policy.
It is also the case that greater mobility for residents of
the social housing sector could help address the needs of business.
Conversely, certain policies can have an impact on housing.
Traditionally, through a neglect of housing issues, economic strategies
may create longer journeys to work and disillusionment within
local communities. Ultimately, through inadequate provision of
aspirational housing within Birmingham, employers may choose to
"up-sticks" and relocate to the "shire" districts,
where their workforce have been commuting from. Currently, AWM
have recognised this as an issue, and are trying to address this
through partnership working, particularly in the Regeneration