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Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by Royal Institute of British Architects Planning Policy Group (AFH 31)

  The RIBA Planning Policy Group supports the aspiration of the committee to make decent houses affordable and that affordable houses are made decent. Our evidence would focus on the obstacles that at present exist which inhibit this objective:

    —  the definition of affordable;

    —  the concentration on affordability at the expense of quality; and

    —  the failure of many authorities to specify other social criteria.


  It must be understood that the main mechanism for generating affordable housing comes when a private developer wishes to develop. The definition of affordability and the extent to which the local authority demands affordable housing will affect the profitability of the development and thus its quality and eventually its feasibility. However for many developers it is delays due to lack of clarity from the local authority rather than ultimate cost which kill a scheme.


  Different authorities interpret affordability in different ways. At one extreme some demand social rentable housing which they wish to be gifted to them and which they will then fill with people from the housing lists. In other cases local authorities will use their own housing grant allocations to assist with cross subsidies of such housing, which will generally then be owned and/or managed by a housing association. In more enlightened cases authorities accept a wider definition of affordability. In these locations authorities will have completed a housing needs study and will have established what types of housing are needed and where.

  Many local authority housing departments think only of their own (social) sector. However many surveys have shown that affordability needs run far wider than this. For example in central London even those on quite high wages cannot afford housing. There is a "poverty trap" for those who do not qualify for social housing but who cannot afford to rent or buy on the open market. Conversely in some areas where there is an imbalance of social housing, affordable housing would not be appropriate.

  There is also an issue relating to specialist housing. Only recently the GLA announced that it is to designate dedicated housing for teachers. In the past we have had police housing and nurses' homes. However historically these have not proved sustainable even though the need for such housing has not diminished. There seems to be a disinclination on the part of different professional groups to live in too close proximity. We would also question the flexibility of single-user housing.

  Before a good affordable housing policy can be implemented each local authority should undergo the following in order to generate appropriate definitions and policies. 1 We suggest that the following stages should be created:

  Every ten years

    —  review affordable housing policy as part of major Local Plan review.

  Say every three years

    —  research housing need;

    —  publish housing needs survey;

    —  public consultation on housing needs;

    —  publish housing needs policies;

    —  review Local Plan policies1.

  Every year

    —  update local housing figures;

    —  review housing needs;

    —  review housing needs policy;

    —  review Local Plan affordable housing policies (in the light of other social, economic and physical criteria);

    —  publish revised housing needs policies (if required).

  It should be noted that affordable housing can also include:

    —  housing for single parents;

    —  small units for single people;

    —  live/work units;

    —  shared accommodation for young people of single parents;

    —  housing for the elderly;

    —  housing for the disabled;

    —  low-cost housing;

    —  self-build housing;

    —  shared ownership;

    —  low market rent; and

    —  many others.

  These options should be available to local authorities in line with their own needs.


  There is a fear that affordable housing is becoming a pawn in the negotiation of planning obligations (Section 106 agreements). In some cases the imperative to negotiate a satisfactory affordable housing provision binds the local authority to accept less than high quality of design. It should also be noted that if a scheme is to have a significant element of social rented housing it is likely to require, for example, more carefully designed public open spaces, ie a higher quality of design.

  Developers are often reluctant to include socially rented housing within their schemes and try to deal with this by:

    (a)  Paying for the social housing elsewhere; and

    (b)  Separating off a section of social housing on the least attractive part of the site.

  Neither of these options is very satisfactory.

  Given that the developer has a fixed budget there is an inevitable balance to be struck between affordable housing and other criteria. Often this low quality is most noticeable in the social element of the scheme. 2 In other cases a lack of funding may result in cutting corners on other elements which might also contribute in some way to community benefits.

  The RIBA has received many representations from planning authorities who regret the poor quality of design in mass housing. On investigation we discover that architects are not used in these schemes and the quality of design is indeed very low. However, costs are involved in employing a competent design team which, if we are to achieve sustainable housing, should include at the very least an architect supported by such specialists as structural engineers, services engineers and landscape designers.

  The market may demand higher quality of design for housing within the private sector. But where affordable housing is to be constructed the final client is not known and the brief may be very vague at the time of the planning application. The outcome may be far from successful. Once the Section 106 agreement has been signed it is too late to re-negotiate.


  Requirements for affordable housing are just one element of a planning negotiation. When an authority considers a planning application they should consider it in the light of a whole series of social, economic and physical or environmental criteria. If social housing policies are established in isolation to these other, equally relevant, criteria there is a danger that the scheme will not be successful.


  Where a local authority is the landowner this balance of criteria may become very acute. For example the property division may wish to establish the highest price on a piece of land while the highways department might wish to secure a road widening scheme and the housing department may wish to accrue an element of social housing. These conflicting criteria, all of which the developer has to meet in some way, often cloud any initiative the developers themselves have to add to the qualities of the scheme in other ways. For example we have observed many different ways that commercial development can contribute to social improvements.

  These include:

    —  public open space;

    —  providing space for social or cultural activities within the development;

    —  sponsoring business start-up initiatives or job initiatives; and

    —  considering the way that labour and suppliers are procured within the construction process;

    —  considering labour and suppliers in the finished building.

  The very mixture and variety of uses can also be endangered by an over-insistence on a high element of social housing.


    —  LAs should establish and monitor housing needs.

    —  Housing needs should be considered by planning authorities in association with other social, economic and physical requirements.

    —  These needs will not be the same throughout an authority area.

    —  LAs should publish and consult on housing needs policies.

    —  The definition of affordable housing should be as wide as possible in order to encourage innovative schemes.

    —  The extent of affordable housing should be negotiable if other equally important features are offered by a developer.

    —  The quality and sustainability of the finished development should be considered as part of the negotiation.

    —  The final client and management system for social housing element should be clear at the time of signing a 106 agreement.

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Prepared 1 July 2002