Housing and Planning Bill

Written evidence submitted by Waverley 8th Fully Mutual Housing Co-operative (HPB 71)


Waverley Eight is a small, self-managed cooperative comprising 35 units. It was established in 1979 and many original members remain as tenants in, and shareholders of, the co-op. The initial Housing Corporation grant to establish W8 has, after 35 years, been almost completely repaid from rental income. Final repayment will be made by 2019. As such W8 is a non-subsidised housing provision that will in the near future become collectively owned outright. It is, and remains, non-transferable property, managed as collective social housing allocated according to the principles of cooperative living. Our allocation policy privileges housing need as a major criterion of allocation and extends to those on the local authority housing list.

1.2 Although we have an agent, the Co-op runs its affairs through a monthly Management Committee, Quarterly General and Annual Meeting structure that makes the majority decisions underpinning the workings of the housing group. The continuity of the W8 membership has allowed for a successful housing community to flourish over 36 years and proposals to stratify tenancies through pay to stay legislation based on income would undermine the group’s cohesiveness and therefore its future viability. In this sense the Bill represents a threat to social housing not, as is claimed, an attempt to extend it.

1.3 Income levels within the group are varied: these differences echo our demographic diversity as well as diversity in work histories, family formation, disability, ethnicity and background. Using income differentials to separate tenants would undermine the ethics of shared responsibility for our housing provision. This is particularly so given that collectively we have all participated in maintaining the well being of the coop, the health of its finances, the maintenance of the housing stock, and the sociability of the tenant group. Like many welfare reforms the Bill is at risk of overriding social complexity with a one size fits all policy that is inflexible and therefore ineffective.

1.4 The collective voluntary work of the coop has enabled us to maintain affordable rents and the proposal of the Bill to disaggregate these would be counterproductive and undermine its functioning, democratic, organisational structure. All of the investment that tenants, as a collective, have made in securing the quality of their housing in W8 will be devalued and diminished by the proposed changes which will weaken the terms of collective participation.

1.5 In the event of our fully mutual status being superceded it is unlikely there will be any capacity for right to buy amongst our tenants, particularly in light of the prohibitively expensive London housing market. We would argue that this market not only subverts the Bill’s claims to be extending owner occupation it also limits the possibility of increasing social housing through like for like replacement. This is particularly so in London with the scarcity of brown field sites and the excluding competitiveness of private sector buyers. In addition the burden of organising replacement properties with a reduced tenant based voluntary work force, and the inevitable increase of management costs, will be compounded by the additional management cost of service provision and charges for mixed housing ownership and tenancies within coop properties.

1.6 The rental market boom also presents problems: the proposed 40k thresholds which would attract an 80% market rent contribution would, because of the ever increasing levels of London rent, be contrary to the recommendation regarding proportionality of rent in relation to income. [recommendation needs to be grounded]

1.7 The 40k/80% ratio moreover makes no allowances for the variable expenditure commitments of the units involved arising from differences in relation to family composition, number of dependents, costs such as disability or care, employment status and changing employment circumstances.

1.8 The combined impact of low wages and high private sector housing costs mean that the proposed 40k threshold could disincentivise people from improving their employment prospects for fear of loosing their home. This could be seen as a further attack on those striving to make a better life for themselves and their family. It could also be perceived as a policy that suggests that for tenants in social housing work simply does not pay.


2.2 Our primary concern with the threshold is the 40k ceiling. In London households are diverse and 40k for a single person household relative to a family or multioccupancy household are widely divergent propositions. Moreover the cost of living in London means for many an increase in rent would have the same consequences as the proposed reduction in family tax credits in generating an increase of at-risk families. We would endorse a taper system to mitigate sudden rental increases when people reach the threshold.


Implementing guidelines on market rents would be difficult and open to dispute given the range of market rents with a single borough. Discrepancies in rental levels could result in the inability to assess fairly and adequately the actual market rental rate. This could introduce a second layer of tenant conflict in addition to that inspired by some having to pay a percentage of market rent: there would be another division between properties in the same general areas that nevertheless attract different rental values.

3.2 The administration of replacement housing post implementation of right to buy would be difficult on several counts: personnel resources would not match the additional workload; funding paid workers would undermine the principle of collective voluntary management work; new tenants could opportunistically use cooperative membership as a platform into private housing; the existing skill base within the coop would have to be developed and this in conjunction with related developments around the RTB replacement provision would contravene the conditionality attached to our founding charter.

3.3 Given the fluidity of the London job market, the increasing high level of self employment, and the disrupted employment patterns experienced by many people it would be extremely challenging to administer interventions based on income level with our current work structure. And as we noted above whilst income levels may go down or up, rental levels, for the purposes of administering the 40k rule, continue to increase thereby introducing another variable into the calculation. The income/rental ratio is problematic on many different levels and this complexity represents a potential administrative minefield.


In conclusion we want to stress our absolute commitment to the ongoing development and provision of social housing and the protection of existing social housing.

4.2 RECOMMENDATION : We are committed to the development of social housing and think affordable housing should be made available to communities throughout the UK. In our view this would best be achieved through a properly resourced programme administered through a joint central / local government grant. We do not think this development should be at the expense of existing social housing provision as proposed by the current bill. We would like to re-iterate that the right to buy legislation, in the context of London would, we fear, severely reduce the social housing stock where replacing like with like is potentially undeliverable.

4.3 RECOMMENDATION : We are committed to the equity of collective contribution, and to protecting the voluntary self management that underpins affordable rents in the cooperative housing sector. For this reason, and because of the low wage/high cost of living index of many major UK cities, but particularly London, we think a more viable and reasonable threshold would be 80k.

We would like to re-iterate that the right to buy legislation, in the context of London would, we fear, severely reduce the social housing stock where replacing like with like is potentially undeliverable.

November 2015

Prepared 24th November 2015