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Chapter 5 - HOUSING

5.1 INTRODUCTION

5.1.1 This chapter contains policies covering new housing of all types, created both from conversion and new development. Policies on mixed-use development are contained in the Built Environment chapter. The Employment chapter contains special policies on office conversions and work-live development.

5.1.2 The Council's roles as a planning authority and a housing authority are distinct but complementary. Increasing the quality, provision and affordability of housing in the Borough will require a partnership between a variety of private housebuilders and landlords, registered social landlords and the Council in its roles as both housing and planning authority. In line with national policy, Brent closely allies its housing strategy and its UDP. The housing strategy will regularly assess housing needs in the Borough.

5.1.3 As a housing authority the Borough has published its Housing Strategy 2002-2007 which has (among others) the following aims:

1. To increase the supply of affordable housing and thereby reduce homelessness.
2. To improve the quality of existing stock;
3. To integrate housing issues with other corporate plans and initiatives;
4. To link housing regeneration with other regeneration projects.

5.2 BACKGROUND

5.2.1 Shelter is one of the most fundamental human needs. The issue of meeting the housing needs arising from the projected additional '4.4 million households' has become the centre of media attention. A recent Government policy announcement (Sustainable Communities: building for the future, 2003) seeks to significantly increase the amount of housing built on previously developed land within urban areas. This chapter seeks to positively meet this challenge.

5.2.2 The other key factor highlighting this as a priority is the Brent housing needs and conditions surveys - indicating that Brent has one of the highest levels of housing need - and some of the worst housing conditions - in the Country. Brent has one of the highest number of families in temporary accommodation in London. However, previous UDP targets for affordable housing provision have not been met. This is a social exclusion issue that affects all Brent residents because of the exceptionally high costs of temporary accommodation as a result of the shortage of permanent affordable housing. The programme to rebuild most of the Council's major social housing estates has also come forward.

Household Change; Nationally and London

5.2.3 In 1999, the ODPM published 1996 based household projections. Taking England as a whole there will be an extra 3.8 million households projected to form between 1996 and 2021. However they are trend based and are simply projections - the Government uses them to inform policy.

5.2.4 Taking the 1996 based household projections at their face value, if directly translated into policy then London would require an increase of 21.4% in its number of dwellings. The projected increases approximate to two additional boroughs in terms of population and six additional boroughs in terms of households. Of the projected national growth in the number of households 57% arises from population growth, 20% from changes in the age structure, and 23% from changing family structures. Around 70% of the growth is expected to consist of single-person households, arising from divorce and separations, people choosing to live alone (of all age groups, and for longer periods of time), and people living longer and outliving their partners. The increase in the population is due to inward international migration and fewer deaths not being offset by fewer births and decreased outward migration.

5.2.5 Recent GLA projections show that:

• The number of households in London is projected to increase by 20,700 each year to 2016;
• 70% of the growth will be one person households, predominantly single men and divorcees;
• 70% of the additional households will need social rent or intermediate affordable housing provision.

Housing Provision and Needs in Brent

5.2.6 The Census (2001) identified 261,232 residents living in 99,991 individual households with an average household size of 2.6 persons, representing an overcrowding level of 24%. These figures, substantially higher than most London boroughs, reflects Brent’s distinct ethno-cultural demography, which makes the Borough one of the few authorities in England where ethnic and cultural minority residents comprise the majority of the population. This is likely to contribute towards a substantially greater growth in new households than in London generally (20% :14%, GLA Population Forecasts).

5.2.7 Slightly more Brent households live in houses (54%) than in flats (46%). The relatively high respective proportions of households living in semi or detached houses (35%) and in purpose built flats (27%) illustrates the range of Brent’s dwelling stock and the Borough’s diverse townscape; which ranges from suburbia in the North to very dense inner city streets of terraced houses and flatted blocks in the South. Just over half of Brent households live in owner occupier homes (54%), with most of the remainder either renting from a social landlord (25%) or privately (17%) . Appendix 1 provides more key housing data from the Census and other sources.

5.2.8 As the Census is only undertaken every ten years and does not provide all the necessary information on housing needs and dwelling stock condition, the Council regularly carries out its own Housing Needs and Stock Condition Surveys. The surveys undertaken in 1997 and 2002 informed the review of the previous UDP (1996). The 2003 Housing Needs Survey encompassed all tenures whereas the complementary Stock Condition Survey excluded the Council’s own housing stock (about 10,000 dwellings). Both surveys were undertaken in accordance with Government guidance (Local housing needs assessment: a guide to good practice, ODPM, 2000). These surveys enable an evaluation of the Borough’s housing position against other metropolitan and national data bases, such as the English House Condition Survey (2001).

5.2.9 Their key findings are summarised below and will be updated regularly:

• 20,404 households live in statutorily unfit and overcrowded etc housing (20.3%).
• Brent is the fourth most overcrowded London borough.
• 90% of those whose housing is so poor they need rehousing cannot afford market housing.
• Residents median household income (excluding benefits) was £16,063.
• 4116 ‘homeless households’ are in Council temporary accommodation; largest number in West London
• Brent needs at least 3,386 new affordable homes annually.

5.2.10 The reasons for the overall very high level of need are numerous but include:

• The very poor state of much of the housing stock, over 70% is at least 60years old; significantly higher than most boroughs;
• Poverty due to the high level of households with special needs;
• High land prices in London;
• Low pay in much of the Brent economy;
• Large household sizes leading to overcrowding;
• Growing numbers on council and housing association waiting lists;
• General growth in household formation;
• Growing levels of homelessness and families in temporary accommodation; and
• Loss of units as a result of estate development.

5.2.11 Whilst, in previous years, providers of affordable housing have been successful in securing larger sites at a period of depression in the housing market; this period has come to an end and larger sites seem to be in increasingly short supply. This situation has been exacerbated by Right to Buy social rental stock loss, the implications of the Borough's Estates Regeneration programme and the Government’s ‘Decent Homes by 2010’ improvement strategy.

5.3 STRATEGIC CONTEXT

5.3.1 This section covers the broad thrust of national, regional and metropolitan strategy to ensure sustainable housing development. Policy on specific topics (such as provision, density and affordable housing) is covered in the specific sections.

National Housing and Planning Strategy

5.3.2 The evolving Government strategy on sustainable housing development, including the growing emphasis on affordable housing provision, was generally set out in Towards an urban renaissance (2000) and more specifically in The Way Forward for Housing (2000). This strategy has been, recently, further elaborated in Sustainable Communities: building for the future (2003) which emphasises that a key requirement to ensure socially inclusive sustainable communities is;
“A well-integrated mix of decent homes of different types and tenures to support a range of household sizes, ages and incomes...” (page 4).

5.3.3 The Government’s planning strategy for housing provision proposes regionally led strategies to revitalise towns and cities and protect the countryside by making the best possible use of recycled land. It proposes to raise the national proportion of new homes to be built on previously developed land to 60 per cent over the next 10 years, which will be refined in the light of regional targets. It emphasises that national household projections are guidance not building requirements.

5.3.4 This 'Plan, Monitor and Manage' approach will be subject to monitoring by the Secretary of State "we need to avoid unduly restricting supply and thus increasing the pressure on the ability of both the social housing and market housing sectors to maintain the supply of affordable housing" (Planning for the Communities of the Future, 2000, para 22). Local authorities have to monitor and report on the effects of their decisions.

5.3.5 Planning Policy Guidance Note 12 Development Plans (PPG12) stresses the importance of identification of sources of land supply, in particular the use of the National Land Use Database. Development should be related to infrastructure and there should be targets for development on previously used sites.

5.3.6 Planning Policy Guidance Note 3 Housing (PPG3, 2000), which provides the Government’s primary planning guidance on sustainable housing development, advises local authorities to provide sufficient housing to meet the requirements of the whole community, including those with special needs and for affordable housing, and to provide this housing as part of mixed communities. PPG3 gives priority to re-using previously developed land within urban areas and creating more sustainable patterns of development. This is achieved by exploiting sites accessible to public transport, encouraging mixed uses, and by accommodating higher densities through changed design standards but ensuring that good design creates high quality environments in which people will choose to live.

5.3.7 The Government has recently indicated its intention to significantly revise PPG3 and has published a draft (Influencing the Size, Type and Affordability of Housing, 2003) which emphasises the importance of socially inclusive communities and stresses that “The planning system has an important role in creating communities with a better mix of housing- in terms of size , type and affordability - than is currently available.” (para. 1).

Regional Strategy

5.3.8 Regional Planning Guidance for the South East (RPG9, 2001) stresses that the provision of housing should be achieved without continuing the trend to more dispersed and land-intensive patterns of development. It recognises the need for a plan, monitor and manage approach. It proposes provision for an average of 23,000 dwellings per year in London. Dwelling completions should be monitored and provision levels reviewed at least every 5 years. At least 60% of all new housing development in the region should be on previously developed land. Targets for affordable housing should be set locally and sufficient affordable housing should be provided to meet locally assessed needs.

Metropolitan Strategy

5.3.9 Sustainable communities in London: Building For The Future (ODPM, 2003) sets out the Government‘s strategy for new housing provision in London, to be overseen by the London Housing Board which will regularly publish a London Housing Strategy. This Strategy encourages the preparation of sub regional strategies, such as Building Communities: A Housing Strategy For West London (2003) which has been prepared to co-ordinate the housing and planning strategies of seven boroughs, including Brent.

5.3.10 Strategic Guidance for London Planning Authorities (RPG3, 1996) notes the limited supply of land in London and the imbalance between supply and demand for housing; especially in the light of projections of increased population and a proportionately greater increase in the number of households. As a result it advises that:
“Boroughs should seek to make the maximum contribution to meeting the demands for housing in London and to encourage the provision of well designed housing of all types whilst safeguarding the quality of the environment.” (para. 4.1).

5.3.11 RPG3 requires Brent's UDP to demonstrate how the Borough will exceed the minimum revised allocation of 6,850 dwellings from 1992-2006 (LPAC 1994 housing capacity study). Over 5,700 had already been completed between 1992 and 1999. RPG3 requires Boroughs to allocate sites for housing development where “...other uses are unlikely to come forward.” (para. 4.14). Boroughs are required to have regard to four components of new housing supply (para. 4.6), and UDP policies to maximise dwelling provision should be tested against them (para. 4.9):

• New dwellings provided on sites redeveloped or made available from other uses, including a housing component in suitable mixed use development;
• The adaptation of existing buildings in other uses for housing;
• The redevelopment of land used for housing to a higher density;
• The conversion of the existing housing stock for occupation by more households

5.3.12 RPG3 will soon be replaced by the Mayor of London’s Spatial Development Strategy for Greater London (The London Plan) which is fundamentally based on the concept of the socially inclusive ‘compact city’, in which brownfield land is maximised for new development, through higher densities, in areas with good public transport accessibility, and mixed use schemes, so as to maintain existing open spaces. The draft London Plan includes housing targets for the London boroughs, based on the Borough’s estimates of housing capacity, to enable the provision of the estimated additional 23,000 homes (50% affordable) that London annually requires to meet the housing needs of a projected 700,000 additional residents by 2016. This forms the basis of the housing requirement figures set out in this Plan which is statutorily required to be in ‘general conformity’ with The London Plan.

5.4 Borough POLICY OBJECTIVES

5.4.1 Taking into account the state of Brent's housing and the Borough's housing need, and the various requirements of government policy and guidance, the objectives of the Unitary Development Plan's policies towards sustainable housing development are as follows:

1. To ensure the development of mixed and balanced residential communities where areas suffering from social exclusion are regenerated;
2. To significantly increase the supply of affordable dwellings;
3. To give Borough residents the opportunity for a decent home by making reasonable dwelling provision to meet household growth;
4. To improve the existing dwelling stock;
5. To regenerate the major run-down estates in the Borough;
6. To link housing regeneration with other regeneration pro- grammes;
7. To ensure the participation of local residents in meeting their housing needs;
8. To ensure that new dwellings are located where they will min- imise energy use and the need to travel and maximise the re- use of previously developed urban land;
9. To ensure that new housing is provided alongside its necessary new infrastructure, open space and community facilities; and
10. To ensure that the needs of Borough residents with special housing need is met.

5.5 BOROUGH STRATEGY

5.5.1 Brent's aim is for everybody to have the opportunity for a decent home. Brent's overall strategy is to achieve mixed and balanced communities of quality housing where social exclusion is tackled, making best use of previously developed land and buildings. This will mean both improvements to the existing stock and new building; with particular priority to the regeneration of the major estates.

Need for Additional Affordable Housing

5.5.2 Brent has regularly assessed the Borough’s growing affordable housing needs in surveys undertaken in 1997, 2002 and 2003 (all by Fordham Research Services). Brent’s 2003 Housing Need Survey employs the Government’s preferred definition of affordable housing need as;
“households lacking their own own housing or living in housing which is inadequate or unsuitable, who are unlikely to be able to meet their needs in the housing market without some assistance” (Local Housing Needs Assessment: A Guide to Good Practice, ODPM, 2000, page 116).

5.5.3 This very restrictive definition therefore excludes lower income households who are concerned about the insecurity of their, short term, private tenancies and hence would prefer social rental accommodation. It also effectively ignores high rental cost concerns as it assumes a potential housing benefit subsidy, even though this may frustrate access to much private rental housing.

5.5.4 Brent’s Housing Needs Survey uses the, Government recommended, Basic Needs Assessment Model which involves the evaluation of existing and estimated newly arising housing needs. Any household need which can be resolved through the improvement of their existing accommodation or the ability to afford the required type of accommodation, is discounted to establish the minimum essential affordable housing need of 6,430 dwellings. This figure is further refined, to include an annualised ‘backlog’ reduction and offset against recent affordable housing relettings and new provision, to generate a net affordable housing requirement of 3,386 dwellings a year. A figure several times in excess of recent annual total new housing provision in Brent and almost ten fold the new affordable housing provision level; graphically illustrating the Borough’s acute affordable housing need which is significantly in excess of the total housing target from 1997 to 2016 as set out in Policy H1.

The Brent Housing Provision Study 1999

5.5.5 In order to comply with the requirements of RPG3 to estimate the extent to which earlier estimates of the supply of new housing can be increased, the Borough has carried out a detailed study of the potential provision of new housing, in conjunction with a Londonwide study (London’s Housing Capacity, GLA, 2000) and the National Land Use Database (a study of previously developed urban land available for development). The study also examined the rate at which previously unidentified sites (so called windfall sites) have been coming forward. The study examined two aspects which may affect current completion and windfall trends. Firstly, by comparing past sources of housing land by land-use to potential development sites that came forward through the National Land-Use Database the Council has been able to estimate the degree to which these trends could be continued in the future. Secondly, the Council assessed the potential increases in provision that could arise through the four changes in supply indicated in RPG3.

5.5.6 Walkable Neighbourhoods; changes in density policy and car-parking standards will increase this level of provision, by adopting the ‘Sustainable Residential Quality’ (SRQ) approach towards assessing housing provision focusing on such neighbourhoods, where new housing can often do most to sustain the vitality of those centres and where the need to travel can be minimised. The most potential for housing was found to lie at the edges of town centres and restricting residential parking could significantly increase potential capacity. This approach endorsed in Policy STR19 will involve new site survey work and a 'design-led' approach where the potential for housing on each site is assessed individually. Such 'walkable neighbourhoods' are defined for the purposes of this Plan as that area within reasonable (600m) walking distance of a district or major town centre - measured by actual walking distance and excluding barriers such as major roads.

5.5.7 The outcome of the study is that current housebuilding rates can broadly continue through some increased use of previously developed land and slightly increased densities. It is therefore proposed to set (in Policy STR18) an additional dwelling target of 9,600 (minimum) between 1997 and 2016 (an average of 480 units / year). This figure encompasses sites identified within the Plan, windfall sites, changes of use to housing and conversions.

5.5.8 The study examined how affordable housing policies in the replacement plan would apply, resulting in approximately 2,600 additional units. Together with additional sites purchased outright by registered social landlords on projected levels of funding a target was set, as part of the overall housing target (in Policy STR18) of 4,800 additional affordable dwellings (minimum) between 1997 and 2016 (an average of 240 units per year). Without the strong policies in the Plan it would not be possible to attain this rate and the housing performance of the Borough, as assessed by GOL, would fall, leading to a substantial cut in Government funding. Even with this additional housing most of the new households in housing need would have to be housed, at least temporarily, in subsidised private sector housing (at considerable cost to the taxpayer).

5.5.9 The Boroughwide target will be a guide in allocating and negotiating on individual housing sites as to how much affordable housing will normally be expected to be secured. Brent will carefully monitor the progress of affordable housing completions and permissions (see Appendix 1) and the development of housing need, proposing adjustments to the affordable housing target where necessary.

5.5.10 The Borough proposes to work closely with other boroughs, particularly its West London Sub Regional Housing Strategy partners, and strategic bodies on a unified approach to the assessment of affordable housing needs and targets and to ensure that all boroughs reasonably contribute to meeting London's housing needs.

5.5.11 These provision levels have been set on the assumption of windfall rates being maintained and sufficient financing by the public sector or otherwise in order to support these additional dwellings. If these assumptions prove not to be correct, or if one or more particular sources of supply perform less well or better than expected, it does not imply that other sources of supply should be adjusted accordingly. The Council will monitor overall completion levels and, as part of the overall 'plan, monitor and manage' approach, assess in future regular reviews of the Plan what action needs to be taken.

Making better use of existing properties

5.5.12 One key way where the activities of the Council can meet both housing need and support other planning objectives is through making better use of existing vacant property, in accordance with PPG3 (paragraph 41) and RPG9 (Policy H4). For example, in 1997 the Council launched it's Empty Property Strategy. About half of all empty homes are due to house sales / deaths / moving into care etc. But the overall number is unacceptably high and the national aim is to reduce it from 5% to 3%.

5.5.13 The Council Tax Register indicates 5,268 empty homes in the Borough in 2003, the vast majority being in the private sector. 77% of the 4,272 private owned empty homes have been vacant for more than six months, representing 4.6% of all privately owned housing stock. Whereas, all of the public sector’s (Council and Registered Social Landlords) 663 void (empty) dwellings are either between lettings or in housing regeneration schemes. A dedicated empty property team is working with the private sector, promoting flats above shops and encouraging housing use not just of empty homes but empty properties in general suitable for residential use.

Affordability & the Plan Strategy

5.5.14 Because Brent has some of the highest housing needs in London, with relatively high housing prices, but lower than the London average household income (£21,552 as compared to £27,000), and given the importance of the planning issues surrounding estate regeneration, the Plan priorities affordable housing (Policy STR1). This would not mean that affordable housing would predominate over other land uses - the Council would still continue its aim of an overall balance and distribution of land uses, and given that these are mostly small sites set against a residential backdrop this aim would be strengthened. Nor would it mean a lessening of a commitment to regeneration. After all people only need affordable housing when they have no job, have low household income or cannot work.

POLICIES AND PROPOSALS

5.6 Additional housing

5.6.1 Brent’s additional housing figures have been incorporated into the GLA’s London Housing Capacity Study which the Government has accepted in RPG9. As well as bringing empty housing into use, empty and underused buildings can be converted into new housing, as promoted in PPG3. Making good use of previously developed land can also be a sustainable use of existing resources.

5.6.2 The draft London Plan, 2002, sets out in Table 3A.1 additional homes targets for London 1997-2016. It requires Brent to provide 13,510 extra homes between 1997 and 2016. This is based on the Housing Capacity Study published by the GLA (2000). Brent’s capacity for new self contained dwellings, to be produced through new build and conversion, is 9,647 with a potential total of 13,510 homes including non self-contained dwellings and vacant dwellings brought back into use. These capacity figures are rounded up in The draft London Plan and form the basis of Brent’s additional housing requirements from 1997 to 2016.

5.6.3 The additional housing target will be comprised of housing on small and large sites, office conversions, conversions of residential dwellings and work-live units. The supply of housing is set out in the GLA’s Housing Capacity Study 2000. Also identified in this study was an element of windfall dwellings. This is supply that is anticipated given current and future trends but not yet identified on particular sites. These various components of housing supply will be monitored over the Plan period to identify the contribution each will have, to meet or exceed the Plan’s housing targets.

5.6.4 The housing development trend in recent years indicates that Brent is on target to meet its capacity allocation as permissions and completions rates are exceeding the GLA’s annual monitoring indicator of 480 new self contained dwellings per year (see Appendix 1).

5.7 Affordable housing

5.7.1 This section looks at exactly what 'affordable' housing means in the Brent context, how much of it is needed in the Borough and how it might be provided. Affordable housing does not mean 'council housing'; it is an objective term relating cost of housing to income, rather than specific to a tenure. However, it is the cost of general market housing (such as housing for sale freehold / leasehold or private sector housing for rent) that necessitates a 'social housing' sector - this can span local authority housing, housing associations, trusts, co-operatives and similar bodies - generally for rent but also including various forms of shared ownership and subsidised housing to buy and rent at below market cost. The majority of affordable housing in the Borough is no longer Council managed.

National Policy Context

5.7.2 PPG3 states: that a community's need for a mix of housing types, including affordable housing is a material planning consideration which should be taken into account in formulating development plan policies.

5.7.3 Circular 06/98 Planning and Affordable Housing, states that the aim of Government policy is to secure mixed and balanced communities to avoid areas of social exclusion. Where affordable housing is to be provided the preference is to provide it as part of the development. Affordable housing encompasses low cost market and subsidised housing that will be available to people who cannot afford to rent or buy homes generally available on the open market.

5.7.4 Authorities should make a rigorous assessment of need for affordable housing. Where the assessment demonstrates a need then local authorities should include in the Plan a policy for seeking an element of affordable housing on suitable sites and indicate in the Plan how many affordable homes need to be provided in the Plan’s area(s). In assessing the suitability of sites for affordable housing (including windfall sites) the planning authority should take into account site size, suitability and the economics of provision and the need to secure a successful housing development.

5.7.5 Draft PPG3 proposes the cancellation of Circular 6/98 in favour of giving local authorities substantially greater flexibility in securing the level and types of affordable housing that best meet their local identified needs. This would permit authorities to further reduce site size thresholds and define specific tenures to satisfy affordable housing needs, which may exceed overall housing provision. Draft PPG3 also proposes to remove the Circular 6/98 presumption that ‘low cost market housing’ is universally ‘affordable’.

Regional Policy Context

5.7.6 RPG9 specifically recognises the need for substantial new affordable housing provision in the South East (para 8.7) by setting out indicators equivalent to 42% - 44% of the total dwellings provision being affordable (Policy MON1).

Metropolitan Policy Context

5.7.7 RPG3 states that UDP policies on affordable housing are best implemented by taking a clear and consistent view of the needs of the Borough in the context of London as a whole. RPG3 suggests that Boroughs should; “...identify sites or areas which are particularly suitable for affordable housing...” (para. 4.21).

5.7.8 The Government’s national affordable housing strategy as specifically applicable to London has been recently elaborated in Sustainable Communities in London: Building For The Future (2003) which notes with particular concern that;
“The demands of the capital’s economic and population growth have not been matched by an increase in the supply of housing . Skills shortages are often linked to a lack of affordable housing which is pricing key workers out of the housing market.” (page 4).

5.7.9 The draft London Plan emphasises the key importance of affordable housing and proposes that 50% of all new dwellings should be affordable. It specifically indicates, on the basis of detailed housing market viability research, that this target should be attainable in boroughs with land values and house prices such as in Brent.

5.7.10 The Draft London Plan (DLP) Policy 3A.8 specifies that the 50% affordable housing element should be provided on the basis of 35% social rental and 15% intermediate housing which are defined as:
“Social Housing - Housing usually provided by a Registered Social Landlord or Housing Authority, using public subsidy, at levels no higher than Housing Corporation target rents.” (DLP, para. 3A.31).
“Intermediate Housing - Sub-market housing substantially above Housing Corporation target rents, but substantially below open market levels. This category includes low-cost home ownership schemes and key worker housing. It may also include some low cost market housing where its price is close to other forms of intermediate housing.” (DLP, para. 3A.31).

The Affordable Housing Site Size Threshold

5.7.11 The 'size-threshold' is the level above which 'large' housing sites should include affordable housing. Circular 06/98 classifies Brent as an Outer London borough which has higher site size threshold (25 dwellings) than Inner London (15). However, it does concede that some authorities may be able to demonstrate exceptional local constraints which may justify a lowering of the higher threshold. This flexibility is substantially expanded in the proposed revisions to PPG3 which seeks to have a lower nation wide threshold of 15 dwellings, which may be further reduced if the local authority can justify this in terms of acute housing need.

5.7.12 In terms of almost every conceivable measure - overcrowding, housing need, poverty, demographics, regeneration needs etc. Brent most closely matches the characteristics of Inner London boroughs rather than most Outer London ones. The 'official' definition of 'Outer London' is based on the historic boundary of the London County Council - rather than modern day realities. It is argued then that Brent is best characterised as an 'Inner London' borough for purposes of this threshold - especially as Brent is considered an Inner London borough by the Housing Corporation; and that a realistic threshold of 15 units / 0.5 Ha should apply. Particularly as the housing provision study shows that in comparison to the proposed threshold the Circular threshold would only result in just over 500 affordable units from identified sites, as there were few previously developed large sites, with a predominance of small sites. But these small sites could provide 200 extra affordable units with the lower threshold.

5.7.13 The Council will encourage the provision of affordable housing below the ‘Inner London’ threshold and will have regard to the Mayor of London’s proposals in The draft London Plan not to include a site threshold for affordable housing.

The Definition of Affordability

5.7.14 The Council is proposing to follow, as the basis of policy, the RPG3 definition of affordable housing as housing affordable to “...households...in unsuitable accommodation and [who] cannot afford market housing...” (Para. 4.21). “Affordable housing is here taken to mean both subsidised and market housing designed for those whose incomes generally deny them the opportunity to purchase houses on the open market, as a result of the local relationship between income and market price.” (para 4.19). None-the-less this 'local relationship' needs to be elaborated. The formula used by the policy is based on typical lending formula for mortgages and ODPM suggested maximum rental levels (source:Appendix A2 Brent Housing Needs Survey 1998). It does not imply regulation of housing association rents and is entirely neutral of tenure, as any tenure falling below the definition will be regarded as affordable.

5.7.15 None-the-less RPG3 recognises, however, that “Boroughs may find this need can only be realistically met through the promotion of subsidised housing (whether in the public or private sector).” (para. 4.19), and Brent falls into this category. It is accepted that 'typical' outgoings for some specialist forms of accommodation may be, of necessity, higher than normal, e.g. key workers housing / homeless persons accommodation. To meet the meet the definition of affordable housing, housing must be so in perpetuity, i.e. affordable to both initial and subsequent occupiers. The involvement of a registered social landlord is considered sufficient to meet this test.

5.7.16 The Brent Housing Need Survey 2003 established that it is necessary to ensure a satisfactory range of affordable dwelling type and size to meet the Borough’s specific need to accommodate family households, as it requires a minimum household income of £46,000 (assuming £10,000 savings) to purchase the cheapest two bed flat in Brent. Larger families, who particularly tend to require affordable housing, face a very significant shortfall between the estimated demand and supply of three (866 : 115) and four or more bedroom (744 : 28) affordable units.

5.7.17 The Survey also found that about a third of the households in housing need, mostly requiring one and two bedroom dwellings, would be able to afford intermediate housing, including shared equity housing. Therefore, shared ownership housing will have a supporting role to play in contributing to meeting part of this need.

5.7.18 'Priority need' as defined by Section 59 of the Housing Act 1985 is principally where the applicant, or person who might reasonably be expected to reside with them, has dependent children, is pregnant, or is vulnerable through mental or physical illness, disability or old age.

continue to rest of Chapter 5

Foreword

Introduction

Strategy

Built Environment

Environmental Protection

Housing

Transport

Employment

Town Centres & Shopping

Tourism, Entertainment & the Arts

Open Space & Recreation

Community Facilities

Waste

INSET PLANS

Park Royal

Wembley Regeneration Area

Site Specific Proposals

Glossary

Borough-wide maps