Policy 3.8 Housing choice



A  Londoners should have a genuine choice of homes that they can afford and which meet their requirements for different sizes and types of dwellings in the highest quality environments.

LDF preparation and planning decisions

B  To inform local application of Policy 3.3 on housing supply and taking account of housing requirements identified at regional, sub-regional and local levels, boroughs should work with the Mayor and local communities to identify the range of needs likely to arise within their areas and ensure that:

a  new developments offer a range of housing choices, in terms of the mix of housing sizes and types, taking account of the housing requirements of different groups and the changing roles of different sectors in meeting these

a1  the planning system provides positive and practical support to sustain the contribution of the Private Rented Sector (PRS) in addressing housing needs and increasing housing delivery

b  provision of affordable family housing is addressed as a strategic priority in LDF policies

c  ninety percent of new housing[1]meets Building Regulation requirement M4 (2) ‘accessible and adaptable dwellings’

d  ten per cent of new housing[2] meets Building Regulation requirement M4 (3) ‘wheelchair user dwellings’, i.e. is designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users

e  account is taken of the changing age structure of London’s population and, in particular, the varied needs of older Londoners, including for supported and affordable provision

f  account is taken of the needs of particular communities with large families

g  other supported housing needs are identified authoritatively and co-ordinated action is taken to address them in LDF and other relevant plans and strategies

h  strategic and local requirements for student housing meeting a demonstrable need are addressed by working closely with stakeholders in higher and further education and without compromising capacity for conventional homes.

i  the accommodation requirements of gypsies and travellers (including travelling show people) are identified and addressed, with sites identified in line with national policy, in coordination with neighbouring boroughs and districts as appropriate.

j  appropriate provision is made for the accommodation of service families and custom build, having regard to local need.

Supporting text

3.48  Many households in London already require accessible or adapted housing in order to lead dignified and independent lives: 28,000 are attempting to move to somewhere more suitable to cope with a disability and more than 267,000 need a home adaption[3]. More Londoners are living longer and more older people are choosing to remain in their own homes rather than go into residential institutions. To address these and future needs, 90 per cent of London’s new build housing[4] should be built to Building Regulation requirement ‘M4  (2): Accessible and adaptable dwellings’[5] and the remaining 10 per cent of new build housing[6] should be built to Building Regulation requirement ‘M4 (3): Wheelchair user dwellings’ [7].  LDF policy departures from these requirements must be justified by authoritative evidence from local needs assessments.

3.48A  As set out in Approved Document M of the Building Regulations - Volume 1: Dwellings, to comply with requirement M4 (2), step free access must be provided. Generally this will require a lift where a dwelling is accessed above or below the entrance storey. The application of requirement M4 (2) has particular implications for blocks of four storeys or less, where historically the London Plan has not required lifts.  Boroughs should seek to ensure that dwellings accessed above or below the entrance storey in buildings of four storeys or less have step-free access. However, for these types of buildings this requirement may be subject to development-specific viability assessments and consideration should be given to the implication of ongoing maintenance costs on the affordability of service charges for residents. Where such assessments demonstrate that the inclusion of a lift would make the scheme unviable or mean that service charges are not affordable for intended residents, the units above or below the ground floor that cannot provide step free access would only need to satisfy the requirements of M4(1) of the Building Regulations. All other standards should be applied as set out in this Plan. Further guidance is provided in the Housing SPG.

3.49A  The requirement for ‘wheelchair user dwellings’ applies to all tenures. However part M4 (3) of the Building Regulations regarding ‘wheelchair user dwellings’ distinguishes between ‘wheelchair accessible’ (a home readily useable by a wheelchair user at the point of completion) and ‘wheelchair adaptable’ (a home that can be easily adapted to meet the needs of a household including wheelchair users). The Planning Practice Guidance[8] states that Local Plan policies for wheelchair accessible homes should only be applied to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling. Boroughs should therefore specifically assess the level of need for wheelchair accessible dwellings and identify this in their LDF policies.

3.50  The Mayor has identified the growing and changing requirements for housing older people in London as one of the most important emerging planning issues for London. It is anticipated that between 2011 and 2036 ‘over 65s’ could increase by 64% and ‘over 90s’ could grow in number by 89,000.

3.50A  Most older Londoners are likely to prefer to remain in their own homes, and some will require support to enable them to do so. It is important that new development expands this choice for existing and future generations of older Londoners. Policy 3.5 on housing quality and its associated housing standards[9] will play a key role in extending choice by ensuring 90 percent of new dwellings are ‘accessible and adaptable dwellings’ and ensuring that 10% are wheelchair user dwellings[10].  More generally, London’s changing urban environment must respond positively to the needs of an ageing population, including through the principles for inclusive design and those to develop and extend Lifetime Neighbourhoods set out in Policies 7.1 and 7.2.

3.50B  Research suggests that the choices (see Glossary) open to older Londoners to move into local specialist housing may have been constrained through inadequate supply. Extending these choices through a higher level of specialist provision will in turn free up larger homes for family occupation. Over the period 2015 – 2025 older Londoners may require 3,600 – 4,200 new specialist units per annum. At the mid-point of this range, these might be broken down broadly into 2,600 private units pa, 1,000 in shared ownership and some 300 new affordable units. There may also be a requirement for 400 - 500 new bedspaces pa in care homes[11]. The draft London Housing Strategy[12] sets out proposals for investment and partnership working to support this provision.

3.50C  Boroughs should demonstrate in their LDFs and other relevant strategies and plans how they have identified and addressed the local expression of these strategic needs including through targets and performance indicators. These should be informed by the indicative requirement benchmarks set out in Annex A5: Specialist housing for older people. Boroughs should work proactively with providers of specialist accommodation for older people to identify and bring forward appropriate sites, taking particular account of potential capacity anticipated from housing led, high density, mixed use redevelopment of town centres (see Policy 2.15). Both should work with registered providers and other relevant partners to support the provision of additional ‘intermediate’ models of housing. In order to widen the choice of residential environments for older people, boroughs should also encourage ‘mainstream’ housing developers to extend their product range to meet specialist needs. More generally, it is important that viability assessments take into account the distinct economics of specialist housing and care home provision.

3.50D  Through his role as Chair of the London Health Board the Mayor will promote recognition of the importance of decent housing for older Londoners as a strategic health issue. He will encourage the Health and Wellbeing Boards to address this, especially through coordination of social and other services to enable older people to remain in their homes. He will also encourage the London Health Commission to take it into account when reviewing health and care service resources[13].

3.50E  The Housing SPG provides guidance on implementation of this policy to help ensure the highest quality of life for older people. The glossary to this Plan and the SPG provide guidance on the different types of specialist accommodation and the SPG outlines innovative approaches and initiatives to meet need, ranging from supported independent living through the promotion of lifetime neighbourhoods, accommodation with some linked care and services, and more specialist care accommodation.

3.51  In view of the scale of the projected growth in London’s older population and the housing affordability issues it raises, this Plan supports boroughs in seeking application of the principles of its affordable housing policies (policies 3.10, 3.11, 3.12 and 3.13) to the range of developments – including those falling within Use Class C2 – which cater specifically for older people.  These principles include taking account of site circumstances, development viability, needs assessments and availability of development capacity and relevant public subsidy; the need to encourage rather than restrain residential development and to promote mixed and balanced communities and circumstances where ‘off-site’ contributions, ‘contingent obligations’ or other phasing measures may be appropriate. The way in which these principles can be applied most effectively will vary with local circumstances and will require close integration between planning and other borough strategies to meet social needs. Such an integrated approach will also be required to address the needs of other groups which may require accommodation-based, supported care services such as hostels, refuges and foyers, as well as housing needs connected with particular types of occupation e.g. health workers, police, hotel staff.

3.52  London’s universities make a significant contribution to its economy and labour market (Policies 3.18 and 4.10). It is important that their attractiveness and potential growth are not compromised by inadequate provision for new student accommodation. While there is uncertainty over future growth in the London student population and its specialist accommodation needs, including the unmet demand, there could be a requirement for some 20,000 – 31,000 places over the 10 years to 2025[14].  New provision may also tend to reduce pressure on other elements of the housing stock currently occupied by students, especially in the private rented sector. The SHLAA has identified a pipeline of circa 20,000 student bed spaces 2015–2025.

3.53  Addressing these demands should not compromise capacity to meet the need for conventional dwellings, especially affordable family homes, or undermine policy to secure mixed and balanced communities. This may raise particular challenges locally, and especially in four central London boroughs[15] where 57% of provision for new student accommodation has been concentrated[16].

3.53A  In addressing the need for specialist student housing, the Mayor will support proactive, partnership working by boroughs, universities, developers and other relevant bodies, including through his Academic Forum, to:

  • encourage a more dispersed distribution of future provision taking into account development and regeneration potential in accessible locations away from the areas of greatest concentration in central London, especially that anticipated from housing led, high density, mixed use redevelopment of town centres (see Policy 2.15);
  • secure accommodation which is more affordable for the student body as a whole;  and
  • ensure that in identifying and addressing local and strategic needs[17] for student accommodation, boroughs are informed by working with other relevant partners as indicated above.

3.53B  Student accommodation should be secured as such by planning agreement or condition relating to the use of the land or to its occupation by members of specified educational institutions. Where there is not an undertaking with a specified academic institution(s), providers should, subject to viability, deliver an element of student accommodation that is affordable for students in the context of average student incomes and rents for broadly comparable accommodation provided by London universities.  Information on this will be provided through the Mayor’s Academic Forum in the London Plan Annual Monitoring Reports.  Guidance on how such accommodation should be defined, delivered and retained will be provided in Supplementary Planning Guidance.

3.53C  If the accommodation is not robustly secured for students, it will normally be subject to the requirements of affordable housing policy (policies 3.10, 3.11, 3.12 and 3.13). While student accommodation is accounted as part of overall housing provision, it should be monitored separately because it meets distinct needs. Because of uncertainty over future demand/supply relationships the monitoring process must have particular regard to these.

3.54  Private renting (PRS) is the only housing sector to have shown relative growth in recent years and is set to play an increasingly important role in meeting Londoners’ diverse housing requirements. One in four London households now live in the sector and around two thirds of the one in eight of households in London that move home each year move into or within it. The planning system must take a more positive approach in enabling this sector to contribute to achievement of housing targets.  Montague’s[18] recommendations and the Mayor’s London Housing Strategy show how covenanted PRS can contribute towards this. Viability tests of covenanted PRS proposals should take account of the distinct economics of this type of PRS, as suggested by the Government’s Beta guidance[19].

3.54B  The Mayor will continue to work with institutional investors to encourage greater institutional involvement, more professional and less fragmented management, greater stability, high quality standards and, potentially, longer term rental periods and affordable homes for rent. More generally, the planning system should complement policies in the London Housing Strategy to support growth in private renting where this will result in well managed, good quality accommodation, mixed and balanced communities and sustainable neighbourhoods.

3.55  Shared accommodation or houses in multiple occupation is a strategically important part of London’s housing offer, meeting distinct needs and reducing pressure on other elements of the housing stock, though its quality can give rise to concern. Where it is of reasonable standard it should generally be protected and the net effects of any loss should be reflected in Annual Monitoring Reports. In considering proposals which might constrain this provision, including Article 4 Directions affecting changes between Use Classes C3 and C4, boroughs should take into account the strategic as well as local importance of houses in multiple occupation.

3.56  People from different communities should be free to lead their lives in different ways, subject to the need for mutual respect and responsibility. The Mayor is clear that the planning system should ensure fairness between the settled and traveller communities. It is his view that assessing levels of genuine local need, deciding on the level and location of suitable provision to meet that need and carrying out the necessary consultation with relevant communities and stakeholders is far more effectively done locally. Both because of the level of locally-specific detail involved, and the scale of the issue (relative to London’s other strategic housing needs), the Mayor agrees with national Government that boroughs should work with gypsies and travellers and other stakeholders to identify local needs for temporary and permanent sites, and develop and effective strategies to meet need through the identification of land for sites through their LDFs as set out in accordance with national guidance[20].

3.57  National guidance requires boroughs to identify, and keep updated a supply of:

  • deliverable sites to provide five years’ worth of sites against their locally set targets
  • developable sites or broad locations for growth for years 6-10 and, where possible, for years 11-15

with the number of pitches or plots related to the circumstances of the specific size and location of the site and its surrounding population’s size and density[21].  They should ensure that traveller sites are sustainable economically, socially and environmentally[22].

3.57A  The SHMA identifies the need for housing for service families and people wishing to build their own homes to support Policy 3.8[23]. The Mayor has refined the national housing strategy’s support for ‘custom build’ and the ‘community right to build’[24], by supporting this through his ‘Build Your Own Home – The London Way’ programme. The Mayor is keen to work with local communities and other partners to expand the concept so self build can be developed on a greater scale, and make a significant contribution to the evolution of a London vernacular[25].

3.57B  Government’s approach to meeting the needs of service personnel and their families is essentially through the housing allocations process. However, it suggests that self build may provide particular opportunities for members of this group to access owner occupation.

[1]     Unlike the other standards in this Plan, Part M of the Building Regulations generally does not apply to dwellings resulting from a conversion or a change of use.  Additional guidance on the applicable requirements of the Building Regulations (amended 2015) can be found in: Approved Document M Access to and use of buildings Volume 1: Dwellings.

[2]     ibid

[3]     GLA. Analysis of English Housing Survey 2008/09 -2011/12

[4]     Unlike the other standards in this Plan, Part M of the Building Regulations generally does not apply to dwellings resulting from a conversion or a change of use

[5]     Requirement M4 (2) Schedule 1 to the Building Regulations 2010.  HM Government 2015.

[6]     Unlike the other standards in this Plan, Part M of the Building Regulations generally does not apply to dwellings resulting from a conversion or a change of use

[7]     Requirement M4 (3) of Schedule 1 to the Building Regulations 2010. HM Government 2015.

[8]     The Planning Practice Guidance  (Housing- Optional Technical Standards) Paragraph: 009 Reference ID: 56-009-20150327 DCLG Revision date: 27 03 2015

[9]     Mayor of London. Housing Supplementary Planning Guidance. GLA, 2012 Note: this document has been superseded – please now see 2016 Housing Supplementary Planning Guidance

[10]     Requirement M4 (3) of Schedule 1 to the Building Regulations 2010. HM Government 2015

[11]     Cambridge Centre for Housing & Planning Research, Three Dragons, Land Use Consultants. The role of the planning system in delivering housing choice for older Londoners. Report for the GLA, GLA, 2012. Update GLA 2013

[12]     Mayor of London. Homes for London. The London Housing Strategy. Draft for Consultation.  GLA, 2013

[13]    London Assembly. Homes for older Londoners. Building healthy homes for a comfortable and independent  retirement. GLA, 2013

[14]    Mayor’s Academic Forum. Strategic planning issues for student housing in London. Recommendations. 2014. GLA

[15]    Islington, Tower Hamlets, Southwark and Camden

[16]    Mayor’s Academic Forum. 2014. op cit

[17]    ‘Strategic needs’ means a demonstrable need generated by institutions located beyond the boundaries of boroughs where development is proposed.

[18]    DCLG. Review of the barriers to institutional investment in private rented homes 2012. DCLG. 2012

[19]    DCLG. Beta draft National Planning  Practice Guidance. Viability: how should viability be assessed in decision-taking (accessed 29th October 2013).

[20]    CLG. Planning policy for travellers sites. March 2012

[21]    Ibid, paragraph 9

[22]    Ibid, paragraph 11

[23]    As required by para 50 of the NPPF

[24]    HM Government. Laying the Foundations: A Housing Strategy for England. CLG, 2011 HCA CLG. Custom Build Homes Fund Prospectus. HCA, 2012

[25]    Mayor of London. Build Your Own Home – The London Way. Supporting Custom Built Housing and Community Right to Build. Funding Prospectus. GLA, 2012

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