Karen Buck

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My response to the Westminster Housing Strategy

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Whether measured by unmet housing need, the human and financial costs of homelessness or the pressure of maintaining viable mixed communities, Westminster (..London, the country…) is locked into a housing crisis. The national, London and local housing strategies currently being implemented are wholly insufficient to the challenge and are in some cases making matters worse.

Too few homes, especially affordable ones:

It is worth remembering the conclusions of last year’s Ramidus report into the Prime Residential market in Westminster- commissioned by the Council- which said:

Westminster already has a severe shortage of affordable housing, a growing population, a very large and growing economy, and intense demand pressure from UK and overseas buyers and renters. It is inevitable that high prices are being driven ever higher, and that the cost of a home in Westminster is moving further from the reach of Londoners with ‘ordinary’ incomes.

 

It is striking that the borough has been losing lower income social groups; and the question that arises is whether this attrition is sustainable, without compromising Westminster's capacity to service itself?”

Furthermore:

The Local Housing Market Study identifies a requirement for delivery of around 1,180 social housing units each year over the next 5 years (2014-19), if the CoW was to clear its backlog in 10 years. In addition the LHMS identifies a need for intermediate housing over the period 2014-18 to of some 1,300 homes (260 homes per annum). Taking into account intermediate homes under construction and in the pipeline there is a requirement for provision of 355 intermediate homes per annum during the next 5 years.

Westminster has identified capacity for development of 1,068 new homes per annum through the London-wide SHLAA. If affordable homes account for 24% of completions as they have in the past 10 years, and this level of overall housing delivery is achieved, then about 255 additional affordable homes would be developed each year. This may be compared to the need for 573 affordable homes per annum identified in the LHMS over the long term, and the need for 1,180 social housing units over the next 5 years (2014-19)” (Wessex Economics: Westminster Housing Market analysis Dec 2014)

Westminster Council’s last Annual Supply and Allocation report confirmed the scale of the shortage of social housing- there were just 859 lettings in 2013/14, despite their being 2200 homeless households alone, even before taking over-crowding; medical needs and other drivers of need into account.

Social housing is a stable and cost-effective housing option, especially when viewed in the context of the exponential rise in Housing Benefit and the instability of life in the private rented sector. Yet the share of Westminster’s housing stock that is socially owned has fallen from 32% in 1986 to 23% now. The de facto shift of around 6000 housing units out of the social and into both the owner-occupied and (more crucially) private rented sectors over recent decades has directly contributed to the undermining of stable communities and to the high cost of homelessness = estimated to have cost Westminster over £100 million since 2010 alone.

So we need more homes, but especially more genuinely affordable homes both to rent and to buy, if the city is to remain economically and socially viable, and if Westminster is to meet its share of its obligations to those in housing need.

As the independent report by Wessex Economics study of the Westminster Housing market says:

there is a case for seeking to house low to middle income households in Westminster in terms of ensuring that those with long-standing community connections in Westminster can continue to live in the City, ensuring stability in local communities, and in the case of intermediate rented housing, a more stable form of tenure than private renting”

The Council also needs to develop a strategy for dealing with the implications of the growth of the Private Rented sector, which now accounts for close to half of all local properties. Much of the PRS locally is high value and in good condition, catering to international and business requirements. However, Increasing pressure is being generated via the short-let/tourist industry, especially in areas like Bayswater and Lancaster Gate. Even excluding short lets, the expansion of the private rented sector has an impact on communities and public services, high turnover, high cost and (at the bottom end of the market) some very poor conditions.

I support the key points made by my Labour councillor colleagues in their submission:

The draft Westminster Housing Strategy sets out a target of 250 per year (1,250 over 5 years) for the building of new affordable homes. Thought not currently stated in the document the Council says that this refers to building inside Westminster, and Labour asks that this be formally clarified in the strategy. Westminster has decided to set a 250 per year target despite the strategy admitting that there is (at least) a 420 per year need for new affordable housing in Westminster, while over 6,000 households are waiting, on heavily restricted lists, for new social and intermediate housing.  The Mayor’s London Plan sets out a 1,068 per year overall house-building target for Westminster and a London-wide target of 17,000 affordable housing units annually. This means that Westminster’s current plan would see just over 23% of the new-build housing in Westminster be affordable, contributing only 1.47% towards London’s annual affordable housing target.[1]

There is therefore a gap of 7% between proposed new affordable house-building and Westminster’s planning policy target of 30% or more of all new housing development in the city being affordable. This gap will in part be plugged by the council purchasing properties from housing associations[2] and the private sector. While helpful in housing management terms in particular circumstances, housing buyback should not be such a significant part of Westminster’s current and future new affordable homes strategy, particularly at such a low proposed level of new build, as they are not truly ‘new housing’”

We need:

 1. ….Greater ambition in securing more genuinely affordable housebuilding. This should include:

 

-          A higher percentage of new homes being affordable. Westminster’s current plan would see just over 23% of the new-build housing in Westminster being “affordable”, and that is on the narrow definition of affordability now in use.

 

-          An affordable housing target of 40%, not 30% of new developments. The 30% affordable housing target itself is the core of the problem with the proposed strategy. This is lower than in any other Inner London Borough. 40% (427 out of 1,068) is not an unreasonable starting point for a housing target, given that the majority of inner London boroughs (including our tri-borough partners) have set this goal or higher.

 

-          Whilst there is undoubtedly a need for additional ‘intermediate’/ sub-market properties, for rent and for sale, there is no justification for reducing the proportion of social housing in new developments, given the scale of need and the human AND financial cost of failing to meet it.

 

-          A more realistic definition of what is ‘affordable’—properties are not ‘affordable’ when they require an income of £80,000 in order to cover the cost whilst spending no more than 40% of household income on housing.

 

-          Following the example of other local authorities now pressing more strongly on developers’ viability assessments, to ensure that the process is more rigorous and transparent.

 

 2.……To avoid making a bad situation worse through further loss of stock- particularly family-size homes- as a result of forced sales of social housing to fund HA ‘Right to Buy’ (and other disposals). Exact figures are not yet available but lettings would be at least halved under current proposals- and possible worse. The replacement ratio for properties sold under Right-to-Buy is around 1 in 11- it is simply unrealistic on the basis of past performance to believe that sales will be balanced by local, equivalent replacement.

 

 3. …..Tougher action to ensure vital housing stock is not lost in scale to the ‘short let’ hospitality industry. The government has enacted measures in the De-regulation Bill that make it easier for owners to let their properties for up to six months in a single year, without the safeguards Westminster Council demanded. This creates opportunities for the systematic use of property for these purposes- not a ‘casual holiday let’, but a commercial venture. There should be renewed efforts to get these safeguards.

In addition:

12% of Westminster properties do not have anyone registered as a permanent resident. This is socially damaging and represents a poor use of homes. We need stronger action against ‘buy to leave’ investment and empty homes, again in line with good practice in other London boroughs.

In the light of recent revelations concerning alleged money-laundering and related criminal activity in the top end of the London residential marker, Westminster should be taking a lead with the government to lobby for tougher rules governing disclosure of and company ownership of property.

 

 4. …….A far better deal from the government in respect of Discretionary Housing Payments to cope with the impact of the Household Benefit Cap and other benefit cuts (there are still 817 households affected by the Bedroom Tax 2 years in, and new additions all the time) on households in housing need. Westminster has already had to contribute £1.1 million this year to cover for reduced Government funding. These pressures are certain to intensify with the proposed reduction in the Household Benefit cap and LHA freeze, and as more new households become subject to the Bedroom Tax over time.

Westminster should also agree to exempt Disability Living Allowance from any income calculations when making DHP decisions.

 5. …..A comprehensive assessment of the impact of homelessness and housing need in Westminster on health, well-being, educational achievement and life changes. Homelessness, over-crowding and housing need cannot be seen solely as a housing problem but in the context of public health, child welfare, education and economic development.

 At last count, Westminster had 2420 households in (expensive, unsuitable, often ex-Right to Buy) Temporary Accommodation properties. Homelessness continues to rise although the Council originally anticipated pressures would be easing by 2014/15. Many homeless households experience frequent moves, including moves to the other side of London and beyond. Schools are reporting more cases of children travelling for several hours a day to get to school. Parent’s employment and children’s education and well-being are severely damaged- and that is even before the financial cost of homelessness is factored in.

-          Westminster should also not be lobbying the government for a change to the law enabling permanent homes to be provided outside the borough. Out-of-borough Temporary Accommodation may sometimes be unavoidable, but Westminster should be lobbying for support to keep all vulnerable households and those with local family connections/children in Westminster schools in or close to the borough.

 6. ……Westminster has lost a number of recent court cases in respect of homelessness decisions (on out-of-borough placements, ‘reasonable preference, single homeless priority need)  and there have been many other cases that should have been resolved without the need to go to court. This is expensive and bureaucratic, as well as adding to the stress on already vulnerable individuals and families. The gatekeeping and decision making processes should be reviewed to reduce the number of cases brought against the Council.

 7. …A strategy to tackle over-crowding in both CWH and Housing Association properties,  and to increase the range of options open to the adult children of local tenants, in line with the Mayor of London’s original commitment. It is unacceptable that Housing Associations are failing to meet their own obligations to reduce over-crowding (especially whilst also selling local stock) and many local families are caught in extremely difficult circumstances, with the Housing Association offering no prospect for a move and the Council unwilling to assist.

Whilst agreeing with the importance of ‘intermediate’ housing options (for rent and purchase), these should be  aimed at those on average and below average earnings, so as to support local people and provide some of the same opportunities which were previously available via the Family Quota scheme.

 8. …Tougher action by the council to ensure that Housing Associations fulfil their duties as landlords (my recent survey of standards in Genesis property revealed the extent of the problem in relation to one large local provider, but there are also problems with other HAs, ranging from repairs to transfers to neighbourhood management.

 9. …A ‘Lessees Charter’, clearly specifying Westminster’s mutual rights and responsibilities, and with a commitment to greater speed and transparency in dealing with leaseholder’s concerns. A substantial proportion of my casework, and that of councillors, is generated by leaseholders unhappy with the quality of Major Works and Services; inadequate consultation procedures and poor billing and the clarity of financial information (a level of dissatisfaction borne out by the significantly lower level of satisfaction with CWH among leaseholders than amongst tenants).

 10. …A strategy for the the growing Private Rented sector in Westminster- up from 32% to 43% in a decade, and covering a wide range of properties, from the top of the luxury market catering to international and business tenants to ex-Right to Buy properties and properties in multiple occupation, some of which is characterised by poor conditions and bad landlords.  Apart from the fact that the entire sector is characterised by very high turnover; tenants across the spectrum can be at risk from exploitative letting agency fees and risks to deposits and there is a substantial need for better advice to this group.

Tenants need better access to advice and advocacy (see below); and Westminster could do more to promote the London rental standard and the London Landlord Accreditation Scheme. The Council should also be supporting measures to encourage longer tenancies for those who want them, to mitigate the impact of high population churn.

Two last comments:

11. ...I welcome the commitment to further action to tackle excess cold and damp in council properties (although Westminster should acknowledge the problems that have been caused by excessive delays in Major Works in some areas, such as the Hallfield Estate). However, it is often private and Housing Association properties were many of the most serious problems occur. Excellent work is being done by the Residential Environmental Health team but prevention would be greatly preferable to intervention after the event, when the resident has already suffered months and sometimes years of life in sub-standard accommodation.

12. The Council’s Housing Advice strategy was based on a comprehensive piece of consultancy five or so years ago- and never acted upon. The impact of the shortfall in advice was spelt out in the recent ‘Reform Advice in Westminster’ report and in the annual reports of the CAB, Law Centres and Z2K.

In the light of the loss of legal aid in many areas of housing/welfare/debt, and the high and rising level of need, Westminster needs to recognise the importance of advice, advocacy and representation- not only to residents, but to the Council itself- costs can be lowered, income can be maximised and homelessness applications sometimes avoided with the right intervention.

Finally, I agree with the comments from the Labour Group regarding the importance of tenant participation and consultation- this has been a fraught relationship for a number of years- and the benefits of an integrated and out-reach-based approach to raising skills and reducing worklessness and poverty locally. Westminster Council needs to better appreciate the complex demography and social factors (such as high population churn) which cut across many of its strategic objectives in these areas. There have been some examples of good practice (such as in Church Street and Harrow Road) with some genuinely good partnership working, but these are rarely sufficiently comprehensive enough, so that good work done by one team of officers is contradicted by Council actions in another area. Neither the establishment of genuinely ‘mixed, stable communities’, nor neighbourhood regeneration, nor an improvement in life chances for the poorest can be achieved without whole-hearted and sustained commitment.

Karen Buck MP

July 2015



[2] Please note that for ease of public understanding this document uses the term ‘Housing Association’ to denote all types of Registered Social Landlord/ Registered Provider.

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