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
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
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
publish housing needs survey;
public consultation on housing needs;
publish housing needs policies;
review Local Plan policies1.
update local housing figures;
review housing needs policy;
review Local Plan affordable housing
policies (in the light of other social, economic and physical
publish revised housing needs policies
It should be noted that affordable housing can
housing for single parents;
small units for single people;
shared accommodation for young people
of single parents;
housing for the elderly;
housing for the disabled;
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
(a) Paying for the social housing elsewhere;
(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
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
LAs should establish and monitor
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
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.