Housing Core Strategy Review Issues and Options

Housing Issues and Options

8 Issue: The On-site/ Off-site Debate

Issues

8.1         One issue relating to affordable housing is the question of securing the ‘Maximum Reasonable Amount’ of affordable housing which is required by the London Plan.  To maximise the delivery of affordable housing the interlinking themes of on-site as opposed to off-site provision, financial contributions (either through s.106 agreements or through CIL), and how and where to provide the affordable housing that is secured need to be explored. The following issues cover how the maximum reasonable amount of housing could be secured. 

8.2         On - site delivery figures have been very low compared with the London Plan target. If additional affordable housing can be provided off-site (either within or outside of the Borough), should this be promoted?  This could be the case where, for example, the amount of affordable housing to meet local needs could be significantly increased.  In such cases, policy could incorporate additional flexibility to recognise these benefits. 

8.3         An off-site solution can help with overall housing delivery, provided that suitable sites can be identified.  It may be possible to secure additional benefits through off-site delivery of affordable housing: for example, a greater number of units could be provided, more closely aligned to our bespoke needs.  

8.4         A site may be too constrained to allow for appropriate on-site provision including the provision of larger family units, or, on-site provision may yield very few units which may give rise to management problems or an increased cost to the occupier.  In such cases, policy could incorporate additional flexibility to recognise these benefits. 

8.5         Although there are delivery benefits to off-site provision, there are also potential difficulties.  The availability of other suitable sites in, or close to, our small and densely-built borough is limited due to the central London location.  Development beyond London also risks failing to meet the aspirations of some of Kensington and Chelsea households, many of whom would anticipate having a link as close as possible to the Borough.  

8.6         What is meant by off-site, and the types of locations suitable would require careful consideration and definition, and such an approach would mean that local needs are not necessarily met locally.  Promotion of off-site provision either through in-kind provision on another site, or through the acceptance of a financial contribution in lieu of affordable housing could reinforce a geographical division of housing types, although this does not necessarily follow, or it could result in a borough where there is less diversity and one that is dominated by very high cost housing. However, many would argue that this is the case already and the planning contribution makes little difference, it is the rate of delivery that is important and off- site provision is the only way of seriously tackling housing need in the Borough.  

8.7         It may be possible that a slightly more sophisticated approach could be taken to the off-site as opposed to on-site provision.  This could involve seeking on-site affordable housing only on our much larger sites (e.g. our Strategic Sites).  Any financial contributions secured (through s.106 contributions or through CIL) would be ring fenced for affordable housing delivery provided that it met the concept of a mixed and balanced community. Whilst there may be variations on the example quoted it may offer a third option regarding affordable housing delivery in the Borough.    

The bulk of ‘In Kind’ affordable housing delivery: should it be on-site or off-site?

Options

Option 1: Retain the existing on site policy approach.  This requires that affordable housing is delivered on site and only in exceptional circumstances is off site provision supported.   

Pros 

    • The policy promotes housing diversity, and a balance of housing types across the Borough.
    • Has enabled delivery on-site and in-kind in a Borough with some of the highest land costs in the United Kingdom.
    • Provides a small contribution of affordable housing within the Borough to meet a small proportion of identified need.

Cons

    • Has involved low delivery figures, in terms of the number of units and makes little contribution towards housing need.
    • Is not always practical from a design or management perspective.
    • Does not always deliver the type of affordable units that are required.
    • May contribute towards a polarised community as in reality it has little material effect.
    • Involves immense administrative and legal effort for quite little gain.
    • Involves planners on viability discussions, for which they are not qualified, is complex to administer and can lead to delays. 

Option 2: Move towards in-kind but off-site delivery within the Borough. This might be justified where the number of housing units that could be delivered are significantly more than on-site provision or there may be practical delivery issues with on site provision. The off-site delivery approach: 

Pros

    • Could result in an increase in the number of affordable housing units being delivered.
    • May make it easier to provide a particular type of affordable housing unit, for example larger family units which are in great demand.
    • May make it easier from a design and management perspective as larger sites are easier to administer.
    • Could still be part of a more comprehensive scheme that provided a suitable mix of market and affordable units. 

Cons

    • May not meet the expectations of potential residents in terms of location.
    • May be difficult to administer within the Borough boundary because of the shortage of suitable sites.
    • May be difficult to administer if off-site was permitted only in the same ward.
    • May not necessarily contribute to a diversity of housing, especially on the donor site.  

Option 3: Relax the geographical restrictions on provision of affordable housing in the Borough.  The policy would be more flexible in allowing affordable housing to be provided anywhere in the Borough, irrespective of the existing levels. 

Pros

    • The approach would increase flexibility of affordable housing provision.
    • It could deliver significantly more affordable housing.
    • It would allow an easier response to changing needs over time.
    • It would treat the Borough as a single housing market, responding to needs across the Borough rather than attempting to be overly prescriptive. 

Cons

    • Certain areas or wards may receive a greater amount of affordable housing simply because they provide the opportunities.
    • The approach could conflict with strategic objective of creating housing diversity and mixed communities.
    • The policy may result in a mismatch of affordable housing types within areas, for example, too much intermediate housing where the need is for Affordable Rented housing, or vice versa.