GLA response to tenant inquiry about Cavalry Barracks housing development, Hounslow

Published on July 18, 2023

Published on July 18, 2023

A tenant representative wrote to the GLA about the Cavalry Barracks housing development on public Ministry of Defence land in Hounslow, where we might have reasonably expected to get a large amount of desperately needed social rented housing.  Below, are their questions (bolded) and the GLA’s response, which in many ways confirm that current London Plan policy fails to provide the social rented housing that so many London residents so urgently require. 

1. Since this is on public land (Ministry of Defence) should the amount of affordable housing not be 50 per cent, not 35 per cent?

London Plan Policy H5 sets a 50 per cent affordable housing threshold for schemes on public land which enables applications to follow the Fast Track Route. Proposals on public land which do not provide 50 per cent must follow the Viability Tested Route to determine the maximum viable level of affordable housing that can be delivered. In this case, the scheme was viability tested because only 25 per cent affordable housing was proposed originally. This was increased to 35 per cent by habitable room (and 36 per cent by unit) following viability testing. This was assessed as more than the maximum viable level of affordable housing that can be provided. Issues affecting viability in this case included the relatively high existing use value and low residential values in this location compared with other parts of London. 

A number of viability review mechanisms were also included in the S106 agreement which will determine whether a greater level of affordable housing can be provided if viability improves as the development progresses.

2. Why are there still London Affordable Rent properties rather than all rented properties in the affordable category being social rented?

The scheme will provide an affordable housing tenure split of 60 per cent social rent (62 units)/ London Affordable Rent (103 units) and 40 per cent intermediate housing (111) which is in line with the Hounslow Local Plan 60:40 tenure requirement. This is also in line with London Plan policy H6 which allows the provision of social rent and London Affordable Rent, reflecting the restrictions placed by government on the 2016-23 Affordable Homes Programme which could fund London Affordable Rent, but not social rent.  

3. The number of social rented homes in Phase 1 – 62 out of a total of 765 homes – is very small and as you know, London Tenants Federation constantly highlights that this is the only type of housing actually affordable for most Londoners, particularly those on borough housing lists.  How does this square with the aims of the London Plan?

As set out above, London Plan H6 allows the delivery of London Affordable Rent, however the Draft Affordable Housing London Plan Guidance prioritises the delivery of social rent in line with the 2021-26 Affordable Homes Programme which funds social rent, but not London Affordable rent. The guidance cannot however change London Plan policy and so the provision of London Affordable Rent currently complies with the Development Plan and it is not possible to refuse planning consent on this basis. 

In this case the scheme originally proposed to provide no social rented housing, however this was amended during the application process to include 62 social rented units. The number of family sized units was also increased. The applicant did not agree to provide more social rented housing which would have reduced the viability of the development and resulted in the delivery fewer low cost rent homes and less affordable housing overall.  

4. Has this large development already been approved by the Mayor or will it still be coming to him for approval or rejection?

The scheme was considered at Stage 2 of the Mayoral referral process in March 2023. The decision was to allow the Local Planning Authority to determine the application itself.