LTF submission to GLA: Affordable Housing and Development Viability

Published on July 18, 2023

Published on July 18, 2023

London Tenants Federation has submitted commentary to the GLA on the Mayor of London’s two new London Plan Guidance (LPG) documents. Key points from the submission are outlined below and the full submission can be downloaded at the bottom of the page. 

LTF encourages others — whether as individuals or organisations — to write to the GLA in support of LTF’s submission or share their own comments highlighting that LPG documents must emphasise prioritising the delivery of housing at social rent levels and maximising delivery to meet housing needs of Londoners. LTF also expressed concerns about estate regeneration and how social rented homes are lost and replaced mostly with market homes for sale (see our research on 2012-2022 demolitions and 2019/2020 delivery).

The two LPG documents can be found at the following links: Affordable Housing and Viability. The closing date for making comments is 24 July 2023.

Key Points from the Submission:

Key Greater London Authority (GLA) strategic issues:

  1. Delivering more genuinely Affordable Housing (AH).
  2. Maximising delivery is critical to meeting the housing needs of London.
  3. Maintaining the function and resilience of the city.

Facts indicate a failure to meet these objectives:

  • Between 2005 and 2018, an additional 397,000 homes were built in London; just 12 % were social rented.
  • London’s unmet housing need was 78% social rented (2017 London Strategic Housing Management Assessment – SHMA).
  • In 2019/20, of 38,577 homes, 78.7% (30,387) were market homes. Only 2 % of homes delivered in London in 2019/20 were social rented.
  • The term Affordable Housing is meaningless for most Londoners as it encompasses shared ownership, aimed at households earning up to £90k pa; London Living Rent, aimed at households earning up to £60k pa; and even certain types of housing for sale.


The London Plan Guidance (LPG) needs to change. Developers, councils and housing associations must meet their obligations to provide affordable housing by building more social rented homes.  The London Plan stipulates that 30 % of Affordable Housing (AH) should be ‘low cost’, which includes the more expensive London Affordable Rent as well as social rent, further diluting the numbers of social rent properties; currently of the other 70 %, 30 % is intermediate and 40 % is left up to the provider to decide. 

The 35 % AH threshold to follow the fast track route (FTR), where no viability proposal is required, is too low.  The minimum should be at least 50 %. The AH LPG refers to the ‘strategic 50 % target’.  Why not make it a consistent, actual target instead of a theoretical ‘strategic’ one? 

The LPG needs to implement requirements on developers, and demand they meet their obligations.  The delivery of overall housing targets should not be relied on as a reason for reducing affordable housing delivery and this needs to be a watchword for councils and housing associations as well as developers.  

Section 106 agreements should include restrictions on the occupation of a proportion of market housing before an appropriate proportion of the affordable housing, particularly low-cost rent, has been constructed and disposed of to a registered provider (housing association) or the council.

We are deeply concerned about references to estate regeneration in both LPGs. The result of such regenerations in recent years is numbers of social rented homes are reduced, with much higher density largely of market homes for sale, and displacement of social housing tenants on the estate.