They want affordable rents & security of tenure so they can live without the fear of landlords turning them out and have a bit of money left for other basic needs & travel costs

28 February 2018

Comments on the nightmare of bureacratuc definitions in The New London Plan 

Dear Mayor Khan, 

It is the income of the household that determines whether a home is genuinely affordable, not only the rent. 

It is the integrity of the Chartered Surveyor and the Chartered Accountant that determines whether the viability assessments provide enough affordable homes or not. It is not the Mayor's strategic target of 50% genuinely affordable homes .


  1. All public land ought to be used to build 100%  genuinely affordable housing with rents related to incomes not the Mayors strategic target of 50%, and private rents ought to be controlled.
  2. Land ought to be removed from the calculation of genuinely affordable housing as in Council Housing , Community Land Trusts and The Walterton and Elgin Community Housing.  

It is the income of the household that determines whether a home is affordable –  Only 100% genuinely affordable housing ought to be built on public land.

I am showing below the bureaucratic nightmare of definitions that determines whether low income Londoners can live a healthy life at genuinely affordable rents. The principle concern of Taxpayers Against Poverty is the fate of Londoners receiving statutory minimum incomes, including housing and council tax benefit.  A statutory minimum income is either the National Living Wage created by George Osborne plus housing & council tax benefit (he stole the name of the real living wage but not the substance) or the Universal Credit or the social security incomes and housing & council tax benefit provided to disabled people. See;

It is the income of the household that determines whether a home is affordable.  Londoners currently receiving statutory minimum incomes are not able to live a healthy life given the fact that their incomes and housing benefit have been cut and can even be stopped for weeks or months by a benefit sanction, the universal credit or a zero hours contract. That creates debts that are linked to mental health problems See;

None of the definitions of genuinely affordable housing in the London plan provide genuinely affordable housing in London because there is no statutory link between affordable housing  and statutory minimum incomes, or the real living wage. Until land is taken out of the calculation and builders build to that specification, as it is at the Walterton and Elgin Community Housing, The Community land Trusts and with Council Housing, London’s housing crisis will not be solved.  Therefore all public land ought to be used the build 100%  genuinely affordable housing, not the Mayors strategic target of 50%,  and private rents ought to be controlled.

A supporter of TAP has written “It sickens me that my children's years of study and hard work are rewarded so shoddily in terms of the kind of accommodation they can afford. They aren't asking for salaries in the millions - unlike the highly socially useful bankers. They don't want gold-plated Rolls Royces. In fact, neither of them has a car at all. They do want affordable rents and security of tenure so they can live without the fear of the landlord turning them out on a whim and have a bit of money left after paying the rent, travel costs and other basic necessities.“

It is the integrity of the Chartered Surveyors and the Chartered Accountants that determines whether the viability assessments provide enough affordable homes.

Viability assessments are not used, as the New London Plan definition suggests, “to determine the maximum level of affordable housing”. They are used by Chartered Surveyors and Chartered Accountants to determine the maximum level of profit for the developer and the landowner, which means the fewest possible truly affordable homes. The fewer the truly affordable homes the better the profits from homes sold or rented at market prices. See;

The Mayor has a “strategic target of 50 per cent of all new homes being genuinely affordable”. That is an open door for Surveyors and Accountants to walk through. A target is not a commitment to Londoners to provide enough truly affordable housing. Surveyors and Accountants are committed to the clients who pay their fees not to the poorest people, who need an affordable home in London.


Rev Paul Nicolson,

Taxpayers Against Poverty.




Definitions in The New London Plan.  

Affordable housing

Affordable housing is Social Rented, Affordable Rented and Intermediate Housing, provided to eligible households whose needs are not met by the market. Eligibility is determined with regard to local incomes and local house prices. Affordable housing should include provisions to remain at an affordable price for future eligible households or for the subsidy to be recycled for alternative affordable housing provision. This is a broad definition of affordable housing and is consistent with the 2012 NPPF. Paragraphs 4.7.3- 4.7.6 of this Plan set out the Mayor’s preferred affordable housing tenures

  • Social rented housing is owned by local authorities and private registered providers (as defined in section 80 of the Housing and Regeneration Act 2008), for which guideline target rents are determined through the national rent regime. It may also be owned by other persons and provided under equivalent rental arrangements to the above, as agreed with the local authority or with the Homes and Communities Agency.
  • Affordable rented housing is let by local authorities or private registered providers of social housing to households who are eligible for social rented housing. Affordable Rent is subject to rent controls that require a rent of no more than 80 per cent of the local market rent (including service charges, where applicable).
  • Intermediate housing is homes for sale and rent provided at a cost above social rent, but below market levels subject to the criteria in the affordable housing definition above. These can include shared equity (shared ownership and equity loans), other low cost homes for sale and intermediate rent, but not affordable rented housing.

Homes that do not meet the above definition of affordable housing, such as “low cost market” housing, may not be considered as affordable housing for planning purposes.

Viability Assessment An assessment of the financial viability of a development to determine the maximum level of affordable housing and other policy requirements where relevant to be undertaken in line with the methodology and approach set out in Policy H6 and the Mayor’s Affordable Housing and Viability SPG.

Viability Review Mechanism A review of development viability defined with a Section 106 agreement enabling the reassessment of development viability after permission has been granted, at an early, mid or late stage in the development process. These mechanisms address uncertainties in the application stage assessment of viability to enable the maximum level of affordable housing provision over the lifetime of a proposal.





from the Rev Paul Nicolson