Simon Osborn, Esq
Programme Officer
Lambeth Core Strategy Examination in Public
Dear Sir
I attach further statements on behalf of the Kennington Association, in relation to
- affordable housing
- employment land
- tall buildings
We are disturbed that no community association has been listed in your provisional list of participants, only developers and the Council, and that such an abbreviated timescale is being adopted, to deal with so many issues (4 days only, cf 8 days for the equivalent proceeding in Southwark).
We ask that we be listed for all four days' discussions
Yours sincerely
David Boardman
Chair
Kennington Association Planning Forum
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Note by the Kennington Association Planning Forum
Lambeth Core Strategy
Examination in Public –Affordable Housing - Policy S2(c)
1 This Association is a Rule 6 party at the current Bondway/Octave Tower Inquiry, at which the full Affordable Housing Assessment and Independent Appraisal for the proposed, predominantly residential, development were put in evidence. From these, and evidence emerging at the Inquiry, it is possible to form a more detailed view of the methodology of viability testing using the “Three Dragons” toolkit.
2 The current issue of the toolkit requires, before the application is lodged, a comparison of likely costs of development, particularly construction costs, financing charges and developer profit at standard rates, versus likely proceeds, particularly the estimated value of ultimate market sales, and capitalised value of any rental element like office floorspace. The amount of affordable housing is computed as that proportion of the residential build, with or without housing grant, that is calculated to allow the residual value (proceeds minus costs) just to exceed the existing use value of the site. In the Bondway case, the affordable provision emerged from this process as 23% affordable with grant (cf the 50% headline rate in policy)
3 This calculation is performed well before determination of the application (in the case of Bondway in mid 2009, with appeal not likely to be determined until the last quarter of 2010). Typically it is subject to independent technical appraisal by outside experts on behalf of the Council, and in the Bondway case they estimated future flat prices as 5% more than the developer. It emerged in evidence that this higher figure would support not 23% but 32%, a full nine percentage points higher, a highly leveraged result.
4 This affordable provision is subject to a review mechanism, under which the process is repeated 3 months before implementation. This still involves the estimation of flat prices some four years before completion, which is a highly inaccurate process. As the attached note shows, the professional forecaster Property Forecasts, forecasting house prices only three years ahead for towns and cities, finds that only 25% of its forecasts are within 15% of the actual results (2009 actual compared with 2006 forecasts).
5 Given the sensitivity to estimated market sales, there can be no confidence that the methodology is delivering an accurate assessment of the capacity of developments to sustain affordable housing, and an inevitable suspicion that estimates will be made conservatively, to the detriment of affordable housing provision. There is no regular post implementation review of the assumptions made, once actual market sales proceeds are known, and if there is to be any confidence in the methodology, there should be. We think Policy S2(c) should be amended to provide for just such a post implementation review.
David Boardman
Chair
Kennington Association Planning Forum
2 August 2010
Note by the Kennington Association Planning Forum
Lambeth Core Strategy
Examination in Public –KIBAs - Policy S3(b)
1 This Association is a Rule 6 party at the current Bondway/Octave Tower Inquiry, at which a development with
· 90% residential floor space,
· one and a half percent commercial Gross Development Value,
· on a KIBA (MDO81 under the current UDP) requiring 30% employment floor space for any redevelopment
· a reduction of 40% in employment floor space compared with the existing use of the site
argued that it should be allowed to proceed.
2 In the light of this development, pressure to bias “mixed use” development very heavily to the residential end, is likely to dramatically reduce employment floor space in aggregate. This would be to the detriment of employment uses, along with the de-designation of the Vauxhall KIBAs and the softening of the employment space test, so eg that provision of employment floor space of no more than 50% of site area would satisfy the policy. We oppose the de-designation of the Vauxhall KIBA, and argue that Policy S3 should have as an underpinning minimum, that no redevelopment on a KIBA should reduce existing employment floor space on that site.
David Boardman
Chair
Kennington Association Planning Forum
2 August 2010
Note by the Kennington Association Planning Forum
Lambeth Core Strategy
Examination in Public –Vauxhall, Tall Towers
1 This Association is a Rule 6 party at the current Bondway/Octave Tower Inquiry, at which the basis for a cluster of tall buildings for Vauxhall was examined, together with the issue of provision of additional open space, as an element critical to the success of any cluster. Through Freedom of Information requests, this Association was able to illuminate these issues by putting before the Inquiry two urban design studies of potential clusters at Vauxhall, commissioned by Lambeth Council, but previously unpublished, and these are attached to this note.
2 At least 4 sorts of cluster are on offer at Vauxhall, all in studies or draft planning documents, and nothing useful in adopted policy. As the 2006 urban design study foresaw, the absence of adopted planning guidance has meant that tall tower proposals are coming forward piecemeal, and some, such as Bondway, cite the Draft VNEB Opportunity Area Planning Framework’s suggested cluster as justification for a 150m tower to the south, close to conservation areas and Vauxhall Park, rather than the draft SPD’s proposed cluster with its roof lines rising toward the Vauxhall Cross site in the middle.
3 Supplementary planning guidance is urgent, and the cited policies are deficient, in that they fail to require new open space at the heart of any cluster. This was a significant element of the draft SPD (at p72) and was seen as critical by CABE to the success of the entire cluster, when reviewing the Bondway design. But developers are declining to provide it, looking to the next set of developers to do what they are unwilling to do themselves.
4 We strongly believe that these policies, particularly S9(d) and PN2(f) should be amended to require any cluster at Vauxhall (which is indeed in an Open Space Deficiency Area) to be designed round additional new open space, and that developers should expect to contribute to its establishment in kind or cash equivalent, as already provided for by the current Lambeth SPD for S106 contributions for open space in Vauxhall (Appendix D1).
David Boardman
Chair
Kennington Association Planning Forum
2 August 2010
Historic accuracy of 3 year forward flat price estimates – Note By KAPF
Source: Propertyforecasts.co.uk – 29 July 2010
Historic accuracy figures summary, Towns & Cities (tested Sept 2009)
As with the Neighbourhoods, comparisons are between forecasts we made in Aug 2006, from Land Registry data to June 2006, and filtered Land Registry data up to the end of second quarter 2009. Averages for Towns & Cities are calculated from postcode sector (neighbourhood) forecasts, using (mainly) the Royal Mail definitions for towns and averaging relevant sector values .
· Overall for houses, around 81-86% of three-year historic forecasts are classified A or B, down around 10% from last year; 25-29% are classified as A, significantly down from last year’s 64-70%.
· Around 38 % of A forecasts for houses are within 15% of the averaged filtered Land Registry values at June 2009, well down on last year, with only around 7% within 5%.
· For houses, 27-28% of A and B forecasts are within 15%, and 25-26% of all forecasts (including U) are within 15% at the end of three years. For flats & maisonettes, this figure has fallen somewhat to 23% of A and B forecasts within 15%, and 20% of all forecasts.
· Less than 2% of all house price forecasts are classified as U; for flats & maisonettes, around 5.3% are classified U.
· Around 26% of all forecasts are in the same overall direction as the smoothed Land Registry data. For A category forecasts, this is 33-37%.
· Average error at the end of three years for A classified forecasts is around +16% (standard deviation SD of 6.5%), while that for A and B classifications together stands at around 21% (SD around 11.4%). For flats & maisonettes, average error for ‘A’ and ‘B’ classifications was +22%, with an SD of 11.7%.
· Overall average error was between +22.8 and +23.7% for houses (SD 15-16%), and +28% for flats & maisonettes, with a somewhat higher SD of around 20%.
Once again , a ‘-’ sign against an error value would show an underestimate, while positive values show over-estimates. All values indicate overestimates, as one would expect in the boom-and-bust climate prevailing over the last three years.
Flats & Maisonettes: | 'A' | 'B' | 'C' | 'U' | ALL |
Proportion of dataset (%) | 10.6% | 54.3% | 26.3% | 8.8% | 100% |
Average error | 13.8% | 21.8% | 34.3% | 67.0% | 28.2% |
Standard Deviation of error | 7.8% | 13.4% | 26.0% | 40.7% | 24.8% |
Proportion positively correlated | 51.2% | 28.7% | 27.5% | 19.3% | 30.0% |
Average correlation | 0.02 | -0.17 | -0.21 | -0.29 | -0.17 |
Within 5% after 3 years | 10.5% | 8.5% | 5.4% | 0.4% | 7.2% |
Within 10% after 3 years | 28.2% | 17.7% | 12.4% | 1.1% | 16.0% |
Within 15% after 3 years | 52.4% | 27.5% | 18.4% | 2.4% | 25.5% |
David Boardman
KAPF
29 July 2010
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