To the Rt. Hon. James Brokenshire, MP
Secretary of State for Housing, Communities and Local Government
Dear Mr Brokenshire
I am writing to you in regard to a request which you may have received from Haringey Council, regarding housing land at Love Lane, part of the High Road West (HRW) redevelopment scheme.
I hope that you do not agree to this request, as there several outstanding issues with this development:
ONE: Loss of council housing
The on site provision of council housing at social rent would be reduced from 212 to 145.
TWO: Area impact
The wider area impact of the scheme, with its excessive provision of market sale dwellings, would drive up house prices and rents in the surrounding area. Based on market forces, there would be a negative impact for local people, who would be priced out of North Tottenham.
THREE: Not policy compliant
The scheme does not comply with the Local Plan, providing only 30% affordable housing, rather than the 40% required by policy.
FOUR: Excessive service charging
Love Lane tenants have been advised of seven likely new or increased service charges after redevelopment (p 184 of the Cabinet reports pack, 12/09/17):
‘We are committed to ensuring that the service charge for the new homes within the development are affordable for all residents, however, due to the fact that there will be more services provided for tenants in an improved and more secure environment, it is likely that the cost will go up – this may be due to increased services such as CCTV, concierge, lift maintenance, cleaning, repairs, more lighting, lots of green space and planting’.
Council tenants in Haringey have never paid service charges for lift maintenance or for repairs. The latter is a standard landlord obligation under the tenancy agreement. ‘Green space and planting’ should be a normal environmental provision which is not service chargeable; and the necessary maintenance of these green areas should not be service chargeable to tenants, if these are publicly-accessible spaces.
FIVE: No right of return
No right of return has been offered, instead the Council has worked hard to move secure tenants away permanently. Regeneration should be for the benefit of existing residents, but that is not so in this scheme.
SIX: Inadequate consultation
There was no ballot for residents on demolition. No alternatives were proposed for investment in the existing housing stock.
SEVEN: Poor doors and residential segregation
Lendlease’s business plan for High Road West is based on residential segregation by tenure. It is proposed to build a separate block for secure tenants and council resident leaseholders, on the least desirable part of the site behind the railway line.
Haringey Council needs to have the opportunity to reconsider this important issue.
The High Road West development is not viable in its current form, because Tottenham Hotspur Football Club has extensive strategic landholdings within the development site, which it is not prepared to sell. Tottenham Hotspur has lodged a planning application for a mixed use development with 316 dwellings at ‘The Goods Yard’ within High Road West. Apart from The Goods Yard, Spurs own a further nine plots of land within High Road West. All are owned offshore; this information comes from the Private Eye website.
NINE: Procurement and densification
The proposals for High Road West were effectively densified by the successful bidder Lendlease during the procurement process. The three shortlisted bidders were advised that the site capacity was 1,400 homes according to the masterplan, but Lendlease was awarded the contract based on proposing to build 2,500 homes.
There has been no adequate public explanation of this sudden additional densification, and no adequate discussion about what masterplan changes are proposed in order to increase capacity by 70% in this way. The probity of the procurement itself must be questioned, when one of the three bidders is allowed to offer much more development than the others. There is also the question of preferential treatment for Lendlease, who the previous Council administration saw as their cross-borough development partners.
TEN: Equality Impact Assessment issues
(a): Lack of assessment of differential impacts
The Equality Impact Assessment provided for the Cabinet meeting of 12/09/17 and the Full Council of 04/12/17 is an assessment of discrete impacts upon those who share relevant protected characteristics.
The differential impact of the scheme on black and minority ethnic (BAME) persons and non-BAME persons has not been considered, as it should have been according to the Public Sector Equality Duty under the Equality Act 2010 S149 (1b), which states that: ‘A public authority must, in the exercise of its functions, have due regard to the need to – (b) advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it’.
In other words, would the scheme mitigate or exacerbate the existing inequalities affecting BAME people? Haringey Council has made no attempt to address this question.
(b): Inadequate assessment of income and savings
The discussion of equality impacts does not consider the ability of BAME people to access the new homes being built, by payment of rents, service charges, mortgages, deposits and advance payments.
The Council’s Housing Needs Survey (2013) has not been referenced in the Equality Impact Assessment. Research into the Housing Needs Survey via Freedom of Information requests shows that while 48% of local households have no savings or are in debt (excluding mortgages), 61% of households of mixed heritage, 69% of black households, and 74% of Asian households in Haringey have no savings or are in debt.
(c): The only quantifiable target outcomes for BAME people are employment-related rather than housing-related. The area could become a place where black people may work, but cannot afford to live.
(d): The Equality Impact Assessment should consider the impact of higher service charges on equalities, but it has not done so.
ELEVEN: Changes in Council membership
There has been a change of Council membership this month, following the elections on 3 May.
By signing a Development Agreement with Lendlease, conditional on the Secretary of State’s consent to the land disposal, the previous council leadership sought to fetter the discretion of those who have now been elected to replace them.
The decision to apply for permission to dispose of housing land was made at a Full Council meeting on 04/12/2017, where the 49 Labour members were whipped to vote for it. In fact, twenty defied the whip by staying away, or by walking out to the bathroom before the vote was taken. The vote of 27 to 8 saw less than half of the Council’s membership voting in favour; and only 6 of the Councillors who voted for this application are members of the Council today.
In all the circumstances, I hope you can agree that it would be reasonable and fair to allow the newly elected Councillors a chance to re-examine this project.
Please can you advise me whether you have received a request to dispose of this land, and if so when, and how you expect to proceed in reaching your decision.