London Housing Commission - submission

Here is SHOUT's submission to the London Housing Commission. It sets out a carefully argued case for investment in social rented housing as the best way of dealing with some of London's intractable housing problems.












Response to Call for Evidence





SHOUT ( is a volunteer-run campaign making the case for investment in genuinely affordable homes and demonstrating the positive effects that such housing has on people and communities.



September 2015






Key messages


Our response to the Commission’s core questions is:


  1. There is no prospect of increasing building to the 50-60,000 a year in the London SHMA without a large programme of public investment.  20-30,000 a year of the new units need to be at genuinely affordable, that is significantly below-market, rents[1].  A mix with lower volumes of below-market rent would waste taxpayers’ money, result in continuing high levels of in-work poverty, and provide insufficient housing for the lower-income workers needed for London’s economic vitality.
  2. Increasing the stock of significantly below-market units over 10 years by around 250,000, as we propose, would be the most significant part of a strategy to address affordability, for renting and for owner-occupation.  It would:
  • directly offer homes at genuinely affordable rents to many more Londoners;
  • by increasing total rental supply, create downward pressure on rents in the private sector;
  • offer a route to home-ownership for currently priced-out private renters, by enabling them to save from their income and enter owner-occupation via Right to Buy or the general market;
  • create downward pressure on prices of homes for sale through increasing total housing supply, rebalancing the market between landlord and owner-occupier purchasers.

The public investment case for such a programme is unanswerable, but there are ways initial investment could be delivered without adding to the public spending and debt totals.

  1. Our campaign is concerned with social and community housing, so we leave it to others to make proposals directly addressing quality in the private rented sector.  However, the current inadequate supply of homes for rent at genuinely affordable levels, managed by accountable, regulated, social landlords is one of the main reasons why some private landlords can get away with renting out poorly maintained and managed homes.





SHOUT welcomes the opportunity to make a submission to the Commission.  We would be very interested in participating in any hearings or discussions in the next stages of the process: we may be contacted via Martin Wheatley,, 07722 997246.

SHOUT is an entirely volunteer-run campaign, set up in 2014, to make the case for public investment in genuinely affordable housing, and to combat the negativity and stigma which often surrounds debates about housing association and council homes and the people who live in them.  Its leadership group and wider base of sympathisers includes people with political opinions across the spectrum, as well as those who are non-aligned.  John Healey MP, Lord Porter, now Conservative LGA Chair, and Liberal Democrat, Green and cross-bench figures spoke at its launch in June 2014.  Leading members have recently been in dialogue with, for example, Treasury and CLG officials, and business trade bodies.  It has built its support base largely through social media: it has nearly 3,400 followers on Twitter.   More information about the campaign can be found on the website

Building New Social Rent Homes: An Economic Appraisal

National analysis

2.1 The points we make in this submission rest heavily on an important recent report Building New Social Rent Homes: an Economic Appraisal which SHOUT commissioned, in partnership with the National Federation of ALMOs (NFA), from the leading economics consultancy Capital Economics.  The report is included in this submission and is available to download at  We find the analysis and conclusions in the report very convincing, but they are not ours: they are based on Capital’s professional expertise and judgement.

2.2 The purpose of the research was to evaluate the fiscal and economic benefits and costs of scaling up public investment in England in housing for rent at genuinely affordable levels[2] to 100,000 a year by 2020-21, against a continuation of current policies, involving declining investment in housing for rent, with most of it at “Affordable Rents.  Its main findings are:

  • in almost all parts of the country, the cost to the welfare system of supporting low income households in private rented housing (and, to a very considerable extent, in homes at Affordable Rent) is greater than supporting equivalent households in homes at social rent;
  • the decline in the stock of social rent homes, and rising private rents, means that the cost to the welfare system arising from the housing costs of low income households has increased very fast in recent years: it has nearly doubled in real terms in the last 10 years, and now accounts for over 37 per cent of housing benefit spend;
  • if this trend were to continue, expenditure on housing benefit would increase, by the end of the OBR’s long term forecast period in 2065-66, to £197.3bn in nominal terms, or nearly £62bn a year at today’s prices, with the private sector component more than quadrupling, to £38bn at today’s prices;
  • set against the significant risk to fiscal sustainability of carrying on with current policy, a policy of resuming the development of homes for genuinely affordable rent at scale “is fiscally sustainable and economically efficient.”  It would bring about “a sustained structural improvement to public sector finances – by reducing spending on welfare payments and stimulating higher tax receipts.”  Other things equal, public borrowing would be 0.5 per cent of GDP lower by 2065-66, and the stock of public debt 5.2 per cent of GDP lower;
  • if the increased investment in new homes were scored as public expenditure, the proposed policy would initially, of course, lead to an increase in public spending and borrowing, as the up-front investment in new housing would be greater than the welfare savings achieved early in the policy.  However, the report notes that the impact would be very modest (peaking at 0.13% of GDP in 2020-21), opinion in the markets would be very sympathetic to investment in tradeable and income-generating assets which would help address the longstanding economic risks caused by inadequate volumes of housing development, and there are ways the Government could support investment without it scoring in the public spending totals;
  • the estimates of benefits and costs in the core analysis is very cautious, limited to the direct cost of building new homes, welfare savings and increased tax receipts from higher construction activity.  However, there would be significant additional socio-economic benefits in terms of health, wellbeing and education.

Applying the analysis to London

London is at one extreme of the analysis on all its key dimensions.

Housing supply and affordability

As figure 1 shows, housing supply in London in the last 30 or so years has been volatile, largely because of very significant fluctuations in private sector development, with a five-fold difference between the years of highest and lowest output.  


However, private sector supply has never gone higher than 30% of the requirement in the London SHMA.  Cumulative output in the last 15 years is less than a quarter of the SHMA requirement.   Even with social building added in, London has never reached even half of the SHMA requirement, and cumulative output over the last 15 years is only just over a third of the SHMA requirement.   While output in England as a whole has persistently been below the 200-250,000 generally agreed to be required, the difference is less extreme.  As the price line in Figure 1 shows, the volatile and inadequate level of building has resulted in extreme house price inflation, with at best a weak supply response to rising prices.

Figure 2 illustrates further how London is an extreme version of the national phenomenon.  It shows trend starts and house prices for London and England.  London’s house price inflation has been significantly greater than England as a whole (prices have increased 8.5 times since 1982, compared with 5.9 times nationally), yet the trend in private sector starts is only modestly higher (though admittedly indicating slight growth, as opposed to a downward trend in England as a whole.


Affordability and consequences for tenure

In England as a whole, house price growth is persistently higher than earnings growth, but this is even more so in London.  Figure 3 shows how price increases and London have become even more decoupled from earnings growth than in England generally.  The trend since 2011 is particularly disturbing: house prices in London have accelerate compared with the rest of the country, while London’s earnings lead has narrowed.   The average price of a semi-detached house in London is now more than 15 times average household income; and the average price of a flat or maisonette well over 10 times average household income.[3]   Rents have increased by nearly 6 per cent a year in London in the last 4 years.[4]  Since the 2008 financial crisis, average household income in London has been increasing by less than 2 per cent a year.[5]  As of 2013, a household on the average income for London would be spending over 40 per cent of its income on rent in a property at the average rent for London.[6]  The gap between incomes and rents has widened further since.


These trends have resulted in dramatic changes in tenure mix. Figure 4 below (reproducing a table in the English Housing Survey 2013-14, shows how private renting has more than doubled its share, while the shares of owner-occupation and social renting have fallen.  This is the inevitable result of rising population, rising prices for sale, and very low levels of social development.

Figure 4: Tenure


Consequences for housing benefit

The figures below, from Building New Social Rent Homes, show, for illustrative household types and locations, the impact of rents on housing benefit.  Despite the restrictions on Local Housing Allowance rates, the cost to the benefit system of supporting a low income household in the private sector is up to 93 per cent higher than a similar household in a social rent home



Benefits, social rent and private rent, illustrative household types and locations




Household type

Household income (per year)

Benefits at social rent (per week)

Benefits at private rent (per week)

Additional benefits cost for private rent*


Single, 2 children










Couple 1 child





Couple, retired






Single, 1 child










Couple, 3 children





Single, retired






The consequences for housing benefit are very significant.  As Figure 5 shows, in just 6 years, the number of working households living in the private sector claiming in London has increased by nearly 170%, to over 140,000, or around 1 in 17 of working households.  This exceeds even the 140% increase for England as a whole.  Such claims now account for 17% of caseload, compared with 7% in 2009.  Over the same period, there has been almost no change in the social housing caseload.  This is a very clear demonstration of the extent to which, as a consequence of purchase being increasingly unaffordable, and rents rising faster than earnings, housing costs are putting the finances of working households under intolerable strain, and increasing welfare dependency and spending.   As the CBI has recently pointed out, this also has labour market consequences, as living and working in London in modestly-paid work becomes increasingly unattractive, indeed unviable.[7]



In every way, the situation in London is a much more extreme version of a national picture which is itself deeply troubling:

  • private sector building has never reached anywhere near the levels required to meet demand;
  • as a consequence, house price inflation has accelerated, and (especially recently) is far outstripping earnings growth;
  • rents are increasing much faster than earnings too;
  • despite restrictions in entitlement, increasing numbers of working London households have to claim welfare benefits to afford private rented housing, at much greater cost than if they were living in social housing.

The pace at which the crisis is deepening is extreme.


The Commission’s Core Questions

1.  How can we double the delivery of homes in London every year, and maintain high levels of housing delivery in the long term?

We suggest the analysis above demonstrates very clearly that the ambition to double the number of homes built, and maintain delivery at that higher level, is absolutely essential.   It also shows that around half the additional development must be via publicly-supported investment in homes for genuinely affordable rent, for two reasons.

First, there is no prospect of increased private sector development alone increasing to the extent required.   For the last 15 years at least, from the Sustainable Communities Plan onwards, national and London government have, through the planning system, the deployment of public land and institutional mechanisms, sought to enable and support more development in London.  Despite that, and the very strong price signals, the rate of private development over the period has barely changed, and for a considerable phase was running at much lower levels. Additional development needs to be by all types of player and at all tenures, and we wish the Commission success in identifying further ways to bring about additional private development.  If the private sector alone were to bring about the necessary additional development, its output would need to more than triple from current levels, which are themselves higher than much of the last 30 years, and stay at that level.  We see no plausible mix of interventions which could achieve that.

Second, a very large part of the requirement needs to be met via homes at rents well below market rates, to put into reverse the increasing poverty and pressure on the welfare system and labour market resulting from the current situation.   Even if it were possible for the private sector to build over 50,000 units a year, as we explain above, increasing numbers of working London households could not afford either to buy or rent them, certainly not until such a rate of development has been sustained over the decades needed to put into reverse recent trends in prices and rents.  The conclusion of Building New Social Rent Homes about England as a whole, that there is an unarguable fiscal and economic case for very much higher levels of development for genuinely affordable rent, is even stronger when applied to London.

We strongly support the methodology for setting such rents proposed in Savills’ recent work for JRF and the National Housing Federation.[8]  By being anchored on local earnings, this approach would ensure that rents were set at levels genuinely affordable to Londoners, while also being able to reflect London’s somewhat higher earnings levels.

There may be scope for social landlords and others to develop homes for rents at what are often called intermediate levels, and which, as “Affordable Rent”, has become the main new development output of social landlords since 2010, to meet demand at a certain level of the market.  However, we argue strongly that, in the London context, where market rents are so far adrift of social rents and modest earnings,  most publicly supported development must be at much lower rents, and that intermediate or “Affordable” rent, on a large scale, will waste taxpayers’ money and fail to address poverty and welfare dependency.   That new Affordable Rent homes can usually only be delivered through the conversion of current social rent properties to the higher rent level only worsens the economic case.   In the illustrative household types and locations examined in Building New Social Rent Homes, Affordable Rent is between 73 per cent and 109 per cent higher than social rent in the Camden cases, and between 16 per cent and 151 per cent higher in the Brent examples.[9]   The rents in these examples range up to 45 per cent of average household income.  In the London context, Affordable is clearly a complete misnomer for middle to lower income households.

In conclusion, therefore, we propose that there should be a sustained programme of up to 30,000 new units a year at genuinely affordable rents.

2. How can we reconnect the costs of home ownership and renting to incomes in London?

If a programme of the kind we propose were maintained over 10 years, it would increase the stock of significantly below market units by between 200,000 and 300,000.  It would address affordability for rent and owner-occupation, both directly and indirectly:


  • it would directly offer homes at genuinely affordable rents to Londoners on low to modest incomes, notably the current 140,000 households who are working and claiming local housing allowance;
  • by increasing very significantly the total stock of homes to rent, it would help stabilise the private rental market and prevent a continued upward spiral which is the near-certain outcome of continuing with the current level of development;
  • a significant obstacle to home ownership at the moment is that households paying very high private rents are not in a position to save for a deposit.  If they were instead able to rent at genuinely affordable levels, more would be able to save, and then buy, either via Right to Buy  (which SHOUT supports if landlords can keep sufficient receipts for genuine one for one replacement at genuinely affordable rents) or in the general market;
  • the contribution the additional units would make to wider supply would assist in reducing upward pressure on prices across the whole market.


Building New Social Rent Homes demonstrates that there is a unanswerable case for public investment in new genuinely affordable housing on this scale, above all in London and other high cost areas.  Its calculations of scheme viability in central and outer London are extremely positive, demonstrating present values over 25 years, net of build cost, of between £100,000 and £260,000 per property.[10]  Across England as a whole, the report shows that a sustained programme of 100,000 units a year would bring very significant benefits to PSBR and the stock of public debt over the medium to long term.[11]  Capital did not calculate separately the benefits of London’s share of such a programme, but it is clear that a 20-30,000 unit a year programme in London would bring about particularly strong exchequer benefits, since the scheme viabilities in London are at the top end of the range for England as a whole.


Such investment would, of course, require initial public investment to secure the reduced welfare spending and other benefits over the medium to long term.  The Treasury is likely to have concerns about any upward pressure on spending in the short term.   Our response is twofold:


  • the impact is very modest and would be viewed by the markets much more positively than incurring a similar impact for other purpose.   The PSBR impact, for England as a whole, peaks at the end of the Spending Review period at 0.13%.   While the term ‘investment’ is often misused in relation to the public finances, investing in new housing is among the most genuine and sustainable investments the public sector can make.  Unlike other kinds of public infrastructure, homes are a tradeable asset, with an easily realisable market value.  Once built, the management, maintenance and debt service associated with social homes are met via the rent which tenants pay.  Capital’s advice, based on their experience of the bond markets, is that additional borrowing for this purpose would be positively viewed in the City, both because of its clear benefits in terms of medium term fiscal sustainability, and because the under-supply of housing is recognised as a key economic risk;[12]
  • there are ways the policy could be implemented without any short term upward pressure on the PSBR.  There is a strong case, based on international practice, for excluding public corporations’ borrowing from the target definition of PSBR.  The policy case for this is the very different character of borrowing to invest in an income-generating asset with a realisable market value, as opposed to borrowing for welfare or public sector pay, or even spending on less marketable forms of infrastructure.[13]  Such a reclassification would unlock the very considerable investment capacity in the balance sheets of council and ALMO landlords.  Across England as a whole, this has been estimated as, enabling, on very cautious assumptions the delivery of 60,000 new homes over 5 years without central government grant or any impact on target PSBR.  Using the full potential balance sheet capacity could enable the delivery of up to 230,000 new homes.[14]  Capital Economics propose that finance for additional council or ALMO homes, and for housing association homes, could be provided through a housing investment bank partially backed by the Treasury (see Figure 6).  Finance provided through such a mechanism would not impact on the PSBR.[15]










Figure 6: Funding platform to mitigate the impact of additional borrowing on public sector net debt



Capital’s illustrative proposal is for a national institution.  However, the current emphasis on devolution makes a strong case, rather, for institutions meeting the needs of different city-regions and other functional economic areas.  Applied to London, the approach would have particular attractions:

  • the higher asset values of existing social housing in London and associated land holdings;
  • the continued ownership of most of London’s council-built stock by the boroughs.  Compared with much housing association stock, there is very significant balance sheet capacity in this publicly-owned stock.


We plan, if we can create a suitable partnership and secure funding, to investigate the viability of such institutions further, and would hope to look at London, among other sub-national locations, as part of this work.   We would welcome the Commission’s involvement in work of this kind, and suggest the staff team contact us if they want to talk about it further.


3. How can we provide a high quality private rented sector?


The focus of SHOUT’s campaign is on social and community housing, so we leave it to other respondents to make proposals in response to this part of the Commission’s brief.  We would, however, observe, that one reason why London private tenants often experience such poor conditions is that the very constrained availability of genuinely affordable housing managed by public and social landlords means low income and vulnerable households have no option but to look for private rented housing.  However, their limited incomes, and the reducing proportion of the rental market affordable within LHA rates which are falling in real terms, as rents rise, mean that they face very constrained choices and have even less scope than other tenants to challenge poor conditions and landlord behaviour.   The programme of building we propose would allow many more to access more suitable genuinely affordable housing, and would reduce pressure on the private rented market in ways which would force poor landlords to raise their game.



September 2015

[1] See page 7 below for an explanation of what we mean by ‘significantly below-market’

[2] See page 7 below for how we would propose to define “genuinely affordable.”

[3] Halifax

[4] VOA

[5] GLA

[6] GLA

[7] London Bbusiness Survey, CBI, September 2015, p10-11

[8] Living Rents – a new development framework for Affordable Housing, Mark Lupton and Helen Collins, Savills, June 2015

[9] Building New Social Rent Homes, p48

[10] Building New Social Rent Homes, p27

[11] ibid, p36-37

[12] ibid, p41

[13] ibid, p41 and Let’s Get Building, John Perry, National Federation of ALMOs, 2012

[14] Let’s Get Building, p19-20

[15] Building New Social Rent Homes, p42 and Increasing Investment in Affordable Housing, Capital Economics, 2014

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    UPDATED October 2016 Capital Economics report: Building Social Rent homes
    SHOUT Supports ending the Housing Crisis in a Generation