Is Brent Council using Sadiq's or Boris's definition of 'affordable' homes

Brent Planning Committee at its meeting on April 26th will be hearing two pre-application presentations from Quintain and making a decision on two planning applications from them. All contain references to 'affordable' housing.

Over the weekend my attention was caught by a tweet from Sadiq Khan, the London Mayor, publicising his draft affordable housing and viability supplementary planning guidance (November 2016 LINK)

As I have long had a gripe with Brent Planning Officers over their failure to explain what they mean by 'affordable' housing in their reports to Planning Committee (usually 80% of market ents which are not affordable for local residents) I thought it was worth looking at what the Mayor had to say.

The supplementary guidance states:

The Mayor strongly encourages LPAs (local Planning Authorities) to apply the affordable housing threshold approach to applications for sites which are capable of delivering ten or more units. In addition, when developing future affordable housing policy (and other policies on planning obligations and CIL levels) LPAs are strongly encouraged to take account of this Supplementary Planning Guidance (SPG) and the importance the Mayor places on increasing the numbers of affordable homes

Central to this is the London Living Rent capped at one-third of the median gross household income for the borough:

Definition of London Living Rent

London Living Rent is a new type of intermediate affordable housing that will help, through low rents on time-limited tenancies, households with around average earnings save for a deposit to buy their own home. Eligibility for London Living Rent is restricted to existing tenants with a maximum household income of £60,000, without sufficient current savings to purchase a home in the local area.

It is aimed at single people, couples and other households with more than one person, but is unlikely to be suitable for house shares of multiple adults due to the household income limit. Any update to this criteria will be provided through the GLA’s annual monitoring reports. The GLA has calculated ward-level caps for London Living Rent homes based on one-third of median gross household income for the local borough.  

The cap varies from the Borough median by up to 20 per cent in line with house prices within the ward. The caps have further variation based on the number of bedrooms within the home. Registered Providers (RPs) have the flexibility to let homes at lower rents if they wish. 

RPs are expected to actively encourage London Living Rent tenants into home ownership. They will be expected to assess the ability and inclination to save of prospective tenants and, where part of mixed-tenure schemes, offer tenants
the right to purchase their London Living Rent home on a shared ownership basis.  Further information on this product is available in Homes for Londoners: Affordable Housing Programme 2016-2021. As set out in the current annual monitoring report, for intermediate dwellings
 to be considered affordable, annual housing costs, including mortgage (assuming reasonable interest rates and deposit requirements), rent and service charges should be no greater than 40% of net household income.(My emphasis)

Importantly in the light of Quintain's entry into the Build to Rent market the guidance says these should 'preferably' be at London Living Rent levels:

Affordable housing tenure: the pathway recognises the need for all homes on the Build to Rent development to stay under single management and as such will encourage affordable homes on the development to be delivered as discounted market rent (preferably at London Living Rent levels), managed by the Build to Rent provider (or possibly via another designated manager). 

At the very least Planning Committee members should establish with officers whether they are using Sadiq Khan's definition of 'affordable' based on the median borough income or Boris Johnson's 80% of market rent.