Our Future Cities Comment on the Western Cape Draft Inclusionary Housing Framework
It is admirable that an Inclusionary Housing (IH) framework has been drafted given that little has been done thus far in the Western Cape – outside of policy parameters and ideas – to enable the private sector in delivering IH units. Ultimately, the delivery of IH relies on an ecosystem of parts which includes amongst others: establishing a functioning relationship between the municipal officials and private sector, a stable or growing economy and a commitment to delivering inclusionary housing projects (with targets where possible) even where projects may not be entirely perfect.
Inclusionary housing taps into the energy and resources of the private sector i.e.acquiring land, holding land, designing, planning, and construction – which can at times take 5 years.
While there is a need for this framework, for quite some time tools have existed that have already been available at a municipal level to expedite or even give priority to the delivery of affordable housing or a form of IH. For example: reducing red tape, improving the town planning application delays and so forth. We would caution against cities and towns starting 3-5 year IH policy formulation periods without using what is already at their disposal.
The provincial IH framework should not be viewed as an isolated policy instrument but be seen as part of a wider affordable housing strategy/plan for SA cities. That is massive amounts of affordable housing should have been delivered year on year for over 2 decades with IH acting as an addition to this to support integration and the goal of a more equitable city.
These two conversations can not be had separately.
The WC government and City of Cape Town have multiple parcels of land – in all sizes – that have been identified but not been released from Woodstock to Salt River to Parow, Goodwood and the broader Bellville Area. These sites are ideal for affordable housing developments and therefore, must be utilised and can support IH development – alongside other affordable housing delivery such as student housing, gap housing and social housing units.
What has blocked or stifled any form of large scale government delivery of affordable housing must be addressed before expecting the private sector to do what government agencies have not done in over 20 years i.e. well-located affordable housing for a diverse set of household incomes.
Furthermore, in principle, we support mandatory inclusionary housing approaches within areas identified in 6.1.3 as suitable for IH for example, within restructuring zones and Human Settlement Housing Development Areas given South Africa’s history of racial segregation and also taking into consideration the residual spatial and socio-economic segrgation in our post Apartheid urban landscapes.
If mandatory approaches are to be adopted, more guidelines are required to ensure how incentives will be attractive to developers, and how these incentives can be utilised. For incentives to be attractive, there should be a basket of incentives from which developers can pick and choose. But ultimately, and crucially, incentives to encourage IH developments must remain attractive to developers in the short and long term, i.e they should be both feasible and viable and a culture of accessing incentives to make developments a reality should be developed.
We also remain cautious about the barriers of implementing IH policies at the municipal level. For this reason, we argue that IH policies drafted within the WC province need to be context-specific and tailored to the various unique contexts and housing markets. We also argue that the WC provincial government as well as the City of Cape Town must play their part in releasing state owned land in well-located and accessible areas, for the rapid implementation of IH by the private sector. Other barriers to ensure IH delivery at scale are the generally slow development application time-frames in the SA context. This approval period must be sped up, especially in the application for IH proposals in well-located areas within Cape Town.
The provincial IH framework vaguely mentions various stakeholders, however financial and property institutions and their influence in the market property play a notorious role in creating inclusive and gentrified communities. For future IH policies derived from this framework to be effective In a South African context and remedy spatial transformation, it’s success would lie in how accessible tenureship is to individuals.
Whilst long-term affordability preservation has been conceptualised through the method of maintaining property value market and balancing gentrification, the strategy is not clear. In order to maintain accountability and effective service delivery and administration within the system, clear, efficient and robust systems of managing and regulating the income certification system will need to align with financial institutions.
Below is a summary of parts of the framework that remain either unclear or ineffective:
Table 1: Issues identified in the IH draft Framework
|3.1.2 Legal Mandate||Entire section||The numbers of this section are not clear. It would be helpful to understand the relevance of the laws and acts mentioned in relation to Inclusionary Housing.|
|5 (pg. 23)||Management and Compliance||There should be a clear guideline as to what actors will be responsible for the management of the housing units and beneficiaries’ and a few potential approaches or models should be encouraged.|
|7.2||Partnerships||How can partnerships between different actors be encouraged and bridged into alliances that benefit the implementation of IH?|
|6.13||Determining Where Inclusionary Housing Should be Applied – Spatial Targeting||How can IH impact the amount of time spent on these processes? How can processes become more effective? Local governments need to shorten land use application times – we propose the creation of a specific mayoral or special acceleration targeted to inclusionary housing developments|
|7.2 (pg 40)||Discussion of ‘pipeline’ of well-located municipal land for development||Not clear if and how municipal land is to be released for IH delivery. It is time to deliver inclusionary and affordable housing units NOW. The local and provincial governments must play their respective parts|
|7.2||‘Smart partnerships’||No mention of partnerships with property developers, funders, etc.|
|Pg. 43||Monitoring & Evaluation||Role of academia and research institutions in measuring impact and also IH advocacy work|
|188.8.131.52||Compliance of beneficiaries||Are a set of rules/obligations going to be defined for households to comply once they become beneficiaries of IH? Who is going to overlook this?|
|6.2.2||On-site, off-site and in-lieu provision of IH units||Our Future Cities proposes the addition of a new term: near-site.
These identified near sites must be within 1km of the developed IH project and/or also must ensure the same social and economic accessibility indicators and similar neighbourhood characteristics.
OFC is not in favour of in lieu delivery for IH given the red tape, lack of capacity and slow pace of government and social housing agencies.
There needs to be a cultivation and support of a delivery culture across South African cities. The Western Cape is no exception. The dismally slow pace of any affordable housing delivery across the province must be called out as failure by the local government. Each local government or municipality within the province must play their part and partner with private sector developers by building a culture of appropriate and attractive incentives. With the right incentives, developers will realise the economic benefits that can be derived, leading to more viability for IH developments and ultimately homes for families and individuals.
Over the years, the OFC has sat in countless meetings with the various agencies and actors where IH has been talked about for over 5 years, yet there has been, and there continues to be, no clear action plans to actually deliver any IH units. This clearly demonstrates an urban policy failure. A way forward would be for the framework along with other parties encouraging a pilot phase. That is, Western Cape encourages municipalities to approve or “kickstart” 2 to 5 pilot IH projects (depending on the size or resources of the context) over the next 2 years.
Of course, a ‘one-size-fits-all’ approach to IH delivery does not work and IH incentives and planning mechanisms should suit their local contexts depending on the land values and needs of an area.
Another asset within local governments that must be harnessed is improvement of local property data systems. Such detailed data allows one to quantify the value of rights and incentives and is in line municipal valuations of properties and sites- without building complicated and unnecessarily complex models. Good, frequently updated data would also support municipal capacity in packaging and marketing development incentives to developers to encourage incorporation of IH units in their developments.
Ultimately, the provincial IH framework must pave the way for effective IH policies at the local scale that promote delivery over policy. There is a great urgency and need for IH, as an addition to massive amounts of affordable housing almost completely absent from the Western Cape’s landscape.
IH has been thrust into the media and academic spotlight and it is time that IH delivery actually starts. Greater delivery of IH units will surely promote greater integration of cities and thereby contribute to goals of greater equity in South African cities.
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