AI produced objecton on affordable housing

Claude AI supplied the objection below after I sent them the Redbridge affordable housing statement https://acrobat.adobe.com/id/urn:aaid:sc:EU:338523a7-0907-4a1c-82b4-f2709a4c925e it should be checked by others before sending

Objection to 2498/25 – Tesco Extra, 822 HighRoad, Goodmayes

Oct 20, 2026

·

@Andy

Introduction

Application:

2498/25 – Section 73 variation of planning permission 4309/19, DevelopmentSite at Tesco Extra, 822 High Road, Goodmayes. Applicant: Weston Homes PLC. Agent:Lanpro.

Objector:

Andy Walker, [address].

I object to the application as amended on 8 October 2026. The amendments cutaffordable housing from 35% to 20% by habitable room while increasing the scheme to1,385 homes and 27 storeys.

The applicant says the cut is justified by the Government and Mayor's time-limitedplanning route. On the applicant's own documents, the scheme does not meet thatroute's requirements. No viability case has been published to justify the cut by any otherroute. I ask the Council to refuse the application as amended, or to require it to complywith the time-limited route in full or to be assessed under the Viability Tested Route.

Page and paragraph references are to the documents on the Council's register for 2498/25and 4309/19/33.

1. Background: how the affordable housing offer has changed

The number of affordable homes would fall by 192 compared with the extant permission,while total homes rise by 105.

Stage

Date

Totalhomes

Affordablehomes

Affordable(habitable rooms)

Rented share ofaffordable

Permission 4309/19(granted)

May2022

1,280

415

35%

41% LondonAffordable Rent

s73 as submitted(subject to grant)

Sept2025

1,379

649

50%

41.7% affordablerent

s73 as amended

Oct2026

1,385

223

20%

42.8% "Rent"

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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The GLA's Stage 1 response of 3 November 2025 described the 50% offer as "aconsiderable improvement on the extant consent". The Planning Statement (Rev 4,December 2025) said a "maximum viable position without grant funding will also beestablished". No such position has been published. Eleven months later the offer fell to20%, with the applicant citing a "materially changed" housing market (Position Statement,page 12).

The route to this application also matters. Non-material amendment 4309/19/33 (April2025) removed the school and the storey heights from the description of developmentand moved the limits into a new Condition 88 (23 storeys, 1,280 homes). The officer reportrecords that this "provides the applicant with flexibility to amend the permission in thefuture via S73". This application now seeks to raise Condition 88 to 27 storeys and 1,385homes. The Council should weigh the cumulative effect of these changes against thepermission as originally granted.

2. Ground 1: the scheme does not meet the time-limited planningroute

The applicant's own compliance table shows the scheme fails the route's Social Rentrequirement and rejects its review mechanism.

The Government's policy paper (

Support for housebuilding in London: package ofsupport

) says an eligible scheme must deliver at least 20% social and affordable housingby habitable room, "with a minimum of 60% Social Rent". Schemes on the route are alsosubject to an Early Stage Review.

The Position Statement (24 September 2026, page 15) tests the scheme against thesecriteria:

Requirement

Applicant's response

Comment

At least 60% of affordablehousing must be Social Rent

"The previous offer was40%, which was fullyaccepted by the LPA."

The requirement is not met.Acceptance of a differenttenure split under the 2022Fast Track Route does notsatisfy a new route with itsown criteria.

Early Stage Review

"Noted. The early-stagereview is not applicable."

No reason is given. Thereview is part of the route'sconfirmed arrangements.

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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Despite this, the Position Statement (page 14) concludes the scheme is "fully compliantwith all of the relevant requirements". That conclusion is wrong on the applicant's ownfigures.

The tenure is also unclear. The schedule labels the rented units only as "Rent" (42.8% ofaffordable habitable rooms). The 2022 permission secured London Affordable Rent,which is a different product from Social Rent. The Council should establish which productis proposed.

A scheme that does not meet the route's criteria cannot rely on the route to justify 20%without viability testing.

3. Ground 2: no viability case has been made

A reduction in affordable housing through a s73 application requires a tested viabilitycase, and none has been published.

London Plan.

The applicant's own Planning Statement (para 5.3.4) notes the guidancethat s73 amendments which reduce affordable housing "should be rigorously assessedunder the Viability Tested Route", and that the Mayor should be consulted.

Local Plan Policy LP3.

As the Planning Statement records (para 5.3.8), LP3 requires"justification and a review mechanism" for proposals below the 35% minimum.

The existing s106.

Schedule 3, Part 2 of the 2022 agreement secures an early-stageviability review (Planning Statement, para 5.3.9). The amended offer would remove thereview while cutting the affordable housing.

Transparency.

The Planning Statement lists a Viability Statement by Bespoke PropertyConsultants among the application documents. It is not on the public register. TheMayor's Affordable Housing and Viability SPG (2017) expects viability information tobe made publicly available.

The applicant promised in December 2025 to establish a "maximum viable positionwithout grant funding". The Council should require that position, test it independently,and publish both before determining the application.

4. Ground 3: the affordable housing schedule conflicts with thefloor plans

The Affordable Housing Schedule and the Block A and B floor plans submitted with it (8October 2026) put the tenures in different places.

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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The plans also contain errors that make them unreliable as a basis for securing tenure:

Duplicate unit references, for example B1/B2.04.01–05 appearing twice with differenttypes and tenures.

Unit references on the wrong floor, for example A1.02.06 on the third-floor plan.

Coloured tenure outlines that disagree with the text labels on the same sheet.

The schedule's fourteen 4B5P units at 106 m² shown on the plans as 4B6P units of 102–112 m².

Every sheet is stamped "DRAFT".

The 20% figure is calculated by habitable room, so it depends on which units areaffordable. The Council cannot verify the figure, or secure the affordable units in a deedof variation, until the schedule and plans agree.

5. Ground 4: Discount Market Sale inflates the figure

All 66 Discount Market Sale (DMS) homes in the schedule are 3-beds, which lifts thehabitable-room percentage while only 16.1% of homes are affordable.

DMS makes up 34.5% of the affordable housing. Under London Plan Policy H6,intermediate housing must be genuinely affordable to households within the incomecaps and remain affordable in perpetuity. The applicant has given no evidence that adiscounted 3-bed flat in Goodmayes meets that test.

Local Plan Policy LP3 seeks a 60% rented / 40% intermediate split. The amended offeris 42.8% rented, with DMS the largest intermediate product.

DMS does not qualify for CIL social housing relief, so it should not be counted towardsany relief claimed (see Ground 6).

Block

Schedule

Floor plans

A1, A2

Private and rent; no DMS

Many 1-bed and 2-bed flats labelled"DMS" (ground to fourth floor)

A4

50 shared ownership, 3 rent

Labelled "Rent"

B1, B2, B3

Private and DMS; no sharedownership or rent

Large parts labelled "SHARED" andsome "RENTED"

B4

59 private, 14 DMS

Labelled "RENTED"

DMS unitsizes

All 66 DMS units are 3-beds

Mostly 1B2P and 2B4P

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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6. Ground 5: quality, mix, wheelchair housing and phasing

The amended scheme falls short of housing quality and mix policies.

Wheelchair housing (London Plan D7).

Proposed Condition 33 keeps "no less than 128"wheelchair user dwellings. That was 10% of 1,280 homes. Ten per cent of 1,385 is 139, sothe condition should be updated.

Family housing (Local Plan LP5, London Plan H10).

Only about 10% of homes havethree or more bedrooms, and nearly all private homes are 1- or 2-beds.

Location of social rent homes.

Social rent flats A3.-01.01 to A3.-01.03 are on the lowerground floor beside the Tesco car park, plant room and service yard.

Tenure-blind design.

The applicant states that all homes are tenure-blind (PlanningStatement, para 5.3.11). The ground-floor plan is annotated "social rent units accesseddirectly from podium". The Council should confirm that entrances and access aregenuinely shared.

Phasing.

All affordable homes are in Blocks A and B (Phase 1). Blocks C and D (694homes) are entirely private. The deed of variation should protect against furtherreductions when Phase 2 comes forward.

7. Ground 6: other matters

Health infrastructure.

NHS North East London objects and requests about £1.93mtowards primary care. The applicant replies that health was covered by CIL (PositionStatement, page 11). If the scheme takes the time-limited route, it becomes eligible for50% borough CIL relief, which weakens that answer. The Council should secure theNHS request or explain why it is not needed.

CIL information.

The CIL Form 1 (29 August 2025) reflects the earlier 50% offer,recording 67,725.5 m² of social housing. It needs to be updated before any liability orrelief is calculated.

Outstanding objections.

The Council's sustainability officer objects that therewording of Conditions 14 (Circular Economy) and 83 (Whole Life Carbon) treatsthem as outline matters, although the 2022 permission is a full permission. The LeadLocal Flood Authority's objection and the London Fire Brigade's request for accessinformation are proposed to be left to conditions. These should be resolved beforedetermination.

Environmental information.

The development is EIA development. The October 2026amendments raise the height limit to 27 storeys and add homes. The Council shouldconfirm that any further environmental information has been publicised and consultedon as the EIA Regulations require.

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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Biodiversity.

The Planning Statement claims a 10% biodiversity net gain as a benefit. Ifweight is given to it, it must be secured by condition or obligation.

Condition 88.

The increase from 23 to 27 storeys and 1,280 to 1,385 homes is a materialchange in scale. Its townscape and amenity effects should be assessed against thepermission as originally granted, not only against the last amendment.

8. Conclusion and requests

The amended application relies on a route it does not qualify for and offers no viabilityevidence for losing 192 affordable homes. It should not be approved in its current form.

I ask the Council to:

1.

Refuse the application as amended, or require either full compliance with the time-limited planning route (including at least 60% Social Rent and an Early Stage Review)or assessment under the Viability Tested Route with independent review.

2.

Publish the applicant's Viability Statement and any independent review of it.

3.

Require a corrected affordable housing schedule that matches the floor plans,specifying Social Rent or London Affordable Rent.

4.

Re-consult the GLA on the amended affordable housing offer before any decision.

5.

Update Condition 33 to require at least 10% wheelchair user dwellings (139 homes).

6.

Secure the NHS primary care contribution, or give reasons why it is not required.

7.

Confirm that the amended environmental information has been publicised andconsulted on.

8.

Report this objection in full to the decision-maker, and notify me of any committeedate so that I may request to speak.

Andy Walker

20 October 2026

Objection to 2498/25 – Tesco Extra, 822 High Road, Goodmayes

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