London ‘can’t rely’ on small sites to meet housing need

Review of the London Plan presents Sadiq Khan with a dilemma.


London aerial 1

London can’t rely on smaller sites in the outer boroughs to meet calculations of housing need in Sadiq Khan’s London Plan, planning inspectors have said.

The inspectors have broadly endorsed the plan – acknowledged as the most ambitious and complex seen in twenty years of the London mayoralty.

But that endorsement presents Khan with a dilemma.

Though the inspectors  agree with Khan’s  calculations of housing need, they do not think he can rely on small sites in outer London – some of the most contentious locations for new house building – to meet that need.

“But their call on the Mayor to undertake a strategic review of the Green Belt to plug the gap is likely to prove more popular with planners than with national politicians or the general public,” says Richard Brown, Research Director, Centre for London.

“Reviewing the Green Belt would definitely be controversial, and care would be needed to ensure that it provided for good growth rather than environmentally ruinous sprawl.

“But we agree that the time is right for a review, and that the Mayor of London is the right person to lead it,” said Brown.

The Mayor is required to review the Plan from ”time to time”, but the inspectors reference a letter sent in July last year from the then Secretary of State indicating an  expectation that the Plan should be reviewed “immediately once it has been published.”

This, the inspectors said, is in order that a revised plan has regard to new national policies in the 2019 NPPF at the earliest opportunity.

As part of the examination Khan was asked to comment on how quickly such an exercise might be undertaken and what the implications might be – given his anticipation that a revised London Plan would be in place by 2024/2025 anyway.

Khan has undertaken to review the threshold for affordable housing and the minimum tenure mix by 2021.

But the report concedes that how quickly a review might be undertaken would depend on its scope, saying that even if limited to housing targets there could be implications for other policies of the Plan which would need to be aligned.

With a three-year start-to-finish estimate – including preparation and evidence gathering as well as consultation and undertaking the processes prescribed in the GLA Act and the Regulations for an examination in public – these are not steps the inspectors said could be short-circuited.

The report says that though Mayor’s view that summer of 2023 is the earliest that a revised Plan could be published is “slightly pessimistic” in the inspector’s view – especially if work were to start straightaway – it was difficult to see how it could be done much before the end of 2022. 

Also recognised in the report are concerns that the requirement for an immediate review could deter some boroughs from updating their own local plans as they reason that it would be better to “wait and see” what the housing requirements from a revised Plan are.

Furthermore, the inspectors say developers may also decide not to pursue sites that are consistent with the current Plan in favour of speculating that in future other opportunities will occur.

The report recognises some force to these points, with the inspectors “especially conscious” that the issue of resourcing for boroughs was a matter raised regularly that might also affect whether they embark on local plan production, in the knowledge that some of the fundamental strategic policies are likely to change in the near future.

Khan says an immediate review would divert GLA staff away from the task of seeking to implement the Plan which would be counter-productive.

The inspectors cited “insufficient information” to comment on the resourcing of Mayoral planning functions but  said it is likely that the focus would be on preparing the new Plan rather than on ensuring the present version delivers the growth it is promoting.

Assuming that the capacity for new housing development in London is finite – with the plan reliant on re-cycled land – the approach of sustainable intensification can, the report says, only be taken so far without having an adverse impact on the environment, the social fabric of communities and their health and well-being.

To the inspectors, there would be little to be gained from requiring an immediate review until such time as a full review of London’s Green Belt has been undertaken as recommended to assess the potential for sustainable development there – and whether and how the growth of London might be accommodated.

With no recommendation, then, that an early or immediate review of the London Plan should be carried out.

Instead, the inspectors conclude that the draft Plan published for public consultation in December 2017 provides an “appropriate basis” for the strategic planning of Greater London – with scope to  reflect suggested changes.

GLA Tory housing spokesperson Andrew Boff AM said the report effectively recognised Khan’s plans were “little more than a war on the suburbs” in identifying a  determination to over-develop small sites as neither justified or deliverable.

“There has always been a big question mark over whether this policy was ever going to deliver the number of homes that the Mayor claimed it would, while concerns about the impact of the move on our precious green spaces and existing family homes are entirely valid,” said Boff.


“Londoners want our brilliant green spaces protected and better use being made of the swathes of brownfield land in our city.

“By advocating development on both the Green Belt and back gardens while simultaneously supporting the protection of disused industrial land, the Inspectors have, like the Mayor, demonstrated misplaced priorities and a profound misunderstanding of Londoners’ housing needs,” he said.

Earlier this year, 24housing reported London as in the midst of a “poverty shift” with The Smith Institute revealing equality and deprivation as rapidly shifting from the inner city to the outer boroughs – with affordable housing and rents recognised as key issues.

That report showed 60% of all Londoners living in poverty are now based in outer London –some 1.4 million people and a number almost double that of the 32% fifteen years ago.

Solutions were identified in a ‘first dibs’ policy for new housing in outer London, the GLA and boroughs piloting ‘affordable housing zones’, using their land to create areas where housing is more affordable, including new forms of low-cost homeownership where the prices are kept low in perpetuity, and rent controls to help stop or reduce the displacement of low-income communities.

Meantime, the London homebuilding and renovating market is reported as showing no signs of slowing down, with the latest London Homebuilding & Renovating Show visitor survey recording a 14% increase in self-build projects underway.

In addition, the survey shows an average project increase of over 10% – from £120,000 to £134,000 – alongside a 20% growth in London-based visitors to the event earlier this month.

Organisers say this optimism was also displayed through the ambitions of self-builders and renovators attending the event, with 76% preparing to undertake a live project within the next 12 months.




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