London Plan must seek to address the lack of housing delivery as a priority

London is not building enough homes. Not for the demand for housing in the city, and not against the targets set for it by central government. There was some shock earlier this year when it became known that delivery in a 12-month period was around 9% of the target. Such was the crisis that the then-housing secretary Steve Reed and Mayor of London Sadiq Khan agreed to drop the fast-track (non-viability assessed) threshold for affordable provision from 35% to 20%. Politically quite difficult for Labour politicians, despite the ‘Build, baby, Build’ slogan. 

As well as setting out wider strategy for development types, the London Plan draft published last week must seek to address the lack of delivery as a priority. The draft Plan is mercifully around half the length of the current one (it was apparently a consistent complaint in the industry), but nonetheless here we will only note a few changes that have caught the eye, and a bit of the politics around them. 

The headline draft plan target for the city is 558,000 homes over next ten years, 38% lower than the 880,000 government-issued target. Borough by borough changes have also been made – outer London seeing increases, east London mainly being reduced from a high level. In light of the real delivery numbers, this could be seen as an admission of reality and a belief that setting more achievable goals is beneficial for trust both politically and within the industry. Achieving this ‘minimum’ could then be portrayed as a ‘first step’. There are specific numbers for brownfield and greenfield sites, too: 56,100 should come from greenfield. 

The draft London Plan suggests that the temporary 20% threshold should indeed be withdrawn in 2028. Its replacement is more nuances than the previous one-size fits all. It sensibly recognises that location, size, and type of land will influence. Thus, there is a table and map to spell it out. The fast-track route is available for developments of 10-35 units providing 20% in non-Green Belt locations. For larger developments, the threshold is restored at 35% for inner borough (plus, predictably, Richmond), 25% for the next ring of boroughs, and staying at 20% beyond 2028 for outer boroughs. Green Belt land will be expected to provide 50% and public sector land 40%, although both of these can be reduced if strategic transport infrastructure is to be delivered. On the face of it, this approach suggests positive pragmatism. However, it would only be a ‘game-changer’ if these thresholds could be met. If the viability challenge is more significant than that – as is surely the case for many London-based prospects – it’s back to the Viability Tested Route, and back to square one. Whether boroughs would lobby to be included in one Band or the other, moving up or down the scale, would depend on its political hue and the buoyancy of the market there. Green-led Waltham Forest, Lewisham, Haringey are in the 25% Band B, which may not be welcomed. 

A while ago, I attended a London Plan workshop session hosted by a large planning consultant. A fair amount of the time was devoted to the possibility of mayoral support for Green Belt release to help achieve some numbers. The draft London Plan is the most explicit commitment yet. It is recognised that to deliver the numbers required, some Green Belt development will be needed – providing 56,000 (10%) of the total delivery. Modifications to Green Belt boundaries in local plans will be supported where appropriate and in ‘Broad Locations for Growth’ the release of green belt will be acceptable in principle. Showing some determination to deliver this, a helpful table sets out appropriate densities, heights, car parking spaces for Green Belt locations depending on distance from rail stations (bus stops should always be within 400m). Based on transport accessibility Hillingdon, Enfield, Barnet, Croydon, Havering and Redbridge could be key targets here. Croydon has already announced it will object to the draft London Plan, with the mayor Jason Perry claiming the Green Belt in the borough is sacrosanct. Not for him 5,600 Green Belt Homes between Croydon and New Addington, which is currently mainly golf courses. 

Notably the draft does not mention Grey Belt, explicitly preferring strategic releases of Green Belt. But local plan revisions often take longer than the average longevity of a Prime Minister. Will developers prefer to angle for a site to be removed from the Green Belt, or head down the grey belt route, which in its undefined nature is one for testing each time. 

The draft publication comes at a time when London politics has undergone a political upheaval of massive significance. Those council leaders responding are possibly not the ones that the GLA would have expected when this process began. There are both more Conservative leaders and a new brand of Green leaders than pre-May. Wandsworth and Westminster Conservatives were notable in promising pragmatic and positive engagement with developers in their manifestos. Meanwhile, Hackney, Tower Hamlets, and Lewisham mayors combined to launch a judicial review of the emergency 20% affordable threshold. Hackney’s Zoë Garbett has already claimed the draft London Plan’s thresholds as a win for Hackney and climbdown for the mayor. Green and left-of-Labour administrations could move on to pick on another facet of the local plan in as we build towards mayoral candidate selections (Garbett ran for the Greens last time). Meanwhile the heavy focus on transport infrastructure being in place for outer borough development provides some accountability points for leaders primarily of blue and teal tinge.