Described at Municipal Dreams as “an esteemed figure in housing and planning circles”, Duncan Bowie is a long-standing academic in his field and advisor to London government, including Ken Livingstone when he was mayor. This is his first piece for On London.
There are two main ways in which Sadiq Khan’s proposed new London Plan is significantly different from those produced under Ken Livingstone and Boris Johnson. The first is the assertion that the draft Plan is based on the principles of “good growth”. The second is that it is design led. Both of these concepts are problematic.
Firstly, the difference between “good” and “bad” growth is not established in the document. The principles set out, such as “making the best use of land”, “building strong and inclusive communities” and “creating a healthy city” are, though worthy ambitions, somewhat abstract and fail to acknowledge that plans and planning decisions have differential impacts on different interests – communities, households and individuals may be affected in very different ways.
There is no evidence given to support the assertion that the policies will “work for everyone” and the separate integrated impact appraisal fails to provide a satisfactory assessment. Despite the Mayor’s opening rhetoric, there is in effect no explicit social policy agenda – planning could and should actually have a role in making London a more equal city in which lower income households have better access to good facilities and a better quality of life. There is a perspective that development is of benefit to all Londoners, without thinking too much about what kind of development and for whom. Much recent development in London has contributed to increasing social polarisation and spatial inequities in the city, and the draft Plan does not acknowledge that this trend needs to be reversed.
The focus on design is equally problematic. Definitions of good design are largely subjective, and it is unlikely that any group of design advocates will necessarily agree on what constitutes it. This is why we need standards which can be measured. Moreover, design needs to be set within a planning policy framework. Local authority led plans and policies need to be based on both an evidence base for what development is required and a decision about the most appropriate use for a specific site. Design should be a servant of policy, not its determinant.
The most explicit evidence of the Mayor’s new approach is the abandonment of the policy of sustainable residential development, based on a matrix setting appropriate density ranges for different locations, one which reflect transport connectivity, the existing neighbourhood character and the location of key public services in local centres.
The previous policy sought to ensure that both the built form and mix of new homes were appropriate to meeting the full range of housing needs – so including family homes and homes which were affordable by lower or middle income households. Mayor Khan is proposing dropping this framework and saying instead that in order to maximise housing output, developers can build at as high a density as they like – including high rise residential buildings – subject to convincing planners that their design is “good”. This will lead to developers making higher bids for sites and the resulting higher prices they pay for land will make it more expensive for all developers, public and private alike, to build on.
Rather strangely, and despite all the research available, the draft Plan does not comprehensively set out what London’s requirements will be over the period it is intended to cover. There is no assessment of either existing land use or the space needed for the required development, other than in relation to housing. We have projections of population and household growth, the Strategic Housing Market assessment and the Strategic Housing Land Availability assessment, but there is no quantifying of how many more schools or doctors’ surgeries are needed, nor any calculation of the additional land needed for employment activity or for transport provision or schools or health facilities.
There is also no consideration of alternative development options in terms of built form or spatial distribution. Some of the policies appear to be ideologically driven, such as the presumption that all required development must be undertaken within the existing administrative boundary and that absolute protection be given to the Green Belt. We are presented with a densification strategy on the basis that There is No Alternative.
The Mayor’s team respond that the new Plan has to be realistic in recognising political obstacles and funding constraints; that, given the limitations of mayoral powers and public sector resources, it is not possible to set targets based on an assessment of London’s actual development requirements, due to the Mayor and the boroughs being largely dependent on the private sector (and private investment) to deliver. Most development management (what used to be called development control) is actually reactive – a developer proposes a specific development on a site and the planning authority seeks to negotiate a scheme which either complies with policy requirements or, if it does not, provides a compensatory payment through planning obligations.
So, in striving to be realistic, the Plan understates requirements and sets low targets – so the overall affordable housing target is 50% (and only 35% on private sector sites) when it should be at least 65%, and the social rent target within that is only 15% (with an option for boroughs to add in 20% more if they want to) when it should be close to 50%. The notion that plans should be based on an assessment of the needs of the current and projected population, rather that what is most viable (ie profitable) for developers and investors, seems to be history. While Mayor Khan has to work within the current national planning framework, so far as such a framework actually exists, he could do much more to challenge current preconceptions and constraints.
The draft new London Plan is inadequate as a response to the challenges London and Londoners face. In the terminology used by planning inspectors, it is “unsound”. The Mayor’s team needs to have a serious rethink.