With under six weeks of consultation left for City Hall’s draft London Plan, Sadiq Khan’s new development blueprint for the capital, there’s been something of a feeding frenzy within the “built environment” community of developers, builders, consultants and lawyers – an array of seminars, briefings, technical, professional and legal assessments, and the inevitable political hole-picking.
There has been far less interest from the wider public, despite the Plan setting out big changes. Indeed most Londoners, as Green Party London Assembly member Benali Hamdache said last week, “have no idea we are discussing a really important document that will determine what’s going to happen over the next 10 years and whether or not a lot of people’s situations are going to get better or worse”.
What should Londoners be looking out for?
Most controversially, the Plan identifies 10 “broad locations” for a total of 56,100 homes in the hitherto sacrosanct Green Belt, in Barnet, Enfield, Redbridge, Barking & Dagenham, Havering, Croydon, Hillingdon and Harrow. Nine greenfield areas for potential industrial development are identified too.
Councils must also plan for their shares of the Plan’s overall 10-year 558,000 new homes target, shared out borough by borough by City Hall (Table 3.1). Residents familiar with their local targets may see some surprising reallocations, generally pushing the focus for growth outwards, but also away from previous high-growth hotspots Tower Hamlets, Barking & Dagenham and Newham.
The draft also sets out a new “optimisation framework” – basically mandating denser housing near transport hubs – meaning “many more areas of London must embrace mid-rise development”, perhaps up to nine storeys. More small site development is encouraged, and 17 areas are identified as suitable for tower blocks over 100 metres high, from the Square Mile and Canary Wharf, Stratford, Vauxhall, the Greenwich peninsula and Elephant and Castle, to West Ham, North Acton, Old Kent Road and beside the Millwall football stadium.
The affordable housing threshold incentives exempting compliant developers from lengthy “viability” assessments are changing too, potentially altering the geography of affordability. They will stay at 35 per cent for 12 mainly inner London boroughs, but be reduced to 25 per cent for a “middle” ring of eight boroughs, and to 20 per cent for the remaining outer London boroughs. Thresholds for Green Belt and publicly-owned land are separately set at 50 per cent and 40 per cent.
Overall, the Plan posits a different London: denser, taller and encroaching for the first time on the Green Belt. It’s also significantly more “top-down” than its predecessor, which may come as a shock to residents when they are faced with proposals not to their liking. The new density rules, for example, explicitly prevent councils “acting separately and from their local perspective”. Instead, they must play a collective part in “optimising” opportunities for development that are “vital to help meet housing need for London as a whole”. Basically, there will be less scope for saying “no”.
What’s next?
After considering consultation responses, the Mayor will produce a further draft which will be publicly examined by independent planning inspectors next year. Final government sign-off is expected in early 2028.
It will be a challenging period. Housebuilders will be arguing their corner, looking perhaps for more Green Belt release, further relaxation of design standards, and a wider reduction in affordable quotas. The boroughs, responsible for putting much of the Plan into practice, are signalling their concerns too, around their targets, the need for more affordable homes and the Green Belt grab.
Mayor of Croydon Jason Perry was quick to announce his opposition and pledged to use his influential position as lead member for planning in the city-wide London Councils group to argue for a more “collaborative” plan-making process. And only last week the London Assembly, which scrutinises the mayoralty on a cross-party basis, called on Khan to drop his Green Belt proposals.
City Hall versus Whitehall?
This could be the big battle. The government’s “standard method” of assessment says London requires 850,000 new homes by 2037 to meet housing need, in line with City Hall’s own calculation. But the Plan’s target falls almost 300,000 homes short of that. The Mayor, according to Lisa Fairmaner, City Hall’s strategic planning chief until late last year, “had to walk a tightrope” between the standard method and deliverability, with the Plan figure representing “all of the housing that can realistically be delivered over the 10-year timescale”.
Even that total, the Plan says, depends on an improving economy, a hike in funding for affordable housing and “massive investment in transport”, initially the Docklands Light Railway extension to Thamesmead and the handover to Transport for London of commuter lines into Moorgate. Going further would mean delivering the Bakerloo Line extension, the West London Orbital and more.
That’s a problem for Whitehall. National planning rules say strategies such as the London Plan must set out to meet the standard method figures. A new analysis by leading planning lawyer Simon Ricketts suggests the 300,000-home gap puts the mayor clearly at odds with that requirement. At the examination it will have to be “evidenced, explained and justified, in public, line by line,” according to another expert, the barrister Zack Simons. Allowing it through would set an unwelcome precedent, undermining national housing targets.
Is City Hall on a collision course with not only recalcitrant boroughs but also central government? Pitching the Plan as a plea to the Treasury, or perhaps to Number 10 North, for more money for transport and affordable homes only a year after receiving the city’s “biggest-ever” housing grant – essentially, if you want more homes, give me the money – could look like overreach, rather than a basis for negotiation. But rejecting the Plan – the “nuclear option” available to the inspectors at the public examination, with all the uncertainty that would mean – is unpalatable too.
Possible deals?
Could more government funding for transport be secured in return for the Plan embracing the release of yet more Green Belt land, allowing higher density development in more locations, and even accepting that the 35 per cent affordable homes threshold in central London is too high a requirement in current economic circumstances? Or might there be a government direction to work with local authorities across the wider south east in order to share out the capital’s housing need beyond its boundaries?
Nothing will make everyone happy. But there is a lot at stake. The standard method number, as Simons points out, is an expression of the real need “of the households, the families, the key workers, children in temporary accommodation…hundreds of thousands of people who require somewhere to live…Their need hasn’t gone anywhere.” All the more important, then, for Londoners to have their say. Details on how to give your views on the draft Plan here.
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