Last Friday (29 January), the Secretary of State finally confirmed that the Mayor could adopt the draft London Plan published in December 2020.
It has taken just over three years to get to this stage, so this is very welcome news. There are still formalities that need to be completed, but we expect the Plan to be adopted within the next couple of months. We are therefore of the view that all policies within it can now be given full weight and we have provided a re-cap on some of the key changes that will be introduced to London below.
Higher housing targets
The Plan introduces an overall housing target of 52,287 homes per year over a ten year period (up from 42,000 homes per year in the current plan). This is some 14,000 homes per year below the objectively assessed annual housing need for London of 66,000, as identified in the GLA 2017 Housing Land Supply Assessment. Furthermore, with the introduction of the Government’s standard methodology for calculating housing need, the targets have a massive 42,000 homes in annual unmet need. This is largely due to London’s heavily constrained supply of land.
It is therefore certain that London will remain under significant pressure to meet these targets and the Secretary of State has indicated that he expects the new Plan to be immediately reviewed. Despite the small sites (0.25ha) targets being taken out of the Plan and the small sites housing policy being watered down during examination, we still consider that the optimisation of these sites will be critical if London is to get anywhere near these targets.
It is also interesting that both the Secretary of State and the Mayor ignored the Planning Inspectorates recommendation for a strategic Green Belt review, which would have been critical in exploring all spatial options to sustainably meet London’s spiralling housing need.
Fast-track affordable
The Plan sets out a 50% affordable housing target, but introduces a fast-track approach, whereby if 35% is provided on-site at the preferred tenure split and meets other policy requirements, then it will not be subject to viability considerations. It also removes the need for late stage reviews. The threshold on industrial land is 50% if there is a loss of industrial capacity (existing floorspace or 65% of site area) or on public sector land.
This policy has been used by the GLA for some time, but should now force local authorities to follow suit.
Endorsement of emerging housing types
The Plan introduces policy for a swathe of emerging housing types. For example, purpose-built shared-living (or Co-living), Build to Rent and specialist older persons housing such as ‘extra care accommodation’.
The policies give a significant level of detail for a strategic plan and there are conditions that will need to be noted at an early stage for each. For example:
Co-living (Policy H16): needs to demonstrate that it will be managed by a single management company governed by a management plan, contributes to mixed and balanced communities and is not self-contained homes or capable of being used as self-contained homes. Affordable housing will be sought as a cash in lieu contribution either as a lump sum or in perpetuity. Savills has significant experience arguing these issues, including at appeal.
Build to Rent (Policy H11): needs to be at least 50 units and held under a covenant for at least 15 years, again with a clear management strategy. Affordable housing will be expected on-site under the same approach as conventional residential.
Extra-care Accommodation (Policy H13): will again be expected to provide on-site affordable housing under the same approach as conventional residential, attempting to move away from the long-standing use class debate that has dominated this sector.
We have been of the view that these policies could be given almost full weight for some time, but once adopted, local authorities will have to consider them at application stage and will likely look to introduce local policies dealing with each. There is already a trend of emerging local plans introducing co-living policies –for example in LB Hounslow, LB Southwark and LB Lambeth.
Design-led density
The Plan moves away from the density matrix that traditionally guided residential density in London and moves towards a design-led approach. This approach essentially allows consideration for density on a more site-to-site basis. It requires an assessment of a sites accessibility and areas infrastructure capacity and an assessment of how a scheme will fit in with an area, with the encouragement of ‘incremental densification’. When forming local plans, boroughs will expected to undertake character and infrastructure assessments, identifying areas for growth based on townscape and infrastructure capacity.
Planning tall buildings
The Plan introduces Policy D9 which requires boroughs to define tall buildings (with a minimum height of six storeys) and identify specific locations where these may be appropriate. Development proposals will need to take into account the visual, functional, environmental and cumulative impact of their development.
The inclusion of a six storey minimum in the definition should help to ensure that lower density outer London boroughs cannot unduly constrain incremental densification of areas, including through the upwards extension of existing buildings. But the six storey height could overburden the policy tests that developers need to satisfy in higher density inner or high growth outer London boroughs, until such boroughs have their own adopted definition.
Growth in the green belt or old industrial London?
The Secretary of State successfully forced the Mayor to bring the Plan’s policy on Green Belt in line with national policy, as well as remove the ‘no net loss’ clause from his industrial policies. This will ensure that boroughs have more freedom to explore options to accommodate growth when forming local plans. However, there is clearly a tension between where this growth will go.
Boroughs considering the release of Green Belt to accommodate their housing need have to demonstrate that they have made as much use as possible of brownfield land, including industrial land even in active employment use in exceptional circumstances.
There is therefore an ‘exceptional circumstance’ test to release active industrial land and green belt. However, with the non-committal to the strategic Green Belt review, it seems that industrial land is the politically preferred option.
A green revolution?
With the increasing threat of climate change and air quality, the Plan recognises these critical issues and introduces various policies that seek to tackle them. For example, the urban greening initiative is a new approach that seeks to ensure that all Major development contributes to the greening of London through green roofs, landscaping, green walls etc. Furthermore, all major development (10 or more homes or 1000sqm of new floorspace) will be expected to be zero carbon following the be lean, be clean, be green and be seen approach. Boroughs will also be expected to work with developers to develop energy masterplans for large scale development locations such as Opportunity Areas. There is also an increased focus on reducing waste, reducing the heat island effect, reducing private vehicle use, encouraging cycling and minimising and mitigating flood risk through sustainable urban drainage. Whilst much of this was included in the current London Plan, there is a clear committal to keep momentum going and ensure that development in London pays due consideration to all its potential environmental impacts.
Savills London Planning team has experience advising on all planning issues, on all land uses in every corner of London and beyond. If you have any queries regarding any points raised in this article, please do not hesitate to get in touch with us.