Comment

London Plan: Homes for Londoners?

Planning for and delivering a large number of new homes remains a critical challenge for London’s people and the functioning of its economy. Continuing our series on key aspects of the Publication Version of the London Plan, we look at how the plan aims to meet this challenge.

The perennial challenge of building enough homes drives many aspects of the plan, though housing is but one of many diverse and sometimes competing priorities. Significantly increased housing targets apply to numerous boroughs, in spite of the disappointing outcome of the Examination in Public, which saw the overall target reduced from 65,000 to 52,000. Boroughs with big increased targets are predominantly, though not exclusively, east and/or outer London boroughs, with Southwark as a notable more central exception, largely due to its significant Opportunity Areas. At the same time, the 2020 MHCLG Housing Delivery Test identifies under-performing boroughs, with a focus on many in the north and east of London as well as all the central boroughs except for the City. Greenwich, Tower Hamlets, Southwark and Barnet fall under MHCLG’s spotlight and will also have some of the highest GLA housing targets. We consider the impact of the Housing Delivery Test in London in our comment on the NPPF. HDT figures indicate average delivery of just 37,000 homes per annum in London 2017/18 – 2019/20, underlining the scale of the challenge.

Whilst conventional supply and associated affordable housing delivery is a significant focus, there is support for Built to Rent and muted support for Co-Living, where the latter delivers a cash payment towards self-contained affordable housing.

Housing delivery

Housing delivery is challenging for many authorities, particularly in the context of protected industrial and Green Belt land, though modifications to the plan do assist in relation to industrial land as set out in our comment. New homes are directed to higher PTAL sites, including town centres; under-utilised sites, such as car parks and low-density retail; public-sector and utilities land, and appropriate industrial sites. Smaller sites will also play a crucial role in spite of challenges about deliverability during the Examination and are subject to separate housing targets. The Mayor will also focus increasingly on build-out rates, to ensure that homes on paper translate to places for Londoners to live.

Within town centres there is acknowledgement that one and two bedroom homes may be more appropriate than family-sized homes. At the same time, the importance of family housing in general is acknowledged, including through a direction from the Secretary of State, who also directed a potential relaxation of car-free housing rules, where this would support additional family homes. Not all town centres are equal however, with ‘residential growth potential’ defined in relation to each and classified as high, medium or incremental. In the Central Activities Zone (CAZ), excluding Opportunity Areas and established residential areas, new homes should not compromise CAZ strategic functions, particularly offices and new homes are not appropriate in parts of the City and Northern Isle of Dogs.

Quality as well as quantity

Whilst housing numbers are important, so is housing quality. The plan contains extensive detail in this respect and wading through the increased complexities of London’s two-tier system will require an eye for detail as well as a good sense of balance. Familiar provisions in relation to space standards and amenity space are supplemented with more nuanced guidance on matters such as internal and external layouts, the orientation of individual homes and usability and maintenance considerations. There are also new quantitative design standards to contend with, such as the Urban Greening Factor and developments must apply the principals of Healthy Streets and associated public realm requirements.

Supporting this focus on quality, the plan ushers in a new approach to density. Gone is the top-down ‘sustainable density matrix’, though we suspect this will survive as a reference for many. In its place is a more nuanced and contextual approach, with the aim of optimising housing delivery; however that may come to be defined. ‘Incremental densification’ is preferred in lower PTAL areas, such as the suburbs, echoing the Government’s ‘gentle densification’. 

In implementing the plan, the industry must square the circle of housing numbers, design quality, contextual sensitivity and competing land uses. However, whilst this will no doubt create challenges, the overall agenda is one of growth.

 

See our recent articles for further information on the broader changes of the plan and on the approach to industrial land.

Please contact Oliver Jefferson for more information.

27 January 2021