The draft new London Plan Examination in Public has reconvened over the past two weeks to discuss the housing strategy matters. We’ve had some very interesting, albeit high-level and philosophical, debates around the overall housing strategy to deliver Good Growth and how London can achieve the step change required to meet its projected need. However, we’ve now started drilling down into the detail of delivery and, in particular, the small sites strategy.

The boroughs have been very engaged in these sessions, as have the community and amenity groups. We’ve even seen some old faces from the GLA who worked on previous versions of the London Plan. However, MHCLG has been conspicuous by its absence from the table, and representatives were only in attendance to observe from the audience. To quote the London Tenants Federation, ​“it’s a shame that central government isn’t participating in these housing sessions to allow us to pin the tail on the donkey’.

A lot of criticism has been levelled at the Mayor’s team in terms of the evidence base (or lack thereof) and assumptions that underpin the Strategic Housing Land Availability Assessment (SHLAA). The West London Alliance described the SHLAA as more akin to a think tank report than the ​“compelling” and ​“proportionate” evidence required by the NPPF, particularly in light of the drastically different policy approach in this new Plan.

With regard to the shortfall between the identified housing need of 66,000 and the total annualised average housing target of 64,935, the Mayor’s team confirmed that there is no expectation that the Wider South East should absorb this shortfall. The boroughs may set higher targets if they wish, and the Mayor’s team pointed to the draft new Westminster City Plan, which has already come forward with a 500 unit/​pa increase, thus covering half of the shortfall.

The Mayor’s team noted that they do not currently undertake housing trajectories, as these are undertaken by the boroughs; however, they are discussing whether there should be a London-wide trajectory. This would be dependent upon gathering data from the boroughs because they allocate the sites. The Panel advised that they would consider putting forward a recommendation for the Mayor to initiate this to give weight to the process and to encourage the boroughs to engage.

The Mayor’s team asserted that the Plan is deliverable, although they conceded that the targets would be challenging and that external factors beyond planning – including central government funding, infrastructure delivery, and the land market – will all affect its deliverability.

Significantly, the Mayor’s team have accepted that there will be a gradual increase in delivery, not an immediate step change, and through the examination process they have encouraged boroughs to set realistically achievable targets, including the use of stepped trajectories to ratchet targets up gradually over the 10-year period. The GLA has made £10m available to the boroughs through its Homebuilding Capacity Fund to help the boroughs resource work like their small sites strategy, yet the Mayor’s team noted there has been limited uptake from the boroughs to date.

As expected, the small sites session proved to be a lively debate and had the highest attendance by far in terms of both official participants around the table and observers. Whilst many of us agree that the potential of small sites should be better exploited, especially in Outer London, there was overwhelming concern amongst the respondents about the extent of supply that can realistically be delivered from small sites and whether the targets are realistic and deliverable. In the words of the South London Boroughs group, ​“Policy H2 is not the silver bullet that the Mayor thinks it is on which to wholly justify the step change in growth”.

The Mayor’s team asserted that there is huge untapped potential in the SME construction sector, and the introduction of Policy H2 will reduce the risk and uncertainty for small sites, making it easier for them to access finance. However, London First countered that the constraints on delivery are more complex than that. The time and costs involved in navigating the planning process for small sites are often disproportionately high for the anticipated financial return by comparison with those for medium and large sites, and this deters small sites from coming forward. 

The boroughs clearly have genuine concerns about how they can deliver the level of growth envisaged from small sites and noted that the use of design codes to release small sites will be an evolution, not a revolution. London First’s recent YouGov poll showed that only half of Londoners would welcome homes built in their area (down from 57% last year) and this indicates the extent of opposition that the boroughs have to deal with. The fact remains that the draft new London Plan is highly dependent upon the small sites strategy to achieve its identified housing need, and yet it carries huge risk in terms of being deliverable; realistically alternative sources of land supply need to be brought forward if we are to meet the Plan’s ambitious targets. 

We shall all reconvene on 26 February to discuss affordable housing. In the meantime, please follow this link to view all our examination written statements submitted to date, and if you wish to discuss anything in greater detail, please contact Sarah Bevan