Despite the chaos of the ‘Beast from the East’, my colleagues and I recently submitted representations to Sadiq Khan’s Draft London Plan on behalf of a variety of our clients.
The points we raised were informed by several roundtable discussions and seminar sessions that we organised with people at all levels from across the development industry over the last four months.
Sadiq Khan has made it clear that this Draft London Plan is a reflection of his 2016 manifesto commitments and that London has a ‘housing crisis’. This in turn will be translated into his platform for re-election in 2020 with housing continuing to be the number one local election issue for Londoners.
From the roundtable discussions and sessions it is apparent that the industry’s shared objective is to help shape the Plan and sharpen its focus to address this crisis. As well as engaging with the nitty gritty detail, our clients’ representations hone in on this.
Fundamentally, the Plan should help Planning Officers justify recommendations and Committees resolve to grant planning permission. It should be clear to communities about what ‘optimisation’ means, especially in suburban London, while setting stronger policies in support of development new homes and integrating the following.
- The Draft Plan sets a presumption in favour of the development of new homes at certain (not all) ‘small site’ schemes of 25 homes or fewer. Given the need to address the ‘housing crisis’ shouldn’t this principle apply across all sites?
- 65% of London’s housing need is for affordable homes. Shouldn’t the delivery of ‘genuinely affordable’ homes be afforded significant weight when planning decisions are made? Many Londoners would be stunned to hear that planning policy is generally silent on this. This doesn’t help house those on Council waiting lists, lifelong residents who can’t access local homes or key workers who feel priced out of the city.
- The Draft Plan does not reflect on the consequences for Londoners of failing to address the housing crisis. Wouldn’t it help decision-makers if there was a summary of these real-world social, economic and environmental consequences that could be copied and pasted into Committee Reports?
Integrating the above should significantly help deliver new homes. But will it be enough to meet the housing crisis?
Our analysis suggests housing need is underestimated, housing supply is overestimated and that housing delivery rates may be unachievable. Moreover, there is a reliance on infrastructure-led growth but ambiguity about whether all of this infrastructure will be delivered and what will happen to schemes if they are not.
All of the above indicates a review is required of London’s protected land (including the Green Belt, Metropolitan Open Land and appropriate industrial sites). It also emphasises the need to engage with local planning authorities in the South-East of England to identify willing partners and realistic locations for growth beyond the city boundaries.
The Mayor’s ambitious target is to move swiftly towards Examination of his Draft Plan in Autumn 2018 and we look forward to working with our clients throughout this process, to help achieve the best outcomes for Londoners.
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