Draft London Plan – Housing

04th December 2017
By Charlotte Yarker

An initial observation is that the Draft London Plan has made an advance in being more user-friendly. The chapter relating to housing is entitled ‘Housing’ rather than forming part of a chapter entitled ‘London’s People’.

The chapter seeks to increase London’s supply of housing setting ten year targets for net housing which each authority should plan for. This is sought to be achieved by some innovative means as well as through site optimisation, opportunity areas and strategic provision such as estate regeneration.

The Draft Plan makes provision for mixed use development including residential use on non-designated industrial sites in specified circumstances. There is also provision for the intensification of identified employment sites to release land for housing, although in respect of SILs this appears to only be possible as de-designation through a Local Plan, and in such circumstances 50% affordable housing is sought.

In a departure from previous London Plans there are detailed policies that address non-strategic housing provision recognising the role that they can plan in delivering London’s housing targets. In addition there is an emphasis upon the role that Brownfield Registers can play and a presumption in favour of small housing development, with an increased level of detail regarding the suitability of small sites.

As well as seeking to maximise the ability of small sites to contribute to London’s housing supply, the Daft London Plan includes a policy for ‘Meanwhile use’. The policy encourages identifying opportunities for temporary housing on sites whilst awaiting a longer-term development. The policy seeks to maximise the opportunity presented by vacant sites.

The affordable housing policies hold no surprises following the publication of the Affordable Housing and Viability Supplementary Planning Guidance 2017 in August and the previous draft published in late 2016. The overall target remains at 50% with the ‘threshold approach’ enshrined in policy. There is also policy provision that should be applied to s.73 applications that could affect the agreed percentage of affordable housing of an application. This approach is unsurprising given the Mayor’s reaction to a high profile decision relating affordable housing provision affected by a s.73 application.

The Draft London Plan also formalises the Mayor’s approach to Vacant Building Credit, in that there are few circumstances in which its application would be considered appropriate. This does not come as a surprise to developers with land interests in London.

Build to Rent has a dedicated policy which essentially acknowledges that the product is different to traditional housing types in London. However, Build to Rent schemes will be assessed as market housing when it comes to the provision of affordable housing as the ‘threshold approach’ will also be applied. Similarly there is an expectation that 35% of student accommodation is secured as affordable.

The Mayor has left ‘no stone unturned’ in seeking to maximise housing delivery in London in a dedicated housing chapter that addresses housing provision in the Capital in detail. The Mayor’s approach to housing policy represents a ‘step change’ in the drafting of the London Plan, not least the inclusion a dedicated housing chapter.

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