Draft London Plan Inspector’s Report
Following the Examination in Public during the summer, the Inspector’s Report to the draft London Plan has now been published. The report finds the draft London Plan to be sound. However whilst the Inspector’s report broadly endorses the plan, a number of significant recommendations have been made, which the Mayor will now consider.
There are notable amendments recommended to the policies for housing delivery, Green Belt review and provision of industrial floorspace. A summary of the most significant recommendations are outlined below.
The Inspector’s report agrees with the SHMA that there is a need for 66,000 additional homes per year. It is agreed that Policy H1 (increasing housing supply) provides an effective strategy for plan preparation and the general approach to housing targets and the contribution that large sites would make is justified.
This is in stark contrast to the Inspector’s findings on small housing sites. The report sets out that the presumption in favour of small housing developments of between 1 and 25 homes and the targets identified (Policies H2 and H2a) are neither justified nor deliverable. The report highlights that the targets for small site delivery amounts to over 250% in outer London boroughs. The Inspector identifies that at its most extreme the target for Bexley is almost 700% higher. Historic completions from small sites across London as a whole between 2003 and 2017 have averaged 15,300 per annum, therefore the new target would mean London would have to deliver 24,500 homes per annum, a huge uplift, which based on historic performance seems unviable. The Inspector’s report considers these targets would do more harm than good if left in their current form as it would have negative implications for the majority of outer London Boroughs in terms of achieving a 5 year supply.
The Inspector raises concern that a consequence could be too much focus on simply delivering units rather than achieving the right sort of development in the right place. The policy approach is considered to go “too far too soon”.
The Inspector recommends that Policy H2A (presumption in favour of small housing developments) is deleted in its entirety and the ten year small sites housing targets for boroughs are reduced to give a total of 119,250 dwellings (rather than 245,730). As a consequence this reduces the overall housing targets for boroughs to a total of 522,850 dwellings (rather than 649,350). This would result in a 10 year housing target of 52,285 per annum, which the inspector identifies would be higher than the existing London Plan and above the 45,505 units completed in 2016/2017.
If these reduced housing targets were to be accepted by the Mayor they would likely have a larger impact on the boroughs, however, the retention of Policy H2 demonstrates that the Inspector still recognises the importance of small sites in delivering housing.
The Inspector’s report identifies that in quantitative terms the draft Plan underestimates the industrial land required to meet future demand over the plan period (up to 2041). It is recommended that the wording of the policy is strengthened to focus on providing industrial land as opposed to simply maintaining current provision. The Mayor is advised to give further consideration to, and modify, if required, the categorisations for the management of industrial floorspace capacity at borough level in order to provide a more positive strategic framework for the provision of industrial capacity. The Inspector provides no indication of where such modifications should take place. However, such a review could have implications on industrial land release opportunities for changes to other uses, particularly if more of the London borough’s targets are amended to ‘provide capacity’ for the management of industrial floorspace capacity.
Given the demand for further supply the report recommends that the Plan includes reference to boroughs considering Green Belt reviews in addition to the Strategic Green Belt review across London (see below).
The Inspector agrees with the non-prescriptive approach of Policy E7B which seeks to promote intensification of Strategic Industrial Land (SIL) and Locally Significant Industrial Sites (LSIS), and supports the co-location of industrial with residential uses in LSIS locations.
These recommendations, would have implications for landowners seeking to change the use or increase the capacity of any part of their industrial sites, or where seeking to create new industrial floorspace on sites not currently in industrial use.
In light of the findings and recommendations above, the Inspector’s report advises the Mayor that a London-wide strategic Green Belt review should be carried out as part of the next London Plan, to establish whether it would be reasonable to release Green Belt land in order to close the gap between housing need and supply and accommodating increased industrial capacity. This is likely to prove more popular with the development industry than with national politicians or the general public.
The report also criticises the Plan’s exclusion of the exceptional circumstances and very special circumstances tests, outlined in National Policy and the general approach that the Green Belt is sacrosanct. Amendments to the wording of the Green Belt Policy (G2) and the Metropolitan Open Land Policy (G3) are sought so that they are consistent with National Policy.
If accepted by the Mayor, these recommendations could have implications for landowners as the Inspector recognises the role green belt land could play if released for development, especially in identifying new sites for industrial uses.
What happens next?
The Inspector’s recommendations are non-binding so the Mayor may choose to ignore or cherry pick the amendments he wishes to take forward. Sadiq has already said that he will reject the recommendations in respect of the green belt and sustainability. The Plan will need to be submitted to the Secretary of State and the London Assembly prior to adoption.
It would seem prudent for the Mayor to carefully consider the recommendations to avoid a potential political backlash in the run up to the Mayoral elections in May, particularly given that there has been skepticism about what Sadiq has delivered over the last four years.