The progress of the London Plan

In December last year, the Mayor of London, Sadiq Khan, issued to the Secretary of State for Housing, Communities and Local Government, Robert Jenrick (Secretary of State), his intention to publish a final, updated version of the London Plan. This follows an extensive Examination in Public, by a panel of Inspectors, whose 55 recommendations the Mayor received in October 2019. Of these, 28 recommendations were accepted in full, 12 part-accepted, whilst the Mayor has chosen to ignore 15 of the recommendations.

The Secretary of State now has until 20th January 2020 to consider the proposed changes to the Plan, to assess its compliance with national planning policy, and to determine whether the Plan would cause detriment to the interests of areas outside of Greater London.

The Examination Panel’s report found that the 2017 London Strategic Housing Market Assessment (SHMA) provides a reliable assessment of the housing needs for London, and that it was appropriate for the Plan’s housing targets to be based upon this. However, whilst the Plan had originally sought to set a ten year (2019/20 - 2028/29) housing target for London of 649,350 homes, the Panel were unconvinced about the feasibility of this target and recommended a significant reduction to 522,850 homes. The Mayor has accepted this recommendation.

Much of the Panel’s scepticism related to the faith that the Mayor had placed on small sites (less than 25 residential units) delivering a significant proportion of the overall housing target. The Mayor had initially sought to deliver 245,730 new units from small sites within the ten years from Plan adoption. The Panel considered this unrealistic and recommended a reduction to 119,250 over the Plan period, which the Mayor has also accepted.

This creates a situation where London falls significantly short of its Objectively Assessed Need (OAN) for housing. The National Planning Policy Framework is clear that strategic policies must, at a minimum, provide for OANs for housing. The Panel, foreseeing this issue, outlined clear recommendations that the Mayor should commit to a strategic Green Belt review for housing land. However, in his response to the Panel’s recommendations the Mayor has rejected all suggestions for a review and as a consequence, there will be an increase in London’s unmet housing need over the lifetime of the Plan.

This leaves the Secretary of State in an interesting position. Were he to decide not to intervene what message would this send to the authorities within the Shires adjoining London who have already been hard pushed to accommodate significant growth with their own areas? Equally, will the Secretary of State want to be seen to be endorsing a Green Belt review, given how polarising this issue can be with the wider public?

Also of interest to developers will be the confirmation that once the London Plan is adopted its housing targets will take precedence over those set out within existing Borough plans, even where these are recently adopted. This will create difficulties for certain authorities to demonstrate a five-year supply of deliverable housing sites, and will provide opportunities for developers working in these boroughs.

Boyer will continue to monitor the progress of the London Plan, and our team would be happy to speak to developers and landowners alike about any queries related to the new London Plan.