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Will brownfield land registers solve Greater Manchester’s housing crisis?
It is well-known that Greater Manchester is not immune from the national housing crisis. Going forward, the first draft Greater Manchester Spatial Framework’s (GMSF) housing target is still considered too low by many observers (including ourselves). However, at least it has confronted the issue of Green Belt release. Greater Manchester’s Mayor Andy Burnham campaigned on, and has delivered on this matter through his review of the draft Framework, and it will be covered in the much anticipated, upcoming 2nd draft of the GMSF. Whether this represents the promised “radically changed” approach to make more use of the city region’s brownfield sites, and reduce the impact on the Green Belt, we will have to wait to see. New rules in force since last April mean that all local planning authorities (LPAs) had to publish a brownfield land register before 31 December 2017. Nationally, Lichfields’ analysis shows that only approximately half of English local planning authorities have published their brownfield land registers (BLR); the registers tend to simply include sites identified in strategic housing land availability assessments/ allocated housing land. This is possibly related to, and symptomatic of, the slow delivery of local plans, with patchy coverage at best nationally and a similar development planning pattern across Greater Manchester too. As part of Lichfield’s analysis highlighted in this blog, we focus on the Mayor’s stated aim of tackling the city region’s ever-growing housing crisis with the re-use of brownfield sites. How will the GMSF make better use of brownfield land, and how realistic is this policy approach? Publication of the region’s registers in December 2017 provides some insight on this issue. To be fair, all 10 Greater Manchester authorities have published their registers, reflecting their wider regeneration aspirations and the drive to maximise the re-use of brownfield land for housing-led development. In total 1,314 PDL sites have been identified across Greater Manchester which collectively have the capacity to deliver around 100,100 new homes over the next 15 years. How many of these are deliverable without significant public sector investment will be interesting to see. It is by any measure a significant number, but it only helps to crystallise the case for retaining the Green Belt around Greater Manchester or not; the number of homes on BLR sites equates to only around 44% of the draft GMSF housing target of 227,200 new homes up to 2035. Many within the industry considered this aspiration to be too low already, identifying how it failed to serve aspirations for economic growth and the Northern Powerhouse agenda. Irrespective of this, we all have to grapple with where the other 127,100 or more homes will be built. It is also fair to say there is a mixed picture across Greater Manchester in terms of distribution of brownfield land. Figure 1 below compares the quantity of brownfield land to the previous draft GMSF requirement. Only Manchester, Salford and Bolton can deliver over half of their target. Six local authorities (Bury, Oldham, Rochdale, Stockport, Tameside and Trafford) can only deliver less than 30% of their requirement. Figure 1: Brownfield land register proposed dwellings compared to the previous draft GMSF’s requirements   Source: GMSF, MHCLG The capacity gap in Trafford (86%) and Stockport (88%) is very substantial to say the least. So what does this mean for the future spatial strategy, and what are the consequences? How are Trafford’s and Stockport’s (and others’) needs to be met, without further increasing the affordability gap and the pressure on house prices. The previous draft GMSF identified a series of greenfield sites - predominately from the Green Belt - that would be required to meet need, contributing some 63,850 dwellings overall. Since it was formally adopted in 1984, the Greater Manchester Green Belt boundary has largely remained unaltered and it is a highly controversial topic - hence the Mayor’s review of the first draft GMSF. However, even if one adds all of the potential GMSF allocations to the BLR sites, the total falls a long way short of housing targets. Taking Greater Manchester as a whole, BLR sites and potential GMSF allocations will only deliver 72% of the city region’s housing requirement overall. Again the picture is highly variable, with Bolton and Bury close to achieving their requirement, but others, including Trafford and Tameside, having significant shortfalls. Figure 2: Total GMSF allocation & proposed brownfield land register units compared to the previous draft GMSF requirement Source: GMSF, MHCLG Furthermore, when considering the identified allocations, the GMSF has focused primarily on a few very large sites coming forward to meet the shortfall in supply. This results in inevitable pressure on infrastructure in key communities. We will have to wait and see how the 2nd draft GMSF responds to these issues, but it may for example include a broader range of sites, of different sizes and locations in order to de-risk the delivery issues and problems associated with not achieving the housing requirement. Brownfield land is one step towards meeting the requirement, and key questions will remain around delivery, and how long term requirements are to be met.   However, as demonstrated in Figure 3, there remains a shortfall of 63,245 homes to meet even the first draft GMSF housing target.  Regardless, the 227,000 GMSF requirement still remains well below the level of housing necessary to address housing pressure and the under-delivery that the city region has experienced over the years, even before considering the long-term economic growth needs of the conurbation at the heart of the Northern Powerhouse. Figure 3: Identified housing shortfall Source: GMSF, MHCLG Conclusion Whilst there is much to be welcomed in the Greater Manchester local authorities publishing their BLRs before the deadline, it seems that the re-use of brownfield land for housing can only be part of the solution. Even if every one of these sites were to come forward as intended, the local authorities still need to identify land for more than 127,100 homes just to meet the GMSFs conservative targets. If less land is to be removed from the Green Belt, there remains significantly more deliverable sites that will have to be found to meet need. This is even before a debate as to whether a target of 227,200 is suitably ambitious for a great conurbation such as Manchester, that should be driving the economy of the North in the Northern Powerhouse agenda.   Image credit: A.P.S. (UK) / Alamy Stock Photo  

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The new London Plan: policy preview

The new London Plan: policy preview

Giorgio Wetzl 13 Sep 2017
This has been quite a busy summer for London Mayor Sadiq Khan; while many of us were (rightly) enjoying some time off work, the Greater London Authority and the Mayor released a plethora of documents which will play important roles in shaping London’s future. Furthermore, these publications provide a very clear policy preview of the new London Plan due to be published in November. In the last few months, the Mayor has published (in draft) his statutory Transport (TS), Health Inequality (HIS), Environment (ES), and Housing Strategies (HS) [1]. He’s also issued the final version of his Affordable Housing and Viability Supplementary Planning Guidance (SPG) [2], his vision for a night-time economy [3], and a tourism vision for London (through London & Partners) [4]. The Mayor has also announced investment and funding allocations to increase the delivery of affordable housing in the capital [5], as well as releasing the preliminary draft charging schedule for the Mayoral Community Infrastructure Levy to fund Crossrail 2 (the so-called ‘MCIL2’) [6]. Finally, he released commissioned reports on the impact of overseas buyers on London’s housing market [7], London’s industrial land demand [8], and an office policy review [9]. For those with a little experience and knowledge of London planning matters, this deluge of material comes as no surprise, as the most important strategic document for the city’s development, the new London Plan, is set for publication in draft by the end of the year. As speculation on its content grows, it is possible to preview the draft document’s policies, as many references are made to them, and heavy hints have been spread across all of this summer’s publications.   New Plan, brand new proposals The Mayor has provided us with some very clear insights on brand new policy that he is considering incorporating in the draft London Plan. First, the Mayor aims to embed his ‘new approach to securing affordable homes through the planning system within the draft London Plan’ (Policy 4.2A HS), meaning that the 2017 Affordable Housing and Viability SPG’s 35% threshold approach will become development plan policy and, therefore, have strengthened status (see Lichfields blog for details). Other parts of the SPG will also be incorporated in the new draft London Plan, including: London Living Rent (‘the Mayor’s draft London Plan will support councils, housing associations, and other developers in the delivery of homes let permanently at London Living Rent levels’ – Para 4.23 HS; see Lichfields insight for details); and support for Build to Rent (‘to encourage the development of the sector, the Mayor will embed the BtR pathway approach in his draft London Plan’ – Para 3.75 HS) Second, the Mayor is also minded to ‘give a clear presumption in favour of appropriate residential development on small sites, including specific borough level targets for this type of development’ (Para 3.21 HS); as part of this, the Mayor will include details referring to ‘working with councils to promote the use of Permission in Principle on small sites’ (Para 3.83 HS). This is an interesting policy proposition, and it could potentially lead to an increased contribution to housing delivery from smaller developers and housebuilders. However, the potential for implementation success lies also with the London Boroughs, as all of the stakeholders need to be convinced that Permission in Principle actually does offer effective advantages when compared to other existing planning routes, particularly outline permission (see Lichfields blog for details on Permission in Principle). The draft Environment Strategy also offers some interesting previews of the content of the new London Plan, including the intention to introduce ‘the Agent of Change principle […] through the new London Plan and puts the noise mitigation requirement onto the person or business responsible for making the change rather than penalising existing businesses’ (Policy 9.2.2a – box 35 ES). Other planning-related proposals will be considered for inclusion in the new Plan, such as ‘a requirement to consider the overall suitability of a site (and its design layout) for the proposed end use in terms of exposure to pollution’ (Proposal 4.1.1c ES). Other notable new environmental policies include: ‘all new large-scale developments in London are ‘Air Quality Positive’ and maintain Air Quality Neutral requirements for all other developments’ (Proposal 4.3.3a ES) and ‘fracking is prevented in London’ (Proposal 6.2.2d ES). On the latter, I am not sure that this is a necessary policy – surely there is no real appetite for shale gas development, given its character and the high cost of land in the capital – but it would be a clear political symbol, if nothing else.   New Plan, slightly amended (but still old) policies The Mayor has provided additional details on how he will change some of the policies/ requirements/ standards in the current Plan (published in March 2016) [10]. Among these, the Housing Strategy states his intention to ‘fully revise and update the list of London’s Opportunity Areas’ in the new draft London Plan to maximise the number of new homes that largest housing-led regeneration initiatives could deliver’ (Para 3.16). Also in the Housing Strategy is a reference to the inclusion of a specific policy which will clarify that ‘affordable homes demolished as part of estate regeneration projects should be replaced on a like for like basis’ [the same will apply to homes sold under the Right to Buy] and adds, ‘this means that homes for social rent must be replaced with homes at similar levels’ (Policy 4.3D). This represents a subtle but important change when compared to the current London Plan’s reference to estate renewal and the need to provide ‘at least an equivalent floorspace of affordable housing’, when redevelopment of affordable housing is proposed. Other policy tweaks are to include: ‘more ambitious requirements for sustainable drainage in relation to new development’ (Proposal 8.2.3a ES); the strengthening of ‘the consideration of the impact of planning on health and health inequalities’ (Objective 3.2 HIS); and the possible development of ‘new parking standards […] to ensure car-lite development’, with the aim of restricting ‘car parking provision within new development, with those locations more accessible to public transport expected to be car free’ (Proposal 76 and related guiding principles TS). These expanded requirements, in addition to the new affordable housing contributions (35% threshold) and the revised MCIL2 that the Mayor is currently implementing, will potentially lead to an increased burden overall for developers and housebuilders.   New plan, old policies The latest version of the current London Plan is a stunningly long, 441-page document. From what we know so far, it is already seeming inevitable that the new London Plan will incorporate many of the proposals and policies already included in the 2016 edition – not surprising, given its strategic nature. This is the case for many of the ‘new London Plan’ references included in the different draft mayoral strategies; the policies and proposals are not new. For example, although not providing any detail, the Transport Strategy refers to the need for ‘protecting industrial land through the London Plan’ (Proposal 15b). The same draft Strategy also mentions that although the new London Plan is still in preparation, this is likely to show that ‘the city’s growth potential is concentrated in the Central Activities Zone (CAZ), within its town centres and Opportunity Areas; there will also be growth potential from the managed intensification of suburban areas’ (Chapter 5b). None of the above is at all surprising; the same goes for the reference in the ES to the protection of ‘Green Belt, Metropolitan Open Land and publicly accessible green space’ (Proposal 5.1.1), and the introduction of ‘a zero carbon standard for non-residential buildings in the London Plan from 2019’ (Proposal 6.1.4a), as both of these strategic goals are in the current Plan. In the same way, throughout the Housing Strategy there are references to the ‘Mayor’s housing targets for councils’ (Policy 3.1A), which will be based on a revised Strategic Housing Land Availability Assessment (SHLAA) – the same process as now. Probably a bit more surprising, particularly given the many calls for additional flexibility and potentially revision, is the intention to maintain ‘existing space standards’ and to ‘ensure that any further national reviews of standards take into account London’s circumstances’ (HS, Para 5.14).   First comes planning (the strategy), then comes implementation The above preview is a (not so) brief overview of the policies and proposals the Mayor has decided on, or is considering for inclusion in his new London Plan that will be launched for consultation later this year. The spatial development strategy will be part of the capital’s development plan and set the scene for London’s future development over the next 20-25 years, therefore all of its content needs to be carefully planned and considered throughout. Quite naturally there are high expectations; many stakeholders wish to see certain policy wording or particular proposal which could boost/ improve their sector. Personally, there are three features I would like to see incorporated in the new London Plan. First, a clear focus on the implementation strategy for its policies and proposals, possibly mirroring the Affordable Housing and Viability SPG model; strategic goals are important, but how those objectives will be delivered, and how they will produce effective changes, are both crucial for success; Secondly, improved readability of the document, to make it accessible to as many Londoners as possible and to effectively open up the debate about future development strategies for the city; and Thirdly, consideration to uses/functions other than housing given throughout. Housing, particularly affordable tenures, is clearly the number one priority in London at the moment and, accordingly, should be given the necessary consideration; however, this should not lead to overlooking the importance of other land uses (such as employment – including industry and affordable workspaces - and town centre uses), in guaranteeing London’s future success. An ambitious strategy is a good starting point, but making it work is what really matters in the end.    Footnotes [1] Transport Strategy - https://consultations.tfl.gov.uk/policy/mayors-transport-strategy/user_uploads/mts_main.pdf // Health Inequality Strategy - https://www.london.gov.uk/sites/default/files/draft_health_inequalities_strategy_2017.pdf // Environment Strategy - https://www.london.gov.uk/sites/default/files/les_full_version.pdf // Housing Strategy - https://www.london.gov.uk/sites/default/files/london_draft_housing_strategy.pdf[2] Affordable Housing and Viability Supplementary Planning Guidance 2017 - https://www.london.gov.uk/sites/default/files/ah_viability_spg_20170816.pdf[3] A vision for London as a 24-hour City - https://www.london.gov.uk/sites/default/files/24_hour_london_vision.pdf[4] A Tourism vision for London - http://files.londonandpartners.com/l-and-p/assets/london_tourism_vision_aug_2017.pdf[5] ‘Mayor strikes deal for 50,000 new affordable homes’ - https://www.london.gov.uk/press-releases/mayoral/record-17bn-deal-for-new-homes // ‘Mayor invests in more than 1,000 “Pocket homes” for first-time buyers’ - https://www.london.gov.uk/press-releases/mayoral/sadiq-invests-25m-in-pocket-homes[6] MCIL2 Preliminary Draft Charging Schedule - https://www.london.gov.uk/sites/default/files/mcil2_pdcs.pdf[7] The role of overseas investors in the London new-build residential Market, LSE London - https://www.london.gov.uk/moderngovmb/documents/s58640/08b2b%20LSE%20Overseas%20Investment%20report.pdf // Overseas Investors in London’s New Build Housing Market, University of York and Centre for Housing Policy - https://www.london.gov.uk/moderngovmb/documents/s58641/08b2c%20University%20of%20York%20data%20report.pdf[8] London Industrial Land Demand Study 2017 - https://www.london.gov.uk/sites/default/files/ilds_final_report_june_2017.pdf[9] London Office Policy Review 2017 - https://www.london.gov.uk/sites/default/files/london_office_policy_review_2017_final_17_06_07.pdf[10] London Plan, March 2016 - https://www.london.gov.uk/sites/default/files/the_london_plan_2016_jan_2017_fix.pdf

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