Lichfields is currently monitoring the draft London Plan Examination in Public (EiP), which is scheduled to last until May 2019, and will report on relevant updates as part of a blog series
. The second blog of the series focuses on the hearing session for draft policy H2 ‘Small sites’, which took place on 13 February 2019.
The small sites Policy H2 of the draft London Plan is apparently there to encourage small and medium builders to become more involved in housing delivery, with their contribution having dropped from 40% of delivery to only 12% now as a result of the growth of London’s new big players. But there is a lot of cynicism as to whether the theory of easy planning/fast delivery is anywhere near achievable.
With bigger sites running out and the GLA being pressed to higher targets rising from 33kpa to 65k pa or more – and without opening up green belt or MOL – there is nowhere else to go leading to an emphasis on Outer London, to the (mainly) Tory Boroughs, to deliver nearly 40% of London’s overall need through such small sites. It is recognised by the Mayor as a step change but is, rather, a vain hope for sufficient delivery and fast enough delivery. The focus is placed on those areas within 800m of a station or town centre boundary, wherever that is across London.
Worse, though, it passes the buck on that substantial delivery requirement from the centre (Mayor and Inner London Boroughs) to the Outer London Boroughs – making them responsible for the success or failure of the overall strategy. And of meeting the new local delivery tests and ongoing 5-year housing land supply requirements.
The proposed Plan approach is criticised as being, on a daily and application-by-application basis, no great change from existing policy – windfalls plus small allocations – but that it requires many local planning authorities (LPAs) to allocate substantial numbers of small site (up to 25 units and or 0.25Ha) through their plan-making to top up the rate. And that means lengthy discussions for plan-makers with numerous landowners on availability, assessing capacity, considering amenity issues and housing value to get anywhere near the suggested target.
Even a well-performing Council like LB Croydon - which has been achieving just under 600 units per annum on its existing windfall basis, with an SPD suggesting it can up this to 750 per annum – would have a new small sites target of 1500 units per annum.
There would be a target increase of 1% pa for suburban areas, with extra emphasis on detached/semi-detached housing areas – based on a proportion of the 5% annual sales churn across London. So, a 10% uplift in all areas of London over 10 years. The targets themselves are criticised as ‘reverse engineering’, with the justification created to achieve the identified shortfall elsewhere – based on modelling and without evidence base – and leaving the problems to others and/or for another day.
But at the 13 February session of the Examination in Public Outer London Councils suggested life would not be so easy. Firstly, it would involve 20% of all sales each year to go to redevelopment/extension/conversion rather than re-occupation as is. Secondly, small builders would find financing a small redevelopment with lower density houses rather than with flats as involving lower capital outlay at any one time (reducing risk) and with the same residual land value – undermining potential delivery increases. Thirdly, it would reduce the stock of family housing. Fourthly, it would introduce more housing in flood areas. Fifthly, it would change the character of the suburbs.
Small sites would not normally deliver any affordable housing, particularly for sites up to 10 units or even for larger ones with high existing use values. They would be difficult to plan for en masse in terms of real infrastructure delivery – schools planning, etc.
Perhaps more importantly, the intended ‘presumption in favour’ (but subject to conventional amenity testing) was queried as to what it meant in practice. Does it mean lowering the bar for such sites in order to increase delivery? Outer London Boroughs are already well versed in such matters. LB Bromley said that it is already winning 80% of appeals against overdevelopment. Will the Inspectorate have to lower the bar as well?
There is no Plan B – at least without releasing greenfield land. In this context, negotiating a good consent and with a much larger quantum of housing and faster annual delivery rates is said by some Outer London authorities to be more efficient. There is continued pressure from some London LPAs to relax green belt controls, allowing them to do what those outside London are already doing to genuinely achieve increased delivery.
It appears to be a case of kicking the can down the road (familiar at the moment) – to a later shortfall on delivery and the next review of the Plan. Or of kicking the can to someone else and setting them up to fail.
The Panel will have real trouble in resolving the two distinct positions to achieve soundness. Hope versus experience. But it needs to consider the whole picture of major releases, Opportunity Area development, normal windfall development, etc. and then from where delivery can realistically and best be topped up.
Lichfields will publish further analysis on the draft London Plan Examination in Public in due course. Click here
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Draft London Plan policy H2 ‘Small sites
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Image credit: Paul Hudson