Update 22 December 2023 - The Government has published the terms of reference and objectives for the panel of expert advisers who are to consider any changes to the London Plan which might facilitate housing delivery in London. This states that the Panel's report must be delivered by 15 January 2024.
Back in July 2023, when delivering his speech entitled the ‘Long-Term Plan for Housing’, Michael Gove said, in relation to housing under-delivery in London:
“I also will not hesitate to act in the national interest when politicians fail.” […] “I reserve the right to step in to reshape the London Plan if necessary and consider every tool in our armoury – including development corporations.”
Five months later, the Secretary of State released a Written Ministerial Statement entitled 'The Next Stage in Our Long-Term Plan for Housing Update', which alongside other publications and announcements (such as the contents of the revised National Planning Policy Framework, December 2023, as you may have heard by now), contains some more information on some ‘tools in the armoury’ that are being used, not only in London, but elsewhere too, in a hope to deliver much needed housing.
This blog explores two targeted steps for two cities, from the Long-Term Plan for Housing Update:
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Ordering a review of the London Plan to examine factors that could be causing housing under-delivery in the capital, and threatening intervention if the necessary actions are not taken.
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Establishing a Development Corporation in Cambridge to help realise plans for ‘Cambridge 2040’, alongside a revised building regulation to allow local planning authorities to introduce tighter water efficiency standards in new homes, to ensure “an approach towards water that reflects the nature of Cambridge’s geography.”
Independent Review of the London Plan
In a
letter to Sadiq Khan, published during Michael Gove’s address to the Royal Institute of British Architects on the 19 December (but issued to the Mayor on 18 December), the Secretary of State announced the appointment of an expert panel to conduct a review of the London Plan to consider “
aspects of [it]
which could be preventing thousands of homes being brought forward, with a particular focus on brownfield sites”.The panel comprises Christopher Katkowski KC, Cllr James Jamieson, Paul Monaghan and Wei Yang. Lichfields is pleased to have been appointed to support the Panel, working alongside DLUHC officials.
The Secretary of State's letter includes as a response to the recommendations of the Mayor's London Housing Delivery Taskforce, prepared after Mr Gove first suggested possible intervention in the first ‘Long-Term Plan for Housing’ speech in July 2023
[1]. In that speech, the Secretary of State also announced his ambitions for ‘Docklands 2.0’ as a 3,500-home eastern extension to the city, citing development corporations and the power to reshape the London plan as ‘tools in the armoury’ to make this happen.
In the letter on the 19 December, Mr Gove re-states the threat of intervention, saying, in one line:
“If you cannot do what is needed to deliver the homes that London needs, I will.”
This back and forth over housing delivery has been described by London newspapers - the London Evening Standard and CITY.AM - as a political “row” between the Mayor and the Secretary of State on the undersupply of housing in London. However, it is common ground between the Mayor and the SoS that the pace of housing delivery in the capital needs to increase.
The long awaited 2022 HDT results reveal that over half of the London planning authorities (18 of 35
[2]) will now be subject to the policy consequences set out in the December 2023 revised NPPF. Nearly three quarters (13) of the 18 failing the HDT have underdelivered by at least 25% of their requirement. They will therefore be subject to the application of the presumption in favour of sustainable development, the inclusion of the 20% buffer on 5YHLS (except for those authorities with an up-to-date local plan) and the preparation of an action plan. For a more detailed explanation of the housing delivery test’s new policy consequences, see
Harry Bennett’s blog.
The focus of the independent review will be to explore the relationship between the policies of the London Plan and the pace at which new homes are being brought forward and developed on brownfield land.
Mr Gove and Mr Rowley both said - in their respective 19 December written and oral statements to Parliament - that
“opportunities for urban brownfield regeneration [in London]
go begging” as a result of under-delivery. However, the Mayor has
identified a significant number of housing starts and the GLA argues
[3], based on the findings of the Housing Delivery Task Force’s August report, that a general lack of 2021-26 Affordable Homes Programme funding available to London, coupled with a lack of certainty around funding beyond 2026, means affordable housing developers lack the certainty they need to bring forward complex schemes, including estate regeneration
[4].
On the topic of grant funding and affordable housing, he SoS suggested in his RIBA speech that affordable housing policy for residential developments in the London Plan is a barrier to delivery due to viability. The perceived impact of high affordable housing targets is not a new concern, and one held by a number of those in the development industry.
Development Corporation to be set up in Cambridge
No independent review of housing or economic development delivery is proposed for Cambridge. Instead, the Government is following up on an announcement earlier in the year on its ambitious housing and industry plans for ‘Cambridge 2040’, in a bid to make the city the Science capital of Europe.
Back in July, this involved the establishment of a ‘Cambridge Delivery Group’ to help realise this vision. It was also announced that the Delivery Group would be supported by a
“super-squad of planners” to realise this ambition
[5].
These plans have now been taken further, as Mr Gove’s Written Ministerial Statement confirmed the Government’s intentions to establish a new development corporation for Cambridge. The WMS continues (armament imagery strong still):
“[We will arm this development corporation] with the right leadership and full range of powers necessary to marshal this huge project over the next two decades, regardless of the shifting sands of Westminster.”
In response to Mr Gove’s announcement, the leaders of Cambridge City Council, South Cambridgeshire District Council, Cambridgeshire County Council, and the Combined Authority Mayor of Cambridgeshire and Peterborough released a joint statement
[6] the same day. In it, the council leaders express concerns around the prospects of the Secretary of State’s plans to deliver sustainable growth. They said:
“We note in the latest announcement that the number of new homes put forward by Rt Hon Michael Gove MP has come down from 250,000 to 150,000, but this is still substantially more than the over 50,000 homes we have identified as needed in the emerging Greater Cambridge Local Plan (to 2040) – a number which will already be incredibly challenging to bring forward. We are ambitious for high quality sustainable, green growth but can’t stress enough how vital it is that Government supports us to tackle the issues that will otherwise act as roadblocks to sustainable growth.”
The Secretary of State previously visited Cambridge in Summer 2023, after his July speech, to discuss the Government’s plans for Cambridge 2040.
Conclusion
The Secretary of State’s Written Ministerial Statement and related speech on 19 December, which announced the London Plan’s independent review and the proposed Cambridge development corporation, among many other England-wide interventions and policy changes indicate the Government is prepared to explore different tools in different locations in the interest of housing delivery. Lichfields will continue to monitor closely how the Government’s local interventions play out, with a particular interest in the success of such wholly different approaches taken in these two very different cities.
[1] See our Think Tank Blog The Government’s long-term plan for housing – what’s new?
[2] Including the London Legacy Development Corporation and the Old Oak and Park Royal Development Corporation - HDT technical note says “for the local planning authorities whose boundaries overlap with a development corporation, for the periods that the local planning authority’s delivery is based on the London Plan or the Current Borough Plan, the net homes delivered in the development corporation are removed from the net additional dwellings statistics based on the data provided to the department by the Greater London Authority.”
[3]https://assets.publishing.service.gov.uk/media/65816753fc07f300128d4429/18122023_SoS_DLUHC_to_Mayor_of_London_-_housebuilding_in_London.pdf
[4] The recommendations of the Task Force, and government responses to these recommendations, can be found here https://assets.publishing.service.gov.uk/media/65816753fc07f300128d4429/18122023_SoS_DLUHC_to_Mayor_of_London_-_housebuilding_in_London.pdf
[5] https://www.gov.uk/government/speeches/long-term-plan-for-housing-secretary-of-states-speech
[6] https://www.cambridge.gov.uk/news/2023/12/19/joint-statement-from-local-leaders-and-the-combined-authority-mayor-on-cambridge-2040-announcement
