For the next six weeks, the GLA is seeking views, evidence and experience to shape the next London Plan. The
consultation document considers ways that the Mayor could address the Plan’s most significant challenge – more than doubling housing delivery to achieve c.88,000 homes per year.
In this blog, we explore what the Mayor’s approach to delivering that scale of new homes in London should include. However, there is still a lot of detail to digest and consider – not least how the GLA will distribute those 88,000 homes across its boroughs and what their approach could be for other housing tenures. Those will be matters for us to explore in separate blogs.
Housing in London – context and challenges
The new London Plan will set borough-by-borough housing targets for the next ten years, to meet the Government’s new standard method result of c.880,000 homes over that period. The Mayor recognises that this is a huge increase, which is needed to accommodate future growth and to address the chronic shortage of homes, and that some potentially difficult choices will be required.
The Mayor notes that there are also substantial challenges affecting housing delivery in London, including increasing construction costs, higher interest rates and regulatory changes. These are well-rehearsed
[i] [ii] and the GLA acknowledge that the London Plan is being produced at a time when these challenges will remain.
The effect of these challenges, including the policy burdens of the current London Plan, have been reflected in significant levels of under delivery. Both consents and completions have continued to fall and will need a significant reversal to come close to the new housing target. In 2023/24, just 43,600 homes were approved
[iii] and only 33,000 homes were completed – stark figures in the context of the new housing target.
The clear recognition by the Mayor of this context is both positive and crucial to addressing the challenge. While it is an early stage, it is somewhat reassuring that the Mayor indicates that the overall burden of ‘planning policy requirements’ on development will not increase, and that opportunities to streamline planning requirements will be taken. However, it is hard to know what further policy requirements could be applied and it would be more reassuring if there was an indication that policy would be applied more flexibly to respond to the challenges that face the development industry in London.
…we must get plans in place now to build towards delivery and bring forward as many homes as possible as early as possible.
Sadiq Khan, Mayor of London
Where will the homes be delivered?
It is clear that the number of homes London needs to deliver will require the GLA and its boroughs to consider and optimise all available options. These include brownfield, greenfield, and other opportunities to diversify housing sources and this is recognised by the Mayor.
Brownfield
Consistent with the current London Plan and national policy, there remains a clear focus on prioritising the use of
brownfield land. This will require development at higher densities, with the Mayor recognising that the quality of places needs to support higher density living. The consultation document recognises the need to densify our town centres and high streets; retail parks and car parks; and small sites in suburban areas. Invariably this will mean taller buildings, a need for greater flexibility on policy demands
[iv], and a willingness from existing residents to accept such development.
Opportunity Areas are a fundamental part of the current London Plan, accounting for some 497,000 homes of the total 523,000 target. However, many of these have been predicated on strategic transport infrastructure which has either not materialised or has been delayed. While the Mayor recognises that OAs have permission for over 200,000 homes yet to be built, it is clear that there needs to be streamlining and unlocking of OAs. OAs can be a powerful tool to support growth, however their reliance on investment in infrastructure means that they are long-term opportunities for growth and are highly sensitive to external factors, such as delays in infrastructure investment.
Quite rightly, in our view, the consultation document makes it clear that achieving higher rates of housebuilding depends on funding for transport improvements. This is a strong theme throughout the consultation document and sends a clear message to the government that funding commitments are needed to achieve this level of growth. This is precisely the area within which the London Plan should seek to operate – as a strategic document that can enable cross-boundary infrastructure delivery to unlock growth.
The current London Plan gives
industrial land substantial
[v] protection from alternative uses, including new homes. This was a policy area that the previous Government challenged the Mayor to urgently review
[vi]. The consultation document continues to recognise the importance of providing sufficient industrial capacity but, now recognises that this could be a source of new homes, particularly through the opportunity to swap land and create alternative industrial capacity in London’s grey belt (see below). For housing delivery to be accelerated outside of local plan cycles, it will be crucial that such policies can be used through the development management process.
Greenfield
Given the failed delivery rates in London (as above), against the current London Plan’s capacity-based target of c.52,300 homes a year, the document rightly and necessarily acknowledges that ‘even a big increase from brownfield supply’ will not meet London’s need of c.88,000 homes a year, wholly within London’s existing urban area.
Now, for the first time, in line with national policy the document makes clear that the new London Plan will be supported by a London-wide strategic Green Belt review, which will also include the identification of ‘grey belt’ land – a clear and welcome step change from the current London Plan, which expects all housing supply to come from land not designated as Green Belt (and MOL).
The long-awaited need for this strategic Green Belt review is well documented and rehearsed, indeed the Inspectors’ report into the current London Plan considered a review of Green Belt to be the only realistic way to meaningfully close the gap between London’s need and supply. Key criteria for Green Belt release will include: sustainability and access to active travel options; delivery of or improved access to green space; and, nature and biodiversity gains. The document confirms that Green Belt sites will be expected to meet the NPPF ‘golden rules’ and, helpfully, to make the best use of land, they must be focused on ‘achieving densities’ that support public transport and a local economy.
Opportunities for large-scale development (10,000+ homes in each location) in London’s Green Belt are to be considered in areas with good public transport access (or where this could feasibly be delivered through potential strategic level new public transport). This will inevitably involve high density development to support the necessary public transport infrastructure and optimise the use of land.
Such Green Belt release will be crucial for London to come close to meeting its housing needs in a sustainable way. Notwithstanding the Government’s remit on New Towns, the Mayor makes clear the intention that these homes would need to count towards meeting housing needs. While reference is made to engaging with the Government’s New Towns Taskforce, this differs with the understood position that New Towns should be treated as being additional to meeting housing needs. Given the scale of contribution that these sites could make to meeting London’s housing needs, this position will need to be resolved. It could also indicate that the GLA’s preference is for large scale urban extensions, rather than official ‘New Towns’ as selected by the Taskforce.
The current London Plan links Metropolitan Open Land (MOL) to national green belt policy. However, with reference to the December 2024 NPPF updates, ‘which could be interpreted as requiring London’s MOL to be released for housing and other development’ - the GLA's intention is to redraft the London Plan to distinguish between MOL and Green Belt. This shift would ‘protect’ MOL from Green Belt reviews. Similarly, the document infers that the release of large-scale urban extensions (as above) could enable GLA to ‘enhance, expand or establish regionally protected parks (MOL)’ and other open accessible spaces for Londoners. Notwithstanding, the document does refer to ‘some very specific circumstances’ where certain MOL - such as golf courses - could be considered for release to deliver housing, via a landscape-led approach.
While much of the MOL is valued and important, meeting the intended MOL functions in full, there will be parcels of designated land that do not. It follows that not undertaking a London-wide Green Belt and MOL review is a missed opportunity in the context of meeting housing needs.
What else can we look for?
We know, from working on projects across London, that certain policies within the London Plan cause frequent challenges for the delivery and/or viability of residential projects, in particular:
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Density - in the document the Mayor notes that while there has been an increase in the scale and density of development in London in recent years, it is still less dense than many other comparable cities. As such, he is contemplating that the next London Plan could take a different approach to London’s development potential. For example, it could set out the building heights that should be acceptable in principle in all locations across London that share certain characteristics.
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Tall buildings - the Mayor also notes that tall buildings in suitable locations will play an important role in delivering the new homes but that some boroughs have not identified locations that are suitable for tall buildings (as is required by current Policy D9). He also notes that there have been some challenges implementing the current policy as all tall buildings should be assessed on their individual merits irrespective of their location. As such, consideration is being given to whether the new Plan could take a more active role in identifying and defining tall building clusters. This could allow more strategic consideration of tall buildings, but would also require a decision about what height is meant by a tall building cluster and whether this could be a higher threshold of 20 storeys/60 metres. The policy would also need to be clearer about how planning applications for tall buildings should be assessed outside these defined clusters. The Mayor recognises that “this would provide greater confidence about the approach” which would be welcomed.
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Small sites – the current London Plan has ambitious aims for small site development, but the GLA recognises that this has not been realised. To assist, the consultation indicates the potential to set a minimum height benchmark for small sites alongside the possibility of a ‘Design Code’. Whilst a benchmark could be useful, this would need to be carefully developed, considering viability issues with medium-rise buildings (given fire safety requirements) and how boroughs implement this in the context of heritage assets that are commonplace within London. We question how a ‘Design Code’ would work in practice and whether it is appropriate for an SDS to contain this level of detail.
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Dual aspect – this requirement can contribute to the creation of less efficient layouts and limit the layout of buildings, sometimes with the effect of limiting the number of homes delivered. The consultation document suggests that bespoke policies such as this could be removed, instead relying on national building regulations to deal with ventilation and overheating. Given the constraint that dual aspect requirements can place on layouts, this could be a significant move in both optimising density and enabling innovation in design approaches.
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Cycle parking – the London Plan sets significant requirements for residential cycle parking, which adds significant costs to schemes and are not always well used, becoming an inefficient use of space. The consultation document states that the GLA will review these standards – a more pragmatic approach would be another significant move to help deliver more efficient housing schemes.
Hope for a slimmed down London Plan?
Positively, there is indication from the GLA of an intention to make the London Plan more streamlined and focused, including removing areas of duplication with national requirements. We have previously
[vii] highlighted the importance of slimming down the London Plan and returning to its strategic role for the capital. This alone would make the process simpler for applicants and planning officers and help accelerate the delivery of new homes.
Concluding thoughts
The direction that is being set within this consultation document is a great intention. Meeting the new standard method for London will be a significant and unprecedented challenge, in the face of significant headwinds. Coming close to achieving this will require radical policy changes for London and, it appears, that the Mayor is willing to consider all available options.
The new London Plan will need to deliver these policy changes holistically – increasing density; supporting more tall buildings; refining OAs; reviewing and releasing Green Belt for housing; and giving greater flexibility for new homes on industrial land.
While these intentions are positive, they now need to be translated into proportionate and flexible policy requirements, with a real commitment from the GLA and boroughs to deliver these objectives through planning decisions and new local plans. Only time will tell how these materialise, but key now is for all involved in delivering new homes in London to submit our evidence and experience to help shape an effective and proportionate new London Plan.
Footnotes
[i] Testing times for Engalnds big cities - an extended reach for the presumption and other nppf changes, Lichfields
[ii] Housing Delivery and a New London Plan – Déjà vu?, Lichfields
[iii] Residential approvals dashboard, London Datastore
[iv] For example, with a defined site area, there will need to be flexibility in open space requirements which would otherwise constrain the total number of homes on a site.
[v] In some instances it is effectively a complete protection, requiring the release of industrial land to be plan-led only.
[vi] https://assets.publishing.service.gov.uk/media/65f8030aaf6a0daea190d4ff/SoS_DLUHC_to_the_Mayor_of_London_-_housing_delivery.pdf - although the need for this review was subsequently removed by the Labour Government.
[vii] Housing Delivery and a New London Plan – Déjà vu?, Lichfields
