London Plan Consultation: Towards a New London Plan

Housing features prominently with the government's target of 880,000 homes over 10 years and new NPPF green belt policy exhorting "new approaches to building homes beyond current mechanisms".  So, both a challenge and an opportunity.  

The brownfield-first approach of the current plan is restated but new NPPF green belt policies loom large. The consultation paper notes that green belt boundaries should be reviewed and there will be a need to alter them if housing need cannot be met in other ways. To this end, the Mayor has of course already kicked off a London-wide green belt review.  The review will include an assessment of grey belt land and its capacity to provide not only for housing but also other strategic land uses such as data centres and energy infrastructure.

Opportunity Areas will be streamlined and updated to reflect that some are now "mature" and because some transport infrastructure, such as Crossrail 2, will be delayed.  The Consultation also asks how the work of the New Towns Taskforce might apply to OAs and this will also influence, and be influenced by, the green belt review. A big question is whether the new Plan will propose a new town or towns in what is currently London's green belt. The Central Activities Zone may offer limited opportunities to increase housing supply but the Consultation notes that the London View Management Framework is currently being reviewed to bring it "up to date".  Almost as an afterthought it adds that Mayor "could also consider how the policy works in practice to ensure its impact is proportionate". This sounds like a call for evidence from stakeholders to make their views known on how the LVMF is working.

The Consultation re-states the need for London to build more affordable homes and notes the challenges that have affected housebuilding in recent years with which we're all familiar:  high interest rates, build costs and regulatory requirements.  In the social housing context, add a lack of grant funding to the list.  The Consultation commits to a review of the affordable housing fast-track thresholds and the review will consider whether some types of development are "very challenging to deliver".  It also hints that the 10-unit threshold (at which affordable housing obligations kick in) will be increased.  

On Built-to-Rent the consultation states that the current 50-unit minimum for development to qualify as BTR could be relaxed to "support more diverse types of development".   For student accommodation and co-living, the Consultation notes the importance of getting the balance right between these and other types of housing and asks whether the balance should be set at London-wide level or left to the Boroughs to set acceptable levels in their Local Plans.  It goes on to ask for views on what the right balance should be and on whether the Plan should encourage the occupants of all student rooms to be subject to nomination arrangements or whether those arrangements should apply only to affordable rooms. It seems the Mayor is open to a more flexible approach.

As is to be expected, climate change and adaptation is a clear theme throughout the consultation.  As to whether the new Plan should go beyond national standards to drive towards new zero and tackle climate change, the consultation is currently ambivalent, noting that some stakeholders would wish London to go further but recognising the effects of that on development costs and housing delivery.  Existing overheating policies in the Plan look set to be revised but it appears that the Plan will continue to include specific provision in these areas over and above the national building guidance.  Interestingly, clearer policies for the Plan on the role of heritage assets in meeting net zero and improving resilience, such as new policies on sensitive adaptation and retrofit, are to be expected.

The Consultation emphasises the importance of ensuring the resilience of the CAZ and its ability to safeguard employment, cultural and night-time uses.  This includes meeting the demand for high quality office space and prioritising development in key areas such as the Oxford Street retail and culture hub and areas around key stations such as Euston. Liverpool Street and Waterloo could equally have been mentioned.  

The consultation recognises that clusters of economic activity don't always match existing designations and, while trumpeting clusters such as the Knowledge Quarter, Tech City and the Cancer Hub, suggests that the new Plan could encourage a more flexible approach that recognises the range of locations that support London's economy.  

The new Plan will need to acknowledge the extensive change that town centres are undergoing and it will need to support a wider range of businesses and jobs.  There will be greater policy support for life sciences, laboratories, data centres and last mile logistics although there is a slight sense that the Plan will be catching up with what's already happening on the ground.

London lost 18 per cent of its industrial land between 2001 and 2020 and the Consultation suggests that the new Plan could tell Boroughs which industrial sites should be protected and set targets for industrial capacity; an issue on which the British Property Federation has long campaigned and which now appears to be gaining traction.

References to the role of transport in enabling development, and the role of development in financing transport provide plenty of food for thought and an invitation to the industry to come up with ambitious and creative solutions.  The Consultation notes that "faster, more direct services and more bus priority would help support denser sustainable development". Big new schemes such as the Bakerloo, DLR and West London Orbital extensions can "significantly increase the capacity for new homes along the areas they serve directly".  But there is an emphasis on improvements to existing infrastructure – high metro-like frequencies on National Rail lines serving suburban areas.  London's Overground services are given as the example of successful implementation of this, and the aim is that such improvements, alongside more bus priority, will help support denser, sustainable development. More new homes in such areas will in turn improve the financial viability of better public transport services.  In short, transport will continue to be at the heart of the Plan.

Interestingly, it is proposed to use a new connectivity metric based on journey times by sustainable modes to useful destinations to inform the approach to development densities, building heights and scale.