Ben Derbyshire writes 'Why the London Plan is destined for failure'
It is hard not to conclude that the strategy amounts to a self-fulfilling prophecy of defeat
The Draft London Plan has been through its Examination in Public and mayor Sadiq Khan has now submitted his "Intend to Publish" version to housing and communities secretary Robert Jenrick.
This takes place at an interesting time for planning in the UK, as the new government prepares to reveal much vaunted proposals for streamlining planning, in its belief that the complexity of the current system is to blame for the shortage of housing supply.
Meanwhile, the London Plan process has been going on so long that the version of the National Planning Policy Framework to which it relates was published in 2012, but since then there have been two revisions, in 2018 and 2019. At 500 pages and 110 separate policies, it could hardly be said to be in tune with neoliberal free market politics.
A lack of ambition
It is hard not to conclude that the outcome amounts to a self-fulfilling prophecy of failure. This is not due to over-complexity, but a lack of ambition imposed from above and conveyed to City Hall by the inspectorate in their role of ensuring conformity with higher-level policies.
For example, the mayor’s Strategic Housing Market Assessment (SHMA) established that 66,000 homes a year would be needed between 2016-41 – up from a figure of 49,000 in the 2013 assessment. Despite acknowledging that the city suffers from a backlog of 209,000 families in housing need, the inspectors accepted that delivery capacity is "an acceptable limiting factor". This created the perverse conclusion that despite the need for a substantial change of targets set in the plan, it still felt that housing policies reflect "good growth" objectives.
This assertion raises the question of whether the draft London Plan is actually a rather gloomy forecast of the inevitable consequences of inadequate policies rather than an ambitious plan to solve the capital’s crisis of supply and affordability?
There are further examples: the plan acknowledges there is an acute demand for affordable housing, amounting to 65% of overall need. Accordingly, the Mayor challenged the London Living Rent and shared ownership as intermediate tenures. But this challenge was dismissed by the inspectors purely on the basis that these definitions comply with national policy.
Most telling of all, the inspectors for Examination in Public cite the lack of available subsidy as an acceptable reason for undershooting targets.
Bearing in mind that the plan is endorsed by the inspectorate as being based on the principle of sustainable intensification, perhaps the most disappointing knockback for City Hall is the inspectors’ decimation of their small sites policy and targets.
Here, HTA Design has something of a stake, as originators of "Supurbia", a project that identified some 170 suburban stations with a high public transport accessibility level. We proposed a neighbourhood planning process to arrive at design codes around these so that, using pre-defined "plot passports", individual homeowners could benefit from significant increases in gross development value in a programme of urbanisation. We argued this would yield significant additional housing numbers if taken over 10ha – a total capacity of some 30,000 new homes across London.
The mayor’s plan took a similar approach, proposing incremental intensification in cases where a public transport accessibility level rating of 3 to 6 existed within 800m of a station or town centre. While not proposing comprehensive urbanisations in a zoned approach as proposed by "Supurbia", City Hall’s vision was to recognise the opportunity for changing the character of these areas.
Site specific briefs or design codes were envisaged; local planning authorities were expected to prepare supplementary planning documents and the Greater London Authority is preparing its own supplementary planning guidance, reputed to be due for publication in March.
Even with this less radical approach, the mayor’s targets amounted to an increase in small site delivery of more than 250% in outer London boroughs – exactly what the capital needs.
But the inspectors downgraded the proposed policy from "presumption in favour" to "proactive support" for small site development. In a statement of the obvious, the Examination in Public ruled that this approach would have required "behavioural change" and that as a consequence it deemed it an "unviable scenario". The inspectors slashed the 10-year targets for small sites to 119,250 from the mayor’s plan of 245,730.
Quite apart from the somewhat equivocal wording of this revised statement, there appear to be a number of policies in direct conflict with the objective to intensify suburbia. For example, if an offsite cash contribution is required, calculated as a proportion of the gross development value of a development, this can amount to as much as £1.3m, even in outer London Boroughs, effectively killing viability.
And the Examination in Public warned of the challenge of minimising the impact on green space and biodiversity, as if this could not be overcome with requirements for increased biodiversity in planning approvals.
Selling the big idea
So the London Plan’s approach to "sustainable intensification" of the capital seems underwhelming, and by its own admission fails to deliver on the need City Hall has itself identified. Why is the planning system so bereft of vision?
If we are serious about accommodating households in need, do we not have an obligation to sell the public a big idea? And if that is not to be one of transforming our suburbs, then it needs to be something else.
The long overdue review of the green belt, which could transform miles of agricultural monoculture into a biodiverse landscape for offsetting the city’s carbon footprint, has been kicked down the road.
The uncooperative state of relations between the GLA and the Home Counties has discounted the notion that the economic footprint of the capital, or at least its travel-to-work area, might sensibly form the basis of a contiguous plan area.
What are we left with? Despite promising policy development in areas such as housing quality, high-density housing, tall buildings, fire safety, and carbon reductions, it is hard not to conclude that this is not a plan to tackle the crisis of housing supply, affordability and homelessness.
Whereas the system is quite capable of identifying the nature of the problem, it seems hobbled by self-imposed constraints.
It is clear that the weight of checks and balances has overburdened what could have been a rallying cry for the changes we need and produced instead a behemoth of a plan that admits defeat even before it is launched.
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