1. The capital faces an annual shortfall of 6,600 homes a year under the alterations. FALP set the capital's housing target at 42,400 homes a year, against an assessed need of between 49,000 and 62,000 over the next ten to 20 years. At last September's examination, the mayor voiced confidence that the 6,600 difference could be made up by maximising opportunities in town centres, surplus strategic industrial locations and opportunity areas. In the absence of any mechanism for apportioning these extra homes to individual boroughs, the inspector was unable to see how the mayor could guarantee delivery. "The evidence before me strongly suggests that the existing strategy will not deliver sufficient homes to meet objectively assessed need," he concluded. "This is the first recognition in 15 or 20 years that there are limits to London's housing capacity," said James Stevens, strategic planner at the Home Builders Federation.
2. The mayor needs to explore options beyond the plan's current "philosophy" with other authorities in the South East. The inspector said, in the absence of a wider regional strategy, this "may include engaging local planning authorities beyond the Greater London Authority (GLA)'s boundaries in discussions on the evolution of our city". Independent planning consultant Catriona Riddell said: "Most London councils are doing their bit in meeting housing need, but we also have to look at what the rest of the South East can deliver. A lot of councils around London are already struggling to meet their own needs."
3. London boroughs do not need to assess their housing needs separately. While agreeing that individual boroughs would need to do some "fine tuning" on size, type and tenure to meet local circumstances, the inspector saw no need for them to duplicate work done by the GLA on overall needs.
4. The mayor failed to meet the duty to cooperate. The inspector confirmed that the duty does apply to London's spatial development strategy, because it establishes housing targets and other requirements that guide the preparation of the development plan document. He said the mayor "did not engage constructively with adjoining waste planning authorities" in formulating the alterations. However, he found that this failure was outweighed by the plan's benefits in terms of reducing pressure on waste facilities outside the capital and the urgency of getting higher housing targets enshrined.
5. The alterations are sound, subject to an early review. Despite his reservations, the inspector recommended that FALP should be adopted. This would avoid perpetuating the current underdelivery arising from the 2012 plan's "woefully short" target of 32,210 dwellings per annum, he reported. However, he insisted that a review should commence immediately after adoption this year, rather than waiting until 2016 as Johnson had envisaged.