New London Plan: reaction

London mayor Sadiq Khan's new draft version of the London Plan was published yesterday. Planning has been collating reaction from across the planning sector.

Development: new draft London Plan published yesterday
Development: new draft London Plan published yesterday

Under proposed policies in the document, London boroughs would be set housing targets for small sites and maximum density restrictions would be scrapped.

Melanie Leech, chief executive of property lobby group the British Property Federation, said: "The draft London Plan sets out that, if Crossrail 2 does not get the go-ahead, monies collected from the mayoral Community Infrastructure Levy (CIL) 2 will be used for other strategic infrastructure projects. We need an urgent decision on Crossrail 2, but in the meantime we urge the mayor and his team to reconsider the payment schedule for CIL 2. The initial mayoral CIL, which came into effect back in April 2012, was a success because developers knew that they were contributing towards a single, large-scale infrastructure project in the form of Crossrail 1. Not only would it benefit their developments, but it would also prevent London’s transport network from buckling under the weight of considerable population growth. It is vital that our industry is given clarity around how the monies from mayoral CIL 2 will be used."

"The mayor of London continues to support the build-to-rent sector, recognising that a more diversified housebuilding industry will be vital to addressing the demand-supply imbalance. We are pleased to see the mayor’s support for discounted market rent as build-to-rent’s affordable housing provision. Build-to-rent is delivered using a different financial model to houses for sale, where build-to-rent relies on rental income over the long term from a professionally managed block, and so unified ownership is fundamental to a development’s success. Discounted market rent recognises this structure and also, for example, prevents the creation of ‘poor’ doors, where tenants of the affordable housing provision use a different entrance to the development, and the high-quality services and facilities remain accessible to all. It’s also a huge vote of confidence for the sector that the discounted market rent provision, where it meets the requirements of the CIL regulations, will qualify for mandatory CIL relief."

"Introducing a policy of no net loss of industrial floorspace in strategic industrial land is welcome and developers are keen to work on the innovative approaches outlined, including multi-storey or subterranean warehouses, as well as exploring genuine mixed-use residential and industrial developments. However, none of these will work in isolation and with the competition for land in London so intense, with an acute shortage of housing in particular, we need a balanced approach. Sustainable communities require both high-quality homes and the right infrastructure to provide services, facilities and jobs."

Lorraine Hughes, a senior director at consultancy CBRE, said: "The 530-page document is certainly strategic in presenting a wholesale vision for London as a more equitable, green and liveable city, but is at the same time fairly prescriptive in its policies over growth. The polycentric approach to meeting London’s housing and employment needs is to be supported, with emphasis on greater density in areas well served by public transport. The challenge will come over the increased requirements on all types of developments to provide more, whether it be affordable housing, affordable workspace or green infrastructure, so that schemes aren’t discouraged from coming forward."

Matt Richards, a partner at consultancy Bidwells in London, said: "It's an ambitious plan that seeks to deliver 66,000 new homes a year without allowing London boroughs to dedesignate areas of green belt or provide for development on vacant and derelict sites within the green belt, arguably going beyond the National Planning Policy Framework’s green belt policies. The ability for London boroughs to deliver this new housing will rely on a proactive and positive approach to new development, at higher densities and scale than the prevailing context in most situations. This will be a particular challenge to the outer boroughs, who see the higher increases in their housing targets and are also the ones with green belt restrictions."

Fergus Charlton, legal director at law firm TLT, said: "The draft plan sets out the cascade to be followed where it has been demonstrated that planning obligations cannot viably be supported by a specific development. Affordable housing is supported above all other contributions by being placed at the top of the cascade. This is followed by support for the delivery of transport improvements. Under this policy, in areas with no Community Infrastructure Levy regime, provision for education and community open space will be the losers. However, the inherent difficulties of clearly substantiating viability prior to the submission of the application and the raising of the viability hurdle mean that fewer applicants will be troubled with trying to identify what should be dropped from the planning officer's shopping list of planning obligations."

"The pick of the transport policies are a bold strategic target of 80 per cent of all trips in London to be made by foot, cycle or public transport by 2041 and the integration of land use and transport. Achieving this target requires a rebalancing of the transport system away from cars and making the alternatives, particularly the active travel modes, more favourable. The two-wheels good, four-wheels bad philosophy is evident in the dedicated pro-cycling policy and the policy setting the starting point for development at car-free areas that are well connected by public transport, with developments elsewhere designed to be 'car-lite'. Designing developments to meet these transport policy requirements may have unintended positive outcomes. They will surely provide opportunities to increase housing density.

"With regards to air quality, the ClientEarth judgment earlier this year, and its consequences for national air quality strategy, is telling. The air quality policy has moved from an aspirational one, compliance against which was relatively easy, to a mandatory one, with no deterioration in existing poor air quality and a requirement to align with the capital's efforts to improve air quality. Large-scale developments are to have an 'air quality positive' approach. The draft plan is less prescriptive on how new developments will meet this more stringent air quality policy. Compliance will no doubt turn on good design, placing architects and urban designers at the forefront of delivering on this policy. This policy may push the car-free status requirement beyond areas served by good public transport. Hopefully, the combined effects on viability of scheme responses to these essential air quality requirements will not have too onerous an impact on viability."

London Assembly Green Party member Sian Berry said that the mayor "has failed to fix the definition of an affordable home" in the new London Plan. Berry said: "The assessment of London’s housing needs, summarised in the plan, says that nearly half of all new housing must be at low-cost rent levels. However, the mayor is only asking for these kinds of homes to be 30 per cent of the affordable housing provided. With overall affordable home targets set at 35 per cent of homes, this means developers can make just one in ten homes available at social rent. This is nowhere near what London needs. I’ve already challenged the mayor about why he has included a definition of ‘affordable housing’ at up to 80 per cent of market rates in his draft housing strategy and yet we see this again here."

Faraz Baber, director of planning and design consultancy Terence O’Rourke, said the document contains "a suite of good growth policies", but added that the plans "leave a lot of questions unanswered and those answers are going to be key to whether or not the mayor's theory can work in practice". Baber added: "Khan's ambition is high, but the challenge faced to achieve them is huge. His desire to push for 50 per cent affordable is not new - he has made no secret of this since coming to power.

"The biggest issue he has is that to get anywhere near that target, he is going to need to do something about the cumulative costs and planning requirements of development, because those are hindering developers from being able to strike a better balance between affordability of homes and the commercial viability of projects. This is especially true of the smaller developers that he clearly wants to support, as they are the ones that struggle the most as they have less to play with. The new housing target calculations proposed by government for most of the local councils are going to be very challenging to achieved. To work towards delivering the number of new homes required, greater flexibility will be needed on where homes can be built beyond high-density developments around town centres and transport nodes."

Paul Landsberg, an associate at Nexus Planning, said: "Given previous delivery rates, it will be interesting to observe how the mayor’s ambitiously increased housing target in the new London Plan from 423,887 homes (42,389 homes per year) to 649,350 homes (64,935 homes per year) would be achieved. This may in part be the reason for the emphasis on housing delivery on small sites of less than 0.25 hectares, which are targeted to provide just over a third of the annual housing target. Developers are likely to welcome the opportunities to optimise housing density beyond the current London Plan’s constraints, particularly in the most accessible and well connected places. However, this may be counterbalanced by the new London Plan’s stated intention of embedding affordable housing requirements into land values. The mayor’s previous affordable housing guidance is now enshrined in policy within the new London Plan, which may see developers making more use of the fast track route to avoid the transparent scrutiny of viability assessments, as well as avoiding subsequent early and late stage viability reviews."

Martin Meech, group property director at builders' merchant Travis Perkins, said: "I am pleased the draft London Plan recognises the extreme pressure on essential services in central London and encourages councils to go further in protecting them through planning rules. City Hall has listened to our concerns and is now actively telling councils to consider mixed-use developments on industrial use class land. This is a step in the right direction. We have been in close discussions with the mayor’s team and councils across London calling for greater protection as builders’ merchants are driven out of the capital. More clarity is needed about how measures to protect essential services will work in practice and I would like to see the plan go further with specific concrete planning protections. We will be making this case in our response to the draft plan."

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