The draft plan proposes removing current London Plan residential density restrictions, allowing councils and developers to agree their own densities on a site-by-site basis. A new policy on "optimising housing density" says that development proposals "must make the most efficient use of land and be developed at the optimum density". This would be worked out using a "design-led approach to determine the capacity of the site", taking into account factors including its local context and public transport accessibility. Proposed housing schemes that do not "demonstrably optimise the housing density of the site in accordance with this policy" should be refused, the plan says.
The plan introduces targets for each borough for the delivery of housing on smaller sites, defined as those of 25 homes or fewer. To meet these targets, the plan says boroughs "should apply a presumption in favour" of certain types of small housing development, including "infill development on vacant or underused sites". Key aims, according to the plan, are to assist small and medium-sized builders and to increase housing in "accessible parts of outer London".
While any relaxation of green belt protection was never on the cards, the draft plan goes further than its predecessor in stating that dedesignation of green belt will not be supported. Matt Richards, a partner at Bidwells in London, said the draft policy "arguably goes beyond the National Planning Policy Framework’s green belt policies". Richards says this stance "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".
Boroughs with opportunity areas are given some flexibility over the plan’s affordable housing threshold. As expected, the draft plan enshrines the mayor’s strategic commitment for 50 per cent of all new homes built to be "genuinely affordable", as well as the 35 per cent threshold over which applicants are promised a smoother ride through the planning process. However, the plan allows boroughs to consider a localised affordable housing threshold in opportunity areas that could be less than 35 per cent.
The plan includes a specific policy promoting "purpose-built student accommodation". However, such developments must be "secured for occupation by members of one or more specified higher education institutions". Melanie Leech, chief executive of lobby group the British Property Federation, has expressed concerns that such a requirement would "limit access to purpose-built accommodation for students of smaller institutions, who would probably benefit from it most". Commentators also expressed surprise that student accommodation would be subject to the 35 per cent affordable housing threshold.
Build to rent, a form of purpose-built private rented sector housing, is supported in a dedicated policy. Unlike other forms of housing, the plan allows the affordable housing offer to be "solely discounted market rent". But build-to-rent schemes would also be subject to the 35 per cent threshold fast-track route, the plan says, while "at least 30 per cent" would have to be at London Living Rent level, a form of discounted market rent.
The draft plan goes further than its predecessor in its level of protection for office space. The plan says that "existing viable office floorspace capacity in outer and inner London locations" should be "retained" and supported by article 4 directions to remove office-to-residential permitted development rights "where appropriate". Russell Smith an associate in consultancy Savills' London planning team says that the policy "could be interpreted as blanket protection of office floor space across London".
Provision of affordable workspace is supported in the revised draft plan. Through two new policies, the plan supports "low-cost business space" and "affordable workspaces". The latter policy says that, in defined circumstances, planning obligations may be used to secure affordable workspace at rents held below the market rate for specific social, cultural or economic development purposes, including use by charities or artists. For mixed-use schemes, it adds, the affordable workspace element should be operational before any residential elements are occupied.
The draft plan goes further than its predecessor in its level of protection for industrial land, commentators say. It includes a general principle of "no net loss of industrial floorspace" in designated strategic industrial locations and locally significant industrial sites. The plan adds that any release of industrial land for housing or other uses would have to be through a defined process, including co-locating industrial and residential uses on sites. Planning Officers Society chairman Mike Kiely said this represents a "tightening up" of the current position, which supports "managed release of industrial land".
So-called co-living schemes are supported. For the first time, the plan recognises "large-scale purpose-built shared living" schemes, of sui generis use, saying they can meet a housing need providing they are of "good quality and design". The document says that three bedrooms in a shared living or student accommodation block equates to a single house in borough housing target monitoring.
Any schemes that involve the loss of social infrastructure should be refused. Social infrastructure includes health provision, education, community and recreation facilities as well as green infrastructure. Development proposals that would result in a loss of social infrastructure in "an area of defined need should be refused", the plan says, unless it can be re-provided or the loss is "part of a wider public service transformation plan".
The plan commits the mayor to working with councils in the wider South East. Following concerns raised by an inspector in the examination of the current version of the London Plan, the plan includes a specific policy on joint working with the so-called "Wider South East" on housing and infrastructure delivery.
The draft London Plan is much more detailed and prescriptive than the current version, commentators say. Sara Parkinson, programme director for planning and development at business lobby group London First, says the group would have "preferred a shorter plan". There are areas where the extra detail is "welcome" adds Smith, "but at a time when we need more delivery, are more requirements and policy justifications going to speed up delivery?" he asks.