Briefing: Charting progress in the London Plan examination

The examination into the draft London Plan ends in May. Questions remain on the plan's approach to housing, says Jonathan Bainbridge.

London: examination of city's key planning document expected to conclude at the end of May
London: examination of city's key planning document expected to conclude at the end of May

Q What are the key topics being discussed at examination?

A The 12-week examination enables comprehensive discussion of the plan’s key themes. Housing delivery is given the most consideration. Topics include the plan’s relationship with and approach to the wider South East and the delivery of small sites.

Design, density and tall buildings feature, as well as culture, heritage and the night-time economy. Also included is a discussion on the policies relating to green belt and metropolitan open land, and another on waste and minerals issues.

The examination is expected to conclude at the end of May.

Q What does the draft plan say on housing provision in the capital?

A The target for the next ten years is increased by 53 per cent to 66,000 homes per year, delivered by increasing density in suburban London and capitalising on investment in transport.

But London mayor Sadiq Khan acknowledges that there is only sufficient land for 64,935 homes. Of this, 38 per cent is on small sites that are unallocated. The Ministry of Housing, Communities and Local Government has questioned how the shortfall will be met. The mayor points to authorities outside London, but there is little evidence of formal discussion.

Questions also arise as to the short-term view of the housing target (what happens after ten years?) and the relationship with the government’s standard method of assessing housing need and housing delivery test.

Q Why has the plan sparked a public spat between the mayor and the secretary of state?

A Housing secretary James Brokenshire’s letter of July 2018 is an unprecedented intervention. He said he is not convinced that the plan "reflects the full extent of housing need in London to tackle affordability problems". Critics have expressed concern that the plan fails to clearly explain how the 66,000 homes will be provided. By the mayor’s own admission, there is insufficient land and a heavy reliance on small sites and outer London boroughs.

Brokenshire warned that the government can intervene in the plan’s development, but a government call for an early review seems more probable.

Q What is the role of the examining panel?

A The examination is conducted by a three-person panel – planning inspectors Roisin Barrett, William Fieldhouse and David Smith. The panel takes a structured approach with a series of technical discussions, supported by written submissions. After the hearings, the panel will prepare a formal written report that may recommended modifications. The examining report is due in the summer. The new London Plan should be in place by the end of 2019.

Q Is the final plan likely to change substantially after examination?

A Once the recommendations are received, the mayor will need to consider his next steps. He is not required to comply with suggested changes but is required to send the secretary of state a statement of his reasons should he choose not to. The secretary of state does have the power to make directions with which the mayor must comply.

Q How far will boroughs and consultants working on projects in the capital be expected to apply London Plan policies?

A As a statutory development plan, decisions must in be taken in accordance with the plan’s policies, unless material considerations justify otherwise. But the plan’s policies are intended to set a "strategic" direction and to provide a framework for locally-set policies. While much will depend on the outcome of the examination, boroughs are likely to apply the policies flexibly according to local politics and issues. Where a scheme is referable to the mayor, his policies are likely to be applied.

Ordinarily, it would be expected that there should be no conflict between national policy and the plan itself. However, the draft policies are being considered against the first version of the National Planning Policy Framework (NPPF), so on adoption there is a risk that a number of its policies, specifically those with regard to housing, will not reflect the latest NPPF adopted this year.

Jonathan Bainbridge is an associate at consultancy Bidwells

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