13 key recommendations in the London Plan examination report

The inspectors' report on the London Plan was published this week. Here are 13 key recommendations that you need to know about.

The London Plan examination in public at City Hall earlier this year. Pic: GLA
The London Plan examination in public at City Hall earlier this year. Pic: GLA

The draft new London Plan is the capital’s overarching strategic planning document and sets out development goals for the capital up to 2041. It was examined in public earlier this year by inspectors Roisin Barrett, William Fieldhouse and David Smith. Their post-examination report was published earlier this year. Here are 13 key recommendations.

1. The plan has been found sound subject to a series of modifications recommended by the panel of examining inspectors. The report notes that the legal duty relating to plan soundness "does not apply to spatial development strategies such as the London Plan". However, the inspectors say, "in light of the need to ensure consistency with national policy we have applied the soundness tests set out in the [National Planning Policy Framework (NPPF)], namely that the plan should be positively prepared, justified, effective, and consistent with national policy". Mayor Sadiq Khan must now consider the inspectors’ recommendations before submitting his response and a revised version of the plan to the secretary of state who can approve it or intervene. 

2. The report calls for Khan to commit to a review of the city's green belt to meet future development needs. A green belt review is required "to at least establish any potential for sustainable development", the inspectors said, partly due to the fact that the capital cannot meet much of its housing need on small sites (see below). They asked for a commitment that a review will be conducted to inform the next edition of the London Plan and said it should "involve joint working with authorities around the administrative boundary as well as the boroughs". More details here.

3. The strategy should water down its tough policies preventing any green belt development. The plan states that development proposed in the green belt should be refused and advises London boroughs that plans to de-designate green belt sites will not be supported while any extensions of such designated land will be backed. But the inspectors found that the plan’s blanket opposition to de-designation of green belt sites "is not consistent with national policy" which allows green belt development in "very special circumstances" and the alteration of green belt boundaries in "exceptional circumstances". "It is implausible to insist that the green belt is entirely sacrosanct without having considered what it comprises and the impact that it has on wider strategic objectives," they said. More details here.

4. The plan's controversial small sites housing target should be cut by more than half because it is "neither justified nor deliverable". The use of small sites, defined as those accommodating between one and 25 homes, forms a key part of the mayor’s proposed strategy for meeting housing need.  But the inspectors advised that the target for the development of small sites should be more than halved, from 245,730 homes to 119,250 over ten years after they found that the targets were not "realistically achievable" and "not justified". More details here.

5. The inspectors recommended that the plan’s overall housing target be reduced by almost 20 per cent. As a result of the small sites target being cut, the overall ten-year housing target should be cut by about a fifth from 649,350 to 522,850, which equates to 52,285 homes per year. The inspectors noted that their proposed changes on the small sites target means that housing delivery in the capital is likely to fall short of the 66,000-home identified annual need. "It is difficult to see how the number of deliverable housing units could be increased without consideration being given to a review of the green belt or further exploration of potential with local authorities within the wider South East," they said. More details here.

6. The draft London Plan may need to allocate "many hundreds of hectares" of additional land for industrial, storage and distribution uses, including potentially on green belt land. The report concludes that storage and distribution uses (B8) "are expected to require more land amounting to between 280 and 400 hectares". It also cites data showing that more existing industrial sites are being earmarked for redevelopment into non-industrial uses than previously supposed, which "indicates that there is likely to be a need ... for more industrial land to meet future demand over the plan period to 2041 than assumed in the plan". "Whilst we cannot precisely quantify the requirement, it could be many hundreds of hectares," the inspectors add. More details here.

7. A policy that would make it harder for developers to test viability on specific sites should only apply where boroughs have up to date local plans. Policy DF1 of the draft new London Plan outlines requirements relating to planning obligations and is based on a city-wide strategic viability assessment, the London Plan Viability Study (LPVS). The policy says that "viability testing should normally only be undertaken on a site-specific basis where there are clear circumstances creating barriers to delivery". In addition, if an applicant "wishes to make the case that viability should be considered on a site-specific basis, they should provide clear evidence of the specific issues that would prevent delivery", in line with London Plan policies, before submitting the application. But the inspectors said the mayor should modify the policy "to make it clear that the requirements relating to site-specific viability assessments only apply where relevant policies in local plans are up to date", including local viability assessments. More details here.

8. The inspectors have doubts about the effectiveness of efforts by the mayor to engage with Home Counties authorities on London's development needs but have given it a reluctant thumbs-up. The London Plan has two specific policies (SD2 and SD3) setting out arrangements on engaging with councils in the wider South East. But the inspectors said they are "not convinced that they represent a political and administrative structure that would be capable of resolving more fundamental and challenging issues about how high levels of growth and development could be planned and accommodated in a coordinated way across London and the rest of the wider South East". But they said it was "beyond our remit to make recommendations about whether or how a more effective system of strategic planning for the wider South East should be introduced". They conclude that, subject to their recommendations, the approach is "justified and consistent with national policy".

9. The duty to cooperate does not apply to this London Plan but it will to the next one. The examiners concluded that the duty to cooperate, which requires planning authorities to engage continuously and "constructively" with neighbouring authoritieus on strategic  issues such as housing, does not apply to the London Plan because it is as an old regional spatial strategy rather than a local developmen plan. However, they note that the 2019 NPPF "does explicitly apply the duty to cooperate to a spatial development strategy and therefore the relationship with the Wider South East will become a much more prominent issue in future London Plan reviews".

10. The inspectors would like to see a more streamlined London Plan document next time it is updated. They have encouraged the mayor "to consider setting out a more concise spatial development strategy, focussed on strategic outcomes rather than detailed means of implementation, when the plan is next replaced". According to the report, the plan "comprises around 500 pages and contains over 110 policies, some of which are more than two pages in length". It goes on to say that the document's "length and complexity raise a number of significant issues about the fundamental role and purpose of a spatial development strategy in a three tiered plan-led system". 

11. A policy requiring boroughs to refuse fracking applications should be deleted. The submitted version of the plan "sets out a blanket restriction on the exploration, appraisal or production of shale gas via hydraulic fracturing within London", according to the report. As a result, the policy is "fundamentally inconsistent with the direction of national policy, which sets out the need to explore and develop shale gas and oil resources in a safe, sustainable and timely way". The policy SI11 is also, it adds, "unnecessary" with "insufficient justification for it". 

12. The mayor should commit to leading a London-wide accommodation needs assessment for gypsies and travellers as  soon as possible. Policy H16 of the plan outlines provision for meeting gypsy and traveller accommodation needs, including pitch provision. The inspectors found that "there is clearly a significant immediate need for further provision across London". They recommend that the mayor should commit to instigating and leading a needs assessment "as soon as possible as a priority in order to inform an updated London Plan". 

13. A policy saying the mayor will oppose the expansion of Heathrow Airport "unless certain tests are met" should be deleted. The inspectors said that policy T8 relating to aviation and development at Heathrow and other airports "is not consistent with national policy or otherwise justified" and should be deleted. Part D of the policy which sets out the mayor's opposition to Heathrow's expansion "is fundamentally inconsistent with national policy which supports a specific expansion scheme". 


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