So Many Questions, So Little Time – Update on the New London Plan

22nd January 2020

The London Plan is a statutory part of any London authority’s development plan. When Sadiq Khan came to Office as Mayor of London, he began the review of the current London Plan (2011 consolidated with alterations 2016) and the first draft of that was published nearly two years ago in December 2017.

Bell Cornwell’s last update on the London Plan was in February 2019. Since then the Plan has been through examination and scrutinised by a panel of three independent Inspectors. The Inspectors’ report was published in October 2019, which found that the Plan ‘provides an appropriate basis for the strategic planning of Greater London’. It made recommendations for main modifications to the Plan and the Mayor responded in December 2019 with a version of the plan that he intends to publish.

We highlight below the main points raised by the Inspectors for developers and landowners to be aware of and how the Mayor has responded:

  • Housing Numbers – Overall, it was found that the housing target in the draft Plan of 65,000 per year did not meet the figure generated by the Government’s standard methodology (72,000 per year as at 2017). Nevertheless, the Inspectors are recommending that the housing target actually be further reduced to 52,285 per year (total 522,850 over the Plan period). This is due to their perception that the Greater London Authority (GLA) is over-relying on small sites (those delivering up to 25 units) and that the higher number is not deliverable. The lower target has been recommended to ensure it is more realistic and it is hoped that this will encourage delivery. The Mayor has agreed to go with the lower figure and said that this would still be ambitious and represent a ‘step change’ in housing targets on the current London Plan.
  • Affordable Housing – The approach to affordable housing is changing in the Plan, with an increased emphasis on providing for London living rent and reinforcing the approach for a ‘fast track route’ vs ‘viability tested route’ depending on the % provision offered. This has already been adopted by some authorities. The Inspectors supported the Mayor’s policy approach to significantly increase the supply of affordable housing but altered the wording to limit viability testing on sites ‘where relevant policies in local plans are up to date’. This change was accepted by the Mayor, as it does not represent a significant change.
  • Green Belt – It was recommended that the Mayor should not undertake a review of London’s Green Belt on the basis that the vast majority of brownfield land has been, or soon will be, exhausted. The draft London Plan’s policies on the Green Belt also needed to be updated to be in line with national guidance. However, the Mayor has not proposed any changes to the sections or policies on the Green Belt, which means they would be out of line with national policy.
  • Industrial Land – A more comprehensive assessment is required for the provision and retention of industrial land in each borough. At present, it is not clear what amount of existing industrial land is needed, what permissions for the redevelopment of industrial land will be built out, and whether land that is currently vacant would be subject to redevelopment or be reused for other business purposes. The overall strategy is also linked to the need to undertake a London-wide Green Belt review. The Mayor has also declined to make changes to the plan in this regard, reiterating his view that the policy is suitably clear. We expect that this could provide opportunities for sites that are not allocated for industrial uses to be redeveloped for alternative uses.
  • Heathrow Airport – The Plan should mention the proposed expansion of Heathrow Airport as one of the potential transport schemes for the capital. It currently doesn’t consider the expansion at Heathrow in enough detail and the policy relating to Heathrow Airport is ‘not inconsistent national policy and can operate alongside the Airports National Policy Statement’.
  • Conciseness – The Inspectors’ report suggests that the Mayor should consider setting a more concise spatial development strategy rather than getting bogged down in the detail. No changes in this respect have been undertaken.

It is no surprise that the GLA have resisted incorporating the modifications regarding the Green Belt and Heathrow Airport expansion, due to their political sensitivity. The Secretary of State must now decide whether to call in the London Plan for further consideration or not.

It is not a requirement for the London Plan to comply with the tests of soundness in the National Planning Policy Framework (positively prepared, justified, effective and consistent with national policy). However, it would be best practice for the Mayor to seek to comply with the tests, at least to set a good example to their local London authorities.

It might be that having a new Plan in place is better than an out of date one, after all, the housing target is to be increased. Nonetheless, there are other big issues that need to be considered such as the approach to the Green Belt. The story continues… and the question is, will the Mayor succeed in adopting the new London Plan before the next Mayoral Elections in May 2020?

For more information please contact our London team.

Contact us today

  • For more information about our privacy practices please view our privacy policy. By submitting this form you agree that we may process your information in accordance with these terms.
  • Do you want to contact a particular office, or is it a general enquiry?
  • This field is for validation purposes and should be left unchanged.