London Plan Adopted, but work is still needed to address London’s housing need.

With the London Plan now published, Alec Arrol from GL Hearn's Planning team takes a look in more detail at what this means for London's housing need?

Just over a year has passed since the Mayor of London submitted his London Plan to the Secretary of State for Housing, Communities and Local Government and now, finally, the Plan has been adopted.

In March 2020, the Secretary of State wrote to the Mayor directing for the London Plan not to be published and that a series of changes be made. The global COVID-19 pandemic, and national lockdown, appears to have affected Plan preparation during 2020 as very little happened until December 2020 when a number of letters were exchanged between the two with the Secretary of State continuing to seek changes, including policies on greater flexibility to release industrial land for housing and Tall Buildings.

In the midst of another national lockdown, and somewhat out of the blue, on 29 January it was confirmed that the Secretary of State had no more matters to raise, paving the way for the London Plan to be published. However, the content of the letter makes for interesting reading and only serves to highlight some of the battles that planning departments inside and around London are likely face over the coming years in bringing forward Local Plans.

In setting out next steps the letter states:

“Now that you are in a position to be able to publish your London Plan I fully expect you to start working to dramatically increase the capital’s housing delivery and to start considering how your next London Plan can bridge the significant gap between the housing it seeks to deliver and the actual acute housing need London faces. I would again ask you to work closely with those authorities that surround London to develop a strategy to help alleviate the housing pressure that is faced both inside and immediately outside the capital.”

For local authorities inside London, the task has just been made significantly more challenging for them to meet their housing need with government setting out its revised proposals for the Standard Method for Local Housing Need. The Standard Methodology was first adopted in 2018 with the purpose of reducing time and resources away from the question as to how much housing an area needed to plan for and to shift debate to how and where the housing should go. The latest revision to the methodology retains the same approach as in 2018 but with modification so that the housing required in the 20 largest cities and urban areas is topped up by an additional 35%. This now means that the total housing need for Greater London is 93,579 per annum. This compares to the now adopted London Plan target of 52,287 per annum.

Previous Mayors of London, as well as the current Mayor, have always treated London as an island and able to ‘consume its own smoke’ by delivering the required homes without overspill or Green Belt review. The Secretary of State’s letter appears to signal what most planning practitioners have argued for some time – London needs to work with adjoining authorities to address housing need. However, for this to happen key issues need to be answered. Is it just authorities immediately adjoining London that the Mayor of London should work with, or should a wider geographical area be considered? What is the mechanism for such close working to take place?

It is this later point that probably needs most urgent consideration if housing need in London and the wider South East is to be addressed. There have been countless examples of Local Plan Examination Inspectors concluding that authorities have failed the Duty to Cooperate – Sevenoaks, St Albans, Wealdon. Moreover, what appetite would there be for adjoining authorities to work with London on matters such as accommodating housing need. Similarly, there may be increased pressure for boroughs neighbouring London to accommodate some of the Capital’s employment land needs now that the Secretary of State has provided greater freedom for London Authorities to consider industrial land for release instead of Green Belt.

Spelthorne is a case in point. In January the Council sent a letter to the Secretary of State protesting at the housing numbers that the Standard Methodology sets out is needed just to meet its own local need.

In his letter to Mr Jenrick Deputy Leader Cllr Jim McIlroy has said:

“You have taken away the hope that we could have prepared a Plan based on achievable housing numbers that would not decimate our Green Belt. I urge you to reconsider your ministry’s stance on the standard method and devise one that achieves the stated aims of the Government to deliver much needed homes across the whole of the country without concentrating development in the South East.

“I also implore you to direct the inspectors at the Planning Inspectorate to allow local authorities to give greater weight to retaining their Green Belt even when they are unable to meet their housing need without releasing it, provided they have maximised densities on brownfield sites and have asked their neighbouring authorities to assist.”

Given that Green Belt and housing requirements were key policy areas that were argued between the (Conservative) Secretary of State and (Labour) Mayor of London it may now be harder for the Secretary of State to come to the assistance of Conservative Green Belt authorities seeking to resist meeting their identified housing need. It is notable that the majority of the 20 largest towns and cities that now have a 35% uplift in housing need under the revised standard methodology are Labour controlled. However, perhaps this latest round in political point scoring between the Secretary of State and Mayor of London has just made life much more difficult for the Tory shires.

An important factor that could significantly affect the ability of London and the South East to plan for its housing need will be the outcome of the Government’s proposed Planning Reforms. One of the Government’s proposals is to abolish the Duty to Cooperate (DtC). Whilst the removal of the DtC could remove one of the main hurdles to authorities adopting Local Plans by government’s deadline of December 2023, this begs the question how strategic matters that require cross boundary working will be addressed. The current Government has shown no appetite to return to the days of regional planning.

Good examples of successful strategic planning do however exist. In Oxfordshire there is a Growth Board made up of the partner authorities in the County. Consensus has been achieved on matters such as housing requirements, which includes district authorities planning for the unmet needs of Oxford City. However, even here, intervention was required by the Secretary of State to ensure Local Plan adoption when the Liberal/Green coalition in South Oxfordshire sought to withdraw their Local Plan having been elected on the perceived unfairness that the District had been allocated too many homes. Would the Secretary of State pursue such an intervention with a Conservative controlled authority like Spelthorne?

Clearly, adoption of the London Plan is an important milestone and now provides a period of certainty for London authorities to progress plans and deliver the additional housing Londoners require. As the Secretary of State’s letter to the Mayor of London clearly indicates there is significant pressure upon the Mayor and London Authorities to dramatically increase housing delivery and exceed the London Plan targets. However, with the Mayoral elections due in May, it will be interesting to monitor whether such scrutiny and intervention is maintained in the event a Conservative Mayor is elected.

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