News 29 January 2021: Secretary of State (Mr Jenrick) has agreed to the Mayor’s latest set of revisions so now the Publication London Plan is being sent to the printers. It was a developer’s dream from the outset & is now even worse, especially for low- and moderate-income Londoners, for most ethnic minorities and for productive enterprises. Scroll down to the end of this post for our assessment.
15 January 2021: Deadlock was reached between the Mayor of London Sadiq Khan and the Secretary of State (SoS) Robert Jenrick but the SoS has pulled rank and dictated changes to the Plan which are now embodied in a new version from the Mayor. This seems bound to give us an even worse London Plan than we were expecting a year ago and reads like something from a past era. What happened? A summary…
London Plan Examination in Public (EiP) ended after 34 days over 5 months. About 80 community groups spoke including Just Space; many more wrote in.
Plan is a developers’ charter and needs to be a plan for justice. Only the preface has this stress on justice.
No consideration of alternative strategies, including our own;
Dire impacts this plan would have on lower-income Londoners & groups protected under the Equality Act
Weak approaches to climate change and bio-diversity, lacking urgency, targets and timeframes.
In housing, prioritise meeting the huge and growing backlog of need for low-rent (council) housing (demonstrated by the GLA’s own studies) in place of targets for open-market housing which so few can afford
A complete halt to new Opportunity Areas until impacts so far have been evaluated and a transparent, democratic system devised for their designation, design and implementation
Need for community audit and review for major schemes alongside design review
Protection of industrial / employment land and buildings and of green space from speculative housing development
Convincing ways of paying for social and physical infrastructure without cutting in to the provision of low-rent housing, contributing to unsupportable increases in housing density and probable land price inflation.
And hundreds of smaller changes
The Panel of Inspectors’ report came out, ducking most of the major issues.
It failed to challenge the Plan’s low ambitions for low-rent & affordable housing, which flew in the face of the evidence and would lead to a mounting backlog
It swallowed the Mayor’s proposed removal of density limits and their replacement by ‘design’ negotiations at Borough level
It proposed that the Plan’s “Good Growth” policies should be downgraded and described as Objectives, even though they cover important issues such as health, which are not seen elsewhere in the Plan, and add egalitarian impetus to others
It considered the Small Sites policies unfeasible and proposed their deletion, with a consequent 20% reduction in the housing capacity for London
On the positive side the Panel did recommend strengthening community role in planning, but it considered GLA had (after doing the extra work we demanded) satisfied the Public Sector Equality Duty
The Panel recommended strengthening of industrial land protection & provision which we welcomed but proposed less protection for Green Belt and Metropolitan Open Land.
Mayor of London released his ‘intend to publish London Plan’ and sent it to the Secretary of State for approval. The Mayor’s Plan accepted most of the Inspectors’ recommendations including the downgrading of Good Growth Policies.
It rejected the Panel’s recommendations to narrow the definition of Gypsies and Travellers, to rule out the review of Green Belts, to be less restrictive on developments on Metropolitan Open Land and to increase protection of industrial space.
This version of the Plan has lowered targets for housing output, reflecting the Panel’s rejection of the Small Sites policy – mainly significant for outer London.
The Secretary of State finally replied to the Mayor; a rude and critical letter saying: housing delivery had been ‘deeply disappointing’, house prices had risen, worsening affordability, strategic sites had stalled, eg Old Oak, estate regeneration has “onerous conditions” [these are the hard-won conditions to prevent demolition without democratic ballots, and are not part of the Plan], buying a home is crucial so people can have “a stake in society” so priority to Shared Ownership and First Homes. And he disagrees with rent control (which is anyway not in the Plan).
SoS demanded 11 changes including:
More family housing needed
‘Optimisation’ of density, with the possible extension of Opportunity Areas
Further release of Strategic Industrial Land, though safeguarding of land for ‘Last Mile’ distribution etc near the centre.
Allowing reduction of Metropolitan Open Land
Caveats for development on the Green Belt (in line with national policy)
Allowing more car parking spaces in suburban developments
Mayor replied to Secretary of State saying he was “mindful of the need to support the development industry” and his staff would work with SoS to consider policy changes / minor amendments to ‘achieve the necessary outcomes’.
Details of the Mayor’s counter-proposals were not published.
Mayor wrote to SoS asking for feedback & proposing to publish and adopt his London Plan version if no reply by 21st December.
SoS wrote to Mayor directing him to add two more changes to the Plan, after which it could be published:
as a result of Covid19 he proposes yet more housing land be taken from industrial land, in cases where Boroughs would otherwise use green belt or Metropolitan Open Land.
Tall buildings should be restricted to areas defined by Boroughs and are not suitable for all places, with the default definition changed from 30m to 18m to enable “gentle densification” in these areas, broadly outer London / suburban. This would dramatically reduce the capacity of most surburban areas to densify.
The letter said talks between the Ministry and Mayor’s staff had been ‘ongoing and positive’ and wanted to extend a housing strategy for London and the wider south east (where, evidently, more of London’s need would now have to be met). He also attached a schedule of the changes agreed and some more required in the Plan to satisfy his original 11 directions. Read all the exchanges.
21 December 2020
Mayor issues a ‘Publication London Plan’ version and sends it to SoS who has 6 weeks to respond. Here it is.
This London Plan was a bad one for the London of 2016 when it was being written: stacked in support of developer interests, investors and the rich, bad news for low- and middle-income people and for protected groups – including many ethnic minorities, disabled people, single parents. Bad news too for jobs and production in manufacturing and other workshop industries. Although the evidence showed a huge backlog of unmet need for housing, 78% of it for housing at council rents, the Plan would actually have seen the backlog grow. Emphasis on ‘Town Centres’ and abandonment of ‘Lifetime Neighbourhoods’ leaves local shops and services unprotected. Environmental and climate policies imprecise, lacking timelines. Transport stacked in favour of more heavy radial railways though walking & cycling targets are good and ambitious.
The Plan we are now faced with is even worse. Some small gains in wording (e.g. on local shops) offset by downgrading of the former Good Growth Policies, which gave the plan most of its egalitarian impetus, to mere Objectives at developers’ request. Protection of industry and employment space weakened. Scrapping of Small Sites policies designed to get more housing into outer suburbs, amplified by SoS defining tall buildings so that default densities there will fall further. With sustained pressure to maximise building in London, though, the squeeze on Inner London would be massive. Prospects for social housing production even worse than before as SoS insists that small developments can’t be made to contribute. House prices continue to rise but still developers can’t ‘afford’ the social and physical infrastructure and social housing they are supposed to pay for. Capturing land value has been a failure so how can the plan be implemented?
Covid makes that plan even more irrelevant to London’s needs and we are starting to think what the next London Plan needs to be like to ensure safe, spacious homes with good private and public outdoor space for all, more emphasis on the local and with environmental policies radical enough to reverse the crisis.