M19 Housing capacity, targets 8, 11 Feb

Warning: Just Space and UCL are trying to make available some sort of record of what happens in the EiP for the benefit of community members. Notes are being taken by students and checked/edited so far as possible by more experienced staff and others. Neither Just Space nor UCL offers any guarantee of the accuracy of these notes. If you wish to depend on what was said at the EiP you should check with the speaker or with the audio recordings being made by the GLA. If you spot mistakes in these notes please help us to correct them by emailing m.edwards at ucl.ac.uk

Housing strategy M19 (policy H1)  The overall size of the “need”/requirement target had been debated on Tuesday (matter 17) including the adequacy of the needs assessment (SHMA – Strategic Housing Market Assessment). The compatibility of all that with the overall aims of the Plan (Good Growth policies) was debated yesterday Wednesday (matter 18).  Today was the first half of matter 19 Housing strategy: supply and targets which includes the capacity study SHLAA (Strategic Housing Land Availability Assessment). The panel had lots of sub-questions, a-f covered today; g onwards on Monday.

The Panel asked: Are the overall 10 year housing target for London and the targets for the individual Boroughs and Corporations set out in Policy H1 A and in Table 4.1 justified and deliverable? In particular:
a) Are the assumptions and analysis regarding site suitability, availability and 
achievability and development capacity for large sites in the Strategic Housing and Employment Land Availability Assessment (SHLAA) reasonable and realistic?
b) Have the environmental and social implications of the proposed increase in housing targets been fully and properly assessed?
c) Policy H1 B 2) a)-f) identifies various sources of capacity. Will these be sufficient to meet the ten years targets and what proportion of housing is expected to be delivered by means of the different types? How much is expected to be delivered on existing industrial land in the context of Policies E4-E7?
d) Will the focus on existing built up areas rather than urban extensions using GB/MOL provide sufficient variety of house types and tenure?
e) Is the emphasis on development in outer London consistent with the intention in Policy GG2 that seeks to proactively explore the potential to intensify the use of land on well-connected sites?
f) Does the Plan adequately consider the cumulative impacts of other policies on the deliverability and viability of housing?

[This blog mostly pieced together from tweets; if you have better notes please let us have them. It’s lop-sided because we include a full text of Mark Brearley’s intervention. The blog is not structured to follow the sequence of the panel’s questions above.]

There was a lot of general critique of the SHLAA process and criteria including Just Space explaining how they had, from the outset, challenged the continued attrition of industrial and employment land, the inclusion of council estate ‘regeneration’ not yet 
approved by ballots or proper planning processes and the application of much higher densities to all sites than normal. Strong statements from Highbury Group, especially on how the study had embedded the densities observed in (mainly) non-compliant schemes.

About 40,000 dwellings per year were expected from ’large’ and 25,000 from ‘small’ sites.  Some of the large sites (only 1% of dwellings) were regarded as ‘low probability’ of being developed for a variety of reasons.

Ian Gordon (LSE) points out that almost all the extra capacity compared with 2013 SHLAA is from increased density assumptions; otherwise only about 3k dw/year added.

London Tenants Federation LTF stress that the targets are (wrongly) just for TOTAL housing (mostly market) when we know that the need is massively for social housing.  Need a table broken down by affordability/tenure in place of Table 4.1.

GLA Jennifer Peters insists only a “tiny” proportion of identified sites involve demolition of occupied housing. Some numbers were read out and will be communicated to us by James (and we’ll insert here).

Christine Whitehead (LSE) reported LSE research for GLA which had examined new London housing purchased by foreign buyers, concluding that very few held the dwellings vacant; the vast majority rented them out or used them for family etc purposes.  Michael Bach (London Forum) responded that international buyers may not keep flats empty (cf LSE research findings) but they don’t house people off housing lists! Putting it another way, Peter Eversden insisted that meeting 137% of the requirement for market housing in London year after year while under-achieving low-rent housing can’t go on. It takes up land essential for meeting real needs.

On the continued attrition of industrial floorspace, yardspace and workspace, manufacturer Mark Brearley for Just Space said [his text]:On behalf of Just Space I am Mark Brearley, proprietor of Kaymet, tray and trolley manufacturer since 1947, whose factory in Peckham near the Old Kent Road is proposed for erasure by our local authority who did not ask us. Our Vital OKR business association, with over 300 members, speaks up for the threatened industrial and high street economy of our area.

Delivery of a significant quantity of housing on industrial land has been built into GLA figures. This is a threat to London’s substantial industrial economy, and how it serves London, and the approximately 450,000 people employed, in the context of escalating accommodation shortages.

Some housing delivery will, of course, come from industrial land release already in progress, with permissions, in adopted plans. But estimates going beyond that, assuming the exercise of Policies E4 – E7 as currently drafted, are incompatible with the intention to retain sufficient industrial accommodation capacity. The further loss of industrial capacity that Policies H1 B 2) d) and f) imply would run counter to the conclusions of the GLA’s own careful research evidencing a trajectory towards industrial land shortfall of some 585 ha.

I highlight that justification for Policies E4 – E7 points to the need to halt loss of industrial accommodation across London, and Policy E4 states that retention and provision of industrial capacity should be planned monitored and managed having regard to Table 6.2, a table showing 32 boroughs in either Retain or Provide Capacity categories.

Policy H1 B 2) d) and f), that assume redevelopment of anachronistically labeled ‘surplus’ industrial sites, with additional mention of utilities sites, in ways that would deliver housing, depend on Policies E4 – E7. [refers to Vital OKR submission.] Housing delivery assumptions should be revised accordingly, as should the wording of Policy H1 B 2). Much less delivery of housing on industrial sites should be assumed. This source should be tapering away. We already have an industrial accommodation crisis causing large scale loss of enterprise. We must now stop looking there for significant further housing capacity.

Policy H1 B 2) d) that refers to the redevelopment of surplus utilities and public sector owned sites should be deleted. Who owns land is not a relevant matter, and to additionally highlight utilities (and to extend this to transport functions also as later in the draft plan at 6.4.5) is not consistent with the studies that are the key evidence base, in which predicted changes to demand from a range of sectors (including utilities and transport) were considered, and nil net loss was the conclusion.

Policy H1 B 2)f), that refers to ongoing releases of industrial land, or shifting it into LSIS designation thus allowing co-location with housing, should be amended to make clear that such release should not be ongoing. In order to be consistent with the powerfully evidenced London-wide no net loss policy this source of housing capacity should be presented as finite, only relating to what has already been allowed through planning permissions and adopted development plans.

Finally to chime in with concerns about the targeting of big format retail, as well expressed by Halfords already yesterday. Policy H1 B 2) b) is also in need of amendment. The strip-out of bigger format retail capacity is a concern. An example: In my own Old Kent Road a major application just in for a site where a B&Q store now is. The developers claimed that B&Q do to not want to stay, but now B&Q say they do & have not had their needs considered.

Just two miles away from where we are now in City Hall, around the Old Kent Road, hundreds of businesses are being forced out, their premises listed as housing capacity based on scenarios that do not give us a future. We need a London Plan that helps the likes of us, across this city, and allows for the growth of appropriately located industrial activity. [end]

Caroline Shah (Just Space, Kingston) stressed the damage posed to biodiversity and environment by the densities being imposed on many parts of London, together with the damage to heritage, urban qualities and social infrastructure capacities. The use of Opportunity Area designations to enforce these measures —often by-passing any local democracy or even consultations— is especially alarming and the Kingston case represents a whole new scale of damage: using OA status as a surreptitious blanket coverage for an entire borough. She went on to insist that most of the plan policies designed to regulate development were worded in such soft, imprecise and purely qualitative terms that they would have little or no impact on the outturn: terms like “Emerging Skyline”, “Evolving Context”

Christine Whitehead LSE on deliverability of the housing targets said “We need to be very cautious.” London First has apparently done a rival ’viability assessment’ which casts doubt on the financial viability of some/many of the proposals. John Wacher of the GLA viability unit said that they had tested 35 housing development typologies. Found development should be viable everywhere but different forms likely in diff places. Difference with London First was that GLA had taken care to use baseline land values which had been through scrutiny and were thought to reflect full impact of planning policies, whereas LF had used market transactions, often higher. (John previously at LB Islington and had led on the famous Parkhurst Road territorial army hall case.)

Foreshadowing the session on “small sites” Andrew Barrie Purcell (head of London Plan in the Johnson period), acting for West London Alliance of boroughs, mounted a critique and called for a much more nuanced approach to suburban densification. Echoed by Just Space which called for a rescue of the “lifetime neighbourhood” concept as embodying a bottom-up approach with reduction of the need to travel by getting people closer to services. 800m from town centre boundary or from ‘a station’ not an adequate basis for defining densification zones. GLA must do something better or ensure that boroughs do.

Note edited by Michael Edwards from own notes and various people’s tweets. Please suggest corrections and additions in box below.

End of Friday.  Session resumed on Monday 11th. No notes here (yet) on Monday morning.


Just Space: Thank you for letting us have a few minutes for final reflections on the Housing Strategy and capacity debates of the last few days.

Many of us have been saying in the café that the emperor has no clothes, or words to that effect. So much of the evidence has been to the effect that this draft plan cannot succeed in meeting its own estimation of London’s housing needs, let alone catching up with the unmet backlog fof need for social rented/ low rent housing (which makes up 78% of total need estimated in the SHMA).

We have been here before.  The risk is that you (the panel) recommend the adoption of a deficient plan, subject to an early review of the market demand, social need, capacity and policy situations a few years down the line.

Thus London staggers from Plan to Plan, each of which sees the aggravation of the housing crisis affecting low- and medium-income Londoners (and almost everyone else in various ways). This serial process is simply not acceptable and Just Space urges you to recommend some completely fresh thinking.

That thinking will differ from the past, particularly by including analysis, understanding (and even modelling) of the land market. The land market has never had adequate attention from City Hall but is one of the main roots of our problems and the Mayor will have to consider how to avoid policies which contribute to land price escalation, link this with his lobbying on property taxation and local government finance, and take seriously the role of non-market housing sectors and of the stock of homes. The appointment of Mr Wacher and his viability unit give us hope but they have a lot to do besides ‘viability’.

The UK economy is now generally understood to be dangerously a ‘rentier’ economy and there are national as well as regional moves to re-think the dominance of the property sector over our lives.

Another key feature of the next plan must be a closer and more frequent collaboration between the Mayor, his professionals, London’s communities, communty organisations and universities as well as local governments. We have seen how fruitful this can be in the last weeks. Imagine if it were a continuous process of co-production of the plan.

Finally we should say that we have some sympathy for the GLA teams, despite our criticisms. They are a new and young team, as they say, and have been asked to innovate in squaring the circle (which they do not quite say). They have this big new idea of the small sites policy which in many ways we support as a progressive move.  But they are being heavily criticised because it is a departure from trend which they can’t demonstrate will come true.  Our view is that the future MUST be different from the past, for reasons of equality and dealing with the climate emergency. We must invent the future between us.

[Final comments were also made by Christine Whitehead (LSE), Sharon Hayward [LTF] and Michael Bach (London Forum). To follow, we hope.

Back to the EiP narrative page

On to the next day: Small Sites

Overview of these 2 matters


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