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
Overview of week 4 – Monday 11 and Wednesday 13
Week 4 of the Examination in Public aimed to complete the review of the New London Plan’s (NLP’s) strategy in relation to housing supply and targets (started on Friday 8th& concluding Feb 11th) . This short summary of discussions aims to highlight a couple of issues with the approach used in the NLP, particularly with regards to the delivery of housing targets and the focus on small sites to unlock additional housing provision (Feb 13th). This overview was written before the examination of monitoring and gypsy and traveller accommodation (Feb 15th).
More detailed write-ups are:
Friday 8 and Monday 11 Feb M19 Housing supply and targets
Wednesday 13 Feb M20 Housing on Small Sites
The credibility of housing targets set out in the plan has been a running concern from community groups, London Boroughs (particularly Outer Boroughs), Wider South East Local Authorities and some representatives of the real estate/house building industry since the beginning of the examination. In previous weeks, various stakeholders have indicated these targets were very unlikely to be met and might encourage unaffordable, and very dense housing developments, thus threatening local communities and the preservation of local heritage across London. Just Space indicated that the EiP has repeatedly shown that this draft plan would not succeed in meeting its own estimation of London’s housing needs, let alone catching up with the unmet backlog of need for social rented/ low rent housing.
Furthermore, we highlighted that this situation was not new. We have been here before, and if the panel recommends 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, we know what is going to happen. London will keep staggering from Plan to Plan, and it is the situation not only of low- and medium-income Londoners but of almost everyone across and beyond Greater London, that will deteriorate. We thus urged the panel to advise for a complete new approach to target setting and housing delivery. This requires new thinking and new models of land markets, in order to consider policies that do not contribute to, benefit from and incentivize land price escalation and that take seriously the role of non-market housing sectors and of the stock of homes. This will also require to reconsider how development viability is estimated and framed. This will imply engaging more closely and frequently with London’s communities, community organizations and universities as well as local governments. We observed this had been fruitful in the last weeks and we are even more hopeful that this can lead to more just results, especially as we have seen a renewal of the GLA team, coming up with fresh ideas and willing to invent the future.
The introduction of the Small Housing Sites (policy H2) in the NLP represents one such innovation, and was discussed on Wednesday Feb 13th. The GLA team emphasized the novelty of this policy, which radically differs from previous London Plans focusing on densification and provision through large scale redevelopments. The team also stressed that this strategy aims to incentivize SMEs to enter the housing market and has the potential to create more mixed communities and to encourage the provision of affordable housing. To them, barriers to the widespread use of small sites are not economic or technological but deliberate policy choices.
Whilst the policy itself was broadly encouraged – particularly by community organizations, several issues were raised in relation to its design and implementation. The Examiner first highlighted recurring concerns, notably from the Boroughs, on the modelling of small sites capacity. The assumption and evidence behind the 1% growth target was questioned by community groups and the Boroughs – with the exception of the London Borough of Islington. The GLA team responded they thought the 1% assumption was realistic given the availability of stock and the appetite of small builders in terms of growth of their business, and the rate of growth to serve the population to fill those homes. The London Tenants Federation pointed out that its was unclear how this policy would benefit low-income households. A representative of the Federation flagged that there is a backlog of needs for social rented homes which has gone unmentioned in this strategy of endless subdivision of units. It is unclear how the strategy contributes to the actual needs of Londoners.
More generally, barriers to the delivery of small sites were highlighted by the Boroughs and London First. South London boroughs argued that the policy was simply replicating existing tools which were already being used (meaning a step change in delivery was unrealistic). Furthermore, concerns were raised on a number of points threatening the delivery of this policy:residents might oppose intensification; landowners might be unwilling to bring forward properties; it takes a large amount of planning time to bring applications forward as small developers are not necessarily experienced; boroughs do not have the resources to undertake detailed design code work and do not have the capacity for additional planning application work. London Forum expressed concern regarding whether boroughs had the necessary skills and resources to deliver; they felt this policy weakened the role of Neighbourhood Plans. London Tenants Federation made a strong statement regarding how community led developments on small sites have successfully brought forward social rented housing with genuine community benefits. They proposed specific wording to increase policy support for community, social rent and self-build. Both they and Just Space pressed for social housing contributions to be required from small sites of 0-9 dwellings as well as larger schemes, as practiced sucessfully by a number of Boroughs already. Islington council spoke up in strong suppport based on their experience.
In addition, it was flagged that even when housing provision increases as a result of small sites development, problems emerge in relation to transport and service provision. A representative of the NHS worried about how small sites intensification would impact access to social infrastructures. Just Space added that the spirit of small sites policy should be linked with lifetime neighbourhoods, including investments in local social infrastructure. The London Forum indicated that social infrastructure provision needs to inform decisions about developments and a mapping of these facilities should be undertaken to guide where there is capacity for development. Several organizations indicated that PTAL estimates needed to be taken with care when assessing the accessibility of small sites. For instance, the West London Alliance highlighted that PTAL should be a starting point for a more nuanced approach which considers development levels beyond London wide modelling to look at specific differences.
The Inspector raised at the end the possibility of adopting different ways of setting targets: SHLAA, trend based (as boroughs argued for more realistic setting of targets based on what had been achieved historically), policy-led approach based on identifying sites and local feasibility. It was noted that so many Minor Suggested Changes had now been made to the policy it had become opaque and hard to read!
This post by Enora Robin
More detailed write-ups are:
Friday 8 and Monday 11 Feb M19 Housing supply and targets
Wednesday 13 Feb M20 Housing on Small Sites
Just Space 