Housing Supply in the Context of the London Plan Inspectors’ Report

The Planning Inspectorate’s panel report on the Mayor of London’s new London Plan has now been published. Whilst its recommendations are not binding, it is likely that many of them will be incorporated into the London Plan final version – the Plan was found to be sound overall.

With regard to housing specifically, the report highlights the ongoing tension between attempts to resolve London’s housing crisis and the need to provide accommodation of the right sort and in the right place. Local authorities’ housing supply is of course a very significant factor when considering planning applications, as if a robust five year supply cannot be shown the titled balance in the NPPF applies, with a presumption in favour of development unless there are clear and demonstrable reasons otherwise.

The Mayor’s draft set out very ambitious targets for local authorities’ housing provision, much of which was to be provided on smaller sites. To enable this, the draft included a presumption in favour of infill development on small brownfield sites, upward development and infill development of houses close to public transport links. However, the panel report recommends abolishing the small sites presumption policy entirely, cutting the housing target for small sites in half and dramatically reducing the overall housing target to be provided.

If the final plan stays as recommended, developers will need to consider whether small sites can be redeveloped, as many local authorities own policies would not permit this, and it would only have been with the help of the new London Plan policy that such development could have been allowed. Additionally, lower housing targets will mean that it is easier for an LPA to demonstrate a five-year supply. This is especially so as the recommendations also abolish an annualised target, leaving it open for LPAs to argue that the majority of their 10-year requirement could come forward in the final few years. On the other hand, local authorities still need to find accommodation – the new targets are still a large increase on existing ones, and care will need to be taken to ensure appropriate housing development is allowed to come forward.

Article written by James Kon

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