Sadiq Khan’s London Plan is closer to adoption after the Planning Inspectorate gave it the broad go-ahead in its report earlier this week. However, some substantial concerns were raised, and a number of potentially far reaching recommendations were made. When adopted, the new London Plan will replace the current, much consolidated version issued by London’s previous Mayor (now the Prime Minister).

A series of examination hearings were held on the draft new London Plan earlier in the year, and now the much anticipated Inspectors’ Report has been published. The report confirms that the Plan provides an appropriate basis for the strategic planning of Greater London, provided it is amended in line with the Mayor’s suggested changes and, more crucially, the recommendations put forward by the Inspectors.

In this vein, some of the Inspectors’ recommendations would seem to fundamentally change the Mayor’s approach, including the removal of the proposed presumption in favour of small housing developments and, perhaps most contentiously, a recommended commitment to a “strategic and comprehensive review of the Green Belt in London” (albeit to be undertaken as part of the next review of the London Plan).

Key Recommendations 

Evidently there is a lot to digest in the 125 page report, but the principal recommendations can be drawn into three interlocking themes:

  • The Inspectors’ recommendation to remove the presumption in favour of small housing developments, and cut the small sites housing target in half, after finding the Mayor’s aspirational policy approach to be “highly unlikely to occur, based on the available evidence”, placing an unreasonable expectation on the contribution that such sites can make in meeting housing targets.
  • The draft Plan seeks to apply a blanket approach to prevent the de-designation of Green Belt sites, which the Inspectors consider is not consistent with the NPPF. As a remedy, they suggest that the Plan commits to a review of the Green Belt in future policy work. In addition, alterations addressing the rather stringent original wording of Green Belt policies are suggested, effectively putting them in line with the NPPF.
  • The report finds that the need for industrial land is likely to be greater than assumed in the Plan, and that this demand could be “many hundreds of hectares”. In response, the Inspectors recommend that allowance is made for boroughs to review their Green Belt boundaries in emerging Local Plans, to make allowance for additional industrial capacity.

Commentary

The Mayor has already voiced his opposition to some of the report; not least the principle of a London-wide Green Belt review and it will be interesting to see what his next move is. Further, any suggestion of releasing land from the Green Belt always proves politically contentious – to say the least.

However, in reading the report it is evident that the Inspectors have not come to their recommendations lightly, and from their perspective the recommendations relative to Green Belt policies are intended to bring the London Plan in line with national policy.

The Inspectors also insist that the matter of a Green Belt review must be considered in the light of their findings that “capacity within London is insufficient to meet the identified annual need for housing and the potential shortfall of industrial land in the medium to longer term”, emphasising the issue of competing land uses, and balancing the needs of a growing population against the protecting the fundamental aims of the Green Belt.

The Inspectors also raise difficult questions in respect of the considerable reliance on small sites, an approach which was not considered realistic, leading to recommendations to significantly reduce Borough targets for such sites. This stance, whilst appearing somewhat severe at first glance, is not unsurprising, given the difficulties that are often faced when bringing forward small sites for redevelopment, particularly in London, against the quantum of new dwellings that the new London Plan expected to be brought forward in this manner.

The shortfall in industrial land highlighted by the Inspectors will be familiar to anybody trying to find, for example, sites for logistics development in London, particularly in the inner boroughs, and therefore the attention given to this matter will be welcomed by those in the industry.

In summary, the matters raised by the Inspectors are quite significant and their view is clear that “it would be wrong to unilaterally rule out changes to the Green Belt”. However the report is equally candid in saying that the consequences of not adopting a London Plan would be worse than adopting one that does not meet the capital’s development needs. The ball is now in the Mayor’s court, and we await his response.

For further guidance, please get in touch with Olivia St-Amour or Jason Lowes.

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