Insight

Local Plan Watch | A Spotlight on London

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London is entering one of the most profound shifts in housing delivery anywhere in the country.

For years, Green Belt development for residential development was not an option. Now it is one of the greatest opportunities for developers of strategic greenfield land in England.

This about turn has been caused the introduction of Grey Belt policy and a more pragmatic tone from City Hall. As such, Green Belt release is now being explicitly identified as necessary to meet the capital’s housing target. The Towards a New London Plan consultation confirms this direction of travel: the Mayor accepts that London will need to release parts of the Green Belt to achieve the government’s requirement for 88,000 homes a year - more than double delivery levels…when the market was buoyant.

Currently the market is not buoyant. 

Only 5,000 starts were recorded in the past twelve months and the picture is not projected to significantly improve in the short term. A perfect storm of multi-faceted viability issues and fire safety compliance issues are stalling delivery. Against this backdrop, the business-as-usual approach of brownfield only housing delivery in the Capital is no longer an option. Green Belt development is an unavoidable part of the spatial strategy.

For speculative applications, over the next 12 to 24 months, the planning context will change sharply. The London Plan becomes out of date in March 2026, at which point housing targets for the London Boroughs will revert to (usually much) higher standard method figures. This will push many Outer London boroughs into the presumption in favour of sustainable development (where they aren’t already) as their five-year land supply figures are based on these much higher targets. 

The only protection from this is an up-to-date Local Plan, as this ‘fixes’ the lower housing target for five years. Even this will offer only limited respite. The scale of the delivery crisis in London, with many Boroughs delivering only a few hundred houses in this year and next, means that no Outer London Borough will be likely to be able to pass the Housing Delivery Test and ‘the presumption’ will apply that way.

In practical terms, that means every London borough with Green Belt - eighteen in total - will soon be open to speculative applications and appeals on sustainable sites.

For Inner London Boroughs, the picture is similar, but the brownfield nature of these locations, means the potential of ‘the presumption’ applying and significantly improving the chances of success of a site is more limited. 

The new London Plan will, however, significantly influence the content of these Local Plans though, with even greater densities on sustainable sites and a streamlining of planning requirements to try and kick start delivery on the path to 88,000 homes per annum in the Capital.

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Jamie Sullivan

Partner, Planning

Jamie brings extensive industry experience of greenfield Local Plan promotion as well as securing planning permission for large scale complex brownfield regeneration proposals.

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