Draft London Housing Strategy published – support for small housing sites and town centre regeneration

The Mayor of London, Sadiq Khan, has published his draft London Housing Strategy for public consultation.  In line with national policy, the central priority of the draft strategy is ‘to build many more homes’ for Londoners in a bid to solve London’s housing crisis over the long term.

As expected, the Mayor remains committed to protecting London’s Green Belt and open spaces, meaning new homes will need to be provided within the city’s existing built up area. Whilst we are assured that developing large sites remains important, the Mayor identifies two other opportunities which stand out as means of meeting London’s housing need: housing as part of the regeneration of London’s town centres; and more development on small sites. Both opportunities have particular relevance in outer London.

With regard to town centres, nothing radically new is introduced, but the Mayor rightly seeks to take advantage of better transport links and regeneration opportunities by promoting appropriate development of new homes on brownfield land, in and around town centres.  Other proposals seek to address barriers that prevent more homes being delivered in town centres, such as lack of infrastructure and issues with land assembly.

There is a clear emphasis on the need to increase housing supply through higher densities and co-location of different uses, and it is specifically acknowledged that resulting densities ‘will often be higher than those in the surrounding area’.  Mr Khan intends to introduce a new approach to design-led density in the draft London Plan, expected in the Autumn.

More widely, the Mayor is interested in exploring new incentives that could encourage landowners to consider redeveloping sites which are currently used inefficiently.  Examples include surface car parks and single-storey low density retail centres and stores. Consolidation and intensification of industrial land to retain industrial floor space while opening up sites for residential development will be supported, as will the consolidation of commercial or retail land to support more homes.

Turning to small sites, the strategy recognises that smaller sites tend to be completed more quickly than larger ones, and, when located in parts of London with lower land values, can help to support the delivery of market homes at relatively affordable prices. In a welcome attempt to reverse the decline in the number of smaller sites coming forward for housing in recent years, the Mayor intends to set out policies in the forthcoming draft London Plan which ‘give a clear presumption in favour of appropriate residential development on small sites, including specific borough level targets for this type of development’.

As well as making more small sites available through the introduction of this new ‘presumption in favour’, the Mayor commits to working with councils and Government to set out clearer policies and streamlined planning processes for smaller sites and small builders, which focus on ensuring they are supported and ‘the costs and risks they face minimised’.  The all important detail is lacking on these proposals but we are promised it will be published as part of the forthcoming draft London Plan, and will include working with councils to promote the use of Permission in Principle on small sites.

Mr Khan also intends to amend the Mayoral Community Infrastructure Level (CIL) instalment policy so that small and medium sized builders can pay less upfront.  Councils will be encouraged to do the same where local CILs are in place.

In terms of affordable housing, the new minimum threshold approach set out in the recently adopted Affordable Housing and Viability SPG (August 2017) is to be carried forward.  The threshold works by providing a ‘Fast Track Route’ through the planning system for developers that provide at least 35 per cent affordable homes without public subsidy.  Schemes that do not meet the threshold are subject to a detailed viability analysis. Notably, there is no mention in the Mayor’s strategy of the small site (10 units or fewer) affordable housing exemption set out in national planning guidance which, to the frustration of many small developers, is being implemented inconsistently across London at present.

Public consultation on the draft London Housing Strategy runs until 7 December 2017.