London’s housing requirements (text from London Plan Chapter 3)

London’s housing requirements

3.14A  The Mayor recognises the pressing need for more homes in London and to help boost significantly the supply of housing, this Plan sets out the average annual minimum housing supply targets for each borough until 2025. These targets are informed by the need for housing as evidenced by the GLA’s 2013 Strategic Housing Market Assessment (SHMA)[1] and London’s housing land capacity as identified through its 2013 Strategic Housing Land Availability Assessment (SHLAA)[2].  Consistent with the National Planning Policy Framework, this approach takes account of London’s locally distinct circumstances of pressing housing need and limited land availability and aims to deliver sustainable development.

3.15  Though there are differences in the type, quality and cost of housing across London, the complex linkages between them mean that for planning purposes, London should be treated as a single housing market. Many of these linkages extend beyond London, underscoring the importance of inter-regional coordination in meeting housing requirements in the wider south east, especially in the adjoining counties.

3.16  As noted in Chapter 1, there is clear evidence that London’s population is likely to increase significantly more than was anticipated in the past. However, there is uncertainty as to the actual scale and nature of this increase. This Plan therefore assumes that London’s population is set to increase by up to 2 million in the 25 years to 2036 with the level of growth reducing over time, but still remaining significantly above that assumed in the 2011 Plan. There is also uncertainty as to the size and number of future households. As a central assumption the Plan is predicated on average household size falling in line with DCLG assumptions from 2.47 in 2011 to 2.34 persons/household in 2036. Under this assumption, the number of households in London could rise by 1 million[3]  by 2036.

3.16A  In view of these uncertainties it is clearly not realistic to plan in detail for the whole of this period, but rather to take the possible long term trend as a ‘direction of travel’ for which the Mayor must ‘plan, monitor and manage’.  In this context, the Plan is based on a projection for 40,000 more households a year (2011-2036). These projected trends will be monitored very closely, with a view to a further early revision, or if necessary a full review of the Plan by 2019/20.

3.16b  This level of household growth does not represent the growth in housing requirements over the life of the Plan. This is identified through the GLA’s SHMA[4] which draws on government guidance[5] to identify London’s need for both market and affordable housing. As well as demographic trends the SHMA reflects the Mayor’s intention to seek to address the existing backlog in housing need and takes account of the range of factors which bear on this. On this basis, the central projection in the SHMA indicates that London will require between approximately 49,000 (2015-2036) and 62,000 (2015-2026) more homes a year.  This range incorporates different levels of population change over the period, the time taken to address current need (backlog) and the anticipated under delivery between 2011 and 2015. The 2015-2036 figure of 49,000 additional homes a year provides the basis for the detailed housing need figures set out in this Plan. In light of the projected higher need, especially at the start of the plan period, this figure should be regarded as a minimum.

3.17  On the supply side, the London SHLAA is designed to address the NPPF requirement to identify supply to meet future housing need as well as being ‘consistent with the policies set out in this Framework’[6], not least its central dictum that resultant development must be sustainable. The SHLAA methodology[7] is designed to do this authoritatively in the distinct circumstances of London, including the limited stock of land here and the uniquely pressurised land market and dependence on recycling brownfield land currently in existing uses. This methodology has been developed and refined over time through partnership working with boroughs and others involved in London housing, as well as to reflect the principles of government guidance on preparation of SHLAAs nationally[8].

3.17A  Following the national imperative to address identified need, the 2013 London SHLAA has been more rigorous than its predecessors in testing potential housing capacity. Its results have been translated in Table 3.1 as minimum housing supply targets. It shows that over the period 2015 to 2025, London has capacity for a least 420,000 additional homes or 42,000 per annum.

3.17B  This is not unrealistic in terms of the granting of planning permission – since 2008, despite a major economic downturn, an average of almost 55,000 homes have been approved each year[9]. The greatest challenge is in translating this capacity into completions. As independent research has shown[10], the planning system can help in this but it is by no means the only barrier to delivery of homes on the ground (see para 3.85a). It is clear that a step change in delivery is required if London is to address its housing need.

3.18  As context for this, boroughs must be mindful that for their LDFs to be found sound they must demonstrate they have sought to boost significantly the supply of housing as far as is consistent with the policies set out in the Framework[11]. Of particular importance in this regard is the overarching national objective to secure sustainable development[12] and the need to secure actual delivery[13]. To address government requirements soundly in the unique circumstances of London means coordinating their implementation across the capital’s housing market through the capital’s unique two tier planning system where the development plan for an area is composed of the Local Plan and the London Plan, and the Local Plan must be in general conformity with the London Plan.

3.19  London is part of a global and national housing market as well as having its own, more local and acute housing need which place a unique challenge in reducing the gap between need and supply.  Boroughs should use their housing supply targets in Table 3.1 as minima, augmented with additional housing capacity to reduce the gap between local and strategic housing need and supply. In this regard, town centres (see Policy 2.15), opportunity and intensification areas (Policy 2.13), and other large sites (Policy 3.7) could provide a significant increment to housing supply. In addition, the process of managing the release of surplus industrial land should focus on bringing forward areas with good public transport accessibility which will be particularly appropriate for high density development (Policy 2.17). Experience in preparing opportunity area and other development frameworks (such as those for intensification areas and town centres, as well as broader proposals for growth corridors), demonstrates that through detailed partnership working in light of local and strategic policy, housing output from these locations normally exceeds that anticipated by the SHLAA – frequently by a significant margin.

3.19i  To ensure effective local contributions to meeting London’s need for 49,000 more homes per annum, Local Plans should therefore demonstrate how individual boroughs intend to address in terms of Policy 3.3 the relevant minimum housing supply target in Table 3.1 and seek to exceed the target through:

  • additional sources of housing capacity, especially that to be brought forward from the types of broad location set out in Policy 3.3;
  • collaborative working with other relevant partners including the Mayor, to ensure that the Local Plan is in general conformity with the London Plan and includes final minimum housing targets identified through the above process; and
  • partnership working with developers, land owners, investors, the Mayor and other relevant agencies to secure the timely translation of approved housing capacity to completions taking account of Policy 3.15.

3.19A  National policy requires boroughs to identify a supply of specific deliverable sites sufficient to provide 5 years’ worth of housing against their housing requirements, with an additional buffer of 5% moved forward from later in the plan period (or 20% where there has been persistent under delivery). In compiling their 5 year supply estimates boroughs should demonstrate that they have maximised the number of identified sites. However, given London’s reliance on recycled land currently in other uses, it must be recognised that in addressing this national policy objective, capacity which elsewhere in the country would be termed ‘windfall’ must here form part of the 5 year supply. In order to support the range of activities and functions required in London as set out in this Plan, application of the 5% - 20% buffers should not lead to approval of schemes which compromise the need to secure sustainable development as required in the NPPF.

 

[1]     Mayor of London. The London Strategic  Housing Market Assessment 2013 (SHMA). GLA, 2014

[2]     Mayor of London. The London Strategic Housing Land Availability Assessment 2013 (SHLAA). GLA, 2014

[3]     Mayor of London. SHMA. 2014 op clt

[4]     ibid

[5]     CLG SHMA Practice Guidance 2007

[6]     CLG NPPF op cit para 47

[7]     Mayor of London. SHLAA. 2014 op cit

[8]     CLG SHLAA  practice guidance. 2007

[9]     Mayor of London. SHLAA. 2014. Op cit

[10]    Molior London. Barriers to Housing Delivery. What are the market perceived barriers to residential development in London. GLA 2012

[11]    CLG NPPF 2012 op cit para 47

[12]    CLG NPPF 2012 op, cit, paras 6-10

[13]    CLG NPPF 2012 op cit para 174

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