FALP Inspector Anthony Thickett has recommended that the draft changes to the London Plan be adopted, subject to a commitment to an “immediate full review” of the plan by the Greater London Authority (GLA). This recommendation is underpinned by the Inspector’s concerns that the FALP strategy can only provide a short term solution to London’s housing shortage and as such, will not “provide for objectively assessed need.” Pertinently, the Inspector calls for wider engagement with local planning authorities beyond the GLA’s boundaries, in accommodating the Capital’s growth.
As highlighted during the Examination hearings, the GLA’s accompanying Strategic Housing Market Assessment (SHMA 2013) identifies a need for between 49,000 (2015-2036) and 62,000 (2015-2026) additional dwellings per annum (dpa) in London. However, and as noted by the Inspector, the FALP only allocates a total of 42,389 dpa through targets for individual London Boroughs (FALP Table 3.1) – this results in a shortfall of around 6,600 dpa. Although the Inspector found the evidence basis sound, he was not convinced that the anticipated shortfall could be met in the capital stating:
“There is no mechanism in the FALP to indicate how the 6,600 dpa would be apportioned or distributed. Without this I do not see how the Mayor can guarantee the delivery of the additional housing necessary to meet identified need.”
Furthering this, the Inspector raised caution to the future intensification of housing densities within town centres and existing communities – a key strategy put forward by the Mayor in order to meet London’s housing demand. As such, Thickett highlighted the importance of understanding the individual character of areas whereby to increase densities may not be appropriate in all cases. As highlighted, this is greatly dependent on infrastructure delivery and accessibility, whereby not all areas will benefit/qualify. Consequently, and perhaps most notably, the Inspector expressed that “new, innovative and possibly unpopular solutions” will be required to meet London’s housing requirements, which go beyond the existing philosophy of the London Plan. As such, it is largely insinuated that in pursuing a long term strategy for the Capital’s growth, potential land release outside of London will need to be explored.
Notwithstanding this, and on adoption of the FALP in the short term, London Boroughs will be required to deliver increased minimum housing targets through new allocations in emerging Local Plans (LP’s).It is evident on the ground that London Boroughs are already accounting for this, with LB Redbridge recently consulting on an ‘Alternative Development Strategies’ draft to their Local Plan in accommodating and finding land sufficient to deliver an increased housing target of 1,123 dpa (c. 48% increase on previous target). LB Wandsworth have also halted examination of their LP, following concerns that the plan would be found unsound against revised targets.
The Inspector had no real concerns with other aspects of the FALP, endorsing minor changes to employment, elderly housing, student accommodation, retail and transport policies.
The Mayor of London has accepted the recommendations proposed and has issued a Notice of Intention to Publish the FALP. The Secretary of State has up to six weeks within which to respond, following which the FALP will go to the London Assembly for approval. It is anticipated that the FALP will be published (adopted) by March 2015.
The Inspector’s Report and full response by the Mayor of London can be found at the link below:
We shall continue to monitor progress and report on findings as soon as they are published. In the meantime, if you have any queries or require further information, please contact your usual Iceni contact.