Draft London Plan Examination: Can the small sites initi…

A range of stakeholders were represented including both inner and outer Councils, the BPF, NHS, housing associations and other smaller groups to discuss the methodology, modelling, deliverability and achievability of the draft new policy.

The Mayor of London has made it no secret that he wants to deliver significantly more homes - AND that doesn't necessarily have to be from the larger strategic site allocations. In particular the GLA are seeking, through their draft policy, to encourage local planning authorities to think differently about housing delivery, than perhaps they have done previously, by giving a presumption in favour of development on small sites delivering 1- 25 homes in accessible areas. The GLA are encouraging Boroughs to bring forward small sites as a new way to deliver London's much needed housing and to diversify house building. The GLA has accepted that the policy H2 is a challenge but, in turn stated that the policy will encourage development in areas where this has not previously occurred.

One of the main points of discussion is whether the policy is actually too prescriptive to be in a strategic development plan. Can the policy be streamlined and left to the boroughs to give a presumption in favour of small scale development? The GLA accepted that perhaps there could be avenues to streamline the policy however if it was left to the local planning authorities, it is unlikely that many would follow through to give the same support to small sites that the Mayor would like to see across London. It is known that quite a few Councils are on record in saying they would resist the GLA approach to small sites.

It was the general feeling from stakeholders that the implications of this policy is however more complex than the GLA are suggesting. As we know, smaller sites often have site specific constraints as well as local objection that often delay the planning and post planning programme which could mean that small sites have a similar or worse delivery programme as strategic sites. In other words just because these sites would be 25 homes or below doesn't necessarily mean that these sites would be brought forward quicker than perhaps larger sites so is this the best way to approach increased housing delivery or do we need a plan B?

Draft Policy H2 is due to apply to accessible sites which includes high Public Transport Accessible Level (PTAL) areas, within town centres and within 800m of a town centre boundary. There was some discussion around the relevance of using PTALs when there are some areas of London where this tool does not accurately reflect the access needs of residents. Debate also circulates around the GLA's justification of using the boundary of the town centre as a measure for increased housing delivery on small sites and whether there should be some focal point of centres which all measurements are taken from. The GLA small sites methodology assumes 1% of the existing stock of houses will increase in density in areas which benefit from PTALs 3 of 6 within 800m of a railway station or tube station or town centre. Many questioned how the methodology had been brought about, as the policy approach resulted in an increase of Borough's small site targets for some by nearly threefold, in which many expressed that these targets are unrealistic and unsupported by evidence that is unachievable without conflicting with other policies in the London Plan. Growth factors are then applied to the notional 1%. There were discussions that the GLA provided no justification or robust evidence on the 1% figure, and that it is solely 'policy driven', which has led to wider concerns amongst Boroughs on how physical and social infrastructure will be met for the new increased targets for housing.

Whilst the current national policy does not seek contributions towards infrastructure it was a key concern of stakeholders that the delivery of much of the Borough's housing delivery from small sites will have an adverse impact on the physical and social infrastructure demands. Like other Boroughs in London, will the Mayor look to introduce a tariff to seek contributions from site providing 1- 9 units subject to viability testing? There was discussions that thought that the Mayor should take a more permissive approach to a tariff style, encouraging London boroughs to make the decision to take this policy approach where there is the need as per the Court of Appeal Order 2016 and the Written Ministerial Statement 2014 to avoid discouraging small scale developers from bringing forward development but others suggested that this would be better at a local level if there is a demonstrated need.

In our view, the small sites initiative has merit to helping to achieve the ambitious GLA housing targets but it is clear that stakeholders believes the small site targets was that the policy targets are unachievable in their current form and will not deliver enough housing to meet the stated targets.