The Inspectors Report has slashed the number of homes the GLA thinks it can build on small sites in London – rubbishing its plans as ‘undeliverable’ – and proposed a review of the green belt to ease the housing crisis. Nothing controversial there then. David Blackman reports

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The green belt, along with the NHS, is one of the few institutions founded by the post-war Labour government that survives essentially intact. And both possess a totemic status in national life that politicians shy away from challenging. But last month saw the publication of a report by planning inspectors recommending that the London green belt should be reviewed. The recommendation was part of the Inspector’s Report into the latest version of the Greater London Authority’s (GLA) London Plan.

There’s some good news for London mayor Sadiq Khan in the report, which endorses his once-controversial stances on affordable housing targets and viability assessments. But these glad tidings were overshadowed by the inspectors’ decision to slash the capital’s 10-year target for new homes from 649,350 to 522,850, which prompted their call for a review of the green belt. 

Small site target halved

The recommended 10-year housing target of 52,285 per year is a long way short of what experts believe is required to meet the capital’s housing needs. This is a direct consequence of the panel’s decision to more than halve the 10-year target for small sites, which for the purposes of the plan means any plot smaller than a quarter of a hectare, from 245,730 to 119,250 dwellings. The GLA plan stated that 24,500 units can be delivered each year over the next decade from sites of less than 0.25 ha. This figure was then translated into specific targets for the individual boroughs, involving particularly steep hikes for those in outer reaches of south London. Bromley council has estimated that its new target for small sites equates to an eight-fold increase in the number of homes it would have to deliver on such plots. 

GLA’s modelling of small sites was ‘insufficiently accurate to give a true picture of the likely available capacity’ – planning inspectors

What mainly seems to have undermined the plan’s credibility in the inspectors’ eyes is their judgment that the GLA’s modelling of small sites was “insufficiently accurate to give a true picture of the likely available capacity”. The lack of evidence from pilot projects or past trends means that the targets, including those for individual boroughs, were neither “justified nor deliverable”. 

The inspectors admit that even while the examination in public (EIP) was ongoing, they considered sending the plan back to the drawing board for more work or even withdrawing it entirely. They only decided against such a drastic option because of the “considerable delay” and “uncertainty” that such a move would entail, with a “knock-on” effect on the delivery of London borough’s individual plans, which take their cue from the levels of development outlined in the GLA’s capital-wide blueprint. 

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Who’s interested in small sites?

Small sites matter particularly to housing associations because volume housebuilders are not especially attracted by this type of land. Paul Hackett, chief executive of housing association Optivo, says: “The sites we buy are where housing associations are the main competitor. It’s essential that we keep them coming through the system.” He sees a continued strong pipeline of such sites, particularly in the outer reaches of south London where most of Optivo’s developments are. 

The GLA is right to optimise the amount of homes, but not at the expense of damaging areas - Mike Kiely, chairman of the Planning Officers Society

But Mike Kiely, chair of the Planning Officers Society, describes the methodology developed by the GLA as “clearly ridiculous and unachievable”. He argues that the target was based on the blunt gap between the number of homes needed across the capital and the 400,000 dwellings that the mayor had proved could be developed over the next 10 years on the 11,600 large sites identified in the plan. 

Kiely, a former chief planner at Croydon who advised Bromley during the EIP, says: “They [the GLA] are right to optimise the amount of homes, but not at the expense of damaging areas. There’s no way a sensible person believes that a borough like Bexley could achieve that range of increase.” 

Mansion blocks to replace semis

John Myers, co-founder of the London YIMBY pro-residential development pressure group, believes that there is considerable scope for squeezing more housing out of the capital’s small sites. “We’re not exactly short of 1930s semi-detached houses and could afford to replace a few with mansion blocks. There’s huge scope for densification of low density areas and it can be done very well, but the only way it can be done sustainably at scale is with local people and not being done to local people.” The problem is the London Plan was poorly drafted, he says: “The concern is that it will lead to a backlash and you will end up with loads of appeals that end up clogging the appeals system.” 

Greg Hill, deputy chief executive at mid-sized housebuilder Hill, says London’s council planning departments are incapable of bringing forward the scale of development on small sites that the mayor wants to see. “The small sites target is laudable, but unfeasible and unrealistic: the resource intensiveness of the planning process doesn’t enable you to facilitate the delivery of that many sites.”

Getting more bang for bucks

Given how overstretched the capital’s planners are, they will put scarce resources into sites that are likely to deliver larger volumes of homes, Hill says:  “People have targets to hit and therefore will have to apply resource where they will get more bang for their buck.”

The added factor is that smaller sites tend to throw up more issues than larger ones due to the proximity of neighbours, Hill says: “Very few people would disagree that the ambition is sensible but the reason why brownfield sites haven’t been developed is because people haven’t been able to bring them forward, so the sites that are left are increasingly challenging and difficult.” Even those environmentalists, who have traditionally championed making better use of small brownfield sites to relieve pressure on the green belt, were unconvinced that the mayor’s policy was achievable.  

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Local authorities would need more power

Paul Miner, head of strategic plans and devolution at the Campaign to Protect Rural England, says: “There is scope to build more on small sites in London, but whether it can be done at that rate is another question. 

“It’s difficult to see how you could increase the rate without giving local authorities more power to acquire sites and assemble land.”

Kiely says that the kind of small sites targeted in the GLA policy are too small anyway to justify the use of councils’ compulsory purchase powers even if they wanted to. He says the panel was right to look at the green belt as the ability of London’s urban area to accommodate the additional scale of development widely seen as necessary to meet London’s housing needs is effectively exhausted. The pressure to find sites constitutes the kind of exceptional circumstance that the National Planning Policy Framework states is required to justify a review of the green belt, which makes up just over one-fifth of Greater London’s land mass. 

We don’t have administrative mechanisms to deliver what would be a comprehensive and proper examination of the green belt - Mike Kiely, chairman of the Planning Officers Society

Hard boundaries wrong

London YIMBY’s Myers says the inspectors were right to throw out the hardline interpretation of green belt policy that Khan had set out in his draft London Plan, which stated that the boundaries of the green belt should be set in stone. “It has to make sense that we don’t have hard and fast lines set in the London Plan, which is what the mayor was trying to do. There are plenty of areas where you could do something sensible.”

Jonathan Seager, executive director of policy at London First, says that a review could be a “fantastic opportunity” to take a long overdue strategic look at the green belt, which could improve the environmental quality of the countryside as well as deliver more development. A report published by the property agency Hamptons four years ago estimated that 213,000 homes could be built within walking distance of train stations in London’s green belt.

Not all bad news

While Sadiq Khan will feel bruised about the verdict of the inspectors’ report on his green belt and small sites policies, he will feel vindicated by their backing for his once controversial plans to increase the capital’s affordable housing targets.

The inspectors endorsed the London mayor’s target that half of all new homes should be affordable housing. And they gave their blessing to the GLA’s stance, which is already set out in supplementary planning guidance (SPG), that developers who offer to earmark at least 35% of their sites for affordable housing won’t have to submit onerous viability appraisals.

The inspectors said the increased target is justified by the massive mismatch between the level of affordable housing need in the capital and the proportion that is actually being delivered. And since the mayor’s approach was outlined in the SPG, it has had ‘promising results’ in terms of raising overall delivery, the report notes.

Optivo’s Hackett is glad that the report acknowledges that the mayor’s affordable housing policies, which he describes as “sensible and workable” in a London context, are working.

“It is completely wrong that developers were wriggling out on the basis of viability,” he says.

London YIMBY’s Myers agrees. “More clarity on viability is a good thing, The key thing is that everybody knows upfront so that it can be reflected in the land price: there’s no doubt London has one of the worst affordability problems in the world.”

Tap into local knowledge

But Seager says such estimates must be taken with a “pinch of salt” and that the only way to find out the real number is to tap the knowledge of local councils and communities to identify sites suitable for development. A review isn’t necessarily a silver bullet for solving London’s housing needs, he says: “It may turn out that there is a handful of sites available to build on.” Nevertheless, it is a necessary exercise. 

The main problem though, as the inspector’s report flags up, is which body will carry out the review. The GLA’s remit stops at the Greater London border. And ever since the government scrapped the regional assemblies, there has been no organisation able to corral the South-east’s disparate local authorities together to develop a plan. “We don’t have administrative mechanisms to deliver what would be a comprehensive and proper examination of the green belt,” says Kiely, adding that any review would rely on individual local authorities’ duty to co-operate. 

But report is not binding

In addition, the inspectors’ report is not even binding on the mayor, although he will have to come up with good reasons not to accept the recommendations. The final plan is sent to the secretary of state for housing and communities who will have the final say. The extra uncertainty here is that Khan has until 8 December to respond, only four days before a general election, which is likely to see a change of secretary of state. This all means that the process won’t end until early in the new year. At this point, it will no doubt get caught up in the run into May’s London mayoral election when candidates will be tempted to use the green belt as a political football. 

These political shenanigans will be cold comfort to those badly housed or homeless, says Optivo’s Hackett: “It’s not good the housing target has been reduced because it makes even more unlikely that we are going to meet housing need.” Seager agrees: “It’s not like the people that need homes are disappearing, they are still around.”

Further reading:

The Planning Inspectorate’s Report to the Mayor of London