Aim of the roundtable
The fifth roundtable was held at the point when the Examination in Public of the Mayor’s (draft) New London Plan had been sitting for three months and had dealt with 60 of its 94 Matters. At this point there was a month-long break before starting again (on waste management) and moving on towards completion of the hearings on 22nd May. It therefore seemed a sensible time to take stock of where we have got to and ask where next?
Given our focus on matters relating primarily to housing and spatial strategy, virtually all the relevant sessions have already happened. The significant exceptions are those on ‘viability’ (in both broad and housing specific terms – so including e.g. the Plan’s impact on Transport for London’s finances, the operation of S106 and its relationship to infrastructure and affordable housing provision as well as more general issues of productivity and growth) and ‘monitoring’ on the final scheduled days. These are extremely important topics – but the shape of the new Plan and the criticisms levied at it are already clear.
Rather than revisiting previous discussions about specific Matters, and the rights/wrongs of the Plan, the aim at this roundtable was to assess:
- where do we think an emergent consensus on these Matters might lie which Panel members might share;
- given these areas of consensus, what possible outcomes from the EiP might there be;
and, more broadly
- where/how could there still be scope for influencing the outcome and ensuring suggested modifications are taken into account by the Panel.
Our discussion attempted to avoid repetition and mainly concentrated on three elements where there is continued debate as to whether the draft Plan is ‘safe’: the evidence base, delivery and the green belt.
The evidence base
The evidence base issue goes right back to the first days of the EiP. It has generally been noted that the plan as compared to earlier versions, concentrates more on policy (and sometimes micro-management) rather than providing a strong evidence base. Nor have alternatives been examined in adequate detail – a requirement within the relevant NPPF.
The inadequacy of evidence supporting the Plan is particularly obvious in the context of the core assumption that London can provide the housing required within London’s administrative boundaries and indeed without touching the green belt within these boundaries. As noted elsewhere (see Ian Gordon’s blog) this has been the assumption in all earlier Plans. However, it is becoming an increasingly unrealistic assumption as a basis for ‘good growth’ (the Plan’s overall objective) as projected population continues to grow and land prices to rise.
It was argued that the Plan only needs to show the capacity to meet housing targets, not the capacity to deliver. On large sites there can be little objection (except for the fact that they have not already come forward) as the assumptions are similar to earlier accepted Plans. However, the emphasis on smaller sites is new, very important to ensuring capacity – and claimed by the Mayoral team as representing the required change of philosophy. We discussed evidence from local authorities which strongly suggests that these small site numbers cannot be shown to exist within the timetable of the Plan. Equally a proportion of identified land is only developable if infrastructure is in place – which certainly will not be the case for some major schemes. Further there is clear competition between residential and industrial land as well as between residential and open space so these policies can be argued to be inconsistent – and to mitigate against ‘good growth’.
This is an area where the participants in the roundtable were in near total agreement. Nobody in the room believed the numbers to be credible. The whole Plan is about maximising the additional dwellings delivered. But this emphasis on maximising numbers badly distorts choices with respect to size and tenure. Most importantly there is nothing in the Plan which makes it more likely that building activity can increase in the way required – indeed rather the opposite, in that the Plan includes policies which are more likely to reduce output. All that will happen is the local authorities will be blamed – and central government will blame the GLA.
The Green Belt
The Mayor’s position on the green belt within London and the refusal to interact seriously with authorities around London was one of the issues of particular concern to participants. It technically follows, of course, from the ‘fact’ that enough land has been identified without going into the green belt to provide almost all that is required, based on density and other assumptions. But, given how unrealistic the assumptions are on capacity (let alone delivery), the position on the green belt also appears unacceptable.
As participants noted, green belt reviews are a matter for local authorities who have a duty to cooperate with neighbouring authorities both within and outside the London boundaries. But there needs to be an over-arching policy. While a strategic review involving both London and the Wider South East would take some years; it would be worth it if a coherent policy for the longer term could be developed. If the Plan had a relevant policy this could be the starting point for enabling such a review. But the draft Plan rules it out.
It was argued that the Plan in its current form should fail. In this context, the Panel might conclude that the capacity identified amounted to no more than 55.000 per annum, making it impossible to deliver the identified housing need. This would amount to a rejection of the Plan. In that case we would be left with the current Plan – but would that be so bad?
So what happens now?
The core questions are about the likelihood and implications of Panel responses which could involve:
- simple acceptance;
- approval of the draft, subject to (large numbers?) of specific proposed amendments or requests for revision;
- approval subject to an ‘immediate’ review focused on some key policy fields/targets; or
- rejection – leaving the FALP in place, with a requirement for a new draft to fulfil certain requirements.
The first we argued should be highly unlikely, given the quality of the evidence – but there is always the concern that national government is looking for more and this may therefore be seen as the least-worst option by both the Panel and the GLA;
The second is a far more likely outcome – but one which raises considerable concerns, as the GLA then only has to respond, not to take notice of the suggested amendments;
The third is what happened last time – and all that got us was the new draft Plan;
So the rejection option is the most desirable if anything is to change. Core elements of such a decision would be not just that delivery is impossible but also that the evidence is not there with respect to identifying capacity.
There are additional challenges which make rejection a possible outcome: the lack of proper analysis of the impact on various inequality groups; the failure to consider spatial alternatives; viability – the topic yet to be discussed; and the extent to which communities may lose out particularly in terms of social housing.
In terms of influencing the outcome, the only direct means is through the EiP process – written evidence and participation in the Inquiry sessions. There appears to be no means of making substantive amendments – which would in any case require further consultation – so direct constructive criticism probably cannot be effective, unless the Plan is rejected.
To influence the outcome, and the Mayoral response to any of the possibilities, a wider debate than that taking place in the chamber has to be encouraged. At worst, as one participant said, ‘the plan is constructed around a set of political prejudices. It is fundamentally a fake plan which cannot work as it stands. Sometimes you need to go outside of the arena of the plan and convey these simple messages to the wider public’. Raising awareness of what is at stake is a pre-condition for developing a more coherent approach to planning for London. In this context, it was suggested that LSE London should take a lead in trying to get better media coverage of the issues. (We are working on it! Please help us spread the word).