London Plan: thinking aloud

Warnings: this post (autumn 2018) is an informal attempt to collect my thoughts on the draft new London Plan. It is ‘thinking aloud’ in the sense that I’m tussling with the issues and shall continue to do so before I’m finished. It should not, therefore, be quoted or re-blogged please without cautions.  But if you have comments please do make them, either at the end of this post or on twitter (including @michaellondonsf) or by email m.edwards AT

This post draws heavily on discussions and documents of the last few years, mainly those generated in the network of community and activist groups, but also with students and staff at UCL, LSE and elsewhere. As and when any of this crystallises as submissions to the forthcoming Examination in Public I’ll acknowledge sources as far as possible but I hope people will forgive me for not naming them all in this rough text. The views expressed here are, of course, my own and not those of Just Space, the Highbury Group or (of course) UCL or the Bartlett.

I started this in mid-September, locking it with a password until I had added a lot more. A month later I realise that I’m not going to do that any time soon. So here it is as a fragment. More may follow….

A major weakness: the housing targets

At the heart of the London Plan is a fantasy to which most planners and politicians subscribe, or at least appear to do so while in public. (I haven’t found the right cliche for this: emperor’s clothes? straw men? angels dancing on pinheads? deckchairs on the Titanic? ostrich?)

The fantasy is that the Plan should demonstrate that its targets will meet the projected housing needs and demands within the Greater London boundary and without using Green Belt. All 3 mayors have welcomed projected population and employment growth as an unchallengeable axiom.  The Johnson plan assumed that maximising housing output would solve problems and the draft Khan plan is pretty similar, albeit with a bit more attention to (the upper end of) “affordability”.  The previous London Plan (Johnson’s last one, 2016 version) was only approved by the Inspector very reluctantly as he considered that the targets were too low to “meet need” and insisted that a new one be immediately prepared. The current draft is the result, with vastly increased housing targets.

Very few people believe that these total output targets will be met, any more than previous ones were. Even the mayor complains that more powers and money will be needed from central government. London’s demand pressures will continue to be unmet and people will force their way out into surrounding counties and towns, adding to demands and needs being generated locally there and spreading the affordability crises. The national government, such as it is, won’t acknowledge that because they abolished regional planning in 2010/11 and are dependent on what they assume to be NIMBY votes in the home counties. Crossrail 1 gives the lie to this ostrich approach, as does the campaign for Crossrail 2: both will/would enable a lot of growth of long-haul commuting into Greater London. How people in City Hall can keep a straight face maintaining these contradictory positions is a puzzle.

The Just Space submission to the London Plan consultation in February 2018 (p40) sums this up and continues:

In one sense London’s failure to meet its entire needs within its 
boundary does not matter. The Mayor needs to pretend that this is 
possible to satisfy the requirements of the NPPF. But London’s 
housing pressures have been spilling out to regions near and far for decades and will undoubtedly continue to do so, further propelled by Crossrail 1 and (if it is built) Crossrail 2.

But it does matter for two reasons: (i) the cost and environmental 
impact of all that extra travel is bad growth by any standard, and 
borne by people in all income groups, and (ii) the massive pressure 
exerted by the targets are a grave threat to good growth in London inthe ways outlined...

[‘good growth’ is a central objective of the mayor’s plan]
good beans

These targets for total housing output become the central imperative which has led to most of the adverse features of the Plan: the push for estate “regeneration” which demonstrably reduces the social housing stock, leads to many losses of green space and school recreation space, land price escalation (which displaces jobs, businesses and public services, reduces value for money in market housing and inflates the cost of providing non-profit housing). The targets are to be met, essentially, by intensification / densification of housing and of all other uses of land. This will be a bonanza for land owners, shrewd developers and incumbent owner-occupiers. The journalist Peter Bill, writing in Property Week said “‘Densification’ is the Big Idea. A prescription that will promptly jack up values on the right land.” Was he thinking of the Marx concept differential rent type II which comes from applying additional capital to land?

One of the remarkable features of this Plan is how little attention it pays to the land and property markets. This is a city increasingly subordinated to property market forces and a Plan which relies heavily on market processes for the implementation of its building programme. But there is precious little informed analysis of how the land and development markets actually work, either in the Plan or the Economic Evidence Base.
Property consultants contribute specialist studies on the office market and retailing but nowhere can I find any analysis of how the land market works. Nor have I come across land market people in GLA teams. This may help to explain why the Plan is so cavalier, taking enormous risks of inflating land prices.  My own personal evidence submitted to the panel is on just one such issue: the proposed deletion of the density matrix.
There are a few glimpses of unrelated thought in the Plan: one is the statement that land price escalation through developers bidding too much should be limited by a clear, firm, rule on “affordable” housing requirements (but only in Opportunity Areas, and no mention of clear firm rules on density) §4.6.13. Another glimpse is in the discussion of why large sites take so long to complete. On this issue there has been lots of research and it is generally agreed that developers on large sites ‘build out’ only at the rather slow rates which they judge will avoid flooding the local sales market and undermining prices. This has led to policies favouring Build-to-Rent where build-out rates are thought not to undermine profitability so much.
On the housing targets I’m glad to say there are likely to be strong critiques coming from authoritative experts as well as from Just Space: Duncan Bowie and the Highbury Group; Iain Gordon I hope (see the LSE London submission); Vincent Goodstadt and others (I hope) on inter-regional issues. The critics of targets to maximise total housing output very in the strength of their counter-proposals.  Essentially the strong argument is that the plan should concentrate on meeting the overwhelmingly urgent needs for low rent housing (council housing):  focusing resources there, minimising losses of inherited social housing, mobilising and expanding public land holdings and the non-commodity sectors. All are tricky things to do under this present government but more doable after an election.
On the Land market issues I haven’t yet seen much evidence except from the great surveyor Stephen Hill and the historian Michael Hebbert. The RTPI is rather limp on this and the RICS seems not to have commented on it at all! Whether the panel of inspectors can be persuaded to send the plan back as unsound remains to be seen.
That’s all for now. More on Thursday, I hope.

Author: Editors


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