23.02.2024
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Late last year, the Secretary of State for Levelling Up, Housing and Communities, Michael Gove, appointed a panel of expert independent and impartial advisors to consider any amendments to the London Plan which may facilitate housing delivery on brownfield sites in London. Now the findings have been released DHA’s Jack Harley looks at what this means for new development proposals in the Capital.
The London Plan Review was undertaken by a panel of the “who’s who” of London Property Experts including the leading Barrister Christopher Katkowski KC. The report, which was published on 13th February 2024, makes for stark reading in terms of the problems London is facing within its housing delivery:
The report makes a big play on housing delivery in London being far more dependent on SME housebuilders than other regions of England, with small housebuilders accounting for 60% of new homes in the Capital between 2017/18 – 2019/20, in comparison to a typical range of 25-35% for other regions.
However, the challenges SME housebuilders face in delivering brownfield land is significant. As well as issues surrounding finance and recruiting labour and not being able to mitigate risks across a portfolio of sites, brownfield land often comes with its own added planning complexities, including contamination, ecological issues arising after sites are vacated (only to be exasperated within the introduction of BNG to small sites in April 2024) and disproportionately high CIL charging prices. The report clearly identified that SMEs are clearly impacted by delays or uncertainties in the planning system.
Findings
The panel concluded that the addition of a strong presumption in favour of residential development on brownfield sites to the London Plan would facilitate the delivery of the number of homes London needs and will apply to qualifying Local Planning Authorities where the net housing completions since 2019/20 has fallen below the cumulative annualised total of their ten-year target.
The presumption excludes sites that are in the Green Belt, Metropolitan Open Land or a Strategic Industrial Location and in the case of a designated heritage asset, the presumption only applies where any such harm is clearly outweighed by the public benefits of the proposal.
Where the presumption applies, Councils will be urged to grant permission as quickly as possible, unless the benefits of doing so would be significantly and demonstrably outweighed by any adverse impacts which would arise from not according to policies contained within the Plan.
Hope for the Housing Sector?
Michael Gove has publicly stated that he supports the recommendations of the report and considers the issues are not just related to London, but the rest of England, and intends to consult on changing two policies within the NPPF.
Whilst the presumption in favour of residential development on brownfield land is a welcome step forward to delivering the homes the Londoners desperately require, thought must be given to how this will translate into practise. Many brownfield sites in London are suited towards SME developers, but often come attached with their own issues. Opportunities do exist for SMEs to reduce the costs of delivering brownfield sites for residential development, such as applying for Vacant Building Credits, CIL relief or undertaking early viability studies to understand the cost implications of the development, however the planning system must ensure sites are delivered in a timely manner to reduce the financial burden on SME housebuilders.
DHA have extensive experience of unlocking the full potential of these sites. Should you need professional and honest advice, please contact Patrick Reedman and Jack Harley.
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