Mind the Delivery Gap: From Brownfield drought to Green Belt growth, can the chasm of housing need be crossed in the New London Plan? An Iceni Briefing Note
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London’s next Plan must somehow scale delivery from c. 33 000 completions last year to a national requirement of 88 000 homes a year (880 000 in a decade). Delivery rates are likely to fall further, with just 6,000 starts in London over the past 12 monitoring months (according to MHCLG data) and some Boroughs not registering a single start in the last quarter.
The reasons behind this situation needs its own article, but includes a toxic cocktail of interest rates remaining high, increased construction costs, second staircase issues and the new building safety levy, amongst other things. All this means housing delivery needs to get from historic lows to unprecedented highs. This makes Green Belt release inevitable and in this article I will look at how this situation has come about, how much Green Belt land might be needed and where, as well as why the solutions in New London Plan may not deliver the desired outcome.
Brownfield Land: A Constrained Level of Supply
The current London Plan’s strategy of only bringing forward brownfield land is already way short of what is required for the existing target of 52,000 homes per annum and that’s before you start to even factor in the new target and the scale of current delivery issues. This is demonstarted by the following analysis:
400,000 brownfield plots delivered over the past 10 years – this is not even half the new target, but we won’t deliver even this number in the short term.
Viability is eroding: build cost inflation, second staircase fire rules and flat sales values have pushed starts down to just 6,000 in the past year. We haven’t even started to see the full
extent of this new drop off on delivery levels, but it will be well below 40,000 homes per annum.
Even repeating the last decade’s brownfield build out rate would still leave the Mayor with 440,000 additional homes to be found.
Clearly something very radical is needed to increase housing delivery on brownfield land in the Capital. The consultation draft talks about streamlining requirements and some limited flexibilities, but the GLA is not renowned for taking a laissez-faire approach, so any policy dilution may be limited.
Opportunity Areas (Oas): The Engine Is Stalling
Previously, Opportunity Areas were central to housing delivery in the Capital, but analysis of the data shows that we should be cautious about further growth from this source of housing:
OAs delivered around 50 % of all new homes over the past decade.
Many are now “mature” or stalled; ≈45,000 units in these OAs depend on the long deferred Crossrail 2.
Only 7–8 OAs are earmarked to expand or actually begin delivering in volume this cycle.
A drastic increase in supply from these sources without significant funding for new public transport infrastructure is unlikely.
Small Sites & Industrial Swaps: Helpful, but Not Heroic
There are other potential sources of housing delivery, but none of these are straightforward:
Small site policy has historically under performed and even rapid growth won’t bridge the gap. We saw in the last London Plan the dangers of relying too much on this source of housing, with the Inspectors cutting the housing target by 14,000 homes per annum due to concerns over deliverability.
Industrial land swaps proposed for Grey Belt land are welcomed and have significant potential, but won’t bridge the gap on their own and will take time to deliver/relocate existing businesses.
Green Belt: Welcome Shift, Flawed Execution
Given the issues with brownfield delivery the GLA has no option, but to release significant areas of Green Belt, but the proposed typology is high density flats with limited parking. When you are talking about the scale that is needed here, this is unlikely to be something the market can absorb.
Those looking for new homes in Outer London, often want a new house with a garden and their own parking space, particularly in Green Belt locations, which can be more peripheral than where we have traditional seen higher flatted densities of c. 100 dpa. Trying to deliver hundreds of thousands of flats is not a risk that developers will want to take, particularly given the current issues delivering flatted development in London.
The Enfield Local Plan Example
Experience of the emerging Enfield Local Plan shows why the GLA approach is so risky: outer London markets absorb family houses far more easily than car lite flats. Then there is the need for family affordable homes. Enfield Council’s information to potential Council housing applicants states that in some cases,
individuals may have to wait up to 15 years for a 3-bedroom houses. The emerging Enfield Local Plan, therefore, sought to release Green Belt land for a mix of flatted development and family houses.
TfL and the GLA have objected at the Local Plan Examination on the basis that the Green Belt releases should be solely flatted with much more limited car parking provision on the basis this would support more public transport infrastructure and deliver greater numbers.
It is expected that this is the approach that the GLA will adopt within the new London Plan, but clearly that may mean that the most reliable form of supply – greenfield sites, becomes undeliverable.
How Much Land Might Be Needed?
When you start to look at how much Green Belt housing might be needed you can see why (aside from the public transport arguments) a high density solution is so attractive.
Given the issues with brownfield land viability and the limited other options to increase supply, I would suggest we will be looking at around 300,000 homes over the plan period to come from the Green Belt – the figure may well be higher to meet the 880,000 home target, but let’s be generous and assume industrial land swaps can deliver at scale and the GLA can find a combination of policy changes that encourages brownfield land to return to where they were.
The table below shows how much land might therefore be required:
That’s before allocating space for relocated industry, renewable energy and data centres which will also be required under the New London Plan. Looking at a more granular level, there are 17 London Boroughs with Green Belt within them.
Of these, 6 have less than 700 hectares of Green Belt, with Barnet and Bromley having 6,000+ hectares. If you give each London Borough with Green Belt a proportionate split of that 300,000 homes, there are 6 Boroughs with more than 20,000 homes required in the Green Belt and a further 8 in the 10,000 - 20,000 range. As a reminder in Enfield, where 6,000 homes were proposed in the Green Belt, we have seen huge protests from local residents.
The actual distribution of housing will be led by trying to find the most sustainable locations and those Boroughs that decide to co-operate, but this gives you an idea of the scale of the political challenge we are looking at. Based on this, you can see why high density typologies are attractive to City Hall: they shrink the footprint of Green Belt release and temper political backlash. Therefore, the GLA faces an unenviable balancing act, but at the heart of any successful strategy must be deliverability to help solve London’s acute housing crisis.
Iceni is preparing representations for the Towards A New London Plan Consultation, if you would like to instruct us to produce something for you, please get in touch.
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