I’ll be joining a discussion panel at a Future London event, organised jointly by the London Society and Knowledge Quarter, on May 5. We’ll be talking about the impact of emerging technologies on the built environment, and asking the question “what does the future of London’s built environment look like – and who is it built for?”
Tickets are available using the link below.
I’m honoured to have been asked to present this year’s annual lecture for the Planning Officers’ Society, on 15 April at De Morgan House, 57-58 Russell Square, London, WC1B 4HS.
I’ll be presenting RCKa’s recent research into suburban intensification, including our MHCLG-funded PropTech research into the housing capacity of London’s small sites, our work on the London Plan Small Sites Design Code, and the potential of repurposed golf courses to help deliver new homes and social infrastructure.
Tickets are available from the POS now.
https://www.planningofficers.org.uk/events/pos-annual-lecture—april-2026
In 2023, the G15 group of London’s biggest housing associations convened an emergency summit to address the rapidly worsening temporary accommodation crisis across the city. It was dubbed ‘Project 123’ in response to the grim statistic that, at the time, one in every 23 children in London was homeless.
A year later, the name had already become an anachronism: in just 12 months, the ratio had increased to one in 21 kids.
At the time of writing, London’s councils are spending a combined £5.5 million each and every day on housing families in temporary housing – much of it in B&Bs, emergency overnight accommodation and hotel rooms – up from £4 million a day a year ago. Large numbers of families have been forced to move to homes not in their own neighbourhoods, but scattered across the country; miles from the family and social networks on which they rely.
The cost of housing families in need is becoming an existential burden on already-stretched councils. But, behind the numbers, are a hundred thousand individual tragedies: toddlers living in damp and mouldy flats; youngsters forced to share rooms with parents and siblings; teenagers entering higher education having spent their entire school careers living in hotel rooms. The lives diminished and the opportunities squandered by our inability to build safe, affordable homes is a scandal and we should be ashamed that we have allowed it to happen.
In the first quarter of 2025, London built just 347 affordable homes. Even our private-sector housebuilding was pitiful: only 2,158 homes were built in the first half of this year, just 5 per cent of the government’s target for the city. The reasons for this shortfall are myriad. Following years of extraordinary construction inflation, in much of the country it’s impossible to build homes for anything less than they’re worth. The glacial pace of the Building Safety Regulator has replaced the planning system as the principal drag on large housing regeneration schemes.
Local authorities have a statutory duty to provide accommodation to families who present themselves as homeless. Councils are already under massive financial strain, but the extraordinary costs of temporary accommodation are mind-blowing. The annual cost is now nearly £3 billion – more than we’re spending on building new affordable homes. Much of this cash is pouring into the pockets of private landlords and hotel chains, despite much of the accommodation being substandard and often dangerous. We clearly need solutions to this crisis, quickly and efficiently. But, as we can’t build permanent homes, what else can we do?
During the early days of the Covid pandemic, the government introduced emergency planning powers that allowed health authorities to build hospitals and morgues without following the conventional and convoluted planning process. The nation deemed the situation sufficiently dire that the need to quickly deploy emergency infrastructure justified avoiding the bureaucracy that such buildings would be subject to in normal times.
As it turned out, these Nightingale Hospitals were not required, but they provide a useful example of how the state can step up to combat major health emergencies when necessary. The current homelessness crisis is no less of an emergency and requires a similarly vigorous response.
What London does not lack is space. There are car parks, stalled development sites, vacant plots and redundant scraps of land in abundance across the city. Each and every one could be used to help alleviate the tragedy of the homelessness crisis. With a bit of determination and creativity we could rapidly deploy new homes, at speed and at scale, on these sites within a few months. Consider for a moment the profound impact on the lives of thousands of Londoners that would make.
Many housing solutions already exist. In south-east London, modular specialist ZED PODS has installed 25 zero-carbon homes above a Bromley car park, retaining four out of five spaces below.
And in Cardiff, which has been for some time a pioneer of modular housing solutions, Wates and RSHP have deployed award-winning permanent houses using @Home’s timber-based, carbon-positive offsite construction system (the use of which is perversely prohibited in London, due to grant funding restrictions).
Over the past year, RCKa has been working on a prototype home that we believe could help deliver these objectives. Working with main contractor Wates and offsite specialist Rollalong, we have developed a high-quality home which can be installed anywhere in London in under two hours.
Compliant with space standards, providing a generous two- or three-bedroom apartment, this modular dwelling is entirely made in Rollalong’s Dorset factory and brought to site in three or four separate parts, which can be assembled for considerably less expense than a traditionally built home.
Despite the speed and cost benefits, this is in no way inferior to a permanent home. With a design life of more than 60 years, in some respects these dwellings are better than much of the new housing stock that has been built across the country in recent years. How many new-build homes do you know of that feature a 2.9m ceiling, as does ours? A deep knowledge of what goes into each module allows the materials to be recovered at end of life and the steel frame can be repurposed for other uses, such as classrooms, site accommodation, or even another home.
Some compromises are necessary to achieve these homes at that pace, however. The homes lack private external amenity space, so we will need exemplary placemaking and high-quality external space and play areas to compensate. Their location is vital, too. They will need to be close to public transport and local amenities, such as shops and schools. Community space should be included and the arrangement of the homes on the site will be vital to embed a sense of belonging, security and community.
The country has the technical capability to deliver these homes at scale, but the regulatory and policy environment needs to adapt. Permitted development regulations must be expanded, as they were during the pandemic, to allow us to deploy meanwhile homes without the inherent complexities of full planning permission. Inherent in this are dimensional parameters which should protect neighbouring properties, and appropriate locations will need to be identified close to social infrastructure and public transport. Councils need to adopt progressive procurement too, encouraging direct awards and comparing cost submissions not between different bidders, but rather with the amounts currently being squandered on hotels and private landlords.
The pandemic was brought to an end when the pharmaceutical industry mobilised to deliver a vaccine in a fraction of the normal time, and this subsequently led to a flurry of innovative life-changing therapies in other areas of medicine. In a similar way, a co-ordinated national strategy to industrialise housing could address the urgent need for emergency accommodation while building a robust manufacturing sector which is prepped to deliver the permanent homes the government has committed to in the coming years.
Over 130,000 households spent last night in temporary accommodation, up by 14,000 since last year. We have all the tools we need to put this right. There’s no excuse for us not to use them.
This article was published in the Architects’ Journal in December 2026.
London’s suburbs, which Sir John Betjeman famously called “the home of the gnome” half a century ago, have become the hunting ground of the SUV. These hulking death machines dominate the streets and their presence is a blight on our neighbourhoods.
This is not something we collectively agreed to; it’s the product of personal choice, inadequate regulation and cheap finance.
In 1973 the poet laureate was conflicted in his disdain for the loss of the countryside to suburban expansion, while also celebrating the value of the commonplace to the “ordinary citizen”. Betjeman could never have anticipated the arrival of the Personal Contract Purchase.
The argument goes that car ownership is a manifestation of personal freedom, yet this liberty is desperately dull. Fully 70% of private vehicles sold in 2024 were grey, white, black or silver.
One by one, the streets become increasingly achromatic: white cars, white homes – the coral bleaching of our towns and cities
We see the same in our houses too: the depressing prevalence of house-flipping, where developers buy up characterful but shabby properties and expunge any remnants of joy by wrapping them in clinical white insulated render, and swap timber sash windows with anthracite grey aluminium. One by one, the streets become increasingly achromatic: white cars, white homes – the coral bleaching of our towns and cities.
Some of this is driven by sales conventions: grey windows shift more easily than green. Part L requires a new thermal envelope and crisp white render is an easy sell. Increasingly prescriptive space standards demand a precise number of rooms of a particular size, and build costs make it impossible to provide any more than the bare minimum. Like pebbles in the ocean, the churning of the regulatory tide softens every hard edge into vapid uniformity.
Last week a draft replacement National Planning Policy Framework (NPPF) appeared, correctly diagnosing that the simple division between major and minor applications with a threshold of 10 homes was anachronous. A new category – medium – is proposed, capturing schemes with 10 or more dwellings, but fewer than 50, with an accompanying reduction in the burden on applicants and a scheme of delegation to elude incalcitrant planning committees. This is welcome, but also a missed opportunity to add a further category covering single family homes.
Since its introduction in 2012, the NPPF has included a specific allowance for single houses in rural areas that are “truly outstanding” where they would otherwise be refused. Oligarchs, hedge fund managers and wealthy actor types are well-served, all able to afford the world’s most talented designers (or the most expensive planning lawyers) to smooth the path to constructing gaudy palazzi or sleek modernist mansions in the countryside. The new NPPF retains it.
It is not right that there is no equivalent provision for urban areas, precisely where we should be encouraging new homes to be built. A new category of development application is needed which enables individuals or families to buy up scraps of land and transform them into homes that respond to their individual needs and personal tastes.
Maintaining the alliterative terminology, the introduction of a new micro classification for new houses should remove all of the conventional planning requirements and impose just dimensional parameters to ensure limited impact on neighbours: no taller than the highest point of an immediate neighbour, perhaps; no closer to the road than the front face of an adjoining property; remaining outside a 45-degree angle drawn from the primary window serving an existing habitable room.
In line with the requirement to make the best use of land, this should impose a maximum site size of, say, 200sqm, but beyond that the Building Regulations would be enough to ensure that the dwelling is safe, secure, well ventilated, warm, sustainable and accessible.
As for space standards? Forget them. Japan has demonstrated how a talented architect can squeeze exquisite homes from the most preposterous of plots when freed from the constraints of a suite of housing standards that assume every family unit falls neatly into normative expectations.
Automatic permission, even within spatial constraints, would inevitably lead to some localised horrors, but the upside would be a parallel wave of surprise and joy sprinkled across the suburbs
Not everyone adheres to the conventions expected of them by government decree, nor does everyone desire to live in a standard home. Extended and non-nuclear families are poorly catered for by the NDSS, and the demographic target for a two-bed, four-person flat is surely so niche that their prevalence speaks more to our failure to build proper homes than it reflects a genuine need.
A micro planning category, freeing individual houses from the constraints of the planning system, save from the obvious safeguards needed to protect the amenity of immediate neighbours and important heritage, would – at the very least – allow families to build the homes they really need. Within conservation areas, new development must “preserve” or “enhance”. It follows that, outside of them, character should be free to evolve and adapt.
“In-keeping”, “subservient” and “sympathetic” are the last refuge of the chronically unimaginative. Let’s excise them from the lexicon.
For sure, automatic permission, even within spatial constraints, would inevitably lead to some localised horrors, but the upside would be a parallel wave of surprise and joy sprinkled across the suburbs. And, let’s be honest – can we really claim that the current planning system is effective at preventing the most egregious designs? At best, it drives us inexorably towards housing homogeneity.
It is time to loosen up. As Hannes Coudenys, founder of Ugly Belgian Houses, a website dedicated to poking gentle fun at the peculiar aesthetic choices of Flemish self-builders, said: “It’s better to be ugly than to be boring.” Who are we to argue?
This article was first published in Building Design.
With revisions to the National Planning Policy Framework complete, and clear parameters for the strategic release of green belt now established, the government is rightly turning its attention to the plight of SME developers which have yet to benefit from planning reform but perhaps have the most significant part to play in helping to deliver the 1.5m homes promised in Labour’s manifesto.
The collapse in SME development in recent decades has been striking, with diminishing diversity and mediocre design and poor construction quality now a prevailing characteristic of the new-build housing market. According to government statistics, by 2022 a quarter of new homes were being delivered by just three plc developers, and nearly half of them by the top ten. In 2020 SME developers were providing just 10% of the nation’s homes, down from 40% in the 1980s. These figures will not have improved in more recent years.
For SME developers, and especially those operating at the small end of the market, planning remains the most significant barrier to growth. Although the risk of refusal remains a constant concern, it is more often than not the inevitable delays to decision-making that can quickly turn a marginal scheme into an unviable one. Delays cost money, as small developers are rarely flush with cash and often borrow money to acquire land at higher rates than plc housebuilders, which means interest on the debt starts accruing immediately. All of this could be planned for and factored into investment decisions were the timescales predicable, but according to research by planning consultancy Lichfields, in 2024, just 36% of major planning applications (those comprising ten or more homes) were determined in less than a year. This figure is a remarkable change from ten years earlier, when 78% of major applications were decided in this time. The statutory timescale for determination is 13 weeks.
The cost of acquiring land is usually, by some margin, the largest financial outlay. Nevertheless, professional services, surveys and application fees can quickly add up. The number of reports and surveys required to accompany planning applications (“validation requirements”) have increased dramatically over time. This has two effects: firstly, the cost of commissioning these documents is significant. Even for a relatively modest application, the cost can run into tens, or hundreds of thousands of pounds. Secondly, by making the validation process more complex and uncertain, the risk of delays between submission and the case officer even looking at an application can be significant. The slightest error in documentation, or omission of a report, can result in additional cost as the statutory eight- or thirteen-week determination period cannot commence until an application has been made “valid” and assigned to a case officer.
The number and type of reports required to accompany a planning application are the responsibility of the local planning authority, although there is a mandatory national requirement which comprises just the application form, Design and Access Statement, location plan, ownership certificates and fee. The LPA can use a “local list” to add a plethora of additional requirements depending on the type of development. For a recent scheme for 21 flats in south London, we were asked to provide an aviation impact assessment, TV and radio reception impact assessment, construction logistics management plan, microclimate wind assessment, agent of change assessment and a public art strategy, among the more than 40 items required to accompany our submission. Each one of these requires a separate consultant to be engaged, managed, and paid.
This is a preposterous amount of work to undertake at pre-planning stage when even the principle of development might remain undetermined. Many of these things should not be required at all – energy performance and safety requirements are set out in the Building Regulations, for example – but even those that could reasonably be the concern of planners should be attached to a planning consent as conditions, rather than required upfront.
The front-loading of the validation checklist might be an unintended consequence of the 2016 Neighbourhood Planning Bill which placed restrictions on the number of conditions that could be attached to a planning consent. To forestall development, too many LPAs have instead shifted these requirements to the beginning of the process, rather than scrapping them altogether.
Fire safety is dealt with Part B of the Building Regulations, compliance with which is mandatory for all development. A building which does not meet these regulations cannot be occupied, so why require a fire statement in addition to this as part of the planning process when it falls outside the scope of the Building Safety Act? While the intention might seem sound, the reality is that a completed building will rarely be assessed by planning compliance officers to ensure that it meets with the approved drawings.
Likewise, environmental performance. Requiring enhancements above the level described within the national Building Regulations is unnecessary. This isn’t to diminish the importance of sustainability initiatives, but their inclusion within a planning application should be up to the applicant to determine and form part of the “on balance” decision made by planning authorities, having weighed up the relative merits of the scheme.
There is no reason why all planning validation requirements should not be set at national level. Radio waves do not behave differently between Bromley and Barnet; the good people of Havering have no less of an appreciation of public art than they do in Hammersmith.
The government’s recognition that the demands on SME developers are far different from those of the volume housebuilders, and that these entities operate within entirely different constraints, is welcome. This presents the opportunity to align validation requirements with these categories of development. Consistent with the alliterative naming convention, a new “micro” development category for sites with an area of less than 100sqm or providing a single dwelling should be introduced, with nationally determined validation list and design parameters and nothing else. This would unleash a wave of creativity and innovation, providing self-builders and small-scale developers with the certainty to bring forward new infill homes in sustainable locations.
Minor applications (those between two and nine dwellings) need not be accompanied by much more than this: plans, elevations, sections, a Design & Access Statement and daylight and sunlight report should be enough to determine whether an application meets the requirements of local policy. A prohibition on locally set affordable housing “levies” should be part of this reform, as these undermines the national threshold intended to encourage small site development. As with proposed changes to Biodiversity Net Gain requirements, statements of community engagement, open space assessments and the like are unnecessary at this scale and place an unreasonable burden on prospective development. In all but exceptional circumstances the provision of new homes far outweighs any negative impact of development.
There is no reason why validation requirements should not be set entirely at national level, and at a level commensurate with the size of the development being proposed. SME developers are desperate to help the government deliver on its housing ambitions. Raising the barriers will help them do it.
This article was published in the Pocket Living publication “The Road to a Proportionate System” in September 2025.
In May this year, the government launched a consultation on the potential sub-division of planning application categories. Up to now, full planning applications fell into one of two classifications: minor, and major, with the threshold for those schemes falling into one or the other being the net addition of 10 homes. Any less than this, you’d be a minor application; any more, a major—regardless of whether this involved the creation of 10 homes or 1,000. This has consequences in the level of information required to validate the application and the time taken to determine it: minor applications should receive an outcome in no more than eight weeks from the point of validation, but for major schemes this rises to 13 (although very few applications are ever actually determined within this period).
The proposed bands retain the minor category at between 1 and 9 inclusive, but introduces a new medium definition of between 10 and 49 homes, with the major classification now including those schemes yielding more than 50 dwellings.
This makes a lot of sense, although perhaps it doesn’t go far enough. Applications for 50 homes should not be treated in the same way as those for 500, so there should be a further division of the major application type, probably around the 250-home mark.
But what about at the smaller scale? SME developers are likely to be the ones building the majority of homes within the minor category, but community builders, councils and housing associations also have a part to play. But what about those new homes for private clients; the boutique developers who have managed to acquire a tiny scrap of land in a fashionable area, or the families who want to carve out a sliver of their back garden in order to build a home for their kids? Single family homes are an opportunity for creativity and innovation, as well as being a vital tool in our attempt to intensify our towns and cities. Many well-known architects have cut their teeth on crafty infill projects that squeeze delightful and spacious homes on the most constrained urban sites.
The National Planning Policy Framework (NPPF) has, for some time, included a clause which allows new homes to be built in the countryside provided that certain criteria are met. The most recent iteration of the NPPF encapsulates this objective in paragraph 84, which states that “…decisions should avoid the development of isolated homes in the countryside unless one or more of the following circumstances apply:”
e) the design is of exceptional quality, in that it:
Extract from paragraph 84, National Planning Policy Framework, December 2025
i. is truly outstanding, reflecting the highest standards in architecture, and would help to raise standards of design more generally in rural areas; and
ii. would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.
This is great for wealthy actors, hedge fund managers and oligarchs, but why should they have all the fun?
I think it’s time to introduce a similar policy to allow the development of single homes in urban areas, free from the many restrictive planning constraints which consistently make small-scale development costly and unpredictable. In keeping with the alliterative minor/medium/major naming convention, we need a new category: micro.
Here’s my proposal:
Within urban and suburban areas, but outside conservation areas and not within the curtilage of a statutorily listed building, it should be possible to build a new house with automatic planning permission, provided that the external volume of the house fits within a set of maximum parameters determined by the outlook of neighbouring windows and private amenity space. Applications must demonstrate only how they respond to a) flood risk, b) highways and transport requirements, c) waste and recycling provision, and d) risk of contamination.
The dimensional parameters might include the following limitations:
This is how these policies might appear in three dimensions, using a street infill site type:
External appearance should be entirely down to the applicant: local character does not have to be “adhered to” or “respected”. I have no say in the colour or model of the car my neighbour chooses to park outside the front of their house; nor should they have a say in what I want my home to look like.
Building Regulations compliance is distinct from planning, so each home delivered this way will need to confirm to minimum levels of structural integrity and feature basic amenities, such as a toilet. It’s unlikely a mortgage lender is going to let self-builders create anything too outlandish.
Beyond these constraints, there should be no requirement to adhere to local planning policies, including space standards. You want to create a voluminous home consisting of a single room? No problem.
Not every site will allow a house to be built using these parameters, but then there’s always the normal planning route to fall back on.
Of course, there’s a risk that such a permissive policy could result in some dreadful interventions, but on the other hand, it could also unleash a wave of creative and extraordinary homes to meet a range of different needs. And can we really say that the planning policies of the last century has allowed only buildings of exceptional quality to be built? I don’t think so.
Existing planning policies are necessarily prescriptive to ensure that rogue developers don’t throw together exploitative shoeboxes that can’t meet the basic standards necessary for a comfortable existence, but these requirements also assume that everyone neatly slots into a conventional family unit. What about the extended multi-generational families; co-habiting friends happy to share a living room, but not a bathroom; or the retired couple who don’t need the space afforded by their large family home, but who have a lifetime of possessions that can’t be squeezed into a one-bed flat?
Giving almost complete flexibility to design an entirely bespoke houses—free from planning conventions and context—would allow families to create homes to suit their specific needs, and encourage architects to come up with innovative ways to craft extraordinary homes from the most unlikely of plots: witness the brilliance of the Japanese “jutaku” houses which exploit tiny urban sites to deliver some of the world’s most striking architecture. This would have the added benefit of adding new layers of interest and surprise into otherwise homogenous residential neighbourhoods.
There are risks, of course: many planning applications are already of extremely low quality, with scant attention paid to even the most basic tenets of good design. But this, I think, is a risk worth taking. Any damage would be limited, and local.
What policy levers might be pulled to achieve it? There are several options. The first might be the use of a National Development Management Policy (NDMP). An NDMP allows the government to establish a nationwide planning policy that overrides local plans, although planning permission would need to be sought in the usual way. A second route is through a new class of permitted development within the GDPO (General Permitted Development Order). This would allow homes to be built without the need to secure planning permission, instead seeking “prior approval” to ensure that (for example) the new home considers flood risk, contamination, impact on transport and highways, and the means through which to dispose of waste and recycling. Beyond that, anything goes. The latter option would be the most credible, but the most controversial too.
The dream of designing and building one’s own home should not be out of the reach of ordinary people, and at the same time we desperately need to fill the forgotten gaps and vacant plots of our cities with as many homes as we can. Single family houses provide an opportunity for innovation and the possibility of people owning a home that is designed specifically for their needs. We should let them get on with it.
Inexplicably, allotments have been in the news this week. Responding to a parliamentary question raised by Kevin Hollingrake, the government confirmed that Angela Rayner had approved the disposal of eight allotments by the local authorities that own them.
“Is this government going to put the nail in the coffin of the joy of digging ground for potatoes on a cold, wet February Sunday afternoon?” pondered Jeremy Corbyn in a letter to the famously left-leaning Telegraph. Of course, Angela Rayner didn’t instruct these sales, but under the Allotments Act of 1925, has the final say on whether their disposal can take place.
The Ordnance Survey’s green space dataset counts around 150,000 allotments in the UK, although reports elsewhere suggest there’s more than double this figure. Clearly the loss of eight of these is a tiny fraction of the total amount, but could the release of a few more redundant growing spaces really be a practical means to build new homes – particularly in urban areas where the need is greatest?
London alone has around 770 allotments across 31 boroughs. Only the City of London and Kensington & Chelsea are without at least one allotment within their boundary.
By and large, allotments don’t take up much space: just shy of 1,000 hectares in total. That’s about one third of one percent of London’s total area.
The largest single allotment in the city is the Fuel Land Allotments in Finchley, Barnet, which is around 11.5 hectares. It’s owned by The Finchley Charities, a small housing association that provides housing for elderly people. Its foreboding steel fence that faces the Great North Road conceals a vast landscape of neatly parallel plots extending into the distance.
Coming a close second is the Addiscombe, Woodside & Shirley Leisure Gardens, a privately-owned allotment society in Croydon with a total area of around 10.5 hectares.
These are far from the norm. The median size of London’s allotments is a modest three-quarters of a hectare. Barnet, home to London’s largest allotment, also has the most space dedicated to them, with just over 100 hectares of growing space.
Haringey has the largest proportion of its area occupied by allotments, but even then it’s only a modest 1.4%.
Their size pales into insignificance when compared to the city’s golf courses, however. The amount of space dedicated to hitting a little white ball around is the same as a mid-sized borough; together allotments occupy about the same area as Richmond Park.
Even if we were to build homes across every plot in the capital, how many homes might result? At a reasonably dense 50 dwellings per hectare, replacing peas with people would yield about 48,000 homes—just six months’ supply. This perhaps is a battle that even the developer-friendly Labour government would be unwise to fight.
Losing local authority land to housing isn’t the whole story, however. While allotments provide vital outside space for many people who have none at home, waiting lists in many parts of London are decades long, and because of this, favour long-term residents. There are many examples of owners objecting to development adjacent to their plots, in some of the best located and most appropriate locations for new homes. Anecdotally, many of those continuing to enjoy the benefit of allotments for many years no longer live in the same borough – or even the same city – as their discounted growing plot. One can imagine how a young person who is struggling to find a home might consider it unfair that publicly-owned but privately-managed space is rented at low cost to those who are no longer residents of the borough.
This week’s hoo-ha around the disposal of a few surplus allotments is likely to quickly fade. There are far easier—are considerably larger—locations for housing than allotments. The capital’s comedic carrots and amusing marrows are safe, for now.
Five years ago, during the early months of the pandemic lockdown, I taught myself how to use the open-source mapping software QGIS, applying my new-found skills to locating and measuring the golf courses which pepper London’s suburbs. I’d suspected that the area of London occupied by golf was large, but I hadn’t anticipated it being as much as a mid-sized borough.
What I wanted to know was: given the huge area of land dedicated to this single use, how many homes might be built if we were to allocate some of this space for development.
In May this year, the Mayor of London published his long-awaited outline proposals for how the city might evolve over the coming years. “Towards a New London Plan” is his consultation on the the future of the London Plan, the spatial policy plan for London.
In my article I’d argued that, on the whole, golf courses fail to meet the criteria for Metropolitan Open Land; a specific planning designation within the London Plan, designed to protect open space from development, effectively benefiting from the same protections as green belt. A key criterium for MOL is that the open space in question must “serve either the whole or significant parts of London”. While it’s the case that some courses have public paths within them, woe betide anyone who fancies a Saturday afternoon picnic on the fairway of the ninth. As for biodiversity: well, golf courses are largely monocultural with sterile soil. Research from abroad has even suggested that living close to a golf course can give you Parkinson’s Disease.
It was a welcome surprise to see the Towards a New London Plan agreeing with my analysis. The chapter covering MOL included the following text (my emphasis):
2.11 Metropolitan Open Land
The Mayor will continue to give protection to MOL given its vital role for Londoners and providing a liveable city as London grows. However, some areas of MOL, such as certain golf courses are not accessible to the wider public and have limited biodiversity value. This undermines the purpose of the designation. These areas could be assessed to understand whether they should be released from MOL. They may be able to help to meet London’s housing and accessible open space provision (for example opening up strategic new open spaces accessible to Londoners alongside new homes). At the same time, they could improve biodiversity through landscape-led redevelopment. Clearly there are key issues to explore. For example, could golf courses with Sites of Importance for Nature Conservation (SINC) designations be released (with compensatory biodiversity uplift), and if so, in what circumstances.
Towards a New London Plan, Mayor of London, May 2025
Later in the document, the following paragraph expands on this point, suggesting that some courses could be released for genuine public benefit.
Given the challenging housing target, there may be some very specific circumstances where certain MOL, such as golf courses, could be considered for release for housing. These are often not publicly accessible and offer limited biodiversity value. They could also provide new accessible open spaces and parks alongside housing and other development.
Towards a New London Plan, Mayor of London, May 2025
In fact, since I first conducted my research, Ealing Council did exactly this, having converted Perivale Golf Course into Pear Tree Park.
40 of 93 of London’s golf courses fall within the designation of Metropolitan Open Land, totalling 1,578 hectares. In simple terms, that’s a little larger than the borough of Islington, which has a population of nearly 250,000 people.
Building at an approximate gross density of 50dph (an average for London, equivalent to compact Victorian terraced streets), building on all of the city’s MOL golf courses would yield some 79,000 homes. I don’t think London’s golfers would thank us for that. Besides which, many of the city’s courses are not in easy reach of public transport or high streets – two things new housing will likely need access to. So if we exclude those bits of the courses that are less convenient to get to, we arrive at around 625ha of land. That’s still 31,150 homes – not to be sniffed at, but it’s still only a third of London’s annual target. The graph below shows the accessible areas of those golf courses protected by Metropolitan Open Land, and within 800m of a station or high street (a useful policy definition set out in H2 of the London Plan).
Nevertheless, this is a number of homes worth having. Given that the total area of golf courses in London is well over four thousand hectares, losing just 17% of this for housing doesn’t seem too much of an ask.
The proposed changes to the London Plan are heading in the right direction.
Planning is all about compromises. It nigh on impossible for any scheme to be fully compliant with every policy: a presumption against height might limit the amount of affordable homes that can be provided; accepting a taller building might mean that the garden of a neighbouring house is overshadowed at certain times of the day.
The purpose of planning is to determine which of these criteria has the most importance – one person’s right to enjoy their garden might be diminished, but the lives of future occupants of the flats next door could be greatly enhanced. It’s the job of the planning system to distil these competing objectives into a binary outcome.
Often the responsibility for making such a call falls on the planning case officer, whose job it is to compare the application against the local, regional and national planning policies and decide whether it should be approved or refused. In particularly contentious cases—where there are a large number of objectors, for example, or for a large development—the decision will often be made by a planning committee consisting of elected politicians, many of whom discharge their responsibilities with diligence and care. Often, though, smaller applications are left to be determined by officers without the appropriate experience and confidence to reach a considered and reasonable conclusion.
The issue of balancing competing demands can be particularly challenging when considering applications for housing on smaller developments. Because of their size, such schemes are often handed over to more junior officers. They also tend to be more complex, often close to existing homes and squeezing the most out of fiddly sites. An aggrieved neighbour might be particularly vocal about losing an extra hour of sunlight on their prized carrots, or simply dislike the idea of an open plot of land they’ve looked across for years being occupied by a new home. How is a local authority officer supposed to determine which of the multitude of competing policies takes precedence? And how can they turn this information into a single binary decision?
I was intrigued by an article in The Economist newspaper (and an accompanying methodology) which described a system for weighing up competing priorities in a fair and transparent manner. A set of questions is presented, with a single pool of points that can be assigned to a positive or negative response to each. As each preference is made, the pool depletes; but expressing a stronger opinion for each challenge reduces the remaining points by a square factor. So, if you have a mild concern about the potential impact on neighbouring amenity of a new development, you can use a single point to express this. If you have a significant concern a second vote will cost you not two points, but four—two squared. Expressing a major concern would then diminish the available points by a further seven (16 less the nine you’ve already spent), and so on. You continue until there are no points remaining or it’s not possible to assign them to any further questions. Allocating no points to one question simply means that the assessor believes there the policy implication is neutral.
Using a standard set of topics which planning officers usually assess an application against it’s possible to construct a series of positive and negative questions against which an application is assessed. This allows the different aspects of a scheme to be weighed up against one another: a less-than-substantial harm to a conservation area might be mitigated by an outstanding design, for example.
The following application is a crude example of how such a system might work.
Since taking power last summer, the government’s barrage of announcements around tackling Britain’s sclerotic planning system, and how it intends to ‘back the builders, not the blockers’, has been head-spinning to say the least.
Bold changes to the National Planning Policy Framework were adopted, as promised, in December; there has been no let-up during the post-festive fug. Since the beginning of 2025, we have witnessed a flurry of striking reforms, including changes to planning committees, reforms to judicial reviews, brownfield passports, development around stations, and a slew of individual approvals for data centres, solar farms and power lines.
There can be no doubt that, when it comes to critical national infrastructure, the current way of doing things doesn’t really work. We have failed to complete a single new reservoir in more than 30 years, yet water scarcity is often a justification for refusing new homes.
Planning is not solely responsible, but doubtless the delay and uncertainty of Britain’s discretionary system is a contributing factor: the cost of the Lower Thames Crossing application alone has exceeded £300 million; you could build a mile-long tunnel for roughly the same amount.
Change is necessary: we need renewable energy, and we need pylons to move it around. We need water piped to where people live. This will involve negotiations and compromises – but finally it’s a matter of how, not if, it happens.
Despite this, things aren’t so straightforward when it comes to housing. New towns, with the best will in the world, are 10 to 15 years away. Green belt will be tangled up for the next half-decade.
The immediate opportunity is the rapid intensification of our towns and cities, but we’ll need an equally ambitious approach. Perhaps pre-approved design codes for suburban corners? Minimum building heights close to stations? A national policy that recognises character is not immutable, and change is both inevitable and necessary? Such bold thinking is required. After all, housing is infrastructure too.
The next parliament is not that far away. It’s time to get building.
This article was originally published in the RIBA Journal in March 2025.
At the end of 2024 London boroughs were spending £4m each and every day on housing families in temporary accommodation—nearly £1.5bn every year. One in 23 of London’s children are growing up homeless, many in substandard converted offices, mouldy privately-rented flats, or overcrowded hotel rooms without private kitchens. Many young adults have spent their entire primary and secondary education living in precarious circumstances, their student rooms now providing the most stable accommodation they can remember.
Aside from the extraordinary financial implications of the worsening housing crisis, the human cost is profound. At a time when public finances are under a greater strain than they have been in generations, scandalous sums of money are cascading into the pockets of private landlords and hoteliers. Inadequate and unsafe housing leads to poor health outcomes, putting a strain on an already overstretched NHS—but the real tragedy is the lives that are diminished, the opportunities thwarted, and the potential of future generations squandered. The homelessness crisis is a national emergency and a stain on our country. We must take bold steps to confront it.
During the COVID 19 pandemic, the country mobilised to build a series of temporary hospitals at speed. The government adopted emergency measures that allowed the bypassing of conventional planning processes so that health needs could be prioritised. The public and private sector came together to quickly design, install and operate the so-called Nightingale Hospitals under emergency amendments to the Town & Country Planning Act which granted specified healthcare bodies permitted development powers to construct or convert buildings for a range of uses including hospitals, mortuaries and testing units, whilst avoiding the need for expensive, time-consuming planning applications. It was a remarkable response.
A similarly ambitious approach is now required to address the housing crisis. The public emergency of substandard temporary accommodation deserves to be treated with the same urgency as the pandemic. In the end the Nightingale Hospitals were not required—the housing emergency is real and present, and has similarly profound long-term implications.
Permitted development rights should be extended to allow the installation of temporary accommodation on vacant plots of land in appropriate locations, with a time limit of no more than five years before permanent development or its return to a pristine state. Naturally, safeguards must be included to ensure that the homes are of a sufficient standard: compliance with Building Regulations to ensure thermal comfort, accessibility and safety; and broad compliance with Nationally Described Space Standards, although perhaps a concession should be made to allow dwellings 85% of the total required area to optimise the use of land.
Homes delivered under this method should have easy access to the public transport network, and so located no more than 800m from a station; also close to local amenities such as high streets and social infrastructure. To avoid large numbers of people in need being placed in areas already suffering from high levels of deprivation, an impact assessment should be carried out to understand how these temporary homes might affect the wellbeing of existing residents. These powers could also include an upper limit on the number of bed spaces within a single location: 250 would seem reasonable. Dimensional parameters should also be established: a similar Class TA Permitted Development Right already allows the Crown to erect certain structures within closed defence sites provided that they are below a height threshold and a sufficient distance from neighbouring homes.
Importantly, the homes should be demountable and capable of being relocated elsewhere with ease. This will ensure that a five-year lifespan is achievable and that the homes are designed and manufactured with appropriate quality and robustness. This would provide a boost to the UK’s beleaguered modular manufacturing industry too.
Consideration should also be given to the siting of new accommodation, with the provision of external amenity space and play equipment ensuring that these temporary developments meet the needs of the children and young people who will live there.
There is no reason whatsoever that the quality of these homes should be in any way compromised: there would be little sense in moving families from precarious lodgings to overcrowded and substandard accommodation elsewhere.
There are thousands of hectares of vacant land that could be temporarily repurposed for this use: surface car parks next to suburban train stations, disused golf courses, council estates awaiting regeneration and brownfield land awaiting permanent development which is delayed due to uncertainty over viability or forming part of a later phase of regeneration.
In the case of the homelessness crisis, it is likely that councils will be the ones applying to themselves for permission, but given the nature of the emergency it cannot be allowed that unnecessary interference from external interests can delay or otherwise frustrate the construction of these dwellings, provided that they meet the pre-determined criteria sketched out above. Limited and specific permitted development rules would help achieve this.
Work already undertaken in this area has demonstrated that it is possible to install temporary homes at between half and two-thirds of the cost of conventional affordable housing, and the relocatable nature of the modules enables the homes to be either repurposed elsewhere as permanent homes or to continue their life providing emergency accommodation for those in need. Councils across the country have already demonstrated how, with the appropriate supply chain and procurement processes in place, public sector temporary housing can be comfortable, safe and cost-effective. We should learn from these lessons and apply them at scale. The potential cost savings to the public purse are also vast: the typical payback for a temporary dwelling can be as little as a year.
We owe it to our fellow citizens who are not adequately housed to provide them with a safe and secure home in which to raise their children. Their needs should take precedence over those who already benefit from a place to live. Time-limited permitted development powers could provide a way.
This article was featured as part of a Homes for Britain policy pamphlet “Brownfield Planning Passports: Fast-Track to Growth” published on 10 February 2025.
The planning system is a curious thing. On one hand, it’s a highly technocratic enterprise. Impenetrable reports, documents and surveys are interrogated by under-resourced and overworked planning officers with the solemn responsibility for weighing up thousands of pages of jargon against vague and frequently antediluvian policy.
On the other, there’s ‘planning by vibes’ – the approach adopted by those with limited interest or understanding of how the planning system works or what it’s actually for; those who navigate their way through this complex landscape by intuition and blind faith. Planning by vibes rejects procedure, policy and convention and instead defers to personal preference and peer pressure.
Planning committees tend to fall into one of these categories. While there are thousands of dedicated and knowledgeable councillors up and down the country who discharge their duties with gravity and grace, there are far too many who see their role as the last line of resistance against rapacious developers determined to lay waste to local character.
Since last year’s general election, there has been a flurry of policy announcements as the new government attempts to make good on its ambitious promise to build 1.5 million homes before the end of this parliament. A revision to the National Planning Policy Framework was published quickly in July and formally just before Christmas.Accompanying this announcement was a declaration of war on troublesome planning committees via a new Planning and Infrastructure Bill due out in the coming weeks.
Transparency in decision-making and, more critically, in the consequences of those verdicts, is a key part of the proposals. The consultation paper describes several examples of where refusals contrary to officers’ advice have cost taxpayers vast sums of money – and that’s leaving aside the emotional and economic burden of a nationwide shortage of homes. Were opponents of development aware of the financial impact of erroneous decisions, they might not be quite so keen to delegate their responsibilities to the Planning Inspectorate. Anything we can do to shine a light on this profligacy should be welcomed.
Mandatory training for planning committees seems like an obvious improvement. One wonders why individuals in positions of such influence shouldn’t already possess a rudimentary understanding of the nature of their responsibilities, and this will only impact those elected members who have not taken the time to acquaint themselves with the Town & Country Planning Act or, at the very least, the local policy they’re supposed to be assessing applications against.
Reforms to the mechanism through which officers decide some planning decisions (‘schemes of delegation’) are also long overdue. Currently, the number of objections an application receives (and the system is almost always tilted toward objection) determines whether it gets decided by the case officer or at planning committee. This threshold can be as little as just two or three.
Elevating this number significantly might help. Thousands of angry letters might raise eyebrows and get a mention in the local press, but when considered as a percentage of the total population of a district, these rarely translate into an overwhelming mandate for refusal.
There’s no limit on geography either, and anyone who has submitted an application in recent years will be familiar with objections submitted by those many kilometres – or even continents – away. Letters of support should have equal weight to those in opposition, too. In most cases, they don’t. Those in favour of building new homes need to be heard as clearly as those who are not.
Opponents of centralised planning reform will doubtless consider these suggestions as an affront to democracy, but they are nothing of the sort. There are few other areas of decision-making that are subject to local referendums with such nebulous protocols. The number of objections received in response to a planning application is no indication of its quality; nor, for that matter, compliance with policy. Once an application comes before a planning committee its fate should already have been decided and the decision should be a matter of procedure rather than determination.
This is why the government wants to return more power to officers to decide applications that already comply with the local plan or are on sites allocated for development within the local plan. Nobody is helped by a system which is often little more than a roll of the dice.
This isn’t to diminish the agency that communities should enjoy in setting the parameters for new development, be that housing, railways or solar farms. It is right that housing targets – as those for all infrastructure – are set at national level. Where they go and, to a degree, what they look like should indeed be in the hands of local people. But the time to engage with this is during the plan-making process, not every time an individual application comes forward.
Perhaps an understanding of the basics of planning should not be limited to just those sitting on committees, but form part of the national curriculum too. That way we might finally call time on ‘planning by vibes’ and instead focus our efforts on delivering the homes and infrastructure the country so desperately needs.
This article was published in the Architects’ Journal on 9 January 2025.
The 2023 Housing Delivery Test score for every English planning authority was published last week, and I’ve mapped the results to show those areas with the highest and lowest performance against their targets.
The southeast has, as expected, performed particularly poorly with several of the London boroughs falling below 50%. Of these, Lewisham is the worst, with a score of just 32% and a placement sixth from bottom in the national ranking. The highest score of all of the boroughs (with the exception of the City of London) is Croydon, with a score of 160%—although this is likely to diminish in the future now that its new local plan has been adopted, scrapping many of the progressive planning policies which enabled it to build more homes than any other borough bar Brent and Tower Hamlets.
The highest score in the country was Richmondshire, which managed a stonking score of 6,121% which seems extraordinary until one realises that significant overperformance was likely when its absolute housing target was a pitiful 24 homes: just one for every 5,500 hectares of land. It actually built nearly 1,500 homes in the three-year period from 2020-2023; not to be sniffed at, but hardly an exceptional amount considering its size. Richmondshire is no more: in 2023 it was absorbed into a new Unitary Authority covering North Yorkshire.
Here’s a scatter graph showing the Housing Delivery Test scores for all of London’s planning authorities, including the 33 boroughs, the City of London, and the two Mayoral Development Corporations.
And here’s the same graph but including all of England’s planning authorities.
The publication of the revised National Planning Policy Framework in December 2024 was accompanied by a new set of Housing Targets for each of England’s unitary, district and borough authorities.
Much has been made of the new targets by rural councils, claiming that these will require large areas of countryside will need to be “concreted over” to deliver the number of homes demanded of them. This is, of course, hyperbolic nonsense: the amount of land required is often a fraction of one percent of the total area of the council areas, even if this assumed that all the new homes were to be built on virgin land. In fact, most of the new homes will come from urban and suburban intensification.
For each authority in England, I’ve created a single map tile which demonstrates how much land would be needed to deliver the local housing targets were they built at a modest density of 40 dwellings per hectare (dph). Clearly in urban areas this figure would be significantly higher, and lower in rural regions; but sticking with a consistent density makes a comparison easier.
Here are all of the authorities in England and the number of new homes required per hectare needed to meet the new targets. As you’d expect, the highest concentration of homes is in London, with the Royal Borough of Kensington & Chelsea topping the league with a requirement to find 20 new homes per hectare (bearing in mind that many parts of outer London are already below this density, even consider existing homes).
Around England’s rural railway stations there is the capacity to build between 1m and 2m homes depending on where one sets an appropriate development density.
My own research has established this figure at around 1.2m homes, assuming development is constrained to just 10 minutes’ walk (approximately 800m) from a station, assuming a gross residential density of between 40 and 75 dwellings per hectare.
The eastern branch of the Thameslink railway franchise links London St Pancras (and beyond it, Brighton) to Cambridge, passing through Essex and the south Cambridgeshire countryside. The total journey time from Brighton to Cambridge takes just under two-and-a-half hours, with St Pancras the halfway point. Three quarters of an hour later the train arrives at the first of four rural stops: Ashwell & Morden, Meldreth, Shepreth and Foxton. In the middle of these sits the town of Royston (see map, below).
Foxton is just 12 minutes from Cambridge station; Ashwell & Morden 47 minutes from St Pancras and an hour from Kings Cross. These stations are extremely well connected, but serve a very low number of homes within the surrounding area.
In the year ending March 2023, Ashwell & Morden station had 140,000 passenger movements (entrances and exits) with just under a third of these in the direction of Cambridge.
Connections to the road network are also strong, with Meldreth, Shepreth and Foxton all located on, or close to, the A10, which links London to Cambridge. Ashwell & Morden is immediately adjacent to the A505, linking the M1, A1(M) and the M11.
Currently, Thameslink trains call at Ashwell & Morden and Royston, but Meldreth, Shepreth and Foxton are served by the Great Northern franchise, linking Cambridge to Kings Cross. The track is the same, and there is no reason why these two could not be consolidated into a single service. The proposed route for East West Rail also joins this line north of Foxton, with the potential to link these towns with Bedford and Oxford. It is also close to the new Biomedical Campus at Cambridge South, and the line passes through the new station being built there.
According to my research there is the potential for approximately 10,000 homes in the undeveloped land around Ashwell & Morden station alone. It is unencumbered by green belt designation nor is it covered by ecological land protections. The developable area around the station totals approximately 170ha within an 800m radius, and with an average density of just 60dph this would deliver more than 10,000 homes.
There is further potential for urban extensions to other villages along the line. Shepreth could accommodate 7,200 homes through a northern expansion of the settlement (the station itself separates the town from the countryside). 2,800 homes could be built through infill and enlargement of Meldreth.
Foxton straddles the boundary of Cambridge’s southern green belt yet has the capacity for 6,800 homes around a station that is largely surrounded by open fields. Together, the areas around these stations could accommodate at least 27,000 homes—considerably more, if the radius was expanded slightly further into the countryside.
The proposition becomes more attractive when one starts to think of these stations not as individual settlements but as a single entity. The potential journey time from Ashwell & Morden to Foxton is no longer than 16 minutes, meaning that a series of smaller towns, each with a population of some 40 to 50 thousand, could support significant new social infrastructure: several new primary schools in each location, with a new secondary school at Ashwell & Morden, and perhaps a second a Shepreth.
A new Development Corporation, structured along the railway line rather than around a single settlement, could coordinate physical and social infrastructure in the appropriate locations, and produce a masterplan and design codes to lock in placemaking and quality objectives. The Corporation would adopt planning powers to ensure that delivery and quality objectives are met. With the exception of a small part around Ashwell & Morden, all of these proposed settlement expansions fall within South Cambridgeshire District, simplifying planning powers.
The land either side of the track is mostly owned by Network Rail. With some creative thinking this could be exploited to provide cycleways linking the expanded settlements, supporting a transport modal shift away from car dependency.
Based on the assumptions set out above, the approximate capacity of each new or expanded settlement would be as follows:
| Station | Developable Area | Density at 60dph |
|---|---|---|
| Ashwell & Morden | 170ha | 10,200 homes |
| Meldreth | 47ha | 2,800 homes |
| Shepreth | 120ha | 7,200 homes |
| Foxton | 113ha | 6,800 homes |
| Total | 450ha | 27,000 homes |
There are many other examples of such stations along the railway lines that extend out from our cities where this approach to Development Corporations could be adopted too.
On 11 March 2025, the government published its long-awaited Planning and Infrastructure Bill. Included within the bill is an important amendment to the scope of Development Corporations, under paragraph 79, which states:
“A single development corporation may be established for the purposes of the development of more than one new town in England if the Secretary of State considers that having a single development corporation would facilitate efficient development.”
Paragraph 79(3), Planning and Infrastructure Bill, March 2025
Previously, the area of individual Development Corporations could only be contiguous. This amendment enables exactly the configuration that I am advocating for above, clearing the way for a single administrative body to cover several new settlements even where these do not share a common boundary.
For the last few months I’ve been attempting to map every bit of “grey belt” land within London’s green belt. As there’s been some uncertainty over exactly what qualifies as grey belt, I’ve adopted a cautious definition, including areas which appear to have been previously developed, including car parks and yards, earthworks and hard standing.
This builds on work I’ve previously undertaken which attempts to use AI to locate small site development opportunities in London’ssuburban areas. You can read more about this here.
I used our existing learning model (based on the InceptionV3 convoluted neural network) to assess an area of green belt using higher-resolution aerial photography provided to me by aerial mapping specialist Bluesky with the purpose of categorising the types of land cover. Our learning model was trained on aerial photography / satellite imagery from Google.
The following describes the methodology followed and some of the initial findings.
The area of sample data provided by Bluesky is contained within the white rectangle shown within the following image. The pink masked area is not within metropolitan green belt; the remainder is. The total area of the sample data provided by Bluesky covers an area of approximately 390ha, with just over three quarters of this within the metropolitan green belt.
Within this area I created a grid of points at 25m centres (i.e. a 625sqm tile). The image to the right shows the distribution of these within the examination area.
Using our existing learning model (based on Google satellite data), I assessed the ground conditions at each data point. The image on the right shows how the AI learning model has categorised the landscape features at each point. The pattern of ground cover can be seen here, with dark green representing woodland and tree cover, blue corresponding with areas of water (although there are some limitations to this, described below).
One of the limitations of this is that using the higher-resolution Bluesky photography some tiles contain multiple “types” and the AI struggles to distinguish between, say, a domestic garden and a residential house. Because of the limited resolution of the Google imagery this was not a significant issue, but at higher resolutions the data points can miss key features, such as entire houses, classifying the gardens to the front and rear, but not the structures themselves.
To address this, I introduced a data point grid with double the resolution, with points at 12.5m intervals. The image here shows the distribution of these on the same map. Given that the 25m grid across the entirety of London’s metropolitan green belt results in more than 8m data points, adopting a 12.5m grid will result in four times this amount.
Running the AI again using data with the Bluesky imagery results in this image, which includes the non-green belt area in the south west of the map, (which was included in error, but demonstrates the efficacy of the process). The patterns of land cover are clearly visible at this scale.
The image below shows a small area of the sample data. Moving the slider across the page reveals the AI predictions for each point at 12.5m intervals.
Golf courses are generally identified correctly, likely due to the presence of sand bunkers and the curved shapes of the fairways visible in the image, although there are some odd predictions for “water” which need further investigation.
Water is being identified correctly, as this lake within Aldwickbury Park Golf Club shows. There are some anomalous categorisations occurring around the periphery of the lake, likely due to surface markings fooling the AI into thinking these are sports pitches, as the pale line around the edge resembles the white lines of a football pitch.
As with the golf course, crops and woodland which appear as dark areas of consistent colour are incorrectly being identified as water. An improved learning model will be needed to account for this, as with this resolution these types should be distinguishable from bodies of water.
Car parks appear to be identified correctly, although due to the resolution of the image some areas within the car parking areas are being incorrectly identified. In some cases the markings on roads, or areas where no cars are parked, are fooling the AI into thinking that these are hard courts. The presence of parked cars is generally necessary for the AI to correctly identify land used for this purpose.
Domestic gardens need to be included within the “allotments and garden centres” type. Previously, most gardens fell within the “buildings – domestic” type as the 25m tile would generally include both. At 12.5m, the two are usually found in separate image tiles and therefore correctly identified.
For an unknown reason, some crops appear to be categorised as golf courses. Unclear as to why. Further investigation required. It is likely that adding these areas to the test and training data will teach the AI to distinguish between these with a greater degree of accuracy.
Fallow fields appear to be correctly identified, although the sample data from Bluesky does not include and “earthwork” sites so the accuracy of this prediction cannot be assessed. Note some anomalous identifications as “water” to the right of this image. Futher training of the learning model using a larger sample of the Bluesky data should assist in correcting these.
This exploratory exercise has demonstrated that higher-resolution mapping data, with imagery taken within a narrower seasonal timeframe, results in more accurate predictions, although to take advantage of this, a significant increase in data points will be required. The length of time required to generate the imagery and process the data will be significant and demand an increase in processing power.
All aerial imagery is copyright Bluesky International Limited, all rights reserved.
The following describes a potential methodology for establishing the extent of “grey belt” using a geometrical approach to settlements within London’s metropolitan green belt.
1. This example uses Brentwood in Essex. The settlement is entirely enclosed by London’s metropolitan green belt.
In this diagram the orange colour shows the extent of Brentwood which is not within this green belt.
2. Creating a new boundary around the furthest extents of Brentwood’s boundary.
This identifies those areas which do not contribute to the five purposes of the green belt according to the NPPF. These areas could be developed without the settlement encroaching into the countryside.
3. To ensure that neighbouring settlements are prevented from “merging”, establish a 250m buffer where no development should occur.
Should this distance vary depending on the nature of the landscape? Is 250m too great, or too little?
4. Those areas within easy access of a station should also be developable, provided that this does not encroach on the buffer zone established above. Here, this has been set at 1,600m from existing stations: approximately 5 minute’s cycle ride.
4. Subtracting the geometries above, arrive at a net area which is contained entirely by the outer extents of the settlement, but excludes those areas not covered by green belt protection.
5. From this area remove any protected habitats such as SSSIs, Ancient Woodlands, Areas of Outstanding Natural Beauty, and so on.
6. Here the final geometry is shown with an 800m / 10-minute walking distance and 1,600m 5-minute cycle distance.
7. And then overlaid onto a satellite photo of Brentwood, showing the landscape around the town which could be considered as grey belt.
Following on from my experiments using AI to identify and classify small site development opportunities in London’s suburbs, I’ve been deploying the same pattern recognition software on aerial photography to see if it’s possible to categorise, and quantify, how much of London’s green belt has the potential for new homes.
The new government has made much of the potential for so-called “grey belt” to meet the country’s housing need, particularly where this is located close to public transport. The Labour manifesto stated that “the release of lower quality ‘grey belt’ land will be prioritised and we will introduce golden rules’ to ensure development benefits communities and nature.”
This was followed by a consultation version of the National Planning Policy Framework (NPPF) in July 2024, which established a definition for what grey belt is:
“For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the green belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes (as defined in para 140 of this Framework), but excluding those areas or assets of particular importance listed in footnote 7 of this Framework (other than land designated as Green Belt).”
In her statement to the house which accompanied the launch of the draft NPPF, Angela Rayner said the following:
The Green Belt today accounts for more land in England than land that is developed – around 13 per cent compared to 10 per cent. Yet as many assessments show, large areas of the Green Belt have little ecological value and are inaccessible to the public. Much of this area is better described as ‘grey belt’: land on the edge of existing settlements or roads, and with little aesthetic or environmental value. It is also true that development already happens on the Green Belt, but in a haphazard and non-strategic way, leading to unaffordable houses being built without the amenities that local people need.
There are wildly varying estimates as to how much of the green belt could be considered as “grey”. Property technology outfit LandTech suggested it could be around 0.4%, but CBRE estimated it as 7%. Bearing in mind that England’s metropolitan green belt covers some 16,384 square kilometres (with London’s 5,085sqkm of this), even at 2% this would be enough for more than 1.6m homes. It’s a lot.
Setting aside for one moment the varying definitions of grey belt, I’ve been trying to calculate how much of the green belt is covered by stuff that’s clearly not green. This isn’t necessarily an attempt to find locations to build new homes, but simply an exercise to find the car parks, breaker’s yards, quarries, waste transfer depots and landfill sites that are currently protected from development by virtue of green belt protection.
Using GIS mapping I created a grid with intersections every 25m and applied this to the entirety of London’s green belt. In total that’s approximately 8.1 million data points. This is too much to handle in one go, so I divided this down according to planning authority; there’s 72 district councils, unitary authorities and London boroughs who have at least some of the capital’s green belt within them.
The unitary authority of Buckinghamshire has the greatest area of green belt, with 15,630 hectares. This map is taken from article I wrote about the impact of new housing targets on each of England’s planning authorities, and provides a quick overview of the green belt in each:
The smallest is the Royal Borough of Greenwich, which has a tiny area of green belt in its south east corner (so small it can’t be seen in the map below).
At every data point within an authority area I exported a Google satellite image covering an area of 625sqm (i.e. contained within a 25m x 25m tile). I then manually grouped a number of these into categories. Here’s an example of each classification showing the types of images generated:
Armed with a large set of images sorted into folders according to what I could see in each tile, I then trained an AI learning model on the resulting data. Applying this learning model to the remaining images and returning this data to the GIS software, I was able to map the location of every data point and show the distribution of different land types across each authority area.
I started with St Albans City and District Council (SACDC). Below you can see an area in the south of the district, close to the border with Hertsmere. Each coloured circle corresponds to a different designation. The outer colour shows the AI’s best estimate at what’s on the ground, the inner colour are those categories I have determined could be classified as “grey belt”. Tarmac’s Harper Lane asphalt plant appears as a concentration of red and orange blobs; woodland as dark green rings, fields as lighter green, and agriculture in a lighter shade. The grey rings represent buildings, which you can see to the right of the image, with car parks among these in red.
Although it’s possible to spot some inaccuracies in the classifications, overall this appears to be pretty convincing. One of the issues is that Google’s satellite data varies in resolution across the country, and at which time of the year it was taken. This can lead to agricultural land being misidentified as earthworks, for example, when the picture was taken in winter and the crops harvested. In some remote places the ground is obscured by cloud or vapour trails from passing planes. The use of better aerial photography will help iron out these inconsistencies.
Zooming further into the image you can see numbers appearing within the centre of each dot. This is the “confidence level” that the AI has ascribed to each identification. A score of, say, 60%, means that the AI thinks the tile meets the characteristics of a classification with this degree of confidence. The higher the figure, the greater the chance it’s correct.
This is useful, because the AI also then includes a secondary and tertiary prediction with reducing levels of confidence. Because the tiles cover an area of 625sqm it is likely that they might include different types of ground cover: part car park, part woodland, for example. By multiplying the percentage confidence level by 625 we can get an approximation of how much of the tile is covered by each category. So, a tile that the AI has identified as having a primary classification of “tree cover” with a confidence level of 80% and a secondary classification as “car park”, with 20% confidence, might contain 500sqm of the former and 125sqm of the latter.
While individual data points can display odd results, there are ways to even out the anomalies. Grey belt land uses tend to cover a wider area than just 625sqm, and as can be seen above, the significant opportunities tend to be where a number of these are grouped together. Using a clustering algorithm in GIS we can find those parts of the study area in which many of the positive data points appear. Although these are not particularly useful for analysis, they can help signpost parts of the green belt which are worthy of further investigation.
The map below shows the southeastern corner of Buckinghamshire, a unitary authority. Here I’ve used a clustering algorithm to create a series of circles where groups of grey belt points occur. The grey areas in this image are not within the green belt – everything else is.
Zooming into this area further shows that these clusters are broadly correct. There are some large solar farms in this area, something that’s not found in St Albans (and the dataset on which the learning model was trained), so the AI is incorrectly identifying these as water. A further refinement will be to include a new category for photovoltaic panels. I’ve masked the areas not covered by green belt protection, which are shown in grey.
In the image comparison above you can see the large earthworks (Cemex’s Langley quarry) in the centre of the frame, and the eastern part of Thorney business park to the north. The two areas to the west are Traveller sites, with a solar farm misidentified as water in the bottom right. What this shows is that the use of clustering can help in identifying the areas of potential grey belt. The M25 can be seen running north to south on the right-hand side, and the Elizabeth Line across the centre, broadly parallel to the Grand Union Canal above it. Importantly, Iver Station is just about visible to the left of the intersection between the railway and motorway. Trains stop here every few minutes, so one wonders whether this not make a good location for new homes: the area to the north of the station is clearly a candidate for new development were it not protected by virtue of its green belt designation.
We know that each data point represents an area of 625sqm, so by counting the number of these within each category as determined by the AI, we can quantify the total amount of land occupied by each.
The following table shows the classification of each of the 210,283 points within St Albans District. I’ve highlighted in green those categories of land that I think could be included within a “grey belt” designation.
| Category | Data points | Area (ha) | % of Total | Grey Belt? (ha) |
|---|---|---|---|---|
| Allotments & Garden Centres | 2,102 | 131 | 1.00% | 0 |
| Buildings – Commercial | 2,035 | 127 | 0.97% | 0 |
| Buildings – Domestic | 5,208 | 326 | 2.48% | 0 |
| Car Parks | 1,963 | 123 | 0.93% | 123 |
| Cemeteries | 202 | 13 | 0.10% | 0 |
| Earthworks | 1,066 | 67 | 0.51% | 67 |
| Golf Courses | 8,217 | 514 | 3.91% | 0 |
| Highway | 11,612 | 726 | 5.52% | 0 |
| Open Space – Agriculture | 65,846 | 4,115 | 31.31% | 0 |
| Open Space – Fallow Fields | 11,349 | 709 | 5.40% | 0 |
| Open Space – General | 38,778 | 2,424 | 18.44% | 0 |
| Open Space – Wasteland | 171 | 11 | 0.08% | 11 |
| Polytunnels & Greenhouses | 1,325 | 83 | 0.63% | 0 |
| Railways | 1,205 | 75 | 0.57% | 0 |
| Sewage Farms | 4 | 0 | 0.00% | 0 |
| Sports – Hard Courts | 4,493 | 281 | 2.14% | 0 |
| Sports – Pitches & Fields | 2,868 | 179 | 1.36% | 0 |
| Tree Cover | 40,772 | 2,548 | 19.39% | 0 |
| Water | 9,680 | 605 | 4.60% | 0 |
| Yards | 1,387 | 87 | 0.66% | 87 |
| Total | 210,283 | 13,143 | 100.00% | 287 |
| 2.18% |
Based on these figures we can see that 287 hectares (or 2.18%) of St Alban’s green belt is being classified by the AI as “grey”. This includes earthworks, some of which are likely to have been misidentified due to the similarity between this and dry / fallow fields.
Looking generally at the distribution of these “earthworks” classifications, it appears that around half are likely identified correctly. That leaves around 250 hectares of land with which there’s a high level of certainty over the nature of the surface. That’s just shy of 2% of St Alban’s green belt: or 12,500 homes, if this were built out to a notional capacity of 50dph.
Of course not all of this land will be suitable for development—some is far from public transport or the road network, or otherwise occupied by productive pourposes (some of those concrete batching plants will actually be needed to build these homes!). But even if we generously discount half of the space identified, that still leaves a huge area of grey belt that can be developed for new homes. St Albans’ new five-year housing target, under the new Standard Method, is 7,720 homes. Most will be delivered, one assumes, through urban and suburban intensification. But let it not be argued that the district doesn’t have enough land to deliver these homes.
England’s metropolitan green belt covers an area of 1.64m hectares. Even if just one percent of this falls under the commonly-accepted decision of “grey belt”—car parks, breaker’s yard and landfill—then at over 800,000 homes that’s more than half of the new government’s five-year housing target. This is clearly an opportunity not to be missed.
At the weekend MHCLG published a draft working paper setting out plans for a “brownfield passport”, with the intention of finding ways to make the intensification of urban areas easier.
This is long overdue. The planning system is disproportionately complex for small-scale development, and this is one of the primary reasons why the country has witnessed a collapse in the SME developer market in recent decades. In London, Barratt Homes currently builds one in ten of the city’s new homes—this is not a healthy state of affairs. I have written elsewhere about the need to provide greater certainty for small developers who are less financially resilient than their corporate counterparts.
Importantly, the document recognises the woefully low density of many of our towns and cities:
Given our relatively low densities, there is scope in many areas for increases. While such increases should take account of local character, existing character should not be used to block sensible changes which make the most of an area’s potential, and which can create sustainable, well-designed and productive places to live and work.
This is an encouraging acknowledgement, as for too long, “character” has been used as a means to refuse new homes. The draft NPPF which was published in June helpfully removes paragraph 130, which requires LPAs to refuse applications which are “wholly out of character with the existing area”. Combined with a national policy which sets out parameters for intensification, this could be powerful indeed.
Policy could, for example, say that development should be of at least four storeys fronting principal streets in settlements which have a high level of accessibility, and/or set acceptable density ranges that allow for suitable forms of intensification.
We know from previous experience that liberal design codes can be difficult for existing communities to accept. An example of this is in Croydon, where a suburban intensification policy was so hated that a new mayor was voted in just to scrap it, despite delivering nearly 2,000 new homes in a three-year period. The reason for the disgust at the Croydon policy was because it concentrated new homes in a relatively small area, and the pace of change was rapid.
How might a similarly ambitious policy, set at national rather than local level, provide certainty to small developers whilst delivering high-density development in sustainable locations? The following paragraph from the document is intriguing:
[W]e are keen to explore how this might be done – for example, whether densification in some areas should focus on corner plots and those adjoining them rather than whole streets, or linking densification opportunities to accessibility.
This makes a lot of sense. Corner developments tend to be better suited to intensification as they are less likely to overshadow or overlook adjoining gardens. They can act as wayfinding devices at key road intersections, helping bring clarity and legibility to suburban areas. And they can help provide non-residential uses such as small shops at ground floor level.
We included a specific design code for corner plots in our Small Sites SPD for Lewisham Council.
In this example a single corner dwelling is replaced with a small block of flats—four storeys in height, as it happens, as the document suggests—and provides six new homes. As Lewisham was keen not to see a net loss of family-size dwellings, this includes a pair of duplex flats with rear gardens.
In outlying areas there are even more opportunities for intensification. This lovely scheme by architects Harp & Harp replaces a sprawling family home on a corner plot with no less than seven family homes. Repeating this on each of the remaining three corners of the block would result in an increase of some 24 homes; that’s almost doubling the density, with no discernible detriment to character (I’d argue a significant improvement).
Here’s another striking example by OB Architects that we included as a case study in the Lewisham SPD. It replaced a single family house on a corner plot close to South Croydon station with an attractive four-storey apartment block containing eight new homes. We should be doing this on every suburban corner.
So, how many of these opportunities exist? With support from MHCLG’s PropTech Round 4 funding, I’ve been developing an AI tool that can identify and characterise different types of small development plot. I’ll be writing about this more in due course, but one of the powerful features of this is that it can find combinations of different site types. For each site it assesses, the AI determines a “ranking” according to the confidence in its prediction. So, it may think that a site has a 60% chance of being an “infill” type, but also a 30% chance of being a “semi-detached” type (it could be both, of course), reducing the percentage confidence each time until it has accumulated five predictions.
Searching for sites which fit both the “corner” (ranking first or second) and “detached” categories (again, ranked first or second), for instance, reveals approximately 320 properties in Croydon which could be intensified in this way—that’s a potential net increase of around 2,000 homes. Croydon’s small sites target in the current London Plan is 6,410 homes, so this would deliver nearly a third of this total alone—as well as concentrating low-rise intensification in those areas best suited to accommodate it.
There are fewer of these sites—around 150—in Lewisham, partly because it’s a smaller borough, but also lacks the large areas of suburban development. Even so, there’s plenty of potential: take the example below, a stone’s throw from Grove Park station. My suburban intensification study suggests that this neighbourhood has a prevailing density of some 16 dwellings per hectare (dph). This is a dreadful figure for somewhere with such good access to public transport and a Public Transport Accessibility Level of 4.
A development here could increase the number of homes on the site from one to fifteen or so, but as we know, local politics means that “character” inevitably takes precedence over additional homes. We cannot, therefore, rely on local policy to take the bold steps needed to intensify our suburbs: the only solution is to introduce a strategic policy that removes the potential for political interference and starts to deliver the homes we desperately need.
A national brownfield passport would be a great place to start.
‘The horrific fire at Grenfell Tower … may emerge as the latest, and most tragic, manifestation of decreasing oversight that architects have been warning about for so long … Design and build [produced] a transfer of risk, with the balance of power shifting from the contract administrator (a role most often fulfilled by the architect) to the builder.’
I wrote these words just a few months after the inferno at Grenfell Tower took 72 lives. This quote and the article it was taken from were submitted in evidence by the Bereaved, Survivors and Residents (BSR) group to the public inquiry, which last week published its long-awaited final phase 2 report.
There’s a lot to digest in the more than 1,700 pages, and they make for a sobering read. It’s difficult to feel proud of being part of an industry that allowed this to happen.
The inclusion of my article in the evidence demonstrates that the BSR group understood from early on that a pervading culture of negligence, ambiguity and obfuscation enabled the Grenfell tragedy to happen. Yet, working through the final report, it seems there’s little acknowledgement of this fact. While the public inquiry has diligently diagnosed the symptoms, it has ignored the disease. And that malady is design and build.
There are just 19 mentions of design and build in the 326 pages of Part 6 of the report, which covers the refurbishment of the tower itself. The inquiry did not look closely at design and build because industry procurement somehow fell outside the scope of its investigations as defined by the terms of reference chosen by then prime minister Theresa May in 2017.
But the inquiry was tasked with examining the decisions relating to the tower’s ‘modification, refurbishment and management’ and, to me, it’s an inescapable fact that poor procurement and the diminishment of quality are inextricably intertwined with the decisions at the heart of what went wrong. Design and build doesn’t just allow a culture of dereliction of responsibility to perpetuate; it positively encourages it.
Consider for a moment one striking scenario outlined in the findings, when the Celotex RS5000 insulation was suddenly switched for Kingspan K15 without approval by anyone in a position of authority or oversight. The report describes how photographs ‘indicate that [Kingspan K15] was certainly used on the west side of the tower, but the precise locations where it was used are not known and cannot be established given that much of the insulation was consumed in the fire.’
The report goes on to describe how nobody from main contractor Rydon ‘consulted the TMO [tenant management organisation] or informed building control that a substitution was going to be, or had in fact been, made’.
So, a unilateral decision was at some point made to switch one product for another, without this being approved prior, or recorded afterward. As it happens, neither product was suitable for use in this application so the outcome was the same. But what if they’d decided to replace a non-combustible product with an inflammable one? And how many other changes were made that weren’t recorded?
More importantly, this poses serious questions about our knowledge of what else is out there. We are already too aware of the thousands of buildings that have been covered in combustible cladding, but how many more are there that we assume are safe but have in fact been wrapped in flammable materials, hidden away behind innocuous façades? And what other perilous changes have been made to details or material selections in buildings that have yet to come to light? I know of at least one building where flammable cladding was removed to reveal a previously unknown problem with the concrete frame that rendered the entire building structurally unsound. Make no mistake: this is design and build in action.
Design and build became the default form of contracting for large projects in the late 90s and early 2000s when clients realised that they could offload much of their risk on to builders willing to accept it. Yet all that happened was contractors passed that risk down their supply chains; on to subcontractors and consultants – those least able to accommodate it. Architects had their fees slashed and their authority diminished, and were incapable of understanding their place within the increasingly entangled web of responsibilities.
The inquiry found that ‘Rydon was responsible for inspecting the work done by [façade contractor] Harley and other subcontractors at Grenfell Tower’, but failed to acknowledge that it is nonsensical for one company to be responsible for checking what’s happening on site, and a different consultant, Studio E in this case, to be recording this information.
‘As built’ drawings, according to the inquiry, ‘are part of the information that should be handed over to the building owner as part of the health and safety file and are clearly an important record of the construction for future users of the building’. Yet this is a source of never-ending dispute. Building contracts and CDM Regulations demand this information is produced at the conclusion of every project, but it is a foolish architect who takes blind responsibility for others’ work. Instead, we’ll usually settle on insurer-approved phasing: ‘final design’ or ‘as instructed’ or something similarly non-committal, but this hardly gives confidence to the facilities management team when they need to replace a broken window or a concealed pipe.
That Studio E appears to have stamped drawings ‘as approved’ speaks more to their naivety than their negligence. How can any architect in their right mind claim to know what’s been installed on a building when others routinely change specification without regard to the documentation setting out what needs to be done?
There are also limits to what a reasonably competent architect can be expected to understand, and we are increasingly reliant on the specialist expertise of others to fill the gaps in our knowledge. The conductor of an orchestra knows how a symphony should sound, yet she might not know how to play each and every instrument. Design and build not only deprives the architect of the baton, it demotes us to somewhere in the second violins, leaving the podium vacant. And while we might all be looking at the same sheets of music, even the most capable musicians will struggle to make much more than an unlistenable cacophony.
None of this is to let Studio E off the hook. It was neither qualified nor capable of taking on a project of this complexity, and fully deserved the condemnation it received for its lack of professionalism and cavalier attitude to risk. Its acceptance of a fee of around half what it should have charged for a project of this size is a lesson for public sector clients everywhere. But every decent architect out there will know the familiar feeling of being undercut to a level where we know it’s impossible to carry out the most basic of services. There must surely come a point when rock-bottom fees should be considered professionally negligent: there’s no miraculous way to design a building for half the cost; you just end up making 50 per cent of the effort.
Fundamentally, the inquiry has misunderstood the nature of the relationships between different parties within modern contracting. It demands that the architect take responsibility for approving the work of others, as if some unwritten hierarchy exists that empowers them to instruct changes, order the redoing of unsatisfactory work, and keep the client informed when things go awry. Yet we jettisoned these powers when we allowed our appointments to be transferred to builders.
Instead of serving society, our obligations are now to the interests of shareholders. Post-planning, Studio E was novated to Rydon, with any contractual bond with the original client, and its tenants severed. Any temptation (or moral obligation) to report derogations from the employer’s requirements would have constituted a breach of contract. Why did the inquiry not question this?
The report concludes that ‘such a casual approach to contractual relations is a recipe for disaster if events take an unexpected turn. All those involved in whatever capacity in a complex project need to understand clearly what they have agreed to do and what they are responsible for.’
This may be true, and we can introduce all of the legislative reforms and corrective regulations we like. But until we fundamentally transform the culture of construction in the UK, I can’t see that we’ll have learned very much from the Grenfell tragedy at all.
This article originally appeared in the Architects’ Journal on 13 September 2024.
When the new Labour government’s proposed housing targets were published in July there was some surprise that many planning authorities, particularly urban ones, had seen a significant reduction in the number of homes they were being expected to deliver, and that there was a discernible shift away from the south-east of England to the north-west.
The map below shows the percentage change for each planning authority in England. The authority with the largest reduction is Tower Hamlets, going from 5,190 homes to 2,177 using the proposed Standard Method; a reduction of 58%.
At the other end of the scale, Redcar & Cleveland’s increase of over 1,300% seems large until you realise this is a jump from just 45 homes per annum to 642. That’s just 30% of Tower Hamlet’s new total, despite Redcar & Cleveland having an area more than 11 times greater than the east London borough.
Maybe, then, the changes in numbers expressed as a percentage of previous calculations are not that useful? A different method might be to consider the total number of homes in terms of density. The map below shows what this looks like.
As expected, those areas that you’d assume would have the highest housing demands (in and around England’s major cities) see the greatest number of homes her hectare. Top of the list is London Borough of Kensington & Chelsea, with 3.45 homes per hectare required to meet the new targets. This is an outlier: next on the list is neighbouring City of Westminster, with a target of 1.72 homes per hectare. The top 25 authorities by density are all within London, and the first ranked authority outside the south-east is the City of Bristol, with a target of just 0.28 homes per hectare.
These housing targets have been greeted with considerable uproar, particularly from the anti-development brigade which spuriously claims that this amounts to nothing less than “concreting over the countryside”.
As an example, in an open letter to Angela Rayner published shortly after the targets were revealed, East Hampshire District Council raised the following concerns:
“East Hampshire’s housing targets, as determined by the standard methodology, show we must identify sites for almost 11,000 homes by 2040.
“But those calculations take no account of the fact that 57 per cent of the district is inside the South Downs National Park, an area where development is restricted.
“That leaves the remaining 43 per cent of the district to take the lion’s share of development.
“Inevitably that will put pressure on our highly-prized countryside and our rural towns and villages, which have already seen so much change over the past few years.
“This is not sustainable development. It is the damage done by a blunt instrument – a planning policy that takes no view of unique local factors.”
Whilst it’s true that a large proportion of East Hampshire is located within a national park, to suggest that these figures are unachievable is ludicrous. Even building at a relatively low density of 40 homes per hectare, its five-year target of 5,370 would require just a quarter of one percent of its total area to deliver—even if it were to be accommodated in a single location. The reality is, in fact, that most of this will be achieved through the intensification and expansion of existing settlements.
Here’s a map of the district showing the land required to deliver 5,370 homes at 40 dwellings per hectare.
Similar complaints have been heard in Cherwell, which sits to the north of Oxford. Cherwell is similar in size to East Hampshire, albeit without a chunk of national park, so it would take rather a lot of effort to “carpet over” it, as Conservative Councillor Eddie Reeves suggests will happen under the new targets.
To be fair, Cherwell does accommodate some of Oxford’s green belt in the southern region, but other than that is pretty much free from planning constraints. Again, even with a 55% uplift in housing numbers it could find all 5,475 homes using just 0.23% of its land. Suggestions that significant parts of the countryside will be lost to development are very wide of the mark.
Down in Kent, Conservative councillors of Tonbridge & Malling got particularly excited about their new targets, being required to find space for 5,285 homes over the next five years—an increase of just under a third. A large part of the district is within London’s green belt, with some of this coinciding with the Kent Downs AONB. But, as the green belt is no longer a constraint on development, there’s more than enough space for these homes. Hardly the “naked opportunism” that the local Tory Councillor Matt Boughton seems to think it is.
West Berkshire is on a war footing after council leaders described the new targets as a “bombshell“. The CPRE, which can always be relied on to keep a level head in the time of crisis, backed these protestations, claiming that the authority’s new targets of 5,285 homes over five years are “excessive and unsustainable”.
A large chunk of West Berkshire is, to be fair, covered by the North Wessex Downs AONB, and this will certainly prevent housebuilding at scale. But the remaining areas to the southeast, around Newbury and Thatcham, have no such constraints, so there’s no reason why these homes cannot easily be accommodated, particularly as most will be located within the boundaries of existing towns.
It’s tempting to snigger at the hysterical language employed by the many politicians who oppose the building of homes in their local areas, but I genuinely believe that they have a very limited understanding of the scales of land involved. It’s easy to look out of your window at miles of fields and worry that a housebuilder is going to come and plonk a bunch of executive homes in the way of your view, and in some cases that is bound to happen.
But as for “concreting over the countryside”, well, nothing could be further from the truth. The countryside is huge.
We know from previous research that the public has little understanding of how much of the country is built on. A survey in 2018 showed that people tend to think that nearly half of it is. But England’s urban areas take up about 14% of its total area—and that includes urban parks and gardens. The land covered by buildings themselves is even smaller than this. That leaves around 11.5 million hectares of open countryside, most of which is for agriculture.
Now imagine that the government’s 1.5m home target was being located in an entirely new settlement somewhere in the countryside. At a modest density of 40 homes per hectare it would take up an area of 37,500 hectares. That’s just over 2% of the size of England’s green belt. This is what a circle with an area of 37,500 hectares overlaid on a map of England looks like:
Whichever way you look at it, the countryside is safe.
You can view a map of every planning authority in England by choosing from the dropdown list below.
A few years ago I took it upon myself to submit a supporting comment on Transport for London’s plans to build new homes on the car park at Cockfosters station. Although it’s just across the borough boundary in Enfield, it’s only a few hundred metres from where I live in New Barnet, and the application was worthy of support. Then Chipping Barnet MP, Theresa Villiers, was running an active campaign against the plans, which was as a good a reason as any to add my name to the list of those in favour.
I’d not thought much about it before then, but having found the application reference (handily provided on one of the many anti-development leaflets that dropped through my door), and registered on Enfield’s website, I found myself presented with a long list of checkboxes setting out the reasons why I might want to object to the proposals. This included a veritable NIMBingo card of objections; yet missing was anything that could be considered a positive justification for the development.
Many weren’t even valid planning objections at all: included on the list was “general dislike of proposal”, but nothing about the desperate need for new homes. “Noise nuisance” made an appearance, but missing was a checkbox acknowledging a positive contribution to the local area.
If you found yourself wanting to object to a planning application but you weren’t sure why, this provided you with a perfect “to do” list of reasons. It’s difficult to imagine anyone sufficiently enraged by the idea of new housing that they’d be selective about what they were ticking and why. “I just don’t like the look of it, but yeah – the land is probably contaminated too!”
To Enfield’s credit, when I raised this with the head of planning, he acknowledged that this list was unnecessarily biased, and it was duly revised to include an equal balance of positive and negative sentiments. Alongside “development too high” appeared “improves the quality of the area”; “loss of parking” was countered by “makes sustainable use of land”, and so on. Simply ticking every box from top to bottom was now counter-productive: those wishing to object, or support, an application were now forced to carefully consider each option.
This got me thinking about the inherent bias in the planning system in favour of those railing against development. I spend a lot of my life raking through planning applications and am familiar with many of the terms used, but for someone who’s engaging with the system for the first time this can be an intimidating and confusing experience.
You just need to look at the front page of many council homepages to see this bias at first hand. The screen grab below is from the front page of Barking & Dagenham’s website (I’m not picking on LBBD here: it just happens to come first in the alphabet), and demonstrates a tacit assumption that nobody would, in their right mind, actually write in favour of development:
Clicking through to the planning portal itself, it gets worse.
The impenetrable nature of Idox is for another day, but even once you’ve managed to locate the reference of the application you want to comment on, you are required to complete a long and complicated registration form to do so.
I suppose that, unlike me, most people will be commenting mostly on applications which immediately affect them and will only every need to go through this procedure once, but you can see how someone without much time on their hands, who moves home regularly as a consequence of precarious circumstances, or is unfamiliar with engaging with the authorities, might be put off by this step.
I’m in two minds about the need to register to make a comment: on one hand I can see how it might limit spurious or trivial comments that take up officer time; on the other, I can also see that it might be off-putting for those more likely to support new development (older, established residents are, I suspect, more likely to have the capacity to spend time grappling with user-unfriendly web portals). But, on balance, I’m not sure that requiring commenters to register is a good thing.
Some planning authorities—my home borough of Barnet included—have removed this list entirely, so it’s up to respondents to decide for themselves whether they believe a particular scheme meets local planning policy. The bias against supporters is apparent elsewhere on the site, however.
It’s well known that public consultation is a bit of a nonsense anyway as every application needs to be assessed on its own merits, and officers are perfectly capable of determining whether a proposal for development is broadly compliant with policy (and if the planning committee disagrees, the Planning Inspectorate certainly is). The only purpose served by the commenting process is to apply pressure on elected officials to resist development.
Islington Council’s website is entirely neutral in its language, offering visitors the opportunity simply to “view or comment” planning applications; although the ability to find anything without the specific planning reference is impossible. Not to have an interactive web map displaying all current planning applications cannot surely be acceptable in a planning website that was only updated this year.
Richmond-upon-Thames’ website is marginally better: searching for applications is painful (another borough without an interactive map), nowhere does the site refer to “objecting”, and there’s no need to register in advance. Sensibly, personal details are limited to a name and email address.
All in all, the general state of London’s planning portal is woeful. A lack of online mapping, anachronistic interfaces and dysfunctional search facilities abound. Given the importance of housing in London, surely we deserve better than this? It’s no wonder people, including those for and against new development, feel disengaged from the planning process when it’s so hard to register an opinion. Perhaps the new government might want to invest in a unified platform, provided freely to local planning authorities, to speed up the planning process.
As it happens, despite Theresa Villiers’ intervention and a vigorous local campaign, the Cockfosters application was narrowly approved by Enfield’s planning committee—albeit in a meeting that went on into the early hours. The application was later stalled by an intervention from then Minister of Transport Grant Shapps, and when this was overturned, by issues around financial viability. In total, Enfield received 2,852 formal objections, with just 15 in support. That the committee voted in favour of the scheme is a credit to elected members. But it does suggest, at least to me, that the system is rigged and it’s time to do something about it.
If you’re interested in knowing more about the planning system works, and how you can help support planning applications for new homes in your area (or anywhere else, for that matter), I wrote a handy guide which you can download here.
In recent weeks the Labour party has reaffirmed its commitment to building 1.5m homes in its first term of government. What is not yet clear is how it intends to achieve this figure. Part of the strategy is a new towns programme, as announced by Angela Rayner at the UKREiiF property conference in Leeds last month and confirmed in last week’s manifesto.
But, while building new settlements in the countryside is a headline-grabbing proposal, this is a multi-year enterprise, relying at the very least on compulsory purchase reform, huge investment in infrastructure, changes to strategic planning, and the formation of development corporations. Even with a good headwind and an improving economy, there’s little chance of the target 300,000 homes each year being built via this route any time soon.
The UK has not achieved anywhere near this level of housing delivery since the 1970s, despite this being a central tenet of the Tory manifesto. Housebuilding has sent the Conservatives into paroxysms, with its own backbench MPs campaigning against the very policies ministers have claimed are necessary to meet these targets. So how might a new administration jump-start housing delivery without getting bogged down in the quagmire of long overdue planning reform? The leafy suburbs of south London might provide a clue.
In 2017 Croydon Council published guidelines setting out how its outlying areas should be gradually intensified through small site development. The council was already delivering a heroic number of new homes through the development around East Croydon station, although for a time this included a large number of very poor office-to-residential conversions. Rightly identifying that every part of the borough has a part to play in meeting the city’s acute housing need, its Suburban Design Guide received plaudits as an innovative way to meet its housing targets as set out in the London Plan.
The guidance was intended to provide applicants with certainty around what type of development would receive support. It included a range of long-term development scenarios which showed how different suburban conditions might evolve over the next 20 years, providing explicit examples setting out how, for example, a single detached family house on a large plot might be demolished and replaced by a block of flats facing the street, augmented by a small terrace of townhouses to the rear. Other examples set out conditions through which semi-detached and terraced houses might be redeveloped to significantly intensify individual plots and, through assembly of adjoining dwellings, push the uplift even higher.
Armed with this guidance, small developers could acquire land with a good idea of what it was worth, due to the ability to predict what might be built on it with a high degree of certainty. And by following the guidance in the SPD, schemes could be drawn up by architects safe in the knowledge that they would be supported by planning officers. The accurate balancing of acquisition cost and development value also meant that there was little benefit to flipping sites, in the hope that each time this happened a little more could be squeezed from the scheme — a phenomenon which pioneering small site developer Roger Zogolovitch referred to as “pass the parcel”.
The Croydon guidance focused on a handful of areas identified for intensification where the council believed there was greatest capacity for new homes — primarily those with low densities but close to high streets or train stations. The results of this policy were remarkable: in a four-year period, Croydon delivered nearly 2,000 homes on small sites, three quarters of which were within developments comprising fewer than 10 homes — by far the largest number of any borough in London. That’s not just approved, but built. The second highest (some way behind) was Barnet, which in the same period managed 700, despite being almost exactly the same size and having the same area of green belt.
Extrapolating this approach across the remainder of London’s low-density suburbs surely has the potential to yield a very large number of new homes. But how many?
Most of central London sits somewhere between 20 and 60 homes per hectare (dph), with a few pockets around Kensington, Bayswater, Tower Hamlets and Maida Vale which top out at about 150dph. In outer areas this drops as low as two dwellings per hectare, even within ten minutes’ walk of suburban stations (Crews Hill, in Enfield’s green belt is an egregious example; albeit soon to be corrected).
This is clearly an aberration in a world city, particularly when one considers the massive green belt, the very purpose of which is to promote urban intensification. Current green belt designations make little sense where there’s nothing to distinguish it from the boundaries of those cities it’s intended to constrain. 10% of London’s total area is located within ten minutes’ walk of a station whilst simultaneously having a residential density of less than 20 dwellings per hectare.
An obvious route to meeting the one-and-a-half million homes that Labour has committed to would look more closely at these areas and focus development on suburban intensification. Croydon has shown this can work. But development of this scale does not come without compromises, and incoming Conservative mayor Jason Perry unceremoniously scrapped the SPD after running on an unashamedly NIMBY ticket.
Across London there’s around 47,000 hectares of suburban housing within 800m of a station, once protected open space and industrial land are removed. This has an average density of just over 31 dwellings per hectare. An uplift of just 25% in density, capped at 100dph and no lower than 40dph, could yield some 900,000 homes — just in those areas less than ten minutes’ walk from a station. Coupled with more modest increases outside these areas, the figure is well north of a million — and that’s just in London alone.
Expanding this approach across the rest of the country could easily get to the targets that Labour has set for itself; putting a rocket booster under regional economies to boot, as local developers, trades and supply chains respond to a sudden increase in demand for their services. Berkeley Homes alone currently builds around 10% of all homes in London. This isn’t a healthy state of affairs, but when we place so many hurdles in the way of small-scale development, it’s no wonder we suffer from housebuilding hegemony.
40 dwellings per hectare isn’t high, being equivalent to a neighbourhood of two-storey Victorian terraces. Applying a 25% increase in density to all of the areas identified, with a minimum threshold of 40 and a maximum of 100 and making a modest adjustment for those parts of London which have a high proportion of detached and semi-detached houses or large gardens, the areas within 10 minutes’ walk of London’s stations can accommodate around 850,000 homes. Include the areas just outside this, and there’s potential for over a million. Far from being a “war on the suburbs” as some have claimed — such an approach would help breathe new life into them.
Despite the protestations of comfortable suburban homeowners, suburban intensification would not radically transform the character of their neighbourhoods. There are myriad examples across London of sprawling, inefficient, land-hungry houses being replaced by compact and sustainable family homes. A charming example of this is to be found in Purley, where small site specialists Harp & Harp have designed seven new family homes on a corner plot. Repeating this on each corner of the block would easily achieve a 40% uplift in density, whilst being entirely compatible with local character. Yet local Nimbys have repeatedly attempted to challenge the planning approval, including at the High Court, no less.
What policy levers might an incoming government pull to jump-start intensification? Paragraph 129 of the National Planning Policy Framework already states that local plans “should include the use of minimum density standards for city and town centres and other locations that are well served by public transport.” However, a get-out clause remains: authorities can knock back development “if the resulting built form would be wholly out of character with the existing area”.
It’s time to pop that statement in the recycling bin. Instead, the government should follow examples in Canada and New Zealand and adopt a very strong presumption in favour of intensification close to stations, coupled with a prohibition on minor applications being decided under anything other than delegated powers. National housing targets should include a proportion to be delivered on small sites, rather than considering these as “windfall”. Finally, all planning authorities should be mandated to produce small site design codes, with a national version to fall back on should they refuse to do so.
Labour has already identified the lagging economy, pitiful productivity and the dire social and environmental consequences of poor-quality housing as major barriers to growth, but the idea that it can deliver 1.5 million homes via a new town programme in the first term of government if for the birds. Rapid intensification of our cities’ suburbs might offer a solution.
This article originally appeared in Building Design.
“Boroughs should…recognise in their Development Plans and planning decisions that local character evolves over time and will need to change in appropriate locations to accommodate additional housing provision and increases in residential density through small housing developments.”
Draft London Plan, December 2017
I live in suburban north London, in a neighbourhood which sprang from almost nothing in the late nineteenth century with the arrival of the railway. New Barnet station is at the end of my road and my house was built on land previously bought by the railway company: we still have the original deed of transfer from 1899 which details the sale of our plot from the railway company to the developer who bought it and built the home in which I now live.
The streets here are largely lined with Victorian terraces, with some grander villas dotted around on larger plots. Sprinkled among these are houses and flats built in the later years as a result of incremental intensification, some on the former gardens of the bigger homes, others on the site of houses destroyed by bombs in the Second World War. : There’s a handful of more recent interventions: nearby, a backland site turned into eight contemporary houses which, of course, Theresa Villiers—our local MP (for the time being)—objected to, and so on.
Although we’re in Zone 5, trains run into town in less than half an hour; to Moorgate via Finsbury Park and Old Street, and recently our line has been connected to Thameslink, with peak-hour trains connecting commuters with the Elizabeth Line at Farringdon and on to southeast London. It’s a convenient place to live.
But, having said all of that, New Barnet—and other parts of suburban London just like it—simply aren’t that dense. Pockets of new development have been snuck into redundant land, former garages and car parks, derelict pubs and disused warehouses, and even so, the most recent Census data from 2021 tells us that the density of this part of north London is just 18 dwellings per hectare (dph). Maida Vale, as a comparison, has a density of more than five times that. And Maida Vale is hardly somewhere you could describe as an unpleasant place to live.
Whichever way you look at it, suburban London can clearly do more to meet the city’s housing needs.
The shortage of housing in London is at crisis levels and manifests itself in many ways. Young people have been particularly badly hit, and the consequences for our economy and society are dire. In Hackney, schools are closing because young couples are unable to afford to start families. Homelessness is at record levels, with one in ten children in parts of London classed as effectively homeless. Median house prices in the capital are now 14 times average incomes while wages have stagnated. While this cannot be entirely blamed on our inability to build enough homes, it certainly plays a very large part.
Land in London is precious, yet the suburbs have a hegemony over it. Those lucky enough to own a house in the suburbs and, in particular, those living close to public transport, surely have a moral duty to allow more housing to be built around them so that others can benefit from convenient access to all of the amenities that the city has to offer.
So where might these houses go? Do we have the space? And how can we encourage intensification to happen?
The current Mayor of London’s strategic plan for the city, the “London Plan”, was finally adopted in 2021 it set ambitious targets for new homes across the city, compelling each of the planning authorities to meet specific annual housing targets both, with a proportion of these to be delivered on small sites, that is any plot with an area of less than 0.25ha (about a third of a standard football pitch).
An early consultation version of the Plan was accompanied by a series of policies which provided a framework for intensification, clearly stating that boroughs needed to accept that “local character evolves over time” and that it would “need to change in appropriate locations to accommodate additional housing provision”.
I’ve written elsewhere about the push-back from many of the outer-London boroughs to this policy which resulted in the final version eviscerating the small sites targets, and Croydon’s progressive attempts to densify suburban areas that were unceremoniously chucked out by an incoming NIMBY mayor. But even in the short period of time that Croydon’s policy was in place, it resulted in a remarkable outcome, delivering around 2,000 homes within developments of fewer than 10 homes, with house prices and rents levelling off as a result.
So, what if the lessons from Croydon could be repeated across the rest of suburban London? That’s what I’ve set out to establish.
It’s about to get a bit geeky from here on in.
Using a combination of data from Ordnance Survey and Greater London Authority, I assembled a map of London and marked on it every station in the city – both Underground and mainline stations. Many stations are within 800m of each other, so I created Voronoi polygons to establish the closest station to every area in London.
Around each station I created an 800m diameter circle, which equates roughly to a ten-minute walking distance. By combining the two geometries I established the closest station to every area in London that’s no more than ten minutes’ walk away.
Clearly this approach doesn’t take into account the various constraints on potential development, including lots of areas which would, of course, be impossible to build on. The Thames, for example, but also areas of protected land such as Strategic Industrial Land (or “SIL”) Locally-Significant Industrial Sites (“LSIS”), green belt and Metropolitan Open Land. There’s a discussion to be had about whether protecting any space close to stations is sensible, and whether golf courses and industrial land might be put to better use. But for the purposes of this exercise, I’ve excluded them; together with parks, gardens, sports pitches and any other type of open space. Given my focus on suburban areas, I’ve also excluded the “Central Activities Zone”, which covers central London. Further refinements exclude a buffer either side of national and regional roads, and existing railways.
The resulting map of London looks something like this:
So now that we have a map showing all of the potential areas that might be intensified around London’s stations, we need to introduce some data which tells us more about the neighbourhoods around them.
The 2021 Census provides a huge set of data broken down into geographic zones that enables us, with a bit of mapping jiggery-pokery, to intersect them with our areas of interest.
Using Census data broken down by Medium Super Output Area (MSOA) I divided the mapping areas by the equivalent polygon areas. First, though, I ran a series of mapping exercises to establish some additional figures for each of these regions: for example, using Ordnance Survey Zoomstack data to measure the approximate coverage of buildings for each MSOA polygon. Bringing the two together enabled me to examine each of these areas in more detail. Here’s an example: MSOA ref. E02000028 which is located immediately to the west of New Barnet station.
Measurements taken from GIS tell us that MSOA E02000028 has a total area of 105.61 hectares, and the census data tells us that this contains 2,783 homes (45% of which are detached or semi-detached houses) – an equivalent density of about 26 dwellings per hectare. The footprint of all the buildings is about 18.7% of the MSOA, which makes sense given the large rear gardens, even though there are no large areas of open space within it. The census also tells us that, with a total population density of 62 people per hectare, the occupancy level is only 2.35 people per dwelling…which is surprising given the number of very large houses found here (the highest dwelling occupancies in London tend to be in the East End, with parts of Bethnal Green exceeding eight people per home).
You can see the hatched areas overlaid on the image above, which represent the different Voronoi polygons described early. To the bottom right of the image you’ll find Oakleigh Park station, and this MSOA is divided into three sub-areas, each part closest to a different station: in addition to New Barnet and Oakleigh Park, the north-west corner is within 800m of High Barnet Underground Station.
26 dwellings per hectare is pretty low, although not untypical of suburban London. A modest increase over this area could result in a significant number of new homes – let’s imagine for a moment that this is increased by just 25% (hardly a transformative figure). Yet, even at these modest numbers this results in 686 additional homes – an uplift in density from 26 to 32 dwellings per hectare.
Even 32 dwellings per hectare is pretty modest when compared to other parts of London. MSOA E02000589 covers the area around High Street Kensington, topping out at 137 dwellings per hectare (dph). This is probably a bit much for Zone 5, but Herne Hill (MSOA E02000642) achieves a density of 40 dph and can hardly be considered overcrowded.
With all of this in mind, I’ve established a few rules to apply to my data to try and estimate what a modest uplift in density might achieve. Arguably, nowhere in London that’s within 800m of a station should have a density of less than 40dph, so I’ve set that as a minimum. And, although some parts of the capital exceed this, I suggest that the increase in density should not push an area beyond 100dph. Within these thresholds, I’ve set a few additional rules: where detached and semi-detached houses form more than 40% of the total dwellings, I’ve set the potential density increase at 50%; where they’re less than 10% of the total housing stock, it’s 10%. For everything else I’ve assumed a 25% increase.
I’ve made a further adjustment where buildings cover less than 25% of the available land, adding a compound increase of 40% to this figure. The resultant algorithm is something like this (where “familyHouses” means a semi-detached or detached dwelling):
# First, calculate the initial uplift in density based on the proportion of "family homes"
IF familyHouses > 40% THEN newDensity = existingDensity x 1.5
ELSE IF familyHouses < 10% THEN newDensity = existingDensity x 1.1
ELSE newDensity = existingDensity x 1.25
# Then add a compound density based on the total percentage coverage (footprint) of buildings over the MSOA area
IF coverage < 20% THEN newDensity = newDensity x 1.4
# Finally, if the new density exceeds 100 dph, cap the increase to this level (this means that any areas that already exceed 100dph see no increase)
IF existingDensity > 100 THEN newDensity = existingDensity
ELSE IF newDensity > 100 THEN newDensity = 100
ELSE IF newDensity < 40 THEN newDensity = 40Applied across the entire city, this results in a net increase of some 900,000 homes, with each of the boroughs seeing the following uplift:
| Borough | Net New Homes |
|---|---|
| Barking & Dagenham | 15,070 |
| Barnet | 54,129 |
| Bexley | 37,985 |
| Brent | 32,719 |
| Bromley | 68,426 |
| Camden | 8,625 |
| Croydon | 67,165 |
| Ealing | 34,616 |
| Enfield | 57,520 |
| Greenwich | 28,739 |
| Hackney | 10,886 |
| Hammersmith & Fulham | 9,755 |
| Haringey | 18,646 |
| Harrow | 39,122 |
| Havering | 33,385 |
| Hillingdon | 47,922 |
| Hounslow | 27,313 |
| Islington | 7,336 |
| Kensington & Chelsea | 5,537 |
| Kingston upon Thames | 27,862 |
| Lambeth | 16,601 |
| Lewisham | 31,801 |
| Merton | 23,681 |
| Newham | 26,094 |
| Redbridge | 31,856 |
| Richmond upon Thames | 31,589 |
| Southwark | 17,817 |
| Sutton | 32,490 |
| Tower Hamlets | 11,633 |
| Waltham Forest | 21,822 |
| Wandsworth | 15,593 |
| Westminster | 5,040 |
| Total | 898,776 |
Unsurprisingly, those boroughs with the largest area see the greatest net increase in new homes, with Bromley at the top with 68,426 new dwellings, and Croydon slightly behind with 67,165. The inner London boroughs such as Camden, Kensington & Chelsea and Westminster see the least. The City of London is at zero and doesn’t appear in this table because it’s entirely within the Central Activities Zone and excluded as a result.
It’s important to remember that the figures I’ve listed above are limited to those areas within 800m of a station. That means there’s a lot of outer London excluded from my estimates, but imagine that we increase the density here as well, perhaps by a more modest amount…there would surely be many more thousands of homes that could be built in addition to the 900,000 I’ve suggested above.
Due to limitations in the mapping data, there are some anomalies which skew the figures in a few areas. For example, the Ordnance Survey mapping data doesn’t identify football stadia within its “sites” geometry, and while I’m ambivalent about the so-called beautiful game, and would be quite happy for every football stadium in London transformed into housing, I’m not sure Arsenal fans are quite ready for the Emirates Stadium to go the same way as their former ground just yet.
There’s also no adjustment made for those areas subject to wider regeneration schemes or empty sites. The large car park to the east of Stratford Westfield, which was going to be the home of London’s version of the Madison Square Gardens’ Sphere has an area of around 2.5 hectares and could feasibly provide 200-300 homes, but my methodology only shows an uplift of eight, as the density calculation is based on the entire MSOA area rather than this small section of it.
There are some other issues which could do with refinement. The MSOA boundaries do not take into account the type of space within them so, for example, with two polygons of equal size might have varying levels of undevelopable space. The total number of existing dwellings might be the same in both cases, and therefore the overall density would be shown as equal, however in reality the same number of homes could be crammed into a smaller area. This would mean that the impact of intensification would be more profound in the latter.
In reality, though, I’m not sure these anomalies make much of a difference overall as they seem to balance out across the wider picture.
So, these oddities aside, what does suburban intensification look like when applied to largely residential neighbourhoods?
The troubled history of Croydon’s Suburban Intensification SPD is beyond the scope of this article (I wrote about its demise for OnLondon), but it really was the gold standard for how outer London boroughs might encourage development on small sites in residential areas.
The guide provided a series of simple diagrams which mapped out the evolution of suburban blocks to show how, over an 18-year period, infilling gap sites and the replacement of some large houses with a combination of flats and houses. Let’s take a look at these to see what this means in numerical terms.
The first extract, below, shows a typical suburban block of detached houses. In the top example (2016) there are 37 detached houses. Although the plan is supposed to be a generic example, it’s almost certainly based on a real part of Croydon. There are large rear gardens and gaps of varying widths between the houses themselves.
In the “evolved” condition of 2036, several of the houses have been replaced with new buildings, and some have had new homes erected in rear gardens. From this plan it’s impossible to count the new number of dwellings that might be delivered in this way (it’s not really the point of the drawing), but the drawing does attempt to show the subdivision of the new buildings into the individual demises. Assuming nothing is taller than three storeys, I count at least 50 new homes, including a mix of houses and flats—and 29 of the original houses remain. In total, that’s a doubling of density – and it can hardly be said that the character has changed beyond all recognition: the large rear gardens largely remain and the coverage of buildings relative to undeveloped space is minimal.
This demonstrates that the kind of intensification we’re talking about is entirely achievable, and any objection on the basis of unacceptable change in character is for the birds.
Such an approach is entirely possible if we’re prepared to implement to bold policy reforms needed to enable this kind of development to come forward. In the brief period between the Croydon SPD being adopted in 2018, and it’s unceremonious scrapping in 2022, there was a remarkable uptick in small site development across the borough. The GLA’s annual Housing in London report shows that during this time Croydon delivered (delivered, not just approved) nearly 2,000 homes within developments consisting of fewer than 10 homes: more than three times the next highest, Barnet.
It’s time to adopt a London-wide policy which encourages similar levels of development across all of London’s suburbs. We know we need the homes. We now know we have the capacity. Let’s get on and do it!
You can have a play with my online map showing all areas of suburban intensification by clicking the image below.
In comparison to other similarly sized world cities, London is not very dense. With limited exceptions, such as Maida Vale, parts of Tower Hamlets and Kensington, much of the city has no more people per hectare than the satellite towns surrounding it. Arrive by train and this is only too apparent, with railways cutting through miles of two-storey Victorian terraces, only giving way to mansion blocks, high rise towers and high-density housing estates close to the heart of the city. Our housing is too thinly spread.
All land in London is a precious resource, and to sustain our capital’s economy and vitality we must use it more effectively—and more fairly.
Living in any major city—and benefiting from all the amenities and conveniences that it has to offer—comes with a moral responsibility to allow others to do the same. London’s suburbs could do much more to help provide the homes that the city so desperately needs—no more so than in those areas which benefit from good access to the public transport network, and where reliance on private car ownership diminishes. But in outer areas which have not been identified for large-scale regeneration, the process of intensification can be a tortuous one.
Obtaining permission to build even a small development of new homes is disproportionately complex, time-consuming and risky when compared to larger strategic developments.
Yet, even within existing planning policies, all the tools exist to establish
an environment where land seemingly lost to low-density housing can be
reinvigorated through a process of gradual densification.
Focusing on areas within a ten minutes’ walk of the city’s suburban train and Underground stations, there is the potential for up to a million new homes to be built, surprisingly quickly and effectively. When Mayor of London Sadiq Khan’s London Plan was adopted in 2021, it set out, for the first time, housing targets that must be achieved on small sites in each London borough.
This included the City of London Corporation and two Mayoral Development Corporations. In this case, small sites were defined as anything with an area of less than 0.25 hectares—roughly a third of a standard football pitch. Accompanying these targets was guidance and policies on how such development should be encouraged through plan-making and decisions.
Although it didn’t become formal policy until 2021, Khan’s version of the Plan had first been published in draft form at the tail end of 2017. The boroughs either embraced or resisted the Plan’s ambitions largely depending upon their political persuasion at the time. Labour-run Croydon Council, on the southern edge of the Greater London area, was one of the first out of the blocks, quickly establishing a set of planning principles to be followed by applicants wishing to bring forward small-scale development in suburban areas—generally towards the southern border with Surrey.
The award-winning Suburban Design Guide was adopted in April 2019, and provided clear parameters for the transformation of large, land-hungry houses into efficient, mid-rise developments. Essentially, if developers followed the rules established by the guidance, there would be no reason for their applications to be rejected. Some examples provided within the document demonstrated how, for example, a pair of adjoining large houses
could be turned into as many as 20 to 30 new homes.
Five years on from the adoption of the guidance, which was scrapped in 2022 by the incoming Conservative mayor, there is sufficient data to demonstrate the effect.
The impact this policy had on housing delivery—and the figures are remarkable. In the four-year period between 2018 and 2021, Croydon managed to complete nearly 2,000 new homes on small sites within developments consisting of fewer than ten dwellings (noting that even this is below the London Plan’s small site threshold, which determines plot size but not the number of homes within it).
The next highest delivering borough was Barnet, which in the same period delivered around a quarter of this figure.
The Suburban Design Guide neatly illustrated how larger areas of suburban housing could be intensified incrementally, resulting in a broader mix of smaller flats, townhouses, and large family homes. This is exemplified above showing how two large homes could be replaced with a block of flats and eight townhouses. This approach is borne out by the number of homes delivered in Croydon during a relatively short period of time: around 500 per year. There are 20 outer-London boroughs including Croydon.
If the remaining 19 had managed to deliver housing on small sites at the same rate, we could have had another 25,000 homes built by now.
Suburban intensification is tricky, and alone will never be able to deliver all the homes that London needs. But experience from Croydon has demonstrated that when the right conditions are in place, it can be implemented quickly, and at scale. As the country recovers from a long period of stagnation, this is one way that we can not only build the homes we need—quickly, where they’re most needed—but also promote economic growth.
This article was originally published in the Fabian Society pamphlet “Homes for London” in April 2024
When the latest iteration of the London Plan was adopted in 2021, for the first time in its 20-year history the policy demanded that the capital’s 35 planning authorities deliver a proportion of their overall housing targets on small sites – that is, with an area of no more than 0.25ha. The figures varied across the city, but the total number of homes to be found on these pockets of land stood at 120,000 – just under a quarter of the overall housing target for the whole of London.
This number was way below that originally proposed by the London mayor in 2018. Alongside a ‘presumption in favour’ of development on small sites close to public transport, the earlier version of his plan compelled planning authorities to find space on small sites for a quarter of a million homes, with the outer boroughs expected to deliver the lion’s share.
The pushback was inevitable, with London Assembly member Andrew Boff claiming, hyperbolically, that this amounted to a ‘war on the suburbs’. With the GLA lacking convincing data to demonstrate the figures were achievable, the targets were slashed before adoption.
But quiet, in the background, progressive boroughs knuckled down and got on with putting plans in place to promote intensification. In 2020 – nearly a year before the final version of the London Plan was adopted – Lewisham Council appointed RCKa and Ash Sakula to prepare dedicated guidance for new homes on its small sites. Just six months after the London Plan became official policy, Lewisham’s Small Sites SPD was formally adopted.
Two years on, as Sadiq Khan looks towards what’s increasingly likely to be a third and final term, he will be considering updates to the London Plan to cement his legacy as the mayor who did the most to tackle the city’s profound housing crisis. Small sites are likely to be a key focus of this work, and it would be a shrewd move to ramp up the small sites targets accordingly. But the question remains over whether there is sufficient data to justify this increase. To counter resistance to suburban intensification (as happened in Croydon) the new plan will need to be backed with robust evidence of the quantity and distribution of these sites.
So where are they? And how many? We tried to find out.
Land Registry data tells us that there are some 66,000 freeholds in Lewisham, and about 85 per cent of these meet the small-site criteria. Armed with our intimate knowledge of the Lewisham SPD and the site “types” it identifies, we set about mapping every one of them. Having built up a vast library of sites, based on the SPD, we trained an AI to categorise a bunch: backland, infill, amenity space and so on. Then, setting our learning model on the remainder of the borough, we created a complete map of Lewisham, including the location, size – and a rough idea of capacity – of every development opportunity from Deptford to Beckenham.
What we found was striking. While Lewisham’s London Plan 10-year small sites target is currently 3,790, based on early outputs from our data we think there might be capacity for two to three times this number. In fact, our AI model shows that there are enough sites to deliver Lewisham’s target on just two types alone. And as we trawl through the data, the AI improves. Ultimately, our plan is to apply the learning model to capture the whole of London.
Now, just because a site is developable it doesn’t mean it will come forward. The AI makes no distinction between public and private ownership, and many of the sites it has picked out will not provide new homes: some are private gardens, others active builder’s yards and occupied garages. But by establishing a policy landscape that makes planning less risky – as Lewisham has done – boroughs can go a long way to meeting these targets.
Extrapolating these figures across the rest of London, we think there’s sufficient capacity for at least 350,000 homes. Backed by our AI, there can be no more arguing over targets when we know not just how many sites there are. We can even point to them on a map. This is a huge opportunity, and those boroughs still lacking a dedicated small-sites policy should be compelled to implement it as soon as they can. It’s time to take small sites seriously.
This article was originally published in the Architects’ Journal.
This describes a typical limited tender process using standard methods of price / quality measurement, with a pricing ratio set at 50%. It demonstrates that this scoring ratio will almost certainly result in the cheapest price winning the project, even with a very low quality score.
The sample scores used to test this model is as follows:
| Bidder Name | Fee (£) | Quality Score (Out of 100%) |
|---|---|---|
| Practice A | 102,450 | 82 |
| Practice B | 78,000 | 75 |
| Practice C | 125,150 | 85 |
| Practice D | 98,500 | 68 |
| Practice E | 25,000 | 25 |
| Practice F | 107,000 | 76 |
Note that the scoring for Practice E has deliberately been set very low, scoring just 25% for quality but also coming in at less than a third of the next cheapest bid. Unfortunately, such wild variations in price scoring are not unusual when bidding for public sector work. There are few other sectors where any sensible person would accept a tender which was so much lower than the broad average of others; yet, for architectural services, such low-ball bidding is common—and rarely rejected, despite the Public Contract Regulations allowing commissioning bodies to reject “abnormally low” bids. Given that architectural salaries are broadly similar, the only explanation for low fees is that the bidding practice is anticipating spending far less time working on the project than others. There are no innovations in the market which enable practices to significantly reduce the cost of delivering their services without reducing amount of time spent performing it, and therefore the quality of the design which derives from these efforts.
For the purpose of this exercise, the most expensive practice has also scored the highest for quality. This is useful to demonstrate how different scoring methods can achieve a reasonable balance between quality and price, delivering best value for the client.
The following sections explore different methods of scoring and, using the figures above, illustrates how different ratios and scoring methods result in very different outcomes.
In our example, the lowest financial bid was £25,000, and the highest £125,150. Scoring was based on a quality / cost ratio of 50:50.
The highest quality score was 85% which, when adjusted to the quality ratio of 50%, results in a quality component of 42.5%.
Using this method of scoring, Practice E (the cheapest) is the winning bidder. Clearly, any practice securing work with a fee of less than a third of the nearest bidder is either going to be unable to service the project properly or will be making a significant loss. Nobody in their right mind would accept such a low tender from, say, a builder, as clearly the quality of the work would be commensurately poor. Yet this happens all the time when it comes to commissioning architectural services.
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 50.00) | Quality Score (%) (max. 50.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice E (WINNER) | 25,000 | 50.00 | 12.50 | 62.50 |
| 2 | Practice B | 78,000 | 16.03 | 37.50 | 53.53 |
| 3 | Practice A | 102,450 | 12.20 | 41.00 | 53.20 |
| 4 | Practice C | 125,150 | 9.99 | 42.50 | 52.49 |
| 5 | Practice F | 107,000 | 11.68 | 38.00 | 49.68 |
| 6 | Practice D | 98,500 | 12.69 | 34.00 | 46.69 |
Out of interest, let’s test the same figures using an alternative ratio: 70% quality and 30% price. This gives us the following results:
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 30.00) | Quality Score (%) (max. 70.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice C (WINNER) | 125,150 | 5.99 | 59.50 | 65.49 |
| 2 | Practice A | 102,450 | 7.32 | 57.40 | 64.72 |
| 3 | Practice B | 78,000 | 9.62 | 52.50 | 62.12 |
| 4 | Practice F | 107,000 | 7.01 | 53.20 | 60.21 |
| 5 | Practice D | 98,500 | 7.61 | 47.60 | 55.21 |
| 6 | Practice E | 25,000 | 30.00 | 17.50 | 47.50 |
This result isn’t ideal either, as now the most expensive bidder has won the day, with a quality score that’s only marginally higher than the nearest competitor, but a pricing score which is a fifth higher.
Perhaps this suggests that the relative to cheapest method of scoring is never the best one to use?
An alternative way of assessing quality is to award all of the available quality points to the best submission. Having established a shortlist of what are, presumably, the most capable qualifying competitors on the market, it is nonsensical that the cheapest price tender receives the full 50% of the price score, but the best submission does not receive the full 50% of the available points for quality.
It may be that assessors have already given the best submission the full available score for quality, but if not, this method assesses all quality scores relative to the maximum percentage available, as well as giving the maximum marks for price to the cheapest bid. In other words, the best quality submission receives the whole 50% available, with all the remaining scores calculated proportionately to this.
It goes some way to preventing the cheapest bid “buying” a project with an inferior submission accompanied by an abnormally low financial submission—but does it ensure that the client is receiving the best value for money?
In this example, and using the same 50:50 ratio, Practice E still wins, having scored 50.00% for price and 14.71% for quality. So, pursuing this method doesn’t seem to make much difference.
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 50.00) | Quality Score (%) (max. 50.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice E (WINNER) | 25,000 | 50.00 | 14.71 | 64.71 |
| 2 | Practice A | 102,450 | 12.20 | 48.24 | 60.44 |
| 3 | Practice B | 78,000 | 16.03 | 44.12 | 60.14 |
| 4 | Practice C | 125,150 | 9.99 | 50.00 | 59.99 |
| 5 | Practice F | 107,000 | 11.68 | 44.71 | 56.39 |
| 6 | Practice D | 98,500 | 12.69 | 40.00 | 52.69 |
The mean narrow average (MNA) method of scoring discounts the highest and lowest tenders, establishing the mean value of those that remain, and scores all tender prices against the closest to that mean value. Fee bids which are less than half, or more than double, the mean value receive a price score of zero.
With Mean Narrow Average scoring, bidders are compelled to identify the appropriate fee required to service the project rather than cutting prices to buy the job, which could lead to underperformance or claims for additional fees later in the programme. Excessively low—or high—fees are penalised.
For these pricing figures, the mean (average) bid, including the lowest and highest fee submission, was £89,350, and the median was £100,475.
The highest and lowest fee bids have been excluded when calculating the mean average.
Using Mean Narrow Average with a price ratio of 50% results in Practice A being the winning bidder. Intuitively, that seems like a reasonable result: Practice A scored very close the median score (there were two more expensive bids, and three cheaper ones), and scored second highest in terms of quality. The full rankings are as follows:
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 50.00) | Quality Score (%) (max. 50.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice A (WINNER) | 102,450.00 | 46.91 | 41.00 | 87.91 |
| 2 | Practice D | 98,500.00 | 48.96 | 34.00 | 82.96 |
| 3 | Practice F | 107,000.00 | 44.55 | 38.00 | 82.55 |
| 4 | Practice B | 78,000.00 | 40.42 | 37.50 | 77.92 |
| 5 | Practice C | 125,150.00 | 35.15 | 42.50 | 77.65 |
| 6 | Practice E | 25,000.00 | 0.00 | 12.50 | 12.50 |
To test a few alterative scenarios, I’ve run the same figures as above, but using different price/quality ratios. In most cases, the outcome is the same: Practice A wins, right up to the point where price comprises just 10%. Then, the highest scoring quality submission—and the most expensive bid—is the one that’s successful.
This means that the use of Mean Narrow Average is probably best deployed with a quality/cost ratio of around 60% – 70%.
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 40.00) | Quality Score (%) (max. 60.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice A (WINNER) | 102,450.00 | 37.53 | 49.20 | 86.73 |
| 2 | Practice F | 107,000.00 | 35.64 | 45.60 | 81.24 |
| 3 | Practice D | 98,500.00 | 39.17 | 40.80 | 79.97 |
| 4 | Practice C | 125,150.00 | 28.12 | 51.00 | 79.12 |
| 5 | Practice B | 78,000.00 | 32.34 | 45.00 | 77.34 |
| 6 | Practice E | 25,000.00 | 0.00 | 15.00 | 15.00 |
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 30.00) | Quality Score (%) (max. 70.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice A (WINNER) | 102,450.00 | 28.15 | 57.40 | 85.55 |
| 2 | Practice C | 125,150.00 | 21.09 | 59.50 | 80.59 |
| 3 | Practice F | 107,000.00 | 26.73 | 53.20 | 79.93 |
| 4 | Practice D | 98,500.00 | 29.37 | 47.60 | 76.97 |
| 5 | Practice B | 78,000.00 | 24.25 | 52.50 | 76.75 |
| 6 | Practice E | 25,000.00 | 0.00 | 17.50 | 17.50 |
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 20.00) | Quality Score (%) (max. 80.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice A (WINNER) | 102,450.00 | 18.76 | 65.60 | 84.36 |
| 2 | Practice C | 125,150.00 | 14.06 | 68.00 | 82.06 |
| 3 | Practice F | 107,000.00 | 17.82 | 60.80 | 78.62 |
| 4 | Practice B | 78,000.00 | 16.17 | 60.00 | 76.17 |
| 5 | Practice D | 98,500.00 | 19.58 | 54.40 | 73.98 |
| 6 | Practice E | 25,000.00 | 0.00 | 20.00 | 20.00 |
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 10.00) | Quality Score (%) (max. 90.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice C (WINNER) | 125,150.00 | 7.03 | 76.50 | 83.53 |
| 2 | Practice A | 102,450.00 | 9.38 | 73.80 | 83.18 |
| 3 | Practice F | 107,000.00 | 8.91 | 68.40 | 77.31 |
| 4 | Practice B | 78,000.00 | 8.08 | 67.50 | 75.58 |
| 5 | Practice D | 98,500.00 | 9.79 | 61.20 | 70.99 |
| 6 | Practice E | 25,000.00 | 0.00 | 22.50 | 22.50 |
Out of interest, what happens is we reverse the ratio to prioritise cost over quality, using the Mean Narrow Average scoring method? Well, here we go:
| Ranking | Bidder Name | Fee (£) | Price Score (%) (max. 80.00) | Quality Score (%) (max. 20.00) | Total Score (%) |
|---|---|---|---|---|---|
| 1 | Practice D (WINNER) | 98,500.00 | 78.33 | 13.60 | 91.93 |
| 2 | Practice A | 102,450.00 | 75.06 | 16.40 | 91.46 |
| 3 | Practice F | 107,000.00 | 71.28 | 15.20 | 86.48 |
| 4 | Practice B | 78,000.00 | 64.67 | 15.00 | 79.67 |
| 5 | Practice C | 125,150.00 | 56.24 | 17.00 | 73.24 |
| 6 | Practice E | 25,000.00 | 0.00 | 5.00 | 5.00 |
Surprisingly (at least to me), Practice A still scores very highly, coming second to Practice D which had a similar, but slightly lower price, but the second-to-bottom quality score. Nobody in their right mind would advocate for the commissioning of architectural services based on such a skewed ratio, but this serves to demonstrate that our earlier conclusion that a quality ratio of between 60% and 70% is likely to yield the best outcome for everyone.
A combination of Mean Narrow Average (MNA) and Relative to Best scoring methods could also be used, i.e. where the price score is calculated as the MNA result with the highest quality score receiving all of the points available, but given the success of the simple MNA method, it’s probably unnecessary.
All of these figures have been generated using a live model which you can test with different figures of your choice, here. And if you’re a procurement officer or public client, try putting so real-life tender figures you’ve received into this too, and see whether the outcome would have been any different.
After posting this article on LinkedIn, I’ve been directed to a comprehensive analysis of the various pricing models available to the public sector, written by Rebecca Rees of Trowers & Hamlins, which sets these out far more comprehensively than I could ever hope to do.
You can download the document using the button below.
I contributed to an article in the Economist newspaper about the state of Britain’s green belt, and the potential to build hundreds of thousands of homes around rural stations.
No aspect of planning policy is quite as divisive, or as misunderstood, as the green belt. Covering some 16,000km2, England’s 14 green belts occupy one-eighth of England’s total area (equivalent to three-quarters of the area of Wales, if that’s your preferred unit of measurement).
London’s metropolitan green belt alone stretches from Haslemere in Hampshire to the North Sea—a distance of some 100 miles—and with an area of over half a million hectares is over three times larger than the city itself.
Although its origins precede the Second World War, the green belt was formally established by the Town and Country Planning Act of 1947, which allowed planning authorities to protect open space with this designation. And while the policy has been extremely successful in achieving its original objective of constraining urban expansion, three-quarters of a century on, it’s surely time to reform this anachronistic policy and ensure it meets the needs of the modern world.
Among the marshes of estuary Essex and the undulating hills of Hampshire, there are motorways, waste transfer depots, landfill sites, distribution centres, poultry farms, golf courses and car parks that are all protected from development by the simple virtue of their presence within the green belt. Many areas of otherwise undeveloped space are of limited quality too.
One of the most prominent obstacles to a sensible discussion is the fact that the arguments for and against the green belt have become so utterly polarised. Listening to both sides of the debate, you’d be forgiven for thinking that we face a simple binary choice between the preservation of dwindling landscapes and concreting over every last inch of them. And yet, the green belt has actually grown in recent years. It’s preposterous to claim that it’s under threat.
While we can’t lay the blame for our pitiful national productivity solely at the feet of green-belt policy, it’s clear that our inability to build – whether it’s homes, railways or solar farms – in the places we need, is partly a product of misplaced constraints on development.
Lobby groups like the Campaign for the Protection of Rural England (CPRE) insist that any rethink of the green belt isn’t necessary, but these claims simply don’t stand up to scrutiny. Its latest State of Brownfield report confidently concluded that 1.2 million homes could be built on brownfield land alone, but this is only a quarter of the current shortfall, and certainly insufficient to meet future demands. Furthermore, many of the areas it proposed for new housing aren’t even in the places where need is most acute. I’m not aware of many CPRE members upping sticks from leafy Surrey to the post-industrial wastelands of northern Britain.
There’s a common misconception about the purpose of the green belt in the public sphere, with many mistakenly believing that its purpose is to protect precious rural landscapes. Close to where I live, campaigners against the Cockfosters car park development argued that planning permission should be refused because it would be visible from the green belt, as if the prospect of catching a glimpse of it whilst hurtling along the M25 was a prospect so horrific it didn’t bear thinking about.
In a poorly researched article in the Guardian, Simon Jenkins recently pondered why there wasn’t the same level of protection for the country’s rural parts in the same way that our cities are preserved by Conservation Areas. Any architect or planner could have pointed him towards a whole bunch of protections: AGLV, AONB, Ancient Woodland, SSSI, Ramsar and National Parks, to name a few. Rural areas in fact benefit from far more protections than our towns and cities do, but this is indicative of a wider misunderstanding of planning policy, where green belt is wrongly conflated with other designations that actually do pertain to landscape quality and biodiversity.
It is true that too many open spaces have been relinquished to low-quality, car-dependent sprawl, and nobody – other than the volume housebuilders – wants to see more of that. But, despite what the CPRE claims, we cannot build the homes our country needs on brownfield alone, so some release of open space is inevitable and probably desirable.
There’s a compelling argument that green-belt policy is actually damaging the valuable open spaces that the CPRE is keen to protect. Because building homes is so difficult in places with large areas of green belt, developers target sites beyond it, creating their unsustainable car-dependent sprawl on the outskirts of settlements instead.
Likewise, building new homes on brownfield land far from public transport makes little sense when we could instead cluster them around stations in rural areas, and as an added bonus, give millions of families convenient access to the countryside – something the CPRE claims to support. Not that this should be a free-for-all. Any release of green-belt land for development must be accompanied by robust masterplanning and design codes to ensure that when land is set aside, it is done in a way that is sustainable, accessible, and responsive to local character.
The amount of green belt that would need to be lost to provide a million new homes is so small that it’s little more than a rounding error. Even with modest densities, we’d lose just 1 per cent of the green belt to deliver a million homes. That’s a price worth paying.
Labour’s recent pronouncements in this respect are welcome – if vague . But there are encouraging signs from planning authorities, such as Enfield, that are prepared to tackle this challenge head-on. And emboldened by a lacklustre field of opposition candidates, the mayor of London might revisit his blanket opposition to green-belt release in the next iteration of his city-wide spatial plan. We can but hope.
It’s surely time to set ideology aside and face the fact that an evidence-based review of green-belt policy is long overdue. If we’re to have any chance of facing the challenges of the coming decades, we need to roll up our sleeves and, maybe, loosen our belts.
This article originally appeared in the Architects’ Journal.
Since its introduction in the post-war period, where it started life as a pragmatic constraint on urban sprawl, the green belt has mutated into an ideological battleground.
Those who consider it to be an unnecessary constraint on progress advocate for its complete removal; others consider it to be sacrosanct, inviolable from development and to be protected at all costs.
The reality is—of course—more complex than this, yet it cannot be argued that a blanket ban on any form of development within the green belt, or any amendments to its boundaries, is either pragmatic or reasonable.
It is increasingly apparent that green belt policy needs to be revisited to ensure that it is delivering the best outcomes for citizens. There is not enough land to deliver the homes that we need.
Local planning authorities, who are responsible for managing green belt boundaries, are unlikely to be able to undertake such a task, needing a unified strategy spanning multiple authorities.
Given the strength of feeling and the geography of England’s green belt, this should take the form of a Royal Commission. Only an inquiry with this authority will be able to bring together the relevant parties to properly consider the full range of issues.
As it becomes increasingly difficult to find affordable housing within our cities, those who need to travel frequently to work are forced to live beyond the green belt – in particular, those on lower-paid jobs and the key workers on which cities rely. This adds significant time to the daily commute and acts as a huge drain on productivity and hampers growth.
A core objective of green belt policy is to prevent the merging of adjacent settlements. This is sensible. On the other hand, the almost blanket ban on any significant development within designated green belt represents a misunderstanding of its original purpose.
Many cities are surrounded by smaller towns which sit within the green belt: St Albans, Coventry, Guildford, Potters Bar, Macclesfield: these are all towns which are located entirely within the green belts of England’s cities. Green belt inhibits the merging of adjacent settlements, but also prevents the introduction of new settlements within it, even if they possess clear boundaries and sufficient green space to ensure they remain distinct from one another.
England’s train routes tend to radiate from the centre of its cities. Along many of these are stations which benefit from short travel times to urban centres, but which are located entirely within the green belt or open land.
These rural stations provide an obvious opportunity for high-density development close to public transport and within easy reach of places of work.
Multiple studies have shown that these rural stations have the capacity to sustain well over a million new homes. Yet restrictive planning policies, not least green belt protections, prevent this from happening.
10 minutes’ walk equates to around 800m (half a mile). A circle around a single station with a diameter of a mile could, even at modest densities, support up to 15,000 homes. That’s around half of the total number of homes that will be delivered on the Olympic Park.
Unlike Victorian and pre-war England, where new train lines and stations were built so that the land around them could be developed for housing, we would not need to construct new railways for this purpose. They already exist. But the mechanisms for bringing forward such development are subject to considerable planning constraints which often delay projects for years.
To speed up the delivery of homes in these locations we might adopt a Development Corporation model, with planning powers devolved to a specially incorporated body responsible for delivery. These development corporations would be responsible for bringing forward development in these locations within a defined period – perhaps 10 years – acting as a “master developer”, acquiring land and setting out a masterplan for each location, accompanied by a strict design code informed by the location and local character.
Design codes should set out building heights, street patterns, the quantum of accommodation, orientation and massing, but not favour any particular style: they should promote specificity and a sense of place, rooted in an understanding of context, but this does not mean that they should attempt to ape local vernacular styles.
To coordinate development along transport networks, development corporations could be established following railway lines. This would allow the introduction of social infrastructure, such as schools and healthcare facilities, which need a certain population to support. For example, Meldreth, Foxton and Shepreth stations, which lie on the London to Cambridge line, could together provide homes for over 50,000 people—yet none of these stations is more than 12 minutes apart.
The introduction of new active transport routes, such as cycleways, could also be enabled through the acquisition of land either side of the existing railway, linking these new settlements by sustainable means.
It is not just stations within rural areas that should benefit from development. Transport for London has struggled with securing planning consent for some of its suburban stations.
Therefore, there should be the introduction of new policies to make such development easier. This might take the form of a “presumption in favour” of development close to all stations – including those in urban areas, where densities are significantly higher than those in the surrounding areas.
To mitigate the loss of open space in rural areas, for every hectare taken out of green belt for the purposes of development, an equivalent area could be included within it elsewhere, resulting in no net loss of protected space.
Building within ten minutes’ walk of England’s accessible stations could yield at least 1.2m homes, with the loss of just 680 square kilometres of green belt (in fact it grew by 242 sq km between 2022 and 2023 alone).
There are more reasons to build around stations than not. The mild inconvenience faced by those living in outlying areas who will be unable to use station car parks will be more than mitigated by the huge gains achieved through the provision of new homes, social infrastructure, increased productivity, and economic growth.
This article was first published in the Fabian Society pamphlet “Homes for Britain” in March 2023.
Perhaps we’ve been desensitised to the stark realities of the housing crisis, with the ‘keep calm and carry on’ attitude of the baby boomer generation (which, we need to remember, lived through very little genuine hardship in the post-war years) prevailing. But in other any functional democracy where 3.6 million young adults remained at home due to generational housing inequality, this would be a national scandal. According to some estimates, we are millions of homes short of where a country with our population should be.
The fact that none of the mainstream parties have yet to articulate a plan to address this crisis is a damning indictment of current political discourse. Not only is this a social failure, it’s an economic one too. Productivity in the UK is woefully low, with young people unable to relocate to where jobs are, or otherwise struggling with extended commutes. Worse still, a generation is delaying starting families as housing costs, employment precarity and overcrowding threaten to detonate a demographic time-bomb which nobody seems willing to defuse.
I live on the northern fringes of London, the final stop before the railway plunges into the capital’s green belt. In less than 30 minutes I can be in central London, on one of six or more trains that run every hour. There are many similar lines that extend out of London, providing convenient access both to the city and countryside for those who live close to them. It’s difficult to think of more appropriate locations for new homes.
Resistance to urban expansion is often (rightly) based on a fear of perpetuating low-density, car-dependent sprawl on the outskirts of our rural towns and villages. So it follows that, in order to create new homes less dependent on private vehicle ownership, we should instead look to optimise development around existing public transport networks. But how many homes might we build? And where?
Using various publicly-accessible data sources, I mapped every train station in England and examined the constraints on development around each. Anywhere at risk of flooding was excluded, as was land within national parks, existing urban areas, or those sites protected by landscape designations because of their quality or scientific interest. Green belt, though, I considered fair game: regardless of what the CPRE claims, it’s increasingly clear that we cannot deliver the homes we need on brownfield alone, and a pragmatic review of green belt policy is long overdue. Drawing an 800m radius around each station (equivalent to a 10 minute walk) and extracting constraints, I arrived at a pleasing 777 stations with development potential.
Not every one is close to a population centre, and some are used by only a handful of passengers each year. As there’s no easy method of measuring current or potential frequency of service, I pegged target densities to passenger annual numbers. Those stations closest to major cities were assigned 75 homes per hectare, those in remote areas much less. But even at modest densities this reveals a huge potential for delivering the new homes we need.
A case in point: Ashwell & Morden sits mid-way between London and Cambridge, with frequent services to both. Yet look at it on Google Maps and you’ll see the station is surrounded by little more than open fields. It’s not even in the green belt of either city. Even at modest densities, this site could accommodate 7,000 homes for some 30,000 people. Development of this scale, supported by a decent masterplan and robust design coding, could provide social infrastructure and sustainable travel for residents. And rolling out a similar approach to the rest of the country could be transformational in providing high-quality homes in sustainable locations such as this.
The familiar complaint from those in comfortable circumstances that we risk ‘concreting over the countryside’ doesn’t stand up to scrutiny when – even with these additional numbers – we’d lose less than 0.4 per cent of England’s rural space in the process (Britain’s roads take up around three times this area).
The coming general election could be a turning point in whether we take genuine steps to address generational inequality, particularly in respect of housing delivery. Building homes around rural stations won’t go the whole way to achieving this but, combined with other bold ideas, it could play a part.
This article was originally published in the Architects’ Journal.
Announced with considerable fanfare in 2018, and becoming formal planning policy the following year, Croydon Council’s Suburban Design Guide supplementary planning document (SPD) was London’s first – and, even now, most ambitious – attempt at encouraging its woefully sparse outer areas to do more to meet the city’s housing needs.
The publication made no bones about its intentions. “The evolution of the suburbs to provide homes that will meet the needs of a growing population,” its introduction stated. It went on: “It must however be recognised that delivering approximately 10,000 homes in the suburban places of Croydon will result in an evolution of the existing character of suburban streets, and that the increased density of homes can impact on the amenity of existing residents if not properly managed.”
The guide was rightly heralded as a progressive and practical attempt to deliver new homes in those places best able to accommodate them, and it was quickly celebrated as an exemplar for how to sustainably densify the city’s fringes. Croydon’s in-house spatial planning team took home a planning award in 2019 and the guide was highly commended at the New London Awards the same year. From a personal point of view, it was an important reference for my architectural practice’s own small sites SPD in Lewisham, which was adopted by the council a year ago this month.
However, just three years on, Croydon’s Suburban Design Guide is no more. In May, the borough’s voters elected Conservative Jason Perry as their first Mayor. He had promised that one of his first acts if he won would be to revoke the “dreaded” SPD, which he claimed has “destroyed” Croydon’s character and led to the “destruction” of homes – a peculiar claim given the huge number of dwellings it had in fact enabled in a relatively short time.
The SPD had been produced in response to Sadiq Khan’s London Plan, which was first published in draft in 2017 but not formally adopted until March 2021. The Plan enshrined the need for the boroughs to consider the importance of small sites in meeting London’s housing needs. For the first time, every London planning authority was tasked with finding ways to encourage development on sites with a total area of less than a quarter of a hectare (roughly one third of a standard football pitch), with a ten-year small-site housing target set out in unequivocal terms.
Not only was this to be a way of delivering much-needed homes, the Plan also acknowledged the importance of nudging small-scale developers back to a market that had become dominated by a handful of volume housebuilders since the 2008 financial crash.
Inevitably, the draft Plan’s publication was met with hyperbolic outcry: a “war on the suburbs” is how Conservative London Assembly member Andrew Boff described the proposals, oddly failing to recognise that small-scale infill development tends to deliver a higher proportion of family homes than small flats; another bête noire of his.
After a robust challenge from several outer London boroughs, Khan was forced to dramatically reduce the small sites housing targets and blunt the “presumption in favour” the Plan had demanded. Having been required to deliver the highest absolute number of homes on small sites of any of the London planning authorities, Croydon Council received the greatest net reduction, with its ten-year target reducing from 15,110 to 6,410 – a drop of nearly 60%.
Croydon is one of London’s least dense boroughs, even when its 2,300 hectares of Green Belt and Metropolitan Open Land are excluded from the calculation. At 65 people per hectare, it has around a third the population density of Islington. Its number of homes per hectare is broadly the same as other similarly sized outer boroughs, such as Barnet and Kingston. And, like those boroughs, it clearly can accommodate many more.
In its defence, Croydon has delivered a lot of new homes in the last decade and a half—more than any other borough—so it’s perhaps fair to argue that the council had indeed “played its part” in meeting the city’s housing need. Yet the figures are misleading. Much of Croydon’s new development is concentrated in the urban centre, where clusters of tall residential towers have sprung up around East Croydon station within easy reach of central London.
This is good. Less good, however, is the quality of much of this new housing. Until halted by the implementation of an Article 4 Direction, more new dwellings were created under dubious permitted development rights, which allow commercial buildings to be cheaply converted to residential outside conventional planning permission, in Croydon than in any other borough. It’s not a statistic to be proud of given the sub-standard quality and small size of many of them. Until the introduction of the Suburban Design Guide, the leafier southern wards had got away without making much of a contribution.
Aware of the inherently risky nature of small sites, and that developers interested in taking them on are less able to absorb the cost of delayed or unpredictable planning decisions, the guide presented a series of suburban intensification methods which, if employed, were highly likely to be nodded through.
The acquisition of a pair of suburban semis – of which Croydon has many thousands – could easily lead to their replacement with a small block of flats at the front of the plot and mews houses in the rear garden. In this scenario, there could be a net gain of up to ten homes with no loss of family housing. The guide demanded that new development be no lower than three storeys – a not unreasonable request if we are to have any hope of densifying London’s laughably sparse peripheral areas.
Of course, this inevitably meant that some areas of the borough would experience some change, but that is a small price to pay for living in this great city. There would be benefits too. As the guide’s introduction made clear, higher housing density inevitably attracts local amenities and better social infrastructure – shops, restaurants, schools, healthcare and community facilities – that might actually mean suburbanites wouldn’t need to hop into their giant SUVs quite so often.
It’s no surprise that those areas most resistant to the principle of intensification tend to lie on the city’s fringes, and often consider themselves to be residents of the Home Counties rather than London. The Green Belt itself is often declared as an unnecessary and anachronistic constraint on the capital’s growth. There is some truth in this, but we should start by turning our attention inwards a little: it is the sparsely populated “greyfields” of outer London we need to tackle first.
The citizens of the suburbs must accept that the evolution of local character is a small price to pay for easy access to everything this wonderful city has to offer – and that it is also their duty to enable others to do the same. Croydon’s Suburban Design Guide was a valiant and progressive attempt to achieve this. We should mourn its passing.
This article was originally published by OnLondon.
The summer lockdown of 2020 in England allowed some of us who were working from home to explore parts of our neighbourhoods where we had not previously ventured. I took the opportunity to poke around bits of north London close to where I live.
Most days my walks took me from familiar Victorian terraced streets into the green fringes of Barnet. Reaching the edge of the built-up area, my route took me along a path that plunged into the dense, ancient woodland of Monken Hadley Common.
This comprises part of the London Outer Orbital Path (LOOP) linking Cockfosters at the end of the Piccadilly Line to Chipping Barnet a few kilometres to the west. In the heart of the woodland lies Jack’s Lake, a popular spot for fishing and picnicking.
On a map, the common’s straight northern edge marks a clear boundary between the London Boroughs of Enfield and Barnet; a buffer of green belt separating the wealthy community of Hadley Wood – home to footballers, pop stars and bankers – and the working-class neighbourhood of New Barnet immediately to the south.
The dividing line is not just administrative or economic. Visitors to the common unfamiliar with the well-trodden paths through the trees find their route blocked by a battered sign nailed to a tree warning:
With club membership capped at 500 and fees of more than £2,000 per year, the course is an extraordinarily exclusive use of land. Yet is it far from unique. It is only one of seven courses in use in Enfield, and its proximity to the borough’s boundary with Barnet places it ten minutes’ drive from half a dozen more.
Enfield’s courses together take up an astonishing 330ha, around 4% of the borough’s total area. Two – Hadley Wood and Bush Hill Park – are privately owned, and yet the freeholds to the five other courses are under public control.
One, on the far eastern flank of the borough, is owned by the Lee Valley Regional Park Authority. The other four belong to Enfield Council, totalling 180ha. Coincidentally, this is almost precisely the same area of green belt that the borough is currently – and controversially – proposing to remove from its green belt in its draft local plan.
This is a common pattern across London – particularly in the outer boroughs where fingers of green belt push their way towards the centre between radial rail and tube lines. Nearby Barnet has nine courses; Bromley in the south east of London has 11. Although Richmond upon Thames has only seven courses, together they take up 7% of the borough’s area, the largest proportion of any in London. Southwark’s Dulwich & Sydenham Hill Golf Club is the closest to central London, owned by the Dulwich Estate, and extends to more than 33ha in the borough’s southern tip.
At the time of writing there are 94 golf courses in use in Greater London. Cumulatively they occupy an area greater than the whole of Brent, which is home to 330,000 people. London’s publicly owned courses alone – of which there are 43 – take up an area larger than the borough of Hammersmith and Fulham, with a total population of 185,000.
When the city is under such pressure to provide homes for a growing population and with house prices continuing to spiral upwards, it is only right to question whether golf represents a just use of a scarce resource.
In Enfield, where there are six golf courses in the affluent western half of the borough, there are some 10,500 people living in temporary accommodation and 4,500 households on the council waiting list. Everyone in dire need of housing in Enfield could be provided within a home by developing just two of the council’s own courses at modest densities.
Of course, wholesale redevelopment of Enfield’s – or any borough’s – fairways and putting greens is not realistic. Irrespective of the political challenges, the planning constraints are considerable. Most golf courses sit either in green belt or metropolitan open land, the latter being a planning designation unique to London that affords the same protections as green belt.
But surely it’s right to question whether a game enjoyed by a small proportion of the population – around 1%, and likely far less in a relatively youthful city such as London, should occupy such a huge amount of valuable land.
It’s true that golf has had a modest resurgence during the pandemic, but this is likely a temporary blip in a long-term decline. Despite this – and with clear evidence that many golf clubs are struggling to survive – the idea that we might take a more nuanced approach to the city’s green spaces is usually met with outrage.
Others are investigating ways to release land for other uses that might provide much-needed income to invest in tired facilities, but they come up against the very planning barriers imposed to protect them from unwanted development. Even when development is necessary for a club’s survival, the mere suggestion of building on surplus green space is met with opprobrium.
The argument reinforced by planning policy is that golf courses provide vital open space accessible to Londoners and they contribute to the city’s ecology. But this is a fallacy. High water usage and frequent mowing of a largely monocultural landscape do not, as many claim, provide significant biodiversity benefits. While trees and hedges along the edges of fairways attract wildlife, the same argument could be made about motorways – and no one is promoting those as a means to green the city.
An average-sized suburban golf course might have around one-fifth of its area occupied by either fairways or green, half by rough, and 30% by tree cover. That’s not an insignificant amount; but rewilding and opening these spaces to the public, as Lewisham Council did in 2019 at Beckenham Place Park, could offer significant ecological benefits to the wider area.
It’s become clear during the pandemic, if evidence were needed, that open space has an important part to play in enhancing mental and physical well-being. Before the introduction of housing space standards there was nothing to stop developers building flats without external private amenity space, and millions of homes were built lacking such provision.
Fortunately, parks and gardens occupy around 11,500ha of land in London, and playing fields and sports grounds 5,600ha. That compares well with other global cities, and a third of London’s area considered to be green.
Golf courses are the third largest category of open space, though, occupying more than 4,330ha. With each golfer requiring around 1.6ha to play, this significantly limits the capacity of the city’s courses to deal with a wider societal need.
Indeed, one of the definitions of metropolitan open land as set out in the London Plan is that it must ‘serve either the whole or significant parts of London’ – a difficult argument to make when the density of use is so limited and the barriers to entry so high. The area required for a single golfer to enjoy a round could provide homes for approximately 380 people. So is it time to start replacing golf courses with housing?
Although it is often presented as a binary choice between fields or concrete, development in open space does not have to be a zero-sum game. There is no reason why, with a little creativity and imagination, we cannot find ways to improve public access, promote biodiversity, provide vital new social infrastructure, parkland, food production, leisure uses and new housing, while at the same time respecting the important contribution that open spaces make to the character of suburban London – or even enhance them.
Clusters of high-density housing, set in biodiverse landscapes and linked to the wider public transport network by cycle routes, would be entirely compatible with the broader policy aims of the London Plan, if carried out in an intelligent way. Policy must evolve to allow this to happen.
This could be achieved without a net loss of golfing capacity. The intelligent consolidation of a single course could shorten some higher-par holes without reducing their total number, releasing much-needed land for other uses and improving the experience for time-poor players.
A surprising number of London’s courses lie in easy reach of public transport or close to high streets. More than 1,400ha – exactly a third – lie within what the London Plan considers to be highly accessible zones and therefore suitable for incremental intensification.
Public golf course areas could provide homes for 140,000 people. If redeveloped, London golfers would still have 1,500 holes to play. There are further 74 golf courses within 5km of the outer edge of London. 1,400ha of highly accessible zones. 2,800ha free highly accessible zones left according to the London Plan
The areas of public courses that meet these criteria could alone provide homes for 140,000 people, and London’s golfers would still have 1,500 holes to play. Most of London’s courses lie within the outer edges of the city, and there are a further 74 courses no more than 5km over the border into the Home Counties. Golfers are not deprived of choice when it comes to places to play.
The challenges facing London are myriad, and no single change will solve the current housing crisis. But failing to house those who need a decent place to live is not a result of factors outside our control, but a choice. Access to decent housing is one of the most significant contributors to social and economic inequality. Perhaps more sophisticated thinking about the use of land in London is one way in which we might start to bridge this divide.
This article was first published in the RICS Land Use Journal on 26 July 2022.
Together with campaign group PricedOut, I’ve written a brief guide on how to support planning applications for new homes.
The planning system is too often skewed in favour of those who object to new housing in their area, so this guide sets out how those with little knowledge of how planning works can register their support for much-needed new housing.
The Mean Narrow Average method of scoring tender submissions is an alternative way of assessment which prioritises quality over price in a more intelligent manner than the traditional method of scoring bids, whilst also ensuring that financial offers remain within acceptable parameters. This page allows you to test both methods using your own data.
Take a stroll around any London suburb and before long you’ll come across a pocket of land – a row of garages too small for modern cars, an overgrown gap of uncertain ownership nestled between houses, a sliver of broken concrete beside a railway line – which, with a little tenacity and creativity, could provide space for a new home or two. These sites exist in their thousands across London and are particularly abundant in the outer fringes of the city.
London itself is not very dense. Islington, with around 160 people per hectare, is the borough with the greatest number of people relative to its size. Bromley, with the smallest, has 22 people living in the same area. Compared to Paris and Madrid (neither of which could reasonably be described as unpleasant places to live), with figures of 213 and 286 per hectare respectively for the cities as a whole, it’s clear that London should be able to accommodate far more people than it already does.
In his version of the London Plan (the blueprint for London’s growth over the next ten years) Sadiq Khan set out ambitious targets for the delivery of new housing across the capital. Where the previous mayor, Boris Johnson, adopted a “blue doughnut” approach to planning, which capitulated to the Outer London, largely Conservative-voting, boroughs’ demands for more autonomy over planning decisions, Khan initially required those very councils on the edges of the city to do more to help deliver new homes. As an example of this new approach, Merton’s housing targets rocketed from just over 4,000 in the Johnson’s version of the London Plan to more than 13,000 in Khan’s – an increase of nearly 225 per cent.
For the first time, a key strategy of the Plan was the exploitation of small sites to help achieve overall housing targets. (Small sites, in this context, are defined as those providing up to 25 homes). Previous Plans had ignored the potential of such sites to make a significant dent in housing targets, largely because their capacity was so hard to quantify. Yet under the current Mayor this was to become an important component of the new housing strategy. In total, it required no less than 245,730 homes to be delivered on small sites over ten years—more than a third of the total housing target for London over that period.
To compel insubordinate councils to comply, the Plan included a controversial clause requiring them to adopt a “presumption in favour” of approval for small developments on sites close to stations or high streets, at the same time acknowledging that the character of some areas would need to evolve to accommodate London’s anticipated population growth.
Predictably, this was met with a hyperbolic response from Conservative politicians, with Andrew Boff, leader of the Tory group on the London Assembly, claiming that the policy amounted to “war on the suburbs”. Yet a less partisan analysis clearly shows that the Outer London boroughs are not doing nearly enough to combat the housing crisis. Even the government’s own, less ambitious, targets demonstrated that several of the suburban boroughs are falling short, with Havering achieving only a third of its target.
Prior to becoming official policy, any new London Plan has to go through a process of public consultation and interrogation by an independent planning inspector. With Mayor Khan’s draft new Plan, this took place in spring of 2019, with a queue of homeowning suburbanites duly trotting up to City Hall to lambast the Mayor’s proposals. Complaints were raised about the complex statistical methods for calculating the capacity of Outer London to deliver new homes and familiar, tired accusations that a wave of “garden grabbing” would be unleashed were made. Inevitably it was the least dense boroughs – and therefore the ones with the greatest capacity for growth – which pushed back hardest against the Mayor’s proposals.
The outcome of the examination was a resounding rejection of the small sites policy by the inspector, who called for its wholesale removal. A recently as November the Mayor rejected this call, claiming that London could indeed “deliver those homes within London’s boundaries with no development on the Green Belt” (the latter stance, by the way, was something else the inspector had recommended the Mayor reconsider). However, when the Mayor’s final version of the Plan appeared in December, the small sites policy was almost entirely gone – and with it the associated housing targets. In some cases the numbers had been slashed by half. Across London, this resulted in a total reduction of 125,000 potential homes.
What was the reason for this extraordinary change of heart? With an election looming, perhaps the Mayor was hopeful of making a political play for support in those boroughs currently holding fast against the red tide? After all, eight of the ten biggest reductions for small sites targets were in non-Labour voting boroughs, the same number that voted Conservative in the 2016 mayoral election. Perhaps it was felt that this policy risked holding up adoption of the Plan? That seems possible, though recent criticism by secretary of state for housing Robert Jenrick suggests that the government considers the Plan not to be ambitious enough. In his letter to the Mayor, Jenrick also objected to the Plan’s emphasis on building flats rather than family houses – something that small sites tend to deliver.
The idea that the suburbs continue to represent a bucolic escape from the grime and overcrowding of Inner London has long been anachronistic. With home ownership in the central boroughs now out of reach for most, Outer London is increasingly proving an acceptable compromise between commuting and housing costs. Change in the character of Outer London is inevitable as the city adapts to growth, yet in reality even the more ambitious small sites targets of the Plan would hardly have resulted in noticeable change in the character of suburban neighbourhoods. Dividing large houses into flats, small-scale development on infill sites, utilising scraps of redundant land and above shops: all of these count against the figures, and when spread across a wide area would barely be noticeable, even with the higher targets.
The claim that suburban boroughs are unable to deliver their fair share of the homes is preposterous: under the latest, less ambitious, version of the London Plan, Hackney – with a total area of 1,900 hectares – is, over the next decade, expected to deliver 6,580 homes on small sites compared to 2,950 in Hillingdon, despite the latter having an area six times larger. Inevitably some standards must change: policies that require a minimum distance between windows of no less than 20 metres, as is the case with many suburban boroughs, are no longer fit for purpose in a rapidly densifying city. As has consistently been pointed out by campaign group Create Streets, many of the older homes considered desirable today would not comply with contemporary planning policies.
The removal of the small sites policy from the London Plan represents a betrayal, not only for those citizens of London desperate to get a foot on the housing ladder but also for all of those small businesses so vital to the city’s construction economy: builders, developers and design professionals, for whom the risks inherent in the planning and delivery of small-scale developments are often too great to justify. With the last-minute extension to the Mayor’s term due to the coronavirus we can only hope for the reintroduction of the small sites policy so that we can get on with delivering the homes London needs.
This article was originally published by OnLondon.