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.
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?
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.
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.
He Lives in a House, a Very Big House
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: 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.
Extract from paragraph 84, National Planning Policy Framework, December 2025
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.
Micro Scope
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:
The development must comprise a single dwellinghouse on a plot no larger than 200sqm;
The development volume must be no taller than the highest part of an immediate neighbour;
The development volume must be no closer to the highway than the principal elevation of an immediate neighbour;
The development volume must not extend beyond a 45% line drawn in a horizontal plane from the nearest jamb of any primary window serving any habitable room;
The new dwelling must be no closer to the site boundary than the neighbouring dwelling is;
The distance between the principal window serving a habitable room in the new development must be no closer than 16m from that of a principal window serving a habitable room within a neighbouring dwellinghouse.
This is how these policies might appear in three dimensions, using a street infill site type:
View from streetView from rear
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.
Be Careful What You Wish For
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.
OHouse, Kyoto, by Mitsutaka Kitamura
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.
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.
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.
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.
A map showing the 2023 Housing Delivery Test score of every planning authority in England.
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.
Update 11 February 2025
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).
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.
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.
Extract from the Lewisham Small Sites Supplementary Planning Document, adopted in 2021, by Ash Sakula Architects and RCKa
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).
Design for a new development of seven family homes in Croydon by architects Harp & Harp
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.
A land-hungry detached house occupies a corner plot close to South Croydon Station.
OB Architect’s Greyfort House replaces this property with eight new homes.
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.
This corner plot in Lewisham is ripe for intensification, with a large single-family home and deep garden, close to a suburban station, this is exactly where we should be enabling a significant uplift in density.
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.
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.
Maps of Every Planning Authority in England
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.
Typical page from a London borough planning portal, showing an entire list of reasons to object to a planning application – but none to support.
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.
“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.
New Barnet in 1897. The railway arrived in 1850 when farmland was acquired by the Great Northern Company to enable the construction of the route, and then the land around it was sold to the British Land Company (image from National Library of Scotland).
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.
A typical suburban neighbourhood with deep rear gardens and lots of parking. Most of this area is less than 10 minutes’ walk from New Barnet Station (Google Maps).
Let’s Take a Ride…
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.
A map of London showing residential densities in dwellings per hectare.
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?
Diminishing Ambitions
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.
Cum On Feel The (Voro)nois
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.
A Voronoi diagram showing every station in London and the areas of the city which are closest to each.
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.
A map of London showing every area within 800m of a station.
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:
Excluding surface water, green space, industrial land and the Central Activities Zone, this map shows all the areas in London with potential for intensification.
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.
Census Sensibility
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.
A plan showing the boundary of MSOA E02000028, 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 areaIF 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 = 40
Applied 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.
Using this methodology, the Emirates Stadium is identified as a location for intensification; Arsenal’s previous ground can be seen in the top right of the image, which was converted into homes after the club moved to its new location in 2006.
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 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.
Map of London showing population density using data from the 2021 Census.Map of London showing dwelling density using data from the 2021 Census.
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.
Extract from Croydon’s Suburban Design Guide Supplementary Planning Document.
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.
Extract from 2023 Housing in London report by the GLA showing the number of homes delivered on small sites, and with fewer than ten homes.
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
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.
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 Green Belt Challenge
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.
Station Development
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.
Development Corporations
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.
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.
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.
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.
