The new, draft, big, bold, long London Plan

Jenna Goldberg provides a pre-Christmas assessment

Sadiq Khan has a problem. He is the first Mayor of London who is not made of Teflon.

He is a consummate campaigner, with an acute sense of political expediency, and this is his greatest strength and his biggest weakness.

Those of us who have worked with Ken and Boris’ City Hall administrations, are used to dealing with ambitious, dare we say ego-driven men. But both previous Mayors had something that Sadiq, much to his presumed dismay, does not. They were so utterly convinced of their own entitlement to power, so sure of their political status and winning ‘maverick’ personalities that they had the freedom to govern beyond the confines of party politics. In both cases this led to a willingness to take a pragmatic, flexible approach to leadership. They could operate well beyond the confines of the box marked ‘politically safe’.

That personality type suits city government – I’m thinking of Bloomberg and Giuliani here too – bold personality with chutzpah to spare goes a long way especially in London, where the powers are limited but the platform is considerable.

A challenging environment

But Sadiq doesn’t have the history nor cosy entitlement of his predecessors and with at least half an eye on his career after City Hall, he has to traverse a politically treacherous landscape – look to the left and there’s Momentum, to the right a wobbly Tory government with no interest in making him look good – though it can be argued that he sometimes doesn’t help himself on that front – and just there, on the horizon, is Brexit, threatening to dampen the growth and success of his city.

It is within this context that I read the new, draft London Plan. And yes I know, I haven’t even written the words ‘housing crisis’ yet.

The London Plan is the most powerful tool in the Mayor’s limited policy arsenal, but to make a success of it Sadiq really has to make it work hard. He has to ensure that it is immune to too much political protest and he has to show he is serious on housing delivery and affordability. The Mayor also has to be mindful that it is an industry-facing document to be pored over by developers, planners and borough officers, and of the headlines that will be generated for consumption by civilians (especially those written by one former Chancellor for the Evening Standard). He has to silence the critics who have criticised him for being ‘all talk and no action’ in a policy document that will take at least 18 months to be officially adopted.

Progressive and prescriptive?

So how has he done?

It is certainly an ambitious document and this has been recognised in the industry reaction. Richard Garlick, editor of Planning Resource, comments that ‘the task the Mayor has set himself is formidable’ and notes that the new guidance on densities in particular is welcome but will be a tough sell in some places, particularly the suburban town centres that Sadiq has set his sights on. It is this that the London Assembly Tory group has pounced on, somewhat disingenuously accusing the Mayor of giving ‘the green light to gardens being concreted over’. The Evening Standard went with that as their front page splash too. Tellingly, Estates Gazette quickly denounced this take as ‘fake news’.

Critics and populism aside, this is definitely a document that poses solutions to problems. The more flexible approach to density, a presumption in favour of development of smaller sites, clarity over built to rent viability and Strategic Industrial Land (SIL) and even the new, much tougher parking rules for new developments seek to paint a clearer picture for developers and local authorities, even if they don’t always like what they see.

It is also quite progressive. The overall theme of ‘good growth’ or ‘delivering a more socially integrated and sustainable city’ comes through most clearly in the new chapter on social infrastructure – which reads as a good practice guide on health and education services and provision of community facilities – and in the focus on greening the city (zero carbon and no waste to landfill by 2050) and tackling London’s air quality problems. There is much that is new here including a three letter acronym for planners to add to their lexicon – UGF or Urban Greening Factor – a measure of how much ‘greening’ major developments should deliver. There is also a new chapter specifically on heritage and culture, which has pleased Historic England and reflects the significance of London’s cultural industries to the economy of the capital.

Cumbersome and contradictory?

Ambitious, constructive, progressive; all sounds pretty good so far. But where has our politically sensitive Mayor not dared to tread? Six of 15 outer London boroughs with greenbelt land are now Labour-controlled, and Sadiq hopes to increase that number in May 2018, so it’s no huge surprise that the greenbelt is untouched in this Plan, as is Metropolitan Open Land. Since its publication the London Chamber of Commerce and Industry has called on the Mayor to review this position, pointing out that 54% of the capital’s emergency service workers live outside of London due to the cost of housing.

Perhaps more surprisingly, and despite a rather vague ‘Good Practice Guide to Regeneration’ published earlier this year, there’s nothing in here about balloting residents on estate regeneration, a subject that makes many developers and borough officers nervous and excites many to the left of Sadiq on the political spectrum. It was perhaps wise to avoid it especially given the Khan administration’s desire to stay within the safe zone (though he has just this week refused a major estate regen scheme in Barnet because it would have led to a net loss of social housing, a nod to his leftie compadres in the marginal Tory borough perhaps?).

Despite these omissions, this is unavoidably a cumbersome document. Its detailed approach has some inherent contradictions built in. For example, there are some boroughs where protected greenbelt and SIL will prevent them from unlocking land value and therefore new homes when Crossrail 2 comes along (Deputy Mayor for Planning, Regeneration and Skills, Jules Pipe did address this at a recent event, noting that the Mayor is keen to explore ‘innovative, mixed use approaches including co-location of light industrial and residential’). A bolder approach on this would have been welcomed by many, not least those who would like to see the business case for Crossrail 2 made as strong as possible.

Equally, it will be tough for outer London boroughs to balance higher targets and relaxed density guidelines with the mandate to give Local Views the same degree of protection as Strategic Views and protect every office, pub, club, community hall and music venue in town.

And for any of us who have been involved public consultation of any kind beyond Zone 1, traffic and parking specifically are often very sensitive issues. Is the Mayor hoping that politicians grow thicker skinned when it comes to permitting dense schemes with very little parking provision? It seems somehow contradictory, or even vaguely hypocritical, to ask boroughs to impose unpopular policies while strengthening local heritage, views and cultural protections as he has done (pubs should be marketed for an eye-watering 24 months before they can be sold for development…).

It is also incredibly prescriptive in some areas and we have heard some complaints from some boroughs that they already feel hamstrung by its detail (and this is only likely to get worse as it goes through consultation) and that there is little point in them pouring work into their own Local Plans.

The message from the GLA is that the Plan can be applied immediately at local level, despite not having been through consultation and despite it being a strategic document that sits above their own Local Plans – see Simon Ricketts’ amusing blog on this here. Meanwhile Jules Pipe has defended its length and complexity, noting that there is precedent – notably the 1949 London Plan – for using planning to address wider problem. In fairness, planning is really the only area where the Mayor does have significant policy powers, so of course he’s going to max them out.

Given its context, this is a commendable effort. Sadiq’s acute sense of how he is perceived, and his Deputy Mayors’ feel for the industry (James Murray) and the boroughs (Jules Pipe) has so far paid dividends with a document that is clearly the result of an intensive listening exercise. But of course, policy is just policy; as Centre for London’s Richard Brown writes in the Guardian ‘planning as a tool works better at directing development than initiating it’, Sadiq can’t make the builders build.

The next stage of the plan’s process is consultation until early March 2018, providing developers, local authorities and a plethora of special interest groups (community, architecture, heritage, transport etc) and consultants with an opportunity to give their views.

More interesting though will be how day-to-day planning processes are impacted. The Plan is already leading boroughs and developers to re-think schemes, numbers and mixes. We saw an application in Kingston deferred two weeks ago so that officers could have more time to ‘assess the implications of the draft London Plan' . And how will this effect, if at all, the upcoming London local elections in May 2018 and the often uneasy relationships between councils and City Hall over large scale development?

We have already seen the Mayor play politics with planning. Over the last few months he has intervened in schemes in two major Labour target boroughs – Barnet (times two) and Wandsworth – so we can assume there will be more of that to come at least up until the local elections in May, at which point his attention will likely turn to his own re-election campaign. Would he even take on Labour boroughs where the prevailing mood seems to be increasingly anti-development? As Dave Hill points out on his excellent London blog ‘the difference between Protest Left activism and militant conservationism can often be hard to detect’. The fact that Sadiq is growing his planning department from 50 to 63 permanent positions would certainly suggest a more interventionist approach than we have seen before.

With a document as prescriptive as this, and issues as emotive (remember we’ve got a housing crisis on our hands), we can be sure that Sadiq will be judging his own success as much by the headlines generated and votes counted as by the number of homes built.