The recent draft London Plan proposes to meet more than a third of new housing on "small sites". To meet that ambitious target - of over 24,500 houses per year - in this way, the Mayor tells boroughs to apply presumption in favour of certain small housing development on such sites where they meet design codes. This includes infill, conversion, extension and garden development in high transport locations or near town centre and upward extensions or resi and non-resi buildings for housing. There are exceptions, notably for listed buildings and co-living proposals. The Mayor even encourages boroughs not to seek on-site affordable provision for the very smallest of small sites and to delay commuted payments until occupation to aid cash flow.
The small sites presumption looks like a very positive move to speed delivery and generate certainty. The real test will be how the "presumption" interacts with existing policies which contain more specific controls. Unlike the presumption in favour of development in the NPPF, there is no suspension of other development plan policies, so while the London Plan will have extra weight because it is newer, there will remain scope for individual boroughs to continue to include their own priorities in the decision-making mix.
The Mayor states that the remaining two thirds of the housing can be delivered on large sites without touching the Green Belt. Critics suggest that is unachievable.
The Plan reinforces protection of the Green Belt along with Metropolitan Open Land. On the face of it, it makes sense to protect green open spaces as a vital ingredient to the physical and mental wellbeing of an urban population. One could question, however, whether areas designated as green belt – many of which were designated more than 60 years ago – currently fulfil their purpose. There is also the question of whether protection of the 'green girdle' is more important than town planning considerations which may enable a greater number of people to benefit from green spaces. The motivation appears to be that the 'green girdle' must be protected without question and that the need for housing must be satisfied within these constraints.
We currently face a critical housing crisis. Unquestioning and complete protection of the green belt will likely prevent us from being able to look objectively at all possible ways of enabling delivery of housing through proper town and country planning considerations.