Written evidence submitted by London First [NPP 29]
London First is a business membership organisation with the mission to make London the best city in the world in which to do business. We represent the capital’s leading employers in key sectors such as financial and business services, property, transport, ICT, creative industries, hospitality and retail. Our membership also includes higher education institutions.
We welcome the opportunity to respond to the CLG’s Communities and Local Government Committee on the call for evidence on the proposed changes to the NPPF.
The proposals in the consultation affecting green belt land
London First welcomes the proposed changes to the NPPF which provide greater support for the delivery of homes on brownfield land and small sites in the green belt. This policy support should be extended to require the delivery of a wider mix of housing, not just starter homes. This is essential in order to provide a sustainable mix of homes to meet London’s diverse housing needs, including rented accommodation (social, affordable and private) and homes for purchase for households who do not qualify for starter homes.
In line with the conclusions of a report produced by London First in 2015 ‘The Green Belt: a Place for Londoners’ the NPPF should encourage a wider review of the green belt through local plan reviews that considers the potential release of green belt sites in areas of high public transport accessibility, that are of poor environmental or civic value and could better serve London’s needs by supporting sustainable, high-quality, well-designed residential development that incorporates truly accessible green space.
Consequences of changes to the definition of affordable housing
We welcome widening of the definition of affordable homes to include a wider variety of low cost home tenures. It should also be amended to include homes for older persons such as extra care or sheltered housing tenures. How the expanded definition subsequently relates to requirements placed on developments will be important. London needs to build 50,000 homes a year and requires a mix of tenures, and in particular, a mix of affordable products. A blanket imposition of starter homes on all reasonably-sized sites as required by the Housing and Planning Bill, has the potential to crowd out other important affordable products in London. The Government should not apply a one size fits all approach to the application of affordable products to new developments, allowing London government the ability to judge an appropriate policy response according to market needs.
The housing delivery test and its implications
London First welcomes the additional scrutiny for local planning authorities that are not meeting their housing targets. Where this is the case, the allocation of additional sites for new housing through the local plan process, may increase the number of sites with planning permission and therefore the probability of development coming forward. However, a two year period is far too short to assess an LPA’s performance.
The Government should use this round of changes to the NPPF as an opportunity to join up two related policy areas – the stick of extra scrutiny (as proposed) with the existing carrot of the New Homes Bonus. Without reform, the existing system of targets and incentives risks failing to deliver the homes we need. In our report Carrots and Sticks, we outlined how a reformed system which provides better incentives and tougher penalties aimed at the people at the sharp end – the boroughs – has the potential to drive a step change in housing delivery.
Proposals on the use commercial land and developments for housing
Whilst London First agree that underutilised and vacant land should be released for alternative uses, it is important that London’s strategically important employment locations both office and industrial, remain exempt from such blanket policy approaches. The release of land in such locations should be carefully managed through the local plan review process.
Other proposals in the consultation
London First supports the policy objective to increase residential densities at commuter hubs. This will unlock the development potential of accessible areas to deliver new homes. In order to ensure that development is sustainable, the NPPF should be clear that regard should be had to the capacity of the transport network in informing the scale and density of development that can be accommodated on specific sites.