Last week, Angela Rayner gave Marks and Spencer permission to demolish and rebuild their flagship Marble Arch store, in line with plans first submitted to Westminster City Council in February 2021. In between those dates, the proposal was considered by Westminster and by Sadiq Khan (both of whom approved it), by a public enquiry and by Michel Gove (who overruled them all and turned it down), by the High Court (which overturned Gove’s decision) and by Rayner (who gave the go-ahead). Whatever view you take of the proposals, these layers of decision-taking and months of delay cannot be right – the reconstruction phase of the Notre Dame project took less time.
Against this backdrop, you can see why the Deputy Prime Minister has announced major reforms of planning this week – a consultation on planning decision processes on Monday and now a new National Planning Policy Framework. The consultation paper proposes a national “scheme of delegation” to ensure that more planning decisions are taken by planning officers, rather than by planning committees. The paper also proposes smaller strategic committees to agree documents such as opportunity area planning frameworks, and seeks to beef up training for planning committee members.
The proposals have been widely welcomed as a helpful act of streamlining, which reduces the risk of capricious committee decisions to reject proposals even when they are in line with local planning policy. Such refusals may lead to amendment and a new application, or to appeals to the planning inspectorate, but cause delay and incur cost either way.
For some commentators, this approach is also a helpful first step towards a “zoning” process that shifts the political focus from considering individual applications to agreeing policies and design codes. “Shouldn’t we be aiming for a system which makes [planning committees] redundant entirely?” architect Russell Curtis asked. If proposals comply with policies and codes, they can go ahead with minimal paperwork, though agreeing local plans and policies would become more complex and contested were they to give an automatic green light to compliant proposals.
As ever, London is a bit different. The capital already leads the way in delegating planning decisions and in processing applications fast. The most recent government stats show that in the year to June 2024, 97 per cent of decisions were delegated to officers, more than in any other region. Some boroughs delegated nearly all decisions.
London boroughs work fast too, deciding an average of 93 per cent of major applications within government-mandated deadlines (or other deadlines agreed with applicants) in the two years to June 2024, compared to 90 per cent or fewer in other regions. The capital also has lower rates of decisions being overturned on appeal than most other regions. The system works efficiently.
But it is not enabling the homes London needs to be built. London planning authorities turned down more applications than in other regions: 20 per cent across the capital compared to 15 per cent across England, and as many as a third in some outer London boroughs. Total application numbers are for around 60,000 homes per year, and their number has fallen by a third since 2016, significantly faster than in other regions.
This fall off in planning activity and low rate of approval feed off each other – if it is difficult to get planning permission in London, some developers stop trying or look elsewhere. London’s problems look like problems of policy as well as process.
That is where the new National Planning Policy Framework (NPPF) comes in. It confirms binding targets for local authorities across England. London’s new target is around 88,000 homes per year. That’s higher than the 80,000 target proposed after the general election, but lower than the 99,000 target that the Conservative government set in 2020 (though in 2022 the Conservatives also made targets “advisory”). It is, nonetheless, a huge jump from the current London Plan target of 52,000 homes per year, let alone the average 38,000 net additional homes built over the past five years.
The big policy change in the NPPF is its very careful relaxation of Green Belt rules. The Framework says that if a council is unable to meet its target through using previously developed land and densification, and if it is unable to collaborate with a neighbour to plug the gap, then it can consider using Green Belt land.
It must first look at previously developed land in the Green Belt, then at “grey belt” land which does not strongly contribute to the Green Belt’s core purposes – checking unrestricted sprawl, preventing urban areas merging into each other and preserving the setting of historic towns.
Other rules, relating to affordable housing, new and enhanced green space, design quality and infrastructure provision, still have to be followed, and land that is protected for special scientific interest or outstanding natural beauty, as a “local green space” or as part of a national park is excluded.
Even with all those caveats, the new policy makes London’s edges ripe for review. The definition has helpfully moved on from an aesthetic focus on “poor quality” Green Belt (which may be in entirely the wrong place), to considering whether Green Belt land actually does what it is meant to do.
On the face of it, a lot of the inner Green Belt within Greater London could meet the criteria for consideration: there’s still plenty left to separate London and surrounding towns, and a managed release is not unconstrained sprawl. But governance and geography are tricky: some of the boroughs facing the biggest shortfall don’t have much Green Belt land, and even when they do the land may not meet the government’s tests.
That could be a recipe for mess and disagreement but could also be the opportunity for a metropolitan solution. The Mayor could work with boroughs to marginally redefine London’s edges, to share the load of housebuilding, and to plan for urban extensions that make the most of existing and new infrastructure.
Could that happen? Khan opposed Green Belt reviews in the past (when a Conservative government would have vetoed them anyway), but times have changed. Khan’s 2024 manifesto was silent on the Green Belt, and a London-wide review would be a good way of demonstrating the value of a Labour Mayor to a Labour government, and vice versa.
But Green Belt extensions will not solve all of London’s housing delivery problems. London needs more planning permissions and more building, including of the around 300,000 homes that already have permission. But a viability crisis is holding back both. Former Southwark leader Peter John has argued that affordable housing requirements without sufficient grant subsidy are stifling development in some cases, and pushing up prices of market homes to enable cross-subsidy in others: “a vicious circle of non-affordability is made worse by demanding ever higher levels of affordable housing without some other grant subsidy being provided.”
Other commentators, such as Beacon Partnership’s Steve Beard, have argued that it is the sheer weight of design, carbon offset and infrastructure obligations imposed in London that is making schemes unviable. Centre for Cities’ Ant Breach argues that the London Plan duplicates local plans and suppresses development, pointing to the London Plan review commissioned by the last government, which found “persuasive evidence that the combined effect of the multiplicity of policies in the London Plan now works to frustrate rather than facilitate the delivery of new homes, not least in creating very real challenges to the viability of schemes”.
Given London’s slowing rate of housing delivery, and its stock of permitted but stalled developments, these arguments should be taken seriously. Are the policies that worked in a boom, when rising prices washed away the costs of planning obligations, also the right ones for when house prices are stagnant and delivery is stuck? After the financial crisis, quantitative easing, a cheap pound and open borders helped fuel a property boom, but these engines have fallen silent.
At the same time, affordable housing provision has become increasingly dependent on market housing. Around 50 per cent of affordable housing in London is now delivered as a planning obligation, so when private housebuilding slows, so does affordable housebuilding. Recent Greater London Authority (GLA) analysis shows the impact of this. In 2023, 38 per cent of the homes granted planning permission in London were affordable – a total of 11,725 units. In 2015, only 26 per cent were affordable, but this totalled a higher 14,000 units.
If a system based on cross-subsidy has stalled both affordable and market provision, either policy or funding need to shift. London has an urgent need for more affordable housing, so lowering targets too far seems perverse. But 35 per cent of something is still better than 50 per cent of nothing.
Alternatively, higher grant levels would enable boroughs, housing associations and private developers to build more affordable homes. A recent Centre for Cities report suggests that the government’s £500 million Affordable Homes Programme (administered by the GLA within London) would need to triple in size to get public housebuilding rates back up to their mid-20th Century levels. A tall order, but maybe one that could be justified as an investment to save on long-term housing benefit and temporary accommodation costs.
Finally, central government should recognise that it too needs to be part of the solution. Successive governments’ accumulation of policy prescriptions (including new duties such as “biodiversity net gain”) represent a tax on development, adding to those imposed by local and regional government.
Everything is introduced for good reason, but maybe the time has come for an open discussion of where other policies and stakeholder interests are strangling the government’s declared growth imperative. And, to end where we started, if an application has been considered by London’s elected local authorities and by its Mayor, does Whitehall really need to have a go too?
First published by OnLondon.
