Agenda item

City of London Housing Delivery Test Action Plan

Report of the Director of the Built Environment.


The Committee considered a report of the Director of the Built Environment regarding the City of London Housing Delivery Test Action Plan.


A Member questioned whether the Ministry of Housing, Communities and Local Government accepted the conclusions of this report. Officers reported that the City Corporation had set out its case in the Action Plan and that the government did not respond directly to such plans. However, in due course, the Local Plan public examination would take into account this Plan as a background document and this would provide the organisation with the opportunity to state its case further before a planning inspector came to a view on it.


Another Member spoke to receive clarification. He stated that, as he understood it, the City Corporation had missed targets here for two consecutive years and that certain consequences would flow from this, one of those being that an Action Plan was required, another (applying a 20% buffer) which seemed to be inapplicable to this organisation and a third which involved applying an presumption around sustainable development. He added that, as he understood it, the City Corporation was now governed by this guidance and had to abide by it for a period of time until they were able to meet targets, however, the paper seemed to imply that this was not necessary. Officers responded by stating that the next test results were due to be released in November 2020 and that the consequences would apply until that time. They went on to highlight that, for reasons articulated within the report, the data on which the City Corporation had been judged last year was incorrect and that the belated inclusion of 165 units at Sugar Quay would mean that next year’s result would vastly exceed requirements. The bigger picture was that this was a backward looking, 3-year time horizon assessing housing delivery when, in reality, housing strategy was set across a 10-15 year period and it was therefore felt that targets should instead be based upon average delivery across this time period. Officers reported that the government were looking to reform planning in general and that it was expected that the current test would be reviewed and refined as a result of this. In response to further questions, Officers reported that there would be no need for the City Corporation to change its current policy position in the short-term.


Another Member spoke to underline that even if the revisions had been made, the City Corporation had fallen below the required minimum figure on housing delivery. The response from the MCLG explaining why they would not amend the figure referred, in part, to the long period of time it had taken for the City to notify them of the required revisions. She therefore questioned whether this broadly indicated how low down the priority list housing was and noted that one of the consequences of the City Corporation’s historic approach to housing was that, as suburban high streets began to look busy again with the easing of lockdown measures, the City lacked resilience in this respect due to its lack of sufficient local community.


The Member went on to refer to the Action Plan itself and questioned whether projections around the increase in City workers by 2036 mentioned within it needed to be reviewed in light of the ongoing pandemic. She noted that the document was dated August 2020 yet contained no reference to the matter or to the potential for a change to the presumed upwards trend in terms of workers and required office space. More broadly she stated that, whilst it seemed that the City’s transport approach to the pandemic had been responsive and flexible, this did not seem to be reflected in any planning or housing delivery aspects of the work of this Committee. She suggested that a paper setting out current trends and best estimates and how priorities should be reviewed in light of these would be useful. Officers reported that the reference to 600,000 additional city workers by 2036 had been taken from the draft Local Plan and was based on pre-COVID GLA projections. In light of the changing context, it was recognised that some of the projections within the Local Plan would need to be revisited before the document was submitted for examination. The Local Plans Sub-Committee would be called to meet later this year to consider these matters.



Ms Lloyd-Owen asked that her objection to the publication of the Plan be noted.


RESOLVED – That Members approve the publication of City of London Housing Delivery Test Action Plan attached at Appendix 1.

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