The major points are as follows:
The new Standard Method for setting housing requirements is wholly inappropriate for London. Overall, the Capital will be expected to deliver almost three times as many homes annually as it has averaged over the past 5 years, with much of the increase directed at those boroughs with the least capacity to raise output. The method takes no account of London’s great shortage of homes for social and low-cost rent for key workers and their families.
Councils will be required to produce new Local Plans in 30 months, an impossibly short timescale given the need to map the entire borough into Growth, Renewal and Protected areas, and to create design specifications (known as Design Codes) for all sites earmarked for development. Until this task is completed, it is likely that highly inappropriate and unpopular developments will gain planning consent.
The proposals foresee more intensive public participation in producing Local Plans and Design Codes, but curtailment of the public’s right to comment on specific planning applications. This might be acceptable were there a requirement for all applications to comply with those plans and designs. But there isn’t. It appears that developers may submit non-compliant applications and have them assessed against planning policies that have been determined centrally, but with nationwide application having no regard to local circumstances. This will rightly incense communities whose up-front efforts have been by-passed or over-ridden.
No mention is made of the London Plan (currently awaiting approval by the Secretary of State), nor of Metropolitan Open Land which currently enjoys the same protection as Greenbelt - and should continue to do so.
A new single-rate Infrastructure Levy, not payable until completion of development, is proposed to replace Section 106 agreements and the Community Infrastructure Levy. This will expose Local Authorities to risks they are ill-equipped to bear in borrowing to build the required infrastructure, and the various exemptions proposed will further reduce the delivery of genuinely affordable homes.