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  • Writer's pictureAndrew Black

Gove, Stones and Glasshouses

On Tuesday, the report of Gove’s expert advisors into Housebuilding in London was launched. It contains a number of recommendations to Sadiq Khan on increasing housing delivery in London.


In his letter to Khan, Gove pointed to the fact that from the 2022 Housing Delivery Test results, only 13 of 32 boroughs scored higher than 95%. He used his letter to also fire some warning shots of raising the threshold at which planning applications would land on Khans desk from the current 150 home limit to something more like 500 (as was originally suggested) and also of further measures in future if he doesn’t buck his ideas up. His sign off ‘with every good wish’ was the most passive aggressive thing I’ve heard all year.


Diving into the detail of the report, of all of the London Boroughs it was only Brent, Croydon, Tower Hamlets and Wandsworth who outperformed the target over the previous 3 years as this chart in the report shows us:


If only someone could produce a table which showed how authorities outside of London performed. Well…..ta daaaa!! (I even got the colours to match – took me chuffing ages to do that btw!) Here’s how such a table might look for Gove’s constituency county home of Surrey:


Yes, a mixed bag but definitely more who are not performing than those that are. Only 4 out of the 11 authorities doing the heavy lifting and overall only 94% delivery.  But then compare it to somewhere a bit further away from town like East Sussex and things become significantly bleaker:


Overall a figure of just 58% of the required housing delivery. So it's definitely not just a London problem. In fact far from it.


The report points towards a worsening delivery in London, from 89,000 in 2018/19 to 40,200 in 2022/23. The same isn’t necessarily reflected in the home counties where delivery is more consistent across the last three years (mostly) but then these figures are still representative of a post covid housing market which recovered much quicker in the shires than in London. In some instances the market went gangbusters further away from London where potential buyers focused on the new norm of more home working and being able to stomach a longer commute if it was only for a day or two a week.


The more interesting thing is exactly what was being built across London.


The Residential Completions Dashboard for the GLA can tell you exactly what and exactly where housebuilding occurred across London. Quite a nifty little tool that is worth a play with in your lunch hour at some point. It’s certainly much more accurate and usable data than many authorities provide in AMRs if at all.


One thing is for sure about what is being produced within the housing numbers. They aint houses. They’re flats. I mean they would be wouldn’t they because its London right? But the Residential Completions Dashboard will tell you that of 140,000 homes built in London over the last five years 60,000 (43%) were one bed dwellings, 54,000 (39%) were two bed dwellings, 20,000 (14%) three beds and only 3,025 (2%) were four beds. Why does that matter? Well the Strategic Housing Market Assessment for London from 2017 showed the need for new homes across all sectors:



So London might have got the delivery of 3 beds bang on but there were too many 2 beds and not enough 4+ beds. So its not just how homes are being delivered but what type.


The report produced by the expert panel is excellent and the scrutiny of barriers to supply is welcomed. But for me, there was one thing missing that the report didn't touch. The Green Belt.

The Green Belt was one of the things that inspectors of the last London Plan examination the Inspectors told Sadiq one of the things he needed to do. Look at the green belt. It wasn’t just a passing comment either. They went into a lot of detail.

Paragraph 453 of the report says this:


There have been a number of calls for a review of the Green Belt in London to be carried out. This matter needs to be considered in the light of our earlier findings that capacity within London is insufficient to meet the identified annual need for housing and the potential shortfall of industrial land in the medium to longer term. We take a review to mean examining all land within the Green Belt to ascertain whether and to what extent it meets the Green Belt purposes defined in the NPPF and also to take into account any potential to promote sustainable patterns of development in line with the 2019 NPPF. This, in turn, might identify possible locations for growth and so lead to an assessment of whether exceptional circumstances might exist to justify the release of Green Belt land.

We know Khan was and still is against a review of the green belt and he has since slammed other boroughs such as Enfield for even considering the prospect as part of Local Plan consultations


But there it is in black and white in the inspector report at para 455:

In any event it is implausible to insist that the Green Belt is entirely sacrosanct without having considered what it comprises and the impact that it has on wider strategic objectives. Furthermore, the NPPF does not entirely rule out changes to Green Belt boundaries although exceptional circumstances are required to justify this.

And the conclusion of the position on green belt at para 457:

Therefore from the evidence we heard the inescapable conclusion is that if London’s development needs are to be met in future then a review of the Green Belt should be undertaken to at least establish any potential for sustainable development. Therefore we recommend that this Plan include a commitment to a Green Belt review [PR35]. This would best be done as part of the next London Plan. Given its strategic nature and to ensure consistency the review should be led by the Mayor and should involve joint working with authorities around the administrative boundary as well as the boroughs. This would form the basis for the Mayor to consider Green Belt release as a means to deliver housing and industrial development that cannot be accommodated in the existing built up area or in adjoining areas.

Finally the conclusion that capacity for new housing in London is finite. Paragraph 599 (with my emphasis):


Furthermore, the position in London is that capacity for new housing development is finite. Indeed, the Plan relies on re-cycled land. The approach of sustainable intensification can only be taken so far without having an adverse impact on the environment, the social fabric of communities and their health and well-being.

So with that in mind why did Gove’s report not go there? It barely even mentions green belt, only to make it clear that any amendment to the presumption being applied to brownfield site would not apply in the green belt.


I don’t dare to suggest for one minute that the authors of the report chose to deliberately ignore the green belt but more that it was outwith the remit of this particular report and I personally think that is a massive shame.


People have been calling on government to hold a sensible debate on the green belt for years now. I don’t really know what that looks like, nor I suspect do many of those calling for it. But. This could have been the starting point for such a conversation. Of course, Gove wont go there, and certainly not in an election year. But also Khan knows he wont either and can seek to rebuff this report as undeliverable, or overly political. He has already hit back and said that he wont take lectures from a government that has scrapped housing targets nationally and sent people’s rents and mortgages soaring.


Perhaps he has a point. Let he who is without sin cast the first stone.


‘with every good wish’





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