MD2711 Real-Time Strategic Housing Land Availability Assessment project

1.1 The Greater London Authority Act 1999 places responsibility for strategic planning in London on the Mayor and requires him to produce a spatial development strategy for London (the London Plan), which he is also required to keep under review.

1.2 Strategic Housing Land Availability Assessments (SHLAAs) – a requirement of the National Planning Policy Framework (NPPF) – identify sites and assess their development potential, suitability and likelihood of coming forward. In doing so, they reveal an estimate of housing capacity across any given plan period; and inform the Mayor’s strategic and London borough housing targets. SHLAAs also have the potential to influence the delivery of housing, as they influence the behaviour of the market through providing insight for developers. They therefore play an important role in the GLA’s ability to effectively contribute towards meeting the housing needs of Londoners. 

1.3 SHLAAs have been prepared periodically during the evidence-base stage of the plan-making cycle, but currently only represent conclusions at a fixed point in time. They therefore do not readily react to the potential impact of changes in economic circumstances; improvements in the availability of data and delivery of infrastructure; and substantial changes in government policy that can affect the projections relating to land supply.

1.4 GLA SHLAAs were published in 2009, 2013 and 2017, to accompany new or updated London Plans. Work on the most recent 2017 SHLAA began in 2016, when the London Land Availability Assessment database was built, and ended with publication of the SHLAA document in November 2017. Using a probability-based land assessment tool, the latest SHLAA identified available sites from existing permissions, site allocations, and any other sites with potential to come forward in the 24-year period from 2017 to 2041. For a description of the SHLAA development phases, please see Appendix 1.

1.5 Whilst London SHLAAs cover long-term periods, given a lack of certainty (e.g. over market conditions, policy, delivery and their combined impacts on land supply), the spatial accuracy and ability to predict potential housing capacities diminishes over time. The housing targets of the London Plan 2021 – and borough housing targets within these – are based on the SHLAA work undertaken in 2016-17. These are increasingly being considered out of date. As borough planning cycles move forward, without a SHLAA update, boroughs have to undertake substantial separate new housing-capacity work to inform their housing requirements. It is therefore important that the GLA (in collaboration with boroughs) refreshes housing-capacity evidence as early as possible.

1.6 In addition to ensuring that spatial development strategies (such as the London Plan) are reviewed every five years, and updated as necessary, the NPPF states that such plans should “be accessible through the use of digital tools to assist public involvement and policy presentation”. In the context of planning reform, the government has also expressed its commitment to the digitalisation of planning in order to improve decision-making; facilitate engagement in the planning process; and enhance our understanding of how our cities are changing.

1.7 It is therefore proposed that the GLA replaces the ‘fixed point in time’ SHLAA with a ‘live’ system. The ongoing London Development Database (LDD) automation project (Planning London Datahub (PLDH)) provides an opportunity to facilitate this; revisit methodologies that the GLA has previously used; and develop a new system to manage and understand land supply data.

1.8 The new system will integrate live planning permission data from the PLDH into land availability assessments. These assessments would allow the GLA to understand how the potential development capacity identified in land availability assessments weighs up against London’s planning pipeline and actual housing delivery. This understanding is currently difficult to piece together without significant manual intervention.

1.9 Such an approach should be able to consolidate borough and GLA data streams; reduce duplication; and aid resource-constrained borough planning departments. It could also potentially provide an opportunity to consolidate housing and economic data sets by building a system that could also host a live Employment Land Availability Assessment tool. This tool is a study undertaken to assess the availability of developable land for employment uses.

1.10 Such a tool could provide a strong platform for public understanding and engagement, making land-supply assessments more accessible and transparent where possible (currently, SHLAAs are typically published in long PDF reports with little transparency over where the sites are). This would enable the GLA to fulfil the objectives of London Plan policy GG1A, by facilitating early engagement with local communities about sites in their area. Subject to the agreement of London’s local planning authorities, it could also provide a platform through which the public and other stakeholders could suggest sites to be considered for allocation and development.

1.11 The success of this is in part dependent on the support of boroughs, to supply data and support the implementation of the platform. Much of the data needed to develop the platform has already been provided to (or produced by) the GLA, de-risking the need for early engagement with boroughs. Moreover, re-examining and updating previous SHLAA data on land supply beyond the London Plan’s 2019-29 target is important to local planning authorities – many of which are at different stages of Local Plan production, and need to fulfil NPPF requirements around identifying developable sites and broad areas for growth in the longer term. Notwithstanding this, to make this an overall success the team is committed to working with all/any boroughs that are interested in producing a digital solution for the SHLAA as a collaborative project.

1.12 The estimated cost for this is £235,000. This includes system build, and some dedicated officer resource.

1.13 The entire spend is expected to occur during the 2022-23 financial year. However, there is a risk that, due to timing, some costs may fall into the subsequent year, with any resource requirement in subsequent years (e.g. for training) coming from existing staffing.

1.14 The estimated cost is made up of the following:

1.15 Additional project team members will be pulled in from across the planning service (and potentially boroughs) to support the project. These are assumed to be funded from current budgets.

1.16 An element of discovery cost is included in the budget to enable preliminary learning on areas that we do not understand well, such as user interfaces.  

1.17 Two additional temporary positions (project management and project officer, as outlined above) are required to directly support and deliver this project, given its complexity. The project management role is an extension to an existing post; and the project officer role will be created and recruited in accordance with GLA staffing protocols.

1.18 The project is to be funded from the Planning Digitalisation programme budget. The ongoing costs of the project will be established following a review of the Planning team’s digital assets. This review will look at combining the hosting and maintenance costs of similar tools/datasets provided by the Planning team, with the combined ongoing costs covered through this programme.

1.19 The predicted timescales for the development and implementation of the system is 16 months, split into the following two phases:

i. a nine-month build process following developer commission, with completion in Spring 2023

ii. seven months to train/work with the boroughs to ensure that: the system is fully operational; initial data is inputted; and it is subsequently in use, with completion in Winter 2024.

2.1 The overarching objective of this project is to create a new, online, real-time GIS-based SHLAA in collaboration with the London boroughs, replacing the process, platform and outputs of previous GLA SHLAAs. This objective is aligned with the wider digitisation of the planning system, and with the aim to create cost-effective live data that can be used by a number of stakeholders.

2.2 The development of the new SHLAA will be led by the Planning team, in collaboration with other teams across the GLA (including digital), developing the work already undertaken on the PLDH. This will require the procurement of a central database/platform to be developed externally.

2.3 In considering how to undertake this project, the limitations of the current land assessment process have been examined, together with how these could be addressed or improved through this proposed digitisation. This is discussed in the table below, alongside the project’s intended outcomes.

2.4 Building upon the key outcomes set out in the table above, the Real-Time SHLAA Project will also secure several additional benefits. These are detailed below:

Financial

Savings: Previous SHLAAs required the development of a bespoke GIS-based data-entry system each time a SHLAA was undertaken. This was built using external consultancy support at a cost of more than £100,000 per SHLAA (every five years). The new system will be designed to be adaptable to future needs, and will therefore avoid the costs of creating a bespoke system for each new SHLAA. The SHLAA will also be available for all of the boroughs to use as a single shared data set, and should enable them to save on the cost of producing their own.

Improved data management

i. Relationship to other projects: Building a system that has the ability to better consume data from, and push data to, other GLA projects, including:

i.i. Opportunity Area Planning Frameworks

i.ii. Planning London Data Hub

i.iii. London Data Map

i.iv. Infrastructure Mapping Application

i.v. London Underground Asset Register

i.vi. 3D London

i.vii. London Housing Stock Model

i.viii. PRISM

i.ix. work on automation of viability assessments

i.x. Hounslow Housing Numbers Project (using 3D to map site capacities)

i.xi. Housing and Land data sources and work programmes.

ii. Transparency: Ability to provide live open data to allow:

ii.i. others to understand criteria and assumptions around development capacity and increase transparency in planning and decision making

ii.ii. the GLA to more easily respond to criticisms of housing delivery with real-time information, and provide more transparency for residents and the development industry 

ii.iii. A developed platform with a public interface to enable wider understanding and opportunities for engagement in land and housing supply across London.

iii. Open data: Both the software and most of the data will be open and available for reuse by other organisations. Publishing open data will also allow other organisations to innovate on the software which may lead to new software that brings wider benefits for the built environment.

Support for boroughs

i. Providing support for the boroughs to better monitor and understand their land supply and how it fits in with the wider London context, thereby also reducing potential risks from the Government’s Housing Delivery Test to local borough plans.

ii. Eradicating duplication, and thus reducing the time boroughs spend inputting sites data into their housing trajectories, land supplies and LDD.

iii. Reducing workloads for preparing Local Plans and Site Allocation documents.

Boroughs have been made aware of the aims for this project, but much more substantial engagement will be undertaken in order to ensure that the system built is fit for their requirements.

2.5 The data surrounding the SHLAA is a shared asset between planning authorities across London, the development industry and communities. In the creation of this asset, it is important that all parties have oversight of the development of the datasets and platforms used. To achieve this, it is proposed to create a strategic-level project board that meets quarterly to steer the project, and ensure that all parts of it achieve an appropriate level of transparency as well as borough-level and strategic objectives. This will be in addition to officer-level working groups that meet more regularly, as well as open reporting at regular intervals to enable wider understanding of the work taking place and of the shared learning to take place.

3.1 The public-sector equality duty (PSED) under section 149 of the Equality Act 2010 requires the identification and evaluation of the likely potential impacts, both positive and negative, of the decision on those with protected characteristics. The Mayor is to have due regard to the need to eliminate unlawful discrimination, harassment and victimisation; and to advance equality of opportunity, and foster good relations, between people who share a protected characteristic and those who do not. In particular, this may involve removing or minimising any disadvantage suffered by those who share a relevant protected characteristic and taking steps to meet the needs of such people. In certain circumstances compliance with the Act may involve treating people with a protected characteristic more favourably than those without one.

3.2 To assess the possible impacts of this project on those with protected characteristics, a scoping Equality Impact Assessment has been carried out, which concluded that the project is unlikely to have a significant impact on any persons with protected characteristics. The two possible impacts that were identified were the accessibility of the tool for people affected by sight loss, and those with limited access to computer software.

3.3 To mitigate this, the digital platform will be designed in a way that is accessible and compliant with the Public Sector Bodies Accessibility Regulations 2018 and Web Content Accessibility Guidelines 2.1 (level AA). For example, it will be possible to enlarge on-screen text without compromising the usability of the system.  

3.4 Elements of the new system will be publicly accessible, giving the public the ability to engage with assessments of London’s land supply. Should this be limited by lack of access to a computer or the internet, GLA officers responsible for the day-to-day running of the project will be available to discuss any concerns with the relevant parties, and to submit/extract information on a person’s behalf.

3.5 Equality considerations will continue to be considered as the project develops. No negative equality impacts are believed to remain after the mitigating actions described in paragraphs 3.3 and 3.4, above. As part of the ongoing PSED, further consideration will be given to how the data collected is used, and how that may have an impact on any protected group.

Risks and issues

4.1 There are a number of key risks to the delivery of this project, which are outlined in the table overleaf.

Mayoral strategies and priorities

4.2 This project contributes to a number of the Mayor’s adopted strategies, as follows:

i. The London Housing Strategy and the London Plan 2021 promote the delivery of more housing through the identification of suitable sites and best use of limited land supply. This project will deliver a new system that facilitates the identification of sites; allows for a more nuanced understanding of development capacity across London; and gives decision-makers and other stakeholders a ‘live’ picture of London’s limited land supply.

ii. London Plan objective GG1 encourages early and inclusive engagement with stakeholders, including local communities, in the development of proposals and policies. The new system would provide a platform through which the GLA and London boroughs could engage with the public on land supply and development capacity.

iii. The Smarter London Together roadmap promotes city-wide collaboration; and encourages the GLA Group to ensure the most effective use and coordination of resources in data and digital transformation. This project would deliver a platform that allows greater sharing of data between London boroughs and the GLA on land supply; and reduces the work needed to be done by boroughs when carrying out land supply assessments and preparing housing trajectories.

iv. The Smarter London Together roadmap also outlines the Mayor’s commitment to supporting an open-data ecosystem; and encourages the provision of open data to enable better decision-making and improve transparency. The new system would make use of the PLDH’s open data to provide more up-to-date land-supply information and, ultimately, enable better-informed decision-making. Data output by the new system could also be made open pending further consideration of any confidentiality issues.

Conflicts of interest

4.3 There are no conflicts of interest to note for any of the officers involved in the drafting or clearance of this decision form.

5.1 Approval is sought for the expenditure of up to £235,000 on the next phase of the LDD project, a new in-house, real-time SHLAA system.

5.2 The majority of the project expenditure will occur in 2022-23, and be funded from the Digital programmes budget within the Planning and Regeneration Unit. This budget is funded via an annual drawdown from the Planning Pre-applications reserve; any costs not expended in 2022-23 will form part of future years’ drawdowns.

5.3 Estimated expenditure in 2022-23 is based on anticipated spend and costs of recruitment to posts from October 2022 (second half of 2022-23) of around £190,000. The remaining term for the posts will occur in 2023-24, which will be funded by further drawdowns.

6.1 The NPPF requires strategic policy-making authorities to have a clear understanding of the land available in their area through the preparation of a SHLAA. The SHLAA is a technical exercise to determine the quantity and suitability of land potentially available for housing development; and a required part of the evidence base needed for the preparation of a Local Plan. The Mayor carries out a London-wide SHLAA to determine the borough housing targets that form a key part of the London Plan.

6.2 The preceding sections of this paper indicate that the decision requested falls within the statutory powers under section 30 of the Greater London Authority Act 1999 (the Act) to do anything to promote the improvement of the environment in Greater London; and, in formulating the proposals in respect of which a decision is sought, officers have complied with the Authority’s related statutory duties to:

i. pay due regard to the principle that there should be equality of opportunity for all people

ii. consider how the proposals will affect:

ii.i. the health of persons in greater London

ii.ii. the health inequalities between persons living in Greater London

ii.ii. the achievement of sustainable development in the United Kingdom

ii.iv. climate change, and the consequences of climate change.

6.3 Section 34 of the Act also gives the Mayor authority to do anything that is calculated to facilitate, or is conducive or incidental to, the exercise of any of the statutory functions of the Authority. Section 334 of the Act provides that the Mayor shall prepare and publish a document to be known as the spatial development strategy (London Plan); and section 340 of the Act states that it shall be the duty of the Mayor to review the spatial development strategy from time to time. Section 339 of the Act provides that the Mayor shall keep under review the matters that may be expected to affect the development of Greater London or the planning of its development; or which are otherwise relevant to the content of the spatial development strategy.

6.4 Section 333A of the Act provides that the Mayor shall prepare and publish a document known as the London Housing Strategy. By virtue of section 41(2) of the Act, the Mayor is required to keep the London Housing Strategy (and other strategies identified in section 41) under review; and to make such revisions to it as he considers necessary. Section 41 also obliges the Mayor to ensure that his strategies are consistent with, inter alia, national policies and each other.  

6.5 In this case, the decision to undertake this project may reasonably be regarded as facilitating, or being conducive or incidental to, the exercise of the powers detailed above.

6.6 Should the Mayor be minded to make the decisions sought, officers must ensure that, to the extent that the expenditure proposed concerns the purchase of supplies or services, they are procured in accordance with the GLA Contracts and Funding Code, engaging with TfL Procurement to develop and follow an agreed procurement strategy; and that appropriate contracts are entered into and executed by the GLA and contractors before the commencement of the supplies or services required.

6.7 The equality duty is addressed above.

7.1 This project includes six work packages, some of which will be pursued concurrently and in close collaboration with boroughs (particularly the user research and system testing). The anticipated timetable for delivery is detailed below:

7.2 Please note that the above work stream timelines include procurement periods, since many of the streams will require independent procurement strategies.

7.3 The project aims to deliver a collaborative resource between the boroughs and the GLA. As such, in setting up this project, a strategic-level Project Board will be established that will make key decisions about the direction of the project. This will include representatives of borough planning authorities.