Richmond Council has declared the housing targets outlined in the draft London Plan as unrealistic, pointing to the borough's consistent failure to meet similar goals in the past. The council argues that the proposed annual housing target of 540 homes, representing a 31% increase on the current target, is unachievable due to a combination of limited strategic development sites and existing challenges in building out approved homes.
During a meeting of the Environment, Sustainability, Culture and Sports Committee, councillors debated the proposed response to the draft London Plan. The council's position paper highlighted that the proposed annual housing target has not been met in any of the past 10 years and only three times in the last 25 years. This is a significant concern, as national policy weakens the influence of a local plan where delivery falls below these targets, for example, through the housing delivery test.
Beyond the stated issues of 'limited strategic development sites' and 'existing challenges in building out homes', Richmond Council faces further obstacles. These include unrealistic and unachievable targets, with the 31% increase being a particular point of contention. Furthermore, there are concerns about stalled development sites where consented schemes have not progressed, leading to Richmond appearing to miss its housing delivery target despite having approved developments that, if built, would have brought it closer to achieving its goals. This issue is noted as being beyond the control of the committee and council.
Councillors also raised concerns about the potential impact on local jobs and economies. The draft London Plan assumes the capacity for 181 homes from industrial land release in Richmond. While this figure may seem modest, it could necessitate a significant loss of industrial land locally, despite evidence indicating strong ongoing demand for such land both locally and across London. This could lead to the displacement of businesses and jobs.
Inconsistency with local evidence for Gypsy and Traveller pitch targets was also raised. The draft London Plan sets a target of 5 additional Gypsy and Traveller pitches over 10 years, which contradicts the most recent evidence supporting Richmond's Local Plan (published in 2023) that indicated no demonstrated need for additional pitches.
Another point of contention is the market housing mix, which the draft London Plan proposes should only reflect the London-wide Strategic Housing Market Assessment (SHMA). This implies no provision for family-sized market housing, which is inconsistent with identified needs in Richmond, where there is a significant demand for larger family homes. The Council's response advocates for the removal of restrictions on using local evidence to inform market housing mixes.
There are also concerns that the proposed change in the definition of a 'tall building' to 30 meters (around 10 stories) could undermine Richmond's ability to manage development in line with its heritage and low-rise suburban character. The proposed Optimisation Framework may not be sufficiently sensitive to Richmond's local context, heritage, and townscape, potentially leading to inappropriate densities and building heights in sensitive areas.
Forceful Representation to the Mayor
Councillors are considering making forceful representation
to the Mayor regarding the draft London Plan. Specifically, they are advocating for greater local flexibility for boroughs to set policies that reflect local needs and viability, particularly concerning housing targets, affordable housing tenure splits, and market housing mixes. They are seeking greater support to address stalled sites and poor build-out rates, highlighting that without new powers or policies to encourage or enforce build-out, higher housing targets are at risk of not being met.
Concerns have been raised about the removal of borough discretion on affordable housing tenure, as Richmond's Local Plan policy requires a 70:30 split (Rented Affordable to Intermediate), which better reflects local needs and viability than the proposed London-wide 60:40 split. They are also challenging the restriction on using local evidence to inform market housing mixes, advocating for the ability to set market housing mixes that reflect local needs, particularly the need for family-sized housing.
The council is opposing the removal of carbon offsetting payments, raising concerns about how planning authorities will address circumstances where targets cannot be met without this mechanism. They are also expressing significant concerns over the evidential basis for Richmond's housing target, questioning the realism of assumed capacities for identified sites, the balance of delivery from small sites with historic character, and the lack of assessment of impacts from industrial land loss. They are advocating for targets to be set at an evidentially achievable level.
While supporting the principle of opposing Heathrow expansion unless no unacceptable environmental, transport, and congestion impacts are demonstrated,
they express concern that this caveat could weaken the overall policy position and advocate for the Mayor to align with Richmond's position on Heathrow expansion. Furthermore, they oppose the proposal that prevents individual boroughs from setting their own energy efficiency targets, advocating for the ability to do so where evidenced as justified and achievable.
The overall sentiment is a call for a more nuanced approach
and greater local flexibility
where London-wide policies may not fully reflect Richmond's circumstances.
Impact of Failing to Meet Targets
Failure to meet housing targets could lead to a weakening of the local plan's influence under national policy, as stated in the meeting information. The draft London Plan also sets higher housing targets, and continued failure to meet these could result in further scrutiny and potential weakening of the local plan's influence. However, specific consequences from the Mayor's office or in terms of regional housing needs beyond this are not detailed.
Infrastructure Concerns
The draft London Plan continues to set policies on transport and utilities infrastructure but no longer includes dedicated policies on key social infrastructure, including education, health, and playspace. The council's response aims to highlight the important enabling relationship between housing targets and meaningful infrastructure provision, and the need to ensure the new London Plan's removal of these policies does not weaken this relationship. While the proposed 31% increase in the housing target is discussed, the specific projected impacts on transport, schools, and healthcare facilities are not detailed.
Alternative Strategies for Housing Delivery
Richmond Council is concerned about its housing target due to 'limited strategic development sites' and 'stalled delivery of some existing sites.' The response to the draft London Plan advocates for greater support for boroughs to address stalled sites and poor build-out rates, citing local examples where the council has approved developments that subsequently have not been built as expected. The draft London Plan's Optimisation Framework, which focuses on urban and suburban intensification, is also discussed. The council's response recognises the logic behind optimising development in areas with higher levels of accessibility but raises concerns over the practical application of the Optimisation Framework in areas with significant heritage and townscape constraints. While the council supports increasing housing delivery and maximising brownfield land opportunities, and is exploring intensification, the text does not explicitly detail alternative strategies beyond these points that are not reliant on strategic development sites.
Public reports pack Tuesday 15-Sep-2026 19.00 Environment Sustainability Culture and Sports Co.pdf Agenda frontsheet Tuesday 15-Sep-2026 19.00 Environment Sustainability Culture and Sports Comm.pdf