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The Housing Delivery Gap: Borough Performance Against London Plan Targets

Quantifying where London is falling short — and why the data tells a more complex story than headline numbers suggest

Ralf LindemannFounder, Stormglass 20 July 2024 11 min read
67%
London's delivery vs London Plan target
Across all 33 boroughs 2019–2024
8
Boroughs meeting or exceeding target
Tower Hamlets, Newham, Barnet, Croydon, Brent, Ealing, Southwark, Greenwich
31%
Affordable housing delivery rate
Vs 50% London Plan benchmark across approved schemes
4.1 years
Average permission-to-start lag
For major residential schemes approved 2019–2021
Abstract

London's housing crisis is well-documented. Less understood is which boroughs are most responsible for the delivery gap, why they are underdelivering, and whether the problem lies in approvals, starts, or completions. This report uses PLD data to disaggregate the 67% below-target figure into borough-level patterns.

Not a planning problem — mostly

The headline — London is delivering 67% of its housing target — is frequently cited as evidence of planning system failure. The data tells a more nuanced story. In most underdelivering boroughs, the approval rate for residential applications is not the constraint. The PLD dataset shows that across London, 71% of major residential applications (10+ units) were approved in the 2019–2024 period. The gap between approval and delivery — between a planning permission and a completed home — is where most of London's shortfall sits.

71% of major residential applications were approved. London is not refusing its way to underdelivery — it is approving schemes that don't start, or that take so long to start that market conditions change the economics.

Stormglass Research, July 2024
The permission-to-start lag
4.1 yrs
Average start lag
Approved 2019–2021 major schemes
28%
Permissions not started
Approved >3 years ago, no start recorded
£340M
Estimated unbuilt S106
Obligations attached to unstarted permissions
18,400
Homes in stalled pipeline
Approved but not started, London-wide

Which boroughs are delivering

Eight boroughs are meeting or exceeding their London Plan targets. What they share: a combination of large-site delivery (regeneration areas, opportunity areas) rather than infill; active council housing programmes; and where relevant, mayoral development corporation oversight which removes the scheme from borough planning determination. Tower Hamlets, Newham, and Greenwich benefit from all three. The lesson is not replicable everywhere — most boroughs lack the large brownfield landholdings that make regeneration-led delivery viable.

The affordable housing compliance gap

The 50% affordable housing benchmark in Policy H4 is being met in full compliance in only 14% of major approved schemes. The median affordable housing percentage in approved major residential applications across London is 31% — a 19-percentage-point gap from the London Plan benchmark. Viability assessments are the primary mechanism through which this gap is justified. 35% of major applications with below-benchmark affordable housing ratios submitted a viability assessment as part of the planning application.

Primary causes of delivery gap by category

  • Build-out lag: permissions secured but construction not commenced (estimated 18,400 homes)
  • Viability: schemes approved at reduced affordable ratios that require market conditions to improve before starting
  • Phasing: multi-phase schemes where later phases are contingent on sales absorption from earlier phases
  • Infrastructure: schemes dependent on Section 278 agreements and utility connections not yet completed
  • Ownership: sites in multiple ownerships where assembly is incomplete despite planning permission
Methodology

Completion data from MHCLG represents net additional dwellings, which includes conversions, changes of use, and demolitions offset against new build. PLD approval data covers applications submitted to the 33 London boroughs plus the GLA for referable schemes. The affordable housing delivery rate was calculated only for applications with residential_details data present in PLD — approximately 61% of approved major residential decisions. Schemes without residential_details data were excluded from the affordable housing analysis but included in the headline delivery statistics.

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