Quote of the Day:
“And marbled clouds go scudding by
The many-steepled London sky.”
― John Betjeman
In a stunning departure from the norm, the Draft London Plan was published today, not only on the promised day but early in the morning as well. Apparently it had to be pushed out ahead of a key member of staff going on maternity leave, proving once and for all that having mothers in the work place only makes things much more efficient and effective.
The document is well over 500 pages so what follows is a brief (yes genuinely brief compared to the document itself) canter through some of the key issues as we read it. I am sure there are others we have missed and I am happy to review and debate at length with anyone interested!
The Plan has been heavily trailed with a series of supplementary policies indicating the direction of travel – not to mention the already very clear policy on affordable housing requirements (although the Draft document continues to reference a ‘strategic target’ of 50% genuinely affordable housing, I have no idea what that actually means in practice). Whilst Sadiq got off to a very slow start in terms of housing delivery, his team have begun to pick up the pace with both the recent Mill Hill and Wandsworth Homebase site decisions signalling a determination to secure housing delivery (particularly where it isn’t threatening a Labour majority – or perhaps I am just cynical?)
There is, however, a continued reluctance to call in applications in Labour-run boroughs ahead of the May elections, particularly in boroughs such as Tower Hamlets. Clearly nothing to do with the elections, all just a strange coincidence. However, that may well change after polling day as Sadiq increasingly turns his mind to his own election in 2020 and the promise to deliver significant housing numbers before that point.
And from the politics, on to the substance…
The premise of the ‘Good Growth’ Plan is the need for at least 66,000 new homes and space for tens of thousands of new jobs to be created every year. The Plan is intended to provide a framework for action rather than an extensive vision statement – whether that is the case remains to be seen post-implementation.
The Plan is not always consistent with national policy – so where that sits if there is a conflict with either local authorities or applicants is not clear. Certainly housing numbers are different from the new OAN system which central government is introducing.
The Plan is very specific on individual Opportunity Areas and Housing Zones, specifying housing and development requirements in particular areas. Some of these are touched on later in this document – for the rest, there is a link to the document itself as it would be a very long read if we covered all of the detail. Safe to assume, anywhere with new transport links coming forward, or anywhere deemed to be part of a strategic network to main routes out of London are all deemed suitable for intensification of development and potentially subject to AAPs and further guidance/scrutiny.
The CAZ also has a very clear description of the role and function beyond housing and in terms of provision of all of the facilities expected within a large city. Key to this is the relationship between different areas of the CAZ, connectivity and the appropriateness of development in different areas. The Plan also includes the need for industrial land and supply to be considered in CAZ policies, at the same time providing protection for CAZ areas from PDR and giving those affected local authorities the ability to prioritise the provision of offices over residential where appropriate, this includes Vauxhall Nine Elms, Battersea and Elephant & Castle and also brings in the potential for land use swaps, credits and off-site contributions.
There is much focus about inclusivity and the role of town centres and diversity in development in this context – ultimately, it is all about placemaking having a key role alongside the delivery of affordable housing (something frequently overlooked by some local authorities).
The document also floats the introduction of Health Impact Assessments for developments which will look at the impact on health and wellbeing of development proposals. This is a pretty vague proposal at this point and we certainly would need clarity on what this actually entails, how it will be implemented and what the costs and effects on development proposals will be. One outcome from this is likely to be the restriction in the numbers of ‘unhealthy food options’ that can be within developments or communities – as clearly people can’t make their own decisions on what to eat.
The provision of social facilities, health care, education, environment, air quality etc all have a dedicated section, following previous London Plans but going into much more detail about how thinking about such inclusion needs to be factored into design at the earliest stages and needs to form part of early discussions with boroughs. More detail can be found in the document, or I am happy to provide info on specifics if you are interested.
There is also a whole section on food and a section on heritage and culture (culture and creativity good, let’s have more of it) at around page 300, covering strategic views (reinforces existing policies and adds a few local nuances in), conservation areas again, I have not focused on this primarily due to brain freeze but happy to review!
Pretty good really if it all gets implemented. Positive approach, carrots and sticks, lots of work for everyone to do. Let’s hope Brexit doesn’t tank the economy and no one can then pay for or implement anything. On the basis it won’t, the specifics and very targeted approach of aspects are a determined move which suggests Sadiq will accelerate intervention and drive forward delivery of all functions of the Plan. Let’s hope he does.
Not wishing to totally alienate the outer borough Tory vote, Sadiq reinforces a commitment to preserving the greenbelt – making the rather bold statement that it will accommodate all growth without intruding on any greenbelt or protected green spaces (possibly not the best news for those applicants with proposals for greenbelt release). The inevitable consequence of this is increased densities in other areas, those with good transport links and in existing well connected and well served areas.
For the first time, the Plan specifically looks to work with boroughs outside of the capital to seek strategic partnerships to accommodate growth and take some of the housing need as apparently London can only take 65,000 of the required 66,000 per year (rather conflicting with the earlier statement about all of London’s growth being accommodated without encroaching on greenbelt, clearly Sadiq meant without encroaching on London’s greenbelt but other boroughs’ greenbelt is clearly fair game).
Design has a renewed focus as a solution to crime and anti-social behavior as well as place-making, environmental and ecological. Inclusivity forms a key part of this and, within this, a move to eliminate so called ‘poor doors’ from future developments described as allowing everyone to use entrances without ‘separation or special treatment’. It will be interesting to see how this translates on the ground when the complexities of service charges and costs are factored into the delivery and management of housing by the RP – could an unintended consequence be that it pushes developers more towards entirely separate affordable blocks rather than mixed tenure blocks?
The Plan also reiterates the minimum space standards, lifetime homes and changes the focus on the way in which storage is dealt with in terms of the overall space standards. Higher density developments will be subject to greater scrutiny through the GLA design team with a ‘Delivering Good Design Management Plan’ to be submitted for developments over specific densities in different PTAL areas: 110 units per hectare in PTAL 0-1; 240 units per hectare in PTAL 2-3 or 405 units per hectare in PTAL 4-6.
Tall buildings and basement developments also receive reference with a focus again on design and relationship with the existing streetscape. In terms of tall buildings, the policy is similar to that which went before (although I may have missed some key difference so accept my apologies in advance if so). In terms of basement development, a policy has never really been needed before and it really affects a very small proportion of the city.
Clearly the Plan is primarily about housing, not just about where it should go and what it should look like but also about how it should be delivered. The Plan seeks to implement build out target rates as part of planning consents, both incentivizing and penalizing applicants to ensure delivery.
The Plan sets out ten year housing targets for each borough placing a requirement on boroughs to prepare delivery-focused development plans looking at all potential sites within their areas. Boroughs also will need to publish annually updated progress reviews and regular reassessments based on infrastructure capacity. Page 146 of the Plan sets out the targets for each borough which differs significantly from the OAN assessments so that will be interesting to watch play out.
The Plan also talks about ‘sustainable and inclusive’ regeneration – perhaps a nod to the current Labour leadership policy focusing on ‘regeneration not gentrification’. We can probably expect a more stringent focus on re-providing affordable homes on a like for like basis and a wider inclusion of community uses and accessibility.
The existing Opportunity Areas and CAZs are expected to take the majority of the growth with the intention being for much greater densification of those areas. The Plan also recognizes the need for many more small sites of up to 25 homes to be delivered as well as incremental densification of existing developments – these can be assembled and delivered quickly without getting caught up in planning and conditions as the larger sites do. A separate table targeting small sites across each borough is also set out with specific numbers.
Supported and elderly housing plus student housing all have individual focus. I have not covered these in detail but happy to provide the info if anyone wishes to have it.
Estate regeneration will be expected to provide at least the same amount of affordable floorspace (key is the use of the word floorspace here rather than number of units) with social rented to be replaced by the equivalent accommodation with rents based on the same levels. The Plan recognizes that this will largely be delivered through an uplift in densities and intensification of development on site. Any deviation from the existing provision of affordable housing will be scrutinized by the Mayor.
In a slightly unusual policy, the Plan also sets out an aspiration to secure ‘meanwhile housing’ on land set aside for large scale phased development. Using off site construction and setting specific time periods, the theory is that this can provide a quick fix for a large problem. This may well work in some locations, but there is huge potential for difficulties when it comes to removing the meanwhile housing in some circumstances. Certainly an interesting and innovative policy and one which could make a real positive change if the detail of it is absolutely watertight and well understood.
The intention is to limit off-site contributions and cash in lieu contributions (although it is recognized that this is the most appropriate option for smaller developments). The Plan sets out a requirement to ringfence any commuted sums to ensure they are specifically used for delivering affordable housing. For off-site or commuted sums, the affordable housing target is 50% rather than the 35% which can be delivered without viability. In OAs, the target may be changed with boroughs enabled to apply a localized threshold.
The 50% target is also set for development on public sector land or development on SILs and locally significant industrial sites. Affordable housing will be measured on the basis of hab rooms rather than units with a requirement for figures to presented as a percentage of total provision in terms of hab rooms, units and floorspace to enable comparison.
The following tenure of affordable is to be applied: 30% low cost (either Social or London Affordable rent); 30% intermediate (including London Living Rent and Shared Ownership), 40% to be determined by the borough depending on local need. Only schemes which meet this split will be eligible for fast track.
In a change to previous Plans, family housing can now be considered as two-bedroom and above rather than three-bedroom and above. This reflects growing trends towards people starting families in smaller properties both in the private and social sector.
Build to Rent
BTR gets a mention as qualifying as part of affordable housing if it meets the rental criteria as above, has at least 50 units and is under covenant for rental for at least 15 years. Viability assessments will also be expected to take account of the differences between BTR and sale developments.
There is also focus within the Plan on implementing measures to incentivize and encourage BTR on specific smaller sites within boroughs and supporting BTR on public sector land.
In a swipe at the growing Air BnB trend, there is a new requirement for planning permission for any homes which are let for more than 90 days a year.
Vacant Building Credit
VBC will only be applicable if:
- The building is not in use at the time of an application
- The building has been vacant for at least 5 years prior to an application and marketing for a least 2 years at realistic prices
- The building is not covered by an extant or recently expired permission
- The building is not protected for alternative land use
- The building has not been made vacant for the sole purpose of redevelopment
Car free, car free, we’re all going to go car free – except where we’re not because the local authority won’t let us… Good news for all those developers who are struggling in areas like Havering where councillors in particular demand at least 1:1 car parking regardless of proximity to train stations. The car free policy in areas of good public transport will provide the necessary substance to much of the debate surrounding car parking within development proposals, particularly at the early stages of consultation and design.
Sadiq is formally promoting the Bakerloo Line Extension (BLE) from Elephant & Castle to Lewisham stopping at Old Kent Road and New Cross Gate. The anticipation is that this will be largely paid for through developer contributions in the beneficial areas. The areas which will then have access to the tube network will subsequently be expected to promote significantly increased densification of development.
Similarly in those areas benefitting from Crossrail 2, a significant regeneration impact is expected and with it a densification in housing development – this includes Kingston, Wimbledon and Clapham Junction in the south, Poplar, Royal Docks and Thamesmead to the east and Lee Valley, Wood Green and New Southgate in the north. All of these areas are deemed to be capable of accommodating significant levels of housing, employment, infrastructure and associated development.
The Plan identifies the changing role of town centres, heavily influenced by the trend towards online shopping and the particular impact this has on smaller town centres. Whilst offering no silver bullet – but then who can offer that – it gives greater flexibility for local authorities to look at how town centres are classified and planned and how to make best use of space and facilities to create a sustainable location with active day and night time economies. At the same time, the Plan re-emphasises the need for sequential testing and town centre first policy, resisting out of town and refreshing the focus on the purpose and role of town centres. Again, an Article 4 provision is included facilitating resistance to PDR if it is felt to damage the viability of a town centre.
As highlighted before, there are increased protections against PDR where appropriate and a far greater overall focus on the provision of different types of space for business and employment than previous Plans reflecting the different markets in different parts of the city and the need for variation in terms of size and type of provision. It is expected that there will be a need for up to 6.1m sq m of office space to 2041.
As expected, the Plan not only requires the delivery of employment space, but also the delivery of affordable employment space for SMEs. Where B1 space is lost, it is expected that this be re-provided elsewhere or demonstrated that there is local surplus. There is a lot of focus on the need for more flexible space across the city, whether co-working, managed or serviced and recognition of the role that this has to play in the economy as a whole. This is a marked shift from previous Plans which have regarded such space as more of an afterthought whilst pursuing big floorplate businesses potentially to the detriment of smaller businesses. The Plan effectively rectifies that and looks at using planning to support the increase in such space across the capital.
Developments of over 2,500sq m gross external space should consider the scope to provide flexible workspace. Furthermore, in larger developments or areas in which there is a demand for space from a range of sectors such as charities or social enterprises, planning obligations can be used to ensure the provision of discounted workspace, this has to be managed by a workspace provider with a long-term commitment to maintaining the space. Local authorities are expected to include such provisions within their local plans and applicants are expected to design in appropriate workspace at the outset to ensure the space is configured and managed effectively.
The Plan references the need to sustain Strategic Industrial Locations (SIL) and making more efficient use of the land. It is likely that mixed use will become at least part of the focus – boroughs such as Wandsworth have already developed their own review and redesignation of industrial sites, other boroughs such as Brent and Barnet are rapidly converting industrial sites to resi in a number of locations.
In specific reference to Old Kent Road and the AAP which is currently in preparation, the Plan states that the AAP should plan for no net loss of industrial floorspace capacity (although it doesn’t specify the type of industrial uses). This may well pose a challenge given the huge amounts of resi already proposed and the current anticipated loss of industrial sites. This is closely linked to the proposed BLE.
The Plan sets out specific sites and areas where industrial locations are to be protected and introduces policies to support the intensification and enhancement of others taking into account the wide range of businesses that can now be classified as industrial. There is also a requirement for any provided (or re-provided) industrial units to be occupied and operational prior to any residential elements being occupied – presumably this is to ensure that people know they are moving next to industrial uses and to expect a degree of noise or disruption from such operations. At the same time, the Plan specifies the need to take into account the proximity of residential to industrial in the design of mixed use development.
There is a lengthy section on funding the Plan, in summary – the public sector will pay for some of it and will borrow under permitted mechanisms where we can, but we are basically totally skint so please can you the private sector mainly pay for it? Lovely, thanks!
“As a cloud crosses the sun, silence falls on London; and falls on the mind. Effort ceases. Time flaps on the mast. There we stop; there we stand.”
Virginia Woolf, Mrs Dalloway