Planning in London January - March 2024 issue 128 by brianwaters1

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The Journal of the London Planning & Development Forum Issue 128 JANUARY-MARCH 2024

LEADERS page 5 FINCH page 7 MALLETT page 8 ¡PILLO! page 48 PLANNING PERFORMANCE p30 ROGERS page 47 LP&DF page 38

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THE LONDON PLAN AND HOUSE BUILDING Simon Ricketts page 20; GOVE’S LETTER TO MAYOR KHAN Katy Davis page 14; LEADERS pages 5 & 6; TIME FOR SMEs IN HOUSE BUILDING Marc Vlessing page 19; AFFORDABLE RENT-TO-BUY Emma George page 63; LP&DF ON PERMITTED DEVELOPMENT Ben Clifford page 38; INTERFAITH UNDERSTANDING Daniel Leon page 60 THE ESSENTIAL GUIDE TO DEVELOPMENT IN THE CAPITAL

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CONTENTS

PIL 128 CONTENTS

5 LEADERS Mr Gove goes topsy-turvy Time to show some teeth 7 PAUL FINCH Neophobes are always with us 8 LEE MALLETT Big shifts in the right direction 9 Fleet Street Quarter | Lady Lucy French

FLEET STREET QUARTER | Lady Lucy French page 9

OPINIONS 14 On the newly revised NPPF | Colin Brown & Gove’s letter to Mayor Khan | Katy Davis 15 Hybrid working | Mark Dixon 16 Cracking the housing nut | Ritchie Clapson 17 Affordable housing | Andrew Golland 19 Time for SMEs in house building | Marc Vlessing 20 London Plan and house building | Simon Ricketts 22 Carter Jonas Outlook for 2024 25 BRIEFING City’s new transport strategy | Nico Bosetti 30 CLIPBOARD: Challenge to the London Plan; Sixth time lucky for South Ken station; London boroughs are five of top ten that earned most from pre-application advice; Statutory consultees under pressure to respond; More money, no problems?; M&S hits back; Keir Starmer pledges; Extension of time agreements to be cut short; One of the last large PD office-to-residential schemes delivers

INTERFAITH UNDERSTANDING | Daniel Leon page 60 30 PLANNING PERFORMANCE Decisions both decided and granted show strong fall over the past year Latest planning performance by English districts and London boroughs: planning applications in England July to September 2023

MOMENTUM CONNECT Transport and the commitment to the climate challenge page 49 www.planninginlondon.com

LONDON PLANNING & DEVELOPMENT FORUM Planning reforms from UCL, ACA & POS: 38 Permitted Development - Professor Ben Clifford 42 Ideas for Planning Reform led by Andy Rogers of the ACA Continues 43 Plan-making reforms led by Mike Kiely, chair next page >>> >>> of the Planning Officers Society Issue 128 January-March 2024

CONTENTS CONTINUED

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47 ANDREW ROGERS A tale of two sillies 48 ¡PILLO! COP-out: Climate verbs; Britain did not grow rich from refused planning applications; Winner: best retrofit; The remaking of Foster’s City Hall; The world's most expensive cities to live in

¡Pillo! The remaking of Foster’s City Hall page 48

49 MOMENTUM Connect Transport and the commitment to the climate challenge FEATURES 60 Interfaith understanding | Daniel Leon 63 Affordable rent-to-buy | Emma George BOOKS 66 The Mansion Block | Reviewed by Lee Mallett 67 Modernism Beyond Metro-Land | Joshua Abbott 68 Mr Chelsea | Paul Davis 70 Lubetkin and Goldfinger | Nicholas Russell 73 Projects In Property | Denis Minns 75 PLANNING AND ENVIRONMENT REFERENCE GUIDE 78 SUBSCRIPTION ORDER FORM 79 SHAPING THE WORLD London’s new mega neighbourhoods

Mr Chelsea by Paul Davis page 58

83 ADVICE

Publishing Editors: Brian Waters, Paul Finch and Lee Mallett editor@planninginlondon.com, planninginlondon@mac.com ISSN 1366-9672 (PRINT) ISSN 2053-4124 (DIGITAL) Issue 128 JANUARY-MARCH 2024 www.planninginlondon.com

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The London Planning and Development Forum (LP&DF) The LP&DF was formed in 1980 following an all-party inquiry into the development control system. It selects topics to debate at its quarterly meetings and these views are reported to constituent bodies and published in Planning in London. It is a sounding board for the development of planning policy in the capital, used by both the public and private sectors.

The LPDF is administered by: Honorary Secretaries: Riette Oosthuizen riette.oosthuizen@hta.co.uk & James Mitchell RIBA jm@axiomarchitects.co.uk

Agendas and minutes are at www.planninginlondon.com To attend please email the Hon. Secretary

Member bodies Association of Consultant Architects Planning Officers’ Society/Association of London Borough Planning Officers

Planning in London

Chairman: Brian Waters MA DipArch (Cantab) DipTP RIBA MRTPI ACArch ppACA FRSA Principal: The Boisot Waters Cohen Partnership brianwaters1@mac.com Vice-Chairman: Jonathan Manns: JLL jon.manns@gmail.com

Available only on subscription: £99 pa Provides a licence for five copies by email See subscription form or buy online at www.planninginlondon.com. Planning in London is published quarterly in association with The London Planning & Development Forum by Land Research Unit Ltd Studio Petersham, Gorshott, 181 Petersham Road TW10 7AW

Contributors write in a personal capacity. Their views are not necessarily those of The London Development & Planning Forum or of their organisations. Correspondence and contributions are invited for consideration. The editors reserve the right to edit material and letters supplied.

London Councils British Property Federation Design Council CABE City of London Law Society Confederation for British Industry DLUHC Design for London/ Urban Design London Historic England Environment Agency Greater London Authority Home Builders Federation Landscape Architecture SE London Chambers of Commerce & Industry London Forum of Amenity Societies London Housing Federation National Planning Forum ICE, RIBA, RICS, RTPI, UDAL, TCPA

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LEADERS

Mr Gove goes topsy-turvy As ever, Secretary of State Michael Gove wants to have it both ways

Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992

Was it the grandstanding claim by Keir Starmer that he would ‘drive a coach and horses’ through the planning system in order to deliver more housing that prompted Michael Gove to go all Stalinist about housing delivery? As the front-page Times headline put it: ‘New homes to be forced through’, with the additional heading ‘Councils risk losing planning powers if they reject developments’. The longer story included the suggestion that Gove would set up a state housing organization (shades of Singapore) to ensure that housing takes place where and when it is needed. Particularly around Cambridge, it seems. That city, despite well publicised water shortages, is to be on the receiving end of plans for 150,000 homes (100,000 fewer than previously announced, but still . . . ) Is this the same Michael Gove who called in for inquiry a large housing scheme approved by Hounslow Council in spring 2021? Indeed it is – perhaps with good cause, since the planning inspector recommended refusal, describing the proposed development, featuring 16 blocks of up to 17 storeys as being too large in scale, and collectively forming an ‘incongruous, monolithic wall of development’. Guess what? Gove then rejected the inspector’s findings and granted approval! The question the grateful housebuilder was too polite to ask was: why Gove had initiated a public inquiry in the first place? It has taken nearly three years for nothing to be built. The Secretary of State for Levelling Up (or is it Dumbing Down?) is now the greatest advocate for hitting that pesky 300,000 homes a year target, which only recently he dismissed as only being a number, whereas what really matters is quality. Identification by planners of land for housing development is back, after recent attacks on the idea of five-year land supplies. On the quality front, all we can say is that this government cannot even commit to compulsory minimum space standards; their advisory standards for family homes are a joke unless you like killing cats by swinging them in any dimension in the miserable bedrooms politicians think are suitable for proles. As ever, Gove wants to have it both ways. He is keen on being the housebuilders’ greatest supporter, but also happy if planning authorities reject designs which harm the character of an area – presumably excluding 17-storey towers. There is always an escape clause in Gove-land, which is why his fantasy-figure housing targets are being treated with healthy scepticism by companies that actually build homes. Of course the chickens in Gove-world are unlikely to come home to roost – because we have an election coming up next year. Those Hounslow homes may have made a start on site by >>> then, but it is all too little, too late. n

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Issue 128 January-March 2024

LEADERS

Time to show some teeth It’s no longer about money. It’s about existential need.

Planning in London

Michael Gove’s letter to Sadiq Khan in December responding to the London Housing Delivery Taskforce’s (LHDTF) position statement shows some dirigiste thinking unhelpful to solving a truth universally acknowledged - London has the UK’s worst housing crisis. ‘If you cannot do what is needed to deliver the homes that London needs, I will,’ he threatens. If only. We doubt you’ll get the chance, Mr Gove, and, if an unlikely miracle general election offers an undeserved lifeline, that you will unlock the resources needed to build the true amount of social and affordable homes London needs. Which is way beyond the London Plan’s official targets for each year and for the plan period. One sensible suggestion made by the LHDTF is that Government should re-open the Housing Revenue Account (HRA) debt settlement to enable local authorities to borrow cheaply. This was agreed in 2012, 12 years ago. Gove’s answer is deeply ideological. The settlement, he says was intended to run for 30 years – ‘the length of the typical HRA business plan. There are no plans to review it ‘as we are only 10 years into the settlement’. This is ye olde Monetarism. Nothing, not a housing crisis, and certainly not the fiscal desires of spendthrift local authorities, gets in the way of the holy war on inflation. Not even if the economy of the capital begins to fail because of the lack of affordable homes. Wrong Mr Gove. And to keep sticking to a 30 year plan is daft when all around is evidence of the need for fresh thinking. It’s no longer about money. It’s about existential need. The only way sufficient affordable and social homes will ever be provided is if collective money – taxes – are used to encourage their development by whoever can deliver. The Public Works Loan Board, the bank boroughs borrow from, should offer fixed rate loans, ideally at a reduced rate, argues the LHDTF. No way, says Gove. You get a 0.4% reduction on market interest rates as it is and we’ll review as usual in June 2024. Wrong again. The rocketing of interest rates, in case you hadn’t noticed Mr Gove, bust a hole in all private and public housing development plans, and the HRA settlement is also deeply unhelpful. It would be a devout atonement if the Treasury were to make available fixed rate long term loans to local authorities. Housing development needs certainty, in finance (as in planning). But see again the dead hand of the Treasury and outdated Tory ideology in Gove’s response. No amount of S106-provided affordable homes will ever touch the sides of the capital’s shortage. Fiscal relaxation is needed, so the public sector can partially fund, and the private sector can help deliver, the homes Londoners need. Let’s hope the Mayor’s task force, due to respond in January, shows some teeth in asking for what’s needed. n

OPINION: NEOPHOBES ARE ALWAYS WITH US | PAUL FINCH

FINCH

Neophobes are always with us ‘It hurts me when I see new buildings.’ This statement of confidence in the present and future appeared in a Times interview with Lord Mendoza, appointed as head of historic England in the summer,. As provost of Oriel College Oxford, he knows a thing or two about troublesome presents, since the college’s connection to colonialist/imperialist/benefactor Cecil Rhodes caused student protests who wanted his statue removed. And why stop there? Resolution of the issues suggests that Lord M is a skilful diplomat, so his neophobe comments about new buildings are a little surprising. He wonders if retrofits and the sustainability benefits they bring should be part of the Historic England strategy for protecting buildings and places which might be threatened by development, good, bad or indifferent. This is not a bad idea. It always seemed extraordinary that HE’s predecessor body, English Heritage, was so keen on knocking down Robin Hood Gardens in east London, by Peter and Alison Smithson, given the huge amounts of embodied energy contained in the social housing block. But then at the time, the organization was bending over backwards to please its Secretary of State, who had made it quite plain that neither she, nor her constituents (who were completely irrelevant since they were not local to RHG), liked concrete. Even former apostles of the new, like David Chipperfield, seem to be having second thoughts about the merits of new construction. At an Architecture Foundation event, to celebrate his Pritzker Prize award, he said he regretted the demolition of a slim 1960’s building in Hanover Square, and its replacement with a more up-to-date building no doubt delivered for investors who simply saw profit to be made from increased land values. Well yes, but you couldn’t help wondering what the 1960s building replaced. Message to Lord Mendoza: everything was new once.

Over-egging a bland pudding Thomas Heatherwick is no neophobe. On the contrary, he wants everything to be whizzy and designerly. The worst thing you can say about a building, in his book (and he has just published one), is that it is boring – or bland, if there is a dis-

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tinction to be made. Humanise: a maker’s guide to building our world has some thoughtful arguments and insights within it. He argues among other things that we have been suffering from a ‘global blandemic’, flowing from the evils of Corbusian town planning and the ‘cult of Modernism’ which has stealthily infected every architecture student in the land. Up to a point, Lord Copper. An accompanying BBC radio series (hats off to TH’s marketing people!) was, however, a curate’s egg. Among the claims made: people can die from heart attacks brought on by bland environments; the Syrian civil war was fuelled by boring buildings; architects were forced to be members of the RIBA at the end of the 19th century (in fact compulsory registration was only introduced in 1931, and did not require anybody to join the RIBA). It was also stated that the new president of the RIBA, Muyiwa Oki, is the first non-white to hold the post. This will have come as a surprise to Sunand Prasad (RIBA president 2007 to 2009). I suppose facts can be boring too. All eyes on the London Stirling Prize Although this year’s Stirling Prize dinner was held in Manchester, five of the six finalists were London projects, which looked unbalanced to say the least. No big architectural beasts this year, but a very worthy winner in Mae Architects’ facility for the elderly. Alex Ely of Mae makes a good point when he argues that the standards they achieved with the project should be the norm rather than the exception; were that the case then the search for the truly outstanding would be that much more difficult. This brings us back to another Heatherwick issue: the desirability the ordinary. It must have occurred to him that his often-extraordinary structures and designs have that quality because of the existence of the mundane everyday. Frankly, I would rather have boring housing which is decent in terms of space, volume and environmental standards, than something with immediate external visual appeal which may be a disaster internally. Designing exclamation marks and putting them all together means none of them are exclamations any more. Queston to Thomas: is quiet prose boring?

Paul Finch is programme director of the World Festival of Architecture and joint publishing editor of Planning in London

When retrofit is not the answer The legal challenge to refusal of planning permission for a redevelopment of the Marks & Spencer store at the east end of Oxford Street continues to generate debate about carbon, concrete, intensification, land values and the integrity of the UK planning system. As readers may recall, Westminster Council and the London mayor supported the redevelopment proposal, but it was called in for public inquiry by the Secretary of State responsible for planning, Michael Gove. After a lengthy public inquiry, the inspector concluded that the development should be permitted. Mr Gove overturned that decision, but his own conclusions, which are fuzzy and certainly do not focus on carbon as an issue, are now being challenged legally by a furious M&S. Having founded and launched the Architects’ Journal Retrofit Awards a decade ago (they are still going strong), I am all in favour of this form of architecture, and I agree that an analysis of retrofit/reuse/recycling options should by part of any architectural analysis. However, this does not automatically mean that it is always appropriate. The inquiry inspector said the retrofit proposed by Save Britain’s Heritage ‘is so deeply problematic, even for Oxford Street that noone would be likely to pursue it or fund it’. At Para 13.70, the inspector’s letter says this: ‘I find that there is no viable and deliverable alternative and that refusing the application would probably lead to the closure of the store, the loss of M&S from the Marble Arch end of Oxford Street, and substantial harm to the vitality and viability of the area. This is a material consideration of substantial weight.’ No wonder M&S are going to court. n

Issue 128 January-March 2024

OPINION: THE CITY TRANSPORT STRATEGY

MALLETT

Big shifts in the right direction Amid ongoing stories about the waning appeal of the UK stock market - the IPO desertions to the US where values are so much stronger, the lack of confidence that pension funds’ minimal 4% holding in UK equities represents - an ever more nurturing City Corporation is, despite the gloom, steadily transforming the roads, pavements and public realm we imagine as made of gold, while also approving 11 new towers. Dick Whittington would approve the chutzpah and faith in the future. The Corporation is already reviewing its farsighted 25-year Transport Strategy, only adopted pre-pandemic in 2019. A public consultation on closed on 7 January. We can expect the review to complete in May 2024, when the strategy will be adopted and published, to align with the Draft City Plan 2040, which goes to committee approval between January and March and then to public consultation. Assistant director for policy and projects, Bruce McVean, summarised the strategy review at December’s City Architecture Forum meeting under the heading City Streets Transport for a changing Square Mile. And the impression is not so much of a transport strategy, as a strategy for place. Every effort is being made to optimise public realm. Other boroughs should be envious. Transport is of course a big villain in climate change. And the Government’s policy, as Roy McGowan of consultants Momentum Transport reminded attendees, envisages decarbonising transport by 2050. We’ve been told to stop predicting and providing, and to ‘vision’ and ‘validate’ using eviStreet space reallocation at Bank Junction

Planning in London

dence instead. And this is what the City seems to be about. The good news said McVean is that ‘we’ve seen a pretty solid return to the office’. Total entry and exits at TfL stations in the City – on Tuesdays, Wednesdays and Thursdays only at around 2.2m is up on 2022 and rising to meet 2019 levels (c2.7m). More speculative, but perhaps even more impressive is that the GLA is projecting City jobs to jump from around 650,000 now to more than 740,000 by 2040. These are the drivers of the City’s desire, and the need, to optimise the City’s public realm. City to create a spectacularly transformed string of major new public realm And in terms of modal shift, overall traffic since 2000 has fallen by around 20%, while the number of people cycling keeps rising, having increased fourfold in that time. Numbers driving in the City has been slashed by two-thirds. These are big shifts in the right direction. Cycles are now the biggest percentage of wheeled movement at 26.8%, although taxis, cars and private hire vehicles combined still account for c.40% when combined. But unlike all other categories, cycling is increasing, while other categories are declining. The overall need, however, remains how to balance the fiercely competing needs of pedestrian and vehicular movements that will only increase if the predicted jobs turn up. A streets survey of City folk last year makes people’s priorities clear – they want great accessible walkable streets that are safer and quieter. A desire expressed more intensely than the need, for example to ‘get more people cycling’.

Lee Mallett is a founder editor/publisher of PiL and urban regeneration consultant/writer

Streets that inspire and delight, inclusivity and accessibility are the watchwords, and the notion that ‘the City’s success cannot be separated from the outstanding environments that enable it.’ Place is what generates everything, in other words. And there are now five Business Improvement Districts in the City that fervently believe in that all pursuing change with the Corporation’s blessing. New, colourful, playful and more widely distributed public seating is being installed in various locations. ‘We need more,’ said Mc Vean. And shade and shelter, along with raised crossing to slow traffic, and more pedestrianisation, recaptured from roadways or where feasible, minor road closures to create new pockets of pedestrian dominated public realm where vehicles have restricted access only. The changes at Bank junction since 2017 will continue and have so far ‘saved’ or recaptured six tennis courts’ worth of space for pedestrians. So much that after no less than 25 years of being badgered by the highly successful restaurant at 1 Lombard Street overlooking the junction, the City has finally found the space and allowed one of the City’s best know eateries to put some tables outside. Some things could perhaps move faster. Further changes include making Threadneedle Street cycle only in term of vehicle movement. And the much anticipated demise of the St Paul’s gyratory system will create another major new public space on the core’s western end, linking up to the improvements of Paternoster Square – and eventually perhaps combining with the proposed development at London Wall West, and who knows, London Wall itself, to create a spectacularly transformed string of major new public realm. Plans are also afoot for improvements to Fleet Street, to augment the arrival of the new City of London Courts (SEE next item). n SEE ALSO report by Nico Bosetti

FLEET STREET QUARTER | LADY LUCY FRENCH

Placemaking vision with £5bn development pipeline Following last issue’s feature by Lee Higson of Eric Parry Architects on their Salisbury Square development, Lady Lucy French sets out the ten year masterplan for the Fleet Street Quarter

Ludgate Circus AFTER ABOVE: Ludgate Circus BEFORE

Lady Lucy French is CEO at Fleet Street Quarter

An unprecedented development pipeline is set to transform the skyline and buildings across the Fleet Street Quarter’s 43 hectare footprint. Over the next five years over 3m sq ft of Grade A commercial space will be delivered, which will support the 25,000 additional workers set to come into this area of the City by 2028. This next phase of reinvention will bolster the Fleet Street Quarter’s economic contribution to the City of London, boosting and cementing its important role as a major hub for employment. The Fleet Street Quarter BID alongside developers, investors and key stakeholders are spearheading this movement, facilitating change in this part of London by bringing together public and private sectors. For this once-in-a-generation opportunity to be truly seized upon, and to support an expanded workforce, the spaces inbetween these extraordinary schemes need upgrading. To realise its full potential, the Fleet Street Quarter needs to provide a stronger sense of place and movement. There are pre-existing challenges to overcome too. Like many

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post-pandemic global cities, the Fleet Street Quarter needs to adjust how flows of people and spaces for reflection are incorporated into external environs. Currently, vehicular traffic dominates our streets, wayfinding could be improved and there is a distinct lack of green space. Finding solutions to these problems will be critical in drawing workers back into the city. This November, in collaboration with Gensler, NRP and UP Projects, the Fleet Street Quarter BID unveiled a public realm and placemaking vision formulating a strategy that lays out how this can be achieved. The proposals are ambitious and bold, outlining what could be the biggest transformation this part of the City has seen since Bazalgette’s Embankment 150 years ago. Built very much in-line with the City of London’s Draft City Plan 2040, the proposals match the scale and ambition of the development pipeline. Blending vision with pragmatism, this public realm strategy is the next natural step in the development of the Fleet Street Quarter. Currently, this estimated £80m proposal remains purely a vision. The proposals are still subject to further feasibility studies, >>>

Issue 128 January-March 2024

FLEET STREET QUARTER | LADY LUCY FRENCH

RIGHT: Holborn Circus BEFORE

BELOW: Holborn Circus AFTER

>>> consultation and exploration on the sources of funding with the City of London Corporation, Transport for London and stakeholders across the area. The vision provides a 10-year masterplan to transform an urban commercial centre. 34 opportunities to upgrade public realm are identified in the vision, creating a destination of the future by seamlessly unifying the external environs across the Quarter. The proposals aim to build a community founded on place and establish a destination of choice – for both business and leisure. It reinvigorates the Fleet Street Quarter’s urban fabric by building on its strengths; the area is already a significant hub, boasting a strategic central London location, rich history and unrivalled connectivity. This public realm vision amplifies that position, fostering greater economic resilience. The vision sets four site wide ambitions, creating a robust framework towards achieving these aspirations. Proposals aspire to enrich the connections, nurture public realm, enhance biodiversity and drive activity. The overarching mission is to develop an inclusive, sustainable and innovative district. Central to the vision is Fleet Street itself, a Roman thoroughfare and the beating commercial heart of the area. Fleet Street has built a foundation as one of London’s more recognisable thoroughfares and is the identifier of our district, but requires a

Planning in London

series of future-proofing changes. Exemplifying the area, Fleet Street currently prioritises vehicular traffic and affords pedestrians limited time or space. Our proposals seek to reorder this relationship, with a long-term view to limiting vehicular traffic. An improved pedestrian experience would see widened pavements, tree planting and increased seating. Fleet Street would be reimagined by prioritising pedestrians as the primary mover, encouraging dwell time with seating and softening the experience with green space. Changes would allow workers and visitors space to soak up spectacular views of St. Paul’s, whilst increased footfall could drive the retail and hospitality recovery. Across the Fleet Street Quarter, the vision sets goals to reduce service and delivery vehicles by 75%, whilst doubling safe cycling routes. An additional 3,000 sqm of pedestrian space is targeted, to improve journeys through the area for workers and visitors. With Farringdon and the Elizabeth Line on its doorstep, Holborn Circus is another location that is earmarked for radical change but provides a different perspective. In recent years, the junction has seen incremental improvements but there is an opportunity to unify change and create a destination in its own right.

LEFT: Blackfriars BEFORE

BELOW: Blackfriars AFTER

With an eye to meeting biodiversity targets, our proposals envisage a bold transformation creating, ‘Holborn Forest’. Tree planting and art installations would create an urban oasis and a place to unwind in this western side of the City. Holborn Forest would diversify the out-of-office experience, helping create a desirable location for occupiers, residents and visitors. Sustainability is at the core of the vision. Many of the developments in the pipeline target exceptional sustainability credentials – it is essential the external environment responds to this in a complementary manner. Throughout the area, the vision aspires to a 25% tree count increase and 50% increase in ground-floor planting. Together, this would reduce pollution, cut traffic noise and double the plant, insect and bird species in the Fleet Street Quarter. The proposals go deeper than major junctions and streets. The Fleet Street Quarter is a place with a deep past and is characterised by a fascinating medieval street pattern. Ceremonial routes, gateways and thoroughfares are connected by winding lanes, public squares and quaint alleyways. These pockets of our past are hidden gems today. Our vision

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reignites this vibrant network and repurposes rich historical places. A multifaceted urban fabric of courts, churchyards and plazas presents an opportunity to promote social interaction, community engagement and inspire spatial experiences. Gough Square is one example. The forecourt of Dr. Johnson’s House, Gough Square – home of the English dictionary – is a landmark cultural site. The vision seeks to celebrate this with additional seating and greening. Gough Square would be transformed into a cultural hotspot, driving activity and strengthening the Fleet Street Quarter’s cultural offering. Playhouse Yard, Bride Lane and Carter Lane are all pockets also highlighted for change, to improve experiences for workers, visitors and residents. Our vision targets a 50% increase in footfall to historic and cultural destinations that in turn would help grow a weekend economy. There is a wealth of history, culture and intrigue in the Fleet Street Quarter, from Sir Christopher Wren’s St. Bride’s Church to some of our oldest pubs, such as Ye Olde Cheshire Cheese. An enhanced public realm will showcase these cultural assets, highlighting our role as custodians of an unrivalled history and driver

Issue 128 January-March 2024

>>>

FLEET STREET QUARTER | LADY LUCY FRENCH

RIGHT: Fleet Street BEFORE

BELOW: Fleet Street AFTER

>>> for the future. Our vision seeks to put the Fleet Street Quarter back on the map as a destination for both work and play. Enhanced public realm could increase footfall, bring culture to the forefront and create an outstanding environment. If pursued, this vision could transform the Fleet Street Quarter as a destination beyond a 9 to 5 task-based destination, into a vibrant hub with a thriving

Planning in London

night-time economy and weekend visitors. The Fleet Street Quarter is riding on the crest of an exciting new wave. Backed by the invaluable support of the City of London, the BID is bringing together a coalition of the willing, eager to drive change. Together we are curators of an exciting future, pushing to create an inclusive, diverse, innovative and sustainable district. n

LEFT: Holborn Viaduct BEFORE

BELOW: Holborn Viaduct AFTER

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Issue 128 January-March 2024

OPINION: ON THE NEWLY REVISED NPPF | COLIN BROWN & GOVE’S LETTER TO MAYOR KHAN | KATY DAVIS

On the newly revised NPPF The Government appears to have taken the view that there will be some votes in facilitating, rather than blocking, development, suggests Colin Brown I was pleased to have attended the launch of the revised NPPF at the RIBA in London late last month and confess that, contrary to my initial expectations, I was moderately encouraged by the greater certainty that it will provide to developers, house builders and land promoters. Having made that bold assertion, we will have to wait and see how this all plays out on the ground, so I reserve the right to change my mind! Ordinarily, Governments might be expected to sit on the fence and bide their time as they approach a general election. Alternatively, they could seek to become more radical in their position, providing a stark contrast to that of the opposition. However, in my opinion, Michael Gove’s announcement did neither. After almost a year of distinct uncertainty pending the response to the consultation on the NPPF, we finally have some direction, even though some elements of the announcement do appear to be flawed. Counter to expectations, the Government has not completely given into the NIMBYs. In retaining the Standard Method as a starting point in assessing housing numbers, reasserting the 300,000 homes per year target, introducing league tables for LPAs, retaining the housing delivery test, putting two further LPAs into special measures and requiring seven local authorities to come up with an urgent action plan relative to the preparation of new local plans, the Secretary of State has sought to demonstrate that he is committed to growth. He even went as far as to declare himself a YIMBY! The willingness of Government to intervene and propose a new approach to planning in specific locations is encouraging at a time when the sector had become increasingly concerned that entrenched, and slow local decision-making was delaying much-needed development. This new approach is discernible both in the decision to fast-track significant new development in Cambridge through the establishment of a development corporation, and through the increased use of special measures where local delivery has proven to be poor. Having spent the majority of my career as a planning consultant in Cambridge, my experience of planners and politicians at Cambridge City Council and South Cambridgeshire Council has generally been

Planning in London

very positive, but I confess that I can see that a development corporation is likely to be necessary to take on the challenging task of more than doubling the size of the city (especially in view of the significant amount of Green Belt that surrounds it). I do think it will however be important to ensure that the proposed development corporation seeks to work with local leaders and councils in a collaborative and joined-up way. So, as we approach the next general election, it would seem that the divide between the Conservative and Labour parties on housing delivery is perhaps lessening – in fact both have asserted that they are ‘on the side of the builders, not the blockers’, while of course accusing each other of precisely the opposite! Blockages do potentially remain of course, not least the ability of LPAs to ignore their standard method housing calculation on the basis of arguing that to accommodate such levels of growth would be inappropriate to local character. Equally, where an

Colin Brown is Head of Planning & Development at Carter Jonas authority is a predominantly green belt authority, it seems they may be able to duck the need to deliver much-needed housing. This would be highly regrettable and runs the risk of leaving a generation without suitable housing choices. Despite this, the Government appears to have taken the view that there will be some votes in facilitating, rather than blocking, development – making the publication of the new NPPF a more positive development if the proposals can be delivered as intended. nsaying he wanted. n

Katy Davis, partner, Carter Jonas (London) comments on... Michael Gove’s very personal letter of 18 December to Sadiq Kahn sets out some very stark facts. It highlights that housing delivery in London is considerably short of the Mayor’s own London Plan target by approximately 15,000 homes per year, and approximately 63,500 homes lower than was needed last year under the standard method. It also confirmed that fewer than half of the London Boroughs and Development Corporations delivered in excess of 95 per cent of their housing requirement over the last three years. There are conclusions to be drawn from the content of this letter, its tone and its timing. First is the alarming fact that London is significantly under-delivering in terms of housing while other areas are delivering relatively well. London is a driver of the economy – so why has it fallen short in terms of housing delivery? The answer may well be the Mayor’s affordable housing policy – not so much the proportion of such housing required (which is consistent with that of previous Mayors) but the rigidity with which it has been applied. In many circumstances the requirement for 35 per cent plus affordable housing has led to schemes becoming unviable and ironically thwarted development of both affordable and market housing. Additionally, there appears to be concern that under a future Labour Government, a similar policy may be rolled out across the country, with wider implications for delivery. Perhaps the direct nature of this public letter and the stark statistics that it contains are aimed at encouraging the Labour Party to take a more considered approach to the proportion of affordable housing to be provided on future development sites. The urgency with which the Secretary of State has commissioned a panel of experts to produce a report on the London Plan by January is in sharp contrast to the concerns over the delay and uncertainty that has dominated the planning system for the past year and more. It even raises the possibility that Green Belt release will be considered as a means of alleviating the housing crisis in London. Whether or not this specific issue is addressed, the letter is encouraging in that, like the revised NPPF, it points to a renewed determination in the Government’s attitude towards housing delivery.

OPINION: HYBRID WORKING | MARK DIXON

A rebalancing between city suburbs and countryside We are witnessing the rebirth of suburbs, towns and the countryside through hybrid working, says Mark Dixon Today, we’re in the midst of a quite unprecedented societal shift that is radically changing the geography of work. With the advent of technology and the newfound freedom to work remotely, individuals in London are increasingly choosing to work from their local communities. And their employers are responding to that demand. This shift will not only alleviate the congestion and long commutes associated with daily visits to the city centre, but also contribute to the revitalisation of suburbs and dormitory towns. It’s a subject that’s close to my heart. As CEO of IWG plc, the global leader in delivering hybrid work solutions to many of the world’s largest (and smallest) businesses, I’ve had the opportunity to see first-hand the transformative effects of the hybrid revolution. I’ve been talking about the rise of hybrid working for more than two decades now. Liberated by the enabling effects of technology, cutting the ties that have restricted people across the world to a single (and usually city centre-based) workplace and instead empowering them to work in the heart of their local community. As a result, IWG has seen record demand in our co-working and office locations across the suburbs, small towns and countryside in all of the global markets in which we operate. For generations, the city has been at the epicentre of people’s lives. Its pull has emptied communities of their most economically active talent. Commuter-belt towns and parts of cities have become barren during daylight hours, solely serving as dormitories. Perhaps above all, the city-as-workplace has exposed millions of people to the destructive daily commute, brought about in the 19th and 20th centuries by business bosses’ determination to keep their people under their eye – and under their control. However, thanks to the recent conjunction of digitalisation, environmental awareness and pandemic lockdowns, things are changing fast. New research, from IWG’s partnership with Arup, illustrates the sheer pace at which the transformation is happening. London, a city steeped in this tradition, is adapting to this modern work revolution,

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reflecting the broader global trend toward more flexible and location-independent work practices. Our research shows that people are leaving cities. Since 2020, outbound migration from major U.S. cities to smaller communities has increased by a staggering 59 per cent. And now, close to half a million further city-dwellers in the U.S. are projected to leave urban areas for the suburbs, smaller cities and rural regions, most of them in search of larger homes and a better work/life balance – and this is a trend we are witnessing globally. These changes are having an impact on property prices. Between 2020 and 2021, home prices in 20 British cities (excluding London) rose by an average of 8.9 per cent, below the 10.8 per cent growth rate recorded by properties in their surrounding areas during the same period. It’s not just about where people want to have their homes. It’s also about where they want to spend their time and money. UK mobile phone data tells us that footfall in small towns, suburbs and seaside communities has risen by a full 50 per cent since 2019. The impact of that 50 per cent rise in footfall, creating new opportunities for many communities, is clearly reflected our research. It reveals how the resulting higher levels of economic activity in suburbs and small communities are breathing muchneeded financial vitality into areas. And it aligns with the findings of another IWG/Arup research study from 2021, which measured the positive economic impact to be gained from the rebalancing of where work takes place. This found that rural and suburban economies could generate annual increases in local consumer spending of $1.3 billion in the U.S. and £327 million in the UK as a result of the growth of hybrid working. Today, 58 per cent of workers in the UK and 47 per cent of those in the U.S. prefer working in the hybrid model and it’s continuing grow in popularity. In the UK, 88 per cent of workers say that flexible working arrangements are essential for a more fulfilling professional life that delivers improvements in their mental, physical, financial and social health. So it’s unsurprising that 83 per cent of the UK’s HR professionals recognise hybrid working as

Mark Dixon is Founder and CEO of IWG plc

a means of attracting and retaining talent. City authorities can seize the opportunity that hybrid working offers by promoting investment in flexible workspaces near local communities and leveraging their central position to become vibrant hubs for decision-making, social interaction, entertainment, and tourism. Daily commuting to city centre offices has the biggest carbon footprint of any way of working. The Future Earth’s Global Carbon Project reported a 2.4 billion-tonne fall in fossil CO2 emissions during the 2020 lockdowns, with the largest proportion coming from reduced transport emissions, so it is clear changing this can have a considerable impact. Previous Arup and IWG research* has shown that a permanent shift towards hybrid working in the heart of local communities would drive carbon reductions of up to 87 per cent in the U.S. and 70 per cent in the UK. We are clearly witnessing the rebirth of suburbs, towns and the countryside through hybrid working. Domestic migration to smaller cities and rural areas continues to accelerate ahead of pre-pandemic levels. That’s why clear-sighted policymakers, planners and businesses are embracing its benefits in their droves. And it’s essential for all of us and our planet as a whole that these visionaries convince their peers to listen. n *SEE page 75 et seq of the last issue of Planning in London

Issue 128 January-March 2024

OPINION: CRACKING THE HOUSING NUT | RITCHIE CLAPSON

Cracking the housing nut Developer Ritchie Clapson says it’s time to take the politics out of housing My children can’t imagine a world with only three TV channels and no mobile phones or internet. But a country with a severe housing shortage is no stranger to them. If things continue the way they have, it’s an issue that appears likely to outlive them. The reason we’ve had a housing crisis for as long as most people can remember is because it’s impossible to solve without upsetting people. And most politicians are predisposed not to want to upset people for obvious reasons, even though many of them somehow manage very successfully to do quite the opposite. So, when faced with an issue that’s both hugely important and not easy to fix, politicians have a tendency to kick the can down the road. They’re not allowed to ignore the problem and hope it goes away, because that would be irresponsible. But equally they won’t actually change anything meaningful because it upsets voters and gives the Opposition something to beat them up with. Which isn’t something you’d want to do when the next general election is only five years away, tops. So, rather cynically, we end up with a plate spinning exercise where success can be counted as reaching the next election with the plate still intact and everyone thinking that a solution is around the corner and it’s all still work-in-progress. Cracking the housing nut Let’s consider the scale of the problem. Both main political parties agree that we need to be building 300,000 new homes each year. And if you say it quickly, that number can wash over you without really resonating. But if I told you that there are a total of 275,000 homes in Oxfordshire, then you’ll start to appreciate that building a small county’s worth of homes each year is no small task. And you may

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well also start to wonder where exactly these new counties are going to fit. After all, there’s not a lot of empty space on the map, and you can’t just plonk 300,000 new homes in the middle of nowhere and expect people to want to live there. Even if you created brand new towns, they still need to go somewhere and be connected to everywhere else. Back in the day we used to have a new town building programme. The New Towns Act 1946 reflected the need for post-war reconstruction but also acknowledged that simply adding to London’s sprawl wasn’t the answer. Instead, we saw a total of 27 new towns emerge, including the likes of Stevenage, Crawley, Bracknell, Hemel Hempstead, Peterlee, and Runcorn. Milton Keynes was one of the later creations and went on to become the largest with some 117,000 households today. England’s biggest new town since Milton Keynes is Northstowe, near Cambridge. Here around 1,200 homes have been built out of a planned 10,000, although some six years after the first house was built, it still has no shop, pub, doctor’s surgery, or café. It does have a post box however, which one assumes will be the hub of all social activity until a café eventually turns up. Despite its growing pains, Northstowe serves to underline the scale of the challenge. The village/town is on a 20-year journey to reach its 10,000th home, yet we need the equivalent of 30 Northstowes to be built every year if we’re to meet the housing target. And that’s no mean feat, even if you had lots of places to put them all; places where nobody minded you building a new town. The simple truth is that everyone would quite like the housing crisis to be solved, but no one wants any houses built anywhere near them. We are all NIMBYs at heart, and as many a local MP has found out, people get well and truly exercised if you try and build pretty much anything, anywhere.It means we simply end up in another Groundhog Day. Once again, we have a load of preelection promises being made by politicians that offer a glimmer of hope that, for some reason, their party will be able to do what all their predecessors have failed to do. And as long as their words don’t become actions, they’re on pretty safe ground. It’s

Ritchie Clapson is a cofounder of property development training company propertyCEO

only when implementation comes around that the public starts getting twitchy, which is when the whole sorry cycle repeats itself again. The other big issue with the housing crisis is that you can’t solve it within a single parliamentary term. Five years simply isn’t long enough; it will have to be a 10-20 year plan, minimum.

Suggesting a solution So, my suggestion for knotty problems such as the housing crisis is that we take them out of the political agenda and establish a cross-party group that will be responsible for recommending a solution and then implementing it. In this way, the housing agenda is removed from the short-term party politicking that sees nothing change, and instead becomes a long-term solution that all parties have signed up to, with an agreement that the implementation does not get derailed, irrespective of any change of government. Is it the perfect solution? No. Will it be easy to get everyone on board and to work out the terms of engagement. Same answer. Will some members of the public be completely outraged with whatever is proposed? Ditto. But then if solving the housing crisis was a walk in the park, we’d have done it by now. Ultimately, we need to find a solution that doesn’t rely on a vague hope that the next bunch of ministers will somehow magic up a palatable solution, because frankly that’s cloud cuckoo land. As luck would have it, there are some bright people working in Westminster. Let’s task the best of them with coming up with the optimum solution with the shackles off and see where it takes us. It certainly can’t be any less productive than what we’ve seen up to now, or what we’re likely to see tomorrow. n

OPINION: AFFORDABLE HOUSING | ANDREW GOLLAND

Viability, planning and a potential Labour government Andrew Golland thinks that for things to be turned around for the provision of affordable housing will depend on the market Although we are potentially several months away from a General Election, it now looks likely that we may have a change of government next year. The current government looks to have run out of steam and the latest cabinet appointments suggest that the Tories have perhaps reached their ‘Sam Allardyce’ moment, from which only a narrow escape from relegation is the best to be hoped for. Indeed nothing perhaps may save them from disassociation with their parliaments of political and economic malaise. Certainly within the Planning and Housing fraternity, there is enough dissatisfaction and frustration with a property market of falling prices and rising costs, of pulled local plans, of scrapped housing targets and over 5 years of trying to drive the square peg of the Infrastructure Levy through the round hole of Section 106, to warrant a demand for a plebiscite which could move things in a more positive way. But, if there is a change, what might be the implications for Planning, Housing and Viability? Here I consider some possible impacts based on what the Labour Party were saying at their October Conference in Liverpool. A continuation of the Levelling Up agenda? Will Labour pick up the baton of Levelling Up as a policy? Here it is highly unlikely that it will be announced as a principle, defunct, but any sage analysis will show that development in large areas of lower value markets in the Midlands and the North is now unviable as a result of a combination of falling house prices, rising construction and finance costs and historic land values. This situation cannot be rescued by subsidy. The Tories’ levels of investment here have been pitiful and London remains the outsized but now spluttering engine of the economy. The macroeconomy was always too weak and the government never serious about re-balancing in the way that for example, German governments were about bringing the former DDR back into the wider German economy. So Levelling Up may remain in name only (or perhaps under another cosmetic guise). >> A reversal on housing targets? If an incoming government listen to the industry

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then they will re-instate housing targets and firm up requirements on 5 year land supply (and if they have any sense extend this to say 10 years). This does mean more forward planning and Labour have stated that they ‘will put the local plan front and centre in the planning system and create a genuinely plan- led system.’ Therein lies a problem in that a ‘genuinely plan led system’ will require significant resources to test, not least viability. The current best practice assumes that local authorities will set default values for all key variables and it is assumed that this effectively ‘front loads’ viability into plans. But the problem was always evident: that sites specific economics never marry up with these assumptions. What Labour should do, if it is to lead by Plans is to make policy more fine-grain. That is to say, all plans should reflect variations in viability and in particular Affordable Housing targets. Far too many are single and general and which lead to situations where schemes in weaker sub markets are loaded with completely unrealistic targets. A Plan-Led system should envelop the land supply situation and should ensure that supply is fluid enough to prevent situations where land deals are done at levels which don’t discount for community contributions. Whether the planning process can do this in the face of local objections remains to be seen. Much will depend on how strongly Labour perform in the rural constituencies. A Labour minority government, propped up by Lib Dems who have won seats in these areas may stymie this possibility. Local planning departments – more power to their elbows? The shadow chancellor, Rachel Reeves, has announced a Labour government would increase planning capacity – ensuring every local authority has ‘at least one full time, experienced planning officer and expanding the government’s strategic planning capacity for housing and infrastructure – funded by increasing stamp duty on overseas buyers.’ All help is welcome here, but really whether having ‘at least one’ experienced planner is enough is highly debateable. In viability terms, some local

Dr Andrew Golland specialises in the field of housing, planning and regeneration

authorities already have Section 106 and Viability ‘supremos’ but these are few and far between. The bigger question is whether additional resources will allow local authorities to take a much more proactive role in sorting out negotiations. There is no reason why this can’t happen, although this potential may be stymied by speeding up the appeals process (also promised!) where local planning authority officers fear taking on greater responsibility for viability assessment because they may easily get bounced into appeal. The more practical challenge here will be to put local authorities into a sound financial position; six have already reported bankruptcy and there are apparently 30 odd more who say they are headed towards severe financial trouble in the next few months. Against this background the potential of a Labour administration to expand planning resources may prove too challenging.

More Affordable Housing through the planning system? The Section 106 process has proven a remarkable success, delivering almost half the Affordable homes developed each year. Labour, whilst it appears almost evangelical in its support for Affordable Housing (it really doesn’t have a choice with the levels of need) have said very little about how they will deliver it. There is nothing yet on whether they will follow the Tories with their attempt to scrap Section 106. Probably they will not want to rock the boat. After all a vast number of authorities have not adopted CIL, and this is largely on the basis that it’s too inflexible when it comes to negotiating viability. So Labour will probably scotch the latest government bill to introduce an IL (Infrastructure Levy encompassing >>>

Issue 128 January-March 2024

OPINION: AFFORDABLE HOUSING | ANDREW GOLLAND

>>> Affordable Housing), as feedback through consultation already reveals much opposition. We will see. It is to be hoped that Section 106 is maintained not just because it is the best way of mitigating the externalities from new development, but because it is an excellent vehicle for negotiating the best outcomes for local communities. As ever, new governments make great exhortations to build out ‘stalled sites’ and Labour, should they be elected, are going to help solve the problem of viability via money through Homes England. Good luck with that. The sums that are required are mouth wateringly huge. A Labour government will need to do considerably better than the typical chicken feed £2 billion odd that the Tories have tossed in this direction during their tenure. Massive funding is needed and ultimately it is better use of the Section 106 provisions that will take up the slack. The return of the ‘experts’? It was Michael Gove, currently Minister for Levelling Up, Housing and Communities, who famously said the country had had enough of ‘experts’. One might argue that this is now blatant in the mess that envelopes the housing and planning system. The question is then whether a Labour government would want to re-engage with the industry and if so, with whom. The need for new evidence on how the housing market and planning systems are working is clear. There is an acute lack of supply, a huge affordability problem and growing regional economic inequality. A key question that was addressed in the much lauded Barker Report (2004) was whether additional supply would help in reducing house prices to any extent. The report concluded that, in essence it wouldn’t. And in more detail, that a huge increase in building would be required even to make a minor ‘dent’ in house prices and affordability. An updated report (which is now likely to show that the huge requirement becomes a gigantically huge one – to help affordability) would be no surprise but would help an incoming government make the case to a sceptical shire electorate that additional house building would have little downward impact on their asset values. Likewise ‘big picture’ evidence and research look-

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Success in delivering Affordable Housing looks likely to prove the key issue against which an incoming Labour government will be judged. ing at housing and planning systems abroad would now not go amiss. We used to look at European housing and planning systems for indications as to how to solve our own problems. These have tended to show the benefits of local authority led development (Netherlands), land assembly solutions (France and Germany) and annual housing wealth taxes (Denmark). Invoking any of this means big change, but an incoming government could be looking at these changes whilst trying to get a few ‘quick wins’ by leaning on planning authorities to get housing consents approved. Whatever befalls, the case is clear for greater involvement of the industry, the professions, and importantly, the university sector. The latter is charged with impartiality and there is great expertise which should be drawn upon in property, land, planning and surveying schools. The direction of travel here under a potential Labour government is encouraging. They are committed at this stage to greater transparency of information on land ownership which, it is hoped, for the benefit of viability discussions, will be accompanied by some form of systemized data on land values. In practice much of this is longer term for any incoming government. The short term objectives are obvious. Labour have stated: ‘upon entering office, the deputy prime minister and secretary of state for levelling up, housing and communities, Angela Rayner, will publish a written ministerial statement and write to all chief planning officers to instruct local planning authorities to approve planning applications in areas which do not have a local plan and fail other key policy tests, such as the housing delivery test.’ You heard it here first.

A Labour government – implications for viability A proper, fully funded forward planning system will be beneficial to the challenge of housing as it will strengthen knowledge and expertise in the critical

task of viability assessment. That said, the process of front loading viability into a plan needs to be practical, and focus mainly on sub markets and settlements rather than setting parameters for individual sites. There is a lot that can be done without pretending that LPAs can cover every site at plan making stage. Speeding up the planning process by accelerating the presumption to development as a principle, is a good idea, but the question is whether that comes at the expense of infrastructure. Viability assessment will probably prove the arbiter of this dilemma. Success in delivering Affordable Housing looks likely to prove the key issue against which an incoming Labour government will be judged. Here again, panic measures to increase housing delivery generally may mitigate against the delivery of Affordable homes. This means Labour need to employ policy carefully, and, if it is genuinely interested in Affordable Housing delivery, recognise that thresholds need to come down in stronger market areas, whilst going up in weaker areas. Moreover LPAs need much better evidence bases to exclude certain types of small developments (e.g. replacement dwellings and some conversions) from the liability to Affordable Housing. Again, this is a viability task. More comprehensive planning information and market led data will help enormously with delivery. There needs to be resources behind this and where appropriate, help and training. Ultimately whether an incoming administration can turn things around in terms of housing delivery will depend on the market. Currently viability assessments seem to be focused on review mechanisms, challenging existing Section 106 for unviable developments and on ‘value engineering’ marginal schemes. To get to a position where the focus is mainly on new development, and particularly large new development with say a 2 to 3 year timeframe, will require a big change in the current relationship between sales values and costs. This in turn will depend on the new government being able to instil confidence in the market, probably initially by repairing relations with Europe, by rebuilding our failing institutions and by generally gaining the trust of the electorate to operate in the interests of business and the state. n

OPINION: TIME FOR SMES IN HOUSE BUILDING | MARC VLESSING

Time for SMEs in house building With volume house builders slashing output now is the time for the government to think the unthinkable in its support for the SME sector, says Marc Vlessing

Marc Vlessing is Chief Executive of Pocket Living

Addiscombe Grove CR0 in East Croydon has been designed by award-winning architects Metropolitan Workshop and offers one bedroom discounted Pocket homes minutes away from East Croydon Station.

Competition and choice are two words you would expect to be intrinsically linked to the ideology of any Conservative government. Yet these are two words that you very rarely hear mentioned by ministers, especially when it comes to housing and planning. This is hardly surprising when for many people no effective choice exists, and competition is negligible in their search for a place to live and ultimately buy. For many people it literally is take what you are offered, a 21st Century version of Henry Ford’s you can have any colour you like as long as it’s black. Much of this is driven by an effective lack of competition and choice in who actually builds our new homes. Arguably this is mostly due to England’s costly and overcomplicated planning system, as well as limited choice in terms of future residential sites coming forward. But also, as a consequence of the rationalisation, or decimation, of the housebuilding sector over the last 20 years. Whereas once SMEs, particularly on a local and regional level, delivered a significant number of homes per year, the consolidation of supply around a number of larger volume builders has resulted in

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fewer homes being built by even fewer builders. In many respects it is something of a miracle that England has managed to deliver the homes it actually has in recent years. In fact, aside from during the pandemic the recent decline in residential construction work has been the steepest since the spring of 2009, despite the fact that the UK is gripped by an ever-worsening housing shortage. This consolidation of the market supply is clearly enough to worry ministers and likely initiated the recent CMA review into the sector. The planning system needs reform and resource is beyond question, but fundamentally we need more builders to build. Yet this is unlikely to happen in a market where starts are slumping faster than the share price of some of the volume builders. Challenge the housing minister and I’m sure that the enviable response will be “yes, but what can be done”. Actually, plenty if only government acted with the same urgency as is now apparent with the energy sector and wind farms and did more to support SME builders and would-be homeowners. In all of this, confidence to build is key and at the moment many of the larger house builders lack that due to a

challenging sales environment and the cost and complexity of bringing forward large sites. Herein lies the opportunity for the untapped force that is the SME sector, currently on the verge of extinction with just 2,500 currently operational across England, over 80% fewer than in 1988. That support can take many forms, with planning reform and simplification being top of the list. On this as part of a broader coalition we are calling on the government to urgently issue a Written Ministerial Statement to implement a small sites proposal with the potential to unlock an extra 1.6 million new homes as part of the update of the NPPF. An alternative would be to look at the potential for local authorities to acquire unsold or future phases of new housing schemes and offer sales certainty to the sector to get on and build. Given the scale of the affordable housing crisis and the need to provide key worker accommodation this could have the added benefit of increasing the number of affordable homes through acquisition in the short-term. To be clear this is not a call for the government to underwrite the sales pipeline of every developer, but to have the flexibility to be able to support the industry on a case-by-case and site-by-site basis to get these new homes built. With the output of the major players dropping now is the time for the long overdue renaissance of the SME sector. If this government fails to seize the opportunity, then perhaps the next one will. To steal a phrase from a then potential incoming Labour Prime Minister now is the time to “think the unthinkable”. Only this time please don’t sack them as a minister if they do! n First published in Property Week with kind consent

Issue 128 January-March 2024

OPINION: LONDON PLAN AND HOUSE BUILDING | SIMON RICKETTS

Does the London Plan stifle house building? Simon Ricketts looks at Michael Gove’s decision to appoint a panel of expert advisers to consider and report this month on aspects of the London Plan The next London Mayoral election will be held on 2 May 2024. As of 9 November 2023 Sadiq Khan held a 25 point lead over conservative candidate Susan Hall, according to a YouGov poll. Anything could of course happen between now and 2 May though, the greatest risk for Khan possibly being if Jeremy Corbyn stands as an independent candidate and splits the labour vote. The deadline for candidate nominations is 27 March so I suspect we will see increasing levels of speculation in the meantime… To his left, Mr Corbyn. To his right, Mr Gove. As part of the flurry of DLUHC announcements on 19 December 2023 the Secretary of State wrote to Mr Khan. The letter included the following passage: “Due to the significant shortfall in housing supply and under delivery of housing in our capital, I have concluded that it may be necessary to take further action now, as a matter of urgency, to make sure London is delivering the homes our capital needs. With this in mind, I have asked Christopher Katkowski KC to lead a panel of expert advisers comprising Cllr James Jamieson, Paul Monaghan, and Dr Wei Yang, to consider the aspects of your London Plan which could be preventing thousands of homes being brought forward, with a particular focus on brownfield sites in the heart of our capital. I have asked them to produce their report by January and will make sure that it is shared with you. If you cannot do what is needed to deliver the homes that London needs, I will.” The terms of reference given to the advisors were published on 22 December 2023. Lichfields have been appointed along with the advisors previously announced. “The expert advisers will assess whether there are specific changes to London Plan policies that could facilitate urban brownfield regeneration in London for housing delivery in an appropriate manner and, if necessary, recommend changes to the London Plan accordingly. The output of the review will be a short report, delivered by 15 January 2024, to the Secretary of State.” The objectives of the work are as follows: “To consider and, if appropriate, make recommen-

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dations for specific changes to the London Plan. The Secretary of State will share the recommendations with the Mayor to consider their implementation. To work with Lichfields consultants to ensure that there is an evidence base which supports the recommendations of the expert advisers. To complete a report on how, specifically, the London Plan could be improved to facilitate the delivery of new homes on brownfield sites.” 15 January! It will be interesting to see what emerges. I assume that aside from the implications of the detailed and prescriptive approach taken by the London Plan – a document which is instead meant to operate only at a strategic level – one potential area for investigation will be the extent to which the Mayor’s rigid approach to minimum levels of affordable housing, even in the face of agreed unviability, and/or his requirements as to review mechanisms which can cause difficulties with fun-

Gove to Khan: “If you cannot do what is needed to deliver the homes that London needs, I will.” ders, is holding back delivery (although of course the Mayor’s response is always to point to the level of need for social housing). Will another be the Mayor’s resistance to development in the green belt? But this would only make sense in the context of Mr Gove’s letter if the focus is on previously developed land in the green belt – and even this would uncomfortably with the Government’s 19 December 2023 revision to the NPPF, absolving authorities of the need to review green belt boundaries when preparing local plans… Are there possibly any clues in two recent Secretary of State decisions?

Hounslow On 11 December 2023 the Secretary of State overturned inspector Jennifer Vyse’s recommendation and granted planning permission in relation to called-in applications for mixed use development at Homebase and Tesco Osterley, Syon Lane, Hounslow. His approach to the planning balance

Simon Ricketts is a partner with Town Legal LLP From Simon’s blog at simonicity.com/author/simonicity/ Personal views, et cetera

and overall conclusion in his decision letter is as follows: “64. For the reasons given above, the Secretary of State considers that the application is not in accordance with LonP policies D9 and HC1 and LP policies CC3 and CC4 of the development plan, and is not in accordance with the development plan overall. He has gone on to consider whether there are material considerations which indicate that the proposal should be determined other than in line with the development plan. 65. Weighing in favour of the proposal is the regeneration of under-utilised brownfield land which carries substantial weight. Also weighing in favour is the delivery of up to 2,150 homes which carries substantial weight, and the delivery of 750 affordable homes designed to meet the current housing need profile in Hounslow, which each carry substantial weight. Economic benefits carry significant weight whilst the provision of open space and significant biodiversity net gain both carry moderate weight. Highway and transport improvements carry limited to moderate weight and the reprovision of an existing Tesco store and the provision of community space each carry limited weight. 66. Weighing against the proposal is less than substantial harm to a number of designated heritage assets which carries great weight. Moderate harm to the character and appearance of the area in relation to the Homebase scheme carries moderate weight. Heritage harm caused by the total loss of a non-designated heritage asset (the Homebase store) carries limited weight and the Secretary of State has considered paragraph 203 of the Framework in coming to this decision. 67. In line with the heritage balance set out at paragraph 202 of the Framework, the Secretary of State has considered whether the identified less than

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substantial harm to the significance of each designated heritage asset is outweighed by the public benefits of the proposal. Taking into the account the public benefits of the proposal as identified in this decision letter, the Secretary of State agrees with the Inspector at IR15.11 that the public benefits of the appeal scheme are more than sufficient to outweigh the identified harm, including cumulative harm, to the significance of the designated heritage assets. He considers that the balancing exercise under paragraph 202 of the Framework is therefore favourable to the proposal. 68. Overall, in applying s.38(6) of the PCPA 2004, the Secretary of State considers that despite the conflict with the development plan, the material considerations in this case indicate that permission should be granted. 69. The Secretary of State therefore concludes that planning permission should be granted.” Note the weight placed on delivery of homes, including affordable homes, on under-utilised brown-

field land, together with economic benefits, versus heritage harm.

Barnet On 4 December 2023 the Secretary of State agreed with his inspector’s recommendation and granted planning permission for the demolition of existing buildings and the comprehensive phased redevelopment of the site for a mix of uses including up to 1,049 residential units and up to 1,200 square metres of flexible commercial and community floorspace in buildings ranging from 3 to 18 storeys along with car and cycle parking, landscaping and associated works. His decision letter demonstrates a similar balancing exercise, in the additional context of Barnet Council not having a five year supply of housing land: “35. Weighing in favour of the proposal is the delivery of market and affordable housing which each carry significant weight; the reduction in traffic, provision of open space, biodiversity improvements,

regeneration benefits and employment provisions which each carry moderate weight; and improvement in healthcare facilities which carries minimal weight. 36. Weighing against the proposal is the less than substantial harm to the designated heritage asset which carries great weight. 37. In line with the heritage balance set out at paragraph 202 of the Framework, the Secretary of State has considered whether the identified less than substantial harm to the significance of the designated heritage asset is outweighed by the public benefits of the proposal. Taking into the account the public benefits of the proposal as identified in this decision letter, overall, the Secretary of State agrees with the Inspector at IR238 that the public benefits outweigh the identified less than substantial harm to the significance of the designated heritage asset, and that the proposal would secure the optimum viable use of the site (IR235). He therefore considers that the balancing exercise under paragraph 202 of the Framework is favourable to the proposal.”

Housing being delivered in London: Related Argent’s Brent Cross Town

The time it all takes Whatever we think of the Secretary of State’s reasoning in granting these permissions, let’s not give him credit for thereby speeding up the development process. These were both applications which had been resolved to be approved by Hounslow and Barnet respectively in 2021! Petty point scoring Finally, how about this for petty point scoring, in relation to the continuing political pawn which is the Mayor’s extended ULEZ scheme? The Secretary of State would like the Mayor to arrange for vehicles that are the subject of his scrappage scheme to be provided to Ukraine to help with its war effort. The Mayor’s position is that this is not within his legal powers. This is Mr Gove’s latest letter dated 21 December 2023 to the Mayor of London. I have no idea what the right answer is on this specific issue but in a year where there are too many real battle grounds around the globe, perhaps let’s try to avoid unnecessary domestic political battlegrounds? Even in an election year? n >>>

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Issue 128 January-March 2024

OPINION: CARTER JONAS OUTLOOK FOR 2024

Outlook for 2024 Partners and colleagues in Carter Jonas brave their predictions for the coming year

Matt Lee, Partner, Carter Jonas

Life sciences The outlook for the UK life science sector in 2024 is optimistic, with strong employment and venture capital investment growth prospects. Real estate in this sector is set to become more dynamic, with increased demand for lab space and energy-efficient facilities. There remains a significant opportunity for UK institutional investors to engage more deeply with this sector to close the gap with the levels of investment seen in other markets. We expect the life sciences sector to maintain its growth trajectory, with employment growing at a faster rate than in the broader economy. The ‘Golden Triangle’ (Cambridge, London, and Oxford) will continue to provide a significant draw, yet other cities are also gaining traction in attracting investment, including Manchester, Edinburgh, Bristol and Birmingham. The UK's ambition to be a ‘Science Superpower’ by 2030, underpinned by government R&D funding, the recent re-joining of the Horizon programme, and a possible regulatory review postBrexit, will likely bolster the sector's growth further. A near term shortage in new development coming forward in key markets means that demand for lab space continues to outstrip supply, particularly in established hubs, which will likely continue into 2024, driving laboratory rents up. Labs are intensive energy users, and there is increasing demand for energy-efficient space, driven by rising energy costs and the push towards net-zero carbon goals. This may result in an amplified focus on developing energy-efficient real estate for life sciences. Recent supply chain challenges have underscored the UK's over-reliance on overseas markets for drug manufacturing. With only 25 per cent of medicines produced domestically, there is potential for growth

Planning in London

in onshoring, reshoring, and nearshoring operations. The UK's highly skilled workforce positions it to attract advanced therapies manufacturing. The availability of risk capital in the UK for investment in life science companies reflects a mixed landscape as we look towards 2024. Despite a recordbreaking year in 2021 for funding into life sciences, 2022 and 2023 saw a decrease in funding. This decline was attributed to economic uncertainties that affected costs, supply chains, and the ability to accurately forecast cash flows. However, this did not signify a withdrawal of interest but rather a strategic pause, with pent-up capital expected to re-enter the market. The UK sector's growth, backed by government support and record levels of equity finance, indicates a promising future, yet it underlines the potential for UK institutional investors to increase their engagement to match the sector's growth and the global investment landscape. While there is a notable pool of risk capital available, the uptake by UK institutions has been conservative compared to other markets. We view the recent slowdown in funding as a temporary recalibration rather than a withdrawal, setting the stage for renewed activity as market conditions stabilise.

ensure that developers leave the environment in a better state than they found it by creating or enhancing habitats for wildlife. It comes into effect from January 2024 (or April 2024 for small sites) having been delayed from Autumn 2023. We expect BNG to have a significant impact on the development process in the UK, with increased focus on green infrastructure and more innovative design solutions. It will also transform the relationship between developers and landowners, who will enter BNG agreements for mutual benefit. Meanwhile, Local Planning Authorities (LPAs) have been preparing their own policies and guiding framework on BNG. Many have introduced BNG requirements prior to the implementation date, and some are exploring higher percentages of net gain than the 10 per cent prescribed. We are increasingly seeing LPAs deviating from the national position, either in the percentage net gain required or in their guidance for delivery. We are also seeing more LPAs adopting measures to channel investment towards local sites to accelerate the local market. We expect that the year ahead will bring even more creative and resourceful local solutions.

Mark Hall-Digweed, Partner and Head of Infrastructure, Carter David Alborough, Consultant, Carter Jonas

Biodiversity net gain What will the introduction of mandatory biodiversity net gain in January 2024 mean for developers and landowners? One of the key changes for the planning system in 2024 is the introduction of Biodiversity Net Gain. This requires most new developments in England to be able to demonstrate and deliver a mandatory 10 per cent net gain in biodiversity either on the development site or by purchasing BNG units offsite from third parties in this newly created market. It will

Jonas

Infrastructure investment In our outlook for 2023, we anticipated a period of continuity, with the government having just committed to delivering key rail schemes including HS2 phase 2 to Manchester. The cancellation of the Manchester HS2 leg has been damaging for the UK’s global image and for long-term strategic infrastructure delivery. On the positive side, the funding has been reallocated to ‘Network North’, a vision to “deliver faster and more reliable journeys between, and within, the cities and towns of the North and Midlands”. Improving transport connectivity between key eco-

nomic centres outside of London and the South East is indeed a vital tool to ‘level up’ the UK. Whilst we welcome the ‘Network North’ vision, there is little confirmed detail on the specific schemes that will be delivered, or timescales. This will need to be a priority for 2024. It is also very positive that proposals for Northern Powerhouse Rail (NPR) are continuing to be developed. The aim of this much-needed scheme is to transform connectivity between Liverpool, Manchester, Leeds, York, Newcastle, Sheffield and Hull, incorporating both new line and upgrades. The Transpennine Route Upgrade is now being delivered as phase one of NPR, electrifying and upgrading the line between Manchester and York. Carter Jonas is currently instructed on this major infrastructure scheme, delivering land assembly, consenting, and land referencing services. The establishment of Great British Railways (a new public body to own, run and plan the rail network) was included in November’s King’s Speech, but the necessary legislation for reform is unlikely to be passed before the general election, effectively ‘kicking the can down the road’ again. Although transport schemes tend to grab the headlines, other infrastructure projects are also vital and are arguably increasing in importance. Upgrading the capacity of the National Grid is becoming a critical issue, given the sheer amount of additional power that will be needed over the next decade to electrify building heating systems and road transport, plus cope with population growth, housing development, rising data centre demand, and more. The National Grid projects that demand for electricity will increase by 50 per cent in the period to 2035. At the same time, electricity generation will need to be decarbonised if the UK is to meet its ambitious climate targets. The National Grid and the Distribution Network Operators are planning significant investment and we should see this coming through from mid-2024. Similarly, the water industry faces the challenges of catering for additional demand, planning for the impacts of climate change, and reducing water and sewage leaks. 2024 will see a further gearing up of investment to deal with these challenges. The year ahead cannot be ‘more of the same’.

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Significant investment will be required to deliver the infrastructure the UK needs, creating opportunities across the infrastructure spectrum. Indeed, residential and commercial development in certain key locations is already being held back by the challenges of obtaining sufficient power and water. But infrastructure investment is a long-term proposition, not suited to political cycles of five years (at most), and current initiatives will be either underpinned or undermined by the outcome of the General Election. We hope 2024 will be a year for bold decisions.

Andy Smith, Partner, Carter Jonas

per cent across the locations we monitor, and therefore have the greatest potential for uplift. Valuing open storage sites is challenging, as relatively few property professionals have sector-specific experience and there remains a lack of data, a situation we expect to improve over the next year. As the market grows in scale and increasingly forms part of institutional portfolios, it will become more important to value open storage as a use in its own right, taking into account the quality of sites. With some commercial developments on hold in 2024, more consideration may be given to open storage as an interim use, although the capital expenditure required to create a high-quality site normally requires several years payback. Given the favourable shifts in open storage rents compared with other sectors, 2024 could see more investors re-evaluate how this use could work in higher-value locations over the longer term.

Open storage Occupier demand for open storage sites has risen exponentially in recent years. Our monitoring shows an increase in enquiries from just 300 acres in 2019 to more than 2,000 acres in 2022. This figure is likely to have exceeded 2,500 acres in 2023. Demand will continue to be strong in 2024, focussed on high-quality class 1 sites, with features such as excellent vehicle access, concrete surfacing, and high security levels. This will be buoyed by corporates requiring more sites to charge their expanding electric van and car fleets, as well as ongoing demand from logistics and parcels operators. With structural undersupply in urban areas and double-digit rental growth over the last two years, investor appetite to enter the open storage sector will remain strong in 2024. However, some who made significant purchases in 2023 may pause activity while they assess their portfolios and develop strategies to increase rental income. Open storage portfolios have been trading at a premium, and this trend is poised to continue in 2024. We expect further rental growth in 2024, albeit at a slower pace than the last two years. Prime rental levels in the regional markets remain well below those in London and the South East, by typically 40

Colin Brown, Partner and Head of Planning & Development, Carter Jonas

Planning for housing delivery With 2024 almost certain to be an election year, what policies for housing delivery are we likely to see discussed and implemented? Delivery of new homes The delivery of new housing has stalled. The government’s target to build 300,000 homes per annum in England was downgraded to ‘advisory’ status in 2022, and whilst it is still the stated aim to achieve this figure, no timescale is attached. Meanwhile, fewer than 200,000 net additional homes per annum were actually delivered over the last decade, meaning that year on year the deficit in delivery is growing. It is likely that both main political parties will maintain a focus on achieving the 300,000 per annum figure in their manifestos. Indeed, Labour >>>

Issue 128 January-March 2024

OPINION: CARTER JONAS OUTLOOK FOR 2024

>>> have confirmed they will reinstate this figure as a mandatory target, in addition to updating planning laws to give local authorities a greater say in delivery. The big debate looks likely to be around land value capture (a mechanism by which a greater proportion of the uplift in land value arising from planning consent can be captured for public benefit such as infrastructure and affordable housing). Labour leader Sir Kier Starmer has referenced an ambition to build 1.5 million homes through a new generation of new towns. This is a highly ambitious strategy, and the mere fact that is it being advocated acknowledges the radical step-change that will be required to raise housing delivery to a rate anywhere near the target. Under the Labour proposals, the development of new towns would be achieved through development corporations with CPO powers to capture the land value, so that the infrastructure has a better chance of being funded. There is some logic to this approach. It is likely to prove divisive for landowners, but we foresee that there will end up being a degree of compromise involving some sharing of the uplift in value. Indeed, if we are going to develop at scale, then some form of land value capture is probably almost inevitable.

Although the previous target of building 60 per cent of all new homes on brownfield land has been removed, the ambition lives on in the NPPF (2023), and it has undoubtedly slowed the rate of housing delivery. Brownfield housing development is not always viable and policy needs to reflect this reality. It is positive that Labour has recognised the potential of the low-quality, mostly brownfield, ‘grey belt’ that is unnecessarily protected through green belt allocation. In any case, there is nowhere near sufficient brownfield land to meet the 300,000 figure, certainly across multiple years, and meaningful greenfield development will be integral to increasing the rate of delivery.

The green belt The debate around building major new settlements also raises the question of the green belt.

Biodiversity net gain One of the key changes for the planning system in 2024 is the introduction of Biodiversity Net

House price affordability Demand for homes will continue to be impacted by a fall in mortgage availability and affordability, exacerbated by the ending of the Help To Buy scheme for first-time buyers, with housebuilders also feeling the ongoing effects of labour shortages and elevated build cost inflation. Accelerating the rate of housebuilding will not be easy for whoever wins the election, and 2024 looks set to be a challenging year for housebuilders against the continuing subdued economic outlook.

Gain. This requires most new developments in England to be able to demonstrate and deliver a mandatory 10 per cent net gain in biodiversity either on the development site or by purchasing BNG units offsite from third parties in this newly created market. It will ensure that developers leave the environment in a better state than they found it by creating or enhancing habitats for wildlife. It comes into effect from January 2024 (or April 2024 for small sites) having been delayed from Autumn 2023. We expect BNG to have a significant impact on the development process in the UK, with increased focus on green infrastructure and more innovative design solutions. It will also transform the relationship between developers and landowners, who will enter BNG agreements for mutual benefit. Meanwhile, Local Planning Authorities (LPAs) have been preparing their own policies and guiding framework on BNG. Many have introduced BNG requirements prior to the implementation date, and some are exploring higher percentages of net gain than the 10 per cent prescribed. We are increasingly seeing LPAs deviating from the national position, either in the percentage net gain required or in their guidance for delivery. We are also seeing more LPAs adopting measures to channel investment towards local sites to accelerate the local market. We expect that the year ahead will bring even more creative and resourceful local solutions. n

The next meeting of the London Planning & Development Forum will be the annual planning update with the Cambridge University Land Society and the ACA kindly hosted by Dentons at Fleet Place EC4 on the afternoon of Tuesday 19th March To attend please book at https://www.culandsoc.com/events/annual-planning-update-3/

Planning in London

BRIEFING: CITY’S NEW TRANSPORT STRATEGY | NICO BOSETTI

The City of London’s new transport strategy The City Architecture Forum had early sight of the City’s upcoming Transport Strategy, presented by Bruce McVean, Assistant Director for Policy and Projects at the City of London Corporation. He and Roy McGowan, Managing Director at Momentum Transport Consultancy, took questions from the audience at a City Architecture Forum event last month. Nico Bosetti reports. Why the City needs a new transport strategy The City’s previous transport strategy was published in 2019 – not long ago in policy terms, but just months before lockdowns boosted remote working. The 2019 document offered a radical rethinking of the City’s streets to accommodate significant growth in the number of people travelling. While the pandemic has taken some of this pressure off, the City’s streets still work very hard to accommodate demand, especially at mid-week peak times. And the City expects significant growth in years to come: new office space being built or planned will bring tens of thousands of new workers and visitors. The transport strategy needs to help the City get ready for growth and shape it. An active travel mini revolution There have been some big changes in how people move around the City lately. The number of entries and exits at stations indicates that footfall on City streets on Tuesdays, Wednesdays and Thursdays is around 75% to 80% of pre-pandemic levels. Mondays and Fridays are still noticeably quieter. Meanwhile the City has gone through a quiet active travel revolution. Cycling is up almost fourfold from 2019, while the number of motor vehicles on the City’s roads has fallen by two thirds. There are now more bikes on the City’s roads than there are private cars and private hire vehicles – and bikes make up a quarter of all vehicles on the City’s streets. Pedestrians are still, by far, the largest user group on the City’s streets. In addition, new vehicles have appeared on the City’s streets since 2019. A range of micromobility vehicles such as dockless e-bikes and e-scooters are now available and these create new demand for street space when parked. As anyone using the City’s streets will have noticed, the competition for space between different users is still there. What the new strategy will include The outcomes the City was looking to achieve with its 2019 Transport Strategy have not changed

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either. This is because the challenges the strategy seeks to answer remain, and because according to surveys, people continue to favour streets that are more pleasant to spend time in, and more conducive to active travel. Twice as many people agree with the statement that cycling should be encouraged than disagree with it. The City of London wants its streets to be inspiring, high-quality and delightful – and it’s easy to understand why given its architectural renown, central location, world class public transport links, and programme of pop up cultural events. Bruce signalled that inclusion and accessibility take a greater role than they did in the previous strategy – recognising that walking and wheeling are the primary modes of travel on the City’s streets, and that that there are numerous barriers to the streets being accessible to everyone: narrow and crowded pavements, the lack of places to sit and rest, and in some cases, the lack of safe road crossings. Removing these barriers will be a priority in the new strategy. The City has examples of what more accessible streets look like: it has planned programme of raised tables to slow down vehicle traffic at pedestrian crossings, while the Thames to Eternity project turns stones from the Old Embankment, made redundant as part of the Thames Tideway construction, into seating elsewhere in the City. The City will use its new street accessibility tool to assess where accessibility improvements are needed – and anyone can use the tool to audit a City street. The new transport strategy will also include additional focus on micromobility. The City wants to anticipate the growth in micromobility, for example by ensuring there is adequate provision for e-scooter and e-bike parking. Sustainable drainage will also be used more widely - and the City will be looking for opportunities to retrofit streets that can slow down water runoff, to reduce pressure on the sewage system and ultimately reduce river pollution. The strategy will rely on other partners for delivery of its aims. It plans to work closely with the City’s five Business Improvement Districts, which it sees as

Nico Bosetti is principal transport planner with Momentum Transport Consultancy

partners to shape longer term interventions and deliver smaller, quicker interventions. And it will continue to work with developers on their public realm contribution, so they provide “not just a great front door but also a new public space back to the City”.

Projects underway Current projects showcase how the City wants to improve transport and its public spaces and the City is implementing the final stages of its All Change at Bank programme, which started in 2017. Since then, the programme has changed the junction into a destination as well as a transport corridor. A combination of wider pavements and bus gates has created the equivalent of six tennis courts worth of public space at the junction. This new public space means that Bank Junction is now a place where people can enjoy spending time as well as passing through. There is already evidence that the public space is welcoming a much broader range of users – providing space for people to wait, speak to each other, for outdoor seating, and for tour groups to enjoy the junction’s landmarks. Audience members asked how this intervention impacts on accessibility. Bruce explained that for some users who rely on a car or taxi to get around, the changes at Bank will mean a longer journey to reach a destination on, or in the immediate vicinity of Bank junction (all buildings retain vehicular access). At the same time, the junction is now much more inclusive to many people with accessibility needs. Indeed, the wider pavements, shorter crossings and the removal of cars and taxis between 7am7pm have made it a lot safer and comfortable for people to walk, wheel or cycle across the junction. This positive experience overall is further encour- >>>

Issue 128 January-March 2024

BRIEFING: CITY’S NEW TRANSPORT STRATEGY | NICO BOSETTI

>>> agement for the City to provide a new public space at St Paul’s gyratory – and the plan is for this space to become one of the largest new public spaces in the city. Temporary and long-term plans to improve Fleet Street are also on the cards. What does this mean for other areas? Roy McGowan offered a national view on transport strategies – why we need them now more than ever, and how we can become better as a country at implementing them. Transport remains the UK’s biggest carbon emitter – over a quarter of UK territorial emissions come from transport (this includes UK flights but excludes international aviation). The estimated carbon emissions generated by cars, LGVs, HGVs, buses and motorcycles have flatlined since 1990 – apart from a lockdown dip in 2020 and 2021. In comparison, the UK’s overall territorial emissions dropped by 42% between 1990-2019. In this context in 2021, Government published a vision to decarbonise our transport system by 2050. It set out a priority to make “public transport and active travel [will be] the natural first choice for our daily activities”, to deliver “a world class cycling and walking network in England by 2040”, and to give “all places the ability to take bold action to decar-

New St Paul's gyratory

bonise transport”. Despite this overarching ambition, we as a country have as many national transport strategies as we have transport modes, and some of these contradict each other. For example, the Government’s 2021 decarbonisation plan showcased Low Traffic Neighbourhoods, the Ultra Low Emissions Zone and parking levies as examples of good practice to reduce car dependency. The Plan for Drivers published in 2023 has shifted to focus on improving the experience of car-based transport. Roy argued that the UK needs a long-term transport strategy – one that considers all modes of transport at once – and that we need to be consistent in implementing it. Infrastructure takes time to deliver, and requires significant investment. The All Change at Bank project took 6 years to deliver on the ground. The think tank Resolution Foundation

City Boardwalk To promenade along the south-facing City frontage from Blackfriars to The Tower compares poorly with the South Bank as do the frontage buildings. BWCP with Avery Associates were commissioned by overseas clients to come up with a scheme to upgrade the river frontage, intoduce much needed power and internet services and so enhance property values. The City public realm and movement strategies need to take this forward. ©AAA and BWCP

Planning in London

recently published the findings of its Economy 2030 Inquiry, which found that UK public investment has been the second most volatile among advanced economies over the past 60 years. Volatile public investment creates a “stop-start” approach to project delivery, and drives up project costs. The City of London strategy is an example of a long-term view, ambitious goals and collaborative working to reach these goals. The projects in the pipeline show an example of what is possible – and many boroughs and indeed cities are following a similar course of action. By providing them with a stable, long term policy context, and devolving additional resources at local level, Government can set transport decarbonisation in motion. n

SEE also Lee Mallett’s column on page 8

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The Aim of the Society is to stimulate a wider concern for the beauty of the capital city, for the preservation of its charms and the careful consideration of its developments

WHY DO WE EXIST? We believe that London's future must be shaped by contemporary culture as well as its rich and layered history WHAT WE DO Celebrate and enjoy the capital’s culture and architectural history. Debate how we plan a future that is beautiful, sustainable and fair HOW WE DO IT Engage Londoners with how the capital is designed and planned through tours, walks, talks and debates FIND OUT MORE www.londonsociety.org.uk

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CLIPBOARD

Challenge to the London Plan Housing secretary Michael Gove last month wrote to mayor Sadiq Khan to tell him he has appointed a panel to review the London Plan “to consider the aspects of your London Plan which could be preventing thousands of homes being brought forward”. Gove had in July asked officials at the Department of Levelling Up, Housing and Communities (DLUHC) to review housing delivery in London to gain a greater understanding of the reasons for what the minister calls the capital’s “significant under-delivery”. In his letter Gove said: “Due to the significant shortfall in housing supply and under delivery of housing in our capital, I have concluded that it may be necessary to take further action now, as a matter of urgency, to make sure London is delivering the homes our capital needs.” He has appointed Christopher Katkowski KC to lead a panel of expert advisors to consider the aspects of the plan “which could be preventing thousands of homes being brought forward”. The panel’s other members are former Conservative Local Government Association chairman James Jamieson; architect Paul Monaghan who is a cofounder of Allford Hall Monaghan Morris and chair of the Construction Industry Council and past RTPI president Dr Wei Yang. Their report will have a “particular focus on brownfield sites” in the “heart” of the capital, Gove said, adding: “If you cannot do what is needed to deliver the homes that London needs, I will”. Housing delivery in London is “far below the levels needed”, he told the mayor. “Not only is delivery considerably short of your own London Plan target by approximately 15,000 homes per year, it was approximately 63,500 homes lower than actual need last year, as calculated by the standard method”. He claimed it was not a national problem and that London was the “worst performing region” in the Housing Delivery Test 2022. A spokesperson for the Mayor of London said: “London as a whole has outbuilt the rest of the country since Sadiq took office in 2016 and housing completions in London in recent years are at the highest level since the 1930s, with the highest council homebuilding since the 1970s. If the rest of the country had built housing at the same rate

Planning in London

Sixth time lucky for South Ken station RSHP has been given the green light for its controversial redevelopment of South Kensington Station, two years after councillors rejected the scheme in the face of officers’ recommendations. A planning inspector has ruled that the bulk of the scheme – created for developer Native Land and Transport for London property company Places for London – can go ahead. The only elements of the South Ken proposals that were dismissed at appeal were plans to insert two shops in the grade-II listed subway that links the station with the Victoria & Albert Museum and the Science Museum. RSHP’s scheme will deliver 50 new homes, along with a range of shops, restaurants and workspace – and station improvements including step-free access to platforms from the Thurloe Street entrance. Almost 3,000sq m of new office space will be created under the proposals. The scheme will involve the demolition of the station area’s existing two-storey “Bullnose” building for replacement with a new four-storey structure. Planning inspector Zoë Hill acknowledged that the “quirky” semi-circular building had its own clear character and identity. But she added that its was only a “curtilage listed structure” as part of the station’s grade II listing and that there was “sound reason” for its redevelopment. She said RSHP’s proposals for a new Bullnose building would retain the current structure’s historic plan form at the same time as offering increased floorspace. “Once the principle of demolition is accepted it is necessary to consider what would be appropriate to replace it, and those factors must have regard to the surroundings, the listed building itself and other material factors,” she said.

as London since 2016, there would be more than 300,000 additional homes nationwide." Khan has called for £2.2bn in emergency funding and £4.9bn a year in affordable housing investment, and to "give house builders urgent clarity on new fire safety rules around second staircases on taller buildings".

London boroughs are five of top ten that earned most from pre-application advice Half of the authorities that earned the most from

pre-application advice in the year to March 2023 did so despite not being among the authorities that received the most applications over the same period. Cornwall Council, which received more applications than any other authority in 2022/23, unsurprisingly also reported the highest level of preapplication fee income. However, the secondplaced London Borough of Camden does not feature among the top ten authorities that received the most applications, yet reported similar levels of income to Cornwall from pre-application >>> advice. Daniel Pope, chief planning officer at

BRIEFING

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Camden Council, says much of this comes from “high value” commercial developments in its Knowledge Quarter, which spans the area within a mile of King's Cross station. Camden is joined in the top ten for pre-application fee income by Kensington and Chelsea, Brent, Croydon and Barnet councils, which also do not feature in the top ten for the highest application numbers. A spokesperson for the London Borough of Brent attributes this to its newly adopted local plan, which “identifies a number of areas for growth, including locations for tall buildings” and says the authority has received a “significant amount of development interest”. Camden Council also reported the highest rate for pre-application fee income per application received, in a top five that only includes London authorities. The London boroughs of Kensington and Chelsea and Croydon came in second and third, having reported receiving an average of £183.95 and £183.15 of pre-application fee income per application received. This is significantly higher than the £74.23 average.

Statutory consultees under pressure to respond SoS Michael Gove has said that he is "worried about delay and procrastination with statutory consulting" and that "the performance of Natural England, the Environment Agency, Historic England and other arm's length bodies needs to improve". In a speech launching the new NPPF at the RIBA in December, Michael Gove said that he believed that statutory consultees are "an important check and balance within our planning system, safeguarding the environment, respecting heritage, ensuring health and safety considerations are properly taken into account": "A superficial glance at the statistics suggests that most statutory consultees respond within the expected 21 day limit, but look a little closer, and you can observe the regular use of holding responses - effectively an 'I'll get back to you later' acknowledgement. It meets the headline target for a response, but it disguises foot-dragging and delays development. The wider public interest is poorly served by this." The minister said that he has appointed

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Sam Richards to lead a rapid three-month review into the statutory consultee system. Sam Richards is campaign director and chief executive at campaign group Britain Remade. He is also a former special advisor at Number 10, where he worked on energy and the environment. Michael Gove said: "Sam will look at whether the current group of consultees is right, whether the performance reporting is effective, and whether the absence of a reply within an appropriate timeline should be treated as a green light rather than a red one. Sam will report back to me and the chancellor and we will then seek to act on his recommendations in the new year."

More money, no problems? Lichfields provide this guide to changes to planning fees applicable from last month. Repeat Applications Will Soon Incur A Fee Planning Guarantee Timeline Reduced No Ring Fencing Planning Skills Strategy What Might Have Been Amending Planning Permissions The Town and Country Planning (Fees for Applications, deemed Applications, Requests and Site Visits) (England) (Amendment) Regulations 2023 have been made The increase to planning fees applies from 6th December 2023. Fee levels will be reviewed no later than three years following implementation and raised in line with inflation each April1. This means applications submitted on or after 6th December 2023 will use the new fee regime, subject to transitional and savings provisions2. The headlines are as follows: • A 35% initial increase in planning application fees for major applications; • A 25% increase for all other applications which include prior approval applications, minor and householder applications; • Fees to rise yearly with inflation from 1st April 2025 (capped at 10%, measured by the Consumer Price Index from the preceding September); • Removal of the 'free go' for repeat applications; • A reduction in the 'planning guarantee period'

for non-major applications from 26 weeks to 16 weeks, unless extended in exceptional circumstances; and • No ringfencing of planning fees. Lichfields have listed the new fees and commented on the changes. Extracts follow. Find their paper here: https://tinyurl.com/y6hrfzn3 All repeat applications will soon incur a fee – the free go is (almost) gone The ‘free go’ for repeat applications is coming to an end, from 6th December 2023 – subject to savings provisions. Currently, for many application, where applicants reapply within 12 months of submitting an application for development of the same character or description on the same site, subject to certain conditions, they can do so without paying a fee. Repeat applications submitted and found valid on 5 December 2023 or sooner will continue to benefit from the free go, if they meet the necessary conditions. The ability to do so will start to disappear from 6th December 2023. Free go applications will only start to disappear, rather than immediately stop, because the saving provisions mean that applicants can continue to benefit from the free go, after 6th December 2023, where the necessary conditions are met, notably that the 12 month potential resubmission period for a repeat application on a given site is still running. Therefore, it is our understanding that it will take a year for this amendment to have full effect, because the free go provision will be available to certain applications determined up to and including 5th December 2023. Government guidance will likely provide clarity on this point. The removal of the free go is designed to “encourage applicants to engage in pre-application discussions and support the submission of high-quality applications first time round”. However, this viewpoint fails to acknowledge the political nature of planning that can lead to officer recommendations being overturned and the desire of applicants to resubmit and re-engage locally rather than proceeding to appeal. Late last year, the Planning Inspectorate encouraged such re-engagement. In (Lichfield’s) view, the ‘free go’ recognises that schemes evolve for market reasons and in >>>

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>>> response to concerns raised by consultees, officers, members and/or the community. It is too simplistic to say that removal of the free go will lead to better use of pre-application advice services (which are not always available) or the submission of higher quality applications. Some LPAs might also be incentivised to reject applications within the statutory time limits, regardless of the suitability of the application, to receive a second set of planning fees. A common concern throughout the consultation was that the removal of the free-go could lead to more appeals, for which there is no fee, with a consequential unfunded resource pressure on local authorities. As a result of this proposal, there is certainly potential for the number of appeals to increase rather than a greater uptake of pre-application services, which remain stretched. 1

FOOTNOTES The Government initially laid the Regulations before Parliament in draft on 20 July, alongside a response to the February 2023 consultation “Stronger performance of local planning authorities supported through an increase in planning fees”, stating its intention to increase fees over summer, which was delayed. The Consultation response stated that fees will be reviewed by the Secretary of State no later than three years from when they come into force. 2 Savings provisions to the Town and Country Planning (Fees for Applications, Deemed Applications, Requests and Site Visits) (England) (Amendment) Regulations 2023 (legislation.gov.uk)

Keir Starmer pledges “We’ll build new towns and Georgian-style homes”. At his conference speech last autumn the Labour leader made a big play on planning reform. He said new new towns will be developed by state-backed companies with compulsory purchase powers, with a cap on what landowners can charge to free cash for local amenities. Doctors’ surgeries, schools, transport links and other infrastructure would be “hardwired” into the plans, Starmer says in the speech. Developers will be given “planning passports” to build on brownfield land if they meet the new design standards, with a “stronger presumption in favour of permission”. Guidance will specify a focus on “gentle urban development” emulating fivestorey townhouses built during the 18th and 19th centuries. Promising “a big build”, Starmer would also allow low-quality green belt such as scrubland and car

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M&S hits back M&S has been given permission to proceed with a legal challenge against Michael Gove’s decision blocking the demolition of its flagship Oxford Street store. The levelling up, housing and communities secretary refused the controversial plans in July, rejecting Pilbrow & Partners’ 10-storey replacement scheme over heritage and design concerns, as well as its embodied carbon impact. But the High Court has now given M&S permission to proceed with a judicial review against the government over the decision. The substantive judicial review hearing is expected to take place next year. For a successful challenge, M&S will have to prove to the courts not that the government’s decision was wrong, but rather that it made an error in its decision-making. This could include convincing them that Gove missed material that was relevant – or else considered material that was irrelevant to the case. M&S chief executive Stuart Machin confirmed the store’s intention to proceed with the claim. According to the AJ he said: ‘We are pleased that the court has recognised the merits of our legal challenge on every single one of the six counts that we raised, and has approved our case to proceed to the next stage.’ Machin, who previously described Gove’s decision as ‘unfathomable’, said it was ‘bewildering’ that M&S was ‘again having to go through this after two years of support and approvals’. He added: ‘We have been clear from the very start that the refurbishment of the existing store was not possible, so this is only the first step in the lengthy process of overturning the government’s senseless decision to reject our Marble Arch proposal – the only retail-led regeneration on Oxford Street.’ Conservation group SAVE Britain’s Heritage said it will 'continue to defend the claim', adding in a statement: 'The court has granted permission for the claim to proceed to a two-day hearing. In doing so, the court has accepted that the claim is "arguable".' Gove overruled the planning inspector by rejecting the contentious redevelopment proposals on 20 July. Setting out his decision for refusal in a letter, Gove said the 10-storey replacement scheme conflicted with policies on heritage and design. He also specifically highlighted the embodied carbon impact and waste involved in the plan. Although the plans had been approved by both Westminster City Council and London mayor Sadiq Khan, the application was called in by Gove last summer. In his decision letter, Gove said: ‘The secretary of state is not persuaded that it is safe to draw the same conclusion reached by the inspector, namely that “there is no viable and deliverable alternative” ... which leads to the inspector’s overall conclusion that “there is unlikely to be a meaningful refurbishment of the buildings”… He does not consider that the applicant has demonstrated that refurbishment would not be deliverable or viable and nor has the applicant satisfied the secretary of state that options for retaining the buildings have been fully explored, or that there is compelling justification for demolition and rebuilding.’ In response to Gove’s decision, M&S chief executive Stuart Machin described the rejection as ‘unfathomable’, especially when other demolition-led developments around the site had been waved through. He added: ‘The suggestion the decision is on the grounds of sustainability is nonsensical.’ Pilbrow & Partners founder Fred Pilbrow also expressed shock at the decision, branding it ‘bizarre’. He told the AJ: ‘How can a planning system that charges no less than three separate authorities – Westminster City Council, the Mayor of London and now the planning inspector – to determine one application, simply overrule their unanimous conclusions?’

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>>> parks to be released for development. The party has branded the areas “grey belt” and will specify that half of homes built are to be sold at affordable prices. The first new towns were created by the postwar Labour government, which designated areas for building and set up development corporations to oversee settlements such as Stevenage, Crawley, Basildon and Milton Keynes. Three million people now live in such towns and Labour will promise a similar model to create “entirely new, large-scale housing settlements”, insisting it can overcome inertia that has prevented previous attempts to revive the idea. Referring to his childhood home, Starmer said “That pebble-dashed semi was everything to my family. It gave us stability through the cost of living crises of the Seventies, served as a springboard for the journey I’ve been on in my life. And I believe every family deserves the same.” He promises a “decade of national renewal”, suggesting that his party would be in power until the mid-2030s, after previously telling activists it would take more than one parliament to achieve his goals. Following his shadow chancellor Rachel Reeves’s speech which set out plans to reform the “antiquated” planning system so that new infrastructure gets built, Starmer contrasted the approach with Rishi Sunak’s decision to abandon the northern leg of HS2. He pledges Labour would “get Britain building” and “the winner this time will be working people, everywhere”. Promising a “big build” for the country, he says: “What is broken can be repaired, what is ruined can be rebuilt.” Starmer signalled that he would resist tax rises while living standards are squeezed and tells activists: “We should never forget that politics should tread lightly on people’s lives, that our job is to shoulder the burden for working people — carry the load, not add to it.”

repeat agreements”. His aim being to prevent local planning authorities using them to mask underperformance. “Some authorities use so-called extension of time agreements – that is to say, an insistence on delays – to slow down the system,” he said. “Strip these agreements out of the system, and in the two years to September, only nine per cent of local authorities determined 70 per cent or more of non-major applications within the statutory eight-week period.” He pointed out that on major applications it is even worse: “strip out the extension of time agreements and only one per cent of local authorities managed to get through at least 60 per cent of plan-

ning applications within the statutory 13-week period.” The use of planning performance agreements, which extension of time agreements come under, has significantly increased in recent years. According to the Department for Levelling Up, Housing and Communities’ (DLUHC) latest set of planning statistics, 43.2 per cent of all planning decisions in 2022 involved either a planning performance agreement, extension of time, or other performance agreement. In 2013, just 0.4 per cent of decisions involved a performance agreement. The SoS announced that the government would begin publishing league tables revealing local planning authorities’ “real performance”. n

One of the last large PD office-to-residential schemes delivers Work has started on the final phase of the Headingley Park residential scheme. Headingley Park is an office to residential conversion scheme in which four office buildings have already been converted to create 152 residential units. This final phase is 70 units. Work has started following the NHS vacating the offices in Stockdale House which is being converted under the last major PD Prior Approval issued in Leeds. The scheme is by Addington Capital and is designed to meet current space standards. The Headingley Park development with its parkland setting has proved attractive to young professionals and post graduate students being close to the City Centre and the University. Headingley Park is currently ranked ‘The best place to live in Leeds’ by HomeViews.

Extension of time agreements to be cut short In a written ministerial statement published last month, the levelling up secretary said that he intended to consult on constraining the use of extension of time agreements, including banning them for householder applications, limiting when in the process they can apply, and prohibiting

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Issue 128 January-March 2024

BRIEFING | PLANNING PERFORMANCE

Decisions both decided and granted show strong fall over the past year Latest planning performance by English districts and London boroughs: planning applications in England July to September 2023, OVERVIEW

Between July to September 2023, district level planning authorities in England: • received 87,800 applications for planning permission, down 12% from the same quarter a year earlier; • decided 85,600 applications for planning permission, down 13% from the same quarter a year earlier; • granted 73,500 decisions, down 14% from the same quarter a year earlier; this is equivalent to 86% of decisions, down one percentage point from the same quarter a year earlier; • decided 88% of major applications within 13 weeks or the agreed time, up one percentage point from the same quarter a year earlier; • granted 7,900 residential applications, down 10% from the same quarter a year earlier; • granted 1,700 applications for commercial developments, down 10% from the same quarter a year earlier; and • decided 45,100 householder development applications, down 19% from the same quarter a year earlier. This accounted for 53% of all decisions, down from 57% a year earlier. In the year ending September 2023, district level planning authorities: • granted 303,600 decisions, down 13% from the year ending September 2022; and • granted 33,200 residential applications, down 8% from the year ending September 2022.

Planning applications received During July to September 2023, authorities undertaking district level planning in England received 87,800 applications for planning permission, down 12% from the same quarter a year earlier. In the year ending September 2023, authorities received 369,900 planning applications, down 13% from the year ending September 2022 (Live Table P134, PS1 Dashboard). Planning decisions Authorities reported 85,600 decisions on planning applications in July to September 2023, down 13% from the same quarter a year earlier. In the year ending September 2023, authorities decided 352,100 planning applications, down 11% from the year ending September 2022. A decrease in the number of householder development decisions (of 19%) was a key driver of this, with numbers of decisions made – excluding householder developments – decreasing by a much lower 5%. Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (Live Tables P120/P133/P134, PS1/PS2 Dashboard). Applications granted During July to September 2023, authorities granted 73,500 decisions, down 14% from the same quarter a year earlier. Authorities granted 86% of all decisions, down one percentage point from the same quarter a year earlier. In the year ending September 2023, authorities granted 303,600 decisions, down 13% from the year ending September 2022. Authorities granted 86% of all decisions, down one percentage point from the year ending September 2022 (Live Tables P120/P133, PS2 Dashboard). Applications on hand Authorities reported that they had 131,900 applications on hand as at 1 July 2023, down 14% from the same quarter a year earlier. This is 54% above the number of decisions made during the quarter. The corresponding figure for the same quarter a year earlier was 57%. (Live Table P133, PS1 dash-

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board). Historical context Figure 1 shows that, since about 2009-10, the numbers of applications received, decisions made and applications granted have each followed a similar pattern. As well as the usual within-year pattern of peaks in the Summer (July to September quarter) and troughs in the Autumn and Winter (October to December and January to March quarters), there was a clear downward trend during the 2008 economic downturn, followed by a period of stability. There was a large dip in 2020 following the start of the pandemic and a subsequent recovery in early 2021, including a particular peak in applications received, but since the peak there has been a steep downward trend. Regional breakdowns Table 1 shows how numbers of applications received, decisions made and decisions granted varied by region. It also shows how the percentage of decisions granted varies widely by region, from 79% in London to 92% in North East (Live Table P133, PS1/PS2 Dashboard). Table 2 like Table 1 shows how numbers of applications received, and planning decisions made, varied by region. It also shows the percentage change in number of applications received and decided compared to the same quarter a year earlier. The percentage change in the number of applications received varies widely by region, from 16% in Yorkshire and the Humber to -4% in North East (PS1 Dashboard). Decisions granted Figure 2 summarises the distribution of the percentage of decisions granted across authorities for major, minor and other developments using box and whisker plots. The ends of the box are the upper and lower quartiles, meaning that 50% of local authorities fall within this range, with the horizontal line in the centre of the box representing the median. The whiskers are the two lines above and below the box that are 1.5 times the size of the box (the interquartile range) with the dots representing outliers. Figure 2 shows that the

Planning decisions by development type, speed of decision and local planning authority. All tables and figures can be found here: http://tinyurl.com/8ubpjfy2

Source: DLUHC/ONS range between the whiskers for the percentage of applications granted is widest between authorities for major developments (40% to 100%), followed by minor developments (54% to 100%) and other developments (72% to 100%) (PS2 Dashboard). Speed of decisions In July to September 2023, 88% of major applications were decided within 13 weeks or within the agreed time, up one percentage point from the same quarter a year earlier. 21% of major applications were decided within the statutory time period of 13 weeks, up two percentage points from the same quarter a year earlier. In the same quarter, 85% of minor applications were decided within 8 weeks or within the agreed time, up three percentage points from the same quarter a year earlier. 39% of minor applications were decided within the statutory time period of 8 weeks, up three percentage points from the same quarter a year earlier. Also in the same quarter, 90% of other applications were decided within 8 weeks or within the agreed time, up three percentage points from the same quarter a year earlier. 56% of other applications were decided within the statutory time period of 8 weeks, up five percentage points from the same quarter a year earlier. For more information on major, minor and other developments please see the PS1 and PS2 district planning matter guidance notes. Figure 3 shows that range between the whiskers for the percentage of decisions made in time this quarter for major developments was (50% to 100%), for minor developments it was (62% to 100%) and for other developments it was (72% to 100%) (PS2 Dashboard). Use of performance agreements ‘Performance agreement’ is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments. Between July to September 2023, 42% of all planning application decisions involved a performance agreement. Major developments were more likely to involve a performance agreement compared to minor and other developments

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with 74% of major decisions involving a planning agreement, compared with 51% of minor decisions and 37% of other decisions (Reference Table 2, PS2 Dashboard). Figure 4 shows, from April 2010, the numbers of decisions on major, minor and other developments made involving a performance agreement, compared with numbers without a performance agreement. Notwithstanding definition changes, there has been a marked increase in the use of agreements since early 2013 (see Technical Notes for more information). This longer upward trend has been driven by both the additional scope for recording them and their additional use (Live Table P120, PS2 Dashboard). Figure 5 shows that in the quarter to September 2023, 91% of major development decisions involving performance agreements were made on time. In comparison, 79% of major decisions not involving performance agreements were made within the statutory time limit of 13 weeks (see Reference Table 2, PS2 Dashboard). Performance of individual district level local planning authorities The existing approach to measuring the performance of authorities was introduced by the Growth and Infrastructure Act 2013 and is based on assessing local planning authorities’ performance on the speed and quality of their decisions on applications for major and non-major develop-

ment. Where an authority is formally designated by the Secretary of State as underperforming, applicants have had the option of submitting their applications for major and non-major development (and connected applications) directly to the Planning Inspectorate (who act on behalf of the Secretary of State) for determination. See Improving planning performance: criteria for designation for more information. Speed of decisions The designation thresholds, below which a local planning authority is eligible for designation are: • For applications for major development: less than 60% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant; • For applications for non-major development: less than 70% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant. See Live Tables P151/P153 Quality of decisions The threshold for designation on applications for both major and non-major development, above which a local planning authority is at risk of designation, is 10% of an authority’s total number of decisions on applications made during the assess- >>>

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>>> ment period being overturned at appeal. See Live Tables P152/P154 Residential decisions In July to September 2023, 11,200 decisions were made on applications for residential developments[footnote 3], of which 7,900 (71%) were granted. The number of residential decisions made was down 7% from the same quarter a year earlier, with the number granted down 10% from the same quarter a year earlier. 900 major residential decisions were granted, down 10% from the same quarter a year earlier and 7,000 major residential decisions were granted, down 10% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard). In the year ending September 2023, 46,400 decisions were made on applications for residential developments, of which 33,200 (71%) were granted. The number of residential decisions made was down 6% from the previous year, with the number granted down 8% from the year ending September 2022. 4,000 major residential decisions were granted, down 10% from the previous year and 29,200 minor residential decisions were granted, down 8% from the previous year. Residential units The figures collected by the Department are the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each application, such as the number of homes in the case of housing developments. The Department supplements this information by obtaining statistics on housing permissions from a contractor, Glenigan. The latest provisional figures show that permission for 245,000 homes was given in the year to September 2023, down 15% from the 290,000 homes granted permission in the year to September 2022. On an ongoing basis, figures are revised to ensure that any duplicates are removed as far as possible, and also to include any projects that local planning authorities may not have processed: they are therefore subject to change, and the latest quarter’s provisional figures tend to be revised upwards. For the previous eight quarters, the year to figures have been revised upwards by 2% on average. These figures are provided here to give contextual information to users and have not been designated as National Statistics. When considering the above figures in relation to the central government ambition of raising housing supply to 300,000 homes per year on average by the mid-2020s, it should be noted that many permissions do not result in a home being delivered in practice. This is due to a range of reasons, relating to the circumstances of landowners and developers, as well as the local and national

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economy. In addition, i) time lags in building can affect the number of homes built in a particular period; and ii) the methodology used cannot guarantee that all double counting of permissions is removed from the above figures. In comparing the number of residential applications granted and the number of units granted, it should be noted that the two series measure different things and use data from different sources, and so may not track each other closely over the short term. More specifically, this difference is likely to be due to a combination of differences in the timing of recorded decisions and a difference in the average numbers of homes included within the relevant planning applications. Commercial decisions In July to September 2023, 1,900 decisions were made on applications for commercial developments of which 1,700 (87%) were granted. The number of commercial decisions made was down 7% from the same quarter a year earlier, with the number granted down 10% from the same quarter a year earlier. 400 major commercial decisions were granted, down 14% from the same quarter a

year earlier and 1,300 minor commercial decisions were granted, down 8% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard). In the year ending September 2023, 7,800 decisions were made on applications for commercial developments, of which 6,900 (89%) were granted. The number of commercial decisions made was down 7% from the previous year, with the number granted down 8% from the year ending September 2022. 1,500 major commercial decisions were granted, down 9% from the previous year and 5,400 minor commercial decisions were granted, down 8% from the previous year. Trends in the percentage of residential and commercial decisions granted SEE Fig 7 BELOW Householder developments Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (see Definitions section of the Technical Notes).

The number of decisions made on householder developments was 45,100 in the quarter ending September 2023, accounting for 53% of all decisions, down from 57% of all decisions made in the quarter ending September 2022. Authorities granted 89% of these applications and decided 91% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard). In the year ending September 2023, 189,100 decisions were made on applications for householder developments, accounting for 54% of all decisions, down from 57% of all decisions made in the year ending September 2022. Authorities granted 89% of these applications and decided 90% within eight weeks or the agreed time. Major public service infrastructure development decisions Since August 2021, major public service infrastructure developments broadly defined as major developments for schools, hospitals and criminal justice accommodation have been subject to an accelerated decision-making timetable. Separate figures on major public service infrastructure development decisions have been collected on the quarterly PS2 return with effect from October 2021. During July to September 2023 there were 17 decisions, of which all 17 were granted and 14 were decided in time (Live Table MJPSI, PS2 Dashboard). Please note that figures are not collected on the CPS1/2 return and so don’t include education developments by county councils. Permission in Principle/Technical Details consent decisions Since April 2017, local planning authorities have had the ability to grant permission in principle (PiP) to sites which have been entered on their brownfield land registers. Where sites have a grant of permission in principle, applicants have been able to submit an application for Technical Details Consent (TDC) for development on these sites. In addition, since June 2018, it has also been possible to make an application for PiP for minor housingled development as a separate application, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC. Figures on PiP/TDC decisions have been collected on the quarterly PS2 return from January 2020. During July to September 2023, local planning authorities reported 127 PiP (minor housing-led developments) decisions, 12 TDC (minor housingled developments) decisions and 2 TDC (major developments) decisions. The totals for the previous quarters have been similar although there has been a slow upward trend since 2020, when there were about 60 PiP decisions per quarter (Live Table

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PiP/TDC1, PS2 dashboard). Permitted development rights Planning permission for some types of development has been granted nationally through legislation, and the resulting rights are known as ‘permitted development rights’ (PDRs). For certain permitted development rights, if the legislation is complied with, developments can go ahead without the requirement to notify the local planning authority. Hence no way of capturing this data exists and these are not accounted for in this report. In other cases, the permitted development right legislation requires an application to the local planning authority to determine whether or not prior approval is required and to determine as appropriate (see the Definitions section of the Technical Notes). Between July to September 2023, 6,100 applications were reported, of which prior approval was

not required for 3,100, permission was granted for 1,600, and 1,400 were refused. This resulted in an overall acceptance rate[footnote 6] of 78%. Large householder extension accounted for 58% of all PDR applications reported, with 27% relating to All others, 7% relating to Agricultural to residential, and 5% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2). In the quarter to September 2023, 800 permitted development right applications were made for changes to residential use, of which 500 (66%) were given the go-ahead without having to go through the full planning process. Overall during the 38 quarters ending September 2023, district planning authorities reported 319,400 applications for prior approvals for permitted developments. For 179,600 of them prior approval was not required, 74,200 were granted and 65,600 were refused (Live Table PDR2). n

Issue 128 January-March 2024

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM

Planning reforms from UCL, ACA & POS: Permitted Development Ideas for reform Plan-making reforms Account of Forum meeting on 4th December 2023 at Assael, 123 Upper Richmond Road SW15 2TL. Minute by Riette Oosthuizen and Michaela Oberhuber of HTA Design also at planninginlondon.com > LP&DF DISCUSSION TOPICS on planning reforms 1 Permitted Development Professor Ben Clifford of UCL opens a discussion on extending PD rights and the Prior Notification process Overview of Adaptive Reuse and Sustainability The presentation began by addressing the concept of adaptive reuse, focusing on the conversion of under-utilised or vacant commercial buildings, especially offices, into housing. This approach is seen as a way to combat urban decline. It's increasingly linked to sustainability debates due to the significant carbon emissions from buildings. As buildings become more energy-efficient operationally, the focus shifts to reducing embodied carbon. Permitted Development (PD) in the UK The concept of PD, which has been in place since the 1947 Act, was discussed. PD allows certain minor developments without explicit planning permission from local authorities. Originally, this included small and temporary structures and was

Extending permitted development in England Professor Ben Clifford ben.clifford@ucl.ac.uk / @drbenclifford Presentation to London Planning and Development Forum 4 December 2023 based on the proportionality principle, limiting state intervention to developments unlikely to have significant impact or cause harm. Extending Permitted Development The government's expansion of PD since 2013 was highlighted, including the significant change in

2013 that allowed office-to-residential use under PD. This was made permanent in 2015 with no floor space limit. Additional expansions included conversions from various commercial spaces to residential, with specific size limits, and extensions to light industrial buildings. The introduction of Class E to residential PDR in 2021 increased the

Meeting held on Monday 4th December 2023 at Assael ATTENDANCE Brian Waters Chairman Riette Oosthuizen HTA Design Ben Clifford UCL Les Mayhew Bayes Business School Michael Bach London Forum Peter Eversden London Forum Andy Rogers ACA Andrew Catto ACA Robert Fiehn London Society

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Richard Diaz Lopez Freeform Architects Stephen Heath Bloomsbury Association Samin Almagableh Asp Architects Nick Ferguson PMA Traffic Deon Lombard Deon Lombard Architects Dewean Rowe TCPA Félicie Kikler Assael Jon Rowles CPRE London

Judith Ryser UDG Suinder Singh Singh Fudge Architects Tim Wacher RICS London Mark Willingale Willingale Associates Philip Waddy West Waddy Architects APOLOGIES Michael Edwards UCL Mike Kiely POA Joanna Averly DLUC

number of eligible buildings for conversion. Recent Proposals for PD The presentation covered recent proposals from 2023, including extending PD to protected locations, a new Class C1 to residential PDR, and increasing size limits for certain conversions. It also mentioned the Autumn Statement 2023's announcement of a new PD right for subdividing houses into flats without altering the facade. Prior Approval Processes: The complexities of the prior approval processes under PD were discussed. This includes consideration of various factors such as transport impacts, contamination risks, noise impacts, and compliance with national standards like adequate natural light and space standards. The presentation noted varying practices among local planning authorities (LPAs) in handling these approvals and the strengthened requirements following an independent review. Understanding PD Impacts Studies examining the impact of PD highlighted concerns such as the loss of planning gain contri-

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butions and affordable housing, as well as economic impacts due to commercial space being converted to housing. There were also issues raised about the quality of housing developed under PD rights and their impact on health. Health Impacts of PD Conversions The presentation delved into the potential health impacts of PD conversions, citing studies that showed lower mental wellbeing among residents in PD housing compared to the general population. Common problems in PD housing included a shortage of space, noise, pollution, and inadequate natural light. The positive correlation between housing quality, particularly space standards, and mental wellbeing was emphasised. Recommendations and New Studies Recommendations for improving PD housing focused on enforcing space standards, integrated design approaches, better use of Article 4 directions, and enhancing local open space access. A new major study funded by NIHR from 20232026 aims to investigate the health and equality

impacts of planning deregulation in England, focusing on PD housing. Current and Proposed PDRs The presentation highlighted the complexities arising from the range of PD rights, differing prior approval requirements, and frequent amendments to the General Permitted Development Order (GPDO). The current proposals to increase size limits and introduce new PD rights were mentioned, along with questions about the best approaches to protect occupier health without compromising development viability. Local Authority Approaches The varying approaches of LPAs in handling prior approvals under PD rights were also noted, raising questions about the effectiveness and consistency of these processes across different jurisdictions. Conclusions: Adaptive Reuse, Health, and Wellbeing The presentation concluded that while adaptive

Issue 128 January-March 2024

>>>

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM: PERMITTED DEVELOPMENT

>>> reuse of vacant buildings for housing aligns with sustainability and regeneration goals, the quality of PD housing varies, often resulting in poor design. Despite these challenges, the government continues to favour PDRs for creating new housing. There was a call for balancing occupier health and well-being with housing development viability. DISCUSSION Complexities in Prior Notification and Building Standards: The discussion revolved around the challenges in the prior notification process under PD. It was noted that planning policies should not duplicate other regulations, particularly building standards. However, the current practice often involves planning authorities in matters outside their expertise, like building control, leading to inefficiencies and suboptimal outcomes. A clear division of responsibilities between planning and building control to ensure better compliance with building standards and to promote higher living standards was argued. Subjective Criteria in Planning Approvals: The discussion emphasised that subjective aspects, such as the external appearance of upward extensions, should not fall under PD but rather require a full planning application. This approach would allow for a more thorough consideration of contextual and aesthetic factors relevant to urban development. From Over-Prescription to Lax Standards: A shift from highly prescriptive requirements to a more relaxed approach in planning was critiqued. This pendulum swing is seen as a reaction to the housing shortage, resulting in policies that may overlook important aspects of housing quality. Concerns were raised about the mixing of building regulation requirements with planning requirements, leading to scenarios where planners are expected to oversee aspects they are not qualified to handle. Building Control and Implementation Challenges: The conversation also touched on the role of building control in enforcing standards. There was an acknowledgment that effective enforcement is crucial but often hampered by inadequate jurisdiction or oversight. This leads to situations where substandard housing developments occur, reminiscent of pre-Victorian standards, with issues like inadequate natural light and poor living conditions. Need for Clear Division and Effective Enforcement: A call for a clearer division between permitted development rights and building regulations is needed. There was a consensus that while PD can facilitate certain developments, it should be subject to stringent building standards. This approach would help in addressing the housing shortage without compromising the quality of living environments and adhering to essential health and safety standards.

Planning in London

Adaptive reuse • The conversion of under-utilised or vacant (obsolescent) commercial buildings (particularly offices) into other purposes (particularly housing) is commonly proposed in relation to combating urban decline (Wilkinson and Remøy, 2018) • Often now being linked to sustainability debates, e.g. better use of resources (Armstrong et al, 2021). Buildings a significant source of global carbon emissions and as they become more energy efficient during their operational phase, embodied carbon becomes a greater concern

Permitted development • In the UK, the definition of ‘development’, in place since the 1947 Act, is wide-ranging so to avoid the system becoming clogged-up with minor matters, there has always been a category of development which does not require planning permission expressly granted by the local planning authority but are rather ‘permitted development’ (PD) • This was based on proportionality principle, because state intervention should be based on likelihoods of impact or harm. PD traditionally small and temporary structures Urban Development Focus in London: • A focus on London's unique challenges in urban development, particularly the trend of converting houses into flats and the transformation of commercial spaces into residential units. • In inner London, the discussion noted that house-to-flat conversions are less prevalent due to the scarcity of smaller houses. In contrast, outside of London experiences significant tension over these conversions. The participants discuss the defensive attitude of outer London residents towards such changes.

Planning Policies and Development Rights: • Permitted Development Rights (PDR) Impact: PDR, especially office-to-residential conversions, was discussed extensity. It was noted that these conver-

sions contribute significantly to London's housing supply with the majority stemming from office to residential conversions. • Housing Quality Concerns: Participants raise concerns about the quality of housing resulting from PDR conversions, citing issues like reduced unit sizes and inadequate amenities. A specific example includes a planning appeal case involving the division of a house into units, where substantial payment for affordable housing was initially demanded. • Complexities in Policy and Politics: The discussion revealed the complexities in planning rights and the influence of political decisions on planning permissions. The varying implementation of these policies by local authorities, and the impact of political points on planning rights, were highlighted.

Extending permitted development • Since May 2013, the government have allowed the change of use of offices-to-residential use as permitted development. Initially experimental but made permanent in 2015, with no floorspace limit for the size of conversion • Added in 2015: - Retail, betting office, pay day loan shop, amusement arcade, casino, launderette, hot food takeaway to residential with 150m2 size limit - Storage or distribution centre to residential (500m2 size limit)

- Agricultural to residential (450m2 and 3 unit limit, 2 and 5 unit limit) extendedpermitted in 2018 to 865m Extending development • 2021 saw Class E to residential PDR introduced, including offices, retail, light industrial, restaurants, cafes, clinics, nurseries, day centres, gyms and recreation centres, all subject to a 1,500m2 scheme floorspace limit • In research published by the TCPA in 2021, we looked at the new right in four case study authorities (Barnet, Crawly, Huntingdonshire, Leicester). Estimated that introducing this right saw a 33.6% increase in number of buildings eligible at least in part to convert and increasing the floorspace eligible for conversion by 127.7% • 80.3% of buildings paying business rates (most nondomestic buildings) potentially eligible at least in part for conversion under PDR Recent proposals • July 2023 report from APPGs on housing market and ending homelessness supportive of converting commercial buildings to residential to help meet housing need, but raises concern over affordability requirements and quality • Summer 2023 on extending / amending PDRs • Proposal for Class E to residential size limit: double to 3,000m2 or remove floorspace limit altogether, proposal also to remove 3 month vacancy requirement • Proposal to extend the PDR to apply in protected locations including National Parks

• Proposal for a new Class C1 (hotels and boarding houses) to residential PDR APPG= All party parliamentary group

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Challenges in Planning and Development: • Challenges for Local Authorities: The conversation highlighted local authorities' struggles with planning, including resource constraints and balancing development with community interests. A specific example is given of Richmond, where maintenance and upgrade issues lead to poor living conditions. • Developers' Perspective: Developers face challenges in navigating the planning system, with issues around obtaining planning permissions and bureaucratic delays. A notable point is the discrepancy between applications for prior approval and actual construction, reflecting the unpredictability of the process. Community Impact and Public Opinion: • Effects on Local Communities: The broader impact of urban development on communities includes housing quality, access to services, and preservation of neighbourhood character. An example discussed is the conversion of shops into residences, leading to inadequate living conditions due to poor natural lighting and ventilation. • Influence of Public Sentiment: The role of public opinion in shaping planning decisions is significant, as local sentiments can greatly influence the outcomes of development projects. The conversation underscored the need for local authorities to take a consistent approach to prior approval and apply permitted development controls effectively. Suggestions for Future Planning Practices: • Improvement Proposals: Suggestions for improving urban planning include simplifying the planning process to make it more efficient and transparent, enhancing the resources and capabilities of local planning authorities, and adopting innovative, community-centric development approaches were discussed. • Addressing Housing Demand: The persistent need for more housing in London and the challenges of meeting this demand within the existing planning framework were discussed. The conversation suggests the need for policy reform and the introduction of new development strategies. • Balancing Development and Preservation: Emphasis is placed on maintaining a balance between new development and the preservation of local character. The discussion included the need for more age-friendly housing options and the consideration of retirement communities in urban areas. Additional Insights from the Conversation: • Planning Permissions and Appeals Process: The forum cited examples where planning permissions and appeals have been unpredictable or influenced by external factors, such as political pressure. • Resource Allocation in Local Authorities: The >>>

Issue 128 January-March 2024

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM: PERMITTED DEVELOPMENT/ IDEAS FOR PLANNING REFORM

allocation of resources within local authorities and its impact on the effectiveness of planning policy implementation was discussed, with a focus on the need for more determination to prevent unsuitable developments. • Local Politics in Planning: The influence of local politics on planning decisions was debated, including potential conflicts of interest and the impact of political leadership on planning outcomes. The discussion also touched on the tension between national policies and local implementation. n

Article 4 Directions (as in July 2023) Other?

Borough

E to resi?

Other?

Barking and No Dagenham

HMOs, upward ext

Greenwich

Yes

HMOs

Barnet

HMOs

Hackney

Yes

Storage Launderettes

Bexley

HMOs

Hammersmi No th & Fulham

Basements

DISCUSSION TOPICS

Brent

Yes

HMOs

Haringey

2 Ideas for Planning Reform led by Andy Rogers of the ACA

HMOs Storage

Bromley

Yes

Upward ext

Harrow

Camden

Yes

Launderettes Basements

Havering

Hillingdon

Yes

Upward ext

HMOs

Hounslow

HMOs

Islington

Yes

Tower Hamlets

Yes

HMOs

Three ways to improve planning were outlined. These are based on the wide-ranging experience of members of the RTPI’s Planning Consultants’ Network, the ACA’s Planning Manifesto and the recent British Land / Landsec publication More Growth, more homes, more jobs. Firstly (and as the government has it seems belatedly realised, although whether £100,000 for each English authority will make a real difference is doubtful) Local Planning Authorities must be better resourced, by providing more and better-qualified planning officers (it used to be a fact that your planning application had a one in ten chance of being processed by a qualified planner - not sure about that now but it’s likely to be worse, especially at validation). And resourcing should include the proper monitoring and regulation of pre-application procedures, as well as the mandatory training of planning committee members. Secondly there should be clearer zoning of land to include a focus on brownfield urban regeneration and realistic grading of green belts, together with a further simplification of the Use Classes Order. These changes could make the release of development land easier and should be introduced alongside the removal of technical matters that are covered by other legislation, such as building and public health regulations, from the information required when submitting a planning application. Thirdly, to follow the reduction of onerous development control work by the removal of technical matters from planning applications, the government should continue its widening of permitted development rights and implement the introduction of properly qualified local agents to process planning applications, which could also be streamlined to just three levels: outline approval (as per the current PiP system), full planning and approved for construction. Agents would be used to assess the more straightforward applications and make recommendations for approval or rejection - in the same way that planning inspectors work but with the LPA making the final decision. n

Planning in London

Borough

E to resi?

HMOs

City

Yes

Croydon

Ealing

Enfield

HMOs

Kensington & Chelsea

Yes

Launderettes Basements

Kingston

Yes

Waltham Forest

Yes

HMOs

Lambeth

Yes

Wandsworth

Yes

Public house

Lewisham

Under prep

Westminster

Yes

Basements

Merton

HMOs

Newham

HMOs

Redbridge

HMOs Storage

Richmond

Yes

Basements

Southwark

Yes

HMOs Public house

Sutton

Conclusions • Existing strong evidence on the relationship between housing and health. PD housing varies in quality – there are actually some very good schemes – but has often associated with poor quality design. • Controversy over lack of planning gain (although new Infrastructure Levy would apply to PD conversions) • Nevertheless, government continues to favour use of PDRs to support creation of new housing – so this is unlikely to go away • Adaptive reuse of vacant buildings can be good for sustainability and local regeneration so in principle is a positive thing

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM: PLAN-MAKING REFORMS

DISCUSSION TOPICS

3 Plan-making reforms led by Mike Kiely*, chair of the Planning Officers Society The Levelling-up and Regeneration Bill: consultation on implementation of plan-making reforms was published 25 July 2023 for 12 weeks until 18 October 2023. There were three omissions that made commenting on this publication a challenge: 1. Details of the Alignment Test 2. NDMP – National Development Management Policies 3. A post-NDMP NPPF Alignment Test Potentially a good idea, but there have been no details from DLUHC about how it’s going to work. If Inspectors into Local Plans are going to try to fix strategic issues using this test, which is welcomed, they will struggle to do so without all the relevant local plans before them. POS has proposed to government how this could be done – more on that later. NDMP Again, potentially a good idea, but if we are going to keep a plan led system, there must be room for local nuance where that is necessary. POS agrees with the principle of NDMPs, as repeating them in Local Plans serves no purpose other than giving them s38(6) status. With amendments to this section through the LURA, NDMP will have the same status as a Local Plan policy (LPP). However, the LURA says that if there is a conflict between a NDMP and LPP it will always be settled in favour of the NDMP. POS thinks that this is wrong. The most up-to-date policy should have precedence (s38(5) requires that where there are conflicts between policies in different development plans) and that is what the LURA should have said about conflicts between NDMP and LPP. The Local Plan Regulations should have been amended to say that in examining the policies in a local plan the Inspector should delete policies that merely repeat NDMP unless the difference is demonstrated to be necessary by the LPA given its local circumstances. Unfortunately, DLUHC has ruined something that had the potential to be an improvement to the spatial planning and decision-making processes and instead has pulled significant power to the centre and considerably diluted a locally led, planning system. New NPPF When DLUHC produces its NDMP we will also see a redrafted NPPF which will mainly be focused on the plan-making side of the system. Without this,

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it felt like we were commenting on these proposals in a national policy vacuum. In fact we haven’t even seen the current variations to the NPPF that were consulted on nearly a year ago (22 December 2022) and we were promised the results in Spring 2023. Even in the weird world of DLUHC seasons, we are way past Spring! In fact we have only just seen the latest variations to the NPPF that DLUHC consulted on nearly a year ago (22 December 2022) and were promised the results in Spring 2023. Even in the weird world of Government seasons, December is way past Spring! The principal consultation take-aways The main features and our views were: • 30-month target: when you start and finish measuring this will be vital. The evidence gathering and analysis stage shouldn’t be included. It should also not include the Examination (but it seems to) as this is outside the control of the LPA. The rules around consultations need to be clearer and LPAs should be able to amend the plan (in response to consultation responses) after Reg 19 which they can’t do now. Nevertheless, POS struggles to see how this target can be achievable without significant simplification of the plan-making system, which does

Whilst there is much to recommend in this DLUHC consultation, there is far more that is missing or misguided. POS is ready to work with government, this one or the next, to improve the planning system so that it can do its job of delivering sustainable development not seem to be what is proposed. • The evidence gathering changes are welcomed and we await the production of centrally curated evidence so that LPAs in England don’t have to procure 317 different versions of essentially the same thing. It is important that the evidence for a plan is frozen at the start of the plan-making process to save wasted time and money in always having to have the latest numbers. In truth, the small differences that such data updates add rarely make a material difference to a plan. Much of the evidence that is used are at best estimates of what the future may hold, rather than predictions of the future. We need to stop treating evidence as the latter and start to see it as a systematic process that provides a basis that is good enough upon which to plan. • The consultation proposed a series of three

Gateways to manage the plan-making process to ensure that it sets off in the right direction, meets the legal and procedural requirements and that it sticks to its timetable. Whilst the Gateways seem appropriate, they are prescribed quite widely and we have a fear that they could become a bit meaningless, although we would expect more detailed advice to come forward from DLUHC that should avoid this. A further fear is that the person making judgements at each Gateway must be the same person for reasons of consistency. We don’t want one inspector/examiner saying one thing and the next one disagreeing. Our main worry, apart from the additional cost of all this additional PINS involvement, is does PINS have the resources to deliver these new checks in a timely manner. Their current performance clearly suggests not. • PIDs (Project Initiation Documents) replacing SCI (Statement of Community Involvement) is broadly welcomed as a PID sets out a wider range of matters relevant to a project (which is how LPAs should see the Local Plan making process) than a SCI, which just looks at community involvement. Some commentators have pointed out that SCI also deal with the DM process but, in reality, much of what an LPA does in DM is governed by statute and secondary legislation as well as being specified in Council Constitutions (especially around committee procedures such as public speaking). It is not uncommon for the DM side of a SCI to be out of step with either legislative or constitutional provisions, so a lighter touch to this area is to be welcomed. • POS considers that the proposals around Supplementary Plans are a sledgehammer to crack a nut. The problem that the proposals are designed to address is a fault in the wording of the Local Plans Regulations that unintentionally limit what an SPD (Supplementary Planning Document) can deal with. Rather than just fix those regulations, DLUHC has produced a new product that is overengineered (in terms of procedures for what it is trying to do) and is unlikely to be used. POS has proposed a better way of dealing with this which I will introduce in the next section. • The emphasis that a Local Plan should be vision led and outcome focused is very welcome, but POS considers this to be a job half done. Our proposals for strategic and spatial planning are set out next.

What POS would have proposed? POS considers that our plan-making system has been broken since 2011 and needs to be fixed. There are two fundamental problems: we don’t plan strategically anymore, and we have a standard methodology for assessing housing need that is not fit for purpose. DLUHC’s current position is that strategic planning should be voluntary, and POS cannot understand how government can hold such a position. >>>

Issue 128 January-March 2024

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM: PLAN-MAKING REFORMS

>>> Strategic planning is vital, should be compulsory and based on a city-region approach, rather than the old regions from the 1960s. When planning for an area, the main decisions will be based on employment patterns and housing needs. Most employment activity is focused on cities and people’s housing choices are invariably linked to their employment circumstance, so we think it makes sense. These groupings of LPAs should be required to produce a joint strategic plan across that regional geography. Decision making in these new structures must be by voting and not consensus – the current consensual model has not worked in nearly all cases, often because just one local authority says no and pulls out. The purpose of the plan, with respect to housing, would be to calculate housing need using a new standard methodology. That process would be done with “policy off” and not make any distribution decisions at that initial stage, It would produce the number of households needed to meet need and attempt to identify household sizes and typologies. This is not to suggest that housing is the only matter that needs to be planned for strategically! POS supports the principle of having a Standard Method for assessing the actual level of housing need in a locality. The current Standard Method does not do that for the following reasons: 1. It is based on out-of-date data – 2014 ONS data. The reason is that subsequent data sets gave lower numbers, and the sum total of all Councils’ housing need figures did not get government to its 300,000 target. Any method must be based on the latest data – to do otherwise undermines the methodology. We now have 2021 census data, rather than ONS estimates, and that must be used. 2. The Affordability Factor makes no sense: if you have estimated how many homes you need – who are the additional homes driven by the Affordability Factor for – second homes? Housing does not operate as a commodity but as an asset which has different economic drivers. See our Manifesto Background Paper 13: Addressing the Housing Crisis[1] for more details. 3. The 35% increase for the 20 largest conurbations is completely arbitrary and is not based on any evidence. Planning for housing in London, and many other large cities, has been based on a capacity-based approach and without a wholesale review of the Green Belt coupled with significant densification in the suburbs, the housing numbers produced for the Capital by the Standard Method are undeliverable. The same applies to the other conurbations and cities. A Standard Method must be based on sound demographic methodologies that seek to estimate the following: • The growth of the population: births over

Planning in London

deaths. It is considered that ONS generally do a sound job of estimating the level of growth between censuses at larger geographies but when it gets down to the Local Authority level it can become unreliable and needs local knowledge (eg of significant new housing developments) to produce accurate predictions. That is why this exercise must be done at a larger regional geography. • The net migration into or out of an area. Much of this will be movement within the UK (mainly between large cities and their hinterlands and from poorly performing areas into economically more successful areas) with an element being international migration. It is also considered that ONS do a sound job here, except for London where the GLA’s statistical methods are considered more accurate for the unique characteristics of the Capital. Again, reliable data can only be produced at a large geography. • An estimate of the level of hidden households: the number of people who want to have their own home but cannot afford one and so are still living with their parents or in other households, or they are homeless or being emergency housed by Local Authorities. This is the most challenging aspect to estimate, but census and electoral role data coupled with housing waiting lists and other data can be used to provide sound methods that are locally responsive, rather than an arbitrary national measure.

Having identified the scale of the population that will need to be housed over the plan period, we must then convert it into households so that the number and type of homes needed can be specified and planned spatially. In doing this, it will be important to identify the areas of specialist housing that will be needed, such as housing for students and the elderly, so that appropriate provision can be made. In many ways this is the most important part of the process because it is the foundation upon which everything else is built. It is essential that LPAs are dealing with numbers that are realistic because they need to have a conversation with their local politicians and communities along the lines, “this is the number of extra people we will have to house in the future and this equates to this many homes of these types, so how can we house our children, and our children’s children.” Currently the conversation is more along the lines, “we have this number from government that has no empirical basis, but if we don’t meet it, they will punish us.” Is it any wonder that we have got into such a mess over planning for housing? Without a sound basis for starting the conversation of how many homes we need to build to house our population, everything falls apart, as we have seen. The process of broadly distributing these homes can start once the quantum and nature has been calculated and this is when you turn “policy on”. An LPA

will need to make sure that they have sweated their brownfield opportunities first before starting to look at greenfield options. At such a larger geography, appropriate strategic decisions can be made about what is the best way to accommodate growth that cannot be accommodated within existing built-up areas. This will inevitably involve a strategic review of any Green Belt and POS has set out in its Manifesto Background Paper 3: We need to talk about the Green Belt[2] the best way to do this. The Strategic Plan should be examined using the current/proposed procedures: SEA, Alignment Test, NPPF conformity etc and Examined by an Inspector. The aim, as government seems to be proposing in its consultation, should be to fix problems to get a plan in place. We have let the best be the enemy of the good and we should stop doing that. With a Strategic Plan in place the detailed local policy framework will need to be put in place. POS considers that with a sound strategic planning process and a suite of NDMPs, the rest of the process should be very locally specific. We advocate a lighter touch process, similar to the current SPD process, with PINS only being involved to deal with outstanding objections. This was how plans were examined in the pre 2008 system, so it has precedence. In the new model, if PINS, on checking the representations on a local plan and agreeing that that there are no outstanding material objections, the LPA would be free to adopt the plan without the need for an examination. If an examination is necessary, in most cases this could be done via written representations we think. This approach would save considerable time and money, streamline the process whilst safeguarding local participation. Full details of these recommendations are set out in our Manifesto Background Paper 9: Spatial Planning: simplifying the process[3].

Conclusions Whilst there is much to recommend in this DLUHC consultation, there is far more that is missing or misguided. POS is ready to work with government, this one or the next, to improve the planning system so that it can do its job of delivering sustainable development. (*Mike was unexpectedly unable to attend but provided us with this text) Footnotes [1] https://www.planningofficers.org.uk/uploads/POS-MBP13Housing%20Crisis(1).pdf [2] https://www.planningofficers.org.uk/uploads/POS%20MBP3% 20Green%20Belt.pdf [3] https://www.planningofficers.org.uk/uploads/POS%20MBP9% 20Spatial%20Planning.pdf

London of the Future is a once-in-a-century publication from the London Society. The 昀rst edition was created in 1921 and proposed such ‘radical’ ideas as a green belt around London and a tunnel that would connect London to France. 100 years later, we asked a group of experts what could and should happen to London in the coming years and the responses have included natural solutions, different scales of economy, new forms of governance, better local food production, a radical rethink of education, improved housing provision and even dabbling in arti昀cial intelligence. Contributors include: Anna Minton, Carolyn Steel, Claire Bennie, Baroness Lawrence, Gillian Darley, Grafton Architects, Hugh Pearman, Indy Johar, Jude Kelly, Kat Hanna, Mark Brearley, Mark Stevenson, Neal Shasore, Roma Agrawal, Sarah Ichioka, Smith Mordak, Tony Travers and Yasmin Jones-Henry.

londonsociety.org.uk

“An essential travelling companion for those in the FAC-1 team, with Professor Mosey as your expert tour guide.” — Julian Bailey, partner at Jones Day and author of Construction Law (3rd edition) “… provides excellent guidance to support the effective use of FAC-1.” — Alison Nicholl, head of Constructing Excellence “… enables all parties to a project or programme of works to understand their roles and responsibilities in creating an alliance capable of delivering safe, quality and value-formoney project outcomes.” — Rebecca Rees, partner at Trowers & Hamlins “An essential catalyst in helping clients and industry supply chains actively work together to deliver the new ways of working that are required to unlock the vision of a social and productivity revolution that our industry needs.” — Terry Stocks MBE FICE, director at Faithful+Gould “The best friend of everyone, in every sector of the construction industry, who wants to make a real difference.” — John P. Welch FRICS, Deputy Director of Construction, Crown Commercial Service Dr David Mosey CBE is a professor at the King’s College London Centre of Construction Law & Dispute Resolution and was formerly head of the projects and construction department at law firm Trowers & Hamlins. He is the principal author of the FAC-1 Framework Alliance Contract and has advised on the procurement of collaborative projects and programmes of work for more than twenty years. David was appointed by the UK government in 2021 to lead an independent review of public sector construction frameworks. His recommendations for improving value, improving safety, managing risk and achieving net zero carbon are set out in ‘Constructing the Gold Standard’ and have been widely endorsed by both government and industry. David received the 2021 TECSA Clare Edwards Award for ‘professional excellence and an outstanding contribution to the legal profession’ and was awarded a CBE in the 2023 New Year honours list for ‘services to the construction industry’.

To buy a copy of the book with 15% off the cover price, visit

https://bit.ly/Mosey15PC or scan the QR code on the right. 46

Planning in London

ANDY ROGERS ON A TALE OF TWO SILLIES

ROGERS

A tale of two sillies Andy Rogers is a planning consultant and former director in architects The Manser Practice

Andy Rogers brings us a little New Year quiz. What is remarkable about these two houses? The answer goes back to my continuing concern about the interpretation of planning terms and the lack of common sense displayed by many local planning authorities when making their decisions. For both of these houses, the planners decided that a remarkably obtuse interpretation should be placed on the wording in planning policy documents. Number one is a semi-detached house where the owners wanted to extend to the side , behind a close-boarded fence, using permitted development rights. The planners determined that this would not be allowed because the extension would be sited forward from the front of the house. You may think this odd, because it seems to me that the front of the house is where the entrance door, porch and small garden (enclosed by a picket fence) are situated. But the planners decided that the front of the house should be the “principal elevation” as defined in the General Permitted Development Order: “…in most cases the principal elevation will be that part of the house which fronts (directly or at an angle) the main highway serving the house.” So here we have a problem as to what is the definition of a highway (generally agreed to be the roadway that allows vehicles to pass and re-pass), which in this case is of course at the side of the house. But the GPDO definition goes on to say that the principal elevation “will usually contain the main architectural features such as main bay windows or or a porch serving the main entrance to the house”. Therefore for this house the front elevation not only doesn’t face the highway, but the so-called ‘front’ (gable) elevation doesn’t include the main entrance or any other similar architectural features. The definition then goes on to say that “where there are two elevations which may have the character of a principal elevation, for example on a corner plot [as here], a view will need to be taken as to which of these forms the principal elevation”. You would think that a sensible planning authority would consider the words “in most

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Silly: Foolish, imprudent, imbecilic… – The Concise Oxford Dictionary

1 cases” and “may” to realise that there are sometimes cases where very rigid interpretation of the wording in planning policy makes little sense. Number two is a partly derelict building on the edge of a Welsh village where the owners wanted to apply for demolition and the construction of a state-of-art modern sustainable home in its place. The local planning authority decided that modern was not a good idea and said that permission would not be granted. This was followed by declaring the modest house to be a non-designated heritage asset (NDHA). This is of course rather less important than a listed building, but is nevertheless a much-used designation to make it more difficult to obtain planning approval for modern designs (however beautiful) and brings into play the procedures for designation. The question is whether this can be done by

an officer expressing his own personal opinion or whether the designation should go to a planning committee. Either way, there seems to be no chance of challenging such a designation except by going through the appeal process if an application for permission is refused. This will then hinge upon whether there is a reasonable foundation for considering its heritage significance - which I submit in this case, with no other buildings nearby, means that a modern house has nothing to be “in keeping” with. Yet another reason for local planning authorities to block redevelopment against the wishes of Mr Gove and the current government. n ...but 'modern' would change the character of the area so falling under Mr Gove's new universal reason for refusing any new development. - Ed.

Issue 128 January-March 2024

¡PILLO!

COP-out: Climate verbs A lot of climate worriers are unhappy with the promise merely to “transition away” from fossil fuels. But it is in fact quite right to talk about a transition, which implies that we need some large-scale alternative to move towards, rather than vowing simply to phase out the use of the world’s most important fuels. That is because a genuine transition, unlike a shutdown, actually has a chance of succeeding. Why exactly we needed 100,000 politicians and lobbyists gathered in a desert city to tell us this is anyone’s guess, but I’m glad at least they all got the full fat climate experience. The rest of us, looking on from afar, will have to be content with the low carb version. – Juliet Samuel in The Times

Britain did not grow rich from refused planning applications I often finish with quotes from writers more erudite than myself and I was taken recently by the author/ journalist Rahul Raina comparing us to India. “Britain is not in terminal decline, as it often seems to want to believe. Its history, its sense of self and its value to the world did not end in 1945. Britain did not grow rich from refused planning applications. The country houses, the dreaming spires, the suburban villas, the very riches of Britain did not create themselves.

Winner: best retrofit HTA Design won NLA’s best retrofit award for their own new office in Hackney Wick where they acted as client, developer, architect and tenant.

Planning in London

The remaking of Foster’s City Hall St Martins Property has released Gensler’s design remaking Foster + Partners’ now vacated City Hall

They were the product of centuries of relentless investment and innovation, of constant progress, of annoyed neighbours, of hisses and sneers, of tearing up the settled, mottled fabric and building something new”. – Stan Shaw of estate agent Mervyn Smith in the Ham & Petersham magazine

The world's most expensive cities to live in Singapore and Zurich surpassed New York to become the world's most expensive cities to live in this year, according to a new global survey. The sky-high cost of car ownership, pricey alcohol and rising grocery prices saw Singapore pull ahead of the US city, with which it shared top spot last year, according to the Economist Intelligence Unit's Worldwide Cost of Living 2023 report. Zurich jumped from sixth place last year to joint first, thanks in part to the strong Swiss franc, as well as expensive groceries, household goods and recreation. Geneva, tied with New York in third position, and Hong Kong rounded out the list of the top five costliest places. Overall, global prices rose an average 7.4% year-on-year in local currency terms, slightly down on last year's 8.1% increase. Chinese cities were among the biggest movers down the rankings, mainly due to the country's

slow post-pandemic recovery and subdued consumer demand. Other findings from the study were: • Los Angeles (sixth place) and San Francisco (10th) were the only other US cities to make the top 10 • The cheapest city remained the Syrian capital of Damascus, in spite of its cost-of-living basket price rising 321% • Mexico's Santiago de Querétaro and Aguascalientes were the biggest global movers upwards in the ranking after the peso strengthened against the US dollar • The weaker Japanese yen saw Tokyo slip 23 places to 60th place and Osaka drop 27 spots to rank 70th. • While Israel's Tel Aviv made the top 10, the survey was carried out before the Israel-Hamas war, which may have affected prices Utility prices rose the most slowly out of the 10 broad categories of goods and services examined, increasing by 5.7%. "The supply-side shocks that drove price increases in 2021-22 have reduced since China lifted its Covid-19 restrictions in late 2022, while the spike in energy prices seen after Russia invaded Ukraine in February 2022 has also eased," said Upasana Dutt, head of worldwide cost of living at EIU – Alex Millson, Bloomberg n The survey was carried out between Aug. 14 and Sept. 11 and compared more than 400

Putting people at the heart of what we do. 49

2. 2.

Transport and the commitment to the climate challenge have both been under the spotlight in the UK . With debate on all sides of these politically hot topics, we’re going back to Momentum’s core foundations in this issue of Connect. Since our company was founded in 2012, we have aspired to design for everybody, putting people are at the heart of what we do. This fundamentally means our strategies always aim to improve the lives of the communities we’re working in. To do this means taking into account differing needs and offering considered and progressive transport solutions. Many of our guiding principles mean we’re strongly in favour of sustainable modes of transport, good public transport and active travel. Simply, we believe they improve people’s lives through better air quality, addressing climate change, and creating better, safer spaces with fewer dispossessed communities and reduced road traffc accidents. Since our last Connect, we have launched our Conversations in Momentum podcast, and have been joined by some incredible guests to bring these ideas to life. In this issue of Connect, we bring together a snapshot of those conversations. You can fnd the full written transcripts of the podcasts at www.momentum-transport.com/blog/ - or listen wherever you get your podcasts, just search for ‘Conversations in Momentum’. We also take a look at what’s ahead for Momentum City, our exemplar global city which showcases how progressive transport planning and urban design involves understanding the link between transport and land use, and the future shape of our towns and cities. There are many solutions in our transport and urban design toolkit to build equitable cities, address the challenges of public health and climate change and deliver connected spaces which safeguard our environment for future generations. We hope you enjoy fnding out more about these in Momentum City and in this edition of Connect.

Contents Conversations in Momentum

04 - 05

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Conversations in Momentum

06 - 07

Season 2, episode #5 3.

08 - 09

Case study snapshot 10 - 11

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3. 3.

Nova with Derek Griffths and Claudio Borsari.

4. 4.

Momentum and CDA Momentum has been working on an ongoing basis with Central District Alliance Business Improvement District (CDA) since 2021. This support allows CDA to deliver public realm and movement improvements across the BID area. The work includes providing highways expertise and design development on the Central District Alliance BID Place Plan, which is a strategic, coordinated approach to supporting streets and public spaces in the CDA BID area. Momentum has also supported with identifying places where there may be an opportunity for CDA to support public space improvements that help celebrate neighbourhood identity, enrich the natural environment and promote sustainable movement. In November 2022, working in partnership with Camden Council, CDA supported public realm works at Red Lion Street, providing new trees, improved cycle lanes and pedestrian links and better wheelchair mobility. Residents, workers, and visitors are now enjoying more public space in Holborn. In June 2023, a temporary pocket park was delivered in Clerkenwell and was showcased throughout June as part of the London Festival of Architecture. This was a collaborative project alongside the London Borough of Islington which is providing innovative solutions to implementing new green spaces in the highway. This rewarding project saw a number of benefts, such as greening the highway and the associated positive impact on people’s physical and mental health, providing an additional place to stop and rest, and providing a place to socialise and enjoy interaction with others. Momentum has also been working alongside Islington on the development of a council-owned garden, St John’s Garden, close to Farringdon Station. To fnd out more visit: www.momentum-transport.com 52

Conversations in Momentum: season 2, episode 4, July 2023.

BIDs . Debbie Akehurst...

“I think what’s really important is that BIDs are a real catalyst for change.” But I also think, if you stopped Joe Bloggs on the street and asked him what a business improvement district was, I don’t think many people would know. But BIDs, especially now, play such an important role in terms of London and London’s economy. And not just London, because obviously there are BIDs across the country, but there’s 70 currently in London. I think one of the things that COVID has shown is the real importance of outside space. So we as a business improvement district are doing a lot of work around how we implement outside space, working closely with both of our boroughs of Camden and Islington. We do a lot around place making but also about showcasing the area. So working very, very closely with our businesses so that we can help them in terms of where they do business. For Central District Alliance, we sit between the City and the West End. So what we want to make sure is that people don’t just see our area as an area to pass through to get somewhere else, but that actually it’s very much, ‘well, what can I do in this area?’. So we have the British Museum as an example, which gets in the region of six and a half million visitors a year. But what we want is those six and a half million visitors to stay in the area, go to some really nice restaurants, cafes and bars, and actually see some of the other great cultural and architectural interests that we have in the footprint. And that helps feed the whole SME ecosystem, that in turn helps support those bigger, global and corporate businesses that we have in the area. But then on the other side our businesses operate within a community, so we do a lot of community outreach as well through our ESG programme. I think overall BIDs are a real, good force for change. We act as brokers, so we’re very good at bringing the private, public and voluntary sectors together to work collaboratively because we all operate in the same area.

Almost acting as a translator between many different stakeholders, who obviously have different levels of engagement with the local area, whether they’re workers or residents, whether they’re members of the council or the business community. The frst UK BID was in Kingston, and originated with the conception of a BID being a high street. Something that I really like about the way that we’ve articulated the strategic spatial vision for the BID here, is moving away from just that high street model and considering what it means to look at a place in context. Particularly with all of those complicated stakeholder networks and partnership opportunities that Debbie just mentioned. I think it’s really powerful. And moving away from just thinking about a high street, part of what we consider as connecting people now, in these discussions of climate and active travel, are green links and low-pollution links and common spaces like parks. And not just thinking about those places where people might gather to have coffees and conversations, but how they get there to begin with and whether there are alternatives to highlytraffcked roads. We’re working with Islington Council on St. John’s Garden, a garden just behind Farringdon Station. This is a project which has 50/50 CDA and Islington council contribution, but has also been informed by really, really deep collaboration with the local residents’ network. Equally a lot of the ideas that we got for what might shape the park, and what people might want to see, came from knocking on doors and talking to people, which is a very soft form of stakeholder engagement that from a planning point of view can really have so much practical power. So yes, that BID model, of us navigating between different stakeholders is also informed by the way that we ourselves navigate the space, which can be a really powerful thing when it comes to place making and place shaping.

To hear the full conversation with Debbie Akehurst and Katie Mulkowsky, search for ‘Conversations in Momentum’ wherever you listen to podcasts.

…and Katie Mulkowsky.

“That’s a really good point. We have a few projects happening right now on the public realm side that demonstrate the potential of the BID model.”!

Derek Griffiths & Claudio Borsari.

Conversations in Momentum: season 2, episode 5, June 2023. Reclaiming the highway, taking bold action to create new space for pedestrians and cyclists in Westminster.

Momentum and Nova Victoria Nova is Landsec’s exciting development linking Victoria Station, Buckingham Palace and the Royal Parks in the heart of Westminster. The substantial scheme comprises a mix of world class offce space, high-quality residential apartments, retail units and 17 restaurant destinations, together with a signifcantly improved public realm. The generous street-level public spaces are complemented by active facades and pockets of desirable areas of public realm designed for the 115 million commuters, visitors, workers and residents who reside and travel through Victoria Station. On behalf of Landsec, and working with a the PLP Architecture-led design team, the team at Momentum was pivotal in ensuring numerous successful planning applications for the scheme and securing a signifcant transport benefts package as part of the Section 106 agreement. Momentum led the preparation of the detailed design of over £10m of Section 278 highway and transport improvement works surrounding the development, securing full approvals with both Westminster City Council and Transport for London as highway authorities. Momentum’s work has been instrumental in transforming Victoria into a people-focused destination. To fnd out more visit: www.momentum-transport.com/portfolio_items/nova-victoria/

To set the scene, Nova is immediately to the north of Victoria train station and Momentum has been involved with Landsec’s scheme since we were founded eleven years ago. This island site stretches and is bounded by Buckingham Palace Road, Bressenden Place and Victoria Street, and also encompasses London’s Inner Ring Road. It’s a very vehicle-dominated space but also one with a huge number of opportunities for sustainable transport with the train links, the coach station, and all the bus services that run through that space. The area had been closed since 2011 as part of the works for the improvement to Victoria tube station. So fve years ago, when we got to design and develop the next stage of the Nova Estate, that area became a clear opportunity to create a much better space rather than a vehicle-dominated road. Some of the functions for vehicles had to be retained and it was a fairly long negotiation with the nearby theatre to understand their servicing requirements and how we could accommodate those into the newly-developed Allington Street. The result of that was the creation of a time-based access system and booking system to be operated in conjunction between the Victoria Palace Theatre and Nova, that allows us to concentrate deliveries for the theatre in the morning and then close the street in the afternoon and evening and leave it almost as a completely-pedestrianised area. To try and isolate - and fnd a way of freeing up - Allington Street as a street for public realm really meant that we needed to look more widely at the wider network. Allington Street had previously been used by buses, and by deliveries and servicing. So we really needed to look for a solution to remove or manage those functions. One of the key ways we looked to do that was to provide a bus link that effectively ran against the fow of the one-way traffc that we had on Victoria Street, to allow those buses to turn and avoid Allington Street. That solved one problem, but it created another one - ie we needed to entirely redesign two fairly signifcant, signalised junctions within Central London, put additional traffc stages through those junctions, which impacted on capacity, impacted on pedestrian crossings and really constrained the area even further from a general traffc point of view. But it also provided opportunities to do better in all of those cases and to really look at a vehicle-dominated space and how we could create new spaces and new crossings for pedestrians. Additionally, overall it probably reduced the journey time for each bus around the area by about one or two minutes for each of them, which in the context of Central London is quite

a signifcant result. All the knock-on effects of eliminating what were previously-designed staggered crossings and creating a new large crossing, which is more aligned with the main pedestrian fows between Victoria Street and Victoria Stations, as well as looking at some of the safety issues around some of the side road junctions like Carlisle Place, gave us the opportunity to look more widely at all those issues. In terms of improvements for cyclists, what had been the case for the last ten years is that cyclists had a gap of about 40 or 50 metres between Allington Street and Bressenden Place, where they literally had no way of actually cycling in an eastbound direction. So if you were arriving at Victoria Station and wanted to just quickly jump on your bike and go to Parliament Square, to do that legally you’d have to travel along a loop of probably a kilometre to get to where you’re going, which is obviously a long way from sustainable ideals. The new contrafow really helped resolve that gap and allowed us to provide that link in the eastbound direction, and also really added value to some of the existing cycle provision in the area. All of a sudden the cycle hire dock in Allington Street become accessible in terms of travelling east and Nova’s basement cycle parking facilities are all serviced from Allington Street as well. Previously you would have been expected to push your bike down the footway. We anticipated that that wouldn’t necessarily have happened and you’d have got cyclists either cycling on the footpath, or taking their life in their hands and cycling on the road, neither of which we’d want to encourage. So resolving that has certainly improved one of the cycle links in that area. The project has been a clear game changer. I think it demonstrates a process of how to transfer priority from vehicles to people and cyclists, even in relatively recent schemes (the overall master plan of the area was designed and built in the last decade) - this is an update and a step forward. The transport assessment, which was written in 2018, was one of the frst documents in London to start to utilise the Healthy Streets indicators, although still in a very high-level way because they were still being developed by TfL themselves. But that was very appreciated in the discussions with Transport for London and the GLA, which I think links to the next key element of building consensus across multiple stakeholders. In this case that included Westminster City Council, TfL and the transport users of the area, with an evidence-based and systematic approach, and with the support of an interested client like Landsec, the Nova developers. When the site fully opens in the next few weeks I think then we’ll really see some of the new pedestrian desire lines open up through the area and people really being able to embrace access across that Nova island. All things point to it being a really positive change.

To hear the full conversation with Derek and Claudio, search for ‘Conversations in Momentum’ wherever you listen to podcasts.

In our podcast, Derek and Claudio pick up the baton from Niamh Sutherland, Senior Engineer at Momentum, who presented the bold transformations at Nova to the London Walking and Cycling Conference 2023.

Momentum City. Safeguarding our cities for future generations.

01 The Train Station

The University

10.

Where academia meets community and industry. A collaborative 24-hour space, embodying cutting-edge tech, sustainability and mobility. Connected yet providing places to ‘disconnect’ and learn. It’s a ‘mini city’ inspired by, and for, the next generation of Momentum City dwellers.

If mass transit is the backbone of a city, then the train station is the beating heart. The entry and exit point for thousands of commuters and the frst experience of the city for many.

Public Realm

02 The Museum Visitor experience, visitor experience, visitor experience. Moving at your pace through a beautiful space, where exhibitions are the hero, and back of house, front of house and the surrounding area perfectly interact to create a comfortable and inspiring community space.

!"#$%&'(%)&*+ www.momentum-city.com 56

Connected, inclusive, sustainable. A comfortable space to walk, to sit or just ‘to be’. A place to observe and socialise, yet a driver of our economy and society that interacts with our natural environment. A space for trees and trade, birdsong and city sounds.

03 04

Commercial District Old buildings meet new in Momentum City’s commercial district, bringing external connectivity, fexibility to adapt to tenants’ needs, effective internal movement, activated spaces and seamless logistics and back of house operations. An area of exciting development and places to relax for our City commuters.

The Logistics Hub Good logistics management ensures that valuable city space is used effectively. And the simple aim of our Logistics Hub is just that – by making distribution, deliveries and servicing more effcient and sustainable.

06 Co-location A mixed-development model, where new homes sit alongside light industrial, retail and offces. Bringing opportunities and challenges, and requiring careful planning and consideration. Transport becomes the key to balancing the competing demands of residential and industrial land use.

05 The Stadium

11.

A cultural and community hub bringing together thousands of people in one place. The stadium has unique characteristics and distinct design solutions to avoid pressures on the transport and pedestrian environment. Spectator comfort and safety are the priorities.

07 Our Homes

There’s no place like home! Momentum City residents live in a mix of dense urban centre developments colocated with manufacturing and retail, student accommodation, affordable housing, and housing developments in our suburban areas, across owneroccupied and social and privately-rented accommodation.

The Hospital

11 The Festival

A spot in Momentum City where vehicle access is a must. Arrival is calm and relaxed, blending drop-off points and accessible parking, with public transport connections, active travel and wayfnding for all. Green spaces around the hospital provide tranquillity for staff, patients and visitors alike.

Partnerships lead the way and bring a long-term, strategic outlook to events that last just a matter of hours. Momentum Fest generates revenue, protects the environment, promotes sustainability and above all makes sure everyone, no matter who they are, has the time of their lives celebrating our City.

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INTERFAITH UNDERSTANDING | DANIEL LEON

Interfaith understanding through design Daniel Leon says religious architecture can be a powerful tool for fostering unity

Daniel Leon is founder and director of Square Feet Architects

Planning in London

The Brighton and Hove Reform Synagogue, designed by Derek Sharp in 1967, is a modestly handsome building, tucked away in one of the city’s leafier suburbs. The building makes no great architectural statement. Elegant arches frame some fairly standard postwar brick masonry. This structure has a shy mien. The windows, at least the ones that face the street, are small and tinted. The whole building seems turned inwards, secreted away behind the trees that surround it. Head inside and the mood changes abruptly. You’re hit square in the face by an enormous set of stained-glass windows, which dominate the interior. The windows were designed by the Welsh artist John Petts. They depict a scene from Revelations, but many have since taken it as an allegory for the Holocaust, and the Imperial War Museum has indeed designated it as an official memorial. What the Brighton and Hove synagogue shows is that religious structures, even humble ones, have a unique power and force. World religions have for millennia used various design principles to inspire awe, contemplation, and self-reflection. Go to a London mosque and see its spare and elegant simplicity, both within and without. Go to your local Gothic revival church, a commonplace in each of the city’s boroughs, and see how the ornament and twisting tracery can evoke a feeling that the universe is beyond our own mortal understanding. Buildings like these speak to us in a profound way – even if we are not believers ourselves. The current approach: Beautiful husks In Britain, there is now something like a consensus that these buildings are valuable – in an architectural sense at least. There is a feeling that, even in an increasingly secular age, these buildings should be kept around in some form for sentimental reasons. The previous decade has seen a spate of conversions in London, where old churches were turned into houses, flats, or secular cultural centres. The conventional wisdom seems to say that these buildings are to be appreciated on aesthetic grounds – not so much on cultural or social ones. It's a consensus that Brighton and Hove Reform Synagogue has ended up on the wrong side. Its modernist design is – to put it mildly – out of style, and because of this, it’s now slated for demolition. It is due to be replaced with a block of flats, alongside a smaller new synagogue. A 2017 bid to have the building listed failed – though another one lodged by the Twentieth Century Society (which aims to preserve structures from this era) is now in the works1. The unfortunate fate of this building shows how wrong-

headed our attitude to religious architecture still is – both in London and elsewhere in the UK. By any definition, the Brighton and Hove Reform Synagogue is an important cultural sight. It is both a memorial and a place for Jewish worship in a part of the country that has fairly few of them. We are making a profound mistake when we judge these buildings merely as pretty shells for developers.

Abiding importance Recent events show the poverty of this approach. Events in the Middle East have ignited communal tensions in London, and the 2021 census has revealed a city that is only becoming more religiously diverse, with over a quarter of residents belonging to non-Christian faiths2. In times like these, it is vital that every faith community in the city has visible and physical symbols of itself, as well as meeting places for its members. This can be accomplished with a new approach to religious architecture in London, one which recognises them not merely as aesthetic objects, but as important cultural and social sites. As we chart the future of the built environment in London, we should bear this in mind. Sites for development are

of course scarce, but we should resist the temptation to treat our city’s religious architecture merely as so many plum opportunities for retrofitting. We should instead aim to keep as many of London’s religious buildings consecrated as possible. The social and cultural benefits of this would be considerable – far in advance of any marginal gain in housing stock we’d get by converting them. Even if these buildings are little used in some cases, their very existence serves as a powerful means to build interfaith understanding in a more diverse society.

By preserving our stock of religious buildings, Londoners of all backgrounds and creeds will be able to see and appreciate the architectural, cultural, and aesthetic traditions of different faiths. Visiting or even passing a religious building from a different faith reminds us that all of the world’s different peoples have been moved by the same basic impulses. A Christian, Jewish, or Muslim Londoner will be able to see how other cultures have – through their buildings – approached the human condition, life and death, and our relationship with the spiritual world. These buildings are a powerful way to build empathy and fellow feeling. Religious structures are also socially important in a more practical sense. Much of the modern effort at interfaith dialogue takes place in religious buildings. These sites are also important for the religious education of children and young people. And, perhaps most importantly, these buildings provide a physical meeting place for London’s different faiths. Preserving them intact will ensure that every faith community feels as if it has a spiritual home in the city in which they live.

Interfaith understanding through design For my part, I have grappled with these questions throughout my career. We know that religious architecture can inspire feelings of awe and devotion – but I contend that architecture can also inspire interfaith understanding. To this end, I collaborated with Matthew Lloyd (an architect and expert in church design) and Shahed Saleem (an architect and the author of The British Mosque: An Architectural and Social History) to design the ‘FridaySaturdaySunday’ building — a conceptual project that aims to foster interfaith unity. This innovative structure is designed as a meeting point for the three Abrahamic faiths: serving as a mosque on Fridays, a synagogue on Saturdays, and a church on Sundays. Our motivation for this project was to build up mutual respect and understanding, to break down barriers and, in the words of Rabbi Sir Jonathan Sacks, “heal a fractured world” – especially in light of recent events in London and elsewhere.

www.planninginlondon.com

Issue 128 January-March 2024

>>>

INTERFAITH UNDERSTANDING | DANIEL LEON

>>>

1 https://c20society.org.uk/news/t he-guernica-of-brighton-listingbid-to-save-modernist-synagogue-and-holocaust-memorialwindows#dismiss-cookie-notice 2 https://www.ons.gov.uk/datasets /TS030/editions/2021/versions/1 /filter-outputs/8f748994-2bd6407c-b7f8-7f9d7fafbe6f

Planning in London

I’d venture that this project is what a twenty-first century approach to religious architecture in London might look like in practice. Driven by the lack of places to build in the capital, and the underuse of existing religious buildings, as well as considerations of cost and land use demands, this project explores the potential of shared worship to help us transcend cultural divides. In this project, we hoped to provide a physical symbol of the unity between the faiths – and a physical space to build inter-confessional fellow feeling. We aimed to achieve this through design. In the project, we made use of design elements like natural light, beauty, washing,

and water to celebrate the shared feelings and impulses that drive each of the Abrahamic faiths. Myself, Matthew, and Saleem’s respective Jewish, Christian, and Muslim faiths were an integral part of the design – we worked together collaboratively to include each of our own faith requirements in the concept. As we manage what is an increasingly diverse city, religious architecture can be a powerful tool for fostering unity. Let’s recognise the aesthetic richness and utility of this stock of buildings, preserving and repurposing these structures – and even constructing new ones - to build bridges between faiths in twenty-first century London. n

AFFORDABLE RENT-TO-BUY | EMMA GEORGE

Affordable rent-to-buy A rent to buy model successful in turning renters into homeowners, explained by Emma George

Emma George is Rentplus’ South East area director

Tenants of an innovative affordable rent to buy home ownership scheme are already buying the homes they are living in using a high street mortgage, after just five years of renting. They moved into a brand new home with no deposit. Five years later they are buying 100 per cent of their home. As the market leader, Rentplus has proved that this model works to turn renters into homeowners and is reaching those on much lower incomes than the average users of other home ownership schemes. The premise is simple: tenants move into a brand new home with no deposit. They pay affordable rent set by the local authority, for 5-20 years. At 5-yearly intervals as agreed with them when they move in, they have the chance to buy 100 per cent of their home, helped by a gifted 10 per cent sum from Rentplus. The average household income of tenants using the model is just £32,500. This is almost half the average income of those using the Help to Buy Mortgage Guarantee and the Help to Buy Equity Loan, both of which have an average household income in England of £60,000. The first Rentplus tenants moved in in 2016. In 2021, 100 per cent of the first planned sales took place. In 2023, 95 per cent of tenants are buying their home at the planned time. Figures for the numbers of Shared Ownership transitions to 100 per cent home ownership are not available as DLUHC does not collect them and it remains the case that almost half (48 per cent) of private renters – over 2 million households - have no savings at all, meaning they are unable to access Shared Ownership1. The model is complementary to existing Government schemes by significantly expanding the overall number of first-time buyers. By removing the deposit barrier, it provides the opportunity for home ownership for those who otherwise could not afford it. The other major difference is that it is all privately financed and there is no cap on the potential funding. There are millions of pounds of institutional funding waiting to be invested. With the Government committing in its Levelling Up White Paper that by 2030 all renters will have a secure path to ownership, one of the most effective ways to achieve this will be through scaling up schemes like this. How the model works Under the model, tenants move into a new build home which they rent at a below market rate (80 per cent of market rent, including service charges) for between 5 and 20 years whilst they save up to buy it. Tenants have the option to purchase at 5 yearly intervals. At the start of their tenancy they undergo a financial assessment to decide which is most realistic, 5, 10, 15 or 20 years. If their circumstances change, it may be possible to extend their rental period or to bring forward their purchase date. Having a long-term, secure tenancy contributes to placemaking and enables families to settle in the area they want to live. “It

www.planninginlondon.com

makes a massive difference. You start thinking about it as “your area” and it's all about our community: when renting, we never became part of the community - now we feel we are.” - says Pavel Poc, a former Rentplus tenant, now home buyer. Tenants are working families on lower incomes, often key workers. They have said that the scheme has enabled them to buy close to their family and work where otherwise they would be unable to afford to. The average age of our tenants is 31, and nearly half have children. The below market rent enables tenants to save more than if they were renting privately. At the point of purchase, we gift tenants a 10 per cent deposit to add to their savings and reduce their mortgage payment. Tenants buy their homes using a normal high street mortgage with no restrictions, as if they had bought on the open market. “I plan to be in a position to buy the house in five years’ time. I’ve got an ISA set up and I can already see that growing each month, even after just two months. Rentplus is a fantastic opportunity to help people such as myself to save to purchase their first home and I am so grateful to find this opportunity” - says Nicole.

Wider benefits for the sector A significant proportion of tenants (in some area up to 100 per cent) come from the social housing waiting list where often they had been for a number of years but weren’t a high priority and were unlikely to be allocated a social home. One scheme saw 50 per cent of tenants move out of social housing that they no longer require, freeing this up for those in greater need. We work in conjunction with local authorities to help meet their housing demand, for example by prioritising local first-time buyers or key workers. Rentplus is now working across the country with schemes on the Devon/Cornwall borders, in Mid Sussex close to Heathrow, up to Longframlington in the North East. We are currently working on schemes to deliver across Enfield, Haringey and Southwark in London. Planning status Rentplus funds the delivery of new build homes through s106 agreements. The model can be included as affordable housing through two definitions in the National Planning Policy Definitions: a) affordable housing for rent and d) other affordable routes to home ownership. Some local authorities continue to be reluctant to accept the model on the grounds that they want housing at an affordable or social rent ‘in perpetuity’. We counter that there is no difference from social housing, where tenants are eligible to buy their home through either the Right to Buy or the Right to Acquire after just three years. We provide homes at a long-term, affordable rent for a >>>

Issue 128 January-March 2024

AFFORDABLE RENT-TO-BUY | EMMA GEORGE

>>> minimum of 5 and up to 20 years. We also enter into a memorandum of understanding with local authorities to endeavour to replace all homes sold with new affordable rent to buy homes, so that future generations can also benefit. In the majority of local authority areas that have adopted us we are already planning multiple schemes. By diversifying the tenure mix and addressing the needs of different parts of the housing market, Rentplus can help to boost the delivery rates of new homes. Rupert Warren KC was asked to provide Counsel’s Advice as to whether the Rentplus model constitutes affordable housing, by reference to the categories “affordable housing for rent” and “rent to buy” within the definitions set out in Annex 2 to the National Planning Policy Framework 2019. Mr Warren has little doubt that the Rentplus model falls within the term “affordable rented” inpart (a) of the NPPF definition, for the reasons set out above, and also within the “rent to buy” aspect of part (d) of the NPPF definition. Rentplus has engaged with and is looking to develop homes in over 200 rural and urban local authority areas. There is significant For any further information on potential and has enough funding to do far more. Rentplus, to request a meeting or visit a site, please contact the South East’s Area Director, Emma George on egeorge@rentplusuk.com or Stevie Pattison-Dick at spattison-dick@rentplus-uk.com

Planning in London

Injecting private funding into affordable housing We are fully funded by institutional investment which finances the delivery of new homes, injecting additional funding into the

affordable housing sector. A recent report from Legal and General and the British Property Federation estimates that £34 billion a year is needed to meet a 95,000 home per year shortfall in affordable housing and calls on the Government to scale the levels of institutional investment in affordable housing. Whilst there are no policy barriers preventing local authorities accepting institutional investment to deliver their affordable housing provision, be it for rent or ownership, in our experience, some are reluctant to do so. The challenge is inherently a cultural one. Even if council leaders are supportive of the model, there is a tendency amongst officers to favour sticking to traditional delivery models, ie grant funding, rather than accepting institutional investment for affordable housing. This means the country is losing out on additional affordable housing that could be delivered at no cost to the Treasury and will fall short on delivering the amount of new homes required because of ideological reasons, and against the rule of planning law. Some authorities have lost cases when challenged by the Planning Inspector. Government has called on local authorities to make use of institutional investment models, like Rentplus, to support their home building programmes. Peter Denton, CEO at Homes England, said: “The use of institutional capital can have a profound

influence on affordable housing, and housing in general.” Our model is fully funded by institutional investment such as pension funds and injects additional funding into affordable housing in the

area at no extra cost to the council or taxpayers, without threatening the supply of existing social housing. No loans or grants are needed. n

ABOVE: Affordable rent to buy homes on the award winning Taylor Wimpey Duke’s Quarter development at Whitehill and Borden LEFT: 22 Rentplus affordable rent to buy apartments on the Urban & Civic Huntingdonshire District Council Alconbury Weald development which needed no deposit for tenants to move in

FOOTNOTE 1 Figures from the English Housing Survey 2023

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Issue 128 January-March 2024

BOOKS: THE MANSION BLOCK | REVIEWED BY LEE MALLETT

At Home in London The Mansion Block In the context of London’s housing shortage, the mansion block might be a strong contributor to a planning-led solution writes Lee Mallett in his review

By Karin Templin, published by MACK and the Architecture Foundation 160pp £50

Lee Mallett is a founder editor/publisher of PiL and urban regeneration consultant/writer

Planning in London

A sumptuous tome from art publisher MACK in partnership with the Architecture Foundation, as part of a promised series looking at London housing types – and where better to start than with the most salubrious of residences, the mansion block? Author Karin Templin is a seasoned academic from UCL and the University of Cambridge. She shares her interest in mansion blocks with husband Alfredo Caraballo, Allies & Morrison director and designer of modern mansion blocks in Victoria. These feature in the book among 27 fine examples ranging from the 1850s to the present day. Why a review in Planning in London? Because, in the context of London’s housing shortage and the need to densify, and much dislike of towers, the mansion block might be a stronger contributor to a planning-led solution. Templin’s opening essay refers to the potential of the mansion block as an antidote to character-depleting towers, and a way of creating more affordable housing. It’s an ambition worth exploring in more detail, which this book doesn’t really offer, but it is an interesting examination of how the mansion block evolved as a distinct London typology. Mansion blocks were the answer to socio-economic necessities and drove three main periods of building. 1852-1903, when we were awash with ill-gotten gains from Empire before WW1 put paid to development; 1930-1937 when industrialisation and expansion demanded inner city homes for a burgeoning middle class, and latterly, from 2010 to date, when the mansion block has to a limited extent been revived and updated in the effort to achieve a more ‘gentle’ densification of London while emptying overseas investors’ piggybanks. ‘Gentle density’, you may recall, is the Government’s official preferred approach. And London’s population is not getting smaller. Nine exemplars illustrate each era of building, central and suburban. But the forces that produced them were driven by very different economic models. The earliest, grandest blocks were for rent. To produce an income stream for their developer-investors. The concept of widespread home-ownership, no mortgage market in a modern sense, the absence of an evolved long-leasehold system, meant developers did not sell the apartments they created. But they offered nice amenities to attract tenants. Apartments produced in blocks more recently, however, were and are for sale, because the faster capital receipts produced from sales, rather than long term rental income, produces better returns on the capital employed to create them. And that in turn bolsters the price developers will pay for a site, which cuts into the budget for quality and shared amenity. This is particularly the case for short-term developers, who will usually include an element of ‘other people’s money’ to build. The newish Build to Rent model, fuelled by institutional

money, has yet to fully demonstrate a superior cash flow, lacking the big bang of bucks up front in the appraisal, so competition for suitable sites still favours speculative developers. But their short-termism has stripped most apartment blocks of the civilising elements we love the mansion block for. Maybe that is changing, or greater civic and aesthetic virtue might be encouraged by the planning process. In this uneven battleground for acquiring land, the spec’ developer of the private-for-sale block has found viability progressively eroded by social or affordable housing quotas, by increased interest rates and inflation recently. This drove the race for towers. Build higher, sell more. If this wasn’t intended as a book primarily for architects, it would have been interesting to explore the economic models and planning conditions that created each era of mansion block development. What appeals to architects is that mansion blocks require their input to a greater extent than the traditional terraced house, or indeed today’s housebuilder product. In the 19th century the Architectural Association and the RIBA hosted lectures about the proliferating mansion block, while there was widespread press coverage because of public interest. But if architects do believe in mansion blocks, and planners want more of them, they have to engage with the market in understanding the forces that produce them. Then there’s the question of opportunity. Most mansion blocks were produced in the pre-planning era. As with towers, mansion blocks today have to jump the hurdles strewn across the existing built environment. It’s not easy assembling the kind of sites they require. Yet the parts of London we like most, Kensington say, or St John’s Wood, would be virtually impossible to repeat east of the River Lea (outside the Olympic Park of course) where most development is now set in the aspic of two to three storey terraces, or semi-detached/detached estates. It seems impossible today to densify existing built up areas, although that might be desirable if we want to tackle climate change. Perhaps this book is most important for bringing to our attention a favourite housing type that is slowly reviving. That needs nurturing in policy and in public. We like them. We need more homes. Why not let planning encourage their development? Curiously the book does not focus much on the lifestyles that made mansion blocks so appealing. More interiors, with people, and detailed apartment plans at a larger scale, and the clear delineation of apartments within blocks, would have made it more persuasive. And despite being sponsored by Lend Lease and residential investor Dorrington, if the book had been targeted more at developers and planners, and included some opinions from them, it would be even better than it is. n SEE leader on mansion blocks in our last issue no 127

BOOKS: MODERNISM BEYOND METRO-LAND | JOSHUA ABBOTT

Modernism Beyond Metro-Land Celebrating “Art Deco, Modernism and Brutalism in the suburbs of London and beyond” – by Joshua Abbott Paperback 144 pages £9.99 on Amazon Publisher: Unbound

Joshua Abbott first started documenting the moderating and Art Deco buildings of the Metro-Land era when he moved to South Harrow, a London suburb that formed part of the early Metro Land expansion during the 20th century. His labour-of-love website is a treat, comprising a series of photographic slideshows with buildings categorised by area and type. And now there is a book to go with it, celebrating “Art Deco, Modernism and Brutalism in the suburbs of London and beyond”. Modernism Beyond Metro-Land continues the work of Joshua Abbott’s first book, A Guide to Modernism in MetroLand, in mapping and documenting the art deco, modernist and brutalist buildings of London’s suburbs. Taking in the eastern and southern boroughs, the guide will feature art deco cinemas, modernist tube stations, brutalist office blocks, stunning post war houses and much more. It will include the work of renowned architects and designers such as Charles Holden, Richard Rogers, Wells Coates and Owen Luder, as well as more contemporary designers such as Peter Barber. The guide covers twelve London boroughs from Waltham Forest in the north east to Kingston upon Thames in the south west as well as a portion of Surrey. Each section features a map, descriptions of each building and colour photographs. It also features extended sections on areas of interest like Croydon town centre, the Central Line stations of Charles Holden and the self built houses of Walter Segal.

As well as exploring the architectural history of the suburbs, the book examines how this area has changed from the start of the 20th century, when much of it was part of the neighbouring counties, Essex, Kent and Surrey. The expansion of the capital's road, tube and rail network allowed people to commute to London from further away, creating new housing estates and kickstarting the growth of suburbia. New architectural styles from Europe and America like Art Deco and Modernism were imported to sit alongside more traditional building forms. Modernism Beyond Metro-Land will give centre stage to suburbia's most radical architecture of the last 100 years. n

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Issue 128 January-March 2024

BOOKS: MR CHELSEA | PAUL DAVIS

What does an architect do in retirement? Paul Davis tells the story of who he is, how, why and what he changed A large format 300gsm cover, thread sewn paperback with 250 pages. 194 drawings, paintings and photographs are embedded within the text. £30 from mrchelsea.co.uk

Paul Davis, author, architect and past president of the Association of Consultant Architects

Planning in London

Paul founded two practices (Davis & Bayne 1976 -94 & Paul Davis + Partners 1994-2013) which were responsible for regenerating much of Sloane Street and the King’s Road through three decades, culminating in Duke of York Square and the new the Saatchi Gallery as well as Cadogan Hall for the Royal Philharmonic Orchestra. Paul worked for seven of the central London landed estates as well as developers and private clients in Westminster and RBK&C, notching up almost 300 projects in the two boroughs. Other major projects include award-winning towers in Hong Kong and Tokyo as well as restoration and new build at Sir Christopher Wren’s Royal Hospital Chelsea and a hotel for The Dorchester at 45 Park Lane. Sequential projects along Sloane Street on behalf of the Cadogan Estate led to a creative understanding and interpretation of conservation policies. Working over almost 30 years, his practices reinvented multiple buildings whist retaining the memory of place. Thereby transforming the street, its uses and activity. This is a memoir of a life in design and architecture. It begins with a small boy being made to stand in a corner by his teacher because he was partially deaf. Aged 10, an operation restored his hearing and from there he went from strength to strength. Teenaged years were spent learning to draw at school at Alleyn’s in South London while being inspired by live performances by Bob Dylan, Jimi Hendrix, David Bowie and the Rolling Stones, often at intimate local venues such as the Bromley Court Hotel or Chislehurst Caves. Never a mere spectator, he created some of the first 1960s lightshows for bands including Pink Floyd and The Who. This would lead on to designing innovative recording studios for Roxy Music in the UK, then New York, Oslo and Paris. Houses for members of Roxy Music and four of Duran Duran in the 80s was fun and the source of entertaining anecdotes. Strong relationships led to commissions for touring stage sets for Supertramp, Roxy Music, the Moody Blues and Duran Duran. Collaborating with Nicky Haslam, he restored a major country house for Beatle Ringo Star and his wife, Barbara Bach. Whilst studying at Nottingham and Kingston, Paul set out on adventures across North Africa and Iran in the early 70s in search of sustainable indigenous architecture. Journeys almost impossible to experience today. He deals frankly with both the pride of success as well as the difficulties and frustrations of being a practising architect, including fights with planning officers, work with difficult clients, and projects that go awry, including major ones at Cliveden in Berkshire and Chelsea Barracks (where he worked with Thomas Heatherwick).

Inspiration and insight into the specific skills and approach to residential design were gleaned from student-day pilgrimage visits to Charles Rennie Macintosh’s famous Hill House on Loch Gare and Frank Lloyd Wright’s Falling Water in Pennsylvania. More than 30 private house designs for different families and characters lead on to inform major speculative residential projects in London, Hong Kong and Tokyo. Themes of placemaking are discussed in short essays about the Alhambra and London’s Inner Temple, both of which underline his core philosophy of ‘place’ being of more fundamental value to people’s lives than icons. The aim of the book is to provide a lavishly illustrated account of the hands-on difficulties of being an architect, whilst maintaining passion and vision. This book will hopefully be of use and inspirational to students and practising architects whilst its diverse episodes in the world of rock n’ roll will entertain a wider audience. Paul’s contribution to changing Chelsea will no doubt focus and broaden its appeal and market. “Mr Chelsea” is a memoir of a life well lived written with honesty and humanity. n

LEFT: 1 Hans Street RIGHT: Duke of York Square, King’s Road Chelsea BELOW: Cadogan Hall

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Issue 128 January-March 2024

BOOKS: LUBETKIN AND GOLDFINGER | NICHOLAS RUSSELL

Much of significance in the life stories of Lubetkin and Goldfinger occurred in the 1930s when they were young and modernism was still the future. Nicholas Russell tells their story Paperback £8.39 on Amazon

Nicholas Russell

Planning in London

Lubetkin and Goldfinger The Rise and Fall of British High-Rise Council Housing Tower blocks of council flats, relics from the mid-twentieth century, are dotted all over the country. For many people they are symbols of deprivation, overrun with antisocial children and drug dealing teenagers who terrorise the local population. They ask how such abominations could have been built? The culprits must surely be arrogant modernist architects in league with unfeeling local politicians who filled the towers with dysfunctional families. What were they all thinking? And yet high-rise, residential towers are going up again in city centres, not for deprived council tenants, but as homes for ambitious professionals who want to live close to city facilities. High-rise was and remains an important part of any solution to housing people decently in big towns and cities. The designers of mid-twentieth century high-rise council housing were not to blame for its demise. It was the result of cost-cutting and neglect by local authorities struggling to cope with social breakdown from rising unemployment, insecurity and homelessness in the 1970s and 1980s. The situation was not helped by the slow loss of faith in any role for the state in housing after its highpoint in the post-war Labour administration. Many architects of high-rise council housing in the three decades after the war have been forgotten. This is true for Berthold Lubetkin and Ernö Goldfinger, idealistic communist migrants from central Europe, arriving in the 1930s and in a good position to take central roles in post-war council housing design. They understood the virtues of the key construction material, steel reinforced concrete, which allowed tall towers to be built for an acceptable price. They also realised that residents of high-rise buildings needed to feel emotionally engaged with their homes and tried to ensure the buildings they designed were warm and welcoming places. In practice they had only minor roles in the post-war highrise boom because their design principles, aesthetic concerns and belief in quality reduced their opportunities as pressure increased to build housing cheaply and fast. Lubetkin is wellknown for the aphorism ‘nothing is too good for ordinary people’ but the cost of providing quality accommodation for most ordinary people proved beyond this country’s political will and economic capacity then (and now). Too many high-rise council estates were bad places to live. Poorly constructed, badly positioned and under maintained with minimal security and no adequate infrastructure and facilities, many such estates deteriorated so badly they had to be

demolished. Many that survive have been refurbished, often by covering them in cladding to improve insulation and hide the exposed concrete on their facades, which stains and cracks in Britain’s climate. That cladding, applied without adequate regulation, has proved a disaster, from the lethal Grenfell Tower fire in 2017 to the large number of unsafely clad buildings that have yet to receive remedial treatment. The old towers have been cursed a second time, the responsible architects and planners further vilified, their reputations buried deeper under the rubble that the towers may eventually become. Lubetkin, Goldfinger and their peers do not rest in peace. Like any type of building, concrete tower blocks are not perfect but the best of them provided (and still provide) good homes for large numbers of people. Lubetkin and Goldfinger tells these architects’ stories to re-evaluate their reputations. They were almost the same age, shared aspects of architectural

training and worked with similar design principles, although they did not like each other. They both came from wealthy assimilated Jewish backgrounds, arriving in this country before fascism drove many of their friends and colleagues to flee to Britain and beyond in the late 1930s. They were modernists without close association to the Bauhaus school in Germany, another possible reason for their neglect. They were also difficult and, at times, unpleasant characters. Their solutions to Britain’s chronic housing problems were flawed, though not necessarily disastrous. While the heyday of tower blocks was in the 1950s and 60s, much of significance in the life stories of Lubetkin and Goldfinger occurred in the 1930s when they were young and modernism was still the future. Our protagonists wanted to put modernist ideas to social use, believing that if people lived in good housing, they would be better citizens and lead happier and more fulfilled lives. That idea was certainly naive, but there is something in it, as most critics of Britain’s present housing crisis will admit. There is no doubt that bad housing is associated with bad social outcomes. So let’s encourage better (and higher) social building once again. n

FAR LEFT: Wells House front facade with main entrance and parabolic cover, Spa Green Estate, Finsbury LEFT: Stairwell, Mödling House, Cranbrook estate, Bethnal Green. A relatively subdued example of Lubetkin’s love of staircases.

Nicholas Russell was a university reader in science communication and college lecturer in biology and history of technology. Always interested in art and design, he keeps busy as a heritage volunteer spending several seasons as a National Trust guide at the architect Ernö Goldfinger’s house at Willow Road in Hampstead. He has also written on industrial invention and design exemplified by the history of the manufacturing firm, Russell Hobbs.

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Issue 128 January-March 2024

BOOKS: PROJECTS IN PROPERTY | DENIS MINNS

Projects In Property Author Denis Minns introduces his book on the business of residential property development Published October 2023 Hardback £35 + £4 P&P from bathpublishing.com

Denis Minns

This book is directed at small scale developers and those wishing to become small scale developers. It is not directed at the national house builders. Many of these have all the resources of a public company and a whole range of expert staff to turn to. The national developers are well placed to provide the volume of homes our country needs. So why do we need small scale developers? Small scale developers are defined as those who undertake small developments, both new builds and restoration projects. These developments are not of interest to national developers but they are more often sited in sustainable urban areas close to all the facilities and where there is strong and established demand. Potential development sites are often identified long before these sites become available for construction with small developers engaging in negotiations and often acquiring interests for site assembly. Small development sites frequently require demolition of obsolete buildings or restoration of existing buildings - it is rare for such sites to consist of open fields. Individual homes (which could include bespoke houses for clients) are regularly designed to enhance an existing neighbourhood rather than designed from a standard plans book. So why is it that the number of small developers active in the market is at an all-time low? As you read through this book you will begin to discoverWho are you? This book is directed at small scale developers and those wishing to become small scale developers. It is not directed at the national house builders. Many of these have all the resources of a public company and a whole range of expert staff to turn to. The national developers are well placed to provide the volume of homes our country needs. So why do we need small scale developers? Small scale developers are defined as those who undertake small developments, both new builds and restoration projects. These developments are not of interest to national developers but they are more often sited in sustainable urban areas close to all the facilities and where there is strong and established demand. Potential development sites are often identified long before these sites become available for construction with small developers engaging in negotiations and often acquiring interests for site assembly. Small development sites frequently require demolition of obsolete buildings or restoration of existing buildings - it is rare for such sites to consist of open fields. Individual homes (which could include bespoke houses for clients) are regularly designed to enhance an existing neighbourhood rather than designed from a standard plans book. So why is it that the number of small developers active in the market is at an all-time low? As you read through this book you will begin to discover the answer to this question. It is my

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hope that this book will help to identify issues and provide solutions. There is potentially a large number of small scale developers and those wishing to become involved in the industry. However, the complexities encountered by the small scale developer restrict the numbers willing to take the risk. If this book helps to de-mystify the process and assists the would-be developer in their quest, the country will benefit hugely from the creation of more new homes. It is my aim to see more small scale developers profiting from projects in property. n

Denis Minns is a chartered surveyor and a specialist in property law. He has been developing projects in property for over forty years both speculatively and for housing associations and custom build clients

Issue 128 January-March 2024

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Planning in London