Planning in London 115 OCTOBER-DECEMBER 2020

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The Journal of the London Planning & Development Forum Issue 115 October - December 2020

LEADERS page 5 CLIPBOARD page 32 ¡PILLO! page 35 ANDY ROGERS page 41 LP&DF on Planning for the Future and more page 44

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BUILD HOMES, BUILD JOBS, BUILD INNOVATION, Mike De’Ath on modular building page 54; Norman Foster on the future of cities page 11; What is planning for? Nicholas Boys Smith page 15; Guiding transformation around Oxford Street, Lucy Musgrave page 63; The wrong answers to the wrong questions? Hugh Ellis page 73 THE ESSENTIAL GUIDE TO DEVELOPMENT IN THE CAPITAL

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CONTENTS

page 5 LEADERS Doing the sums on London housing; If we want more subsidised housing we should subsidise it 7 HAMMERSMITH BRIDGE Competition for a new bridge

NORMAN FOSTER ON THE FUTURE OF CITIES page 11

11 OPINIONS Norman Foster on the future of cities; Propositional planning, Lee Mallett; What is planning for? Nicholas Boys Smith; Use Classes Order, Federica Buricco; Building beautiful, Ben Derbyshire; Bridging the Thames barrier, Paul Finch; Occupier relationships, Carl Whayman; Waste collection, Jonas Törnblom and Tony Yates; The Suburban Taskforce, Dimitrios Panayotopoulos-Tsiros and Lucy Natarajan; White Paper and Use Classes Order, Craig Blatchford and Gareth Fox; Commercial Property, Paul Howells; Permitted Development Rights, Gary Hoban; Airspace development, Mani Khiroya; The Planning White Paper, Iain Gilbey, Jamie Lockerbie and Sue Chadwick; New futures for the workplace, Paul Finch 30 LETTERS Mayor of London writes to the SoS on planning system changes; Zoning town centres from Michael Bach Wargaming for the Future, from Mark Willingale Excessive pointless pseudo scrutiny, from Alfred Munkenbeck Onward and upward not, from Andrew Rogers

LONDON PLANNING & DEVELOPMENT FORUM page 44

32 CLIPBOARD Action in the Old Kent Road; PD for Freeports; A new safeguarded wharf, Royal Primrose Wharf, to go ahead; Two-stage competition launched for Camden’s ‘high-line’; The City’s new civic hub for justice, policing and commercial activity; £12 billion not enough say boroughs 35 ¡PILLO! Needing an outfit to match; Only in the unhinged western system; The virtues of virtual architecture; Nicholas Boys Smith to head new body to create local design codes; Steve’s Bon Mots 36 PLANNING PERFORMANCE Decisions down 9% so far this year but catching up on lockdown’s 22% drop 41 ANDY ROGERS Planning spins out of control

SAVING THE HIGH STREET - THE COMMUNITY TAKEOVER, POLLY SWANN AND NEIL LEE page 68 COVER IMAGES courtesy HTA Design and factory image Legal & General www.planninginlondon.com

44 LONDON PLANNING & DEVELOPMENT FORUM Planning for the Future and other changes, including Government White Paper reforms; In Continues short, let planners free! – Paul Finch next page >>> Issue 115 October-December 2020

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CONTENTS CONTINUED

>>> 54 MODULAR BUILDING Build Homes, Build Jobs, Build Innovation, Mike De’Ath 58 HOUSING TARGETS The Standard Method has produced unlikely figures London Forum of Amenity Societies, Michael Bach 61 BUILDING SAFETY Wholesale reform for building control and safety, Stuart Brown 63 PUBLIC REALM Guiding transformation around Oxford Street, Lucy Musgrave 68 SAVING THE HIGH STREET The community takeover, Polly Swann and Neil Lee

73 THE PLANNING WHITE PAPER The wrong answers to the wrong questions? Hugh Ellis 76 SUBURBAN LIVING Reappraising London’s suburbs, Russell Curtis 79 BOOKS: Sustainable Approaches to Urban Transport, Dinesh Mohan and Geetam Tiwari; The Goddess – La Déesse, Christian Sumi; Simon Jenkins’ A Short History of London, Reviewed by Nigel Moor 87 DIRECTORY Planning and Environment Reference Guide 90 SUBSCRIPTION FORM

70 55+ HOUSING COMMUNITIES A new dawn for housing a more mature city, Lars Christian

90 ADVICE Consultants and services BOOKS: The Goddess – La Déesse, Christian Sumi; page 79

Publishing Editors: Brian Waters, Paul Finch and Lee Mallett editor@planninginlondon.com, planninginlondon@mac.com

ISSN 1366-9672 (PRINT) ISSN 2053-4124 (DIGITAL) Issue 115 October - December 2020 www.planninginlondon.com

The London Planning and Development Forum (LPDF) The LPDF 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. It is a sounding board for the development of planning policy in the capital, used by both the public and private sector. Agendas and minutes are at planninginlondon.com. To attend please advise hon. secretary Drummond Robson: robplan@btconnect.com The LPDF is administered by: Honorary Secretary: Drummond Robson MRTPI,

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41 Fitzjohn Avenue, Barnet, Herts EN5 2HN Tel: 0208 449 3113 Fax: 0208 440 2015: robplan@btconnect.com Chairman: Brian Waters MA DipArch (Cantab) DipTP RIBA MRTPI ACArch P.ACA FRSA Principal: The Boisot Waters Cohen Partnership brian@bwcp.co.uk Member bodies Association of Consultant Architects Association of London Borough Planning Officers/Planning Officers’ Society London Councils British Property Federation Design Council CABE City of London Law Society Confederation for British Industry

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

MHCLG 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 Transport for London London University (The Bartlett, UCL) University of Westminster Affiliated members: Planning Aid for London London Metropolitan University

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.  Made on a Mac

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LEADERS

Doing the sums on London housing There is a strong case for rebalancing responsibility for housing provision, whereby the private sector is under no obligation whatsoever to sell homes at below market value

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

The debate is ongoing about the appropriate number of homes as a construction target for London, prompted by the planning White Paper and accompanying algorithm suggesting how much should go where. The Tory shires are up in arms over what is being suggested for them, but then so are the outer London boroughs, some central ones like Kensington & Chelsea, and of course Mayor Khant’s (CORRECT) Greater London Authority. Everybody accepts there is a housing shortage but nobody beyond government will accept any responsibility for doing something about it. This is pitiful. The suggested figure of 93,000 homes a year for London may get modified down, but if it goes down too much, the results will be disastrous for another generation of Londoners and incomers. In any event, is the number so wrong? It looks in round terms like 3,000 units per borough per year. Given that most boroughs are the size of towns outside the capital, does that look like an impossible annual total? No – provided the public sector starts doing its bit. All the arguments suggesting the number is impossible assume that everything will be initiated and delivered by the private sector, a mayoral obsession which has failed to produce the goods under Livingstone, Johnson and now Khan. With a few honourable exceptions, boroughs themselves have no proactive plans to deliver what is necessary, particularly in respect of affordable housing, which seems of little interest to a Conservative government obsessed with handing out public subsidies to anyone except the most needy – because the latter are not seen as Conservative voters. Mrs Thatcher must be turning in her grave. The public sector has the land, buildings, finance and planning powers to get a grip on housing provision, but seems remarkably reluctant to stand up for itself, instead moaning about allowing smaller builders to develop up to 40 homes without having to provide absurdly-named ‘affordable’ units. There is a strong case for rebalancing responsibility for housing provision, whereby the private sector is under no obligation whatsoever to sell homes at below market value, any more than bakers are required to sell loaves at a discounted ‘affordable’ price. It is noticeable that we do not have a bread shortage. Market failure to provide a sufficiency of new dwellings each year should trigger public procurement to make up the shortfall, a policy which kept supply and demand in some form of balance in the capital for a century, but now seems strangely forgotten. As for worries about social ghettos being recreated in the form of council estates, they can be assuaged by simply requiring a percentage of new council homes to be sold or privately rented. >>> Perhaps 50 per cent would be an appropriate figure. n

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LEADERS

If we want more subsidised housing we should subsidise it There is demagogic madness in requiring developers to do the state's work

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The Local Government Association has warned that councils 'could see an almost 50% reduction' in affordable housing delivery if the White Paper's proposals to exempt smaller sites of less than 40 or 50 homes from the need to provide on-site affordable homes. This would, claims the LGA, have resulted in 30,000 fewer affordable homes looking at similar size schemes of between 10 and 49 units in the last five years. But this is to ignore how much more housing might have been provided had this tax on private developers not been in place. More money might have been raised in the last 20 years had the land value uplift been taxed at non-negotiable, national rates in a simpler, easier to collect and spend, fashion. And then distributed according to need to councils that made a good case for re-investing it. Shoehorning subsidised affordable homes onto small sites, requiring dual cores and separate management regimes, added huge complexity to the supply side and did more harm than the proposed changes to the rules might. Lack of clarity and simplicity screwed up the supply side of the housing market and made a misery of finding a home. It's not been fun for developers, or planners. No-one argues about the need for socially mixed communities, and for local people to remain living in their communities, but lack of supply is the biggest obstacle to all worthy ambitions. There is demagogic madness in requiring developers to do the state's work. You won't lose votes if you are tough on developers. But you won't get the homes you want. If we want more subsidised housing we should subsidise it. Everyone accepts investors benefitting from a democratically approved uplift in value should contribute to the burden their development places on public services and infrastructure.But smaller sites cannot realistically carry this burden, and to work out what they can carry has created a substantial new industry that has diverted resources to this end. In the process we have lost a generation of small builder/developers and all but extinguished the small site market. Only the big beasts remain. Local authorities have been shackled in how they can unlock their own ageing residential portfolios, how they value them, how they spend receipts, how they can borrow, what grants they can give, where they raise development finance. No similar-sized private provider would dare face shareholders, or customers, if the capital employed in creating and providing this basic social commodity was treated in such a shoddy fashion. There should be more public accountability for these assets and their management. Councils are fighting hard to establish a more dynamic approach. More money is being made available. But billions remains hidden, tied up in public sector portfolios, of councils and Registered Providers. Councils and RPs are insufficiently incentivised and too tightly restricted to do their duty by the tax capital we've all invested in them. The problem is of course much bigger than tweaking affordable housing planning rules. This Government, any government, should think harder about the real fiscal mechanics of housing. n


HAMMERSMITH BRIDGE: COMPETITION FOR A NEW BRIDGE

‘Don’t faff around, knock it down and build a new structure that is fit for purpose’ Perhaps you could run a design competition? asks Mike Adams writing to the editor

Well, YES! Readers are invited to submit ideas for a replacement structure to carry traffic, cycles and pedestrians. As last year please fit all information on a single sheet capable of reproduction at A3 landscape. Tim Beckett, winner of our challenge for a temporary crossing, as reported in the Evening Standard [over the page], has met resistance despite the PLA commenting in Planning in London: “The scheme Looks, in principle, acceptable, but this is on the basis that discussions would be required on the proposed pier locations toensure river traffic could continue to pass through safely.“ See PiL111 October 2019. As of 13 August 2020, the bridge is now closed, even to pedestrians and river traffic below. A ferry is contemplated. As newspaper correspondence has said, this makes London look ‘thirdworld’... and see Paul Finch’s column a few pages on. Tim Beckett writes: “There is certainly a debate to be had about whether to repair the existing bridge or to replace it with a new one. Replacement is likely to be quicker and cheaper as well as delivering more functionality, such as carrying double decker buses. There ought to be no reason why a new bridge should not be as inspiring as the old one so an architectural competition seems a pretty good idea. However, in general I think architects, as a profession, do far too much for nothing (engineers are usually

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more canny) so if the authorities can come up with some prize money that would be better still. The situation has obviously changed now that the bridge has been closed to all traffic and the need for a temporary alternative crossing is urgent. I have concluded that no temporary bridge can be built quickly enough since it would need to go through the planning system and even TfL's proposed temporary footbridge has not yet been submitted for planning. Indeed, TfL have said they have paused work on preparing its application pending the government's agreement to funding both the temporary bridge and the repairs to the existing bridge. So I have worked up a proposal for a temporary ferry service with Thames Clippers who have 20 years’ experience of running a similar ferry operation at Rotherhithe. The scheme uses two second-hand piers which are available on the river. Thames Clippers have three 62 seat vessels available so two could be in service at peak times with one in reserve. This would give a passenger capacity of 1,200/hr in both directions. The vessels can also carry bicycles and wheelchairs. Under the PLA Act 1968 the Authority has permitted development rights to install mooring and berthing facilities so, if the pier installation is done by or on behalf of the PLA, it does not need planning permission. The works still need marine consents from >>>

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HAMMERSMITH BRIDGE: COMPETITION FOR A NEW BRIDGE RIGHT: Extract from PiL 111: Mike Adams’ contribution OPPOSITE & OVERPAGE: reports on Tim Beckett’s in Evening Standard and New Civil Engineer BELOW: It became a feature of the General Election too

>>> the PLA, MMO and EA but, if treated as emergency works these could be obtained in four weeks with the ferry up and running in another four. On 27 August we put this proposal to both councils, the PLA and TfL. We had a second meeting on 21 September to explain it again. The councils tell me they are looking at a number of other proposals although I very much doubt whether any other one can meet the passenger demand quicker or cheaper than our scheme while satisfying TfL’s safety standards for ferries. I find it frustrating that all the statutory authorities involved with Hammersmith Bridge have adopted a passive role towards the problem. It is now eight weeks since the total closure of the bridge but there has been no brief issued saying what service requirements a temporary river crossing should meet and there has been no request to the industry for proposals. All the proposals that have been submitted are unsolicited and, unsurprisingly, vary greatly in their capability. Indeed, so far, Planning in London is the only organisation that has issued an invitation for proposals!” Tim concludes: “As we approach the anniversary of PiL's publication of quick fix ideas I look forward to your next report on it!”

COMPETITION DEADLINE 5TH DECEMBER. Send your entry to editor@planninginlondon.com

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HAMMERSMITH BRIDGE: COMPETITION FOR A NEW BRIDGE

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OPINION: THE FUTURE OF CITIES | NORMAN FOSTER

Norman Foster on the future of cities The pandemic could accelerate significant change Norman Foster told the first UN Forum of Mayors First, I would like to congratulate the UN on recognising, through this gathering, the importance of cities, their mayors and civic leaders. Cities are the future of our society – of our civilisation. The words are interchangeable – civic, civilised, cities, citizens. We all know that the world is urban but, in 30 years’ time, 2.5 billion more people will live in cities. Consider the pace of urbanisation before this pandemic, the equivalent of eight cities the size of New York were emerging annually around the world. In two years, 2011-13, China consumed more concrete than America used in the entire 20th century. Why? Because they are generators of wealth, opportunity, liberation and innovation. But these powerhouses of our future need day-to -day running – leadership, vision and inspiration. And here I pay tribute to you – the Mayors and the teams that you lead – you are where the action is. Over six decades as an architect and urbanist, through my practice and more recently through my foundation – I have engaged directly with many city mayors and regional governors – so I speak from the heart when I talk about the challenges that you face. I have seen first-hand how, with courage and foresight, that power can be used to change cities for the good of

The UN Forum of Mayors will bring together city leaders from Europe, North America, Central Asia and the Caucasus to address the key challenges of our time. Under this year’s theme “City action for a resilient future”, mayors will have their hands full discussing critical questions: What will our urban life look like after the global pandemic? How can cities spur ambitious climate action? How can we become more sustainability while leaving no one behind?

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their citizens. I can think back to working with Pasqual Maragall in Barcelona to get rival TV companies to occupy one single communication tower to avoid a mess on the Barcelona skyline. Often, national leaders are just too removed from the front line to get things done. Another of the many mayors who I have worked with is Mike Bloomberg, who argues that with collaboration cities, business and citizens can succeed in battling the big issue of our time, notably climate change – because governments are simply too slow and sclerotic. Where do pandemics come in this discourse? Is covid-19 going to change our cities? I suggest that it might seem so now, but in the wider arc of history, the answer is no. Instead of change, it has merely hastened, accelerated, trends of change that were already apparent before the pandemic. The only constant is change and cities are forever evolving, learning from each other across continents. Changed by the technologies of their times and by leaders who have the vision to embrace them. Take London as an example. The Great Fire, 1666, created building codes that led to fireproof brick construction. The cholera epidemic, of the mid-19th century, cleaned up the Thames from an open sewer and was the birth of modern sanitisation. In its wake came the healthy dimension of public parks. Then tuberculosis struck and helped the birth of the modern movement in architecture – big windows, sunlight, terraces, white and clean. But every one of those consequences – fireproof construction, sewers, green parks, modernism – would have happened anyway and not just in London but in cities around the world, because cities learn from each other – each crisis hastened and magnified the inevitable. Is covid-19 going to change our cities? I suggest that it might seem so now, but in the wider arc of history, the answer is no It has been said: if you want to look far ahead, then first look far back. History tells us that the future is not two metre distancing. The last major pandemic 1918-20, claimed more lives and young ones, created deserted city centres, face masks, lockdowns and quarantines. Sounds familiar? It also her-

Norman Foster is founder of architects Foster + Partners

alded the social and cultural revolution of the 1920s, with big public gathering spaces, department stores, cinemas and stadia. What, after this pandemic, will the equivalents be for our coming age? What defines us? It’s mobility. Mobility of people, goods and information at a time of climate change and decarbonisation. Look at some trends of change in mobility. Some with us – some on the way. Many are being implemented by the mayors here today: • Clean electric vehicles – away from fossil driven. • Induction charging on the move. • Driverless, densely packed, nose-to-tail. • Young people less interested in ownership. • Their embrace of ride sharing and on-demand services like Uber. • Rise of e-bikes and scooters. • Prospect of drone technology to move goods and people. • Much less space needed for vehicles. • Car parks could be obsolete. • Monorails could have a new future Look at some trends of change in the patterns of working: • More working from home or a third place, which could be an electronic Starbucks in the high street or a retreat in the high Alps. • A greater appreciation of the benefits and need for face-to -face contact in the traditional workplace, but with a far greater emphasis on social spaces and healthy environmental systems. • More flexible hours and less travel. We now have scientific evidence to prove that green buildings with natural ventilation are not only good for your health, but they enable you to perform better. These kinds of buildings are now the exception. But they could become mainstream. We also have proof that green spaces in cities –

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however big or small – contribute to health and wellbeing. I have worked with civic leaders over several decades in the German Duisburg to bring green and progression to what could have been a rust belt. Finally, some trends on industry and culture: • Globalisation has lifted billions out of poverty but created local rust belt communities of despair. So, a better balance of local and global is on the way and each city could play a part. • Industry is no longer about smokestacks. Urban manufacturing is clean, creates jobs and can reinvigorate the economy. • Encouraging culture in spaces for the arts is another economic lifeline. • Urban farming once a reality in cities past, could enjoy a renaissance in the future – hydroponics uses a fraction of precious water, make for greater yields to deliver fresher, cheaper, more flavourful food on the city’s doorstep. Imagine an urban version of the farmers’ market. An obsolete multistorey car park makes the ideal urban farm. The cumulative effect of just some of these many trends are transforming city centres and local neighbourhoods, making them quieter, cleaner, safer, healthier, more friendly, walkable, bikeable and, if the opportunity is grasped, to be greener. As less space is needed for transport, we could see increased paved public space, avenues of trees, mini parks, new terraces using radiant technology to be cooler in summer, warmer in winter. Trees beautify as well as absorbing Co2 to improve the air quality. This is what I mean when I say that covid-19 has accelerated more sustainable and equitable trends. Many of you at this event have embraced change with enthusiasm and, through leadership, have brought your citizens with you – setting new standards for all. What is new? Attitudes – a public attitude of mind that is more open to change than ever before. Neighbourhoods have seen a resurgence in appeal with the tag of the “15-minute city” – where living, working, dining, learning, being entertained and entertaining can all happen within walking distance. This is not new, but it has been boosted by the

pandemic, and by design could be improved. Some dense communities have not seen higher infection rates than the suburbs. The problem is dense cramped households, which could be within cities or suburbs alike – already an issue before the pandemic. Affordable housing remains a challenge and is linked to the homeless issue. Some of these trends are not new. I led the changes that transformed Trafalgar Square, in the heart of London, and rescued the Port of Marseilles from traffic, to bring it back to a neighbourhood. I witnessed in America Boston’s big dig, in Europe Madrid’s Rio Project and in Asia Seoul’s city centre – all have created vast new green parks out of highways from the past. So, what is new? Attitudes – a public attitude of mind that is more open to change than ever before and with that a new range of opportunities to improve the quality of life for urban citizens as well as helping to combat climate change. Buildings and transportation, between them, account for 42 per cent of greenhouse gas emissions.

So the dense, compact pedestrian-friendly European city is a model of sustainability and sociability, compared with the sprawling car borne gas guzzling metropolis. Now is the time to make it even more compact and liveable. City planning should not be two-dimensional paperwork – the reality is in three dimensions and should be modelled accordingly. Public spaces are outdoor rooms. Culture, clean industry, leisure, commerce, shopping and housing can all co-exist side by side but that needs changing attitudes to zoning. On the question of housing, if the market is unable to address issues of equality with the right kind of affordable accommodation then, as in the past, that could be a civic initiative. When I was a young student, some of the most outstanding public housing was commissioned by city authorities. In the move to making cities self-sustaining, barriers between different interest groups and professions need to be relaxed in a holistic approach. An obvious example is when those concerned with waste work with the energy sector to convert waste to energy – but there are many other examples of such synergies. The pandemic is a tragic event for so many. We have all lost loved ones and for the moment the virus continues. But, stepping back, I am confident that cities will prove their resilience and appeal – they will bounce back stronger and better as a consequence. We are all of us grateful for the untiring efforts and leadership that you, the mayors and civic leaders are achieving in these difficult times and looking beyond into a bright future. n IMAGES: Foster ideas for greening our streets, a before [LEFT] and after [ABOVE] study by their urban design team. Norman Foster photo credit: Frederic Aranda

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OPINION: PROPOSITIONAL PLANNING | LEE MALLETT

Using design for real planning The White Paper's proposed areas of Growth, Renewal and Protection will need to use 'design by research' and propositional planning, not just development management, to work well argues Lee Mallett The chief proposition in the White Paper, Planning for the Future, is that development should be permitted in areas of Growth, Renewal (or Growth and Renewal) and carefully proscribed in protected areas. Local plans should also take 30 months to resolve, not decades. Both the Bishop and Farrell reviews (of 2011 and 2014) advocated a revival of propositional planning, not a return to the 'Utopian' planning of the post-war period, but the use of Britain's wealth of design skills to anticipate and accommodate needs brought about by change. The fundamental proposition of the 1947 Act was that planning should mediate fairly and democratically how we plan for the future. To deliver on that promise, which remains socially valid, our system needs to 'get in front of' what we need. Not to react late or to preserve vested interests. We now also accept the imperative to be ecologically, socially and economically sustainable. The White Paper's propositions are rooted in the belief planning has become a prophylactic, when we need it to enable. Sir Terry Farrell's propositions over the decades have showed how we might use propositional design and planning to create development frameworks. These can be codified to modulate detailed responses. Shortly after the Bishop and Farrell reviews I interviewed key figures for an MA thesis. They provided some fuel for conclusions on how we might restore propositional planning as a key tool in a more intelligent and liberal planning system that didn't focus so much on development management. National policy The NPPF explicitly supports the idea that design is valued, and the White Paper concurs: 'there is not enough focus on design'. There are no legislative excuses for the planning system to avoid using design as a tool to discover potential, whether in partnership with the private sector or unilaterally. But what the NPPF does not do, nor the White Paper (and nor did the Bishop and Farrell reviews) is spell out how local authorities might do it, or how

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the Government might use design to plan. This seems odd when you consider how much design is clearly valued in other areas of our lives - personified perhaps in the late Sir Terence Conran. New local plans may have to be produced in 30 months. Local development frameworks and highlevel design codes will be needed, or those plans will be hollow promises riddled with planning risk.

Netherlands v. England Around the same time as the Bishop and Farrell reviews, five Dutch ministries jointly published a joint Action Agenda (imagine that) for Architecture and Spatial Design which set out the specific efforts that central government would make to ensure these core skills 'contribute excellently and effectively to spatial and cultural development and strengthen our international economic position'. It set out a series of key urban design tasks, using 'design by research' and shifted the emphasis of national policy to 'transform existing cities and landscapes. The new tasks in building and in areas are infill development, embedding, renovation, reallocation and redevelopment. ‘From building to city, and from road to landscape, the emphasis will be on transforming urban space already utilised.' This generated a new emphasis for policy at the heart of government that recognised the role of design in achieving it. ‘The White Paper's proposals for a focus on Growth, Renewal and Protection will require a similar trans-governmental focus with local propositional research by design, to discover more precisely what that might mean for each area. It needs spelling out. Design by research Planners, in partnership with architects, developers, communities and stakeholders, will need to explore ideas to create development frameworks and design codes for areas of Growth, Renewal and Protection. Planners can co-ordinate and contribute to 'light touch' design to research spatial and physical problems and suggest opportunities quickly and inexpensively without turning it into official policy-speak.

Lee Mallett is an urban regeneration consultant and joint publishing editor of Planning in London

More resources Planning will need more resources to pursue this shift in focus. The White Paper refers to application fees being increased or diverted. Perhaps extra investment could come from new national Infrastructure Levy receipts. No use having that money without having figured out where it's going to go. Higher status Planning's low status is a problem. David Cameron's reductive comment that planners are 'the enemy of enterprise' remains misguided. Planners need to take back a higher profile in local and national debate, not take a back seat behind politicians. Finn Williams at Public Practice has been doing a good job. A bigger, louder push is required. The greatest enabler There are plenty of examples of how design has been used as a research tool. Our system remains the best mechanism we have for managing competing interests. That's why we invented it and why we need it, now especially, to do what it is supposed to do, to improve society and our response to climate change. It might be a way of reinvigorating democracy. And far from being an 'enemy of enterprise', it could be its greatest enabler. If the White Paper's ideas are to translate into a better system, the Act that follows must restore and resource propositional planning as the heart of what Planners do, and what Planning does. n


OPINION: WHAT IS PLANNING FOR? | NICHOLAS BOYS SMITH

Shield or sword? Nicholas Boys Smith welcomes the government’s white paper on planning reform which asks profound questions about what our planning system is for In the Building Better Building Beautiful Commission’s final report, my co-chair, the late Sir Roger Scruton, wrote that “beauty must become the natural result of working within our planning system” not “a cost, to be negotiated away once planning permission has been obtained.” We need, he argued, to turn our planning system round, “from its existing role as a shield against the worst, to its future role as a champion of the best.” Does the Government’s planning white paper start to achieve this? I think it does. It’s certainly ambitious. That brings risk (“very courageous Minister”) but it’s getting three big things right. Firstly, it accepts that the popular beauty and liveability of the new settlements that we create matters. It matters for the public acceptance of their creation and for the lives that our children and children’s children will lead in them. There’s a growing corpus of evidence that many of the components that make places beautiful (such as walkable streets, ‘gentle density’ and street trees) also make them healthy, happy and sustainable. Far too few new places achieve this, less than a quarter in one recent study. That must change with more visual local plans setting popular ‘pattern books’ for what’s acceptable. Secondly, the white paper is right that we need to create a more predictable level playing field. There is a smoking gun if you want to understand why we don’t build enough homes in England. It’s that our system operates on a uniquely discretionary case-by-case basis. This creates greater uncertainty which has increased planning risk, pushed up the price of permissioned land and acted as a rising barrier to entry. It’s no coincidence that the proportion of homes delivered by small builders market is declining (12% and falling); that only 10% of our homes are self-built versus a 50% European average; or that modular construction is struggling to gain a foothold. Finally, the white paper is right that we need to ‘bring the democracy forward’ and re-invent the ambition, depth and breadth with which councils engage publicly in the creation of local plans. Creating shorter, more powerful and more visual local plans will help but councils will also need to reinvent their use of digi-

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tal technology. It does not stop there. I have huge sympathy with public sector planners. The vast majority, certainly of those I have met and worked with, are well-meaning, hard-working and under-paid. This white paper could be good for them too as well as for the quantity and quality of the places we create. One very experienced London official said to me last year: ‘I was brainwashed into the world of thinking that development control is planning but it isn’t. The planmaking exercise has been marginalised.’ A process which has clearer, more map-based and more visual local plans and better digital engagement would free up planners better to support the public and not just be development control officers on a depressing and needless treadmill treating ever planning application as if it was bespoke. This would be good. Implemented well, these proposals should help to move planning from a culture of fear to a culture of

There is a smoking gun if you want to understand why we don’t build enough homes in England. It’s that our system operates on a uniquely discretionary case-by-case basis. This creates greater uncertainty which has increased planning risk, pushed up the price of permissioned land and acted as a rising barrier to entry. affirmation. We are heirs to beautiful towns, set in incomparable countryside. Our goal should be to pass that heritage to our successors, not depleted but enhanced. Quantity matters. But so does quality. Some predictable voices came out immediately criticising the report in blood-curdling terms. Most appear not to have read it before they spoke, not to understand the politics or economics of development

Nicholas Boys Smith is the director of Create Streets and was co-chair of the Building Better Building Beautiful Commission alongside the late Sir Roger Scruton

or to be so wedded to the 1940s approach that they refuse to countenance change even when it is palpably and desperately needed. (To be fair, there are also some good questions emerging as well – above all on the inescapable tension between meeting housing demand and ‘levelling up.’) But the ‘end of the world’ style critics (some of whom are not just shouty journalists but working for organisations that claim to care about planning and design) need to be able to answer these questions: • What is so different about how we live in England to most of the rest of the world that means we cannot plan strategically but have to focus on every decision case-by case? • Why do they think that the UK housing market is so concentrated? Might it possibly have anything to do with the near unique way we run our chaotic planning system? • Why do they think there are so few self-builders in the UK? • The UK is a pretty entrepreneurial place: why is modular build struggling to take off? • Why should we not move to public engagement that is profoundly more digitally enabled? If they don’t have convincing answers to these questions which don’t involve the high-risk nature of our planning system (and I have not seen any) then I would politely urge them to roll their sleeves up and help fill in the detail rather than just shouting ‘fire’ from the smokeless rooftops. There are risks. But there’s also every reason to hope that a revitalised planning system would help us again aspire, with Clough Williams-Ellis, for a ‘happy awareness of beauty’ to be ‘the everyday condition of us all.’ n https://www.createstreets.com/create-communities/

Issue 115 October-December 2020

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OPINION: USE CLASSES ORDER | FEDERICA BURICCO

Flexible legislation designed for a more flexible world Local doesn’t necessarily mean better so it is important that people can enjoy places where they feel identified, safe, and accepted says Federica Buricco The Government’s new legislation regarding flexibility for the Town and Country Planning (Use Classes) Order has come as welcome news to the urban design community. The way we live, shop and work has changed significantly, a fact that has been drastically accelerated by Covid-19 in the past few months, and it is reassuring to see planning policy now catching up. It is a landmark move, which I hope will also form the catalyst for change across Europe. This is not an entirely new concept though. As custodians of the built environment, for decades we have sought to achieve “architectural flexibility” - the ability to adapt the space, layout, and even the structure of a building to meet evolving needs. Now we have the legislative green light to do so. High streets in the 17th and 18th centuries were hubs of mixed-use activity that kept them vibrant, yet over the years they have become stale and rigid for a multitude of reasons, whether that is inflexible planning, occupation by massive retailers and large chain stores, or a move away from the high street to shopping centres and online, the combination of which has led to demise of our high street. So how do we make it work? Design changes for the future In the same way that we are seeing more mixtures and nuances in the way we live, work and express ourselves, I hope this overhaul will mean that the days of inflexible, rigid zoning and singleuse buildings are over. All future buildings will need to be designed with flexibility in mind and with the view that they could adapt from lease to lease and accommodate a more expansive range of uses. As a result we can expect modular construction to continue growing in popularity owing to its speed and adaptability, likewise the design of easily dividable spaces with moveable partition walls and multipurpose furniture that allow spaces to flourish under various guises will be key. Goodbye to the long lease While we can make design changes to ensure our buildings are future-proofed and flexible in line with the new planning guidance, for lasting

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change to happen we need to see landlords and asset managers also embrace this new way of thinking. The days of locking in an anchor tenant for eight-10 years are over, today flexibility and agility must come first – think rotating pop ups, cultural and experiential retail that creates memorable experiences for consumers. Camden Market in north London is a prime example of this, with its pop up culture and varied calendar that blends retail with performance, food and beverage, labs, makers’ studios and co-working spaces, retains its appeal with an ever-evolving offer that provides enduring value to both operators and visitors. Collaboration will be key here; landlords who have historically focused on their own assets and portfolios would do better to form co-operatives

While this new found flexibility is welcome, it is perfectly possible to have too much of a good thing. In the bid to mix it up and survive, we risk oversupply of any one offering and work together to bring footfall, vibrancy and profits back to our high streets. Ultimately, they are championing the same cause and carving a new path of less resistance for retail.

Everything in moderation While this new found flexibility is welcome, it is perfectly possible to have too much of a good thing. In the bid to mix it up and survive, we risk oversupply of any one offering; five trendy new gyms appearing in place of failed retail isn’t going to achieve the balance we need. We need shops, co-working spaces, gyms, cafes and more to bring the balance back and we must embrace the concept of multi-use spaces – a crèche in the morning, yoga studio during the day and auditorium at night, for example.

Federica Buricco is an Associate at CallisonRTKL

Museums, libraries and galleries are a modern day illustration of how this multi-use flexibility can foster prosperity; the rise of in-house coffee shops, cinemas, pop-up markets, community classes and evening events has helped ensure their future and capture a broader audience. Our high streets must now follow suite. Conversion of redundant space to residential, although not covered under this specific legislation, will also help add to the mix as long as it is done in a measured way where quality assurances can be made.

The rise of localism The Covid-19 pandemic forced us to revaluate the way we live our lives and has shone a light on localism. We are already seeing employers of all sizes making commitments to more flexible ways of working with less time required in the office. We have less of a want or need to make extended travel into central London and we have seen the ‘go local’ community ethos really gather momentum, meaning that local high streets are primed for a comeback. In fact, for many of the neighbourhood grocers, butchers, delicatessens and similar the last few months have been some of their most profitable, with people favouring the independents and boutique operators over the mass chains and crowds. It is clear that if local doesn’t necessarily mean better, it is important that people can enjoy places where they feel identified, safe, and accepted. With legislation in place to further encourage and support this, plus a renewed consumer appetite for change, the future is looking brighter. We mustn’t rest on our laurels now though, with the success of this new legislation now dependent on a concerted effort from the entire stakeholder map, whether local authorities, urban designers, landlords, asset managers or occupiers. n


OPINION: BUILDING BEAUTIFUL | BEN DERBYSHIRE

Beauty, privacy and cupboards What do the people really want? Ben Derbyshire asks how we should approach a nationwide design code It is now received wisdom that resistance to new housing development would be greatly reduced if only local objectors could be convinced of the quality of homes to be constructed in their neighbourhoods. The Prince of Wales sums this up in his foreword to the Prince’s Foundation publication Housing Communities: What People Want”. He says: “Local communities must be involved at the earliest stage, and as the key partners. If this happens there is a chance that we might see rather less campaigning against the things people don’t want and rather more pro-active campaigning for the things they do want.” Much the same sentiment has found its way into the government-sponsored Living with Beauty report, widely endorsed by the secretary of state, Robert Jenrick, which asserts investment is needed into the values it avers matter most to people – beauty, community, history, landscape. As a consequence, the highly respected practice, Urbed (Urbanism, Environment and Design), has been appointed by MHCLG to come up with a national model urban design code, capable of delivering these outcomes. I understand Urbed’s draft proposal will be put out for consultation this autumn. It’s really important that these proposals are not subverted by a political sensibility with its roots in a conservative predilection for all things “traditional” and lest the stylistic preferences of the traditionalists impose a presumption in favour of Widow Twankey aesthetics on what should otherwise be a very worthwhile formula for finding out what local people really want in their neighbourhoods. I am sure I am not alone in harbouring a suspicion that the “evidenced-based” proposition put forward by some lobbyists has more than a hint of tendentious historicism in the case made for traditional aesthetics as the key to popular development. But happily this is not a new topic. And there is plenty of evidence to be found from recent research that shows that a traditional aesthetic isn’t the primary factor in garnering local support. As president of the RIBA and chair of HTA Design (designers and placemakers in the built environment), I have often described the quest for quality in the built environment as the pursuit of planning and

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design that gives rise to human wellbeing and a positive relationship with the natural world. Three studies confirm that the lay public have a wide view of what outcomes they are seeking from the development of new homes and neighbourhoods – and beauty is just one of these. So in seeking support the design code formula must obviously spread its enquiry wider than just considering what local people want development to look like. A Cabe study, What Home Buyers Want (2005), found that the first concern is the quality of an area, notably in terms of access to facilities and services, a sense of community, safety and security. Space, both inside and outside the home, ease of access and privacy are important criteria, as is convenience of parking. All these issues are addressed in the report before it gets to external appearance where Cabe concluded

Traditional architecture or ’houses that look like houses’ came sixth and last in the ranking of spontaneous likes...the first concern is the quality of an area, notably in terms of access to facilities and services, a sense of community, safety and security that the key to acceptability appears to be not the style but rather the richness of the architecture, so that a modern architecture that is not minimalist and is rich in detail is regarded as equally desirable. The authors also note that presence of high-quality landscaping increases aesthetic approval. Research carried out for the RIBA’s Future Homes Commission (2012) concluded that good-sized rooms, storage, natural light, privacy and sound insulation and the flexibility to accommodate future needs and family members are the most important criteria for judging the quality of a home. High levels of natural light stands out as a consideration with 63

Ben Derbyshire is immediate past president of the RIBA and chairman of HTA Design

per cent of respondents regarding this as of the highest importance. After that, space in rooms and corridors (51 per cent), privacy and freedom from noise outside (49 per cent), outside space (47 per cent). Neighbourhood design follows at 43 per cent, alongside privacy and noise insulation inside the home and security. Adequate storage scores 42 per cent. The Prince’s Foundation report of 2014, mentioned earlier, is based on findings from 26 “enquiry by design” projects in which local residents are engaged in the design of new development or regeneration projects in the course of which their preferences are expressed in consultation workshops and interviews. “Traditional architecture” or “houses that look like houses” came sixth and last in the ranking of spontaneous likes expressed in workshops, behind green space, a revitalised local economy, sense of place and character, integration with context and a village-like feel. The report’s summary cites traditional architecture based on local precedent and retention of local identity as key principles for new developments, but it is important to recognise that these criteria rank among 13 other recommendations. I would be the last to argue that the external appearance of development is unimportant. But it is crucial that the national design code recognises a critical observation of the Cabe study that, “Consumers are smart – it is not a question of ‘educating’ them but of ensuring that the potential benefits (of development) are in fact realised”. These reports make it abundantly clear that there are many aspects of housing development that make it attractive to people. If the object of the exercise is to encourage the conversion of NIMBYS to YIMBYS on the basis of an understanding that adjacent development is of a quality that will meet local aspirations, there is more to it than what it looks like. n First published in BDonline with kind consent

Issue 115 October-December 2020

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OPINION: BRIDGING THE THAMES BARRIER | PAUL FINCH

London is closed Currently, the experience of travelling in what is supposed to be a ‘world city’ is evidence that it is anything but says Paul Finch I voted for Sadiq Khan, both as my former constituency MP, and when he stood as a candidate to be Mayor of London. So what follows is not generic criticism from a political critic, but a plea from a Londoner who would like the mayor to ensure that this great capital remains just that. Currently, the experience of travelling in what is supposed to be a ‘world city’ is evidence that it is anything but: instead a messy amalgam of failed ideas, operational incompetence and political indifference. Last month, in what was a symbolic moment, Tower Bridge became stuck, having opened to allow a ‘tall ship’ through but then jamming. The police, invariably absent when traffic problems occur in the capital, on this occasion eventually arrived on the scene, providing useless advice to road users that they should ‘seek alternative routes’. To Londoners such as myself, especially those who dare to live south of the Thames, this advice was par for the course in being useless. The moment you drive west of Tower Bridge you incur a £15 road tax penalty (sorry, ‘congestion charge’). If you reverse your journey, you negotiate the night-

River Thames crossings Graphic from Complex City by Allies and Morrison RIBA Publishing

mare of crossing the river via the Rotherhithe Tunnel, hopefully not when the police are conducting one of their helpful traffic checks on the other side, thereby extending the crossing time by 15 minutes (as happened to me that day). If you just keep going, bear in mind that the £15 penalty now operates at the weekends, as Mayor Khan’s contribution to making life easier during the pandemic. To cross the river is no simple matter. You cannot turn left from the Embankment on to Westminster Bridge. Vauxhall Bridge is closed to most traffic because of road works. You cannot turn left onto Chelsea Bridge. Wandsworth bridge is half-closed for road works Hammersmith Bridge is closed (as usual) for ‘strengthening’. Almost needless to say, there are no extant plans for replacement/relief bridges in central London, though there are terribly exciting plans to illuminate those that exist – a good example of decadent design trumping good old engineering principles which explain why we have bridges and tunnels in the first place. Bring back Brunel, you might say. At the time of writing, it had just been confirmed that any plan for a relief Hammersmith

Paul Finch is editorial director of the Architects’ Journal and AR and joint publishing editor of Planning in London

bridge has been scrapped – one day after traffic was made crazy by the closure of the Rotherhithe tunnel on a Sunday, generating predictable chaos around Tower Bridge. London has lost the habit of bridge-building. The last new crossing, the Millennium Bridge, was a private initiative and contributed nothing to relieving traffic congestion. It is hard to think of a new London bridge carrying vehicles, built in the 20th century and still operative. Public policy appears to be that bridges are bad – unless they are for pedestrians and cyclists. But if you hate the idea of bridges for cars, it is a short step to hating any bridge: hence the abandonment of the Rotherhithe Park to Canary Wharf idea, and further west the proposal to link Vauxhall and Pimlico. It goes without saying that there is no extant proposal (see above) to build a relief crossing, despite the repeat closures of Hammersmith Bridge, which again unduly penalise Londoners living south of the Thames. Mayor Khan hails from Tooting, so must be well aware of the grotesque inequity of London Underground provision for people like him and me, with only about 10 per cent of stations south of the river. We need bridges and we need transport policies that work for all, not just the lucky transpontine majority. The mayor claims that he wants London to get back to work, yet he has done little or nothing to encourage this to happen. On the contrary, the message is that not only should we be wary of using public transport, but that we should avoid the £15 penalty charge for travelling about in our own city by other means, weekends included Message: London is closed. n First published in AJ with kind consent

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OPINION: OCCUPIER RELATIONSHIPS | CARL WHAYMAN

The Covid challenge for property management Carl Whayman thinks about maintaining occupier relationships in a COVID-19 world March 2020 was a turning point for all of us. We went from getting on with our lives, believing that COVID-19 was something that had nothing to do with us in the UK, to suddenly being in the midst of a worldwide pandemic that dominates almost every conversation and interaction. The challenges across our portfolio were varied and at times exceptional, but one key factor has always been the relationships that we have maintained with our occupiers and communication. We have all found out a lot about ourselves, but as property managers, it is the basics that have proved the most important part of our work. Going further for our occupiers, looking to be solutions-orientated when challenged and being tenacious to secure the best results for all involved are claims that sound clichéd, but are nevertheless true. When operating across a large UK wide portfolio that includes mixed-used residential, commercial and retail units, needs vary, and it is our job to understand

A residential estate suddenly fully occupied seven days a week by a diverse cross section of city professionals, families, key workers, vulnerable and elderly residents needs to provide more than ever a sense of community and safety. Communication is vital them and help facilitate the right services. A residential estate suddenly fully occupied seven days a week by a diverse cross section of city professionals, families, key workers, vulnerable and elderly residents needs to provide more than ever a sense of community and safety. Communication is vital. This could be as simple as setting up a WhatsApp group or organising for a vulnerable person to have shopping brought to their door. Often small and random acts of kindness, thoughtfulness and help are really appreciated. These things may not be in the typical job description for the typical block manager, but these are unusual times, to say the

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least. Stepping up and filling the void is the right thing to do. As we heard from Government, we are all in this together and we are in a unique and privileged position as managing agents to step up to the plate and we are pleased to do so. In a commercial office block, needs are very diffi- Carl Whayman is Chief cult. This is not just about rent collection. Yes, both Executive at Lee Baron quarter one and quarter two rent days have been challenging, but crucially not impossible. We have sought When we looked to reopen one of our large central to better understand our occupiers: what is their busi- London estates, we did not simply affix signs to the ness? How is COVID-19 affecting them, both as indi- doors instructing people to social distance and sanividuals and as businesses? Understanding their needs tise. We ran a comprehensive consultation to underand circumstances is crucial. If a tenant’s team can stand what the needs of workers in the building were only operate in their place of work, we need to find and produced a bespoke booklet that was designed to safe ways of getting them back and operational as inform and reassure all parties that we have their safesoon as it is practical and legally permitted. On the ty and best interests at heart. other hand, if they are operating remotely, what can The next few months will continue to be very chalwe do to ensure that they don’t have to worry about lenging with winter approaching and local lockdowns their office and that everything will be functional and becoming more common. Now is not the time to forsecure for when they return? get the basics; it has been our relationships and our Regular dialogue with each tenant increases the desire to go further for our clients that has got us chance that you will be able to work collaboratively through this far and it will be these things that get us and constructively through difficult times. This has through the next stage. n been especially true through COVID-19 and we have been able to fully utilise these good relationships for the benefit of our clients. No matter who the tenant is, a mutually acceptable arrangement ought to be capable of being found if there exists a history of dialogue. Where the dialogue is missing, misuse and misunderstanding can develop and it is more likely that both landlord and tenant will become entrenched in their positions. Another key area of focus over the last few months has been ensuring everyone’s safety covering not just tenants but also on-site staff, all our supply chain partners and of course our own staff. It should go without saying that treating health and safety as some type of tick box exercise is never appropriate or acceptable – particularly today. In some settings, we are seeing those in charge putting up a few signs and clearly hoping for the best. This approach will not cut it and an Operating throughout the UK, we are leaders in all aspects of properintentional and robust plan is the order of the day. ty management across all sectors.We specialise in retail, mixed-use Also, including occupiers in the reopening process residential and are renowned for managing large complex estates. offering includes advisory and consultancy services, compliance means that it is more likely that the facility will be Our and risk management and property, financial and data manageused and changes will be embraced, as safety remains ment. For more information: https://www.leebaron.com/ together at the forefront.

When we looked to reopen one of our large central London estates, we did not simply affix signs to the doors ... we ran a comprehensive consultation to understand what the needs of workers in the building were and produced a bespoke booklet that was designed to inform and reassure all parties that we have their safety and best interests at heart

Issue 115 October-December 2020

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OPINION: WASTE COLLECTION | JONAS TÖRNBLOM AND TONY YATES

De-risking the capital’s waste collection in times of a crisis A pandemic or climate change could negatively impact entire communities in a very short space of time explain Jonas Törnblom and Tony Yates Urban waste management is a critical function. When it breaks down, the consequences are wide reaching and its impact is felt across all parts of society. Why, then, is the majority of the world’s waste management infrastructure built upon systems that are rarely assessed in the context of a global pandemic? Why are most of the world’s cities’ waste collection solutions – London included unable to even withstand severe weather conditions? In light of Covid-19, we should now assess how effective London’s waste management solutions are, not only in the context of a global pandemic, but also other disruptive events caused by climate change. Different collection systems exhibit different advantages and disadvantages. Some may be more expensive than others, whilst some are more user and environmentally friendly. System resilience and robustness in the face of a severe crisis are, however, rarely prioritised when selecting an appropriate handling concept for cities, new developments and regeneration sites.

done to reduce the risk factors associated with waste handling, particularly in densely populated areas such as London. If infectious diseases can be spread through waste material and animals, then implementing solutions that minimise – if not eradicate – physical handling of waste are essential. As we begin an era of social distancing, it goes without saying that bin storage rooms and waste processing facilities, both of which carry risk of transmission, must be effectively managed. And, as

The three contenders: bin collection, underground containers and pneumatic waste transportation systems Covid-19 has left few parts of society unaffected and its fallout continues to unfold. Yet, we have been here before. Previous pandemic episodes, which include the Black Death of the 14th century, two cholera pandemics of the 19th century and even the SARS outbreak in 2002, have a number of things in common. Firstly, they collectively killed millions of people. Secondly, they proliferated through waste such as contaminated food and water, and through vermin.

more is known about the substantially higher risk of infection within indoor environments, outdoor disposal facilities are likely to come into the spotlight.

Reducing the infection potential of waste in a thriving capital Surely now, in the 21st century, and whilst we are still in the eye of the Covid-19 storm, it is time to explore what a resilient waste management infrastructure looks like and consider what could be 20

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Whilst you can address London’s growing population by building upwards, you cannot simply keep adding more bins to streets already crowded with them; not only in the context of a pandemic, but also aesthetically

Designing in operational resilience The majority of London’s waste is still manually collected in bins or bags that line the streets, are often overfull and are therefore vulnerable to littering and vermin. However, considering that some parts of London are developing 400 homes per hectare, the question of where will all the bins required to collect the waste of all the residents inhabiting these homes go quickly comes into focus. Whilst you can address London’s growing population by building upwards, you cannot simply keep adding more bins to streets already crowded with them; not only in the context of a pandemic, but also aesthetically. Underground containers, which store waste in hidden chambers, remove aboveground risks of

Jonas Törnblom (RIGHT) is Director at Envito and Tony Yates (BELOW) is Director at SLR Consulting

disease transmission and reduce the risk of attracting vermin in shared public spaces. This solution is becoming more prevalent in London and several suppliers have established a presence. Automated waste collection systems (AWCS), also known as pneumatic waste collection systems, are another option. Not only do they store waste underground, limiting human interaction with waste and vermin, but they also transport waste automatically through an underground pipework to large containers, eliminating contact points between humans and waste, and reduce the need for heavy waste transportation by up to 90 per cent. Whilst there is only one AWCS firm currently in the UK, it has a large-scale installation operating in Wembley and is in the process of installing a second system - Europe’s largest - in Barking, where less than 500 waste collection inlets will replace 19,000 traditional on-street bins. The risks of physical contact with potentially contagious waste, and thereby disease, must be taken seriously. Therefore, it would be advisable to minimise the need for manual handling of waste bags and containers, and design out interactions between waste collectors and residents wherever possible. This becomes even more important if London is subject to another lockdown. Factors such as local storage capacity, the availability of skilled personnel and a system’s ability to operate automatically, or even remotely, are also key points to be considered.


THE SUBURBAN TASKFORCE |DIMITRIOS PANAYOTOPOULOS-TSIROS AND LUCY NATARAJAN

The Suburban Taskforce Dr Dimitrios Panayotopoulos-Tsiros and Dr Lucy Natarajan both of the Bartlett School of Planning (UCL) From the perspective of a changing climate, some technologies have proven particularly resilient and have remained operational during some of the most severe storms. Hurricane Sandy, for example, killed 72 Americans, affected 24 states, knocked out power to more than seven million people and caused an estimated $70 billion in damage. However, when Hurricane Sandy hit the New Jersey coastline, flooding and destroying homes and entire streets, the area’s AWCS remained operational. In fact, the system was one of the only public services to remain operational throughout the entire disaster. Surely there are lessons here from which London can learn. Futureproofing waste management during a crisis The fact that the majority of London’s local authorities place bins and manual collections at the heart of their waste management strategy means that the capital is perpetually at risk; a precipice whereby a crisis – be it a pandemic or climate change – could negatively impact entire communities in a very short space of time. It is time to embrace new methods and technologies; the potential costs for not doing so are far too great. The Covid-19 crisis has been devastating and has focussed attention on the potential risks of waste management systems. Whether or not the capital is sufficiently prepared for the next one remains to be seen. n Jonas Törnblom with a 30 years executive background in the international environmental technology industry - and since 2017 advising companies, organisations and cities in the Nordic countries, Germany, Canada and China on cross sectional governance issues in the fields of energy, the environment and urban development. Dr Tony Yates has 25 years in the waste management industry advising on all aspects of waste collection, management and disposal. He has provided independent technical advice on the Wembley and Barking AWCS installations.

The risks of physical contact with potentially contagious waste, and thereby disease, must be taken seriously www.planninginlondon.com

An Inquiry into the Future of the Suburbs Suburbs, suburbia or the suburban ‘condition’ have over the years received various degrees of attention. Yet, despite the vast pool of research and policy initiatives, the lack of a contextual approach leads to one recurrent argument: that overall, much is asked of the suburbs with outcomes that do not necessarily represent or fulfil the needs and aspirations of local communities. Amidst the current environment of uncertainty and crisis and in reaction to the oversimplification and eventual disregard of suburbs, the Suburban Task Force calls for a reconceptualisation of what suburbs are – and represent – through a profoundly contextual lens. This alternative understanding must, at its core, reconcile the socio-economic, political and spatial features of suburban areas. More than attempting to add to the existing pool of knowledge, the Suburban Task Force aims to investigate the challenges and opportunities facing suburbs and the ways in which they can be better supported in the future. Starting from the most elementary question, the Task Force asks what constitutes a suburb in 21st C Britain and whether there is such a definition to be found? Although it is understood that suburbs are distinct in nature from more rural or central urban areas, it is undeniable that the nature of suburbs varies spatially; not only between cities but among the suburbs of one city as well. Hence, in an attempt to concentrate efforts and to explore in depth the contextual attributes that characterise suburbs, the Task Force will focus at first on London’s outer Boroughs. The deeper more fundamental driver of this initiative is a recognition that people choose to reside and work in suburban areas at least partly on the basis that they offer a particular set of qualities not found in more central or rural areas. However, the conditions and expectations of any locality necessary change over time, and so there needs to be a wider acknowledgement that the challenges and solutions offered to suburban areas might not reflect the changing needs or expectations of local communities. Indeed, the nature of local governance, and the expectations of spatially just development are often distinct for suburban areas. As

policies have distinct spatial and social implications they are often experienced very differently by different groups within communities, which will create unique local challenges and opportunities. Therefore, policy implications need to be continually considered. The Task Force aims to shed light on the experience of the suburban context today, this research seeks qualitative evidence from local people and their democratically elected representatives on their views and aspirations for the areas. This will be combined with quantitative data related to the configuration of the urban environment, such as demographics and economic wellbeing, transport infrastructure, as well as spatial and environmental characteristics. Together, this data will be assessed and reported with a view to helping local authorities and strategic planning actors at the regional scale to understand how suburban areas are evolving and might be supported as they change. This new understanding and knowledge is expected to feed into developing specific goals and visions in conjunction with localities and communities. The Task Force also aims to synthesise what is already known about the nature of socio- economic activity in the suburbs. A call for evidence is out now for further evidence on the existing relations between selected suburbs and central London, as the point of orientation and magnet for their wider connections. The questions surround spatial and socio-economic elements and the logistic connections and ‘flows’ (i.e. socio-economic interactions) that exist between suburbs and London. We hope to uncover the local patterns of work, life and play, in relation to the condition of the built and natural environment, and relevance of current pattern of investment and expenditure. n SEE https://suburban-taskforce.org/

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OPINION: WHITE PAPER AND USE CLASSES ORDER | CRAIG BLATCHFORD AND GARETH FOX

Making it happen: immediate opportunities, practical needs Craig Blatchford and Gareth Fox think with active and full engagement the proposed planning changes could be a game changer If it can deliver on its ambitions, there’s much to welcome about the Planning for the Future White Paper as far as London is concerned: a stripped back Local Plan process with more focus on strategic decisions, clearer designations and a simpler, quicker planning application process – all while ensuring design quality, sustainability and the other characteristics that create successful places. How well this vision works in reality, however, will come down to how deftly its principles can be translated into legislation, put into practice and then enforced. For many of us, this means tackling three key areas. We need workable structures around developer contributions, public services and infrastructure, particularly for the replacement of S106 and CIL. The certainty of standard, nationally-set Infrastructure Levy charges needs to be blended with bespoke local measures usually dealt with through the S106 process and to reflect divergent land values. The relationship between individual London Boroughs, the Mayor/GLA and Transport for London in the decision-making process needs clarifying. For example, will the referral process also need to be reviewed to align with the overall objectives of a more streamlined and accountable process? Above all, local authorities need the leadership and resourcing to grapple with the big issues, particularly to consult on and create effective Local Plans that are right for their area and within the new 30-month timeframe. LPA teams must adapt and grow, and councils will need to look externally for more specialist advice to tackle the challenges we face around growth and housing without losing the heritage – and of course beauty – we all benefit from. Supporting all of this, local engagement – which is already moving to more digital channels as a result of lockdown – will also be transformed, harnessing technology to reach out at an earlier stage to a broader base. In the meantime, the direction of travel is clear and those bringing forward new development should accelerate as far as practical rather than

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Planning in London

wait for the new shake-up to take effect. For all the changes ahead, local authorities will still need to take decisions on the schemes coming before them. Immediate housing need isn’t going to fall away and local authorities still need to work to meet housing delivery tests and five year supply, which in turn bring into play the presumption in favour of sustainable development where such requirements are not met. This all creates short term opportunities, and it would be counterproductive for the pace of delivery to slow as this wider restructuring takes place. There will be challenges facing the London market in particular. For some authorities, especially the outer London Boroughs, the need to address housing supply is compounded by the presence of protected areas within their boundaries that seemingly remain off limits as far as the current reforms go. But there are also huge opportunities too – particularly the latest changes to the use class order. Commercial assets now have greater possibilities to find their place in the ‘new normal’ and there is potential here for many parts of the capital, especially the Central Activities Zone, that has never been seen before. Together with the General Permitted Development Order, the UCO changes will embed flexibility within the planning system in a way not seen in the post-war era. Landowners, asset managers and developers are now freer than ever before to repurpose struggling assets, unencumbered by a borderline obsolete land use categorisations and plan policy that prevents its loss. In the extreme, we are in a world where the Gherkin could, in principle, could be converted into a multi-use retail, food and drink and leisure destination without there being any need to engage with the planning system. Central London gyms, health centres and clinics can become

The London market has potential to benefit from all of the changes currently being proposed

Craig Blatchford (RIGHT) is Head of Planning and Gareth Fox (BELOW) Associate at Montagu Evans

offices overnight. Supermarkets can become vast food halls. Of course, in most cases such changes would not stack up commercially, but this does underline an important point. Realising the full potential of these freedoms will rely on innovative thinking, new commercial business models and a complete rethink of management strategies for commercial property portfolios. All this comes at a time when the City in particular is reshaping and widening its offer to be more culture and leisure-led as well as a global business centre. These planning changes are an additional boost, especially for City Fringe and other locations where office values may not offer the best returns and owners can now reassess their options. So, while there will be opportunities to bring forward proposals that respond to the White Paper’s aims long-term, there also a moment, now, to progress schemes through to delivery before these changes take place. The London market has potential to benefit from all of the changes currently being proposed. To make the most of them, we will need a change in approach to a more development plan-led system – but with active and full engagement this could be a game changer, especially for potential growth areas and the large scale urban renewal projects and estate regeneration that are an essential part of the capital’s future. n


OPINION: COMMERCIAL PROPERTY | PAUL HOWELLS

COVID-19 has changed the property needs of businesses The flexible working revolution is well underway and the commercial property sector must be adequately prepared for the oncoming shift in working culture thinks Paul Howells The COVID-19 pandemic has radically altered society. Even at a time when the government is encouraging businesses to slowly transition back to the office, many are still working from home or implementing flexible working schedules for their employees. This will have a significant impact on the commercial property market. Flexible working arrangements and co-working spaces were already lessening the need for businesses to subscribe to the traditional one-desk-per-person office culture that had dominated the corporate world for the last 80 years. While smaller companies have been able to adapt to changing employee needs, COVID-19 and the need to work from home made this a sudden necessity for businesses of all sizes and across all industries. In my mind, the COVID-19 pandemic has forced employers to reassess their current processes and structures, and ultimately understand how flexible working arrangements can ultimately benefit them. These advantages extend from reduced operational costs to working in tech-enabled workspaces. Heading towards the new normal Accumulate Capital recently commissioned research to explore how fast the UK business community was heading towards the scenario outlined above. We surveyed more than 500 senior decisionmakers from businesses all over the UK. Of those that were surveyed, 73 per cent believed businesses are going to be downsizing en masse as a result of the coronavirus pandemic over the next 12 months. What’s more, 37 per cent of business leaders are actively planning to relocate their own companies to a smaller commercial space themselves. This will undoubtedly have a massive impact on the commercial real estate market. Medium sized enterprises will downsize to smaller spaces, and smaller companies may even simply just rent a single room for meetings or a rotating selection of key staff members to be present for in-person decision making. So, the question becomes, how will the commerPaul Howells is CEO of Accumulate Capital – an investment and property development firm. Accumulate Capital connects registered investors with developers in the property development finance sector to enable selected, high-yielding projects in the UK and overseas.

www.planninginlondon.com

cial real estate industry accommodate these changing attitudes?

A sector in flux Exactly half (50 per cent) of the decisionmakers spoken to by Accumulate Capital admitted that their preferences for commercial premises had changed, with 58 per cent stating that working from home will become their new norm. Some may believe that the rise of co-working spaces in recent years is perfectly positioned to accommodate these shifting priorities. However, many of these spaces were more specifically designed to entice companies that foresaw themselves growing at a rapid rate. In other words, it pro-

Pessimistically minded operators may fear that COVID-19 has essentially ended the very idea of an office altogether... 57 per cent of businesses will still rely on a physical workspace in order to network and collaborate with partners and prospective clients. vides an easy opportunity for businesses to expand their office space without needing to seek out a new real estate provider. A look at the pricing structure of the most successful co-working space company, WeWork, is indicative of this. Factor in WeWork’s emphasis on shared spaces for the occupants of any given premises, and it becomes clear that the traditional co-working space model is not equipped for this new era of uber-flexible office working; especially given the new need for social distancing. So, what can commercial realtors and developers do to entice businesses back to the office?

Changing trends, changing spaces Pessimistically minded operators in the commer-

Paul Howells is CEO of Accumulate Capital

cial property sector may fear that COVID-19 has essentially ended the very idea of an office altogether. However, our research showed that 57 per cent of businesses will still rely on a physical workspace in order to network and collaborate with partners and prospective clients. Smaller, more flexible workspaces will inevitably become the new norm, then. Companies will want the freedom to occasionally have their staff mostly present for an important presentation or meeting, but not be weighed down by exorbitant rent prices for a space that can facilitate such meetings all the time. That’s why it is important that those involved in the commercial property sector adapt to the changing needs of the market. It may be worthwhile, then, for commercial property investors to seek out new opportunities in less central, but more accessible, areas. If the right social distancing measures are undertaken, a large property could well be sub-divided to meet the new needs of multiple different downsizing companies. Finally, there are significant opportunities in many of the UK’s rising regional hubs. The government has committed billions of pounds into the construction of infrastructure and new-build properties in the coming years. With market preference for commercial property changing, this could be an ample time for developers to address the needs of the postCOVID-19 workforce in the regions. Of course, all this speculation must come with the caveat that a COVID-19 vaccine or second spike could well derail this trend. As it currently stands, however, the flexible working revolution is well underway, and the commercial property sector must be adequately prepared for the oncoming shift in working culture. The industry must respond to changing business needs and ensure the availability of commercial working spaces accordingly. n

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OPINION: PERMITTED DEVELOPMENT RIGHTS | GARY HOBAN

The right to build up is useful The upward permitted development right can help tackle the housing crisis, argues Gary Hoban Truly disgraceful. Damaging. A serious error. A striking failure. Populist but fallacious. Slums of the future. An uncontrolled experiment. These are just some of the things architects and planners have been saying about the government’s radical shake up of planning rules, which will initially see permitted development rights expanded before a whole new zonal planning system is eventually introduced. While there are many legitimate concerns about these far-reaching proposals, could it be that the critics are missing the potential benefits of some of the more immediate changes? Since last month property owners have been able to use expanded permitted development rights to add two storeys to purpose-built blocks of flats. For some this may conjure up nightmarish visions of profit-crazed developers opportunistically building on every available rooftop. But it makes me think of a small but vital “airspace” social housing project I’m leading in south-west London right now. We are in the process of adding 71 desperately needed new social homes for elderly people on top of dated 1970s tower blocks owned by the Sutton Housing Association. We obtained planning permission in June under the old rules but it is highly likely we would have been able to build even more homes had it taken place this month.

Planners rejected our application to build two storeys on one of the blocks as it was close to a tall church. In the end we were given permission to build one additional storey. This meant we were unable to provide a further six new social homes at a time when there are 1.6m households on social housing waiting lists and Shelter estimates we need 690,000 social homes to give the over-55s struggling with high housing costs some security in old age. Despite its proximity to the church, I firmly believe that the two-storey approach was suitable for the site and surroundings. The building was wide and low and the extra storey could have been sensitively and sympathetically handled. This is, of course, crucial. If we had obtained prior approval under permitted development rights it would have been incumbent on us to make sure the design complemented rather than detracted from the look and feel of the rest of neighbourhood. The density of rooftop extensions may be another concern. Sutton were very clear about what they considered an appropriate number of flats for the space but we were still able to exceed their housing yield by six per cent. However, not all clients will be as conscientious so it will be vital architects ensure that the freedoms that come with these changes are wielded responsibly. It is unlikely to be a complete free-for-all. Adding

Gary Hoban is director at Hoban Design

more than one storey to a building usually requires new structural support, along with new lifts, stairs and fire escapes. These should all still require formal planning. This is clear from our own experience. Sutton Housing Society didn’t just settle for additional rooftop homes, it upgraded the 50-year-old buildings below. We were asked to design new facades, windows and improved communal facilities to the longterm benefit of existing and new residents. Yet it can’t be denied that some unscrupulous developers will seek to game the system for their own advantage. This is a real risk and I share the concerns of others in the profession. However, I can also see how responsible developers, housing associations and even councils could use these rights to build upwards, providing some of the millions of new homes we need to tackle the housing crisis responsibly. Whatever you might think of these permitted development rights, they are now in place. Responsible architects must learn how to use these opportunities to provide much-needed, liveable, welldesigned new homes in the underused spaces above our heads. n First published in BDonline with kind consent

LEFT: How the new PD rights will work. Analysis by Andrew Rogers from the ACA September Newsletter

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OPINION: AIRSPACE DEVELOPMENT | MANI KHIROYA

The unintended ending of airspace development? The unintended consequence of this legislation is that residents are stuck in buildings that are less safe than they would otherwise be thinks Mani Khiroya The government’s recently published legislation following the ‘Building a Safer Future’ consultation signalled many welcome changes that should strengthen our building safety regime. Improving of the Fire Safety Order for existing buildings through the Fire Safety Bill is positive and reflects our experience of old buildings which are unsafe by current standards. This naturally aligns with the aims of airspace development, owing to the upgrade works to the whole building that take place when developers add an additional storey or more . However, just two of the new changes could spell the end of airspace through unintended consequences, something at odds with Robert Jenrick’s recently published permitted development right allowing upwards extensions on existing buildings. The consultation paper proposes to lower the ‘18-metre height threshold to at least 11 metres’ for the ‘current ban on the use of combustible materials in the external walls of high-rise buildings’. This is likely to be brought in via an amendment to Regulation 7 which is an absolute requirement for non-combustibles (what we call ‘A2-s1, d0 Euroclass or better’). The practical effect of this is that only mineral wool insulations are likely to be allowed and the vast majority of existing building stock will not comply with this requirement. When it comes to airspace, Regulation 7 is not usually applicable due to FAQ (1) of the Building (Amendment) Regulations 2018, however, this exception only applies when the building was already a ’relevant building’ prior to the development. Thus, if the airspace development pushes it into a new threshold, adding a storey above 11m when it did not have one before, the development will need to comply. This will effectively illegalise airspace development on the vast majority of four storey buildings (apart from the few exceptions that use solid wall construction), while buildings that are already over four storeys will be exempt. The second change comes via amendments to Approved Document B stating that ‘blocks of flats with a top storey more than 11m above ground level should be fitted with a sprinkler system.’

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This means that any airspace developer will require access to the homes of every existing leaseholder which will not only cause disruption to residents, but means that residents can be held to ransom with just one owner being able to stop an improvement project which the vast majority of the block supports. Although there have now been two circulars that suggest that alternatives will be considered, most Fire Engineering firms and Approved Inspectors we consulted with were not aware of this as a potential solution and there is no clarity on the alternative ‘additional protection’ that would be required. These changes threaten to unintendedly end airspace development and mean that residents are stuck in buildings that might have been compliant at the time they were built but would not get sign off under today’s regulations, rather than allowing them to benefit from upgrade works that accompany an airspace project. Given the greater burden placed on the building owners and managers by the updated Fire Safety Bill and new regulatory regime for Accountable Persons, airspace development offers an excellent way to release value thereby covering the cost of the works required to make the building fire safe – which should always be the

Mani Khiroya is managing director of Fruition Properties

number one priority. Experienced airspace developers are well placed to advise on the extent of the safety works required and can project manage them, working hand in hand with residents, owners and industry leading fire engineering firms to come up with a detailed Fire Strategy. Often this includes upgrading the building’s alarm systems, removing or encasing potential combustible material in communal areas, installing fire doors and installing fire-fighting shafts for larger developments. The unintended consequence of this legislation is that residents are stuck in buildings that are less safe than they would otherwise be, with costs that they would not otherwise have. We hope the government will take this into consideration when implementing the new legislation, >>>

The View – Upper Richmond Road

Issue 115 October-December 2020

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OPINION: AIRSPACE DEVELOPMENT | MANI KHIROYA

>>> particularly when it has otherwise been so vocal about encouraging airspace development. n

Examples of our successful airspace developments The View – Upper Richmond Road, SW15: For this project, we worked with leaseholders in this tired 1970s block to create four new apartments in an additional floor above the existing building. In just 32 weeks, we had built the new homes using innovative methods of construction, refurbished the existing internal communal areas, updated the façade and windows, and re-landscaped the gardens and driveway. New cycle and bin stores, post boxes and an audio-visual entry system were also provided. Now completed, the existing residents benefit from higher value apartments and they share running costs with the owners of the new apartments, which has reduced their annual service charge by 25 per cent.. Ladbroke Crescent – Notting Hill, W11: We delivered Ladbroke Crescent in partnership with the existing owner of one of the four flats. Through the addition of an extra floor, the dated flat was transformed into a stunning light-filled duplex with a modern, open plan living space ideal for family living. The entire block was refreshed with a modern uplift to align it with the neighbouring stucco-fronted Victorian terraces, which included re-rendering, slate cladding and improved communal areas.

Ladbroke Crescent – Notting Hill business to drop by over 20% during the entire build phase. However, we worked closely with the owner to develop a programme of works that considered the impact on his business. In turn, the restaurant only had to close for five weeks, which was carefully scheduled to happen during a quieter trading period.

The View – Upper Richmond Road,

The One – Porchester Road

Ladbroke Crescent – Notting Hill The Carob Tree – Highgate Road

The One – Porchester Road, W2: This was an interesting project liaising closely with Young’s Brewery to deliver eight contemporary apartments in the airspace above the existing pub. Despite the need to build an additional floor, we successfully navigated the build over a busy junction so that the pub was able to remain fully operational. The scaffolding was designed to avoid obstruction of the retail frontage and to ensure the corner entrance to the pub was easily accessible. This allowed the pub to continue to attract customers whilst new value was added. The Carob Tree – Highgate Road, NW5: Here, we created three new homes through the refurbishment of the existing upper floors and addition of one new floor above an existing restaurant – The Carob Tree. The owner was initially weary of the impact to the restaurant from construction, where they expected

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Ladbroke Crescent – Notting Hill


OPINION: THE PLANNING WHITE PAPER | IAIN GILBEY, JAMIE LOCKERBIE AND SUE CHADWICK

What the White Paper could – and should – do to reform developer contributions The current times require less fanfare but more agility argue Iain Gilbey, Jamie Lockerbie and Sue Chadwick What reform could look like As with other issues, the Government's proposals are spread through the White Paper. The Prime Minister's foreword promises “radical reform” so that developers can no longer “dodge their obligations” while the Introduction argues for development supported by community facilities and simpler viability assessments, and criticises the current processes for their length and lack of clarity. The next broad summary of the overall proposals introduces the notion of a new Infrastructure Levy that will “sweep away” the need for negotiations, deliver more infrastructure and be wider in scope than current agreements. Infrastructure delivery is addressed in detail under Pillar 3. Section 106 agreements are criticised for a lack of clarity, dependence on complex viability assessments, and delaying the delivery process. CIL contributions are seen as insufficiently flexible, and responsible for creating cashflow issues for developers, while local authorities come under fire for being “slow to spend” it. Within the specific proposals the government asserts (Proposal 19) that the new Levy will create a system that is more responsive, transparent, consistent and fair, and that captures more of the land value uplift because it is based on a “flat-rate, valuedbased charge” based on the final value of a development (subject to minimum value thresholds). It could not be charged until properties were occupied but local authorities could borrow against expected revenues. The new Levy could also be charged on some changes of use and other automatically permitted types of development, specifically including office to residential conversions and the new demolition and rebuild permitted development rights (Proposal 20). It could also allow for on-site delivery of affordable housing, including the new First Homes (Proposal 21) and could morph back into a financial contribution where there is no uptake by providers. Under Proposal 22 it looks as though the 2008 Act definition of ‘infrastructure’ could be replaced with the relaxed restrictions for neighbourhood por-

www.planninginlondon.com

tions: the “provision, improvement, replacement, operation or maintenance of infrastructure; or anything else that is concerned with addressing the demands that development places on the area.” Finally, buried deep within Proposal 23 there is the suggestion that a “small proportion” of the Levy could be used to cover costs – including the preparation and review of Local Plans and design codes and enforcement activities.

What reform should look like The White Paper has attracted a lot of comment, both positive and negative. Our view is that, if there were an easy way to solve the problem of how to turn development uplift into good quality infrastructure that meets all needs, someone would have found it by now. Rather than aim to reform the entire system in the middle of a global pandemic and the worst recession in more than a decade, we suggest retention of the system of planning obligations but with some small but significant changes that would deliver lasting positive effects for minimal administrative pain. Changes to legislation • Replace the current ‘purposes’ a)-d) of section 106 and replace them with wider, more general, power to secure obligations of any nature but subject to compliance with the tests set out in Regulation 122. This would allow s.106 agreements to lawfully secure, for example, measures such as residents not being permitted to apply for parking permits, land transfers to the local authority or other third parties and to enter into contracts in the future. This would also avoid the need for the parties to have to undertake 'work around' process such as additional agreements and use of restrictions etc on the register of title to the property. • This simplified s.106 could also be amended to allow local authorities to contract with themselves and ensure that the obligations are binding on successors in title and function . This would deal with the significant complexities that currently exist when a local planning authority is also the land

Iain Gilbey and Jamie Lockerbie are planning partners, and Dr Sue Chadwick, is a strategic planning advisor at Pinsent Masons, London

owner and therefore needs to 'contract with itself'. • The cost of the on-site delivery of infrastructure should be an allowable deduction from the new infrastructure levy. This could be legitimised through an amendment to the CIL Regulations and with the value of the deduction formally recorded in the 106 agreement. • Finally we suggest that guidance and/or possibly legislation is changed to explicitly state that a local authority is able to, and should, covenant back to the developer to deliver infrastructure where the developer is paying significant sums towards the provision of infrastructure that is necessary to make the development acceptable in planning terms. Changes to policy • The NPPG should be amended to encourage planning authorities to start negotiating the agreement itself promptly following validation of the >>>

Issue 115 October-December 2020

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OPINION: THE PLANNING WHITE PAPER | IAIN GILBEY, JAMIE LOCKERBIE AND SUE CHADWICK

>>> planning application, with external solicitors system that reflects the nature of funding of Conclusion appointed (at the applicant's cost) at that point if infrastructure serving many projects). The combined experience of the Pinsent Masons There will in-house. be multiple and interaction opportunities asking there are insufficient resources Costs networking • Create an arbitration process for resolving dis- Londonincluding planning team means that we have over could be covered via the usual solicitor's underon section 106 agreements.for This all newof body years seen section 52 replaced with section speakers questions live,putes polls, plus networking our the attendees, speakers takings or covered in asponsors, Planning Performance couldsafet deal withof a range of o issues 106, muddled through interpreting Circulars and a from the our n including o ce or home during these Agreement. The uncertain decision-making committee • Imposing sanctions that refuse to 16/91 times egister no and nd on outparties more information viaand 1/97, flirted with the Planning Gain would have a much clearer picture of what was meet their obligations, including the local authori- Supplement, adjusted to accommodate MCIL, surwww.planningportal.co.uk/conference. being approved if the detail was available at the ties and/or applicants who delay negotiations or vived the partial introduction of CIL and still find time of the committee meeting and could also refuse to engage/move drafts on ourselves mostly using section 106 agreements as We are delighted to welcome on board our key sponsor will be Objective take into account the extent to which the devel- • Issues of alleged breach (including securing the least worst way of delivering on-site infrasrape e urpose ui t for p anners and ui ding o cers, rape e ena es the oper engaged with the s106 negotiation process. enforcement measures) where a local authority tructure in a flexible way within the confines of accurate anning and uiwith ding app ications at over • The PPG should be updated toand state e that cient where assessment has entered intoofa p section 106 agreement development viability. We have also lived through 500 local authorities across the UK, Australia and New Zealand. The Trapeze a local authority is seeking large financial contri- itself as landowner as per our suggestion above numerous attempts by governments to reform will be sharing insights how innovative councils are applying butions to deliver team specific infrastructure then thetheir • Arguments on into whether or not proposals comply the system – with mixed results. authority is strongly encouraged toto enter into a with whatever legal tests (e.g. Regulation 122) control. are It is always tempting for a government to technology development management and building reciprocal commitment delivery. in place; a fresh ic to ets are on and are comp ete free for pu icpromise sector o start ciarather s than deal with the cur• Disputes about viability rent book complexities of the system – and governments Over 80% of tickets have now been sold, issues so don’t hesitate and your place Other changes now. • Settling drafting points where parties have have been planning reform of the system almost • As well as being able to borrow against the costs reached an expensive impasse; since the first planning act of 1909. The current of anticipated funding, options should be The arbitrator could have powers to impose times require less fanfare but more agility - a Sponsorship, exhibitor and speaking opportunities are also available, giving explored to allow a developer to borrow from the penal costs in the event of a vexatious and unrea- response that works within the existing system to you access to an audience of 500+ senior level industry leaders. Please contact local authority to secure delivery of large scale sonable referrals and scope to involve the public deliver small effective changes. conference@planningportal.co.uk for more information. infrastructure. This could (subject to reformed much more widely than is usually the case. Referral Some of our proposals need changes to legislaState Aid considerations) be part of the new sec- fees could be set at a level so as to ensure it is self- tion and might take time, but others could, with tion 106 so that an obligation to recover those funded and therefore not an additional cost to the energy and motivation, be in place by the time we costs from other schemes provided the propor- public purse. really are ‘building back better”. We commend them tion is fair and reasonable (an enhanced "pooling" to the Government. n

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Planning in London


OPINION: NEW FUTURES FOR THE WORKPLACE | PAUL FINCH

Office rethinks should stem from opportunity, not fear Paul Finch thinks the only thing we have to fear is fear itself ‘As the office sector faces seas of change, we challenge you to imagine a better future. Entrants are encouraged to think outside the box to present innovative and thought-provoking solutions that bring to life how workspace may change over the next five years.’ Thus the preamble to details of a British Council for Offices ideas competition, aimed at its younger ‘NextGen’ members. This is only the second time that such a competition has taken place, but older readers may remember a famous predecessor won by Andrew Chadwick in the 1990s on the same sort of subject. His suggestion was that the office of the future would comprise what today we would call a laptop. So challenges to the conventional office have been around for a long time. The question of how post-pandemic conditions will affect it will no doubt allude to existing trends. Remote working isn’t new, ‘hub’ or ‘club’ office environments have been with us for much of this century. The serviced office, WeWork-style shared space and the recent rise of Zoom and Teams meetings are all proof that change is the only constant. What seems to have gained currency in the mainstream media is the idea that the office as we know it is finished. To some extent that idea is reflected by what the BCO suggests competition entrants might address: • Redefining the purpose of the physical office space: Why work in the office when you can work anywhere? • Shifting work patterns: The rise of working remotely and more flexibly, with teams connected via technology. • Increased localism: The potential for suburban hubs with blended uses, to support traditional city office locations. • Reduced densities of office buildings: Opportunities for alternative uses or sustainable re-use to drive greater utilisation and value. • Designing Inclusively: Intergenerational working, mentorship and work experience opportunities.

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• Increased data tracking, gathering and analysis: To ensure the office is a safe environment to visit. • Hygienic and healthy buildings: What they require and the role of new technologies to accelerate this. There are other areas for examination which with luck will emerge, both in the competition and more generally for discussion across the sector. For example: • What materials could we use to counteract virus spread on ironmongery and the myriad things we touch in the workspace, from lift buttons to keyboards? For example bronze or graphene. (Unless recently reported research, suggesting that touched surfaces are not a source of virus spread, is WHO-endorsed) • What makes an office environment more appealing than ‘workspace’ inserted into homes? What are the good bits about home that might transfer? How can office environments lift the spirits? • How could we develop ideas about the multi-use foyer, including using it for visitor meetings? • Should the default idea about office buildings be that they are workspace-led hybrids? • Should the office be a ‘universal building’, as pioneered through projects like the White Collar Factory, where plug-in operations could replace offices if necessary? The assumption is that the ‘office’ is a long-life building rather than assumed to be redundant after 25 years. The key to creating successful new futures for the workplace lies in the attractions of human interaction, which is very different on screen, and is even more different/difficult if you are communicating with colleagues that you have never had the chance to meet face-to-face. Most people like people – so the question is how to make the office the best environment in which to interact. Employment problems are currently associated with shops and hospitality rather than office-based activities. The former will benefit from the health of the latter, so there is a strategic imperative for the latter to flourish. This may well mean more hybrid developments, flexible uses, generous new space

Paul Finch is editorial director of the Architects’ Journal and AR and joint publishing editor of Planning in London

standards, new amentities and so on, but this will be underwritten by office activity and tenants paying rent for newly appropriate space and facilities. In short, office development and retrofit will be a focus for new thinking and constructive improvement. The only thing we have to fear is fear itself. n First published in Property Week with kind consent

BELOW: Frank Lloyd Wright’s Larkin Building in Buffalo, one of the first office buildings

Issue 115 October-December 2020

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BRIEFING: MAYOR WRITES TO THE SOS

Mayor of London writes to the SoS on planning system changes Open letter from the Mayor of London, Sadiq Khan, to the Secretary of State, Robert Jenrick MP

Friday, 2nd October 2020 Dear Robert, Changes to the current planning system Further to my previous correspondence on this issue, I am formally responding to your ‘Changes to the current planning system’ consultation. I believe we share the same desire to build more of the homes that Londoners need. Over recent years, real progress has been made. The three years with the highest levels of housing delivery have all been during my tenure. I have delivered over 40% more homes than the previous Mayor did in his last term. In 2018/19, Greater London delivered 15% of England’s Homes on just 1.2% of its land. My approach, including in my new London Plan and the support measures I have put in place for SME builders, is facilitating delivery of housing even through an unprecedented time of economic and social disruption. What’s more, despite what the proposed changes seem to be trying to address, the granting of planning permission for new homes simply isn’t the problem. There are over 300,000 homes in the pipeline for London waiting to be completed which is almost 6 years’ supply of homes. Instead of building on the progress the city has made, working closely with myself, the boroughs and local communities, and addressing those issues which continue to hold back the building of new homes, I believe these proposals will be a retrograde step, risk alienating communities and actually make it less likely London builds the homes it needs. In addition, centralising the planning system with targets driven from Whitehall is a backward step and flies in the face of the Government’s commitment to devolution. The proposals represent a serious weakening of local democracy, and undermine the almost universally acknowledged notion that local areas know what works best for them. Trying to construct a one size fits all planning approach for a country as diverse as ours would be a mistake. In addition, every four years Londoners have the opportunity to directly elect a new Mayor on the back of this mandate successful candidates should have the freedom to create a planning

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framework that works for the city. The current Government has no mandate in London to introduce these changes. There needs to be much more recognition of the unique challenges different areas face, not least the specific circumstances faced by a large conurbation of 10 million people, like London. The recent experience of the pandemic has shown that the country actually needs less control from Whitehall, not more. My consultation response is attached, but to summarise these are my concerns that urgently need addressing: There is already planning permission for over 300,000 homes in the capital that have not been completed. Planning permission is not the key problem. Instead London needs further funding for much needed infrastructure to unlock sites and deliver more affordable housing. A diverse tenure mix boosts building out of sites and absorption rates exactly as set out in the Government’s own Letwin Review in 2018, creating jobs and growth to support London and the UK recover from the COVID-19 pandemic. The proposals contain no evidence to support any of the four proposals to amend the current planning system or the potential impacts on communities and on its ‘levelling up’ agenda. If this evidence does exist, it must be published without delay. If it doesn’t, the proposals should be dropped. The step-change we need to see in housing delivery is never going to happen without additional government investment in skills and training, and in supply chains to support the sector. The proposed standard methodology is not fit for purpose in a London context: it does not respond to the complexity of London’s housing needs and produces, and results in, an undeliverable target for London. This is widely accepted across London and the South East, with cross-party opposition to the plans. The algorithm is flawed by doubling-down on the affordability weighting, driving higher housing targets in areas where no land is available because it is already intensively developed. For example, in the Royal Borough of Kensington and Chelsea, the algorithm generates a housing need figure of 3,285 homes per year, com-

pared to the 448 homes the borough actually has capacity for, as agreed by the Inspector Panel for my new London Plan. A significantly more sophisticated model is required to better reflect the reality of dense urban areas and ensure housing calculations do not actively discourage ambitious boroughs elsewhere in England. I am also concerned about the proposed raising of the affordable housing threshold to 40-50 homes and the introduction of the First Homes product, which will be unaffordable for the vast majority of Londoners. These proposals could lead to a pause in the delivery of housing on small sites. It is clear to me that the most likely outcome will be a considerable drop in vital affordable housing delivery. If the Government is truly serious about providing the development sector with the conditions it needs to bring sites forward and take investment decisions, my new London Plan must be agreed without delay, so the industry and boroughs can get on with meeting their increased housing targets and delivering the homes London’s communities desperately need, as well as delivering Good Growth. This is the time for certainty and stability, not upheaval, confusion and instability. The Prime Minister says he wants to build, build, build. The best way to do this is to provide certainty. Yet the proposed changes to the planning system will result in the opposite and stall development at the worst possible time. As I have previously requested, I would welcome a meeting to discuss these matters with you as soon as possible. Yours sincerely, Sadiq Khan Mayor of London


BRIEFING: CLIPBOARD

LETTERS

Zoning town centres From: Michael Bach London Forum of Amenity and Civic Societies If the Government wants to do something positive and popular with the planning system, how about a town centre zone? At least it could be a positive tool for supporting town centres rather than just letting the market deconstruct it. Is that positive enough – we need a planned, pro-active, positive approach to creating/maintaining vital and viable town centres. If the Government is serious about supporting town centres, create a town centre zone for which there would be an opportunity to draw up a strategy, action plan. Now that would be planning!

Wargaming for the Future From: Mark Willingale, Willingale Associates A recent article in the FT provides essential background to the Planning for the Future reforms. Software developer Improbable is creating a “single synthetic environment” digital replica of the UK for wargaming. “Real-world uses range from predicting natural disasters such as floods to calculating the effect of a cyber attack….” in order to “ solve complex problems in real time, take better decisions, and conduct more decisive and efficient operations.” Supporters include Mark Sedwill, Michael Gove and Dominic Cummings. The immediate priority is to build a digital twin of the UK, “to enable governments to test ideas and test choices of action in a virtual world before implementing them in the real world” “Its success would rely on accessing high quality data to train the algorithm.” If you did not know this article was about wargaming for the Ministry of Defence it would read as a prospectus for the Planning in the Future reforms with its emphasis on developing an accessible interactive data set. So the purpose of the reforms is confirmed. The same players are involved, led by Dominic Cummings. Here’s the outfit that is investing in PropTech: https://localglobe.vc/

www.planninginlondon.com

The London Borough of Hackney has won an injunction preventing display of art installations at Brunswick Wharf in east London ahead of a court hearing over the issue. Jaimie Shorten – co-founder of local practice Barker Shorten Architects – won the Architecture Foundation’s 2020 Antepavilion contest with his proposed family of five ‘leaping and lunging’ sharks. Almost complete, the £25,000 floating installation at the Hoxton Docks canal was due to be unveiled on Friday 21 August before the court order halted installation of the fifth and final shark. Architecture Foundation director Ellis Woodman slammed Hackney’s ‘heavy-handed and unwarranted interference’ and called for the sharks to be allowed in the canal. – AJ report

Excessive pointless pseudo scrutiny From: Alfred Munkenbeck, Munkenbeck & Partners I am always amazed how ignorant UK architects are of how the rest of the world manages. With planning we, in the UK, have backed ourselves into a never ending spiral of subjectivity about things that should be objectified which has had a debilitating knock on effect throughout the economy. Too many people are employed overscrutinizing. Bit by bit, they should be finding things for which rules can be made and then making them…. There will ALWAYS be a mechanism for obtaining a “variation” ie. an exception with good reasons but having few agreed rules invites time wasting amongst warring subjective factions. Each application triggers reinventing the wheel.

Candidates for “Planning" rules include flooding, rubbish and storage, space standards, “sustainability”, ecology, accessibility, noise level, boundary proximity, height, volume, Floor Area Ratio, Infrastructure contribution, Emergency access...all of which could be determined by an architect and checked by an approved inspector or similar but they could not prohibit development per se. Most of the world has such rules. So much of planning seems subjective. One of the things that takes time is sorting out opposing views within the planning departments themselves. When that happens, they usually go with the safe option ie. refuse or postpone. If the rules were clearer, so much harmless stuff could progress instead of being subjected to excessive pointless pseudo scrutiny. ACA (Association of Consultant Architects) says that once objective rules are formulated as many as possible should be shunted towards the building control system leaving planners free to deal with >>>

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BRIEFING: CLIPBOARD

CLIPBOARD

>>> exceptions, areas of special historical importance, exceptional beauty etc. where subjective interventions are helpful. I have heard Jack Airey interviewed and even though he is a Roger Scruton disciple I think he can be reasoned with and won around. He just needs a dose of skepticism about rigid “Design Codes” as a guarantee of aesthetic merit. Aesthetics will never follow clear rules… (if only) Anyway, this is THE important subject for UK architects to sort which stops our effectiveness. Sadly the RIBA love the system as it is because it provides fee paying “work” for architects to navigate an unnecessarily complicated process. I am disappointed that president of the RiBA has opposed these reforms ab initio.

A new safeguarded wharf, Royal Primrose Wharf, to go ahead

Action in the Old Kent Road Onward and upward not From Andrew Rogers I’m asked why is the two-storey block not given any pd rights. The reason is that the rules have become so complex that two-storey blocks of flats have been overlooked. Extension rights are given to dwelling houses (whether detached, semi-detached or terraced), blocks of flats of three storeys or more (up to a total height of 30 metres), and a variety of commercial or mixed-use buildings - such as blocks of flats that include shops or other uses. A two-storey block with only flats has therefore fallen between the cracks of the new legislation. Is that clear? ———————————————————-

Sylvan Grove, designed by HTA Design for developer Joseph Homes, will deliver 219 homes, of which 35 per cent will be affordable, and 33,000 sq ft of light industrial and flexible SME workspaces. The site is within the Old Kent Road Area Action Plan, an area undergoing extensive regeneration of large areas of industrial land.

PD for Freeports Ports are to be given the same permitted development rights as airports by April next year and the use of local development orders (LDOs) in such facilities will be "encouraged", the government has announced in a consultation response on its freeports initiative.

MHCLG has confirmed the continued protection of strategic sites for port use on the banks of the Thames in London after an extensive review process conducted by the GLA and supported by the Port of London Authority (PLA). Wharves on the Thames were first protected in 1997. Since then the initiative has become a wellestablished feature of planning in the capital and many millions of tonnes of materials have been handled through the sites, keeping countless heavy goods vehicles off London’s congested roads. Jules Pipe the deputy mayor for planning, regeneration and skills at City Hall received confirmation of the MHCLG secretary of state’s agreement with all of the recommendations included in the Implementation Report – Safeguarded Wharves Review 2018-2019 last month. The review included a consolidation of wharf capacity in Thameside West that had been the subject of work between the GLA, PLA and the London Borough of Newham, an area that is set to see significant development in the next few years. The consolidation results in the creation of a new safeguarded wharf, Royal Primrose Wharf, located immediately downstream of Peruvian Wharf and an increase in the area’s capacity to handle waterborne freight.

Two-stage competition launched for Camden’s ‘high-line’ The Camden Highline project, planned to open in phases from 2024, will create a new central London park and linear walking route – inspired by Diller Scofidio + Renfro’s New York High Line – featuring seating areas, cafés, arts and cultural interventions and spaces for charitable activities. The two-stage competition – organised by Colander Associates on behalf of the Camden Highline Charity – seeks a design-led team with the ‘right skills and ethos’ reports Merlin Fulcher in the AJ. The Camden Highline will occupy 1.1km of disused railway viaduct running from Camden Town to King’s Cross and the vacant platforms at Camden Road station, with a number of access points along its route to connect it to road level. ‘This is a very special project that needs an exceptional team both to design it and deliver it, one that balances design, community, nature and innovation alongside technical experience. For this reason, we invite submissions from partnerships which include established and experienced organisations alongside emerging designers’ they say. The Camden Highline project will regenerate an 18m-wide and 8m-high stretch of disused track, formerly part of the North London Railway.

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BRIEFING: CLIPBOARD

The City’s new civic hub for justice, policing and commercial activity The City of London Corporation has launched a full public consultation on its plans for a new courts, police and commercial development on Fleet Street, revealing design proposals for the three buildings and the landscaped masterplan. The flagship Courts building, with its main public entrance on Fleet Street, will be a combined court housing Crown, Civil and Magistrate’s courts, and will help to meet the objectives of the HM Courts and Tribunal Service’s reform programme by equipping the legal system with the facilities to deliver justice in the modern age. The new City of London Police HQ will bring together a large part of the force - currently spread across a number of buildings in the City - in one purpose-built headquarters, designed in consultation with officers and staff, to support modern policing and improve operational effectiveness. A commercial building will be located towards the rear of the site providing office accommodation and space for retail, bars, or restaurants at ground floor level, capitalising on proximity to the cycle superhighway along Embankment and drawing footfall down through the city towards the river. The masterplan, designed by Eric Parry Architects, prioritises walking and cycling with new east-west routes through the site. Landscaping and townscaping proposals make the most of the views of the Grade I listed Wren-designed St Bride’s Church and the historic fabric of the Square Mile. An integrated

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LEFT: Aerial sketch of the proposed Salisbury Square development (preliminary illustration). Eric Parry Architects. ABOVE: Passage to St Bride’s - A new east-west passage through the site will frame views of the historic St Bride’s Church (preliminary illustration) Dbox for Eric Parry Architects

public art strategy will be a vital part of the masterplan, imbuing a sense of public ownership and civic pride. New artwork will be integrated into the fabric of the buildings so that it becomes part of the architecture. The buildings have been designed so that each retains a strong individual identity whilst responding to each other and to the context of Fleet Street, the surrounding area and the wider City of London. The City of London Corporation has also laid out a robust, zero on-site emissions sustainability strategy for the Salisbury Square Development, which will include reclaiming materials from existing buildings where possible and creating adaptable, robust buildings designed to last at least 125 years. In addition, the buildings will be designed to international WELL Building Standards - the leading tool for advancing health and well-being in buildings globally. It is estimated that the new civic hub for justice, policing and commercial activity will support 2,100 jobs directly, including 400 brand new jobs in the City of London and an estimated 280 more through the supply chain and related economic activity.

£12 billion not enough say boroughs Responding to the latest details of the government’s Affordable Homes Programme, London boroughs have warned that the plans “won’t do nearly enough” to address the capital’s chronic shortage of affordable housing. Although they welcome the government’s £12 billion investment in affordable homes, there are concerns that London’s proportional share of the funding is being reduced – despite the capital facing the most severe homelessness crisis in the country. Boroughs also point to the significant need to increase investment in homes for social rent, while the government instead says it will rebalance grant funding in favour of affordable homeownership tenures. There are currently 243,000 London households on waiting lists for council housing. The capital accounts for two-thirds of homelessness in England and has the highest regional disparity between housing costs and household income. n

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¡PILLO!

¡PILLO!

Needing an outfit to match James Max writes of Rich People’s Problems in the Weekend FT. Agonising what to do in lockdown with his collection of Hermès ties, he says: "When I started my career as a chartered surveyor in the 1990s, hats were out, but suits and ties were compulsory. You could tell which department someone worked in by their choice of attire. An off-the-peg shiny suit, button cuff shirt and rubber soled shoes meant you worked in Property Management, dealing with bogs and boilers. Or you were a quantity surveyor and counted bricks. “City office agents (leasing clerks as I called them) and other highly specialised paper pushers with delusions of grandeur wore pinstripe suits. Surveyors flogging investment properties were the glamour end, doing the big deals and earning the big fees. Their garb comprised an Oxford shirt with a semi cutaway collar, striped or plain, with an end-onend or poplin cotton weave, double cuffs of course and a bright tie. Shoes were always black and had laces, unless you're a bit louche and had a buckle (I had a buckle). If you were working with the firm’s best clients you needed an outfit to match.”

Only in the unhinged western system The Financial Times also took a look at how safe it is to go back to the office. Here’s an online comment from Triple Bee Plus, who opines: “How safe?” An absolutely unaffordable luxury, falsely and irresponsibly propagated - only in the unhinged western system. How safe is it to drive your car? To cross the road, eat out, swim in the ocean.... mind you accidental death statistics in some of those activities are higher than the covid death rates. In other parts of the world people must work as normal to feed their families and they can’t afford to think “safety” on certain activities and ignore on others as the west does (ok to order takeaway food which may or may not be prepared by an infected cook but not ok to go to work for example..... ok to fly to South of France for holiday but not safe to take the train to work).

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I find it impossible not to resent the hypocrisy of it all. The FT response: ‘Frankly, Triple Bee Plus, the real reason most people are still working from home is that while they are allowed to, why would you go back to be near that annoying workmate?’

The virtues of virtual architecture “The lowest carbon building is one that doesn't need to be built”. So said Professor David Ness of the University of South Australia writing in the Architects' Journal. That must've gone down well with their readers!

to be established as part of the overhaul of England’s planning system. The body will be responsible for helping local authorities to create design codes which will be embedded into local plans. Boys Smith has been named as the head of a steering group which will advise the government on what the new design body should look like, and will later become chair of the body which is likely to be created in the first half of 2021. Announcing the appointment, housing secretary Robert Jenrick said there would be a ‘very, very strong’ emphasis on design – and the roles of design guide and codes – in the new English planning system. – AJ

Steve’s Bon Mots Nicholas Boys Smith to head new body to create local design codes The government has appointed Create Streets founder Nicholas Boys Smith to set up a new body which will oversee the creation of design codes for neighbourhoods throughout England The as-yet unnamed national organisation is set

One time government Chief planning officer Steve Quartermain is becoming known for his insights into the planning system now that he is working with law firm Town LLP. These include "A vision without reality is an illusion". And "This spring” – a government seasonal reference – “to be candid it means between now (March when he said it) and Christmas – but likely sometime later this year”. n


BRIEFING | PLANNING PERFORMANCE

Decisions down 9% so far this year but catching up on lockdown’s 22% drop Latest planning performance by English districts and London boroughs: Planning Applications in England: January-June 2020 OVERVIEW

April to June 2020 Between April and June 2020, district level planning authorities in England: • received 88,000 applications for planning permission, down 23 per cent on the corresponding quarter of 2019; • granted 71,700 decisions, down 22 per cent from the same quarter in 2019; this is equivalent to 87 per cent of decisions, down from 88 per cent in the same quarter of 2019; • decided 89 per cent of major applications within 13 weeks or the agreed time, up one percentage point from the same quarter in 2019; • granted 9,100 residential applications, down 17 per cent on a year earlier: 1,000 for major developments and 8,100 for minors; • granted 1,600 applications for commercial developments, down 26 per cent on a year earlier. January to June 2020 In the year ending June 2020, district level planning authorities: • granted 323,100 decisions, down nine per cent on the year ending June 2019; and • granted 41,900 decisions on residential developments, of which 5,300 were for major developments and 36,700 were for minors, down by 15 and eight per cent respectively on the year ending June 2019. This is equivalent to a decrease of nine per cent in the overall number of residential decisions granted.

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Taking account of the challenges and additional pressures local authorities have been facing due to the coronavirus outbreak (COVID-19), the department changed its data gathering and release practices for planning application statistics for the first half of 2020. This involved extending the period for submission of PS/CPS returns for the January to March 2020 quarter; the cancellation of the statistical release and live tables that had been scheduled for that quarter; and the publication of this expanded release, covering data for both the January to March 2020 and April to June 2020 quarters. Planning applications During April to June 2020, authorities undertaking district level planning in England received 88,000 applications for planning permission, down 23 per cent on the corresponding quarter in 2019. In the year ending June 2020, authorities received 398,700 planning applications, down 10 per cent on the year ending June 2019 (Live Table P134, Table 1 and PS1 summary dashboard). Planning decisions Authorities reported 82,100 decisions on planning applications in April to June 2020, a decrease of 21 per cent on the 103,900 decisions in the same quarter of the previous year. In the year ending June 2020, authorities decided 369,600 planning applications, down eight per cent on the number

in the year ending June 2019 (Live Tables P120/P133/P134 and Table 1). Applications granted During April to June 2020, authorities granted 71,700 decisions, down 22 per cent on the same quarter in 2019. Authorities granted 87 per cent of all decisions, down one percentage point from the June quarter of 2019 (Live Tables P120/P133). Overall, 82 per cent of major and minor decisions were granted, down one percentage point from the quarter ending June 2019 (PS2 development types dashboard). Over the 12 months to June 2020, 323,100 decisions were granted, down nine per cent on the figure for the year to June 2019 (Table 1 and PS2 development types dashboard). Historical context Figure 1 and Table 1 show 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 (April to June quarter for applications and July to September for decisions) and troughs in the Autumn (October to December quarter for applications and January to March quarter for decisions), there was a clear downward trend during the 2008 economic downturn, followed by a period of stability with reductions in more recent


RIGHT: FIGURE 1 Number of planning applications received, decided and granted by district level planning authorities

quarters. Historical figures for all district level decisions dating back to 2008-09 are set out in Live Table P120, with separate breakdowns for residential and commercial decisions being shown in Live Tables P120A and P120B respectively. These latter two tables are discussed below in the sections on residential and commercial decisions1. Speed of decisions • In April to June 2020, 89 per cent of major applications were decided within 13 weeks or within the agreed time2, up one per cent from the same quarter a year earlier. • In the same quarter, 85 per cent of minor applications were decided within eight weeks or the

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Planning decisions by development type, speed of decision and local planning authority. All tables and figures can be found here: https://tinyurl.com/yxhahqjf Source: MHCLG/ONS agreed time, unchanged from a year earlier. • Also in the same quarter, 90 per cent of other applications were decided within eight weeks or the agreed time, unchanged from a year earlier. Use of performance agreements Table 2 shows the increase in the use of performance agreements3 since April 2014. It shows that they are more commonly used for major developments than minor or other developments, with 69 per cent of major decisions made during

April to June 2020 involving a planning agreement, compared with 47 per cent of minor decisions 4. Figure 4 shows, from 2010, numbers of decisions on major developments made involving a performance agreement, both in absolute terms and as a percentage of all decisions on major developments. Notwithstanding definitional changes, there has been a marked increase in the use of agreements since early 2013. In reality, this longer upward trend has been driven by both the additional scope for recording them and their addition- >>>

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BRIEFING | PLANNING PERFORMANCE

>>> al use. The three final columns in Live Table P120 give corresponding figures for planning applications involving a planning agreement for all types of development (major, minor and ‘other’ combined), showing numbers of decisions and percentages decided within time. Performance of individual district level local planning authorities Live Tables P151a and P153 present data on the performance of district level local planning authorities against the latest published criterion in Improving planning performance: criteria for designation on the speed of decision-making for informing decisions on the designation of poorly performing local planning authorities under section 62B of the Town and Country Planning Act 1990. In particular, Live Table P151a gives detailed figures for the time taken for major decisions to be made over the eight most recent quarters and Live Table P153 presents data for the time taken by district level local planning authorities for decisions on ‘non-major developments’ (previously ‘minor and other developments’, and defined as minor developments, changes of use and householder developments) to be made over the eight most recent quarters. Similarly, Live Table P152a, presents data on the performance of district level local planning authorities against the latest published criterion in Improving planning performance: criteria for designation on the quality of decision-making for assessing performance under section 62B of the Town and Country Planning Act 1990. In particular, it gives detailed figures for the percentage of major decisions subject to a successful planning appeal, by matching eight quarters of the department’s data on decisions and all available quarters of Planning Inspectorate data on appeals. This table is usually published a few weeks after the statistical release and most of the other live tables, to take account of the latest appeals data. Live Table P154 presents data for the percentage of decisions on minor and other developments (as defined for Table P153) subject to a successful planning appeal, by matching eight quarters of the department’s data on decisions and all available quarters of Planning Inspectorate data on appeals. Like Table P152a, this table is usually published a few weeks after the statistical release and most of the other live tables, to take account of the latest appeals data. Residential decisions In April to June 2020, 12,300 decisions were made on applications for residential 5 developments, of which 9,100 (74 per cent) were granted. The number of residential decisions made decreased by 16

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per cent from the June quarter of 2019, with the number granted dropping 17 per cent. The number of major residential decisions granted decreased by 27 per cent to 1,000, and the number of minor residential decisions granted decreased by 15 per cent, to 8,100 (Live Table P120A, and the PS2 development types dashboard). In the year ending June 2020, authorities granted 5,300 major and 36,700 minor residential applications, down by 15 and eight per cent respectively on the year ending June 2019 (Live Table P120A and the PS2 local planning authorities dashboard). This is equivalent to a decrease of nine per cent in the overall number of residential decisions granted. 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.6 The latest provisional figures show that permission for 356,300 homes was given in the year to 30 June 2020, down 11 per cent from the 398,800 homes granted permission in the year to 30 June 2019. On an ongoing basis, figures are revised to ensure that any duplicates are removed, 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. These figures are provided here to give contextual information to users and have not been designated as National Statistics. Table 3 and Figure 6 show how the rolling annual total of housing units granted has changed since 2008.

FIG 9: Applications for prior approvals for permitted development rights reported by district planning authorities. England: 22 quarters from April 2014 to December 2019

Commercial decisions In April to June 2020, 1,800 decisions were made on applications for commercial developments, of which 1,600 (92 per cent) were granted. The total number of commercial decisions granted decreased by 26 per cent on the same quarter of 2019. In the year ending June 2020, 8,000 applications for commercial developments were granted, down 10 per cent on the year ending June 2019 (Live Table P120B). Trends in numbers of residential and commercial decisions Historically, numbers of residential decisions dropped sharply during 2008 (particularly for minor decisions) but have been increasing since 2012, albeit with some decreases recently. Numbers of commercial decisions made also decreased sharply during 2008 and then stabilised at around 2,100 per year for major and 10,000 per year for minor commercial decisions, but have undergone some further decreases recently, particularly for minor decisions. In 2019/20, numbers of major commercial decisions were at about 52 per cent of the pre-recession peak, with the numbers of minor commercial decisions being at about 34 per cent (Live Tables P120A and P120B, Figure 7). Householder developments Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (more details are in the glossary accessible from the Definitions section). The number of decisions made on householder developments was 43,500 in the quarter ending June 2020, accounting for 53 per cent of all decisions, down 22 per cent from the 55,800 decisions made in the quarter ending June 2019. Authorities granted 90 pc of these applications and decided 92 per cent within eight weeks or the agreed time (Ref Table 2 and PS2 development type dashboard).


Permission in Principle/Technical Details consent decisions In summary, during January to March 2020, local planning authorities reported 64 PiP decisions (minor housing-led developments), five TDC (minor housing-led developments) and no TDC (major developments). The totals for the April to June 2020 quarter were similar, at 60, four and no decisions respectively. Live Table PiP/TDC1. 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’. In some cases, if the legislation is complied with, developments can go ahead without the requirement to notify the local planning authority and hence no way of capturing data exists. In other cases, the legislation requires an application to the local planning authority to determine whether prior approval is required (more details are in the Definitions section). A local planning authority can withdraw specific permitted development rights across a defined geographical area, bringing these types of development within the control of the main planning process. The results for the latest quarter for which they have been collected (April to June 2020) are included in Live Tables PDR1 (local authority level figures) and PDR2 (England totals). Of the 6,600 applications reported in the April to June quarter of 2020, prior approval was not required for 3,600 and permission was granted for 1,700 and refused for 1,300. This

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resulted in an overall acceptance rate10 of 80 per cent. Larger householder extensions accounted for 64 per cent of applications (4,200), with seven per cent relating to agricultural to residential changes and six per cent to office to residential changes. ‘All other’ permitted development rights, accounted for 18 per cent of applications, up from 15 pc a year earlier. Taking i) granted applications and ii) those for which prior approval was not required together, 5,300 applications were approved without having to go through the full planning process, up 3 per cent from a year earlier. Within an overall decrease of one per cent in the reported total number of PDR applications between April to June 2019 and April to June 2020: • larger householder extensions decreased by one per cent; • office to residential changes decreased by 16 per cent; • agricultural to residential changes decreased by 15 per cent: and • ‘all other’ permitted development rights increased by 18 per cent. Figures for the total number of permitted development right applications made for changes to residential use for quarters from July to September 2014 are given in the quarterly worksheets in Live Table PDR1. These show that a total of 1,100 applications for changes to residential use were reported in April to June 2020, of which 800 (72 per cent) were given the go-ahead without having to go through the full planning process. Overall during the twenty-five quarters ending June 2020, district planning authorities reported 223,600

applications for prior approvals for permitted developments. For 126,900 (57 per cent) of them prior approval was not required, 52,300 (23 per cent) were granted and 44,400 (20 per cent) were refused (Figure 9). To put these recent figures into context, Live Table P128 and Figure 10 show how the number of ‘determination applications’ received remained broadly stable at around 5,000 to 8,000 per year from 2004/05 to 2012/13, but approximately doubled to 15,700 in 2013/14, following the creation of new permitted development right categories in May 2013. Since April 2014, there have been 36,500 PDR applications in 2014-15, 40,200 in 2015-16, 39,400 in 2016-17, 36,800 in 2017-18, 34,900 in 2018-19 and 29,100 in 2019-20. The quarterly pattern since April 2014 reflects a combination of both: i) the introduction of new permitted development right categories on several occasions; and ii) the seasonal peaks and troughs that have previously also been observed for planning applications, as shown earlier in this release, in Figure 1 (Live Table PDR 2 and Figure 10). The initially large increase since 2014 in reported numbers of PDR applications for a change of use (e.g. office to residential), followed by a more recent decrease, is consistent with the annual numbers of dwellings added to the net housing supply as a result of a change of use. These have shown increases of 65 per cent in 2014/15, 48 per cent in 2015/16 and 22 per cent in 2016/17, and a decrease of 20 per cent in 2017/18 and two per cent in 2018/19. n

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PROVISIONAL

The next meeting of the London Planning & Development Forum will be on Zoom Please join us on Wednesday 2nd December at 2.00pm This is the postponed March event and the agenda is being reviewed. Expect an equally informed and entertaining line-up! More at www.culandsoc.com - events as it happens

Annual Planning Update Wednesday 18th March 2020 Hosted by Dentons at One Fleet Place London EC4M 7RA 1.30 FOR 2.00pm followed by drinks

• The White Paper • Beauty and planning • The London Plan

INFO & BOOKING AT: https://tinyurl.com/ulmtscx or call 01638 507843

in collaboration with

BOOK AT: https://tinyurl.com/ulmtscx or call 01638 507843 Supported by Bath Publishing

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Planning in London

PROGRAMME ON NEXT PAGE >>>

Discussion will be reported in the January issue


ANDREW ROGERS

How the urn lost its listing With acknowledgements to Rudyard Kipling

This, O my Best Beloved, is a story - a new and a wonderful story - a story quite different from the other stories - a story about the most wise judge Lord Carnwarth and the rather strange case of Dill v Secretary of State for Housing, Communities and Local Government and Stratford-upon-Avon District Council: 2020 Now attend all over again and listen! Lord Carnwarth was wise. He understood what the beasts said, what the birds said, what the fishes said, and what the insects said. He understood what the rocks said deep under the earth when they bowed in towards each other and groaned; and the understood what the trees said when they rustled in the middle of the morning. And above all, he knew that a decorative urn, however large and imposing it may be, is not a building. Our tale begins in 2009 when Marcus Dill sold a pair of 18th century urns at auction for £55,000, that he had inherited alongside a Grade II listed manor house. Now these giant urns, attributed to John van Nost (circa 1700), along with their limestone piers, had been moved several times before they ended up on the entrance drive to Idicote Park in 1973, prior to the listing of the house in 1986. Mr Dill did not realise that the urns were included on the statutory listed buildings register and was therefore surprised and indeed aggrieved when Stratford-upon-Avon District Council wrote to him in 2015, asking him to restore them to their previous location. This being both difficult (as they had gone abroad) and expensive, he contacted English Heritage, who indicated that they would not agree to have the urns de-listed. However he decided to apply for Listed Building Consent to allow their removal, which the Council refused in February 2016 before serving him with a listed building enforcement notice in April. Mr Dill (unsurprisingly) appealed against the notice and the Listed Building refusal, but in January 2017 an Inspector dismissed both appeals. Action now moved to the High Court, which dismissed Mr Dill’s challenge to the Inspector’s decision in September 2017, and then the Appeal Court, which upheld that ruling in November 2018. So eventually we arrive at the Supreme Court and the learned judgement of Lord Carnwarth, handed down in May 2020. This clarified two separate legal issues: first, whether an Inspector determining a listed building appeal

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Don’t clap too hard, it’s a very old building – John Osborne The Entertainer 1957

under the planning acts is allowed to consider a challenge that something listed is in law actually a “building”; and second, what is a building? On the first issue, Lord Carnwarth determined

that because it is a Rule of Law principle that “individuals affected by legal measures should have a fair opportunity to challenge those measures…”, it was legitimate for Mr Dill to query whether the urns were buildings. On the second issue, Lord Carnwarth applied a test set out in the case of Skerritts of Nottingham v Secretary of State for the Environment, Transport and the Regions (no.2) (2000), that in common law the definition of a structure as a ‘building’ depends on its size, permanence and the degree of physical attachment to its site. In this case the urns were large but not as big as a house, were not fixed to the listed building and were (obviously) capable of being moved. In addition, they were not even part of the original manor. The moral of this tale, Best Beloved, is contained in Lord Carnwarth’s comment that there is “a disturbing lack of clarity about the criteria which have been adopted by the relevant authorities [such as English Heritage], not only in this instance but more generally, in determining whether free-standing items such as these are regarded as qualifying for listing protection”. Appearance on a statutory list does not necessarily mean that an object is a ‘listed building’. “If it is not in truth a building at all, there is nothing to say that mere inclusion in the list will make it so”, he added. Clarity in listing (as with much else in planning) is required. It is not simply that an object may be of special artistic or historic interest in itself, but “the special interest must be linked to its status as a building”. So now we know, a listed building is a building, not the works of art contained within or around it - unless, indeed, they are an essential part of the original design. So that’s all right, Best Beloved. Do you see? n With aching hands and bleeding feet We dig and heap, lay stone on stone… Not till the hours of light return, All we have built do we discern – Matthew Arnold 1852

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THE LONDON SOCIETY

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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Planning for the Future and other changes, including Government White Paper reforms Account of Forum Zoom Meeting on 7th September 2020: Greater London 2020-45 Full minute by Drummond Robson at planninginlondon.com > LP&DF Minutes of the meeting held as a zoom session on Monday 7th September 2020 between 2.30pm and 5.00pm (BST) Brian Waters acted as convener in Spain. Introductions and Apologies. Apologies were given by Riette Oosthuizen, Brian Whiteley, Max Farrell, Andy Rogers and Hugh Ellis. DISCUSSION TOPICS on the agenda: a Planning for the Future and other changes including Government White Paper Reforms. The consequences of Zoning for Planning. Simon Ricketts (Partner, Town Legal) has confirmed his attendance to introduce the item. Michael Edwards (Hon Prof, Bartlett School of Planning, at UCL and his colleagues, notably Ben Clifford) also provided contrast to the government’s proposals as a compendium of quick reactions from a dozen university planners in a paper entitled “The wrong answers to the wrong questions”. b The London Plan Reviewed. See Rethinking The

Planning System for the 21st Century by Jack Airey and Chris Doughty of The Policy Exchange. A Policy Exchange representative has been invited but no-one was available. Their report A Planning System for the 21st Century with its advocacy of Zoning is nevertheless finding favour in government and will form part of wide ranging reforms. Its vivid cover of dense urban development is certainly unmistakable, (though I wouldn’t want anyone to live or work there, certainly post COVID DR): One of its key tenets is that “Land should be zoned either as development lanwhere there is a presumption in favour of new development, or non-development land, where there is not a presumption and minor development is only possible in more restricted circumstances. Land zoned as development land will include existing urban areas and urban extensions made possible by improved infrastructure.” c Reconsidered purposes of the High Street following the Pandemic d Launch of Suburban Task Force introduced by Jonathan Manns and Dimitrios Panayotopoulos. e Account of the Lockdown Meeting held on

Monday 1st June 2020, Chaired by Brian Waters and set out in PiL on July 12th. f Expected Next Meeting planning update seminar hosted by Dentons and administered by the Cambridge University Land Society on 2nd December 2020 starting at 2 pm. Brian Waters welcomed participants saying that there had been a Tsunami of papers from government associated with the White Paper reforms – some appearing to be disconnected in their present form. He introduced Simon Ricketts, Partner at planning law firm, Town Legal LLP who has provided clear interpretations and assessments of the proposed changes and has given advice at Webinars organised by Landmark Chambers. He introduced the topic for discussion. See also https://simonicity.com/2020/08/07/ for-the-future/ from which the following is an extract: The Government “proposes a revised standard method for calculating local housing need which will be used as the basis for plans created prior to any changes outlined in Planning for the Future

Meeting held on Monday 7th September 2020 on Zoom Brian Waters (Chairman) Alix De Nercy: Deloittes Manager FA Real Estate Ben Clifford: UCL Dimitrios Panayotopoulos:UCL Duncan Bowie: Ian Butcher: Janice Morphet: UCL Jessica Ferm: UCL Judith Ryser: Ugb/Cityscope Europe

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Karen McCormick: Senior Development Manager at U+I Lisa Fairmaner: Head of London Plan GLA Mark Willingale: Michael Bach: Michael Coupe Michael Edwards: UCL Nick Belsten: WSP Professional Services Nigel Bidwell: Nigel Abbott: UCL

Paul Finch: Editorial Director of AJ and AR and jt publishing editor of Planning in London Peter Eversden: London Forum Ron Heath: Living Architects Sarah Bevan: London First Simon Ricketts: Stefanos Koryzis: Tim Wacher: RICS Drummond Robson: Honorary Secretary


being introduced.” There will be two steps: Step 1 – the “baseline for the standard method should be whichever is the higher of 0.5% of existing housing stock in each local authority OR the latest projected average annual household growth over a 10-year period” “The household projections element of the baseline will use the latest ONS national household growth projections for the local authority area (Principal projection, table 406). The projected average annual household growth over a 10year period (10 consecutive years, with the current year being used as the starting point from which to calculate growth over that period) will be used.” Step 2 – “We propose the standard method will include two adjustments to the baseline using the workplace-based median house price to median earnings ratio. Initially it is proposed that

the ratio for the most recent year for which data is available in order to address current affordability of homes would be used. Then how affordability has changed over the last 10 years of published data would be incorporated, using that same statistic.” The precise formula is reproduced below The Government proposes the following transitional arrangements: “from the publication date of the revised guidance, authorities which are already at the second stage of the strategic plan consultation process (Regulation 19) are given 6 months to submit their plan to the Planning Inspectorate for examination. Authorities close to publishing their second stage consultation (Regulation 19), should be given 3 months from the publication date of the revised guidance to publish their Regulation 19 plan and a further 6 months to submit their plan to the Planning Inspectorate.” Simon Ricketts explained that it was one

month and one day since MHCLG issued the White Paper and the shortened version which contains the measures to calculate housing need figures. These will be set by government rather than determined locally. (Lichfields have made an assessment of implications of using the formula set out above). Other papers are also being issued providing a diversity of disparate measures aimed at rewriting the planning application process. Three new key land categories are proposed as set out in the White Paper. • Land suitable for growth will be approved for development at the same time that plans are prepared, meaning new homes, schools, shops and business space can be built quickly and efficiently, as long as local design standards are met. • Renewal areas will enable much quicker development where it is well-designed in a way which reflects community preferences. • Development on Green Belt land will continue

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to be restricted as it is now with policy remaining a decision for local authorities as they prepare their plans.

Simon summarised this succinctly as: Growth Areas Renewal Areas Protected Areas He queried how these will be made to work in practice assuming consultation is required during concurrent local plan making, with comments on the White Paper by 29th October and the short term measures paper by 1st October. The housing assessment by Lichfields for London is set out below in plan RIGHT and tabular form on the next page. Local authorities are being required to prepare new local plans too, and to tight timetables, namely 30 months from start to finish, abolishing soundness and duty to co-operate in favour of a sustainable development test (however defined). (Though not mentioned by Simon, if that were not enough the government commissioned PwC, also in August, to evaluate the importance of scale for the reform of local government reorganisation presaging the White Paper on Devolution and perhaps resulting in merging county and district councils to create unitary authorities with obvious cost benefits). Simon also referred to digitisation, availability of data, and tying in the conclusions of building better using design codes and technical and local plan details in each of the newly zoned areas. Infrastructure with replacement of the current community infrastructure levy (CIL) and s.106 system to result in the combined infrastructure levy. He explained that this meant contributions to affordable housing from a national levy based on value at the time of permission being granted, but payable before occupation. There is no guidance on how the London Plan is supposed to fit into the White Paper (although Lichfields housing assessment perhaps offers some clues).

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DR asked when the local plans should be completed by. Simon explained that is should be by the end of this Parliament which is May 2024 so legislation needs to be enacted by September 2021 to enable this to happen, hence a bill early in 2021 in Parliament. Brian Waters thanked Simon for his clear summary and invited Simon’s to be followed by Ben Clifford of UCL. Ben referred to the TCPA’s The Wrong Answers to the Wrong Questions (which included many academics’ reviews including those by Michael Edwards and himself). See https://www.tcpa.org.uk/Handlers/Download.ash x?IDMF=f53db0a4-b78d-4898-80e4647080dad84b Ben Clifford was very critical of the White paper and the short term measures paper and very questioning of many of its tenets. He specifically cited the protection of Green belt which would do nothing to relieve housing pressures on London. He preferred to defer to Michael Edwards who invited closer consideration of the Wrong Answers to the Wrong Questions criticisms. He encouraged everyone to read the papers. He cast doubt on the rationale that not

enough housing was being built because of delays in the planning system. He thought that lack of supply was not the main or only drag on the system, and did not justify turning to a zoning methodology, simple or not. However the detail of this is yet to be discerned. Michael asked who should write the zoning definitions given that urban development is complex. He pointed up that evidence from other zoning systems that these don’t normally make quicker or simpler decision making. (Ben Clifford made the related concern of pattern book design being facilitated by zoning). Michael considered that merging CIL and s.106 agreement finance, based on a national rate of charge, would do nothing to ease spatial inequalities (GDV yielding more in SE and little elsewhere) and would be likely to result in less money for affordable housing. First Home will have to be met as a priority from the combined fund. He added that the public expressions of concern are usually made much later than the front loading of consultation proposed will allow. [But development can’t be planned on the basis of being delayed simply to satisfy later concerns, can it? It’s like complaining about a grocery delivery because


the grocer’s selection has earlier use by dates than you would like – you can’t have it all! – DR.] Michael concluded that most people now have access to online data and resources which could help if used well for planning but about 15 million have no or very limited access and must not be excluded. Brian Waters acknowledged the many uncertainties at the current stage of White Paper exploration but said that this was something for us each to influence in different ways as more is revealed. Brian then invited Karen McCormick Senior Development Manager at U+I for a high level developer perspective on “all this”. Karen spoke of the large mixed use develop-

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ments of their business which dominate their portfolio. Even though they have site specific allocations it still takes a long time to work through the detail of a scheme with a Council. Looking at the White Paper the Company’s interest is in whether it will speed up the process of Masterplans in spite of the large consultant teams spending millions of pounds getting the detail right. Whether the new processes will assist remains uncertain as yet. Jonathan Manns concurred with this and wondered how the White Paper will affect London. Perhaps no change? (Duncan Bowie indicated disagreement with this). Picking up from Michael Bach Jonathan wondered if Housing numbers might be “smudged” across London giving anxieties about the future charac-

ter of places, notably in Outer London – and which Dimitrios Panayotopoulos plans to study. Duncan Bowie suggested that the intended new authorities both inside and outside London will be impacted by the proposals just as much as elsewhere, certainly implying significant change to the Capital. He thought a particular weakness of the proposals is to provide new accommodation where capacity is currently limited and where infrastructure affects a larger number of areas. He doubted whether the White Paper, having removed the duty to co-operate, will provide any mechanism for inter authority co-operation, irrespective of size. The Devolution White Paper may assume that all local authorities become a unitary authority with strategic planning powers, though >>>

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BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM

>>> not necessarily dealing with some of the strategic powers which currently concern us. Michael Bach was concerned with Housing need, not in a demographic sense - for London – the 93,000 of the 300,000 – which is far more than any other target we have ever had. This has no relation to the capacity for London to provide that. Lichfields data indicates that some Boroughs will have huge targets which are impossible to meet. No-one has a distribution or redistribution role to overcome this problem. Michael Bach also reiterated Michael Edwards concerns in relation to community engagement. He thought that neighbourhood planning was Cuckoo-land in London. People should continue to be able to tailor local plans to local communities and local circumstances. Mark Willingale responded to Michael Edwards’ last point, on the substantial growth of planning data sets, by noting how the planning reforms, accompanied by the new use classes orders, PD extensions and proposals for local government reorganisation, share an ambition to create open-access, interactive planning data sets supported by “PropTech”, a term found peppered throughout the WP. A standardised, rules-based, 3D digital planning data set for each LPA would enable the formation of a 3D digital planning data

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The White Paper “pillar 3” building beautiful sustainable places has within it a number of images which are presumably intended as expressions of good design, but perhaps beauty may also be in the eye of the beholder and are these places we should want to live in? A selection follows

model for the whole of England that everyone could share and refer to. (The MoD is using a similar system for a war games program). The ambition promises a much more accessible and democratic process than the current system. Brian sought to reconcile this high level thinking with the practical aspiration of “Build, build and build”. Defra’s https://magic.defra.gov.uk/ is exactly the kind of open-access, rules-based, interactive mapping technology that is behind the ambition of the planning reforms. It is available to everyone. It contains nothing, absolutely nothing, however about the Green Belt since this has no con-

ceivable definition. Brian then invited Lisa Fairmaner, Head of the London Plan to say how this was being seen in the GLA, and the aims to try and get a London Plan adopted before the next National election. Lisa spoke of the need for certainty, in spite of some necessary delay. 24th December 2019 GLA request has taken until 13th March 2020 for a Direction but in September 2020 we still do not have an agreed Plan. Holding up a decision on 93,000 homes – a large proportion of the national total – is causing delay not just in London but much of England. She believes there is some reference in the documents for London still to have a role in the allocation of targets. Chris Pincher made reference to local authorities applying the identified constraints, even though it is expected that the government will issue binding government targets. Raising affordable housing thresholds to 40 or 50 would be horrendous for London where many sites are smaller than that. GLA would expect growth in poorer areas – 15 minute cities with people living their lives more locally. She feared growth of inequalities in London. She was concerned too about problems arising from new zoning ideas, having regard to her own experience of using zoning which could lead to mismatches between the rules and what developers want to do. Nick Belsten thought that the Mayor would be given responsibility to allocate targets in London but that local authorities lack the resources and skills to fulfil this role. He also


thought that cpo powers would be needed for adequate land assembly to achieve White Paper aspirations, and that again the skills are lacking to deliver the prospective growth areas. He thought that local minority groups which are currently ignored will need to have a wider role in consultation and engagement, going well beyond the technological solutions suggested. Duncan Bowie, endorsing Nick Belsten’s view of cpo said that local authorities will need powers to acquire at existing use value, He thought that SHLAAs will be needed on a City Region basis and queried the value to the proposed algorithm to assess housing need. He also considered that a review of Green Belt is absolutely essential for the whole region in considering housing capacity. Peter Eversden repeated criticism of housing need numbers and referred to the MHCLG writing to the Mayor in March seeking a joint review with the wider south east. He elaborated with other criticisms of the irreconcilability of the proposals and policy. Judith Ryser asked what purpose the London Plan was supposed to fulfil and the purpose of a two tier system. This provocative question invited a wide range of responses. Mark Willingale however responded as a professional saying that frequently the planners ask him to tell them what the megabytes of data which the authority has asked for mean in terms of their policies! He concludes that the system has

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failed in terms of overload of information. He suggested that the new unitary authorities should provide a new data model based on the data model they already have, so that the decision becomes more self evident. He suggested that the London Plan has no role in this and would just disappear. DR asked why we are all so very good at criticising the various plans that are proposed and yet we have a very large range of extraordinary people in this zoom session who are very capable in suggesting what should be done rather than spending all our time criticising what is not being done. Instead we have sophistications in skills we ought to be using. It is what we are capable of providing. Michael Edwards supported this case, as the academics’ report backs up. Brian Waters followed this by inviting people to read Michael Edwards precis in the next PiL and saying there should be more emphasis in visionary planning and less on development management – engage more in plan making and less of the NIMBY attitude of trying to stop housing being built. Instead people need to be encouraged to engage at the planmaking or zoning stage. Interestingly Peter Eversden interposed in this to say, not what he was doing, but his interpretation of what Ealing, Hounslow and other policy making Councils were doing with large numbers of policies – thus acting as policy amplifier and interpreter to a wider public rather than being concerned with the plan itself and making it work. >>>

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Paul Finch said that the tone of much of the present meeting explains why the government has introduced the White Paper. You can’t use the technology because it doesn’t work and wipes out what people can actually see in what is proposed for their areas, drawings they can understand with 3D models. He considered that the White Paper is the most radical reform since 1947 and also the Community Land Act 1975 were trying to do. These defined where we should actually be building – in other words it is plan led: actually have to have a plan. The next objection is that you cannot produce a plan in that amount of time because you need environmental assessments etc. – you can’t do this, you can’t do that, whereas in fact of course you can. It is what people around this table should do to make this happen using the huge opportunities which are possible. He urged moving away from a party of gloomsters.

He therefore supported the radical measures which are exactly what is being proposed. Brian Waters at this point suggested that we should turn to two subsequent items, (passing over the London Plan already considered) since both will have effects on the lasting impacts of the pandemic on spatial planning in the suburbs (Town centres and High Streets) and where people gather. This has been succinctly expressed (by Philip Aldrick Economics Editor of The Times and Sunday Times) as

“off line to on-line, office to home, mass business to zoom, central to local, efficiency to resilience” BW asked Jonathan Manns and then fleshed out by Dimitrios Panayotopoulos “what is the Suburban

Task Force?” Jonathan explained that it was voted on by a cross party group of MPs in March 2020 since suburbs have become a hot topic: The Red Wall has become the Blue Wall, suburbs have been neglected. It is where many of us live and so require more considered appraisal – character, challenges and opportunities etc. both quantitative and qualitative. (Also in answer to a later question by Jessica Ferm) It raised was prior to the pandemic. It is currently making a call for evidence, with a view to publication midway through 2021. It is been largely led by UCL and Dr Lucy Natarajan. Michael Edwards offered the reference to a report Peter Hall. Drummond Robson and he wrote in 1999 just before the formation of the GLA: London’s Spatial Economy: the dynamics of change London, London Development Partnership (LDP) and Royal Town Planning Institute. Eprint


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free at http://discovery.ucl.ac.uk/ 1369585/ This led in practice in the Overground. Jonathan and Brian invited Dimitrios Panayotopoulos to speak with a slide presentation of Towards a Suburban Renaissance. He may be contacted at d.panayotopoulos@ucl.ac.uk / @dimitris_pan An Inquiry into the Future of the Suburbs. This was set out as a largely methodological catalogue of what the group intends to do and so it is premature as responding to the questions of the previous intense debate. Brian Waters and Peter Eversden also raised the seven year work of the Outer London Commission which the present administration did not want to pursue. Also the July-September 2020 edition of PiL – issue 114 - is also very relevant in our present context. Dimitrios as a final comment said that the issue of scale should be made more prominent. The goals and aims of the research are 1 To unpack the nature of socio-economic activity in the suburbs. 2 To illustrate the potential differences between suburban areas and those which are either more central or more rural. 3 To identify policy mechanisms and interventions which may assist in supporting the long-

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term sustainability of suburban areas. Phasing Phase One is intended to establish key considerations. It will focus specifically on the Outer Boroughs of London. Phase Two is intended to expand upon initial conclusions and assess whether it is possible to expand the geographic focus of the research Key considerations and questions 1 The Nature of Suburbs 2 The Circumstances facing Suburbs 3 The Policy Framework 1. The Nature of Suburbs What are the unique characteristics of suburban areas? How might we define suburban areas, and differentiate them from urban / rural areas, in terms of their social, environmental, economic, and other dimensions? 2. The Circumstances Facing Suburbs What unique challenges and opportunities face suburban areas? What are the concerns and aspirations of suburban communities for their places? Are there any dimensions of spatial equality, which are unique, or of particular relevance to

suburban areas? How might the nature of suburbs affect issues of social, environmental, economic, or other types of disadvantage? 3. The Policy Framework What are the governance implications arising from these challenges and opportunities? How can policies, policy-thinking, or policy networks adapt to the needs and goals of suburbs? What existing policies or policy ‘silences’ have the most significant impact on the suburbs? What new policy reforms or new policy initiatives could be deployed? Call for Evidence Aim to compile a dataset that allow us to reflect on the existing relations between selected suburbs and London. Socio-economic characteristics Transport The commercial link between suburbs and London Spatial characteristics Environmental characteristics Investment and development patterns and history

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Plus Open Questions. Summarising the meeting Brian emphasised the need to embrace the need for change. He reminded us of the information lists produced by Arups as checklists of what should be provided as part of all planning applications. Government said that local authorities would use only what they need, but since this discretion has been ignored, using the fear of judicial review as the pretext so requiring lorry loads of (digital) reports, hundreds of consultants and huge expense to the applicant. PiP will become the new outline planning application as a counter to this. He also invited more consideration of the value of time as part of the planning process.

Next meeting is planned for 2nd December at Dentons and will be administrated by the Cambridge University Land Society (CULS), either face to face or on zoom or both. The agenda is likely to flow from White Paper outcomes but much can change in the interim. SEE back cover for details of how to book. It replaces the annual planning update event postponed from March – flyer BELOW.

Annual Planning Update Wednesday 18th March 2020 Hosted by Dentons at One Fleet Place London EC4M 7RA 1.30 FOR 2.00pm followed by drinks

• The White Paper • Beauty and planning • The London Plan in collaboration with

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LONDON PLANNING & DEVELOPMENT FORUM POSTSCRIPT: PAUL FINCH

In short, let planners free! The Forum discussion provoked paul Finch to write this postscript I neither expected nor intended to be the last speaker in what was a fascinating discussion about the White Paper, particularly in respect of the implications for the London Plan, which I must say I had not previously thought as being threatened. One to watch. I agreed with many of the points made in the discussion; I have some serious criticisms of the WP in respect of its genuflection to the BBBBC’s notions about aesthetics – they cannot define ‘beauty’ in planning terms, which is a problem to put it mildly. However, as a very occasional attender at Forum discussions, my observation was that the overarching tone is one of relentless negativity. It is rather as though the Forum reviews any proposal rather like a planning committee which has fallen prey to the idea that is there to promote development control. What I like about the White Paper is that it takes planning seriously as a proactive and constructive activity, in respect of spatial development and the future of our towns and cities. What is wrong with trying to identify areas in each planning authority that are suitable for growth, reinforcement or protection? It requires the sort of thought and analysis which made British town planning the envy of much of the world before the system became a Sergeant Hodges ‘you can’t do that here’ issuer of rationing coupons. There has been no real attempt to address the issue of development land potential since the Community Land Act introduced by Anthony Crosland in the early 1970s. Although not properly thought through, the question it addressed is extant – and I believe the White Paper is tackling it head on. The motives of its proponents may well be different from those of Crosland et al, but they are the same issues. Three other strands presented during discussion seem worrying: 1 Technology is the enemy of democracy and communities. This strikes me as bizarre, and a reflection of the age of most forum representatives, even though they themselves are perfectly capable of deploying the tech. You posit a problem for people without technology, who you then assume will be the most active consultees (really?), and then condemn the bulk of the community to struggling with conventional drawings and zero data, even though it is readily available. 2 The fantasy that London cannot house itself within its own boundaries. This is a hangover from GLC days, including the Location of Offices Bureau, which had a death wish about the capital and advised anyone with any sense to leave it. We created overspill locations, compromising decent market towns like Ashford, as a result of a complete lack of confidence in London itself. As was subsequently proved by the repopulation

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Paul Finch is editorial director of Architects’ Journal and AR and joint publishing editor of Planning in London

of London from the late 1970s, we didn’t have a problem at all. As the LSE’s Tony Travers has pointed out, were we to develop out London (the developable bits that is, not everything), to the same density as Kensington & Chelsea, we could accommodate twice our current population. (No doubt the development control fraction will give a hundred reasons why this is impossible!) And as stated in the discussion, London has accommodated 2 million net incomers without expanding its boundaries in the last 25 years. 3 This of course would affect the suburbs, the second part of the discussion. After more than 50 years as part of London, some of the outer London boroughs (eg Bromley) are in denial about being part of London at all. In considering London-wide housing requirements, they absolutely are, whether they like it or not. The ridiculed target of 90k-plus new homes per year for London is far from ridiculous if you regard it as 3,000 homes per borough, most of which are the size of provincial towns. What is the problem? If the London Plan is to be believed, we need housing for an additional 1 million people over the next decade. One million divided by ten is . . . My final general point relates to politics rather than spatial planning. I do not believe, along with probably all Forum members, that it is possible (or desirable) to generate the required level of affordable housing in London by relying on/penalising housebuilders, a failed strategy under three mayors. It is an absurdity. London (sort of) housed itself for a century in a mixed-mode way, prior to government restrictions on public house-building in the early ‘80s. There is no reason why a public sector-led housing construction programme should not be re-introduced at scale, if the political class is prepared to support the idea. Isn’t it time to recognize that spatial planning and economic planning, while related, are not synonymous? Nor is spatial planning and the minutiae of environmental control, which should be left to people equipped to assess it. In short, let planners free! And in a best Michael Edwards sense, view problems and challenges in the round, always looking for desired outcomes rather than outputs. I feel that is the decent aspiration of the White Paper, despite some detailed drawbacks. n

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MODULAR BUILDING | MIKE DE’ATH

Build Homes, Build Jobs, Build Innovation Mike De’Ath outlines the thinking behind the report he has co-authored with Mark Farmer

RIGHT: Holloway Ride modular building by HTA Design

Mike De’Ath is a partner in HTA Design

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We stand at a critical juncture in our nation’s history. The global Covid-19 pandemic has had a structural impact on our society and economy in a way we could not have imagined even a few months ago. What the UK now faces is the critical task of rebuilding confidence across a range of areas including public health, job security, consumer spending, and of course the housing market. There is no doubt that we are in a period of massive disruption for housing delivery, with the potential for significant lasting impact. The Government has previously stated its objective to deliver 300,000 homes a year by 2025 to meet the country’s needs, whilst the Prime Minister has promised that his Government will ‘Build, Build, Build’, putting investment at the heart of the post-pandemic recovery, with housing clearly on the agenda. The recent Planning White Paper also offers opportunity, removing some of the hurdles to ambitious investment in housing delivery, and accelerating the procurement and design process through the introduction of pattern books and design codes. In our recently published whitepaper, Build Homes, Build Jobs, Build Innovation, my friend and colleague Mark Farmer (Government MMC champion and CEO of Cast Consultancy) and I propose that modular construction should play a key role in the UK’s recovery, with the potential delivery of 75,000 new modular homes a year, creating 50,000 new jobs, reducing carbon emissions by 40 per cent, and delivering on the Government’s levelling up agenda. As practitioners, we have benefited from operating with long term relationships in sectors which have ebbed and flowed through the three most recent recessions, giving us some insight into how the government and housing market might react to the predicted slowdown that will follow the current pandemic. The urgency for creating a multiplier effect in the post pandemic economy is unprecedented. Any measures need to flow both into the construction supply chain and, in turn, the wider market in a way that supports economic recovery as well as the UK target to achieve a net zero carbon economy by 2050. We are seeking to create a platform for significant additional housing delivery and market diversification that also places modern methods of construction (MMC) and, particularly, modular manufactured housing at the heart of making quality homes. In doing so we envisage a major industrial strategy boost that moves us towards a greener future with resulting jobs and opportunities. The past decade has seen significant growth in the use of modular construction in the UK and at HTA Design we have long championed its many benefits, delivering numerous envelope-pushing projects across the country. Despite this modular is yet to make it into the mainstream in housing delivery.

One major hurdle has been the planning system: Planning has been the punchbag for the failure to deliver homes for many years, particularly for housebuilders, and it’s not hard to see why. I personally have sat in many planning committees where several years of work and investment of, sometimes, millions of pounds of clients’ money comes down to some pretty alarming conversations between members, on occasion incredibly ill informed, who had just considered a rear extension in the same session. Modern (including modular) methods of construction (MMC) necessitate a high up-front investment cost, as well as certainty: production slots must be booked in factories, with potentially hundreds of people relying on jobs in a production line. The risks posed by the present planning system, often incurring lengthy delays, are unsurprisingly prohibitive to the kind of pipelines that manufacturers must work with. In our consultation process, manufacturers overwhelmingly told us it was impossible to invest in greater delivery, where planning created a binary outcome that could mean a huge gap in the production line. For modular manufacture to scale up we need a long-term visible pipeline of demand that allows the investment necessary to build, we believe, a further 75,000 additional homes a year by 2030. The Government’s Planning For The Future white


paper provides an opportunity to transform the system, potentially opening up a far swifter and less costly approval process, which will give modular construction its chance to become an increasingly viable and mainstream form of construction, helping to deliver much needed homes across all tenures. The white paper also represents a great opportunity to use a more digitised and progressive planning system to enable a whole new generation of digitally designed and manufactured high quality homes using mass customisable pattern books to align to local design codes, creating beautiful, high quality homes that are appropriate to their local context, at maximum speed. As well as quality, lower carbon, reduced waste and reduced disruption, the phenomenal speed with which homes can be delivered is perhaps the biggest benefit of modular construction. Our country needs this after 40 years of failure to keep up with demand. This key feature of modular delivery is one of the main attractions for us as designers. Often, we find projects in a traditional process are designed without a contractor on board, using costings based on market research up to planning. On consent the scheme is tendered at which point extensive ‘value engineering’ is applied either with the client knowledge, and sometimes without it, in a ‘design and build’ contract. Sadly, we find such schemes are often quite different to the consented vision, often with the design architect being replaced by delivery architects without the commitment to the original design intent. There are

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also obviously now questions regarding construction and material defects which are coming to the fore on buildings which are effectively ‘one-offs’, where continuous improvement is just not a realistic principle. If a modular manufacturer is engaged from the outset, with a system that is flexible and responsive to local context, the architect, who should consider themselves a ‘designer in industry’ can create beautiful homes at planning stage that will be the same delivered post approval. A manufacturer is not interested in testing the market for a better price, extensive value engineering or waiting for market prices increases. The costs are largely known at planning stage and the prime motivation is productivity in the factory. We concluded that the most important step to achieve the growth in modular manufactured homes was to create a smooth, sustained, long-term pipeline of demand that is visible and appropriate for modular delivery. To do this we are calling for greater collaboration and aggregation of demand by the public sector, underpinning the nascent growth in municipal housebuilding. This requires the spanning of planning jurisdictions with a pooling of knowledge, processes, standards, R&D, typologies, land and commitment into a programme of scale that can be aligned to capacity and readily manufactured. Fundamentally, our requests of Government are as follows: • Modular must be placed at the heart of policy and the ‘build build build’ agenda, with co-ordination between BEIS, HMT and

ABOVE: Greenford Quay modular building by HTA Design

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MODULAR BUILDING | MIKE DE’ATH

RIGHT: Padnall Lakes modular building by HTA Design

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MHCLG to implement modular homebuilding activity as a primary lever for levelling up the UK. • Additional funding must be allocated to more diverse forms of housing that can be absorbed quickly into the market with linked targets for modular housebuilding, building further on the recent announcement of MMC targets being set in the 2021 – 2026 Affordable Housing Programme. • We must capitalise on the planning white paper’s ideas to promote more rules-based and codified planning to help accelerate modular delivery and create beautiful manufactured homes. • Homes England must create a national level brokerage platform, that simplifies the procurement process by bringing buyers and sellers of modular housing together at a scale that allows the market to grow sustainably. Our propositions require a change in planning, and design codes and zoning proposed in the white paper could be the opportunity to bring a new digitised environment for precision manufacture of homes on the scale that the country needs. There is no doubting the challenges ahead, but the potential to transform housing delivery so lacking for the past four decades, could be a positive to come from the pandemic and one we at HTA, along with Mark Farmer and our industry consultees, are keen to help realise. Our ask of government is simple: help us stimulate and then galvanise the demand for modular homebuilding. With this help, a sustained long-term pipeline can underpin investment in manufacturing to deliver the quality homes we need, creating the jobs we want. n

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HOUSING TARGETS | LONDON FORUM OF AMENITY SOCIETIES

The Standard Method has produced unlikely figures London Forum has responded to the consultation on ‘Changes to the Current Planning System’

Michael Bach drafted this response for the LFofC&AS

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The following comments are made on 1st October 2020 on ‘Changes to the Current Planning System’ consultation by the London Forum of Civic and Amenity Societies, a charity established by the Civic Trust in 1988 to network, support, inform and represent over 120 community groups in London, which in turn have over 100,000 individual members. Standard method for assessing housing numbers in strategic plans Our key points on this subject are that • The Standard Method would give targets for some London boroughs that would not be achievable due to land capacity restraints, yet it gives up to a 25 per cent reduction on the number of homes in some boroughs compared with the commitment to a high figure those local authorities made in 2019. • The methodology applied for housing targets in London using SHMA and SHLAA processes was approved last year by Inspectors of the draft New London Plan, now the ‘Intend-toPublish’ version. It would utilise land in the capital for housing in a more efficient way than the Standard Method would achieve. • The Standard Method formula considers the unaffordability of homes to buy in locations in England but in London, market homes are affordable to only 8 per cent of the population. Homes to rent at prices key workers can afford is the housing requirement in the capital, calculated as required to be 47 per cent of all new homes built which the Standard Method would not ensure were delivered. That would be a serious problem as it is vital those truly affordable homes are built to alleviate the problem of “overcrowding and concealed households” (para.13 of the consultation paper). London Forum’s full comments that follow on this subject deal with the specific circumstances of London, where, unlike most of the rest of the country, the physical and policy constraints have meant that reconciling “objectively-assessed need” and capacity has been difficult. Most London boroughs’ new housing is achieved 95 per cent or more on previously-developed sites – in almost all boroughs there are no greenfield sites other than Green Belt and Metropolitan Open Land, both of which have the same level of policy protection. In London, the London Plan process considers both the “need” through a Strategic Housing Market Assessment (SHMA) and assesses the capacity through a Strategic Housing Land Availability Assessment (SHLAA). Those have been drawn up in partnership with the London Boroughs and other key stakeholders, such as the Home Builders Federation and included London Forum. The headline London Plan target is then distributed after considering local capacity. Current London Plan housing target: Currently, local planning

authorities – in London the Mayor and some boroughs – establish the “objectively-assessed need” based on demographic factors (e.g. household formation and net migration). This is translated into local housing “need”. In the latest version of the ‘Intend-to-Publish-New-LondonPlan’ the additional housing “need” (66,000pa) was nearly matched by “capacity” (65,000pa), but this figure made a substantial allowance for windfall sites. This approach was challenged at the EiP. The Panel who examined the London Plan subsequently reduced the London-wide housing target to 52,000pa, as they did not consider the assumptions about windfall sites were realistic. The main feature of London Plan, however, is that the borough-level targets are the result of redistribution of the headline housing target for London - housing targets for boroughs are based on their ability to accommodate additional housing.

New Proposal The latest proposal from MHCLG is that there should be an annual target for England of 300,000 dwellings pa, which would be distributed by them to local authority level based upon a formula/algorithm – the new Standard Method which puts considerable weight on building more housing in areas with high house prices. This means, according to analysis by Lichfields, the target becomes 337,000 to allow for slippage, of which 93,500pa would be the “housing requirement” for London. However, capacity factors need to be taken into account - which they have not been in that use of the new formula. All of the "housing requirement" figures are to be directed to individual local planning authorities, with MHCLG agreeing any proposed reductions. Thus, not only is the new overall London “housing requirement” figure much higher than the London Plan target, but when distributed within London to boroughs with high house prices, the new “targets” for more central boroughs would be greatly increased. For example, the new “housing requirement” figures for these boroughs compared to the ‘Intend to Publish New London Plan’ (NLP) would be: • Tower Hamlets: LP 3,473pa and 6,121pa (new housing requirement) • Westminster: LP 985pa and 5,750pa (new housing requirement) • Barnet LP 2,325pa and 5,744pa (new housing requirement) • Camden: LP 1,038pa and 5,604pa (new housing requirement) • Hackney: LP 1,328pa and 5,031pa (new housing requirement) • Greenwich LP 2,824 and 4,289pa (new housing requirement) • Lewisham: LP 1,667pa and 3,735pa (new housing requirement) • Kensington & Chelsea: LP 448pa and 3,285pa (new housing requirement) • Bromley: LP 897pa and 2,487pa (new housing requirement) • Hillingdon LP 783pa and 2,026 (new housing


See also table in Forum report

requirement). In Outer London, there would be a significant rise in housing requirement for the boroughs of Barnet, Greenwich and Bromley. A full comparison by London borough of the “Intend to Publish London Plan” (2019) and the table produced by Lichfields (see the LP&D Forum report) highlights the major gulf between the London Plan borough annualised average targets for net housing completions and figures that the Government intends to apply at borough level for “housing requirements”. The way in which the Standard Method seems to have produced unlikely figures for London’s boroughs is illustrated by the Lichfields’ map above. Two boroughs, Hounslow and Barking and Dagenham would have their housing target reduced by the proposed Standard Method, compared with the figures in the New London Plan. Barking and Dagenham borough, which is part of the main development area ‘City in the East’, has within it a major Opportunity Area in the LP with high future borough housing objectives. Hounslow Council has exceeded its 2016 London Plan housing target and accepted a doubling of that target in 2019 based on its growth area strategies. It seems strange that both boroughs could be discouraged, as a result of applying the proposed formula and reducing their targets, from achieving the quantity of new homes that are possible. The Standard Method would reduce their housing target by 15 per cent and 25 per cent respectively.. The massive increases in housing targets for RB Kensington and Chelsea and the City of Westminster seem unlikely without large-scale redevelopment and high rise towers in sensitive locations as large parts of those local authorities are conservation areas.

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The new method has an algorithm which focuses high levels of growth to London (and the South East) regardless of whether there is the capacity to deliver these numbers. The Government proposes, in the Planning White Paper proposal 4 and para. 2.25 bullet point three, that “The housing requirement would factor in land constraints” and “the practical limitations that some areas might face, including the presence of designated areas of environmental and heritage value, the Green Belt and flood risk.” However, the ‘Changes to the Current Planning System’ consultation paper does not mention constraints. As a result, the MHCLG proposal would be politically impossible to meet in many London boroughs with or without reallocation by the Mayor, which demonstrates the flaw in the process. The highest prices are in the areas with the greatest shortage of sites and with major constraints to redevelopment. The consultation paper states in para.14 that the Standard Method has to “be consistent with the Government’s ambition for a housing market that supports 300,000 homes by creating a method with a suitable overall national number that enables achievement of this aim.” What is needed is a methodology and a set of policies for England that relieve the problem of “overcrowding and concealed households” (para.13 of the consultation paper) by ensuring the provision of enough homes to rent that are affordable by key workers. So, what happens if the “housing requirement” figures cannot be accommodated in, for example, various Central/Inner London boroughs? If London as a whole must accommodate 93,500pa for the next 10 years, how would any “excess” in these boroughs be redistributed either within London or outside London? Note that

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>>> in the London Plan there is redistribution to those boroughs with the capacity. It is highly implausible that any of the detailed suggestions in this consultation and in the ‘Planning for the Future’ White Paper will result in a durable and sustained increase in volumes of housing construction sufficient to reduce prices. Greater pressure for large-scale redevelopment would take a long time and would run into constraints and public opposition. “Take up” is dependent on housebuilders being prepared to develop this scale of housing and having the short-run capacity and resources to do so. The Government claims in para.2.24 of the White Paper that the current SHMA and SHLAA processes have “not led to enough land being released where it is most needed (as reflected by worsening affordability).” Unfortunately, the Government seems to relate affordability to the price of a home to buy, whereas in London boroughs are desperate to obtain homes to rent at prices key workers can afford yet developable land is being consumed by developers for unaffordable homes. It is not the fault of the SHMA and SHLAA process nor of the boroughs that low cost rent homes are not being adequately funded. However, a major problem, not covered in this consultation, is housing delivery. That was explained by Rt Hon Sir Oliver Letwin MP in his analysis for the Government in October 2018 but his recommendations for resolving it are not covered in ‘Planning for the Future’ except for promotion of small builders. It is all very well setting high targets, but if developers get consent and do not deliver all of the housing, there will be a growing number of unimplemented housing consents (there are around 300,000 unimplemented units in London at present). High targets may not necessarily translate into higher rates of delivery of housing, let alone affordable housing, if developers decide not to develop out their consents, but to “bank” them or sell them on. All this achieves is high book values, not more housing delivered. Furthermore, the White Paper does not specify what policies will be overridden by its proposed new presumption in favour of development if housing requirements are not met. There is a danger that when high targets are inevitably missed, the presumption will override green space protection, including Metropolitan Open Land, design codes, stated local authority requirements in sites and areas, heritage protection and, possibly, Green Belt all of which the Government indicates it does not want. The lack of control for councils over delivery rates means that penalising councils when targets are not delivered on a backward-looking basis is grossly unfair and will guarantee that the new higher targets will sometimes be missed due to recessions or other factors. There should be some power to encourage delivery, perhaps through allowing councils to impose council tax or a land value tax on unimplemented full permissions, a certain period after those permissions are granted. The bottom line is that this new method seeks to fit quarts in each of the pint pots. The London Forum strongly opposes the use of the new housing requirement approach in London, preferring an approach based on “need” and for London’s housing need based on household projections to be redistributed between boroughs in relation to capacity. This is best done by the Mayor after consultation with the boroughs through the London Plan process.

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Our experience over the last three Mayors of London, is that the Greater London Authority has the skills and capacity to assess “objectively-assessed need” through their SHMA, with a full understanding of the constraints that London boroughs face through the SHLAA, and, in particular, has worked closely with the boroughs and other stakeholders, including London Forum, to assess capacity. This has informed the redistribution of the London-wide housing target to London boroughs based on their capacity to take this growth. London Forum strongly opposes the possible top-down, algorithm-driven housing requirement that seems to be proposed, and strongly supports the current method used in the London Plan process to redistribute growth to boroughs with capacity. That is covered in the Planning White Paper which states in para. 2.26 “It may be appropriate for Mayors of combined authorities to oversee the strategic distribution of the requirement in a way that alters the distribution of numbers, and this would be allowed for.” There must be a similar provision for the Mayor in London to allocate housing numbers to boroughs after modelling the housing requirement and types of homes needed. Also, perhaps in recognition of the capacity restraints in meeting London’s housing need, the Secretary of State wrote to Sadiq Khan on 13 March 2020, following the report of the Panel of Inspectors on the examination of the New London Plan (NLP) as follows. “I would like you to commit to maximising delivery in London, including through taking proactive steps to surpass the housing requirement in your Plan. This must include producing and delivering a new strategy with authorities in the wider South East to offset unmet housing need in a joined-up way.” The proposal is for each borough as well as London as a >>> whole to ‘consume its own smoke’. The South East, which will also have higher “housing requirements”, will not be receptive to receiving London’s “overspill”. Clarity will be required on when and how any application of the Standard Method could or should be applied in London. That is because the draft NLP passed its public examination, the Mayor has agreed the Panel’s recommendation on the housing targets and it is ready for Secretary of State approval and implementation. That is vital as soon as possible because the current 2016 London Plan is out of date. The NLP would introduce design codes as proposed in ‘Planning for the Future’ and its Good Growth policies relate to the requirements of the NPPF. That would assist London boroughs in updating their Local Plans in whatever way the outcome of the Planning White Paper will propose. It seems that the Standard Method, as modified as a result of this consultation, would be applied in the next replacement London Plan. That would take at least three years to complete its consultation and examination unless the approval system is accelerated. That could result in a draft altered London Plan in 2021/22 to which London boroughs’ Local Plans would have to be in general conformity as they amend them for changes introduced by the outcome of the Planning White Paper by 2024. The complications of that will need careful management, as there will be a new NPPF also for consideration in Local Plan revision and the date for that is not clear. n


BUILDING SAFETY | STUART BROWN

Wholesale reform for building control and safety Stuart Brown gives us an introduction to Trowers & Hamlins' Essential Guide to the draft Building Safety Bill

Following Dame Judith Hackitt's Building a Safer Future report and recommendations, published in 2018 as a response to the Grenfell Tower fire, the Government has now published its draft Building Safety Bill. The draft Bill represents a wholesale reform of the regulatory system for building control and safety in England, and the proposals are designed to improve building and fire safety with the primary aim of ensuring that residents will be safer (and feel safer) in their homes. Our Essential Guide to the draft Building Safety Bill provides an overview of the key elements of the proposed law changes. As an introduction to the Essential Guide, we have set out below some of the key issues and principles set out in the draft BIll. In-scope buildings The Explanatory Notes to the draft Bill provide a proposed definition of higher-risk buildings as being at least 18 metres above ground level (whichever is reached first) or more than six storeys above ground level; and having two or more dwellings or two or more rooms used by one or more persons to live and sleep. Houses, flats, serviced apartments, supported accommodation and student accommodation facilities are all expected to be within the scope of higher-risk buildings whereas residential care homes, prisons, hotels, hospitals and hospices are likely to be excluded (currently). In-scope buildings are now defined as "higher-risk buildings". The enhanced regime of regulation applies to this category of buildings, but the draft Bill includes a changed regulatory regime covering all buildings.

Stuart Brown ia an associate and member of the Trowers & Hamlins' cross firm Building a Safer Future Team

Overview of the draft Building Safety Bill and timings The draft Bill is divided into 119 sections in 5 different parts: • Part 1 - Overview of the draft Bill; • Part 2 – Establishes the Building Safety Regulator; definitions and scope of the regime; • Part 3 – Amends the Building Act, and sets out information on the design and construction phase (dutyholder regime) and building control and inspectors (registration and competency requirements); • Part 4 – Sets out in-occupation obligations and the roles of the Accountable Person and Building Safety Manager, and sets out details of offences and sanctions; and • Part 5 – Sets out supplementary provisions relating to: • The establishment of a New Homes Ombudsman; • Powers to make provision about Construction Products; and • Changes to the registration and monitoring of the competence of architects in line with new competency requirements. The Explanatory Notes also acknowledge that many aspects of the regime will be taken forward via secondary legislation. For

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example, the competency requirements and the design and construction Gateway policy. As the draft Bill is still undergoing pre-legislative scrutiny, it is not yet known as to when the provisions of the draft Bill will come into force. MHCLG will consult with stakeholders and the Housing, Communities and Local Government Select Committee will report its feedback and suggested amendments before the draft Bill is finalised. There is currently no commencement date envisaged for the provisions contained within the draft Bill, nor is there a timetable for the tabling of required secondary legislation. Crucially, there is no timeline for when in-occupation obligations will apply to existing in-scope buildings. However, we do know that on the commencement date of the final Bill, Accountable Persons will be required to provide fire safety information to residents, and failure to provide this information will constitute an offence under the proposed legislation. Additionally, two months after the commencement date, rules around constructions products and amendments to the Architects Act 1997 come into force. The Building Safety Regulator The draft Bill proposes that the Building Safety Regulator will sit within the Health & Safety Executive (taking the form of a new division within the HSE) and report to the Secretary of State. The Regulator is the lynchpin of the new regime, and its approach to and execution of its functions and powers will determine how successful the new regime is. The Regulator will have three broad functions under the new regime: 1) Implementing the new, more stringent regulatory regime for higher-risk buildings; 2) Overseeing the safety and performance of all buildings; and 3) Assisting and encouraging competence among the built environment industry and registered building inspectors. Additionally, the Regulator will be required to establish three committees: 1) Building Advisory Committee; 2) Committee on Industry Competence; and 3) Residents' Panel. The Regulator is able to set up a multi-disciplinary team of authorised officers to exercise powers to carry out relevant building functions on its behalf, and it will be an offence to obstruct an officer, or to impersonate an officer, of the Regulator. It will also be an offence to provide false or misleading information to the Regulator.

Amendments to the Building Act These amendments are critical to the effectiveness of the enhanced regime during the design and construction phase. Amongst other things, the amendments: • Establish the Regulator as the building control authority for >>>

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BUILDING SAFETY | STUART BROWN

>>> higher-risk buildings; • Introduce the Dutyholder regime; • Introduce the competency regime; • Give the Regulator the power to issue Compliance Notices and Stop Notices, and introduce sanctions for failure to comply with such notices; and • Provide that the Regulator will establish and maintain a register of building inspectors (public sector) and building control approvers (private sector), and associated professional conduct rules. In-occupation obligations The draft Bill also includes various provisions relating to the in-occupation stage of higher-risk buildings, covering the Accountable Person and the Building Safety Manager. The draft Bill sets out the proposed definition of the Accountable Person as: • a person who holds a legal estate in possession in any part of the common parts; or • a person who is under a relevant repairing obligation in relation to any part of the common parts. The draft Bill also sets out how the Accountable Person will be identified where there are two or more persons with legal interests in a building in scope. Whilst there is limited preliminary guidance in the Explanatory Notes, further guidance and information will be needed on complex ownership structures and the identities of relevant Accountable Persons. Amongst other things, the draft Bill confirms that the Accountable Person will be responsible for: • registering higher-risk buildings; • applying for building assurance certificates; • appointing the building safety manager; and • assessing building safety risks as soon as reasonable practicable.

Stuart Brown, Associate and member of the Trowers & Hamlins' cross-firm Building a Safer Future Team (spbrown@trowers.com / 020 7423 8143)

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Residents Residents are held to be at the centre of the new regime proposed by the draft Bill. There are comprehensive arrangements set out in the draft Bill to promote the participation of residents and “flat-owners” in the decision-making about building safety risks in their building. The Accountable Person will need to produce a Resident Engagement Strategy (either as part of Gateway 3 requirements or as required by the registration process/Safety Case for existing in-occupation higher- risk buildings). The draft Bill provides some high-level requirements as to what the Resident Engagement Strategy must include, and it is expected that the Government will issue a Good Practice Guide to provide practical help to Accountable Persons in developing the strategy (including examples and templates).

There are also express duties on residents to keep their properties in good repair, take reasonable care to avoid damaging safety items and comply with any request made by the Accountable Person to fulfil safety duties. Accountable Persons are able to give residents notice that they have contravened their duties and require them to provide information or cease certain behaviour. If the resident breaches this notice, the Accountable Person may apply for a court order to enforce it. Accountable Persons will also have rights to enter residents' dwellings via application to the county court. The new legislation will also imply terms into leases covered by the Landlord and Tenant Act 1985, including obligations: • on landlords to comply with rules about building safety charges; • on landlords to carry out the Accountable Person role, or to cooperate with the Accountable Person; • on tenants to pay any building safety charges required; and • on tenants to allow the landlord or authorised person to enter their dwelling to carry out building safety measures or inspect/assess the property, at reasonable times and on reasonable notice. Landlords should note that they are unable to contract out of these obligations, and may not exercise any forfeiture or penalty in respect of either landlord or tenant enforcing their rights.

Supplementary provisions Finally, the draft Bill sets out various supplementary provisions, including: • The requirement for the Secretary of State to establish a new Homes Ombudsman for complaints by all owners and occupiers of new homes; • The ability for social housing complainants to complain directly to the Housing Ombudsman without having to make a complaint via a "designated person"; • The ability for the Secretary of State to regulate all construction products made available in the UK; and • Changes to registration of architects. The draft Bill is now undergoing a period of pre-legislative scrutiny, and the Housing, Communities and Local Government committee issued a call for evidence which ended on 14th September 2020, and has heard oral evidence from a variety of experts on their views on the draft Bill (including from the National Fire Chief's Council, the Home Builders Federation, and the Royal Institute of British Architects). Trowers & Hamlins has been involved with government working groups on the competency regime, and we have participated in the consultation of the legislative proposals and the implementation of the draft Bill. A link to the Essential Guide can be found on https://www.trowers.com/insights/2020/august/ essential-guide-to-the-draft-building-safety-bill. n


PUBLIC REALM | LUCY MUSGRAVE

Guiding transformation around Oxford Street Lucy Musgrave explains Publica’s new design guardian role for creating a resilient and improved Oxford Street District

Lucy Musgrave OBE is founding director of Publica

In August, Westminster City Council (WCC) appointed Publica as Design Guardian for the public realm of the Oxford Street District. In this new specialist advisory role, we will provide strategic oversight to shape the holistic design and delivery of the Council’s £235m plan to strengthen the district’s iconic status as one of the world’s top places to live, visit, shop and work. This follows our previous work in 2019 on the Council approved Place Strategy and Delivery Plan for the Oxford Street District, which sets out an ambitious plan to improve the whole of the district around Oxford Street. This strategy identifies streets and spaces for improvement and district-wide strategies for delivery – including flagship public realm schemes at Oxford Circus and Marble Arch – and through the Design Guardian role, we will

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ensure a consistent design approach across the programme, and the integration of innovative, sustainable and inclusive design-led practices to support the Council’s objectives for the district. This work now has greater impetus on account of the Covid-19 crisis, and through our work we will support the Council in creating a resilient district, adapting to the issues and potential possibilities caused by the impact of Covid-19. Rachael Robathan, Leader of Westminster City Council, says “This project has only grown in importance in the wake of the pandemic which has left many of the country’s businesses struggling. The ambitious plans we are developing will see the Oxford Street District revitalised for residents and our city’s millions of visitors and secure its global reputation as the place to enjoy >>>

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PUBLIC REALM | LUCY MUSGRAVE

>>> London’s finest retail, leisure and culture. We will incorporate innovative smart city ideas and aim to boost air quality by being one of the greenest schemes worldwide.’ The Oxford Street District encompasses a large area of the West End, including the street and its links to the surrounding historic neighbourhoods, commercial areas, garden squares and cultural attractions. Oxford Street itself is one of the world’s most celebrated retail streets, and one of its most important strengths is its vitality and inclusivity – it is a space for residents, workers and visitors of all ages and backgrounds. The district is a historically resilient area built on incremental growth over centuries and has adapted to social, environmental, political and economic challenges. Now, more than ever, there is the opportunity to enhance the district’s complex and multi-faceted built fabric and urban character to retain Oxford Street’s reputation as the nation’s favourite high street and an internationally renowned destination. Large-scale infrastructural developments, such as the future opening of the Elizabeth Line, are an indication of this, but fastpaced smaller innovations for buildings and public spaces are needed to address innovation and environmental enhancements. This momentum is evident with transformative projects, including the revitalisation of Hanover Square, a major design competition for Grosvenor Square, a new vision for the public realm Marble Arch and significant developments at Cavendish Square. The maintenance and management of new streetscape, spaces and amenity will be crucial for the success of all these projects,

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which will be well-connected destinations in their own right with true civic amenity. Publica has had the privilege of studying and designing areas in the district for almost a decade. Working with WCC, we have previously undertaken a major public realm study of Soho, redesigned Marylebone Lane and the whole of Bond Street, and our design for new public realm and civic amenity at Hanover Square is currently under construction. Our new role as Strategy and Design Guardian for the OSD is progressive. Given the scale and rate of change in the area, it is important for consistent design quality oversight across the district’s streets and spaces. The role is an opportunity to realise the PSDP strategy and seek to establish the highest standards based on our embedded knowledge and expertise within the area, and our long and positive relationships with its stakeholders to facilitate the careful consideration needed when addressing the connections and interactions that visitors, residents and stakeholders have in the area. We will be integrating innovative, sustainable and inclusive design-led approaches to support the Council’s objectives and sharing international best practice to inform the process. We will play a key role in the governance of the design process, including participating in an integrated design review process for the OSD to incorporate world-class quality and design elements into the deliverables, and that these are joined up across the district. The holistic role we are undertaking in this significant area will ensure that a comprehensive and multi-layered approach is taken to the streetscape of the entire district. High-quality streetscape – walkability and clean air


The Covid-19 pandemic has brought to light how crucial it is to create and maintain an accessible, safe and welcoming streetscape that supports all aspects of public life. These range from the design of the public realm itself, to land uses and programming of the streetscape to improve the overall city experience. The revitalisation of the environment will be addressed to ensure it is fully accessible, walkable and safe for all, at all times of the day, evening and night-time to encourage visitors and Londoners of all ages to use and explore the district. Working with the City Council, Publica will seek to deliver a cleaner, healthier district with less traffic congestion, more active travel routes, cleaner building emissions, improved air quality, and better lighting in its streets and spaces. A key objective is to reduce air pollution along the street, which has in the past been regularly recognised as one of the most polluted in Europe. New uses, creativity and innovation Like so many high streets in the UK, Oxford Street and its businesses, shops, restaurants and bars are facing huge challenges. The design and delivery of the Oxford Street District scheme will need to be flexible and adaptive, anticipating new uses and programmes, and enabling testing of new ideas for retail space and possible other uses. The demand for more stimulating and multi-faceted or experiential forms of shopping and leisure will require a more active and diverse public realm, providing greater character and programme to the spaces between and

www.planninginlondon.com

around buildings on Oxford Street. Land uses are evolving and changing, supported by new policy, presenting an opportunity to test alternatives and lead innovation on the future of high streets and retail. Oxford Street benefits from many stakeholders who are leading this field of innovation and adaption, and we hope the reimagining of the district will provide many lessons and ideas that can be shared with other towns and cities. As such, the advisory role will inform an integrated design review process, seeking to incorporate all aspects of design and the many cross-cutting layers such as play and a programme of culture and public art, hard and soft landscape, street furniture, lighting, wayfinding, trees and planting, play, amenity — all of which are important to revitalise the district and ensure it is a destination for the day, evening and night-time. Through this new role, Publica is proud to be continuing our work with Westminster City Council to implement a holistic, multi-layered approach to urban change. We believe this is one of London’s most significant projects, urgently needed and with the opportunity to demonstrate an international showcase of longterm, innovative, creative and sustainable adaptation of a major apart of the West End. Westminster City Council’s Leader Rachael Robathan says, “Publica share our vision, understand the challenges we face and the delicate balance that must be struck to ensure our ambitious plans works for residents, businesses and visitors alike. We look forward to continuing our work with them during the next steps of this scheme.” n

SEE https://publica.co.uk/projectsoxford-street-district

Issue 115 October-December 2020

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Planning Portal Virtual Conference 2020 Planning in London readers receive 10% oć˜€ tickets with voucher code: PIL10% Taking place online from 16-19 November, the CPD accredited conference will provide over 12 hours of content, covering the most important topics eć˜€ecting planning and building. Our opening keynote speaker, Joanna Averley, MHCLG’s new Chief Planner, will be addressing the extremely pertinent topic of planning reform, addressing changes made in the Government whitepaper, just three weeks after the consultation on it is due to close. Following hot on the heels of a series of permitted development changes announced for August, the white paper has had a mixed reception by the industry but proposes some radical changes in an attempt to streamline and modernise the process and make it more accessible and transparent for all. Other key issues being addressed in the conference programme include the impact of the Environment Bill and net zero carbon commitments, the Building Safety Bill and building standards, and technology in the development management and wider planning process. 66


There will be multiple networking and interaction opportunities including asking speakers questions live, polls, plus networking for all of our attendees, speakers and sponsors, a from the safet of our o n o ce or home during these uncertain times egister no and nd out more information via www.planningportal.co.uk/conference. We are delighted to welcome on board our key sponsor will be Objective rape e urpose ui t for p anners and ui ding o cers, rape e ena es the accurate and e cient assessment of p anning and ui ding app ications at over 500 local authorities across the UK, Australia and New Zealand. The Trapeze team will be sharing their insights into how innovative councils are applying technology to development management and building control. ic ets are on and are comp ete free for pu ic sector o cia s Over 80% of tickets have now been sold, so don’t hesitate and book your place now. Sponsorship, exhibitor and speaking opportunities are also available, giving you access to an audience of 500+ senior level industry leaders. Please contact conference@planningportal.co.uk for more information.

Planning Portal Virtual Conference 2020 16 - 19 November www.planningportal.co.uk/conference


SAVING THE HIGH STREET | POLLY SWANN AND NEIL LEE

Saving the High Street: the community takeover Local community business ownership and access to buildings is essential to the survival of our high streets say Polly Swann and Professor Neil Lee

This is a critical moment for our high streets. The sight of boarded-up shops has become an increasingly common one in London and across the country, as high streets have had to compete with the rise of out-of-town shopping centres and the growth of online retail. They now face the very real challenges of the Covid-19 pandemic and social distancing measures. Yet, the pandemic also appears to have reinforced the growing recognition that the future for high streets lies in meeting peoples’ desire for more community-centred and vibrant town centres. There has been a clear resurgence of community spirit, a renewed connection with local areas, and a growing recognition that communities need to play a central role in shaping their town centres and high streets. A recent study commissioned by the independent trust Power to Change - Saving the High Street: the community takeover by the London School of Economics and Political Science - explores how community businesses can help revive the high street’s fortunes and suggests that where local authorities have helped bring about community business ownership and access to both public and privately-owned buildings, the result has been more vibrant and resilient high streets. Evidence gathered from the activities of six ‘best practice’ community businesses (see below) on their respective local high streets and town centres, strengthens the argument that community businesses can (and do) go further in offering a locally focused and longer-term solution to high street regeneration. • The Old Library in Bodmin, Cornwall – where a ‘significant’ local building has been used by a community business as a cultural facility • Midsteeple Quarter, Dumfries - a collaboration between the community, public and private sectors that is developing a group of high street buildings into a live/work quarter • Made in Ashford, Kent - an independent shop providing a platform for local business to sell on the high street and for community-based craft activities • Hebden Bridge town centre, West Yorkshire - a town with a thriving high street, with multiple community businesses supported by the local authority’s ‘community anchors’ policy • Radcliffe Market Hall in Bury, Greater Manchester - a rejuvenated market hall, combining a traditional market with an evening dine-in street food and community venue • Ultimate Picture Palace in Cowley, Oxford - an independent cinema that locals are trying to bring into community ownership The impact of community business on the high street Community businesses typically deliver what a particular place needs. Run by local people who understand their communities, they offer diverse and distinctive services that are

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tailored to local requirements. The study shows that community businesses can also have important wider impacts on the high street, extending beyond their ‘basic’ role of providing goods and/or services. For example, their ability to create ‘destination places’ that draw a broader mix of people back to the high street, helping to increase footfall and potentially the number of customers in other commercial businesses. Radcliffe Market Hall has successfully created a vibrant community space that is used throughout the day and into the evening for its dining experience, helping support an evening time economy in the town centre. Community businesses can also play an important role in building the reputation of the high street and in positively shaping people’s views of what can be achieved. The Midsteeple Quarter project has a very clear vision for Dumfries town centre based on local views and aspirations: to redevelop an under-used high street block into affordable homes, shops and work space. In addition, community businesses are often very conscious that they are stewards of important local buildings (such as former municipal town halls and libraries) and are willing to use them in different ways to support the local community and build its resilience. For example, Hebden Bridge Town Hall played an important role in the town’s recovery from three major flooding events in 2012, 2015 and 2019. The concern that community businesses might be competing in some unfair sense with existing businesses (particularly given they are able to use volunteers, access grants and make use of subsidised assets), is an important one. Yet, the evidence gathered points to community businesses acting as a complement to other high street businesses and they often offer a service which would not have been provided by the market, such as the Ultimate Picture Palace independent cinema. Lessons for communities, local and national policymakers While the driving force of the six community businesses has been the local community, the local authorities have realised it is in their enlightened self-interest to work to support them. Efforts to do this have included asset transfers, subsidised leases and using community businesses to deliver services. However, town centre regeneration is often made harder for local authorities because of fragmented property ownership and a lack of transparency on who owns the high street. With so many different landlords, it can be impossible for local actors to create unified regeneration strategies. The examples show how local authority support for asset ownership and management can give back more control and enable this sort of regeneration. Similarly, the ‘meanwhile use’ of buildings during the asset transfer process can be just as important. Local authorities can also support community businesses to


manage both public and privately-owned assets through shortterm leases and licenses. Whilst ownership of the asset remains with the freeholder and provides no legal rights of tenure, it can be an important part of the process towards full community ownership and can allow community businesses to bring empty or under-used buildings into immediate community use.

Challenges of financing community businesses Community groups often face difficulties in gaining access to assets and/or making the transition from grassroots fundraising to running a successful community business. Local authorities and other statutory funders can play a crucial role in supporting community businesses through these challenges. There is a clear need for local authorities to increase the level of funding and low-cost finance available to community businesses to support asset transfer, particularly funding to support planning applications, business development and ongoing sustainability of an asset. Investing in community shares is another practical way of supporting a community business, generating income and community buy-in, with good examples in London and across the country (e.g. The Ivy House Community Pub in Southwark, Nudge Community Builders in Plymouth and Stretford Public Hall). Crowdfunding is increasingly being used to fund a broad range of local assets, on and off the high street, that would otherwise struggle to access funding elsewhere - including saving local shops and pubs from closure, to creating new community centres and leisure facilities. Guiding principles for local authorities and communities Local government clearly plays an important role in ensuring the success of community business and Power to Change is now urging local authorities and statutory funders to do more to support community businesses to grow their presence on high streets. The study suggests some guiding principles that can help local authorities achieve this:

www.planninginlondon.com

1 Providing flexible finance for establishment, growth, and sustainability. Local authorities have an important ‘enabling role’ to play in providing flexible funding to community businesses. For example, through: – Pump-priming investment to support planning applications, business plan development and ensuring the ongoing sustainability of an asset; and – Providing grants, bridging loans and co-investment in properties to overcome early-stage financing problems faced by community business. 2 Ensure access to high street locations. Local authorities can: – Ease the asset transfer process/support greater community ownership; – Support the ‘meanwhile use’ of buildings and management leases of high street assets such as markets, public spaces, libraries and community hubs, directly to trusted community businesses; – Connect up community businesses with vacant properties on the high street; and – Provide leases which are either secured leases (providing security), or which start at a low level and scale up gradually, giving community businesses time to become financially sustainable. 3 Build effective, clear and collaborative long-term relationships. Local authorities can place community businesses at the heart of their strategies. For example: – Having a designated policy for community businesses; – Having community business representatives in the governing bodies of Business Improvement Districts; and – Ensuring community businesses are represented in economic development discussions, in particular Local Enterprise Partnership Boards and the London Economic Action Partnership. n SEE: www.powertochange.org.uk/research/saving-highstreet-community-takeover/

ABOVE: Vision of a future high street that is communityled. Credit - Buttress

TOP & BOTTOM: Midsteeple SECOND: Made in Ashford THIRD: Oxford picture house

Issue 115 October-December 2020

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55+ HOUSING COMMUNITIES | LARS CHRISTIAN

A new dawn for housing a more mature city Increasing numbers of single households among adults with grown up children makes the post-war housing model of families in car-suburban housing unsustainable, in a society with a growing proportion of over 55 year olds says Lars Christian

Lars Christian, Urban Pilot London & Scandinavia

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Planning in London

After reading the latest London plan and the Westminster local plan, I wonder whether either authority have adequate regard for the oldest one sixth of the population. Twenty-first century London is about to either fail a majority of elderly or a large proportion of the elderly. Why that is, may be partly social, partly economic, partly cultural, partly ignorance. This article argues that the provision of housing for the elderly should change. For the benefit of the elderly, their children and grand children, the economy, the state, the health service, the social services, our local neighbourhoods, communities, villages, towns and cities alike. As well as for the benefit of families with school-age children, needing family size homes, now frequently occupied by senior couples and single pensioners. Post-war wrong & inadequacy My arguments build on the presumption that the western post-war model of providing housing, social services, health services and caring for the elderly is inadequate or wrong. As the model is too focused on two proportions of the elderly, the 10 per cent sickest and the 10 per cent wealthiest. As about a third of the former is cared for in state provided nursing homes, one in twenty of the latter in private nursing homes or similar, and maybe one in ten of the 75+ with (high intensity) home help or home nursing. But that leaves maybe as much as a quarter of the remaining 80 per cent in inadequate housing, in inadequate communities, with little or inadequate care, too far away from services, close relatives, family or friends. It is some of these 1 in 5 elderly that I believe can be housed for differently, housed better and housed at a lower cost than at present – to the state, the individuals, and the society at large. In London, the number of elderly is proportionally lower than in any village, town or city elsewhere in the UK, with a few exceptions. But I still believe that London could do or should do its outmost to cater as best as possible for the 'average' mid-income elderly, as the total number of elderly in London is still staggering: two-third million in their 60s, two-fifth million in their 70s and one-third million in their 80s or 90s. [60s 70.000p 45.000h; 70s 40.000p 25.000h; 80/90s 30.000p 20.000h] Accessibility, mobility & e-cycling The elderly need easy access to amenities, services, transport, 'neighbours' and friends. Some will have relatives or family nearby, others will not. With an increasing number of single elderly, housing these in isolated suburban communities is by default the wrong solution. The elderly should increasingly be housed in or within long walking or short cycling distance of town centres and/or train/tube/trams stations. In communities where walking or (e-)cycling are the default modes of

transport – with public transport and the car as number three and four. (E-)Cycling allows the elderly to easily get around in (e-)cycling friendly communities, if and where local authorities and road authorities plan for this. Where the elderly can travel a mile or so by (e)-bike for everyday chores, amenities and services. Rather than be restricted to half a mile, a quarter of a mile, or less where they are restricted to walking only. Look to Denmark & New Labour One nation that has maybe done more than any other nation in housing the elderly differently, is Denmark, where a small proportion of the over 55 year olds have chosen to form or move to a growing number of 55+ housing communities. Typically in communities of 20-30 row houses, but also a small number of 30-50 apartments around a courtyard garden, with a guest bedroom, common kitchen and dining room, but no staff. Some as owners, some as tenants. All targeting primarily 'younger' elderly to move in. And mostly for the mid-income elderly, rather than the poorest or the richest (1). In Denmark, the 55+ housing communities typically self-organise weekly dinners, one or more weekly social gatherings in the garden or dining room, and mostly look after their garden or courtyard themselves. A model that requires a balanced proportion of elderly in different age groups. And a model where the elderly themselves 'vet' who is eligible to join them, for the community to remain self supporting with no staff. Germany, Japan and the Netherlands also have extensive purpose built senior housing, the two latter with dedicated taxes, but these are typically staffed, so catering for elderly with premium pension and/or premium health insurance. Somewhat similar, New Labour revolutionised student housing throughout the UK, to the extent that as many students at present live in purpose built private student housing as university run student housing (one sixth each). Or about one third of a million units, typically with up to 500 units per building or site – in a thousand or more buildings. About 50 purpose built annually during the last 2 decades, mostly in or near city centres. Rethinking London delivery If 5 to 10 per cent of elderly households in London are gradually over 2-3 decades housed in 55+ housing communities, this amounts to about ½ to 1 per cent of households in their 60s yearly moving into purpose built senior housing communities. Leading to 2½-5 per cent of the 60-80 years old living in 55+ housing communities after ten years. And 5-10 per cent of the 60-100 years old throughout London after a further ten years. This may seem a small proportion of elderly, but in total across London, this amounts to 70–140.000 elderly or 45–


8

10 bud på fremtidens seniorbofællesskab

Ovenlys

3. Tænk hverdag før fest Mange eksisterende seniorbofællesskaber består af individuelle boliger, der ligger samlet omkring et centralt fælleshus. Det kan fungere godt, men der kan også være tilfælde, hvor man ikke får nok ud af de mange fælles kvadratmetre, som går til et fælleshus. Det kan være, fordi fælleshuset ligger væk fra boligen, så man aktivt skal vælge at gå derhen. Eller fordi fælleshuset er indrettet til fest og fællesspisning og i mindre grad indbyder til uformel hygge og de aktiviteter, som beboerne kaster sig over i hverdagen. Ofte er det også i de uformelle og uplanlagte møder, at fællesskabet folder sig ud. Når man hilser på hinanden på vej til og fra. På opgangen, svalegangen, ved vaskemaskinen, i haven eller drivhuset.

Tagterrasse

Læsesal

Café/Lounge

Tekøkken PC-rum

Fra fælleslokaler til hverdagsfællesskab Når man skaber et nyt seniorbofællesskab, har man muligheden for at tænke forfra i forhold til at blande boliger og fællesarealer. Man kan skabe et hverdagsfællesskab, hvor de fælles rum er en naturlig udvidelse af boligen, og ikke bare et sted, man kommer forbi engang imellem. Man kan arbejde med ankomsten, opgangen og hverdagspraktikken såsom at hente post og gå ud med affald. Alt sammen kan være små anledninger til fællesskab.

Motionsrum

Bibliotek

Man kan eksempelvis invitere til hverdagsfællesskab ved: – At placere fællesrum ved ankomsten til bofællesskabet, så det bliver naturligt at kigge forbi, når man går til og fra.

Fælleskøkken Tagterrasse

– At tænke praktiske funktioner som modtagelse af post og varer, vask, parkering af cykler o.a. sammen med mulighe90.000 households (2020). Elderly that can benefit socially, cultur- their local borough or housing associader for ophold.

ally, mental/physical health and/or economically from living in tion. A third could opt for shared own– At indrette fællesrum, så de kan bruges til mange forskelliIndgang Værksted purpose built or provided 55+ housing communities. With no staff ership, mostly households previously ge ting. except for home care and/or nursing for the most elderly propor- owner occupied with an average or – At skabe rammer for uformelle hilse-på-situationer mellem tion of households. above average pension. And a third of naboer. Det kan f.eks. være med små nicher til ophold ved But could such a model be delivered throughout London? households could opt foretoutright fordøren, naboaltaner med plads til at stille bord ud ownetc. Where the target is mid-income 55+ households, rather than the ership. Maybe halfså within thesigsame – At skabe synlighed på kryds og tværs, man føler elite or the poorest? With about 15 per cent of the London popumixed også housing community, ABOVE: som en del af et 55+ fællesskab, når man ikke aktivtand er half in single tenure comlation being 60+ in 2011, against 24 per cent in sammen the rest med of nogen. munities. Whether the community housing model could beneThe figure shows a multi I PFA’s seniorbofællesskab i Horsens ligger de fællesEngland. With an average of 75 homes per community, this fit 55+ households in private rent on average pensions needs story block by Praksis faciliteter op igennem etagerne som en udvidelse af opgangen. but Et konkret på, hvordanpotentially man tegner forin amounts to 600–1200 housing communities across London, or further exploration. Maybe not a short term requirement, a bud Arkitekter, hverdagsfællesskab. 20-40 housing communities per borough. If this is to be provided need that will nevertheless soon. Horsens, Jutland, with a Illustration fra værdiprogram: Praksis Arkitekter over 2-3 decades, about 30 to 50 housing communities have to be handful of apartments per established yearly, or about 1½ 55+ housing community per bor- Small household & suburban rethink needed floor around a stair with ough annually. Maybe half as new built and half reusing existing If more and more urban and suburban households consist of common areas on each (social) housing stock. Freeing up maybe as many as 45-90.000 only one person – young, middle-aged or elderly – how does floor, a workshop on the family size homes for couples with school-age children. this manifests itself in the provision of new housing in inner ground floor, a common In comparison, Legal & General through Guild Living aims to and outer London? During the twentieth century, councils and kitchen and dining room on provide 6000 senior housing units during a five year period. This housing associations typically provided family size housing, in the first floor and a rooftop equals to four communities yearly at an average of 300 units the form of apartments in inner London and a mix of apartterrace with allotments each, mostly in the southeast. Six times larger than the average ments and row houses in outer London. As more and more Danish ones. Whether L&G is targeting primarily the 10-20 per households consist of only one person, the provision of housing cent wealthiest pensioners, and what age group, is unclear. have to adapt and change faster than at present to catch up with the society-at-large. Similarly the provision of single or Mixture of tenures couples-only occupancy flats in suburban locations, more than Across London, maybe a third of the 55+ households could be ⅔ to 1 mile from town centres or train/tube stations need to at social rent level, equal to what households pay at present to be reduced, maybe to a maximum of half of new flats in any >>>

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Issue 115 October-December 2020

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55+ HOUSING COMMUNITIES | LARS CHRISTIAN

>>> authority or location, with the other half being closer. Many can agree that existing and new row housing communities in the UK could benefit from more diversity. But to make sure that the majority of the apartments are within walking or short (e-)cycling distances of squares, gardens, clusters of cafes, shops, services, amenities, train, tube, tram stations etc is more of a challenge. Including in the several dozens of new garden communities throughout southern England, all planned as 20th century car-suburban rather than 19th or 21th century walking and (e)-cycling (sub)urban. As well as throughout the fast growing coastal communities of Hampshire, Sussex, Kent, Essex and Anglia – where a growing proportion of affluent elderly retire – many in (new) car-suburban family size housing communities and neighbourhoods. Typically where 9 in 10 local journeys are by car, and 9 in 10 of local destinations are more than ⅔ to 1 mile away.

Footnotes (1) seniorboligen.dk & realdania.dk/tema/seniorbofaellesskaber (2) Including Chichester (25 per cent above 65), Arun (26 per cent), Rother (28 per cent), Tendring (27 per cent), N.Norfolk (29 per cent). (3) Few ±1 million suburban communities exist in northern Europe where the majority of the inhabitants has no access to frequent suburban trains, metro or trams for local journeys, with maybe the exception of several of the home counties around London, West Yorkshire, south Wales, and 'outer' Dublin (800k). (4) Two other 'row housing nations', Denmark and the Netherlands, are also among the top three cycling nations across the North Sea, together with Germany.

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Land requirement per borough Identifying enough housing land may prove challenging, depending on what proportion of land is in public or local authority ownership per London borough. Similarly, building 900–1800 new homes yearly for 55+ households may prove impractical as this amounts to 3-5 per cent of homes built in London yearly. On the other hand, if one 55+ housing community is built every 3 to 5 years per local authority borough, one per housing association and one per private developer per borough over 2-3 decades – maybe the task proves less 'mammoth'. With a similar number of homes converted every 3 to 5 years by the same organisations using existing housing stock. Further, as most London boroughs are the single biggest landowner, and the state in some boroughs the second biggest, identifying land in a majority of London boroughs may prove less of a challenge over 2-3 decades. But how much land does a 55+ housing community of 50100 homes in inner and outer London need? Building a block of 50-100 homes, with 8 storeys of 7-14 homes per floor, has a footprint of 500-1000 sq.m. With a 500 sq.m ground level garden – in addition to roof top gardens and communal balconies facing east, south and west respectively – sites of 1000-1500 sq.m are needed in inner London and in 'urban' outer London locations, close to high streets and train/tube stations. In more 'suburban' outer London – with 4-6 storeys of 15-20 homes per floor and building footprints of 1000-1500 sq.m – sites of 15002000 sq.m are needed. Home counties & coastal suburbia Elsewhere in the home counties, including along the coasts of Anglia and the Southeast, establishing 55+ housing communities on a similar (or larger) scale than in London – in the form of apartment or mansion blocks, near high streets

and/or train stations – would release an even higher number of much valued family size suburban housing. Including in three of the largest clusters of senior coastal communities in England outside London – in Sussex, Kent and Essex/Anglia (2). The three also being among the largest and most carintense suburban communities in northern Europe – with about 1 million inhabitants along a 70-80 mile long coastal strip in the two former (3). Social, demographic and economic benefits The 55+ housing communities advocated here are for the 'younger' elderly, moving house in their late 50s or early 60s. Where the housing communities are self supporting, with no staff. Where the cost to the occupiers, whether they are owner-occupiers, shared ownership or tenants – as well as the cost to local authorities, housing associations and the state – is equivalent to typical local authority, housing association and mid-market private housing. Including freeing up larger family size (row) housing for couples with children. With the social, cultural, health, demographic, ecologic and economic benefits 55+ community housing offers all generations – children, in-laws and grand children included. Where the social benefits of having several dozens 55+ within one medium size community is invaluable. Where the various personalities, whether they are exceptionally introvert, extrovert, curious, gossipy, organised, chaotic, proactive, lacy or sporty, can primarily be found in groups over a certain size. Not in groups that are too small, and less distinct in groups that are too large. Afterword With an increasing number of single households among adults with grown up children, the post-war housing model of families in car-suburban housing neighbourhoods is not sustainable, in a society with a growing proportion of over 55 year olds. This is particularly evident throughout the British Isles, where a larger proportion of households live in car-suburban neighbourhoods than elsewhere in Europe. Where new car-suburban (typically row or semi-detaching) housing, outnumber new urban housing. Throughout most of England and Ireland, with the exception of London and maybe a handful of larger English cities (4). Above, I advocate for a majority of new homes to be built in more accessible walking and bikeable urban communities – as quality apartments or mansion blocks with communal gardens – within long walking or short (e-)cycling distance of high streets and town centres. With the added benefit closer (urban) living has on mental and physical health – as well as for commercial, retail, social and leisure pursuits. Among both the over and under 55 year olds – singles, single parents, the young and childless couples included. n


THE PLANNING WHITE PAPER | HUGH ELLIS

The wrong answers to the wrong questions? Countering the misconceptions driving the Government’s planning reform agenda Hugh Ellis introduces a paper published by academics in August in response to the planning White Paper

Hugh Ellis is policy director at TCPA

The “radical reforms” proposed for the planning system in England are framed by a view of planning as an outdated blockage to the development we need to “build back better” from the economic impacts of COVID-19. As a group of planning academics and researchers, we are deeply concerned that this agenda has been driven by ideologically-motivated free-market think tanks and self-interested property lobbies rather than sound evidence. In The Wrong Answers to the Wrong Questions published on the TCPA website today we set why the government is wrong, how many of their key claims fly in the face of that evidence and ignore significant tensions and trade-offs involved in the development of land. In particular, we present a critical review of five key claims that underpin the reform agenda: The government is wrong to say the planning system is responsible for the housing crisis The claim: The government claims that the planning system acts as a major constraint on development and blames it for the existence of the housing crisis. The reality: Around 90 per cent of applications for planning permission are approved in England. Consent has been granted for between 800,000 to 1,000,000 new houses that remain unbuilt. Rather than the Soviet-era anachronism described by think tanks, the planning system in England is already permissive and more than capable of supplying land to the market. The failure to build new housing is not a result of excessive state regulation, but of dysfunctional markets and a failure to invest in social housing. Further deregulating the planning system simply will not resolve the crisis of housing affordability. [For more on this see the contributions by Quintin Bradley, Bob Colenutt, Andy Inch, Kiera Chapman and Malcolm Tait] The government is wrong to suggest that radical simplification will produce a more efficient and effective planning system The claim: Up to now the English planning system has used a discretionary model of decision-making. This means decisions are made on a case-by-case basis, informed by local plans and planning experts who are democratically accountable to local government. The government has presented this way of working as a major drag anchor on development, claiming that a ‘zonal’ approach based on earmarking land for either ‘growth’, ‘renewal’ or ‘protection’ would work better. Under this change, local plans will effectively determine rights to develop, theoretically removing the need to negotiate over individual developments. Government argue this will simplify the process of gaining development consent, offering greater certainty to developers and communities. They also propose to switch from a

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qualitative document-driven system to a quantitative datadriven one, arguing that this standardization will make planning more efficient and modern. The reality: The government is overstating the costs of discretionary decision-making and the benefits of zoning. Evidence from other countries with zoning systems in place suggest that they do not necessarily improve efficiency or outcomes, and that they can lead to bad decisions because they are inflexible in the face of changing circumstances. Experience in England already shows that simplified planning zones create significant risks for communities and local democracy, and don’t necessarily provide certainty for developers either. The proposed combination of broad, centrallydefined categories of land use with slimmed-down plans is highly unlikely to work and far removed from international examples of zoning. It fails to acknowledge the variety of complex issues raised by development and the inevitable conflicts they generate between different interest groups. Our existing discretionary planning system is far from perfect but it’s not the real problem here. At its best it offers a flexible and democratically accountable way of balancing the needs of developers against those of communities. The introduction of a data-driven process is likely to be used to automate and to privatise parts of the system, further reducing democratic accountability. >>>

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THE PLANNING WHITE PAPER | HUGH ELLIS

>>> [For more on this see the contributions in the report by Philip Booth, Sue Brownill, Edward Shepherd, Alexander Wilson, Geoff Vigar and Mark Tewdwr-Jones, Andy Inch, Kiera Chapman and Malcolm Tait] The government is wrong that more permissive planning will produce better places The claim: We need a more permissive planning system, so that developers and landowners can change the use of land in response to market signals. The economic benefits of this outweigh the risks. The reality: These reforms will afford power to the already privileged to pursue development in their own self-interest, irrespective of whether this benefits the wider community. Previous deregulation of planning control (such as granting automatic rights to change the use of buildings) has led to the production of sub-standard housing that lacks basic amenities and is poorly connected to jobs, schools and other facilities. This has exacerbated spatial and health inequalities by creating poor quality living conditions for many of the most vulnerable in society. Further deregulatory measures will exacerbate these problems, creating dysfunctional development and undermining attempts to coordinate public and private investment. Deregulation will create a race to the bottom, lowering quality rather than improving standards. [for more on this see the contributions in the report by Ben Clifford and Sue Brownill] The government is wrong about the capacity and willingness of the market to build back better The claim: Freed from the unnatural ‘rationing’ of land by the planning system, the free-market will build back better, and help to ‘level up’ parts of the country that have been left behind over recent decades. The reality: England already has a poorly resourced and highly permissive planning system, which produces outcomes that favour the interests of property developers. There is no evidence to suggest that a more permissive approach will improve the quality of our built environment or address the inequalities generated by market-led development. Good design, for example, will not result from the automatic application of standardised codes and measures. And good planning is about much more than the design. Building better places requires the strategic coordination of infrastructure investment with high quality development that can unlock its benefits, something the current proposals completely ignore. Failing to plan for this is hugely wasteful and will generate social, economic and environmental costs for future generations.

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[for more on this see the contributions in the report by Bob Colenutt, Tim Marshall, Sue Brownill and Michael Edwards] The Government is wrong to say that the reforms will lead to greater democracy and participation in the planning system. The Claim: participation is restricted by the cumbersome nature of the current system, local democracy and accountability will now be enhanced by technology and transparency. The Reality: while it is true that digital methods may enable some sections of the population to engage more with planning, this is only part of the story. There are real dangers of digital exclusion in any wholesale move towards e-participation. The proposals in the White Paper also cut in half existing opportunities to engage with the system by removing the public’s right to comment on planning applications and restricting it to plan making and design codes. Experience shows it is only when a proposal is actively being discussed, rather than the plan-making stage, that most people are motivated to engage. Participation restricted to commenting on what buildings look like rather than what they are providing and whether this meets local needs is not meaningful. Neighbourhood plans are to be brought more into line with local plans, thereby removing a key current aspect of planning democracy. Finally, these reforms represent a major centralisation of power by central government and it’s redistribution to the private sector; not the general public. [for more on this see the contributions in the report by Alexander Wilson, Geoff Vigar and Mark Tewdwr-Jones, Andy Inch, Kiera Chapman and Malcolm Tait and Sue Brownill] The Questions We Should Be Asking Following decades of piecemeal reform and underfunding, our planning system is weak. It lacks the powers it needs to create high quality development. From the tragedy of Grenfell Tower to the scandalous shortage of decent, affordable housing and the looming threat of climate breakdown, there is overwhelming evidence that the prevailing model of light-touch regulation and market-driven change has failed. Rather than less planning, we need more. To build a better, more democratic future, we need to strategically integrate investment, coordinate development, and ensure high-quality outcomes. Of course, there are costs to such a system but the wider public benefits are potentially immense. A period of significant public investment offers huge opportunities to tackle some of the biggest challenges we face as a society: the crises of decent, affordable housing, physical and mental health, climate change, and social inequality. A more positive planning reform agenda could play a crucial part in these vital tasks. n This article is based on the executive summary of the report. You can read the full


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SUBURBAN LIVING | RUSSELL CURTIS

Reappraising London’s suburbs We need to accept that the character of our neighbourhoods may need to change to accommodate new homes says Russell Curtis

Russell Curtis is a director at RCKa

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It is becoming increasingly apparent that the coronavirus pandemic will have a profound effect on the way our cities function. Social media has been littered with photographs deserted London streets while the government pleads with workers to return to their city centre offices after half a year of working from home. Doubtless some of the changes lockdown has imposed over the last six months will become permanent. For many this transition has initiated a re-evaluation of whether proximity to the office (if we still have one) is necessary at all. The recent announcement of a Surburban Taskforce by the All Party Parliamentary Group (APPG) for London’s Planning and Built Environment is one encouraging demonstration of a new interest in the periphery of our cities. One consequence of this new paradigm has been a longoverdue reappraisal of suburban living. It’s been apparent for some time that anachronistic perceptions of suburban life as a trade-off between weekdays in the city and weekends on the bucolic fringes of London is outdated and anachronistic, and now is surely the time for a more nuanced reassessment. Even before lockdown the suburbs were increasingly the destination of younger people forced out of inner London by the housing crisis, accepting that the marginally longer commute is preferable to relocating to satellite towns on the other side of the green belt. It’s widely known that London is not particularly dense. Kensington & Chelsea is the city’s most tightly-packed borough, with around 80 dwellings per hectare—but this swiftly drops away to 30 dwellings per hectare in outer London, even with green belt and metropolitan open land removed from the equation. At the other extreme, Paris famously has a density in excess of 125 dwellings per hectare. If we are to have any hope of achieving the required growth London needs to achieve if it wants to retain its status as a global city, these figures need to change significantly; and, as the new London Plan suggests, the character of some neighbourhoods will inevitably have to evolve accordingly. Yet the housing crisis will not be solved by any one silver bullet: tall buildings, in the right places, are one part of the puzzle. Selective release of some green belt land will also be required; likewise making the development of brownfield land more straightforward and enabling small site delivery less risky for specialist developers will help too. The fourteen London boroughs sharing a border with the home counties will together need to deliver 52,000 homes on small sites over the next decade: 10 per cent of the London’s total housing target. But to date the delivery of homes on small sites in these areas has been notoriously difficult: habitable room distances, derived from prevailing patterns of suburban development and encoded within planning policy, often preventing development coming

forward on the pockets of disused land found scattered around outer London—and complaints of “garden grabbing” abound. Barnet is London’s most populous borough, and despite its location on the northern edge of the city, it has the largest area of land that falls within the emerging London Plan small sites policy H2 zone; that is either 800m from a station or town centre boundary, or with a public transport accessibility level (PTAL) of 3 or more. It is an obvious first choice to explore ideas around how a creative approach might deliver more homes on small suburban sites. According to planning consultancy Lichfields, which has analysed the government’s proposed 2020 Standard Method of calculating housing delivery, Barnet is placed third in London in the league table of new homes to be delivered, behind Tower Hamlets and Westminster. Although this calculation is likely to change prior to adoption, even current targets are significant with the new London Plan requiring the delivery of over 23,500 homes over the next decade - the fourth highest target in London - and the highest of the suburban boroughs. Of these, 18 per cent are to come from small sites; although this is a dramatic reduction compared to the version of the plan presented at the 2018 examination in public, where nearly 40 per cent of new homes were expected to be delivered on sites of a quarter of a hectare or less. With this in mind, RCKa has recently submitted a planning application for a gentle intensification of the Broadfields Estate in Barnet, which we believe provides a potential model for how an increase in density might be achieved in outer London that does not irrevocably change local character. Delivering 47 new affordable homes, the scheme deploys RCKa’s proprietary Common Home housing system which has been designed to address the specific site conditions of outer London. Comprising a suite of semi-detached, terraced houses and small apartment blocks, the dimensions of each have been tailored to slot neatly into the particular conditions of suburban housing estates. Broadfields is typical of many edge-of-the-city housing estates: numerous open spaces of indistinct purpose and ownership which are often problematic for residents as a source of anti-social behaviour, and a maintenance headache for the local authority landowner. Residents are heavily dependent on their cars as the nearest station is over a mile away and access to the bus network is poor. Common Home came about at the intersection of several of RCKa’s interests: our ongoing interest in the potential of small sites; how to achieve sensitive intensification of the suburbs and how to use appropriate offsite construction techniques to achieve higher levels of quality and sustainability in affordable homes. It began life four years ago when RCKa partnered with fintech (financial technology) firm Native Finance, which provides an investment platform for property development. Our


discussions galvanised around ideas for how we might make full home ownership accessible to those on lower incomes. With the knowledge that the price of land is the key barrier to affordability, and aware of the many publicly-owned sites around the capital which lay vacant or under-used, our proposition was that we partner with the public sector to provide a full design, delivery and management service, taking on full responsibility for the provision of new homes on land which is provided on a long lease, for free. In return we would provide affordable homes for key workers from the local area. Any savings we could achieve within the design and delivery process would be passed on to the purchaser. In this way we believe we can deliver one-bedroom homes for sale at £215,000, with two-bedroom properties at £240,000. We are currently engaged in discussions with several London boroughs about deploying this system on land owned by them but in the case of Broadfields, which is managed by Barnet Homes - the council’s arms length management organisation only the architectural design element of the system will be deployed across the estate. Disused garages, no longer large enough to accommodate

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modern vehicles and rarely overlooked by adjacent homes, are a common sight across suburban housing estates and often a source of antisocial behaviour. The Common House replaces four garages with a neat three-bedroom dwelling, with garages either side removed to provide garden space. As garages often back on to the gardens of neighbouring homes, bedrooms are arranged so that window positions can be altered to avoid overlooking. Staggering these homes along a narrow garage site allows a development of around 50 dwellings per hectare—double the prevailing density—without exceeding two storeys. Likewise, Common Terrace has been designed to match the dimensions of a suburban terraced house built between 1950 and 1980 which are typical of many suburban estates of this period. At the Broadfields Estate the Common Terrace has been used as a new bookend to rows of existing homes, with windows in the front and rear allowing two or more homes to be appended to an existing row of houses without compromising the character of the street. Although the system comprises a range of homes for small sites, we are mindful of the combined impact of the overall proposal. One of the criticisms levelled at the London Plan small

ABOVE AND NEXT PAGE: RCKa and Barnet Homes have submitted plans for a new development project within the Broadfields Estate that will provide 100 per cent affordable housing on a low-density, suburban site in the north of the borough. Taking advantage of the Common Home model developed by RCKa, the 47 homes will be delivered across the estate using a modular construction system, with the potential for future expansion

>>>

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SUBURBAN LIVING | RUSSELL CURTIS

>>> sites targets is the net effect that many new homes will have on the wider area; not only the change in character than the plan states is, in some places, inevitable, but on social and physical infrastructure: parking demand, traffic congestion and local services. In some respects this is true—in isolated development of a handful of homes is unlikely to have much of an impact, but the existing community are right to expect some benefits if new homes are being built around them. At the Broadfields Estate we are using these to improve legibility of the public realm, providing overlooking of previously unsurveilled space, and to enhance wayfinding through the estate. Investment in the remaining green spaces, including play areas for children and mini parks for residents, offer something

Renders by Darcstudio

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back to local people who will inevitable face some disruption while the construction works take place. Living in London is a privilege, and those of us lucky enough to own our own homes have a duty to the rest of London to accommodate others who also want to enjoy the same benefits that we do. Part of this responsibility is the acceptance that the character of our neighbourhoods may need to change to accommodate new homes. Rather than debating whether new homes should be built near us at all, we need to start engaging with the question of how they are built when they are. We hope that our proposals for Broadfields illustrated here start to give an indication of how this might happen. n


BOOKS: SUSTAINABLE APPROACHES TO URBAN TRANSPORT | DINESH MOHAN AND GEETAM TIWARI

Sustainable approaches to urban transport The editors Dinesh Mohan and Geetam Tiwari introduce Sustainable Approaches to Urban Transport

CRC Press £128.13 from Amazon

Dinesh Mohan and Geetam Tiwari CVs next page

This volume includes contributions of an international interdisciplinary group of experts dealing with urban transport who met in Agra (India) to discuss the challenges facing us in design of urban structures, policies and technologies and to suggest possible ways forward. The Workshop was sponsored by the Volvo Research and Educational Foundations. The contributions focus on forms of city structure, urban governance, alternate transport policies, safety and the environment, paratransit operations and emerging technologies. A special feature of these contributions and discussions was the focus on recent knowledge generation and data from cities in low and middleincome countries. In 1961, Jane Jacobs published The Death and Life of Great American Cities and coined the terms "social capital", "mixed primary uses", and "eyes on the street", phrases which are commonly used in urban design, sociology, and other fields today. Half a century later most cities in the world are still grappling with issues concerning sustainable transportation and safety on urban streets. The reasons why people and governments do not or cannot follow many of the prescribed goals get less attention. Organisation of urban governance mechanisms that deal with transport have attracted a great deal of attention in recent years

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and in his chapter, Gerald Frug captures the complexity of the problem succinctly: “Transportation decisions will be illegitimate unless they respond to local residents’ needs and desires – respond, in other words, to the democratic will. But this does not mean that there isn’t a role for experts too. Of course experts have a role. But expert decisions have to be connected to democratic decisions. In short, we need to be broad and narrow at the same time. This conventional wisdom is easy to state. But, as far as I know, it is not implemented anywhere in the world.” Taking governance issues as a given, Hermann Knoflacher gives suggestions for future research but maintains that sustainable development of cities would be possible only if planners make parking regulations that separate parking sites from human activities. Sirish Patel and Philipp Rode deal with city design densities and transport planning. Rode’s work from London demonstrates that only density levels of more than 100 persons per hectare ensure that the percentages of public transport trips to work remain above 40% and he suggests that this would offer clues “that might become increasingly relevant for a developing world context”. However, Patel’s data from Mumbai suggest that densities there are generally much greater than 100 persons per >>>

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BOOKS: SUSTAINABLE APPROACHES TO URBAN TRANSPORT | DINESH MOHAN AND GEETAM TIWARI

>>> hectare and that higher densities should not be confused with high rise buildings and higher FSI (Floor Space Index). In addition to concerns with city governance and urban form the authors also focus on issues of alternative transport policies, influence of city infrastructure on access, role of paratransit, taxis and non-motorised transport, safety and technology. Geetam Tiwari warns us that:As far as actual mobility is concerned ‘informal’ transport services (minibuses, vans, taxis, three-wheelers, motorcycle taxis) transport more people than formal public transport systems in a large number of cities around the world. Robert Cervero, Geetam Tiwari and Roger Behrens provide data and case studies from around the world which show that these services may be termed as ‘informal’ but the availability of these systems at the relatively low fares they charge makes it possible for millions of people to access jobs and their daily needs. In his contribution, Matthijs J. Koornstra uses evidence from Europe and USA to show the relationship between safety and various factors including speed, policing intensity and vehicle design. Dinesh Mohan adds that to promote walking, bicycling and public transport use, we will have to make traffic safety a priority along with city designs that include denser layout with smaller size of city blocks. Carlos Dora brings together the issues of traffic safety, health and the built environment, climate change, and insists that evaluation of the performance of transport policies should involve documentation of all the health impacts those policies have on city populations. The contributors to this volume bring to us the depth and diversity of the challenge we face in the way cities are conceived, adapted, designed, developed, and managed in a world confronted with increasing road accident fatalities, and disease and death due to climate change and atmospheric pollution. These contributions should help policy makers and researchers to better equip them for the road ahead. n

Dinesh Mohan Dinesh Mohan is Honorary Professor at the Indian Institute of Technology Delhi. He was Distinguished Professor Shiv Nadar University (2016-2018) and formerly Volvo Chair Professor for Biomechanics and Transportation Safety at the Transportation Research and Injury Prevention Programme of the Indian Institute of Technology Delhi. He has worked on epidemiology of road traffic crashes and injuries, helmet design, pedestrian, bicycle and motorcycle crash modelling, and technological aids for the disabled. Concerned with mobility and safety of people outside the car he is trying to integrate these issues within a broader framework of sustainable transport policies, urban transport options and people’s right to access, safety and clean air as a fundamental human right. Geetam Tiwari Geetam Tiwari is the MoUD Chair Professor for Transport Planning at the Department of Civil Engineering, and Transportation Research and Injury Prevention Programme (TRIPP) at IIT Delhi. She obtained her B. Arch degree from the University of Roorkee, and a Master of Urban Planning and Policy, and Ph.D. in Transport Planning and Policy, from the University of Illinois, Chicago. She has received the degree of Doctor of Technology honoris causa from Chalmers University of Technology, Sweden, in 2012. She has been an Adlerbretska Guest Professor for sustainable urban transport at the Chalmers University of Technology, Sweden, 2007– 2010. She has been working in the area of traffic and transport planning focusing on pedestrians, bicycles, and bus systems. She is editor-in-chief of the International Journal of Injury Control and Safety Promotion.

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BOOKS: THE GODDESS – LA DÉESSE | CHRISTIAN SUMI

Investigations on the Legendary Citroën DS Here’s one for Christmas

Christian Sumi The Goddess – La Déesse Investigations on the Legendary Citroën DS Author(s): Christian Sumi With photographs by Michel Zumbrunn, Heinz Unger Design: Karin Schiesser Lars Müller Publishers hardback. 35,00 €

At its launch in 1955, the Citroën DS was a sensation and a magnet for designers, philosophers, and politicians alike. No other automobile was able to combine form and technology so coherently and seemingly effortlessly. Radical in its implementation and revolutionary in terms of comfort and safety, the DS is one of the most innovative design icons of the 20th century. In collaboration with Lars Müller Publishers, the Swiss architect Christian Sumi published the new edition of AS in DS by Alison and Peter Smithson in 2001. In this new publication, he analytically examines the characteristics of the classic vehicle. Carefully arranged picture series and drawings by Flaminio Bertoni and the Citroën design team, for example of the body, the chassis and the legendary hydraulics, illustrate the essay. Using advertising images Sumi critically analyzes, in both a contemporary and a philosophical context, the iconization and reception of the Citroën DS, as well as the theories arising from this phenomenon. n

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ABOVE: It’s not just aerodynamics and styling. Diagrams explain the hydraulic self-levelling suspension dubbed the ‘Magic Carpet’ ride of the DS

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JUST PUBLISHED BY BATH PUBLISHING How does a neighbourhood plan get off the ground? How do communities make sure that it comes into force? And, more importantly, what are the essential features of an effective plan; one that can withstand the often intense pressures for new development? This unique book answers these and many other questions with a clear, pragmatic focus and in sufficient depth to arm both lay readers and planning professionals with the knowledge they need to operate effectively within this novel planning regime. Published June 2020 Paperback, 340 pages ISBN 9781916431553 ÂŁ30 - print and / or digital

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BOOKS: A SHORT HISTORY OF LONDON | REVIEWED BY NIGEL MOOR

London’s Empty Luxury A Short History of London: The Creation of a World Capital

Nigel Moor reviews A Short History of London by Simon Jenkins

Penguin paperback £8.19 Amazon

Dr Nigel Moor is a chartered town planner

Simon Jenkins, knighted in 2004 for services to journalism, first came to prominence in the Swinging Sixties as a young journalist writing for the Evening Standard. Supported by his editor the legendary Charles Wintour, Simon`s trenchant commentary on the plans being drawn up by the GLC and boroughs for the redevelopment of Covent Garden finally shredded the scheme. The fruit and vegetable market was to relocate to Nine Elms south of the river in 1972.The plan heavily influenced by the Buchanan report`s recommendations to accommodate traffic in towns, included the demolition of the whole of Maiden Lane and building a dual carriageway along the Strand. A sympathetic minister Geoffrey Rippon frustrated the plan by listing 250 buildings across the Covent Garden area. Simon`s suspicion and apprehension of master planning is the thread that runs through this book. This is an unusual history because it is not dominated by a chronology of royal families, but is concerned with the evolution of London`s appearance, why it looks as it does today. In the first sentence his stall is set out. “The view of London from Waterloo Bridge is of a mess-an eccentric, unplanned, maddening, exhilarating mess. I have seen it evolving all my life, and still struggle to understand what moves it.” The author is too modest. Better than anything else I have read, he understands the capital and how it works. London`s pragmatism contrasts with the glory and splendour of cities such as Paris, Madrid or Rome with their broad boulevards and gigantic master planning. This book could become a primer for young professionals working in the built environment. Jenkins brilliantly dissects the misguided and poorly conceived strategies that have blighted the planning of the capital. No reputation is sacrosanct. Sir Patrick Abercrombie, the doyen of planners, is scolded for his plan to move over half a million people to eight new “satellite towns” in the Home Counties, including 40 percent of the population of East London. Jenkins concludes that as with any plan, the only question for Abercrombie`s, was how long it would survive first contact with the enemy. As it raised its head from the dust of war, London looked at the denizens of Whitehall and County Hall and said no. His greatest angst is reserved for London` obsession for tall buildings. Ken Livingstone when Mayor was fascinated by skyscrapers and would shout at planning meetings “Make it higher”. Boris performed a personal U-turn on tall buildings. Having accused Livingstone when in opposition of creating “Dubai-onThames “, he became high –rise`s most ardent advocate. These enthusiasms were shared by Peter Rees, the then Chief Planner for the City of London. The developers and their architects quickly realised the structures were virtually immune from restriction since there was no policy against them. Commenting on the Shard, Jenkins wrly observes that no other borough but poverty-

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stricken Southwark would have tolerated such a structure, with not the slightest nod of respect to its location in low-rise Bermondsey. The new towers that rose over the metropolis in the first two decades of the new century appealed to their purchasers precisely for the reasons they should not have been allowed. They offered privacy, secrecy, gated security and a lack of nosey neighbours. Many lie empty. Yield matters little to overseas investors wanting secrecy and security. In a chapter titled Constructs of Vanity Jenkins slates Boris Johnson for a succession of expensive failures, the loss – making cable car over the river in the East End, the “Garden Bridge” over the Thames at Temple, the closure of Hammersmith Bridge for want of £30 million for its maintenance, and new double –decker buses, where the rear platform proved almost unusable. There is praise for the positive impact that the Civic Amenities Act 1967 had on London. The act authorised local councils to declare neighbourhoods of architectural or historic importance. These took hold across London and within a decade they had spread to every London Borough other than Barking.

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BOOKS: A SHORT HISTORY OF LONDON | REVIEWED BY NIGEL MOOR

>>> Two hundred and fifty were in place by 1975, mostly in former Georgian and early Victorian neighbourhoods. Conservation replaced public with private money. Large areas of Central London began to change character as home owners and landlords sold to those able to spend on restoration. This gentrification has its critics but Jenkins points out that many of these areas had been built for middle –class Londoners, only drifting downmarket in the twentieth century. In this sense they were being ”regentrified”. Simon Jenkins concludes that past experience –London has coped with many seismic changes – suggests that Brexit would not seriously affect London`s long –term prosperity. While some activities might disperse to the continent, the city`s global status looks secure, as does its cultural appeal as an educational and tourist destination. The book was written and published before the Covid-19 pandemic took hold in the spring of this year. Does this pose a bigger threat to London than anything experienced before. New ways of working, shopping and travelling that have gathered momentum in just a few short months, suggest that in the future, London`s property market and particularly it`s fascination for tall buildings could falter. I don’t think this would sadden the author. n IMAGES PREVIOUS PAGE: The Shard under construction & The loss- making Gondolas across East London RIGHT: Covent Garden`s Moving Covent Garden today ABOVE: RIGHT The Shard at night

THE REVIEWER Dr Nigel Moor is a chartered town planner who began his career in London and has written two books: The Planner and The Market and The Look and Shape of England. He is now a Gloucestershire County Councillor and a cabinet member for Environment and Planning.

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Collaborative Construction Procurement and Improved Value

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DIRECTORY

Planning and Environment Reference Guide Please notify any changes immediately by e-mail to planninginlondon@mac.com with the subject ‘planning in london directory’. LONDON BOROUGHS DIRECTORY

London Borough of Barking and Dagenham Barking Town Hall Barking IG11 7LU

Mr Paul Moore Acting Chief Executive paul.moore@bexley.gov.uk 0203 045 4901 David Bryce-Smith Director Public Protection, Housing and Public Realm david.bryce-smith@bexley.gov.uk 0203 045 5779

020 8215 3000 https://www.lbbd.gov.uk/residents/planning -and-building-control/ Chris Naylor Chief Executive London Borough of Barking and Dagenham chris.naylor@lbbd.gov.uk 020 8227 2137 Simon Green Predsident of Barking and Dagenham Chamber of Commerce info@bdchamber.co.uk 020 8591 6966 Jeremy Grint Divisional Director of Regeneration and Economic Development jeremy.grint@lbbd.gov.uk 020 8227 2443

London Borough of Barnet Building 4 North London Business Park (NLBP) Oakleigh Road South London N11 1NP 020 8359 3000 John Hooton Chief Executive john.hooton@barnet.gov.uk 020 8359 2000 Lesley Feldman Planning Development Manager lesley.feldman@barnet.gov.uk

Seb Salom Head of Strategic Planning and Transportation seb.salom@bexley.gov.uk 0203 045 5779 Kevin Murphy Head of Housing and Regeneration kevin.murphy@bexley.gov.uk 0203 045 5837 Robert Lancaster Head of Developmental Control robert.lancaster@bexley.gov.uk 0203 045 5837

London Borough of Brent Brent Civic Centre Engineers Way Wembley HA9 0FJ 020 8937 1200 www.brent.gov.uk Carolyn Downs Chief Executive chief.executive@brent.gov.uk 020 8937 1007 Amar Dave Strategic Director Regeneration and Environment amar.dave@brent.gov.uk 020 8937 1516 Alice Lester Head of Planning, Transport and Licensing alice.lester@brent.gov.uk 020 8937 6441

Annie Hampson Chief Planning Officer and Development Director annie.hampson@cityoflondon.gov.uk 020 7332 1700 London Borough of Croydon Development and Environment Bernard Weatherill House

London Borough of Bromley Civic Centre Stockwell Close Bromley BR1 3UH 020 8464 3333 Ade Adetosoye OBE Chief Executive ade.adetosoye@bromley.gov.uk 020 8313 4060

8 Mint Walk, Croydon CR0 1EA 020 8726 6000 www.croydon.gov.uk/ planningandregeneration

Jim Kehoe Chief Planner jim.kehoe@bromley.gov.uk 020 8313 4441

Chief Executive Ms Jo Negrini jo.negrini@croydon.gov.uk

Lisa Thornley Development Control Support Officer

Director of Planning and Strategic Transport Ms Heather Cheeseborough heather.cheeseborough@croydon.gov.uk Director of Development Ms Colom Lacey colm.lacey@croydon.gov.uk 020 8604 7367

lisa.thornley@bromley.gov.uk London Borough of Camden Town Hall Extension Argyle Street WC1H 8EQ 020 7974 4444 www.camden.gov.uk

Head of Building Control Ric Patterson richard.patterson@croydon.gov.uk

Jenny Rowlands Chief Executive jenny.rowlands@camden.gov.uk 020 7974 5621 Frances Wheat Acting Assistant Director for Regeneration and Planning frances.wheat@camden.gov.uk 020 7974 5630

London Borough of Ealing Perceval House 14-16 Uxbridge Road Ealing London W5 2HL 020 8825 6600 www.ealing.gov.uk/planning Chief Executive Paul Najsarek najsarekp@ealing.gov.uk 020 8825 5000

Aktar Choudhury Operational Director of Regeneration aktar.choudhury@brent.gov.uk 020 8937 1764

City of London Department for the Built Environment PO Box 270 Guildhall London EC2P 2EJ 020 7332 1710 www.cityoflondon.gov.uk/planning

London Borough of Bexley Civic Offices Broadway Bexleyheath DA6 7LB

Rob Krzysznowski Spatial Planning Manager rob.krzysznowski@brent.gov.uk 020 8937 2704

Town Clerk and Chief Executive John Barradell OBE john.barradell@cityoflondon.gov.uk 020 7332 1400

Executive Director of Environment Keith Townsend townsendk@ealing.gov.uk 020 8825 5000

020 8303 7777

David Glover Development Management Manager david.glover@brent.gov.uk 020 8937 5344

Director of the Built Environment Ms Carolyn Dwyer carolyn.dwyer@cityoflondon.gov.uk 020 7332 1600

Director of Safer Communities and Housing Mark Whitmore whitmorem@ealing.gov.uk 020 8825 5000

www.bexley.gov.uk/planning

www.planninginlondon.com

Director of Regeneration and Planning David Moore moored@ealing.gov.uk

Issue 115 October-December 2020

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Chief Executive Tim Shields tim.shields@hackney.gov.uk 020 8356 3201

London Borough of Enfield PO Box Civic Centre Silver Street Enfield EN1 3XE 020 8379 4419 www.enfield.gov.uk/planning Chief Executive Ian Davis chief.executive@enfield.gov.uk 020 8379 3901

Assistant Director of Planning and Regulatory Services John Allen john.allen@hackney.gov.uk 020 8356 8134

Head of Development Management Andy Higham andy.higham@enfield.gov.uk 020 8379 3848 Planning Decisions Manager Sharon Davidson sharon.davidson@enfield.gov.uk 020 8379 3841 Transportation Planning David B Taylor david.b.taylor@enfield.gov.uk 020 8379 3576

020 8863 5611 www.harrow.gov.uk/planning

Director of Regeneration John Lumley john.lumley@hackney.gov.uk 020 8356 2138

Chief Executive Tom Whiting tom.whiting@harrow.gov.uk 020 8420 9495 Divisional Director of Planning Paul Nichols paul.nichols@harrow.gov.uk 020 8736 6149

The London Borough of Havering Town Hall Main Road Romford RM1 3BD

Head of Planning Regeneration John Finlayson john.finlayson@lbhf.gov.uk 020 8753 6740

01708 433100 www.havering.gov.uk

Royal Borough of Greenwich The Woolwich Centre 35 Wellington Street London SE18 6HQ

Director of Regeneration, Enterprise and Skills Pippa Hack pippa.hack@greenwich.gov.uk 020 8921 5519 Assistant Director of Planning Victoria Geoghegan victoria.geoghegan@greewich.gov.uk 020 8921 5363 Assistant Director of Transportation Graham Nash graham.nash@greenwich.gov.uk London Borough of Hackney

Environment and Planning Hackney Service Centre 1 Hillman Street E8 1DY 020 8356 8062

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Planning in London

Chief Executive Andrew Blake-Herbert andrew.blakeherbert@havering.gov.uk 01708 432201

Planning and Building Control Simon Thelwell simon.thelwell@havering.gov.uk 01708 432685

London Borough Of Haringey Level 6 River Park House 225 High Road Wood Green London N22 8HQ

Head of Development Management Dean Hermitage dean.hermitage@haringey.gov.uk

Head of Regeneration & Spatial Planning Ian Rae ian.rae@hounslow.gov.uk 020 8583 2561

London Borough of Islington 222 Upper Street London N1 1XR 020 7527 6743 www.islington.gov.uk/planning Chief Executive Ms Lesley Seary lesley.seary@islington.gov.uk 020 7527 3136

Team Leader for Planning & Projects Eshwyn Prabhu eshwin.prabhu@islington.gov.uk 020 7527 2450

Director for Housing, Regeneration & Planning Dan Hawthorn dan.hawthorn@haringey.gov.uk

Head of Planning Policy, Transport & Infrastructure Rob Krzyszowski rob.krzyszowski@haringey.gov.uk

Head of Development Management Marilyn Smith marilyn.smith@hounslow.gov.uk 020 8583 4994

Service Director of Planning & Development Karen Sullivan karen.sullivan@islington.gov.uk 020 7527 2949

020 8489 1400 www.haringey.gov.uk

Assistant Director for Planning, Building Standards and Sustainability Emma Williamson emma.williamson@haringey.gov.uk

020 8583 5555 www.hounslow.gov.uk/planning

Planning Control Manager Helen Oakerbee helen.oakerbee@havering.gov.uk 01708 432800

Development & Transport Planning Martyn Thomas martyn.thomas@havering.gov.uk 01708 432845

020 8921 6426 www.royalgreenwich.gov.uk/planning

London Borough Of Hounslow Civic Centre Lampton Road Hounslow TW3 4DN

Strategic Director of Housing , Planning & Communities Peter Matthew peter.matthew@hounslow.gov.uk

Chief Executive Ms Kim Dero kim.dero@lbhf.gov.uk 020 8753 3000

Head of Policy & Spatial Planning Pat Cox pat.cox@lbhf.gov.uk 020 8753 5773

Head of Major Initiatives, Strategic Planning & Transportation Jales Tippell jales.tippell@hillingdon.gov.uk 01895 250230

Chief Executive Niall Bolger niall.bolger@hounslow.gov.uk 020 8770 5203

London Borough of Hammersmith & Fulham Hammersmith Town Hall Extension King Street London W6 9JU 020 8748 3020 www.lbhf.gov.uk

Head of Development Management Ellen Whitchurch ellen.whitchurch@lbhf.gov.uk 020 8753 3484

Acting Chief Executive Ms Debbie Warren debbie.warren@royalgreenwich.gov.uk 020 8921 5000

London Borough of Harrow PO Box 37 Civic Centre Station Road Harrow HA1 2UY

Head of Spatial Planning Randall Macdonald 020 8356 8051

Head of Planning Policy Joanne Woodward joanne.woodward@enfield.gov.uk 020 8379 3881 Assistant Director Planning, Highways & Transportation Bob Griffiths bob.griffiths@enfield.gov.uk 020 8379 3676

Head of Planning & Enforcement James Rodger james.rodger@hillingdon.gov.uk 01895 250230

London Borough of Hillingdon Civic Centre High Street Uxbridge UB8 1UW 01895 250111 www.hillingdon.gov.uk/planning Chief Executive & Corporate Director of Administration Ms Fran Beasley fbeasley@hillingdon.gov.uk 01895 250111 Deputy Director of Residents Services Nigel Dicker ndicker@hillingdon.gov.uk 01895 250566

Deputy Head of Development Management & Building Control Andrew Marx andrew.marx@islington.gov.uk 020 7527 2045 Head of Spatial Planning Sakiba Gurda sakiba.gurda@islington.gov.uk 020 7527 2731


PLANNING AND ENVIRONMENT REFERENCE GUIDE

Chief Executive Ms Janet Senior janet.senior@lewisham.gov.uk 020 8314 8013 Royal Borough of Kensington and Chelsea The Town Hall Hornton Street London W8 7NX

Development Manager Geoff Whittington geoff.whittington@lewisham.gov.uk

020 7361 3000 planning@rbck.gov.uk

020 8891 1411 www.richmond.gov.uk/planning

Chief Executive Barry Quirk barry.quirk@rbck.gov.uk 020 7361 2991 Executive Director of Planning & Borough Development Graham Stallwood graham.stallwood@rbck.gov.uk 020 7361 2612

Chief Executive Paul Martin paul.martin@richmondandwandsworth.gov.uk 020 8871 6001 London Borough of Merton Merton Civic Centre London Road Morden Surrey SM4 5DX 020 8545 3837 www.merton.gov.uk/planning Chief Executive Ged Curran chief.executive@merton.gov.uk 020 8545 3332

Royal Borough of Kingston Upon Thames Guildhall 2 High Street Kingston Upon Thames KT1 1EU 020 8547 5002 www.kingston.gov.uk/planning

Assistant Director Traffic & Engineering Nick O’Donnell nick.o’donnell@richmondandwandsworth.gov. uk Deputy Director Highway Operations & Street Scene Kevin Power kevin.power@richmondandwandsworth.gov.uk

The London Borough of Tower Hamlets Mulberry Place 5 Clove Crecsent London E14 2BE 020 8364 5009 Chief Executive Will Tuckley will.tuckley@towerhamlets.gov.uk Divisional Director Planning & Building Control owen.whalley@towerhamlets.gov.uk 020 7364 5314 Strategic Planning Manager Adele Maher adele.maher@towerhamlets.gov.uk 020 7364 5375

Director of Community and Housing Hannah Doody hannah.doody@merton.gov.uk 020 8545 3680 The London Borough of Southwark 160 Tooley Street London SE1 2QH 020 7525 3559 London Borough of Newham Newham Dockside 1000 Dockside Road London E16 2QU 020 8430 2000 www.newham.gov.uk/planning Chief Executive Kim Bromley-Derry kim.bromley-derry@newham.gov.uk

London Borough of Lambeth Phoenix House 10 Wandsworth Road London SW8 2LL

Director of Housing and Regeneration Brian Reilly brian.reilly@richmondandwandsworth.gov.uk

Director of Environment and Regeneration Chris Lee chris.lee@merton.gov.uk 020 8545 3051

Interim Chief Executive Roy Thompson roy.thompson@kingston.gov.uk 020 8547 5343 Head of Planning Lisa Fairmaner lisa.fairmaner@kingston.gov.uk 020 8470 4706

London Borough of Richmond Upon Thames Civic Centre 44 York Street Twickenham TW1 3BZ

Executive Head of Economic Development, Planning & Sustainability Eleanor Purser eleanor.purser@sutton.gov.uk

The London Borough Of Waltham Forest Town Hall London E17 4JF 020 8496 3000 www.walthamforest.gov.uk

Chief Executive Eleanor Kelly eleanor.kelly@southwark.gov.uk 020 7525 7171 Strategic Director of Environment & Social Regeneration Deborah Collins deborah.collins@southwark.gov.uk 020 7525 7171

Director of Commissioning (Communities, Environment & Housing) Simon Litchford QPM simon.litchford@newham.gov.uk

Chief Executive Martin Esom martin.esom@walthamforest.gov.uk 020 8496 3000 Strategic Director, Corporate Development Rhona Cadenhead rhona.cadenhead@walthamforest.gov.uk 020 8496 8096 Director Regeneration & Growth Lucy Shomali lucy.shomali@walthamforest.gov.uk

Chief Executive Andrew Travers atravers@lambeth.gov.uk 020 7926 9677 Divisional Director for Planning, Regeneration & Enterprise Alison Young ayoung5@lambeth.gov.uk 020 7926 9225 Divisional Director Housing Strategy & Partnership Rachel Sharpe rsharpe@lambeth.gov.uk

London Borough of Lewisham Town Hall Catford London SE6 4RU 020 8314 6000 www.lewisham.gov.uk/planning

www.planninginlondon.com

London Borough of Redbridge 128-142 High Road Ilford London IG1 1DD

The London Borough of Sutton 24 Denmark Road Carshalton SurreySM5 2JG

020 8554 5000 www.redbridge.gov.uk/planning

020 8770 5000 www.sutton.gov.uk/planning

Chief Executive & Head of Paid Service Andy Donald andy.donald@redbridge.gov.uk

Chief Executive Helen Bailey helen.bailey@sutton.gov.uk

Interim Head of Planning & Building Control Ciara Whelehan ciara.whelehan@redbridge.gov.uk

Assistant Director, Resources Directorate (Asset Planning, Management & Capital Delivery) Ade Adebayo ade.adebayo@sutton.gov.uk 020 8770 6349

Head of Inward Investment & Enterprise Mark Lucas mark.lucas@redbridge.gov.uk 020 8708 2143

The London Borough of Wandsworth Town Hall Wandsworth High Street London SW18 2PU 020 8871 6000 www.wandsworth.gov.uk

Strategic Director of Environment, Housing & Regeneration Mary Morrisey mary.morrissey@sutton.gov.uk 020 8770 6101

Chief Executive Paul Martin paul.martin@wandsworth.gov.uk 020 8871 6001 Head of Development Permissions Nick Calder ncalder@wandsworth.gov.uk 020 8871 8417 Environment and Community Services Directorate

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Mark Hunter mhunter@wandsworth.gov.uk 020 8871 8418 Head of Forward Planning and Transportation John Stone jstone@wandsworth.gov.uk 020 8871 6628

Chief Executive Stuart Love slove@westminster.gov.uk 020 7641 3091 City Of Westminster Westminster City Hall 64 Victoria Street London SW1E 6QP 020 7641 6500 www.westminster.gov.uk

Please notify any changes immediately by e-mail to planninginlondon@mac.com with the subject ‘planning in london directory’.

Director of Planning 020 7641 2519 Head of City Policy and Strategy Barry Smith bsmith@westminster.gov.uk 020 7641 3052

OTHER ORGANISATIONS Greater London Authority City Hall The Queen’s Walk London SE1 2AA

Assistant director, planning Juliemma McLoughlin

Martin Cowie Strategic Planning Manager martin.cowie@london.gov.uk 020 7983 4309

020 7983 4000 www.london.gov.uk

Justin Carr Strategic Planning Manager justin.carr@london.gov.uk 020 7983 4895

Sadiq Khan Mayor of London mayor@london.gov.uk 020 7983 4000

Graham Clements Senior Strategic Planner graham.clements@london.gov.uk 020 7983 4265

Urban Design London Palestra 197 Blackfriars Road London SE1 8AA 020 7593 9000 www.urbandesignlondon.com

Executive director, development, enterprise, environment Lucy Owen

Martin Scholar Strategic Planning Manager (Planning Frameworks) martin.scholar@london.gov.uk 020 7983 5750

Planning Officers Society The Croft, 81 Walton Road, Aylesbury HP21 7SN tel: 01296 422161

Design For London City Hall The Queen’s Walk More London London SE1 2AA info@designforlondon.gov.uk Ministry of Housing, Communities and Local Government 020 7944 4400 enquiries.br@communities.gsi.gov.uk planning.policies@communities.gsi.gov.uk Steve Quartermain, director, chief planner Simon Gallagher, director, planning

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