Planning in London No 129 APRIL-JUNE 2024

Regulars

LEADERS page 5

FINCH page 7

MALLETT page 8

¡PILLO! page 57

PLANNING PERFORMANCE p32

ROGERS page 55

LP&DF page 36

PLANNING UNDER LABOUR – WHAT MIGHT AND WHAT SHOULD CHANGE? Michael Edwards page 52; London's next 30-year development cycle, Greg Clark page 64; London’s productivity, Jon Tabbash page 67; Ramboll’s Green spaces toolkit, Lee Mallett page 58; Small sites, Riëtte Oosthuizen p15; Planning for water stress, Matt Clarke p23; AI in architecture, Dean Hodcroft p24

21-23 may

Clerkenwell Design Week returns to London from 21 – 23 May 2024, marking its 15th year as a global design festival. Building upon its record-breaking 2023 edition, which drew over 37,000 visitors, the upcoming event is set to elevate the experience with new venues, expanded exhibition spaces, thought-provoking installations and a stronger-than-ever line-up of both British and international brands.

Expect more than 600 curated events spread throughout the EC1 neighbourhood, complemented by a network of over 160 local design showrooms and 300 exhibitors across 12+ venues.

"Not only is Clerkenwell Design Week one of the most attended speci昀cation events in the architecture and design calendar, it is also an important platform to discover new talent and ideas," says Marlon CeraMarle, Design Division Director of Media 10 which organises the annual design festival.

“This year, we’re excited to showcase an unprecedented number of participating brands, re昀ecting strong demand from both home and overseas. In response, we’re expanding our exhibition and installation spaces, including the newly revamped, pedestrian-friendly Clerkenwell Green.”

Event details:

When? 21–23 May 2024

Where? Across Clerkenwell, London, EC1

How much?

Free but pre-registration is required

For more details visit

www.clerkenwelldesignweek.com

28 BRIEFING

CLIPBOARD: Dirty protest – Spectral residues haunt the platforms of the Elizabeth Line; Homes granted permission fall 20 per cent over the year; Second staircase requirement to take effect in September 2026; Validating applications adds to delays; Government clampdown will lead to more refusals and appeals; London’s councils £400m shortfall; Retrofit Toolkit aims for a net-zero Square Mile – Retrofit Toolkit summary

32 PLANNING PERFORMANCE

Decisions both decided and granted continue to fall over the past year

36 LONDON PLANNING & DEVELOPMENT FORUM

Annual planning update conference

New NPPF, more homes, transport planning and what might change under Labour

36 THE NEW NPPF & DEVELOPMENT MANAGEMENT REFORM

Mike Kiely & Dan Slade

46 THE LONDON PLAN AND HOUSE BUILDING Prof Janice Morphet, UCL: building by local authorities

Prof Les Mayhew, Bayes Business School: Older peoples housing – time for change

48 TRANSPORT PLANNING, what’s new? David Hart & Jolyon Drury on kerbside challenges –freight, distribution and kerbside conflicts

Continues next page

52 PLANNING UNDER LABOUR – WHAT MIGHT AND WHAT SHOULD CHANGE?

Prof Michael Edwards, UCL & John Walker, CT Group

55 ANDREW ROGERS

Let’s not trouble the planners

57 ¡PILLO!

They keep on coming; This is an M&S planning decision; F–Off!; MMC gone wrong; Re-imagining The Tipperary; Presumption in favour of brownfield; Budget comment

FEATURES

58 Ramboll’s Green spaces toolkit | Lee Mallett

61 Build to Rent | Jacqui Daly

64 London's next 30-year development cycle | Greg Clark

67 London’s productivity | Jon Tabbash

70 Housing for seniors | Nicola Gooch and Oliver Knight

BOOKS

72 Property: The myth that built the world | Reviewed by Nicholas de Klerk

75 PLANNING AND ENVIRONMENT REFERENCE GUIDE

78 SUBSCRIPTION ORDER FORM

79 SHAPING THE WORLD

The Gerrard Arcade | Mark Willingale

83 ADVICE

ISSN 1366-9672 (PRINT)

ISSN 2053-4124 (DIGITAL)

Issue 129 APRIL-JUNE 2024

www.planninginlondon.com

The London Planning and Development Forum (LP&DF)

The LP&DF was formed in 1980 following an all-party inquiry into the development control system.

It selects topics to debate at its quarterly meetings and these views are reported to constituent bodies and published in Planning in London.

It is a sounding board for the development of planning policy in the capital, used by both the public and private sectors.

Agendas and minutes are at www.planninginlondon.com

To attend please email the Hon. Secretary

The LPDF is administered by: Brian.Whiteley@planningaid.rtpi.org.uk & Riette Oosthuizen riette.oosthuizen@hta.co.uk & James Mitchell : jm@axiomarchitects.co.uk

Chairman: Brian Waters MA DipArch (Cantab) DipTP RIBA MRTPI ACArch ppACA FRSA

Principal: The Boisot Waters Cohen Partnership brianwaters1@mac.com

Vice-Chairmen: Riette Oosthuizen HTA Design: riette.oosthuizen@hta.co.uk and Jonathan Manns: JLL jon.manns@gmail.com

Member bodies

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

Reviewed by Nicholas de Klerk page 72

London Councils

British Property Federation

Design Council CABE

City of London Law Society

Confederation for British Industry DLUHC

Design for London/ Urban Design London

Historic England

Environment Agency

Greater London Authority

Home Builders Federation

Landscape Architecture SE

London Chambers of Commerce & Industry

London Forum of Amenity Societies

London Housing Federation

National Planning Forum

ICE, RIBA, RICS, RTPI, UDAL, TCPA

Transport for London

London University (The Bartlett, UCL)

University of Westminster

Affiliated members: Planning Aid for London

London Metropolitan University

THE

Ramboll’s Green spaces toolkit, Lee Mallett page 58

Thames Tideway is arguably the most significant piece of infrastructure for London since the water Ring Main

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

Achievement to be celebrated

As news media waxed furious about sewage discharges into the Thames coinciding with the Oxford/Cambridge Boat Race, few bothered to celebrate the completion of the Thames Tideway Tunnel, which is now being tested and will come into full action next year, eliminating 95 per cent of ‘incidents’ where heavy rain results in overloading of Joseph Bazalgette’s extraordinary Victorian sewerage system.

Thames Tideway is arguably the most significant piece of infrastructure for London since the water Ring Main, though one should forget neither the Jubilee Line nor the Elizabeth Line in a list of great achievements which suggest our metropolis can still feel like a world-class city.

In the case of TT, the fact that it is largely invisible means that it lacks the glamour required for a ritzy celebration. For ideologues who believe that private sector investment inevitably results in the public bring ripped off (and in the case of Thames Water they have a point), TT is an unhelpful example of capitalism put to good use. (Needless to say this project was opposed on planning grounds by the usual collection of hopeless luvvies incapable of understanding the infrastructure needs of a 21st century city.)

Completion of the project raises a question which our politicians should give more consideration to – which is why we cannot treat the provision of mass housing as an infrastructure exercise, rather than a series of one-off developments all over London.

This is especially so, given that the idea that we are so short of money that we cannot build out way out of the housing shortage is evidently not the case. The ability of private investors to raise all the capital they needed for TT suggests otherwise.

The short answer to the above question is that we do not appear to have an organisation that has the necessary commitment to delivering what we need on the housing front, at least in London.

Where is the equivalent of Homes England in the capital? We desperately need an overarching body that has funding, planning powers (and cpo powers too) which can address severe shortage in the way that the TT folk addressed a pressing environmental need.

The current mayoral election campaign shows little sign that anyone is taking the subject with the necessary vision or commitment.

Everyone seems to agree we should build more council houses to solve the housing crisis, for which the planning system is taking flak

Let’s not go back to the future

Here, for argument’s sake, are some reasons why we shouldn’t rush back to the future - or blame planning.

1 – Architects are very keen on it. It comes with a warm sense of social fulfilment. Like being a doctor, proof of socially useful status. And you might be able to design something that actually looks like decent residential architecture. But architects’ record isn’t fantastic. And neither is local authorities’ management record. A road paved with good intentions, but less happy destinations, unless carefully conceived and managed by a dynamic and sensitive owner.

2 – Councils would love to. It earns them money and cements them in public life. Who wouldn’t vote for a local authority that provided one with a less expensive place to rent with affordable service charges and a secure tenancy? But what about the large amounts of economic value trapped in the vast residential property portfolio of UK local authorities? Taxpayers fund this service and we hear little about the condition and effective management of this asset.

3 – Taxpayers would like it. They are fuming about the amounts of rent they have to pay in the private sector and because it is pretty much impossible to get a council flat and the cost of what they want to buy are utterly out of reach in London. You want kids? Leave London. But would Councils deliver for taxpayers? Unlikely as they don’t seem very interested in anything but social housing. Nor are they much good at extracting full value from their property holdings.

4 – Councils will become much better developers and managers than they have been. Some councils do good works. But even so, there isn’t much public information made available about their performance as developers and managers, such as you might expect of private housing providers. A quick dip into the condition and development potential of many public property portfolios reveals missed opportunities that might not go unpunished in a private company. Housing associations are not famed for their management abilities either. There’s an opaque accountability deficit. And Croydon’s experience is a salutary reminder that development is risky and can rapidly turn toxic.

5 – There is no better way of delivering the housing we need at scale. There is. The assumption that subsidised housing should be provided by the public sector alone doesn’t stand up. There are tens of billions of pounds trying to get into the UK’s undersupplied rented sector. Could the private sector working with the public sector do it quicker and better?

Maybe a more productive role for the public sector would be to closely police and manage a joint public/private housing delivery system for affordable housing to circumnavigate the worst of all worlds that prevails where affordable housing planning policies fail to deliver and local authorities are too constrained in what they can do. n

London – procrastination city FINCH

To pick up on two London stories covered in recent months: first, the courts decided in favour of Marks and Spencer in their action against the government’s planning refusal of redevelopment in Oxford Street. The relevant minister, Michael Gove, now has to reconsider his decision, given that five of his six reasons for refusal have now been rejected by a High Court judge. He would have been forced to reconsider if only one of the six had been rejected, so five out of six is something of an embarrassment. We wait to see what happens next.

Predictable news on the South Bank, where the government upheld a planning inspector’s decision that a major development by Mitsubishi, designed by Make Architects, should be approved. Now opponents are seeking funding support in order to launch a legal challenge against the decision. Watch this space – this was a very carefully written inspector’s report which Mr Gove could not reject, even though he does not like the proposal.

Our mercurial mayor, Sadiq Khan, supported both of these developments so cannot be accused of being a stereotypical left-wing opponent of development. Moreover, recent nasty attacks accusing him of being controlled by Islamists, clearly not the case, have generated a certain amount of sympathy for him, even among political opponents.

The sympathy starts to run out in respect of things he himself should be instigating or generating but has failed to. This is most obvious in respect of the ongoing scandal of the closed Hammersmith Bridge (closed to ordinary motorists, that is), where there is no extant plan to do anything about it.

But it has also applied to housing, where every announcement he makes has to be read twice in order to understand the real implications, which are that he is doing very little to help. These often take the form of statistical wizardry where housing planning applications are elided with construction starts, then elided with completions and occupation. Another trick is to cite large numbers of new homes on projects where substantial demolition is involved: the ‘net additional homes’ statistic is rarely supplied.

You can understand why, since the mayor has

land, planning powers and funding from government to produce those net additional dwellings – but he doesn’t do anything directly, instead making announcements about what he hopes other people will do.

On the day of writing this column, Mayor Khan announced he was going to ‘build 40,000 council homes’, part of his manifesto for re-election as mayor, which looks like a formality given a lacklustre Conservative candidate and the general state of that political party. Examine the 40,000 figure and it looks like peanuts. For one thing it will take until 2030 to deliver, so a pitiful 8,000 dwellings per year. By the way, these won’t be Greater London Authority homes, but homes actually procured by local authorities, whose track record in these matters is, to put it mildly, patchy.

In May last year, City Hall said London was in the process of ‘delivering the highest number of council homes since the 1970s’, with 23,000 council units started since 2018 – again a confusing number which ignores the lack of completions earlier this century, and amounts to a start (not completion) rate of under 4,000 a year.

To understand how pitiful this is, you have to understand what is happening to London’s population: it is rising at an extraordinary rate, with more than two million residents added in the past 30 years while housing completions have been at a historic low. With another million residents (net) by the end of this decade, triumphalism about the mayor’s proposals, let alone his achievements, looks highly inappropriate.

A near-laughable set of recommendations from the Greater London Authority to the mayor, about his next spatial plan, rambles on about genderdiverse spaces, inclusive design, the architectural design of social housing and the importance of women. There is no mention of the chronic undersupply of housing or how a planning policy might address this. Pathetic. And check out the images of the committee and advisers ‘at work’. About as an unrepresentative group of Londoners as you are every likely to see.

Meanwhile the lust for further regulation, gum-

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

ming up an increasingly sclerotic planning process, is doing nothing to encourage the private housebuilding sector, including small and medium-size enterprises. We have had alarms, some exaggerated some not, about a shortage of qualified building control officers as a results of new registration requirements prompted by the Grenfell Tower fire disaster; and we now wait to see the effects of new biodiversity increase requirements (net) on production and timely planning.

Since there are not enough experienced ecologists to conduct the necessary analysis work on applications, expect a lot of cut-and-paste applications and reviews – a boon to the myriad people and groups who love nothing more than trying to block housing development anywhere near them, sometimes with the support of local authorities.

An example from a location an hour outside London: a very civilised proposal in a heritage setting of 117 net additional homes, included development on three small sites recommended by the local authority as suitable for development. The proposal was supported by the authority’s own urban design official. Bizarrely, the authority then brought in an outside urban design consultant who gave a different opinion about the merits of the scheme (ie condemning it), and criticised use of one of the sites recommended for homes by the planning case officer. Result: a planning inquiry after the architect and good clients (46% affordable homes in the project) had worked on the proposal for four years.

This gives the planning system a bad name – and a housing delivery blockage replicated in many different guises, across the country.

No wonder the UK has a housing shortage. n

A more humane City MALLETT

‘The Invisible Hand’ was the vivid metaphor 18th Century economist Adam Smith coined to describe the mechanism by which useful social and economic outcomes arise from the self-interested actions of individuals, or other entities, none of whom may directly intend to bring about such outcomes.

From this end of the neo-liberal era, which championed the notion things will be better left to the market, the concept is showing its limitations, not least at Thames Water. There are some things the market will not do, unless forced or effectively policed by the hand of socio-political leadership.

In London the lack of housing (and other problems) must be laid at politicians’ door. If we wish to rely on the market to do stuff in the way we want, politicians and civil servants have to create the right conditions, not the wrong conditions. The mess we have made of planning for the market to provide affordable housing is something any future government must visibly grapple with and resolve. PDQ.

Prof. Greg Clarke writes about London’s resilience, inventiveness, ability to scale-up, its outward looking internationalism, and the new postpandemic cycle we are embarked on. His parting shots in his Shaping a Better City essay for NLA’s New London Agenda, however, talks about the need for a new ‘social contract’ for the capital that addresses planetary, social and spatial justice’ as a way of ameliorating and reversing the existential threat to London of a ‘long cycle of uncertainty and perhaps unmanaged decline’.

There are a lot of those ‘post’ conditions the capital still struggles with. War (looming again), Empire, departure of industry and people until the 80s, 2008’s Global Financial Crisis, Brexit, and our current political crisis which led to Brexit and the post-Truss bombing of the economy last September by a party that invented the era now departing.

It's not a pretty picture in the run up to the Mayoral or national elections. And yet, London is rammed with visitors and new migrants, despite the indigenous population’s falling birth rate, and the departure of couples seeking a viable place to raise a family.

London was all too familiar with unmanaged decline prior to the 1980s. Its effects are still around

us, despite the dramatic market driven ‘unmanaged’ growth we’ve been living through, which is failing to meet the capital’s broader range of needs.

The City of London has been central to that growth. It was one of the chief beneficiaries of the Thatcher era, even though the stock market had to be dragged kicking and screaming to Big Bang. The City ‘fathers’ had to be shocked into approving new office development by the threat of upstart Yanks creating an alternative venue down in darkest Docklands. Competition, eh?

Now the City has finally got round to completing its new plan, City Plan 2040, and is shortly due its final round of public consultation. Meanwhile though, the UK stock market, perhaps the chief barometer of the City’s status, is floundering with companies jumping ship to New York and uncaring UK investing institutions looking on. Not something planning can meaningfully address perhaps.

London was all too familiar with unmanaged decline prior to the 1980s. Its effects are still around us, despite the dramatic market driven ‘unmanaged’ growth we’ve been living through, which is failing to meet the capital’s needs.

But the arrival of a new local plan in a place that contributes more than £90bn annually to the UK economy and provides jobs for 615,000 people is also a snapshot of a ‘visible hand’ of local government and offers directions for planning everywhere. Its policies encourage a new urbanism that should help establish the renewed ‘social contract’ Greg Clark seeks. The City’s chief politician, Chris Hayward Policy Chairman of the City Corporation, writes about it in City AM this month: ‘improving our environment and open spaces strengthens our communities, public services and competitiveness, which will provide better economic growth…our corporate plan and people strategy are opportunities to provide a world-class experience for all those who live

work learn and explore in the Square Mile…’ It’s about people and place.

There are policies which require developers and designers, for example, to include more mixed uses, including cultural activities, to demonstrate biodiversity net gain, to consider retro-fit first and demonstrate scientifically why redevelopment might be better. The City’s transport strategy, which we wrote about in our last issue, PiL 128, and which supports this plan, also pursues vigorously the enhancement of the City’s public places and discourages private vehicles while encouraging healthier options.

The policy thrust is all about making a more humane place with more diversity of uses, including no less than 2m sq ft of additional retail space –pretty much the equivalent of at least one Westfield. Major developments must also make cultural plans for arts, culture and leisure uses, which can be pooled with those from other schemes. Provision for visitor facilities must be made.

The UK operates on a social contract that balances opportunity with needs and some semblance of fairness. The City Plan 2040 demonstrates the need for that contract to be tangible to shape a better City. It is not an insensitive piling of market forces. And even the City, in all its affluence, continues to need dynamic and creative planning, in its seven Key Areas of Change - Smithfield, the core City Cluster, Fleet Street and Ludgate, Blackfriars, the Pool of London riverside, Liverpool Street station and Aldgate-Tower of London.

Economic, climactic and technological change are driving transformation such that even in a continuously evolving confined area like the City, the need for an intelligent, visionary, visible hand is a necessity to invent the future and generate opportunity for the market. n

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

Nick White

sets out the basics of BNG now it has kicked-in for both major and minor developments

What Is Net Gain?

Net gain is an approach to development, and/or land management, that leaves the natural environment in a measurably better state than beforehand

Does not change existing environmental protections or legal requirements and is not applicable to irreplaceable habitats

Mandatory Biodiversity Net Gain – Key Components

The Environment Act

•England only

•Amends the Town & Country Planning Act (TCPA) & 2008 Planning Act

•Applies down to mean low water

•Minimum 10% gain required calculated using Biodiversity Metric & approval of a net gain plan

•Habitat secured at least 30 years

•Delivered, on-site, off-site or via statutory biodiversity credits

•National register for net gain sites

•Legal requirement from – February 12th 2024 major TCPA development, 2nd April 2024 minor TCPA developments + late 2025 (NSIP)

•Does not change existing legal protections/processes

Dr Nick White is principal advisor - Net Gain, Natural England

The Four Crises

Four Crises

What Is Net Gain?

Net gain is an approach to development, and/or land management, that leaves the natural environment in a measurably better state than beforehand

Does not change existing environmental protections or legal requirements and is not applicable to irreplaceable habitats

Mandatory Biodiversity Net Gain – Key Components

The Environment Act

•England only

•Amends the Town & Country Planning Act (TCPA) & 2008 Planning Act

•Applies down to mean low water

•Minimum 10% gain required calculated using Biodiversity Metric & approval of a net gain plan

•Habitat secured at least 30 years

•Delivered, on-site, off-site or via statutory biodiversity credits

•National register for net gain sites

•Legal requirement from – February 12th 2024 major TCPA development, 2nd April 2024 minor TCPA developments + late 2025 (NSIP)

•Does not change existing legal protections/processes

Secondary Legislation, Statutory Metric and Guidance

Secondary legislation

•Exemptions – de minimis impact, permitted dev, householder, some custom/self-build + enviro projects selling biodiversity units

•Net gain register

•Irreplaceable habitats

Additional BNG Guidance incl

•‘Significant’ onsite

•Additional developer guidance

•Additional land manager guidance

Statutory biodiversity metric

BNG Planning Practice Guidance

• Sets out BNG planning process

• Introduces a Biodiversity Gain Hierarchy –explore onsite before going offsite

• Details how significant onsite gains must be secured for 30 years

• Requires onsite habitat management and monitoring plan (NE voluntary template)

• Covers relationship between existing local plan BNG requirements and statutory BNG – former cannot trump the latter

• Details what BNG info to provide to LPA when

Mechanisms for Biodiversity Net Gain Delivery

The Importance of a Metric

Fundamental to net gain

Net gain is an approach to development, and/or land management, that leaves the natural environment in a measurably better state than beforehand.

The metric:

•Calculates baseline + forecast outcome

•Provides confidence

•Ensures consistency of approach

Needs to be:

•Simple yet sound

Metric Applications

Changes from Metric 4.0 to Statutory Biodiversity Metric

Developments subject to mandatory BNG legally MUST use the Statutory Biodiversity Metric.

Key changes compares to metric 4.0 include:

•Intertidal habitat calculation changes

•Changes to application of strategic significance when an LNRS is in place

•Tool include a statutory biodiversity credit calculator

•Very high distinctiveness habitat trading rules

•Irreplaceable habitats

•Rule 4 – deviation from metric

Exemptions + Tools for Smaller Development Sites

Minor TCPA developments temporarily exempt until 2nd April 2024

The following are fully exempt:

•Householder applications

•Some custom/self-builds exempt

•De minimis habitat impact exemption - less than 25m (area habitat) or 5m long (linear habitat)

•Permitted developments

Tools for Smaller Developments

• Small Sites Metric – lower user competency threshold but restrictions on use

•Simplified habitat management & monitoring plan template

BNG – Top Tips

•Consider early! – site selection + outline design

•Refer to guidance/standards – CIRIA/CIEEM/IEMA, BS8683 or Government Advice

•What are the local priorities? e.g. LNRS, GI strategy, biodiversity opportunity areas etc

•Undertake baseline metric calculations

•Determine your delivery strategy – onsite/off-site or combinations of + how relates to other obligations

•If delivering onsite how will this be maintained?

The Role of Natural England in BNG

Natural England is not a statutory consultee for Biodiversity Net Gain matters in relation to individual applications.

•Natural England will:

•Operate the net gain register

•Operate the statutory biodiversity credit sales service

•Oversee macro-level monitoring & evaluation

•Periodically make recommendations to the Secretary of State on Statutory Biodiversity Metric updates

•Provide a net gain enquires/signposting service

Natural England Additional Activities

•Publishing Habitat Management & Monitoring Plan and Management Reporting templates (optional)

•Running a pilot BNG quality assurance project

•Produce additional guidance notes as needed e.g. guidance for coastal LPAs

•Engaging strategically with LPAs and other local stakeholders through our area teams

•Continuing to publish/commission BNG blogs

•Convene BNG-related events + provide training content

Additional Information About BNG

•Statutory biodiversity metric - Statutory biodiversity metric tools and guides - GOV.UK (www.gov.uk) - includes small sites metric

•Defra guidance on BNG - Biodiversity net gain - GOV.UK (www.gov.uk)

•DLUHC BNG PPG - Biodiversity net gain planning practice guidance - GOV.UK (www.gov.uk)

•NE Blogs about BNG - Biodiversity Net Gain - Natural England (blog.gov.uk)

•NE BNG high-level brochure – Biodiversity Net Gain: An introduction to the benefits

•Planning Advisory Service website has good links on BNG - Biodiversity Net Gain for local authorities | Local Government Association

•CIEEM/CIRIA/IEMA good practice - Biodiversity Net Gain: Good Practice Principles for Development

Think small to up housing supply

Small sites can contribute to housing supply via infill development and rejuvenation of existing supply, argues Riëtte Oosthuizen

There is little doubt that brownfield land as a source of housing delivery is not fully exploited in England.

In its 2022 report 'State of Brownfield', CPRE, the countryside charity, estimated that 1.2 million homes could be built on 23,000 sites across more than 66,720 acres of brownfield land.

Brownfield land is an important source of housing delivery and sustainable development. On 13 February, the government announced a new presumption in favour of' brownfield land to bolster development in English towns and cities that had housing delivery test scores below 95% of the total need. The pressure, of course, will be on London, where there is an estimated backlog of well over 60,000 homes, four years into the current 10-year London Plan.

The newly introduced presumption in favour of brownfield development might be like the emperor's new clothes. My bet is it will not make the planning journey a smoother one. The problem is multifaceted and the planning system alone is not to blame.

The real issues

The proposals from housing secretary Michael Gove do little to tackle some of the real issues that stifle the delivery of brownfield land: constant policy change on the viability of developing large regeneration schemes, local political opposition and the difficulty in engaging with under-

resourced planning departments, at huge cost.

Small sites may be an easier target; they can make a huge contribution to housing delivery in the form of infill development or through the rejuvenation of the existing housing supply. However, these sites face significant planning hurdles owing to heightened scrutiny.

Before the latest iteration of the London Plan, a presumption to approve housing on small sites was downgraded to 'proactive support', and a previously set housing target for small-site delivery was reduced from 245,730 to 119,250. Small and medium-sized enterprises have also previously lobbied the government to bring in a presumption in favour of small sites that provide 60% affordable housing.

HTA Design believes the potential of small sites is significant, as demonstrated in our work on 'supurbia'. We estimated the potential of small sites in the outer circle of London to be more than 360,000 new homes. This could be put in motion through area-based design codes and local development orders on undeveloped land in suburban areas, while maintaining a more sustainable character.

Local authorities could proactively identify suitable areas for intensification (maybe even through permission in principle) rather than community members needing to bear the cost of drafting design codes, as would be the implication of the government's Street Votes proposals.

Permitted Development Rights – changes

Gove's announcements also introduced changes to permitted development rights (PDR], removing the floor area limitation for converting commercial buildings into residential. If more emphasis is put on increasing PDR, it needs to be accompanied by an emphasis on creating homes that are sustainable and contribute to healthy living - a principle overlooked in the final legislation, despite being heavily campaigned for by the Town and Country Planning Association.

Are they well located for access to amenities? How do they perform in terms of air quality, noise and floor-to-ceiling heights? Do they form a community and provide internal liveability for families?

There is a vast body of evidence setting out the pitfalls of this avenue for housing supply, not least whether this Is a sustainable way for the long term. It seems quantity, rather than quality takes precedence here.

If these latest announcements do introduce flexibility on the multitude of policy expectations that need to be justified to get planning approval, I am sure they will be welcomed. It will ease the pressure, but I wonder where the flexibility emphasis will be. Too much time and energy is spent on decision-making on small sites which could easily be shown to comply with an area-based design code.

Somehow, I doubt it will all be so simple. We seem to be building an ever-more complicated and multilayered planning system, leaving to the wayside a wider and connected vision of focusing on good-quality, affordable and sustainable housing for the long term. n

Based on piece first published in Property Week, with kind consent

Dr Riëtte Oosthuizen is planning partner at HTA Design

HTA Design for housing on a small site in Croydon

Reform needed to deliver the homes we need

Just Build Homes is at the forefront of the YIMBY movement, bridging the gap between supporters of housebuilding and the official planning process, explains Millie Dodd

London is one of the most unaffordable places to live in the UK. So why aren’t there hundreds of people supporting every planning application in the city to deliver more homes?

The imbalance between the supply and demand of housing has continued to push rents to record highs and the prospect of homeownership even further out of reach for many. The average London home now costs fourteen times the typical annual income1, and ‘the housing crisis is getting worse’ is a statement you hear month on month.

For younger people like myself experiencing the housing crisis, it could be easy to become desensitised to the issue and accept that perhaps you will just have to pick up a second job in the evenings to be able to afford your rent and consequent independence. Or that maybe living in your childhood home until you are in your 30’s isn’t quite so bad if you can perhaps afford to buy a house eventually. After all, if the only information you see about new housing developments is people telling you how to object and what to say on the local Facebook group – it must be bad, right?

The truth is that housing is popular. In fact, The British Social Attitudes Survey shows that in every area of the UK the majority of people support building more homes in their own area. So where are these millions of angry people demanding more housing to be built?

Supporters of housebuilding are there: they are just not being reached in the traditional planning process. Before joining Just Build Homes I was aware of the housing crisis and frustrated with my experience of delayed adulthood. And yet, I had never used a planning portal to support a local development, nor did I realise how important it is for decision makers to hear from local supporters of new housing to ensure that more homes get built.

This disconnect between frustration and action, has in part been created because the planning process has unfortunately been dominated by objectors. Traditional consultations tend to attract existing homeowners in the area who will likely never change their mind about development, arguing about height and density whilst not even considering the housing need in the area. Planning portals

themselves are complex and full of jargon, and in some cases do not even consider that there could be support, asking only ‘do you object or not object’.

Just Build Homes is out to change that. We are at the forefront of the YIMBY movement, helping supporters’ voices to be heard by bridging the gap between supporters of housebuilding and the official planning process. We make it simple and easy to comment on planning applications to get the homes we need approved and built, because we believe that the voices of those who want to get on the housing ladder are as important as those who are already on it. Supporters of housebuilding do not care about planning arguments, height, or density, they care about community ties and having access to secure housing near their family and friends. By giving a voice to the silent majority in favour of building more homes, we are providing decision makers with an evidence base of housing attitudes in their area.

We have now worked on over one hundred projects nationwide, enabling over eight thousand local people to submit a letter of support for a development in their local planning authority. We have worked in almost twenty London boroughs including Camden, Kensington and Chelsea, Lewisham and Redbridge.

Working with Ballymore and Sainsburys, four hundred and fifty local residents used Just Build Homes to share their personal reasons why they support the plans to deliver a new neighbourhood and 2,500 new homes at Kensal Canalside, Royal Borough of Kensington and Chelsea. Each supporter lives locally, and their individual letters of support are uploaded on the development’s local Planning Authority portal. Supporters share their personal stories of the housing crisis, as shown by Ana, a forty-six-year-old private renter from Hammersmith and Fulham:

“As a parent navigating the challenges of the housing crisis in London, the opportunity presented by this development gives me hope. With the current housing market, finding a suitable and affordable home has been a relentless struggle”.

Stories like Ana’s reveal the human cost of the housing crisis, and provide an evidence base to

Millie Dodd is the Senior Communications and Marketing Manager for Just Build Homes

decision makers of real people, often ignored in the process, who stand the most to gain from developments going ahead. When the playing field is levelled, decision makers can make decisions on the merits of the scheme, not the politics.

Across London we have had multiple similar success stories, engaging over one hundred and fifty local people to support Galliard Homes’ redevelopment of Leegate Shopping Centre in Lewisham to provide over five hundred and fifty new homes which was recently approved.

Michael Gove recently stated that ‘restoring young people’s dreams of a roof over their heads will give democracy itself hope of survival’, and whilst access to secure, safe, and affordable housing should be a necessity, not a luxury - I agree that housing is the one of the most pressing political issues for my generation. The planning system needs serious reform to deliver the houses that we desperately need, but until then Just Build Homes is bridging the gap because everyone deserves a decent place to call home. n

1 https://www.standard.co.uk/homesandproperty/propertynews/average-home-cost-times-typical-income-londonb1097122.html

BELOW: Kensal Canalside – Over 450 people have used Just Build Homes to support Ballymore’s plans for 2,500 homes at Kensal Canalside

Viability – a happy new year?

Andrew Golland thinks that we need to get away from the rather rigid methods of viability assessment we now have

Initially, I was tempted to try to look at the implications of the updated and revised (December 2023) NPPF for viability assessment and housing development more generally. But having read much of the initial reaction it would appear that government achieved only a fudge – simultaneously strengthening the position of developers (a bit), as well as locals (a bit). It seems only that the fig leaf for potential objections to this fudge is to shout ‘Cambridge!’ and hope for the best. This is presumably on the basis that it this is an area with scope for development, and where local people are more friendly towards new housing development than most others elsewhere.

Suffice to say that after five years of the Tories trying to sort out Housing and Planning, there has been virtually no improvement, only frustration and lack of delivery.

Better to look at the moment at what the market can do. I examine here market change, and in particular, the relationship between development value and costs. Changes in these two key variables give an indication of the viability ‘gap’, which is broadly measured in terms of residual values which in turn have implications for housing development.

The viability gap (since Covid)

The data (table below) shows price changes by region (plus Scotland, Wales and Norther Ireland) as well as changes in construction costs. Sources are HM Land Registry (prices) and UK Tender Price and Building Cost Indices for costs: https://cost-

modelling.com/construction-indices.

For prices I have taken terraced housing, as this is probably the most consistent product from area to area. I have looked at the post Covid period – March 2021 to the latest period for which data is available (prices) – Sept 2023.

The table shows that prices have risen across the regions and countries fairly robustly. The highest increases have been in Northern Ireland, in the South West, in the East Midlands. Wales has also seen higher house price growth. Lower house price growth has been in Greater London, the North West and the East of England.

Costs nationally have risen by around 13% over the period. To calculate a viability gap – a net change – I have taken the costs at 60% of values.

All regions plus Northern Ireland, Scotland and Wales have seen an improvement in the viability gap. For Greater London the viability gap has remained virtually constant (increase at 1.1). This is an outlier, with most regions/countries seeing increases in the viability gap in the range 5% to 7%. The best net increases have been in Northern Ireland (11.5%), South West (8.5%) and East Midlands (8.4%).

These figures may be surprising given the general economic gloom around. They do reflect a theoretically improving situation. North Ireland sticks out in particularly, probably because it remains the only area which is effectively still part of the European Union. Correspondingly, Greater London, a region which grew hugely during our time within the EU, now appears to have been hit worst in terms of

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

development potential.

The Mayor of London is now campaigning for rejoining: https://www.ft.com/content/bcc52e35f5b1-4c26 -abbf-422f613d54e2.

The viability gap and house building

An improving viability gap should lead in principle to increasing house building as land is more likely to be supplied where the gap between prices and costs increase.

The data, even over a relatively short period shows support for this assumption. The tables below show a positive statistical relationship between the viability gap and increases in house building. As there is more land value, housing output increases.

At one end of the scale, Greater London has seen the lowest increase in the viability gap and correspondingly has the seen the lowest increase in house building. At the other end, the East Midlands has seen significant increases in both variables.

It is important to state that the data for the viability gap is nominal, not real. Importantly land own-

ers will consider real rather than nominal land value change.

It is further important to recognise that planning policy plays a role where market change does not necessarily translate to house building. This appears to be the case in a region such as the West Midlands.

Lessons for policy makers

The main experience for the English regions, Scotland, Wales and Northern Ireland is that the viability gap has increased since Covid and that where this has happened house building has benefitted most where that viability gap is greatest.

The answer for policy makers is to create a planning system which is responsive to market change.

Clearly housing requirements and five year land supply assessments are key. In this respect the idea of the current government that a local plan provides a substitute

for housing targets is problematic for the obvious reason that local plans are almost always out of the date, and lagging the market and household formation.

An important change here would be to elevate the place of market analysis in the assessment of land supply. Currently the methodology is overlyfocused on survey work, and in particular on including sites in the plan on the say-so of particular land owners and site promoters. Sites don’t come forward unless the market will deliver them, and in particular unless house prices are rising. The last time we saw house building really boom was between 2006 and 2008, when the market was

indeed booming.

The other implication of a changing viability gap is for Section 106 and CIL (Community Infrastructure Levy). In principle changes in the market can be reflected in policy and SPD. In practice, it is much more difficult. Annual market monitoring can help; alternatively, having a viability matrix where changes in a policy position reflect the trade-off between GDV and construction costs. But so far, nothing very responsive or flexible has emerged.

What is needed are a number of more innovative tools and methodologies for assessing how to deliver housing in the right quantities, of the correct type

and tenure and in the right places. In all cases, viability should be the driving factor.

We need to get away from the rather rigid methods of assessment we now have – ‘Needs’, ‘Requirement’, ‘5 Year Supply’, ‘Viability’, etc. In large measure we need to triangulate assessment, and in particular between Needs, Viability and Land Supply. Such an approach should have the capability to be dynamic and responsive to market change. It’s a task for large scale research, an activity which has been entirely missing over the last decade. We therefore await a change of government to potentially come up with more innovative solutions. n

The right to quiet enjoyment or a living nightmare?

Leaseholds rely on the fragile assumption that landlords, freeholders and managers will always behave ethically and without self-interest.

Nick Baker thinks it takes a new charity to sort out the consequences

Thirty years ago M bought the leasehold to a second floor two-bed flat in a Georgian terrace, as her long-term home and an investment. It was in poor condition, but much of the major work was to be carried out by the freeholder under the terms of the lease.

The property had been converted into small lets with poor design and workmanship. For example, the kitchen was a single-story extension with an uninsulated flat roof. This leaked, and the problem was exacerbated by it supporting a water tank serving another flat. Access to the flat above had been badly planned with a shared lobby. Inadequate sound insulation resulted in constant disturbance. Major works to the flat above resulted in further disturbance during execution and subsequent structural damage (identified by a qualified surveyor) to M’s flat. There was also a major leak from the flat above.

In spite of repeated requests from M, these matters were either executed badly after much delay, or not at all. Up to this point M was on good terms with the other residents and in an effort to improve the management of the flats, M and the other residents formed a management company. The freeholder, a resident, was one of these. But far from solving problems, this created new ones as relations between M and other residents began to break down. It seemed that pacts were made between the other directors of the management company and M found herself being marginalized and discredited, and her claims for repairs and services ignored.

At some stage in the deteriorating situation, M decided to stop paying the service charge, reasoning that it was her only sanction left. Now M had lost everything, the right to appropriate repairs in her flat, and the right not to have damage to her home. M lost her share of the freehold from a change in the company; it had been set up as a “right to manage company”, but had now become a business.

This relentless pressure began to take a toll on M and she became anxious and depressed. Around this time her mother died, after being cared for by M and her sister, and M blamed herself for being distracted from her mother’s illness by her own plight. M had also become physically ill while trying to sort out the

multiple problems encountered. In desperation, she has now left the flat and is residing elsewhere. This is an indication of just how bad things had become for her.

The charity would have three broad objectives:

1 To be a first port of call for people experiencing stress due to leasehold housing issues – a listening ear, a first aid post and point of triage.

2 To establish the facts of the case and provide technical/legal help and advice, either directly or by reference to other specialist agencies.

3 To develop a database of case histories which would be available for academic analysis, with a view to campaigning for improvements in leaseholders’ rights.

She approached me to discuss the physical problems of the flat, but I quickly realised that these were just the manifestation of a deeper problem, rooted in the legal structures of the leasehold. These relied on the fragile assumption that landlords, freeholders and managers would always behave ethically and without self-interest. To me, a layman in property law, the thought of “owning” a space, defined and supported by bricks and mortar owned by others, on land owned by others, and with service connections and access owned and controlled by others, sounds like a recipe for disaster. M’s experience seemed to bear that out, and it underlined the need for robust and enforceable legal structures that, rather than being aimed at the financial protection of the landlord, were primarily concerned with the wellbeing of the occupant.

Dr Nick Baker is an environmental scientist, Architectural Association and Cambridge University

As often happens, when people suffer trauma or tragedy, they seek some kind of comfort by supporting others in preventing the same occurrence. This is what M wants to do and, rather than dealing with problems of dampness, air quality and noise, I found myself helping her with a proposal for a charity.

The charity would have three broad objectives:

1 To be a first port of call for people experiencing stress due to leasehold housing issues – a listening ear, a first aid post and point of triage.

2 To establish the facts of the case and provide technical/legal help and advice, either directly or by reference to other specialist agencies.

3 To develop a database of case histories which would be available for academic analysis, with a view to campaigning for improvements in leaseholders’ rights.

It is estimated1 that there are almost 5 million leasehold residences in the UK, 20 per cent of the total UK housing stock. Of the 5 million, 2.9 million are owner-occupied and the majority of these are flats in multi-occupancy buildings. The terms of the lease will normally include a service charge payable to the freeholder of the site, to cover shared expenses associated with the whole building. Whilst this works for many there is clearly room for much to go wrong. In a recent survey by the Home Owners Alliance2 more than half of the leaseholders polled reported dissatisfaction with service and maintenance charges.

Clearly, then, M’s experience is not unique, and until there is a change of the law, the charity should have many takers. If you have any relevant experiences, or interest in supporting this project, please email us at chrishomegate@gmail.com. n

1 Gov.uk Leasehold Dwellings 2020-2022

2 Home Owners Alliance 2019

An accelerated planning system?

How clear do you think you are on the various pulleys and levers that make up the English development management system? A further series of proposed alterations was announced on budget day. Simon Ricketts provides a commentary

I will restrict this article to DLUHC’s “an accelerated planning system” consultation paper (6 March 2024), which seeks views by 1 May 2024 on “proposals to:

1. introduce a new Accelerated Planning Service for major commercial applications with a decision time in 10 weeks and fee refunds if this is not met

2. change the use of extensions of time, including ending their use for householder applications and only allowing one extension of time for other developments, which links to a proposed new performance measure for local planning authority speed of decision-making against statutory time limits

3. expand the current simplified written representations appeals process for householder and minor commercial appeals to more appeals

4. implement section 73B for applications to vary planning permissions and the treatment of overlapping permissions”

I will leave the 4th strand of that, section 73B, for another day as in order to do that justice I would need to go into some heavy legal engineering detail, but today I will summarise the main components of the rest of the proposals and then wrap up with a few guesses at the more obvious risks to be avoided, if acceleration is indeed to be achieved without unintended adverse consequences.

The Accelerated Planning Service “9. All local planning authorities will be required to offer an Accelerated Planning Service for major commercial applications [i.e. applications for major commercial development which create 1,000 sqm or more of new or additional employment floorspace, including mixed use developments if they meet the employment floorspace criteria]. The applicant would pay a higher planning fee to the local planning authority which, in exchange, will be required to determine these applications within 10 weeks (rather than the 13-week statutory time limit), with a guarantee that the fee would be refunded if the application is not determined within this timescale.

10. We are exploring two options for the detailed design of this service. Under the first discretionary

option, applicants could choose to use the Accelerated Planning Service where their application meets the qualifying criteria or they could use the standard application route for a major development (with a lower fee and longer timescales). A second mandatory option could be that the Accelerated Planning Service is the only available application route for all applications in a given development category. This would have the benefit of clarity and certainty for applicants and local planning authorities but remove the element of choice for the applicant.”

The service would not apply to applications which are for EIA development, although DLUHC is “interested to receive views on whether there is scope for EIA development to also be covered by an

I suspect that the proposals will be cautiously supported, but we all know it is all going to be about the actual implementation

Accelerated Planning Service that offers a guaranteed decision before the 16-week statutory time limit.”

“The service would apply to section 73 and 73B applications which seek to vary existing planning permissions for relevant commercial development.”

“Over time, we are keen to explore the extension of the Accelerated Planning Service to similar major infrastructure and residential developments. But we want to ensure the Service works for commercial development before any extension is made, given that there are significantly more residential applications and often a larger number of matters to be considered with these types of applications.”

“The key aim is to ensure that these applications are prioritised through the local planning authority’s own internal processes faster. This would require local planning authorities to: set up efficient case work systems; ensure validation teams, lawyers and internal expertise are on hand; and, where relevant, convene planning committees on time. The availability of a higher planning fee (discussed below) is intended to ensure that local planning authorities have the resources to do this.”

The ten weeks’ deadline would be “used as the trigger point for when appeals can be made against

Simon Ricketts is a partner with Town Legal LLP

From Simon’s blog at simonicity.com/author/simonicity/ Personal views, et cetera

non-determination and for monitoring the performance of local planning authorities”.

DLUHC recognises that it is “crucial that the applications submitted are of good quality with the right information” and to that end proposes that:

• “local planning authorities should offer a clear pre-application service to potential applicants so they can discuss their proposals, key issues, information requirements and any other issues (such as EIA screening), and we will strongly encourage applicants to use these services… We will ensure best practice is disseminated across the sector building on the work the Planning Advisory Service has been undertaking on pre-application services”

• “prior to submitting their application, applicants should notify key statutory consultees which are likely to be engaged that they are making an application under the Accelerated Planning Service… The government will look to use its oversight of statutory consultees to prioritise applications under the Accelerated Planning Service and to monitor their performance. In the meantime, we welcome views about how statutory consultees can best support this accelerated service. In most cases, early pre-application engagement will be important”

“To cover the additional resourcing costs, we propose to set a premium fee for an application through the Accelerated Planning Service… It is proposed that an applicant or the local planning authority would still have the ability to propose an extension of time to the determination of the application (for instance, if there is an outstanding matter which could be readily resolved to make an application acceptable). But such an extension of time should be an exception. An extension of time would not affect any potential refunds… We propose that either all or a proportion of the statutory application fee must be refunded by the local planning authority to the appli-

cant if the application is not determined within the 10-week timescale, even if an extension of time has been agreed. This refund policy differs from the existing Planning Guarantee where a refund is not provided if an extension of time has been agreed.

We have considered whether it is appropriate for the whole fee to be refunded if the application is not determined within the required 10-week period and recognise that if the whole fee is refunded at 10 weeks, in cases where no decision has been made, and the performance target is therefore missed, there is no further incentive for the local planning authority to make a decision on the application. To mitigate this, we consider that there is an alternative option, to stagger the fee refund. For example, if no decision has been made within 10 weeks, the premium part of the fee or 50% of the whole fee could be refunded at that point with the remainder of the fee refunded at 13 weeks, if the application was still undecided.”

As part of the consultation, views are sought as to whether the accelerated planning service should be optional or mandatory.

Planning performance and extension of time agreements

“the government has published a new Planning Performance Dashboard. This dashboard displays performance figures over a 12-month period and includes performance within statutory time limits, excluding extension of time agreements, so a true picture of local planning authority performance figures is accessible. We expect local planning authorities to report on their data from the Planning Performance Dashboard to their planning committees and other stakeholders, in order to drive continual improvements in performance, identify areas of weakness at an early stage, and help inform priorities for service delivery.”

“It is proposed that the new performance thresholds would be:• major applications – 50% or more of applications determined within the statutory time limit; and

• non-major applications – 60% or more of applications determined within the statutory time limit

The proposed thresholds do not preclude the use of extension of time agreements and planning performance agreements, but the expectation is that

such agreements are used only in exceptional circumstances. The proposed threshold is also lower for major applications in recognition that, in more instances, extension of time agreements may still be required due to the more complex nature of the applications and major applications are also more likely to be subject to a planning performance agreement.”

“Following a transition period, it is proposed that we measure performance against both the current measure, which includes extension of time agreements and planning performance agreements, and the new measure, which would cover decisions within statutory time limits only. We would continue to measure major and non-major applications separately.

Local planning authorities would be at risk of designation for speed [of] decision-making in the following circumstances:

1. if a local planning authority does not meet the threshold for the current measure, inclusive of extension of time agreements and planning performance agreements (as per current regime), or 2. if a local planning authority meets the threshold for the current measure, inclusive of extension of time agreements and planning performance agreements, but does not meet the new threshold for the proportion of decisions within the statutory time limit, or

3. if a local planning [authority] does not meet the threshold for both the current and the new measure

Where a local planning authority is designated, applicants may apply to the Planning Inspectorate (on behalf of the Secretary of State), rather than the local planning authority, for the category of applications (major, non-major or both) for which the authority has been designated.”

It’s worth clicking into that Planning Performance Dashboard which will provide some welcome transparency as to individual authority performance.

Performance for speed of decision-making is currently assessed across a 24 month period. DLUHC is seeking views as to whether the assessment period should be reduced to 12 months.

Incidentally, whilst there is a reference in the general introductory passages of the consultation paper

to only allowing one extension of time, I couldn’t find it in the actual section on the proposals (paragraphs 40 to 46) – can you?

The proposed assessment periods and measures of performance for speed of decision-making are as follows:

DLUHC proposes to remove the ability to use extension of time agreements for householder applications and is considering prohibiting their use where a repeat application is submitted.

Simplified process for planning written representation appeals

There is already an accelerated appeals procedure for householder and small commercial appeals, with for instance no opportunity for additional information to be provided at the appeal stage by the main parties or other interested parties. DLUHC proposes to expand this to a far greater range of written representations appeals, namely:

• appeals relating to refusing planning permission or reserved matters

• appeals relating to refusing listed building consent

• appeals relating to refusing works to protected trees

• appeals relating to refusing lawful development certificates

• appeals relating to refusing the variation or removal of a condition

• appeals relating to refusing the approval of details reserved by a condition

• appeals relating to the imposition of conditions on approvals

• appeals relating to refusing modifications or discharge of planning legal agreements

• appeals relating to refusal of consent under the Hedgerow Regulations

• appeals relating to anti-social high hedges

Time limits for appealing would remain unchanged but “appeals determined through the simplified route would be based on the appellant’s brief appeal statement plus the original planning application documentation and any comments made at the application stage (including those of interested parties). There would be no opportunity for the appellant to submit additional evidence, to amend

the proposal, for additional comments to be made from interested parties or for the main appeal parties to comment on each other’s representations.” Non-determination appeals would still follow the existing procedure.

What do we think about all this?

From a development industry perspective I suspect that the proposals will be cautiously supported, but we all know it is all going to be about the actual implementation, about the proactive management and resources available to authorities and about closing off the obvious loopholes:

• If there are hard-edged consequences for authorities of not determining applications within ten weeks, won’t some authorities be tempted to persuade applicants to delay submission until they can be sure that the application is ovenready, or to delay validation (NB we really do need controls on local validation lists which have become lengthy shopping lists)?

• Won’t we see more refusals where the authority is approaching the relevant determination deadline without being in a position to agree an extension of time and should the appeal costs regime be updated to ensure that authorities do not take this step unreasonably?

• What about where any delay is not down to the authority (or the authority alone), as is often the case? The exhortation to approach statutory consultees at pre-application stage may not be enough to ensure a timely response.

• Wouldn’t it be helpful for any guidance to encourage that a greater proportion of decisions are taken by way of delegated powers, particularly where applications are consistent with the relevant local plan?

• How do we ensure that section 106 agreements are completed in a timely manner, given the lack still of any recommended template and, in particular, the delays caused by the push and pull of negotiations in two tier areas, whether county and district, or London Mayor and borough?

• Does the idea of excluding third parties from written representations appeals accord with the principles of natural justice if issues arise or arguments made by the main parties which could not have been foreseen at the application stage?

• Will there be time to introduce the necessary legislation before the election, whenever that may be, and how many of these proposals may in fact ultimately have cross-party support?

In the meantime, two further authorities have been designated for their poor speed in determining applications for non-major development: St Albans and Bristol, meaning that applications for minor development other than householder development and retrospective applications may be made direct to the Planning Inspectorate. n

Reform needed to boost housebuilding

The UK has a housebuilding crisis and we cannot boost housebuilding rates significantly without reforming the planning system. The Competition and Markets Authority (CMA) is the latest organisation to reach this verdict. Its comprehensive report on the causes of low housebuilding rates and corresponding high prices highlights that the speculative development model of house builders is a problem. But what stands out most in its research is that uncertainty brought about by the planning system is slowing housebuilding down.

So, what is it that makes the current system so "complex and unpredictable", and what should we replace it with?

The Centre for Cities estimates that the UK is missing 4.3 million homes that were never built because of problems with the current planning system, dating back to the Town and Country Planning Act 1947. Since the act's introduction, house building rates have never recovered to the rates they reached in the 1920s and 1930s.

Over the last 70 years, the planning system has enlarged the size of green belts and empowered local opponents to new developments, which has made trying to build new housing in Britain increasingly difficult and risky. It is a very discretionary, case-by-case system in which even if you meet all the requirements, local objections can still topple a planning application at the final hurdle.

This creates great uncertainty and means new entrants to the market face unnecessarily high barriers, which stifles competition and innovation within the housebuilding industry and ultimately hurts consumers. The overall result is fewer homes being built, and mismatches between supply and demand in the places that most need new homes.

Average house prices have risen everywhere in the UK, adding to pressure on people's incomes and making it harder for people to move to places with good jobs. New housing in the Greater South East would make the biggest difference as that is where housing affordability ratios are highest.

Reforms to the planning system in New Zealand and places in the US show reforms can increase housebuilding rates and make it more affordable. So, how radical does reform of the British planning system need to be?

The CMA recommends, rightly, removing the power of local councillors to block planning applications that comply with the local plan. This would represent a move towards a rules based system

There is increasing cross party consensus that serious proposals to boost housebuilding will require planning reform to achieve them

where planning applications that comply with the rules are guaranteed assent.

Rigid bans on building housing in certain parts of the country contribute to the inefficiency and high cost of housebuilding, too. The green belt is the best example. The Centre for Cities estimates that by building on less than two per cent of the green belt around existing railway stations we can add between 1.7 million and 2.1 million homes for suburban living located at most 45 minutes away from the five biggest cities in England. This would have significant economic benefits as well as the obvious housing-specific benefits.

As the CMA says, we will never solve the problem of unaffordable housing without reforming the planning system. We know what needs to be done to switch to a more predictable system that allows planned developments that comply with the rules to get built. The obstacles to implementing this system are political.

Hopefully, that is beginning to change. There is increasing cross party consensus that serious proposals to boost housebuilding will require planning reform to achieve them.

We cannot take the politics out of planning altogether; but with a growing awareness that low housebuilding rates are affecting housing affordability, economic growth and net zero, as well as political voting decisions, planning reform could rise to the top of the political agenda very soon. n

First published in Property Week with kind consent

Andrew Carter is chief executive of Centre for Cities

Addressing water stress

A good case can be made for a truly strategic planning approach to water scarcity at national, or at least regional level, says Matt Clarke

The threat of water scarcity is becoming increasingly common as climate change results in an increasing number of regions experiencing long dry periods. And although we have seen plenty of rainwater recently, the fact is that the storms and extreme weather events which increasingly deliver the majority of the rain are often so intense that the water cannot be captured and stored effectively.

In the Eastern region where I am based, the issue has impacted negatively on planning and development for some time and has become an increasing concern as the Government progresses its ambitious plans to triple the size of Cambridge under the Cambridge 2040 banner. And so as the Eastern region, with some Government support, grapples with the issue, we can give some insight into how it is being addressed and what remains to be done.

And London is not far behind the East, as many in the planning and development sector will know. London’s growing population and ageing pipes, combined with a changing and increasingly extreme climate, means that water resources are under growing pressure. In 2018 the Beast from the East resulted in flooding and water outages due to pipes freezing, thawing and bursting. Similarly, recent dry summers and unexpected heatwaves, have meant that London cannot continue to rely on rainwater to replenish water stocks.

In July last year, the CEO of the Environment Agency (EA) warned that within 25 years London and the South East could run out of water. And the cost of a severe drought to London's economy is estimated to be £330m per day.

So what can be done to address the issue? The Government has addressed the issue in Cambridge through its recently published document, The Case for Cambridge. It renews its commitment to new reservoir and a new pipeline to transfer water from an existing reservoir. It also promises to deliver a unique offsetting intervention and has established a Water Scarcity Group.

One of the immediate challenges, however, is the need to adopt a Water Resources Management Plan (WRMP). In February this year, Cambridge Water issued its third draft WRMP, the earlier iterations having been objected to by the EA. The 25 year strategy, as required, demonstrates how Cambridge Water will

ensure the continued supply of safe clean water while protecting and improving the environment.

But while the proposed solutions (addressing leakage, reducing household consumption, introducing universal metering and the proposals outlined above in relation to new reservoirs and infrastructure) are laudable, it remains to be seen whether the EA will support the latest WRMP (this decision rests with DEFRA and OFWAT), and in turn the extent to which the EA will support projected levels of future development before the planned supply options are fully in place. A phased approach, balancing longer-term growth with delivery of the proposed supply infrastructure could realistically be anticipated.

Another problem is that the solutions are long term: a 50 per cent reduction in leakage is due to be in place by 2040; the reduction in household consumption targeted for 2050; the reduction in nonhousehold consumption due to occur by 2038 and universal metering should be in place by 2030. The transfer from an existing reservoir is due to complete in 2032, the new Fens Reservoir is due to open in 2036, and an effluent re-use plan is due to be in place by 2041.

A more immediate solution is needed and a water credits system due to be put in place, for the first time, in Cambridgeshire, this year, is a step it the right direction. The water credits system is set to help unlock the 9,000 homes and 300,000 square metres of commercial space that are currently held up in the planning system due to water scarcity concerns.

The scheme will give developers the opportunity to offset the water demands of development through the purchase and sale of water credits to ensure they have a neutral impact on water demand. It will be overseen by a market operator and the credits will initially be provided through the retrofitting of properties (both commercial and residential) with Government investment.

Alongside this the Government is also undertaking a pilot to understand the scope for nature-based solutions to enhance the long-term flow of water bodies and improve resilience to floods, as well as seeking innovation in agricultural water resource management.

There are no details available about how the credits system would work within the planning process,

Matt

Clarke is a Director in Boyer’s Colchester office

but the announcement states that the Government will work with the local planning authority, developers, the EA, and other key stakeholders on its implementation.

One of the EA’s key concerns is the way in which local authorities engage with water companies to plan development in line with available water resources. Coordinating water supply and new housing development is compromised by the different timescales for local plans and WRMPs and the very long-term delivery of water infrastructure such as new reservoirs. This can lead to the undesirable position of a considerable slow-down in the granting of planning permissions, and in turn a slow-down in the delivery of sites whose allocation had been confirmed through Local Plans adopted in line with the current WRMP.

Connected to this problem is the fact that funding for infrastructure projects is controlled by OFWAT and is reviewed only on a five-year basis, which makes it difficult for the water authorities and local authorities (whose boundaries invariably do not align) to change their infrastructure planning to address significant changes in local circumstances.

The scale of infrastructure involved and the typically cross-boundary nature of the required longerterm solutions mean that a good case could be made for a truly strategic planning approach at national, or at least regional level. Clearly the water scarcity situation must be resolved quickly both to unlock muchneeded housing on sites already allocated in local plans and to allow future growth to be appropriately planned.

For Cambridge, guidance issued by the Government in March suggests recognition of the need to address the issue, but clearly it is not just Greater Cambridge which is impacted. The East of England may be one of the first regions to be so badly affected but others will follow and it will be important that the lessons learnt and solutions found are considered on a national scale. n

Does AI in architecture herald a new era?

Dean Hodcroft hopes AI can free the human brain from excessive menial tasks to be more imaginative and expressive

AI has the potential to reshape the architectural landscape the world over. This presents a dualedged sword—offering unprecedented design capabilities while challenging the very essence of architectural practice.

The La Sagrada Familia is perhaps one of the most famous landmarks globally, famous both for the striking pose it cuts through the Barcelona skyline and the fact that it is still unfinished after more than 140 years. Its architect, likewise, is one of the most famous the world over.

What would happen if we could all be an Antoni Gaudí at the press of a button? Can the power of Artificial Intelligence (AI) enable anyone to construct an architectural marvel like La Sagrada Familia? Essentially, does technological advancement bring us closer to emulating the genius of Antoni Gaudí? Perhaps.

For now, we know the integration of AI in architecture and the built environment has started what will be seen in the future as a transformative era in design and practice, offering a suite of innovative tools and raising profound questions about the future of the profession.

The integration of AI in architecture marks the beginning of a transformative period in design and practice. This shift is not just theoretical; buildings are already being designed and built with the help of AI. Venture capital firm A/O Proptech highlights the significance of this trend, noting that AI startups focusing on the built environment have garnered $12.3 billion in funding over the past three years.

Xkool was one of the first AI tools for architects, where structures like the La Sagrada Familia are potentially just a few clicks away, but other technologies like Midjourney, Stable Diffusion facilitate text-to-image generation capabilities that are routinely mistaken for photographs. Other niche AI tools exist, like 3DGuru, Hypar and Delve, tools which can do everything from speeding up early concept design to interiors and predicting how much sunlight each property in a development would receive.

Xkool stands at the forefront of AI in architecture, experiencing rapid growth with over 50,000 users in China and the recent introduction of its image-to-image AI tool, LookX, the first AI tool trained on data for and created specifically for architects.

The company was established in 2016 by Wanyu He and some former colleagues, driven by a vision to innovate beyond traditional architectural practices. Xkool's platform harnesses AI to offer comprehensive solutions, from creating masterplan layouts that adhere to specific requirements like daylight exposure, spatial standards and local regulations, to detailing interiors and construction. Additionally, Xkool has developed technology capable of converting 2D building images into 3D models and transforming lists of room dimensions into practical floor plans.

There is conversation around how AI’s most prolific impact on architecture will be to eradicate the profession - but that seems to be a very long way

off from happening. Nicolás Valencia from ArchDaily suggests AI's role in architecture is not to supplant human creativity but to empower professionals with efficiencies. For example, had Gaudí had access to an AI when he was designing the La Sagrada Familia, would it be the same structure today - and be finished already? Between his genius and AI as a technological marvel, it’s hard to think that it couldn’t be done.

A significant issue with AI in architecture is its inherent cultural biases, but also well documented technological biases. Andrew Kudless, an Associate Professor of Architecture at the California College of the Arts in San Francisco, points out AI's reliance on existing data pools can lead to overrepresentation of certain styles and underrepresentation of others. This bias is not necessarily intentional but reflects the predominance of certain data in the AI's training. Put in other words, if architects all use the same AI platforms, what happens to true originality – and our built environments?

One of the most promising aspects of AI in architecture is its potential to enhance sustainability. AI can optimise energy efficiency, thermal comfort and material selection, significantly reducing environmental impacts.

However, this transformative potential is accompanied by its own set of challenges. As AI integrates into architecture, the industry faces the challenge of balancing traditional values with new demands in data literacy and interdisciplinarity.

My ultimate hope is that architecture is no exception to the overriding premise of AI, whereby the human brain is freed up from excessive menial tasks to be more imaginative and expressive. That could be pretty exciting for the future of architecture in particular. Who knows what 22nd century designs will look like? n

Dean Hodcroft is Chief Executive of Crestbridge Limited

La Sagrada Familia

London of the Future is a once-in-a-century publication from

Contributors include:

Tony Travers and Yasmin Jones-Henry.

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

www.londonsociety.org.uk

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Dirty protest

The ghostly imprints of passengers leaning on Elizabeth Line Station walls are intriguing, intimate - and disturbing, says Will Wiles (SEE right).

Back when the paint was still drying on the Jubilee Line Extension of the London Underground, the scheme was widely celebrated for its quality of design and finish - a break from the network's long-running, meaner way of doing things. That was summed by an unnamed old hand: 'It doesn't matter how much it costs, as long as it looks cheap.' Cheap was never a word that could be applied to the Elizabeth Line. Far beyond any par ticular design detail, the first impression of its new, eye-wateringly expensive subterranean stations in central London was their generosity. Such long platforms, such wide concourses, so much air, so much headroom. It was a welcome change from the troglodyte experience elsewhere on the network. Almost utopian, in fact.

Spectral residues haunt the platforms of the Elizabeth Line

TFL's trial fix with sticky-back plastic is, I suspect, whistling into the wind says Will Wiles. The ghosts were just the advance guard. A more pervasive haunting is slowly revealing itself: a continuous faint band all along the platform wall, from about waist to shoulder height. This tide mark may be less noticeably human, and so of course easier to ignore. But plastic covering might end up looking just as tatty in time - a dado rail might be the only lasting solution, or we could just live with It.– RIBAJ

at its lowest level in a decade.

As with most utopias, it had an antiseptic quality that was a little at odds with the human element. But now that quality is under siege by something rather unexpected: ghosts. Shadowy forms have manifested on the walls behind benches all along the line. The lightweight curved panels of glass-fibre reinforced concrete that clad the interior spaces of Elizabeth Line stations might be miracles of modern materials engineering, but they have proved unfortunately susceptible to a particular kind of dirt. Passengers sit on the benches and lean against the wall, they leave a little grime and human grease from their clothes and hair which has grown to deposit a spectral head and shoulders above every seat.

Stuff gets dirty with time, of course, there's no avoiding it. But these ghosts have proved quite a talking point, prompting revulsion, amusement and official embarrassment. TFL is scrambling to find a solution. Plastic backing may be applied behind the benches to protect the panels.

– Will Wiles writing in the RIBA Journal

Homes granted permission fall 20 per cent over the year

Planning reports that the number of homes granted planning permission across England in 2023 has dropped 20 per cent compared to last year and is

Around 233,000 homes in England were granted planning permission in 2023, according to the latest data published by DLUHC. (SEE our full planning performance report).

The figures show that the number of homes given consent has dropped 20 per cent on last year and the number of homes granted permission was at its lowest since 2014, according to the data.

Housing projects that included ten or more units accounted for 90 per cent, or 210,400, of the housing units that were granted permission.

The figures show that London accounted for 43,400, or 19 per cent of the homes allowed in the year ending December 2023. Authorities in the South East granted permission for 38,700 homes (17 per cent), while councils in the North West granted permission for 27,000 (12 per cent).

The report notes that “many permissions do not result in a home being delivered in practice”, owing to various reasons, including circumstances of landowners, developers and the current state of the economy.

DLUHC also reports that 2,000 decisions were made on applications for commercial developments from October to December 2023, down one per cent from the same quarter a year earlier.

In the year ending December 2023, 7,800 decisions were made on applications for commercial developments, down five per cent from the previous year. Of these 88 per cent were granted.

Second staircase requirement to take effect in September 2026

The government has published revised fire safety guidance which brings in a new requirement for buildings over 18 metres tall to include a second staircase. This will come into force on 30 September 2026.

Last year, the government announced its intention to mandate second staircases in residential developments over 18 metres tall, one of the safety measures responding to the Grenfell Tower fire. It is significantly tougher than the 30 metre threshold previously proposed.

The new requirement will form part of a revision to “Approved Document B” though industry people have warned that the change is causing delays to new homes and will result in more work for council planners as permitted developments will have to be changed to meet the regulations. The government has now published this revised guidance.

In October, the government set out its “intended transitional arrangements” which made clear that developers will have 30 months to conform to the new requirement, but any that do not meet the new rules must “get underway in earnest” within 18 months.

The Department says that existing guidance will “continue to apply where a building notice or

E WUNDERLICH PHOTO: LINDA BYRNE

CLIPBOARD

an initial notice has been given to, or a building control approval application with full plans made to, the relevant authority before 30 September 2026 and either the building work to which it relates:

a. has started and is sufficiently progressed before that day; or

b. is started and is sufficiently progressed within the period of 18 months beginning on that day”.

“After that time and from 1 October 2026 all new applications will need to conform to the new guidance”.

Validating applications adds to delays

Many planning authorities have failed to keep their validation requirements lists under review and therefore up-to-date as required at least every two years.

The RTPI independent consultants network has circulated the following model response from one of its members, which he finds he has to use quite often:

'Regarding the requests to provide the above to validate the application, the Council’s Validation List is considered out of date as it is dated from 2016 (Version 1.1 Created TS 26/09/2016). / would draw your attention to the Town and Country Planning (Development Management Procedure) (England) Order 2015, Article 11 2(e) and 3(d).

Therefore, under the national requirements, whilst you have requested further information (that can be submitted), the requested information is not required to be submitted as part of validation procedure for this application. Notwithstanding your requirements, the application should have been validated on xxx date’.

Another ICN member complained that for a simple Permission in Principle application the council had demanded the following just to validate it:

• Application form

• Location plan

• Block plan

• Ecological survey

• Unilaterial undertaking for GIRAMS

• Heritage Statement

• Arboricultural Report

• Contaminated Land questionnaire

• Healthy Planning Checklist (if more than 5 dwellings or more than 1000sqm floorspace).

Government

clampdown

will lead to more refusals and appeals

Housing secretary Michael Gove does not appear to be a fan of councils’ use of extension of time agreements. These agreements between local authorities and applicants are widely used and give the council more time to consider a planning application, beyond the statutory limit, before an appeal for non-determination can be lodged, writes Ben Kochan in Planning.

New government measures to limit councils' use of extension of time agreements are unlikely to meet the objective of speeding up planning decisions and will probably lead to more refusals and appeals, practitioners warn, he reports.

Last December Gove said: “Some authorities use so-called extension of time agreements – that is to say, an insistence on delays – to slow down the system.” Strip these agreements out of the system, he claimed, and in the two years to September, only nine per cent of local authorities determined 70 per cent or more of non-major applications within the statutory eight-week period. The government has revealed how it intends to restrict councils’ use of extensions of time agreements in the consultation paper An accelerated planning system. This acknowledges that agreements can offer benefits to a local planning authority and applicant. But it says the government “knows that extension of time agreements can also be used by authorities to compensate for delays in decision-making, which masks poor performance and does not incentivise local authorities to determine applications within the statutory time limit”.

Council performance in processing planning applications, according to the government proposals, is to be measured against the current metric, which takes account of extension of time agreements, and also a new one that would disregard those agreements and cover decisions taken within the statutory time limits only.

From October 2024, councils will be required

to achieve 60 per cent of decisions on major planning applications within the statutory time limit or with an agreed extended period or 50 per cent within the statutory time limit disregarding any extensions. And the target for non-major applications is 70 per cent including extensions and 60 per cent disregarding them. The consultation also proposes removing the ability to use agreements for householder applications.

The proposed penalty for councils failing to meet either or both of the metric targets will be designation in so-called ‘special measures’, meaning that developers will be able to make planning applications to the Planning Inspectorate for determination, rather than the local authority which will mean the loss of control and planning fees.

Between 2021 and 2023 only one per cent of local planning authorities “determined 60 per cent or more of major applications within the statutory 13- or 16-week statutory time limits.”

Restricting the use of extension of time agreements is unlikely to speed up consideration of planning applications and can be expected to lead to more planning appeals, comment planning consultants. “The widespread use of agreements reflects the complexity of many schemes and the many issues which need to be considered,” say some, but for years now the ACA (Association of Consultant Architects) and this magazine have been urging government to reduce the workload of planners by moving measurable and technical issues into the Building Regulations and enforcing the principle that planning should not duplicate other legislation or regulation.

This argument was made more than once to the government chief planning officer at the recent ‘Planning Update’ conference reported on other pages. It would reduce the need for more resources for planning departments.

“There could be a lot more appeals if councils are forced to make a decision before they are ready,” said Nicola Gooch, partner at law firm Irwin Mitchell (who writes elsewhere in this issue). “Developers generally agree to extension of time agreements, because without them, councils may be minded to refuse their applications. And the planning appeal process could then kick in, which takes a long time before a decision is reached.”

CLIPBOARD

Ben Kochan quotes Tim Burden, director at consultancy Turley: “Some councils at the moment don’t offer pre-application advice (but) to avoid having to use extension of time agreements, they may decide to introduce that service.” These generally cost more than the application in fees and add months to the process with mixed outcomes.

notices, which effectively is a declaration of bankruptcy, since the Local Government Finance Act took effect in 1988. In London, Croydon Council has issued three Section 114 notices in the space of two years, between 2020 and 2022. Hackney and Hillingdon had also issued Section 114 notices prior to the current crisis.

“Extension of time agreements are needed because statutory consultees are so slow in responding to planning applications,” claims Sam Stafford, planning director at the Home Builders’ Federation. “The statutory consultees need to be integrated properly into the planning process. If councils don’t have the responses from the statutory consultees then they could be forced to refuse applications to make a decision within the statutory timescales.” The government seems to be onto this problem.

“The proposals to limit extension of time agreements will put more focus on the pre-application process, but not in an open and measurable way,” says Mary Cook, partner at law firm Town Legal. “There will be more pre-application planning performance agreements and possibly the submission of draft applications.”

“Extension of time agreements can mask weaknesses in the performance of planning departments,” says Brett Leahy, director of planning at Enfield, who stopped the use of the agreements when he moved to the council in 2022.

London’s councils

£400m shortfall

London Councils, which represents the capital’s 32 boroughs and the City of London Corporation, has renewed its calls for extra government support after warning that more authorities are likely to face effective bankruptcy. They claim Local authorities in the capital are facing a funding shortfall of at least £400m in the next financial year amid a “bleak” outlook, reports Sharelines. MPs have been debating and voting on the local government finance settlement.

Claire Holland, deputy chair of London Councils, said: “The increase in funding set out in the government’s finance settlement will not be enough to address the enormous funding gap we are grappling with. Massive pressures on local services, skyrocketing costs and years of inadequate funding have left town hall finances teetering on a cliff edge.”

Fourteen councils have issued Section 114

London Councils said that despite a 5.5% realterms increase in core spending power in the settlement, town halls will face an “enormous” funding gap due to service pressures and costs.

The £400m funding shortfall is roughly the same amount as London boroughs collectively spend on homelessness in a year. The group said that 31 out of the capital’s 33 local authorities are forecast to overspend their budgets this current financial year (202324), totalling more than £600m. It also warned that government’s plans to increase council funding rely “too heavily” on council tax.

The group also flagged that rising demand for services and inflationary costs will pose “major budgetary challenges”. Housing and homelessness services are among the “key drivers” of councils’ finance concerns, the group said.

According to London Councils’ calculations, the 2024-25 finance settlement will leave boroughs’ overall resources 15% lower in real terms than in 2010. The group said it was also calling for the Household Support Fund to continue as it is currently due to end in March.

Councils also need “greater investment in affordable housing and homelessness prevention”, the group said. One in 50 Londoners are homeless and living in temporary accommodation, according to London Councils’ estimates.

Retrofit Toolkit summary

The City of London is home to more than 600 listed buildings (covering an area of about 500,000 sq m), 27 conservation areas, 48 scheduled ancient monuments and four historic parks and gardens. For centuries we have adapted these buildings to respond to changing environmental and social contexts, securing their cultural and economic benefits for future generations.

With the climate crisis representing the single greatest challenge facing our generation, bold and ambitious action is needed to unlock the potential in our built heritage and reduce greenhouse gas emis-

Retrofit Toolkit aims for a netzero Square Mile

The City Corporation has launched a Heritage Buildings Retrofit Toolkit.The toolkit seeks to empower owners of heritage buildings to initiate the adaptations necessary to reduce carbon emissions and build climate resilience, a key priority of the City Corporation’s Climate Action Strategy, as it progresses toward a net-zero Square Mile by 2040.

With more than 600 listed buildings, 28 conservation areas, 48 scheduled ancient monuments and four historic parks and gardens, the Square Mile’s heritage structures pose a significant retrofit challenge, given the diverse range of buildings and their specific planning and conservation considerations.

The open-access toolkit provides a nine-step methodology to enable building owners to confidently start the process of responsible retrofit, to build a business case and deliver the necessary adaptations, in a way that protects these important community assets.

Whilst this toolkit draws on the historic environment of the Square Mile, referencing structures that are most significant to the City’s unique character, it is equally relevant to towns and cities in the UK and around the world who are exploring how to adapt their historic buildings for a sustainable future.

sions, adapting them to the extreme effects of a changing climate.

Furthermore, the reuse, refurbishment and retrofit of existing buildings represents an crucial step in reducing the impact of the built environment, which is responsible for almost 40% of greenhouse gas emissions, 50% of extracted materials, and one third of waste globally.

By creatively unlocking the potential in our her-

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itage buildings we can provide long lasting, resilient and beautiful places, whilst preserving our natural resources and reducing emissions. The Historic Buildings Carbon Reduction and Climate Resilience Challenge is a collaboration between the City of London Corporation (CoLC) and Purcell, running from 2022 to 2023.

It is set within the context of the CoLC’s wider Climate Action Strategy, which sets out how the organisation will achieve net zero, build climate resilience and champion sustainable growth. The Challenge has drawn from research and engagement with owners, occupiers, and caretakers of historic buildings within and around the City, which highlighted that whilst there is a large amount of interest and focus on addressing carbon emissions and climate resilience in heritage buildings, action has so far been limited, and projects that have sought to lead the way are not widely publicised or shared.

In an effort to address these issues, the campaign has culminated in this open-access, toolkit which provides a nine-step methodology aimed at empowering building owners to initiate the adaptations necessary to reduce carbon emissions and build climate resilience in their heritage buildings. Whilst the diversity of the built heritage within the Square Mile is a considerable challenge (there is no one-size- fits all solution), the toolkit aims to provide a common methodology.

Framed around eight core building types (or typologies), it is intended to facilitate a better understanding of heritage retrofit, drawing comparisons across similar buildings, and developing an adaptable and considerate approach.

By collating and signposting best practice principles and examples across these typologies, the toolkit provides a resource that will allow building owners to confidently start the process of responsible retrofit, build a business case and deliver the adapta-

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The nine-step methodology, summarised below, is based on latest best practice guidance and will ensure an iterative, whole building approach that is sensitive to the particular challenges of heritage buildings.

1. Start from a position of knowledge

Understanding the existing building is crucial to developing an appropriate retrofit response. Gather all available data and consider the building’s architectural and historic interest; context, construction and condition; form and layout; performance and patterns of use; energy consumption and any anticipated future changes.

2. Identify the risks Consider the increased risks from our changing climate, like overheating and water ingress from extreme weather events. These should be addressed as part of any retrofit. Also consider the risks of maladaptation, for example reduced heritage significance, increased energy consumption, abortive work, fire safety, moisture build up, poor air quality.

3. Evaluate the opportunities Opportunities to reduce carbon emissions and build climate resilience should follow a whole building approach, where the consequences of every retrofit measure is fully understood, and the building is considered as a whole system. Priority should be given to measures that eliminate unnecessary energy wastage and mitigate the impact of unavoidable energy use, before considering improvements to a buildings fabric, and installing zero carbon systems.

4. Develop a whole building retrofit plan This should set out a plan for all the work that will be needed to retrofit the building, how it will be phased and how each phase interrelates. It should set out the building constraints and risks; carbon reduction and climate resilience strategy; requirements for statutory approvals; as well as a plan for monitoring

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and reporting energy consumption.

5. Build a business case The benefits of taking climate action in heritage buildings go beyond reducing carbon emissions to reduced energy costs and providing long-term energy security; creating healthy, comfortable internal environments; ensuring resilience against future uncertainty and minimising risks; increasing market value and avoiding stranded assets. Clearly identifying these benefits, and understanding any external funding opportunities will help build a strong business case.

6. Detail design and specification All changes, whether small-scale repairs or larger alterations, require an appropriate level of detailed consideration. Seek professional advice and consider issues such as compatibility with future phases; whole life carbon; usability; vapour permeability and moisture movement; air tightness and adequate ventilation; and thermal performance.

7. Seek relevant approvals With some retrofit work, particularly involving a listed building, or buildings in a conservation area, certain statutory approvals will need to be obtained prior to starting the work. Consult with an expert and confirm approval requirements with the CoLC in terms of planning; listed building consents; building regulations; and party wall awards.

8. Installation and work on site Site operations can have a significant impact on the effectiveness of a retrofit project. Find a contractor who is familiar with your building type and construction and shows interest in what you are trying to achieve.

9. Feedback loop The ongoing monitoring and long-term oversight of the delivered outcomes will be key to understanding the impacts of any retrofit project. Test the completed building against the original brief; engage with building users to ensure correct operation; and feedback lessons into future projects. n

Decisions both decided and granted continue to fall over the past year

Latest planning performance by English districts and London boroughs: planning applications in England October to December 2023

OVERVIEW

Between October to December 2023, district level planning authorities in England:

• received 85,200 applications for planning permission, down 9% from the same quarter a year earlier;

• decided 80,700 applications for planning permission, down 12% from the same quarter a year earlier;

• granted 68,900 decisions, down 13% from the same quarter a year earlier; this is equivalent to 85% of decisions, down two percentage points from the same quarter a year earlier;

• decided 90% of major applications within 13 weeks or the agreed time, up three percentage points from the same quarter a year earlier; and decided 20% of major applications within the statutory period of 13 weeks, up two percentage points from the same period a year earlier;

• granted 8,100 residential applications, down 8% from the same quarter a year earlier;

• granted 1,700 applications for commercial developments, down 4% from the same quarter a year earlier; and

• decided 40,600 householder development applications, down 18% from the same quarter a year earlier. This accounted for 50% of all decisions, down from 54% a year earlier.

In the year ending December 2023, district level planning authorities:

• granted 293,000 decisions, down 13% from the year ending December 2022; and

• granted 32,500 residential applications, down 9% from the year ending December 2022.

Planning applications received

During October to December 2023, authorities undertaking district level planning in England received 85,200 applications for planning permission, down 9% from the same quarter a year earlier. In the year ending December 2023, authorities received 361,800 planning applications, down 12% from the year ending December 2022 (Live Table P134, PS1 Dashboard).

Planning decisions

Authorities reported 80,700 decisions on planning applications in October to December 2023, down 12% from the same quarter a year earlier. In the year ending December 2023, authorities decided 341,100 planning applications, down 12% from the year ending December 2022 (Live Tables P120/P133/P134, PS1/PS2 Dashboard).

Applications granted

During October to December 2023, authorities granted 68,900 decisions, down 13% from the same quarter a year earlier. Authorities granted 85% of all decisions, down two percentage points from the same quarter a year earlier. In the year ending December 2023, authorities granted 293,000 decisions, down 13% from the year ending December 2022. This represented 86% of all decisions, down one percentage point from the year ending December 2022 (Live Tables P120/P133, PS2 Dashboard).

Applications on hand

Authorities reported that they had 125,400 applications on hand as at 1 October 2023, down 15% from the same quarter a year earlier. This is 55% above the number of decisions made during the quarter. The corresponding figure for the same quarter a year earlier was 60%. Taking account of numbers of applications received, decisions made and applications withdrawn during the quarter gives a total of 122,600 as at 31 December 2023, down three percentage points from the same quarter a year earlier (Live Table P133, PS1 dashboard).

Historical context

Figure 1 shows that, since about 2009-10, the numbers of applications received, decisions made and applications granted have each followed a similar pattern. As well as the usual within-year pattern of peaks in the Summer (July to September quarter) and troughs in the Autumn and Winter (October to December and January to March quarters), there was a clear downward trend during the 2008 economic downturn, followed by a period of stability. There was a large dip in 2020 following the start of the pandemic and a subsequent recovery in early 2021, including a particular peak in applications received, but since the peak there has been a steep downward trend.

Regional breakdowns

Table 1 shows how numbers of applications received, decisions made and decisions granted varied by region. It also shows how the percentage of decisions granted varies widely by region, from 79% in London to 91% in National Parks (Live Table P133, PS1/PS2 Dashboard).

Decisions granted

Figure 2 summarises the distribution of the percentage of decisions granted across authorities for major, minor and other developments using box and whisker plots. The ends of the box are the upper and lower quartiles, meaning that 50% of local authorities fall within this range, with the horizontal line in the centre of the box representing the median. The whiskers are the two lines above and below the box that are 1.5 times the size of the box (the interquartile range) with the dots representing outliers. Figure 2 shows that the range between the whiskers for the percentage of applications granted is widest between authorities for major developments (40% to 100%), followed by minor developments (55% to 100%) and other developments (72% to 100%) (PS2 Dashboard).

Speed of decisions

In October to December 2023, 90% of major applications were decided within 13 weeks or within the agreed time, up three percentage points from the same quarter a year earlier. 20% of

Planning decisions by development type, speed of decision and local planning authority.

All tables and figures can be found here:

https://tinyurl.com/33bkf5hm

Source: DLUHC/ONS

major applications were decided within the statutory time period of 13 weeks, up two percentage points from the same quarter a year earlier.

In the same quarter, 86% of minor applications were decided within 8 weeks or within the agreed time, up three percentage points from the same quarter a year earlier. 39% of minor applications were decided within the statutory time period of 8 weeks, up three percentage points from the same quarter a year earlier.

Also in the same quarter, 90% of other applications were decided within 8 weeks or within the agreed time, up 3 percentage points from the same quarter a year earlier. 56% of other applications were decided within the statutory time period of 8 weeks, up five percentage points from the same quarter a year earlier.

Use of performance agreements

‘Performance agreement’ is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments. Between October to December 2023, 42% of all planning application decisions involved a performance agreement. Major developments were more likely to involve a performance agreement compared to minor and other developments with 75% of major decisions involving a planning agreement, compared with 52% of minor decisions and 36% of other decisions (Reference Table 2, PS2 Dashboard).

Figure 4 shows, from April 2010, the numbers of decisions on major, minor and other developments made involving a performance agreement, compared with numbers without a performance agreement. Notwithstanding definition changes, there has been a marked increase in the use of agreements since early 2013 (see Technical Notes for more information). This longer upward trend has been driven by both the additional scope for recording them and their additional use (Live Table P120, PS2 Dashboard).

Performance of individual district level local planning authorities

The existing approach to measuring the performance of authorities was introduced by the Growth and Infrastructure Act 2013 and is based on assessing local planning authorities’ performance on the speed and quality of their decisions on applications for major and non-major development. Where an authority is formally designated by the Secretary of State as underperforming, applicants have had the option of submitting their applications for major and non-major development (and connected applications) directly to the Planning Inspectorate (who act on behalf of the Secretary of State) for determination. See Improving planning performance: criteria for designation for more information.

Speed of decisions

The designation thresholds, below which a local planning authority is eligible for designation are: For applications for major development: less than 60% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant;

For applications for non-major development: less than 70% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant.

See Live Tables P151/P153

Quality of decisions

The threshold for designation on applications for

both major and non-major development, above which a local planning authority is at risk of designation, is 10% of an authority’s total number of decisions on applications made during the assessment period being overturned at appeal.

See Live Tables P152/P154

Residential decisions

In October to December 2023, 11,400 decisions were made on applications for residential developments[footnote 3], of which 8,100 (72%) were granted. The number of residential decisions made was down 7% from the same quarter a year earlier, with the number granted down 8% from the same quarter a year earlier. 1,000 major residential decisions were granted, down 15% from the same quarter a year earlier and 7,100 major residential decisions were granted, down 7% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard).

In the year ending December 2023, 45,600 decisions were made on applications for residential developments, of which 32,500 (71%) were granted. The number of residential decisions made was down 6% from the previous year, with the number granted down 9% from the year ending December 2022. 3,800 major residential decisions were granted, down 13% from the previous year and 28,700 minor residential decisions were granted, down 8% from the previous year.

Residential units

The figures collected by the Department are

the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each application, such as the number of homes in the case of housing developments. The Department supplements this information by obtaining statistics on housing permissions from a contractor, Glenigan.

The latest provisional figures show that permission for 233,000 homes was given in the year to December 2023, down 20% from the 291,000 homes granted permission in the year to December 2022. On an ongoing basis, figures are revised to ensure that any duplicates are removed as far as possible, and also to include any projects that local planning authorities may not have processed: they are therefore subject to change, and the latest quarter’s provisional figures tend to be revised upwards. For the previous eight quarters, the year to figures have been revised upwards by 2% on average. These figures are provided here to give contextual information to users and have not been designated as National Statistics.

When considering the above figures in relation to the central government ambition of raising housing supply to 300,000 homes per year on average by the mid-2020s, it should be noted that many permissions do not result in a home being delivered in practice. This is due to a range of reasons, relating to the circumstances of landowners and developers, as well as the local and national economy. In addition, i) time lags in building can affect the number of homes built in a particular period; and ii) the methodology used cannot guarantee that all double counting of permissions is removed from the above figures.

In comparing the number of residential applications granted and the number of units granted, it should be noted that the two series measure different things and use data from different sources, and so may not track each other closely over the short term. More specifically, this difference is likely to be due to a combination of differences in the timing of recorded decisions and a difference in the average numbers of homes included within the relevant planning applications.

Commercial decisions

In October to December 2023, 2,000 decisions were made on applications for commercial developments of which 1,700 (88%) were granted. The number of commercial decisions made was down 1% from the same quarter a year earlier, with the number granted down 4% from the same quarter a year earlier. 400 major commercial decisions were granted, up 3% from the same quarter a year earlier and 1,300 minor commercial decisions were granted, down 6% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard).

In the year ending December 2023, 7,800 decisions were made on applications for commercial developments, of which 6,900 (88%) were granted. The number of commercial decisions made was down 5% from the previous year, with the number granted down 7%. 1,500 major commercial decisions were granted, down 7% from the previous year and 5,400 minor commercial decisions were granted, down 7% from the previous year.

Trends in the percentage of residential and commercial decisions granted

SEE Fig 7 BELOW

Householder developments

Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (see Definitions section of the Technical Notes).

The number of decisions made on householder developments was 40,600 in the quarter ending

December 2023, accounting for 50% of all decisions, down from 54% of all decisions made in the quarter ending December 2022. Authorities granted 88% of these applications and decided 91% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard).

In the year ending December 2023, 180,200 decisions were made on applications for householder developments, accounting for 53% of all decisions, down from 56% of all decisions made in the year ending December 2022. Authorities granted 89% of these applications and decided 91% within eight weeks or the agreed time.

Major public service infrastructure development decisions

Since August 2021, major public service infrastructure developments broadly defined as major developments for schools, hospitals and criminal justice accommodation have been subject to an accelerated decision-making timetable.

Separate figures on major public service infrastructure development decisions have been collect-

ed on the quarterly PS2 return with effect from October 2021. During October to December 2023 there were 33 decisions, of which all 33 were granted and 31 were decided in time (Live Table MJPSI, PS2 Dashboard). Please note that figures are not collected on the CPS1/2 return and so don’t include education developments by county councils.

Permission in Principle/Technical

Details consent decisions

Since April 2017, local planning authorities have had the ability to grant permission in principle (PiP) to sites which have been entered on their brownfield land registers. Where sites have a grant of permission in principle, applicants have been able to submit an application for Technical Details

Consent (TDC) for development on these sites. In addition, since June 2018, it has also been possible to make an application for PiP for minor housingled development as a separate application, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC.

Figures on PiP/TDC decisions have been collected on the quarterly PS2 return from January 2020. During October to December 2023, local planning authorities reported 145 PiP (minor housing-led developments) decisions, 10 TDC (minor housingled developments) decisions and one TDC (major developments) decision. The totals for the previous quarters have been similar although there has been a slow upward trend since 2020, when there were about 60 PiP decisions per quarter (Live Table PiP/TDC1, PS2 dashboard).

Permitted development rights

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

Between October to December 2023, 5,100 applications were reported, of which prior approval was not required for 2,500, permission was granted for 1,400, and 1,200 were refused. This resulted in an overall acceptance rate[footnote 6] of 76%. Large householder extension accounted for 54% of all PDR applications reported, with 26% relating to All others,

8% relating to Agricultural to residential, and 7% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2).

In the quarter to December 2023, 900 permitted development right applications were made for changes to residential use, of which 600 (64%) were given the go-ahead without having to go through the full planning process.

Overall during the 39 quarters ending December 2023, district planning authorities reported 327,100 applications for prior approvals for permitted developments. For 182,500 of them prior approval was not required, 77,000 were granted and 67,600 were refused (Live Table PDR2). n

New NPPF, more homes, transport planning and what might change under Labour

Selective account of Forum Annual Planning Up-Date on Tuesday 19th March 2024 hosted by Dentons

Given the range and depth of presentations and discussions we can only publish a selection of the contributions based on presenters’ notes and slides.

Joanna Averly’s opening keynote was partly ‘off the record’. The full programme is shown on the next page.

THE NEW NPPF & DEVELOPMENT MANAGEMENT REFORM

Mike Kiely, Chair Planning Officers Society

2023 NPPF – the main changes – what was included | what was not | what’s new:

• Throughout the Framework “beauty” is inserted wherever possible.

• The overall purpose of the framework has been boosted from providing a framework within which “locally-prepared plans for housing and other development can be produced” to one where “locally-prepared plans can provide for sufficient housing and other development in a sustainable manner”. Plus preparing up-to-date plans is now seen as a priority in meeting this objective. This new emphasis is added in several places throughout the Framework.

• At the end of the introduction, the WMS on Affordable Homes Update (24 May 2021) which contains policy on First Homes is specifically mentioned – this was not in the consultation.

• The changes in para 11 to building at densities significantly out of character with the existing area and evidence of and allowance for past over-delivery have not been included in the final version.

• Footnote 8 to para 11 introduces the new 4YHLS test which is set out in para 226.

• Para 14 extends the period within which Neighbourhood Plans carry weight from two to five years after being Made where they contain policies and allocations to meet the NP’s identified housing requirement.

• The changes in para 35 to plans being positively prepared and the deletion of the Justified requirement have not been included in the final version.

• Surprise, surprise – lots of changes in Chapter 5 (Delivering a sufficient supply of housing):

• Makes it clear that the aim is to meet as much of an area’s housing need as possible – with an appropriate mix.

• It states clearly that the outcome of the Standard Method is “an advisory starting point” but it is only if there are exceptional demographic [inserted post ConDoc] circumstances that justify it – so it’s not the easy “get out of jail card” most people (rural councillors) think.

• The Urban Uplift is now in the NPPF, but they’ve added a piece about cross boundary redistribution agreements. The exception “conflict with the policies in this Framework” remains but “and legal agreements” is deleted – I assume that this was an imprecise reference to cross-boundary redistribution agreements.

• The elderly housing additions to potential mixes are retained.

• The addition to para 67, “The requirement may be higher than the identified housing need, if it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment” is retained.

• A new bullet under para 70 (relating to small site) encouraging community-led development for housing and self-build and custom- build housing.

• Using tools such as Permission in Principle is added.

• Further changes (in para 73) to encourage community led exceptions developments – not in the ConDoc.

• Para 75 has changed since the ConDoc and now sets out that a 5YHLS supply no longer needs to be calculated until the plan is more than 5 years old provided it did identify a 5YHLS. 5 & 10 % buffers no longer apply, only a 20% where there is a HDT failure. Operation of the HDT is also tweaked with a new 85% delivery failure consequence, so it’s now 95% - action plan, 85% - 20% buffer, and 75% - presumption.

• Further encouragement of community-led hous-

ing in rural areas.

• Everyone will be pleased that the vital encouragement of mansard roofs is still there in para 124.

• Paragraph now added at the end of Chapter 11 (Making effective use of land) on not having to meet housing need with “significant uplifts in the average density … if the resulting built form would be wholly out of character with the existing area” provided it is “evidenced through an authoritywide design code which is adopted or will be adopted as part of the development plan” – so not an easy get out of jail card!

• Chapter 12 (Achieving well-designed AND BEAUTIFUL places): further promotes the use of design codes and requires good quality submissions (especially around details and materials so compliance and, if necessary, enforcement is facilitated.

• Chapter 13 (Protecting GB Land): the wording is changed from the ConDoc, but no real change in policy despite the politics – just clarification that you only have to do a GB review if there are exceptional circumstances.

• Chapter 14 (Meeting the challenge of climate change, flooding and coastal change): when dealing with renewable and low carbon energy and heat, plans, we now need to consider future replacement and maintenance and there is greater support for these developments.

• Transitional arrangements are in Annex 1

• Only material changes to the Glossary are a definition of community-led developments and the deletion of Entry-Level Exceptions Sites plus –thankfully because it wasn’t in the ConDoc – a definition of a Mansard Roof – all praise the Govemiester!

• In its response to the consultation on changes to the NPPF, DLUHC said it will bring forward “additional Planning Practice Guidance” to set out exactly how councils will be able to account for past oversupply in calculating their housing land supply – something they have not previously been able to do but no clues yet on what it will say!

Other DM related changes

announced by Santa (AKA Gove) on 19/12/23:

• EoTs and new League Tables

• The Super Squad is on its way!

Annual Planning Up-Date

2pm Tuesday 19th March 2024

At Dentons, One Fleet Place EC4M 7RA

New NPPF, more homes, transport planning and what might change under Labour TIMINGS v.8

2.05 WELCOME

Michele Vas partner, Dentons

2.15 KEYNO KEYNOTE TE

Br Brian W ian Wateraters s intr introduces oduces

Joanna Averley Go Government c ernment chief planning of hief officer icer

Q&A

2.50 2 50 THE NEW NPPF & DEVELOPMENT MANA THE NEW NPPF MANAGEMENT GEMENT REFORM

Mike Kiely, Chair Planning Of Chair Officericers Society s

Dr Dan Slade, P Policy Manag olicy Managerer, R RTPI TPI Q&A

3.20 3 20 THE LONDON PLAN AND HOUSE B UILDING

Ross Raftery, Associate Dir Director with Lic ector Lichfhfields ields

Hashi Mohamed, Landmark Chamber Chambers

Prof Janice Morphet, UCL – building by local authorities

Prof Les Mayhew, Ba Bayes Business Sc es School & the Older hool Peoples Housing eoples Task F ask Force 4.00 Q&A

4.00 ••••••••••••••TEA•••••••••••••

*speaker to be confirmed.

•

4.20 TRANSPOR TRANSPORT PLANNING, T w what’hat’s ne s new? w?

Da David Har vid Hart, director of Momentum Transport Consultancy

Jolyon Drury, on freight, distribution and kerbside conflicts 4.40 Q&A

4.50 PLANNING UNDER LABOUR – WHAT MIGHT AND WHAT SHOULD CHANGE?

Matthew Pennycook MP*, Shadow minister for planning

Professor Michael Edwards, UCL

John Walker, CT Group formerly Westminster City Council

5.20 PANEL DISCUSSION with Q&A

Dr Riette Oosthuizen head of planning at HTA Design,

Michele Vas partner Dentons, Phidel Adeleke, co-living and House of Praise

Thomasin Renshaw, chief development officer at Pocket Living – Moderator: Lee Mallett

5.45 THE WIND-UP Paul Finch

5.55 NETWORKING & DRINKS courtesy of Dentons

Proceedings will be fully reported in Planning in London magazine: www.planninginlondon.com

BOOK HERE: https://www.culandsoc.com/events/annual-planning-update-3/

More Councils are on the Naughty Step - St Albans, Amber Valley, Ashfield, Medway, Uttlesford, Basildon, & Castle Point for plan making and Chorley & Fareham for major and St Albans & Bristol for non-major decision taking.

• Review of Statutory Consultees by Sam Richards

• Review of London Plan by Kit Kat (which is in –more later).

ATTENDANCE

• Plans for Cambridge to deliver Gove’s vision for Cambridge 2040

What’s to come:

• BNG is now in!

• Nutrient Neutrality – still not resolved

• Street Votes consultation

• New PD rights that are in or on their way:

Meeting held on Tuesday 19th March 2024

Brian Waters Chairman

Adams Mike Adams Infrastructure Planning Ltd

Adekele Phidel Co-Living/House of Praise Church

Allan Jay London Communications Agency Director - Politics, Engagement and Planning

Astbury Mike Mondrem CIC Chief Executive

Averley Joanna Government Chief Planning Officer

Bach Michael

London Forum of Amenity & Civic Societies Chair: Planning, Environment & Transport Committee

Bateson Ashley Hoare Lea Director

Bedwell Paul

Paul Bedwell Town Planning Limited

Breach Anthony Centre for Cities Associate Director - Policy & Research

Butcher Ian

Andrew Martin - Planning Limited Associate Director

Butters John

Hoburne / Burry and Knight Chairman

Catto Andrew

Andrew Catto Architects Ltd Director

Clifford Ben

UCL Bartlett School of Planning Professor of Spatial Planning

Davies Robert Pinsent Masons LLP Partner

Drury Jolyon

Surge Logistics Consultants Director

Edwards Michael

Bartlett School of Planning, UCL Honorary Professor

Eversden MBE Peter

London Forum of Amenity and Civic Societies Chair

Finch OBE Paul World Architecture Festival Programme Director

Formston Daniel

Savills Residential Research Analyst

Fredricks Laurence Onward Energy and Environment

Gambill Vendela Deloitte

Goodstadt Vincent UK2070 Commission

Gough Tim

Austin Winkley & Associates Director

Hart David Momentum Transport Consultancy

Heath Stephen Bloomsbury Association ex- architect

Herbert Rachael Dentons Senior Associate

Hodges Hipolit University of Cambridge Student

Huang Byron Urban Redevelopment Authority Singapore

Humphreys Matt H Planning Ltd

Inglis Patrick President ACA

Jarvis Philippa PJPC Ltd Director / Consultant

Jones Iwan JIG Planning & Development Ltd MD

Kaya Una

Keyhan-radshayan Investre Limited MD

Kiely Mike Planning Officers Society

La Torre Pablo Assistant Development Manager

Lee William Buckminster Director

Levine Pascal DS2 LLP Partner

Levine Pascal Guest

Lim Yu Xin

University of Cambridge Student

Lincoln Bryan Sherrards Consultant Solicitor

Lombard Jacobus Deon Lombard Architects Principal

Lovedale Ben Sheppard Robson Associate Architect

Mallett Lee Urbik Director

Marrs Colin Construction News Editor

Mayhew Prof Les

Bayes Business School & The Older Peoples Housing Task Force

Miller Fidel FJ Urban Planning Ltd Planning Consultant

Milliken Simon

Milliken & Company Chartered Surveyors & Town Planners Director

Mohamed Hashi Landmark Chambers Counsel

Morphet Dr Janice UCL

• Open prisons

• Solar panels on flat roofs

• Further commercial to residential PD – axing

1,500 sqm limit and the need to be vacant (as consulted on) – 5 March

• New use class for short term lets + PD for C3 to C5! – this summer

• Proposed PD rights (consultation):

Morton Richard Richard Morton Architects Ltd

Mulhaire John Momentum Transport Associate Director

Noorani Odin University of Cambridge Student

Dr Oosthuizen Riette HTA Design LLP Partner

Owen Ellis Grace CMS London Partner

Pilbrow Fred Pilbrow & Partners Senior Partner

Pinault Grace Dentons Associate

Pinnock Roy Dentons Partner

Pomeroy Stewart Colne Valley Regional Park Managing Agent

Procter Chris ACAN Architect

Raftery Ross Lichfields Associate Director

Renshaw Thomasin Pocket Living Senior Development Manager

Rogers Andrew ACA Planner

Ruane Erik

Real Estate Business Consultancy Services Ltd

Ryser Judith Urban Design Group

Book review editor

Samoun Melina

Shone Harriet London Communications Agency

Shrestha Mahanta Khukuri Beer UK Ltd Chairman

Slack Oliver

Slade Dr Dan RTPI Policy Manager

Speakman Ben CBRE Graduate Surveyor

Thompson Martin CULS

TozerLukePitman Tozer ArchitectsDirector

Trowbridge Andy Ardent Consulting Engineers

Principal Transport Planner

Vas Michele Dentons Partner

Vasdekys George Salisbury Jones Planning Partner

von Preussen Tatiana VPPR Architects Director

Walker John CT Group

Willingale Mark Willingale associates Principal

Young Alexandra Cambridge University Land Society Society Secretary

Vekaria Rohini Dentons Associate

Houston Roddy

Net Zero Now

• Residential extensions – 4-5 Det | 3-4 S&T | 2st 3-4 | roof vol – 40/50m3

• Building upwards – scrap 1 July 48 – 1930 or none

• Demolition & rebuild

• EV charging points – now up to 3m

• Air source heat pumps – 2 and closer to boundary (now 1m)

• Poss new agricultural PD (Richie announced at NFU Conference) the Diddly Squat rules?

• 2024 NPPF & NDMP + a review of NPPF that might cover:

• An emphasis on social rent

• Definition of affordable rent

• Promoting community led housing

• Promoting small scale development

• Climate change and adaption

• Safety for women and girls

• Free ports

• EV charging points

• Local plans & the 30-month target – DLUHC wants to bring in by Autumn 2024 – 3 Gateways

• Environmental Outcome Reports – but not until 2025

• Will we see the IL – let’s hope not!

• Proposals to encourage faster build-out of PPs –the “use-it-or-lose-it” proposals!

• Kit Kat’s London Plan Review: tilted balance to apply to all brownfield land development in 20 largest cities if scoring < 95% on HDT plus a general requirement to be flexible on granting PP on brownfield land but no specifics as to what they mean – we will have to cram them in (maximum amount of housing) and make them beautiful!

• Consultation on above + GLA referrals thresholds to increase – from 150 units to ? – it was 500 but consultation asking what it should be

• CPO amendments – inc “no hope Value” for public interest schemes – 31/01/25

• An accelerated planning system consultation (6 March 2024)

- Accelerated Planning Service – 10-week guaranteed service or money back

- Planning performance and extensions of time

- Extension of simplified Written Reps to nearly all appeals

- S73b – varying overlapping planning permissions. n

THE NEW NPPF & DEVELOPMENT MANAGEMENT REFORM

Dr Dan Slade, Policy Manager, RTPI

Dan followed Mike with the following slide presentation:

THE LONDON PLAN AND HOUSE BUILDING

Ross Raftery tgAssociate Director with Lichfields

Hashi Mohamed, Landmark Chambers

Prof Janice Morphet, UCL – building by local authorities

Prof Les Mayhew, Bayes Business School & the Older Peoples Housing Task Force

Ross Raftery’s slideshow follows on the next page:

THE LONDON PLAN AND HOUSE BUILDING

Prof Janice Morphet, UCL Building by local authorities

What did we do?

The research follows the same approach we took in our 2017, 2019 and 2021 reports and comprises of:

1.Desk survey of public information on activity by each LA in England, undertaken spring 2023

2.Direct questionnaire survey to officers in each LA in England, undertaken summer 2023. 231 responses from 159 different authorities

3.7 roundtable discussions held across England in spring and summer 2023

4.6 case study interviews with officers volunteering via the direct survey

Who Paid? Savills, Willmott Dixon; National Planning Forum and POS

Key desk survey findings

•Overall, there has been a steady increase in the level of housing activity across English local authorities in comparison with 2017

•94% of local authorities are engaging with housing provision through at least one method and the range used by councils is gradually increasing

• 76% local authorities have affordable housing as a council corporate priority

•14% of local authorities are Registered Providers

Key desk survey findings

•Programmes of development are increasing in some areas but may be reduced or extended in others by inflationary costs in construction

•There is a growth in housing acquisition

•Councils are still active in the use of their own companies and joint ventures with housing associations, developers and, in some cases other councils, to provide a range of housing

•The number of joint ventures and companies have reduced as an absolute number since 2021 although for some activity has increased.

Key direct survey findings

•79% of local authorities self-reported that they were directly delivering housing, compared to 65% in our 2017 survey, 69% in 2019 and 80% in 2021

•Only 7% of local authorities responded that the recent S.114 notices had impacted their plans around direct delivery of housing

•53% of authorities (81 answering – presumably all stock owning authorities) reported that increased costs of retrofitting existing housing (for example in relation to fire safety, damp and/or mould) were impacting plans to deliver new housing.

•68% of authorities had a strategy beyond just

relying on S.106 for affordable housing delivery:

- having housing strategies with specific housing delivery action plans

- actively supporting housing association or other registered provider partners, developments planned on council-owned sites (including small sites and garage sites)

- buying back former RTB properties

- taking on S.106 properties a Registered Providers are not interested

- use of the council’s housing company

- having a housing company which is a RP (and can access Homes England grants)

- use of council-owned sites in partnership (e.g. working with RPs on vacant land)

- an empty homes purchase scheme and direct purchase of existing housing

- building under the Housing Revenue Account (HRA)

- using the Public Works Loans Board

- building out rural exception sites

- proactively targeting stalled sites

- working directly as an authority on land purchase and assembly.

•Despite higher costs and pressures on land availability, London Boroughs, supported by the Mayor of London’s application of the Affordable Housing Programme are still delivering more homes than other parts of England

•In London, the Boroughs can apply for funding for five year programmes, whereas elsewhere in England affordable housing funding is made available on a scheme-by-scheme basis through Homes England (some mayors of Combined Authorities are now starting to provide housing programme support)

What are LBs doing to provide housing?

•Developing municipal campuses (eg H and F; WF; Lambeth)

•Using own companies to develop (eg B and D; Barnet, Brent, Hounslow)

•Building for sale (eg Ealing; Enfield)

•JVs with developers (eg Kingston-upon Thames; Ealing; Havering)

•JVs with HAs (eg Southwark)

•Extending HRA programmes for social rent (most)

•Acquiring from developers (eg Brent)

•Acquiring land to build homes (eg Barnet)

•Undertaking estate regeneration (eg Harrow, Havering; Islington)

•Regeneration (eg Bexley; Brent; Lewisham; Hounslow)

•Redeveloping council land in current other uses (eg Ealing; Haringey; Lewisham; Redbridge)

•Providing homes for key workers (eg Brent)

•Develop small sites for TA (Bromley)

•Providing student accomodation (eg Camden;

Enfield)

•Providing special needs housing (eg City of London)

•Using MMC to provide homes (eg Croydon. Enfield, Greenwich)

•Providing safe and secure homes (eg Ealing)

•Establish housing investment fund (eg Merton)

•Acquiring street properties (eg Ealing)

•Acquiring former RTBs (eg Barnet; K and C; Sutton; TH)

•Building on former warehouse land and retail land (eg H and F; Kingston upon Thames)

•Using SME builders on small sites (eg Enfield)

•Building to high environmental standards (eg Greenwich; Hounslow; Newham)

•Using housing to promote town centres (eg Hackney; Hillingdon; KuT; )

•Building larger accomodation (eg H and F)

•Providing homes for rough sleepers (eg Sutton)

•Council company acquiring s106 (eg TH)

•Working with TfL (eg Hounslow)

•Operating as a registered provider (eg Lambeth; Westminster)

•Working with HAs (eg Merton)

•Providing shared ownership homes (eg Richmond upon Thames)

•Providing funding to HAs (eg Waltham Forest)

•Redeveloping housing estate land eg garages (eg Wandsworth)

•Building extra care homes for the elderly (eg Westminster)

•Converting existing property into new homes (eg Tower Hamlets). n

Report available here:

https://www.ucl.ac.uk/bartlett/planning/news/202 4/jan/fourth-report-local-authority-housebuilding-launched

Prof Les Mayhew, Bayes Business School & the Older Peoples Housing Task Force International Longevity Centre UK

Older

peoples housing –Time for change

OPHTF looking at options for the provision of greater choice, quality and security of housing for older people.

Recommendations covering:

•the appropriate level of older people’s housing

•the enablers and barriers to growth of supply and

•options to increase the range and choice of specialised housing available to older people

•Due to report in May 2024 and led by Prof. Julienne Meyer with a wide range of support across multiple professions and backgrounds

https://www.gov.uk/government/groups/olderpeoples-housing-taskforce

Topics

•How demographic ageing is fuelling the housing crisis

• Older peoples living arrangements

• Current rates of building of OP homes

• Barriers to downsizing and investment

•Simplifying typologies

• Emerging themes

Why don’t more people downsize?

•Cost barriers to moving into private sector housing:

- High cost of specialist housing per sq meterage versus mainstream

- High transaction costs viz estate agent fees, stamp duty and legal

- High on-going costs such as service charges and event fees, rents

•The general complexity of buying and selling especially for older people unless it is a forced sale

•A wide range of tenure ships including social and private renting, shared ownerships leasehold which consumers find confusing

OP’s specialist Housing

•Simplifying the typology and types of specialist housing (sheltered, alms housing, retirement housing, IRC, retirement villages are some examples)

•The main types boil down to unsupported (mainstream homes), supported (e.g., with warden), supported with care (e.g., Extra care), supported with care and nursing (e.g., integrated care communities)

•Higher profiles by advertising more widely e.g., in estate agent windows and on-line

•Simple A,B,C categorization of homes based on attributes such as thermal efficiency, step free

access, close to local amenities, number of beds.

Supply-side measures

On the supply side

- more government focus on the sector

- investment in failing town centers and using brownfield sites

- changes to the planning system

- possible use of targets

- develop age friendlier areas by improving access to services people use and need

-greater use of financial incentives and disincentives

-Financial advice and help

Areas of focus

•Viability of the sector

•Consumer protection

•Design

•Age friendly areas or placemaking

•Health benefits of specialist housing

•Developing, and embedding research, development, and innovation in planning, construction and design

•Investment n

Mayhew review:

https://ilcuk.org.uk/wp-

content/uploads/2022/10/ILC-FP-RetirementXSUM_final_oct_24.pdf

lesmayhew@googlemail.com

TRANSPORT PLANNING, what’s new?

David Hart, director of Momentum Transport Consultancy

2.3 REDUCING THE IMPACT OF DELIVERIES CARGO BIKES

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Kerbside challenges

Freight, distribution and kerbside conflicts

Jolyon Drury FCILT

Chartered Institute of Logistics & Transport

Central London Freight Quality Partnership

The size of delivery drives economics. For example the Brewery Logistics Group reports a figure of 20% loss of productivity which has resulted in the uplift of Dray numbers to around 73 vehicles at the last count at the end of 2023 since the Streetspace schemes were introduced.

That figure is expected to rise in 2024 with the introduction of more cycle lane schemes and kerbside restrictions. Some of the increase is also down to working practice with brewery logistics operators using smaller vehicle due to on street and kerbside access issues. This increases fleet sizes and a reduction in consolidated loads which in turn increases deliveries e.g. where a consolidated load is delivered once a week a smaller fragmented load will need to be delivered between 3 & 5 days a week.

Permitted delivery using marked timed kerbside bays still works. A consolidated load can take about 40 minutes.

Long tramming as a result of restricted and unavailable unloading provision is becoming the norm in busy replenishment areas such as Soho. Concerns about operator safety and load security, especially in the chilled supply chain.

Provision for service vehicles is as important as loading access: often with longer dwell times. These pallets of kegs were trammed for some distance as a result of the service vans occupying the bay.

Alfresco dining hung over from Covid block delivery opportunities. Here in Charlotte Street they have been subject to waste abuse.

For consolidated developments, off street loading bays prevent delivery and waste abuse. The closely managed St Pancras station loading bay houses two compaction skips and accommodates deliveries for replenishing the concourse retail outlets.

Uncoordinated construction blocks scheduled deliveries. Here a scaffolding team, but it might as well be deliveries or collection of construction materials, concrete pumps, cranes which require developers’ site managers to coordinate in real time across a zone.

Parking controls must be enforced. However worthy, unstructured cycle drops result in kerbside anarchy

PLANNING UNDER LABOUR –WHAT MIGHT AND WHAT SHOULD CHANGE?

Professor Michael Edwards, UCL

John Walker, CT Group formerly Westminster City Council

The Labour party offer

Michael Edwards

The major issue I want to press upon the Labour leadership is this:

As a society we need urgently to find ways to live in our profoundly unequal, unbalanced, scattered, energy-wasteful settlements, to deal with crises of inequality and environment without rebuilding everything.

There is a lot for planning to do so don’t dismantle it.

I had hoped to see Labour offering an intelligent critique of the Think Tank theory of housing affordability – that supply-demand relations for land and housing are similar to those for produced commodities where a boost to supply will bring prices down; furthermore the key supply constraint is alleged to be the freedom for stroppy DM committees to refuse permissions against officer advice and plan allocations.

But…

1 The market for new homes is not a competitive perfect market. Landowners and housebuilders act as cartels, constraining the land supply, trickling out their completions slowly so they don’t have to give discounts. Good to see that the Competition and Markets Authority has been probing this. Housebuilders also take options on land which prevents community initiatives and other builders (especially smaller ones) from getting it and these options are not recorded in the Land Registry so cannot be scrutinised.

2 The nation’s stock of council housing has been decimated, mainly by the Right to Buy, so more and more people are now dependent on the private rental market. With inequality of income and wealth on today’s scale it is unrealistic to imagine ANY market sector – rental or sale – that could house everyone decently.

3 Government schemes ostensibly designed to increase output, like Help to Buy, turn out to have inflated prices and developer profits rather than increasing output.1

4 There is convincing evidence that any national strategy of building massively (hundreds of thousands of homes per year) would be impossible without transgressing environmental limits.2

5 House prices and rents are determined across the whole local or regional stock of homes so the

impact of new building on prices is heavily diluted. “Estimates of the sensitivity of UK house prices to increases in housing stock consistently show that a 1% increase in housing stock per household delivers a 1–2% reduction in house prices. This is minimal in the context of a 181% increase in mean English house prices from 2000 to 2020 (£84,620–£253,561).” 3

6 As people get richer their housing expenditure grows. So when the housing stock in the market grows, richer people obtain more of it – as extra floorspace or as garden space or as proximity to better schools, or as second homes, leaving less for those with low market power4. In an unequal society this is both an important consequence of inequality, and something which reinforces, the inequality.

7 The escalation of house prices has been fuelled or facilitated by the huge growth of credit and –until recently – by negligible interest rates.

8 Much of the research literature concerns itself with national data but the significance and power of land ownership varies from place to place and a national target for output is almost meaningless.

9 International demand for housing in London appears to be, in part, a quest for what are perceived as safe havens for money, including the laundering of ill-gotten gains from corrupt regimes. Overlapping parts of the demand from abroad are in pursuit of current returns from renting and/or the prospect of capital gains. This demand comes on top of demand generated by the national economy and helps to inflate prices. In some places the corresponding homes are not even occupied, though estimating and controlling the extent of vacancy are controversial.

10 A part of the housing stock is devoted to short-term letting via online platforms and control of this phenomenon is very weak compared with many places in the world. It removes a very great deal of housing from normal use by the permanent population and also undercuts the relatively wellregulated hotel sector.

11 Finally, the thrust of planning policy and practice by national, regional and local governments have inadvertently contributed to strengthening the stranglehold of landed and development interests in our society. The resulting settlement pattern is environmentally inefficient as well as socially unjust, but reducing the discretion of local councillors could not conceivably solve our problems.

Perhaps it’s too much to hope that any political party will announce that it’s planning to lower or even stabilise house prices! But we should be able to expect that Labour would prepare the ground for decommodification – e.g. by developing savings media and tax reforms which could attract our savings away from just adding to demand on housing and head off inflows from abroad;

The scaling down of the promised £28bn fund to mitigate climate impacts is a major loss. The Labour commitment to growth of GDP looks bad too since GDP growth here produces so much poverty alongside wealth and seemingly can’t be de-coupled from carbon emissions. We have to console ourselves with the fact that Labour’s quite unnecessary commitment to continued austerity means there won’t be much GDP growth to worry about. n

1 Chris Foye and Edward Shepherd, 2023, Why have the volume housebuilders been so profitable? CACHE, https://housingevidence.ac.uk/project/why-have-the-volume-housebuildersbeen-so-profitable/

2 Sophus O S E zu Ermgassen, M P Drewniok, J W Bull, C M Corlet Walker, M Mancini, J Ryan-Collins and A Cabrera Serrenho (2022)

"A home for all within planetary boundaries: Pathways for meeting England's housing needs without transgressing national climate and biodiversity goals" Ecological Economics 201: 107562

3 The quotation is from zu Ermgassen and others (above). They quote Auterson, T, 2014, Forecasting House Prices (Working Paper No 6) Office for Budget Responsibility; Oxford Economics, 2016, Forecasting UK House Prices and Home Ownership (Report for the Redfern Review); MHCLG, 2018, Analysis of the Determinants of House Price Changes, Ministry of Housing, Communities & Local Government, London; HMLR, 2022. UK House Price Index - UK Land Registry

4 The work of Paul Cheshire on the income elasticity of demand for housing is the source of this statement.

21-23 may

Clerkenwell Design Week returns to London from 21 – 23 May 2024, marking its 15th year as a global design festival. Building upon its record-breaking 2023 edition, which drew over 37,000 visitors, the upcoming event is set to elevate the experience with new venues, expanded exhibition spaces, thought-provoking installations and a stronger-than-ever line-up of both British and international brands.

Expect more than 600 curated events spread throughout the EC1 neighbourhood, complemented by a network of over 160 local design showrooms and 300 exhibitors across 12+ venues.

"Not only is Clerkenwell Design Week one of the most attended speci昀cation events in the architecture and design calendar, it is also an important platform to discover new talent and ideas," says Marlon CeraMarle, Design Division Director of Media 10 which organises the annual design festival.

“This year, we’re excited to showcase an unprecedented number of participating brands, re昀ecting strong demand from both home and overseas. In response, we’re expanding our exhibition and installation spaces, including the newly revamped, pedestrian-friendly Clerkenwell Green.”

Event details:

When? 21–23 May 2024

Where? Across Clerkenwell, London, EC1

How much?

Free but pre-registration is required

For more details visit

www.clerkenwelldesignweek.com

“An essential travelling companion for those in the FAC-1 team, with Professor Mosey as your expert tour guide.” — Julian Bailey, partner at Jones Day and author of Construction Law (3rd edition)

“… provides excellent guidance to support the effective use of FAC-1.” — Alison Nicholl, head of Constructing Excellence

“… enables all parties to a project or programme of works to understand their roles and responsibilities in creating an alliance capable of delivering safe, quality and value-formoney project outcomes.” — Rebecca Rees, partner at Trowers & Hamlins

“An essential catalyst in helping clients and industry supply chains actively work together to deliver the new ways of working that are required to unlock the vision of a social and productivity revolution that our industry needs.” — Terry Stocks MBE FICE, director at Faithful+Gould

“The best friend of everyone, in every sector of the construction industry, who wants to make a real difference.” — John P. Welch FRICS, Deputy Director of Construction, Crown Commercial Service

Dr David Mosey CBE is a professor at the King’s College London Centre of Construction Law & Dispute Resolution and was formerly head of the projects and construction department at law firm Trowers & Hamlins. He is the principal author of the FAC-1 Framework Alliance Contract and has advised on the procurement of collaborative projects and programmes of work for more than twenty years. David was appointed by the UK government in 2021 to lead an independent review of public sector construction frameworks. His recommendations for improving value, improving safety, managing risk and achieving net zero carbon are set out in ‘Constructing the Gold Standard’ and have been widely endorsed by both government and industry. David received the 2021 TECSA Clare Edwards Award for ‘professional excellence and an outstanding contribution to the legal profession’ and was awarded a CBE in the 2023 New Year honours list for ‘services to the construction industry’.

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

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

ROGERS

Let’s not trouble the planners

Andy Rogers checks what can already be done without troubling the local planning authority

Andy Rogers is a planning consultant and former director in architects

The Manser Practice

Reading yet another government consultation on extending permitted development rights, it occurred to me to check what can already be done without troubling the local planning authority.

Mr Developer has purchased a dilapidated detached house on sloping ground in a residential road. It is not listed, nor is it in a conservation area. Works that are allowed in order to enhance the property for re-sale are set out in the diagram.

All of the works noted on this diagram are allowed by The Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended), except for those that are not classified as development by The Town and Country Planning Act 1990: section 55(2), which allows the maintenance, improvement or other alteration works which are interior alter-

ations or operations that do not materially affect the building’s external appearance and uses within the curtilage of a dwellinghouse for any purpose incidental to its enjoyment (such as gardening or playing games).

But there are many other changes that Mr Developer can make with only a minimal reference to the Local Planning Authority by means of ‘prior approval’.

These include the addition of another one or two storeys, raising the rear extension by an extra storey, and (if the latest permitted development rights consultation is implemented) erection of a bin/bicycle store in the front garden, formation of an L-shaped ‘wrap-around’ side and rear extension, installation of an air source heat pump, and even in some circumstances, complete demolition and reconstruction of the house. n

PDRs, in my view, are best looked at not as a deregulatory thing; think about them in terms of the 1947 act…[when] development needed permission .. some permission is given by local authorities, and some permission is given by government.”

– Steve Quartermain, 2020

If what is called development is allowed to multiply at the present rate, then by the end of the century Great Britain will consist of isolated oases of preserved monuments in a desert of wire, concrete roads, cosy plots and bungalows … [named] SUBTOPIA. – Ian Nairn in the Architectural Review, June 1955

¡ PILLO! PILLO!

They keep on coming’

Is there anyone actually surprised that the population of London is within a squeak of exceeding its pre-pandemic levels, according to the Centre for Cities.

That is, just over 10 million. And the reason is down to the simple reality that an awful lot of the people who come to the UK gravitate — surprise! — to London.

The capital takes in more than a third of incomers, some 35 per cent, possibly more. And so the more immigration goes up, the more the London population rises. It really is that basic.

– Evening Standard

This is an M&S planning decision

Any decision Michael Gove issues in the wake of his legal setback may also be challenged and the M&S debate could well head back to court on a new point of contention later this year.

"So, many years, millions of pounds, a planning application, an inquiry and a High Court hearing later, M&S have lots of national headlines, but still no planning permission for their new building " barrister Zac Simons reflects. "What a wonderful system we have."

F–Off!

Mark Brown, the general secretary of the BTU trade union, which represents some Lloyds workers, said: “The more we allow people to claim they have been offended because they disagree with the use of certain words or phrases, the more they will seize the opportunity to be offended.”

MMC gone wrong

What has gone wrong with MMC is brutally simple. Those gulled into investing in factories to produce prefabricated homes failed to fully test market demand, instead relying upon government hype and the personal hope that developers would pay a bit more for MMC, in much the same way shoppers will pay more for organic produce.

Never going to happen.

– Peter Bill on LinkedIn

Re-imagining The Tipperary

The first of several new and restored pubs coming into operation over the next few years, the Tipperary pub on Fleet Street has reopened to the public after three years of closure, following repairs and preservation works to the building.

The Tipperary first opened in 1605 as The Boar’s Head and was renamed after it was bought by Irish pub group JG Mooney and Co. in the 1800s.

With its iconic green paint and Guinness signage, there have been claims that The Tipperary is London’s oldest Irish pub. The wood-panelled building is Grade II-listed and was bought by Greene King in the 1980s. It closed during the pandemic.

Re-imagining existing pubs within development schemes is a key part of the City Corporation’s initiative to turn the Square Mile into a seven-day-a-week visitor destination. Part of this includes negotiating with developers to provide new pubs in prominent locations.

Presumption in favour of brownfield

The government is absolutely right to super-charge brownfield development – and not solely because it delivers on ministers’ political objective of resisting greenfield development. We need to develop on both green and brownfield land in order to meet the nation’s needs.

Christopher Katkowski KC’s review of the London Plan is an excellent assessment of planning in London and is relevant to urban areas elsewhere in the country.

The proposal that a presumption in favour of brownfield development should apply where housing delivery is below 95% is an excellent recommendation, and not just for London.

– Grant Leggett, Executive Director of Boyer

Budget comment

The Budget was notably short on fiscal incentives for housebuilding, support for first time buyers and a means to address housing targets - which must now rise to 385,000 pa according to analysis by Capital Economics, due to previous undersupply. To address this issue planning needs root and branch reform, not a mere tinkering at the edges and we had hoped for something more substantial. I am not convinced that AI can speed up local plan production. Essentially local plans are based on local engagement and local input. They must remain locally nuanced and cannot be created by an algorithm or by taking human contact out of the equation. I come into contact with the expression ‘democratic deficit’ all too often, and this would only be increased

– Pete Canavan, Partner, Carter Jonas n

A ‘toolkit’ for communities looking to create and manage green space has been launched by Planning Aid for London and consultants Ramboll, writes Lee Mallett

Free community guide to creating green space

Every square inch of London’s green space is precious, as anyone who has made a planning application that impinges upon it can tell you. But it is really daunting for local community groups to transform themselves into semi-professionals to even get to the point where they can project manage getting planning permission for something everyone would like to see created - never mind getting it built and managing it for a long time afterwards. Consent can be just the start of a whole new set of issues. It can be a mountain and not a molehill to climb for the uninitiated.

Which is why engineering, design and sustainability consultant Ramboll teamed up with Planning Aid for London to produce a new ‘toolkit’ for community groups setting out ‘steps needed to get a community green space planned, designed and growing’.

It has been produced in consultation with London community groups, planners and designers, and can be used anywhere in England, and includes guidance that is specific to London.

‘It fills a gap that Planning Aid for London had spotted,’ says Ramboll’s principal urban planner Rebecca Dillon-Robinson who lives in east London and has been involved with establishing community green space projects there.

application. In one space a community created, I was involved with, there was a long shipping container installed and it became desirable to move it to improve sightlines and people’s sense of security. But we couldn’t just move it because its location was a material planning condition. There is complexity to establishing green spaces that communities may not be aware of,’ she points out.

‘I’ve been working with the local community on Wild Green in Plaistow, E13 (images this page and overleaf), which was designated as community space,’ she says. ‘It’s a corner of a local park owned by the council and the community group manage it.’

‘A lot of these types of spaces are coming up. Sometimes they are abandoned parking lots or leftover or neglected spaces, and there may be some sort of CIL-funded mechanism to provide some money with the community voting which space they wish to adopt.’

‘The local authorities are challenged so they usually welcome the chance to facilitate the community taking it over. For the community, however, if you’re dependent on the local council to manage some of these spaces, you might not get the

All images are of Wild Green Community Garden, Plaistow, London E13

‘There is currently a big push for community gardens and green spaces to be created that is often community-led. But it can be very difficult to know where to start if you aren’t familiar with the planning system,’ she observes.

‘You have to find out how to speak to the police about security, for example. Discover and understand what all the material considerations are, what the planners need to know, how to present it all. This toolkit tries to bring all the issues into one plane for community members. It’s a capacity-building exercise.’

So why have Ramboll and Planning Aid for London teamed up? ‘Local authorities are so challenged in delivering things they really do welcome community initiatives, but it’s dependent on community groups’ capacity. But in the current climate of austerity it is unclear how a garden get delivered unless the local community did it themselves,’ says Dillon-Robinson.

‘We’ve tried to create a toolkit that alerts them to all the things they need to consider. Long term sustainability is the key. Understanding the context, what water source is there, what sort of planting will work best, orientation of things and furniture, security and sightlines, safety for women and children, lighting, accessibility. We are capacity- building and sharing knowledge with the toolkit.’

‘You have to use some forethought about where you place things, for example, and how that features in the planning

Lee Mallett is director of Urbik and joint publishing editor of Planning in London

outcome you want.’

‘The problem is there are a lot of “roadblocks” to work your way through. For example, you will need to talk to the police about tackling anti-social behaviour and for some groups that might pose some difficulties.’

‘I think there’s also some potential here for private developers to use the toolkit and help community groups tackle taking on their own bit of green space, or growing space. Especially now more of them are getting interested in delivering some social value impact.’

To remind PiL readers, Planning Aid for London, Ramboll’s partner in the venture, is a registered charity, founded in 1973 by the Town and Country Planning Association and members of the Royal Town Planning Institute.

With help from volunteer planners, architects, urban designers and other built environment professionals, it provides free advice and training to Londoners from underserved communities to help them to participate in and navigate the planning process and make a difference in their neighbourhoods.

Denean Rowe, Project Manager at Planning Aid for London, said at the toolkit’s launch: ‘It was great to collaborate with Ramboll on this. We know access to green space is important for good health and wellbeing. But many underserved communities in London don’t have adequate access to them. We hope the toolkit will serve as an important tool for groups to create and maintain green spaces in their neighbourhoods.’

Rebecca Dillon-Robinson again: “Being part of creating and

Community-led green space toolkit

Information for communities and individuals on how to plan and design green, sustainable and vibrant spaces for all to enjoy.

January 2024

maintaining a local green space can support communities to be more resilient and create a sense of local stewardship. Yet the planning system can be difficult to navigate, especially for our most disadvantaged communities, who are often time poor and for whom English is not a first language. If we want to create an equitable city, we need to ensure everyone can take part in the planning system and we hope this toolkit goes someway to achieving that.’

What’s in the toolkit

The kit, free online (see link below) divides into four sections: Planning and Governance, Designing and Engaging; a Checklist of key actions; and a section on Case Studies and Further Resources. It runs in total to around 26 pages – not too long, but covering all the bases.

Planning and Governance

The initial planning and governance section includes information on setting up your group, arranging insurance cover, health and safety regulations to consider, financial sustainability and fundraising, establishing a relationship with the landowner, and securing long-term protection for your green space. Or where it is due for redevelopment, community groups will need to

reassure the landlord that they can be confident the community will hand back the land at the point they’ve agreed to.

Strong plans that demonstrate community involvement, financial sustainability, and how maintenance will be managed into the future will be needed. And it is a good idea to plan in some education and outreach events that engage the landowner and the broader community. Buy in from the community results in fewer instances of damage or anti-social behaviour and helps strengthen community and a sense of place.

Whether or not the community’s plans will be regarded as ‘development’ and require permission is explained, and that there are currently no permitted development rights for community gardens. There is a sub-section devoted to achieving long term stewardship, by designing a plan with community maintenance in mind and arranging for an asset transfer of the space to the community, if that’s desired.

Design

On design, it covers who to engage, visioning, understanding your site – water, wind, daylighting, topography, soil, past uses, invasive species, users, and zoning your site into different areas before moving onto materials, accessibility, drainage

There is some useful advice on not getting fixated on one layout, but to explore as many different iterations quickly, then filtering the options to a few designs that will work, and then how to phase the garden so that it can evolve over time as funding and resources allow.

Material choices that deliver long term sustainability or use reclaimed materials and components (a link to recycling organisation ReLondon is included), accessibility issues, water and drainage, lighting and planting, biodiversity are all considered.

There’s also a checklist of the headline things you’ll need to think about to keep everything on track and a section on further resources to look up. The toolkit also includes a list of six case studies with links to their individual websites, including schemes in Brussels, Mexico and the US, if you need ideas from further afield,

Wild Green, Plaistow – the scheme Rebecca Dillon Robinson has been involved with, which cost £20,000, is also included link here), alongside schemes for Walworth Garden, Lambeth, a growing space (link here) and London’s pocket parks programme which ran from 2013-15, providing £2m to create more than 100 parks across 26 boroughs, ranging from community orchards to edible bus stops. Further information on the pocket park projects can be found here

Here's the link to the Community-led Green Space Toolkit –Are you planning a community-led green space?

Download the guide from Planning Aid for London here: https://tinyurl.com/dxwd7a22

The private rental sector has stopped growing, explains Jacqui Daly

Build to Rent delivers homes quickly and secures investment

The Future of Build to Rent Houses

to buy and renting for longer becoming more culturally acceptable.

The UK is not building enough homes to meet demand. This supply/demand imbalance means average house prices are nine times average earnings and it takes over 10 years to amass a housing deposit. If people cannot buy, they must rent. A comprehensive approach is needed to address the housing crisis across all tenures and build to rent can play an important role in meeting future rental demand.

What is single family housing?

The term ‘single family’ is an investor term for ‘build to rent houses’. In England and Wales, there are currently 5 million households renting privately according to the 2021 Census. Most privately rented homes are in the Buy to Let sector (4.9 million homes, 98%). This sector includes individual investors or small companies owning properties either with a mortgage (2 million homes) or owned outright without a mortgage (2.9 million homes).

The research found that local authorities prefer the term ‘build to rent houses’ because it is defined in national planning policy guidance which is easier to understand. It is an emerging segment of the rental market where new homes are funded by investors to let to households. Investors and advisors adopted sub-division with-

in Build to Rent: Multifamily (urban apartments) and Single Family Housing or Single Family Rental (suburban houses).

Investors in build to rent are driven by the requirement for income. Many are pension funds that are investing to receive an income that matches their liabilities (paying people’s pensions). Housing is a good match for this type of investor. It doesn’t provide enormous returns but it provides what pension funds need to match liabilities. UK pension funds are much more motivated by income, stability of income and growth through rents than capital receipts. This means that investors are less concerned about selling homes and the potential to switch tenures as they want investments that they can hold for a long time.

Why has single family / build to rent houses become so popular?

Build to rent houses have proven popular with young, middle income households with many people moving twice as far to secure the opportunity to rent one of these homes than in the wider PRS. They are generally newly built homes in suburban markets, on low rise housing developments that have good connectivity to schools and transport infrastructure. Nearly 90% of occupiers are under the age of 45 compared to 51% across the

Jacqui Daly is a housing market analyst in Savills Residential Research & Consultancy team

whole PRS and 57% in new build residential markets.

According to Savills’ survey, local amenities are the number one priority for tenants. In practice, this means proximity to local schools, green spaces and health services, given the high proportion of families living in build to rent housing developments.

In England & Wales the largest pool of rental demand is in suburban markets. It is increasingly difficult for prospective tenants to find opportunities to rent because the number of homes available to rent has reduced. What’s more, longer tenancies and people moving less frequently is contributing to the reduction in available supply.

What are the benefits?

There are a number of benefits to local authorities and their communities from securing investment in single family / build to rent houses. These benefits are around:

• Boosting housing delivery by enabling housebuilders to deliver a range of tenures at the same time

• Improving the amount of housing stock in the private rented sector that meets EPC C or higher

• Securing early investment in place and community infrastructure (e.g. schools, roads)

• Supporting multi-tenure delivery on large sites that helps to create mixed communities were people can put down roots and

move between housing options and tenures

• Accelerates housing delivery and provides rental homes that are affordable to local families

Large housebuilders currently provide the vast majority of build to rent homes, but delivery is just 0.5% of new supply. Housebuilders are keen to establish partnerships with investors on sites where they can deliver at the pace of build rather than sale. This can significantly boost housing delivery rates. Partnerships between housebuilders and investors helps to provide certainty around cashflow, decrease sales timelines and delivers a product that adds social value by creating communities that people want to live in.

At the same time, local authorities are recognising that the sector is adding decent quality homes to the private rented sector and that supply is needed to meet Government housing targets. The number of local authorities with single family build to rent homes within their residential development pipelines has more than doubled in the past five years to over 30%.

There are twice as many homes classified as non-decent in the PRS than in the social housing sector with improvement in the private rented sector is lagging behind other tenures. 72% of SFH homes have been delivered with EPC ratings of ‘B’ or above, whereas only 12% of existing privately rented dwellings meet this standard. 90% of investors we surveyed are targeting a minimum

of EPC ‘B’ across their portfolios, with 20% targeting a minimum of EPC ‘A’.

Part of the investor’s strategy for housing is delivering a mix of tenures on sites. There are very few sites coming forward that are seeking a mixed tenure planning consent. With an increasing proportion of the planning pipeline coming through as large sites, there is more that could be done to help deliver mixed tenure developments. This could take the form of identifying sites for mixed tenure delivery where there is a clear variety of local housing needs.

A key concerns for local authorities we interviewed is how to treat affordable housing. The main concerns were around the covenant, Discounted Market Rent (DMR) and the duration of the investment (in perpetuity). DMR is understood as an appropriate form of affordable provision on Build to rent developments, and the rents are frequently set at different levels to allow for a range of household incomes (and housing needs) to be accommodated. Local authorities were concerned that over time the DMR would switch back to market rent rather than another form of affordable housing. On build to rent housing developments we see two options that can work in practice:

Discounted Market Rent where the rent is up to 80% of local market rents and the units are provided throughout the development that are owned and managed by the investor with no nomination rights to the local authority.

Traditional 'Affordable Rent' where the rent is up to 80% and meets the local housing allowance. Taking this approach would meet Affordable Housing requirements; the units would be transferred to a Housing Association and the rent capped at Local Housing Allowance, inclusive of service charges. Affordable Rent and other traditional low-cost rented homes are subject to nominations and provision on-site will need to consider the design requirements to enable RPs to manage effectively.

Final thoughts

The PRS has stopped growing. Successive tax changes have sought to reduce the extent to which buy-to-let investors are active in the housing market. The effect of these changes is now evident from the reduction in the number of properties available to rent.

We project that up to one million households will need rental accommodation and the largest requirement is in suburban markets where over half a million rental homes and over £160bn of investment is needed to meet demand. With house builders actively trying to increase delivery with investors, Savills anticipates that the acceleration in the number of people and organisations active in delivering build to rent homes will increase overall housing supply. Further policy support and guidance will aid delivery as the sector grows. n

London could decline if we fail to resolve its risks and address its imperatives, says Greg Clark

London's next 30-year development cycle

No city has a right to perpetual success. Baghdad, Athens, Rome and Istanbul attest to the impermanent nature of even centuries long metropolitan glory. In recent decades Mumbai, Milan, Moscow, Hong Kong and San Francisco have felt the shudder of a sudden loss of status. Despite a very long cycle of recent success, London could also decline if we fail to resolve its risks and address its imperatives.

London: A Negotiated City

Deep in London’s DNA are core ideas about how we live together. Living by a major river requires certain obvious forms of cooperation; the management of tides, winds and water levels, protection of wharves and moorings, rules and codes through which to share space and much more. Living by a river requires a social contract between all those involved.

As population expanded around the Thames, the built environment became the key enabler of development. Bridges and wharves, markets and exchanges, homes and offices, and eventually railways, tunnels, airports and roads, enabled our expansion. The invention of the underground railway in London some 160 years ago, addressed our local development challenge, and created a global innovation that has now been adopted by over 200 cities world-wide.

London’s long history of negotiating its preferred place within the realm really took off in 1067 with the charter between Norman King William 1st and the City of London. The rights to trade and associate were enshrined in return for loyalty to the King. That is how we progress, through negotiation.

Since then, London has been through multiple cycles and that ‘contract’ has been tested and revised. Plague, fire, rebellion, war, battle, bombing, stink, smog, flood, contamination, and the losses of empire, industry, and population, have befallen the city on occasions. Yet London has proved resilient. London is not a planned or institutionalised city, it is that negotiated city. That means we can always renegotiate London. We have an inbuilt agility.

London has developed the capacity to enrich lives through connections, opportunity and experience. Anyone can become a Londoner, if they move to the city, as long as they adopt its ‘live and let live’ mindset and are open to its cosmopolitanism and quirkiness.

A new social contract for our new cycle?

We know that pandemics, wars, and natural disasters often reveal the underlying frictions and inequalities within civilisations and are therefore often followed by a new era of substantial reform, or might trigger an uncertain, and potentially long, cycle of decline. The overcoming of a major threat through collective action can lead to an increase in both

common purpose and social capital to address and resolve deep challenges that thus seem more achievable. After World War II we invented the National Health Service, guaranteeing healthcare for all people for the first time.

Our established social contract has been challenged by the COVID experience. It revealed immiseration of the people through unaffordable housing, insecure jobs, unfair treatment, unbreathable air, extreme inequalities and other sharp disparities.

London’s leadership in cycles of change

These moments of change are also opportunities to innovate anew. London brings important capabilities to such imperatives that have built up over time.

1 Drawing upon the endowments of nature, people in London have used the combined effects of a temperate fertile climate, an island location with a proximity to a major land mass, a westerly wind and an east facing tidal river, to embrace an outward perspective on the world that matured over time to become a strategic location between trading continents where London and its language, laws, codes, rules, media and institutions have developed an outsized influence in the world. The world looks to London, providing us with the opportunity both to lead and to magnetise engagement from beyond our realm

2 London’s long history of evolution and reinvention enables confidence toward change and the future, whenever there is adequate leadership and defined mutual interest. A city that has survived and prospered through multiple cycles is also likely to inspire expectation and confidence externally and will be more oriented towards embracing opportunities to change.

3 London’s sheer size, scale and diversity provides it both with a form of resilience, and a source of flexibility. Although all parts of London are somehow inter-dependent, they are also distributed in ways that foster independence in contrasting ways, enabling different things to happen at distinct times, in diverse parts of London. This provides a basic kind of security that reduces risk, and a fertile ground for distinctive innovations in diverse locations.

4 A unique strength of London is its social diversity. This brings people of many perspectives, backgrounds, languages, faiths, orientations, experiences and ages to our city. It provides human awareness, creative spark and global reach that aid change and support progress. It also means that solutions built in London can be relevant in multiple other globally diverse contexts.

5 At the same time, the scale of London has a mutually reinforcing dynamic: 8.8 million people, one million businesses, 6 million jobs and a £1.5 trillion asset base, create a powerful internal market, as well as an attractive hub for mobile popula-

tion, capital, ideas and businesses. This means London has the critical mass to make change without significant external input, leveraging its multiple forms of existing capital when required.

6 London is often a reference for what is new and emergent. For several centuries London has been a pioneer of modern society and economy. From establishing the rules of banking, insurance, media, stock markets, currency exchanges, fostering breakthroughs in science and technology, to producing iconic creative leaders in discovery, music, arts, literature, architecture and design, to codification of modern sports, London has defined new ways for new times.

7 London is the ‘scale up city’. London is both a trend-setting city and an innovation hub. It has an innate ability to take emerging ideas and approaches from across the world and to scale them in important ways. London has the open systems and market depth and dynamics to take great ideas and translate them into codes, systems, ventures, platforms and infrastructures.

Consequently, when faced with times of change, or shift, London is ready to take leadership to define new waves and even whole eras.

The Back Story

In the cycle before the last one, roughly from 1950 to 1980, London had been plunged into a deep post war decline. Bomb damage, population loss, deindustrialisation, growing calls for independence of colonial territories, fragile post-war finances, with a diminished place in the world, led to a London that was grey, drab and vexed. New York had emerged as the pre-eminent city of the mid 20th century. London was beaten.

Valiant attempts to renew London’s verve, such as the 1951 Festival of Britain (which first initiated the regeneration of the South Bank) would only find their true engine several decades later when globalisation triggered a new development cycle. But the revised post war social settlement did lead to expansion of public services including health (the NHS), transport, housing and education, with renewed infrastructure investment and rehabilitation. This eventually led to population stabilisation and then growth, with a new cycle of migration into London.

London’s hard power as an imperial capital rightly diminished, but its leadership and soft power in banking and finance, media, publishing and broadcasting remained strong, as did its universities. Deindustrialisation and unemployment fuelled edgy creative

ABOVE:

Image the City has recently released of the cluster in 2030

©City of London Corporation

and cultural production, most obviously in the punk scene of the 1970s. London’s role in the wider popular music of the time included the Rolling Stones, David Bowie, The Kinks and of course The Clash, whose anthem London Calling rehearses our DNA strapline: ‘We Live by the River’.

The Recent Cycle

In the last cycle (from c 1990 to c 2020) London gained vast new opportunity from accelerating globalisation in media, education, information, finance, services, IT and creative industries. The revised ‘contract’ was then about how a new ‘world city’ would serve the nation with opportunity, highvalue jobs, tax revenues, connections and foreign investment, through specialising in newly globally traded services, technology and creative content.

The idea was to let London grow and to assume that all would benefit. This recent cycle of globalisation led to massive reinvestment in London’s built environment at waterfronts and docks, markets, stations, stadia and the densification and diversification of successful business districts, combined with widespread regeneration of the period housing stock.

As the global cycle matured and required ‘hub cities’ in each continent, London’s bounce in the 90s and 00s led to rapid population growth and diversification, with it reclaiming its crown as one of the world’s great cities, consistently vying with New York for top status.As that cycle concluded, London confronted the major challenge of the Global Financial Crisis.

It took time for the full implications of this ‘world city model’ to be revealed. Whilst London prospered overall, and attracted new talent and massive investment, the gaps between London and the rest of the UK grew wider, and the inequality and affordability within London got markedly worse. The unintended consequence of globalisation in capital mobility was inflation in real estate prices in global gateway cities as capital flooded into them.

The New Cycle

Our new cycle is beginning. The COVID pandemic closed the constrained mini-cycle that had teetered forwards in a troubled way since the GFC, the Brexit vote and the anti-London sentiment of recent Conservative Governments. The Pandemic itself revealed in great detail the extremes of inequality and vulnerability in our city and made a powerful case for wider reforms in housing, air quality, health care, and public space.

London can now lead the world to build a new social contract that addresses planetary, social and spatial justice. This new social contract will be intolerant of high carbon living, and much more focused on access to clean air, healthy lifestyles and affordable housing. It requires a city that works for all its citi-

zens, not simply the high skilled or well paid. London must also take more responsibility for its relationship with other regions and towns, creating good neighbour policies and programmes and collaboration for mutual advantage across the nation.

This is London’s opportunity to define the new contract for a future 10-million-person city as we move towards a world of 10 billion people living in 10,000 cities, where multiple leadership models and proven practices of metropolitan success are needed. London can serve the global network of reinventing cities, by being a leader in urban innovation.

Shaping a Better City: A New London Agenda

In our modern world of ongoing rapid urbanisation and planetary peril, the built environment will only grow, thrive and succeed if it fosters the social contract that in turn enables it. The built environment is the fabric of the city. It is the places and spaces that enable shelter, consumption, interaction, mobility, trade, productivity, culture and collective experience. The built environment hosts the whole city and provides that city with its agility, flex and power to change, or with its force of resistance and rigidity.

The post-pandemic city is recasting urban value less about commuting and concentration and more around habitat, innovation and experience, underpinned by a fresh approach to place leadership. This is encouraged by a growing recognition of the potential of social capital and physical agility to both help us remake our city and also foster new forms of value. In London, our experience has been that the most successful reinventions of place have been ones where high social value has been central to the mission, leading to a high-trust and highconfidence equilibrium that has ‘crowded in’ diverse activities, people, communities and amenities, sucking in other forms of capital.

The built environment is core to the new social contract. It is an eco-system that can be agile, intelligent, sympathetic, inclusive, sustainable and resilient. It has personality. It is the active ingredient in urban change. We are shifting from the built environment as a collection of passive assets, to it being the city fabric that is dynamic as a platform, a service, and an experience.

No city has a right to succeed. In the long-run success of cities, the physical fabric is a secret weapon because it inspires human imagination, shapes other changes, and drives urban invention. No city can succeed without optimising its physical shape and built form to meet the needs of its people and the planet. If we don’t learn, and show, how to do this now, we face a long cycle of uncertainty and perhaps unmanaged decline. n

London’s continued success cannot be taken for granted. It will need focused investment and policy attention, says Jon Tabbash

Reversing London’s productivity slump

The UK is in poor shape, economically. Since the financial crisis, falling productivity growth has led to stagnant wages and living conditions – one analysis predicted that if we’d continued becoming more productive at pre-crisis rates, the average worker would be £10,700 better off every year. But although this is increasingly well-known, much of the conversation around the UK’s ‘productivity puzzle’ presumes that the capital is the one part of the country in relatively good health. As the region of the UK with the highest productivity and wages, there is a widespread assumption that London can be expected to chug along happily while we focus on revitalising left-behind regions.

The problem is that London has also experienced a distinct slowdown in productivity growth since the financial crisis – one that is key to the UK’s woes. Before the financial crisis, London enjoyed the highest productivity growth rate of any UK region. Every year from 1998 to 2007, the capital became nearly 3 per cent more productive – meaning we needed to do less work for the same amount of output. But from 2007 onwards, productivity growth flatlined. Rates have averaged 0.1 per cent - the lowest of anywhere in the country. Some of the challenges it faces are national, but not all.

ONS, Annual regional labour productivity

If the capital had maintained its previous performance, it would have been a third more productive in 2021. Up to the start of

the pandemic, continuing pre-financial crisis trends would have meant productivity in finance and insurance would have been over 50 per cent higher, in information and communication, over 40 per cent. The growth model with which London flourished before the financial crisis is no longer delivering the goods.

ONS, Annual regional labour productivity

It is hard to overstate how important productivity growth is to an economy. It is the key prerequisite for rising wages and, with them, buoyant tax returns to fund public services.

Although in terms of raw output, London recovered relatively quickly from the financial crisis, this was achieved by growing the number of people in employment – in simple terms, we threw more labour at the problem. Before the crisis, output had grown significantly faster than jobs. Afterwards, the situation was reversed. This meant productivity hit rock bottom.

Although some of the causes of that slowdown are national –low investment rates and policy uncertainty are problems across the UK – London has its own set of problems. For one, the capital’s economy is biased towards high-value services, like finance and IT, that have been particularly hard hit by the global downturn in trade and increasing risk aversion and deleveraging.

But crucially, London’s success has begun to create its own problems. Real estate is unusually expensive in the city, particularly for residential use. The marginal young worker, moving to

Jon Tabbash is a Senior Researcher at Centre for London

London, will rent privately – average rents now cost approximately 35 per cent of average incomes, the highest of any part of the UK. Those aspiring to own their own home face house prices 12.5 times the average salary – double the ratio seen 20 years ago.

Private rental affordability, England, Wales and Northern Ireland: 2022

Best estimates suggest that London would need to double the number of homes it builds every year for 15 years to fill the backlog of unbuilt homes and address our challenges with affordability and homelessness. If it doesn’t, the housing crisis will continue to drag down our ability to innovate and grow. Median incomes in London are 17 per cent above the English average, but housing costs in the capital reduce this to 7 per cent. Talented workers won’t be able to afford to live in the capital, and high-skilled migrants – the backbone of London’s high-productivity economy – will be attracted by other cities with a lower cost of living.

Our failure to fulfil housing demand during London’s boom years, as the population returned to growth and became more affluent, is one of the central causes of the rampant inequality generated over the 2000s and the poverty we are now plagued by, even after a vast expansion in employment. A fairer, more inclusive model of growth in the capital will have to address our housing shortage.

If we do not, it will eventually begin to affect London’s deep, diverse labour market and its ability to benefit from agglomeration effects – the positive productivity impacts of highly skilled people working in close proximity to one another. More than two thirds of London businesses polled in 2022 reported shortages in key skills (rising from 58 per cent in 2021), of which 31

per cent reported that skills shortages had lowered their productivity, so the importance of this agenda can’t be overstated. The staggering cost of real estate may have already attracted investment away from high-productivity uses – such as ‘intangible’ assets like intellectual property and software – to relatively lowutility uses.

Our planning and land use systems slow growth and adaptation. In the decade after 2013, the proportion of residential planning application decisions that were made within statutory time limits (without a performance agreement) fell from 78 per cent to 46 per cent in England. This is perhaps unsurprising, given cuts of nearly 60 per cent to public funding for planning departments on a per capita basis since 2010, causing a 50 per cent fall in expenditure on planning.

But the problem is not just resourcing. Restrictions on where homes are permitted in the first place are a significant part of our housing shortage. As the government has recently argued, encouraging development on brownfield sites can contribute to addressing this – Michael Gove’s recently announced ‘presumption in favour of development’ on such sites has been forecast to unlock over 11,000 homes a year. But such an approach has natural limits. Only 29 per cent of London’s 15-year housing need could theoretically be met using land on local authorities’ brownfield registers, much of which, in practice, is unviable for development. And in many cases, unlocking brownfield sites will not just require relaxing planning regulations, but investing into infrastructure. One need only look at TfL’s proposal to build 25,00030,000 homes in and around Thamesmead – an excellent opportunity that will require a relatively small investment to extend the Docklands Light Railway over the river. Investigating how land value capture could fund further expansions in the network must also be on the table. Planning is important, but it isn’t everything.

Transport for London, Extending the Docklands Light Railway to Beckton Riverside and Thamesmead.

We believe that the final piece of the puzzle is to be found in

London’s Green Belt. Although the Metropolitan Green Belt contains some areas of natural and ecological value, unlocking a small fraction of land outside these high-quality areas surrounding public transport stations could enable hundreds of thousands of new homes.

In partnership with representatives of local authorities of the Wider South East, through a revitalised system of strategic planning, the Mayor and national government could set up an expert commission to choose 10 sites in the Metropolitan Green Belt for development. New development corporations could purchase and assemble land, and masterplan urban extensions across these sites. They could use land value uplift from development to fund affordable housing, improvements to infrastructure, and investment into high-quality green space in other parts of the Green Belt.

But agglomeration isn’t just about housing. Transport allows workers living far from the city centre for commute in, deepening the capital’s labour market. And although London’s public transport system is by far the best in the UK, due to years of sustained investment and competent, integrated management by Transport for London, it is far from comprehensive. TfL’s data from 2019 showed that suburban rail in South London is a particular weak point – from 2010/11-2017/18, the London Overground saw 80 per cent of trains arrive on time, Southeastern only saw 62 per cent on its mainline and metro services, and Southern only 53 per cent. This leads to many South Londoners using slower bus services to reach Tube stations.

The creation of the London Overground in 2007, which replaced suburban rail services in North and East London, improved service reliability and frequency, leading to a boom in passenger numbers and enabling significant growth in housing around the network. A 2016 Centre for London study estimated that a similar programme in South London (known as 'metroisation') could provide an 130 per cent increase in capacity on the suburban rail network and accelerate the development of approximately 13,000 additional homes in south Central London, alongside enabling the creation of 3,000 extra homes through higher densities.

Investments like these will tackle the housing shortage, reducing the crushing burden of rent and house prices on Londoners, while enabling London’s labour market to keep growing in depth and complexity. It will allow the city to stay competitive in the international market for highly skilled talent, an essential requirement for succeeding in growth industries. And beyond its benefits to productivity, it will make the city fairer and more liveable.

London’s continued success cannot be taken for granted. It will need focused investment and policy attention, despite its political unpopularity. But it is a prize worth having.

In our recent report, Rebooting London’s Economy, we laid out the components of a new local industrial strategy to increase productivity growth in the capital – from the investments into housing and transport described above, to devolving power and finances to enable a new, locally designed skills and apprenticeship system. n

A huge demographic shift has implications at all levels of society, including housing policy and social care but governments struggle to as to how to respond, say Nicola Gooch and Oliver Knight

The case for seniors housing

The UK’s population is ageing rapidly. In 2023, approximately one in five of us were aged over 65. That equates to approximately 11 million people in England alone. According to ONS projections, by 2028, the 65+ population in England is due to increase by 9.9 per cent (approximately 1.3 million people). By 2043, it will increase by 30.5 per cent, which equates to an increase of 4 million people. This huge demographic shift will have implications at all levels of society, including housing policy and social care. And yet, despite the increasing urgency, both local and national government have historically struggled to get to grips with how to respond to it.

Historical trends

In 2017, we started to analyse and grade local plans for all local planning authorities (LPAs) in England based on their approach to housing for seniors. We assigned grades based on whether an LPA had either a policy for seniors housing in its local plan, and/or whether the local plan included site-specific allocations. That information was then supplemented by looking at wider demographic changes, recent seniors housing delivery, residential pricing, and housing wealth to produce an overall ‘opportunity score’ for seniors housing across England.

Whilst previous versions of the report showed slow, but steady, progress; the table below demonstrates that over the last two years the pace of change has stalled. Between 2017 and 2022, there was a 13.5 per cent increase in English local authorities that had both adopted planning policies and allocated sites for seniors housing. Between 2022 and 2024, the figure has not changed.

This static national picture masks an increasing number of regressions in the data. In our last survey, in 2022, thirteen local authorities had moved backwards when compared to their previous score. In 2024, the number of authorities whose position has regressed over the last two years stands at 34.

Since the last report was published, there has been unprecedented political turmoil, including two changes of Prime Minister, three Secretaries of State at DLUHC and six Housing Ministers. We have also seen major legislative and policy

changes to the English planning system. The Levelling-Up & Regeneration Act 2023 (LURA) entered the statute books and major amendments were made to the NPPF in December 2023. The last two years have also seen the publication of more than a dozen consultations seeking views on a wide variety of proposed reforms to the planning system.

Against that background, the policy inertia revealed in the 2024 Report is disappointing, but probably not surprising.

Green shoots of optimism

This year’s survey has not managed to escape the political storm, as it has been released in the run up to the general election. Which coincidentally, despite the current local policy inertia, seems to be bringing a sense of urgency over the need to get behind the sector to the national stage.

In terms of policy, the Government’s support for the sector has been recognised both in greater recognition in the NPPF itself, but also in LURA. LURA contains provisions which, when brought into effect, will place the Secretary of State under a specific legal duty to provide detailed guidance on how local authorities should plan to meet the needs of the elderly population. It also lays the ground for the introduction of National Development Management Policies (NDMPs), which would sit alongside, and it some instances, override, local plan policies. These have the potential to standardise the planning policy approach to seniors housing across England.

The Older Person’s Housing Taskforce is also set to publish its recommendations later this year, hopefully providing further political impetus for all political parties to support the need for more seniors housing.

This sense of optimism in the face of a difficult few years, seems to be reflected on the ground, with increased activity from existing providers and new entrants coming to the market. This has resulted in an overall increase in the supply of new senior housing stock across the UK. In 2023, more than 9,140 new seniors housing units were built, up 19 per cent on the previous year’s delivery and the strongest year for new supply since 2016.

The most popular of these development types that has

Oliver Knight is a Partner and Head of Residential Research at Knight Frank

Nicola Gooch is a Planning Partner at Irwin Mitchell

emerged over the past couple years are towards homes within Integrated Retirement Communities (IRC), which deliver larger communities with higher levels of services. In total, IRC schemes accounted for 58 per cent of new seniors housing units built in 2023.

The benefits of IRC schemes for residents and wider society are clear, with a growing recognition of the role that seniors housing can play both in improving quality of life for seniors and relieving pressure on the NHS and social care system. Research from the ExtraCare Charitable Trust found significant improvements in health and wellbeing among residents, for example, as well as a reduction in use of health care resources.

We are also seeing an evolution of the seniors housing model to cater to a broader range of residents. This includes a trend towards larger developments, for example, typically with 60-200 units. The planning pipeline suggests this will continue – there are 115 schemes with 100+ units in the planning pipeline, compared to 255 currently operational, the majority of which are social housing and built pre-1980. There is also increasing development activity in urban locations.

The data also points to a further increase in the provision of age-targeted rental product and shared ownership, as investors and operators look to offer seniors the broadest choice possible. Delivery of rental product is expected to increase further in the coming years, with analysis of the pipeline suggesting total private rental units will nearly double to just shy of 10,000 by 2027.

The need for progress

Yet, while delivery has picked up it remains significantly short of need. Even with recent progress development, annual delivery accounts for just 3 per cent of the total number of new homes built each year, despite the seniors age cohort accounting for the lion's share of past and future population growth.

As a reminder, there will be an additional four million seniors living in the UK by 2043, according to ONS projections. Over that time, the over-65 age cohort is expected to grow at three times the pace of the national average.

Whilst there has been progress in recent years, the latest analysis suggests that the rate of change has now stalled. With a third of local authorities still yet to adopt specific planning poli-

cies and site allocations addressing seniors housing, and 34 authorities having slipped backwards over the last two years.

Planning is, of course, just one barrier holding back delivery. Inflationary pressures have raised construction and operating costs over the last two years. The elevated cost of debt has posed another challenge for those needing to fund development. Nutrient and water neutrality issues, insufficient local government resources, and local plan failures add another layer of complexity in some locations.

And yet construction activity has been resilient. Analysis of planning data shows more new seniors housing schemes are coming forward. Around 200 new planning applications were submitted last year, roughly on par with 2022. Since 2022, some 270 schemes have received planning permission accounting for a potential 14,474 additional homes.

The appetite from new and existing market players to deliver more age-appropriate housing is clear. A more consistent and supportive policy environment will help unlock more supply, more propositions, and more choice for seniors.

Indeed, in our survey of the leading operators of Integrated Retirement Communities (IRCs) in the UK, 65 per cent and 55 per cent of respondents respectively highlighted better awareness of the seniors housing proposition from local planners, and clear targets for seniors housing in Local Plans as the two changes required to accelerate the growth of the seniors housing sector.

From a policy perspective the message is clear. The focus should not just be on building more homes; it is about building the right types of homes, and given the demographic changes that we are facing, many of those homes need to be targeted at seniors! n

Rowan Moore writes a powerful examination of how property shaped the modern world – and why it now threatens the freedoms and stability it was meant to sustain.

Reviewed by Nicholas de Klerk

£12.99 from www.faber.co.uk

Property: The myth that built the world

When I first picked up Moore’s new book, I assumed it had to be about housing. This assumption wasn’t entirely off the mark, and the cover illustration of brickwork in a stretcher bond hints at the crux of the argument which Moore sets out in the book. The subtitle too, suggests some of the inherent contradictions in this issue, characterising property as both myth and concrete reality.

In The Reality of Realty, Moore describes what I think lies at the heart of this contradiction. Using the popular Netflix series Selling Sunset as both case study and metaphor, he demonstrates that the very image of property is something of a mirage – a compelling and in some ways addictive illusion that has become tied into our very sense of being, of achievement and of place in society.

And yet, as the value of property as an asset class quickly outstrips the ability to earn a living in order to afford it (as it has in the last generation) – the very idea of labour as a means of improving your situation is untethered from anything we might recognise as objective reality. If this sounds like the roots of anarchy, then the opposite side of the equation offers no succour.

In Britain’s ‘property owning democracy’ – a phrase coined by MP Noel Skelton over a century ago, and one which bookended Margaret Thatcher’s prime ministership – the stability of the property market depends on ever inflating values; increasingly so given the schism between houses as places to live versus as an asset class. This has been achieved over at least the last couple of generations, with intermittent and minor corrections, at the expense of new entrants to the market, to the point where gaining entry depends largely on intergenerational wealth, known colloquially as ‘the bank of mum and dad’.

Anyone making an investment is generally warned that they risk making a loss or a return, but oddly not property which, as a concept in which we are both politically and socially invested, is a project that cannot be allowed to fail. If this sounds like a ponzi-scheme in all but name, we need only look at the last global financial crisis which originated in the US sub-prime mortgage market, and which underpinned the use of ‘opaque and complex’ Collateralised Debt Obligations or CDO’s which in turn relied on ever inflating values.

sense. This becomes dangerous nonsense when it starts to imply risks to individual rights in a democratic society. It is instead indicative of a property market and wider society that is deeply unequal, and which provides barriers to entry to those not already invested; a rentier economy that instead of growing and creating more opportunities for a (still) growing population, seeks instead to control more and more of a flatlining or shrinking economy within the hands of fewer and fewer people.

It is, however, in medieval England in the feudal late fifteenth and early sixteenth centuries where, as Moore sets out, the modern concept of property first emerges. The first enclosures dismantled the hitherto feudal system of tenancies and commons into one of enclosed pastures that ‘transformed the economy from one based on the exchange of services into one based on money, in which everything had a price.’ This concept of property,

Moore describes later in the book, is a legal construction, ‘a set of invented ideas, practices and laws that seek to manage fundamental questions of territory, shelter, and survival. It also, inevitably, sets up power relations between those who own and those who don’t, which also proved useful in the colonies of the new world in order to claim land conveniently identified as ‘empty’.

This is a brief canter through a complex topic which Moore explores in far greater detail, but it is astonishing that something which has become so fundamental to the way in which we organise our lives remains relatively unexamined. Is this perhaps because the status quo is so entrenched that there seems little point in speculating on alternatives? For the same reason, it is also easy to become disheartened by the status quo, unless you are or stand to become one of the system’s lucky beneficiaries.

Rowan Moore is the awardwinning architecture critic of the Observer and author of Slow Burn City (2016) and Why We Build (2012). He was formerly Director of the Architecture Foundation, architecture critic of the Evening Standard and editor of Blueprint magazine.

Moore spends the first chapter of the book setting the broader historical context of this out in extensive and fascinating detail, examining historical episodes across the globe, such as Kinloch, Missouri, Levittown, Thatcher’s sale of council houses in the UK, real estate markets in Las Vegas and Los Angeles, as well as Gurgaon in India.

Linking universal franchise with property ownership, indeed with moral character, as Skelton did, is fraught with issues. It implies that those either unable or perhaps unwilling to secure a place on the property ladder must then be in possession of some kind of character flaw, which is, of course, patent non-

What is also clear is that the current political settlement is out of ideas, aside from thinly ideological gimmicks like help to buy (or indeed, right to buy before it), as well as housing targets that government after government has failed to reach. It is this scenario that Moore explores in the last section of the book, What Else Could There Be? Examining more modern notions of the ‘commons’ in new towns such as Milton Keynes, cooperative developments in New York and Vienna, as well as Britain’s council housing programme, Moore demonstrates that even within this status quo there are examples, which offer alternative ways of living – to differing degrees of success.

It seems there is no universally fair way of righting this system in a way that neither penalises those who have nor those who do not. Unless, and at the risk of coming over a little polemical myself in this election year, the incoming government has the courage to revisit the idea of a wealth tax. This would doubtless a harder sell than repealing non-dom status, as it could potentially affect ordinary people, but as a recent report by the LSE notes: ‘Governments have made radical

changes to taxes when there has been public understanding that change is needed.’

Assuming, then, that this revenue was hypothecated to a fund that improved the quantity and quality of, as well as access to, housing across the country, the debate would take on a different complexion. It’s something of an irony that in this market, the UK has produced so very many excellent housing architects who could help with this. Easing the chokehold that supply has on both the availability and cost of housing through providing alternative types of accommodation and forms of tenure (the value of which is retained as sovereign wealth) would benefit everyone, it seems, apart from those who have a vested interest in maintaining an unequal status quo.

What is clear, however, is that something must be done. That process starts with a better and much broader understanding of the challenge (as well as the possibility of change) amongst the electorate, which is where books like this offer invaluable insight. n

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 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 Planning and Building Control 2 Bristol Avenue Colindale

London NW9 4EW

020 8359 3000

Fabien Gaudin Head of the Planning Service

020 8359 2000

There are 3 area teams

Lesley Feldman is head of the Finchley and Golders Green area team lesley.feldman@barnet.gov.uk

London Borough of Bexley Civic Offices

Broadway Bexleyheath DA6 7LB

020 8303 7777

www.bexley.gov.uk/planning

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

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

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

020 8937 1764

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

020 8937 2704

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

020 8937 5344

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

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

Lisa Thornley Development Control Support Officer

lisa.thornley@bromley.gov.uk

London Borough of Camden Town Hall Extension Argyle Street WC1H 8EQ 020 7974 4444 www.camden.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

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

Town Clerk and Chief Executive

John Barradell OBE john.barradell@cityoflondon.gov.uk 020 7332 1400

Director of the Built Environment

Ms Carolyn Dwyer carolyn.dwyer@cityoflondon.gov.uk 020 7332 1600

Gwyn Richards

Chief Planning Officer and Development

Director

gwynrichards@cityoflondon.gov.uk

020 7332 1700

London Borough of Croydon Development and Environment

Bernard Weatherill House

8 Mint Walk, Croydon CR0 1EA

020 8726 6000

www.croydon.gov.uk/

planningandregeneration

Chief Executive

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

Director of Planning and Strategic Transport

Ms Heather Cheeseborough heather.cheeseborough@croydon.gov.uk

Director of Development

Colm Lacey colm.lacey@croydon.gov.uk 020 8604 7367

Head of Building Control

Ric Patterson richard.patterson@croydon.gov.uk

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

Director of Regeneration and Planning

David Moore moored@ealing.gov.uk

Executive Director of Environment

Keith Townsend townsendk@ealing.gov.uk

020 8825 5000

Director of Safer Communities and Housing

Mark Whitmore

whitmorem@ealing.gov.uk

020 8825 5000

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

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 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

Royal Borough of Greenwich

The Woolwich Centre

35 Wellington Street

London SE18 6HQ

020 8921 6426

www.royalgreenwich.gov.uk/planning

Acting Chief Executive

Ms Debbie Warren

debbie.warren@royalgreenwich.gov.uk

020 8921 5000

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

Planning in London

Chief Executive

Tim Shields

tim.shields@hackney.gov.uk

020 8356 3201

Assistant Director of Planning and Regulatory Services

John Allen john.allen@hackney.gov.uk

020 8356 8134

Head of Spatial Planning

Randall Macdonald

020 8356 8051

Director of Regeneration

John Lumley

john.lumley@hackney.gov.uk

020 8356 2138

London Borough of Hammersmith & Fulham

Hammersmith Town Hall

Extension King Street

London W6 9JU

020 8748 3020 www.lbhf.gov.uk

Chief Executive

Ms Kim Dero kim.dero@lbhf.gov.uk

020 8753 3000

Head of Planning Regeneration

John Finlayson john.finlayson@lbhf.gov.uk

020 8753 6740

Head of Policy & Spatial Planning

Pat Cox pat.cox@lbhf.gov.uk

020 8753 5773

Head of Development Management

Ellen Whitchurch ellen.whitchurch@lbhf.gov.uk

020 8753 3484

London Borough Of Haringey Level 6 River Park House

225 High Road Wood Green London N22 8HQ

020 8489 1400 www.haringey.gov.uk

Director for Housing, Regeneration & Planning

Dan Hawthorn dan.hawthorn@haringey.gov.uk

Assistant Director for Planning, Building Standards and Sustainability

Emma Williamson emma.williamson@haringey.gov.uk

Head of Planning Policy, Transport & Infrastructure

Rob Krzyszowski rob.krzyszowski@haringey.gov.uk

Head of Development Management

Dean Hermitage dean.hermitage@haringey.gov.uk

London Borough of Harrow PO Box 37

Civic Centre Station Road

Harrow HA1 2UY

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

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

01708 433100 www.havering.gov.uk

Chief Executive

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

Planning Control Manager

Helen Oakerbee helen.oakerbee@havering.gov.uk 01708 432800

Planning and Building Control

Simon Thelwell simon.thelwell@havering.gov.uk 01708 432685

Development & Transport Planning

Martyn Thomas martyn.thomas@havering.gov.uk 01708 432845

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

Head of Planning & Enforcement

James Rodger

james.rodger@hillingdon.gov.uk 01895 250230

Head of Major Initiatives, Strategic Planning & Transportation

Jales Tippell

jales.tippell@hillingdon.gov.uk 01895 250230

London Borough Of Hounslow Civic Centre Lampton Road

Hounslow TW3 4DN

020 8583 5555

www.hounslow.gov.uk/planning

Chief Executive

Niall Bolger niall.bolger@hounslow.gov.uk

020 8770 5203

Strategic Director of Housing , Planning & Communities

Peter Matthew peter.matthew@hounslow.gov.uk

Head of Development Management

Marilyn Smith

marilyn.smith@hounslow.gov.uk 020 8583 4994

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

Service Director of Planning & Development

Karen Sullivan karen.sullivan@islington.gov.uk 020 7527 2949

Team Leader for Planning & Projects

Eshwyn Prabhu eshwin.prabhu@islington.gov.uk 020 7527 2450

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

Royal Borough of Kensington and Chelsea

The Town Hall

Hornton Street London W8 7NX

020 7361 3000 planning@rbck.gov.uk

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

Royal Borough of Kingston Upon Thames Guildhall 2

High Street

Kingston Upon Thames

KT1 1EU

020 8547 5002

www.kingston.gov.uk/planning

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 Lambeth

Phoenix House

10 Wandsworth Road

London SW8 2LL

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

Chief Executive

Ms Janet Senior janet.senior@lewisham.gov.uk

020 8314 8013

Development Manager

Geoff Whittington geoff.whittington@lewisham.gov.uk

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

Director of Environment and Regeneration

Chris Lee chris.lee@merton.gov.uk

020 8545 3051

Director of Community and Housing

Hannah Doody hannah.doody@merton.gov.uk

020 8545 3680

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

Director of Commissioning (Communities, Environment & Housing)

Simon Litchford QPM simon.litchford@newham.gov.uk

London Borough of Redbridge 128-142 High Road

Ilford London IG1 1DD

020 8554 5000

www.redbridge.gov.uk/planning

Chief Executive & Head of Paid Service

Andy Donald andy.donald@redbridge.gov.uk

Interim Head of Planning & Building Control

Ciara Whelehan ciara.whelehan@redbridge.gov.uk

Head of Inward Investment & Enterprise

Mark Lucas mark.lucas@redbridge.gov.uk

020 8708 2143

London Borough of Richmond Upon Thames Civic Centre

44 York Street Twickenham TW1 3BZ

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

Chief Executive

Paul Martin

paul.martin@richmondandwandsworth.gov.uk 020 8871 6001

Director of Housing and Regeneration

Brian Reilly brian.reilly@richmondandwandsworth.gov.uk

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 Southwark 160 Tooley Street London SE1 2QH

020 7525 3559

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

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

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

Chief Executive

Helen Bailey helen.bailey@sutton.gov.uk

Assistant Director, Resources Directorate (Asset Planning, Management & Capital Delivery)

Ade Adebayo ade.adebayo@sutton.gov.uk 020 8770 6349

Strategic Director of Environment, Housing & Regeneration

Mary Morrisey mary.morrissey@sutton.gov.uk 020 8770 6101

Executive Head of Economic Development, Planning & Sustainability

Eleanor Purser eleanor.purser@sutton.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

The London Borough Of Waltham Forest Town Hall London E17 4JF

020 8496 3000

www.walthamforest.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

The London Borough of Wandsworth Town Hall

Wandsworth High Street London SW18 2PU

020 8871 6000

www.wandsworth.gov.uk

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

Mark Hunter

mhunter@wandsworth.gov.uk

020 8871 8418

Head of Forward Planning and Transportation

John Stone jstone@wandsworth.gov.uk 020 8871 6628

City Of Westminster

Westminster City Hall

64 Victoria Street London SW1E 6QP

020 7641 6500 www.westminster.gov.uk

OTHER ORGANISATIONS

Greater London Authority City Hall

Kamal Chunchie Way

London E16 1ZE

020 7983 4000 www.london.gov.uk

Sadiq Khan Mayor of London mayor@london.gov.uk

020 7983 4000

Greater London Authority Executive Director, Good Growth

Philip Graham

Assistant Director, Planning (GLA) and City Planning (TfL)

Lucinda Turner

Head of Development Management

John Finlayson

Head of the London Plan and Growth Strategies

Lisa Fairmaner lisa.fairmaner@london.gov.uk

Planning Change Manager

Peter Kemp

Chief Executive Stuart Love slove@westminster.gov.uk 020 7641 3091

Director of Planning 020 7641 2519

Head of City Policy and Strategy

Barry Smith bsmith@westminster.gov.uk 020 7641 3052

Urban Design London Palestra

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

Planning Officers Society

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

Design For London City Hall

Kamal Chunchie Way, London E16 1ZE info@designforlondon.gov.uk

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Joanna Averley, director, chief planner chiefplanner@levellingup.gov.uk

Sarah Allan, head of design designquality@levellingup.gov.uk

Simon Gallagher, director, planning

The Gerrard Arcade

Willingale introduces his vision for a new arcade in London that resolves a 346-year-old problem in the urban grain of the West End

There is a case for a new arcade in London that resolves a 346year-old problem in the urban grain of the West End by providing new connectivity and infotainment between Soho and Leicester Square: the Gerrard Arcade.

The problem

The 17th century Military Ground, used for military training and parade, was an open area of two and three-quarter acres enclosed by four walls between King Street and Leicester House. Nicholas Barbon, responsible for the financial innovation of leasehold development in London following the Great Fire, turned his early profits to developing terraced housing west of St. Martin’s Lane telling his ally, the property lawyer Roger North, “it was not worth his while to deal little; that a bricklayer could do.” In July 1677 Barbon purchased a 51-year lease of the Military Ground from Lord Gerard along with some other land. He demolished the walls to the north, east and west but kept that to the south, as it formed the boundary to the grounds of Leicester House built in 1635 by the Earl of Leicester on land the earl had enclosed in the Parish of St. Martins-in-the-Fields. Barbon laid out Gerrard Street across the middle of the Military Ground parallel to the boundary wall and divided up the south side into plots to be developed first for the larger houses. He needed to improve access without

relying on the existing streets east and west including the notoriously narrow Whitcomb Street on the route of Wardour Street. His solution was to form Macclesfield Street, a tribute to Lord Gerard who became the Earl of Macclesfield, aligning this north across King Street to Dean Street to provide access through the area being developed by Henry Compton and Richard Frith across Soho Fields to the main thoroughfare of the Tyburn Road.

The area evolved to become Soho and the main thoroughfare was soon to acquire the name Oxford Street. Barbon started building some of the larger houses himself, including Gerard House for Lord Gerard facing north along Macclesfield Street, and leased other plots to builders including sites for smaller terraced houses on the north side. Completed in eight years, Gerrard Street was a successful development becoming part of Soho connected north to Oxford Street.

In the meantime the Leicester Estate to the south had begun to develop land around Leicester Fields. To the northeast the grounds of Leicester House were laid out with modest plots in 1682-83 for the development of terraced houses on Leicester Street, Sidney Street and the western end of Lisle Street. Leicester House was demolished c1791-92 for the continuation of Lisle Street east to Little Newport Street and for the development of Leicester Place south to Leicester Square. So by the late 18th cen-

Mark Willingale is principal of Willingale Associates

tury the grid of streets between Soho Square and Leicester Square had been established, with Gerrard Street and the former Military Ground south boundary wall dividing those looking north to Oxford Street from those looking south to Leicester Square. The only other significant change to the pattern was the Metropolitan Board of Works 1877 – 86 development of Shaftesbury Avenue incorporating King Street between Piccadilly and St. Giles. This eased congestion by opening a new route between the West End and the City, becoming the focus of theatreland, but the busy route tended to increase the separation of Soho to the north from Leicester Square to the south.

Earlier in the 19th century Leicester Square had first attracted the development of music halls and theatre to emerge as the centre for entertainment this continuing through the 20th century with cinema, casinos and venues for tourists. From the 18th century the Chinese in London had settled beside the Docks in the East End. This community was dispersed by the bombing of WW2 and from the 1970’s a new focus formed in Soho south of the Shaftesbury Avenue to become

Chinatown around Gerrard Street.

The districts of Soho and Leicester Square evolved to become the West End we know today, still divided by the former boundary wall of the Military Ground, resulting in poor north-south connectivity. Gerrard Street forms a barrier between Soho and Leicester Square and regularly experiences some of the highest footfalls in the metropolis, with Wardour Street and Newport Place often becoming congested, sometimes dangerously so, requiring pedestrian flow management during festivities like the Chinese New Year. In contrast, only a block to the south, unsupervised areas of Lisle Street behind the Empire Leicester Square provide a haven for anti-social behaviour on the northern fringe of the Leicester Square entertainment and tourism district.

The proposal

Nos. 32-35 Gerrard Street including the site of Gerard House and 8-10 Lisle Street were redeveloped as a post office and telephone exchange designed by

Leonard Stokes that opened on 28 September 1907. This was the first building to breach the former Military Ground boundary wall and have fronts on both streets. With demand for telephony soaring Stokes’ building was replaced in 1935-37 by the current building by Frederick A. Llewellyn, two storeys higher with matching grey granite arcades on the ground floor fronts, eight arches for Gerrard Street aligned with seven for Lisle Street. Ninety years later and the telecommunications functions are now mostly located on the roof leaving the space below free for alternative uses. The China Exchange, a venue for the promotion and exchange of Chinese culture in the UK and Silver Time, an adult gambling venue, occupy five of the arches on Gerrard Street, leaving three on this frontage, and the end arches on Lisle Street provide access to the other floors leaving five on this frontage still part of the telephone exchange and free for use subject to internal re-arrangement.

Here is the opportunity to create the Gerrard Arcade, with a high pedestrian flow, by providing a new north-south connection between Soho and Leicester Square through the Telephone Exchange on Gerrard Street, making good use of the existing architectural composition. The arcade is realised by linking the arch on Gerrard Street beside Silver Time through the ground floor to the central arch on Lisle Street without requiring other alterations to the elevations or to the China Exchange and Silver Time leaseholds. A small change in levels between the streets is accommodated within the plan by a shallow ramp to Lilse Street.

A traditional arcade with barrel vault is illustrated but within the building the proposed space can be free-form and include immersive technology, like the Outernet Now Building, for display and entertainment. Blinding of electronic dis-

plays by direct sunlight is prevented by the orientation of the arcade and the streets enclosing each end. On the rear wall of the Empire Leicester Square in Lisle Street an axial mirror doubles the virtual vista and reflects the experience. Immersive screens on the east side can be used for advertising products and services with inputs from the China Exchange and Silver Time. Boutiques on the west side and the Lisle Street frontage can include access to available areas in the basement and on the first floor. The arcade spaces and adjoining areas can be lined with screens to become separate immersive experience rooms. Hence the arcade can provide seamless or cellular immersive experiences to generate revenues from the display of products and services in addition to advertising and retail use. The minimum area required on the ground floor to complete the pedestrian link is the arcade itself, along with a small area for the site manager, IT equipment and security. The arcade can be shuttered at night, as deemed appropriate for security and insurance, or during times when telecommunications equipment is being raised to the upper floors and roof from Lisle Street, as occasionally required to update BT operations.

The Gerrard Arcade opens a direct new route north to Soho and Oxford Street and south to Lisle Street and Leicester Square. Congestion in Gerrard Street, Wardour Street and Newport Place is relieved and currently anti-social parts of Lisle Street become well frequented and supervised. With a capacity of up to 10,000 people per hour many will find the arcade an efficient and entertaining new route between Soho and Leicester Square throughout the day and late into the evening, a route that provides an immersive experience while introducing them to the products and services of Chinatown, China, London and the UK. n

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