IS IT TIME TO BRING BACK COUNCIL HOUSING? Brian Waters page 14; Will Labour London have a heart? Lee Mallett page 12; On colouring the Green Belt, Andrew Rogers page 67; London’s electrical grid, Barny Evans page 70; Changing commuting patterns, Ciaran Gunne-Jones page 72; BOOKS p75: Our Housing Disaster by Julian Richer; INTERWAR British Architecture by Gavin Stamp
page 84
London of the Future is a once-in-a-century publication from the London Society. The 昀rst edition was created in 1921 and proposed such ‘radical’ ideas as a green belt around London and a tunnel that would connect London to France.
100 years later, we asked a group of experts what could and should happen to London in the coming years and the responses have included natural solutions, different scales of economy, new forms of governance, better local food production, a radical rethink of education, improved housing provision and even dabbling in arti昀cial intelligence.
Contributors include: Anna Minton, Carolyn Steel, Claire Bennie, Baroness Lawrence, Gillian Darley, Grafton Architects, Hugh Pearman, Indy Johar, Jude Kelly, Kat Hanna, Mark Brearley, Mark Stevenson, Neal Shasore, Roma Agrawal, Sarah Ichioka, Smith Mordak, Tony Travers and Yasmin Jones-Henry.
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LONDON PLANNING & DEVELOPMENT FORUM
PIL 130 CONTENTS
Design codes, Old Kent Road, PD changes of use and the City Plan 2040, from page 42 PAGE
5 LEADERS
Up the Old Kent Road!
Exciting times ahead
7 Opinion: The Planning Premium | Brian Whiteley
8 PAUL FINCH
The City 2040: perspiration outweighs inspiration
12 LEE MALLETT
Will Labour London have a heart?
14 BRIAN WATERS
Is it time to bring back council housing?
16 From the London Society | Rob Fiehn
OPINIONS
17 Flexible offices | Piers Townley
18 Getting Britain building again | Ben Standing
20 Brownfield sites | Andrew Golland
22 Not ‘Brownfield Only’ | Nick Taylor
23 Housing Delivery| Katy Davis
24 Gentle density | Grant Leggett
25 Green Belt review | Ian Barnett
26 New Towns and Music Venues | Simon Ricketts
28 Scope 3 emissions (Finch) | Ben Standing
29 Permitted development rights | James Doherty
30 Youth and planning | Katherine Jones
31 Rights of Light | Paul Greatholder
34 BRIEFING
CLIPBOARD: Chancellor Reeves: “We are going to get Britain building again”; Angela Rayner and Matthew Pennycook appointed; Tallest City tower decision delayed; Elevated views prove popular; London boroughs top lowest approval rates; Labour should overhaul planning; Reflect the genius of our age; Legislation, not taxation; System-wide failure; Carbuncles; Carbuncle Cup; Our corrupt planning system needs rebuilding
38 PLANNING PERFORMANCE
Decisions down 11 per cent and decided down 9 per cent over the past year
Continues next page
GREEN BELT: Ian Barnett p25 & Andy Rogers p67
42 LONDON PLANNING & DEVELOPMENT FORUM Design codes, Old Kent Road, PD changes of use and the City Plan 2040
43 Design codes
57 Permitted Development Conversions from Offices to Homes
60 City Plan 2040 – is it a model for authorities to focus on branding?
67 ANDREW ROGERS on colouring the green belt
69 ¡PILLO!
The God of Boring; Peter Bill in Property Week; London is the brightest jewel; Coping strategies
FEATURES
70 London’s electrical grid | Barny Evans
72 Changing commuting patterns | Ciaran Gunne-Jones, Emma Taylor and Ed Welch
BOOKS
75 Our Housing Disaster | Julian Richer
76 INTERWAR British Architecture 1919-39 by Gavin Stamp reviewed by Jeremy Melvin
79 Look Here - On the Pleasures of Observing the City by Ana Kinsella
81 PLANNING AND ENVIRONMENT REFERENCE GUIDE
84 SUBSCRIPTION ORDER FORM
85 SHAPING THE WORLD
Forging a deliverable zero-carbon blueprint | Paul Finch
ISSN 1366-9672 (PRINT)
ISSN 2053-4124 (DIGITAL)
Issue 130 JULY-SEPTEMBER 2024
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OKR shows that planning can be the friend of enterprise and the community
Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992
LEADERS
Up the Old Kent Road!
The Old Kent Road is ‘not any old road’, says page one in Southwark Council’s ‘Mini Area Action Plan’. Being London’s oldest road link to Europe, it certainly isn’t any old road, but there is nothing ‘Mini’ about the transformation underway.
While TfL dithers over the Bakerloo Line extension to what used to be one of the two poorest addresses on the Monopoly board, the extension’s route is thankfully safeguarded. The last six years or so have seen, despite the dithering, Covid, and Liz Truss’s Bonfire of the Viabilities, a host of new tall, mid and lower rise proposals for housing and commercial space should spring upassuming viability can be revived.
Now that all local authorities are required by the NPPF to use ‘local design codes’ as the tools ‘to assess and improve the design of development’, Southwark’s Council’s approach to planning the Old Kent Road Opportunity Area, offers an interesting twist on what a ‘code’ might do, or how development might be guided.
Chief Planner Colin Wilson gave an explanation of how planners are managing the ‘design’ of development down the Old Kent Road as part of a discussion on design codes at June’s meeting of the London Planning and Development Forum (see pages 42-66).
The Mini Area Action Plan has interesting lessons for London’s 46 other Opportunity Areas. The implication being that authorities need to establish a vision first with communities, before producing more detailed ‘design codes’ required by the NPPF.
‘In London, public authorities have to take the lead in guiding development, otherwise it will be a free-for-all,’ he suggested to attendees at the Forum.
Most people probably believe ‘free for all’ was the Conservative’s idea of what planning should be – ie market driven – or otherwise it becomes, as David Cameron put it back in 2010, ‘the enemy of enterprise’.
But then the Conservatives came a cropper in leafy Aylesbury precisely because instead of ‘planning’ carefully where to build they attempted to impose ‘targets’ on local authorities.
Southwark’s approach to OKR is that spatial design can be much more important and influential in the early stages than a detailed design code rooted in local vernacular – which many such codes may aspire to.
‘The Old Kent Road Mini AAP is a strategic design idea. We want to try and engage local people with the bigger picture. It’s rather like an outline planning permission for the Old Kent Road - a strategic area vision.
‘These are the foundations of the [planning] system we all work in, after all. The state owns the development rights under the 1947 Act. And land use is an absolutely key design consideration.
‘We never intended to produce a prescriptive design code,’ to govern development down the Old Kent Road, says Wilson. ‘We wanted instead to provide some direction, but to also leave ‘wriggle room’ to encourage and incorporate better ideas.’
Members and local people are generally supportive of the vision that has emerged for Old
No planning policy or decision should duplicate or overlap with other regulation or legislation
Kent Road, said Wilson, with 3,300 new homes proposed of which 1,800 are under construction. A tall buildings strategy is in place reshaping the urban form of the area and slowly recovering underused land lost to car-driven, low density uses that, didn’t resolve the area’s post-industrial problems.
An ‘audit of delivery’ on the OKR Area Action Plan will demonstrate to locals that the plan is delivering what’s been agreed to. Local engagement has been ‘critical’ to the whole process and Wilson prefers the term ‘framework’ rather than ‘code’ to describe what’s been achieved. For his planning team, the engagement process has been ‘an eye opener’. The AAP will get a design code, he said, which is being worked up. It will be ‘highly visual’, and provide advice, for example, on how you can have ‘beds and sheds’.
The one big result for locals is that where there had originally been an emphasis on offices in developers’ aspirations, local feedback early on ensured this was switched to tackle the need for homes.
‘Planning’ in this instance, Mr Cameron, has been the friend of enterprise and the community, it might be argued. n
Exciting times ahead
The new government promises a draft new NPPF by the end of this month and to bring it into effect in October. Headlines suggest this is about re-introducing housing targets but it presents the new government with the opportunity to match some of its electioneering rhetoric about reforming and speeding planning. There will be no shortage of pundits and editorials urging this or that reform, and here is one for starters.
An immediate change to the NPPF to bring back the following provision: “No planning policy or decision should duplicate or overlap with other regulation or legislation". Rather than responding to the universal cry that planning departments are under resourced and short of skills (though true), a more practical and immediate fix would be to reduce the burden imposed on the development management process. At both the plan making level and in development management the system should be stripped back to land-use planning and only directly related matters.
Unless very special circumstances apply, inspectors should not allow either local plans or development proposals to go into technical or measurable matters which are covered by building regulations, environmental legislation and other controls. In so far as they are relevant, they should be dealt with by condition and planning officers should not be expected to have the skills or the time to address these matters or to bring in consultants where they stray beyond the immediate land-use impact of a policy or development. This change will apply to such things as viability assessments as well as biodiversity net gain while immediately relevant matters such as the long established consideration of daylight and sunlight and of traffic will remain within the purview of Development Control.
This change is likely to be seen as something of a culture shock and may meet resistance, especially from the plethora of consultants who have emerged to feed the system or be fed by it. It also adds considerable risk to the developer. The number of planning permissions which prove to be unbuildable for non-planning reasons will increase and so it is up to the developer and their consultants to assess those risks and maybe to commission their own feasibility assessments on technical matters when producing proposals before making planning applications.
Enforcing this change will have the immediate effect not only of speeding up the consideration and processing of planning applications but also of simplifying local plans and making them more easily kept up to date. It will be the responsibility of applicants to ensure that permissions they seek are actually buildable rather than expecting unqualified planning officers to assess objective matters which have little to do with land-use planning. This will release resources and reduce the need to increase the number of planning officers to the impossible levels implied by politicians' pronouncements. n
The Planning Premium: The Value of Well-made Places
By increasing housing development without investing in planning the UK could miss out on over £70bn in additional value over 10 years, reports Brian Whiteley
Town planning has been a constant feature of political debate in recent years, with politicians calling for radical changes to ‘streamline’ or ‘bulldoze’ the system. The run up to the 2024 General Election brought attention to a major issue that all parties seem to agree on – the need to build more homes on brownfield and now “greyfield” sites to help a generation get onto the property ladder. All the parties also seem to agree that the feasibility of these pledges, their impact on existing communities, and the national benefits hinge on one key factor: the planning system.
Historically, we’ve seen a lack of co-ordinated town planning lead to unplanned city expansion, lowdensity housing, single-use zoning, and an overreliance on cars. These types of developments come with increased energy use, pollution, congestion, longer travel times and a decline in community cohesiveness.
Earlier this year the RTPI commissioned Public First to research and assess the potential contribution of proper resourcing to planning in the UK economy. The results revealed that by increasing housing development without investing in planning, the UK could miss out on over £70bn in additional value over 10
years. The study also showed that by taking a proactive, planned approach to development – through development corporations or other positive methods – could result in building 150 per cent more homes.
One key message of the report is that by continuing to underinvest in planning, home buyers miss the opportunity for well-planned homes that benefit from a “planning premium” by being located in a desirable and productive area. This includes good mixed-use development, proximity to shops, walkable and internally connected places, denser and visually appealing environments, and access to public parks and open spaces. It is not simply the volume of house building which better resourced planning might lead to, but through taking a wider holistic view of the need to locate housing in places with sufficient public transport, employment opportunities, environmental quality, recreational opportunities, community facilities, health care provision, schools, etc., to better places in which to live.
A major barrier to development has been the mismatch between the wider economic needs of regional economies, including the social and economic requirement for housing, and the local interests of
Summary of the report’s main findings
● Good town planning could lead to a ’planning premium’ of over £70 billion of additional value if applied to the Government's housing targets over the next two parliaments. This rises to over £90 billion were higher housing targets to be achieved.
● Characteristics that support the development of vibrant and safe communities form part of the ‘planning premium’ and provide an additional value of just under £50 billion, again over a ten year period.
● Delivering half of new housing within city boundaries would increase density and, if delivered appropriately, could lead to productivity growth worth £23 billion over the next ten years.
● When developers, planners, and those with the authority to grant planning permission are all aligned in purpose, a planning-led approach to development can deliver at scale.
● Development Corporations, which place town planners at the heart of the development process, can, under the right conditions, deliver significantly more housing than the status quo.
● Development corporations can be high value for money, with benefit-cost ratios of approximately 3.7 or even 6.7 possible.
Brian Whiteley is Planning Advisor at Planning
Aid England
planning committees and the residents they represent. Section three of the report provides evidence that putting town planners at the heart of the development process, and providing them with the necessary remit, funding, and agency, can help mitigate these barriers and deliver housing at scale. It reviews the work of development corporations delivering large-scale projects in the Thurrock & London sections of the Thames Gateway, in west Northamptonshire and in Cambridge & Cambridgeshire as practical examples. n
“The Planning Premium: The Value of Well-made Places”1 – report by Public First2
The City 2040: perspiration outweighs inspiration FINCH
The draft City of London local plan, at 44,000 words, is a prodigious effort, suggesting future development can be directed or fine-tuned to suit a very decent set of strategies reaching 2040. The product of a process which began in 2016, which has been subject to five public consultations so far, the latest ending on 17 June.
So the CAF talks event at Temple Bar on 14 May, chaired by Lee Mallett, was a timely opportunity to hear about the plan from the horse’s mouth, as it were. Or rather two horses, the first of whom was Shravan Joshi, chair of the City’s Planning and Transportation Committee, who stressed the importance of metrics and data in the planning process.
This showed that while footfall in the City had risen to about 80% of pre-Covid levels, the people in
the Square Mile are very different to the previous world of traditional business office-workers. More tourists, more digital tech start-up types, more media-tech folk. Having said that, legal and insurance sectors were still critical to City activity – with no sign that demand for office space would evaporate.
In fact quite the opposite. Joshi noted that predicted demand for additional office space suggested a minimum of 1.2m sq m of space would be required, with that sum increasing to a potential maximum of 1.9m. These figures take into account hybrid working and are partly based on current activity, with 0.5m sq m of space under construction currently – 18 Gherkins, as Joshi noted. The City may be changing, but the assumption is that it will continue to be an engine for growth, the first priority of the
City plan, which is intended to enable and encourage rather than prescribe (though there is proscription too, for example a ban on any automatic conversion to residential use of redundant office space).
But along with growth comes policies aimed at whole-life carbon ‘optioneering’, with a retrofit first
Paul Finch is programme director of the World Festival of Architecture and joint publishing editor of Planning in London
One of the main visions for the City in 2050, created by John Robertson Architects and used in The Developing City exhibition of 2012, showing a new riverside park on the North Bank, embracing the Tower of London and linking back into the heart of the City. SEE also the City Boardwalk scheme on page 26 of PiL 128, January 2024
BELOW:
City Plan 2040’s two proposed tall buildings clusters
test applied to new development; protection of heritage given greater priority, perhaps, than has been evident in the recent past; taking into account the visitor implications of the Elizabeth Line; and not least the opening up the planning process, providing ‘more security for stakeholders’.
A confident and coherent overview was supplemented by the second ‘horse’ in the person of Rob McNichol, Assistant Director (Policy and Strategy), who put some flesh on the bones of the overview, talking about the suite of policies which would achieve the vision that had been set, which apart from economic growth included the importance of making the City ‘vibrant’, which everywhere wants to
be these days, and welcoming to all, irrespective of gender, ethnicity and all the other wokescript definitions of people making up what used to be called the general public.
Some refreshing pointers to new ways of thinking included the idea of fast-tracking retrofit projects through the planning process, and the importance of educational and cultural facilities forming part of major development proposals. All this would be combined with clear guidance on the location of tall buildings in respect of views and heritage, without any instruction as to style or appropriate height. We were invited to think of the policy on height contours as being like a ‘trellis’ with, as it were, different sorts
of plants with different dimensions.
We also heard that sustainability should mean designs showing the possibility of dismantling buildings which had outlived their usefulness, in order for building elements to be re-used or recycled in the line with circular economy principles, though there is little in the document showing exactly how 50storey towers would be made in such a manner, or indeed what longevity might be expected of the contemporary City office.
Thoughtful responses came from a handful of invited contributors, and then the audience as a whole. Taking the positives first, the development growth strategy was warmly welcomed by David
Ainsworth of CO-RE London, who noted the incredible demand that still existed for space in what is London’s Central Business District, including companies migrating back from Docklands like HSBC –what a change from the era when some thought the
City would ‘be the Latin Quarter of Canary Wharf’. It was the creation of Lloyd’s of London which had changed all that. His plea to the planners was not to become too prescriptive about height, style and precise location – he didn’t want to be blocked or boxed (he might have cited Bing Crosby’s yesteryear hit, ‘Don’t fence me in’, particularly in relation to a trellis. . .)
The other developer speaker was Jay Ahluwalia of
Dominus, who welcomed the diversity of development envisaged in the plan, not surprisingly given his company’s successful activities in the hotel and student housing sectors. He welcomed the 2040 plan approach of identifying key change areas and urged the City not to underestimate the importance of the non-office market.
Urbanist Kathryn Firth of Arup liked the retrofit-
The City ‘trellis’ viewed from the river
first approach, the concept of the provision of ‘affordable offices, and the way the plans addresses diversity, edges and delivery. She had some warnings, however, including what she thought were inadequate additional housing numbers (though in good locations), given the City’s ambition to be a seven-daysa-week hub. This in turn would have implications for the location and nature of the retail offer envisaged. She also worried about the dependency on big developments to supply cultural facilities which might result in ground-plane voids, and the too-heavy reliance on the private sector to deliver public realm benefits. What happens if there is an economic downturn? Would it result in a rash of ‘stranded assets’?
Townscape consultant Peter Stewart had a more fundamental criticism of the plan, which referenced a point made by Lee Mallett in his introduction about the architectural relationship between plan and section: ‘If the plan is prose, the section is poetry’. Stewart was concerned that the enormous quantity of words in the plan were not accompanied by visuals giving an idea of what the City’s vision of itself might be. (And what about a concise statement of
aspirations?’)
He noted the success of the ‘Eastern cluster’ of tall buildings, which had shown it is possible to combine the big, new and shiny with the old, traditional and smaller scale. There were no surprises (and therefore not much interest) in the design section of the plan, but nor had it addressed what Stewart called the ‘in-between areas’, where architects were grappling with the challenge of finding forms, designs and materials which have little to do with the rivalry between the extravagant new and the quiet old. But the big question was why we couldn’t be shown more? Why couldn’t we have some visionary propositions of the sort produced by John Robertson, Gensler and others in The Developing City – a Vision for 2050 exhibition organised by Peter Murray in 2012 as part of the London Festival of Architecture. This was picked up from the floor, with a plea for more proactive policies in relation to the north bank of the Thames; the City does indeed want to see improvements but one got the feeling that the policies are all about guiding what other people want to do, rather than setting out positive planning ideas that the City would itself promote.
ABOVE:
City Cluster imagined as a 3D ‘trellis’
Rob McNichol defended the words-based approach, suggesting that things had moved on from the world of the Abercrombie Plan, with its diagrams and illustrations.
But surely the intention to make the City evermore desirable suggests that, in our new world of digital visual culture, more attention to look-and-feel in a weighty plan would not go amiss?
A lively discussion continued after the formal event ended, in the Temple Bar room overlooking both Paternoster Square and St Paul’s cathedral, in the end a successful piece of town planning and civilised architectural responses to the past and the future. As Lee Mallett had noted, David Cameron’s criticism that planning ‘is the enemy of enterprise’ is quite wrong. Bad planning might be, but good planning is exactly the reverse. Illustrating the desired outcomes would be worthwhile. n
SEE Gudrun Andrews presentation to the Forum in the LP&DF report
Will Labour London have a heart? MALLETT
You are probably reading this in a city turned red. A good moment to ask ‘Whither London?’ – the title of a talk given by our chief commentator on urban matters, Professor Tony Travers of the London School of Economics and Political Science.
To kick off at the Temple Bar Trust in the week preceding the election, Travers reminded the audience of the capital’s ability to regenerate itself. Look at today’s Paternoster Square, for example, where Wren’s Temple Bar is now resurrected. The area north and west of St Paul’s has been reincarnated several times since 1666. More recently, out of the Luftwaffe’s efforts arose Sir William Holford’s 1967 piazza and office blocks - only to be replaced within 40 short years by today’s ‘zoo’ of architectural approaches, commissioned by Mitsubishi and Stanhope.
Endless change and outward growth is what London mostly manifests, Travers observed. Except when it doesn’t. It declined drastically after WW2 as industry departed. People quit in millions as homes had been destroyed by the Luftwaffe or self-inflicted ‘slum’ clearances. The population collapsed from around 8.3m in 1939 to something like 6.1m in the
early 1980s. And London became grim in parts, offering a lively breeding ground for protest, squatting, then Punk and Art.
Neo-Liberal economics and Thatcher flicked a transformative switch. Privatisation, Big Bang, the reinvention of service industries with new tech’, the arrival of overseas capital, and burgeoning multi-culturalism began to transform London again. Londoners ‘born overseas’ as a percentage of its population rose from 5% in 1931 to 40.7% in 2021. It’s still rising, said Travers.
The virus of ubiquitous Gentrification slunk through every inner borough, into Docklands, and now to outer boroughs in places like Walthamstow, where you can no longer go to the dogs, as the deco’ stadium is now housing.
Six decades passed that saw huge changes. The Sixties’ progressive social reforms also saw the end of the post war office boom and early attempts to redistribute London’s prosperity elsewhere. They saw the final years of mass social housing construction, the creation of the GLC and the 33 boroughs –which have, and are likely to prove, remarkably resilient, said Travers.
Lee Mallett is a founder editor/publisher of PiL and urban regeneration consultant/writer
The 70s were grim, with more population decline, the closure of the docks and ‘inner city’ problems peaking with the Brixton riots. ‘Peak Thatcher’ was achieved in the 1980s. Big Bang, Right to Buy, GLC death, LDDC birth, and the Central London Rail Study that created the impetus for our world beating public transport system, second only to Tokyo’s.
The 90s saw the emergence of the ‘World City’ club, London being a founder member. Then in the Noughties the population grew by more than a million and we got a new Mayor and the GLA while watching Notting Hill, a film that captured London’s rebirth.
But the rest of Britain began to envy London’s ‘over-performance’. Almost every government has attempted to redistribute its growth to no avail. Non-Londoners took some revenge in 2016, while London continued to power eastwards, driven by the Olympics. Boris Johnson deserted his local power base for national politics, and offered northern voters Levelling Up as a vacuous atonement and HS2 got cancelled. He conspicuously failed to nurture what he’d achieved politically in London, being in thrall to a new northern ‘blue’ wall – that may have now dematerialised.
London’s success pumped up the wider south east too. Excluding London itself, Travers told us, the population in the wider region increased by six million between 1961 and 2020. An increase of 62%the equivalent of six Birminghams.
By 2050, with international in-migration likely to slow, London’s population is likely to hit 10m, adding around 40,000 net a year (according to the GLA’s London Datastore).
To tackle the housing crisis, Travers pointed to promises in both the main parties’ manifestos to ‘get Britain building again’ (Lab) with a new genera-
ABOVE: Our biggest UK cities fit easily inside London’s boundaries.
LEFT: The new ‘red’ capital, as predicted
tion of new towns, devolving more power to mayors, giving brownfield land a Planning Passport for high density housing, and rather surprisingly offering a distinctly ‘demand-side’ incentive of a mortgage guarantee scheme to first time buyers. That will please the housebuilders.
More shocking than surprising, he thought, was the Conservative’s last-minute dash for “raising density levels in inner London to those of European cities like Barcelona and Paris”. And there goes another squadron of flying pigs… Travers’ prediction for the election just past was that the Tories would scrape seven seats, Labour 61, the LibDems 10, and others 20.
Looking further ahead to 2074, he predicts a city of 11-12 million people in a region of 30 million with the possible extension of some of London boundaries by a modest five to ten miles and likely incursions
into the sacrosanct Green Belt. A Labour Mayor, like Sadiq, might get more powers under a sympathetic Labour government.
Our 60-year old boroughs will remain, he felt, with several acquiring a population near the 500,000 mark – bigger than many UK cities, and we will see much larger outer London sub-centres with their own tall ‘downtowns’ – like Croydon and burgeoning Walthamstow.
The car’s tyranny in inner London will continue its decline, but less so in outer boroughs while central London will move even further towards a bigger leisure, tourism, cultural focus – something the City of London is already pursuing.
Be careful of what you wish for, might be the response from Londoners who feel the core of their city increasingly belongs to visitors.
Concluding Travers felt the crash of 2008 was the
biggest lasting factor affecting London in recent decades, reducing subsequent growth to anaemic levels still well below the rather exciting 2.5% pa achieved in the chaotic 1970s, but still greater than the rest of the UK.
We are, mused Travers, perhaps between growth periods, or at least between things that deliver growth. The arrival of AI and developments in London’s bio-tech and science sectors, point to future spurts and the ongoing replacement of departed industries.
Most pressing (and depressing) is the ‘growth’ in inequality. London increasingly feels like a ‘heartless’ city, ‘where only the rich and poor can live’. The lack of sufficient housing being ‘a desperate failure of public policy’.
An inconvenient truth London’s new Labour intake ignore at their peril. n
WATERS WATERS
Is it time to bring back council housing?
This question comes to prominence for a number of contemporary reasons. The first and most obvious is the shortage of social homes i.e. those which carry subsidy from the taxpayer.
Second is the excellent work by Janice Morphet and friends at UCL researching the growing extent and range of methods by which councils are now procuring social housing (SEE page 46 of the last issue).
The change of government and its priority on building more houses is another but above all the catastrophic policy which has emerged over recent decades of getting private housing developers to use market homes to subsidise social homes, threatening their viability, raising costs and extensively delaying development.
As Paul Finch has said more than once, if the government forced bakers to give away one loaf at half price for every loaf of bread they sold at full price, we would have bread queues. This mirrors what has happened in the housing market especially in London.
A recent book by Jack Young "The Council House" is a paean to the building of council homes over the last century. Started in 1900 when the LCC built Arnold Circus in Shoreditch – still very impressive – it became an established phenomenon under the Addison Act of 1919. Examples
from the book and the author's introduction I reproduce alongside. These are heroic examples and the author illustrates 68 of them. Their declining reputation was down to poor management rather than their designs.
The architects are all named and many are now famous, a proportion of them having been staff of local architects departments rather than consultant architects. Post-war public architects often built empires which tended to exclude consultant architects. This in the end became their downfall. But like so many a swing of the pendulum it has gone too far because local authorities deprive themselves of the architectural skills and talent needed to be able to properly select and instruct consultant architects.
This needs to be rectified and the Borough Architect should be reinstated not only to be able to direct consultants in an expanded house building programme but also to advise the planning department on design matters, as used to be commonplace.
It is easy to blame the right-to-buy policy for some of the demise of council house building but this is not entirely fair. Building magazine used to carry dramatic headlines of how the maintenance of the postwar housing estates would bankrupt the country. Selling homes to their occupiers at a dis-
Brian Waters is joint publishing editor of Planning in London and chairs the London Planning & Development Forum
count so passing on the maintenance liability away from the taxpayer was actually quite a smart move. Its failure was not using the proceeds to build more social homes as was the original stated aim – as usual we can blame HM Treasury for that.
So where does this take us now? Local authorities own extensive land banks, most of them previously developed or 'brown land' and where it is already housing, as many estate regeneration schemes demonstrate, there is good scope for densification.
The Morphet research provides guidance to the considerable range of options in this regard, but we should resist future Borough Architects wanting to keep all the work in-house.
As for funding, the billions spent on housing benefit should be redirected with urgency to a new local authority homes building programme topped up by a tax on the actual profits of private housebuilders (rather than commuted payments on hypothetical and expensively contrived viability exercises) and the new CIL tax should do what it says on the tin, namely only be charged for infrastructure directly necessary for the carrying out of the development and no more. Section 106 agreements likewise and "affordable housing" taxation abolished. n
The book demonstrate the involvement of distinguished architects, here including Denys Lasden [LEFT], Berthold Lubetkin [TOP RIGHT] and many who started their careers at the LCC [under Leslie Martin at Roehampton for example].
Odhams Walk in Long Acre was one of the last to come out of the Greater London Council. By Donald Ball it is based on designs for the courtyards in the aborted scheme for Hounslow Heath by Paul Rutter, Mike Fiertag and your author!
Jack Young’s introduction to the book
My fascination with council estates began with the multicoloured Modernist architecture of Golden Lane Estate (no.19), which I started exploring on my lunch breaks in 2018 while hiding from an ever-mounting workload by day, l'm a digital product designer. It wasn't long before my weekends were spent searching out and photographing more of these playful, surprising buildings that weave their way through the city. Sometimes I would have a destination in mind, but more often I would simply set out from my own home on Camberwell's Lettsom Estate, camera slung over my shoulder, hoping to discover something exciting; it was very rare that I didn't. In my search I got to know London more intimately than ever, navigating its streets by the now familiar tower blocks on the skyline.
Since starting this project I've become increasingly accustomed to the confused stares of onlookers as I take these photographs. Sadly, my enthusiasm for council housing isn't universally shared. Where once these were pioneering projects, undertaken by passionate architects dedicated to providing quality homes to those most in need, today many of London's remaining estates have sadly slipped into disrepair - the public's view of them largely following suit. That is really what has inspired this book. It is my hope that in showcasing and championing the beauty and intelligence in these buildings, I can help to restore some of the rightful pride that was once felt in them. Many of the residents I met while taking these pictures invited me into their lives and their homes. The tales of community they told me often restored my faith in what can feel like a rather isol Hoxton Mini Pressating city. As we bonded over our shared appreciation for their home (or they laughed at me as I obsessed over their ribbed-concrete staircase), their pride in these estates was joyfully clear.
The 68 buildings featured in this book aim to illustrate the endless individualism of London's estates that initially hooked me - the selection revolving around council housing's golden era after the Second World War. Flipping through these pages, hope you too will agree that council housing is beautiful, inventive and inspiring - and as integral to London's architectural make-up as Buckingham Palace or Big Ben. – Jack Young. Hoxton Mini Press £19.95
Letter from the Director Rob Fiehn explores trends and events that are taking place across London. Here he explores sustainability initiatives that have recently surfaced in the capital
London old into new
Dear London enthusiasts,
It appears that the city is going green but this isn’t a reflection on politics or landscape but rather a more general pervading attitude to the ways we think about our buildings, old and new.
Achieving net-zero targets was recently invited to attend a property conference called Footprint+ that specialises in helping us all deliver net-zero carbon targets, hosting a range of different experts from a wide variety of backgrounds. They used to stage their show in Brighton but this year it moved to the former Billingsgate Market that sits right on the Thames in the City of London.
The most surprising element of the event was the claim that we are heading for a new stone age. This is something that is being championed by the Stone Collective, who believe the humble material has the potential to lead us out of the climate emergency thanks to its strength, durability and low-carbon footprint.
Across town in the Building Centre, a new exhibition is focused on the various ways our existing built environment can be repurposed for a new lease of life. Retrofit 24 has tasked itself with showcasing the best examples of ways to decarbonise the UK’s real estate. They outline that 80% of the buildings that will be here in 2050 already exist, so how do we make sure they are resilient for the challenges ahead?
The show features a series of case studies of best practice and it’s on until 30th August.
As some will already know, the Society was taken
on a tour of Sustainable Ventures that occupies the fifth floor of County Hall on the South Bank. The workspace is full of 100+ start-up companies that are all taking on environmental schemes in their own unique way. The office certainly practices what it preaches, with a bar clad in a material made of old orange peels, a reception comprised of reused coffee grounds, acoustic panels of mycelium (a mushroom product to the uninitiated) and experimental walls that grow their own moss.
A world-class museum
Finally, we took a turn around the construction site of the new London Museum, formerly known as the Museum of London, that is moving from its Barbican site to Smithfield Market. We were overwhelmed by the scale and ambition of the project. Workers on site are painstakingly repairing and retaining as much of the original buildings as possible. Materials that do have to leave the site are being catalogued (you wouldn’t expect anything less from a museum) and will find new homes as part of a circular economy approach.
All in all, we can see that London is slowly but surely adapting to the new pressures it’s facing and it turns out that the future might be based on the past after all!
Rob Fiehn, Director, The London Society
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Grosvenor flexes office muscle
Fitted and managed offices create the opportunity for us to provide valued services to businesses says Piers Townley
At Grosvenor, our goal is to create exceptional offices in Mayfair, Belgravia, and core regional cities. We recently announced our plans to convert 300,000 sq. ft. of existing office space to flexible, fitted, and managed workspaces. There are many reasons for this updated strategy, but at its heart is customer demand and our desire to improve the experience in a Grosvenor office through contemporary, flexible offerings to occupiers.
In recent years, we’ve seen huge growth in demand for flexible space as more and more occupiers see the benefits of improving their office and access to amenities by sharing them with other businesses. In leasing across our sub-5,000 sq. ft office portfolio, 50% of enquiries are now specifically for fitted and managed offices – and we’re seeing this space lease three times faster than unfitted space.
We believe this trend in customer demand will only strengthen for a number of reasons.
• Agility: occupiers are looking for shorter lease terms, to provide greater flexibility for their space to evolve alongside their business. With shorter lease terms, there is an inherent requirement for property owners to fit out space for their occupiers, so that the economics of taking an office for a short period works.
• No capex: fitted offices allow occupiers to avoid a large upfront investment in their space, enabling businesses to focus their capital on their core business.
• Hassle free: smaller occupiers need to concentrate on running their businesses, and don’t want the effort of arranging, managing, and paying for the services to run their office. They want a partner who can manage the cleaning, ensure the kitchen is well stocked, and of course make sure that the
meeting room technology works!
• Valued experience: post-covid, the experiential elements of a workplace play a critical role in encouraging employees back into the office. A fitted and flexible workspace enables business owners to provide the engaging, premium experience that employees are looking for, without having the large upfront cost that would otherwise be needed. For small businesses in particular, an effectively run shared office can become a key ingredient to building their company culture.
Encouraging colleagues to return to the office is increasingly a priority for businesses, fuelling demand for better quality, well-equipped workplaces in centrally connected locations.
To this end, businesses want to reduce the commute for their employees as much as possible and have their office provide updated facilities, from technology enabled meeting rooms and bike storage, to kitchens and breakout space. The result is increasing competition for premium offices within a 5-minute walk of the best-connected commuter stations.
For Grosvenor, this strategic push goes beyond just reacting to customer demand, to a focus on creating longer term customer relationships. Historically, we have attracted occupiers by providing great office space within our heritage buildings, but also by ensuring there are distinctive amenities such as independent retail, exceptional wellness, and dining options for workers in the area. By having a variety of office products, we’re able to attract a broader range of businesses and meet the requirements of existing customers as their needs change, which in turn allows us to be a longer-term partner to our occupiers.
Fitted and managed offices create the opportunity for us to provide valued services to businesses.
Piers Townley is Director of Belgravia Offices and Flexible Workspaces at Grosvenor
Our goal is to provide a personal and premium service, such that they see our team as an extension to theirs. Concierge services not only take away the hassle of running an office, but also creates those moments for their team to enjoy being in the office, whether it is through organising wine tasting events, social opportunities, or just simply enjoying a team drink at the end of the week. With a personal service, we can build relationships, better understand what occupiers need and ultimately become a trusted partner for the longer term.
For property owners, managing the office for occupiers has another significant benefit – driving sustainability and social impact. By controlling the operations and fit out of the office, we can reduce the impact on the environment. Whether it is only using deep green electricity, installing software to analyse and reduce energy use, or using recycled materials in the fit out, we can minimise the carbon impact of our buildings. We are constantly looking at how we can have a positive impact on the communities that we operate in. Recent initiatives include creating a flexible office ‘Fivefields’, dedicated to charities, connecting workers with local retailers, and linking occupiers with volunteering opportunities at local charities. There is more to do in this area, but managing offices and creating closer connections with businesses that choose to partner with us, gives us an opportunity to collectively increase our impact.
This is an exciting time in the office sector, with customers shifting towards higher quality sustainable offices in the best, amenity rich locations. We believe that those that can invest in fitting out offices and provide valued services will ultimately create longer lasting customer relationships and subsequently have buildings that will continue to thrive into the future. . n
Getting Britain building again
The priority should be to streamline the process for updating local plans, and then bolstering councils with sufficient planning officers to process applications, says Ben Standing
The level of success Labour has in achieving its vision to ‘get Britain building again’ will be fundamental to sparking sustained economic growth over the next five years and beyond – but it must overcome major obstacles to deliver this.
“It’s commonly accepted that the planning system simply isn’t delivering because of the delays and costs it incurs. There is wide agreement that an improved system would be agile, speedy and proactive to deliver the right development and infrastructure in the right places. However, this is not as easy to achieve as it sounds.
“While Labour’s commitments to building 1.5 million homes, and delivering major transport projects 25% faster and 20% cheaper than current levels, represent the type of ambitious thinking the
Building Safety Act 2022
UK economy needs, it will have to find ways to get communities onside as well as navigate swathes of competing planning and environmental laws.
“This leaves the new Government with two choices – it can either loosen planning requirements so it’s quicker and cheaper, but may not have the necessary protections or achieve desired placemaking objectives, or it can invest more into the existing planning system to try make it work via increased resources.
“We’ve already seen radical planning reforms, such as those proposed by the Conservative government in 2020, watered down over time amid various opposition that illustrates the tension between a desire to speed things up and the lack of a clear path to achieving this.
Ben Standing is a partner in law firm Browne Jacobson
“The priority should therefore be to streamline the process for updating local plans, giving the private sector certainty over strategic direction and reducing the potential for disputes, and then bolstering councils with sufficient planning officers to process applications and get building work underway quickly.” n
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Unlocking housing sites needs viability expertise
Andrew Golland says delivering both brown field and grey land is going to be a challenging task without fully resourced policy makers understanding the viability constraints
A housing development panacea of many recent governments has been brown field sites. Politically, building more homes on brown field, eases the fears of those living near to green field that new housing might be headed their way.
Indeed, perhaps the Tory government’s Planning swansong is yet another look at how brown field sites may help housing delivery and numbers. Under the heading of ‘Strengthening planning policy for brownfield development’ government wishes to hear back from interested parties on how delivery of what are often considered to be, more difficult sites, can be enhanced.
An optimistic reading of the Paper might conclude that it will lead to more rational and robust policy making along the lines of sequential tests. A more cynical reading is that government is using the paper to be generally cross with LPAs who are coming up short on their Housing Delivery Test (HDT) and further, to be very cross with London planning authorities more specifically.
This is unjustified as there are a number of (viability related) reasons for both issues, and not least in the case of London, the challenge of high existing use values.
Viability models for brownfield site development
Brown field sites, like any other site, become in most cases only developed when they are viable. But how does this happen and what are main drivers? I identify here what I would call four ‘viability models’ which relate to brownfield site development.
Cost Plus
‘Cost plus’. This is where residual valuation is put into reverse, with costs driving the equation rather than gross development value. In short, land is purchased as a cost to the overall development, the build is constructed, a margin added and the resulting price passed on to the eventual buyers.
This model has worked best in situations where there is a landmark or iconic building where people are prepared to pay a premium to live in; usually an apartment converted from commercial use. People will be able to relate to examples. Closer to home, prices in a majestic Leicester converted shoe factory prices are double those in high quality housing opposite.
This model is likely to yield less housing going forward as very many of the country’s iconic buildings have already been converted. And it is questionable whether a ‘cost plus’ viability approach would be applied in a market such as the current one where costs are rising faster than values. Such an approach is highly risky, and particularly in lower value areas; for example with the many mill conversions still to be carried out in northern towns.
To a large extent this viability model is a declining one, unless government or local authorities suddenly come into money to help deliver these buildings to housing.
Competitive residual
A traditional approach – GDV less construction costs and margin gives the promoter an idea of what to pay for land. Brownfield land competes directly with green field using this model although not very effectively for several reasons.
First, existing use value is normally higher for brownfield than green field. Brown field has a claim to alternative use value and this claim is enshrined within the NPPG on viability. Indeed, viability tends to be measured differently between brown and green field. Local authorities can use a multiplier approach to farm land, whereas the argument, correctly, put to LPAs with brownfield is that there should be a small premium over and above commercial use (as this is already higher).
In addition brown field very often has clearance costs and/or, more challenging, decontamination costs. For heavy industrial uses this means that land has a negative residual value. Even for lightly contaminated sites, costs can be enough to give a negative residual, or certainly to squeeze out any Section 106, which the LPA is obviously interested in.
Brown field sites are often tight, more difficult to access and attract abnormally high preliminary costs. For a given location, they compete poorly therefore with green field.
Composite brown field assessment
For many brown field sites, the developer will look to make a clear distinction between margin and land uplift. There are many instances however where a more composite approach is taken, with a
Dr Andrew Golland specialises in the field of housing, planning and regeneration
blended (between margin and uplift) approach is adopted. Most obviously this would be with joint ventures – although these of course are not limited to brown field.
A composite approach is well suited however where there are many uncertainties with the scheme – conversions as a good example. With smaller developments it won’t be possible to pass on unexpected costs to the buyer as s/he will have adequate choice in the second hand market. Sharing uplift and or margin here may help to make these schemes viable and competitive.
This approach works well in principle with a plethora of annual life changing decisions (e.g. retirement ‘churn’) of property owners where a land price horizon is envisaged, but may not be realised due to the economics of the scheme. In practice this model may flounder of course where the land owner is intransigent and just ‘wants out’. Readers will recognise this one no doubt.
The
‘Just do it’ approach to brown field assessment
There are a surprising number of appraisals which I have sight of which appear not to stack up, yet owners/promoters or developers are prepared to take on the schemes anyway.
Costs exceed GDV, and where this does not happen, the residual value is exceeded by the land value benchmark.
In some significant measure, the latter (residual lower than benchmark) is explained by the fact that land value benchmark is a technical construct rather than a value imputed by a property owner; in other words, people are prepared to be flexible in how they see their current asset (and/or remain indifferent to this rather strange construct).
In other instances there are ways of ‘stretching GDV’. Typically by assuming investment value rather than a scheme for sale into the immediate market. Then return is taken over a longer period.
With these appraisals the issue of the source of cost estimate comes sharply into focus. Using industry standard costs (e.g. BCIS) the assessor will have to plump for e.g. ‘higher/lower (quartile), mode or median costs and make a case (either for LPA or applicant) but in practice the actual incidence and quantum of costs will not be found out until the scheme is underway.
Nevertheless this remains, and will remain, an important source of supply for housing from brown field sites.
Implications for Section 106
One main issue with Section 106, viability and brown field sites is the Affordable Housing threshold. This is because brown field sites are often smaller and government believes (wrongly I think) that scale of development is a good proxy for viability. Nevertheless a dual market is created. This generates significant questions as to whether an
applicant should go for more units, at higher margin, whilst taking on an Affordable Housing target, or less units, with potentially less uplift, no Affordable but at lower margin. This is why first, a viability study may have in the first instance to be a feasibility study, and second, looked at in a more composite way, as outlined above.
An additional issue for brown field is often information. The local authorities promoting a low threshold will have to make sure the justification is well set out because owners of smaller sites and properties are sometimes not as well informed on policy implications as larger ones. This leads to the idea that Affordable Housing is a ‘tax’, rather than a benefit to the community triggered by the addition of newly provided homes in an area.
So it could be argued that brown field sites are more challenging generally although where the market is weaker this is almost certainly the key factor in this type of land not coming forward.
Brown field sites, Grey Land and an incoming Labour administration
Should Labour win the election, as looks increasingly likely, what implications will this have for brown
field development?
The last incoming Labour government (1997) promoted brown field and the Sequential Test very strongly. Significantly better resourced planning authorities undertook and commissioned Urban Capacity Studies (UCSs) which became the backbone of development policy. The Urban Task Force under Lord Rogers was instrumental to the drive towards regeneration of urban sites and buildings.
Labour’s position now is still that brown field will come first. In doing so they probably help their electoral chances in some constituencies whilst not harming their position with urban voters who are somewhat conditioned to building near to them.
A new thought is ‘grey belt’ land, which will essentially be green field but in ‘poor quality and ugly areas’. On this land, 50 per cent Affordable Housing will be sought. Therein is the rub. If the land is in a poor area, then the chances of delivering high levels of Section 106 are minimal – because of viability.
There is obviously a long way to go, but clearly delivering both brown field and grey land is going to be a challenging task without fully resourced policy makers understanding the viability constraints. n
Brownfield First does not mean ‘Brownfield Only’
Given changes, maybe, just maybe, in respect of housing delivery through plan making, the inertia of the last 20 years or so could draw to a close, suggests Nick Taylor
Albert Einstein famously said that the definition of insanity is doing the same thing over and over again and expecting different results. In respect of the approach to housing development in Britain, that phrase has never seemed more apt. The policy ambition that we should prioritise the development of brownfield sites over greenfield has seriously challenged everyone involved in this process, delivery has become slower and more politically toxic, and most importantly, caused serious social stress.
And alongside a crisis of housebuilding delivery is an even greater crisis in the delivery of affordable housing, thereby exacerbating social problems in an increasingly unequal society.
So what needs to be done? A potted history of the evolution of this policy takes us back to the 1990s and the proposition that 60% of all new homes should be built on brownfield land. In 2000 PPG enshrined the sequential approach of selecting brownfield sites over greenfield. This remains, a laudable ambition which made sense, but it had unintended consequences. Within three years it was clearly failing: the Barker Review of Housing Supply Interim Report (2003) highlighted in relation to PPG3 that, “It is not the intention of the policy to restrict land supply…some local authorities appear to have over interpreted it to the detriment of housing being delivered.”
Subsequently the target was removed, but the ambition lives on in the NPPF (2023) which states that, “Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.”
Although, superficially, it might be hard but to reach the conclusion that nothing has changed over the last 20 years, I believe that the situation has worsened and we need to revisit the resistance to greenfield housing. Why? Because of the failure for planning policy today to incorporate the fundamental principle that the planning system should be plan-led. Without up-to-date plans and a commitment to plan-making by all local planning authorities, the system is doomed to fail. This has been a failure of all governments - although it is fair to say that matters have clearly taken a turn
for the worse in the last few years. All the evidence shows housing delivery is stalling and the focus needs to be reset, with greenfield housing development integral to delivery.
There is also general increased opposition to greenfield housing development which has intensified with disastrous consequences in particular, the delivery of affordable housing. I believe a number of factors are at play here. First, NIMBYism generally. Second, valid opposition to urban extensions on greenfield land that are not seen to be paying their way as a result of late or under-delivery of social, community and physical infrastructure. Third, a naïve understanding of the economics of brownfield housing development, that it is always viable and that building flats, often at high rise, supplies the homes that we need. It won’t and it doesn’t.
Fourth, the assumption that there is enough brownfield land. The annual target housebuilding target is supposedly is 300,000 homes, but even with the greatest optimism, the most that we can deliver on brownfield land is around 90,000 homes per year. This leaves a requirement for 210,000 homes from greenfield and other sources.
So why can’t we have more on brownfield sites, in particular affordable housing? This is due to the lack of funding for public housing and the requirement for developers to deliver this despite the relatively enormous (and increasing) costs of delivering on brownfield sites, CIL and Section 106 costs, and Vacant Building Credits – all of which almost always (and inevitably) suppress the delivery of social / affordable housing.
Aside from all this, what policy changes need to be made to address the complex challenge that was first identified back in 2003, if we are to increase housing delivery? In my opinion, there are four policy changes that would make a difference. These must come from the top-down because bottom-up has proven to be too big an ask as a means of delivering substantial numbers of new homes.
First, it will be interesting to see whether the NPPF proposal to allow land to be bought at existing use value for schemes delivering large levels of affordable housing has any effect. There are so many questions on this, but my hunch is it will be slow and not many will be delivered - but it might
Nick Taylor is a Partner in Carter Jonas’ Planning & Development team
be worth a try. Second, the NPPF has to be changed back to allowing for reviews of Green Belt boundaries as part of plan-making. Should Labour win the general election, there is potentially good news on this, as it looks as though a Labour government will implement this early on. There will be an inevitable lag but if Labour is in power for more than a single term, this could make a real difference to supply. Third, it is necessary to set the dates for local plan reviews and stick to them. The current stick/carrot approach is a planning free-for-all because unmet deadlines simply become Groundhog days which persist indefinitely. Whatever this mechanism is, it must force local planning authorities to bring forward development plans or allow automatic consents.
Fourth and finally, we need a more nuanced approach to the respective roles of greenfield and brownfield land in housing supply. Local authorities must be encouraged to use brownfield if they can, but if greenfield is the best way forward, they should be allowed to pursue this option within a policy framework that maximises the delivery of affordable housing and contributions to social and community infrastructure - because in the long run, this is the only way that development will pay for itself and be accepted by communities.
Given these changes, maybe, just maybe, in respect of housing delivery through plan-making, the inertia of the last 20 years or so could draw to a close. n
A step-change is needed in housing delivery
Difficult decisions and continuing political disagreements lie ahead if we are to house our growing population, says Katy Davis
The government, in its Long-Term Plan for Housing, has committed to ‘a new era of regeneration, inner-city densification and housing delivery across England’.
It has also launched visions for growth in London, Leeds and Cambridge. The Spring Budget made further commitments to these cities, allocating funding for London and Leeds and the promise of both a development corporation in and a future long-term funding settlement for Cambridge, to be announced in the next Spending Review.
The same day, the government also published an Independent Review of the London Plan and following this highly critical report, Michael Gove ordered the London Mayor Sadiq Khan to conduct a partial
review of the London Plan.
This has two specific areas of focus. The first is industrial land: the government believes that of the 6,800 hectares of land used for industry in London, 736 hectares could be used for housing. The second is opportunity areas which have not delivered the intended 2,500 homes. For the Conservative party, brownfield development remains the priority.
But the government being replaced with a Labour administration, the preferred location for new homes is set to change. In April Keir Starmer set out his policy for housebuilding, specifically freeing up space for between 100,000 and 500,000 homes by building on ‘ugly’ parts of the Green Belt land. His proposals include prioritising brownfield land within what is currently designated Green Belt but also improving green spaces such as parks and woodlands.
The ‘grey belt’ has become a focus of many of Starmer’s pro-development speeches. It was almost a year ago that he depicted a disused petrol station as an example of land within the Green Belt which had little aesthetic value but considerable development value. The petrol station – along with ‘disused car
Katy
Davis is Planning & Development Partner in Carter Jonas’ London office
parks’ and ‘dreary wastelands’ – has since been branded the ‘grey belt’, a new description for protected land which would otherwise be made available for development on the basis of its suitability and sustainable location.
Almost unquestionably, Green Belt release is the single most effective way of resolving the housing crisis. There are many parts of London where the Green Belt is isolated pieces of land between major transport infrastructure and these are prime sites for the development of employment and homes. Some London boroughs including (Labour-run) Enfield are boldly proposing major Green Belt release in their draft local plans.
Development on the Green Belt – and there is substantial Green Belt surrounding London, Leeds and Cambridge - is one of the most contentious planning policies that a government could introduce (as is evidenced by the fact that the current government has made great efforts to avoid doing so).
However, it was only in a surprise announcement on the eve of the local elections in early May that Sadiq Khan apparently came round to the idea of more development on the Green Belt. He has previously gone to great lengths to protect the Green Belt and in the 2021 London mayoral campaign, put “opposing building on the green belt” as the sixth point of his Green New Deal for London.
There is reason to believe that the mayors of Mayor of Cambridgeshire and Peterborough and the West Yorkshire Combined Authority are very protective of the Green Belt.
A Labour government would have to use multiple levers to genuinely achieve a step-change in housing delivery, and this will include the inevitable need to deliver some development on Green Belt land that does not neatly fit the ‘grey’ label. Difficult decisions, and continuing political disagreements, lie ahead if we are to house our growing population. n
Density policy requires better use of brownfield sites
Grant Leggett’s view is that good design is closely linked to good land use. In most situations, and especially in urban areas, density has many advantages
The debate over the Green Belt, and the newly branded ‘grey belt’, has made the headlines a lot recently and will remain at the forefront of development decisions due to the two major parties’ diametrically opposed views on the topic.
For the time being, however, the Green Belt (rightly or wrongly) will remain sacrosanct as the current Government prioritises ‘gentle density’ in urban areas in preference to greenfield development.
So what impact is this likely to have on cities? Can a renewed approach to densification support regeneration, especially for those areas which may lack the necessary quantum footfall?
Density - more specifically, ‘gentle density’ - a central theme of the revised NPPF, which is currently being consulted upon. The changes to the NPPF were in large part a response to a rebellious group of antidevelopment backbench Tory MPs who threatened to torpedo the progress of the Levelling Up and Regeneration Bill. And so some big-ticket changes, including removing mandatory housing targets and tightening up on Green Belt development, were made.
Many in the development sector question whether the rather vague and unquantifiable concepts of 'beauty' and ‘gentle density’ were thrown into the NPPF as a means of stalling proposed new developments for political purposes. For stall them they will; they are terms open to such subjective interpretation that they will tie decision-makers in knots even more than they already are.
To understand whether ‘gentle density’ can help, rather than hinder, the quality and quantity of new developments requires a definition – as it hasn’t had a place in the planning lexicon until now. That’s where the problems start. ‘Density’ is relatively straightforward as it can be measured in quantifiable terms; a relatively simple function of homes and site area. ‘Gentle’ means very little in a planning context but its function, on any plain reading, is clearly to limit density rather than increase it.
The deceit in the wording is it purports to enable a higher volume of housebuilding, while also giving leeway to appease the 'beauty brigade’ as necessary. ('Beauty' however, is even more problematic in planning terms: it is subjective, unquantifiable and very much in the eye of each beholder.)
The notes which accompany the NPPF make some attempt to quantify ‘gentle density’: they state that, ‘Small sites play an important role in delivering gentle density in urban areas, creating much needed affordable housing, and supporting small and medium size (SME) builders’. They go on to be more specific about density, ‘Local planning authorities should identify land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved.’
The guidance also places renewed importance on upwards extensions: ‘Building upwards in managed ways can help deliver new homes and extend existing ones in forms that are consistent with the existing street design, contributing to gentle increases in density… local planning policies and decisions should consider airspace development above existing residential and commercial premises for new homes. This includes allowing upwards extensions where the
Tenuous terms such as 'beauty' and ‘gentle density’ have the potential to result in refusals
development would be consistent with criteria relating to neighbouring properties and the overall street scene, as well as being well-designed and maintaining safe access and egress for occupiers.’
More specifically, it encourages the introduction of mansard roof windows: ‘In some locations, local planning authorities have been reluctant to approve mansard roof development, as it has been considered harmful to the character of neighbourhoods. As a general approach, this is wrong - all local planning authorities should take a positive approach towards well designed upward extension schemes, particularly mansard roofs.
It is proposed that a reference to mansard roofs as an appropriate form of upward extension would recognise their value in securing gentle densification where appropriate.’ In my view, this continued idea that building mansard roofs, or indeed the fascination with ‘airspace’ development can make any significant dent in the housing shortage is a wishful/fanciful case of burying heads in the sand and a means of avoiding the tough conversation about proper development
Grant Leggett is Executive Director and Head of Boyer’s London planning team
on the ground. There is scant evidence that airspace development is actually working.
It seems a step too far for planning policy to identify specific architectural features such as mansard windows as ‘well designed’ and to state that considering them harmful to the character of neighbourhoods is ‘wrong’, as it is commonly accepted that whether any architectural feature is ‘right’ or ‘beautiful’ depends upon the context.
My view is that good design is closely linked to good land use. In most situations, and especially in urban areas, density has many advantages. We have an indisputable shortage of homes which is best addressed by providing an optimal number of homes on all available land; that’s Chapter 11 of the Framework which seeks to make efficient use of land. Doing so helps create a mixed and balanced community, increases the potential for a range of facilities in close proximity, is economically advantageous (allowing resources to be spent on services and amenities) and can facilitate greater variety of uses, such as live/work and co-living.
Denser schemes also have the potential to be more sustainable, not least in terms of sustainable transport, if located close to public transport or withing easy each of local services. Developable land, especially in cities such as London where I am based, is a scarce resource and it is essential that potential development capacity is not wasted.
I would like to think that these changes would have little bearing on my work because, working with my colleagues in Boyer’s Design team, we already produce schemes which are well designed and make good use of available land.
But I fear that tenuous terms such as 'beauty' and ‘gentle density’ despite meaning very little in planning terms, have the potential to result in major schemes being called in and refused permission, exacerbating our current housing crisis. n
Green Belt review no panacea, but discussion welcome
Even the chair of Natural England has stated that building on the green belt should be part of the UK’s answer to the housing crisis, points out Ian Barnett
There’s a very important first step that needs to be taken in resolving the housing crisis: we need a greater understanding of public sentiment around the Green Belt, and a moderate adult conversation to replace the politicking and propaganda.
Of the many issues impacting on the building of new homes, the Green Belt is perhaps the most contentious. Yet the majority of people, if asked whether they would choose a resolution to the housing crisis or an expansion of the Green Belt would probably choose the former.
Furthermore, addressing the housing shortfall, does not require for the Green Belt to be reduced, simply reviewed. It is a lesser known fact that the Green Belt was actually increased last year despite 235,000 new homes being permitted.
A review would make much better use of less attractive areas the Green Belt. Keir Starmer has recently referred to this as the ‘Grey Belt’. In reality there is no ‘belt’ of disused petrol stations and quarries – it’s a much more complex picture whereby large areas of Green Belt are speckled with grey dots.
However, the principle is a sensible one: identifying areas ripe for development. At the same time there is a strong case for identifying and protecting valuable greenfield land including national parks, agricultural land and woodlands, which are rightly appreciated. In fact a review of the Green Belt need not mean a reduction of the Green Belt, simply a change in its boundaries.
This straightforward approach would appeal across the political and demographic spectrums.
Statistics show how public perception has become distorted. For example, the public believes
that 47.1% of England is developed; it’s actually just 8.7%.
In contrast, 12.6% of England is protected by Green Belt, which is increasing year on year. The Green Belt around London is three times the size of the city itself. And there is also substantial Green Belt land around 16 of England’s towns and cities including London, Manchester, Birmingham and Liverpool. Furthermore, contrary to public belief, not all Green Belt land free to be enjoyed by the public: roughly one quarter accessible (only 9.3% of which is allocated as National Park) and the vast majority is privately owned farmland.
The ‘threat’ to the Green Belt has long been a rallying call for campaigners against new development, with a suggestion that the country’s Green Belt is under threat as never before. But again, the statistics paint a very different picture. In 2023, the area of Green Belt land in England, at 1,638,420 hectares, was its highest in twenty years.
I believe that if people understood the impact of ‘protection’ they may see it differently. Far from the vision of a bucolic ring of verdant countryside open to all, much of the Green Belt is unappreciated and underutilised, often previously developed brownfield land. Even the CPRE has put on record that of the 60,714 ha Nottingham and Derby Green Belt, 36% is ‘neglected’.
It’s important to consider how the benefits of the Green Belt can be delivered closer to people’s homes, specifically the inclusion of high quality natural landscapes within and around residential developments which addresses both sustainability and social objectives. Many new developments now do so very effectively – infinitely more so than the housing developments of the 80s and 90s. And the new requirement that new developments achieve a 10% biodiversity uplift is a step in the right direction.
Even Tony Juniper, the chair of Natural England,
Ian
Barnett, National
Land Director, Leaders Romans Group
has stated that building on the green belt should be part of the UK’s answer to the housing crisis, provided more effort is also put into improving the quality of urban green space. In a Guardian article in November he explained that new housing and better protection for green spaces, wildlife and nature should not be seen as opposites. He explains that the “oppositional mindset” that sees the two as “binary choices” does not reflect reality and that, “Putting woodlands in remote areas is going to have much less social benefit than putting woodlands in areas next to where people live.”
The fact is that housing developments which achieves biodiversity net gain through tree planting, new wildflower meadows and habitat creation provides significantly more environmental value than agricultural land and are significantly more accessible.
This position is supported by think tanks left and right: the Adam Smith Institute and the Institute of Economic Affairs have argued that the release of at least some Green Belt land could help solve the housing crisis, and the Institute for Economic Affairs has stated that the existing restrictions “significantly push up the cost of living, while making homeownership unattainable, forcing people into lower-paying jobs and increasing commute times and pollution”.
With housebuilding believed to be at its lowest level since the Second World War and affordability compounded by high interest rates, high build costs, labour shortages and the removal of Help to Buy, a solution to the housing crisis is urgently needed.
Of course a Green Belt review is not a panacea, but since the issue has become one of the emotive issues in what has become an unnecessarily emotive debate, some more moderate dialogue would be an important step in the right direction. n
Coded hints as to Labour’s new towns thinking
Shadow Secretary of State Angela Rayner’s speech at UKREiif in Leeds in May was interesting, particularly on new settlements, notes Simon Ricketts
I have emboldened some key passages.
“New Settlements
And while we work with the grain of local communities and their character, we’ll also consider how urban regeneration and extension can play their part.
We want homes on these sites within the first term of a Labour government.
But these new large settlements must be built in the right place, in partnership with local people.
This is why an expert independent taskforce will be set up to help choose the right sites and a list of projects will be announced within our first 12 months of government, so we can start building the towns of the future within months, not decades.
Our next generation of New Towns will build homes fit for the future. Creating places where people want to live. Inspired by garden suburbs like Hale in Manchester, Roundhay in Leeds, and the Garden City project
But let me be clear – I will not simply demand “more units, at any cost”.
The reason many local communities resist new homes is often because the housing is of the wrong type, in the wrong place – it doesn’t come with the schools, GP surgeries and green spaces that make communities, not just streets.
Or the affordable and social housing local people need.
Our next generation of New Towns will build homes fit for the future. Creating places where people want to live. Inspired by garden suburbs like Hale in Manchester, Roundhay in Leeds, and the Garden City project.
We will set out a New Towns Code – criteria that developers must meet in these new settlements:
More social and affordable homes – with a gold standard aim of 40%
Buildings with character, in tree-lined streets that fit in with nearby areas
Design that pays attention to local history and identity
Planning fit for the future, with good links to
town and city centres
Guaranteed public transport and public services, from doctors’ surgeries to schools
And access to nature, parks, and places for children to play “
New Towns are just one way we get good quality, affordable houses built in the national interest.
Our local housing recovery plan will reverse the Conservatives’ damaging changes to planning, getting stalled sites moving at speed.
We’ll give Mayors the tools they need to deliver homes in their areas, revitalising brownfield first, unlocking ugly, disused grey belt land for housebuilding and setting tough new conditions for releasing that land.
Our ‘golden rules’ will ensure any grey belt development delivers affordable homes, new public services, and improved green spaces.
This means more social and affordable homes and we will ensure that brownfield sites are approved quicker so homes get built fast.
Together, we will unleash the biggest wave of affordable and social housing in a generation.
Because a safe, secure, affordable home is the foundation of a good life.
We can see the consequences when that foundation is taken away.
Today, there is an epidemic of homelessness and rough sleeping in Britain.”
Some intriguing aspects here that go beyond the Labour Party’s Plan to Power-Up Britain that I covered in my 13 April 2024 blog post Powering Up Britain and beyond Sir Keir Starmer’s party conference speech in October 2023 (see 10 October 2023 BBC piece Keir Starmer promises to build new towns and 1.5m homes). Particularly intriguing that “an expert independent taskforce will be set up to help choose the right sites and a list of projects will be announced within our first 12 months of government, so we can start building the towns of the future within months, not decades.”.
The huge question will be how to avoid previous governments’ false starts and missteps. The last Labour government’s eco-towns programme was similarly ambitious, with preferred sites arrived at on the basis of criteria set out in a prospectus which
Simon Ricketts is a partner with Town Legal LLP
From Simon’s blog at simonicity.com/author/simonicity/ Personal views, et cetera
became hotly contested by those whose sites were not selected and by local campaigners. A High Court challenge to the process failed but, given time slippages, the programme was ultimately overtaken by the 2010 General Election. The judgment in the case, Bard Campaign v Secretary of State (Walker J, 25 February 2009) makes for interesting reading as to the context. For a wider piece setting out subsequent proposals by the present government for “locally-led” new towns see my 11 July 2020 blog post The New Towns Question (Again) .
Full marks for ambition but how to balance speedy top-down decisions as to quantum, potential locations, scale and so on (however “independent” “expert” led) with ensuring that (1) there is a joined up plan to deliver the necessary infrastructure (2) schemes have sufficient local buy-in (3) schemes are commercially viable (4) there is a fit-for-purpose consenting process if building is to start “within months” (polite cough) and (5) all legal trip hazards in terms of, for instance adequate assessment and consultation can successfully be navigated? Those will be some of the questions.
And the “gold standard aim of 40%” affordable housing is an interesting political phrase! n
Grassroots Music Venues Report/Agent Of Change
Been there, got the t-shirt, says Simon Ricketts
I support grassroots music venues. I’ve blogged a few times in the past about the agent of change principle. And I’ve just read today’s report by the House of Commons Culture, Media and Sport Committee on the steps it recommends to halt the worrying rate at which these venues are clos ing (two a week and the total number in the coun try declining last year from 960 to 835), which includes recommendations to strengthen the agent of change principle. Music Venue Trust has played a vital role in drawing attention to the issue.
Previous relevant posts:
•To The Centre Of The City, In The Night (28 October 2021)
• Sajid Javid: Agent Of Change? (19 January 2018)
• Noise Annoys (24 October 2016)
As with many public policy issues (housing, the economy, climate change, inequality, health dispari ties), we in our planning bubble need to remember that when it comes to protecting the conditions for grassroots culture to flourish, whether for its own sake or to grow the next stadium acts, the operation of the planning system is only one part of the prob lem – but the planning system does need to put its shoulder to the wheel.
The report includes calls for:
• A comprehensive review by the Government (by summer 2024!) to fully examine the long-term challenges to the live music ecosystem
• A voluntary levy on large venues by September 2024 and “if a widespread voluntary levy is not in place by September 2024, or if its level does not stem the tide of closures, the Government should introduce a statutory scheme.”
• Temporary VAT cut and simplification of processes for grant applications, as well as resolution of disputes within the industry on performing rights payments and the like.
• Placing the “agent of change” principle, which has been in the National Planning Policy Framework since 2018, on a statutory basis.
Briefly on that last point, the agent of change principle forms paragraph 193 of the current NPPF: “Planning policies and decisions should ensure that new development can be integrated effectively
with existing businesses and community facilities (such as places of worship, pubs, music venues and sports clubs). Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed.”
Paragraphs 90 to 95 of the report consider how the policy is applying in practice. It was recognised that policy represented progress, however concern as to how local planning authorities interpret and apply it. The Committee supported calls for it to be given more teeth by way of being placed on a statutory footing “at the earliest opportunity”.
Everyone of course calls for legislation about everything. I hope that any subsequent Government review examines this specific aspect in more detail: to
what extent is the policy not working and in what respects and in what ways would legislation assist without unintended consequences?
Those with long memories may recall that Labour tried to include such a provision into the Housing and Planning Bill back in 2016.
Just reflecting on what we gain from protecting and encouraging these venues (have you been to the relatively new, cosy but fabulous, Lafayette venue in Argent’s Kings Cross development?), it’s not just about nurturing artists – one great quote from the report, courtesy of a participant from Manchester: “Taylor Swift’s lighting director didn’t start out as Taylor Swift’s lighting director”.
These venues can sometimes even be the catalyst for the rebirth of a whole city – I recommend the excellent book Manchester Unspun – How A City Got High On Music by Andy Spinoza for a description of possibly the world’s most extreme version of this (and let’s not currently mention Co-op Live shall we?) n
Lafayette venue in Argent’s Kings Cross development
New emphasis on Scope 3 emissions in planning
Planning officers may have to give greater consideration to indirect emissions when judging applications following a Supreme Court ruling, says Ben Standing
It's not every day that local authority planning departments make decisions in relation to onshore oil. The implications of a rare such case (‘Finch’) could be far-reaching for planning law following the intervention of the UK’s Supreme Court.
A landmark judgment last month could place greater emphasis on Scope 3 emissions – those indirectly connected to a commercial operation and notoriously difficult to calculate – in everyday planning applications.It poses a series of questions regarding how we estimate the downstream environmental effects of development, the impact on capacity in planning authorities and whether it could another headache for politicians promising to streamline the planning system.
Supreme Court case explained
The case concerned Surrey County Council’s decision in September 2019 to grant planning permission to Horse Hill Developments for an oil extraction project in the Surrey Hills.
A judicial review was launched the following year after the decision was challenged by the Weald Action Group, led by Sarah Finch. The campaigners argued it was unlawful for the council to exclude the impact of Scope 3 emissions in the Environmental Impact Assessment (EIA).
These claims were initially dismissed by the High Court and Court of Appeal, but the Supreme Court overturned both rulings on Thursday 20 June. In giving the majority verdict, Lord Leggatt said: “I do not accept the premise that it would be wrong for a local planning authority, in deciding whether to grant planning permission, to take into account the fact that the proposed use of the land is one that will contribute to global warming through fossil fuel extraction.”
The six wells at Horse Hill, near Gatwick Airport, would produce an estimated 3.3 million tonnes of crude oil over a 20-year period. Friends of the Earth, the environmental campaigning group, said it would emit more than 10 million tonnes of CO2.
Potential implications for planning law
While a case concerning fossil fuel extraction is relatively unique for local planning authorities, the
judgement represents a step change in thinking for planning law.
The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 – known as the EIA Regulations – enable planning authorities to take account of the environmental implications of development when determining the outcome of a planning application. Scope 3 emissions haven’t typically been included, however.
In its verdict, the Supreme Court said the EIA directive “does not impose any geographical limit on the scope of the environmental effects of a project that must be assessed … it is in the very nature of ‘indirect’ effects that they may occur away from their source”.
Carbon emitted throughout the supply chain during transport and distribution, waste generation, end-of-life treatment of sold products, and outsourced manufacturing could all contribute to Scope 3 emissions in a development. Once occupied, this could also include business travel, employee commuting and the use of sold products.
To understand how this could affect planning law, consider the prospect of a new electric vehicle battery plant that will manufacture products using precious metals mined via polluting methods.
This isn’t to say the strengthened consideration of indirect emissions will determine a specific outcome. In reality, the EIA Regulations enable decisionmakers to consider environmental information and scrutinise this against other factors; in this example, weighing up downstream emissions against the operational purpose of supporting the switch to cleaner transport.
Where this gets more complex is when information is more difficult to come by. A planning officer considering a proposed commercial development, such as speculatively-built warehousing, could use an EIA to analyse Scope 1 and 2 emissions. These could come directly from the building operation or how the facility is eventually used, such as for heating and powering.
The officer won’t necessarily be able to judge the level of Scope 3 emissions without understanding exactly who the occupier will be, and the carbon footprint of both its own and suppliers’ operations.
A trusted methodology that can realistically
Ben Standing is a partner specialising in planning and environmental law at law firm Browne Jacobson
evaluate Scope 3 emissions is therefore required for planning decisions to stand up to legal scrutiny.
Wider impact on planning policy
The Supreme Court decision arrived just weeks before the British electorate went to the polls for a General Election in which various pledges to streamline the planning system were a central plank of political parties’ ambitions to kickstart the economy.
Some politicians will have observed that adding a new dimension to planning policy risks increasing the burden on already stretched planning officers.
But we must remember the planning system is already subject to a series of trade-offs under the National Planning Policy Framework.
There is little opposition to any of its principles –be that delivering a sufficient supply of homes, protecting green belt land or achieving well-designed, beautiful places – in isolation, just as few would challenge the idea that development shouldn’t cause indirect damage to the environment.
But given these are rarely achievable as a collective set of principles, it’s the role of planning officers to balance the positives and negatives – with Scope 3 emissions ultimately just another item added to the scales.
So while we shouldn’t anticipate the Supreme Court’s ruling to usher in numerous legal challenges to previous decisions, we can expect public awareness to grow on the importance of indirect emissions when considering planning applications, whether it’s for the oil well, road scheme or housing development. n
PDR evolution could unlock useful development
Might more flexibility be applied to changes to residential use to include allowance for external alterations in a single prior approval, asks James Doherty
One of the biggest shake-ups to the planning system in the twenty first century has been the increased use of permitted development rights (PDR) for change of use, which in turn led to the introduction of Class E in September 2020 and further flexibility announced earlier this year.
But do the recent announcements mark the completion of this form of planning consent, or can we expect further changes to follow?
The revolution in permitted development rights began in 2013 with a change to the General Permitted Development Order to specific change of use to address the shortage of homes. Two years later, the permitted development rights to allow offices to be converted to residential use was made permanent.
These early days of change of use from commercial to residential saw some poor examples of office and light industrial conversions into homes, which are well documented (unfortunately dominating the media coverage despite some very successful examples).
To mitigate this impact, in 2020 the government introduced a further requirement, for all new PD schemes to provide adequate natural light and comply with minimum space standards, which are set at a national level.
The next stage in the evolution was the amalgamation of a number of different uses under a single use class umbrella. Class E, a new Use Class category, introduced in September 2020, incorporates a variety of uses including shops and professional services, offices, a range of healthcare uses and indoor recreation – meaning that any changes between these uses do not require local planning authority discretion.
Then, from Class E sprang one of the most useful (if somewhat controversial) permitted development rights (PDR), Class MA, which allows the change of use from Class E to residential (Class C3).
Whilst previously Class O had allowed the change of use from office to residential, due to the wide range of uses covered by Class E, Class MA can now be utilised on many more sites and in many more instances.
The introduction of Class E and Class MA seems to indicate an increased desire from the government to deliver much needed housing and, in theory at least,
Class MA should make this an easier process for developers.
The most recent update to the legislation now makes Class MA an even more attractive prospect as the 1,500 sq m floorspace threshold has now been omitted, as has the requirement for a site to have been vacant for a three month period prior to an application being submitted under Class MA.
Whilst there are very obvious benefits to developers under Class MA – such as no requirement to adhere to councils’ preferred unit mix or provide affordable housing (and lower application fees of course!) – the requirements are not dissimilar from other planning applications in terms of the number of supporting documents required.
For example, in pretty much every Class MA application I’ve been involved in, at a minimum, a daylight/sunlight assessment and transport statement have been required. Other supporting documentation could include a flood risk assessment or noise assessment depending on the site’s location. For sites within a conservation area, an impact assessment will also be needed.
Obviously, there is a need and responsibility to ensure that any residential units created under Class MA offer future occupiers a good standard of accommodation and that all units meet or exceed the minimum space standards and receive adequate levels of natural light (hence the daylight/sunlight assessments).
An common issue with Class MA applications is that the site may tick the majority of boxes, but as the host building was not necessarily designed as residential accommodation, external alterations may be required so that the site is suitable for dwellings. Mostly these alterations relate to the addition or repositioning of windows and doors and, in some cases, the provision of cycle and refuse stores. This often results in a full planning application (for the external changes) running concurrently with the application for Class MA (for change of use) which can cause confusion. An appeal decision in 2022 confirmed the eligibility of a prior approval application and full planning application being submitted simultaneously, so this should provide confidence that concurrent applications can work in unison.
Does this case law indicate the next stage in the
James Doherty is a Senior Planner in the London office of Boyer
evolution of change of use policy? Given the number of instances in which a developer will have to run concurrent applications to ensure a good standard of accommodation can be delivered, could even more flexibility be applied to Class MA which makes allowances for external alterations to be covered in a single prior approval?
It is my opinion that this would certainly make life easier for both the applicant and council and avoid confusion though I understand that any such change would need to be carefully worded to ensure that any external alterations covered by Class MA specifically relate to the need to provide a good standard of accommodation.
More than a decade on from the first change of use legislation was introduced, many of the best opportunities – well located offices and former industrial units with good natural light and access to public spaces – have already been utilised. The next generation of conversions will inevitably require more external changes to meet the necessary standards which cannot currently be achieved through PDR alone.
With the Government having recently updated the legislation to provide more flexibility, is it greedy or wishful thinking to hope that a further update could take place to avoid the hassle of having to, at times, run concurrent applications for ultimately the same end goal?
In view of the housing crisis and the need to provide quality homes, especially on central brownfield locations I, and I suspect many others, would support such a move as the next necessary change in permitted development rights. n
(SEE the presentation by Assael covered in the LP&DF report)
The young are most affected by change
Those most in need of new housing are unlikely to receive a notification letter, so how can they be expected to offer support for a development, asks Katherine Jones
Planning, by its very nature, concerns the future. As such, it could (perhaps should?) be argued that those afforded the greatest influence in planning should be those with the greatest stake in the future – the young.
When the Government announced ambitious long-term plans for London, Cambridge, Leeds and other urban areas last July (and made further funding commitments in the Spring Budget), it was immediately apparent that that plans for growth must include a younger representation.
With the average age of a first time buyer being 34, most buying their first home on these new settlements and urban extensions will be at primary school today. Some are not yet born; others may be old enough to contribute to the vision for their city – but do they feel empowered to do so?
There is undoubtedly a need for younger voices in planning discussions, especially considering that new homes tend to attract a younger demographic, and yet the planning applications for that muchneeded housing are frequently defeated by planning committees – committees more often than not comprising an older, home-owning demographic, potentially with a vested interest in resisting house building as a result, maintaining high house prices.
The problem is that the planning system simply isn’t set up to engage with those who are not yet on the housing ladder – which tends to be the younger demographic. For many under 35, the prospect of home ownership seems so distant that they are unlikely to engage with the planning process or shape future proposals for residential development. .
This is partly because young people, especially those who are renting, tend to be more mobile. They will not necessarily buy in the area in which they are currently renting, which further reduces the likelihood that they will take part in discussion on development proposals. Figures from the RTPI state that the majority of those who engage in planning are aged over 55; that response rates to a typical preplanning consultation are around 3% of those directly made aware of it, and for Local Plan consultations, the number is even lower, at less than 1% of the population.
There are many practical reasons for this lack of engagement among the young. For example, planning committees tend to be held during the day when most are at work or caring for children; information about planning applications and consultations is often confined to notification letters sent to existing neighbouring residents and notices in local newspapers – not the headlines which might possibly appear on social media but instead, the small ads which are located towards the end of the print editions – and readership of all newspapers in the UK dropped by two thirds between 2005 and 2021, according to Statistica. There is so much progress to be made. Councils’ requirements of consultation should go beyond newspaper advertisements, posters on lampposts and communication with parish councils, for example. Technology offers an alternative and an opportunity for a broader reach, but even so, the average Facebook user is now in their 30s. TikTok and other social
Katherine Jones is Associate Partner, Planning & Development, Carter Jonas
media platforms may be the means by which many young people engage online, but has such social media ever been used successfully to publicise a planning consultation?
A further issue is that the planning system is skewed towards existing homeowners who are more likely to object to an emerging development proposal or Local Plan, as they are often directly affected due to their proximity. Neighbour notification letters sent to existing properties close to a development proposal, a small notice in a local newspaper, or consultation with a parish council are unlikely to reach beyond existing local residents and garner any support.
Those most in need of new housing are unlikely to be the recipient of a neighbour notification letter, so how can they be expected to be aware and offer support for a development?
It is a factor of all feedback mechanisms – from restaurant reviews to planning consultations – that those more likely to make an effort to respond are those with a strong objection, rather than those accepting of or indifferent to proposals. Furthermore, a planning system disinclined to elicit responses naturally exacerbates this situation and skews perceptions.
Letters of support to local planning authorities, either in relation to development proposals or emerging Local Plans, are few and far between and are typically significantly outweighed by the volume of objections.
The ability of the planning system to reach younger people has traditionally lagged behind that of other sectors despite the fact that young are those most affected by the changes. Perhaps these is an opportunity for the planning and development sector to learn from other sectors, and the large scale city visions present the ideal opportunity to put this into practice. n
What we do in the shadows…
‘Building Bigger’ brings into consideration one of the most controversial of legal property rights – the right to light, explains Paul Greatholder
To paraphrase Jane Austen, ‘It is a truth universally acknowledged that a developer in possession of a good site, must be in want of a new building that is considerably larger than what is there currently.’
But ‘Building Bigger’ brings into consideration one of the most controversial of legal property rights –the right to light. At its simplest, this is a right that a building’s windows (strictly ‘apertures’) has to receive the light which passes over someone else’s land. As such it is an inherently difficult right, because my use of my windows is stopping you from doing what you would like to do on your own land.
This was the situation that faced the City of London Corporation and their plan for Salisbury Square off Fleet Street in the City of London. A very substantial development (dubbed the Justice Quarter, including multiple court rooms and a police station) was planned which would cost no less than a quarter of a billion pounds.
It is important to understand that a right to light is not a right to a view, nor is it a right to sunlight. It is a right to enjoy a particular amount of sky-view, using arising from the long use of identified windows. If windows have a right to light then a neighbouring developer can’t reduce the amount of sky-view such that it is substantially diminished. What is ‘enough’ sky-view is determined by technical analysis that was developed in the 19th Century and usually described as the Waldram method.
There is an entire sector of the right to light and development industry that is gearing up for a fight about whether it is time to scrap the Waldram method. Nevertheless it holds sway at the moment and the practical effect is that developers have to take into account the views (in every sense of the word) of neighbours.
In the current legal landscape affected neighbours can, and do, bring legal claims which prevent development, or in some cases can require development to be ‘undone’ even once completed. If a developer can buy-off a neighbour’s claim then it will usually want to do so. Such compensation payments form a substantial element of any development budget. But the uncertainty such prospective claims bring is a cost in itself and a drag on development.
The City’s plans for the Justice Quarter appeared to affect the rights of light of at least 14 neighbouring buildings, some buildings being so affected that the legal threshold would be met whereby a possible injunction to prevent the development might be granted by a court.
These problems have increasingly been seen as an issue not only of private law rights between neighbours, but also an issue of concern for society as a whole if the interests of an individual property owner are disproportionately frustrating development which in all other respects is of benefit to society.
There is an parallel with compulsory purchase powers. When an authority exercises its compulsory purchase powers, an affected property owner is being deprived of its property. The quid pro quo for exercising CPO rights is that the affected property owner must be compensated for its loss. There are wellestablished processes for ascertaining compensation.
Something similar to CPO rights exists in relation to rights of light, and can be found in section 203 of the Housing and Planning Act 2016. Section 203 says ‘A person may carry out building…work… even if it involves …interfering with a relevant right or interest…’ if certain requirements of the statute are met.
Section 203 is not a new statutory intervention, as it is an updated version of section 237 of the Town
and Country Planning Act which allowed for certain private law rights to be overridden in certain circumstances.
The express material requirements are that there is planning consent for the building works and that the building works are either on land owned by a ‘specified authority’ or which has been appropriated by a local authority for planning purposes. Specified authorities is widely defined as including the Crown, central government departments and local authorities, statutory undertakers and any other statutory bodies.
The calculation of compensation payable to an affected landowner is on the same basis as compensation payable in respect of a CPO.
In the case of the Justice Quarter the City through its appointed surveyors had taken commercial negotiations with neighbours as far as it thought possible, reaching agreement with around half of them. This still however left other potential claims unresolved. The reports from those engaged in the negotiations suggest that the potential for claims would run in the millions of pounds and/or risked legal injunctions which would prevent development.
As such the City exercised its powers under Section 203 and overrode the rights of the neighbours, who must now look to their rights for compensation under the Act.
One point of great relevance to neighbours is that it is quite possible that the compensation they will be paid under s203 could well be less than the commercial proposals on offer as part of the negotiations. There is therefore a careful balance to be struck for neighbours between driving a hard bargain and pushing the authority to the point of exercising its statutory rights. Concerned neighbours should certainly be alert to whether a planned development is being carried out by a specified authority or whether it seems likely that an authority might intervene. n
Paul Greatholder is a partner in Russell Cooke
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Chancellor Reeves: “we are going to get Britain building again”
In her first speech as chancellor, Rachel Reeves pledged to fix the planning system, reintroduce mandatory housing targets and reform the National Planning Policy Framework (NPPF), as part of wide-ranging plans to reboot the economy.
Declaring “we are going to get Britain building again”, the former Bank of England economist said the reforms were the key to boosting growth and “fixing the foundations” of the British economy.
She said the first step in Labour’s plans would be to revise the NPPF, with the government to consult on a new growth-focused approach to the framework with the aim of introducing reforms by the end of this month.
To support this goal, Reeves said a taskforce had been created “to accelerate stalled housing sites in our country”, and was already working on sites such as Liverpool Central Docks, Worcester Parkway, Northstowe and Langley Sutton Coldfield to unlock 14,000 new homes.
Building on Labour’s pre-election pledges, Reeves said her and Keir Starmer’s new government would prioritise brownfield and greybelt land for development, and reform the planning system to “deliver the infrastructure that our country needs”.
Labour will also review planning applications previously turned down that could help the economy. Reeves pledged further intervention from housing secretary Angela Rayner, who is already reviewing two sites in Buckinghamshire and Hertfordshire.
The party has pledged to deliver 1.5 million homes over the next five years, the same as the Tories’ previous 300,000 homes a year target, and Reeves said mandatory targets would be reintroduced.
Rayner will also write to local planning authorities alongside the NPPF Consultation to make clear “what will now be expected of them, including universal coverage of local plans and reviews of greenbelt boundaries”, Reeves said.
She added that local authorities would be supported by 300 additional planning officers across the country, but her plans would not mean a “green light” to any kind of housing development.
Tallest City tower decision delayed
Addressing the wider economic situation, she said: “I have repeatedly warned that whoever won the general election would inherit the worst set of circumstances since the Second World War.
“This Labour government has been elected to get things done and get building again. We will make tough decisions to realise that mandate. With these steps, we have done more to unblock the planning system in the past 72 hours than the last government did in 14 years.”
Her other commitments included giving priority to energy projects, ending the “absurd ban” on new onshore wind farms in England, setting out new policy intentions for critical infrastructure in the coming months, and working with the transport and energy security secretaries to prioritise decisions on unresolved infrastructure projects. –From a report by Ciaran Nerval in Property Week
Angela Rayner and Matthew Pennycook appointed
Angela Rayner has officially been appointed deputy prime minister and the new secretary of state for housing, levelling-up and communities, following the Labour Party's election win.
She will be joined by Matthew Pennycook, who has been appointed as housing and levelling up minister. Pennycook has served as MP for Greenwich and Woolwich since May 2015, and has also served as shadow housing minister since 2021.
Elevated views prove popular
The City of London’s elevated public spaces are proving popular with the public, as visitor numbers continue to soar.
In the year since 20 Fenchurch Street’s Sky Garden welcomed its 10 millionth visitor, a million more have come, reportedly making it one of the world’s most ticketed destinations.
Now, the Square Mile’s newest public roof gardens, terraces and viewing galleries are significantly contributing to the City’s increasing footfall, with 120 Fenchurch’s roof garden (opened Feb 2019) having recently received over 1.5 million visitors, as well as the ‘The Lookout’ at 8 Bishopsgate and ‘Horizon 22’ at 22 Bishopsgate greeting more than half a million people, in less than a year.
With their inclusive, free to visit vantage points and exceptional experiences, each offering unique views over London and its landmarks, this diverse range of award winning and internationally renowned public spaces is helping to drive economic growth, and redefine the City as a welcoming, seven day a week destination, for all communities.
As the public appetite for these sites continues to grow, the City Corporation is aiming to increase their number with more under construction, including 1 Leadenhall Court, 50 Fenchurch Street, Seal House, Millenium Bridge House and Citicape House, Holborn.
Undershaft: Decision on skyscraper as tall as The Shard delayed after public square concerns raised after the chairman of Lloyd's of London had written to the Corporation stating it ‘would rob the City of a really important convening space’.
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London boroughs top lowest approval rates
Department for Levelling Up, Housing and Communities (DLUHC) statistics reveal that of the ten councils with the lowest application approval rates, eight are London boroughs and all ten are in the Greater South East, which includes the South East and East of England.
Of the 50 authorities with the lowest approval rates, 20 are London councils and 38just over three-quarters - are in the Greater South East.
The London Borough of Barking and Dagenham reported the lowest approval rate, having granted permission for just 60.8 per cent of the 719 decisions it made in the year to March 2024. This marks a decrease compared to 2022/23 when the council approved 66 per cent of applications.
The deputy managing director at Be First, the regeneration arm of Barking and Dagenham council, Caroline Harper said: “We are ranked first nationally for determining major and nonmajor planning applications within determination times, even with the government’s changes to its performance metrics.”
Last quarter, Harper said that a “large proportion of refusals on minor and householder applications are for properties within the Becontree Estate” a “non-designated heritage asset where unsympathetic development is resisted”, and this continues to be the case, according to the council.
Meanwhile, some 69 per cent of Barking and Dagenham Council's planning appeals were dismissed in the year 2023/24. Harper said this is "above the national average and shows that the Planning Inspectorate is agreeing with the majority of our decisions".
The London Borough of Croydon came in second place with an approval rate of 64.5 per cent, followed by Essex authority Epping Forest District Council in third with an approval rate of 64.6 per cent. The authorities considered a total of 1,917 and 1,441 applications over the year, the figures show.
This compares to an average approval rate of 85.6 per cent across England.
The City of London and London Legacy Development Corporation came in second and
third place having granted permission for respectively 99.1 and 97.7 per cent of the applications they decided over the 12 months.
The only other London authority that features in the list of 31 councils with the highest approval rates is Old Oak and Park Royal Development Corporation, which granted 96.6 per cent of its 29 decisions it made in the 2023/24 financial year and came eighth.
No councils had a 100 per cent approval rate in the 2023/24 financial year. However, in 2022/23, Ebbsfleet Development Corporation in Kent and Northumberland National Park both granted permission for 100 per cent of the applications they determined.
The regional averages show that London was the region with the lowest approval rate. Of the 44,648 decisions made in the capital in the year to March 2024, just 79.4 per cent were approved.
The North East was the region with the highest average approval rate at 91.4 per cent, approximately six percentage points higher than the national average of 85.7 per cent.
The England-wide average of 85.6 per cent is a slight drop compared to 87 per cent in 2022/23.
Overall, 285,316 applications were decided in the year to March 2024, down from the 376,907 applications decided last year and it marks a decrease for the third year in a row as 423,752 were decided in 2021/22
Labour should overhaul planning
The big opportunity is fixing the planning system. Britain has no more built-up land per person than it did in the 1990s; last year the number of planning applications fell to the lowest in almost three decades.
Labour’s leaders have identified the problem, but their rhetoric far outruns their policies. More planning officers and tougher house-building targets are too timid. Building new towns, a Labour enthusiasm, would be costly and slow: better to make cities bigger and denser.
Instead of trying to squeeze more out of the current planning system, Labour should overhaul it. That means allowing building on the green belt, the
The imminent loss of a daily print edition of the Evening Standard has been announced. Already a fading memory, Tube and bus travellers going home and all reading one of the Standard, the News or, once upon a time, the Evening Star Now it’s just iPhones!
rings of protected land surrounding many English cities, and moving from a discretionary model to a rules-based one in which projects that meet a design code go ahead automatically.
– The Economist
Reflect the genius of our age
A group of high profile architects led by HTA Design chair Ben Derbyshire has called on the Labour party not to “fall for” the idea that the future of housing design needs to be based on “historic” styles.
In a letter to The Times signed by the government’s former chief architect Andy von Bradsky and Proctor & Matthews founding director Andrew Matthews, Derbyshire said the next government should not try to solve the housing crisis by “seducing the electorate with AI-generated populist imagery”.
Last month, shadow housing secretary Angela Raynor outlined Labour’s plans to focus on traditional designs in order to win over the public as part of its drive to build 1.5 million homes during
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the course of its first Parliament if it wins the 4 July general election.
Rayner published a series of images of Victorian and Edwardian style buildings drawn up by Create Streets, the think tank founded by Nicholas Boys Smith which has been a key influence on communities secretary Michael Gove
She said that Labour’s plans to build a string of new towns would only include homes built with an “exemplary design, with real character that fits in around the local area.”
She added: “No more identikit homes straight out of a catalogue. We’re always hearing that people want tree-lined streets of townhouses, so that’s what we’ll build.”
The letter from Derbyshire, who is also an RIBA past president, was a response to Rayner’s comments.
Other signatories included Jane Duncan, also a RIBA past president, PRP director Ben Williamson, Levitt Bernstein managing director Matthew Goulcher, and Patrick Devlin and Andrew Beharrell of Pollard Thomas Edwards.
It said: “There is no need for the Labour Party to fall for the idea that the future of housing must be sold to the public as a return to traditional, historic ideas.”
While Derbyshire says architects can and do learn from the past, he argued the “great places of the future must surely reflect the genius of our age”.
“We agree with Create Streets that success — in terms of sustainable, walkable, attractive neighbourhoods — depends on a pattern of streets and green, open spaces,” he said.
“That is how we can comfortably accommodate diverse peoples, cultures, activities and nature, all at mid-density, but we must have different housing styles that reflect their local context and community.”
Derbyshire added: “The next generation of homes for heroes should be promoted with real design quality in mind, not historical, aesthetic populism.”
Create Streets’ design philosophy, which aims to reduce local opposition to new housing developments, has been highly influential in Tory circles and Gove’s controversial drive to ensure new buildings are “beautiful”.
But Rayner has accused the Conservatives of
allowing “badly designed houses, with families paying through the nose for dingy shoeboxes” as she promised firmer rules on access to nature and infrastructure along with more affordable homes.
– Building Design
Legislation, not taxation
It has to be asked whether offsetting is still an appropriate solution at a time when the need to reduce carbon emissions dramatically is getting ever more pressing.
Andrew Waugh, founding director at architect Waugh Thistleton, which is highly regarded for its work on environmental sustainability, says in Property Week: "The idea that somehow we can replace carbon with cash is crazy.
What we need is proper legislation to reduce carbon. I'm not surprised if developers get furious about this kind of spurious taxation.
What we need is decent legislation, not taxation in place of legislation.
"The idea that we can produce hundreds of thousands of tonnes of carbon and then ameliorate that with a sustainable drainage system or some electric vehicles is insane."
System-wide failure
Just over a fifth (21%) of applications were determined within the specified timeframe during the three months from July to September 2023. The average was closer to 28 weeks.
An 80% failure rate is indicative of a systemwide failure. The (recent planning reform) consultation aims to address the problem by allowing developers to pay a higher planning fee to see applications determined in only 10 weeks. The fee would be refunded if the application is not determined within the required timescale.
There are concerns, however, about whether such lofty ambitions can be met.
David Mathias, planning partner at law firm Shoosmiths, says that if implemented, the proposals could scupper any prospect of an improved planning regime as a whole.
"The emphasis on accelerating decision times and imposing punitive measures on local planning authorities that fail to meet these targets contradicts the goal of building a more efficient, well-resourced and sustainable planning system," says Mathias. – in Property Week
Carbuncles
Liverpool's Lime Street (Broadway & Malyan) is the winner of the 2024 Carbuncle Cup. Most of what is built is execrable. It is also true, however, that most of what is built has never been anywhere near an architect's office. Of all the housing in the UK (and this is where most of the worst architecture is), only about 6 per cent is designed by architects.
It is the model that is flawed. The UK's local authorities have been stripped of cash since the disastrous drive for austerity, their planning departments decimated. Planning is not proactive but reactive. It is left to developers to plan huge chunks of the city and virtually all national housing.
The UK has some of the most widely admired architectural practices in the world but its actual architecture is largely mediocre and often dire. That is what makes even a tongue-in-cheek humorous competition like this problematic. Sure it's a cheap laugh and it highlights some dreadful decisions. But it is only the tip of an iceberg of frozen sewage.
I don't much like singling out the worst. I'm not even that keen on awards for the best. It would be good, instead, to think that we were aiming for a decent average. But that doesn't generate headlines
Image of a traditional high street design, drawn up for Labour by Create Streets
or awards. Perhaps the question then is, has the Carbuncle Cup made architecture any better since its genesis in 2006?
The roll call of architectural disasters is long and depressing with occasional humour at the depths of incompetence. But the question is, has British architecture improved significantly?
And the answer is, probably not.
– Edwin Heathcote, the FT's architecture and design critic
Our corrupt planning system needs rebuilding
A stifling regime is deadening architecture and putting housebuilding in the hands of unscrupulous decision-makers, says Rohan Silva writing in The Times on 8th July. Here’s an extract.
The jobs these ex-government figures do next will rightly be scrutinised by the Advisory Committee on Business Appointments, which guards against insiders selling influence for cash. Compare this scrutiny to what happens when a senior planning officer steps down from a local council. They can quit their job and start working for property developers the next day with no meaningful checks or balances.
And to a greater degree than most former advisers, ex-planning officers can make serious money for clients — for example by calling up their friends at the council to wangle an extra storey on a proposed high-rise, or getting a planning application looked at more speedily.
Over the past few years our stiflingly bureaucratic planning system has become a major political issue because of its ruinous impact on housebuilding and the way it’s driven up the cost of new infrastructure.
An underdiscussed aspect of the broken regime is that lucrative planning decisions depend on backroom access to local bureaucrats and councillors. It’s a recipe for rampant corruption, as I saw first-hand when I started the creative workspace company Second Home after leaving Downing Street. (I stopped being a shareholder in 2022.)
Most of the time this works in a very British way. Rather than bribing a planning officer while they’re in their role, property developers hire them as consultants as soon as they quit the council — meaning their contacts are still fresh and no bribery laws are broken.
We were constantly pressed to hire consultants who had worked for whatever London borough we were trying to get planning permission through. The more recently they’d left their council jobs, the more they charged for their contact book and clout.
This kind of sleaze is endemic. I remember meeting the chairman of a London council planning committee to chat about an application my company had made. He steered the discussion towards a “perfume business” he wanted to start — and asked me if I could help him “get a loan of ten thousand pounds”. I earnestly told him about the government’s
Carbuncle Cup
Liverpool's Lime Street (Broadway & Malyan) is the winner of the 2024 Carbuncle Cup annual architecture prize given to the ugliest building in the United Kingdom. The Carbuncle Cup is an architecture prize, given annually, originally by the magazine Building Design, and since 2024 by The Fence, to "the ugliest building in the United Kingdom completed in the last 12 months". It was intended to be a humorous response to the prestigious Stirling Prize, given by the RIBA – Wikipedia
small business loan scheme, at which point the conversation fizzled out. I met up afterwards with my more streetwise business partner and recounted the story. “You idiot,” my partner said with a smile, “that was the bribe moment.” Suffice to say, we never paid the ten grand and we never did get that planning permission.
Another consequence of the torpid planning regime is the deadening effect on architecture. In every planning process Second Home was involved in, the first question from the planners was the same: what’s the precedent for this design? In other words, they wanted us to show them another building in London that looked like the one we were proposing. So if you wanted to do something new, like we did, the system was against you.
Time and again I saw experienced developers selfcensor and veto interesting architectural designs because they knew it would be far easier to get approval for a sterile grey box.
I’m sorry to say that when I worked in No 10 I didn’t realise how much damage the planning rules were causing. Now Sir Keir Starmer has admirably pledged to take action, in contrast to the craven way recent Tory governments shirked the problem.
The planning system is the last unadulterated vestige of postwar socialist utopianism, created in 1947 by the Town and Country Planning Act and founded on the well-meaning but ultimately flawed belief that a small group of people should dictate the development of complex systems, like an economy. Or a city. So real reform by Starmer will mean taking on cherished ideas of the left.
Other pillars of postwar socialism have been dismantled or have undergone market-oriented reforms, from state-run industries to the NHS, but the planning rules are essentially untouched. If Tony Blair deleting Clause 4 was totemic, Starmer liberalising the planning system would be historic. I sincerely hope he succeeds. n
Decisions down 11per cent and decided down 9pc over the past year
Latest planning performance by English districts and London boroughs: planning applications in England between January to March 2024
OVERVIEW
Between January to March 2024, district level planning authorities in England: received 85,800 applications for planning permission, down 11% from the same quarter a year earlier; decided 79,100 applications for planning permission, down 9% from the same quarter a year earlier; granted 67,400 decisions, down 10% from the same quarter a year earlier; this is equivalent to 85% of decisions, down 1 percentage point from the same quarter a year earlier; decided 90% of major applications within 13 weeks or the agreed time, up one percentage point from the same quarter a year earlier; and decided 19% of major applications within the statutory period of 13 weeks, up two percentage points from the same period a year earlier; granted 7,800 residential applications, down 7% from the same quarter a year earlier;
granted 1,600 applications for commercial developments, down 4% from the same quarter a year earlier; and decided 39,800 householder development applications, down 15% from the same quarter a year earlier. This accounted for 50% of all decisions, down from 53% a year earlier.
In the year ending March 2024, district level planning authorities: granted 285,300 decisions, down 13% from the year ending March 2023; and granted 32,000 residential applications, down 8% from the year ending March 2023.
Planning applications received
During January to March 2024, authorities undertaking district level planning in England received 85,800 applications for planning permission, down 11% from the same quarter a year earlier. In the year ending March 2024, authorities received 350,800 planning applications, down 11% from the year ending March 2023 (Live Table P134, PS1 Dashboard).
Planning decisions
Authorities reported 79,100 decisions on planning applications in January to March 2024, down 9% from the same quarter a year earlier. In the year ending March 2024, authorities decided 332,900 planning applications, down 12% from the year ending March 2023 (Live Tables P120/P133/P134, PS1/PS2 Dashboard).
Applications granted
During January to March 2024, authorities granted 67,400 decisions, down 10% from the same quarter a year earlier. This represented 85% of all decisions, down 1 percentage point from the same quarter a year earlier. In the year ending March 2024, authorities granted 285,300 decisions, down 13% from the year ending March 2023. Authorities granted 86% of all decisions, down one percentage point from the year ending March 2023 (Live Tables P120/P133, PS2 Dashboard).
Applications on hand
Authorities reported that they had 120,300 applications on hand as at 1 January 2024, down 14% from the same quarter a year earlier. This is 52% 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 120,000 as at 31 March 2024, down 14% 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 80% in London to 91% in North East (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 (52% to 100%) and other developments (70% to 100%) (PS2 Dashboard).
Speed of decisions
In January to March 2024, 90% of major applications were decided within 13 weeks or within the agreed time, up 1 percentage point from the same quarter a year earlier. 19% of major applications were decided within the statutory time period of 13 weeks, unchanged from the same quarter a year earlier.
Planning decisions by development type, speed of decision and local planning authority.
All tables and figures can be found here: https://tinyurl.com/49zbvztb
Source: DLUHC/ONS
In the same quarter, 87% of minor applications were decided within 8 weeks or within the agreed time, up 4 percentage points from the same quarter a year earlier. 38% of minor applications were decided within the statutory time period of 8 weeks, up 3 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 2 percentage points from the same quarter a year earlier. 55% of other applications were decided within the statutory time period of 8 weeks, up 5 percentage points from the same quarter a year earlier.
For more information on major, minor and other developments please see the PS1 and PS2 district planning matter guidance notes.
Figure 3 shows that the range between the whiskers for the percentage of decisions made in time this quarter for major developments was 69% to 100%, for minor developments it was 66% to 100% and for other developments it was 75% to 100% (PS2 Dashboard).
Use of performance agreements
‘‘Performance agreement’ is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments. Between January to March 2024, 44% 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 77% of major decisions involving a planning agreement, compared with 54% of minor decisions and 38% 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.
Once the figures for the relevant period have been published in Live Table P152 or P154, which identify local planning authorities are at risk of designation by exceeding the threshold, they are invited to contact Departmental officials with any data corrections, and information on any exceptional circumstances applying to the authority that might be used as reasons why the Secretary of State should not designate them. The Secretary of State then takes this evidence into account when making decisions on which authorities should be designated. See Live Tables P152/P154
Five local planning authorities are currently designated by the Secretary of State in relation to their planning performance. These are Uttlesford District Council (on 8th February 2022), Chorley Council (on 19th December 2023) and Lewes District Council (on 8th May 2024) in relation to quality of decision-making for major applications; and St Albans City and District Council on 6th March 2024) and Bristol City Council (on 6th March 2024) in relation to speed of decision-making for non-major applications.
Residential decisions
In January to March 2024, 11,200 decisions were made on applications for residential developments[footnote 3], of which 7,800 (70%) were granted. The number of residential decisions made was down 4% from the same quarter a year earlier, with the number granted down 7% from the same quarter a year earlier. 900 major residential decisions were granted, down 11% from the same quarter a year earlier and 6,900 major residential decisions were granted, down 6% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard).
In the year ending March 2024, 45,000 decisions were made on applications for residential developments, of which 32,000 (71%) were granted. The number of residential decisions made was down 6% from the previous year, with the number granted down 8% from the year ending March 2023. 3,700 major residential decisions were granted, down 12% from the previous year and 28,200 minor residential decisions were granted, down 8% from the previous year.
Residential units
The figures collected by the Department are the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each application, such as the number of homes in the case of housing developments. The Department supplements this information by obtaining statistics on housing permissions from a contractor, Glenigan[footnote 4].
The latest provisional figures show that permission for 236,000 homes was given in the year to March 2024, down 13% from the 270,000 homes granted permission in the year to March 2023. 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 January to March 2024, 1,900 decisions were made on applications for commercial developments[footnote 5], of which 1,600 (88%) were granted. The number of commercial decisions made was down 5% 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, down 6% from the
same quarter a year earlier and 1,300 minor commercial decisions were granted, down 4% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard).
In the year ending March 2024, 7,700 decisions were made on applications for commercial developments, of which 6,800 (88%) were granted. The number of commercial decisions made was down 5% from the previous year, with the number granted down 6% from the year ending March 2023. 1,500 major commercial decisions were granted, down 6% from the previous year and 5,300 minor commercial decisions were granted, down 6% 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 39,800 in the quarter ending March 2024, accounting for 50% of all decisions, down from 53% of all decisions made in the quarter ending March 2023. Authorities granted 88% of these applications and decided 92% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard).
In the year ending March 2024, 173,300 decisions were made on applications for householder developments, accounting for 52% of all decisions, down from 56% of all decisions made in the year ending March 2023. 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 collected on the quarterly PS2 return with effect from October 2021. During January to March 2024 there were 23 decisions, of which 22 were granted and 21 were decided in time (Live Table MJPSI – for the latest quarter only - PS2 Dashboard and PS2 open data table). 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 January to March 2024, local planning authorities reported 148 PiP (minor housing-led developments) decisions, 17 TDC (minor housingled developments) decisions and 2 TDC (major developments) decisions. The totals for the previ-
ous 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 – for the latest quarter only - PS2 dashboard and PS2 open data table).
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 January to March 2024, 5,300 applications were reported, of which prior approval was not required for 2,700, permission was granted for 1,500, and 1,100 were refused. This resulted in an overall acceptance rate[footnote 6] of 80%. Large householder extension accounted for 56% of all PDR applications reported, with 27% relating to All others, 7% relating to Agricultural to residential, and 6% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2).
In the quarter to March 2024, 800 permitted development right applications were made for changes to residential use, of which 500 (65%) were given the go-ahead without having to go through the full planning process.
Overall during the 40 quarters ending March 2024, district planning authorities reported 330,100 applications for prior approvals for permitted developments. For 184,900 of them prior approval was not required, 77,200 were granted and 68,000 were refused.
(Live Table PDR2). n
Design codes, Old Kent Road, PD changes of use and the City Plan 2040
Account of the Forum meeting on Tuesday 11th June 2024 hosted by UCL Report by Brian Whiteley of RTPI’s Planning Aid England also at www.planninginlondon.com
Summary
At its June meeting the LPDF featured presentations and discussions on three items:
1 Design codes
•Andy von Bradsky, former Head of Architecture, Ministry of Housing Communities and Local Government1 gave a presentation on the National Model Design Code, which is now being reviewed.
•Colin Wilson, Head of Strategic Development and Old Kent Road Regeneration, LB Southwark2 then gave a practical illustration of how an Action Area Plan/Opportunity Area Planning Framework is giving a clear design lead and speeding up housing delivery in a major regeneration area focussed around the Old Kent Road.
2 Permitted Development Conversions from Offices to Homes
•Adam Fothergill and Emily Newton from Assael3 explained how post-Covid office vacancies are a widespread issue across London (and the rest of the country). Using an example from a scheme in New Malden they put forward one suggestion, using GPDO rights (Class MA) plus planning permission, to get conversion schemes off the ground for mixed commercial and residential re-use.
3) City Plan 20404 : is it a model for authorities to focus on branding?
•Gudrun Andrews, Head of Planning Policy, City of London Corporation (CoL)• explained why the latest draft City Plan wants yet more tall buildings in (parts) of the Square Mile – not just to meet expected office demand up to 2040, but also as part of a wider strategy to introduce more cultural and other activities. This is with the (post-Covid) aim of restoring footfall in the City generally - by workers, visitors and tourists. Secondary vacant office space might even be considered suitable for hotel use – something the City has previously avoided.
Meeting recorded at: https://us02web.zoom.us/rec/share/L6Y_R_yJEKgVaM8L3N0FlMgidhp_4TG0HN7nlenGFYFfTSfPdsE3NwWmbCYArTM.BILvEjXITpkT-iqS - Passcode: czC&1CNv
Andy von Bradsky – Head of Architecture, Home Builders’ Federation
1. Outlined how the National Model Design Code (NMDC) gives local design codes statutory status as part of Local Plans6. It is now being reviewed to make it simpler - and is expected to aim to make local codes apply across full local planning authority (LPA) areas.
2. Currently Part 1 of the NMDC contains an exhaustive list of design priorities (see Figure 2 on page 8). Local Plan level codes need to identify key priorities for their areas from amongst that list.
3. Locality has produced Neighbourhood Planning Design Coding Guidance which includes templates groups can use to identify key design priorities for their plan areas7.
4. A key issue for local planning authorities (LPAs) with taking design codes forward in their areas is the current shortage of planning staff - and of relevant training - to skill up both Council Members and staff. Inevitably, consultancy support may be needed by many authorities to have codes drawn up. Authorities might have substantial evidence in place already – e.g. if they have townscape character assessments available. They will also need to appreciate that coding is not just about improving the visual character of their areas – but is about understanding how they function, i.e. a more holistic aim of “making places”.
5. The main benefits of local codes are anticipated as their giving developers more confidence about what LPAs will expect from the design of their schemes, consequently speeding up the planning process.
•Levelling Up and Regeneration Act requires every LPA to produce a design code.
•Authority-wide design codes should address design issues commonly found across the whole LPA area, or across areas and sites that have issues in common.
•NPGs may wish to produce a design code alongside policy or guidance.
•Design codes will have full weight in making decisions on development, either as part of local plans or being prepared as a supplementary plan.
•NPPF includes reference to design codes and NMDC guidance for preparing design codes.
Design code guidance
•DLUHCs Design Code Pathfinder programme worked with LPAs and NPGs using the process as described in the National Model Design Code.
•Programme learnings emphasised the need for guidance specific for NPGs who wish to produce codes for their areas.
•NMDC guidance is being reviewed to take account of feedback from pathfinders and new requirement in LURA for an ‘authority-wide’ design code.
•Need for simplification of the process, clarification of the requirement and more guidance on community engagement.
•Need for guidance for NPGs and community groups.
Brian Waters, BWCP, Chairman
Riette Oosterhuizen, HTA Design
Brian Whiteley, RTPI Planning Aid
Adam Fothergill and Emily Newton, Assael
Andy Rogers, ACAPAG
Benjamin Derbyshire, HTA Design
Andy von Bradsky, vonbradsky.uk
Colin Wilson, Southwark.gov.uk
Jessica Potter, Southwark.gov.uk
Michael Edwards, UCL [HOST]
Jessica Ferm, UCL
Gudrun Andrews, City of London.gov.uk
Katerina Karaga, Farrells
Lee Mallett, Urbik & PiL
Sarah White, wbd-uk.com
Martin Stacey, wbd-uk.com
Jessica Rose, wbd-uk.com
Lizzie Le Mare, Tibbalds
Andrew Catto, AC Architects
Nicholle Kingsley, Pinsent Masons
Grace Beeby, Planning Potentia
Helen Cuthbert, Planning Potential
Michael Coupe, Coupe Planning
Michael Kiely, POS
Paul Higgs, Millbank Land
Eric Sorensen
Patrick Iblis, ACA and ibla.co.uk
Stephen Heath, Bloomsbury Assn
Margaret Hollis, Civic Voice
Michael Bach, London Forum
Jon Donovan, Rolf Judd
Discussion points raised after this presentation included:
a. Currently London broughs are having to concentrate their resources on statutory responsibilities (local plan preparation) rather than non-statutory (design codes). Design criteria probably are less developed in Local Plans – is that a problem? Probably not in the sense that Supplementary Planning Documents can start to be developed alongside Plan policies – and probably take a shorter time (around 12-18 months) to come into effect. Nevertheless, there might be a policy vacuum which developers might try to exploit.
b. Building materials can be included in design codes - where appropriate – e.g. in National Parks such as the Yorkshire Dales or National Landscapes such as the Cotswolds.
c. Design Codes can be drawn up using other Local Plan evidence base documents – e.g. townscape character appraisals.
d. Whilst borough-wide codes seem unlikely to be possible, area design codes for specific, larger development areas seem more promising in London, e.g. in its 47 Opportunity Areas.
The way forward?
• Possible change of Government could lead to change of direction for design coding. They will need to be more permissive and rules based to match ambition.
• Appropriate tool for large scale new development such as urban extensions, new settlements and large scale developments.
• Need for simpler tools and processes for developing design codes including effective engagement processes, visioning and implementation, by LPAs before appointment of consultants.
• Upskilling LPAs and communities to be provided by private or public sector enablers.
• Define a meaningful role for Office for Place that is beyond just ‘visual planning’, providing sufficient resources to be effective nationally.
• Design codes are one of a number of tools that can be used to raise design quality – design review, community led design review, design guides, local plan policies all have a part to play.
• Design codes do not guarantee design quality but should identify a vision and design priorities for an area of change, give confidence to developers and speed up the planning process.
• There is no substitute for good clients, architects and designers. n
Design parameters
• Identify design priorities – not all issues need to be addressed;
• Visual – but not just about how places look;
• Concise – fewer words and more images;
• Relevant – according to context, character and scale;
• Numeric – where possible use precise requirements;
• Clear language – required, must vs should, could.
•NPDC guidance launched by Locality in April sets out practical guide for community groups.
•Simple step by step process, easy to understand for LPA‘s, NPG’s and communities.
•It includes tools and templates for local people and LPA officers to use to identify design priorities, set a vision for change and what should be included in local policies, design codes or guidance.
•The templates can be adapted for use by LPA’s, councillors, the communities they represent, and officers to determine content of design codes in advance of the appointment of external consultants, or project applications.
Community and business engagement
•Purpose of design codes is to speed up planning processes, with community, business, landowner and developer buy in for new development and change.
•Effective engagement is essential for design codes to fulfil their objective in smoothing the passage for applications - YIMBY not NIMBY.
•Simple and effective processes, use of new tools and techniques for place assessment and placemaking.
•Role of Citizen Panels, Citizen Assemblies, Community Review Panels in achieving participation from representatives from across the community.
•Role of Civic Societies, community interest groups, BIDs in shaping design codes.
•Engaging young people, including role of education.
Resources
•LPAs will need new skills to support development of authority-wide design codes – a new role and opportunity for urban designers and architects in many LPAs.
•Resources should be targeted to design coding for areas of change.
•There is not just one place or community in local authorities – a challenge for authority wide design codes which may become too generic to be effective.
•Training will be necessary for officers, councillors and community groups to raise awareness of design issues and design quality in places.
•The role of the private sector in delivering design codes, training and engagement.
OLD KENT ROAD
Colin Wilson – Head of Strategic Development and Old Kent Road Regeneration, LB Southwark
LB Southwark has a multi-disciplinary team tasked with leading regeneration in the Old Kent Road (OKR) Opportunity Area, further to publication of a first Action Area Plan/Opportunity Area Planning Framework in 20178.. The OKR runs for just under three miles from the Elephant and Castle to Peckham. It passes through Bermondsey and Walworth and leads on to New Cross, Deptford and Lewisham.
The area covered by the Area Action Plan (AAP) includes the full length of OKR as well as a significant part of the surrounding area. In total, it covers roughly one square mile (282 hectares). Given it has over 100 separate land ownerships in that area, it has fallen to the local authority to lead with co-ordinating future growth and development. LB Southwark’s framework concentrates on five specific districts in and around the OKR, each with its own distinctive character:
a. Mandela Way, Crimscott Street and the north end
b. Cantium Retail Park and Marlborough Grove
c. Sandgate Street and Verney Road
d. Hatcham, Ilderton and the south end
e. South Bermondsey
Consultancy support has been brought in to assist with drawing up local design codes for individual parts of the area covered by the AAP.
Crucially the AAP gives a lead – in consultation with various local communities across the area (e.g. involving work with community review panels, tenants’ and residents’ associations) – on where major development including tall buildings over 20 storeys in height will be focussed:
a.where two new Bakerloo Line Extension9 Tube stations are proposed, to mark their city- wide significance and optimise the use of land in the most accessible locations; and
b.at principal crossings, where the main roads from Peckham to Canada Water and from Walworth to Bermondsey cross the OKR; and
c.where the new Surrey Canal Park crosses OKR and adjacent to the largest new open spaces.
Auditing performance of the AAP is seen as crucial by LB Southwark. A recent audit showed that over 3,300 of an envisaged extra 20,000 homes have already been delivered or are under construction there (50% of these being affordable homes and a further 30% social rented homes). Having the AAP policy framework in place can be argued to
have speeded up housing delivery as a result Its OKR team offers a single point of contact for local residents, businesses and developers and attempts to balance the long-term objectives of the AAP with developers’ ideas and initiatives. Whilst the AAP sets out visual objectives for future development, it is not prescriptive in its design approach.
Discussion points raised after this presentation included:
a. LB Southwark is trying to foster car-free development across the AAP area. Estate renewal schemes are an exception, as residents insist on retaining car parking spaces there if they are to vote in favour of renewal going ahead.
b. The AAP is shortening the pre-application process for developers as they have much greater certainty about what will be expected on particular sites.
c. By-in to the OKR AAP involved a long period of intensive community consultation across the area. Residents were rarely unanimous in their views. But some of their ideas – particularly on new open spaces – have been taken on board.
B"3640 (66 0"# ,+*#4$(1# 1#6#2(/0C (,D/+E6#*)3/) 0"# ,"(66#/)#4$3/ 0"# (1#( 5+1.3/) (4'31(03+/4$5+1 5-0-1# *#2#6+'.#/0A !"# *#43)/ ,+*#4$"(2# ;##/ E+1*#* 0+ (66+E 5+1 ,#10(3/08 (/* 56#F3;36308 0+ )-3*# 5-0-1# "3)"$G-(6308 *#2#6+'.#/0A !"+4# ,+/43*#1#* (4$( requirement are worded as a ‘must’ and 0"+4# 0"(0 5+1. (4$)-3*(/,# (1# *#53/#* (4$ ‘could’ or ‘should’.
Permitted Development Conversions from Offices to Homes
Adam Fothergill and Emily Newton - Assael
They outlined how London’s high streets are facing re-purposing in the aftermath of Covid-19 and the subsequent change in working patterns. High Street office vacancy rates now stand at around 35%, and vacant retail at 14%. It is important to see a diversification of uses there, taking advantage of proximity to existing amenities and services. Re-use of existing structures offers a more sustainable approach, rather than demolition and redevelopment and can also encourage more active travel choices. It can allow speedier delivery of housing, bypassing the usual process of demolition and redevelopment.
They used a recent project at the former Tudor Williams department store (53-59, High Street, New Malden10 which is illustrated on following pages) as an example of how re-purposing a vacant building might be approached. Retail use of the ground floor was still viable, but not on the upper two floors. A change to a different use(s) on those floors was nec-
essary, preferably to meet other known local needs. They proposed a change of use on the upper floors to meet another major local need – housing – and adding an additional two-floor extension to provide a greater mix of units.
A combination of permitted development and formal planning approval was required. GPDO Class MA11 allowed the use change proposed and a twostorey extension above the existing three-storey original building. Planning permission was only needed for the outward appearance of the extended building – mainly regarding its new fenestration.
Discussion points raised after this presentation included:
a. Deep floorplates might prevent easy adaptation for residential use in vacant commercial buildings due to lack of adequate daylight.
b. Should new residential uses in converted commer-
cial buildings be for rental lettings only rather than for longer-term leaseholds – so as to avoid buildings losing flexibility with their future use?
c. Property values have to be high enough to support the higher costs of building conversions.
d. Post-War office buildings often skimped on floorto- ceiling heights and could make residential conversions difficult due to that.
e. Should all future commercial buildings be designed with flexibility of use in mind – making use of standardised components which allow for disassembly and re-use?
f. Multiple use of former commercial buildings is also possible - through GPDO Class V12
Gudrun Andrews - Head of Planning Policy, City of London Corporation (CoL)
Her presentation throughout emphasised that the City Plan 2040 is more than simply a regulatory land use document. It also fulfils a marketing strategy, in effect by seeking to expand the Square Mile’s attractiveness as a destination for visitors and tourists as well as a better place for the City’s workforce – with a broader range of attractions, leisure and recreational opportunities, greener streets, etc.
Although work started on the current City Plan in 2016 with the publication of Issues & Options, it has proved a longer than anticipated preparation period – partly whilst recovery from Covid-19 took place and revised working patterns and demands took shape in the City; and partly to address concerns voiced by the Mayor of London at the Regulation 19 consultation in Spring 2021. These focussed on conformity with London Plan with respect to tall buildings, sustainability, and inclusive growth.
Notably, the London Plan envisages the Central Activities Zone seeing an additional 1.2m sq ms office floorspace by 2041. An evidence base study in support of the City Plan has since been undertaken by Arups & Knight Frank. Expectations now are that employment will increase to 2040 by c. 60-70k jobs. The City is expected to need an extra 10% new office floorspace to facilitate that job growth. Capacity for 1.4m sq ms of additional office floorspace has been identified.
To meet part of that future office floorspace need, CoL are looking to develop tall office buildings in two clusters – (a) in an area to the north of Fenchurch Street and (b) in the Holborn / Fleet Valley area – see the Policies Maps C and D at: https://www.cityoflondon.gov.uk/assets/ServicesEnvironment/Policies-Maps-City-Plan-20402024.pdf - areas adjudged to be least invasive, e.g. in terms of affecting view corridors across London (using 3D modelling assessment) and impact on local listed buildings and conservation areas, and also with some of the highest accessibility by public transportSustainability is a further core theme. A “retrofit first” approach is being encouraged in the Plan’s design policies – cf: section 9.2 and Policy DE1: Sustainable Design on pages 126-127 and following reasoned justification at https://www.city-
Redevelopment to give an uplift in floorspacewhere this is acceptable in terms of other Plan policies – is also being encouraged. Section 9.3 and Policy DE2: Design Quality on pages 132-133 and following reasoned justification detail the sustainable building standards being sought for new build schemes. Active frontages are a focus, with the aim of encouraging new cultural and leisure uses to be introduced – as at Smithfields where the Museum of London is to be re-housed and with a student housing scheme at Crutched Friars where the Museum of Migration is to be re-housed - cf: https://www.google.co.uk/maps/place/Crutched+Fri ars,+London/@51.5112985,-
a. 55 / 70 / 85 Gracechurch Street – all three schemes involve major office floorspace provision and public amenity space gains – e.g. roof terraces open to the public at levels 29 & 30 at 85 Gracechurch Street.
b.1 Leadenhall – the tallest tower permitted to date is now subject to scheme revisions.
c. 55 Bishopsgate – New London Architecture are assisting the design here with the aim of introducing upper levels which will have public attractions and viewing points.
d. 81 Newgate Street (near St Paul’s) is to be the home of HSBC Bank, which is moving from its former base in Canary Wharf at 1 Canada Square. Open / Green Space provision – CoL are actively looking for opportunities to further enhance local streets and provide additional green space / walls / roofs in future – e.g. see: Section 9.4 and Policy DE3: Public Realm on pages 136-137 and following reasoned justification at
Policy OS1 on page 209 also commits CoL to seeking new open / green spaces where feasible across the Square Mile.
Discussion points raised after this presentation included:
a. General issues facing CoL are the decline in demand for Grade B office stock, with increased vacancy rates, and higher rental levels which upper floors command in new tall buildings. CoL is not looking for residential conversion of secondary, vacant office space; rather, to look at other alternative commercial uses where likely to be viable – possibly even hotels subject to assessment of their feasibility and impacts.
b. One exception to the non-residential stance here is where more specialist residential uses might be possible – e.g. student accommodation.
c. The digital modelling for the City Plan regarding future tall building locations might help introduce greater use of digital planning generally for future
CoL planning work. Certainly it has helped with arriving at future office floorspace potential.
d. The north bank of the Thames in the CoL is underdeveloped compared to the South Bank. Future development of the area for more pedestrian, cycling and recreational opportunities is much-needed.
Greater connectivity across Lower Thames Street would also assist opening up the north bank. n
“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’.
Three cheers for the grey-green belt ROGERS
Andy Rogers goes all colourful
In a dramatic statement one of the outgoing government’s most important and critical final acts (sorry - heavy sarcasm) was to change the designation “Areas of Outstanding Natural Beauty” (AONBs) to “National Landscapes” (NLs?). And in a similar move, Keir Starmer has suggested that numerous Green Belts should be reclassified as Grey - in other words green belt land that is generally ugly, derelict and/or unsightly.
Why stop there? I submit that thousands of hectares of Green Belt land could (along with our multitudinous Conservation Areas) usefully be renamed to better reflect their value and importance as well as to help our harassed development control planners to decide what is or is not ugly. So in the interest of complicating the planning system yet again (see Use Classes Orders and Permitted Development Rights), here is my proposed list of new land classes.
Grey Belts: this refers to land that the Labour Party points out is not “green, rolling hills, but poor quality scrub land, mothballed on the outskirts of towns … [which] should not be off limits while local people are kept off the housing ladder”.
Brown Belts: would refer to land that is or in the past has been occupied by structures or buildings that are no longer in use or have been overtaken by vegetation, but is not captured by the current definition of previously developed land (PDL) - such as airfields, derelict barns, redundant railway sidings, golf courses and abandoned agricultural uses. Also known as brownfield land.
Blue Belts: these are not local hotspots for dogging or other romantic uses but rather are marshy and flooded or similar inaccessible areas, often flood plains or derelict waterworks, where housing that is designed to cope with extreme rainfall (or even floating homes) could be allowed.
Red Belts: this would include areas that once were useful but are now too contaminated to be developed - such as old petrol filling stations, pubs in the remote countryside, derelict warehousing, etc. A system of subsidies and grants would be set
up to facilitate re-use of such land for housing, with the advantage that local infrastructure (roads, etc) would already be in place.
Yellow Belts: to include land currently designated as Open Metropolitan Land that has been recreational, possibly created by landfill waste, which is no longer able to serve the local community but could be arable or capable of carbon storage as well as low-density affordable housing.
Purple Belts: this would be land that has been compromised or detrimentally influenced by adjacent urbanising development, transport infrastructures, or non-agricultural human activity such as dog training areas and paddocks. It could include ‘rounding off’ of existing settlements.
White Belts: areas that might allow new or enhanced green infrastructure, woodland planting, improved landscaping and biodiversity, better recreational and playing field provision, and new or enhanced walking and cycle routes. It might include land that is ecologically and visually marginal, often inaccessible, with no real value to the wider society.
Black Belts: no, these are nothing to do with planning or land use but signify a high level of achievement in karate. (This includes belts of White, Gold, Green, Purple, Blue, Blue with Red Stripe, Red, Red with Brown Stripe, Brown, Brown with Single Black Stripe, and Brown with Double
Black Stripe, but let’s not go mad.)
Gold Belts: this category would be reserved for the exclusive existing areas designated as green belts that are really of high quality and therefore not only satisfy the main requirements of green belt designation (maintaining spatial openness, the prevention of unrestricted sprawl, safeguarding high quality and accessible countryside) but also should never be built on.
Contrary to popular belief, the green belt is not a landscape or environmental designation, but an instrument of physical planning policy constraint. As Nicky Gavron pointed out in The Planner last year, “much of our green belt land is in managed decline and the subject of hope value, as there is no basis to protect it, let alone enhance it for environmental purposes.”
The area of land designated as Green Belt in England has reached the highest level for over 20 years and is now some 1.7 million hectares, or 12.6 per cent of the land area of England. And it’s certainly time this was broken down into real and manageable parcels that properly describe their function and value to the communities living beside them - meaning in effect all of us. n
“The green belt is a Labour achievement –and we mean to build on it.”
– John Prescott, 1998
Andy Rogers is a planning consultant and former director in architects
The Manser Practice
https://www.londonsociety.org.uk
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PILLO! PILLO!
The God of Boring
I was already half way through this book by Thomas Heatherwick when to my surprise I saw that he’s giving the first night’s after dinner speech at the Oxford Joint Planning Law Conference this Autumn.
If you haven’t read it, Humanise is a good old fashioned, well-argued, entertainingly-illustrated, polemic against boring architecture. Page by page the battle lines are drawn:
- The importance of human-scale detail versus modernism (The God of Boring is how he describes Le Corbusier)
- makers versus architects
- scorn for architectural theorising and language.
Heatherwick has strong views but many people of course have strong views about Heatherwick.
For my part I reckon it’s always good to be challenged and whilst some of what he says may be self-serving or simplistic, it really is a brilliant diagnosis of why so much the built environment around us is just so…boring.
I’m looking forward to a non-boring after-dinner speech for once and a few good arguments in the bar afterwards… – Simon Ricketts
Peter Bill in Property Week:
A signed copy of Julian Richer's Our Housing Disaster - And What We Can Do About It plops through the letterbox, the envelope addressed by the man himself.
The Richer Sounds founder has penned a 7" by 4" pocket firecracker, a polemic that echoes, amplifies and adds to our findings in Broken Homes. The 65-year-old hi-fi retailer-turnedphilanthropist concludes there is no cure to chronic housing crises without a massive state-funded supply of 'social rent’ homes. Snap.
A conclusion with no politically acceptable solution, at least not yet.
It is a mark of Richer's inventive mind that he has conceived a way to capture land value before work starts: sell planning permissions. Replace Section 106 with a published tariff that varies, with rich boroughs charging more than poor boroughs. It is a mark of the negative thinking plaguing the planning debate that in response, all you will hear is the scoffing of self-interested experts,
proffering 1,001 reasons why it is unworkable. Remember the Infrastructure Levy? The plan to charge a low, fat, post-development fee on each unit's sale price? A hefty report from 2023 suggesting a 10-year pilot moulders in a Whitehall pigeonhole.
– Peter Bill is the author of Planet Property and Broken Homes AND see our review in Books
London is the brightest jewel
The cumulative burden of regulation and taxation matters when places like Dubai are luring professional services expats with tax-free salaries. Raising livability including by cutting traffic, raising air quality and supporting cultural services also adds an edge.
The next government needs to work with Khan to help drive London's growth. The city's fortunes will depend on national-level strategies on regulation, transport investment and taxation. The devolution of further powers, including for planning reforms and revenue raising, will also determine how effectively the mayor can lead the city.
Khan's growth strategy will in turn matter for the rest of the country. London is the brightest jewel in Britain's economy.
It must be kept shining. – FT leader
Coping strategies
“What if I have made a mistake?” asks Simon Ricketts (of himself, on LinkedIn).
For me that’s the worst part of being a solicitor. Wrong advice, miscommunications, dangerous typos, missed deadlines.
You know that feeling when you look over the balcony of a tall building and your legs go like jelly if you think too much about the consequences of falling? (Or is that just me?). That’s how I feel if start to catastrophise as to what the consequences might be of making a mistake. (Again, is that just me?). It’s not productive but how do we deal with it?
There’s plenty of practical advice around about what practically to do and the support that we need to give each other in an organisation to crosscheck work and make sure there are processes so as to minimise the risk of errors, and to encourage problems to be nipped in the bud and rectified.
But I wonder if the emotional toll this responsibility not to mess up, and squaring this with still being a human, takes over the length of a career is still somewhat of a taboo subject.
I had it again recently – that punch to the gut which saps your energy, makes you feel worthless, preys constantly on your mind. Worst of all/best of all, I hadn’t made the mistake I was worrying overwhat a waste of emotional energy.
I would be interested to hear about people’s coping strategies. For me:
• trying to allow myself enough time to think about what I’m doing, not being bounced into calls or responding to emails if I can’t focus professionally on what is required or am being encouraged to swim out of my lane - and trying to protect the team from being placed in that position
• operating as a team - two or more heads are better than one
• trying not to dwell on work issues overnight. “Sleeping on it” for me usually means not sleeping….
• self-reassurance as to past challenges overcomeand sharing past war stories, good and bad, with others (which is something we have recently done internally)
• Spock-like logic, always - if there really is a problem, share it, sort it. n
In London we have a housing shortage, a need to decarbonise our energy system and a productivity crisis. The electrical grid will be as crucial as our roads in addressing all of them, says Barny Evans
Solving the all-electric capital grid problem
London’s electrical grid is fundamental to the city’s operation and growth. Constraints and delays to it are holding back decarbonisation, business growth, the switch to electric vehicles and new housing and business. Most high profile has been the issues in West London, but at a lower profile, most development is becoming more expensive or slower because of grid constraints.
The solutions lie in a more proactive management of our networks, better recognition of how smart energy management is reducing the issue and incentivising us all to play our part.
In 2014, I worked on a report that explained how London was going to be all-electric. It explained the huge benefits in terms of CO2 emissions, air quality and noise. The all-electric London was going to be amazing. It required radical action; all new development to use heat pumps rather than gas boilers, a programme to support replacement of gas boilers as they failed, electric car clubs to provide universal access and a clear vision of that future.
What that report sought, is coming to pass. After a lot of misguided investment on heat networks and hydrogen cars and boilers, the world is slowly coming to understand that our cities will be all-electric, with some exceptions for heavy industry. What the report did not address was the crucial role of the electrical grid, and this was a major oversight.
The all-electric future means that we will be taking what were three energy supply routes; gas, electric and petrol/diesel and putting them into just one. A reasonable estimate is that London will end up using about 2-3 times as much electricity as it does now - that doesn’t include consideration of what growing demand for data centres will cause. The electrical network will be the universal energy highway of London in the future, and it will have a lot more traffic.
This is not some far-off future, almost all new development in London is now electric, around a quarter of new car sales are electric and we are beginning to see the retrofitting of heat pumps in the 3m+ homes in the city. We have already seen the impact additional grid demand has had in West London where development has been held up. Data centres, industrial development, major renewable energy projects and new housing are all being slowed and made more expensive. Many of the asset managers, investors and developers I work for have lengthy delays on projects to electrify fleets, build new buildings or electrify their existing stock.
The main reason our electrical networks have been unable to respond is that change is happening so much faster than before, and because they are regulated in a way that prevents proactive work. Our electrical system works on two levels, one
is the transmission level, run by National Grid and the second at the distribution level, run by Distribution Network Operators (DNOs). For London, that is mainly UK Power Networks and Scottish and Southern Energy in Hillingdon, Hounslow and Ealing. The DNOs are where most things connect.
Until recently, change on the electrical network had been slow and the system was functional. The problem is it does not work well when we are connecting so much renewable energy, EV chargers and switching gas boilers to heat pumps.
There are a couple of immediate solutions to the problem and the GLA and Londoners have a role to play.
Make better use of what we have
An irony of this problem is that for most of the time there isn’t one. The situation is analogous to our roads. Most of the time there is masses of capacity, but there is often congestion because usage is so peaky and we store cars on roads, unused 95% of the time. Our electrical networks have similar spikes at similar times. Below is a typical home daily energy profile and then an office profile. In homes you can see the rises you would expect as we get up, and then the big peak in the evening as people get home and cook dinner. With offices it is slightly different, matching typical working hours. There is a huge variation between the peak energy demand and the lowest energy demand, but the network must be sized for the peak.
London
Barny Evans is director sustainability and ESG at Turley
Barny Evans is a Director of Sustainability and ESG at Turley. He has worked in sustainability and energy for over twenty years and works for investors, government, asset managers and developers on how to be successful during the net zero transition and energy revolution.
If we can shift energy demands, such as when we heat hot water tanks, charge our electric vehicles, even turn on our dishwashers, then we could reduce peak demands and free-up space without increasing electrical capacity on the network.
The new regulatory structure for the network operators does allow them to incorporate these benefits in their analysis. Many businesses already engage in activities to reduce their peak demand for commercial reasons, but we have barely scratched the surface of what can be done.
Being smarter about new grid connections
Borough and GLA government could help here. For example, engage with major energy users in constrained areas to see how they can reduce peak demands; planning policy to require that all new residential developments provide shared electric car clubs and are set immediately on variable electricity tariffs that reward reducing peak demand; sponsor trials of energy shifting in areas with the network operators; target pinch-points for energy efficiency investment; even direct investment in batteries to help flatten energy demand.
Much of this is already common, people with heat pumps, solar on the roof and/or electric cars are often now on variable energy tariffs. If you have more than one of these things you would already be much better off on a variable energy tariff in most cases.
A major issue I am trying to engage industry on is the overestimating of grid connections for new housing. In the old days, with a gas boiler and no electric car (EV) charging, the industry standard allowance for a new development would be an average of 1.5kVA (a measure of power). In our new world, where almost all homes have heat pumps and EV charging, nobody is quite sure. The number must go up because we are adding electric heating and EV charging. The question is, how much? Some consultants and network operators are suggesting figures as high as 8kVA, although around 4.5kVA seems to be more common.
This may sound nerdy and niche, but it is in fact a huge issue. Even using the 4.5kVA figure means that we need an electrical connection triple the size previously required. This means that we need many more electrical upgrades before connection, all costing millions each time. When you bear in mind that existing homes are going to end up with heat pumps and electric vehicles, it would mean the whole grid needs to be triple the size for homes.
When you look at the data, however, demand is much lower than that. Evidence from the Centre for Net Zero’s Faraday data, that looks at historical energy demands, shows that peak demand in homes with EV charging, heat pumps and solar are <3kVA. The data here is for existing homes, so much less efficient than new homes in most cases. There are other examples.
I am told that the network operators are trapped under the current regulatory regime from incorporating the latest data. That regime changes soon and I expect that the GLA could work with UKPN and SSE to look at trials and or other workarounds for new development to request much smaller grid connections, enabling development. Even consultants and developers can be smarter about how much grid capacity they request.
In London, we have a housing shortage, a need to decarbonise our energy system and a productivity crisis. The electrical grid will be as crucial as our roads in addressing all of them. We need both urgency and innovation in how we enable it to adapt quickly and cost-effectively. n
The latest data on travel-towork patterns presents some challenges for planners, write Ciaran GunneJones, Emma Taylor and Ed Welch
From Rush Hour to Hush Hour?
We are regularly reminded by statisticians that surveys represent a ‘snapshot’ in time, providing a picture of data at a given point in time and not necessarily representative of long-term trends.
The 2021 Census perhaps represents the ultimate case study for the difficulties of inferring trends from a snapshot in time, having been conducted during a time of unprecedented restrictions on travel and social mixing during the third national lockdown of the Covid-19 pandemic.
In particular, the Census Origin-Destination commuting dataset, released by the Office for National Statistics (ONS) in October 2023, unsurprisingly records a significant increase in levels of homeworking and a corresponding fall in commuting flows to work. However, more recent survey data suggests that the majority of workers are now regularly commuting to work again, whether on a full-time or hybrid basis.
This poses a problem for planners and policymakers more widely, who typically rely upon Census commuting data to prepare evidence to inform policy on a range of issues, including both housing and economic development. The unique circumstances surrounding travel in 2021 casts some doubts over the applicability of the long-awaited Census 2021 data for this purpose.
The Census Origin-Destination datasets record the usual place of residence and workplace location of those in work and is used to show typical commuting patterns. This data helps us to understand the spatial relationships and the daily flows of people between places. Therefore, it is a useful tool in informing spatial planning decisions, particularly for both housing and employment land.
This includes helping to define functional economic market areas (‘FEMAs’), which indicate the spatial level at which local economies and markets actually operate. National Planning Policy Guidance (‘PPG’) requires that FEMAs are used to underpin economic development needs assessments which form a key component of the evidence base in planning for the economy.
The Origin-Destination dataset is also used by planners and economists to identify labour market areas for new employment developments, as well as strategic housing and employment site allocations. Given the changing patterns in the use of offices and the rise of home-working, it may also be tempting to look to Origin-Destination data as evidence for policies on the consolidation of office space or when making strategic decisions on public transport provision.
At the time of the 2021 Census on 21st March 2021, the UK was beginning to emerge from a third national Covid-19 lockdown. The Government had issued the ‘Roadmap out of Lockdown’ at the start of the month, reopening childcare facilities, schools, and colleges. However, the ‘stay at home’ rule was
still in effect for everyone except for key workers and construction workers on Census Day.
Despite these extraordinary circumstances, the ONS conducted the 2021 Census as originally planned with only minor clarifications to the questionnaire that had been tested between 2016 and 2020.
Rather than asking individuals about where they would have been working on collection day if lockdown restrictions were not in place, the ONS instead asked respondents where they were ‘ordinarily working’ on 21st March 2021, which may have affected how people responded to the question. This in turn may have inflated the figure for the number of homeworkers and masked the actual picture of usual commuting flows.
At a regional level, different trends emerge. The reduction in commuting flows is most noticeable in major cities, while more rural areas are less affected. The East of England and South East were most affected, a reflection of the prevalence of officebased occupations within the London workplace economy, as well as greater reliance on public transport connections – many of which were significantly reduced during this period – which workers may have chosen to avoid during the pandemic for social distancing reasons.
By contrast, the decline in commuting flow was less pronounced in the North of England. However, there is also a noticeable trend of decreased intercity travel during the pandemic, perhaps also a reflection of the desire to avoid public transport.
The data suggests that any long-term shift in commuting patterns is unlikely to be consistent across the country, with a rural to urban variation, and major office centres such as London being disproportionately affected.
More recently, Department for Transport (‘DfT’) Annual Travel Survey indicates that the number of commuting trips has started to recover since the pandemic, with commuting trips per person per year increasing by around 20% between 2021 and 2022.
This is reflected in public transport usage data – DfT reports that as of October 2023, rail journeys in Great Britain had recovered to around 80-90% of the pre-pandemic baseline, albeit the relative recovery has been largest for leisure journeys at weekends. Taken together, this suggests that the travel patterns observed in the 2021 Census are already outdated and no longer provide an accurate reflection of the current commuting landscape.
Trends from the DfT National Travel Survey and ONS Opinions and Lifestyle Survey suggest that the long-term impact of the pandemic on commuting has brought about a shift towards hybrid working styles, rather than full-time homeworking as some originally predicted. According to the DfT, commuting trips per person per year increased by around 20%
Ciaran Gunne-Jones is Senior Director and Head of Economics at Lichfields. Emma Taylor and Ed Welch are Economics Consultants
between 2021 and 2022.
The ONS survey results show over two-thirds of workers in managerial, professional and associate professional occupations either solely worked from home or hybrid worked between September 2022 and January 2023. Conversely, those in elementary or sales and customer service occupations were less likely to be able to work from home and therefore they mainly commuted to a place of work.
This typically leads to a higher concentration of commuting midweek, rather than an equal distribution across the week. For example, latest data from Transport for London shows that recovery in passenger numbers is consistently greater on Tuesday, Wednesday and Thursday. Meanwhile, younger people (aged 16 to 24) were also more likely to travel to work compared to other age groups, with only 6% choosing to exclusively work at home.
This demonstrates the need to accommodate a mid-week peak workday population into future planning policy. As physical infrastructure and the supply of employment space cannot flex over the course of a week, we must still plan for the peak and the geography of the flows associated with this.
At this stage it is impossible to say whether the trend of returning to the workplace will continue in the coming years; planning for a post-pandemic scenario of increased homeworking and hybrid working may be myopic if travel patterns continue to bounce back.
Underestimating the number of commuters under the ‘new normal’ risks leading to under-provision of employment space (notably for offices), transport infrastructure and public transport services. The long-term consequences of making decisions based solely on data that provides a ‘snapshot’ position of commuting flows in a period of restricted travel could be significant.
With this in mind, going forward there will be a need to integrate a greater range of data sources to the analysis of commuting patterns for planning policy. This may include exploring the use of new real-time data sources from mobile phones or from integrated transport networks, such as Google Community Mobility Reports or TfL data in London.
Building a travel picture from multiple sources would reduce the reliance on Census surveys conducted at ten-year intervals, help to smooth out short-term trends, and may allow for greater local specificity to aid more targeted planning policy. n
Photo credit
Belinda Fewings via Unsplash
This article is based on a blog post first published at www.lichfields.uk.
Julian Richer introduces
the book
Our Housing Disaster - and how to fix it
by Julian Richer with Kate Miller
Our Housing Disasterand how to fix it
Far too many people in this country cannot afford a decent roof over their heads - a growing scandal that is having huge social consequences. As a businessman who has had an active involvement with social housing and as a landlord myself, I've seen this problem grow, read numerous reports exposing the shocking facts and seen housing ministers come and go (15 since 2010!) –while little gets done.
This book has been a long time in the making. It was born in 2017 when I wrote a paper on social housing for the then shadow chancellor, John McDonnell. It started as a hotchpotch of observations and suggestions based on my 40 years of experience as a property owner, now with a sizeable property portfolio, but my frustration with the status quo pushed me to keep my thoughts alive and develop them further. Meanwhile, I could see the housing crisis getting worse, until it is now nothing less than a disaster.
Housing is a fundamental necessity for all of us, but it is a huge subject. Here in this book, I don't intend to cover all aspects of housing in the UK but want to focus on the most challenging and least glamorous sector, which is social housing. This is where I see the biggest problem for society, in that it's the most neglected sector, where there has been the least progress, causing the most suffering and affecting so many people in need of a decent and genuinely affordable place to live. It is also the sector where, I believe, the best solutions to our housing disaster lie.
Every year, as the gap between stagnant wages and rising house prices grows, fewer and fewer people can buy their own home. Consequently, millions are in private rented housing, paying high prices for insecure tenancies and often unsuitable and poorquality accommodation. A million more are on waiting lists for the dwindling number of council or housing association homes, and many more would like to join those lists if they could be deemed eligible.
seem likely. The only other way would be for families to cripple themselves financial ly, taking on a massive bur den of debt if they were allowed to borrow more than five times their earn ings, or locked into immensely long mortgages. Would that be good for them?
As I'll set out in this book, there are 8m people in this country in housing need, plus millions more who have a roof over their head in the private rented sector but live with the fear of arbitrary eviction or rents rising beyond their reach. Votecatching promises about increasing home ownership are not going to bring these people any closer to a secure home, in good condition, that they can afford.
I want a better deal for them.
Julian Richer
Having a secure, affordable home is a vital anchor in people’s lives – I might even argue it is a fundamental human right. It is surely something we expect in a modern democracy. By ‘affordable’ I mean genuinely affordable – where people can cover their housing costs through their caring or through housing benefit, without getting into financial difficulties. I emphasise this because, as I'll come back to in this book, the word 'affordable’ is frequently used in the housing sector in a very misleading way, referring to homes that are not at all within the reach of people on low, or even average, incomes.
Politicians’ responses to the growing housing disaster have been feeble. They are fixated on home ownership and, currently, Labour's main policy on housing is a claim that it will get the home ownership rate back up to 70%.
But let's drop this fantasy and face reality. For there to be a surge in homebuying, young peoples’ wages would have to shoot up, or house prices would have to plummet, or the taxpayer would have to finance huge state 'help to buy' subsidies. None of these
We have a housing disaster on our hands. This book argues that the only way to tackle it is with a new mindset, decisive acton, and cash. There is no escaping that the government will have to invest money, but in the long term there will also be huge savings, plus a gain in state assets. We need to recognise that providing good quality, rented housing, let on secure tenancies, at rents people can afford, is the only way to address society's immediate, urgent needs. We must acknowledge that this calls for state intervention - that the housing this country needs as a priority is what we’d broadly call ‘social housing’: homes to rent that have not been developed for profit. We need to admit that dismantling the supply of council housing, through a combination of underinvestment and the Right to Buy, has created a real social crisis.
Policymakers have already recognised that the UK has an undersupply of housing and that many more homes need to be built over the next decade. My argument is that boosting the supply cannot be simply up to the market. All that will happen is a repeat of what has taken place over the past 20 years, with house prices moving further and further out of reach for ordinary working people and nothing done for those who will never be able to buy.
In this book I look at how bad things are, how Britain got into this mess and what we can do to find practical ways forward. There is much that can be done if there is the will and if we can get rid of the legal and financial restrictions preventing the supply of genuinely affordable homes.
I'm calling on politicians, local authorities, and private landlords to have the courage to act, and to get this country out of the mire of bad housing that is causing misery for millions. n
SEE what Peter Bill says about this book in ¡PILLO!
An authoritative survey of British buildings between the wars by the late Gavin Stamp – one of Britain's bestknown architecture critics
INTERWAR British Architecture
1919-39 by GAVIN STAMP
592 Pp | £40 Hardback Profile books
INTERWAR British Architecture 1919-39 by Gavin Stamp
Jeremy Melvin writes:
Gavin Stamp, who died in 2017, devoted much of his career as an architectural historian to promoting architects whose reputations had suffered from swings in ideology and fashion, writes Jeremy Melvin.
Many of his favourites practised during the interwar period, though some began their careers before 1900 and several survived into the 1950s.
He was instrumental in founding the Thirties Society (itself a response to an influential exhibition at the Hayward Gallery in 1979), which has since become the Twentieth Century Society; he personally resurrected the reputation of Sir Giles Gilbert Scott – designer of Liverpool Anglican Cathedral and Cambridge University’s central library and much else, who was possibly his favourite and certainly the subject of his most extensive research. He also played a role in the revival of Edwin Lutyens’ reputation after another Hayward exhibition in 1981-2, and, as Private Eye’s architectural correspondent Piloti (where he replaced John Betjeman), became the scourge of unthinking redevelopment of buildings with even the most remote merit, their owners, local and statutory authorities and architects.
Left more or less finished at his death, Interwar: British Architecture 1919-1939 (Profile Books, £40) was prepared for publication by his widow Rosemary Hill (herself a biographer of AWN Pugin), who also contributes a foreword. This book can be
seen as the culmination of Stamp’s oeuvre. In assembling a cast of interesting, sometimes superb but often quirky buildings, it does not disappoint. True to form, it is also provocative and opinionated, often with some justification. He claims Lutyens’ Memorial Arch at Thiepval, a tribute to the British army’s missing on the Somme, is the best piece of British architecture of the period, which is eccentric though not wholly unsupportable. Less plausible are the seemingly endless array of elaborated shaped and constructed new churches in suburbs (often London but also other cities). The best are outstanding, but too often they seem formulaic compositions based on a loose interpretation of the ziggurat form. The urge for ziggurats has unclear origins though may have something to do with the awakening interest in Byzantine architecture, with centralised plans rising to a dome. But many of these churches see, to this reviewer at least, to be the equivalent of the long – and dreadfully tedious –poems that TS Eliot, long after ‘The Wasteland’ and ‘Ash Wednesday’, wrote to fulfil his duty as a convert to Anglicanism.
Most of these buildings appear in the chapter ‘Modern Gothic’, though in some examples the gothicness is even less apparent than in Modern Gothic Architecture, a book written by Sir T G Jackson in 1873, which underpinned the ‘Queen Anne revival’ of the late 19th century. Other chapters are Armistice (war memorials); the Grand Manner – monumental classicism; Swedish Grace; Brave New World, in respect of new building
INTERWAR British Architecture 1919-39 by Gavin Stamp
A comprehensively illustrated & refreshing history of inter-war British architecture that looks beyond modernism and gives a fuller picture of a rich and varied era.
British architecture between the wars is most famous for the rise of modernism – the flat roofs, clean lines and concrete of the Isokon flats in Hampstead and the Penguin Pool at London Zoo –but the reality was far more diverse. As the modernists came of age and the traditionalists began to decline, there arose a rich variety of styles and tastes in Britain and across the empire, a variety that reflected the restless zeitgeist of the years before the Second World War.
At the time of his death in 2017, Gavin Stamp, one of Britain's leading architectural critics, was at work on a deeply considered account of British architecture in the interwar period, correcting what he saw as the skewed view of earlier historians who were unable to see past modernism. Beginning with a survey of the modern movement after the armistice, Interwar untangles the threads that link lesser-known movements like the Egyptian
revival with the enduring popularity of the Tudorbethan, to chronicle one of Britain's most dynamic architectural periods. The result is more than an architectural historyit is the portrait of a changing nation.
As an account of the period that still shapes much of Britain's towns and cities, Gavin Stamp's final work is the definitive history of British architecture between the Great War and the Blitz.
Gavin Stamp was an architectural historian and scholar, one of Britain's leading experts on pre-war building and design. 'Brought up in a Tudor bungalow on the Orpington by-pass', as he recalled, he was educated on a scholarship at Dulwich College. Prolific as an author, curator and journalist, as 'Piloti' he wrote Private Eye's 'Nooks & Corners' column from 1978 until his death in 2017.
He was chairman of the 20th-Century Society from 19832007, and wrote more than twenty books on topics including Edwin Lutyens, George Gilbert Scott, brutalism, and telephone boxes.
types like tube stations; Tutankhamen, dealing with the vogue, following the opening of the boy pharaoh’s tomb in 1922, for Egyptiana and its cousin, the English version of Art Deco; the arts and craft diehards in Merrie England; the New Georgians; and a slightly mealy-mouthed analysis of modernism and social architecture in The Shape of Things to Come.
This certainly looks comprehensive. There is much to enjoy, since Stamp writes elegantly, informatively and with wit. His pithy way of recording what his acute eye noticed introduces new ways of looking at buildings that conventional opinion had dismissed. However, at times his enthusiasm carries him away – do we need so many mentions of Sir Giles Scott’s World War I Memorial Chapel at Charterhouse, for instance? I am sure Stamp would have justified this vigorously, if only because to modernists it would superficially have been anathema; his close inspection might reveal greater depth.
Stamp clearly enjoys eclecticism. He relishes Oliver Hill’s undogmatic capability to swing from modernism in a series of houses at Frinton-on-Sea or the Midland Hotel in Morecombe, through the almost Spanish Revivalism (Marylands in Surrey) to the ruggedly magnificent arts-and- crafts-based Cour House in Kintyre. In the same country, similarly rugged but recognisably classical, he admires Robert Lorimer’s Scottish National War Memorial.
And of course his dislike for Herbert Baker’s London work, such as the elephantine additions to the Bank of England, draw his ire, though he respects other commissions such as the Winchester College War Memorial. Indeed his comment that Baker’s triumph in getting that commission over his old bete noire Lutyens may have saved the latter a loss of reputation. It is Lutyens whom Stamp admires alongside Sir Giles Gilbert Scott (two of the six architects to receive the Order of Merit, the highest British honour). Stamp’s opinion of the Thiepval Arch has already been mentioned, but the Viceroy’s House in New Delhi (now Rashtrapati Bhavan or President’s Palace) is almost as praised.
In this range, admirable though it is, lies the rub. For all its erudition, this book remains a litany of building descriptions. There is little analysis of the underlying forces that were driving architecture at the time, bar the odd reference to the collective shock and national grief that arose after World War I, or the need to build new churches in expanding suburbs. The major housebuilding programme following that war gets no more than a passing mention.
This period saw a remarkable and often inventive eclecticism, which was almost guillotined at the end by World War II and its effects, one of which was to bring modernism to the fore as a mode for publicly funded architecture. The generation who held sway after 1945 may not have agreed on what modernism was, but they knew they had to present themselves as modernists. How and why this happened may be outside the strict scope of Stamp’s work, but it does beg the question of why one mode,
which barely existed before 1939, swept almost all before it after 1945.
One partial answer is that the 1930s saw the fulfilment of the RIBA’s policy of compulsory registration for architects. Started in the 1890s, when all the best-known architects opposed it, registration finally became law in 1938. It meant that architects, for the first time, became an identifiable and legally recognisable group to whom a technocratic government, first during World War II and then during post-war reconstruction, could turn to in realising their policies for munitions factories or housing.
Bound up with this is the growth of town planning, again through statutory legislation in the 1930s – generally considered unsatisfactory. Cemented through (second-world) wartime policies established by the Barlow Commission and the Abercrombie Reports, it culminated in the Town & Country Planning Act of 1947. The evil genius behind this was J M Keynes, the leading light on the Macmillan Commission of the early 1930s, who managed >>>
BELOW:
to transform conceptions of planning from a function of public health into a tool of economic policy. Both registration and statutory planning still shape the possibilities and indeed the very existence of the architectural profession. Bound up with this is the growth of town planning, again through statutory legislation in the 1930s – generally considered unsatisfactory.
Cemented through (second-world) wartime policies established by the Barlow Commission and the Abercrombie Reports, it culminated in the Town & Country Planning Act of 1947. The evil genius behind this was J M Keynes, the leading light on the Macmillan Commission of the early 1930s, who managed to transform conceptions of planning from a function of public health into a tool of economic policy. Both registration and
statutory planning still shape the possibilities and indeed the very existence of the architectural profession.
Both registration and planning segued into the architectural profession’s collective liking for socialist policies, which guaranteed a stream of post-1945 work on fixed fee scales. Principals of firms like Yorke Rosenberg and Mardall, Powell and Moya, and Howell Killick Partridge and Amis benefited enormously from the public building policy covering housing, education and health.
Exploring this would require another book and an author with another set of skills. It would complement Stamp’s impressive prelude. n
First published by World Festival of Architecture, with kind consent
RIGHT:
Arnos Grove Underground Station (Charles Holden, Adams Holden & Pearson 1932)
Look Here - On the Pleasures of Observing the City by Ana Kinsella, Daunt
Books reviewed by Diane Cunningham, London Society Trustee
£9.19 on Amazon
Look Hereon the Pleasures of Observing the City
Ana Kinsella takes the reader on a stroll across London observing its buildings, people and seasons as the walks frame moments in time, revisit memories and form new ones. With some of the book set amid the Covid-19 pandemic, it also captures the very strange time when central London was empty; when it felt like someone had pressed pause, yet only a couple of miles either side some neighbourhoods thrived and parks became the centre of outdoor life.
The book connects the reader to London and even for those who don’t know it that well there will be mentions of a view, a building or a journey that will likely stir a memory.
Not content with offering her own memories and observations on her London walks the author also intersperses her thoughts with individuals, tube station staff, musicians, fashion designers and others, some of whom remain anonymous, reinforcing that it’s the capital which is the focus here.
From Chinatown to Smithfield, Hampstead to Mayfair she criss-crosses London and its neighbourhoods from the globally famous Oxford Circus, Tate Modern and Trafalgar Square to the neighbourhood squares at a more local level where she notices the trees and benches near her home and how the people who
use the space interact with each other. Along the way there are field notes to mark the seasons and how areas change.
A quote by American urban planner Kevin Lynch puts the book in context as he suggested that “We use the built environment - streets, walls, districts, monuments - to form a mental map of the place where we live”.
This is what Kinsella does in taking us with her on a walk around London and in reminding us that there are many aspects of cities that shape how we experience them.
Perhaps the key takeaway is how it’s impossible to be an objective onlooker – anywhere - but more so in cities as there is so much to observe. Kinsella suggests that we always bring our own identities and biases and experience with us during our observations and also that there are barriers to movement that relate to class, race and money if we choose to look.
Whether you know London really well or just pass through, this book in an enjoyable read. It comes back to you when you’re walking around some of the better-known places featured and makes you pause a little longer now as a reminder to see what’s around you. n
From the London Society newsletter
Planning and Environment Reference Guide
Please notify any changes immediately by e-mail to planninginlondon@mac.com with the subject ‘planning in london directory’.
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London Borough of Hackney
Environment and Planning
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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
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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
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Head of Policy & Spatial Planning Pat Cox pat.cox@lbhf.gov.uk 020 8753 5773
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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
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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
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The Forge, a net zero scheme on London's Bankside, offers many lessons for sustainable development, explains Paul Finch
Forging a deliverable zero-carbon blueprint
The drive to reduce, and where possible eliminate, carbon emissions continues to grip the property and construction sectors. While the new buzzword about offices and the areas in which they sit is 'vibrancy', it is difficult to legislate for that - as this week's British Council for Offices (BCO) conference, in a newly vibrant Birmingham, will no doubt discuss.
For policymakers, it is much easier to focus regulation on factors that have numbers attached - and the focus continues to become tougher. How is the sector responding to the challenge of avoiding near-pariah status in the world of some environmentalists, who seem opposed to almost any form of new commercial construction?
Paul Finch is programme director of the World Architecture Festival
If you want to see what leading from the front is all about, head down to Bankside and view The Forge, the Landsec development that is its first zero-carbon office project. It is not just the company that is saying this; the design is in accordance with the net zero carbon framework of the UK Green Building Council, whose criteria have been met (with final performance subject to scrutiny of energy bills after a year of occupation). It is net zero carbon in terms of both construction and operation and is BREEAM 'Excellent' and WELL 'Gold' rated.
There are two buildings totalling 139,000 sq ft, the larger of which is 90,000 sq ft; the smaller one run by Myo, Landsec's flexible and fully serviced office operation, is connected by a courtyard.
They replaced a humdrum warehouse and office on the site - the name 'The Forge' referring to previous industrial use as a bronze foundry on the site. The architect is Piercy&Company, and multidisciplinary engineer and designer Bryden Wood played a significant part in the thinking behind the building.
But the key team member behind the nine-storey project is Landsec's head of design innovation, Neil Pennell, who has been ploughing the energy and productivity furrow for
Carbon cutter: Landsec's The Forge is an exemplary low-carbon project
many years, and has given much service to the BCo on a range of technical matters. His enthusiasm for The Forge is huge, not least because it is the thinking behind what has been achieved that suggests it can be a precedent project.
'Design for manufacture and assembly' principles were adopted and combined with modern methods of construction to analyse every aspect of how architecture, engineering construction and delivery could become exemplars of a synthetic approach that incorporated time-saving as a critical element of thinking.
Construction itself was undertaken by a first-time collaboration between Sir Robert McAlpine and Mace, preceded by mockups of certain building processes on a redundant dairy farm in the West Country prior to introduction on site. The project was delivered via a construction management form of contract.
Everything came under scrutiny as the potential of the project to hit net zero generated innovative approaches; the basement was revamped and slashed in area to hit 2030 carbon targets (message: avoid basements if possible); boilers were eliminated and air-source heat pumps introduced; beams were bolted rather than welded; and a reusable set of temporary works was used to create the floor slabs.
This involves a hybrid steel and concrete structural platform, notes Bryden Wood. This was part of a UKRI Innovate UK Transforming Construction Challenge Fund research project, on automated construction. The structural platform developed as part of the project provided the chassis for the office floorspace, while the development of cladding and building services components created a reusable kit of parts.
Pennell points to the 18% of steel and 13% of concrete taken out of the initial estimates of what would be required, reflecting the thinking of the Construction Productivity Taskforce, to drive greater efficiencies in the use of material and labour resources. This resulted in a 40% embodied carbon reduction compared with a first conventional design; of this, 50% came from changes to structure.
Aren't experimental projects like this bound to be expensive? Pennell's attitude to this is based on looking at the whole process of what is involved in creating a building. Where do prelims fit into the cost analysis? How do you reflect in the construction cost the time it takes to build? In the end, if you build it better and faster, making the most of prefabrication (tighter tolerances, factory accuracy), and factor in continuous improvement through reuse of the approach, it will work for you.
As it happens, the Bankside area is currently the subject of a planning strategy to increase its 'vibrancy', which is welcome. Having said that, occupiers still need great kit.
