LP&DF: pages 34-43 Jørn Peters, GLA London Plan team, professor Ian Gordon, LSE and Peter Eversden, Vice Chair London Forum; Encouraging ideas for the next London Plan Lee Mallett page11; Response from London Forum of Amenity Societies page 28; The big change in the next London Plan Zack Simons KC page 46; Section 106 agreements Simon Ricketts page 55; Images from space Dan Lewis page 15; Over-regulation Robert Adam page 17; Temporary modular housing Colin Ainger p58
LP&DF page 34 THE ESSENTIAL GUIDE TO
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PIL 134 CONTENTS
PAGE
5 LEADERS
The pack ice may be shifting; Memorials are tricky; Focus on enhancements to existing housing stock
7 A Fitting Memorial | Bryan Avery & Anthony Carlile
10 PAUL FINCH
Encouraging ideas for the next London Plan
LEE MALLETT page 11
Encouraging ideas for the next London Plan
IAN BARNETT page 20
The architecture of planning
11 LEE MALLETT
Encouraging ideas for the next London Plan
OPINIONS
14 How applications are determined | Paul Smith
15 Images from space | Dan Lewis
16 Planning reforms for small developments | Fergus Charlton
17 Over-regulation | Robert Adam
18 Demand for office space | Will Scott
19 Back the builders | James Cogan
20 A national approach to planning | Ian Barnett
22 The SME sector to the rescue | Andrew Golland
25 BRIEFING
CLIPBOARD: Backing for Oxford Street; Chancellor is accused of 'shortchanging’ the capital; The Economist City liveability index; AI to rev up planning promises PM
27 ¡PILLO!
City of London Building of the Year; 21 Moorfields; Obscene works underground
28 Response to ‘Towards a New London Plan’
30 PLANNING PERFORMANCE
Applications up but decisions down from the same quarter a year earlier
34 LONDON PLANNING & DEVELOPMENT FORUM
London Plan update, (some of) the Green Belt has got to go and Oxford Street pedestrianisation
35 Towards a New London Plan: Jorn Peters, GLA London Plan team with contributions from Professor Ian Gordon, Emeritus Professor of Human Geography, LSE and Peter Eversden, Vice Chair London Forum
40 The Mayor’s decided (some of) the Green Belt’s got to go: Response from Outer London Boroughs led by Yvonne Sampoh, LB Barnet
Principal Planning Officer (Policy) and Christopher Waller, LB Redbridge Planning Policy Officer
41 The pros and cons of Oxford Street pedestrianisation: Discussion led by Mark Willingale, Willingale Associates and Magnus Wills, Barr Gazetas
Continues next page
44 ANDREW ROGERS
Here is the news
FEATURES
45 Rebecca Dillon-Robinson | Design codes
46 Zack Simons | The big change in the next London Plan
52 Cumberland Gate and the Oxford Street shuttle | Mark Willingale
55 Section 106 agreements | Simon Ricketts
58 Temporary modular housing | Colin Ainger
61 Delivering well-designed homes | Glen Richardson
65 PLANNING AND ENVIRONMENT REFERENCE GUIDE
68 SUBSCRIPTION ORDER FORM
69 Shaping the World: Chelsea Waterfront | Shevaughn Rieck
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Lots of European cities are much denser than London
The pack ice may be shifting
Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992
There is one particular striking suggestion for increasing London’s development potential in the Mayor’s consultation document Towards a new London Plan – apart of course from changes to Green Belt policy.
To increase housing supply and encourage more types of housebuilders it suggests the next London Plan ‘could take a different approach’ and ‘set out building heights that should be acceptable in principle in all locations across London that share certain characteristics’.
‘The plan could also set a minimum height benchmark across London to support small site development,’ it adds. And these heights would reflect transport links, PDR rights and ‘opportunity for development already in the area’.
This of course wasn’t really an issue in London’s best-loved, most valuable neighbourhoods pre-1947. When the Victorians built Kensington and Chelsea they built what they thought they could rent, and eventually by the inter-war years, what they could sell.
It became an issue again for different reasons in the City of London which felt the need in the fierce rivalry with an emerging Canary Wharf in the early 90s. The City’s solution was to broadcast it was open for business to developers by indicating precisely what increased plot ratios of 5:1 (if memory serves) could be achieved where. A very handy planning switch that only the City dared flick. London is in a similar existential competition now when it comes to lack of housing.
London has lots of low density, unsustainable, but desperately needed and valuable, low-rise suburban housing and neighbourhoods. Local people and politicians have resisted in recent years, however, any suggestion that ‘zoning’ measures around density and heights might affect them. But that is precisely how London grew when it needed to, by increasing in height. And avoided land take by doing so, concentrating homes where there was (eventually) public transport. Lots of European cities are much denser than London.
A mandate to increase the height of development in some areas could a) encourage developers to pursue denser housing schemes, possibly on a smaller scale, and b) encourage homeowners to sell in designated areas helping site assembly, for private or social development.
Such blanket policies are controversial. Architect HTA’s ‘Superbia’ for example, met with little enthusiasm. But…it is an idea that could, more than any other perhaps, if liberated and accompanied by design guidance, help encourage development – with the possible exception of the scrapping of affordable housing policies which have excluded smaller builders and retarded supply of housing since their introduction in the early 00s.
The other big news in the document is the intention to revisit 10-unit thresholds for requiring inclusion of affordable housing, and the possibility of delaying payment for planning gain and CIL until later in the process when cash is flowing, improving viability and resources available for quality.
Hallelujah.
Nightmare statuary in London is not unknown
Memorials are tricky
It was predictable that Foster and Partners would win the competition for the late Queen’s memorial –at least once they had committed to entering. The practice has managed to combine technical innovation with a grasp of what the public might like for many decades, and the gravitas attaching to Lord Foster himself, now 90. His memorable remark, ‘I have everything left to achieve’ will have no doubt been a comfort to the selection committee; in any event, nobody has ever been fired for hiring Foster . . .
Memorials are one of those areas where the planning system generally feels uncomfortable, since it is not supposed to make aesthetic judgements, especially where (by definition) proposers are informed by a desire to express genuine gratitude/emotion in respect of the person or group being memorialised. You may or may not like the monument to Bomber Command on Piccadilly, but it would have been wrong to try to block it on planning grounds.
Nor is this an easy matter for architects. Adolf Loos declared that ‘Only a very small part of architecture belongs to art: the tomb and the monument’. In the case of the Elizabeth II memorial, there is the awkward question of statuary, with the potential sculptor wisely omitted from the Foster competition entry. Nightmare statuary in London is not unknown – as the memorial to dead warfare animals on Park Lane shows only too clearly. We must cross our fingers.
It should be said that the design drawn up by the late Bryan Avery for a site in Green Park, published in this issue, was a match for anything submitted in the competition, not least because of its use of water as a reflector – a symbol of calm.
One fears that the new Foster bridge in St James’s Park might simply become a maelstrom of selfieobsessed tourists, rather than a focus for contemplation of a royal life well lived. n
Focus on enhancements to existing housing stock
Incentivise better use of existing homes
The shortage of homes in England is more than a housing crisis. The Economist argues that it chokes economic growth and that more radical deregulation is needed.
The OBR predicts the fall of housing starts from 265,000 in 2024 to 192,000 in 2026. The GLA says just 1210 units started in Greater London in the first quarter of this year, the lowest since 2009, and that year-on-year starts have fallen by 31 per cent.
The government's new Affordable Homes Programme with its headline figure of £39 billion is not quite the increase claimed. Just the loss of Right to Buy income – £12.5 billion in the past 12 years –will diminish the impact of public funds available for social housing.
A greater and speedier impact might be achieved by focusing on enhancements to the existing housing stock in England: over 25 million dwellings.
Incentivising better use so as to encourage downsizing of under-occupied houses and the subdivision of homes to provide for young people as well as ‘later living’ households could go a long way to meeting the 1.5 million target for new homes.
Incentives should include discounts on stamp duty to reduce the cost of moving, and the enforcement of government policy to prevent local planning authorities imposing affordable homes taxation on smaller and medium size developments. n
A fitting memorial
With shortlisted competition designs receiving a mixed reception, we publish a scheme by the late Bryan Avery conceived for the Diamond Jubilee of the late Queen in the Green Park
Green Park is the Cinderella of London’s Royal Parks. Despite it being the most central, the closest to the West End, and having, uniquely, an underground station within its boundaries, it still remains the least memorable and least visited of all the parks.
In part this is because it sits between two more
glamorous neighbours, St James’s and Hyde Park but in part too it is because it has no defining feature. There is no attractive circumambulation as there is in the other parks, no “walk around the lake and back” and hence few stroll there.
Furthermore, apart from two wonderful avenues of London plane trees, there is little to occupy the
eye, no long vistas or features whereby to sit and muse, and there is insufficient distance from the noise of Piccadilly to make such a place tranquil.
The park has thus gradually been relegated into the pragmatic service of providing as short a route as possible for commuters and tourists between Green Park Underground and Buckingham Palace - and as a
nearby office workers. The proposal is to create a sequence of reflective pools that will cascade down the 10m (33ft) fall between the two avenues lining up a new statue to ERII in front of Devonshire Gate on Piccadilly with the axis to the Victoria Memorial in front of Buckingham Palace.
The pools will be shallow enough to be safe and the fall of water will generate a delightful background noise to drown out the traffic. At intervals during the day, a mist will be created over the pools like the mists over the Thames and then, as the mists clear, a series of multiple water cannons will project huge cascades of water over the pathways, ascending up the slope like a shoal of salmon leaping. At the top, when the last leap has been made, a row of spectacular fountains will erupt like geysers – like old faithful in Yosemite National Park.
Such will be the delight of this that Green Park may attain a new and unique character of it’s own and people, instead of passing through it, may come to enjoy it, to circum-ambulate around it, and to embrace it as one of the world’s most dramatic and compelling of London’s sights.
Anthony Carlile was a director at Avery Associates Architects and is principal at Anthony Carlile Architects
Here's what the press is saying about the Queen Elizabeth Il national memorial competition with visuals of the five shortlisted designs
• AP News frames it as a "permanent memorial" in St James's Park, noting its reflective purpose and proximity to Buckingham Palace. The five finalist schemes include giant limestone lily pads (Heatherwick Studio), royal gardens with audio installations (Foster + Partners and Yinka Shonibare), a bedrocksymbol stone bridge (J&L Gibbons), a bronze oak tree centerpiece (Tom Stuart-Smith), and woven pathway bridges (WilkinsonEyre)
• The Independent praises the variety: bronze Windsor oak, lily-pad canopy, traditional equestrian statue, audio-garden, romantic "forest bathing" landscape, and a stone bridge with waterfall symbolism
• The Times criticises the more extravagant concepts – like "giant lily pads" and audio-overlays featuring the Queen's voice-as "Disney-like spectacles," arguing these may clash with the Queen's understated dignity, especially given the £23-46m budget
The architecture of planning FINCH
Much of what Krier and the future Charles III were saying at the time have been absorbed into contemporary thinking. Silos have to an extent dissolved, writes Paul Finch
A CBE for Eric Parry, and obituary notices for Leon Krier, are a reminder of the wealth of creativity and controversy in the world of architecture – and also prompt thoughts about the relationship between architecture, planning and urban design.
Parry is a phenomenon among London architects because of the volume and quality of his work in both the City of London and the City of Westminster. His two biggest projects in the City (the Corporation’s new legal mega-complex on Fleet Street and the replacement Aviva Tower which will be the tallest building in the Square Mile) are still in progress. Perhaps once complete they will prompt a knighthood!
In Westminster, there is the work on Savile Row and Bond Street; the triumphant re-working of the Waterstone’s building on Piccadilly; and the subtle office building next to Lutyens in St James’s Square.
Unlike his commercial architect predecessors (probably only Richard Seifert matched him for output in central London), Parry is just as at home in the worlds of art (the extension to the Holburne in Bath) and community/charity projects, for example the work in Charterhouse Square. This Royal Academician has managed occasionally to blend art and architecture, for example through use of colour, and more recently to engage with the natural world through provision of roof gardens, publicly accessible.
So does he have a problem with the planning system, which is supposed by critics to stifle innovation in favour of the bland? Not at all – he just gets on with it, listens to comments and criticisms, and like all good architects declines to be thinskinned, instead responding to what has been said without losing the spirit or integrity of the original idea.
Leon Krier had quite a different attitude to planning, which is to say that he thought he knew best. Sometimes he was right. An excellent architect who worked for James Stirling (and was said to have converted Stirling to the latter’s particular version of post-modernism), Krier was at his most influential in the 1980s and early 1990s because of his influence on the then Prince of Wales. The latter’s distrust of ‘continental theorists’ did not extend to
Krier, whose urban design ideas were made flesh in the Poundbury development on the edge of Dorchester, by the Prince’s Duchy of Cornwall.
The proposal was really a critique of the conventional volume-housebuilder idea of how you provided housing in a situation like this: build lowdensity, car-dependent estates a few miles from the nearest city, where land can be purchased cheaply.
Poundbury was a different proposition, not completed to the scale Krier envisaged, but completed enough to make an urban argument. Needless to say, it was the relentless classicism which enraged some critics and delighted others. Georgian in the late-20th century? Go for it!
Krier once admitted at a Royal Academy public event that in fact the architecture could have been in any style, following a question from your correspondent. But he claimed that only architects who believed in masonry construction would have drawn up the masterplan he had fashioned. On another occasion, on a visit to Poundbury with the Prince of Wales in tow, I asked Krier why he hadn’t invited modernist architects to design things like light industrial buildings. ‘I will invite them, but only after they have invited me to work on one of their projects,’ he declared, with a laugh.
Finch is programme director of the World Festival of Architecture and joint publishing editor of Planning in London
his version how height should work in a city, with a hierarchy of civic and religious buildings outgunning office towers. His version of a single storey development included a church, since the steeple did not contain any floors. His drawings and commentaries on what was wrong with modern architecture, and how it could be adjusted, were one of the best things in Architectural Design magazine at the time, offering a critique with the advantage of witty visuals.
Those arguments and discussions really are evidence that the past is another country. Much of what Krier and the future Charles III were saying at the time have been absorbed into contemporary thinking, while today’s neo-modernists are happier to co-exist with designers of other persuasions. Silos have to an extent dissolved.
In retrospect, everybody had more in common than they wanted to acknowledge. When the Prince made his Hampton Court speech in 1984, I wrote an editorial headlined ‘Two cheers for the Prince’. If only he had realised that instead of criticising architects like James Stirling, he should have recruited them to his cause.
Did the Prince realise, when he attacked Stirling’s No 1 Poultry development in the City of London, that he was criticising an architect for whom Krier had worked and respected? And isn’t that building a bit Krier-esque?
It is certainly not something that Eric Parry would have designed, but he is far from being an austere black-and-white kind of architect. If you get the chance, visit his Leathersellers livery company building in the City. A sumptuous pocket masterpiece. n
DBOX for Eric Parry Architects
Encouraging ideas for the next London Plan
The Green Belt hoo-ha having subsided for now, other suggestions in the Mayor’s Consultation on a new London Plan promise welcome flexibility, thinks Lee Mallett
A new London Plan will be published for consultation in 2026 and adopted in 2027, guiding development in the capital for 20-25 years to 2050. All boroughs’ plans must conform to it. It is the biggest tool in the box for getting the housing London needs. Do the ideas in the Consultation document launched in May go far enough?
The Mayor’s Towards a new London Plan consultation is remarkable for some of the ideas it floats, and perhaps provides clues about the Government’s forthcoming national housing policy, yet to be revealed.
Homes and economic growth
Two key objectives are to ‘fix the housing crisis’ and deliver ‘sustainable economic growth’. The for-
mer is threatening the latter and the Mayor could have made more explicit reference to this.
‘Since 2016 we have worked hard to get London building again. We hit the target of starting 116,000 new genuinely affordable homes and have also ushered in a new golden era of council housebuilding’, claims the consultation. ‘Golden era’ is perhaps an overstatement.
That’s an average of 12,888 affordable homes a year compared to the Government’s stated need of 88,000 new homes of all tenures per year. A rate of building that London last approached in the 1930s. London has been delivering between 30,000 and 45,000 homes a year for the last decade, only half the Government-set target.
‘A huge increase in housing delivery is needed,’
Lee Mallett is a founder editor/publisher of PiL, an urban regeneration consultant and a committee member of the City Architecture Forum
states the consultation. No kidding. The new National Housing Bank should be able to help with its £16bn financial capacity, which the Government hopes will attract £53bn of private investment.
Unlike other parts of the country, the London Plan sets housing targets for each borough based on where homes can be built, rather than where need for those homes arises. This frees up the Plan to meet London’s housing needs as one large housing market.
Blaming the usual suspects is disingenuous
The consultation’s list of usual suspects causing problems - rising construction costs, labour shortages, higher interest rates, little Government funding, new safety reg’s and regime, market absorption rates and ‘general economic uncertainty – is disingenuous.
Nowhere does it mention the cost of planning, the huge delays, the time-wasting paper pushing, the imposition of several levels of taxation via planning policies through S106 and CIL in market where viability has already been blitzed by the challenges mentioned. A major cause of low delivery is the system itself and its policies.
It concedes, however that: ‘The next London Plan will not increase the overall burden of planning policy requirements on development under the current circumstances. Opportunities will also be taken to streamline requirements and speed up consideration of planning applications. Some policy requirements may be phased so they start to apply at a later dates or, for example, when economic conditions or technologies improve.’
These are very welcome suggestions indeed. The idea that planning taxes may not be 100% ‘frontloaded’ into the development process and may be delayed until more propitious times, for example, is revolutionary. And something developers have been pleading forever. It acknowledges cash flow, and could substantially reduce front end risk, costs, while increasing resource for quality and improved viability.
Persuading other builders back into the market
Achieving the homes needed will require ‘different types of housing and housebuilders to increase and accelerate supply’ says the paper. Building affordable homes ‘will rely on increased public subsidy’, especially as providers need to improve the condition of existing homes. More small and medium housebuilders need to be encouraged as well as build to rent providers, government, councils and other public sector landowners.
None of that will happen if development continues to be taxed too heavily, particularly by affordable housing requirements and thresholds which are set too low (see below). Or if subsidy is not forthcoming. Policy, cost, complexity are the reasons small builders and developers have exited housing. There are easier ways to earn a living. Nor will the extra ‘vital transport improvement to unlock additional capacity for homes’ be of much use if that remains the case.
More planners, more frequent capacity studies
Being able to build at the scale London needs ‘would need planning permissions in London to reach even higher numbers sooner and remain at that level’. The 300 extra planners promised nationally by Government, however, are unlikely to touch the sides – even if they were all employed in London. And there is the question of ‘empty planning offices’ as staff continue to WFH.
The consultation refers to London’s call for sites ‘LAND4LDN’ launched in autumn last year which saw 750 sites submitted by developers, landowners, boroughs, and members of the public. The Mayor has worked with boroughs to bring together this information and how it has changed since 2017 – when it was last done. But to wait seven years between assessments is way too long. Private businesses seem to make money out of researching this market annually. We need to know annual figures if we are to manage the issue.
Honing Opportunity Areas
Since 2004 47 Opportunity Areas have been established and in them 250,000 homes have been built in 21 years. There are 200,000 unbuilt homes consented in these areas and the GLA is working to understand how many can be delivered in the next plan period. And, hopefully, if not, why not.
‘All of them’ is clearly the right answer. We need the DLR extension to Thamesmead, the Bakerloo line extension down the Old Kent Road and probably Crossrail 2 to get anywhere near the target. Sadly none of these won in Chancellor Rachel Reeve’s Spending Review, much to Sadiq Khan’s chagrin.
What is useful is the intention to streamline and update the status of the 47 Opportunity Areas (OA’s), because some of them have matured and other circumstances have changed, or some have become rather similar to existing town centres and other London locations. This might help focus attention on remaining, or new, opportunities Other sacred cows being reviewed (besides the Green Belt) are London’s strategic views and the London View Management Framework. Along with amending the Central Activities Zone (CAZ) boundary to better match areas that have a concentration of uses unique to the CAZ. And to potentially exclude residential areas from the CAZ that could play a greater role in housing delivery. Areas like the Northern Isle of Dogs, for example, or areas with older office stock, could be repurposed to provide more housing, as seems likely. Both helpful suggestions.
Welcome signs of flexibility
The 18 per cent loss of London’s industrial land since 2001 remains a concern, but enthusiasm for co-location of homes and substitution of land to allow more homes alongside industrial, in the current plan, remains.
There may be opportunities to provide additional, or swap, industrial capacity in London’s ‘grey belt’, especially in locations less suitable for housing, which could also well-connected brownfield industrial sites to be released for housing. More industrial capacity could be provided in suitable locations, freeing up sites in less suitable places for housing.
For example: ‘…some areas of Metropolitan Open Lane (MOL), such as certain golf courses, are not accessible to the wider public, and have limited biodiversity value. This undermines the purpose of the
designation. These areas could be assessed to understand whether they should be released from MOL…’. And not before time. Architect Russell Curtis’ analysis of the ‘London Borough of Golf’ revealed the shocking and inconvenient truth that there are 94 active golf courses in London, covering 4,331 hectares (larger than Brent, popn 330,000) – a sport enjoyed by a tiny 1% of the national population.
RCKA’s analysis of golf courses in London London’s 43 publicly owned courses take up 1,600 hectares – that’s bigger than Hammersmith & Fulham. Curtis and his colleagues at RCKA deserve the RIBA Gold Medal for this campaign. Golf is an indulgence on a scale London should not tolerate. London’s most serious problem is the impact of lack of affordable housing on those on low and middle incomes - and Council Tax-payers. Temporary accommodation and associated health and welfare cost for all boroughs is a scandal and a serious economic risk to the capital’s future.
Raising thresholds for affordable housing taxes
It seems the failed policy of driving sufficient delivery of affordable housing by taxing development to provide it is here to stay, despite the evidence of the last 25 years. The consultation states that ‘The Mayor’s threshold approach to affordable housing has helped to embed affordable housing requirements into land values.’ This may be true but the arguments around viability it entails have clogged the system and discouraged smaller developers.
It ‘incentivises’ developers to provide higher levels of affordable housing by offering a faster and simpler route to approval – which is that if 35% of affordable housing is provided, no viability information is required. That’s not an incentive. That percentage level takes a chunk of profitability out of larger schemes. It destroys viability on smaller schemes. It is however less than 50%, which will produce very little housing without subsidy.
It is encouraging, however, that thresholds are to be examined. The lower threshold of 10 or more units has always been unrealistically low. And no housing association wants small numbers of social housing mixed up in small private schemes. It doesn’t work. Then there is the problem of different thresholds in different boroughs. Nonsense.
Also the idea that imposing a requirement of 50% affordable housing to be provided on released
green belt land will deliver more, without subsidy, is unlikely. Much better to maximise a commuted payment, cut the arguing and spend it elsewhere to procure more social rent homes. Or subsidise it.
A sign of Labour policies to come?
The consultation states the greatest need is for social rent homes and that more emphasis on this tenure is needed in national policy, including the setting of targets and securing consents. Agreed. But who pays? The Labour Government has yet to unveil its plans on this, so hats off to the Mayor for stating what everyone is thinking. The next London Plan should require the full replacement of social rent homes in estate regeneration schemes, regardless of whether there is a right to remain or not. Will that be subsidised? Presumably.
Growing London’s economy
This was worth £500bn in 2022 – 25% of the UK economy. The Mayor and boroughs have all published Growth Plans. The new class E rules, enabling changes to other uses within this class
without permission, arrived before the existing plan came out, but it was ‘too late’ to include new policy reflecting its impact. A new policy is needed.
More than a million sq m of stock (nine Shards) is at risk of becoming ‘stranded assets’. Planners and politicians need to be more flexible about allowing change of use to more profitable occupations. Being as flexible as possible to encourage emerging clusters of activity would also be helpful to the economy and jobs.
Likewise, to save High Streets from death by departure of unprofitable retailing, ‘the London Plan could take a very flexible approach to the range of businesses in town centres and high streets…and enable any commercial and other appropriate development (places of worship, health and education uses, nursing homes) in any strategic town centre.’ Let’s hope it does.
To this one might add, any other uses that can find a life on the High Street. Particularly cultural or ‘affordable’ uses. Changing town centre boundaries could release poor performing areas. Also there are both high streets and town centres that aren’t des-
ignated, or that lack plans. Some are next to transport nodes. That needs to change. All local centres should have plans for change and growth.
Capacity for growth
Many European cities are more dense than London, which has seen denser development recently. But the amount of development by small and medium sized builders has slumped from 40% in 1988 to 10% of new homes now. That tells its own story about the impact of poor and unrealistic planning.
A radical, exciting suggestion is that the new Plan could set out building heights across all locations (as the City did when faced with competition from Canary Wharf in the early 90s, using fixed plot ratios). This was a game-changer. That would indeed be both welcome (and unwelcome), radical and possibly highly effective. Boroughs are already supposed to identify locations for tall buildings. Many haven’t done so, even though tall buildings have been built within their boundaries. Why hasn’t the Mayor, or Government, enforced this? n
Diagram by RCKa Architects
Removing grit from the system
Amongst the government’s comprehensive planning reform agenda, one area that warrants closer scrutiny is how applications are actually determined – and that should be done with a broad focus, says Paul Smith
The application process is much more than the period between submitting an application and a decision notice being issued. In reality, it starts when a developer first contemplates an application and finishes when planning conditions are discharged. To build more homes, more quickly that whole process needs to be improved.
Efforts to date have focused on the traditional application process. Proposals that would see more applications decided by professional planning officers rather than elected members – rather euphemistically referred to as “modernising planning committees” – should see fewer schemes taken to appeal for political reasons. Ongoing work to reform the role of statutory consultees should reduce delays caused by late feedback on live applications.
While those changes are welcome, we need to look at the application process in the round – from inception to completion, not submission to determination.
The Planning and Infrastructure Bill offers opportunities to do that. The new ability for councils to set application fees locally will ensure the fee paid actually covers the cost of dealing with the application. The government should therefore use it as an opportunity to abolish Planning Performance Agreements.
Planning Performance Agreements can be very expensive. For a scheme of 150 new homes, Hackney Council charges an extra £90,000 in addition to the standard £50,000 application fee, for example.
The original justification for Planning Performance Agreements was for applicants to pay additional fees over and above the statutory requirements in return for the council agreeing to hit performance benchmarks. That made sense when application fees didn’t cover application costs. Yet in reality, few councils are prepared to agree to meaningful performance targets for the understandable reason that the speed in which an application is processed isn’t entirely within their control – it depends on external consultees and applicants too.
So, we’ve ended up with a system that is used solely to secure extra fee income but which adds weeks to the process while the Performance Agreement is negotiated, drafted and signed. Application fees that actually cover costs should remove the need for that whole process, removing time and complexity.
Pre-application advice is another area ripe for reform. Research by the Planning Advisory Service highlighted the wide range of fees charged by different local authorities. For applications for between 10 and 50 homes, the cost of pre-application advice ranged from £116 to £17,059. There is a huge variety in the level of advice offered too, with some local authorities not even offering a preapplication service.
Again, the theory for pre-application consultation is sound – it provides an opportunity for developers and local authorities to agree the parameters for an application and highlight key issues that need to be addressed. But the reality is much different. The advice provided is non-binding so can change; not all consultees provide responses; and it can take months for meeting dates to be confirmed.
We’re told pre-application discussions ensure applications are determined more quickly – and that might be true for the application itself. But under the current approach, that is being achieved by moving work from a period that is measured and regulated – the actual application process – to an unmeasured, unregulated period. That sleight of hand only makes it appear that applications are determined more quickly. In reality, it probably doesn’t make much difference – and might even slow things down.
Standardising the pre-application process could deliver significant improvements.
Section 106 Agreements are another barrier to rapid decision-making, often taking many months to execute as over-stretched council legal teams struggle with the burden of negotiating bespoke agreements for every application. There seems no reason why the government couldn’t introduce standard clauses for S106 agreements, or even
Paul Smith is Managing Director, The Strategic Land Group
template agreements, with blanks to fill in reflecting the site-specific circumstances. For example, the tenure split, unit numbers and occupation triggers for affordable homes will clearly vary from site to site, but the operative clauses explaining how they will be delivered, and what happens if there is no interest in those plots from a Registered Provider, should be the same each time.
Templating could also be used for planning conditions, alongside greater clarity on appropriate triggers for discharge – limiting the number of precommencement conditions in the process.
Nor should planning conditions be used to cover other regulatory regimes, even if we think they aren’t doing a good job. Nobody would condition compliance with Building Regulations but we’re very happy to do that in other areas. Construction Management Plans, for example, have no place in the planning system. There is plenty of legislation that Environmental Health teams can use to deal with noise, dust or other nuisances. It shouldn’t be appropriate to outsource enforcement of those rules to already over-stretched planning departments, adding yet another document that needs to be prepared and approved as part of the application process.
Those few examples only scrape the surface. We will all have our own favourite illogical, inefficient or duplicate processes within that broader application process.
While that may feel depressing at times, it is great news for the government. It means there are a whole host of areas where they can remove grit from the system and really make the planning machine hum, ensuring it delivers the right outcomes more quickly. n
How Quub Satellites can help Britain’s water network
Images from space of the surface can quickly identify the following problems – leaks, algal blooms, illegal extractions, change of land use and much more, explains Dan Lewis
Britain’s 400,000 mile water network is the biggest, oldest and least intelligent network of all Britain’s infrastructure. Much longer than our road, rail, gas, electricity or telephone networks, it could even reach the moon and most of the way back. It is also the “dumbest” or least easy to observe because it’s largely underground, very hard to reach and relay updated information from.
Fortunately, that’s about to change. Dramatic cost falls in space access and the mobile-driven mass miniaturisation of electronics, have created the opportunity for a new class of satellite – the PocketQube satellite. Weighing in under 2 kg each, our 3D printed Quub satellites will provide high frequency imagery, every few hours with accelerated analysis of the network done by AI, automatically pointing to areas of interest. Such has been the rate of progress, that even 5 years ago, this technology was neither affordable nor available.
Images from space of the surface, put through infrared and multispectral filters can much more quickly identify the following problems – leaks, algal blooms, illegal extractions, change of land use and much more. It’s simply a matter of the computer comparing a photo from time point A with time point B and using machine learning and AI to identify the difference and send through gps coordinates of areas of interest – every few hours. The point is, viewed from space, you can really see a lot, quickly. And the key is to process that data in space cheaply – and removing the bottleneck of rooms full of highly skilled human analysts – who still missed much of the imagery’s information.
For this we have to thank OFWAT’s Innovation Fund awarding us £1.3m to build, launch and operate 6 satellites for 3 years. And we must particularly thank South Staffordshire Water for contributing to the investment, along with other enlightened partner water companies joining the project and Wolverhampton University’s AI expertise.
To give some background explanation, Britain’s water companies are conservative regulated monopolies, which over the last 30 years, were tasked by the regulator to keep bills low. And they did. Ever heard anyone talk about water poverty the way they do about fuel poverty?
Invariably though, keeping bills low meant capital intensive investment was put on the back burner, with higher risk innovation placed some way behind. It’s not true to say that the investment didn’t happen and overall improvements in leakage, pollution and wastewater management weren’t made. They were. And if they weren’t privatised, taxpayers would have been on the hook for no small portion of that investment – competing at the Treasury with the NHS, Welfare, Public Sector Pensions and all the rest.
Moreover, outside of the regulatory bubble, as only PiL readers will understand all too well, planning restrictions effectively halted investment in new reservoirs while the population grew by another 10 million. That put the network through even more wear and tear, shortening the lifespan of its assets still further. Not great when your annual pipe replacement rate runs to 0.4%. And it’s fair to say that this restrictive environment, led to companies exiting the stockmarket freeing them to engage in some questionable financial engineering. That was not something stock price sensitive investors or OFWAT were either able or empowered to change. A debt leverage hangover across the sector ensued until today, especially at London’s Thames Water.
That’s why OFWAT’s annual £42m, Water Breakthrough Challenge competition is so important to seeding innovation throughout the sector and start making the big improvements everyone wants. Marginal shifts just won’t cut it, but enough innovation surely will.
The principal aim of our project – Space Eye – is to dramatically reduce costs for participating water companies. That means quickly locating leakages in hours rather than weeks as well as spotting unaccounted for water, reduce potential exposure to regulatory fines for not meeting targets and create
Dan Lewis is executive director of Quub UK
a near real-time analysis model across the whole network. Quub satellites can become the first line of observation across the UK’s water network.
So where did this all come from?
Quub’s origin and vision are very largely the brainchild of its founder and CEO, Joe Latrell. Based in Pennsylvania USA, while working for the water industry and building rockets in his spare time, it became obvious to him that remote observation through tiny, low-cost satellites would help mitigate many of the sector’s woes. And further benefits would accrue by using off the shelf components, 3D printing to reduce typical production time from 5 years to 3 months and automating the analysis process.
There are many types of orbits around the world. The one Quub will use is called Polar Low Earth Orbit. Low Earth Orbit in our case means about 300 miles up, just above the International Space Station and leads to very quick circumnavigation of our planet – every 24 hours. The added benefit of the Polar orbit – North to South Pole then around again - means that every country in the world can be observed.
Going forward, with new capital, Quub aims to exploit its leading position and have several satellite manufacturing plants around the world, using local suppliers. Already, Quub satellites are using Raspberry Pi computers built in Wales. A 200 plus constellation of satellites would even create a revisit rate as high as every 15 minutes. And what is being done for water, can be applied usefully to agriculture, forestry and environmental management.
PocketQube satellites are just one part of the coming New Space revolution. We aim to launch from January 2026 – so please follow our progress online. n
Planning reforms for small developments
Proposed changes should reduce application costs, improve and streamline the determination of applications and imbibe a touch of increased certainty in the outcome, says Fergus Charlton
Housebuilders that are small and medium-sized enterprises (SMEs) occupy a much-reduced share of the housing market than they did at the turn of the century. Recent reports suggest they currently deliver around 10% of housing supply.
Is the decline in the number of SME housebuilders a problem? The government thinks so, believing the loss of SME housebuilders has affected the industry’s ability to meet their stretched housebuilding targets. The provision of homes by SME housebuilders will complement the national housebuilders' business model and will result in different designs and layouts, providing a more diverse housing market.
What is holding back the SMEs? Their market share remains limited by systemic challenges. Reporting to the government in 2021 the Home Builders Federation said: “Over the past 30 years, the process of obtaining planning permission has become riskier, costlier, and more complex” and “While larger companies can mitigate risk across dozens of sites in some cases, small firms encountering delays on one or two sites will be the difference between a year of growth and a year of contraction".
This article considers the government's proposals (currently out for consultation) to address the planning system's complexity, its uncertainties and its delays to encourage the development of smaller sites and thereby encourage SMEs back into the marketplace.
Planning system barriers: Over half of SME housebuilders report waiting over a year to obtain planning permission. Those permissions are becoming increasingly expensive, and this is harder to bear when these costs are proportionally more of your turnover. The additional costs arise from the systemic delays of under-resourced planning departments, together with the implementation of initiatives such as providing biodiversity net gain and meeting building safety standards.
Existing support for smaller sites: Currently a housing development of ten or more homes or that is on site larger than 0.5 hectares is classed as 'major development'. Developments that fall below this major development threshold currently benefit from:
• Not being required to provide affordable housing;
• A relaxation of the sustainable drainage system requirements
• A relaxation of the requirement to provide a design and access statement
• An exemption from the proposed Building Safety Levy
Proposed reform to level the playing field for smaller builders: In late May government began consulting on reforming site thresholds. The consultation document constructs the argument that planning process has become disproportionate for SME housebuilders. The purpose of the proposed reform is "to better support small site developments", "to remove and streamline disproportionate requirements on small and medium sites, while maintaining and strengthening requirements on major development" and to "and enable SME housebuilders to grow".
The consultation firstly proposes reform to the thresholds for residential development. 'Very small sites': Developments under 0.1 hectare. 'Minor Residential Developments': Developments of fewer than 10 homes that are less than ½ hectare. 'Medium Residential Developments': Developments of between 10 and 49 homes that are less than 1 hectare. 'Major Developments': Developments of 50 or more homes or a hectare or more.
The consultation proposes exempting Minor Residential Developments from having to provide biodiversity net gain (BNG), setting national requirements for validation of planning applications such that Minor Residential Developments will not have to provide the full suite of documents, drawings and reports required by the larger schemes, reducing the number of statutory consultees, and forcing local authorities to ensure these applications are determined by professional planning officers under delegated powers (and thereby avoiding determination by the more politically orientated planning committee).
If brought into effect these changes should reduce planning application costs, improve and streamline the determination of applications and imbibe a touch of increased certainty in planning outcome. The absence of environmental gain will have an inevitable direct effect, although the BNG
Dr Fergus Charlton is a partner in Michelmores LLP
regime can still steer these developments away from the most sensitive of habitats. It will have a hard to quantify indirect effect too in that there will be reduced demand for BNG credits which creates uncertainty in the nascent BNG market.
It is proposed that very small sites will additionally benefit from being assessed against a template design code. This rules-based approach to design will help identify opportunities and enable faster application processes. On the other hand, these will typically be windfall sites with irregular boundaries, such that they may not readily lend themselves to a onesize fits all national design scheme.
Medium Residential Developments will benefit from simplified BNG requirements, a possible exemption from the Building Safety Levy, and a promise to hold planning authorities to the 13-week statutory determination timeline perhaps through the proposed national scheme of delegation.
More generally applicable, the consultation seeks views on speeding up section 106 negotiations. This will include addressing the barrier to building out arising from the lack of availability of willing and suitable registered providers to acquire a scheme's commitment to affordable housing. Currently this will focus on the role that commuted sums can play in financing the offsite delivery of affordable housing. These changes will be broadly welcomed by the development industry. There will be gainsayers who are concerned about the potential environmental impact and reduced role of the democratically elected members of the planning committee in local decision making.
Implementation of these new thresholds and the proposed proportional approach to the application of planning regulations will need amendments to primary legislation, the development management orders and several sections of the national planning policy and guidance. This will take time. n
If we need more houses, slash over-regulation
We need an efficiency czar to get down to the detail at the core of the problem of over-regulation, says Robert Adam
The government seems to have woken up to the fact that there’s more to cutting red tape than fast-tracking major infrastructure. For small developers there’s still a crazy maze to navigate to get permission for any small development. Will they tackle this?
There is already an often arbitrary and scandalously slow process for getting something through the planning system, but even if you have a function and design that fits policies and the personal taste of the officers, there’s still a mountain of regulations to climb.
Regulations are catnip to regulators. A new issue turns up; make up a new set of regulations, often clunky and overdone. If there aren’t new regulations, you can beef up the existing ones.
When you put on a new regulation, it becomes a new standard. A whole single-issue industry, bureaucracy and group of activists are created. Once made, the loss of any regulation, however half-baked, becomes a ‘loss of quality’.
Design and Access Statements, were set up in 2006 largely for disabled access. Now the ‘access’ bit has faded away as local authorities ask for more. One saying they should be ‘short and concise’, asks how your couple of houses in a field will, ‘value and embrace diversity and difference’. No surprise these often go to well over 100 pages. Reports for an application can go into the hundreds.
As each coterie of specialists sets up their own set of regulations, their objective is just to protect their specialism. They have no perspective on the housing crisis. The result can be some bizarre contradictions.
We want to re-populate town centres. Places where there is a natural hubbub. But noise regulators can tell you that doesn’t work because there would be too much noise for residents.
Flooding regulations for the 100-year condition came in after the 2007 floods. Did we have any idea about what the environment today would be like in 1925? Now, in places like Poole, a new house near the sea has to be 2 metres off the ground. With the promised deluge, the old town will all be under water. The few residents left will be boat people, surrounded by ruined submerged houses.
You’ll have to report on all your trees on your site, even if not protected. Odds are, any consent will pro-
tect them. If a tree is in the way, the logical answer is to fell it before the application – as is your right. So contradicting the purpose of making the report.
A new constraint, Biodiversity Net Gain, might persuade you keep the credit a tree gives you. But if your housing site has no biodiversity whatsoever and want to plant a lot of trees, they count for nothing. Reason is, there can’t be bureaucrats coming round until 2055 to check the residents are taking care of them.
If you have an existing building, the likelihood is that the date-window for making an application will be determined by the breeding cycle of bats.
An entire application on a large site was delayed by six months with the accidental discovery of a single hazelnut with a nibbled top.
Even after a permission, there are still lots of opportunities for control: planning conditions. These have become like another application, complete with their own fee, no target dates and entirely at the whim of officers. Months deciding whether your material samples are right can delay a construction start date.
A whole series of things can be put in.
You might have to get your gates approved. While on day one a resident can replace them without a planning consent.
Landscape officers dealing with a landscape condition have asked for lawns to be planted with wildflowers. Will they check that there isn’t a robot cutting the lawn to within millimetres of its life? Of course not, and if they did, could they do anything?
And then there are Building Regulations, with a whole new field of control. These seem to be mostly designed for major developments, nothing to do with your two houses in a field.
Not only do you need to name a Principal Designer, as of last year, before you can even make an application you have to be registered with a broadband provider. Try getting those to do anything speedily. This delays even making the application by at least a month, all for a service you won’t need for a year or two and can cancel any time. Does anyone try to sell a new house without broadband?
In a regulation designed for glass-walled office blocks, you have to prove your houses won’t overheat in anticipation of a coming Mediterranean cli-
Professor Robert Adam is Director at Robert Adam Architectural Consultancy
mate. But we don’t refer to what people do with things like shutters in the Mediterranean. You need a calculation for your simple houses with conventional windows that just shows what you knew already.
There is the notorious 1.1m opening window height restriction on upper floors, introduced with no cogent evidence there was a problem. Questioned, there was ‘no apology’ for making things safer. This is an endless regression.
When you’ve got through all that, if you get some legal obligations put on you - Section 106 agreements - you might still be waiting for a year or more until local authority lawyers get round to it. As with conditions, there’s no target date. So your site just sits there leeching capital.
The government wants to revive the fast-dwindling community of small developers, culled by the complexity and uncertainty of planning. Part of the answer proposed is more controllers. Surely, part of the answer is to tackle the granular inconsistences, irrelevances, impracticalities and sectoral interests. More controllers would be welcome but this will release more of their time and help to solve the housing crisis.
Specialist regulators need to be tied to the key objective - more houses now. There should be no conditions on things that can be changed straight away without a planning application. Regulations that are just a speculation that something might be better should be scrapped. There should be ranked regulations or simple deemed-to-satisfy conditions for the scale and type of development. Every part of the process, conditions, legal agreements, consultations should have compulsory target-decision-dates with the default a negation of the constraint. The urgency is the housing crisis and social justice, not a sectoral or administrative interest. We must give the small developers, that we all want to thrive again, some regulatory headroom. Above all, we need an efficiency czar to get down to the detail at the core of the problem of over-regulation. n
London businesses ready to expand office space
Will Scott reviews the key findings from Irwin Mitchell’s recently published Occupiers Report
Half of greater london businesses surveyed are ready to expand office space as hybrid working gains pace. According to Irwin Mitchell’s latest Occupiers report, of the respondents to the survey five times as many Greater London businesses (49%) are looking to expand their office space in the next 12 to 18 months rather than reduce it (10%). This shift comes as more workers return to the office, prompting many companies to reassess their current space allocations. 69% of those London businesses surveyed admitted they overshot their downsizing efforts during the Covid era.
Of those planning to expand, 49% said they would do this by reconfiguring their existing premises rather than relocating to entirely new sites (27%). In a vote for flexibility, 45% of London respondents are considering incorporating flexible workspace options in their property portfolios—perhaps creating the “breathing space” needed as they adapt to evolving operational requirements.
Changing work practices and office attendance
Organisations are capitalising on a marked shift in working habits. Over the past year, of those surveyed 77% of employers in Greater London have noted an increase in office attendance, with 81% predicting further growth in the next 12 to 18 months. This is above the national average, where 74% of employers expect higher in-office numbers in the next 18 months.
The survey also reveals a decisive tilt towards more days expected in the office. While 47% of London businesses now require employees in the office three to four days a week, a third of businesses (33.3%) have moved to a full five-day requirement— reflecting a strong push for traditional office engagement following the pandemic.
Adapting office environments to encourage employees to attend
Current office layouts are also putting pressure on firms' ability to accommodate all their staff in one place. Only 27% of Greater London respondents believe their existing space can handle full capacity, with 55% asserting that if everyone returned to the office, they would fall short. Consequently, many companies are reassessing both the type
and amount of space they require moving forward.
To entice employees back into the office, 46% of businesses are integrating workplace environment and design into their broader strategies to attract and retain talent—and a further 37% are considering doing so. A decisive 97% have already involved HR teams in making decisions on working spaces, evidencing a strong growing trend of linking HR and real estate policies.
In addition, 97% of London employers are offering employee incentives to boost on-site attendance, including flexible hours (66%), improved amenities (54%), adaptable office day arrangements (54%), and bespoke office modifications (50%).
According to the survey, London employers believe the main drivers for increased office attendance include enhanced collaboration and teambuilding efforts. Additionally, over a third (34%) of London workers noted that simply being “visible” in the office is important for career progression during these economically uncertain times.
Environmental considerations in property decisions
Businesses acknowledge the importance of sustainability in their property strategies, but cost and return on investment remain primary drivers. While 46% of London businesses cite expense as the biggest barrier to reducing their office’s environmental impact, many opt for lower-cost solutions such as reducing office waste (44%), purchasing eco-friendly office products (41%), switching to renewable energy (40%), and reducing energy consumption (37%).
Nearly one fifth of London businesses (19%) also said sustainability was not a priority.
When choosing new office space, energy efficiency (43%) and adaptability (40%) rank as top environmental criteria, while factors like biodiversity (21%) and building certification (18%) are less influential. Notably, 48% of Greater London businesses would pay a higher rent for eco-friendly offices—though only if it comes with equivalent reductions in service charges or energy bills.
Businesses show limited concern about government’s EPC regulations, with 78% of London businesses willing to enter a lease on buildings rated
below the required B standard even with a lease expiry beyond 2030—if location or rental terms are more favourable. Many see EPC compliance as a landlord’s responsibility rather than their own. Additionally, nearly one in five respondents (14%) of London businesses doubt the proposed legislation will even be implemented.
Despite these reservations, corporate engagement with environmental initiatives is growing. 82% of London businesses now report on carbon emissions, with 93% voluntarily doing so. While sustainability concerns play a role (56%), brand image (50%), and client expectations (51%) also remain key motivators.
Interest in green financing is also rising, with 46% of London businesses already securing ESG-related finance (compared to 35% in the UK overall) and 41% considering it for future investments.
Conclusion
Considering the survey results, the office's role in the work world is evolving, especially in London. Rising costs and inflation are pushing businesses to improve office productivity to accommodate more returning staff and meet stakeholders' needs.
Environmental considerations are shifting from 'nice to have' to 'necessary' as their benefits become clearer. London businesses are opting for eco-friendly premises to reduce operational costs, support employees, and access better financing options.
In the 'Stay versus Go' decision, more Greater London businesses are choosing to work with their current landlord to rework existing office space and add flex space as needed, giving them time to decide on a permanent solution. n
This study involved 501 senior decision-makers from companies with 20 or more employees, focusing on office property decisions. The research specifically highlighted findings from 177 London businesses and was conducted online between March 14th and March 18th, 2025.
Will Scott is Real Estate partner at Irwin Mitchell
The next London Plan
The Mayor must ‘back the builders’ to deliver the homes London needs, says James Cogan
If, as Harold Wilson said ‘a week is a long time in politics’, it is reasonable to feel as though it has been a lifetime since the adoption of the London Plan back on 2 March 2021. Since when, Sadiq Khan has not only won a second term as Mayor of London but is already well into his third term, and Labour has won a general election pledging to ‘back the builders not the blockers’.
Although the change in government brought a welcome end to the animosity between the Mayor of London and the previous Secretary of State, Michael Gove, which often distracted from those genuine questions regarding the Mayor of London’s record when it comes to delivering new homes, the current party political alignment between City Hall and Westminster (the first since 2016) is unlikely to provide the Mayor with any political cover as the spotlight inevitably returns to the Mayor’s record of failing to deliver the number of homes needed across the capital.
With Angela Rayner continuing to double down on the government’s very ambitious pledge to deliver 1.5 million new homes during this parliament, the Mayor will be asked more and more difficult questions about why housing delivery continues to fail in London. Unlike before, he will now of course not be able to shift the blame on to government.
Of course, for those of us at the coalface of delivering housing in London, the factors resulting in falling housing delivery are obvious, albeit there is disagreement about which of these factors plays the greatest role. However, it is a commonly held position that part of the blame must fall on the current London Plan, or perhaps more precisely the way in which the policies of the current London Plan are applied by the Greater London Authority and London boroughs.
The Housebuilding in London: London Plan Review – report of expert advisers, commission by the previous government and chaired by Christopher Katkowski KC, concluded that the combined effect of the multiplicity of policies in the London Plan acted to frustrate, rather than facilitate, the delivery of new homes. While other factorsmacro-economic conditions (i.e. higher borrowing costs), increased build costs, and stringent fire safety requirements - have impacted housing delivery
across the country, the effect of these factors is felt most keenly in the capital where they are exacerbated by the rigid implementation of the policies of the London Plan. The result has been that London has experienced the greatest regional drop in net housing completions (18%) since 2021/22.
Although the current Secretary of State has decided against acting on the recommendations of the London Plan Review, it would be wrong for the Secretary of State or Mayor of London to discard the conclusions and recommendations drawn. Instead, the conclusions of the London Plan Review should be at the forefront of the Mayor’s mind as he begins the process of preparing a new London Plan. If the new London Plan is to increase the delivery of new homes it must learn the lessons of the past, return to its core function as a spatial development plan for London, and resist the urge to set prescriptive policies that either duplicate or contradict those of the London boroughs – those which, when
How can the Mayor’s team ensure the Plan delivers the homes that London needs?
James
Cogan is a Director in Boyer’s London office
applied rigidly have only frustrated development in the past.
While we hope to see this change in direction from the Mayor of London as the new London Plan begins to emerge over the coming months and years, we are stuck with the current London Plan for some time. If we are to see the short-term increase in housing delivery that is so desperately needed, the Mayor of London must adopt the tone of his ministerial colleagues and ‘back the builders’.
While we await the new London Plan, this can be achieved by adopting a more nuanced interpretation and flexible application of those policies of the current London Plan, recognising the that applying the appropriate balance between competing factors is at the heart delivering good quality development that meets the needs of Londoners. n
Images of London by Frederica Van Weezel
A national approach to planning
Housing targets can only be met if development is assessed and brought forward at a national level, believes Ian Barnett
A new Planning and Infrastructure Bill is now working its way through Parliament. Alongside changes to the National Planning Policy Framework (NPPF), the English Devolution White Paper, various planning working papers, the ongoing consultation on a new Land Use Framework this is quite a significant output for the government’s first half year, but will it have the desired effect of delivering housing and growth?
The government’s ambitious and unyielding housing target means that our planning system is under extreme pressure to perform: to not only functioning effectively, but to more than double the number of housing consents achieved in recent years. What’s more, the growth agenda includes not only the homes themselves, but the energy, transport and community infrastructure necessary to create successful communities.
I have long argued that what is needed is a national plan - one that removes short-term politics from the equation and allows professionals to lead a coherent, long-term development strategy. For years, housing delivery has been hindered by
the tension between national targets and local opposition.
This would set out a clear framework for where and how development should take place, ensuring that housing, infrastructure, and economic growth are planned in a coordinated manner. Such an approach would offer several key benefits: it would give the private sector greater confidence to invest in housing and infrastructure projects, reducing the risk (and costs) associated with navigating a fragmented and politically volatile planning system; better align housing and associated infrastructure; depoliticise planning, and address regional disparities.
The government is currently consulting on a Land Use Framework, to be published later this year. Its contents will include the principles that government will apply to policy with land use implications; a description of how policy levers will develop and adapt to support land use change; a release of land use data and analysis to support public and private sector innovation in spatial decision making, and the development of tools to sup-
port land managers in practice.
The consultation document makes a commitment to ‘taking a spatial approach’, stating in this context how location and climate change impact on land use and must be taken into account at a national level, along with the use of ‘land use incentives’ and transforming, ‘how Government makes policy and the information we provide to decision makers’.
But on reading the document I feel that the strategic, spatial approach is lacking: it appears to make the assumption that that each piece of land has just one use – failing to fully appreciate, for example, that housing developments can deliver shade and biodiversity without land having to be singled out for this purpose. Interestingly, this document – which is produced by DEFRA, not the MHCLG – makes only one reference to the National Planning Policy Framework. Ditto biodiversity net gain (BNG) despite the fact that BNG provides the vital link between housing (and, from November this year, infrastructure too) and environmental protection. So the intent is there, but there does seem to be an absence of joined-up thinking.
To bring about growth, spatial planning must function at a higher tier of government. While there is undoubtedly a role for local voices in development decisions, as we have seen from planning under the previous government, local politics in a thorn in the side of development. Compare the derisory number of homes built under the last government with the New Towns programme of the 1950s and 1960s: it is clear from the New Towns Delivery Programme, which required an Act of Parliament and the establishment of development corporations, that housing figures are only ever truly met when decisions are
Ian Barnett, is national land director at LRG
taken outside the remit of local authorities.
In my view, a national spatial plan is the obvious answer. One option is the return of the National Infrastructure Committee and an ‘infrastructure first’ approach which brings together infrastructure, housing, energy and climate change in a de-politicised environment to expedite the creation of new settlements.
In terms of removing the influence of politics in the allocation of land, there is much that we could learn from the German or Dutch systems. Germany’s strategic planning decisions are made through a series of regional plans at a federal level; the Netherlands has a system more akin to a single national plan. Both countries are seen as having exemplary planning systems which allows development to proceed largely unhampered by political interference.
In the UK, the closest we ever have got to this model was the Regional Spatial Strategies (RSS). RSSs established a spatial vision and strategy specific to a region, for example, including the identification of areas for development with a 20 year timescale while also providing direction for Local Development Frameworks on a local (borough / district) level.
As the New Towns programme shows, when planning works, it is top-down, rather than bottom up. A national spatial plan would properly plan for development that this country needs. Community involvement would have a role to play within this national approach. But the engagement process must be efficient (is three rounds of consultation on a design code alone really the best route to fast-tracking development?), and it must be consistent across the country. As Neighbourhood Planning has demonstrated, the potential for a specific community to impact on planning decisions lies in that community’s demographic: those communities with a professional, prosperous and permanent demographic are likely to exert more power on local issues than deprived areas and those with more transient communities. This factor cannot be changed by sound bites and empty promises; only through a very long-term investment in community development, creating genuine opportunities
for involvement and involving a representative sample of the local community can this be achieved. To do so would require the planning system to pay more attention to the ‘hard to reach’ –for example the young, those in full time work or those busy raising children – those people who are perhaps more likely to be in need of affordable housing options.
An important component of a national spatial plan would be a comprehensive Green Belt review. The government has already made bold moves to enable Green Belt release – specifically the coining of the term Grey Belt to determine land suitable for use. But Grey Belt has proven to be problematic. It works well as a slogan: it’s simple and concise, visual and intriguing, immediately evoking images of unattractive scraps of land which would benefit from redevelopment. But, as the House of Lords Built Environment committee inquiry into the Grey Belt concluded, the Green Belt definition has been, ‘implemented in a somewhat rushed and incoherent manner,’ and the inquiry said it did not believe, ‘that it is likely to have any significant or lasting impact on planning decision-making or on achieving the government’s target of 1.5 million new homes by the end of this parliament’. In my view the updated
guidance will lead to a plethora of speculative applications and appeals, each aiming to determine whether a site is Green or Grey Belt.
If the objective is simply to build more houses (or at least grant more planning permissions) then this will undoubtedly happen as a result of the new NPPF and PPG. However, if the government’s intention is to deliver housing at the required scale in the right areas through a plan-led system then a different approach would be better – by which I mean a national review of the Green Belt, as an important component of the national plan. We review our Local Plans every five years (at least supposedly). A review of the Green Belt needs to be undertaken in the context of the needs of the country – transport, environment, housing, leisure, food, and economics.
My view is that housing targets can only be met if development is assessed and brought forward at a national level. After years of NIMBY appeasement by MPs with responsibility for addressing the housing crisis, this will be difficult politically – but so is the risk of failing to meet the ‘almighty challenge’ (to quote Keir Starmer) of 1.5 homes this Parliament.
A national plan is the government’s greatest hope of success. n
The SME sector to the rescue
It looks like there is a genuine attempt to help smaller builders although the diagnosis is a little weighted towards remedying planning when the real issue is viability and the economy, says Andrew Golland
Coinciding with the Reform Party’s surge in the polls, the government has released a “Reforming Planning Paper”, specifically titled Planning Reform Working Paper: Reforming Site Thresholds (28 May 2025). Recognising the mounting difficulties of delivering large greenfield and grey belt schemes in a fragile housing market, the government is now turning to SMEs (Small and Medium-Sized Enterprises) as a potential means of boosting housing supply.
The paper is built around an interesting hypothesis: That the scale of development is a key determinant of housing supply.
To that end, the government is initiating a discussion—potentially leading to regulation—on how SMEs might be better supported to increase delivery. Several ideas are floated, including reducing planning burdens (such as fewer reports, lighter design codes, faster decisions, and lower financial demands) for smaller schemes. This is to be explored through the intriguing principle of “gradation.”
Is Gradation a Valid Premise?
This premise is certainly debatable. Large volume housebuilders typically set lower limits on site size, below which their interest diminishes—implying diseconomies of scale on smaller schemes.
However, this masks deeper complexities: not only is the product different, but the operational models and land sources also differ substantially.
To promote a gradated approach, the paper proposes three tiers:
• Small sites: Up to 10 homes
• Medium sites: 10–49 homes
• Large sites: 50+ homes
There’s a reference to mixed-tenure development, though details remain vague.
Does This Affect Affordable Housing Thresholds?
In short: No.
The paper reaffirms the government’s commitment to affordable housing delivery. Officials likely remember the backlash when Eric Pickles’ 2014 attempt to override local thresholds met fierce legal resistance—most notably from the London Borough of Richmond, which successfully defended its lower local threshold due to severe housing need.
Many London boroughs still operate below the national 10-unit threshold. Given growing housing lists and the fact that thresholds are typically set via a public Examination in Public (EiP), local authorities are expected to continue defending their positions robustly.
The paper states clearly that the current national
Dr Andrew Golland specialises in the field of housing, planning and regeneration
threshold for affordable housing will be maintained. All other uses of the term “threshold” relate to development scale—not affordable housing.
A Missed Opportunity?
Yes. While it’s often claimed that SMEs are disproportionately burdened by planning processes, there’s no strong evidence that smaller sites are less able to deliver Section 106 contributions than larger ones.
The national affordable housing threshold—set at fewer than 10 dwellings—is arbitrary. There’s no viable justification for that particular cut-off point, and the same is likely true of any proposed medium or large thresholds (if these were extended to affordable housing policy, which they’re not).
What was missed here is the chance to establish a rational, evidence-based national threshold policy. Viability is not determined by scale but by context. In high-value areas (e.g., London and the South), thresholds could be lowered to secure more affordable homes. Conversely, in lower-value regions, even very large sites might deliver no affordable housing if viability is negative. This is not theory—it’s already happening.
What Might Change for SMEs?
The government seems committed to easing the regulatory burden for smaller builders. Proposals include:
• Continued exemption from the Building Safety Levy
• Streamlined Biodiversity Net Gain (BNG) requirements
• Delegation of small scheme decisions to officers rather than committees
• Exemption from build-out transparency rules
(which were never meaningfully applied to SMEs in the first place).
Shorter
Determination Times and Section 106 –A Double-Edged Sword?
Faster planning decisions could backfire. Currently, many LPAs delay determinations on small schemes that fail to meet Section 106 policy, effectively discouraging appeals due to high costs and risk.
If LPAs are required to determine faster, SME developers may be more willing to contest viability—knowing disputes will be forced into the open and resolved more quickly. This could increase the volume and intensity of Section 106 negotiations.
The Real Culprit: The Market
The paper seems to place excessive blame on planning, ignoring a key factor—the shortage of planning staff—which has only been lightly touched upon.
More fundamentally, the economy may be the real barrier for SMEs. Data on house prices and build volumes suggest that the 2008 financial crisis marked a pivotal shift, with more completions shifting to large companies. Flat real house prices and
high risk meant small firms struggled to secure financing.
More recent data shows the SME sector has been further weakened by COVID-19 and Brexit. An improving economy may offer more hope than a simplified planning system.
Streamlining Section 106 Negotiations
The paper invites suggestions on speeding up planning obligations—overlooking that many tools already exist.
For example, standardised Section 106 agreements are already widely used. The paper also asks:
“Would guidance for LPAs and developers on calculating commuted sums, to ensure these reflect onsite delivery values, be effective?”
Yes—it would. Some formulas follow the principle of equivalence (established in PPG3 under the last Labour government); others do not. Some calculations cherry-pick only half of the viability inputs (e.g. revenues and margins) while ignoring costs—leading to wildly divergent outcomes.
This inconsistency is problematic across the board, and government should issue clear best-practice guidance.
Good Intentions—But Are They Enough?
There’s clearly a sincere effort to assist smaller builders. However, the focus remains skewed toward fixing planning when the real levers are economic.
One bright spot is the proposed Housing Delivery Fund, which Planning Minister Matthew Pennycook says will include revolving credit facilities, loans, and lending alliances.
So the approach isn’t entirely one-dimensional. But it is yet another planning paper revisiting old ground.
The true solutions lie in:
• Rising house prices
• Falling or stable development costs
• Adequate land supply
• A well-resourced, responsive planning system
This would benefit both volume builders and oneperson operations alike.
The ball is in the government’s court. What’s needed are bold economic decisions, not just technocratic planning tweaks.n
Andrew Golland Associates – Housing, Planning & Regeneration Experts
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Backing for Oxford Street
The leader of Camden Council has backed Mayor Khan’s Oxford Street plans despite warnings of an investment freeze. Planning uncertainty triggered by the proposed Mayoral Development Corporation could be damaging, the GLA committee was told, reports The Standard.
Sadiq Khan’s dramatic plans to pedestrianise Oxford Street have been backed by Camden’s council leader at a Greater London Authority committee, despite warnings from another witness about the scheme’s potential impact on investment.
The mayor of London released his proposals for the redevelopment of the area last September and, at the end of February, published a consultation on creating a Mayoral Development Corporation to deliver the plan.
Khan is seeking responsibility for plan-making and the determination of planning applications across the area around Oxford Street, the vast majority of which lies in Westminster, with a small part of Camden also included.
The council leader for the latter borough, Cllr Richard Olszewski, told a London Assembly planning and regeneration committee that he and his peers at the council “welcome the proposals which could transform the area and the wider West End by increasing visitors, improving air quality, creating more jobs and supporting businesses to thrive”.
He added that Camden was “also seeking to form a partnership and set agreements with the Mayor” to ensure local residents could “play an active and full part in its future”.
However, the committee meeting also saw the plans subjected to strong criticism from Tim Lord, chair of The Soho Society and the Westminster Amenity Societies Forum, both organisations representing the area around Oxford Street and the West End. Lord said that Khan’s September announcement had been “a tragic mistake” because there had been consensus around an existing scheme for the redevelopment of the area.
Urban design practice Publica had previously been working on a £90m plan for the street proposed by Westminster council, which had blocked a previous attempt at pedestrianisation in 2018 due to concerns over the need to reroute traffic into quieter surrounding streets. ”All of that work has now been lost and wasted because of a press release from the mayor in September saying that he might consider
pedestrianization that then triggered all the businesses to pull their funding from that scheme, and the residents are, I would say, pretty disappointed,” said Lord.
“We now have a whole debate about what will happen to all of planning in the mayoral development area.
“I think all of the property developers will wait till the end of that debate before they make any more investments, because the planning rules might change.
“We might have a different planning policy for the mayoral development area than we do for the rest of Westminster.”
As well as planning powers, the proposals would see the GLA take responsibility for the road itself and retain the neighbourhood portion of the Community Infrastructure Levy for developments within the designated area.
The MDC would be controlled by a board of up to 13 members including an independent chair appointed by the Mayor and representatives from each of the two councils.
The London Assembly has the power to veto the designation of a Mayoral Development Area with a
two-thirds majority vote, although this would require some of the mayor’s own party to support the veto.
Chancellor is accused of 'shortchanging’ the capital
Rachel Reeves has been accused of 'shortchanging’ the capital with little cash for infastructure, schools and policing although TfL will receive its "largest multi-year settlement in over a decade".
London's transport network will get £2.2bn over the next four years for its capital renewals programme, the Chancellor confirmed in her Spending Review last month. The Treasury also revealed that £25.3bn would be provided to help deliver HS2 from Birmingham Curzon Street to London Euston.
However, Sir Sadiq Khan said he was "concerned" that Britain's largest police force could be left with fewer officers because of squeezed budgets. While the Chancellor said the force would get an average spending power increase of 2.3% per year under her plans, the wider Home Office budget is due to fall, official Government documents show:.
A warning of a council tax "bombshell" has also been issued to fund the plans. The Mayor of London >>>
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also expressed his disappointment that the Treasury had refused to commit cash to infrastructure schemes, such as the DLR and Bakerloo Line extensions.
Ms Reeves said: "This government takes seriously its commitment to investment, jobs and growth in every part of the UK. And I have heard the concerns of [MPs] and the mayor of Liverpool City Region, that past governments have underinvested in towns and cities outside London and the South East. They are right."
deal for Transport for London is welcome, the lack of certainty around delivering shovel-ready projects like the DLR to Thamesmead and Bakerloo line extension that could accelerate growth, create new jobs and open up sites for tens of thousands of new homes is baffling."
Following the speech, Sir Sadiq warned that "the way to level up other regions will never be to level down London". "I've been determined to stand up for London and it's good news that we have won extra resources for transport and housing," he said. I have been campaigning for years for a multi-year deal for City Hall and for Transport for London and I welcome this agreement.
"However, I remain concerned that this Spending Review could result in insufficient funding for the Met and fewer police officers. It's also disappointing that there is no commitment today from the Treasury to invest in the new infrastructure London needs.
"Projects such as extending the Docklands Light Railway not only deliver economic growth across the country, but also tens of thousands of new affordable homes and jobs for Londoners. Unless the government invests in infrastructure like this in our capital, we will not be able to build the numbers of new affordable homes Londoners need."
BusinessLDN, which represents company leaders in the capital, said the city had been "shortchanged". Chief Executive John Dickie, said: "The acid test for this Spending Review is whether the Government's rhetoric on growth is matched with the investment needed to kickstart the economy.
"The Chancellor has delivered some welcome additional spending on infrastructure, transport and skills. "But it looks like London has been left shortchanged.
"The Government's growth mission can only be achieved by unlocking the full potential of London. As a UK-wide engine of growth, the capital accounts for a quarter of the country's economy.
"Its substantial net contribution to the public coffers rightly supports spending in other parts of the country but must also enable London to grow. "While the certainty provided by a four-year funding
Councils were also left disappointed. Half of London boroughs are at risk bankruptcy over insufficient schools funding for children with special educational needs and disabilities (SEND), it has been warned. Sixteen of the capitals 33 local authorities have said they face "severe budget deficits" totalling £500million next year over the crisis, according to analysis from cross-party group London Councils.
Boroughs welcomed the cash for house building and additional investment for children's social care and temporary accommodation, saying this will help them invest in prevention.
However, London Councils warned the modest overall increase to local authority funding means boroughs' budgets still face an "extremely difficult" outlook and "serious risks" to financial stability.
Claire Holland, Chair of London Councils, said: "Increased investment in affordable housing is hugely welcome and critical for tackling the capital's housing crisis. This is a potential game changer in our efforts to accelerate housebuilding and it's vital that London gets its fair share of this funding.
"The upcoming reforms to local government funding are now make or break' for London boroughs. The resources we receive must match the high levels of need, deprivation and cost of delivering services in the capital."
The Economist City liveability index
AI to rev up planning promises PM
Prime minister Sir Keir Starmer has promised to launch a new artificial intelligence (Al) tool next spring to speed up planning decisions, following successful trial runs.
The Extract tool, unveiled for testing in April, is intended to speed up the conversion of old planning documents into digital records from one to two hours to a few minutes.
Speaking at London Tech Week, Starmer said Extract should be available to all councils by next spring using Google DeepMind's Gemini technology. The government said Extract could save planning officers an estimated 250,000 hours a year spent manually checking documents.
It added that fully digitising the system would make it "faster, more transparent and easier to navigate for working people, councils, businesses and developers".
– Ciaran Nerval in Property Week
¡¡ PILLO! PILLO!
City of London Building of the Year
The 2025 City of London Building of the Year Award has gone to 21 Moorfields, a complex over-station development designed by Wilkinson Eyre for Land Securities as the UK headquarters for Deutsche Bank.
This year’s jury, made up of architects, experts and representatives from the Worshipful Company of Chartered Architects unanimously selected 21 Moorfields, describing it as “a tour de force both of architectural thinking and creative collaboration.”
Set above Moorgate’s Elizabeth Line station, the project demonstrates an extraordinary level of technical and architectural ambition. The scheme, spanning the size of a football pitch and bridging 60 metres across active underground infrastructure, was achieved without any interruption to the station or rail services beneath. “The challenges facing the architects were extreme,” the jury noted, citing the complex spatial restrictions, asymmetrical support requirements, and integration of new public routes and a bridge to the Barbican.
The result is a distinctive headquarters building for Deutsche Bank, whose dramatic steel structure not only responds ingeniously to these constraints but also elevates the project into a striking architectural statement. The development includes four dealer floors, a substantial auditorium, bike storage and wellness facilities, alongside a fivestorey ‘wellness’ block and a ‘crown’ for leadership and client functions. Landscape design by Andy Sturgeon contributes significantly to the civic quality of the site, with 20 percent given over to open and green space, including a large roof terrace accommodating an independent energy system for the bank’s trading operations.
Wilkinson Eyre said "21 Moorfields has been the work of many hands and a real collaboration between everyone from transport authorities, developers, and tenant over more than a decade. Its expressive structure belies the complexity of the station tunnels and platforms below, and we are proud it will stand for generations to come, showing off the best of London’s skill and talent.”
Two buildings were additionally recognised with Special Commendations:
21 Moorfields
A complex over-station development designed by Wilkinson Eyre for Land Securities as the UK headquarters for Deutsche Bank
• 40 Leadenhall by Make Architects: Described by the jury as ‘volumetrically complex’ this 900,000 sq ft development for M&G Prudential combines stepped and chamfered towers with impressive amenities, including an auditorium, yoga room and screening space. Of special note were the project’s environmental strategies, public access and collaboration during pandemic-era construction.
• 100 Fetter Lane by Fletcher Priest Architects: This major intensification project nearly doubled site capacity and introduced a trio of colourful, generous-volume buildings for YardNine and Beaumont Capital. Innovations such as a bespoke material passport system and underfloor air distribution, along with layered terraces and integrated bike facilities, impressed the panel for their contribution to sustainable and adaptable office design.
The awards are presented at the Livery Company’s dinner on 10th July, with a plaque unveiling ceremony at 21 Moorfields by the Lord Mayor of London on 15th October.
Obscene works underground
Concerns about graffiti on the Underground are not new. According to the Londonist website, the first
documented prosecution for writing “obscene words calculated to pollute the minds of … passengers” was in 1864 on the Metropolitan Railway, a year after it opened as the world’s first underground railway. n
Response of the London Forum to ‘Towards a New London Plan’
A summary of the Forum’s full responses to individual questions by AI and subsequently proofread and edited to provide an accessible public overview
Section 1: The London Plan – Introduction
The London Forum’s primary objection is the Mayor’s acceptance of the government’s housing target of 88,000 new homes per year. They argue this figure should not have been endorsed without first conducting a Strategic Housing Land Availability Assessment (SHLAA) and a Strategic Housing Market Assessment (SHMA) to establish London’s actual housing needs.
The Forum questions the government’s standard method for calculating housing need, describing it as a “one-size-fits-all” algorithm that fails to consider London-specific factors—such as lower replacement rates, reliance on brownfield sites, and more severe affordability challenges.
They believe this top-down target puts undue pressure on boroughs to increase development density, scale, and height—without clear means to fund the essential social and transport infrastructure that such growth demands.
A major concern is the large number of unimplemented planning consents:
• Over 300,000 homes in London have planning permission but remain unbuilt.
• The New London Architecture’s Annual Survey identifies a pipeline of 580+ tall building projects (20+ storeys), accounting for 110,000 homes— equivalent to a 20-year supply without new permissions.
• The Forum recommends the GLA’s Datahub investigate why so many consented homes are not proceeding to construction.
On affordable housing and viability, the Forum:
• Supports viability reviews at each stage of development to recoup excessive profits.
• Questions the Fast Track planning system, despite its apparent delivery of more affordable housing than viability-tested schemes.
• Notes that many tall buildings deliver under 10% affordable units.
While endorsing the “Good Growth” objectives, the Forum recommends:
• More guidance for Policy GG2D, particularly on transport accessibility.
• Expansion of Policy GG3 to include overcrowding.
• A review of the 50% affordability target in Policy GG4B, citing Jules Pipe’s suggestion that twothirds of new homes should be social housing.
Section 2: Increasing London’s Housing Supply
The Forum argues that delivering 88,000 homes annually is unrealistic, given historical delivery of only 30,000–45,000 per year. They advocate starting with a bottom-up assessment using current ONS data and updated SHLAA and SHMA studies.
Key positions include:
• Brownfield Land: While supporting a “brownfield first” approach, they note this has been the norm
since 2000, and that the focus should now be on optimising sites with good public transport links.
• Opportunity Areas: The Forum welcomes the review of the 47 Opportunity Areas, many of which have made little progress due to limited transport investment (e.g., Kensal Canalside) or changing circumstances (e.g., Old Oak/Park Royal). The cancellation of Crossrail 2 warrants a reassessment of Opportunity Areas in southwest London.
• Central Activities Zone (CAZ): They recommend redrawing CAZ boundaries to exclude mainly residential areas (e.g., Pimlico), major parks (e.g., Hyde Park, Regent’s Park), and Opportunity Areas unrelated to CAZ policies. Inclusion should depend on whether the area supports CAZ functions and policies.
• Strategic Views: The Forum strongly supports protection of existing Strategic Views and River Prospects and calls for extension of the latter beyond the CAZ to the west. They criticise the lack of safeguards for Thames Policy Areas, which has led to poor development outcomes.
• Industrial Land: They support reinstating co-location policies for housing and compatible industrial uses, expressing disappointment that the previous Plan omitted these at the government’s request.
• Green Belt and MOL: The Forum supports reviewing Green Belt designations—especially in Bromley, Havering, and Hillingdon—but insists any
development on “Grey Belt” land be sustainable, well-connected, and include substantial social and low-cost rental housing. They strongly oppose any development on Metropolitan Open Land (MOL), which they believe requires separate and full protection.
Section 3: Growing London’s Economy
The Forum supports the London Growth Plan’s ambitions and repeats its call for a review of CAZ boundaries. It also suggests a broader mapping and support of London’s diverse economic clusters.
For town centres, they advocate for boroughlevel responsibility and express concern over the proliferation of food and beverage outlets at the expense of essential services. They also recommend guidance on using High Street Rental Auctions.
Key economic points include:
• Industrial Land: They support protecting strategic industrial land, setting borough targets, and encouraging co-location and multi-storey industrial development.
• Night-Time Economy: They stress the need to distinguish the “evening economy” (6 pm–midnight: dining, culture) from the “night-time economy” (midnight–6 am: clubs, bars), and to protect local residents.
• Visitor Economy: The Forum urges action on short-term lets, which reduce housing supply and cause disruption—highlighting the contradiction between encouraging tourism and addressing housing need.
• Digital Infrastructure: They support a strategic, city-wide approach to data centres, due to their high energy use and local grid impact.
• Affordable Workspace: They oppose greater use of planning obligations to promote employment, calling them a “blunt instrument,” and express strong reservations about removing the same-site requirement for affordable workspace.
Section 4: London’s Capacity for Growth and Design Quality
While acknowledging that growth requires increased density, the Forum insists this be tied to transport access and social infrastructure. They maintain that decisions on height and design codes should be handled at the local plan level.
Tall buildings are a central concern:
• The Forum supports a plan-led approach, with boroughs designating suitable sites in local plans (per Policy D9).
• They strongly oppose assessing tall buildings on a case-by-case basis regardless of location, which would undermine local planning.
• They criticise Mayoral interventions that override boroughs’ efforts to manage tall buildings— though they welcomed the recent decision not to call in a scheme at Battersea Bridge.
• They argue that tall building decisions are rarely strategic enough to warrant Mayoral intervention.
• They strongly object to lowering the height thresholds that trigger Mayoral involvement, particularly along the Thames, where many buildings over the past 20 years have been of “shameful”
The Forum questions the government’s standard method for calculating housing need, describing it as a “one-sizefits-all” algorithm that fails to consider London-specific factors—such as lower replacement rates, reliance on brownfield sites, and more severe affordability challenges. They believe this top-down target puts undue pressure on boroughs to increase development density, scale, and height—without clear means to fund the essential social and transport infrastructure that such growth demands.
quality.
They support the development of a new TfL metric to supplement PTAL and guide large-scale development. They also criticise the Mayor’s failure to better protect World Heritage Sites, warning of the “real risk” that the Tower of London could lose its designation.
Finally, the Forum warns that an overemphasis on small units (studios and 1–2 bed homes) has damaged supply of family-sized housing—especially in the social sector. Pursuing high targets without addressing this risks worsening the crisis for families in need of larger homes—an outcome that “must be resisted at all costs.”
Section 5: Infrastructure, Climate Change, and Resilience
The Forum urges the Plan to reflect real limitations on public funding for infrastructure required to support growth.
Key positions include:
• Energy Efficiency: They oppose any weakening of current standards and are sceptical of carbon offsetting.
• Green Infrastructure: They support reviewing the Urban Greening Factor and identifying areas lacking access to open space. They note that inaccessible spaces (like railway embankments) can still serve ecological functions.
• Waterways: They call for major reinforcement of the Thames Strategy Partnership and highlight that many boroughs east of Chelsea have failed to designate Thames Policy Areas, as required.
• Flood Risk: They back stronger requirements for Greenfield Run-Off Rates and mandatory use of Sustainable Drainage Systems (SuDS) even in minor developments like paved front gardens.
• Transport: They stress the link between growth and transport funding. Given a lack of investment in the 2025 Spending Review, many Opportunity Areas need to be re-evaluated. They recommend stronger disincentives for car use, such as surcharges for large vehicles in parking bays. Where major schemes (e.g. Crossrail 2 or Kensal Canalside Elizabeth Line station) are not delivered, related Opportunity Areas must be reassessed.
• Fire Safety: They support clearer guidance within the Plan but assert that fire safety ultimately requires national-level policy reform. n
Applications up but decisions down from the same quarter a year earlier
Latest planning performance by English districts and London boroughs: planning applications in England during January to March 2025
OVERVIEW
Between January to March 2025, district level planning authorities in England:
• received 90,700 applications for planning permission, up 6% from the same quarter a year earlier;
• decided 70,900 applications for planning permission, down 10% from the same quarter a year earlier;
• granted 61,500 decisions, down 9% from the same quarter a year earlier; this is equivalent to 87% of decisions, up 2 percentage points from the same quarter a year earlier;
• decided 90% of major applications within 13 weeks or the agreed time, unchanged from the same quarter a year earlier; and • decided 19% of major applications within the statutory period of 13 weeks, unchanged from the same quarter a year earlier;
• granted 7,000 residential applications, down 11% from the same quarter a year earlier;
• granted 1,500 applications for commercial developments, down 11% from the same quarter a year earlier; and
• decided 36,200 householder development applications, down 9% from the same quarter a year earlier. This accounted for 51% of all decisions, up from 50% a year earlier.
In the year ending March 2025, district level planning authorities:
• granted 265,800 decisions, down 7% from the year ending March 2024; and
• granted 29,300 residential applications, down 8% from the year ending March 2024.
Planning applications received
During January to March 2025, authorities undertaking district level planning in England received 90,700 applications for planning permission, up 6% from the same quarter a year earlier. In the year ending March 2025, authorities received 335,800 planning applications, down 4% from the year ending March 2024 (Live Table P134, PS1 Dashboard).
Planning decisions
Authorities reported 70,900 decisions on planning applications in January to March 2025, down 10% from the same quarter a year earlier. In the year ending March 2025, authorities decided 307,800 planning applications, down 8% from the year ending March 2024 (Live Tables P120/P133/P134, PS1/PS2 Dashboard).
Applications granted
During January to March 2025, authorities granted 61,500 decisions, down 9% from the same quarter a year earlier. This represented 87% of all decisions, up 2 percentage points from the same quarter a year earlier. In the year ending March 2025, authorities granted 265,800 decisions, down 7% from the year ending March 2024. Authorities granted 86% of all decisions, unchanged from the year ending March 2024 (Live Tables P120/P133, PS2 Dashboard).
Applications on hand
Authorities reported that they had 105,800 applications on hand as at 1 January 2025, down 13% from the same quarter a year earlier. This is 49% above the number of decisions made during the quarter. The corresponding figure for the same quarter a year earlier was 54%. Taking account of numbers of applications received, decisions made and applications withdrawn during the quarter gives a total of 120,100 as at the end of March 2025, down 2% 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 sim-
ilar 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 82% in London to 92% 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 (50% to 100%), followed by minor developments (60% to 100%) and other developments (73% to 100%) (PS2 Dashboard).
Planning decisions by development type, speed of decision and local planning authority.
All tables and figures can be found here:
https://tinyurl.com/5ebzkrus
Source: DLUHC/ONS
Speed of decisions
In January to March 2025, 90% of major applications were decided within 13 weeks or within the agreed time, unchanged 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.
In the same quarter, 88% of minor applications were decided within 8 weeks or within the agreed time, up 1 percentage point from the same quarter a year earlier. 39% of minor applications were decided within the statutory time period of 8 weeks, up 1 percentage point from the same quarter a year earlier.
Also in the same quarter, 91% of other applications were decided within 8 weeks or within the agreed time, up 1 percentage point from the same quarter a year earlier. 58% of other applications were decided within the statutory time period of 8 weeks, up 3 percentage points from the same quarter a year earlier.
Use of performance agreements
‘Performance agreement’ (PA) is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments (EIAs). The EIA process is undertaken to assess whether a project will have a substantial impact on the environment, with applications having an accompanying Environmental Statement[footnote 3] (see Technical Notes for further definitions of PAs). Between January to March 2025, 42% of all planning application decisions involved a performance agreement. Major developments were more likely to involve a performance agreement compared to minor and other developments with 78% of major decisions involving a planning agreement, compared with 54% of minor decisions and 36% of other decisions (Reference Table 2, PS2 Dashboard).
Figure 4 shows, from April 2010, the numbers of decisions on major, minor and other developments made involving a performance agreement, compared with numbers without a performance agreement. Notwithstanding definition changes, there has been a marked increase in the use of agree-
ments 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
Two local planning authorities are currently designated by the Secretary of State in relation to their planning performance. These are Lewes District Council (on 8th May 2024) in relation to quality of decision-making for major applications; 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 2025, 9,200 decisions were made on applications for residential developments[footnote 4], of which 7,000 (76%) were granted. The number of residential decisions made was down 18% from the same quarter a year earlier, with the number granted down 11% from the same quarter a year earlier. 900 major residential decisions were granted, down 3% from the same quarter a year earlier and 6,100 minor residential decisions were granted, down 12% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard)
In the year ending March 2025, 39,600 decisions were made on applications for residential developments, of which 29,300 (74%) were granted. The number of residential decisions made was down 12% from the previous year, with the number granted down 8% from the year ending March 2024. 3,700 major residential decisions were granted, unchanged from the previous year and 25,600 minor residential decisions were granted, down 9% 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 5].
The latest provisional figures show that permission for 235,000 homes was given in the year to March 2025, down 3% from the 242,000 homes granted permission in the year to March 2024. 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 rolling annual totals have been revised 0.8% on average. These figures are provided here to give contextual information to users and are not Accredited Official Statistics.
When considering the above figures in relation to statistics on housing supply, 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 2025, 1,700 decisions were made on applications for commercial develop-
ments[footnote 6], of which 1,500 (88%) were granted. The number of commercial decisions made was down 12% from the same quarter a year earlier, with the number granted down 11% from the same quarter a year earlier. 300 major commercial decisions were granted, down 11% from the same quarter a year earlier and 1,100 minor commercial decisions were granted, down 12% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard).
In the year ending March 2025, 6,900 decisions were made on applications for commercial developments, of which 6,100 (88%) were granted. The number of commercial decisions made was down 10% from the previous year, with the number granted down 10% from the year ending March 2024. 1,300 major commercial decisions were granted, down 13% from the previous year and 4,800 minor commercial decisions were granted, down 10% from the previous year.
Trends in the percentage of residential and commercial decisions granted SEE Fig 7 BELOW LEFT
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 36,200 in the quarter ending March 2025, accounting for 51% of all decisions, up from 50% of all decisions made in the quarter ending March 2024. Authorities granted 89% of these applications and decided 92% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard).
In the year ending March 2025, 157,700 decisions were made on applications for householder developments, accounting for 51% of all decisions, down from 52% of all decisions made in the year ending March 2024. Authorities granted 89% of these applications and decided 93% 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 October to December 2024 there were 20 decisions, of which all 20 were granted and 19 were decided in time (Live Table MJPSI, PS2 Dashboard). Please note that figures are not collected on the CPS1/2 return and so don’t include education developments by county councils.
Permission in Principle/Technical Details consent decisions
Since April 2017, local planning authorities have had the ability to grant permission in principle (PiP) to sites which have been entered on their brownfield land registers. Where sites have a grant of permission in principle, applicants have been able to submit an application for Technical Details Consent (TDC) for development on these sites. In addition, since June 2018, it has also been possible to make an application for PiP for minor housingled development as a separate application, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC.
Figures on PiP/TDC decisions have been collect-
ed on the quarterly PS2 return from January 2020. During January to March 2025, local planning authorities reported 181 PiP (minor housing-led developments) decisions, 19 TDC (minor housingled developments) decisions and 2 TDC (major developments) decisions. The totals for the previous quarters have been similar although there has been a slow upward trend since 2020, when there were about 60 PiP decisions per quarter (Live Table PiP/TDC1, PS2 dashboard).
Permitted development rights
Planning permission for some types of development has been granted nationally through legislation, and the resulting rights are known as ‘permitted development rights’ (PDRs). For certain permitted development rights, if the legislation is complied with, developments can go ahead without the requirement to notify the local planning authority. Hence no way of capturing this data exists and these are not accounted for in this report. In other cases, the permitted development right legislation requires an application to the local planning authority to determine whether or not
prior approval is required and to determine as appropriate (see the Definitions section of the Technical Notes).
Between January to March 2025, 5,600 applications were reported, of which prior approval was not required for 2,900, permission was granted for 1,600, and 1,100 were refused. This resulted in an overall acceptance rate[footnote 7] of 80%. Large householder extensions accounted for 55% of all PDR applications reported, with 26% relating to All others, 9% relating to Agricultural to residential, and 7% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2).
In the quarter to March 2025, 1,000 permitted development right applications were made for changes to residential use, of which 700 (68%) were given the go-ahead without having to go through the full planning process.
Overall during the 44 quarters ending March 2025, district planning authorities reported 356,400 applications for prior approvals for permitted developments. For 197,500 of them prior approval was not required, 85,200 were granted and 73,800 were refused (Live Table PDR2).n
London Plan update, (some of) the Green Belt has got to go and Oxford Street pedestrianisation
Account of the London Planning and Development Forum meeting on Tuesday 10th June at Barr Gazetas, 35 Heddon Street W1B 4BP
Discussion topics
1 London Plan update
Jorn Peters, GLA LP team; Professor Ian Gordon, Emeritus Professor of Human Geography, LSE; Peter Eversden, Chair London Forum; Dr Agnieszka Zimnicka, Head of City Planning Policy Westminster;
2 The Mayor’s decided (some of ) the Green Belt’s got to go. Response from outer boroughs Yvonne Sampoh, LB Barnet Principal Planning Officer (Policy); Christopher Waller, LB Redbridge
3 The pros and cons of Oxford Street pedestrianisation
Mark Willingale, Willingale Associates; Magnus Wills, Barr Gazetas
Report by Riette Oousthuizen of HTA Design also at www.planninginlondon.com >LPDF
ATTENDANCE Meeting held on Tuesday 10th June at Barr Gazetas
LP&DF TEAM, HOSTS AND SPEAKERS:
Riette Oosterhuizen, HTA Design
Brian Waters LP&DF Chairman
Magnus Wills, BarrGazetas
Peter Eversden, VP London Forum
Prof Ian Gordon, LSE
Felicie Krikler, Barr Gazetas
Mark Willingale Willingale Assocs
Yvonne Sampoh L B Barnet
Jorn Peters GLA
Christopher Waller L B Redbridge
MEMBERS & GUESTS:
Deon Lombard, Deon Lombard Architect
Steven Heath, Bloomsbury Society
Helen Cuthbert, Planning Potential
Prof Michael Edwards, UCL
Michael Bach, London Forum
Duncan Bowie, UCL
Andrew Catto, ACA
David Hart, Momentum Transport
Lydia Clarkson, Momentum Transport
Judith Ryser, UDG
Michael Coupe Coupe planning
Andrew Rogers, ACA
Chris Eaglen
Tim Gough, Austi Winkley
Bernard Humphrey, abp architects
David Bieda, Soho Society
Tim Lord, Soho Society
Michael Bolt, Marylebone Association
Prof Les Mayhew, Bayes Business School
Laury Mohirta, Barr Gazetas
APOLOGIES:
Brian Whiteley, RTPI
Nick Cuff, Urban Sketch
Laura Elias, Segro
Paul Higgs, Millbank Land, Colin.Wilson, L B Southwark
Agnieszka Zimnicka, Head Planning Policy Westminster CC
Towards a New London Plan
Jorn Peters, GLA London Plan team with contributions from Professor Ian Gordon, Emeritus Professor of Human Geography, LSE and Peter Eversden, Vice Chair London Forum
Summary points based on presentation by
Jorn Peters, GLA
The ‘Towards a New London Plan’ Consultation Document, published in early May 2025, is not a draft London Plan consultation but a discussion document seeking feedback on a number of policy issues where the London Plan might take a different direction.
The document sets out key direction/choices, not all of which would be possible, or are indeed the preferred route. Where the consultation document is quiet on a matter, it implies that those policy areas would not be subject to significant change and be retained.
This document is preceded by an engagement process that started two years ago.
The London Plan will be completely rewritten with a draft to be published in 2026.
London and the rest of country are in a challenging delivery environment. The London Plan does not want to increase the overall burden on development.
The London Plan will plan for 880,000 homes, 10 years’ supply. This number has no direct relationship with available land at present; the best use needs to be made of land.
The London Plan will set housing delivery targets for all London boroughs. There is a ‘Brownfield First’ approach and a Call for Sites. So far, 700 sites have been submitted. There are 47 Opportunity Areas as a possible source for housing. There is also the opportunity for housing delivery in the Central Activity Zone. Good transport accessibility is a necessary criteria for housing delivery.
Historically, industrial land was also a source for housing, but this document considers a more careful
KEY POINTS
➢ Not a draft plan
➢ Sets out key directions and choices
➢ Not all choices will be possible
London Plan
approach.
Wider urban and suburban intensification will need to happen. Brownfield land alone is not sufficient, so a London Wide Green Belt Assessment is being undertaken to understand how London’s Green Belt parcels are performing. The emphasis will be on release of green belt land to facilitate urban extensions at fairly high density. The emphasis will be on more homes within suitable green belt land parcels, in an efficient manner, ensuring the minimum amount of green belt land is used.
Metropolitan Open Land will be more clearly distinguished from Green Belt land. It is a London Specific designation and it is not suited for this land to be considered under the new rules of national Green Belt policy.
Alongside housing, economic development is important. The CAZ needs to continue to play a significant role in terms of its unique function for the
➢ Not all choices are the Mayor’s preferred approach
➢ Some choices reflect what we have been told already
➢ Everything will be rewritten (even if the policy approach stays the same) – streamlined
➢ Very challenging delivery environment - viability
➢ London Plan will not increase overall burden on development at this stage
➢ All responses submitted separate to events - online survey strongly preferred
London economy. However, parts of it are less commercial in nature than others. It would be appropriate to review parts of this zone that could offer the opportunity for housing – this is a new direction.
It is recognized that there are clusters of economic activity that are not well recognized by existing designations in the London Plan – the document asks whether there should be new designations for these economic clusters?
In relation to Town Centres and High Streets the question is asked whether these could be acceptable for any type of commercial activity related to Use Class E, thus allowing some light industrial and leisure uses. Some exclusions need consideration, e.g. betting shops, as these would not be appropriate. Housing in these areas would be encouraged.
The consultation document also considers managing industrial capacity strategically, so we can safeguarding the most suitable locations for industrial land, while potentially releasing other locations that could be better used for housing. More capacity might be needed for industrial land on appropriate sites in the green belt.
On housing growth and design
Building heights: consider policy levers to bring forward more development capacity in the existing built up areas. E.g. acceptable building heights across the whole of London could be at 4 storeys as a benchmark. This is already possible under permitted development.
Taller building heights would be suitable
where public transport accessibility is better, optimizing building densities. These heights need to be confirmed.
Design codes for small sites intensification could be introduced at the strategic level. Croydon and Lewisham have done some work in this respect.
The GLA could work with Boroughs to set out suitable heights and locations for tall buildings.
There will be less emphasis on heritage policy as these policy levers are well covered at national level. Should there be the option to retrofit our heritage buildings in a sensitive way?
Homes for Families: most of the development that will come forward within London will be flats to achieve the densities required. How do we make it work for families? Lessons could be learned from elsewhere where flatted accommodation is the norm.
On Infrastructure and Climate Resilience Environmental policy – should this be left to national policy guidance? In London there are London specific energy standards. The current London Plan has been at the forefront of the concept of heat networks and circular economy. The document asks whether we should keep the current approach or a new approach?
Open space deficiency – is distance to open space the right metric alone? Do we need to look at the quality of open space? Level of population in area?
In the current London Plan, MOL is linked to national level Green Belt policy. As a result of the changes to the national policy, the position it would leave MOL land in is now more ambiguous. MOL is not to be released to make up for a shortfall for housing.
Next steps
• The consultation document does not present draft policy, the content relates to ideas for policy direction.
• A new draft London Plan will be published in early 2026 for consultation. It is intended that the London Plan will be submitted for examination in 2027 with a new London Plan adopted by early 2028.
Presentation
by Professor Ian Gordon, Emeritus Professor of Human Geography, LSE
Professor Gordon expressed his pleasure with the Mayor having produced a preparatory consultation document, though with disappointment that it did not actually highlight the promised “big issues” or provide bases for their public debate
Instead a reading of the document, suggests a
HOUSING
➢ Plan for 880,000 homes
➢ A very big challenge and increase
➢ London Plan has to set borough targets
➢ Brownfield first (but not a sequential test!)
➢ We can’t do by brownfield alone, even with significant policy changes
➢ Other –
➢ National changes including introducing “grey belt”
➢ Large scale urban extensions
➢ Metropolitan Open Land – e.g. some golf courses
ECONOMY
➢ Dual priority with housing
➢ Maintain importance of Central Activities Zone
➢ New economic designation outside CAZ / town centres / industrial
➢ Town centres and high streets for any commercial activity - potentially with some exclusions e.g. betting shops?
➢ Clearer about reviewing town centre boundaries (especially release for housing)
➢ Set industrial capacity strategically (including grey/ green belt where appropriate)
➢ Focus designated industrial land on heavy industrial uses - consider light industrial in town centres
LONDON’S CAPACITY FOR GROWTH AND DESIGN
➢ Set acceptable building heights (excluding where impact on heritage assets)
➢ 4 storeys everywhere
➢ higher near stations – heights tbc
➢ London-wide design code for small sites intensification
➢ London Plan could set out tall building locations (together with boroughs)
➢ Need transport infrastructure to unlock densities
➢ Heritage – leave to national regime? (except views and World Heritage Sites)
➢ Homes for families to be flats rather than houses –how do we make that work?
polarisation between:
• a couple of big issues treated as now being settled by government edict: a need-based housing target of (88,000 extra homes per year over a decade); and systematic reviews of Green Belt to find more space for this;
• An enormous number of trivial questions about design and environmental measures which will elicit 200,000 different opinions.
The London Plan is supposed to be a strategic
plan, for which there are really 3-4 basic requirements:
1) a longer-term perspective, to make sense of the situation we are in and translate into lessons;
2) a much broader spatial perspective too, beyond the areas to be directly planned, to account for interactions with their hinterlands;
3) paying direct attention to underlying processes that drive individual behaviour and the labour, housing and product markets mediating these;
INFRASTRUCTURE, CLIMATE CHANGE AND RESILIENCE
➢ Environmental policies – leave to national regime or keep?
➢ Use benchmarks to current reporting (so industry know when they have done enough Energy standards
➢ Open spaces – Revisit how we assess and what is open space
➢ Fix unintended national changes to Metropolitan Open Land to distinguish from green belt
LONDON PLAN DEVELOPMENT STAGES
utterly implausible (150% above a recent average of about 33,000 p.a.) is because a series of Mayoral London Plans, over the past 15 years or so, had failed to come near targets that were taken as being credible – and thus got hiked up, like a cumulative overdraft. What is truly shocking about this consultation document is that it neither admits, nor starts to account for this record of chronic failure.
It also needed to be recognised that the optimism bias of London Plan authors (relying on forms of densification) was not shared by other informed observers. There were warnings from deeply sceptical EiPs – wanting a mix of full Plan reviews, Green Belt reviews and WSE-wide strategic engagement (taken further in the 2016 OLC reports, which the Mayor seems just to have ignored). And in 2019 the Inspectors simply removed one over-optimistic element from the target calculation, leaving a 14,000 gap.
On Green Belt review
plus, more pro-actively 4) building political alliances via deals/shared analysis with potentially key public/private actors, to secure more desirable outcomes.
Remarkably none of these are evident within the consultation document.
He then focused on what should have been discussed in relation to the two Big/Settled Issues:
Housing delivery and targets
The set target of 880,000 additional homes over the next decade comes from a sort of “need” calculation in the revised NPPF. The calculation is somewhat arcane (a previous version would have given 990,000). But a central logic running through it is that any shortfalls in one period need to be made up in the next one. So the fact that the target now being set seems
The required Green Belt review in London has already started (with a sudden Mayoral “change of mind”), although on a mundane bottom-up grey-belt basis. Within the consultation document there is no analysis of how/why this could be a game-changer, which on this basis is pretty unlikely. The obstacle is a micro-level (sticking plaster) approach – seeking sites that could be assigned to specific development within the plan period. Rather than recognising/addressing how the market-based WSE housing system, responds to strong external demands so long as a large proportion of potential developable land can be expected to retain Green Belt status, underwriting expectations of long term (30 year) growth in price and consequently slow rates of release. To deal with this, what is needed is a series of Wider South East reviews, involving sets of interested parties (in growth corridors) to generate sustainably acceptable and credible new frameworks/boundaries – rather than an ad hoc and disturbing “moth-holing” of grey belt with only temporary value. Objectively there are shared interests now across the regional boundary, since the Rest of the WSE now also faces a very challenging housing target. This will not be a simple matter, as it requires political alliances –but the Mayor of London ought to be in a position to provide some leadership!
Presentation by Peter Eversden, Vice President London Forum of Amenity and Civic Societies
Peter focussed on more factors for consideration for the challenges and issues in preparing the next
London Plan.
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The Government's imposition of a target 'need' of 880,000 homes over the next decade in London would require additional social infrastructure and transport improvements that will be very difficult to fund. The target in the current London Plan is 520,000 over ten years and recent trends indicate delivery rate is far below that.
Jules Pipe said at the London Forum’s event for the launch of the consultation document (May 2025) that: “We calculate something like two thirds of the 52,000 annual target should actually be in social housing.”
Last Autumn the Government attempted to apply their ‘standard method’ for targets at borough level which demonstrated that their formula does not work in London. The Government’s target for new homes in London over ten years is totally unrealistic and seems to be simply to meet their aim to have one and a half million new homes delivered nationally.
The Mayor will be using the SHLAA and SHMA to determine land capacity and housing need for apportionment to each borough of a housing target, so let’s look at some of the issues in recent housing delivery which have to be addressed. I cannot vouch for their validity but the sources are DHCLG, GLA, TCPA, RTPI, HBF, Shelter, London Councils and the LGA.
Issues in housing delivery
• Affordable homes started in London down by 88% April 2023 and March 2024
• 90% drop in grant-funded affordable homes started in the last financial year
• Housing association starts had a 92% drop in Q2 2024 compared to Q2 2023
• A significant downturn since last Autumn in both applications and construction
• Proposals by Government on biodiversity and nature recovery are adding costs
• 300,000 homes in London with permission but not built (7.5 years’ supply)
• 24,000 affordable homes lost by office-to-residential conversions under PDR
• Councils spend £114 million monthly on temporary accommodation
• Short term rentals (Airbnb) in 2024 averaged 51,000 in London
• 87,000 homes are long-term empty or second homes
The first four points emphasise the stagnation in the market recently and the question is how long will it take to return to anything like previous levels of supply?
Build costs have increased a lot.
We have to know if the three hundred thousand homes with planning permission will be built and when completion of some of them is likely.
Apparently, over 183,000 people in London are homeless and living in temporary accommodation, including nearly 90,000 children – that’s 1 in every 10 in every school class. As a result of that, Councils are having to house and support them at huge cost.
The last two points indicate the amount of potential homes not available for Londoners.
Of those Airbnb lettings, vacation rentals offering a private room within a shared property were 28% of all listings.
There are nearly 600 tall buildings above 20 storeys in the “pipeline” in NLA’s annual Tall Buildings Survey and at a rate of 280 completed on the last decade, this would be a 20-year supply.
These schemes represent over 100,000 homes, more than a third of all unimplemented homes in London. However, their affordable housing content is minimised by the cost of building towers.
Other factors
• Purpose Built Student Accommodation in central and inner London
• Cost of renting
• Some homes are under-occupied and some are overcrowded
• Some Opportunity Areas stalled
• How to densify the low-rise outer London suburbs
London
• London Councils reports that Boroughs in the capital face a funding shortfall of at least £500m this year (2025-26)
• National Development Management Policies and Local Plans
• Seven Mayoral Strategies to be updated and consulted upon
Many housing sites in London are being taken by Purpose Built Student Accommodation (PBSA). Could it be built in outer London instead of the locations in Inner London where we need more homes for local people? Travel concessions for students could be arranged.
The Government’s English Housing Survey 202324 [at https://bit.ly/3SRBHFd] showed that among those in the lowest income quintile, the proportion of household income spent on rent for private renters is rising significantly. That is causing homelessness and adding to the demand for social housing.
The existing housing stock is not always well distributed – for example, some homes are under-occupied, some are overcrowded, some are second homes and many are empty.
There needs to be an analysis of phased delivery of forecast homes and jobs in London’s forty-seven Opportunity Areas which were meant to deliver 25% of all new homes.
Another major issue is how to densify the lowrise outer London suburbs with clarity on CPOs for assembling land for development now that the Government has ruled out 'hope value' in compensation.
London Councils reports that Boroughs in the capital face a funding shortfall this year.
Proposals for National Development Management Policies could have implications for the London Plan and particularly for the content of London boroughs’ Local Plans. London Forum does not understand how the Government expects to write rules for decision making for topics that vary in all parts of England.
Finally, seven Mayoral Strategies have to be revised and all London Plan Guidance documents updated. They will all need consultation.
The outcome of the Planning and Infrastructure Bill as an eventual Act will impose more rules on the Mayor for general conformity in the next London Plan. The Bill may introduce Environmental Delivery Plan (EDP) and Nature Recovery proposals which could adversely affect development viability and weaken environmental protection.
There are current consultations on Government proposals for reforming local planning committees, simplifying decisions for schemes below 10 homes to help small and medium builders (SMEs), introducing a medium-sized site threshold up to 49 homes and ‘Speeding up Build-out’ for major developments.
The GLA and boroughs have to consider what will be done to deal with the issues and other factors that
I have outlined above in preparation for actions, new strategies, revised policies and guidance.
In conclusion, London Forum asks Where should the growth go?
• Increased density in the right places – refocus on town centres and stations – based on public transport, accessibility, capacity and connectivity.
• Opportunity areas – conduct a realistic review of progress and what they can deliver, as they are highly dependent on strategic transport infrastructure investment.
• Explore “grey belt” through strategic review of green belt
What form should it take?
• The preference would be for medium-rise, higher density buildings in right places
• In relation to Tall buidings the following should be addressed:
• Retain a plan-led approach through identifying suitable locations through local plans
• Resist reduction in Mayoral intervention thresholds, especially along Thames
• Revive/extend control of tall buildings along Thames and designate additional views upstream of Lambeth Bridge
• Initiate a major shakeout of the tall buildings pipeline.
Discussion
A number of forum members expressed disappointment with the contents of the document.
Sustainability, for example, appears as an afterthought.
The housing target is absurd. Nick Bannon’s book ‘How to Solve the Housing Crisis’ was mentioned – is there really a housing crisis? It is not quantum of housing that is the issue, it is affordability. Could the housing affordability issue in London be addressed through security of tenure?
The last Government brought in residential reform to get rid of Section 21 notices and short hold tenancies. Could there be a London Plan rent control? It was pointed out that rent control is not a policy issue as such and as such not much the London Plan can do about the issue.
It appeared that evidence collection did not feed into the document. Where, for example, did the existing London Plan fail, and therefore need a new direction?
The Standard Housing method is based on 0.8 x existing housing stock adjusted by an affordability factor. It has nothing to do with what the actual housing need is and what should be done about it; where capacity can be found. The London SHMA is just starting. No survey data is available to come to useful conclusions.
Who are we building for? We are not just building homes. There should be more guidance on tenure and
affordability to establish priorities for different groups. Those in greatest need should be prioritized; don’t just leave housing delivery to the market – it won’t address need.
The housing investment budget needs to be 3 times what is at moment – on social rent. We need to get the existing housing stock in effective use. Bannon is right in this way.
Where will the growth go? Expected progress will not be achieved unless there is significant transport investment. Responsibility should be taken back for the location for tall buildings. it might even be appropriate to lower the threshold for Mayoral intervention on major schemes. Over the last 25 years the Thams have been ruined. There are no strategic views beyond the Lambeth Bridge.
There needs to be a massive shake out of the 600 tall buildings in the pipeline. In the last 10 years 280 tall buildings have been completed. There are 20 years’ worth of tall buildings approvals not implemented.
There was a view that the consultation document is not a tame document. Is it proposing a lot of little land grabs? Is it disingenuous? It is said that the intention is not to make the burden on development worse, but is it decreasing the burden at all? The cost of planning delays and planning taxes through CIL and S106 is not acknowledged.
A view was expressed that brownfield land should not be the first priority. The use of existing buildings should be. Windfall sites should be number two; they grant enormous potential to bring in SME builders. The market is dominated by large developers. The consultation document’s focus on the number of homes to be delivered simply open the doors to provide a lot of housing with everyone in panic mode. This is a downward spiral.
There was a question on how the new London Plan interface with local plans as Local Plans come forward when they come forward. The GLA stated that the London Plan needs to provide certainty; it is not possible that local plan timings always aligns.
It was asked if something more radical should come to the fore. How should the GLA, for example, relate its town and country planning functions to wider interventions. The London plan is supposed to bring together the spatial implications of wider policies.
Whilst it was mentioned that the London Growth Plan is referenced in the current consultation document, it was felt by Forum members that the Growth Plan was more of a PR incentive.
It was questioned that the document reflected an understanding of London’s new economy: Google, life sciences, etc. It appears its focus on industrial land is completely outdated.
Members and others would have had the opportunity to comment on the document up until the 22nd of June 2025. n
The Mayor’s decided (some of) the Green Belt’s got to go
Response
from Outer London Boroughs led by Yvonne Sampoh, LB Barnet Principal Planning Officer (Policy) and Christopher Waller, LB Redbridge Planning Policy Officer
Yvonne Sampoh
The London Borough of Barnet adopted its Local Plan early March 2025. The Inspector’s Report came a month before the NPPF was published late last year, with implications for some Green Belt releast and development in the Grey Belt. So, the NPPF has interesting implications: Barnet Council need to increase their housing targets and as such take a new look at Green Belt land, identifying Grey Belt.
The Council is very much of the view that its Local Plan position regarding the Green Belt is justifiable. They eagerly await the outcome of London Wide Green Belt study.
Christopher Waller explained that in Redbridge, one third of land falls within the Green Belt and it has a range of different designations, including SINCs and SANGS.
However, there are sites, well located, openly talked about in various contexts that are suitable for release. The Council have decided to release some of these sites but were not successful in this process
during the formulation of its last Local Plan, primarily due to a lack of provision of playing pitches.
Christopher Waller was of the view that the Green Belt needs to be reviewed in its totality: there are land uses other than residential compatible with the Green Belt. It would be important to plan for BNG offset, renewable energy and burial space.
The Borough is in the process of scoping out its need for Public Open Space. Christopher Waller stated that the Borough agreed with the overall thrust of the Green Belt review but with two important considerations: 1) will it overlook green fingers/corridors? 2) will it fully consider Green Belt land that would be better partitioned off as MOL.
Discussion amongst Forum Members
It was noted that Green Belt boundaries were a matter for Local Authorities and not in fact the GLA. Historically, the London Borough of Redbridge have been very proactive in thinking about Green Belt release but they were stopped by the Mayor. Now, the situation is different.
The current GLA London wide Green Belt assessment is the first of its kind. The Mayor is conducting a review, but not all boroughs are active participants. The interaction between the London Boroughs and City Hall will be complex and interesting relating to this matter.
The assessment covers all of Outer London which include 18 Boroughs. All were invited to be involved. 16 agreed to co-operate with the Mayor, whilst the London Boroughs of Croydon and Hillingdon have chosen not to engage.
It was noted that the vast majority of new homes to be built in and around London will be flats. A question was raised regarding the marketability of larger flats in an Outer London context. Who will these be for? Will it suit larger household sizes?
It was noted that the intentions of the land owners with pockets of Green Belt land considered suitable for release are unknown. What are their institutional capacity to get these sites built out? Much of this land could come forward at a very slow pace as a result. n
The pros and cons of Oxford Street pedestrianisation
Discussion led by Mark Willingale, Willingale Associates and Magnus Wills, Barr Gazetas
With announcements by the Mayor that Oxford Street will be pedestrianised, two contributors to the Forum discussed visions for how this may work. Various options exist, such as decanting buses onto neighbouring West End streets, shuttle buses with interchanges, travelators, trams, and so forth.
Brian Waters opened the discussion by making reference to the fact that the idea of a pedestrianized Oxford Street is not novel. As far back as 1974 Brian Richards produced a scheme for Oxford Street. In 1967 Brian Waters published ‘Get our cities moving’ (the Conservative Political Centre) exploring how traffic could be reduced on Oxford Street. Brian Avery, architect of the IMAX and London Transport Museum, explored the idea of an elevated bus deck along Oxford Street to release the groundscape for pedestrians. In 2020, Andrew Chadwick suggested Oxford Street’s movement would be massively improved by travelators the length of the street.
Mark Willingale discussed the idea of an Oxford Street Shuttle, an idea that stemmed from his practice’s work on a 1994 competition for the Marble Arch – a gate that sits in an uncomfortable position. A full article on the competition entry is enclosed elsewhere in this issue of Planning in London.
In 1994 a tram system similar to Istanbul inspired the idea of bringing the Arch towards a more prominent position, and creating another landmark reference point on the opposite end to Centre Point. Now Cumberland Gate, a residential tower, is proposed. The returns from the investment on such a proposal could generate the funds to pay for a substantial amount of the money needed for the Oxford Street pedestrianization.
Magnus Wills illustrated a vision for Oxford Street by Bar Gazetas (SEE overpage). Oxford Street has issues with viability due to declining retail vitality. Congestion needs to be dealt with down Oxford Street, but it also needs to be future proofed with safety and accessibility in mind.
The Mayor is going to pedestrianize Oxford Street but the vision for it is not very aspirational. Where is the joy and delight? Where are the multiple uses? Where is the public space?
Bar Gazetas have a vision of turning Oxford Street into an urban park with performance, installations and play. A plethora of opportunities exist, completely overlooked, including our idea of linking the urban squares to north and south of Oxford Street with a network of green routes contributing to the ‘greening’ of Oxford Street
Oxford Street will never become a grand avenue. It is not the Champs Elysees. Historically, a lot of ordinary people have been dragged down Oxford Street to be executed.
What better tribute to ordinary people of London to give them Oxford Street?
Discussion amongst Forum Members:
A question was posed as to the Mayor’s intentions with pedestrianizing Oxford Street. The issue at present is the establishment of a Mayoral Development Corporation to enable it to happen; it is not around the practicalities of pedestrianization. Is the intention to create a funding stream?
The UK Devolution Bill will create powers for the Mayor to become a Licensing Authority. As such the public realm could become one of late night drinking, not unlike the Northern Quarter in Manchester. It was felt that after midnight Soho can be a very dangerous place to be. There are over 2,000 robberies and 2,000 assaults each year, fueled by the nigh time economy and over concentration of drinks licensing. Will all of it be replicated along Oxford Street?
Organisations like the Soho Estates are lobbying against these proposals. It is felt the Mayor is disenfranchising local residents. People in Soho are not against late night licensing but the Mayor is appearing to attempt a blatant land grab.
It was felt that the solution for Oxford Street should be elegant. Group members mentioned examples in other parts of the world, including the Grand Via in Madrid and the wonderful pedestrian centre of Vienna. n
LEFT CLOCKWISE: Brian Richards, Brian Waters & Bryan Avery. BELOW LEFT: Avery; RIGHT: Andrew Chadwick >>>
Oxford Street Pedestrianisation Ideas
Oxford
Pedestrianisation Ideas
Oxford Street Pedestrianisation Ideas
Oxford Street Pedestrianisation Ideas
Making Places
Oxford Street Pedestrianisation Ideas
Heddon Street
Oxford Street Pedestrianisation Ideas
Fair Field Croydon
Oxford Street Pedestrianisation Ideas
The Missing Magic
Here is the news ROGERS
Andy Rogers offers some lighter reading for the summer
Resisting the temptation to write yet another article on the meaning of curtilage and ancillary use in planning (see my last column), here is a selection of planning matters culled from my extensive files for your lighter reading in the summer holiday season.
A condition that allowed only agricultural workers to use a newly-permitted toilet block in Norfolk has been removed. The appeal inspector noted that the condition was neither reasonable nor necessary because the toilet block was on private land and the condition’s removal would have no unacceptable environmental impacts. (The Planner)
An appeal inspector quashed an enforcement notice in January 2023 because it required all unauthorised activity to cease immediately - and immediately is not a period of time for compliance, which must be specified in an enforcement notice. (Planning)
Another appeal inspector has ruled that a shop in Lewes that replaced old wooden entrance doors with smart new partly-glazed ones “harmed the significance of the listed building both through loss of historic fabric and through dilution [sic] of the architectural expression of the elevations.” (The Times). Do you agree?
Although allotments have a different character
and appearance from farmland, they still have an agricultural use, as confirmed by recent appeals. In Crowborough Parish Council v SSE & Wealden DC [1981] it was ruled that allotments fell within the definition of agriculture in section 290(1) of the 1971 planning act because they included activities such as “horticulture”, “fruit growing”, “seed propagation” etc. (Planning)
When a householder applied for a permission that was not required because the installation of a window was permitted development, the LPA nevertheless granted approval but with conditions that removed further pd rights. However the House of Lords, in Newbury District Council v Secretary of State for the Environment [1981], had confirmed that such rights are not lost if the permission on which the condition was imposed was not actually necessary, so the householder ignored the conditions. (Planning)
“A retired newspaper mogul who modelled her home on the Stone Age dwellings of Fred and Wilma Flintstone will be allowed to keep her house, complete with its model dinosaurs, after a long battle with a planning committee.” No, not your usual English blocking committee, but local planners in California who had refused permission to make changes to the local landmark “red and purple domed” house. Permission apparently granted after an appeal and two court cases. (The Times and Palo Alto Daily Post)
Havering Council ran up a bill of £10,000 endeavouring to find out which councillor derailed a planning meeting by continually ‘baa-ing’ in the style of a sheep. This included a 300-page report detailing the investigation, which resulted from a formal complaint to the standards board from a ward councillor when an application for a mobile home on a sheep and horse farm was being heard. (Romford Recorder)
“Fulfilment promised by fast erection” was a headline of the week reported in The Times. Noit referred to a demonstration that constructed a two-storey timber frame house in just five hours. If 1.5million homes must be built by 2029 and each home takes five hours to complete, how long will it take to solve the housing crisis? (Planning).
In Salt Lake City they have the solution to the
problem of concreting over front gardens for parking spaces: a local by-law requires all front yards to be completely covered with flat green grass. The city mayor has a problem – his own front yard has red bark dotted with ornamental grasses and purple sage shrubs, as a drought-friendly solution to the local water shortage. His solution is in line with what London’s mayor would do – the City Council was instructed to change the by-law. (New York Times)
Some years ago a Home Office statement explaining a Government drive to make sports more available to young people stated: “It is concerned with building bridges, using bats and balls as bricks and mortar, to bring ‘cul-de-sac communities’ closer to the social highway.” As clear as adobe. (Regeneration and Renewal)
Here is an old extract from a design statement that was claimed by Chris Shepley to be real: “The central architectural theme used is derived from the successful Mediterranean style of coloured aluminium, white steel and alpine finishes under a traditional red pantile roof. [Pause here for thought and visualisation] The style is developed with Georgian proportions and blended to a Golden Hind hardwood projecting style reminiscent of the stem of a classic sailing ship. This marine style, set on a concrete deck over the water, should make for an ever elegant style.” The only question is – did the conservation officer object to the use of white steel? (Planning)
In May 2002 Lord Falconer said of the development plan system: “It is too slow, too rules-driven, over-complex, people do not understand what guidance the planning system is giving, it is unpredictable, people do not know what results it will produce, it is not user-friendly and does not encourage a greater understanding.” (Planning). In March 2025 Rachel Reeves said that the UK’s problem is “too much overlapping regulation, too much bureaucracy, too slow to get things done.” (The Times). In June 2025 consultancy Stonehaven stated that the planning system has become “one of the most complicated legal frameworks ever built.” (The Times).
We now await yet more legislation, but will things ever really change? n
Andy Rogers is a planning consultant and former director in architects
The Manser Practice
How can design codes be used as an enabler to sustainable and resilient development?
Successful places are selfsustaining, thriving and adaptable and are comprised of more than just housing and are enabled by being robust and well planned, says Rebecca Dillon-Robinson
To truly take an outcomes-based approach, design codes and guidance should prioritise performance against climate-related hazards and sustainable design, alongside character. With uncertain futures ahead, ensuring our housing is future-proofed is imperative. This article explores how changing the way we use design codes could turn obstacles to development into assets for developers, the role design codes and guidance can play in futureproofing housing against climate-related hazards, and how shifting to an outcomes-based approach can create sustainable developments that account for local character and unlock opportunities.
As the climate crisis becomes more severe, climate hazards are fast surpassing the thresholds that our urban areas are designed for and able to handle, putting our communities, structures, and spaces at risk. Alongside this, Net Zero targets, energy security pressures, and a changing funding landscape are increasing the pressure for houses to meet the highest sustainability standards. In short, new homes and developments must be sustainable and resilient to be futureproofed.
Into this heady mix adding another specification – design codes – can be seen as another barrier to achieving the volume of housebuilding so desperately sought by the Government. This is partly because design codes are often viewed as a purely aesthetic tool that are used to dictate local contextual design. But that misses the potential for design codes to be used to deliver more.
When used to their fullest potential, design codes can provide a step-by-step guide to delivering sustainable, resilient and context sensitive developments – removing uncertainty and procedural barriers for developers, and resulting in better outcomes for future residents.
Rebecca Dillon-Robinson is Principal Urban Planner, Ramboll
A recently published Government white paper, currently under consultation, sets out an intention for ‘an updated national Model Design Code… helping to further support simplified design requirements’. It states that this is particularly to support SME housebuilders to help them understand expectations, de-risk development and ultimately build more homes more quickly. This is to support the delivery of 300,000 by SME developers on small infill sites.
The intention from the Government is to provide template design codes that can be used locally for different site size threshold and typologies. These will take a rules-based approach to design to help identify opportunities and enable faster application processes. The white paper also calls for the use of digital tools to support site finding and checking compliance of design requirements on specific sites.
This could be an important step forward. A consistent
approach to expectations on the quality of development would remove barriers for development, for example understanding expectations around provision of outdoor space and parking. However, we should seek to go further. What we need to create is healthy homes for an aging population, that are energy efficient and climate resilient.
Embedding outcomes in delivery
Instead of mandating specific insulation types, an outcomebased code could set a target for overall building energy performance, such as a maximum annual energy consumption per square metre. Codes might require a reduction in average surface temperature for urban developments, for instance by achieving a reduction in surface temperature by 5°C using a combination of green roofs, reflective materials, and strategic landscaping.
Instead of detailing specific accessibility features, codes might set targets for overall accessibility performance such as ensuring all residential units are accessible to people with varying abilities, enabling easy mobility and use of facilities. To align with the Government’s ambitions, these outcomes could be tracked and monitored to ensure compliance and leverage data.
Importantly, the codes would define clear and measurable targets for the desired outcome, along with setting out a stepby-step guide to achieving the outcome, sharing best practice and case studies. Developers would have the freedom to choose the optimal methods and materials to achieve the target, as long as the desired outcome is met. After completion, the performance of the development would be measured to ensure the target outcome has been achieved.
SME housebuilders are resource constrained, by providing them with a clear way to achieve local outcomes, they can build what is needed for the area, and ultimately achieve better value for their investment.
Design codes can also provide the structure needed to implement systemic resilience measures, transforming housing developments from isolated units into interconnected, resilient communities. Government policies that unlock mechanisms to catalyse systems thinking and ecosystem approaches into the planning of new developments. Design codes, when applied comprehensively, ensure that resilience is built into the very fabric of housing developments, addressing vulnerabilities at multiple levels and providing long-term sustainability.
Codes can provide developers a framework for integrating resilient and sustainable outcomes into the planning, design, and construction of housing. Guidelines can demonstrate best >>>
practice examples of implementation.
Practical examples
Design codes can mandate the durability and strength of structures. For instance, specifying the use of flood-resistant materials and elevated designs in flood-prone areas helps protect homes from water damage. Additionally, guidelines for retrofitting existing buildings to improve their structural integrity against extreme weather events can mitigate physical vulnerabilities. Reducing the risk of flooding and its associated damage can also be mandated, with guidance on the use of sustainable drainage systems (SuDS) in order to ensure that stormwater is managed effectively.
Design codes can address ecosystem degradation and biodiversity loss by mandating enhanced levels of biodiversity, although the Government is looking at relaxing these standards, with design guidance demonstrating the use of green roofs, urban parks, and the preservation of natural habitats within developments.
Healthy, inclusive, and cohesive communities are more resilient to climate-related hazards. Design codes can promote social resilience by ensuring that housing developments provide access to essential services, recreational spaces, and community facilities. Mixed-use developments, that integrate housing with commercial, healthcare, and educational facilities reduces residents' reliance on long commutes and enhances community cohesion. Additionally, universal design principles can make housing accessible and functional for people of all ages and abilities, promoting overall wellbeing.
Economic vulnerabilities related to trade, insurance, mortgages, and productivity can be mitigated through resilient
housing designs that reduce damage and repair costs. Design codes can promote energy-efficient buildings that lower utility bills and reduce carbon emissions, providing long-term economic benefits. Guidelines for the integration of renewable energy sources, such as solar panels and wind turbines, can further enhance economic resilience by reducing dependence on external energy supplies.
Technological infrastructure – including power, communications, and data systems – plays a critical role in the resilience of housing developments. Design codes can specify the inclusion of backup power systems, robust communication networks, and secure data infrastructure to ensure continuity during crises. Moreover, integrating smart technologies into housing can enhance resource management and emergency response capabilities.
Institutional resilience through improved risk management, emergency services, and planning policies is also essential. Design codes can foster collaboration between developers, planners, government agencies, and community organisations to create housing that is well-prepared for emergencies. This holistic approach enables the anticipation, absorption, and recovery from climate-related hazards.
Ultimately, when considering design codes, the most important question we should be asking is: what are the places that we want to create for people to live in? Successful places are self-sustaining, thriving and adaptable and are comprised of more than just housing and are enabled by being robust and well planned.
If the Government want their house building programme to be successful, they will be judged on the creation of sustainable communities. n
Zack Simons KC thinks that the outcome of the Mayor's green belt review and its translation into the next London Plan will be absolutely mission-critical for (a) this Government’s wider housing programme, and (b) our shared national prosperity
The big change in the next London Plan
We are living, as the ancient Chinese curse puts it (which is apparently neither ancient nor Chinese), in interesting times:
• As you may just about have heard, the Reform party has the swept the nation, leading #planoraks everywhere to ask the obvious question: what do Faragians think about planning? Well… we don’t know. We just don’t know. You can scour their last manifesto - that will take you all of 2 minutes. They want to “fast-track” brownfield sites [Doesn’t everybody? Ed]. They want more infrastructure [Don’t we all? Ed.]. Beyond that? Tumbleweed. Where is Nigel on the great questions of our time - NDMPs, grey belt, strategic planning, the Habitats Regulations. Time will tell.
• In a dramatic break with the convention that normally sees national planning reforms dumped on us around Christmas Eve, in the fresh blushes of spring, we welcomed to the stage the Planning and Infrastructure Bill 2025. Or… #PIB. Does that work? [I don’t see it catching on, Ed.]. As ever - the main thing - the hyperlinks:
• Soo much more to come on #PIB. But for now, to keep things light, and to give you a sense of quite how tough planning reform is proving even within the Labour Party, let alone outside it, check out some of these proposed amendments. Some from Labour MPs. Including the old classic: the “3rd party right of appeal”:
arguments about whether and the extent to which the scheme accords with the development plan. This amendment is a recipe for chaos. And what party did it come from? Labour (the back of the back benches, to be clear, but still).
• For grey belt watchers everywhere after my last blog post on the topic, the appeal decisions are coming thick and fast. Just to give you a couple from my own desk:
• In April, an Inspector allowed an appeal for a mixed residential, commercial and recycling scheme in Hersham near Walton-on-Thames, Elmbridge, in the metropolitan green belt. What’s worth noting in particular about this one is that originally it was refused on green belt grounds. Then, before the inquiry, the Council conceded and accepted permission should be granted just on account of the advent of “grey belt” policy.
• Also in April, an Inspector allowed a full application for 173 homes at Daws Heath in Castle Point, Essex. The message from this one (as per my last blog) - town ≠ village.
• That one - as I explained here - really takes the biscuit. It would bring the planning system to its knees (which is kind of the whole point). It’s intellectually dishonest. And it’s crumbles on even a moment’s thought. Thousands of major planning applications are granted every year. Thousands. Almost every single one of those involves (i) people who have lodged objections, and (ii)
• I was banging on, in that last blog post, about a pre-PPG “grey belt” decision in Beaconsfield, and wondering whether the outcome would be different in our post-PPG world. Well, turns out we’ll now be able to find out. Because the decision has just been quashed by the High Court with the consent both of the Secretary of State and Buckinghamshire because “as the Inspector’s decision failed to consider and address whether the site was compliant with the Golden Rules, the decision also appeared not to consider the effect of paragraph 158 NPPF, and therefore obviously relevant material considerations were not taken into account."
• An important new Court of Appeal judgment on the meaning of the retail sequential test: here. And another on making sure the draft 106 is on the planning register: here.
• A big-time appeal decision for the former Stag Brewery in Richmond: here. Where the Inspector accepted that 7.5% affordable housing provision was the maximum possible, and accorded with local and London-wide policy.
Those topics are chunky enough to fill many blog posts. But I want to tell you about something else. London. Which is, as the Clash said, is very much calling.
Let’s talk for a minute about our capital city - the place which for 20 years now is where I’ve called home. Tiring of it means you’re tired of life. Apparently. But I don’t think Samuel Johnson ever had to take the Northern Line on a Monday morning. He’d tire of things pretty quick after that, I’m guessing. Here are some key stats:
• 1 in 8 of UK-ers live in London.
• Almost 1 in 4 of the £££ our country generates comes from here. If London were a country, it’d be a top-20 world economy (bigger than Sweden, Belgium, or Argentina).
• And we are very much intending it to grow. Almost 1 in 4 of the new planning permissions for housing this Government now >>>
Zack Simons KC is planning counsel at Landmark Chambers
targets are supposed to come forward in London - that’s 87,992 every year out of the 370,408 annual total. Put another way: unless London hits its targets, we’ve no shred of a hope of getting remotely close to the overall target. Full stop.
So. Will it hit its target? 88,000 homes a year. Eek. Doable? Well, not at any point since before the 2nd world war:
The current London Plan was adopted in 2021. It targets 52k homes a year spread across all 35 of London’s Boroughs. Well below current local housing need of 88k. And, as the chart above shows you, even that target isn’t being met. Not by a long shot. So… there’s a lot of work to do in London. On unlocking designated Opportunity Areas, on funding for transport improvements, on funding affordable housing properly, and making schemes viable in a world of soaring construction costs.
But let’s spend a moment on another of the key reasons that London isn’t getting anywhere near its target: the Metropolitan Green Belt.
The first thing to say about the Metropolitan Green Belt is… it’s huge. Properly huge:
It is by far and away the biggest of England’s 14 green belts. Stretching out from Southend in the east all the way to Reading in the west. From Tunbridge Wells in the south up to the fringes of Milton Keynes. We’re talking over 1/2 a million hectares of land spanning Greater London itself along with 13 counties. An area a 1/4 of the size of Wales, over 3 times bigger than London itself. You get the idea. Big.
Now, most of the Metropolitan Green Belt is way outside London itself: (see map top right)
But just over 35,000 hectares of it falls into the outer Boroughs of Greater London. That accounts for about 22% of the city's total land area (more than half of which is in just three outer London Boroughs - Bromley, Havering and Hillingdon). So, again…
First published in #planoraks, with the author’s kind consent
a lot.
In addition to that, there’s a further 10% of London which is Metropolitan Open Land, which the London Plan says “is afforded the same status and level of protection as Green Belt”. Spread, as you’d expect, toward the outer Boroughs: (see right)
So. The Metropolitan Green Belt has - for many decadesbeen the most enormous strategic planning issue for London to grapple with. And luckily, London has for 20+ years had just the right kind of strategic planning vehicle to deal with it: the London Plan. The kind of strategic plan all of us will be getting soon if the #PIB provisions have their way - more of which in future posts.
So the challenge is there. The imperative is there. The vehicle to address it is there. And yet… the London Plans of 2004, 2011, 2016 and 2021. Did they do any strategic reviews of the green belt? Or the MOL? Did Ken, Boris or Sadiq step up this particular plate?
Nope.
Indeed, last time around, the examining inspectors said that “the inescapable conclusion is that if London’s development needs are to be met in future then a review of the Green Belt should be undertaken to at least establish any potential for sustainable development.” Did it happen then? Nope.
Individual Boroughs - some of them, anyhow - have done their own bits of green belt reviewing over the years. But the green belt’s a strategic, trans-LPA boundary policy. It always has been - going back to Patrick Abercrombie’s Greater London Plan 1944. Or even earlier - the rather more modest idea for a slim “green girdle” in the 1929 report of Raymond Unwin of the Greater London Regional Planning Committee. The green belt itself - which now looms so large in the English psyche - it all started in London. It was a London idea. And it’s a London-wide idea. Not just Hillingdon or Bromley or Havering but everywhere.
So let’s just cut to the chase: when actually was the last time there was a full-scale strategic review of Greater London’s green belt? Or its MOL?
Never.
It has never happened.
Enter stage left: the consultation on the next London plan which runs until June: here. Lots in there. But what do you need to know? On this topic:
• The intention for the next plan (full draft plan in 2026, targeted for 2027 adoption) is to deliver 88,000 homes a year over 10 years. 880,000 homes (which, the consultation notes, will need planning permission to be granted for many more than 880,000). This is, as the Mayor says in the foreword, “more than we have every built before” and represents “an extraordinary challenge”. Housebuilding in our capital has to more than double. ��
• That might sound extreme. But, as the consultation explains, London’s in an extreme position. Over 183,000 Londoners are homeless and living in temporary accommodation tonight. In addition to the moral shame of that situation, it’s deeply expensive. It is, costing boroughs about £100m a month. And the estimate that if housing affordability was improved by one per cent, this would create an additional £7.3bn GVA over 10 years. Our persistent under-delivery of the homes we need is making all of us poorer.
• Getting there will require - in addition to the “brownfield first” approach we have already - a strategic green belt review to
identify, among other things, London’s “grey belt”. On which see this.
• The Mayor’s focus includes large-scale development (10,000+ homes) in green belt areas which have good public transport access. And golf courses - watch out for those! The Mayor tells us that “some areas of MOL, such as certain golf courses are not accessible to the wider public and have limited biodiversity value. This undermines the purpose of the designation. These areas could be assessed to understand whether they should be released from MOL.”
Back in December 2020, I was moaning in the FT about how we need to have, but were not then having, a “frank, grown-up conversation about the future of England’s green belt”. Well, blimey charley, we’re having one now. For my money, it’s not overkill to say that the outcome of the Mayor's once-in-a-generation green belt review and its translation into the next London Plan will be critical, absolutely mission-critical for (a) this Government’s wider housing programme, and (b) our shared national prosperity for the next couple of decades. No pressure, then
In the meantime, I hope you’re keeping well #planoraks, and are enjoying this glorious sunshine. I’m celebrating a particular mile-stone-y kind of birthday this month, so am feeling… old. This is also my first official missive to you as a Kings Counsel, so I thought you might get a kick out of seeing the just-slightly-OTT outfit which (thank heavens) I will never ever have to wear again. But it made for a memorable day out (and thank you to the brilliant Russell Harris KC for the loan of that cracking wig!).
My wonderful practice director Mike Gooch is on the left, and my super clerk Jonathan Barley is on the right. Go on. Have at it. Laugh until your hearts are content. And in the meantime, whatever else you do, try your level best to #keeponplanning. n
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PLANNING UPDATE 2025
Join us again this year to get the very latest on how planning and environment policy is changing under new Government initiatives and how they will affect your own projects.
The Planning and Infrastructure Bill, still working its way through Parliament, introduces environmental development plans the new nature restoration levy, work in practice?
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Mark Willingale, prompted by the prospect again of pedestrianisation of Oxford Street – as discussed at the London Planning and Development Forum – adapts his entry for the 1994 Marble Arch Competition for Cumberland Gate and Oxford Street today
Cumberland Gate and the Oxford Street shuttle
THE ARCH
As for the 1994 Marble Arch Competition submission, an appropriate scale and setting for the arch is provided by raising the attic storey to the intended proportions of the Constantine and John Nash precedents, turning the arch to align with Great Cumberland Place and the axes of the West End estates and bringing the arch forward to the centre of the new square formed between Frank Verity's apartments and the Cumberland Gate development. The illustrations include the drawings submitted for the 1994 Marble Arch Competition while illustrating the Cumberland Gate development on current Google Earth views of Marble Arch to demonstrate how the development can be completed without significant alteration of the Marble Arch circulatory system, allowing the arch to remain in place and be relocated on a separate programme.
USE
Harry Hyams' Centre Point was notorious for being held empty while office rents rose. Now again, after the 2015-18 residential conversion, the tower stands largely empty as the apartments that have been sold mostly remain unoccupied. Instead, Cumberland Gate presents an opportunity for a development designed for the short lets sector. The accommodation can be let on a first come first served basis, like airline tickets, for variable periods from a minimum of one week
to a maximum stay of 90 days. The accommodation will command premium rates but the system can also offer grace-and-favour rates for those with recognised public achievements or public service.
FORM
The tower is formed from two adjoining leaves, stems at the ends, placed orthogonal to Oxford Street, their folded flanks parallel to the west elevation of Frank Verity's apartments. Together they express the North-South axis of the West End Estates while forming the new square. A key design challenge for the pedestrianisation of Oxford Street is the wavering course and various building lines about the anclent road alignment projected over the contours of the Tyburn Valley resulting in an irregular space. Whatever paving and street furniture is applied to this space it cannot become a regular cartesian boulevard like the Champs-Elysées. A different approach is required, one that provides a regular virtual axis high above the pedestrians between prominent bookends. One bookend is already in place at the east end; Centre Point. Cumberland Gate provides one for the west end. Centre Point almost orthogonal to Oxford Street at the end of Tottenham Court Road provides the bookend for Oxford Street East while Cumberland Gate orthogonal to Oxford Street at the end of the Edgware Road will provide the bookend for Oxford Street West. n
Mark Willingale is principal of Willingale Associates, architects
2025 UPDATE : THE OXFORD STREET SHUTTLE
Why does negotiating section 106 agreements have to be such a drag?
It doesn’t have to be this way, suggests Simon Ricketts
Read this:
“To better understand the current state of S106 agreement timelines, the Home Builders Federation (HBF) submitted a Freedom of Information (FOI) request to local planning authorities across England. These results are based on the data from more than 2,500 S106 agreements across over 50 local authorities.
The FOI exercise found that the average S106 approval timeline was:
2022/23: 425 days
2023/24: 459 days
2024/25: 515 days
In just two years, the average time required to finalise an S106 agreement has increased by 90 days – a 20% increase.
The responses also highlight the extremities that developers in some local authorities are facing. The maximum recorded timescale was 2,679 days, or more than seven years, for a single S106 agreement to complete the agreement process. The shortest average timescale reported by any of the respondent councils was 192 days.
Additionally, 35% of all S106 agreements took longer than 12 months to finalise. Across all responses, 76% of local authorities reported average timelines that exceeded a year, and over a third of councils had an average timeframe of over 500 days.
In 2024/25, 45% of LPAs had agreements finalised that had taken over 1,000 days to complete.”
The HBF’s May 2025 research piece What is the timeframe for local authorities to agree community investment? shows what a huge drag on planning permission timescales is represented by the process of negotiating a section 106 agreement (which of course needs to have been completed before planning permission can be issued).
From Simon’s Blog at simonicity.com/author/si monicity/ personal views etc.
The document doesn’t specify the scale threshold of applications considered (I’m assuming by the number of agreements that this is in relation to developments of any scale, not just complex schemes where we know that specific issues requiring bespoke solutions and substantive negotiations may required to unlock solutions). Nor does the document specify when these time periods are measured from: validation of the application, instruction of the LPA’s solicitor or the resolution to grant. Whatever, the statistics are appalling as is the relentlessly worsening trend.
The work is of a piece with the equally depressing Richborough/LPDF research carried out by Lichfields, How long is a piece of string? (16 May 2025). The average determination period for outline planning applications for 10 dwellings or more was 284 days in 2014. In 2024 it was 783 days. Given improvements in the performance of the Planning Inspectorate in relation to planning appeals (particularly appeals determined by way of public inquiry), it is now substantially quicker to secure a decision by way of appeal than by waiting for a final decision from the local planning authority.
This reflects our own anecdotal experience; we are seeing far more appeals on the basis of non-determination within the statu-
tory period, and (tying back into that HBF work) one factor for clients is that with an appeal there is an external discipline upon the parties to agree and complete the section 106 agreement or unilateral undertaking within a specific, externally set, timescale. Stepping back, this is all crazy and contrary to the efficient operation of the public sector. It’s equivalent to the use of A&E departments by those who find it faster, easier or more effective than going to their GP. Something is massively wrong with the operation of the planning system and it’s nothing that the Planning and Infrastructure Bill or indeed in the government’s December 2024 changes to the NPPF will fix. MHCLG’s proposed alterations to the system in relation to “minor” and “medium” residential development (summarised in my 31 May 2025 blog post Small Changes). Indeed I referenced in that post what was said in relation to section 106 agreements for “medium” residential development (less than 50 dwellings – although why stop at that size cap?):
“We … welcome views and evidence on:
1. the specific barriers facing SMEs in agreeing s.106 obligations – including availability of willing and suitable Registered Providers
2. what role national government should play in improving the process – including the merits of a standardised s.106 template for medium sites
3. how the rules relating to suitable off-site provision and/or appropriate financial payment on sites below the medium site threshold might be reformed to more effectively support
Simon Ricketts is a partner in Town Legal LLP
>>> affordable housing delivery, where there is sufficient evidence that onsite delivery will not take place within a suitable timeframe and noting the government’s views that commuted sums should be a last resort given they push affordable housing delivery timescales into the future.”
The lack of a standardised template is one issue. We end up having frustrating arguments over what should be uncontentious and standard wording, for instance to protect mortgagees in a way which is institutionally acceptable, or simply over our attempts to make a particular LPA’s “standard” drafting operate as the parties intend. The failure of the Law Society to update its June 2010 template (which never really achieved sufficient support and was not well used) is disappointing. Without drama we need a national template on the MHCLG website asap for smaller schemes, expressly supported by local government, the development industry and professional bodies (including those representing banks), with specific guidance as to the circumstances in which there can be departures.
But the problems go much wider than that.
Many LPA legal teams are woefully under-resourced, without a lawyer with the necessary experience, project management focus or internal clout to do more than act as a post-box with those instructing them, adding pressure and unfair responsibility on planning case officers or allowing other internal or external consultees to drive their particular agendas. There is often a reluctance on the part of the in-house legal team to outsource to an external law firm (even though the applicant pays and is usually eager to pay more if that results in faster
delivery of the completed agreement) because of internal pressures not to de-skill further the in-house team or lose the ability to recoup costs.
I suspect that LPA lawyers (some of whom are true unsung heroes) would equally point the finger at some applicants’ solicitors – and indeed some applicants – who may be unprepared to back down from unreasonable negotiating positions or may introduce new points post committee resolution – or who may start ghosting them when something commercially is happening in the background.
Negotiations often start way too late. The government’s planning practice guidance on planning obligations (1 September 2019) says this:
“When should discussions on planning obligations take place?
Discussions about planning obligations should take place as early as possible in the planning process. Plans should set out policies for the contributions expected from development to enable fair and open testing of the policies at examination. Local communities, landowners, developers, local (and national where appropriate) infrastructure and affordable housing providers and operators should be involved in the setting of policies for the contributions expected from development. Pre-application discussions can prevent delays in finalising those planning applications which are granted subject to the completion of planning obligation agreements.”
So often though, this isn’t happening.
There also no easy answer if negotiations genuinely hit a brick wall – for instance as to whether a particular contribution is justified or as to the precise drafting of a particular clause.
Section 158 of Housing and Planning Act 2016 specifically inserted section 106ZA and Schedule 9A (“resolution of disputes about planning obligations”) into the 1990 Act, to provide for a system where an independent expert could be called upon where there are sticking points in section 106 negotiations, but it was never brought into force. It’s sitting there just waiting to be fleshed out by an SI and switched on! Whether the third party were to make a binding determination or, more practically, gave non-binding guidance that would still carry some weight if an appeal were subsequently required, in my view this needs to be dusted off!
Section 106 agreements are also of course lumbering beasts of burden, the legal mechanism for delivering so many strands of public policy – affordable housing, affordable workspace, carbon reduction measures, social infrastructure (eg education, health), transport infrastructure, local employment and training, affordable workspace, air quality, the complexities of viability review processes. What can we deal with by way of other mechanisms (eg conditions), or standardise? What should be left to other legislation? The financial weight of the obligations in a section 106 agreement in relation to any large scheme is huge – in some ways, it is no surprise that the agreement may take as long or longer to negotiate than it took for the application to get from validation to committee resolution, but what can we simplify, speed up, twin-track?
The Planning Inspectorate also has its Planning obligations: good practice advice (updated 5 February 2025), which is more specific than the government’s planning practice guidance and has its more prescriptive timing requirements (completed plan-
ning obligation at the time the written representations appeal is lodged is a tough one…). This is the sort of thing (with suitable adjustments) we need for the application stage, with real consequences for those who do not follow it.
Going back to the HBF work, several suggestions for improvements were made, various of them overlapping with what I have been saying:
• “Increase resourcing for planning departments: Local planning authorities are currently under significant resource constraints, which affect their capacity to process planning obligations in a timely manner. To alleviate these challenges, government should allocate targeted funding to increase staffing levels within planning departments. By investing in dedicated S106 teams and offering professional development opportunities, councils can improve both the speed and quality of agreement processes.
• Develop national standard templates and best practices: A lack of standardisation in the drafting of S106 agreements often leads to protracted negotiations and inconsistencies across councils. The government, in collaboration with planning authorities and the development sector, should produce standardised procedural guidelines and clauses to minimise the need to draft agreements from scratch. In lieu of official standardisation, there could be clearer guidance and expectations on good practice.
• Encourage a more flexible use of cascade agreements where necessary to ensure homes can be built and give reassurance to the developer that if an RP cannot be found, that the Affordable Homes can be changed to an alternative tenure or as last resort, a payment made to the LPA in lieu of the Affordable Housing.
• Introduce statutory timelines for S106 agreements: Consideration should be given to implementing statutory or guideline-based timescales into the application and pre-application process for handling Section 106 negotiations and the drafting and signing of agreements.
• Monitor, benchmark, and report performance: Introducing monitoring and reporting of S106 performance metrics could drive improvements. Local authorities should publish data on average timescales, agreement outcomes, and compliance rates as part of the general reporting on S106 agreements through Infrastructure Funding Statements. This information could be used to benchmark performance across regions, highlight best practices, and identify areas needing intervention. Increased transparency can also build trust among stakeholders and help developers better plan and budget projects.”
I’m sure this can be cracked, easily. Look what Bridget Rosewell’s recommendations on the planning appeal process achieved. If in a couple of years colleagues are still spending much of their time chasing for progress on draft agreements and having to explain to frustrated clients why there is no progress, I’ll be pointing you back to this blog post.
I know most of us have all grown up with this section 106 run-around – indeed some of us are in fact part of Generation Section 52 – hard-copy travelling drafts sent by post, marked up in a sequential series of colours, by pen – yes it was, despite all that, a faster process than present – but, in the words of the Blow Monkeys from that period: it doesn’t have to be this way. n
Modular homes can help alleviate the temporary housing crisis, explains Colin Ainger
Temporary modular housing – an urgent solution
Over £90m is spent each month by London Councils on temporary accommodation, with an estimated 85,000 children among 175,000 people in hostels or hotels—roughly one child per classroom without a permanent place to call home. It is a crisis that needs an urgent solution.
Working with Wates Residential and Havering Council, HTA Design’s proposals for 18 temporary, demountable modular homes in Romford offer a small but meaningful step towards alleviating the problem.
The Problem Councils are spending more than ever on temporary accommodation due to a shortage of social housing, rising living costs, and an exodus of private landlords from the sector. Additionally, Local Housing Allowance (LHA) rates haven’t kept pace with rising costs of private rentals, making it harder for councils to find suitable and affordable temporary accommodation.
The Opportunity
In early 2024, Wates and Havering Council approached HTA to design temporary modular accommodation on a cleared regeneration site in Romford, Havering, following Wates’ success with similar schemes for Cardiff Council and the Vale of
Glamorgan Council.
The Romford site forms part of the wider Waterloo Road and Queen Street project, located just 500m west of Romford High Street, where 1,380 new private and affordable, permanent homes are planned.
This is all part of a major regeneration project which will see 3,500 new homes delivered across the borough by the Wates and Havering Council joint venture.
Given the scale of the project on the Waterloo Road and Queen Street site, the final phase is unlikely to begin for at least five years, providing an opportunity for a ‘meanwhile’ use on site. Wates and Havering Council decided to develop temporary accommodation, with the brief that it be demountable after 4–5 years for relocation and reuse.
The Hostel Experience
As we began designing a series of temporary homes, to be factory-built and craned into place on the vacant site, we visited families living in a nearby hostel. Many were relieved to have left hotel rooms but still lived in overcrowded, singleroom spaces, desperate for a permanent home. Parents shared bedrooms with children leaving no privacy or space to cook, study, or relax, voicing deep concern about the impact on their children’s health, development, and ability to
Colin Ainger is a partner and project director at HTA Design
socialise. Sadly, this represents the standard for temporary accommodation across London – and Havering Council is actively working to reduce its use of such facilities, including through these new modular homes.
The Brief
This was an unusual brief, and it was important to look at the challenge from every perspective.
We worked closely with Wates and Havering Council to fully understand the requirements, focusing on resident needs, funding constraints, construction and delivery methods, future relocation of the homes, and long-term management of the scheme.
Collectively, we decided that we should design family homes, accommodating separate living, sleeping and washing facilities and meeting all required standards while maximising speed and cost efficiency. They would be compact, but individually accessed and with an area of private, external amenity space.
The Design
We tested various site layouts, massing strategies, and housing typologies. Using a scoring system to identify the best approach for the site, we assessed each option against 13 specific requirements that were identified as part of the initial briefing exercise, such as speed of delivery, ease of procurement, quality of internal accommodation and the ability to demount the homes to be used elsewhere.
We chose single-module homes, primarily single-storey, with
a few stacked homes to mirror the neighbouring street. Speed was a priority, so we avoided combining modules into larger units which would have added complexity and time. Additionally, the homes are semi-elevated to help speed up delivery, allowing the use of screw piles with minimal ground disturbance.
Each home is triple-aspect, back-to-back with a neighbour to form a recognisable ‘house’ form using a custom-made pergola. It was important to the team that homes blended into their surroundings, with street-facing front doors, quality planting, and a >>>
familiar, residential aesthetic.
A landscaped buffer will provide play space and access to greenery while recessing the homes away from the construction traffic that will be required to pass the site. Each home also has access to private external amenity that meets and/or exceeds Greater London Authority policy.
The Applicability of Modular Construction
Although modular housing has made headlines due to some manufacturers entering administration, we’ve long recognised its advantages, in terms of quality, speed and sustainability for the housing sector.
Each home was designed with a specific manufacturer’s requirements in mind, adjusting dimensions to fit its production process, minimise material waste and optimise modules for transport.
The Planning Process
We had political support from Havering Council, however, we needed to agree an approach to obtaining a suitable and appropriate planning consent with officers.
Havering’s planning team provided strong support for the
scheme, working closely with us to develop a planning strategy and playing a key role in securing the temporary consent under Use Class C3 (eschewing Sui Generis). This created a balance between the flexibility required and an appreciation that these are homes for residents, albeit to be delivered for a limited period.
What Next?
A competitive tender to select the modular manufacturer for the scheme is due to conclude shortly, and work will then commence in the factory, while enabling works get underway on site to allow homes to be installed in the Autumn. With a clear process now in place, it is hoped that this will be a blueprint for temporary modular housing across the capital –enabling the design, planning approval and deployment of new homes within just six months of projects being given the go-ahead on future sites.
Given the opportunity this creates to help alleviate the temporary housing crisis, Wates and HTA are in discussions with other local authorities, landowners and the GLA to seek additional sites on which modular homes could be deployed, thus giving more families a reason to be more hopeful.
Does Chapter 12 of the new NPPF introduce sufficient change? asks Glen Richardson
Delivering well-designed homes
December’s new NPPF introduced some significant policy changes – on housing targets, the 5-year land supply and the introduction of the Grey Belt among others. The fact that it largely removed the controversial references to the word 'beauty' has received less media attention.
So what does the change to the title and content of Chapter 12, Achieving well-designed places (previously Achieving welldesigned and beautiful places) mean in reality? Will design standards be impacted, as the Policy Exchange asserts in Beauty and Socialism: How the Left can put Beauty back into Britain? Or does it remove a subjective and unquantifiable term which had little place in planning policy to start with?
The removal of 'beauty' from the NPPF
Glen Richardson is associate partner in Carter Jonas’ Cambridge office
Like most planning and development professionals, I welcome the change. I think it’s an improvement to remove the word 'beauty' as this removes the subjectivity of what is in effect a highly subjective judgement. Instead, the chapter addresses the principle of good design, which was in place prior to the July 2021 revisions. The inclusion of 'beauty' was at times disastrous, specifically for developers whose schemes were rejected at the last hurdle by Michael Gove on this basis.
Is there a risk that, bearing in mind the government’s need to expedite housing delivery, design standards will be compromised?
Secretary of State Angela Rayner says not: Labour’s 1.5 million homes target will not, she says, lead to “a load of ugly houses”.
Design guidance at a national level
Beauty is not ditched as a high-level aim but the focus is now on high quality design, to be achieved through design coding and guides. Paragraph 133 of the NPPF states that to provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code. A third document which is referenced in this context is Building for a Healthy Life, an updated version of an earlier document Building for Life.
The inclusion of these three national-level documents – which we find are frequently quoted in planning appeals and inquiries –provide a useful foundation and a point of reference to assess the quality of design: one which is much better suited to planning policy than the rather vague concept of 'beauty'.
It’s important to recognise that the NPPF is an overview of policy, a catch-all. In practice, there’s really no place in a document of this type for specific design requirements – for example, the focus on Mansard roofs in the 2022 version, which appeared quite unnecessarily. But documents which provide clear guidance and the basis for local policy, and to which both designers and local authorities can refer, do have an important role to play.”
Addressing the Housing, Communities and Local Government Committee in November last year, planning minister Matthew Pennycook stated that the government intends to update the National Design Guide and the National Model Design Code in
>>>
Spring 2025. So, we can expect some tweaks in these documents imminently, but otherwise don’t anticipate substantial changes, certainly not those which would delay the process of expediting planning consents.
The lesser importance of local character?
On design codes, the NPPF has made a significant change: the previous government had required that councils prepare local authority-wide design codes, which must be adhered to when meeting housing need . In the recent revisions, in place of district-wide design coding, the government substitutes localised design codes, masterplans and guides, “for areas of most change and most potential”. Examples cited are regeneration sites, areas of intensification, urban extensions and large new communities. The new paragraph 135 states that the National Model Design Code is, the primary basis for the preparation and use of local design codes and removes the requirement for local design codes to be the primary means for assessing and improving the design of new development.
It makes complete sense, in both architecture and planning, that design codes, where they exist, should be applied on a local level. To suggest that a local authority should have a single design style is the antithesis to good design: design should always respond to its immediate surroundings. Perhaps more sig-
nificantly given the push for growth and a significant uplift in housing targets, it is important that the National Model Design Code exists for the benefit of those councils that don’t have the time or resources to develop their own design codes.
It’s also clear now that, where local planning authorities can provide their own specific design policies, they should do through community engagement, as per Paragraph 138 of the NPPF.
Design codes in practice
Carter Jonas has created local design codes for specific developments previously. This includes a detailed code for a new community of 1,800 homes in Swale District, Kent, Winterbourne Fields. Quite often we are asked by clients to provide a commentary on their proposals in relation to the National Design Guide and Building for a Healthy Life. Our experience is that these documents are useful in encouraging thought and discussion about building design. While they don’t state that one style is ‘better’ than the other, they do provide the structure for assessing the quality of a proposal against key criteria such as street design, character and connectivity.
From experience I believe that documents such as the National Design Guide and Building for a Healthy Life, which are tried and tested and cite best practice, will continue to be of use and encourage local authorities and developers to retain high design standards. The early stages of masterplanning requires considerable time to be taken to understand objectives and respond appropriately, and these documents help sign-post both designers and local authorities to best practice.
Local vernacular and density
Paragraph 130 of the previous NPPF included a statement (no doubt included to appease backbench disquiet) stating that local character can be taken into account when ‘councils consider their ability to meet their housing needs’ – in other words, schemes could have been rejected if local character was not met. This requirement, which specifically referred to density, has been deleted in its entirety. I agree with this change. The new NPPF strengthens expectations that local plans facilitate an uplift in density, where appropriate. But increased density needn’t be detrimental to local character.
I think it’s wrong to assume that to build at high density you have to build tall. It’s more a case of thinking carefully about issues such as how to design, and where to place, elements including car parking and gardens and providing shared open spaces. It’s about being super-efficient with a more limited amount of space and highly creative with site layout. The NPPF supports building at density, subject to good design.
LDOs: Good design does not equate to less speed
An important role of the NPPF is to enable quality planning to
THIS SPREAD:
Images of Poundbury
takes time. But good policies – those which stem from national policy but are implemented through local policy – are crucial in allowing schemes to progress quickly.
There are many examples, but perhaps the best is Local Development Orders (LDOs) which can promote both speed and excellence in design. We’ve researched them at Carter Jonas, such as in our work for Gascoyne Estates in in Hertfordshire. Another well-known proponent of LDOs is the King, in his new communities at Poundbury, Nansledan and elsewhere.
The somewhat ‘pastiche’ Georgian style in these developments may be divisive in the architectural community, but it’s also popular with many buyers and local authorities. Despite the inspiration for these Georgian-inspired schemes coming from an era before planning was underpinned by an Act of Parliament, such developments can achieve high levels of density alongside clear design intent.
Legacy schemes such as these succeed because they involve dedicated teams of architects who work from a site-wide pattern book. They aren’t granted any greater leniency than other schemes - design is very carefully scrutinised - but because they provide a clear vision for design from an early stage and can be designated as a special planning zone or LDO, planning approval can be fast-tracked.
LDOs: the answer to Labour’s 1.5m challenge?
This raises the question: if fast-track mechanisms such as LDOs can speed up planning consents, will the government encourage their wider use? Are we already seeing something of this nature in the recent announcement that Simplified Planning
It could be part of the solution to enable more homes to come forward. But LDOs are used quite sparingly, usually by ‘legacy’ landowners who want to retain involvement in the evolution of a scheme. While they are successful in specific circumstances, I don’t think they’d necessarily be as straight forward to roll out nationwide.
Conclusion
The 'beauty' issue was a rare case of building design being politicised. If we were to draw parallels with policy documents from other government departments – the Treasury, Department for Education or Foreign Office – the fingerprint of the party in power would be immediately visible. Perhaps partly because of the long duration and prominence of schemes such as Poundbury (by the Duchy of Cornwall), Accordia (Stirling Prize winning housing in Cambridge) and many others, there’s not really a ‘pendulum effect’ in design policy. Consider also how the work of Michael Heseltine (once dubbed the socalled ‘Minister for Merseyside’) in turn influenced John Prescot’s and Lord Rogers’ Urban Renaissance, and further how that earlier regeneration work was continued by the Coalition and later Conservative governments.
Ultimately, consistent and clear policy and guidance is what is needed to enable good quality schemes, delivered at a good pace. Addressing the current housing crisis required change to aspects of the NPPF, as we have seen in the renaming of Chapter 12, but change for change’s sake is rarely the correct option. While politics may flourish on dramatic twists and turns, policy works best when it remains clear and consistent. n
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Farrell’s Chelsea Waterfront masterplan – 27 years in the making
The recent completion of Lots Road Power station is the last phase of Farrell’s Chelsea Waterfront masterplan, writes Shevaughn Rieck
Starting in 1998 with Rosehaugh, then Circadian a JV between Taylor Woodrow Developments and Hutchinson Whampoa then finally with Hutchinson Property Group. Farrells have stayed with the project throughout (working at times with Formation Architects and BPTW) to deliver the original vision.
Shevaughn Rieck is a partner with Farrells
‘We are keen to deliver the construction documentation for our masterplans’ says Shevaughn Rieck, partner in charge of the scheme. ‘There is no better way to make sure the quality of the original vision is delivered in the final product and the big ideas we begin with are enhanced through the crafting of the details’
Farrells masterplan vision centred on two principles, one urban related, the other architectural. The combined industrial site which spanned from Lots Road to the east as far as the western edge of the Chelsea Harbour development was a significant break in the London Thames path and had kept Londoners away from its riverside for over 100 years. The creek was a barrier to pedestrian permeability between the boroughs. Farrells wanted to reverse both to reconnect the site to its neighbours and directly to the river.
Architecturally, they felt the Power station should be retained,
repurposed and become the ‘centre’ of the masterplan. Decommissioned in 2002 and recognised in the GLA’s Thames Strategy as a landmark building. Its story is incredible; when built in 1905 it was the largest steel framed building in London, the largest Power station in the world, generating more electricity than any other through the largest steam turbines ever built, cooled with water from the Thames and sending steam out through the tallest chimneys in Europe. The vast turbine hall was naturally lit with 12-metre-high arched windows on both main facades and a glazed roof. It was known colloquially as the ‘Cathedral of the Industrial Age.’
Already a powerful urban icon which had defined the area for over 90 years it made sense both from a sustainable and urban standpoint to retain the shell, remove the turbines and introduce residential apartments inside the vast internal space using the large windows in each elevation. The ground floor would be a publicly accessible top lit internal street and would link Lots Road to the Hammersmith side of the creek via 2 pedestrian bridges. An additional bridge from the east yard would complete the linkage.
Remarkably this was not a listed building however Farrells worked with English Heritage (now Historic England) to create a Heritage Management Deed to ensure that elements of the industrial heritage were preserved and maintained in the building.
By joining the two boroughs across the creek, Farrells then created a new coherent Place taking its influence from the surrounding but different urban grain on both sides of the creek. On the Chelsea side the Victorian street pattern known as Chelsea Village remained with the powerful mass of the PowerStation acting as an end stop to the denser development before the creek. By comparison, the Hammersmith side was derelict industrial land with the neighbouring grain created by the Chelsea Harbour and Imperial Wharf developments built in the mid 80’s and early 90’s respectively and the masterplan responded to this with a more modest density.
The resultant masterplan reflects both the historic and contemporary urban grains with the creek forming the natural ’fault line’ between the two. The creek mouth, one of the most interesting locations in the area with views down the Thames as far as Vauxhall offered an opportunity for two urban markers, one each side of the creek. Here Farrells designed two rhomboid towers acting as the Metropolitan markers to the site from the river. These are the two tallest buildings in the masterplan - 130m on the Hammersmith and Fulham side and 92m on the Kensington and Chelsea which complement the bulk and mass of the PowerStation.
Farrells first principle of opening the site to pedestrian permeability required a solution to crossing Chelsea creek – the fault line between the two boroughs. The result was three bridges, one for emergency vehicles, cyclists and pedestrians
which was used by the contractor during construction and two pedestrian bridges linked to routes through the Power Station from Lots Road. The pedestrian bridges designed by Farrells and Buro Happold were constructed in Amsterdam and brought from Holland to the site by canal boat.
A pedestrian friendly scheme required a solution to car access and parking which resulted in a single car access point to the western end of the Hammersmith and Fulham side of the masterplan leading to an underground car park and a basement car park part extending under the Power Station accessed from Lots Road.
On the Hammersmith and Fulham land the new private and affordable apartments occupy low rise mansion block buildings (between 4 and 9 floors) clad in Caliza Capri limestone and terracotta panels respectively which define the open space, work as ‘good neighbours’ to the adjacent Chelsea Harbour development and act as a visual foil to the height of the towers and the mass of the Power station.
The Power Station, now renamed as The Powerhouse has been repurposed for mixed use residential with a central atrium along the 130m length of the building and two beams of18 m residential apartments on either side taking benefit from the huge arched full height windows on each principal elevation.
As Rieck says “It’s exciting to see this extraordinary project coming to life. There is no residential experience like it in London, and the team needed to take an incredibly creative, thoughtful design approach to ensure that Powerhouse would do justice to the majestic architecture of the old power station. We carefully restored its historic red brick and terracotta walls, and our priority was to honour the building’s rich industrial heritage while also delivering a new contemporary landmark for many generations
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IMAGES: Andy Stagg
to come.”
The new buildings on the Chelsea side respond to the scale of the Powerhouse and complete the Lots Road Street frontage. The two buildings that sit either side of the Powerhouse on the Lots Road frontage are both affordable tenure and were originally designed to be clad in terracotta panels. When Lots Village became a conservation area in 2014 Farrells revised the cladding via a Section 73 to brick. The resultant building in the West Yard at 8 floors has a solidity and robustness that better complements the rugged majesty of the cleaned and repaired Powerhouse while the building in the east yard complements both in scale and finish the Grade 2 listed Thames Water pumphouse adjacent. The three buildings together form a coherent response to the Lots Road frontage.
Within the East Yard, on land that occupied a gasholder Farrell
designed a rotunda building. This 9-storey building creates an enclosure to the East Yard and will provide ground floor retail use.
Farrell’s masterplan on the 4.6 Ha site delivers 10 buildings including the Powerhouse. There are 710 new homes of which 39% (277) are affordable, 61 of these designed within the converted Power Station. Keen from the start that the whole masterplan would be tenure blind, the design of the affordable buildings have been given the same level of crafting and concern over placement so they make an equal contribution to the character and feel of the development integrating seamlessly into the overall design and giving both private and affordable residents access and use of the same outdoor spaces.
Adopting their contextual approach to master planning this development creates over 50% of the total site area to public open space and delivers 600 meters of newly accessible Thames >>>
River frontage.
Fitting into the existing context meant careful design for the hard and soft landscape. The East and West Yards and the ground level of the Powerhouse are predominantly hard landscaping with raised water features, benches and planting whereas the Hammersmith and Fulham side is gentler with softer landscaped areas of lawns, meandering pathways and swales designed by Randle Siddeley.
A new nursery school is about to open in the East Yard and with the Chelsea academy occupying space in the West Yard building, the opening of a new a restaurant, supermarket, café and flower shop in and around the Powerhouse, Chelsea Waterfront will become the cohesive mixed use ‘place’ envisaged in Farrells original vision. n
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