PiL READER OFFER: Seminar + book deal
PLANNING & THE ENVIRONMENT ACT
2022 SEMINAR + BOOK DEAL
Attend remotely or in-person
The Environment Act came into force late last year and many provisions are now beginning to be implemented with more coming into force on 30 September. All planners and developers need to know what these changes mean for their own projects and how planning authorities are approaching issues around climate change and biodiversity. Join Tom Graham, author of The Environment Act: A Guide for Planners and Developers, and a panel of expert speakers at our forthcoming seminar – available in-person or remote to bring you up to date with the latest changes on these increasingly important issues.
All delegates will receive a free hardcopy and digital edition of The Environment Act: A Guide for Planners and Developers (worth £60) and a recording of the seminar.
Event details:
When? Thursday 3 November, 10.0013.00
Where? One Great George Street, London, SW1P 3AA How much? £150 + VAT - including print & digital editions of The Environment Act: A Guide for Planners and Developers
Can’t make the seminar? You can still buy the book online from £40.
from
Page
5 LEADERS
Planning and politics are like oil and water; Going for growth
7 PAUL FINCH
Volume can count more than space
8 PICTURE FEATURE
The new Putney Bridge pier
14 OPINIONS
What does the growth plan mean for development? | Simon Ricketts ;
16 Suburban Task Force takes stock | Peter Eversden; 17 The West End office market on the up | Freddie Corlett; 18 Is this Localism #2? | Lucy Anderson;
19 The only constant in planning is change | Sam Stafford; 21 How visitor data and insights help councils with planning | Clive Hall;
22 LETTERS
The real worry is National Development Management Policies | Michael Bach,; Compulsory rental auctions are yet another half baked idea | Jonathan De Mello
BRIEFING
23 Whole-life carbon assessment controversy strikes the Barbican
24 CLIPBOARD
Green Belt expands; The Green Belt has been a disaster; Investment Zones: some handy existing legislation? Aylesbury Estate: new plans lodged as council approves compulsory purchase powers
27 ¡PILLO!
Growth, Growth, Growth; Royal Yacht; St Mungo’s homes set for go-ahead; Destination city City
28 PLANNING PERFORMANCE
Numbers of applications and decisions continue to drop
32 LONDON PLANNING & DEVELOPMENT FORUM Population projections, revised NPPF, impact of inflation and embodied carbon
ANDREW ROGERS
Why planning is sexy
City
City
by Nicholas Phelps
Lives of Urban
Britain
ISSN 1366-9672 (PRINT)
ISSN 2053-4124 (DIGITAL)
Issue 123 October-December 2022 www.planninginlondon.com
The London Planning and Development Forum (LP&DF)
The LP&DF was formed in 1980 follow ing an all-party inquiry into the development control system.
It selects topics to debate at its quarterly meetings and these views are reported to constituent bodies and published in Planning in London.
It is a sounding board for the develop ment of planning policy in the capital, used by both the public and private sectors.
Agendas and minutes are at www.planninginlondon.com
To attend please email the Hon. Secretary
by Nigel Moor;
London
Ed Wall;
Publishing Editors: Brian Waters, Paul Finch and Lee Mallett editor@planninginlondon.com, planninginlondon@mac.com
Editorial, subscriptions and advertising: Tel: 07957871477
Email: planninginlondon@mac.com Contents ©Land Research Unit Ltd or as stated
The LPDF is administered by: Honorary Secretaries: James Mitchell RIBA jm@axiomarchitects.co.uk & Riette Oosthuizen riette.oosthuizen@hta.co.uk
Chairman: Brian Waters MA DipArch (Cantab) DipTP RIBA MRTPI ACArch ppACA FRSA Principal: The Boisot Waters Cohen Partnership brianwaters1@mac.com
Vice-Chairman: Jonathan Manns: JLL jon.manns@gmail.com
Member bodies Association of Consultant Architects Planning Officers’ Society/Association of London Borough Planning Officers
Available only on subscription: £99 pa
Provides a licence for five copies by email See subscription form or buy online at www.planninginlondon.com.
Planning in London is published quarterly in association with The London Planning & Development Forum by Land Research Unit Ltd Studio Petersham, Gorshott, 181 Petersham Road TW10 7AW
London Councils British Property Federation Design Council CABE
of London Law Society
for British Industry
Design for London/ Urban Design London Historic England Environment Agency
London Authority
Builders Federation
Architecture SE
Chambers of Commerce & Industry
Forum of Amenity Societies
Housing Federation National Planning Forum
RIBA, RICS, RTPI, UDAL, TCPA
Contributors write in a personal capacity. Their views are not necessarily those of The London Development & Planning Forum or of their organisations. Correspondence and contributions are invited for consideration. The editors reserve the right to edit material and letters supplied.
Made on a Mac
Transport for London London University (The Bartlett, UCL) University of Westminster Affiliated members:
Attacking the planning system
Planning and politics are like oil and water
The new government has old ideas about how to stimulate growth: attack the planning system. As usual, politicians spout nonsense about how they will simultaneously increase consultation, empower communities, and speed up decisions. Alternatively, they will make life easier by creating special zones where normal planning procures will not apply – subject to local political support. Or by encouraging generation of new energy sources, such as shale, but again on the basis of local support. Are these politicians taking any professional advice, one wonders?
At a local level things are no better. Take, for example, the behaviour of councillors in Southwark in respect of an office proposal for the Elephant and Castle area. The planners supported the application, describing the architecture as ‘exemplary’. Councillors on the other hand thought otherwise. The application by Lendlease was rejected, and since rejection requires reasons, out were trotted those old favourites, height, bulk and mass. Not exemplary then. You feel sympathy for the planning officer who might end up at a public inquiry being crossexamined about whether their judgement was utterly incompetent, or whether their political masters were simply inventing reasons for refusal which had no basis in fact.
There is a way whereby government could speed up planning. This would be to provide rapid inspection of applications supported by planners but rejected by councillors. Such cases could be referred to the office of the government chief planner, whose default position would be that the advice of professionals would be supported unless there were compelling planning (not political) reasons for overturning that advice. The local authority would have to pay for this service.
It would be tempting to re-introduce personal liability for councillors wilfully ignoring professional recommendations.
Whatever happened to moral hazard? n
Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992
Going for growth
Liz Truss’s demonisation of north Londoners as key members of an ‘anti-growth’ coalition reminds us of David Cameron’s 2011 broadside labelling planners ‘enemies of enterprise’.
Whilst sending broadsides against KamiKwase Trussonomics, The Economist and The Financial Times also chose recently to target the planning system as an enemy of growth. ‘Britain’s failure to build is throttling its economy,’ The Economist blasted in September, just before Liz and Kwasi put on their own firework show. ‘The country,’ it said, ‘has become a vetocracy…the whole thing is a disaster.’
The FT’s Martin Wolf, a fairly frequent commentator on land use matters, while labelling the
Tories’ dynamic duo ‘mad, bad and dangerous’, instead of their ‘magic potion’ of unfunded tax cuts to encourage growth, called for further deregulation of land use. He didn’t think their proposed local investment zones would deliver desired growth, and nor would a ‘big jump in inequality’ implied by the now-torpedoed cut in the top rate of tax.
But there’s the point. Growth, good growth, encouraged by planning, is our best tool for tackling inequality. Where there isn’t growth, inequality is worse. And if there are people in London who think growth per se is bad, then they probably aren’t living where it is absent or necessary. If you live in an east London borough where the population has risen by 20 per cent again, you may be quite keen on more homes getting built.
And the irony is, the people who hate growth most are the Nimbys with which the Conservative Party is stuffed. Lots of them live around Amersham, where Boris Johnson’s plan ning white paper was blasted out of the water.
It seems unlikely however, even if Truss were to survive for two more years until an elec tion, that the Tories’ planning schizophrenia around its role as promoter or preventer of growth is likely to be resolved in planning reform. Too high above the parapet.
There is a more cunning plan for embedding growth, however. Suggested by former chief planner Steve Quartermain at the September meeting of the London Planning and Development Forum. And that is to swiftly implement the long overdue update of the National Planning Policy Framework, which requires no primary legislation.
Approval of Local Plans could be simplified and speeded up. Support for much needed growth could be strengthened, national development management policies could be stan dardised and downloaded and not reinvented for every topic by every authority, making plans easier and cheaper to create. Pulling all measurable conditions out of planning and into Building Regulations would greatly unburden and speed the process as well.
You would also expect, said Quartermain, that the NPPF might more strongly support legis lation around what needs to be done to deliver the climate change agenda through planning and could be clearer about retro-fit versus redevelopment.
Saving the planet should be a material planning consideration, but so is growth – as voters in the Red Wall, and the poorer parts of London, know only too well from years of waiting. n
Volume can count more than space
Design dilemmas and challenges facing clients and architects increase by the day. Even quite modest proposals require, as part of planning applications, analysis of carbon and fire implications which planners are not trained to pass judgment on. Hence the rise and rise of niche specialists within the planning process, commenting on matters which should properly be part of building regula tions. The idea that we are living in an era of dereg ulation is laughable.
A more important consideration is what it is that architecture can offer clients, investors and society at large to give confidence that we are not being car bon-profligate in the short-term, or that what we are building today will still be fit for purpose within a generation or two.
This raises the under-discussed, question of vol ume (as opposed to square footage). After all, when we enter any building, we move from the world of infinite space/volume, that is to say nature, to a world of enclosure which is defined not by area, but by the volumetric space and sequence of spaces which provide a useful definition of architecture itself. What we experience in any building is volume not area.
The fact that we generally apply rental values to area rather than volume, except in the case of very specific logistics sheds, says something about the way we have divorced real estate values from the experiential. Many of the buildings we admire have had a long life – the Georgian house being one obvi ous example – precisely because they include gener ous volumes within them, or at least volumes which are not simply replicas of every other floor.
Similarly, Victorian board schools have proved capable of adaptation to other uses, from residential to commercial, quite beyond the bounds of what one could think about doing with the supposedly efficient floorplates and floor-to-ceiling heights of commer cial building from the not-too-distant past.
Volumetric generosity, plus a bit of over-engineering, sets the scene for long life, loose fit and low energy.
Architects engaged in current debates about demolition versus retrofit know all about this. Is it necessarily the case that mixed use equals retails on basement and ground, plus offices above on the model familiar to developers from the 1950s onwards? Who says we need the offices more than, say, storage space? Is the future of Oxford Street fixed in time, or might we be on the cusp of a change in outlook where retail equals sampling and ordering – from stock which is stored in gigantic volumes about the showroom?
Indeed, for any architect and client undertaking an analysis of a substantial retrofit project, should the discussion be about area, or should it be about volumes? And shouldn’t it involve a really critical look at the location (or re-location of cores)? What makes
Paul Finch is programme director of the World Festival of Architecture and joint publishing editor of Planning in London
a building difficult to convert for different uses is fre quently this issue.
The most experienced developers can get this wrong because what seems the obvious place to put the lifts etc is not necessarily the one which provides maximum benefit in the short term, but may be dis astrous in respect of cost and difficulty if and when new uses need to be introduced.
This leads us to the role of investors and their sur veyors in respect of formal valuation. These days it is the less scientific but nevertheless significant ques tion of social, economic and environmental responsi bility which needs to be incorporated into valuation ideology. It is no longer acceptable for investment criteria to adopt a who cares attitude after the first rent review.
Investors and planners could promote carbon responsibility by requiring architects to show how their designs could be simply adapted to provide dif ferent possibilities for alternative future uses. A detailed planning application might, for example, be accompanied by indicative designs showing how the building envelope could embrace new possibilities with relative ease. A big part of that story would be how volumes, rather than space, matter. Film produc tion, anyone?n
First published in Property Week, with kind consent.
Full applications might include indicative designs showing how the building envelope could embrace new possibilities, argues Paul Finch
These days it is the less scientific but nevertheless significant question of social, economic and environmental responsibility which needs to be incorporated into valuation ideology. It is no longer acceptable for investment criteria to adopt a who cares attitude after the first rent review.
The new Putney Bridge pier
The new Putney Bridge pier has led to controversy and concern amongst rowers. The architect Anthony Carlile illustrated the scheme for Planning in London
Just upstream of Putney Bridge, the new pier will form the western terminus for London’s river buses. The proposal moves the ferry stop approximately 80m downstream to a new purpose built pontoon.
The existing pier does not serve the ferries well, its linkspan reaches a gradient of 1:4.9 on the low spring tides and it is not accessible for wheelchair users for large parts of each day. At the very highest tides the pavement also floods and the entrance is extremely confusing, feeling much like a pri vate marina.
In contrast the new pier is designed to be a welcoming continuation of the public pavement. It will allow passengers to embark and dis-embark simultaneously which isn’t possi ble at the existing pier, frequently causing knock-on delays along the rest of the central RB6 route.
The proposal also moves the ferries further away from the Putney Crossing and the Upper Tideway to the west where rowing activity is most intense. The face of the new pier is 30m from the navigation channel leaving space for smaller
craft to travel safely outside of the fairway. The new pier also moves the ferries downstream and outside of the competi tive course for the traditional rowing races. As is the case in the current situation, the River Buses will work around special race events ceasing operation.
Accessed from the Thames Tideway build-out, the public transport use is well suited the large new civic space. The planning application is in and Thames Clippers are keen to commence work as soon as possible. Almost all of the pier will be constructed off site which will minimise local disrup tion.
The pedestrian and cycle ferries connect piers through central London to Barking Riverside in the East.
CREDITS
Client: Uber Boat by Thames Clippers Lead Consultant and
Marine Engineer: Beckett Rankine
Architect: Anthony Carlile Architects
Planning Consultant: Rolfe Judd Planning
Heritage Consultant: Alan Baxter
Environmental Consultants: Thomson Environmental Consultants
Assets as smart as you are.
The world is changing rapidly, and you’re expected to be smarter, faster, more connected, more predictive, and accountable for your assets and operations. Our new brand – Brightly – represents who we are and what we stand for. We are the global leader in intelligent asset management solutions, and our purpose is to power smarter assets and sustainable communities.
What does the growth plan mean for development?
Ricketts
All I would say at this point is that:
• I’m not sure whether it’s right to assume that this means the end of the road for the Levellingup and Regeneration Bill in its entirety? Along the way there is reference to a proposed Planning and Infrastructure Bill but there is no detail yet as to its contents and whether of the LURB will be retained or recycled.
• There are some eye catching proposals here and the direction of travel is clear, although in most instances of course what we need is a further layer of detail.
From the executive summary
“The Growth Plan 2022 makes growth the gov ernment’s central economic mission, setting a target of reaching a 2.5% trend rate.”
“To drive higher growth, the government will help expand the supply side of the economy. The Growth Plan sets out action to unlock private investment across the whole of the UK, cut red tape to make it quicker to deliver the UK’s critical infrastructure, make work pay, and support people to get onto the property ladder. New Investment Zones will provide time-limited tax reliefs, and planning liberalisation to support employment, investment, and home ownership.”
Chapter 2, “tackling energy prices”
“To increase energy resilience, the North Sea Transition Authority will shortly launch a new oil and gas licensing round. This is expected to deliv er over 100 new licenses. The government has also announced an end to the pause on extract ing reserves of shale. The government is driving the development of home-grown nuclear –including Small Modular Reactors – hydrogen, Carbon Capture, Utilisation and Storage and renewable technologies. The government will unlock the potential of onshore wind by bringing consenting in line with other infrastructure. The UK is a world-leader in offshore wind, with 8GW of offshore wind currently under construction. By 2023 the government is set to increase renew ables capacity by 15%, supporting the UK’s com mitment to reach net zero emissions by 2050.”
Chapter 3, “growth”
“…the government must cut taxes, streamline the public sector, and liberate the private sector, by making Britain the place for:
• investment: creating the right conditions and removing barriers to the flow of private capital –whether taxes or regulation
• skilled employment: helping the unemployed into work and those in jobs secure better paid work
• infrastructure: accelerating the construction of vital infrastructure projects by liberalising the planning system and streamlining consultation and approval requirements
• home ownership: getting the housing market moving
• enterprise: cutting red tape and freeing business to grow and invest.”
Investment zones
“The government will work with the devolved administrations and local partners to introduce Investment Zones across the UK. Investment Zones aim to drive growth and unlock housing.
Areas with Investment Zones will benefit from tax incentives, planning liberalisation, and wider support for the local economy. The specific inter ventions in Investment Zones will include:
Simon Ricketts is a partner with Town Legal LLP
From Simon’s blog at simonici ty.com/author/simonicity/ Personal views, et cetera
• Lower taxes – businesses in designated sites will benefit from time-limited tax incentives.
• Accelerated development – there will be desig nated development sites to deliver growth and housing. Where planning applications are already in flight, they will be streamlined and we will work with sites to understand what specific mea sures are needed to unlock growth, including dis applying legacy EU red tape where appropriate.
Development sites may be co-located with, or separate to, tax sites, depending on what makes most sense for the local economy.
• Wider support for local growth – for example, through greater control over local growth funding for areas with appropriate governance. Subject to demonstrating readiness, Mayoral Combined Authorities hosting Investment Zones will receive a single local growth settlement in the next Spending Review period.
Specified sites in England will benefit from a range of time-limited tax incentives over 10 years. The tax incentives under consideration are:
• Business rates – 100% relief from business rates on newly occupied business premises, and certain existing businesses where they expand in English Investment Zone tax sites. Councils hosting Investment Zones will receive 100% of the busi ness rates growth in designated sites above an agreed baseline for 25 years.
• Enhanced Capital Allowance – 100% first year allowance for companies’ qualifying expenditure on plant and machinery assets for use in tax sites.
• Enhanced Structures and Buildings Allowance –accelerated relief to allow businesses to reduce their taxable profits by 20% of the cost of quali fying non-residential investment per year, reliev ing 100% of their cost of investment over five years.
• Employer National Insurance contributions relief
– zero-rate Employer NICs on salaries of any new employee working in the tax site for at least 60% of their time, on earnings up to £50,270 per year, with Employer NICs being charged at the usual rate above this level.
• Stamp Duty Land Tax – a full SDLT relief for land and buildings bought for use or development for commercial purposes, and for purchases of land or buildings for new residential development.
The Department for Levelling Up, Housing and Communities will shortly set out more detail on the planning offer. This will include detail on the level of deregulation and the streamlined mechanism for securing planning permission.
The government will deliver Investment Zones in partnership with Upper Tier Local Authorities and Mayoral Combined Authorities in England, who will work in partnership with their relevant districts and/ or constituent councils. All Investment Zone agree ments will contain tax and development sites. Areas will be responsible for putting forward sites and demonstrating their potential impact on economic growth, including by bringing more land forward and accelerating development.
Investment Zones will only be chosen following a rapid Expression of Interest process open to every one, and after local consent is confirmed. However, examples of illustrative sites that may have the potential to accelerate growth and deliver housing in the way the Investment Zone programme envis ages can be found in Annex A.
The government is in early discussions with 38 Mayoral Combined Authorities and Upper Tier Local Authorities who have already expressed an initial interest in having a clearly designated, specific site within their locality. A full list of these 38 authorities is available in Annex A.
The government will deliver Investment Zones in Scotland, Wales and Northern Ireland and intends to work in partnership with the devolved administra tions and local partners to achieve this. The govern ment will legislate for powers to create tax and development sites in Investment Zones where pow ers are reserved.
The government remains committed to the progress of the Freeports programme. The govern
ment will work with local partners involved in cur rent and prospective Freeports to consider whether and how the Investment Zones offer can help to support their objectives, as part of the wider process for identifying Investment Zones. This will ensure that both programmes complement one another.”
Annex A lists 24 examples of “illustrative sites that may have the potential to accelerate growth and deliver housing in the way the Investment Zone programme envisages” and 38 authorities with which the government is in early discussions with a view to establishing an investment zone in their area. There is also an investment zones factsheet.
Housing
“To make buying a home a reality, the government must accelerate housing delivery. Planning permis sion was granted for more than 310,000 homes last year, up 10% on the year before,10 but fur ther reform is needed. Later this autumn, the gov ernment will set out its vision to unlock home ownership for a new generation by building more homes in the places people want to live and work and by getting our housing market moving. This will boost growth across the UK helping more people afford to live near good jobs. The govern ment’s full proposal will be set out in due course.
The government will promote the disposal of surplus public sector land by allowing departments greater flexibility to reinvest the proceeds of land sales over multiple years. This will encourage the sale of more public land for housing and allow departments and the NHS to reinvest in public ser vices. Devolved administrations have bespoke flexi bilities to move funding between financial years and the government will discuss the implications of this change with them in due course.”
Planning
“The UK’s planning system is too slow and too fragmented. For example, an offshore wind farm can take four years to get through the planning process and no new substantive onshore wind farm has received planning consent since 2015.”
“The Growth Plan announces that new legisla tion [the Planning and Infrastructure Bill] will be brought forward in the coming months to address
speed up the delivery of much-needed infrastruc ture. This includes:
• reducing the burden of environmental assess ments
• reducing bureaucracy in the consultation process
• reforming habitats and species regulations
• increasing flexibility to make changes to a DCO once it has been submitted.”
Infrastructure
“The Growth Plan also announces further sector specific changes to accelerate delivery of infras tructure, including:
• prioritising the delivery of National Policy Statements for energy, water resources and national networks, and of a cross-government action plan for reform of the Nationally Significant Infrastructure planning system
• bringing onshore wind planning policy in line with other infrastructure to allow it to be deployed more easily in England
• reforms to accelerate roads delivery, including by consenting more through the Highways Act 1980 and by considering options for changing the Judicial Review system to avoid claims which cause unnecessary delays to delivery
• amendments to the Product Security and Telecommunications Infrastructure Bill to give telecoms operators easier access to telegraph poles on private land, supporting the delivery of gigabit capable broadband.”
“The Growth Plan also sets out the infrastructure projects that the government will prioritise for acceleration, across transport, energy and digital infrastructure. This non-exhaustive list is set out in Annex B and reflects projects which have particular ly high potential to move to construction at an accelerated pace. The government will also continue to focus on delivering its wider infrastructure priori ties, from major projects such as HS2, to its wider nuclear strategy.”
The agenda is set...
Simon Ricketts, 23 September 2022
Suburban Task Force takes stock
Peter Eversden
Suburban Task Force
Rupa Huq MP, Bob Neil MP, Lord True and Peter Murray talked about their contribution to its con tent and the importance of finding the right poli cies for the suburbs. Other cross-party politicians were part of the task force and the London Boroughs of Sutton and Waltham Forest gave evi dence to it.
The study took stock of the suburban places where many people live and ways in which they were experienced through the pandemic.
A repeated observation was the way the suburbs of London have had inadequate policy development for their opportunities and challenges.
The Task Force recommends consideration of a spectrum of characteristics that should be applied to the suburbs and five statistically significant subur ban typologies were identified. New working prac tices require a revised approach to the future of employment.
The report states that “There is evidence that the use of permitted development rights undermines the ability of local authorities to fully manage and mitigate the impacts of certain forms of develop ment.”
Increased digitisation and the engagement of communities and other stakeholders in local plan making, pre-application discussions and decisions are recommended. Some clauses in the Levelling-up and Regeneration Bill (LURB) may lead to that
becoming policy.
The task force seeks national policy guidance on the key principles for handling small scale applica tions in suburban locations. However, the focus of this APPG is London and new guidance for suburban densification will be published before the end of 2022 by the GLA to help boroughs apply the policies in the 2021 London Plan for small and windfall sites. The London Forum of Amenity and Civic Societies has opposed the LURB proposals for imposition of National Development Management Policies as there are too many local variations and options for the Government to try to cover them all.
A correspondent told the taskforce “The diverse nature of suburbs makes it difficult to develop tar geted policies.” There will need to be specific policies in each Local Plan developed with local people.
The impact of development in the suburbs such as very tall buildings without social infrastructure is causing tensions and needs to be better managed for design and context considerations. The report suggests that it is “creating ‘growing pains’ which might contribute to ‘tipping points’ in terms of com munity support for change.” There is a recommen dation for further consideration of the potential ‘tip ping points’ which exist in our suburban communi ties and ways that these might be managed.
The National Planning Policy Framework will be revised next year and that would be an opportunity
Peter Eversden MBE is Chairman of the London Forum of Amenity and Civic Societiesto include policies that would address some of the recommendations of the Suburban Task Force. For those policy options, the report recommends further research is carried out to identify suburban chal lenges.
In considering suburban ‘types’, the taskforce concluded that considerations are important for green space, density of overall development and local land uses (including dwelling types, retail, leisure and office space). That led to the identifica tion of five suburban types. The taskforce’s report has a lot of detail on the types of suburban environ ments within those categories including their social infrastructure.
There is a recommendation that “consideration should be given to a new spectrum model for under standing the suburbs and used by those in research, practice and policy.”
The taskforce report has an analysis of the requirements in suburban areas for transport and traffic, employment, housing and green space. It is recommended that “further consideration is given to the opportunities which exist for an evolution in the nature of local employment as a result of changes to working practices during the Covid-19 pandem ic.” In considering how change should be under stood, the taskforce report has a section on local identity.
In its conclusions the taskforce hopes their report will provide a platform from which to begin a meaningful public discussion and will help support the introduction of policies which are popular, informed and evidence-based for the suburbs. The taskforce intends to do more work on matters such as place-making and suburban culture and it recom mends that further research is undertaken to explore possible policy solutions to address the chal lenges identified.
The West End office market on the up
The West End market defies expectations as occupiers continue to clamor for the best office space, says Freddie Corlett
Those who don’t know London’s West End office market may have looked at the ongoing debate about hybrid working and workers’ being slow to relinquish working from home, then the UK’s pes simistic economic outlook, and assumed that H1 2022 would have seen a disappointing number of occupiers signing up to take office space.
In fact, the market has experienced almost the exact opposite. Firstly, occupancy figures show the West End is leading the way in terms of workers returning to the office, with peak periods of the week now regularly recording occupancy of over 40 per cent (in the City, meanwhile, it’s about 35 per cent). Secondly, the volumes of space being taken belie notions that West End occupiers are looking to put their office requirements on hold any time soon.
By the end of H1 take-up had reached 2.17 mil lion sq. ft across 187 transactions - 13 per cent above the 10-year long-term average and 68 per cent higher than at the same point in 2021. June 2022 alone was the third busiest month Savills has ever recorded for the West End with 1 million sq. ft of transactions completing across 40 deals, including Capital International’s pre-let of 220,000 sq. ft across the 8th to 16th floors at the Sellar Group’s Paddington Square development, W2, and the much-anticipated completion of MSD’s acquisition of Belgrove House, WC1, to form its new 195,000 sq. ft UK HQ and Discovery Centre. As a result, the West End core vacancy rate has moved in by 80 basis points, from 6.7 per cent at the end of 2021 to 5.9 per cent at the end of H1 2022.
The Financial Services sector led the charge in taking space, accounting for 32 per cent of West End offices let so far this year. Drilling further down into this group of occupiers, it’s clear that Private Equity, Asset Management and Investment Management firms were the most acquisitive sub-sectors, contin uing a trend evident since 2021 and reinforcing another theme we’ve been noting (not just in the West End but across most office markets): the rush to acquire top quality space with high ‘green’ cre dentials in response to strengthening ESG require ments and rising employee expectations continues.
89 per cent of West End take-up to the end of H1 2022 was of Grade A quality offices, although in June, Grade A transactions accounted for an enor mous 98 per cent of space taken in terms of square footage. As a result, the supply of prime and Grade A office space in the West End is dwindling – particu larly in the core sub-markets of Mayfair, St James's, Covent Garden, Soho and North of Oxford Street West and East.
Even with several new buildings coming to the market over 2022, the supply of Grade A offices is currently 13 per cent down on the end of 2021, as much of this new space was already pre-let and the rest has been eagerly snapped up. With material and labour cost inflation pushing back the timelines on many future office development and refurbishment projects, competition for the best space is only set to intensify.
At the same time, the amount of ‘grey’ or ‘ten ant-controlled’ space in the West End market (office space that tenants are look ing to sub-let), after surging at the height of the pandem ic when firms were uncertain about their future require ments, has declined. Some has been let and a similar proportion withdrawn after occupiers decided they did require the space after all. West End grey space levels are now 1.3 million sq. ft compared to 3 million sq. ft at their peak in April 2021. This all means that West
Freddie Corlett is a Director in Savills West End office agency teamEnd rents at the top end of the market are only heading in one direction over the short and medium term: up. By the end of H1, the average West End prime rent stood at £119.38 per sq. ft, a 6.6 per cent rise from the end of 2020, and the average Grade A rent was £84.37 per sq. ft, an increase of 2.5 per cent from the end of 2021. While the speed of increases may slow as the wider macro-economic climate plays on occupiers’ minds, the demand/supply imbalance is unlikely to lead to any sudden adjust ment in rents for spaces that deliver on the ‘prime and green’ strategy favoured by most occupiers.
As a consequence of occupiers being willing to pay higher rents for best-in-class space, there has been lessening demand for Grade B offices (spaces which have not been recently refurbished and don’t quite meet occupiers’ current high expectations). This caused Grade B rents to fall 6.7 per cent between the end of 2021 and June 2022 to £51.31 per sq. ft. There is the potential for many of these offices to be refurbished and new amenity spaces added to attract occupiers and thereby justify higher rents. This will come at a cost given the aforemen tioned inflationary pressures on materials and labour, but with thoughtful planning and design there is the potential to make many of the spaces currently considered Grade B attractive to business es. There are other ways of rising above the Grade A/B classification too: the new Class E planning use provides landlords with the opportunity to add dif ferent uses into a building, thereby creating more of the community which occupiers crave for their cul ture and staff retention.
The future of London’s West End market is not without challenges, but given the current dynamics, and the figures we’re recording so far in 2022, it is in a strong position to withstand any bumps in the road ahead and remain one of the UK’s most popu lar office locations. n
Is this Localism #2?
Localism is now over ten years old. At the time of the Localism Act in 2011, Localism was fêted as the necessary impetus for a new era of commu nity empowerment, with the potential to strengthen local economies, rebalance economic growth and create locally-led solutions through partnership and collaboration. Localism estab lished a set of Community Rights which gave communities a framework in which to protect and own valued local assets, influence local plan ning and development, and run local services.
But Localism did not take off as was hoped: in 2017 the Commission on the Future of Localism found that that 80 per cent of people felt they had little or no control over decisions that affect their country and 71 per cent felt they have little or no control over local decisions. Furthermore, 68 per cent said that community spirit, rather than being empowered by Localism, had declined and asked about the specific vehicles of Localism, 79 per cent said that they were unaware of the Community Rights that the Act had introduced.
If the sentiment of Localism remains today it is undoubtedly in the form of neighbourhood plan ning. In June this year, a report by Neighbourhood Planners.London (State of Neighbourhood Planning in London – 2022), confirmed that London has 67 neighbourhood forums and 26 completed neigh bourhood plans. While this is a considerable achievement considering the restrains of the pan demic, it is a poor comparison to the 1,200 com pleted across England.
The report identified the specific ‘neighbour hood planning deserts’ which currently have no designated neighbourhood forum: Barking and Dagenham, Bexley, Bromley, City of London, Croydon, Harrow, Havering , Merton and Newham.
The way in which local residents have engaged in neighbourhood planning across the country gen erally has demonstrated an appetite for grass-roots involvement in planning, which, it has been argued, has led to the range of new initiatives, including design codes and Street Votes which are present in the current Levelling Up and Regeneration Bill. The principle of strengthening neighbourhood planning is also a fundamental aspect to the Bill.
However if neighbourhood planning is to be successful in London and elsewhere, it needs to change. It needs to become more broadly represen tative and cannot remain the NIMBY charter that
some have described it as: due to the presumption in favour of sustainable development, a neighbour hood plan will fail if constructed solely to defeat development.
The Levelling Up and Regeneration Bill includes proposals to create a Neighbourhood Priority Statement, a planning tool which will set out a community’s preferences on development in their local area. Councils will be required to consider such statements when preparing their Local Plan. Neighbourhood Priority Statements could provide a better means of engaging with communities, and could help to address the significant issues of accessibility, complexity and time taken to create a neighbourhood plan. They could also address the common problem of timing: in circumstances in which Local Plans and neighbourhood plans are completed years apart, they will invariably respond to a different set of circumstances and as such they will lack consistency. But the Neighbourhood Priority Statement could be updated at various points in the process of the Local Plan’s prepara tion, giving specific neighbourhoods a more mean ingful input.
I have worked on development schemes which have had significant influence from neighbourhood forums in the shape of neighbourhood plans. These have had both a positive and negative impact. It is important that neighbourhood plans benefit from local dialogue, which can create a scheme better suited to its specific location, but I have broader concerns about how the proposed strengthening of neighbourhood planning sits within the levelling up agenda. Currently the areas most likely to have a neighbourhood plan are established – predomi nately rural or suburban communities with a pro fessional and prosperous demographic, much less so the deprived inner-city communities with more transient populations. This accounts for the relative dearth of neighbourhood plans in London, and is unlikely to change without a significant investment in community development over many years. The detrimental impact of giving strengthened powers to the communities better able to put effective neighbourhood plans, therefore, has the potential to exacerbate the wealth divide - resulting in the opposite to levelling up. Indeed, the complexities and time commitments of undertaking the neigh bourhood planning process already acts as a barrier to a wide range of key demographics within com
Lucy Anderson is a principal planner at Boyermunities from getting involved with neighbour hood planning.
Debate surrounding the Levelling Up and Regeneration Bill should also focus on whether the powers of neighbourhood planning need to be strengthened. Undoubtedly neighbourhood forums would be more empowered to create a neighbour hood plan if they were reassured that it would carry more weight than currently – unfortunately there are many examples of neighbourhood plans being put in place and supported but having little influence on outcomes.
And strengthening is relative: the Levelling Up and Regeneration Bill promises to strengthen neighbourhood planning in addition to Local Plans and spatial development strategies proposed by mayors or combined authorities, while also strengthening planning at a national level by mov ing specific policies from Local Plans to a suite of policies to be defined at Government level. Can every element of planning be strengthened or does strengthening one function come at the cost of reducing the power of another? Furthermore, while technically, neighbourhood planning and Local Plans both carry weight in the planning process, how this works in reality depends on timing: if the neighbourhood planning is out of step with the Plan, its influence is weakened which further aggra vates fractured relationships between local com munities, local authorities, and developers trying to bring development forward.
As examples throughout the country have shown, neighbourhood planning can be an effective tool to involve local voices in the planning process and works well in areas of London with a specific demographic and an established sense of commu nity. But, as is clear from other areas, the real opportunity to strengthen neighbourhood plan ning through levelling up legislation is not simply to strengthen existing policy but to understand where the gaps lie, and to find the means of addressing these serious issues. n
The strengthening of neighbourhood planning through the levelling up and regeneration bill: Is this Localism #2? asks Lucy Anderson
The only constant in planning is change
On the one hand, as largely enabling legislation, it contains a number of hooks on which can be hung at a later date the kind of radical reform mooted by 2020’s ‘Planning for the Future’ White Paper. On the other hand, at present (and at the time of writ ing since being introduced to Parliament on 11 May 2022 the Bill has reached Committee state in the Commons), and perhaps deliberately to smooth it’s parliamentary passage, the detail that has emerged and the narrative around it amount merely to sensible ‘tidying up’ measures.
The LURB, according to the Government, “acts on several fronts to create a robust framework for level ling-up”. Despite the omission from the title, one of those fronts is the improvement the planning pro cess so that, again according to the Government, “it gives local communities control over what is built, where it is built, and what it looks like, and so creates an incentive to welcome development provided it meets the standards which are set”.
The LURB recognises that local plans should be at the heart of the system and its proponents point to two initiatives that it is hoped will incentivise local authorities to get plans in place: the removal of the need to demonstrate a deliverable five year supply of housing (5YHLS) where a plan has been recently adopted, and
Proponents of the Bill also anticipate that it will boost planning officer capacity by rationalising Section 106 (S106) Agreements and the Community Infrastructure Levy into a single Infrastructure Levy (IL); transitioning from the current Environmental Impact Assessment (EIA) regime to a new outcomebased process; and continuing the move to a more standardised, more user-friendly, digitised system.
Within that context, it is possible to identify areas covered by the Bill that the housebuilding industry is likely to be more and less supportive of.
The current crisis in local plan-making highlights the need for urgent action. The idea that a Local Plan Commissioner can oversee gateway progress checks and take over the preparation of a plan seems sensi
Samuel Stafford is Planning Director at the Home Builders Federationble, as does the proposal than an authority cannot withdraw a submitted plan without the agreement of the Planning Inspectorate (PINS).
Whilst Strategic Development Strategies (SDS) are a welcome, tentative step back towards greaterthan-local planning, there is some scepticism as to whether they would address the fundamental rea sons why plans are being delayed and withdrawn. SDSs would only be undertaken voluntarily, but not in areas where there is already a combined authority or a mayoral combined authority and only if a higher tier, county-level authority is involved. SDSs would not allocate sites, would only be reviewed ‘from time to time’, as opposed to the five-year obligation on local plans, and, unlike joint local plans, cannot be willed into existence by a Secretary of State. It is legitimate to ask whether these arrangements will make it more or less likely that the twenty or so authorities that have publicly raised plan-making issues in the last few months will adopt a local plan in anything shorter than the long term.
The industry is likely to welcome the retention of narrower Section 106 Agreements for site-specific infrastructure within a new IL regime. Less negotia tion around S106 Agreements generally should make for quicker site start though it should be noted that the IL could have a negative impact on the amount of land coming forward for development if it is set unrealistically high.
Similarly the industry is likely to welcome a move to towards measuring environmental outcomes, which, whilst undoubtedly causing short-term delays as the EIA regime is replaced, is likely to be a helpful streamlining measure into the longer-term.
A proposed increase in planning fees (35% for ‘major’ applications), to be tied to a “better service for applicants”, will help to build capacity, but this increase on its own will not be enough to compre
The Levelling Up & Regeneration Bill (LURB) is something of a curate’s egg, says Sam Stafford
The word planning noticeably does not appear on the front of the bill, but it does appear 680 times inside.
hensively address the issue of resourcing. A recent report by the Royal Town Planning Institute (RTPI) calculated that net expenditure on planning services by local authorities fell by 43%, from £844 million in 2009/10 to £480 million in 2020/21.
Amending planning approvals can be very compli cated so new ‘fast track’ provisions to determine broadly similar applications “where the local planning authority is satisfied that it’s effect will not be sub stantially different from that of the existing permis sion" are to be welcomed.
Despite not being especially controversial when first mooted by the White Paper, the inclusion of National Development Management Policies in the Bill has precipitated concerns about a ‘power grab’ by Government. It does, however, seem entirely sensible that local plans not replicate or unnecessarily deviate from national policies on matters like, for example Green Belt, and that consistent standards be applied across the country on matters like, for example, sus tainability or space standards.
It could be helpful for inspectors at PINS to be able to change an appeal’s determination procedure. This could lead to quicker decisions, especially if resources at PINS continue to be stretched.
The industry is likely to be comfortable with Commencement Notices, provided that the trigger point is the discharge of all pre-commencement con
ditions, on the basis that every builder is only ever keen to get on site as soon as is possible.
Of the areas that that the industry is less likely to be supportive of, the abolishment of the 5YHLS test, which is unlikely to be any kind of incentive to a recalcitrant plan-making authority, will have a detri mental affect on housing supply in those places. Similarly, it should not be made more difficult for sustainable applications in places without a plan to be approved.
The Duty to Cooperate, whilst a difficult legal test for some authorities to pass, does at least force diffi cult conversations about meeting housing need across a market area. The repealing of and its replace ment with a nebulous new ‘Policy Alignment Test’ is likely to make it less likely that housing needs will be met in full.
The requirement for every local authority to progress a local design code is not necessarily some thing that the industry would be resistant to in prin ciple, but the conclusions of the National Model Design Code pilot programme review were striking in this regard. This concluded that “a steep learning curve is required to produce design codes and to use the new methodology in the NMDC, and with a few exceptions local authorities were not set up to deliv er design coding in-house.”
The industry is likely to be wary of Completion
meeting of the
Notices, which authority’s will have the power to serve ceasing a permission if a development remains uncompleted after a certain time period. This could make it harder for smaller builders to restart on sites that another builder may have had to close down.
Finally, whilst industry welcomes recognition of the role for neighbourhood plans and the desire for them to afforded the same status and scrutiny as local plans, there could be some wariness towards ‘Neighbourhood Priority Statements’ if they can express views on matters such as design and housing locations that would be inconsistent with an emerg ing local plan.
Ultimately though, in respect of the LURB’s plan ning provisions, as has been identified by Levelling Up, Housing & Communities Committee, the main concerns are a lack of detail. As the Committee Chair Clive Betts wrote to Secretary of State Greg Clark:
If one central thrust of the Bill is not to centralise planning decisions, then the remaining planning pro visions in the Bill can be described as loosely con nected proposals to tinker with the current system, hopefully achieving some improvement. We have not received strong opposition to any of the proposals, but in part this is a factor of the detail not being pub lished, so witnesses are having to hypothesise what will be enacted rather than respond to a firm propos al. Added to this, of course, is the LURB’s likely onward progress. The White Paper was published by Robert Jenrick, the Bill was introduced by Michael Gove, has been overseen briefly by Greg Clark, and is to be picked up by Simon Clarke who will undoubt edly have new ideas on it’s timing, scope and con tent.
As always, the only constant in planning is change. n
How visitor data and insights help councils with planning
Footfall and location data help planners understand how their visitors are behaving, where they are being attracted from and what services they are using, explains Clive Hall
Clive Hall is Founder and CEO of Place Informatics
It is certainly a challenging time for anyone involved in the planning process for towns, cities and high streets across the UK. The huge shift in consumer behaviour due to the increase in online solutions and the ongoing impact of the pandemic has changed how our centres are being utilised. For many councils, they have had to quickly adapt to the loss of key visitor attractions such as large department stores or other popular retail outlets disappearing from our high streets.
At Place Informatics we provide footfall and loca tion visitor behaviour data monitoring to organisa tions such as town and city councils, retail and shop ping sites, large chains, leisure parks, tourism destina tions, heritage and environmental custodians.
Our market-leading insights are used by over 250 towns and cities across the UK helping council plan ners understand how their visitors are behaving, where they are being attracted from and most importantly what services they are utilising on their visit including retail, leisure, green spaces and car parks. Our platform offers our customers a featurerich dashboard giving them access to the huge vol ume of data in a useable format with visual graphs and charts for their location that can be distributed to key stakeholders easily.
We work with a number of councils in the Greater London area and our data gives them detailed information to show how their visitors are currently behaving and also which postcodes they
are visiting from, giving them the information they need to ensure their proposed initiatives have the very best chance of being successful. Our solutions offer insights such as the best time of day to run events, the expected increase in footfall and socioeconomic data can even provide guidance and reas surance to investors or funding bodies that the right demographic is in their catchment area.
By using GDPR compliant anonymous mobile GPS location data we are able to provide actionable insights which help support and enable decision making – to assist in health and safety, conservation, events, marketing and return on investment for eco nomic regeneration projects.
One of the London based councils we have worked closely with has used the detailed visitor insights to adapt their largest shopping centre, fol lowing the closure of a large department store and a key green space (urban park) which historically had been a popular destination for visitors. The combined loss reduced the volume of visitors to their main shopping centre and was therefore impacting busi nesses and services and the local community as a whole.
By using our platform, the council planners were able to understand what services were now attract ing visitors and adapt accordingly. It was evident that Doctors surgeries and other community-based ser vices were bringing a large number of visitors to the area, but none of these were available in the town
centre. Armed with this knowledge the team at the council decided to adapt the top floor of the shop ping centre into a community focused space specifi cally for doctors surgeries and other historically pop ular services.
These changes have already hugely increased footfall to the town centre, reduced the impact of the loss of the former visitor attractions and benefit ted many local businesses and services.
Our data dashboards are accessed by various teams across councils’ services, heritage and tourist organisations – ranging from planning, strategic mar keting, public event management, conservation, funding applications, parking to facilities manage ment solutions. A broad range of stakeholders across retail sites such as tenants and landlords, commercial property agents, facilities management and shopping centre owners – can all benefit from access to the data sets.
Across the spectrum, the data can also assist with decision-making for commercial agreements such as between landlords and tenants, advertising rate set ting or commercial pitch trading pricing, shareholder fund investments and proposals for planning and development.
Customers benefit from the simplicity of our market-leading dashboard, our ability to provide ret rospective data going back to pre-pandemic 2019 and the automatically generated charts and graphs that make it easy to spot trends.
Visitor Insights help planners make good, informed decisions based on historic evidence and quickly show how changes have a positive impact on town centres and communities. n
Clive Hall is co-founder and CEO of Place Informatics, a provider of visitor insights and footfall data for over 250 town centres, retail sites, shopping centres, leisure parks, tourism destinations, Heritage Action Zones (HAZ) and custodians of open spaces..
LETTERS LETTERS
The real worry is National Development Management Policies
Sir,
If top-down national housing targets get ditched, London Plan housing figures will remain as London’s targets – although that was expected anyway, if still post 2024.
The real worry is the National Development Management Policies and, specifically their status. The present regime, where a plan is only required to conform generally to a higher level plan, could be adopted, but the threat of nationally determined policies with only a nod to locally-specific circum stances is a recipe for conflict. And why do we need national development management policies when we already have the London Plan?
The NPPF totally lacks any spatial planning poli cies – it is all very well trotting out a mantra – “the right development in the right place” – but totally fails to indicate what a more sustainable pattern of urban development would look like.
Michael Bach, London Forum of Amenity and Civic Societies
Compulsory rental auctions are yet another half baked idea
Sir,
The idea of ‘compulsory rental auctions’ – part of the draft Levelling Up and Regeneration Bill 2022 –has caused significantly controversy since it was ini tially presented a few months ago, and with good reason. Whilst rejuvenating our high streets is abso lutely a laudable pursuit, it seems that the govern ment – via this bill – are placing blame squarely at the feet of property owners for the decline of the high street, as opposed to the inexorable rise of ecommerce – a rise substantially catalysed by COVID.
The reality is that our high streets have been undergoing significant structural change for years. Not only do we have too much retail space in the UK, but also the wrong sort of space – hence the popluarity of out of town retail among traditional high street retailers such as Next, M&S and many others.
The government however seems to view land lords not only as the problem, but as a potential solution – deciding that they clearly do not want to let their premises out to occupiers and therefore forcing them to do so via this draconian idea. Landlords are to an extent a convenient punch bag for the government, enabling them to deflect atten tion from the real issue at hand – business rates.
the previous year or been vacant for at least 366 days out of the previous two years. This in itself is far from easy to determine, and the government has not defined the precise meaning of ‘occupation’ in this instance.
For example, would a property count as unoccu pied if it is currently vacant for site assembly pur poses pending a redevelopment, or if it is undergo ing a major refurbishment? It is also not clear how the local authority will obtain occupancy informa tion. To gain access to up to date information, local authorities would have to engage regularly with agents and landlords, which requires both capacity and resource that many of them do not have, and the government has certainly not offered to provide such resource.
Other questions the government have failed to provide answers to include: who will decide which bidder ‘wins’ the auction, and how? Who has enforcement responsibility if the ‘winner’ does not pay the rent? How is the tenancy granted to the successful bidder? So many unanswered questions.
Finally, the timing of the announcement of com pulsory rental auctions smacks of electioneering, given it came just before crucial local elections. Being seen as doing something proactive to revi talise the high street – particularly in ‘red wall’ towns blighted by high vacancy rates – was certain ly convenient timing.
Michael Bach, London Forum of Amenity and Civic SocietiesThe government have consistently failed to meaningfully reform business rates over the years –their most recent reform rendered almost meaning less for multiple retailers with a very strict cap on rates relief payable. Business rate payments gener ate billions for the Treasury, but they are far from equitable given no such tax exists for online retail ers, and globally there are very few examples of large scale property based taxation – with physical store occupancy costs ratios far more palatable in similarly developed economies.
Not only are compulsory rental auctions unfair, they are also unworkable in practice. The idea is that such auctions would be undertaken in streets local authorities deem as ‘crucial’ to the local economy because of a concentration of high-street uses of premises in those streets.
The issue is that local authorities have made no such designation, and to do so would require signifi cant research into local property needs, which they would first need to undertake. To qualify the proper ty must also have been unoccupied for the whole of
Compulsory rental auctions are yet another half baked idea by a government that has paid lip service to saving the high street over the years, but has failed to act to reform the biggest single issue facing it – business rates.
Jonathan De Mello, Founder & CEO of JDM Retail Ltd
Jonathan De Mello is Founder & CEO of JDM Retail LtdBRIEFING BRIEFING
Whole-life carbon assessment controversy strikes the Barbican
The AJ reports: Plans to demolish parts of the Barbican Estate are based on ‘misleading data’ about carbon emissions and the site’s structure, a residents group has claimed
Last year the architects Diller Scofidio + Renfro and Sheppard Robson unveiled plans to pull down the 1970s Bastion House office block as well as the neighbouring current home of the Museum of London, replacing them with two office blocks separated by a public plaza. A planning application has not yet been submit ted for the proposal.
The early plans caused controversy among Barbican residents, heritage bodies and amenity societies. Resident-led group Barbican Quarter Action argued that the proposals should be reviewed as the Barbican is ‘an area of interna tional and historic significance’.
The City of London, which owns the Barbican Estate and is leading redevelopment plans, published a whole-life carbon assessment for the development in May. The report was prepared by the City ‘in co-ordina tion’ with the architects, engineer Buro Happold and planning consultant Gerald Eve.
The report concluded ‘that retaining the existing buildings is not appropriate in this instance’. It said that demolition and rebuild would ‘require more carbon spend in absolute terms’ but added that it ‘would perform 10 per cent better’ on a kgCO2e/m2 basis…
Barbican Quarter Action’s whole-life carbon assessment was written by architect Simon Sturgis, of Targeting Zero, and says that the City of London’s report ‘appears to be designed to pay lip service to the requirement to exam ine retrofit, and to set out to prove that new build is the only realistic solution’.
Sturgis says that the City of London’s assessment’s refurbishment scenario, which is compared with demolition and rebuild, does not retain Bastion House, which he argues would make a ‘positive difference’ to the
Source: City of London Corporation/Diller Scofidio + RenfroResponse by the City of London Corporation
Our proposals have been carefully developed with industry experts, and would deliver cultural, com munity, and economic investment, and public realm improvements for the benefit of City residents, workers and visitors.
With the Museum of London planning to move, and Bastion House falling below the standards expected for an office block, it is important to find a viable new future for the site.
Fully retaining the existing buildings is not a suitable option due to significant structural issues, fire safety, very poor energy performance, and the limited uses which would be possible at the site.
Redevelopment allows for a larger, more efficient scheme, and will deliver lower whole lifecycle carbon emissions in comparison to the part demolition/part retention option, per square metre.
On balance, redevelopment is therefore considered to be the preferred option for the site.
whole-life carbon emissions for a retrofit option. He adds that the City of London has assumed a new-build scenario would have lower embodied carbon for façades than refur bishment – but suggests this is unlikely given that the proposed new buildings have ‘consider ably more façade area’. And he points out that even under the City of London’s assessment, the new-build and demolition option would
create 20,000 tonnes of CO2 emissions more than the refurbishment – an amount that would take 340,000 trees 10 years to absorb.
Sturgis concludes that, while the City of London has declared a climate emergency and produced guidance for how to respond to this, ‘this ambition and intent are in opposition to the promotion of schemes such as this which are high carbon in construction and use’.
CLIPBOARD
Green Belt expands
England's green belt has expanded for the first time in more than a decade, but the increase is expected to be short-lived because of pressure for new housing. Land designated as green belt jumped by 1.5 per cent, or about 24,000 hectares (600,000 acres), in the year up to March, the Department for Levelling Up said.
The total area under landscape protections now stands at 1. million hectares, leaving 12.6 per cent of the country shielded from urban sprawl.
However, the figures are not evidence of a nationwide bounceback for green belt land, and campaigners warned that they masked declines in several parts of the country. The increase came from land around the market town of Morpeth in Northumberland, which was already effectively treated as green belt but had been awaiting formal designation.
Paul Miner at CPRE said: "We're most concerned by the continued losses in and around London. The Northumberland case is merely confirming what the working boundary had been for some years, so isn't really 'new' green belt.
Of the 14 local authorities that made changes to green belt boundaries last year, Northumberland was the only one to increase the area.
Central Bedfordshire removed 1,290 hectares, followed by Brentwood in Essex 430 hectares and Halton in Cheshire losing 410 hectares. “From our perspective the main concern is really with the con tinued nibbling of the metropolitan green belt caused by substantial and in our view largely unnec essary releases in central Bedfordshire," Miner said.
Housebuilding is forbidden on green belt apart
from in exceptional circumstances, but polling has shown that younger people are far more supportive than older generations of allowing building on such land to go ahead. Rishi Sunak, the former chancel lor, promised during the Conservative leadership campaign to block housebuilding on the green belt, with brownfield sites given priority instead. Authorities under pressure to meet housing targets can remove land from green belt status.
About 260,000 homes are proposed for green field land removed from the green belt, according to CPRE. Miner said there was no reason to expect any thing other than a continued nationwide decline in designated green belt next year.
A spokesman for the government said that it would continue to prioritise development on brown field sites in towns and cities.
The Green Belt has been a disaster
It stops the expansion of productive cities. London should have nearer 20m people than 10m. The secret is that Truss and Sunak are the same candidate: market-loving, awkward and impatient. Liverpool and Manchester should be a DallasFort Worth-style metroplex. The research labs that constitute much of his country's economic future are out of room. And all for the preservation of often nondescript land. If patriotism is the sacrifice of one’s own interests for the nation's, Nimbys are unpatriotic. No prime minister can say that, I
hear you interject, especially one who looks like Sunak. Of course he can.
Voters will - what? - hound him all the way to the Santa Monica branch of his property empire in 2025? Only Sunak can say it.
– Janan Ganesh in the FT
Investment Zones: some handy existing legislation?
Simon Ricketts writes:
I know we all lose bits of legislation down the sofa. The Government’s 24 September 2022 guid ance on investment zones in England said this: “The government will look to introduce primary legislation in order to enable the offer on tax and simplified regulations. The final offer will be sub ject to the passage of that legislation through par liament.”
There really isn’t much clarity as to the nature and extent of any primary legislation that will in fact be required to deliver the regimes envisaged for each investment zone (potentially bespoke for that investment zone). When you add this to the wider confusion as to the relationship of the proposed Planning and Infrastructure Bill with the current Levelling-up and Regeneration Bill (with much of what was trailed for the former either already within the latter - eg environmental law reform - or shortly to be added by way of amendments.- eg amend ments to NSIP processes - or able to be secured by way of secondary legislation), some clarity from Government is urgently needed.
Turning to the question of on what amended planning regimes may be appropriate for some investment zones, people have rightly pointed to the potential use of local development orders, which for example the Government has previously encour aged in relation to enterprise zones and freeports.
However I’m wondering whether, instead of fur ther primary legislation to achieved some unspeci fied new procedure (which sounds slow and imprac tical), the Government has considered whether two provisions which are already on the statute book are in fact sufficient: simplified planning zones and plan ning freedoms schemes. Are ministers even aware of
them? I would be interested in people’s experiences with either.
Simplified Planning Zones were introduced by way of section 82 of the Town and Country Planning Act 19901 which provides as follows:
“(1) A simplified planning zone is an area in respect of which a simplified planning zone scheme is in force.
(2) The adoption or approval of a simplified planning zone scheme has effect to grant in relation to the zone, or any part of it specified in the scheme, plan ning permission—
(a) for development specified in the scheme, or (b) for development of any class so specified.
(3) Planning permission under a simplified planning zone scheme may be unconditional or subject to such conditions, limitations or exceptions as may be specified in the scheme.”
See also the Town and Country Planning (Simplified Planning Zones) Regulations 1992.
This is a good explainer, with examples: How simple are Simplified Planning Zones?2 (Local Government Lawyer, 4 February 2016) and here is some informa tion about Slough Borough Council’s Slough Trading Estate SPZ3
Planning freedom schemes were introduced by section 154 of the Housing and Planning Act 20164. From the explanatory notes to section 154: “Section 154: Planning freedoms: right for local areas to request alterations to planning system
441 This section enables the Secretary of State, by regulations, to make planning freedom schemes in England. Planning freedom schemes may only be made following a request from the local planning authority for the relevant area and only if the Secretary of State considers the scheme will lead to additional homes being built.
442 Before bringing forward proposals for a scheme the local planning authority must consult in their local area.
443 Such schemes will operate for a specified period (although subsection (7) includes the power to bring schemes to an end early, for example, where the local planning authority asks the Secretary of State to do so).
444 Planning freedom schemes will apply in relation
Aylesbury Estate: new plans lodged as council approves compulsory purchase powers
The Aylesbury Estate in Walworth is part-way through a 20-year regeneration project led by Southwark Council, which will see 4,200 homes built on the estate, originally home to 2,758 peo ple. The latest phase, 2b, includes buildings by masterplanners Maccreanor Lavington and four other practices: Sergison Bates, Haworth Tompkins, East, and Architecture Doing Place. It is being delivered in partnership with Notting Hill Genesis.
Phase 2B involves the demolition of the exist ing blocks to make way for five new buildings
to a specified planning area which will be the area of a local planning authority or an area comprising two or more adjoining areas of local planning authorities. The Secretary of State may restrict the number of planning freedom schemes in force at any one time.”
Is anyone aware of this, extremely open-ended, power ever having been used? Planning legislation is full of these false starts and dead ends. I’m sure there’s plenty more that you can point to. Regardless of any substantive changes, a spring clean of the whole legislative framework is well overdue. Although who knows what we’ll find. - Simon Ricketts, simonicity - Personal views, et cetera 1.https://www.legislation.gov.uk/ukpga/1990/8/part/III/crosshea ding/simplified-planning-zones
2. https://www.localgovernmentlawyer.co.uk/planning/318-plan ning-features/28701-how-simple-are-simplified-planning-zones 3. https://www.slough.gov.uk/planning/simplified-planning-zonespz 4.https://www.legislation.gov.uk/ukpga/2016/22/section/154/en acted
between five and 25 storeys, providing 614 homes, of which 165 are social housing, 367 pri vate homes and 82 intermediate. The tallest building will be located on the corner of Albany Road and Thurlow Street as a gateway building to Burgess Park.
Most of the estate is now empty after the council acquired 46 leasehold properties and suc cessfully rehoused 293 households on secure ten ancies. However, negotiations are still ongoing with 11 leaseholders.
In a bid to make progress on stalled discus sions, in June the council’s cabinet approved the use of compulsory purchase orders (CPOs), which ‘as a last resort’ would allow the authority to buy residents’ homes without their consent and move them off the estate.
A previous attempt by Southwark to obtain CPO powers on a different Aylesbury phase was blocked by former communities secretary Sajid Javid, a decision the council eventually over turned in the High Court in 2018.
The Council has drawn up rehousing options for resident leaseholders, from a council tenancy to the purchase of a council property under either shared ownership or shared equity arrangements or the purchase of a housing asso ciation property on either shared ownership or shared equity. Southwark Council decided to demolish and rebuild the estate in 2005 and so far 408 homes have been completed by develop er L&Q in Phase 1a, led by architect HTA Design.
Works are on site for a further 581 council homes and 122 private homes, as well as a new library, health centre and early years centre, scheduled to complete between autumn 2022 and 2025. n
PILLO! PILLO!
Growth, Growth, Growth
Liz Truss vowed to get London’s economy “firing on all cylinders” if she became Prime Minister.
She hailed the capital as key to driving the nation through the economic storm with skyrocketing energy bills in the autumn. Amid fears that the city is losing funding due to the Government’s levelling-up agenda, she also insisted she would be “London’s strongest champion”.
As the economic clouds over Britain were darkening, Ms Truss, writing in the Evening Standard, said: “London has long been the engine of our economy. When Londoners thrive, the rest of our United Kingdom thrives too.”
She added: “I know some of the most deprived areas in the country are found in the capital. So I will take bold action to get London’s economy firing on all cylinders through tax cuts, bold reform and removing regulation that stifles business.”
She also unleashed a stinging attack on Mayor Sadiq Khan, highlighting the level of knife crime in the capital. She slammed the “militant trade unions grinding London to a halt” and the “shocking violence” against women and girls.
Royal Yacht
Following up on Boris Johnson’s promise to build a new Royal Yacht, a transparency request has revealed that, so far, the Ministry of Defence has engaged three external consultants on the project, spending a total of £330,000.
This included the law firm DLA Piper for legal advice and the Royal Institute of British Architects for architectural services. Commentators suggest that given the ‘Cost of Living Crisis’ this new boat idea is dead in the water.
St Mungo’s homes set for go-ahead
AHMM's proposed residential tower and hostel block in west London, designed for charity St Mungo’s: Source AHMM
Proposals for a new centre for homeless people, backed up with a 20-storey development of build-to-rent flats have beengranted approval by Westminster City Council. AHMM’s scheme for charity St Mungo’s will replace an existing west London hostel with a more modern facility featuring 45 self-contained en-suite rooms and 11 fur ther “move-on” units where people will be supported for their next steps.
The 0.12ha site between Harrow Road and the Westway, will see the new hostel facilities delivered in a ninestorey building fronting the main road, and the tower featuring new rental homes to the south. Council officers say the proposals would deliver numerous benefits, including providing better facilities for St Mungo’s and con tributing to the authority’s housing target. They say that while the floorspace for the reprovided hostel would be “slightly smaller” than the existing building, the space would be better used, resulting in four additional rooms and a higher standard of accommodation.
The build-to-rent element of the scheme, which has been worked up in partnership with developer Stories, would feature 98 apartments – up to 14 of which would be designated as “affordable”, depending on the coun cil’s preferred mix of studio, one-bedroom and two-bedroom homes. Officers claim that AHMM’s scheme would deliver a “very substantial” package of public benefits, including replacing an “architecturally harmful” building and making a “significant contribution” to the city’s 985-new-homes-a-year housing target. – BDonline
Destination city City
The City of London’s planning committee has resolved to approve plans for a new hotel development. A higher block facing onto Jewry Street will be 15 storeys and a lower block will be eight. The scheme will have 311 hotel rooms, a café/bar on the ground floor and a rooftop restaurant, both open to the public.
The City Corporation recently announced a bold new vision for the future of the Square Mile –Destination City – to ensure it remains a worldleading location for UK and international visitors, workers and residents to enjoy.n
Numbers of applications and decisions continue to drop
Latest planning performance by English districts and London boroughs: planning applications in England between April to June 2022
OVERVIEW
Between April to June 2022, district level planning authorities in England:
• received 106,800 applications for planning permission, down 17 per cent from the cor responding quarter of 2021;
• granted 87,600 decisions, down 12 per cent from the same quarter in 2021; this is equivalent to 88 per cent of decisions, down one percentage point from the same quarter of 2021;
• decided 86 per cent of major applications within 13 weeks or the agreed time, down one percentage point from the same quar ter in 2021;
• granted 8,700 residential applications, down nine per cent on a year earlier: 1,000 for major developments and 7,700 for minor developments;
• granted 1,800 applications for commercial developments, down five per cent on a year earlier.
• decided 58,000 householder development applications, down 16 per cent on a year earlier.
This accounted for 58 per cent of all deci sions, down from 62 per cent a year earlier. In the year ending June 2022, district level planning authorities:
• granted 362,000 decisions, up three per cent on the year ending June 2021; and
• granted 37,100 decisions on residential developments, of which 4,600 were for major developments and 32,500 were for minor developments, down by 11 and five per cent respectively on the year ending June 2021. This is equivalent to a decrease of six per cent in the overall number of resi dential decisions granted.
Planning applications
During April to June 2022, authorities undertaking district level planning in England received 106,800 applications for planning permission, down 17 per cent from the corresponding quarter in 2021. In the year ending June 2022, authorities received 437,700 planning applications, down seven per cent on the year ending June 2021.
Planning decisions
Authorities reported 99,900 decisions on planning applications in April to June 2022, a decrease of 11 per cent on the 111,700 decisions in the same quarter of the previous year. In the year ending June 2022, authorities decided 412,000 planning applications, up three per cent on the number in the year ending June 2021.
Applications granted
During April to June 2022, authorities granted 87,600 decisions, down 12 per cent on the same quarter in 2021. Authorities granted 88 per cent of all decisions, down one percentage point from the June quarter of 2021 (Live Tables P120/P133).
Overall, 82 per cent of major and minor decisions were granted, unchanged from the quarter ending June 2021 (PS2 development types dashboard).
Over the 12 months to June 2022, 362,000 deci sions were granted, up three per cent on the figure for the year to June 2021.
Historical context
Figure 1 shows that, since about 2009-10, the numbers of applications received, decisions made and applications granted have each followed a similar pattern. As well as the usual within-year pattern of peaks in the Summer (July to September quarter for applications and July to September for decisions) and troughs in the Autumn (October to December quarter for appli cations and January to March quarter for deci sions), there was a clear downward trend during the 2008 economic downturn, followed by a peri od of stability leading to a large dip in 2020 fol lowing the start of the pandemic and a subse quent recovery in early 2021, including a particular peak in applications received.
Regional breakdowns
Table 2 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 81 per cent in London to 94 per cent in the North East.
Speed of decisions
• In April to June 2022, 86 per cent of major appli cations were decided within 13 weeks or within the agreed time5, down one percentage point from the same quarter a year earlier.
• In the same quarter, 82 per cent of minor appli cations were decided within eight weeks or the agreed time, up one percentage point from a year earlier.
• Also in the same quarter, 87 per cent of other applications were decided within eight weeks or the agreed time, up one percentage point from a year earlier.
Figure 3 summarises the distribution of the percentage of decisions made in time across authorities for major, minor and other develop ments using box and whisker plots. The ends of the box are the upper and lower quartiles, meaning that 50 per cent 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 extend to
Planning decisions by development type, speed of decision and local planning authority. All tables and figures can be found here: https://tinyurl.com/ycya4ymv Source: DLUHC/ONS
the highest and lowest observations (the range).
Figure 3 shows that the variation in percentage of decisions made in time this quarter is widest between authorities for major developments (0 to 100 per cent), followed by minor developments (11 to 100 per cent) and other developments (40 to 100 per cent).
Use of performance agreements Table 4 summarises the recent use of performance agreements6. It shows that they are more com monly used for major developments than minor or other developments, with 74 per cent of major
decisions made during April to June 2022 involving a planning agreement, compared with 50 per cent of minor decisions, 37 per cent of other decisions and 41 per cent of all decisions (also shown in Reference Table 2). Figure 4 shows, from 2010, numbers of decisions on major developments made involving a performance agreement, com pared with numbers of major developments with out a performance agreement. The underlying his torical figures are available in the PS2 develop ment type dashboard. Notwithstanding definition al changes, there has been a marked increase in the use of agreements since early 2013. This
longer upward trend has been driven by both the additional scope for recording them and their additional use.
Performance of individual district level local planning authorities
Live Tables P151a and P153 present data on the performance of district level local planning authorities against the latest published criterion in Improving planning performance: criteria for designation on the speed of decision-making for informing decisions on the designation of poorly per- forming local planning authorities under sec tion 62B of the Town and Country Planning Act 1990. In particular, Live Table P151a gives detailed figures for the time taken for major decisions to be made over the eight most recent quarters and Live Table P153 presents data for the time taken by dis trict level local planning authorities for decisions on ‘non-major developments’ (defined as minor developments, changes of use and householder developments) to be made over the eight most recent quarters.
Similarly, Live Table P152a, presents data on the performance of district level local planning authorities against the latest published criterion in Improving planning performance: criteria for designation on the quality of decision-making for assessing performance under section 62B of the Town and Country Planning Act 1990. In particular, it gives detailed figures for the percentage of major decisions subject to a successful planning appeal, by matching eight quarters of the depart ment’s data on decisions and all available quarters of Planning Inspectorate data on appeals. This table is usually published a few weeks after the statistical release and most of the other live tables, to take account of the latest appeals data.
Live Table P154 presents data for the percent age of decisions on non-major developments (as defined for Table P153) subject to a successful planning appeal, by matching eight quarters of the department’s data on decisions and all available quarters of Planning Inspectorate data on appeals. Like Table P152a, this table is usually pub lished a few weeks after the statistical release and most of the other live tables, to take account of the latest appeals data.
Residential decisions
In April to June 2022, 12,000 decisions were made on applications for residential 7 developments, of which 8,700 (73 per cent) were granted. The num ber of residential decisions made decreased by eight per cent from the June quarter of 2021, with the number granted decreasing by nine per cent.
The number of major residential decisions granted decreased by 16 per cent to 1,000, and the num ber of minor residential decisions granted
decreased by eight per cent, to 7,700 (Live Table P120A, and the PS2 development type dashboard).
In the year ending June 2022, authorities grant ed 4,600 major and 32,500 minor residential applications, down by 11 per cent and five per cent respectively on the year ending June 2022 (Live Table P120A and the PS2 local planning authorities dashboard). This is equivalent to a decrease of six per cent in the overall number of residential deci sions granted.
Residential units
The figures collected by the Department are the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each applica tion, such as the number of homes in the case of housing developments. The department supple ments this information by obtaining statistics on housing permissions from a contractor, Glenigan.8
The latest provisional figures show that permission for 280,000 homes was given in the year to 30 June 2022, down 16 per cent from the 334,000 homes granted permission in the year to 30 June 2021.
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. These figures are provided here to give contextual information to users and have not been designated as National Statistics.
Commercial decisions
In April to June 2022, 2,100 decisions were made on applications for commercial developments, of which 1,800 (89 per cent) were granted. The total number of commercial decisions granted decreased by five per cent on the same quarter of 2021. In the year ending June 2022, 7,700 applications for commercial developments were grant
ed, up four per cent on the year ending June 2021.
Trends in numbers of residential and commercial decisions
Historically, numbers of residential decisions dropped sharply during 2008 (particularly for minor decisions) then increased from 2012, before decreasing since about 2018 (major decisions) and 2019 (minor decisions).
Numbers of commercial decisions also decreased sharply during 2008 and then stabilised at around 2,100 per year for major and 10,000 per year for minor commercial decisions, but have undergone some further decreases recently, partic ularly for minor decisions.
Trends in the percentage of residential and commercial decisions granted
The percentages of major and minor residential decisions granted increased between 2008/09 (from about 65 per cent for each type) and 2010/11 (to about 80 per cent for major develop ments and about 75 per cent for minor develop ments) and have stabilised since then, at just over 80 per cent for major developments and just under 75 per cent for minor developments. The percentages of major and minor commercial deci sions granted increased steadily, from 89 and 85 per cent respectively in 2007/08, to 94 and 91 per cent respectively in 2014/15, and have both been largely stable since then.
Householder developments
Householder developments are those develop ments to a residence which require planning per mission such as extensions, loft conversions and conservatories (more details are in the glossary accessible from the Definitions section of the Technical Notes). The number of decisions made on householder developments was 58,000 in the quarter ending June 2022, accounting for 58 per cent of all decisions, down from 62 per cent of all decisions made in the quarter ending June 2021.
FIG 9:
Applications for prior approvals for permit ted development rights reported by district planning authorities.
England, thirty-three quarters from April 2014 to June 2022
Authorities granted 90 per cent of these applica tions and decided 88 per cent within eight weeks or the agreed time.
Permission in Principle/Technical Details consent decisions
Since 16 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 gra of permission in principle, applicants have been able to submit an application for Technical Detail Consent (TDC) for development on these sites. In addition, since 1 June 2018, it has also been pos sible to make an application for PiP for minor housing-led development as a separate applica tion, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC and a determination period of five weeks applies as it is minor development. Extensions of time may be agreed.
TDC applications have a 10-week determina tion period for major development and a fiveweek determination period for minor develop ment. Extensions of time may be agreed and where it is an Environmental Impact Assessment (EIA) development, the 16-week determination period applies.
Major public service infrastructure development decisions
Since 1 August 2021, major public service infras tructure developments – broadly defined as major developments (excluding Environmental Impact Assessments) for schools, hospitals and criminal justice accommodation - have been subject to an accelerated decision-making timetable under which they are to be determined within 10 weeks instead of falling within the normal 13-week determination period.
Separate figures on major public service infras tructure development decisions have been collect ed on the quarterly PS2 return with effect from 1 October 2021. They are provided at local planning authority level in Live Table MJPSI. In summary, during October to December 2021, local planning authorities reported five such decisions, of which four were granted and all five were decided within 10 weeks or the agreed time. During January to March 2022 there were eight decisions, of which all eight were granted and seven were decided in time. During April to June 2022 there were 10 decisions, of which all 10 were granted and eight were decided in time.
Permitted development rights
Planning permission for some types of develop ment has been granted nationally through legisla tion, and the resulting rights are known as ‘permit
ted development rights’. In some cases, if the legis lation is complied with, developments can go ahead without the requirement to notify the local planning authority and hence no way of capturing data exists. In other cases, the legislation requires an application to the local planning authority to determine whether prior approval is required (more details are in the Definitions section of the Technical Notes). A local planning authority can withdraw specific permitted development rights across a defined geographical area, bringing these types of development within the control of the main planning process13.
The results for the latest quarter for which they have been collected (April to June 2022) are included in Live Tables PDR1 (local authority level figures) and PDR2 (England totals). Of the 7,400 applications reported in the April to June quarter of 2022, prior approval was not required for 4,200 and permission was granted for 1,600 and refused for 1,600. This resulted in an overall acceptance rate14 of 78 per cent. Larger householder exten sions accounted for 69 per cent of applications (5,100), with six per cent relating to change of use from agricultural to residential and 18 per cent relating to ‘All other’ permitted development rights.
Taking i) granted applications and ii) those for which prior approval was not required together, 5,800 applications were approved without having to go through the full planning process, down 28 per cent from a year earlier. Within the 28 per cent decrease in the reported total number of PDR applications between April to June 2021 and April to June 2022:
• larger householder extensions decreased by 29 per cent;
• change of use from agricultural to residential decreased by 12 per cent; and
• ‘all other’ permitted development rights decreased by 18 per cent.
Part of the decrease in the overall total between April to June 2021 and April to June 2022 is due to applications under the PDR for change of use from office to residential no longer being able to be submitted after 31 July 2021: 600 such applications were reported for the April to June 2021 quarter.
A new PDR for Commercial, business and ser vice to residential use was created with effect from 1 August 2021. Figures for this were collected for the first time in October to December 2021, when – to quote unrounded figures - 138 applica tions were recorded. Of these, prior approval was not required for 17, 64 were granted and 57 were refused. In January to March 2022, 196 applica tions were recorded, of which prior approval was not re-quired for 18, 113 were granted, and 65 wererefused. In April to June 2022, 231 applica tions were recorded, of which prior approval was not re- quired for 42, 119 were granted, and 70 were refused.
Figures for the total number of permitted development right applications made for changes to residential use for quarters from July to September 2014 are given in the quarterly work sheets in Live Table PDR1. These show that a total of 800 applications for changes to residential use were reported in April to June 2022, of which 500 (63 per cent) were given the go-ahead without having to go through the full planning process.
Overall during the thirty-three quarters15 end ing June 2022, district planning authorities report ed 289,800 applications for prior approvals for per mitted developments. For 163,400 (56 per cent) of them prior approval was not required, 67,500 (23 per cent) were granted and 58,900 (20 per cent) were refused (Figure 9). n
Population projections, revised NPPF, impact of inflation and embodied carbon
Account of Forum meeting on 12 September 2022 on Zoom
Full minute by James Michell also at planninginlondon.com > LP&DF
TOPIC 1
London population projections from the census figures. Implications for planning - see leader in latest Planning in London at . Led by Lee Mallett with Wil Tonkiss and Lisa Fairmaner [Head of London Plan] of GLA.
Lee Mallet (co-publishing editor of Planning in London)
• Since the early 1980s until now, one of the biggest stories was the turnaround in the popula tion statistics:
The city lost 540 000 people in the 60s, 750 000 in the 70s and since early 80s, the population num ber has risen consistently as revealed by the Office for National Statistics, from 6.6 million in the early 60s people to 8.8 people.
• The accuracy of the statics and what they really imply for the number of houses needed is hard to define. The figures continue to reveal that the pop ulation is still increasing, while there are not enough housing being built to match the figures, leading to a shortage of housing.
To what extend is the job of the planning system try to address this issue or the politicians should directly tackle the issue?
• The statistics also revealed an imbalance shift as people from center areas such as Chelsea, Kensington and Westminster had a decrease in population of 9.6 per cent, whilst places such as
Census
Dartford, Tower Hamlets shown a 20 per cent increase in population – areas that also have a high score in deprivation.
Will Tonkis (Senior Data Scientist for City Intelligence Unit)
• WT area of responsibility is population projections –the data is used for the London Plan
• WT starts with the general context of what cen
Meeting held on 12 September 2022 on Zoom
Moderator
Brian Waters (BW)
Speakers
Lee Mallet (LM)
Will Tonkiss (WT)
Lisa Fairmaner (LF)
Steve Quartermain (SQ)
Michel Bach (MB)
Thomasin Renshaw (TR)
Dr Riette Oosthuizen (RO) (Jt Hon Sec)
Siobhan Cross (SC)
Nicholle Kingsley (NK)
Peter Eversden (PE)
Attendees (as listed by Zoom)
Nikki Linsell
Paul Higgs
Peter Stewart
Stephen Heath
Steve Norris
Tim Wacher
Michael Kiely
Mark Willingale
sus says and what it means for us. 8.8 million population now according to the census in London. The previous media estimated for June 2022 – (9 months before the census) - was 9 mil lion.
The difference in number is part because the media estimate is wrong and part because of the pan demic effects. This period had the most population
Nigel Moor Andrew Rogers
Anthony Carlile
Brian Gatenby
Deon Lombard
Eric Sorensen
James Mitchell (Jt Hon Sec)
Michael Coupe
NK Nicholle Kingsley
Stefano Koryziss
Apologies:
Joanna Averley, Jonathan Manns (v-chair)
2021
Wil TonkissPandemic Effects
change in movement.
• The census number is right and it is showing what the population was on the very specific day, specific unique time. How useful that number is for the next year is to be questioned.
How government use that number and how future projections in population incorporate the new census point into the data:
One of the first thing that happen after the cen sus was to go back and check the changes in a decade and draw a line between the 2 census, understanding the reality of how the population changed over 10 years. This is then projected for ward.
ONS (Office for National Statistics) plan is to produce the next subnational population projec tions in early 2024, while City Intelligence hope is to produce them manually by early 2023.
• WT shared screen showing diagram of the num ber of population since the census and the Greater
London Authority (GLA) projections.
Lisa Fairmaner (Head of the London Plan and Growth Strategies)
• The London Plan Population projections are cru cial for the London Plan going forward
• The planning for London Programme:
Discussions with a group of representatives across UK and their views of the future of London, pick ing up themes such as climate change, commer cial opportunities, health, housing, and economic growth opportunities.
The Programme includes Talk London Work. The next phase is deliberative events and stake holders events early next year.
• It is important to reiterate that any change will not be ready until next mayoral administration.
The work is to identify challenges and potential options rather than coming up with what the next London Plan will include.
Demographic of the population projections – are
an important part of the process.
• Running alongside the London Programme, is the new Integrated Impact Assessment Framework (IIA) - literature baseline and information. Expected to have IIA scoping report available in the early new year to use as a framework to con sider and assess all the options for the London Programme.
• Moving towards live digital SHLAA (London Strategic Housing Land Availability Assessment)
Questions:
LM: How do you feel about previous census telling the population has increased by 600 000 in each decade but we did not build nowhere near enough houses? How do you see the plan addressing this issue.?
LF: We are not at that stage yet. We identify that London housing delivery has not kept pace and that London average occupancy rates have increased slightly, but we are not in the stage of putting for
ward what we might do to address that.
LM: Are you able to say how politicians might act to address this discrepancy?
LF: This will be a London Plan and we do not know who the political makeup will be. That is why is so crucial to take all the options that are put forward to us, assess them and identify the pros and cons. It will be up to the next mayor to look at all the policy leavers and create the London Plan.
BW: Property Week reports a study by Hamptons with the headline that ‘inflation and flexible working push Londoners out of town’ and they have a data on that. What extend is a permanent shift or a reac tion to lockdown? What is your perception of your recent trends that might have been distorted or been missed by the census count in terms of the move out of London?
LF: There is a wealth of information out there about what is likely to happen. We will just be con tinuing to update the baseline that we are assessing against. We are still in a fluid situation at the moment.
WT: For the population data point of view – pan demic statistics are particularly timely. We do not know yet what the longer impact of pandemic will look like in a longer span of time. Looking at the jobs data by sector – during the pandemic a lot of jobs such as retail, hospitality disappeared but now they came back. There is a lot of data but it does not cover the whole peace. It is difficult to get a handle of what exactly is going on.
Eric Sorensen (EO): I am interested in population projection. Will’s graph showing a dip and then an increase in population. I would be interested to know what that assumption was based on? The fact is that 6 years ago we were projecting a significant increase in young population and we build many primary schools. We now have many primary schools that are underpopulated by pupils. It is an illustration of how difficult is to make this projections.
One last point – a lot of the house developments particularly in the east London have been high rise residential developments. Talking with estate agents about who actually lives there you will notice that there are not standard families but tends to be short let, Airbnb, parking investment capitals. To under stand how much housing we need, we must under stand what is the mix of housing and who is living there to make any sense of the population and social requirements.
Steve Quartermain (SQ): Question for Lisa –given the change in the figures is there anything you feel you should do in the meantime to encourage the local boroughs to follow the higher figure in esti mating the housing needs rather than the lower fig ure?
LF: We are not expecting to see a change to the role of the London Plan in setting and apportioning the housing targets across London local authorities. It
is an entirely separate question to how the London Plan understands the housing needs in the future and what the housing targets for each local authority should be.
Michael Kiely (MK): The number of houses needs is different than the rest of the country and it is based on capacity.
LF: Establishing the targets is made up of a whole host of very complex factors. MK is right the housing needs is based on capacity and not based on each individual borough need.
MK: The 300 000 figure is not a real figure derived by demographic, it is a political figure. We have the affordability equation – if you build more houses the housing prices drop down. There is no evidence of this. The actual housing needs is below that figure. Hopefully these changes will come from the govern ment and will be addressed properly by looking at people.
Michael Bach (MB): The current situation will make the process even slower with the rise in costs, Brexit, inflation etc.
Short lets are now biting into the housing figures in some boroughs and it is higher than what is deliv ered. For the London Plan, we probably would end up with a negotiation figure of the number of housing needs and I think this is a more sensible solution.
LM: We need to understand how it is impacting on younger generation who are finding difficult to find affordable accommodation.
Thomasin: How much work has been done to underlines where the population projections come in terms of the household size and composition of household with the population changes? How we are using our housing stock? How the real demand is vs the usage vs the projection?
WT: It is partly to do with the population projec tion but it is also to do with the house hold projec tion model and it is based on census data 2001 and 2011 data. The question is if this is fit for purpose as you want to move forward?
TOPIC 2
Changes to the NPPF: The promised update has been trailed but failed to appear before the Summer recess. What might it, should it contain?
Led by Steve Quartermain of Town Legal (recent ly Government chief planning officer) Michael Bach and Peter Eversden of the London Forum of Amenity Societies.
Steve Quartermain:
• 2.5 years later – Planning Bill – so much is not explained. As part of the things promised was an updated NPPF. A revision is long overdue. There are many issues that need to be addressed. It was not a detailed NPPF that was forecast but a perspective of what the revised NPPF might look like.
• National Development Management Policy
Some policies do not attract that much atten tion. The most comments received on policies are on allocation policies.
Michel Gove said there will be consultations on the policy. If that is the case then plan making would be a lot quicker, easier and cheaper if some of the policies would be banged as they were.
The policies in the NPPF should have the same status as in the local plan with legal backing.
Some of the other issues:
- SQ is expecting for the NPPF to be clearer on the climate change agenda, clearer about retrofit and how the planning system should be more support ive, expect to adjust some of the issues we dis cussed today.
-In terms of the government position – there is a 9 months to 2 years window of change – new Prime Minister, Prince Legislation etc.
-The context of the economic challenges, there are concerns about the housing number, questions about the Levelling Up Agenda? Investments zones and planning zones- does that address the level ling up agenda, the approach of green belts?
All this gives a real opportunity to champion the NPPF.
There are things that you can change with imme diate difference. There should be a specific change to paragraph 35 on examining plans –local plans and spatial development strategies to be constantly reviewed. Another change should be to paragraph 33 to keep plans rolling.
Michel Bach:
• MB was responsible for the proactive PPGs (Planning Policy Guidance notes) and PPSs (Planning Policy Statements).
• The problem with the NPPF is that a lot is about process rather than policy. Policies need strength ening. Examples: policies to strengthen town cen ters;
In terms of the allocation, before deciding on the right development for an area, it should be identi fied how the place will look like.
• The biggest problem – there is nothing specific about big cities and London. London Plan provide very specific policies which NPPF will never pro duce.
• GLA talking about the London Plan and about the bill and not about what is going on in London. London situation is extreme with land values, development pressure, housing pressure, social and community uses that need protection. Any devel opment is usually at the expense of something else.
What is worrying is the status that National Development Management Policies would have –they would trump local plan policies. We should not discard the General Conformity principle where The London Plan has to conform with NPPF, and the Local Plan with the London Plan. You can
diverge from the other where it proves that there are local reasons.
• Another concern is the uncertainty about the future of the London Plan.
• Every chapter should have an introduction to make clear what is the purpose. The location development chapter (transport) is very weak. An important aspect is about strengthening local communities.
• A policy on tall buildings as in London Plan should be in the NPPF for all authorites
• A rethink of the content of NPPD and what it is about.
SQ: The government talked about National Development Planning Policies trumping the local policies if there is a difference. The issue is why would be a difference?
MK: National Development Planning Policies –the reason for having the same policies about differ ent things is to give section 38.6 status.
We do not know what policies government will produce. It might be that the generic policies might not be appropriate on specific areas. It is necessary that if it is to depart from the policy, an inspector should check and fresher policies should be intro duced to the specific areas and should carry weight
At the moment there is no freedom for local dis tinctiveness in the areas covered by NPPF.
NPPF is a mixture of policies and processes. There is a need to stand back and review all that; get all the policies in one document and all the proce dures into a practice guidance.
Peter Eversden (PE):
PE view on National Development Planning Policies is that they should be like any other guid ance and should have roots in NPPF. There should be a subject on which the guidance is given, not be
something special to determine if a planning appli cation is approved or not.
Robert Jenrick interfered with the London Plan –after it has been inspected, he ripped and inserted parts of it on the basis that only if you do this he will allow the publishing, reflecting the government attitude towards London and its plan. Clause 85 of Leveling Up and Regeneration Bill threatens the London Plan.
The NPPF does not include many of the subjects the London Plan covers. There are different rules for what would you do, where. The government does not know enough about London to try to change. The NPPF should cover the subjects that needs guidance rather than impose them.
Nigel Moor (NM): Retired local planning, and retired local politician-
In the last two years, the politicians started to see planning as a toxic subject. We need to try and promote a much more bipartisan approach.
Brian Gatenby (BG): Practicing architect and qualifying planner.
Real world planning moves faster than policy. It is not new – planning has been described as a wob bly pillar from the first day. We should look more at implementation with a more focus on reality of how it works in practice.
BW: Looking at the practicality of the process –the development management process is drawing in the process of technical requirements which are demanded before even the planning application is refused. Anything measurable should be in the Building Regulations rather than planning.
MK: Agree with BW in large. There is only a need for 2 documents – a design justification, and the other document should identify the impact of the development. The documents should have a word
limitation. At the moment - trying to access all the documents is impenetrable. We should focus in jus tifying a good design and its impact assessment.
TOPIC 3
Impact of inflation on London’s housing supply
Led by Thomasin Renshaw of Pocket Living and Riette Oosthuizen of HTA Design and BCIS (invited). SEE: Housebuilders costs up 15 per cent in last year - BCIS
Thomasin Renshaw (Development Director at Pocket Living):
Cost of the planning application – is astronomi cal. TS supports the notion that if consent is not implemented it should be because of a problem and not reluctance to the delivery.
Pocket Living
• Focus primarily on delivering 1bedroom homes –(1 bedroom-1 person homes)
• Deliver all over London - 50 live schemes on dif ferent scales. Diversity of schemes.
•The percentage of build cost inflation is higher the smaller the contract value
• Schemes:
West Green Place in Haringey: 98 pocket 1 & 2 bedroom homes, 12 pocket edition 2 bedroom homes and 16 family town houses and communi ty center.
Gainsford Road in Waltham Forest: 45 - 1bedroom pocket homes.
The current state of the industry:
• construction materials up to 23 per cent since August 2021
• cost of materials at a 40 year high.
• As a result there is a lot of insolvency, build cost inflation.
• Alarming signs for housing delivery –the graph >>>
shows the number of affordable housing in 22-23 decreased exponentially in 10 years.
• There are many construction Insolvencies with 213 construction firms becoming insovent in June alone. It makes up a 5th of all insolvencies.
As an example – on one of the schemes the con tractor became insolvent. The project had to be retendered increasing the bill of the scheme by 30 per cent. There was no profit from the scheme.
• The developers profit margins has been impacted by the build cost inflation. You need a higher profit margin at a time that is particularly risky, but what it happened is that the profit margin is squeezed. Very challenging for a market that invested heavily to get a planning consent.
Dr Riette Oosthuizen (Planning partner at HTA Design LLP)
2007 - Established a planning consultancy within the practice
• HTA multidisciplinary practice specializing in house delivery and place making.
• Deliver schemes of all sizes- infill house delivery, 70 per cent of the clients are local authority.
• Schemes:
Joyce and Snells Estate, Enfield - regeneration scheme. Looking at reshaping a place at this scale is affected by a number of different phases. The project is in planning stage and will be delivered in the next 20 years. With the current market there are some challenges to think about as funding plays an impor tant part in the project.
Islington is one borough that HTA Design works closely with- 30 schemes that are build or in the pro cess of being build. The projects cover different scales trying to tap every single space that can be used for additional housing. Most projects are delivered inno vatively and because it is local authority driven they have a high-quality architecture.
Vorley Road, Islington – utilizing a small site to provide 72 new homes and a new library and a GP center.
Local authorities can drive contextual develop ment. It is important to have enough evidence based so you can envisage how the borough will look like in the future.
A number of small Enfield Infill Projects - with Peter Barber and the council Tallest Modular Tower in Croydon
• Construction cost inflation and hosing delivery, a summary:
- Uncertain and volatile market: Brexit, Covid, Ukraine - Russian War
- Volatility in the housing market based on a range of issues from debt exposure, mortgaged to grant availability, land and planning, labour and skills shortages. The market has proven historically to be resilient; will it be again?
- Construction Products Association market impact
analysis July 2022: construction output forecast to rise by 2.5 per cent in 2022 and 1.6 per cent in 2023. Strong growth in warehouses and infrastruc ture offsets, but slowdown in private housing and fall in private housing repair, maintenance and improvement.
- Material cost inflation is acutely felt: the Construction Leadership Council reports in June 2022 that inflation of around 23 per cent has been typical for construction products and material in year.
- Regulations changes – decarbonization and venti lation – to help UK reach 2050 net zero targets are increasing cost on projects.
- Cost of constructing labour (ICMS data) avg cost of construction labour, including skilled and unskilled has reached 33.60 pounds in the UK. Green collar installation operatives – high demand and low supply – installing renewable energy infrastructure – command rates of 52 pounds per hour.
-Balance of project viability considerations are shifting.
- Inflation potentially impacts on social outcomes and not just project delivery.
Experiences from Practice
- Developer forced to renegotiate affordable hous ing levels with the Local Authority as a result of inflated tender return from contractor
- Major developer in talks with the London Local Authority about concessions that will be required
by them to move their predicted return from what is now down at 12 per cent back to the ‘Broad approved’ 15 per cent margin.
- Infill estate regen project now in 4th year post planning struggling with delivering different ele ments of the scheme. Had to be rephrased and was subject to various post planning changes. The origi nal contractor pulled out. A further contractor is on board but the scheme is struggling to get off the ground, due to brick and window prices. Compounded with issue of costs is supply chain.
- Local authority, the client, reaction – as much cer tainty on design detail that is affordable at current prices as possible, leading to difficult discussions with planning officer about the quality of design,
HTA Planning
and leading to extreme project delays.
• Solutions - supply chain resilience, project resilience and pro ject optimization, team culture and leadership and management. (Arcadis, 2022)
- need for greater collaboration between all parts of housing delivery – including earlier selection of contractors and MMC providers and also longerterm relationship to avoid transactional approach es that will create cost spikes.
- Clients driven by ‘patient capital’ in the BtR and PBSA sectors. They currently continue to invest in housing.
Questions