Grey belt policy - Lord Moylan page 38; LP&DF Planning Update report: Unblocking planning, ‘affordable housing’, the BNG regime plus Strategic planning and the London Plan pages 34-54;
OPINIONS
An alternative view on planning reform - Chris Hinchliff MP page13 ; The removal of 'beauty' from the NPPF - Katy Davis page14; Fixing planning boosts growth - Sam Dumitriu page15; The lessons from Mast Quay - Amardip Healy page16; Gateway 2 and the problem of time - Ian Fletcher page18; Reform of planning committees - Nick Diment page19; High street rental auctions -Simon Barry page20; BNG a year on - David Alborough page21; Assessing Gross Development Value - Andrew Golland page24
page
PIL 133 CONTENTS
PLANNING PERFORMANCE page 30 PAGE
Subsidised affordable housing Ben Clifford page 44
5 LEADERS
A mountain to climb; Ungumming planning; A bridge too few
7 Planning for the development of homes | Chris Benham
10 LEE MALLETT
BeFirst evolves
12 PAUL FINCH
Planning has yet to take off
OPINIONS
13 An alternative view on planning reform | Chris Hinchliff MP
14 The removal of 'beauty' from the NPPF | Katy Davis
15 Fixing planning boosts growth | Sam Dumitriu
16 The lessons from Mast Quay | Amardip Healy
18 Gateway 2 and the problem of time | Ian Fletcher
19 Reform of planning committees | Nick Diment
20 High street rental auctions | Simon Barry
21 BNG a year on | David Alborough
24 Assessing gross development value | Andrew Golland
28 BRIEFING
CLIPBOARD: Fast-tracking of consents; Online directory of digital planning services launched; It’s a gas; Another day, another tax on development
29 ¡PILLO!
Raised planning fees ‘will push firms out of housebuilding’; Takeoff for Luton; Commercial property?; Labour strips environmental quangos of powers to delay housebuilding
30 PLANNING PERFORMANCE
Applications and Permissions down 7 per cent, residential applications down 10 per cent from the same quarter a year earlier
34 LONDON PLANNING & DEVELOPMENT FORUM
Grey Belt, unblocking planning and ‘affordable housing’, the BNG regime strategic planning and the London Plan
35 AI summary
38 Grey belt policy | Lord Moylan & Michele Vas: welcome from Dentons
42 The Government’s intentions for the planning system;
Continues next page
BeFirst evolves LEE MALLETT page 10
LONDON PLANNING & DEVELOPMENT FORUM continued
43 How might changes unblock planning? and Panel discussion
44 Subsidised affordable housing | Ben Clifford
46 biodiversity net gain | Nick White, Mark Topping, Shashin Mishra
51 Strategic planning and the London Plan | Tom Venables
53 Good growth? | Michael Edwards
54 The wind-up | Paul Finch
56 ANDREW ROGERS A tale of two curtilages
57 FÉLICIE KRIKLER Reflections on MIPIM
FEATURES
58 Light rail transit | Nicholas Falk and Reg Harman
58 Revitalising high streets | Anna Iceton and Rebecca Chaplin
64 Young People at the Heart of Planning | Jenny Wood
67 London priorities for a prosperous England | Lars Christian
70 investor focus in the housing sector | Robert Reeds
PLANNING
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Issue 133 April-June 2025
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Light rail transit | Nicholas Falk and Reg Harman
FÉLICIE
Affordable housing underlies all economic success and social stability
Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992
A mountain to climb
The topic of affordable housing bubbled away at the recent Forum Planning Update event with the Cambridge University Land Society, in partnership with Planning in London and host legal firm Dentons. That’s because like the crucial infrastructure it is, affordable housing underlies all economic success and social stability.
The view was expressed, as it frequently is, that it is impossible to achieve the quantum needed without state subsidy, so no need to blame the planning system for the hold up. Which isn’t really news, but a handy statement of the obvious. Or is it? An even more obvious statement might be that for the 25 years of planning policies which require the private sector to deliver ‘affordable’ housing have failed to do so. For this there is at least evidence. Like 100 year waiting lists for ‘affordable’ ‘social’ family housing in some London boroughs.
People wonder why student housing seems to be the only thing getting built at the moment. Or hotels. That’s because they remain viable. There are people with money willing to buy or use these property types, which means developers can find funding to build them and demonstrate some sort of a viable exit plan for investors and some profit for themselves. Not so clear with offices, or large-scale housing developments and definitely not clear with smaller developments.
And even, as was also suggested, the planning system allows developers to build taller, to make more space to sell, it is often the case that the development appraisal starts to turn negative at a certain point – because it is expensive to build taller, and the efficiency of the lower parts of the plan reduces as the structure gets more complex (not to mention providing that secondary means of escape)
There are basic fixes needed to policies that have killed the smaller developer’s interest in building housing. Raise the threshold at which affordable policies bite for one. Nine units is infeasibly low. Nor will any housing association take on a small number of units. Ask any developer what’s happened to housing association ‘demand’ for lower numbers of affordable units. The market for offloading affordable homes is at a low ebb, for a variety of reasons. Some to do with that Liz Truss mini-budget, some to do with registered providers’ dire finances, some stemming from their own adventures in development.
Much more sensible to take smaller developments, say anything below 50 homes, out of affordable housing policy requirements altogether, and instead simply collect a commuted non-negotiable S106 levy for social/affordable housing, or indeed any other civic gain, and apply it to another more efficient site elsewhere. At this stage of the game in London, to produce the fastest results, it could be anywhere in the capital that could offer efficient housing development.
Then there is the newfound lust for Build to Rent. Land Securities, a developer investor with roots deep in the last century, announced recently it was making a major adjustment to its portfolio, switching the emphasis from offices (around 60%) to residential by selling the former assets to reduce its office holdings to around one third, while increasing its residential holdings to take up the slack.
That is a signal to all local authorities, particularly in London, that the vast estates they hold in council housing that are ageing, low density and in dire need of estate renewal, simply to meet new building regulation carbon targets never mind any other ambitions, could be a more than suitable repository for some of that investment ambition given the right conditions. Just don’t tax the life out of the deals.
The only thing getting in the way of supplying more ‘affordable’ housing is the vast mountain of shibboleths erected without planning permission in the public sector’s mindset.
Planning is about the acceptable use of land
Ungumming planning
You may have read this sentiment here before but it seems to be gathering momentum. Paul Finch makes the case on page 13 that the government seems remarkably coy about seizing opportunities which can make things happen quickly. The notion of unblocking planning to boost economic growth has been well rehearsed but the initiatives to date, including the revised NPPF, seem to take only a middle- to long-term view.
Mike Kiely, chairman of the Planning Officers Society says [page 45] “Too much is loaded on planning decisions in the form of conditions required to ensure compliance with other legislation or regulations. Informatives about the need to comply with those requirements are as far as planning decision letters should go. It is then for other council services or organisations to ensure compliance with their legislation or regulations”.
Lord Moylan at the recent Planning Forum [page 40 et seq] said: “All I'm saying is that there are things that planning is going to do about sticking stuff in the right place. And there's a load of other regulation of other stuff, which other bits of government do. But if we choose not to regulate through other means, and make the planning regime do it, then we're all stuffed”.
And Robert Oates, founder and chief executive of London-based Arbtech, writing In The Times says: “Right now, local planning authorities are simply firefighting. If their officers had more time and head space they could focus more on strategic functions, such as the production of high-quality planning guidance, community engagement work and up-to-date, detailed local plans”. He, like the Association of Consultant Architects, supports the idea of bringing in private consultants to do some of the processing of the bulk of straightforward planning applications.
We must hope that the eagerly awaited new update of planning guidance from government dissolves some of the glue which holds back the efficiency and predictability of the planning process. n
A bridge too few
Eliminating the private motorist from London
News that the strengthened and re-opened Hammersmith Bridge will nevertheless not carry cars will be no surprise to observers of Mayor Sadiq Khan’s quiet war on Londoners who live on the south side of the Thames. True, the new Silvertown road tunnel will do something to help transpontine movement, but that is as much about traffic coming from outside London as it is about the capital itself.
Meanwhile, central London continues to feel the pinch of hostility towards movement from south to north. Central London’s bridges are narrowed (Wandsworth, Waterloo, Blackfriars); incapable of taking you north because you hit a T-junction (Southwark); barred to ordinary motorists (London Bridge); or just plain slow (Tower Bridge).
One might imagine this is the systematic working out of former Transport for London boss Sir Peter Hendy’s pledge: to eliminate the private motorist from London (instead filling up roads with his beloved but alas mostly empty buses). If so, why grant innumerable licenses to Uber drivers, most of whom hate the Mayor, even if they come from his community? And who but a peculiar person reduces the capacity of a system when demand is increasing because of population growth and the rise and rise of home delivery vehicles? And buses for that matter.
Along with the perverse imposition of near-universal 20mph speed limits – needless to say these do not apply to cyclists who continue to roam London without insurance or registration discs – all this is bound to slow London traffic, which indeed it is doing, thereby increasing fuel emissions because journey times are increasing.
How old do you have to be to remember the last time central London built a new bridge capable of taking car traffic? Answers on a postcard, preferably sent to the Mayor’s difficult-to-reach parlour. n
Hellman cover from PiL131
Planning for the development of homes in London
In Knight Frank's NextGen Living 2025 report investors cite planning issues as one of the key obstacles to growth despite which investor ambition remains strong says Chris Benham
The UK planning system often makes headlines for all the wrong reasons, with stories about delays, inconsistent decision-making, and political interference potentially deterring investors considering the London market. However, looking beyond these headlines reveals a more nuanced picture, with significant positive changes underway that are creating opportunities for living sectors development.
The revised National Planning Policy Framework (NPPF) from December reinstated mandatory housing targets nationwide and strengthened enforcement mechanisms – this has given policy real teeth. It now includes a simplified ‘tilted balance’ test that favours approving development schemes when councils fail to meet housing requirements and when a project's benefits outweigh its impacts.
Another significant addition is the brownfield
land presumption (NPPF Paragraph 125C), creating further opportunities for development with a presumption in favour of development on previously developed land. With housing targets via the standard method simultaneously increasing, many councils now find themselves subject to these presumptions – opening doors for well-positioned developments.
The Planning and Infrastructure Bill has now been published, which seeks to further reduce the burden on developers and to simplify the planning process. Included is a reform of the planning committee procedure, giving more powers to professional planning officers and limiting the number of applications to be determined by planning committee. This is a very positive move. Also suggested is the ability for planning authorities to set their own fee rates for planning applications, and to reinvest these funds into
Chris Benham is a partner in the planning team at Knight Frank
the planning system. Assuming this money is spent in the right areas, that will hugely help the speed and quality of decision making. These planning improvements come at a critical time. According to Knight Frank's NextGen Living 2025 research, 60% of investors cite planning issues as one of the key obstacles to growth in living sectors, making it the second biggest concern after construction cost inflation (81%). The planning chal-
lenges have contributed to housing permissions falling to their lowest level in a decade, directly impacting development activity. For London specifically, BTR starts fell to their lowest annual level since 2014 in the year to Q3 2024, with fewer than 2,500 homes starting on site.
Despite these challenges, investor ambition remains strong. With construction cost inflation moderating to 2.9% in 2024 from a peak of 15.5% in 2022, and further stability anticipated in 2025, viability pressures are easing – creating better conditions for the recent planning improvements to unlock new
development opportunities.
For the living sectors specifically, they are gaining greater recognition in national policy, which is moving in the right direction. Meanwhile, at a local level, the London Plan and associated guidance is setting out clear expectations for development, and boroughs are adopting policies. This is providing greater clarity for the investment landscape, and should lead to improved decision-making for these asset classes.
While these changes are encouraging, securing planning permission still requires careful consideration, and there are some obvious factors developers
should consider in order to maximise chances of planning success.
Strategic location selection
Location selection has become increasingly critical, particularly as funding markets tighten. For co-living and student accommodation, centrally located sites in Zones 1 and 2 with excellent transport links are strongly preferred by both investors and planning authorities. Crucially, there's growing alignment between where policy directs these developments and where funding partners want to invest.
For co-living particularly, vibrant areas – such as Stratford, Wembley, Canary Wharf, Harrow and Earlsfield – will appeal to young professionals and tend to perform well. For student accommodation, proximity to universities and amenities remains essential, with Zones 1 -3 locations most desirable. That said, attitudes vary significantly from borough to borough. Ealing remains positive toward living sectors in the right location, while Camden will accept student accommodation but generally opposes co-living. Lewisham, and Lambeth are broadly supportive. Meanwhile, Wandsworth has shifted from being highly accommodating to much more restrictive.
With all this in mind, it is important to do research and seek advice from planning experts – ideally before site selection.
Embrace mixed-use development
The most significant trend across all living sectors is the growing expectation for mixed-use schemes, particularly those incorporating affordable housing. While co-living and student housing have traditionally provided payments in lieu of on-site
affordable housing or provided affordable student accommodation, London boroughs are increasingly seeking traditional affordable housing delivery within these developments.
Boroughs such as Southwark, Camden, Tower Hamlets, Newham and Lambeth are leading this shift through their local plans. There are now many examples across London of successful mixed use schemes, albeit it is essential that the uses and tenures are clearly separate to meet funding requirements.
Design considerations
Design considerations are increasingly shaped by regulatory factors. Many developers are deliberately designing schemes to remain under the 18-
ments. This process is causing significant delays and uncertainty, and many are opting to design a scheme to avoid it.
Some developers are choosing to keep schemes under the thresholds where schemes are referred to the GLA, as theoretically at least, this could speed up decision making, reduce cost, and potentially allow greater flexibility in the end product which can be more attractive to investors.
The benefits of these approaches of course need to be balanced against the potential sub-optimisation of site capacity, and that the GLA can be a useful ally in negotiating complex applications.
The planning environment for living sectors remains complex but is showing signs of improvement. With the NPPF and Planning and Infrastructure Bill now published, we can expect further positive changes to come
With housing demand remaining high and policy shifts creating more certainty, now is a promising time to move forward with well-conceived living sector developments in carefully selected London locations. Where the opportunity arises to create mixed use schemes, we’d encourage investors and developers to look carefully at these, as they may well present a smoother route through the planning system. n
MALLETT
BeFirst evolves into its next stage
Being bold and getting the basics right demonstrates what can be achieved in getting the planning function working, says
BeFirst has launched ‘phase two’, an evolution in its approach focused on new partnerships to tackle the scale of ambition in Barking & Dagenham, reports Lee Mallett
Be First, Barking & Dagenham Council’s regeneration arm, relaunched itself in February this year, which it described as ‘evolving into its next stage’ and has adopted ‘a new business model that prioritises public-private partnerships’.
Local authority regeneration companies have been established before but none are quite like BeFirst. Notably LB Tower Hamlets’ regeneration company Poplar HARCA was created in 1998. This focused mainly on the renewal of its parent authority’s ageing but considerable housing portfolio in Poplar. Be First was always a uniquely broader local authority-owned subsidiary in terms of what it was set up to do.
Its remit includes regeneration, economic development, commercial development, asset management, grant funding, estate decants, project delivery, building control, infrastructure, transport and policy, planning and design consultancy, design and sustainability, planning development management. This includes providing private planning consultancy services to clients outside the borough – earning money in other words.
Pretty much everything in fact to do with the built environment, but what raised eyebrows back in 2017, was the devolution of planning control to a separate company also in charge of economic regeneration and development. Wasn’t that like a fox being in charge of chickens?
This doesn’t seem to have been a problem in the subsequent eight years. BeFirst has assimilated some of the business acumen of the private sector and accommodate it within the ethos of the public sector – which is how it describes its modus operandi on the BeFirst website.
BeFirst has also won several awards along the way, for developments like Industria, the sustainable multi-story workspace scheme, being ranked joint first in the Planning Performance Tables for on-time major and non-major decisions by the former DLUHC (the Council’s statutory development management services having previously been at risk of ‘special measures’ prior to the establishment of
Lee Mallett
BeFirst), while Caroline Harper herself won the RTPI’s Inspirational Leader of the Year Award, when she was deputy MD for BeFirst in 2023.
That joint first position has been maintained for four years. And in that time a new Local Plan has been produced and adopted in 2024. Since 2017/28 planning permission has been granted for 28,000 homes in the borough. A substantial contribution to London and national housing targets, and making the borough one of the largest affordable housing developers in the UK.
The new incarnation moves BeFirst away from the Council directly delivering development to focus on establishing public-public and public-private partnerships, using the Council’s assets (which are considerable in portfolio terms across a range of uses) to facilitate growth.
Other changes include a slimmed down board and greater Council involvement and the appointment of Carline Harper as Interim Managing Director, replacing Geoff Raw, who took over from his predecessor Pat Hayes. Jeremy Grint is the new chair, having been chair of the Council’s housing management company, Reside and director of regeneration and economic development. Caroline Harper joined BeFirst (from private property consultant JLL) soon after its formation in 2017.
What is noticeable about the underpinnings of
ABOVE::
Caroline Harper, Be First’s interim managing director
Lee Mallett is a founder editor/publisher of PiL, an urban regeneration consultant and a committee member of the City Architecture Forum
BeFirst’s performance is ‘attitude’ – towards the role of planning in the development process. There is a desire to bring some ‘joy’ to the process of planning, rather than it be regarded as a barrier. Planning is regarded as a tool to delivery that supports good development and prevents bad. And because in that process many things are negotiable, this puts power into planners’ hands, rather than following the letter of policy. The commitment is to producing places that really work seems to underpin what BeFirst seeks to achieve.
Then there is the unique circumstance of statutory planning being delivered by a council-owned subsidiary company. This has meant that officers are exposed to colleagues who have had experience in the private sector, possibly working on projects outside the borough, which creates a slightly different perspective. Being more conscious, for example of the cost of the process to an applicant, or the implications of design issues on cost and programme, providing of course that working practices and priorities are appropriate and observed in the statutory process.
There has also been a renewal of the ‘back-up systems’ that support the work of planning officers. These had not been renewed for around 20 years. This was instrumental in achieving a corporate cultural shift that enhanced accountability and avoided double handling of data, making information available off-site, and rationalising case information into a single version of the facts. There was also a new focus on customer experience ensuring officers were contactable, with more digital information being made available to applicants and the establishment of a clear process for development management work, supported by the new office systems.
All these factors enabled the development management function to up its game and to get rid of
any backlog in applications and put a system in place for engagement with councillors and to work ahead. The appointment of new (and some younger) people and a focus on a team approach, with newcomers moving between departments to gain broader experience, has also helped transform performance and resources were also put in place resource to oversee the production of the new Local Plan.
The scale of the opportunity to deliver growth within the borough means Barking & Dagenham is a key element in delivering what the GLA and what Government policy wishes to see in terms of delivering 1.5m new homes within this Government’s term, and on the Mayor of London’s Growth Plan. Four of London’s 15 key industrial sites are located in the borough and two of its key housing delivery sites. London Riverside has scope for example for 39,000 homes.
This scale of opportunity can’t be delivered by BeFirst alone, hence the new emphasis on securing partnerships in BeFirst Phase2, working with investors and developers alongside the GLA and government.
The original model relied on development finance provided by the Council, but this no longer worked at the scale now envisaged to achieve the Barking & Dagenham 2040 vision. So no resting on laurels and the Local Plan will have to flex with what happens next.
In particular BeFirst hopes to unlock partnerships with more ‘patient capital’ sources focused on long term projects, which means the statutory planning function will have to offer as much confidence as it can to attract those partners. This also requires the borough’s political leadership to reaffirm that it is ‘pro-growth’ and as a Labour borough it is obviously aligned with the current Mayor and with national Government.
In terms of the proposed changes to statutory planning in the Planning & Infrastructure Bill, BeFirst is already ahead of the game. Training with members of planning committees is already in place with a thorough members’ briefing system.
It is the attitude however of being bold and getting the basics right that has already demonstrated
ABOVE:
Be First last year launched an investor video seeking partners to invest in The Factory District, based around Thames Road, Barking which will deliver 1300 homes in a co-living business and residential district, and includes the mult-level light industrial Industria scheme. BeFirst has identified around 400ha of potential development land for future industrial and resident expansion.
what can be achieved in getting the planning function working – which is helped considerably by the physical circumstances of the borough which is still tackling a decades-long post-industrial condition.
The scale of Barking & Dagenham’s opportunities means it is at the heart of what happens next for London, and the engine driving that must be a successful and capable statutory planning function. BeFirst’s example holds lessons for local authorities and planning departments everywhere. n
Planning has yet to take off FINCH
Labour seems remarkably coy about seizing opportunities which can make things happen quickly, writes Paul Finch
Our Labour government’s love-hate relationship with planning continues to stimulate and/or baffle those who taking an interest in the politics of the built environment.
Proposed legislation will limit the number of statutory consultees in the planning process, including quangos, many of which have been created or supported by Labour in the past, but which it now claims are a threat to the much-vaunted ‘growth agenda’ – which shows little sing of materialising so far.
Labour seems to have forgotten its own history in ways of approaching housing and city regeneration –scarcely if at all mentioning the only serious government work on this subject in recent decades, the Richard Rogers Urban Renaissance report (1999), which provides a well-considered proposition about how to create housing and revitalise cities.
Currently, Labour has no independent body at is disposal to which it can turn on these matters. This is curious for a party that, shortly after forming its first ever UK government, created the Royal Fine Art Commission in 1924. Seventy-five years after Ramsay MacDonald, Tony Blair’s first government replaced this with the Commission for Architecture & the Built Environment. This was eventually scrapped by an incoming Conservative administration, which also trumpeted a ‘bonfire of the quangos’ message.
Labour is currently fiddling with the UK National Planning Policy Framework as though it comprises the planning system, when in fact it was created in 2012 to cut through the Sargasso Sea of policies which have slowed down a system which has not changed fundamentally since its creation in 1947.
More usefully, funding has been pledged for an additional 300 planning officers, which will supposedly speed up permissions. As far as housing is concerned this is welcome news, because, we are heading for yet another historic low in both applications but more pertinently completions, making the government’s electoral pledge to deliver 1.5 million homes in its electoral lifetime look even less likely.
Clearly there will be some fudging of figures as the next election nears, plus a new blame game of why targets are not being met. Things to look out for include the absence of the phrase ‘net additional’ in
relation to housing figures. If a local authority estate is regenerated and, say, 500 homes are renewed, with 50 new dwellings added, the net additional is 50. I am anticipating that government figures will show 550.
Since net inward migration is likely, according to official forecasts, to result in a population increase of five million by 2040, housing shortfalls will exacerbate a disastrous situation, increase social tension, and magnify intergenerational inequity. Hey ho.
Another thing to watch out for will be a gradual switch from figures about completed homes to applications and approvals. This will then result in claims that housebuilders are ‘sitting on sites’ and ‘profiteering’ from not starting construction where
For an administration that is keen on growth ‘at pace’, the new government description of all its activities, Labour seems remarkably coy about seizing opportunities which can make things happen quickly.
permission has been granted. This accusation will happen partly because the political class has never understood the business model of housebuilders, and has no idea why they would not rush to build when there is scant demand – not because of a shortage of people who need housing, but because of mortgage availability and conditions, average salaries and so on.
The fantasy that the private sector can, would or even should deliver a public sector programme (for which read that often-bogus phrase ‘affordable housing’) continues to inform Labour thinking. They are proud of the fact that multiple applications have been made by organizations who want to development a so-called ‘new town’ in their area, but are short on detail when it comes to how these will be funded and delivered.
Real new towns are dependent on new infrastructure almost by definition. That takes a long time to
Paul
Finch is programme director of the World Festival of Architecture and joint publishing editor of Planning in London
deliver, and will not result in any significant denting of that 1.5 million homes target.
For an administration that is keen on growth ‘at pace’, the new government description of all its activities, Labour seems remarkably coy about seizing opportunities which can make things happen quickly. A good example is what is airport expansion, a tricky subject for Labour because of its previous prognostications about ‘net-zero’ and the artificial political posture of its former leader, Ed Miliband, on the subject. He hates aviation with a vengeance.
Nevertheless the Starmer government is backing Heathrow expansion plans with full support, even though it will take decades for anything to be delivered – and will involve destruction of villages, motorway construction nightmares, and further pursuit of a mad location for an international airport because of the requirement to fly constantly over a major city. Heathrow creates far more noise and other forms of pollution than any other capital city airport.
By contrast, the government is not (so far) giving a green light to the no-brainer expansion of London Gatwick. Instead, it has signalled amber, with more questions for the Gatwick owners to answer before a final decision this October. This is perverse, because Gatwick can increase its aircraft movements (takeoff and landing) from 55 to 70 per hour – if it is allowed to move an existing emergency runway 12 metres, to comply with international aviation rules. This runway will then be able to be used full-time, hence the increase in capacity.
This project could be built without undue difficulty, and probably within this government’s lifetime, generating a huge increase in jobs.
Why not get on with it? n
Housing provision – an alternative view on planning reform
We must reject the narrative that planning is the problem, says Chris Hinchliff
The origins of Britain’s planning system are as deeply rooted in the legacy of the great post-war Labour government as the National Health Service and welfare state.
The 1947 Town and Country Planning Act facilitated Labour’s historic council housebuilding programme and rebalanced power between wealthy landowners and workers. This policy embodies Labour values.
Now, amid a deep housing crisis, with over eight million people facing unmet housing needs, the government is seeking to reshape the planning system. But there is a key limitation in its approach: a narrow focus on increasing housing supply, when we already have substantially more homes per capita than we did 50 years ago.
We must reject the narrative that planning is the problem
In 1971 we had roughly one dwelling for every three people in the UK. Today there is one for every 2.2 people. Yet since 1971 UK house prices have risen by 3,878 per cent. England has seen 724,000 more net additional dwellings than new households since 2015.
The misdiagnosis on supply leads to the flawed conclusion that the solution to the housing crisis is cutting so-called red tape. In this case, red tape seems to mean democratic engagement in the planning process, meaningful community consultation and essential environmental protections.
The problem with the government’s open ear to HSBC, BlackRock and Phoenix on housing policy is that private finance will always prioritise profits over meeting housing needs. Our planning system has faced relentless attacks from developers, wellfunded lobbyists and their political mouthpieces precisely because it puts people before profit.
We must not allow the debate on planning to be reduced to superficial conversations about “builders vs blockers” when the reality is more complex. The overwhelming majority of planning applications are approved. The planning system often grants more permissions than the private sector delivers, with over a million homes granted planning permission in the past decade still yet to
be built.
Deregulation of the planning system will result in serious political risks for Labour. My constituents do not want to lose control over shaping their communities. Disempowerment erodes trust and breeds resentment.
And what will we have to show for it? The government still won’t be building the homes we need, as developers will continue maximising profits by drip-feeding developments into the system, keeping prices high and prioritising buy-to-rents, buildto-rents, luxury apartments and large executive homes over the affordable and council housing our
We should speak with confidence about the planning system – not as a blocker, but as an essential tool that can enable the construction of new communities that meet all the needs and aspirations of ordinary people
communities desperately need. Meanwhile, our wider economic model, including a monetary system in which credit creation by private banks causes massive asset-price inflation, will continue to push house prices further out of reach of ordinary people.
To tackle the housing crisis, we need a widereaching approach, incorporating economic reform alongside empowering local authorities. I am working on a range of amendments to the Planning and Infrastructure Bill, aiming to set out a clear progressive alternative for planning and housebuilding –one that, in the radical tradition of the 1947 Act, does not shy away from taking on the developer lobby. It is pro-building, pro-worker, pro-public health and pro-environment.
For instance, we must end the ‘call for sites’ approach to Local Plan making. Instead, councils
Chris Hinchliff
is Labour MP for North East Hertfordshire
should be empowered to proactively identify the best locations for meeting housing need in line with strict criteria for sustainable development and assemble this land as necessary, free from ‘hope value’ through expanded compulsory purchase powers. Let’s put an end to local authorities having to choose where development can go from suboptimal sites offered by wealthy landowners and developers, while also securing land value uplifts to fund desperately needed council housing alongside the parks, infrastructure and public services so often missing from new build estates.
The challenge for the left in the debate ahead is to refuse to allow the discussion on planning to be reduced to a narrow conversation, with developer demands for deregulation on one side and privileged land-owning voices on the other.
There is a case for improving the development consenting process – this must be coupled with improved funding for planning departments, which were hard-hit by Conservative austerity. But we must reject the narrative that planning is the problem; that the housing crisis is somehow Clement Attlee’s fault. We should speak with confidence about the planning system – not as a blocker, but as an essential tool that can enable the construction of new communities that meet all the needs and aspirations of ordinary people. n
The removal of 'beauty' from the NPPF
Katy Davis hopes that objectivity can be restored to planning decisions
One of the most significant changes made in the revised NPPF is the removal of the word 'beauty' from the title of Chapter 12. The title, previously Achieving well-designed and beautiful places has been amended to Achieving well-designed places. Other than two words, what has actually changed in planning policy and how will this impact on development decisions and the design quality of future homes?
Chapter 12 of the NPPF reduces, but does not entirely remove, references to ‘beauty’ and ‘beautiful’ and makes few other changes to this chapter otherwise, the chapter mostly referring to the process of applying the National Model Design Code. Elsewhere in the NPPF, paragraph 20 removes ‘to ensure outcomes support beauty and placemaking’ from the statement that ‘strategic policies should set out an overall strategy for the pattern, scale and design quality of places and make sufficient provision for housing, infrastructure, community facilities and conservation and enhancement of the environment’. In Chapter 8 (Promoting healthy and safe communities) the words ‘and beautiful buildings’ are removed from the phrase ‘Planning policies and decisions should aim to achieve healthy, inclusive and safe places’. The following paragraph goes on to say, ‘Which are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion – for example through the use of well-designed, clear and legible pedestrian and cycle routes, and high quality public space, which encourage the active and continual use of public areas’ – but removes ‘beautiful’ from this list. Is this a dumbing down of design, with priorities shifting from quality to quantity of homes, along with a renewed emphasis on social and affordable housing?
Speaking to The Guardian shortly after the NPPF’s changes were published, Secretary of State Angela Rayner said that proposed changes will not lead to ‘a load of ugly houses’. Rayner defended the decision to remove the requirement for new homes to be ‘beautiful’, claiming the word was preventing development and is too subjective.
On the point of subjectivity, I agree entirely. Planning is the opposite of subjective, being cen-
tred around objectivity and balance. The profession emerged as a set of rules which, through a structured and rational approach, manage the varying, wide-ranging and ever-changing demands of land use. As professionals facilitating the provision of more housing, and crucially more social and affordable housing, our role balances the social, economic and environmental needs within a clearly defined legislative structure. The term “beauty” was always going to be challenging to define and agree as part of a national framework.
It follows, therefore, that successful planning depends upon a strong and consistent legislative framework, the centre of which is the NPPF; it fails when that framework is weakened. And when this occurs, the supply of housing risks being reduced.
The basics of the planning system – what is permitted and how – have remained fairly constant since planning was ‘created’ with the 1947 Town and Country Planning Act. At the other end of the spectrum, the role of the Secretary of State, with the power to over-rule planning decisions, is much more precarious. The Secretary of State’s veto –and specifically the previous Secretary of State’s rejection of schemes on the basis of 'beauty' - is subjective in the extreme: subject to political pressure, interpretation and even the personality of the individual minister.
So are we likely to see a different approach under Labour? After two significant schemes were scuppered under the last government in relation to the nebulous issue of 'beauty' (a 165-home development by Berkeley Homes in Cranbrook, Kent and a 200-home scheme near Leamington Spa by AC Lloyd), it will be interesting to see how planning applications will fare under the new government.
Prior to the election Angela Rayner said that only “attractive homes” would be allowed in the party’s building blitz, as she set out a series of indicative designs (modern versions of Victorian
Katy Davis, is a Planning & Development Partner in Carter Jonas’ London office
terraces and suburban) aimed at reducing local opposition to development. She promised an end to ‘identikit homes’ and said that the 1.5 million homes Labour plans to build would include “only exemplary design with real character’.
However, it is interesting to note that the government’s ‘golden rules’ for released Green Belt (or 'grey belt') land don’t reference design. The pledge, with features in the revised NPPF, stipulates three types of contributions that schemes on green belt land released for development should deliver. The first of these is that ‘at least’ 50 per cent of housing provided by the scheme should be affordable, with an ‘appropriate’ proportion for social rent (subject to viability). Secondly, schemes should deliver ‘necessary improvements’ to local or national infrastructure and the provision of new or improved green spaces accessible to the public. For residential developments, new residents should be able to access good-quality green spaces within a ‘short walk of their home’, whether on-site or through access to off-site spaces. No reference is made to the design of the built environment. And yet presumably it is in the Green Belt that design is most sensitive.
Balancing priorities is something that we, as planning consultants, grapple with in our everyday work.
In the past few years many of us have been disappointed in the way that seemingly irrational decisions undermine our profession and our output. The fact that professional advice and opinions based on quantifiable evidence are ignored makes a mockery of the objective and evidence-based principles that govern planning and provides the necessary new homes. With a new government, and a new NPPF, we hope that objectivity can be restored to planning decisions. n
Fixing planning boosts growth
Sam Dumitriu on the economic impact of the housing crisis
Britain isn’t, and hasn’t in our lifetimes, been building enough homes. The impacts are easy to see. Children growing up in B&Bs, cramped and badly-designed one-bed office conversions being advertised for eye-watering sums on RightMove and Zoopla, young people stuck at home living with their parents into their 30s.
Harder to spot, but just as important are the economic costs. Britain’s most productive places, especially London, have the worst housing shortages. Londoners earn around 15% more than the national average. But after you take into account housing costs Londoners only take home 1% more than people around the rest of the UK. In other words, people are almost certainly turning down jobs where they’d earn more and be more productive because housing is too expensive.
At the heart of the housing shortage is a planning system that isn’t working. In some parts of Britain, London in particular, a new home can sell for twice the cost of actually building it. By granting planning permission for a plot of undeveloped, councillors have the power to create enormous value. Or put differently, existing restrictions on development whether they be the Green Belt or limits on height destroy value on an industrial scale.
Sir Keir Starmer’s Labour Government was elected on a pledge to change this. Bulldoze through the planning system’s red tape and get Britain building again. Building a lot in fact. The Government has pledged to build not just 1.5 million homes, but to also build Britain’s first reservoir in decades and enough energy infrastructure to get us to a clean grid by 2030.
To their credit, the Government has hit the ground running on planning reform. A new National Planning Policy Framework that raises housing targets, gives them teeth, and opens parts of the green belt up for development will mean more homes get built. A move to a ‘strategic approach’ to environmental protection will cut through the nutrient neutrality problem, while the power of planning committees to overrule (most) developments recommended for approval will give developers confidence.
The Office for Budget Responsibility reckons the changes to the NPPF will get an extra 170,000
homes built over the next five years and boost GDP by 0.2%. They’re yet to score the latter changes, but with, by some estimates, 100,000 homes delayed due to nutrient neutrality, it’s likely to provide a sizable boost to supply too.
Many economists and policy wonks, myself included, argue that the planning system is the number one barrier to growth in Britain. In that context, 0.2% may seem rather disappointing.
We should be careful here. First, the OBR’s forecast for growth from planning reform rises by 0.4% over a decade (and potentially by 0.6% due to benefits from increased worker mobility). Second, 170,000 new homes must be considered in the context of the UK’s 4 million or so home backlog compared to the rest of Western Europe. Third, the changes to the NPPF are important, but to really move the dial on planning reform much more needs to be done.
It is also important to avoid assuming all homes are equal. When it comes to growing the UK economy, that simply isn’t the case. The more homes we can build in places like Oxford, Cambridge, and, crucially, London the bigger the impact. That’s because London’s planning restrictions bite hardest. The gap between build costs and house prices is greatest in the capital. And the more affordable housing in London gets, the easier it will be for people to take that higher paying job away from home. And in turn, pay those extra taxes to the cash-starved Exchequer.
What we really need are policies to boost supply even further in London and other expensive cities. One issue to address is brownfield development –not just building on car parks and ex-industrial sites, but also redeveloping existing properties as is common around Europe. When New Zealand passed planning reforms that effectively created a permitted development right to build up six storeys high in walking distance of train and bus stations, it led to a supply boom and reduced rents by around a third of
Sam Dumitriu is the Head of Policy at Britain Remade
what they would have been had the policy not been implemented. The Government’s proposed Brownfield Passport is an opportunity to do something similar. There is enormous development potential around London’s stations that could really shift the dial and deliver 100,000s of homes.
London’s Strategic Industrial Land policy is worth challenging too. As it stands, it effectively bans development in extremely well-connected sites in London such as the new Old Oak Common HS2 station. Removing the designation in London’s best connected sites could unlock 10,000s of homes.
New Towns are unlikely to deliver growth in the next five years, but if done well they could be a serious contributor to housing supply in the 2030s. What’s key is we learn the lessons from the towns that succeeded and avoid repeating the mistakes that meant some towns failed. That means building them near strong job markets with housing shortages. In short, more Stevenage and Milton Keynes, less Skelmersdale.
Britain built up a massive housing backlog over decades. Our economic powerhouses are held back by expensive housing. There are no quick fixes here and we need a sustained period of growth in the stock of housing at rates Britain last reached in the 1930s. It won’t be easy, but the reward for succeeding is a stronger economy and billions more for schools, hospitals, and defence. I’d say that’s worth the effort. n
Britain Remade is a think tank campaigning to get Britain building again
The importance of planning enforcement
The lessons from Mast Quay by Amardip Healy
Imagine living next to a site where someone is illegally burning tyres, watching vacant land near your child’s school turn into a fly-tipping hotspot full of hazardous material or living in housing which fails to meet minimum safety standards. Planning enforcement is not about aesthetics or bureaucracy, it’s about protecting people’s lives.
At Mast Quay Phase II by the Royal Borough of Greenwich (RBG), enforcement was based on clear and precise allegations, identifying multiple material deviations from the approved scheme. The Planning
Inspectorate’s appeal process led to negotiations and agreements between the appellant and RBG, resulting in revised enforcement measures.
The appellant must now comply with conditions imposed by the Inspector including:
• Fire safety upgrades such as installation of fire lifts, automatic smoke vents, and fire-resistant materials.
• Improved accessibility, ensuring wheelchair access and inclusive design.
Amardip Healy is legal director at Blake Morgan LLP
• Public realm enhancements, such as landscaping and biodiversity net gains.
• Compliance with Section 106 obligations, including financial contributions for affordable housing and infrastructure.
RBG must actively monitor and enforce these conditions, ensuring that all remedial works are completed within the specified timelines. There is a significant amount of work ahead for both sides.
However, the Mast Quay case has sparked debate around how planning enforcement needs to function. The case raises three wider questions for developers and planning authorities:
1. Should councils act when enforcement may lead to the loss of housing?
2. Why did the council not intervene sooner?
3. Is the planning system under-resourced, allowing developers to get away with breaches?
Balancing enforcement with loss of housing
Some have argued that the priority in cases like Mast Quay should be preventing the loss of badly needed housing. However, the real question is whether demand for homes should come at the expense of safe, compliant housing. Weak enforcement only encourages further breaches, ultimately compromising public safety and trust in the planning system. If councils show a willingness to compromise on safety standards for new housing stock, it may give a greenlight for future schemes seek to skirt minimal standards in construction and apply cheaper retrospective fixes. Councils need to balance pragmatism in supporting new housing, while maintaining penalties to ensure that cutting corners does not pay in new developments.
Originally, the ‘Decent Homes Standard’ was introduced to address the poor state of council housing stock. The programme demonstrated that
regulation was a ‘vital security blanket’. If the developers fail, the public rightly expects regulators to step in and up. However, the regulators need a system where is not so easy to fail, and if there is failure, then the powers and resources to act quickly.
Intervening earlier in non-compliant schemes
It is important for the sector, Councils and Developers to reflect on the lessons from the appeal decision. Policymakers may need to consider how best to adapt and improve enforcement and planning processes, including ensuring compliance checks are not delayed, identifying issues earlier when they can be less costly to address.
Equally, providing more explicit guidance on how to handle retrospective planning applications, while maintaining the planning system's integrity, could help to rectify issues before they reach a Mast Quay stage.
There is a also case for strengthening conditions attached to planning permissions and ensuring enforceable timelines for rectification or compliance actions. Perhaps requiring additional community contributions or financial penalties when permissions are granted retrospectively. Doubling the application fee could be a start. The new Planning and Infrastructure Bill could provide the opportunities for achieving this. These are all steps which could make developers more deeply consider the consequences of breaches.
Managing resources in the planning system
The Mast Quay case raises the question of how planning enforcement moves forward within a challenging economic backdrop. Enforcement is a costly process. The total public inquiry costs were clearly substantial. With growing responsibilities, local planning authorities are advocating for better funding and resources but are subject to the financial pressures impacting local government across the
country. The sector needs to find ways of being innovative and managing a greater workload. They were the first to lead the way with aerial surveys, they have used heat mapping to identify ‘sheds with beds’. The use of advanced AI could be a game changer in terms of monitoring and enforcement capabilities, helping to deliver efficient planning enforcement. Again the Planning and Infrastructure Bill could be the used as the funding tool to help the public sector to deliver innovation.
Public policy requires planning enforcement to play a crucial role in maintaining the integrity of urban development and ensuring compliance with regulations. If enforcement is to remain a vital pillar of planning policy, it must evolve. The sector must learn from Mast Quay and push for a system that ensures compliance, accountability, and ultimately, safer communities.
What’s next?
Many will feel the decision serves as a deterrent against unauthorised development and encourages adherence to policies that prioritise public safety. Whether this proves to be the case will very much depend on RBG’s ability to manage and monitor compliance. It will require the developer to take responsibility, and to do what they say they would, rather than finding arguments not to.
Post decision, it must have crossed the developer’s mind that it would be easier to build the approved scheme rather than gamble. There is a lot of work ahead for both parties. How successful compliance will be will very much depend on resources on both sides.
If the system fails, it affects us all. The sector has a responsibility, and we should all be part of the solution. n IMAGES: Mast Quay as built – Comer Homes
Gateway 2 and the problem of time
The problem of time will lead to future poor decisions in this area of policy as politics and politicians, understandably, try to make up for lost time, says Ian Fletcher
The building safety issues that emanated from the Grenfell tragedy were not just an isolated incident. Subsequent audits by our members and wider building owners exposed a variety of serious problems with buildings, not just with cladding, but other inappropriate use of materials, or absence of firestopping. I am therefore no building safety reform denialist, and most decent developers would accept that change is needed, and that the new regime for High-Risk Buildings will deliver better building and safety outcomes.
It was only in April 2024, nearly seven years after Grenfell, that the new regime for High-Risk Buildings in development, what is known as Gateway 2, came into effect. A combination of Brexit, then pandemic, and turnover of ministers has meant that progress on a range of building safety issues has been slow. My fear in recent years is that Ministers are understandably keen to get things done, and that sometimes leads to poor decisions.
For example, originally, Dame Judith Hackitt –architect of the new regime - had recommended only applying it to buildings over 30m high. Instead, a political decision was taken that the new regime should start at 18m, thus bringing far more buildings in scope, and putting far more strain on new Building Safety Regulator (BSR) resources.
A critical aspect of the legislation implementing the new regime is the statutory timescales for processing an application. These are 12 weeks for new
buildings and 8 weeks for changes to existing buildings. During consultation on the new regime these were felt to be at the top end of what was tolerable by the development sector, without severely impacting on the development process. During consultation, the BPF also stressed the importance of ensuring that the new regime was well-resourced, bearing in mind the principle that the new regime would not be a tick-box exercise, but require the substantial transfer of documents (and underlying evidence) to the Regulator in a non-standardised format, and a regular dialogue between Building Safety Regulator and applicant.
Delays well beyond the statutory timescales have been well publicised. The table below is from a Freedom of Information (FOI) request. The statistics do not tell the whole story, however, as very few new developments have made it through the process yet, and we hear regularly of the Regulator asking for extensions of time, beyond statutory time periods.
The Regulator is acutely aware of the delays in the system and has been working hard to recover the situation. It has been bolstered by additional resource, and some of the ways it works, for example via multi-disciplinary teams, have been improved. Timescales for processing applications have been shortening. In the interests of transparency, however, I would argue the Regulator should regularly publish its performance figures, rather than these coming through a succession of FOIs.
Ian
Fletcher is Director of Policy (Real Estate) at the British Property Federation
Undoubtedly, the delays being seen, and anticipated, is having consequences. No developers want to start a residential project over 18m. It is regarded as too risky, and at a challenging time for most project viability. Projects are being delayed, mothballed, sometimes even sold. As Mark Reynolds, Co-Chair of the Construction Leadership Council, recently said in evidence to the HCLG Select Committee, “It is taking 24 to 28 weeks, and some are taking up to 40 to 48 weeks. People are being laid off. People are losing their jobs over this.”
Undoubtedly, the development industry is struggling with ethos of new regime. The BSR cites figures of 70% of applications being refused as either incomplete or wrong. There is a shared responsibility to ensure those engaged in development better understand what good looks like and work is being undertaken under the aegis of the Construction Leadership Council to develop better guidance. The Regulator will also build up a bank of case studies over time, which it will disseminate into the sector. All of this cannot come soon enough.
As said, respectable developers accept the ethos and intentions of the new regime. It is important to divorce policy from implementation, however. The problems being seen in processing applications are not about policy, but implementation. They could be attributed to ‘teething.’ Undoubtedly timescales are improving and will improve as practices at the Regulator and developers become more embedded. A very personal view, however, is that just as 12 weeks for a planning application is notional on large and more complex projects, so too will the statutory 12 weeks for the BSR to process applications on large and more complex projects.
I fear the problem of time will also lead to other future poor decisions in this area of policy as politics and politicians, understandably, try to make up for lost time. n
Reform of planning committees
Reform of planning committees is a feature of the Planning Bill published last month. Here Nick Diment looks at the consultation paper produced at the end of last year much of which has resurfaced in the Bill
In December last year the Ministry of Housing, Communities & Local Government (MHCLG) published the second in a series of working papers, on the topic of Planning Committees.
The paper invited views on how the government could reform planning committees to support a plan-led system and ensure appropriate democratic oversight.
The paper outlines three options for the faster delivery of quality new homes to achieve the government’s target of 1.5m new homes this Parliament – something that Keir Starmer has already identified as an ‘almighty challenge’.
The purpose of the change is to achieve greater standardisation, and in turn, greater certainty for all involved.
The working paper is not a formal consultation, but is intended to inform discussions within the sector, to determine whether and how to take these proposals forward. With the Planning and Infrastructure Bill due to be published next year, it would seem prudent to get those responses in soon rather than later.
Currently a disproportionately large number of planning applications are required to go before planning committee. This introduces considerable additional uncertainly as to whether proposed development schemes will materialise – despite the fact that the principle of development going ahead is technically secured through the Local Plan process. Delays, resubmission of planning application and potentially appeals can introduce significant costs and delays. Greater certainty is required to encourage developers to bring forward proposals (especially when viability might be impact by affordable housing and other requirements) and to speed up the process of development.”
Another benefit of planning committee reform may be to bring back some respect and prestige for officers, whose professional option that an application should be granted, are to often rejected at committee. This is particularly important at a time when LPA resources are stretched, and the industry is trying to attract new professional into the sector.
The white paper proposes three options: Option 1 – Delegation where an application com-
plies with development plan
Under this proposal, the planning application would be determined by officers, assuming that the planning proposal complies with development plan (conversely, if an application is a departure from the local plan, the local planning authority (LPA) would determine it at committee, as is done currently).
The complexity of this option which is common across all alternatives, is that it requires judgement on what complies, or does not comply, with the development plan,” says Nick. “Applying this judgement isn’t new for officers but now, more than ever, consensus needs to be reached between LPA and applicant. Careful consideration of whether policy is outdated and whether the local plan is up to date will be critical. Failure to do so correctly could lead to delays and potentially challenges.
Option 2 – Delegation as default with exceptions for departures from the development plan
The second option involves a national scheme of delegation requiring all planning decisions to be determined through delegated powers unless specific circumstances apply. This would enable committees to focus only on those applications which depart from the development plan and are recommended for approval by officers. It would also ensure, for propriety reasons, that decisions involving the LPA are made transparently.
This option could mean that high numbers of planning applications are determined by officers, rather than planning committees.
My concern is that this approach would be impacted by the fact that only about 35-40% of LPAs have up to date local plans. For those LPAs without a current local plan (the majority), 100% planning applications would be determined by committee – adding a considerable additional burden to those LPAs which are already considerably stretched. Additionally, in circumstances where the majority of planning applications are determined by officers, members will not have a role in determining applications for locally sensitive or controversial small-scale development. In these cases, planning merits are finely balanced in terms of the development plan, and historically officers have looked to the committee to make the final decision. An easy win would be to ensure all reserved matters applica-
Nick
Diment is a Director of Boyer (part of Leaders Romans Group)
tion are delegated following granting of the Outline planning consent.
Option 3 – Delegation as default with a prescriptive list of exceptions
The third option takes delegation a step further, requiring all applications to be delegated to officers. However, under this model, the national scheme of delegation would set out a prescriptive list of application types to be determined by committee, to provide certainty to applicants from the start. Such examples may include major residential or commercial development not on an allocated site; land on the Green Belt which triggers the exceptional circumstances test in the NPPF, and development that would cause substantial harm to a designated heritage asset.
Instead of focussing on whether a specific planning application complies or generally departs from the development plan, this option links to key common tests in national policy and development plans, with the intention of providing greater clarity and consistency to applicants. However, these common tests have yet to be agreed – who will set them, will they be consulted upon and can this be achieved without loopholes emerging in the system? Can such a radical departure really introduce clarity, and quickly?
A hybrid approach
A further option is that the three options outlined above are not mutually exclusive, offering the opportunity for a blended approach.
Dedicated committees for strategic development. It has also been proposed that dedicated committees could address strategic development issues – that proposals which will impact on the long-term future of a location will always be considered by elected members and not subject to the national scheme of delegation.
Committees would operate in addition to the main planning committee and would focus only on those developments that are critical to supporting local economic development and local housing need.
These committees could deal directly with, and have detailed knowledge of, specified strategic development opportunities. They could consider complex issues such as Section 106 agreements, and subsequent post-permission matters such as approval of design codes or reserved matters for key later phases.
Such strategic development requires longer term engagement by committee members and can involve consideration of many technical planning matters.
This approach is very complex and requires detailed working knowledge of the issues. Examples of such committees already exist but tend to cover a wide range of planning applications. I would suggest this option requires clear demarcation of roles/powers and an independent expert panel members or better still the committees could be part-staffed by professional commissioners on highly technical matters such as heritage.
Given the potential far reaching implications of such strategic applications, should this rest with councillors only?
Also, how would the selection criteria work? Surely all medium / large scale planning applications impact on the long-term future of a location?
Mandatory training for planning committee members
Finally, the working paper proposes mandatory training for planning committees. Something I believe all parties would welcome.
Consultation on these very significant changes should be welcomed. The proposals are far reaching, and the industry has a chance to influence real change. However, with so many variations on the theme of additional delegation, we are potentially spoilt for choice and may fail to unite behind the best option.
Whichever route is chosen, it needs to be transparent and ensure that there is no room for ambiguity or local interpretation.
Furthermore, a clear set of definitions will be critical. Careful consideration needs to be given to defining what is an up-to-date development plan, what is compliant with a development plan, what is a departure, what is a strategic development area and when it comes to strategic issues, what is the scope. Unless the emerging legislation is finely drafted by accomplished lawyers, I foresee considerable scope for appeal.
That said, there is a clear need for change and these proposals are a step in the right direction.” The proposal would require primary legislation, which will be implemented through the Planning and Infrastructure Bill. n
High street rental auctions
To what extent can this approach solve the problems on the high street? asks Simon Barry
It is right that the regeneration of our high street is a priority for the government: the vitality of a local high street has a significant knock-on impact on the broader economic and social value of our towns and cities.
But great minds from across retail, planning and regeneration have attempted to find a solution to the ‘perfect storm’ battering so many of our high streets and the failure to do so suggest that the solution is far from simple.
The suggestion by the government that ‘disengaged landlords’ are ‘sitting on empty properties’ highlights the complexity of property investment. No landlord wants their investment to remain vacant while maintenance bills mount or the property falls into disrepair: most would welcome any alternative.
But, as is demonstrated by the number of multi nationals, and independents closing on the high street and the fact that one in seven high street units is empty, the state of the high street is ultimately at the mercy of supply and demand factors. Boyer has first-hand experience of this and we are currently working for a number of clients regarding restaurants, pubs, coffee shops and general retail. We are aware that there are detailed considerations which need to be taken into account before any investment is made.
The previous government’s introduction of Class E was a bold move, using considerable deregulation of the planning system to encourage high street regeneration, allow a wider choice and support local demand. Whilst there has been some success in this and it inevitably increases the flexi-
Simon Barry is a Director of Boyer (part of Leaders Romans Group)
ble use, many properties remain empty.
It seems unlikely, therefore, given the flexibility of change of use and the considerable marketing that is invested in such properties, that an auction could resolve their fortunes. There are many broad, complex and ever-changing factors at play the government’s priority for high street regeneration must be to address them.
The ethos of ‘right to rent’ is a throw-back to Localism – itself an ineffective gesture to offer power to local communities which for a plethora of reasons failed to deliver.
I would question why a building which had been marketed for many months would attract interest at auction; whether landlords’ properties should be removed from their possession (albeit temporarily) when they have invested in both the bricks and mortar and the management and marketing of the unit, and how the new tenants would succeed where the professional landlord has failed.
Furthermore, do local authorities have the resources to do so, in terms of skills and finances? The perilous state of local authority finances would suggest not. n
BNG a year on
David Alborough sets out Carter Jonas’ analysis of implementation, variation, and future challenges
David Alborough is Joint National Lead of Carter Jonas’ Natural Capital Services Team based in Cambridge
A year after the initial implementation of biodiversity net gain (BNG) under the Environment Act 2021, national property consultancy Carter Jonas has published extensive research, Biodiversity Net Gain: Navigating the Evolving Market, exploring the impact of the change in the law on landowners, land managers, developers, local authorities and environmental organisations.
First introduced on 12 February 2024, the mandatory BNG policy requires that all new developments leave biodiversity in a measurably better state: by the statutory minimum requirement of 10% in most local planning authorities (LPAs).
Carter Jonas’ analysis of over 3,300 hectares of development sites across England finds the average habitat baseline value is 3.45 units per hectare. To achieve a 10% net gain on a typical 10-hectare site, developers must therefore enhance or create habitats to achieve at least 37.95 biodiversity units (BU).
The research also reveals that 54.7% of developments deliver BNG entirely on-site. Off-site solutions are either the developer’s own land bank, the purchase of biodiversity units from local or national landowners or third parties, or through the national statutory credit scheme as a last resort.
In this respect, the analysis shows considerable disparity across the country: the East and South East have established habitat banks, while other regions currently face shortages.
Variation exists not only between regional sites but also between different habitat types. However, the variation between greenfield and brownfield land is less than many anticipated. Greenfield sites have an average baseline of 3.60 BU/ha and brownfield sites 3.17 BU/ha.
Although the availability of biodiversity habitat banks is limited in some regions, the development industry’s response to the requirement for BNG has been demonstrably positive, with 69.4% of proposed schemes identifying BNG solutions at the point of submitting a planning application, despite BNG being a pre-commencement condition under the Environment Act.
Naturally, some challenges and potential for refinement have been identified during the first year. From a natural capital markets perspective, The industry has been slowly getting to grips with mandatory BNG over the past year and there are a couple of key issues coming through. Firstly, the invisibility of demand to potential suppliers. Developers of all types are having real difficulty in predicting their likely demand. This means that it is not clear to the likely providers if there will be a market for the units they want to produce. Thus, in some cases, they are not committing to schemes.
Secondly, this bias in the regulations towards on site mitigation is already causing problems, especially for smaller developers and developments. With the additional costs and risks being passed on to the owners of the houses which in turn will make them harder to sell, this risks making some developments unviable.
To solve these problems, firstly developers can use the research we have carried out to give them an estimate of their likely demand. They can then take this information to the market and let the market work out how to deal with any fluctuations. Secondly, government needs to review the bias towards on-site BNG for small developments because in reality impacts are far better mitigated off-site. If we can get this right, we will be on the way towards a properly functioning market which is in all our interests.
From a planning perspective, Richard Holliday, Associate in Carter Jonas’ Leeds office comments, “The take-up of BNG has been generally positive, with the majority of developers providing considerably in excess of the minimum requirement, perhaps due to other planning policy requirements or to err on the side of caution and avoid potentially costly repercussions if the final calculation falls short of 10%. However, if the government is suc-
cessful in meeting its ambitious housing target of 1.5 million homes within five years, demand will increase exponentially. On-site, this may pose issues in relation to density and viability. Off-site, demand may well exceed supply, at least initially.”
The government is currently consulting on a national land use strategy, and resulting policy changes may impact BNG. Lucy George, a Senior Natural Capital Advisor in Carter Jonas’ Natural Capital Services Team in York comments, “We live on an island and as such, there always has been and will continue to be conflicting, and complementary, demands on land. Land is ultimately in finite supply. Any land use policy needs to make sure the markets for nature-based solutions, including BNG, sit alongside economic growth and food security. Engaging in these evolving markets must be a strategic decision for landowners and habitat banking particularly should be viewed as a semi-permanent, if not permanent, land use change. It will be the right move for some but not all, and not only is the ecological capacity of land
important, but property due diligence is critical as part of site selection.”
Another potential change is the national rollout of Local Nature Recovery Strategies (LNRS). This is expected to influence market dynamics significantly, with LNRS attracting premium biodiversity unit values. Additionally, the extension of BNG requirements to Nationally Significant Infrastructure Projects (NSIPs) in November 2025 will intensify competition for biodiversity units.
BNG policy will continue to evolve, impacting differently on housing and infrastructure developers, landowners, LPAs, and environmental stakeholders. Carter Jonas will continue to monitor change, advising on BNG at a strategic, tactical and technical level, brokering biodiversity units, and supporting clients in their understanding of the evolving regulatory landscape. n
A copy of the research is at https://www.carterjonas.co.uk/research-and-insight/biodiversity-netgain-navigating-evolving-market
GDV is king!
For viability and Section 106 issues, the approach to deriving an agreed GDV will remain a huge challenge, explains Andrew Golland
Assessing gross development value (GDV) is arguably the most important step in viability assessment. This is because when the same dwelling is built across a range of locations its price will vary significantly, whilst its cost will not. This means that land values vary and why some local authorities can require high levels of Section 106 contribution whilst others cannot
The assessment of GDV for a new development is not straightforward. Yet it is hugely important and greatly disputed between developers and local planning authorities. I would argue that generally the issue is poorly dealt with.
This paper looks at how the process works, some of the key issues and dilemmas and how the pricing process can be improved.
New or second hand?
Perhaps the most important question is where do we get prices from for the subject development we are trying to come up with a GDV for?
The main dilemma here is that the second hand market is huge, has loads of transactions and hence effectively sets the tone' for prices in a particular settlement or neighbourhood.
This however does not immediately produce new build equivalent prices. But then the problem is that new build has very few examples from which to draw.
The assessor then has two options:
1 Use the large data set of second hand and apply a general new build premium. This can be done using mega data sets produced by HM Land Registry for example. Or:
2 Find a range of new build schemes which can then be applied to the subject scheme without adjustment for age. What tends to happen here however is that 'comparables' have to be drawn from an area rather wider than the subject scheme with the result that the assessor then ends up making location adjustments rather than age adjustments (as is the case with the former approach.
Of these two approaches, I think the former is more robust, because it picks up the important location specific sales and it always possible to apply an uplift for new build.
Where care is needed is that whilst new build premiums are often quoted in the press at a high level (10% across the board is typical) in practice the premium varies by dwelling type with smaller units (c.g. flats) commanding a higher premium than larger ones. With detached housing it is sometimes possible to observe a 'negative premium' where new build appears cheaper than second hand. What is going on here often is that the new build product is actually smaller by comparison than its second hand rival, moreover with the second hand often having greater amenity:
On the market or sold?
Should the assessor use comparables which are on the market or have been sold?
The dilemma here is that with sold properties we don't have to worry about the discount asked for by buyers of properties on the market. However, we do have to deal with sales that are sometimes long out of date, and in some instances took place during an entirely different part of the housing market cycle. This means that unless indexing is applied to take account of time gaps, then sold data can be misleading.
Current market data is arguably a much better measure for viability assessment but then adjustment has to be made for discounting the offers made by buyers to sellers. So whilst I believe there is less scope for inaccuracy here, the method is still not fool proof.
A further point of interest is the discount on new builds which developers usually hold as being small, but where the reason for this is that prices are being bolstered by incentives to cushion the market and sales.
The unit of assessment
Typically this is either by dwelling or by price per square metre (foot in old money).
Viability assessment has improved over the years and thankfully most assessments argue the toss on a 'per square mere basis'. This is critical because two sides presenting an example of say a 'detached house' could actually be comparing two very different entities.
It is important as well to note not only the price
Dr Andrew Golland specialises in the field of housing, planning and regeneration
per square metre but also the size of dwelling achieving that price, as prices per square metre genemily fall as dwellings get larger. I demonstrate this point below.
Old style expertise through to hedonic pricing
The previous govemment may have had enough of 'experts' but the viability assessment profession has not.
Developers rely to a significant extent on local agents and surveyors to give their professional opinion as to the value of a scheme and/or provide pricing for individual dwellings. The justification will be based on a whole range of experience including knowledge of the impacts of location, aspect, design and so on and this is invariably presented in such a way as to put the LPA on the back foot in negotiations.
The problem is that 'expert opinion' doesn't translate transparently to the pricing of new development. There is no systematic method for showing the impacts of each of the important drivers of value, whether size, location or amenity value.
The most transparent approach is what is known as hedonic pricing. This is where each of the drivers of values - location, size, design etc are weighted' within a (regression) equation, or given an individual value. This means deconstructing all influences of the pricing of dwelling and then utilising the power of each of the factors to re-build a price for a particular property. The analysis can indicate the additional value of being say closer to a school, or the loss of value of value of a property being close to say a major road.
This method is fully transparent (as it is 100% statistical) but not practical without large data sets. This simply does not happen within the often pressured time frames of viability assessment and nego-
tiation.
Towards a transparent and practical solution I have thought a lot about these pricing challenges and dilemmas over the years and have adopted an approach to pricing that I think is both practical and transparent. I explain it here
Below are 10 fictitious comparables - second hand local market.
I have then set out prices and dwellings sizes (again fictitious), and looked at the relationship between these two.
This generates a chart showing that as the size of dwellings increases, the price per square metre falls. This is critical and applies in most comparable analysis.
The key to this approach is that the equation generated (between price per square metre and dwelling size) can be applied to any local new development.
The figures in the lower table show how this works. As an example:
The 'Orchard" (2 Bed Terrace), then following the equation - minus 1.8308 x 66 (Sq M) = - 120.83.
Then apply the equation further - minus 120.83 + 3779.9 = £3,659 (price per square metre).
£3,779.9 x 66 (square metres) = f.241,498.
I have then made adjustment from asking to selling (0.95) and for new build (as the comparables are second hand) to get to an indicative new build selling price of £252,366.
Is this approach any good?
I have used this approach over several years now in viability assessment for scheme specific appraisals. It is widely accepted.
In the vast majority of cases, larger units sell at lower prices per square metre (foot) which makes the approach robust. In some markets, the line does not slope 'downwards', but upwards. This is principally in very high value areas (typically central London) where higher value dwellings command higher rates as the specification is normally higher, or indeed the features of these very high spec dwellings command a premium. So care is needed.
A common objection to the approach is that it is overly focused on scale of dwellings to derive prices.
But it is then overlooked that the comparison generates values per square metre that internalise a lot of driving factors - location, design, amenity, neighbourhood etc.
So, all the approach does then, is to utilise this information and apply it to a new build scheme. I think this is robust.
Conclusions
The fact is that the pricing of new build developments is an imperfect science. In my view simply relying on 'expert opinion' is not enough as this approach doesn't allow for a transparent transition from comparable data to the scheme itself. Something much learer is needed. This is why I have promoted the approach above.
This being stated, I accept that the approach is by no means perfect and the property industry should seck to find more robust and more transparent methods to sort out the assessment of GDV.
As ever, in so far as viability and Section 106 issues are at stake, the approach to deriving an agreed GDV will remain a huge challenge. n
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Fast-tracking of consents
The government has suggested fast-tracking of consents for new housing around “commuter transport hubs” and other “key areas”. Observers suggest that local development orders and proposed national development management policies could play a key role but warn that competing site uses around railway stations could limit the measure’s impact.
One of the most eye-catching recent planning announcements is a proposal to promote major new development around public transport hubs. According to a statement released jointly by chancellor Rachel Reeves and housing secretary Angela Rayner: “Untapped land near commuter transport hubs will be unlocked to build new housing for working people… the government will ensure that when developers submit an application for acceptable types of schemes in key areas – such as in highpotential locations near commuter transport hubs –the default answer to development is ‘yes’.” This would involve “streamlining a set of national policies for decision making to guide planning decisions taken by local authorities and promote housebuilding in key areas”.
The new measures could support higher-density housing coming forward on a wide range of sites and provide greater certainty for developers taking on schemes, industry commentators have suggested. However, the opportunities will be limited because of competing uses for the sites and environmental issues, they warned.
“The Planning and Infrastructure Bill was published in March, the new national development management policies expected in late spring and further revisions to the National Planning Policy Framework (NPPF) expected in summer could all help support development around public transport hubs. –Planning
Online directory of digital planning services launched
The digital planning directory is described on its newly-launched website here https://digitalplanningdirectory.org/ as a “one-stop shop" for digital planning services, and was seed funded by the MHCLG.
The directory’s stated objective is to “enhance transparency and knowledge-sharing in the digital
It’s a gas
The redevelopment of Bromley-by-Bow gasworks, a 23-acre brownfield site, has been approved by Newham council. The project, led by St William and Historic England, will transform the site into over 2,000 homes, a 4.2-acre public park, and new sustainable transport initiatives.
planning market, promote fair competition, and facilitate informed decision-making for those looking to adopt and use digital planning tools and services”.
The directory includes details of providers working in ten service areas, including visualisation, 3D modelling and animations and community engagement.
“Each listing includes detailed company profiles and case studies to provide users with actionable insights”, the organisation said.
Speaking at the launch the taskforce’s co-founder and chief executive officer Dr Wei Yang said the “main purpose” of the directory was to “break barriers” and to ensure that digital planning becomes “mainstream”. She added that there was a “huge market” for digital planning services.
The directory focuses on ten areas covering the “whole spectrum of spatial planning”, Yang went on to say, from ensuring the best environmental outcomes to optimising the plan-making and placemaking process.
According to the Digital Taskforce for Planning,
the “free online resource will be accessible to public and private sector stakeholders across the UK via its dedicated website”.
Joanna Key, director general for regeneration, housing and planning at MHCLG, said: “The launch of this digital planning directory ... is a crucial milestone in establishing local government as pioneers of digital planning.” Dr Wei Yang is a former president of the Royal Town Planning Institute.
The site has been built by the Digital Taskforce for Planning, a not-for-profit organisation established in 2021 to develop and implement the digitalisation of planning
Another day, another tax on development
The new building safety levy is a bad tax at the wrong time for UK housebuilding. It penalizes future generations for the mistakes of the past at a time when housebuilding is materially falling across the country. – Nick Cliff MD of Urban Sketch Ltd. n
¡¡ PILLO! PILLO!
Raised planning fees ‘will push firms out of housebuilding’
Trade body warns that Labour’s Planning and Infrastructure Bill, which gives power to local authorities to set their own fees, risks big increases.
Brian Berry, chief executive of the Federation of Master Builders, shared the concerns about increased costs. The MHCLG has indicated that money raised from local authority planning fees will be ringfenced.
“Any increase in planning fees needs to be matched by a better service and ideally not be levied against smaller housebuilders. The concern is that increased planning fees can put the viability of small sites at risk and stop development,” he said.
Berry raised further concerns that it will take time before smaller builders see any of the benefits being introduced by the planning bill, he said: “When they talk about the planning infrastructure bill speeding things up, I can see that overall it will. But when you’re talking about those small building companies, there’s a danger that they’re going to be left out unless it trickles all the way down. It takes time for that to happen.”
Small developers build about a quarter of the 200,000 to 240,000 new homes constructed each year. Official figures issued last month showed that planning approvals fell to a ten-year low last year, while the pace of housebuilding has fallen to the slowest rate since the financial crisis.
The MHCLG says the government remained “determined to get Britain building again so we can deliver our Plan for Change”.
It said the planning and infrastructure bill would “accelerate the delivery of critical infrastructure and unblock the clogged-up planning system that serves as a chokehold on growth”.
Berry said the government would not hit its target unless it does more to help small and medium-sized builders. “The only way they’re going to do that is by diversifying the housing market. I worry that it will take longer than they think it will to actually get the reforms through and then how it will trickle down to the local level.” – The Times
Commercial property?
The clamour to retrofit rather than rebuild is easing. Either way, net zero remains a worthwhile goal. But, please, less of the false marketing.
Takeoff for Luton
The government has approved plans to expand Luton Airport, despite environmental concerns. The expansion will double passenger numbers to 32 million annually and create up to 11,000 new jobs.
The idea that 'sustainable' development will slow global warming is risible. Given the worldwide scale of construction, net zero commercial development in Britain will have less impact on global temperatures than a bucket of water chucked into a volcano. Especially now.
– Peter Bill is author of Planet Property and Broken Homes and writes in PW
Labour strips environmental quangos of powers to delay housebuilding
The removal of powers to delay developments will help up to 150 major road, rail and energy projects, the government claims.
Under the new plans, developers will no longer need to undertake site-by-site mitigation measures but instead will contribute to a new Nature Restoration Fund to fund larger strategic interventions to protect natural ecosystems. Ministers claim the change will speed up and lower the cost of large-scale developments without weakening environmental protections.
The changes were included in the new Planning and Infrastructure Bill. Ministers hope the new law will also unlock housebuilding in areas hit by socalled nutrient neutrality rules.
Designed to protect the invertebrates eaten by protected birds, the rules ban developments where they could result in an increase in levels of nitrates and phosphates in wetland areas.
Tens of thousands of properties have had their planning permission withheld as a result of EUderived phosphate rules.
This has led to many developments being delayed, while industry estimates suggest 80,000 to 110,000 new homes are blocked due to the rules.
In future, developments in areas where nutrient neutrality rules would otherwise have applied will attract the nature restoration levy, which will be allocated to a central fund.
The exact amount paid by the developers is expected to be determined by the environmental regulator Natural England, which will undertake a strategic assessment to calculate the costs of offsetting the pollution created. n
Applications and Permissions down 7 per cent, residential applications down 10 per cent from the same quarter a year earlier
Latest planning performance by English districts and London boroughs: planning applications in England during October to December 2024
OVERVIEW
Between October to December 2024, district level planning authorities in England:
• received 79,000 applications for planning permission, down 7% from the same quarter a year earlier
• decided 75,400 applications for planning permission, down 7% from the same quarter a year earlier
• granted 64,900 decisions, down 6% from the same quarter a year earlier; this is equivalent to 86% of decisions, up 1 percentage point from the same quarter a year earlier
• decided 91% of major applications within 13 weeks or the agreed time, up 1 percentage point from the same quarter a year earlier; and decided 19% of major applications within the statutory period of 13 weeks, down 1 percentage point from the same quarter a year earlier;
• granted 7,400 residential applications, down 10% from the same quarter a year earlier
• granted 1,500 applications for commercial developments, down 13% from the same quarter a year earlier
• decided 37,800 householder development applications, down 7% from the same quarter a year earlier. This accounted for 50% of all decisions, unchanged from the same quarter a year earlier
In the year ending December 2024, district level planning authorities: granted 271,600 decisions, down 7% from the year ending December 2023
granted 30,200 residential applications, down 7% from the year ending December 2023
Planning applications received
During October to December 2024, authorities undertaking district level planning in England received 79,000 applications for planning permission, down 7% from the same quarter a year earlier. In the year ending December 2024, authorities received 330,500 planning applications, down 8% from the year ending December 2023 (Live Table P134, PS1 Dashboard).
Planning decisions
Authorities reported 75,400 decisions on planning applications in October to December 2024, down 7% from the same quarter a year earlier. In the year ending December 2024, authorities decided 316,100 planning applications, down 7% from the year ending December 2023 (Live Tables P120/P133/P134, PS1/PS2 Dashboard).
Applications granted
During October to December 2024, authorities granted 64,900 decisions, down 6% from the same quarter a year earlier. This represented 86% of all decisions, up 1 percentage point from the same quarter a year earlier. In the year ending December 2024, authorities granted 271,600 decisions, down 7% from the year ending December 2023. Authorities granted 86% of all decisions, unchanged from the year ending December 2023 (Live Tables P120/P133, PS2 Dashboard).
Applications on hand
Authorities reported that they had 108,900 applications on hand as at 1 October 2024, down 14% from the same quarter a year earlier. This is 44% above the number of decisions made during the quarter. The corresponding figure for the same quarter a year earlier was 57%. Taking account of numbers of applications received, decisions made and applications withdrawn during the quarter gives a total of 107,000 as at the end of December 2024, down 13% from the same quarter a year earlier (Live Table P133, PS1 dashboard).
Historical context
Figure 1 shows that, since about 2009-10, the numbers of applications received, decisions made
and applications granted have each followed a similar pattern. As well as the usual within-year pattern of peaks in the Summer (July to September quarter) and troughs in the Autumn and Winter (October to December and January to March quarters), there was a clear downward trend during the 2008 economic downturn, followed by a period of stability. There was a large dip in 2020 following the start of the pandemic and a subsequent recovery in early 2021, including a particular peak in applications received, but since the peak there has been a steep downward trend.
Regional breakdowns
Table 1 shows how numbers of applications received, decisions made and decisions granted varied by region. It also shows how the percentage of decisions granted varies widely by region, from 81% in London to 91% in North East (Live Table P133, PS1/PS2 Dashboard).
Decisions granted
Figure 2 summarises the distribution of the percentage of decisions granted across authorities for major, minor and other developments using box and whisker plots. The ends of the box are the upper and lower quartiles, meaning that 50% of local authorities fall within this range, with the horizontal line in the centre of the box representing the median. The whiskers are the two lines above and below the box that are 1.5 times the size of the box (the interquartile range) with the dots representing outliers. Figure 2 shows that the range between the whiskers for the percentage of applications granted is widest between authorities for major developments (50% to 100%), followed by minor developments (57% to 100%) and other
Planning decisions by development type, speed of decision and local planning authority.
All tables and figures can be found here: https://tinyurl.com/ycyj3h9v
Source: DLUHC/ONS
developments (70% to 100%) (PS2 Dashboard).
Speed of decisions
In October to December 2024, 91% of major applications were decided within 13 weeks or within the agreed time, up 1 percentage point from the same quarter a year earlier. 19% of major applications were decided within the statutory time period of 13 weeks, down 1 percentage point from the same quarter a year earlier.
In the same quarter, 88% of minor applications were decided within 8 weeks or within the agreed time, up 2 percentage points from the same quarter a year earlier. 42% of minor applications were decided within the statutory time period of 8 weeks, up 4 percentage points from the same quarter a year earlier.
Also in the same quarter, 91% of other applications were decided within 8 weeks or within the agreed time, up 1 percentage points from the same quarter a year earlier. 62% of other applications were decided within the statutory time period of 8 weeks, up 6 percentage points from the same quarter a year earlier.
Use of performance agreements
‘Performance agreement’ is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments. Between October to December 2024, 39% of all planning application decisions involved a performance agreement. Major developments were more likely to involve a performance agreement compared to minor and other developments with 77% of major decisions involving a planning agreement, compared with 50% of minor decisions and 32% of other decisions (Reference Table 2, PS2 Dashboard).
Figure 4 shows, from April 2010, the numbers of decisions on major, minor and other developments made involving a performance agreement, compared with numbers without a performance agreement. Notwithstanding definition changes, there has been a marked increase in the use of agreements since early 2013 (see Technical Notes for more information). This longer upward trend has been driven by both the additional scope for
recording them and their additional use (Live Table P120, PS2 Dashboard).
Performance of individual district level
local planning authorities
The existing approach to measuring the performance of authorities was introduced by the Growth and Infrastructure Act 2013 and is based on assessing local planning authorities’ performance on the speed and quality of their decisions on applications for major and non-major development. Where an authority is formally designated by the Secretary of State as underperforming, applicants have had the option of submitting their applications for major and non-major development (and connected applications) directly to the Planning Inspectorate (who act on behalf of the Secretary of State) for determination. See Improving planning performance: criteria for designation for more information.
Speed of decisions
The designation thresholds, below which a local planning authority is eligible for designation are:
For applications for major development: less than 60% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant.
For applications for non-major development: less than 70% of an authority’s decisions made
within the statutory determination period or such extended period as has been agreed in writing with the applicant.
See Live Tables P151/P153.
Quality of decisions
The threshold for designation on applications for both major and non-major development, above which a local planning authority is at risk of designation, is 10% of an authority’s total number of decisions on applications made during the assessment period being overturned at appeal.
Once the figures for the relevant period have been published in Live Table P152 or P154, which identify local planning authorities are at risk of designation by exceeding the threshold, they are invited to contact Departmental officials with any data corrections, and information on any exceptional circumstances applying to the authority that might be used as reasons why the Secretary of State should not designate them. The Secretary of State then takes this evidence into account when making decisions on which authorities should be designated. See Live Tables P152/P154.
Five local planning authorities are currently designated by the Secretary of State in relation to their planning performance. These are Uttlesford District Council (on 8 February 2022), Chorley Council (on 19 December 2023) and Lewes District Council (on 8 May 2024) in relation to quality of
decision-making for major applications; and St Albans City and District Council (on 6 March 2024) and Bristol City Council (on 6 March 2024) in relation to speed of decision-making for non-major applications.
Residential decisions
In October to December 2024, 9,800 decisions were made on applications for residential developments[footnote 3], of which 7,400 (75%) were granted. The number of residential decisions made was down 13% from the same quarter a year earlier, with the number granted down 10% from the same quarter a year earlier. 1,000 major residential decisions were granted, unchanged from the same quarter a year earlier and 6,400 minor residential decisions were granted, down 11% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard).
In the year ending December 2024, 41,700 decisions were made on applications for residential developments, of which 30,200 (72%) were granted. The number of residential decisions made was down 9% from the previous year, with the number granted down 7% from the year ending December 2023. 3,800 major residential decisions were granted, down 2% from the previous year and 26,400 minor residential decisions were granted, down 8% from the previous year.
Residential units
The figures collected by the Department are the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each application, such as the number of homes in the case of housing developments. The Department supplements this information by obtaining statistics on housing permissions from a contractor, Glenigan[footnote 4].
The latest provisional figures show that permission for 241,000 homes was given in the year to December 2024, down 3% from the 248,000 homes granted permission in the year to December 2023. On an ongoing basis, figures are revised to ensure that any duplicates are removed as far as possible, and also to include any projects that local planning authorities may not previously have processed: they are therefore subject to change, and the latest quarter’s provisional figures tend to be revised upwards. For the previous eight quarters, the year to figures have been revised 0.7% on average. These figures are provided here to give contextual information to users and are not Accredited National Statistics.
When considering the above figures in relation to statistics on housing supply, it should be noted that many permissions do not result in a home being delivered in practice. This is due to a range of reasons, relating to the circumstances of landown-
ers and developers, as well as the local and national economy. In addition, i) time lags in building can affect the number of homes built in a particular period; and ii) the methodology used cannot guarantee that all double counting of permissions is removed from the above figures.
In comparing the number of residential applications granted and the number of units granted, it should be noted that the two series measure different things and use data from different sources, and so may not track each other closely over the short term. More specifically, this difference is likely to be due to a combination of differences in the timing of recorded decisions and a difference in the average numbers of homes included within the relevant planning applications.
The above numbers of residential units granted planning permission include those granted permission through the planning appeals process. Alongside this, the Planning Inspectorate routinely publishes such figures using its own data. Such permissions can be granted either: i) through a local
planning authority’s decision to refuse a residential planning application being overturned on appeal, or ii) through a planning inspector granting a residential planning application in response to an appeal against the local planning authority’s failure to determine the application. Figures are published annually in Table 2.5a at Planning Inspectorate Quarterly and Annual Volume Statistics.
Commercial decisions
In October to December 2024, 1,700 decisions were made on applications for commercial developments[footnote 5], of which 1,500 (88%) were granted. The number of commercial decisions made was down 14% from the same quarter a year earlier, with the number granted down 13% from the same quarter a year earlier. 300 major commercial decisions were granted, down 23% from the same quarter a year earlier and 1,200 minor commercial decisions were granted, down 10% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard).
In the year ending December 2024, 7,100 decisions were made on applications for commercial developments, of which 6,300 (88%) were granted. The number of commercial decisions made was down 9% from the previous year, with the number granted down 8% from the year ending December 2023. 1,300 major commercial decisions were granted, down 12% from the previous year and 5,000 minor commercial decisions were granted, down 7% from the previous year.
Trends in the percentage of residential and commercial decisions granted SEE Fig 7 BELOW LEFT
Householder developments
Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (see Definitions section of the Technical Notes).
The number of decisions made on householder developments was 37,800 in the quarter ending December 2024, accounting for 50% of all decisions, unchanged from December 2023. Authorities granted 89% of these applications and decided 93% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard).
In the year ending December 2024, 161,200 decisions were made on applications for householder developments, accounting for 51% of all decisions, down from 53% of all decisions made in the year ending December 2023. Authorities granted 89% of these applications and decided 93% within eight weeks or the agreed time.
Major public service infrastructure development decisions
Since August 2021, major public service infrastructure developments broadly defined as major developments for schools, hospitals and criminal justice accommodation have been subject to an accelerated decision-making timetable.
Separate figures on major public service infrastructure development decisions have been collected on the quarterly PS2 return with effect from October 2021. During October to December 2024 there were 20 decisions, of which all 20 were granted and 19 were decided in time (Live Table MJPSI, PS2 Dashboard). Please note that figures are not collected on the CPS1/2 return and so don’t include education developments by county councils.
Permission in Principle/Technical
Details consent decisions
Since April 2017, local planning authorities have had the ability to grant permission in principle (PiP) to sites which have been entered on their brownfield land registers. Where sites have a grant
of permission in principle, applicants have been able to submit an application for Technical Details Consent (TDC) for development on these sites. In addition, since June 2018, it has also been possible to make an application for PiP for minor housingled development as a separate application, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC.
Figures on PiP/TDC decisions have been collected on the quarterly PS2 return from January 2020. During October to December 2024, local planning authorities reported 156 PiP (minor housing-led developments) decisions, 15 TDC (minor housingled developments) decisions and 3 TDC (major developments) decisions. The totals for the previous quarters have been similar although there has been a slow upward trend since 2020, when there were about 60 PiP decisions per quarter (Live Table PiP/TDC1, PS2 dashboard).
Permitted development rights
Planning permission for some types of development has been granted nationally through legislation, and the resulting rights are known as ‘permitted development rights’ (PDRs). For certain permitted development rights, if the legislation is complied with, developments can go ahead without the requirement to notify the local planning
authority. Hence no way of capturing this data exists and these are not accounted for in this report. In other cases, the permitted development right legislation requires an application to the local planning authority to determine whether or not prior approval is required and to determine as appropriate (see the Definitions section of the Technical Notes).
Between October to December 2024, 5,800 applications were reported, of which prior approval was not required for 2,900, permission was granted for 1,600, and 1,300 were refused. This resulted in an overall acceptance rate[footnote 6] of 77%. Large householder extension accounted for 53% of all PDR applications reported, with 28% relating to All others, 9% relating to Agricultural to residential, and 7% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2).
In the quarter to December 2024, 1,000 permitted development right applications were made for changes to residential use, of which 600 (63%) were given the go-ahead without having to go through the full planning process.
Overall during the 43 quarters ending December 2024, district planning authorities reported 350,800 applications for prior approvals for permitted developments. For 194,600 of them prior approval was not required, 83,600 were granted and 72,700 were refused (Live Table PDR2). n
Grey Belt, unblocking planning and ‘affordable housing’, the BNG regime and the London Plan
Account of the Forum meeting on Tuesday 25th March 2025 hosted by Dentons and in collaboration with CULS, the ACA and Planning in London Report by Brian Whiteley of RTPI’s Planning Aid England and Read.ai also at www.planninginlondon.com >LPDF
Grey Belt, unblocking planning and ‘affordable housing’, the BNG regime, the London Plan programme v.17/3
2.00 WELCOME
Michele Vas, partner, Dentons
2.05 GREY BELT POLICY AND ITS ROLE WITHIN THE GREEN BELT Lord Moylan recently chairman of the Lords Built Environment committee
2.40 KEYNOTE Brian Waters introduces William Burgon, MHCLG Director of Planning Q&A
3.20 HOW MIGHT CHANGES TO DEVELOPMENT MANAGEMENT AND GUIDANCE UNBLOCK PLANNING? HAS THE NPPF GONE FAR ENOUGH (YET)?
Mike Kiely, Chair Planning Officers Society
John Walker, CT Group formerly Westminster City Council
Emma Thorpe of Be First, Colin Wilson Head of Strategic Development LB Southwark and Paul Finch Panel discussion moderated by Lee Mallett
4.00
4.10 SUBSIDISED AFFORDABLE HOUSING: THE DIFFICULTY FOR DEVELOPERS IN FINDING AN RSL. AND WHAT LPAS ARE BUILDING – IS THERE A BETTER WAY? Prof Ben Clifford, Professor of Spatial Planning and Governance at UCL and a case study in Southwark by Phidel Adeleke of the House of Praise church Q&A
4.30 HOW IS THE BNG REGIME BEDDING IN AND HOW ARE DEVELOPERS RESPONDING, ESP. IN LONDON?
Dr. Nick White, head of BNG at Natural England
Mark Topping of Lanpro
Shashin Mishra of AiDash Q&A
5.00 THE CHANGING SITUATION AROUND STRATEGIC PLANNING AND HOW IT MIGHT HAVE AN IMPACT ON THE LONDON PLAN
Tom Venables of Prior + Partners Professor Michael Edwards, UCL: Good growth?
5.40 THE WIND-UP Paul Finch
5.50 NETWORKING & DRINKS courtesy of Dentons
AI summary
This is what Read.ai (lightly edited) made of the event
The discussion centered on the evolving landscape of planning and development, particularly in relation to the government's recent reforms aimed at facilitating growth. Key topics included the implications of the private infrastructure bill, the reintroduction of housing targets, and the government's commitment to updating national policy statements. Michelle Vas highlighted the importance of these reforms in streamlining decision-making processes for significant infrastructure projects, while Lord Moylan introduced the concept of the gray belt, which has implications for sustainable growth and development.
Concerns were raised regarding the government's approach to the Green Belt and ‘grey belt’, with clarification provided by a conference room participant that the committee is not opposed to development but seeks clarity on definitions and intentions. The recent mandate for local authorities to allocate Green Belt land for development if housing needs are unmet has sparked discussions about the relevance of gray belts. The need for clear distinctions between isolated sites and urban extensions was emphasized, as well as the impor-
tance of accessibility in urban development, which Ezra noted is crucial for successful urban extensions.
The challenges posed by the new devolution agenda and local government reorganization were also discussed, with concerns expressed by a conference room participant about the complications these changes introduce to funding and transport
ATTENDANCE
and
Committee BlaquiereGregEagle Planning & Development LtdDirector
LandPlanning Director
associate
of Planning
Catto Architects Ltd.Director
BenUCL Professor of Spatial Planning & Governance
Bond Dickenson
of Rural
Firma Capital PartnersAssociate
Logistics ConsultantsDirector EdwardsMichaelBartlett School, UCLHon Professor
Jigsaw Planning and Development LtdDirector
of CambridgeStudent
RobsonPartner
Festival of ArchitectureProgramme Director
ConsultingAssociate Director
& PartnersDirector
Meeting held on Tuesday 25th March 2025 and hosted by Dentons
issues. The conversation highlighted the potential for utilizing Greenbelt land for industrial purposes, suggesting a more sustainable approach to land use. Additionally, frustrations were voiced regarding the regulatory framework that allows Natural England to hinder housing development while permitting harmful agricultural practices, indicating a need for a reevaluation of the regulatory approach to resolve these conflicts.
Will Burgon (MHCLG Director of Planning) presented the government's planning reform strategy, which includes ambitious targets for housing and development consent orders. He acknowledged the challenges posed by frequent policy changes and emphasized the importance of maintaining a planled system for stability. The session concluded with discussions on the necessity of accelerating growth in the planning sector, particularly by supporting smaller developers and fostering ongoing dialogue. The need for cultural change within local authorities was identified as essential for long-term success in meeting housing demands and addressing the complexities of the planning system.
Chapters & Topics:
The session with a welcome, and the challenges of project constraints tied to 2030 ambitions were discussed by a conference room participant. The conversation included the need for better client engagement and the exploration of verifiable facts in project development. The significance of addressing judicial review implications was also mentioned by a conference room participant.
Planning System Reforms and Future Outlook
Michelle Vas of Dentons emphasized the importance of the current planning session, noting the government's aspirations for growth and the reforms being implemented to enhance the planning system. Key initiatives include the reintroduction of housing targets and measures to streamline decision-making for infrastructure projects. The session aims to explore how these changes will support sustainable growth and meet community needs.
Discussion on Green Belt Development and Planning
The Lords committee approached the Green Belt discussion without a NIMBY mindset, aiming to understand the government's stance on grey belts and development, explained Lord Moylan. It was noted by a conference room participant that the government’s recent provisions, which require local authorities to allocate Green Belt land if they cannot meet housing demands, represent a significant shift that complicates the distinction between green and grey belts. This has sparked a more open dialogue about development possibilities.
Discussion on Planning System and Urban Development
Lord Moylan thought that the planning system is equipped to handle current demands, though it may necessitate an increase in planning officers. He criticized the government's responses [to the Lords committee paper] as often inadequate, while Brian Waters pointed out that the grey belt concept is becoming more accepted in planning appeal decisiions. They both acknowledged that the success of urban extensions depends on accessibility and infrastructure, rather than just land value.
• There was discussion on the grey belt concept and its implications for planning and development.
Discussion on Local Government Reorganization and Planning Challenges
A conference room participant questioned whether the new devolution agenda would complicate funding and transport issues, especially with developers not adhering to agreements. It was noted that local government reorganization often leads to confusion and increased costs without delivering tangible benefits. The emphasis was placed on the need for effective planning rather than political motivations.
Discussion on Environmental Regulations and Housing Development
The absurdity of the current regulatory system was discussed, where Natural England restricts housing development due to agricultural pollution, while permits for farming practices remain unregulated. It was emphasized that the lack of political will over the past two decades has contributed to the ongoing issues in the planning and regulatory systems, leading to a slow realization of the problem by the housing sector.
Government Planning Reforms and Future Directions
Will Burgon outlined the government's guiding principles for planning reforms, focusing on the ambitious goal of delivering 1.5 million homes by the end of the Parliament. He noted the need for rapid policy changes to stabilize the planning system and facilitate effective delivery, while also addressing the balance between reform and maintaining a plan-led system.
• There was discussion on overview of the government's ambitious housing targets and the planning reforms needed to achieve them.
Planning Updates and Legislative Changes
The meeting highlighted significant updates to the National Planning Policy Framework (NPPF) and the Planning and Infrastructure Bill, emphasizing the need for local authorities to consider Greenbelt land
release when unable to meet housing targets. The government aims to streamline planning processes and enhance support for mixed tenure developments, which are expected to facilitate faster buildout times. Additionally, the bill proposes changes to planning committees to improve efficiency and support smaller developers.
• There were discussions on Examination of the Planning and Infrastructure Bill and its proposed changes to the planning system,
• The role of environmental delivery plans in addressing sustainability and development challenges and
• National vs. Local Planning Policies
Planning Sector Challenges and Opportunities
Three key areas for improvement in the planning sector were outlined: embracing policy changes, maintaining open communication with stakeholders, and fostering a positive culture within local authorities. It was noted that early signs indicate that recent government changes are positively impacting application processes. Additionally, the need for a cultural shift to support effective planning and development was acknowledged.
• There was discussion on culture in Local Authorities and
• The importance of training and delegation in planning committees to improve decision-making processes.
Community Engagement and Affordable Housing Challenges
Mike Kiely and John Walker discussed the delegation of planning decisions and the potential pressure on officers, noting that central government guidelines could alleviate local pressures. He highlighted the need for meaningful community engagement in NSIPs, while also recognizing the tension between national interests and local input. Additionally, he mentioned the government's commitment to increasing affordable housing and the complexities involved in balancing this with development viability.
• There were discussions on community Engagement in Planning and
• Affordable Housing Policies
Planning Challenges and Recommendations
Concerns were expressed about the impact of heritage assets and local authority regulations on development, particularly regarding taller buildings and brownfield sites. Criticism was directed at the lengthy processes in planning committees and the unnecessary complexities introduced by additional regulations. Support was voiced for the need for streamlined processes, with an emphasis on the importance of focusing on the substance of objections rather than their quantity.
• There were discussions on Planning Committee Operations and
• Cost implications of compliance versus avoidance in biodiversity management.
Planning System Efficiency and Local Authority Performance
Emma Thorpe of Be First provided insights into Be First's role in streamlining the planning process by combining various planning functions within a single team. She noted that many councils are establishing urban regeneration vehicles to maximize development potential, with Barking and Dagenham serving as a notable example. Additionally, the conversation underscored the significance of strong political and officer leadership in achieving planning efficiency.
Discussion on Affordable Housing and Planning Challenges
The critical role of subsidies in producing affordable housing was highlighted, with the statement that the current funding levels are insufficient to meet the UK's housing needs. It was pointed out that planning changes alone will not increase housing delivery, as the real issue lies in the lack of state support for social housing. These sentiments were echoed during the discussion, which included a review of the historical context of planning and the perception of building as a social good, a view that has shifted over time.
Planning Challenges and Opportunities in Barking and Dagenham
The difficulties Be First is encountering in direct housing delivery were emphasized, primarily due to high borrowing costs and insufficient grant funding. The discussion also touched on the necessity for a shift in development management strategies to embrace partnership working, as well as the political context that supports Be First's initiatives.
Planning Update and Team Engagement
Prof Ben Clifford thanked the UCL team for their research efforts, specifically acknowledging the work done with Janet Morphet. The conversation featured light-hearted banter and personal anecdotes, contributing to a friendly environment. There were also mentions of logistical challenges
and the need for better access to shared resources.
Update on Local Authority Housing Provision Research: The research highlights a steady increase in local authority housing delivery since 2017, with 94% of authorities involved in housing provision. While 79% are directly delivering homes, challenges such as rising construction costs and land availability persist. Additionally, 53% of authorities noted that retrofitting existing housing impacts new builds, reflecting a shift in priorities towards quality and design over profit generation.
• There were discussions on the role of partnership arrangements in housing delivery,
• Financial pressures on local authorities and
• Challenges in direct delivery of affordable housing
Planning and Housing Challenges
Brian Waters for Phidel Adeleke discussed a project involving the development of 43 flats and community facilities for a church in Camberwell Road, which has encountered delays since the planning permission was granted in November 2024 on an application made 4 years earlier. The project aims to provide a mix of affordable housing tenures, but finding a housing provider has proven challenging. Local authorities are also struggling with housing delivery due to various barriers, including land availability and financial viability.
Biodiversity Net Gain Overview
Dr Nick White from Natural England discussed the initial year of biodiversity net gain (BNG) and its impact on development practices. He noted that BNG is fostering earlier involvement of ecologists and greater collaboration among professionals, such as landscape architects and engineers. This shift encourages developers to retain and enhance existing natural features rather than starting from scratch.
Biodiversity Gain Update and Challenges
Nick provided an update on biodiversity gain (BNG) in London, emphasizing the need for offsite opportunities as there are currently no registered sites in the area. He mentioned the increase in national sites and the legal frameworks available for landowners, such as section 106 agreements and conservation covenants. Additionally, he pointed out the challenges smaller developers
face in adapting to BNG regulations, which require early planning and context understanding.
• There were discussions on Strategic advantages gained from effective biodiversity management practices.
Biodiversity Net Gain and Master Planning
Approaches
The significance of a landscape and ecology-led approach to master planning was highlighted, particularly in relation to biodiversity net gain (BNG). It was noted that traditional methods often fail to account for site context, resulting in expensive offsite BNG. By involving ecologists early in the planning process, developers can create more sustainable and commercially viable projects that enhance property value and ecological integrity.
Understanding Biodiversity Net Gain Challenges and Opportunities
Shashin Mishra outlined the challenges faced by developers in meeting Biodiversity Net Gain (BNG) requirements, particularly regarding data management and the need for accurate baselining. He highlighted the industry's shift from avoidance to compliance, with many now seeking to leverage technology for better data management. The discussion emphasized the potential for BNG to become a strategic advantage rather than merely a regulatory requirement.
Key Questions:
• How will the government ensure that the planning system can meet the ambitious housing targets?
• How does the government plan to address the challenges of the planning system?
• What are the key changes being made to the planning system to speed up housing delivery?
• What is the government's stance on the balance between national and local planning policies?
• How will the government address the issues of planning committee pressures?
• How can the government ensure that community engagement in NSIP processes is meaningful?
• What are the key barriers to direct delivery of housing identified by local authorities?
• How are local authorities managing the financial pressures related to housing delivery?
• How can technology be leveraged to create a competitive advantage in biodiversity management?
• How can developers effectively manage the costs associated with compliance versus avoidance?
• What are the long-term implications of not integrating biodiversity measurements early in the project lifecycle? n
Grey belt policy and its role within the green belt
Lord Moylan
First I need to talk about hats. I’m currently the opposition transport spokesman in the Lords, but I want to emphasise that I’m not here with that hat on, and you shouldn’t take anything I say as official opposition policy on the matters I’m discussing.
The reason I’m here is that until the end of January, I chaired the House of Lords Built Environment Select Committee for nearly three years. In the last few months of my term, we had a bit of a gap in our plans. The idea of the grey belt came out in September and, with my planning background, I found it intriguing. My committee decided it would be a good idea to conduct a short inquiry.
Long inquiries produce printed reports but short inquiries produce letters to the government, which they’re required to reply to. So, we conducted a short inquiry, produced a letter to the government, and it was released around
Good afternoon everyone, and welcome!
It’s a real pleasure to have you all here today. I’d like to start by extending a warm welcome all of you who’ve joined us for this afternoon's discussion and am looking forward to your participation in the Q and A events.
outlook is quite different from what the position was a year ago at last years conference and what is a critical time for planning; the government has made clear its aspirations for growth and development. A robust and effective planning system is central to achieving these goals. The way we manage and plan for growth today will determine the economic opportunities and quality of life for generations to come.
Since the government came into office in July 2024, we’ve seen a series of measures introduced, and proposed, aimed at reforming the planning system to better facilitate these ambitions. Most notably, the government has introduced the revised National Planning Policy Framework (NNPF) (and along with it the principle of grey belt which we will hear more about later today) and, more recently, issued the Planning and Infrastructure Bill. These ini-
Christmas.
Brian has access to that letter, which is a public document available through this link https://tinyurl.com/4r39yy97. By chance, the government, which is obliged to reply, did so last week. I’ve also sent the link https://tinyurl.com/3xaj8yjh to Brian so that all these documents are easily accessible to anyone here today who wants to see them.
You might be interested in knowing what we thought about the grey belt and what we included in the letter. I won’t read the entire thing or cover all the points, but I want to start with a negative statement. We didn’t approach the issue with any animus against development in the Green Belt. We weren’t a NIMBY committee. It was a cross-party committee. We weren’t a committee that set out to say everything must be done to stop development in the Green Belt. We were very open to ideas, but we were originally
tiatives represent a step forward, and no doubt we’ll be hearing from today’s speakers whether these reforms truly go far enough in addressing the challenges we face.
In addition, we’ve witnessed the re-introduction of housing targets, new towns, and, like Lazarus, the rise, once again, of proposed various forms of development corporations to drive forward the growth agenda and await the findings of the New Towns taskforce. The government is also re-invigorating the Cambridge to Oxford Arc as a critical area for
expansion, with a focus on unlocking its potential for innovation, housing, and economic growth.
At the local level, we’ve seen proposals for devolution and reforms to planning committees designed to improve the speed and efficiency of decision-making. These changes are seen as crucial to enhancing the economic growth we all hope to see, allowing us to better meet the demands of our communities and businesses.
On a national scale, the government has committed to regularly updating national policy statements and introducing measures that streamline the decision-making process for nationally significant infrastructure projects. These steps aim to reduce the ability of third parties to challenge decisions that are crucial for the timely delivery of infrastructure and housing. The de facto ban to onshore wind development has been removed, renewable energy sources are being promoted along with improved technological infrastructure such as data centres.
We have a lot to cover today, and I’m excited to hear the perspectives of our speakers, who will bring valuable insights on the reforms we’ve seen and the road ahead. Once again, thank you for being here, and I look forward to a productive and engaging discussion. n
Lord Moylan, recently chairman of the Lords built environment committee addresses the meeting
Michele Vas, Partner, Dentons
baffled by the concept of grey belts. The idea of building on previously developed land already existed, and there were already powers to allow development in the Green Belt in exceptional circumstances. We had seen development in the Green Belt, and we wondered what this new proposal would add.
The government seemed to talk about previously used sites like petrol stations, which would have high contamination costs and be relatively small. At the other end of the scale, for example abandoned airfields, many had already been developed, and no new powers were needed for that.
I came to the conclusion that possibly the government was being genuinely clever and was using the idea of grey belt development to shake up the debate and present development in the Green Belt in a different light. This idea challenged some of the very hard positions that existed, and I thought it was effective in dissolving them.
In my view, I don’t know how clever MHCLG is nowadays, but I believe that’s what its most important effect was. It didn’t really create a new planning category, as I’ll discuss in a moment. Instead, it fostered a much more open conversation than I thought had been the case before. When the NPPF was introduced, it contained a provision that seemed unrelated to the grey belt issue but ultimately undermined the entire concept. This provision stated that local authorities unable to make a five-year provision for residential or commercial demand within their area were obliged to allocate Green Belt land to it, specifically local authorities adjacent to the Green Belt. This meant they would have to allocate Green Belt land for residential or commercial development if they couldn’t accommodate it within their own urban areas.
However, this essentially destroyed the greay belt idea. It didn’t mandate the allocation of grey belt land or require prioritisation of previously developed sites, greybelt. Instead, it simply mandated the allocation of Green Belt land. This raises the question of where grey belt fits into the plan and what distinguishes it.
After all, once developed, it becomes difficult to determine whether a site was previously grey belt or Green Belt. There’s no way to tell if there was a factory or a green field there before development. The distinction essentially collapses. I believe this was a bold move by the government, and they seem to have got away with it.
Another outstanding question raised by grey belt, which I believe hasn’t been fully addressed, is that it implies the possibility of isolated sites within the Green Belt. However, I think they probably meant small urban extensions, which are adjacent to the existing urban environment and would be developed as extensions. These sites would be eas-
ier to service in terms of transport for local amenities and access to schools, if properly planned. Living on an old factory site surrounded by fields, three miles from the nearest shop, would be much more challenging. Urban extension was likely what they had in mind, but that was never resolved. The focus was on previously identified sites, which could be isolated, but I believe the ambition was more for modest urban extensions.
The entire process has been quite interesting to observe. We made a few other points. We don’t think it will significantly impact the housing market. As I mentioned, I believe the difference it has made is in the conversation about Green Belt development.
We also said, as we have in nearly every planning-related report we have produced, that we don’t believe the planning system has the resources to cope with the demands placed on it. This doesn’t necessarily mean more planning officers are the solution. There must be a limit to how much of the workforce is engaged in planning. It might mean asking planning officers to do less and delegating some of the regulatory responsibilities.
But that’s a story for another day. That was our perspective. We found it very interesting. The government’s reply doesn’t really address most of the important issues, but that’s par for the course. Government replies often provide answers that are simply cut and pasted from previous replies. So, while they may not directly address the question, they can provide answers that are related to it. That’s generally sufficient in government replies. However, it’s important to review the reply and form your own opinion.
I don’t believe it will make a significant difference unless it drives substantial urban extensions. And that’s not currently the government’s policy, I think, but it might become so. I’m happy to answer questions. I’m delighted to be here and to be able to say yes to Brian’s request. Now, it’s your turn for questions. n
Discussion
Chairman: I've got a question, and that is, I've heard a number of observers say what you've just said, that it’s a concept of great weight in itself may not have a direct impact. But actually, listening to Have I got planning news for you from Landmark members as one does...
Moylan: I saw Lord Banner on Temple station just 15 minutes ago.
...Well, lovely, but you can see him on YouTube tomorrow night as well. And we all can. But the point is that they have already got appeal decision letters where the inspectors have relied on the notion of a grey belt to justify the permission. So I think the discussion has got into the bloodstream. And just one little point, the two documents that
Lord Moylan refers to, when we report this in April's Planning in London magazine, I will certainly provide the links to them so that you can get them [SEE previous page].
Lord Moylan: You're quite right, Brian, it has entered the bloodstream, but the remarkably interesting thing, and this is the cleverness, I think, is that it's done so with far less protest than you might have expected, so far at least. I mean, that might be different when particular sites come forward and you get huge local protests, but I think it's gone through so far very much more smoothly than you might expect.
There is is a much bigger thing. After all, choosing the right place is just picking sites. The bigger question is whether the government is missing a trick by not using this change to take the chance to have a more coherent policy on the identification of land for sustainable development as opposed to picking sites that happen to have been previously developed or whatever it might be. And of course that's right but everyone talks about this notion of of sustainable development.
Everyone says why are you building a housing estate that is x miles from the school and where there is no bus service and everyone has to use the car to go everywhere and so and so on, but everyone carries on building them. And the truth is, I don't think there is either the intellectual capacity or the organizational structture to bring this ideal, if that's what it is, into effect. And the government is increasingly and will be increasingly driven by numbers as the days tick by and the 1,500,000 and the date of the next election start to converge, and the government is going to get more frantic about delivering its numbers.
Speaker 3
Duncan Bowie, loosely attached to UCL, formerly a planner at City Hall. Given your experience with the previous mayor of London, how do you think discussions about urban extensions on the edge of London, some of which would be outside the existing London boundary, how do you think they've actually progressed in terms of politics and the structures which don't currently exist?
Moylan: Well, I don't really know. If you look at the London Green Belt and you map onto it the boundaries of the Greater London Authority, of course, the great bulk of the London Green Belt is not in Greater London. But there is Green Belt inside the Greater London boundaries. There is designated Green Belt, especially around the northern side of the Greater London Authority area within the boundaries. And it is a good question unless parts of it are of astonishing beauty, it is a good question whether there is a case for still having Green Belt inside Great London Authority boundary, in my view.
Bowie: Sorry, is that answer adjacent to the question in terms of getting the shires to build new >>>
towns that feed London?
Moylan: Well I don't know, it is of course an adjacent answer, you're quite right, or it's an answer to an adjacent question, which is you can do a lot yourself without actually troubling Hertfordshire or Surrey, because there is a lot of land available to be developed. But you're always going to have difficulty getting local authorities outside London to agree to new towns.
As to large new towns, I used to be on the board of the Ebbsfleet Development Corporation and that might be regarded as a bit of an exception, but most of the successful new towns, the post-war ones, were established by authorities that had powers that I don't think would today pass the European Convention on Human Rights.
Mrs Rayner is trying to do something about basic land values, which is the idea of taking value that accrues to a private landowner, from a regulatory system admittedly, but taking value and stealing it from them by determining the value of that person's land and not using the market price. That I think is already on the edge of what will be admitted under the European Convention on Human Rights in terms of rights to private property. But if you have the sort of corporation that built Milton Keynes, basically they had completely draconian powers to build Milton Keynes. And I suspect that's sort of what it takes. When you compare that to the powers that the Ebbsfleet Development Corporation has, that's easier if the site is empty, it's previously unoccupied, and so on and so on, so there's less push and the local authorities are on side. But when you do look at it, powers are very, very much more limited.
Speaker 7
And I don't think that's through anxiety, I think it's through legal worry.
Moylan: But maybe we should just blast through and say, forget the European Convention on Human Rights, you know, put our banner up with Suella.
Speaker 9
Do you agree that the type of urban areas, Thames Estuary, South Essex and North Kent, which was mentioned absolutely, in terms of London, they're really strong candidates in low land value terms for focusing this grey belt concept?
Moylan: well, they are, but I also sort of have a transport background. And Ebbsfleet has a 19 minute connection to St Pancras and transport really is sort of everything. London's existing pattern, its growth, its development was built around the transport network largely, not the other way around. And so I agree that these places are very attractive, potentially in terms of land value, but they've got to have accessibility. Distance isn't the important thing. The important thing is accessibility and capacity. And a place like Ebbsfleet does have those things, obviously, because as I've just explained that station
takes you straight into St Pancras on the new HS1 line. But there are lots of other places that don't. The real value is in accessibility. Which leads me to the other point, that really it's not the development of the houses on the fringe of cities that matter, it's actually that the infrastructure is in to make that possible.
Speaker 12
Moylan: Yes, but all I was saying is it's possibly easier to extend existing infrastructure, which might just be a bus route, or an urban extension, than it is to give a decent service to an isolated grey belt site, six miles into the Green Belt with nothing around it and you know, no services or facilities at all, we're in just a country lane. Which is why the Thames Estuary is quite strong already, because if you weave together the rail networks and roads, actually the infrastructure is already there. And it would be perfect for a brand new airport to replace Heathrow. It's something I used to argue for and still believe in, yes.
Speaker 13
A slightly different question. Could you clarify what you think the differences are between the terms grey belt and brownfield, green belt and greenfield sites?
Moylan: To me, they're analogous. Well, if I were the Secretary of State for MHCLG, I'd feel obliged to answer that question, but I have the great liberty of being in opposition So I ask the questions and she gives the answers. And I don't have to answer it. I mean, I don't know, it's a matter of context. People tend to use the term brownfield when they're talking about sites being redeveloped, which are in urban areas. So one building is replacing another building. Grey belt was simply a way of trying to designate what existed within designated Green Belt that contributed very little to it in amenity terms, and therefore might be redeveloped. Does it come to the same thing in practice? I don't think so entirely, but I think that it's the difference of context that determines the different language rather than the definition.
Speaker 19
Do you think this overlaying new devolution agenda is going to complicate the whole shebang? Some like Kent are not doing it because they've been allowed to, some like East and West Sussex are doing it. Are we going to have a border control, a border on the transport front? When you look at what's gone on around Horsham and the amount of traffic it's generating, how on earth are we going to do it when developers are reneging on 106 agreements?
Moylan: Well, I don't know that I know what's behind all those questions. As far as the NPPF is concerned, you are right that there is and this is all within one ministry, so you'd think they'd have thought it through.
There is an unfortunate interaction with what you would refer to as devolution, I think, and the government does, and I call local government reorganisation, because that's what we've always called it, when you reorganise local government and you merge different tiers or you merge parallel authorities to make them bigger.
My general view is that local government reorganization should never be embarked on because the downsides are immediate, enduring, and palpable, whereas the upsides are entirely distant and largely theoretical. And the downsides are that everyone starts worrying about what their job is going to be rather than what the job is today and getting on with it. Huge costs are incurred in managing mergers and things like that.
And in London, every reorganisation of London boroughs has resulted in a new town hall. So you have to build a new town hall to mark the creation of this great new local authority. We have all our 1970s halls, the 1965 reorganisation, we have all of them, some been knocked down, our 1890s town halls from the creation of the metropolitan boroughs and so on. I'm sure if we reorganise London again we'd have another layer of town halls and that is your monument.
What actually changes? I don't know. To complicate the life of local authorities and local planning authorities by doing that, by making local plans more difficult to read, I mean the lack of local plans, but when you put local authorities together and you need to start with new local plans, presumably, then everything is being set back at just the time with the clock ticking that you want everything to be moving forward on the ground.
So I think there is a serious issue in the interaction of those two things. I don't think the reorganisation of local government is helpful at all. It's driven by political considerations, but nothing to do with planning. It's not helpful to the government's agenda of delivery.
Speaker 20
Do you think too much of the focus Grey belt was about housing delivery, given a lot of the Greenbelt in London was designated before its motorway network was built. So the M4 built in 1962, Hayes Bypass built in 1983, all through the Greenbelt in Ealing and in Hillington. And the way you have that Grey belt land next to the strategic motorway network, you have an opportunity to actually release it for industrial uses or distribution uses, particularly in Hounslow, Heathrow, and in North London. And in releasing that land, going to the point about sustainability, where it's accessing massive investments in strategic transport over the last half century, you could then release industrial land, which is closer to stations, say, on the Elizabeth line.
So rather than always thinking about it as hous-
ing, it might release other land for housing you could plan in a kind of more joined up, sustainable manner, and also make the most of the billions of pounds spent on building motorways, bypasses, and the Elizabeth Line.
Moylan: I think that sounds eminently sensible. I mean, the government and its predecessor are both driven by making up what they regard as a shortage, a serious shortage of housing and their focus is on housing all of the time. And you're quite right, there is a demand for other land. I don't think the grey belt was exclusively intended for housing. I think they'd have tolerated other sorts of development on grey belt land. But the focus, yes, what you're promising people is, we're going to build more houses and the price of houses will come down and it'll all be more affordable. You're not promising them more warehouses. Even though we may need warehouses, but that's not what people are interested in hearing about. So I think what you're saying is absolutely right.
You're left, of course, with the problem that reorganizing all these bits of land when they're in different ownerships, the whole planning system depends on landowners coming forward with proposals. There isn't a top-down reorganization, but if you had a top-down reorganization. I mean, we might as well be living in the Soviet Union as far as private property is concerned.
Speaker 21
I was at a very interesting talk last night where I learned that Be First, the experience in Barking and Dagenham, was in fact the future, and it was going to lead to all other powers, is this then not the case?
Moylan: I haven't entirely kept up with Be First. I know it's the development arm of Barking and Dagenham, but I'm not sure what your point is. It's not just that. It works as a planning authority. And building control. It works in that way. So they're doing all the local authority applications, all the master plan stuff as well. It's kind of interesting. It was quite a competitive thing.
Moylan: I started out with great admiration for the planning system developed in the post-war period but I reached the conclusion quite a long time ago that it's unfixable and anything changed by MHCLG is that they never give up. So anything that looks like it's an improvement in terms of smoothness or speed or flexibility is achieved simply by keeping all the regulations but moving them to a different part of the system. And never actually getting rid of anything.
And then apart from that, you've got the whole question of habitats regulations and whether we're willing to confront that. My committee, when I was chairing it, did a major report, called Environmental Regulation and Housebuilding, early last year, on the interaction between natural and local planning authorities, and how it had come to be that 14% of
England had a ban on residential development because of Natural England. But not because the housing made the natural situation worse, it's because that was all the farming and the sewage, not the houses.
That's the part of the system that Natural England had purchase on. And so that's the part they squeezed, even though the housing and how much, you know, domestic sewage does a house use? Compared to what farmers are generating but they have no purchase on farmers. This is a mad system as we set out. And then we're never willing to confront the root cause. The root cause with Natural England is the Habitats Regulations.There'd been a failure of regulation over quite a few years by the last government and probably Labour before that to actually confront the fact that there are licences issued by the Environment Agency which do and are now regulating the way that farmers will discharge. And I absolutely agree that we'd end up in a completely bonkers place. But it was a very long, slow train coming for a long time. And the house building sector just failed to see it coming.
Speaker 22
Why would the housebuilders have to see it coming? Well, no one was looking. I mean, the Water Framework Directive, all of those things, not just the Habitat Regulations, have been there for a long time. And these issues were raised in an Environment Agency report 20 years ago. And all I'm saying is that there are things that planning is going to do about sticking stuff in the right place. And there's a load of other regulation of other stuff, which other bits of government do. But if we choose not to regulate through other means, and make the planning regime do it, then we're all stuffed.
Moylan: I'm not disagreeing with what you're saying, but let me reframe what you're saying. What you're saying is you have two agencies of the state, huge, unaccountable, independent powers, both responsible in the same ministry. I think that's correct. Both responsible in the same way. One of which is issuing permits to farmers to put slurry into rivers. The other of which is stopping house builders putting up houses because the farmers have put slurry in the rivers. As if stopping builders putting houses up would make a material difference.
But that's it. That's the English system. And it's all driven as I say, fundamentally by the Habitats Regulations, the Water Services Directive 2 and so on, which still have force. And in fact, I can't remember which ones of them are carried over and which have been replaced. But in effect, the law has been carried on as it was. And nobody's been willing to confront that. Well, that's not quite true. The last Conservative government did make a very halfhearted effort, but in a procedurally cack-handed way, which meant that when it was defeated in the Lords, it couldn't be brought back, which is a very
unusual case for the Lords to actually make a decision, and the Commons can't do anything about it.
But nobody else has tried. Labour opposed it. But that's our system. And you more or less put your finger on. To deal with it, I don't think you can sort that out by moving a few bits here or there, you have to go to the root of it.
I suppose my point is that you choose to regulate the planning system, the regulatory system is sophisticated. There are lots of levers that can be pulled, but it takes an exercise of political will. And it's desire to actually make the right decisions across government. And that's what didn't happen for about 20 years. And that's why there's been a bit of a slow motion train wreck..
Chairman: I suggest we end on a rather constructive note!
And you have opened the floor to William Burgon, Director of Planning at the Ministry, who sends me a text message saying he's snuck in at the back of the room and has listened to all your pearls of wisdom.
Moylan: Yes, William, you came to give evidence to our committee, let me give you the floor.
Chairman: Just to point out that Natural England is also in the room. Well, they're everywhere. You stirred the pot brilliantly for the opening of the afternoon and I thank you very much for your time.
Thank you. n
The Government’s intentions for the planning system
Brian Waters, introduced the keynote speaker William Burgon, MHCLG Director of Planning Reform and Housing Quality
KEYNOTE ADDRESS
William Burgon split his presentation into four parts:
• Its manifesto clearly placed high priority on planning reform in order to speed up housing delivery and achieve its aim of 1.5 million new homes delivered during its first five years in office.
• Recognising the number of changes already introduced over recent years, the Government is not trying now to make further major system changes.
• This is especially the case with the plan-led approach’s retention, rather than adopting a more radical zoning system.
The current NPPF and Planning & Infrastructure (P&I) Bill -
• The NPPF has set mandatory, ramped up housing targets, and changed how these are calculated.
• If a five-year land supply (5YLS) presents difficulty, two avenues of land release are now open to local planning authorities (LPAs) – releasing grey belt and / or green belt land.
• In the NPPF the Government is trying to give added policy support to growth industries and infrastructure provision.
• The P&I Bill passed its second reading in the Commons on 24 March and reached the committee stage.
• The Bill proposes a Nature Restoration Fund which will free developers from a requirement to mitigate biodiversity loss on site. Natural England can now plan on a strategic scale and use developers’ contributions to implement its strategy.
• The Government is relying on Environmental Delivery Plans being in place by the start of 2026.
• Enactment of the P&I Bill is expected this Autumn.
What further measures are on the horizon this year –
• The Government is aware of the wide variety of schemes of delegation across LPAs. These can often hold up smaller housing schemes from progressing due to their need for scrutiny at committee level. It wants to introduce a national Scheme of Delegation so that small schemes in particular
are not subject to committee decision delays –ditto approval of reserved matters.
• Restricted committee sizes and mandatory training for committee Members are proposed.
• A new layer of strategic plans is proposed which will not rely on LPAs engaging in a Duty to Consult but rather rely on Mayoral decision taking. What can the built environment sector doWilliam Burgon suggested the sector should look to embrace the changes proposed – with increased delegation of decisions away from planning committees; and to fully engage in the Local Plan preparation process. He also welcomed continued discussions with MHCLG on how the system is working.
Questions & Answers - points which arose included:
• Peter Murray from New London Architecture noted the success of “Be First” in rapidly raising the efficiency of applications processing at LB Barking & Dagenham to assist regeneration and growth there, helped by supportive local Councillors.
• When asked whether national Development Management policies would take precedence over local ones, William Burgon confirmed this issue would be covered in forthcoming national consultations.
• He accepted there was a balance to be struck between local communities influencing the shaping of NSIPs and national priorities for their delivery.
• Similarly, there was tension in the level of public engagement which could be embraced when drawing up strategic plans – ultimately, the Secretary of State had to hold the final authority with these.
• Provision of sufficient affordable housing remains an issue; the Government wants to see greater provision as part of its housing target and has set a 50% requirement with Green Belt development; MHCLG is considering whether a quota might be set for its provision in smaller schemes and whether to set area differences for Local Plan targets. n
How might unblock pla
How might changes to developmen unblock planning? Has the NPPF go
John Walker of CT Group, former Director of Planning at Westminster City Council
• The NPPF is a step in the right direction, but whatever the proposals about Green Belt and Grey Belt, most development will still be on brownfield land.
• Guidance is needed on tall buildings - especially regarding their sustainability – as they are often the only viable option on sites.
• The Gateways building control scheme has effectively limited new buildings over 18 ms in height coming forward.
• He supports less committee involvement in decision taking; committees are often too slow in reaching decisions and over-involved in processes such as approval of reserved matters.
• Planning reports are currently too long – possibly to avoid later legal challenge – and have to cover a variety of factors which properly are the responsibility of other LPA services or organisations (e.g. SUDS, flood risk, or highways considerations).
• CIL should be abolished – it is a tax which has failed to bring in sufficient infrastructure for communities it is meant to benefit.
• Permitted Development rights are too complex now and the Use Classes Order unmanageable.
• Outline Planning Permission should be made much more simple – as red-lining an area for future development. Currently, too much supporting details are needed at the outline stage.
• National Development Policies are a welcome step – but where are they?
• He welcomed strategic planning coming to the
Two speakers gave their views
t changes anning?
nt management and guidance one far enough (yet)?
fore – giving developers greater certainty – rather than individual LPAs making decisions which often seem aimed more at local decision takers staying in power.
• For major schemes, Councillors should be made to engage in discussion with developers beforehand and be able to give in principle assurances.
Mike Kiely Chair, Planning Officers Society (pictured):
• Too much is loaded on planning decisions in the form of conditions required to ensure compliance with other legislation or regulations. Informatives about the need to comply with those requirements are as far as planning decision letters should go. It is then for other Council services or organisations to ensure compliance with their legislation or regulations.
• Permissions in Principle should be used to redline development sites – and help implement Local Plan policies or proposals. They do not rely on setting conditions, as with outline planning permissions.
• Planning applications now need too much supporting information – even for quite small proposals. It would be preferable to simply require submission of a design and access statement plus an explanation of the impacts of a proposal and any mitigation measures proposed.
• There is a basic legislative issue with planning consents. They can be negated if further later amendments are required (e.g. with a change in legislation requiring such things as additional or revised external cladding).
• “Departures” need to be properly defined in legislation. There is often an issue as a result about whether a scheme really is a departure from local policies.
• Section 106 agreements (S106s) cause too many disputes between LPAs and developers. There is a pro forma from the Bar Council which might help make handling S106s more systematic. Schedules or appendices to planning decision letters could list all the obligations required to be met. n
Panel discussion
Panel discussion moderated by Lee Mallett
John and Mike’s contributions were followed by a Panel discussion moderated by Lee Mallett.
The panel:
• Emma Thorpe of Be First
• Colin Wilson, Head of Strategic Development,
LB Southwark
• Paul Finch
Points which arose included:
• Colin Wilson views S106s as incapable of providing the amount of affordable housing at scale needed by London. Only State funding can help meet that scale of need. Affordable housing only offers a yield of around 1% and therefore will not get built without supporting subsidy.
• The social and economic costs of too little social housing provision are obvious – e.g. with the everincreasing welfare benefits bill.
• Planning changes alone will not increase housing provision. Active State intervention is required. In London two major boroughs, LB Barking & Dagenham and LB Southwark are seeking partnership working to invest in new housing provision. LB Southwark is buying land to provide more homes and jobs, using low-value land to deliver develop-
ment in the absence of central Government funding.
• One suggestion made was that the Government should consider issuing bonds based on the value of individual boroughs’ estates to help fund new housing provision.
• Brian Waters drew attention to paragraph 201 in the NPPF which reads:
“The focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Planning decisions should assume that these regimes will operate effectively. Equally, where a planning decision has been made on a particular development, the planning issues should not be revisited through the permitting regimes operated by pollution control authorities.”
It advises that LPAs must determine planning applications on planning grounds only – i.e. this gives them a means of sidelining other issues such as BNG or highways matters for decisions and enforcement by other appropriate bodies.
Subsidised affordable housing: the difficulty for developers in finding a registered social landlord and what LPAs are building – is there a better way?
Prof Ben Clifford, Professor of Spatial Planning and Governance at UCL outlined the findings or research carried out between 2017-23 in conjunction with Professor Janice Morphet:
• Local authorities are still providing some social housing themselves – around 10k pa. The London Boroughs have been the most active providers with the Mayor’s support being significantly important.
• Outside London Homes England play a similar support role, but it has no 5-year funding programme in place to draw up a pipeline for delivery.
• Joint venture schemes and now companies have been delivery vehicles used – but their numbers have lessened.
• Key barriers have included a lack of development land or of suitable sites; scheme viability concerns as housing grant levels are not high enough; shortages of skilled workers and building materials; and reliance on borrowing at a time of high interest rates.
By way of a case study, Brian Waters explained the background to a mixed use scheme including 43 flats, at the House of Praise Church in Camberwell Road, London SE5. Planning and LBC applications were submitted in November 2020 but only determined in October 2024. Part of the lengthy time involved was due to the difficulty of finding a Registered Social Landlord in an area needing more affordable housing.
Ben Clifford’s slides: Local authority direct provision of housing: research update
Professor Janice Morphet and Professor Ben Clifford Bartlett School of Planning, UCL j.morphet@ucl.ac.uk ben.clifford@ucl.ac.uk
Key desk survey findings
• Overall, there has been a steady increase in the level of housing activity across English local authorities in comparison with 2017
• 94% of local authorities are engaging with housing provision through at least one method and the range used by councils is gradually increasing
• 76% local authorities have affordable housing as a council corporate priority
• 14% of local authorities are Registered Providers
Key desk survey findings
• Programmes of development are increasing in some areas but may be reduced or extended in others by inflationary costs in construction
• There is a growth in housing acquisition
• Councils are still active in the use of their own companies and joint ventures with housing associations, developers and, in some cases other councils, to provide a range of housing
• The number of joint ventures and companies have reduced as an absolute number since 2021 although for some activity has increased
Key desk survey findings
• Despite higher costs and pressures on land availability, London Boroughs, supported by the Mayor of London’s application of the Affordable Housing Programme are still delivering more homes than other parts of England
• In London, the Boroughs can apply for funding for five year programmes, whereas elsewhere in England affordable housing funding is made available on a scheme-by-scheme basis through Homes England (some mayors of Combined Authorities are now starting to provide housing programme support)
Key direct survey findings
• 79% of local authorities self-reported that they were directly delivering housing, compared to 65% in our 2017 survey, 69% in 2019 and 80% in 2021
• Only 7% of local authorities responded that the recent S.114 notices had impacted their plans around direct delivery of housing
• 53% of authorities (81 answering – presumably all
stock owning authorities) reported that increased costs of retrofitting existing housing (for example in relation to fire safety, damp and/or mould) were impacting plans to deliver new housing
Key direct survey findings
• Meeting local housing requirements and tackling homelessness the top two motivations. Since 2017, quality of design seems to have become more important; income generation less so
• 52% of authorities reported having one or more local housing companies understood as a wholly owned or joint venture company focussed on the development of new housing
• 68% of authorities had a strategy beyond just relying on S.106 for affordable housing delivery (e.g. working with partners, using their land, building under PWLB /HRA)
Key direct survey findings
• The top three potential barriers to directly delivery more housing were lack of land (57% of respondents felt this was a challenge this time, and 59% in 2021), lack of suitable sites (56% of respondents felt this was a challenge this time, and 60% in 2021) and scheme viability concerns (56% of respondents felt this was a challenge this time, compared to 47% last time)
• Comment that affordable housing grant funding
not sufficient, particularly given grant levels per unit compared to actual build when wanting to build to higher environmental standards
Key direct survey findings
• For those authorities who are directly delivering housing, their own landholdings remain central to this activity: 95% are building on their own land (identical to our 2021 and 2019 surveys), 34% are purchasing sites to develop (a drop from 50% in 2021), 36% are purchasing existing residential buildings (a drop from the 43% in our 2021 and 42% in 2019 surveys), 14% are using land from the One Public Estate initiative (similar to the 16% in our 2021 and 2019 surveys) and 10% are using other public land (slightly down from the 16% indicating this in 2021 and 13% in 2019)
Key direct survey findings
• 50% of survey respondents were pessimistic about the future prospects of increasing (affordable) housing supply in their area compared to 23% who were pessimistic in 2021
• Those who remained optimistic highlighted factors
such as strong support for housing delivery across the council and strong political will driving this, strategic vision guiding this, affordable housing
development a real and high priority for many councils
Key direct survey findings
• Reasons for pessimism included the challenging economic context, increased borrowing costs, inflation of build costs, less income into the HRA through rent caps, that grant levels for affordable housing not sufficient to actually deliver (leading to a reliance on borrowing, and there are limits to capacity to do that), that it is impossible to crosssubsidise from market housing development to deliver sufficient affordable homes, that revenue
budget pressures on councils continue to grow, retrofit costs for existing stock reducing capacity for new build, as were net zero costs
Key direct survey findings
• Further concerns about labour shortages (particularly skilled construction workers) and supply shortages impacting the construction sector
• The continued existence of Right to Buy in England, including for new social housing built by councils, continues to cause widespread concern and a disincentive to reopen an HRA, although government announcements since we did our survey may not impact this positively
Conclusions
• Delivery of housing is now a mainstream local authority activity and seen as a core function again
• However, with congested priorities and a number of pressures around financing and build costs, activity has not significantly scaled-up since our 2021 report
• The extreme pressures of temporary accommodation funding are spurring more councils into action, and this along with short-term finance arrangements from central government may be behind the rapid rise in acquisitions
• Compared to 2017, more (most) councils now have some engagement (through a variety of means) with direct provision of housing and so a basis on which they could scale-up delivery in future; this must be a priority to actually meet (all) housing need across England. n >>>
How is the biodiversity net gain regime bedding in and how are developers responding, especially in London?
Dr. Nick White, Principal Advisor - Net Gain at Natural England:
• It is too early to assess the success of introducing the BNG requirement as it has only operated for one year to date.
• Green issues are less of an afterthought both in LPAs’ site allocations and in developers’ site designs.
• We now have 58 offset sites (covering 1600 ha) secured through S106s and conservation covenants. Some £400m of private investment is estimated to have been spent on habitats since 2020.
• No offset sites are yet in London – although the Thames, various water courses and Canal & River Trust sites are all potential locations – and there is no Responsible Body here.
Mark Topping of Lanpro:
• Believes BNG is readily deliverable if it is engaged with early enough in the development of a scheme – and it can add to the value of a final development.
• It cannot simply be ascribed to “leftover” parts of sites once the design process is almost completed.
• Challenges to obtaining BNG include the: - cost of land and consequent need to maximise built form on site
- cost of implementing and managing BNG sites for 30 years
- lack of suitable BNG sites in urban settings
Shashin Mishra of AiDash:
• Explained how his firm provide satellite imaging to assess BNG potential and a natural capital baseline against which to assess progress over 30 years.
LINKS:
Natural England - GOV.UK
Lanpro - Multi-Disciplinary Planning Consultancy
Together we safeguard critical infrastructure tosecure the future of humanAIty™
Onsite BNG
•Nature considered at site selection/outline design – detailed design
•BNG as a ‘team sport’ – ecologist, landscape architects, civil engineers, architects etc co-creating/designing
•Long-term management & maintenance (minimum 30 years) factored in
•BNG is new – it can be further improved
BNG Offsite Delivery
•56 registered offset sites in England (+1,500ha) as of 17 March ’25 – more constantly being onboarded
•Currently no registered offset sites in London
•No Responsible Body for London, unlike some city regions –LPAs cannot legally contract with themselves
•Landowners need market demand signals – what habitats, when and where
•More ‘niche’ habitats coming to market e.g. OMH, watercourses etc
BNG – Co-Benefits
•Established a new regulated nature market - estimated circa £400m private capital investment since 2020
•New income stream for farmers, parks & greenspace owners/managers, local government + others
•Wider ecosystem service benefits e.g. flood alleviation, urban cooling, health + well-being etc
•Technology start-ups + innovation – many London-based
•Versions of the biodiversity metric in use on every continent bar Antarctica
>>> BNG Delivery Issues
BNG IssuesSolutions
Variability of LPA advice•Support to LPAs and engagement through Planning Advisory Service (PAS)
•Defra + MHCLG engagement on guidance
Small Sites/SME developers•Promotion of availability of small/fractional offsite units and ability to source these, including via 3rd party digital products
•Small sites metric should not need checking by LPA ecologist (inherently low risk)
•Exploring scope to allow 'nature-rich' private gardens to secure additional onsite biodiversity units
Open Mosaic Habitat (OMH)•OMH starting to become available on net gain register
•Recommended use of metric 'Rule 4' (allows greater flexibility) where OMH offsite not available
•Need for better training/clearer definition of OMH
•Use of existing national (draft) OMH inventory – is it on inventory?
The Future
•BNG and the Nature Restoration Fund – are different
•BNG and Nationally Significant Infrastructure Projects (NSIPs) – 2026?
•Marine net gain?
Mark Topping of Lanpro
The changing situation around strategic planning and how it might have an impact on the London Plan
Tom Venables of Prior + Partners
• Explained how no strategic planning framework has been in place since the Localism Act, 2011. Strategic planning was considered to take too long and led to too many disputes between authorities and communities.
• Currently, the country has no clear spatial vision for its future development. Yet one is needed to coordinate future infrastructure provision with growth (e.g. to link the development of HS2 with potential New Town sites outside London).
• London has led the way on preparing a strategic plan for the whole city – with its simple survey, anal-
OPPORTU NITIES
• Competitive advantage by bringing BNG early in land acquisition process
• Process improvement to do better, faster & cheaper
• Better data management to support 30-year plans
ysis and plan approach. It has strayed though into Local Plan territory in terms of having too many detailed policies rather than remaining a high level strategic document.
• Now the Devolution White Paper and P&I Bill see a system of strategic plans covering the country by 2029. Liverpool is already showing how these plans might take shape – embracing a wider brief than land use issues alone, e.g. covering higher level health and welfare issues.
• Such plans could help steer future strategic infrastructure spending.
• They would need to be tightly prepared, have examinations proportionate to their scale and detail, and ideally cover functional economic areas rather
What is strategic planning?
than – as seems likely – areas based on existing counties’ and unitary authorities’ boundaries. Professor Michael Edwards, UCL: Good growth?
• He posed the question of what is “good” growth and noted the emphasis in the London Growth Plan 2025 for inclusive growth – which aims to prevent the current increasing gap between poor and affluent communities in our cities.
• As starting points, he viewed it important to stabilise land and housing prices and also to improve suburban transport connectivity across our cities.
Strategic plans provide long term spatial investment frameworks that help ensure that cross (local planning authority) boundary issues are addressed effectively and in an integrated way
They align spatial and infrastructure priorities with wider economic, environment and social objectives
They are not ‘big local plans’...
Tom Venables slides:
• Spatial Development Strategies (SDS) will be the new strategic planning model. These will be part of the statutory development plan. Only one currently being prepared (Liverpool CR). Can be used for decision-making where LP is out of date.
• SDS will be high level frameworks with clear links to other plans and strategies e.g. local growth plans, local transport plans, local nature recovery strategies but also to national priorities / infrastructure – they won’t allocate sites and won’t be based on the London or the Greater Manchester models
Housing targets set through standard method will be amalgamated to SDS scale with SPA responsible for distribution to LPAs.
• MSAs likely to have significant delivery tools to ensure SDS is implemented e.g. Strategic Infrastructure Tariff, DCOs, MDCs, call-in powers for strategic applications
A new generation of strategic plans
The Planning and Infrastructure Bill
Universal coverage of strategic plans across England expected by 2029 – needed to manage cross boundary issues and to ensure sum of the parts add up to a national picture.
• Strategic planning authorities will (initially) be combined authorities and upper tier authorities (counties and UAs) although the expectation is that all areas will eventually be represented by a Mayoral Strategic Authority Robust accountability needed to manage political risks.
Will the Government go as far as the London model with Mayors accountable for SDS? Not in the bill as drafted
What might / will a new generation SDS look like?
SDS = Clear 30 year (or longer) spatial vision set out on a Key Diagram (housing allocations, strategic development areas, strategic infrastructure (of all types)
• 4-5 pages of ‘policy’, probably no DM (depending on scope of NDMPs)
Key will be delivery and monitoring frameworks and other plans and strategies that set out priorities for economy, climate, environment etc
A new generation of strategic plans
The Planning and Infrastructure Bill
Professor Michael Edwards, UCL: Good growth?
• He posed the question of what is “good” growth and noted the emphasis in the London Growth Plan 2025 for inclusive growth – which aims to prevent the current increasing gap between poor and affluent communities in our cities.
• As starting points, he viewed it important to stabilise land and housing prices and also to improve suburban transport connectivity across our cities.
Michael Edwards’ slides >>>
Process for preparing SDS - Keeping the content tightly focussed (avoiding mission creep), proportionate evidence base, engagement (what does this look like in terms of ‘community’ engagement), examination, relationship with local plans – and minerals and waste plans
Inter-relationship with infrastructure / investment planning – alignment with NSIP regime & other investment strategies/plans. How do we ensure infrastructure providers are effectively engaged (including utility providers)?
Geography–largely being addressed through devolution but still some problem areas which are likely to be dictated by Government – could also see larger existing CAs. How will cross boundary issues be managed e.g. especially where MS A geography isn’t based on functional geography, where national infrastructure/new towns impact on more than one SDS area?
Decision making – clear accountability, effective, call-in powers or not and process for transition as devolution/LGR progress.What will the balance be between Mayoral powers v Strategic Authority powers i.e. what role will the LPAs play?
Key issues being considered
Timescale – Can the first generation of SDS be prepared in 2 years? What length of frameworks will help build investor confidence- 20-30 years? Review every 10 years with LPs reviewed more frequently?
Capacity and skills – a new generation of strategic planners, rebuild culture, current capacity/ capability. What is needed for a ‘core’ strategic planning team? How do we build knowledge around potential of strategic planning with decision-makers (councillors, Mayor)?
Implications of Devolution/LGR – what will the new emerging landscape mean for spatial planning generally and how will this be managed during transition? What does this mean for local plan preparation in two-tier areas?
Will the Government encourage frontrunners?
Implications for London
Requirement for SDS in London still under Part VIII of Greater London Authority Act 1999
Planning and Infrastructure Bill aligns with Greater London SDS requirements Alignment with surrounding authorities
Best practice – level of detail and process
Dealing with emerging growth issues - “Grey Belt” Need for larger scale / ambition? London and SE or National Spatial Plan?
Post growth London?
Grow GDP? What is the GLA up to? What to do instead Priorities for planning
Grow GDP? What’s wrong with it?
1.Growth on the current basis has proved inseparable from growing emissions, climate and ecological breakdowns. We can’t go on like this.
2.…accepts the market’s valuation of everything and of everyone’s work? In the depths of the pandemic we so often asserted that care workers, delivery staff and health workers were under-valued compared with bankers and lawyers.
3.GDP omits all the non-traded voluntary, reciprocal and family caring work done in the society.
4.Growth includes the costs of containing the damage caused by our behaviours : prisons and policing, decontamination, pollution control.
5. Asset value growth (notably house & land prices) feeds in to the estimation of the housing services enjoyed by owner-occupiers and the estimated ‘output’ of the real estate occupations; feeds inequalities.
What is the GLA up to?
•No more ‘good growth’. London Growth Plan 2025 section on infrastructure and housing says:
1.Set a long-term framework and plan for London’s infrastructure.
2.Rapidly build more homes, prioritising genuinely affordable homes.
3.Develop and implement a new London Plan which prioritises housing and growth.
4.Stabilise funding for London’s world-class public transport network.
5.Extend and upgrade the public transport network, prioritising projects to unlock new homes and growth.
6.Extend internet and digital connectivity.
7.Explore new potential energy sources to
8.power London’s growth.
9.Grow international travel connections.
Instead…
•Collaborate with Barcelona, Amsterdam & other cities trying to do better
•Acknowledge that London’s growth had produced poverty alongside wealth
•Re-think the “inclusive” in inclusive growth
Enforce minimum wage
• Seek output growth in the ordinary economy, not just by boosting FIRE
Focus on already-existing activity, not just startups
•Be prepared for decline of air travel
•And in the built environment…
Priorities for planning
•Be ready for a switch of national policy towards a focus on regional wellbeing
•Try to slow London’s physical expansion & infrastructure needs
•Try to stabilise house prices and development land prices
•…to contain growth of wealth inequalities
•…to lower costs of social house-building
•…to reduce pressure on green space, trees, other land uses, business
•Further develop suburban bus and orbital rail to help outer London business & workers
•Rent controls in PRS and ending of Right to Buy.
•Enforce upper limits on density to reduce over-bidding for sites
•Enforce affordable housing % until we can supercede S106 as funding for housing
The wind-up
Will the Mayor think these thoughts?
•Probably not.
•It will fall to professions, universities and civic networks
•Not enough is being done
More…
•Thanks to Prof Jess Ferm and Dr Matt Thompson who contributed to our article in the latest Planning in London
• Yvonne Rydin Planning without Growth published by Policy Press https://policy.bristoluniversitypress.co.uk/planning-without-growth
• Special Issue of Built Environment on post-growth planning https://www.alexandrinepress.co. built-environment
And from a banker economist Hans Stegeman https://www.triodos.co.uk/articles/2024/what-is-degrowth-or-post-growth-five-questions-abou major-economic-movement
And keep an eye on the Bartlett School of Planning EVENTS list https://www.ucl.ac.uk/bartlett/planning/events
The next meeting of the London Planning & Development Forum will be on Tuesday 10th June 2025
1.30 for 2.00 pm at Barr Gazettas 35 Heddon Street London W1B 4BP
To attend please just email editor@planninginlondon.com For the agenda nearer the date please also look at planninginlondon.com >LP&DF
In conclusion, Paul Finch summed up the key questions he thought were posed at the conference:
• Will the Government’s current initiatives fix the planning system – or is more radical change needed – e.g. by introducing zoning?
• Can we keep London dense and link its future intensified development to improved transport infrastructure?
• Can we develop a fresh generation of new towns to syphon off some of London’s continuing expansion?
• We need to identify empty and under-occupied housing and take (fiscal?) action to bring it back into full use.
• Prefabricated housing needs to be brought into play to help meet some housing demand.
• Planning changes still needed include: repeal CIL, no longer require viability assessments, and remove the expectation that the private sector will provide affordable housing.
• Lastly, a simple proposal: surcharge Councillors who do not follow officers’ recommendations at planning committees. n
With thanks to Dentons for their hospitality and to Brian Whiteley and Riette Oosthuizen for helping develop the programme
A tale of two curtilages ROGERS
Here we are again, examining the meaning of an undefined (in planning law) but very crucial planning term - crucial because The Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended) [GPDO] specifies that permitted development rights allowing householders to construct extensions and outbuildings only apply for any land that is designated as the curtilage of a dwellinghouse.
The Technical Guide to the GPDO (published in 2019 and surely in need of an update) does make clear that curtilage is land which forms part and parcel with a house - usually the area of land within which the house sits, or to which it is attached, such as the garden; but for some houses, especially in the case of properties with large gardens, it may be a smaller area. It is important to note that there is no rule about the size or extent of the area that can be designated as curtilage.
However, what can be constructed within the curtilage is limited by parameters set out in Class E of the GPDO and by the use that is proposed. This has to be incidental to the normal residential use of the dwellinghouse and must not be ancillary (ie similar to domestic uses of the house such as bedrooms), or of a materially different commercial nature (ie being used to run a successful business). This opens yet another set of controversial and ill-defined planning conundrums which I hope to deal with in a later column.
The last time I considered curtilage in these pages was April 2014 and there have been several appeals and court cases since then to throw more confusion and muddle into the mix (as so often with planning terms that are not properly defined). So this is an attempt to shed some light on the question of what is meant by domestic curtilage.
The owners of houses A and B have extended their gardens by purchasing land from their neighbours. It is evident for both that the land remains as domestic garden so there is no change of use requiring planning approval. (This would not be so if either piece of new garden had been purchased from an adjoining field comprising another use such as farmland.)
House A cannot use pd rights because its curtilage is marked by an existing boundary hedge and a stream. In the High Court case of Sumption v London Borough of Greenwich and Rokos [2007] it was emphasised that the Court of Appeal has established, as a matter of law, that the curtilage of a dwellinghouse cannot be expanded by simply annexing adjoining land. In Methuen-Campbell v Walters [1979] it was found that for land to fall within the curtilage of a building there must be an intimate association with it.
House B on the other hand is able to use pd rights because there is now no dividing hedge or fence and the curtilage can therefore be enlarged. The cultivated L-shaped garden forms part and parcel of the residential planning unit and serves the purpose of an amenity for the family living in
the house. The size of the garden area is taken as a matter of our old friend ‘fact and degree’: here the garden area, mostly lawn, is (as a matter of fact and degree) part of the dwellinghouse and its surround.
The new constructions illustrated could be outbuildings, such as garden sheds or hobby studios, swimming pools or sunrooms - but cannot include primary residential uses such as bedrooms or living rooms. More on this later.
curtilage n. An area of land attached and belonging to a house, etc. –Chambers Dictionary
A variant of Old French courtillage, from courtil ‘small court’. n
Andy Rogers is a planning consultant and former director in architects
The Manser Practice
Postcard from Cannes: reflections on MIPIM 2025
Félicie Krikler reflects on a last-minute trip to MIPIM, the intensity of the experience, and the event’s unique role in connecting the built environment on a global scale
Attending MIPIM is always an intense experience, but this year was particularly so. Having recently joined Barr Gazetas, my decision to go was a lastminute one, which meant a short, packed trip rather than the usual four or five days. That only heightened the intensity, but also the impact.
For anyone in the industry who hasn’t been, MIPIM is worth attending at least once – if nothing else, for the experience. There is nowhere better to see the full interconnection of the built environment sector in action.
I’ve always pictured it as a kind of marine food chain, where every part of the industry – investors, developers, lawyers, architects, consultants, recruiters – plays a role, from the biggest fish to the smallest minnows. That’s my romanticised
impression, anyway. But MIPIM is about much more than that.
It covers everything from government initiatives showcasing how the UK, its regions, and its cities are working to attract investment, through to the full spectrum of built environment professionals – investors, developers, lawyers, architects, consultants, recruiters, and everyone in between.
The global scope of MIPIM is also incredible, offering a snapshot of the construction industry on a worldwide scale. It’s fascinating to see this network in action. It’s a reminder not just of where we fit, but also of how we might need to reach beyond our usual networks and collaborators.
More than anything, MIPIM is a place for conversations. Everyone is there to talk, to share ideas,
Félicie
Krikler is Director, Head of Residential with architects Barr Gazetas
to explain what they are trying to achieve. There’s an openness to the discussions that isn’t always present elsewhere.
While the event is often criticised – particularly for not always being the friendliest place for women – I’ve always found that some of the best and most interesting people in the industry are gathered there.
And, of course, there’s the setting. Being in the south of France for a few days, however decadent it might seem, gives MIPIM its own unique atmosphere. This year, though, the weather had other ideas.
It rained so much that any hopes of enjoying the outdoors were quickly washed away – perhaps, as some joked, a curse sent by UKREiiF’s organising committee! Even so, the event remains a fascinating experience, not least because of the strange and wonderful places around Cannes where attendees end up staying (my sketch, attached, provides some evidence).
For me, this year’s trip was particularly different. Starting at a new practice meant bringing together contacts from different sectors, bridging what can sometimes feel like two separate worlds – commercial and residential. It also meant a lot of introductions, a lot of human stitching to connect people who wouldn’t otherwise meet.
That, ultimately, is what makes MIPIM such a valuable tool – a place where, in the space of a few days, the conversations you need to have can happen all at once.
Now, heading back to London via a weekend stop in Lyon to visit my son on his university exchange, I can confirm: it’s been a whirlwind. But, as always, a trip worth making. n
First published in Building Design with kind consent
Nicholas Falk and Reg Harman show why investment in light rail transit is critical to national recovery and the growth and renewal of our major cities
Light rail transit for urban renewal
In parallel with increasing economic growth, the Labour government has committed to building 1.5 million more homes during the present parliament. This figure was set out by Sir Keir Starmer at the party conference in October 2023 and included in the 2024 election manifesto. It is a very ambitious goal: it amounts to increasing the dwelling stock by a figure of 300,000 new homes a year, including new houses and flats and conversions of existing buildings less dwellings demolished or converted. The previous Conservative government also aimed to build 300,000 new homes a year but only managed 235,000 in both 2021-22 and 2022-23. The numbers have been falling as volume housebuilders respond to a drop in housing demand and fears about mortgage costs, while local authorities are overloaded with pressures they cannot meet.
Its achievement is to be helped through planning reforms by updating the National Planning Policy Framework, the release of ‘lower quality’ green belt land, the reintroduction of mandatory housing targets for local authorities, and the development of New Towns, probably as urban extensions. But no mention is made of transport and accessibility, which are crucial to the effective functioning of urban areas in economic and social terms. This article suggests how spatial planning and transport could work far more effectively together, with light rail –
tramways and light metro – at the core.
Density and transport
Development and infrastructure need to be joined up in urban conurbations. Congestion is a burning issue, like housing costs, but not generally understood.. Public transport outside London lags decades behind our European competitors, which helps explain the UK’s poor economic performance1 Good quality integrated transport is essential to achieving the wider aims of the housing goals – higher productivity and better quality of life. It is also vital to cutting carbon emissions and improving public health through reduced air pollution and stress. The revival of East London has been enabled through investments such as the Docklands Light Railway (DLR), and latterly the London Overground. This has increased rail usage in East London dramatically accelerated house building around stations such as Dalston, and is turning development at Barking Riverside into what could become a New Town.
There is little point setting targets without overcoming the persistent obstacles, ranging from fractured and demoralised local authorities to a huge infrastructure deficit and a shortage of skilled people working in urban and strategic planning and in public and sustainable transport. There is little value in building
TOP: Dr Nick Falk of the Urbed Trust
BELOW: Reg Harman of Interfaces
RIGHT:
Nottingham – light rail at the heart of city life
Nicholas Falk
new homes if the current dominance of car use means that working residents spend too much time in traffic jams, cyclists are endangered, and the conditions for walking are highly unpleasant. Yet development in the green belt and urban fringe areas could lead to further car-dependant housing estates on the edge of towns or isolated in rural settings, as authoritative research studies by the RTPI and the campaigning group Transport for New Homes have warned.2
It follows that the government’s plans to provide more affordable homes and boost overall productivity should be based on growing or intensifying development around high quality high capacity public transport, which is where light rail transit scores. . To be attractive and effective enough to counter the car culture, these must be integrated and based round a core of tramways and local rail to provide the reliability and comfort that frequent travellers require. Some will serve newly built housing outside existing urban areas. Local rail lines might also be converted to tramway lines or used on the the SwiftRail principles previously suggested by the authors.3 But we must also build to higher densities and make better use of land too often occupied by sheds that generate few jobs or tax revenue.
How light rail adds value
Persuasive reports in recent years have highlighted the benefits from tramways, such as Leading Light: What Light Rail can do for City Regions from the Urban Transport Group.4 However, potential sponsors and constructors face serious obstacles. Back on Track: how to build new trams in the UK and get Britain moving, published by campaign group Britain Remade, highlighted the excessive time and cost it has taken to build tramways and similar schemes in Britain. It noted the average cost per mile as £87 million, compared to an average of £42 million across the European continent.5 Tight control of spend-
ing decisions by the Treasury has not stopped costs ballooning.
Four lessons stand out from research into why European cities have outperformed their English equivalents: Britain is much more centralised than its European neighbours and the cities with the highest economic growth. Authorities in cities and city regions across the Continent have clear responsibility for most key decisions on spatial development, transport and related fields, plus the funding powers and levels to make things happen. They can thus better judge the relative opportunities and benefits within the overall context and implement projects to achieve them.
• There has been little strategic planning in Britain in recent years and thus every decision is taken in isolation. This contrasts with, for example, the French approach where local public transport strategies are joined up or ‘aligned’ with planning for city regions. Zones d’ Amenagement Concerte and Territorial Contacts provide investors with greater certainty.
Land Assembly Zones are now being promoted in the London Mayor’s Manifesto.6
• Funding does not depend on central government. For example in France a supplement on the payrolls of those employing more than ten, the Versement Transport, provides a degree of local autonomy. The state investment bank, the Caisse des Depots, has the expertise to assess and fund schemes that secure better growth. The UK Infrastructure Bank has been renamed the National Wealth Fund, but the full lessons do not yet seem to have been learned.7
• The systems used for planning and evaluating new projects fail to take full account of the wider and longer-term benefits that come from overall urban renewal. This particularly reflects the role of the WebTAG system, controlled by the Department for Transport and the Treasury (see T&UT for February 20208).
ABOVE:
Docklands light railway
OPPOSITE:
The Grenoble system with typical French features of an effective tramway development. Photo: Reg Harman
This article first appeared in Tramways & Urban Transport, February , 2025, journal of the Light Rail Transit Association, published by Mainspringhttps://www.mainspring.co.u k/products/publications
The Academy of Urbanism drew lessons in a webinar and >>>
BELOW:
Photo: Neil Pulling
report from introducing trams in four leading cities Copenhagen and Aarhus in Denmark, Dublin in the Republic of Ireland, and Nottingham9. These success stories had five factors in common: a compelling vision, practical options, collaborative organisation, packaging funding, and ongoing stewardship. Such an approach will be essential to building the New Towns that Labour has promised. Yet the rate of growth of the proposed Ecotowns at Northstowe, north of Cambridge, and at Bicester has been disappointing. The existing business and development model simply does not work, even with heavy public investment; not least because it is assumed that car use will provide accessibility for a modern lifestyle. Transit schemes, if offered, are usually bus based, chosen for their supposedly lower costs and flexibility. But they do not provide the smooth travel and clear routes that passengers can rely on. For this tramways, both on street and on private rights-of-way, are essential.
Some of the most successful European cities show what works.
• In Vienna, the new town of Aspern Seestadt has kept housing affordable while being rated highly on every account. The innovative settlement is being developed on the site of a former airport and connected through a metro extension.
• Copenhagen funded their first Metro line by building the new town of Orestad on the line to the airport.
• In Zurich, a housing cooperative build stylish new apartments above one of their central tram depots.
These reflect the importance that light rail has always had across most central European and Scandinavian cities. But it is in France, where tramways almost disappeared by the 1950s as in England, where the greatest revival has occurred. Over two
dozen cities have built new tram systems as the backbone of local transit serving urban regeneration and new development areas. Paris continues to extend the major network it started only in 1992 into the city’s suburbs, where it complements the Metro and the RER. The system is also used to help regenerate poorer areas such as St Denis.
A tale of two cities
In the UK the City of Oxford is losing out both to its rival Cambridge which has fast electric trains to London and a very high rate of housebuilding. The striking contrast between Oxford and its twin city Grenoble highlights the missed opportunities. Both are home to internationally reputed universities, with complementary research centres and high quality manufacturing. But while Oxford is mired in congestion, made worse by the closure of the Botley Road next to Oxford Station, and with the least affordable housing outside London, Grenoble has transformed its environmental appeal and economic prospects. This reflects the powers devolved from Paris in the 1990s by President Mitterand.
French city conurbations have seen their economies far outpacing the UK, not least through the enhancement of urban areas, largely based round giving the main streets over to public transport, especially tram lines. In Grenoble’s case this has involved strong cooperation and interworking by the leaders of the city authorities, research centres and commercial undertakings. A network of five tramway lines links the city centre (with the main community and commercial establishments and housing areas on the edge. As these evolve, so too does the tramway. Many other French cities have since done the same,
Dublin’s LUAS network, an ongoing success.
redesigning their principal streets around trams, bicycles and walking.
Two key factors stand out. First, French cities do not build a tramway in isolation. Rather they regenerate a complete corridor. The ‘façade a façade’ principles are very evident in the high quality of built environment along tramways. Second, future development areas are considered in the design of current lines. For example points are installed on new lines where a further line will eventually branch off.
The French approach was borne in mind by Nicholas Falk and David Rudlin in designing the notional Uxcester Garden City, which won the 2014 Wolfson Economics Prize10. Tested out in Oxford, this showed how to build new garden cities that are ‘visionary, viable and popular’ without the need for government subsidy, Projections showed the population could be doubled in size of 30 years by taking a substantial bite (about 5%) from the green belt, rather than nibbling away around villages. The increase in land values could have funded Oxford’s first new tram line as part of an integrated system.
So where do we go now?
So now is the time not just to fund a few isolated transport projects or further consultants reports but to bring the different elements together. This is not an issue of technology: proven options for light rail and other systems can be bought off the shelf and manufacturers continue to put serious effort into research and development. Rather it is about government
having the courage to devolve powers, and to create local organisations with the capacity to deliver and maintain what is needed. The choice of locations is critical as so much depends on where people want to live, as well as how easy it is to get to work and services.. As in France, transport projects need to be seen as part of wider growth plans, and this is where Labour’s promised reform of urban planning and devolution could help. This is not about unshackling private enterprise but rather removing unnecessary risks by assembling sites and installing the infrastructure needed to create healthy and happy neighbourhoods.
Starting with the long established opportunities for tramways in major cities such as Oxford, Leeds, Bristol, or even the Stoke conurbation, this approach would enable light rail to become the basis for accessible and smart urban living across the country. Of course, no one mode can make a city work better on its own, so integration of public transport must replace pointless competition to get the best value from our urban heritage or common wealth.
To enable this approach there are seven steps that government needs to take:
1. Local authorities must have the powers and the funding to undertake serious projects. “We cannot afford it” should no longer be the excuse for another busway when light rail offers the prospects for urban renewal.
2. Honest appraisal requires a framework that clearly indicates
LEFT:
Plan for the notional Uxcester Garden City from the 2014 Wolfson economics prize-winning submission by Nicholas Falk and David Rudlin – a blueprint for Oxford? Urbed Trust
RIGHT:
Tours – older suburbs and well planned highway engineering – Reg Harman
whether a light rail system offers real gains. Clearly our European neighbours have the tools to do this; why can’t we do so in the UK? We need to establish a broad appraisal system that assesses the benefits and impacts in a disciplined and cohesive fashion, with the WebTAG focus on forecast traffic levels forming one of several elements.
3. Development strategies must have clearly focused objectives of minimising car dependence through making it easier and attractive to use public transport and to walk and cycle as a basis for developing better neighbourhoods and towns.
4. Joint ventures to develop local transport systems should be set up between local authorities, public agencies such as development corporations or London and Continental Rail, and commercial partners. These need not be on the same basis for every city region.
5. Professional education and training should seek to produce an increasing cohort of people who are well versed in public transport modes and systems and in the relationships that transport has with economic and spatial development.
6. Government should act in the short term to identify some areas for regeneration or growth that could form pilot projects, finding stakeholders keen to support the approach.
7. Government must make the necessary legislative changes. These would include revisions to the NPPF to require coordination of spatial and transport planning and a new local transport act to allow genuinely integrated public transport.
n
Footnotes
First published in Tramways and Urban Transit, January 2025
4 Leading Light: What Light Rail can do for City Regions Urban Transport Group 2012
5 Back on Track, Britain Remade 2024
6 Capital Gains: A Better Land Assembly Model for London, GLA https://www.london.gov.uk/programmes-strategies/housing-and-land/housing-and-land-publications/capital-gains-better-land-assembly-model-london
7 Nicholas Falk, Funding Housing and Local Growth: How a British Investment Bank Could Help, Smith Institute 2014
BELOW:
Croydon Tramlink – fast travel for young families –– Reg Harman
1 Anthony Breach, Measuring up: Comparing public transport in the UK and Europe’s biggest cities, Centre for Cities 2021
2 Location of New Homes 4 joint research report, RTPI
3 Reg Harman and Nicholas Falk Swift Rail and Growing Cities, Tramways and Urban Transit, January 2016
8 Reg Harman, What’s your tramway really worth?, Tramways & Urban Transit, February 2020
9 Rapid Transit and Urban Recovery: How should towns and cities respond? Academy of Urbanism, 2021 www.aou.org
10. Uxcester Garden City, www.oxfordfutures.org
Reg Harman and Nicholas Falk, Swift Rail- Funding Local Rail Transit for Smarter Growth, Public Money and Management, September 2016
Children and young people are often overlooked in planning decisions, despite being among the most affected by the environments created around them says Jenny Wood
Putting Children and Young People at the Heart of Planning
In the UK, childhood has become increasingly restricted—children today move around their neighbourhoods far less freely than previous generations, with traffic-dominated streets, safety concerns, and exclusionary regulations limiting their independence and play.
While policymakers focus on education, health, and social issues, the role of urban planning in children’s wellbeing is frequently neglected. Yet the built environment profoundly impacts their physical health, mental wellbeing, and social development. Planning decisions determine whether children can safely walk or cycle, access public spaces, or gather with their peers without fear of hostility. The result? An urban landscape that prioritises adults’ needs while diminishing children’s opportunities to explore, play, and form connections with their local area.
Why Children and Young People Matter in Planning
The UK’s commitment to the UN Convention on the Rights of the Child (UNCRC) highlights the fundamental rights of children to participate in decisions that affect them (Article 12), to access and use public spaces freely (Article 15), and to play and enjoy recreation (Article 31). However, planning policy in the UK continues to prioritise economic and infrastructure concerns over social and developmental needs. The dominant approach to ‘child-friendly’ planning—creating playgrounds and skateparks—often fails to meet children's and teenagers' broader aspirations for their built environment.
Children and young people value spaces that offer autonomy, adventure, and social opportunities. Research consistently shows that playgrounds are often not children’s favourite places to play. They prefer parks, woodlands, and informal spaces where they can make their own choices. For teenagers, the situation is even starker: they are frequently treated with suspicion in public spaces and lack places where they can gather without being seen as a nuisance.
Developers, policymakers, and local authorities are increasingly recognising the importance of social value in planning and development. Creating environments that work for all ages fosters stronger, more resilient communities. Places designed with children in mind encourage active travel, reduce car dependency, improve public health, and contribute to safer, more inclusive urban spaces.
In short, children and young people have insights and knowledge that adults don’t have; if we don’t plan with them then we’re missing a core part of the picture!
The Role of A Place in Childhood (APiC)
At A Place in Childhood (APiC), we specialise in supporting child-friendly planning and design. We work with partners and communities to ensure children and young people have a meaningful say in shaping their environments. Our work spans RIBA Stages 0-3, offering on-the-ground facilitation, training, coaching, and practical guidance on embedding child-led approaches in planning. At the same time, we link with local and national curricular goals, and ‘connect the dots’ between planning and other services that influence and support children’s environments.
Despite progress in Scotland and Wales, our research with ZCD Architects and RTPI on child-friendly planning policy across the UK reveals that children remain largely invisible in planning policy. They are most notable through their absence.
One area gaining momentum is the inclusion of children and young people in active travel decisions. They are natural experts in their own mobility and consistently prioritise safe, connected, and enjoyable routes. As policymakers place greater
Dr Jenny Wood, is Cofounder and Co-director, A Place in Childhood
emphasis on local living, the contribution of children and young people is becoming increasingly valued.
However, there remains a significant gap in provision for all ages, but especially teenagers. One of the most common concerns raised in our work is the lack of safe, welcoming spaces where young people can socialise independently. Policymakers and communities often fear that spaces made with young people in mind will increase (rather than lessen) anti-social behaviour. Yet, providing these spaces is fundamental to ensuring young people feel seen, valued, and connected to their local community.
Case Studies: Child-Friendly Planning in Action Neighbourhood Co-Design in Edinburgh and Glasgow
APiC has led impactful neighbourhood co-design projects in Edinburgh and Glasgow, focusing on place-based solutions within RIBA Stages 0-3. These projects show that children and young people have valuable insights and ideas to share, and can play an integral role in shaping their communities.
Key projects include:
• Edinburgh: Co-design initiatives at Leith Links and Pennywell Road, where young people contributed to the development of design principles and prototypes aimed at enhancing public space.
• Glasgow: Six Glasgow Liveable Neighbourhoods projects, each engaging children and young people in reimagining their local environments with a particular focus on creating safer and more inclusive spaces for girls and young women. Additionally, APiC collaborated with Glasgow City Council, St Paul’s Youth Forum, St Philomena’s Primary School, and Sustrans Scotland on a pioneering Minecraft-based public space co-design project. This project provided young people with a digital platform to develop design solutions that were then translated into real-world planning considerations.
The success of this project was widely recognised as it came Highly Commended in The Learning for Sustainability Awards, and won the Scottish Transport Award for Most Innovative Transport Project of the Year.
Co-Creating Neighbourhood Plans
APiC has played a leading role in supporting communities to develop neighbourhood plans that embed children’s perspectives. We have been honing our methods since our inception, but last year got the opportunity to work through an intensive project with seven local partners across Scotland. Through this, we facilitated the co-creation of seven plans, including three focused on a just transition. These plans span a diverse range of locations, including large cities, small to medium sized towns, and remote rural contexts.
Each plan contains an Experiential Map, that shows the participant’s views, ideas and experiences of their local area, along-
LEFT:
A site in Edinburgh that young people have chosen to reactivate for community benefit.
Photo Credit: the pupils of
BELOW:
Inverurie Academy's Plan for an Intergenerational Diner
side a set of Priorities for Action (which are sometimes developed further into Projects). Example priorities from these plans that can be taken forward include:
• The building of new pathways and commissioning of new community bus routes on Shetland’s Mainland.
• A proposed new use for a vacant building in Inverurie as an ‘Intergenerational Cafe’, to support social mixing, address loneliness, and provide affordable food.
• The regeneration of the harbour in Macduff to be safer and more enjoyable for young people to spend time at.
• Installation of more public art in Craigmillar, Edinburgh, to make the area feel more welcoming and exciting for everyone. Young people chose a particular site next to their school’s astro which is particularly neglected. We are now working with children and teenagers and other stakeholders in the area to create a community park.
The impact of our approach has also been recognised by the Thornton Education Trust Inspire Future Generations Awards where we recently won best research project, and not-for-profit of the year.
One of the standout examples is Inverurie Academy, where pupils conducted extensive engagement, including working with
St Andrews SEN school and consulting with over 40% of their wider pupil body. Their work was captured in a compelling video they created themselves.
Beyond the planning process itself, our approach has led to tangible community outcomes. For instance, in Falkirk, young people co-created a community festival that was attended by over 600 residents. This was an action they identified in their plan’s priorities, because they felt the community doesn’t get to come together enough, and they would like to further conversations about the needs of young people themselves.
The impact of these plans extends beyond immediate project timelines, influencing long-term local decision-making and demonstrating the value of child-led placemaking. For example, the plans are being embedded into Play Sufficiency Assessments, Local Place Plans, Children’s Services Plans, and Local Development Plans.
To support wider adoption of these methods, we have developed a How-To Guide for Co-Creating Neighbourhood Plans with Children and Teenagers. This document outlines our framework and methodologies, providing a practical resource for planners and practitioners to try the approach. You can access it here. As well as direct delivery, we also offer training and coaching on the methods.
A Sustainable Future
Planning decisions shape the lives of children and young people in profound ways, yet their needs remain undervalued in mainstream policy and practice. A more inclusive approach— one that genuinely integrates children’s perspectives—will lead to better, healthier, and more resilient places for all.
As the focus on social value continues to grow, now is the time for planners, developers, and policymakers to champion child-friendly approaches. By embedding children’s participation into planning and design, we can ensure that the built environment not only serves the needs of today’s communities but also nurtures the next generation of engaged, independent, and empowered citizens.
If you are interested in learning more about how to embed child-friendly planning into your projects, APiC offers training, guidance, and direct delivery/facilitation. You can contact Dr Jenny Wood at jenny.wood@aplaceinchildhood.org,
RIGHT:
A primary school child designing an 'Art Park' using Minecraft
Brothers in Arms: London priorities for a prosperous England
Lars Christian thinks about improving social mobility, social well being, and quality of life. both for Londoners within a streamlined London and for the inhabitants of the nine largest cities of northern and middle England
IMAGE:
AI generated response to ‘England and London need to find a common Identity‘
England is maybe in need of a reset after fourteen years of Tory and LibDem merry-go-round governments; Akin to a banana kingdom? London is by many seen as the solution; As England's saviour in shining armour? I will in this article, argue that London and Londoners need to tweak direction, and tweak attitude: For north and middle England to resurrect and prosper. I the author, is London born, and lived for a short decade, north-of-the-north, in Edinburgh.
England and London need to find a common Identity. Politics, government ministers, and the media need to be less divisive. Political office holders need to respect each other, and respect their differences. I am unsure when England and the English lost a common focus-post WW2, post 1952 or post 1979? Almost all nations have a national day, England is one of a few odd ones out. Lastly, Londoners need to be better able to identify with fellow Londonersirrespective of postcode, origin and tribe.
Why is it important for London, the East South East, and north and middle England to find a better equilibrium between the four? For one, average wage working families with children, need better quality of life in London.
Only a better equilibrium between the number of jobs, homes and households within London will make that possible.
More high earners and premium professional jobs can be accommodated throughout the dozen largest cities of England. A quarter century into a new millennium, the pandemic has proved that maybe as many as a quarter of the premium paid jobs in London, can be accomplished elsewhere.
Further, does London need thousands of cultural and research institution, or may half the present number be adequate? A quarter century of English, Scottish and Wales devolution, has proved that cities beyond London can deliver as good or better as the capital, in most if not all matters. And if a spread of institutions is possible in all other neighbouring nations, NO, DK, DE, NL, BE, FR and IR included; Maybe it may also work in England?
The top 7x7+7 blue-green wonders of Greater London: The paths along the Thames from Oxfordshire to Margate and Southend; the London Loop; Capital Ring; Green Chain; The top 7+7 remaining paths along major canals, rivers & brooks;
The top 7+7 hills with panoramic views;
The top 7+7 outer borough modern monuments; The top 7+7 sports venues;
The top 7+7 outer borough arts & cultural venues; All bathing ponds and lidos.
Lars Christian is an urbanist and lecturer
>>> Similarly, it is tough to build yet another ½-1mn homes in London, and the social and physical infrastructure that comes with it-lack of builders and SMEs included. House building away from the East South East is 1½ or more cost effective. With more SMEs, lower land prices, less complex logistics, lower labour costs, less dependency on imports of finance, labour and materials.
London will for the foreseeable future still have a superior advantage and competitiveness in a quarter, a third, a half or more of what it does best.
But maybe only if London and Londoners recognise; That a quarter or a third or more can be equally well delivered elsewhere, away from the East South East.
London and England are struggling to achieve higher scores for teenage and young people's well being. Despite a higher proportion of above average school achievers in London than elsewhere in England. With nine million inhabitants, the number of young people under-achieving is considerable. But can the local social and physical environment better cater for young people? In a social media age when fewer teenagers engage in sports. Survey after survey prove that more and more teenagers are struggling. With added pressure on the need to achieve well - in exams, among peers, on social media.
London's 1.3mn increase in population post 2000 and almost one million jobs since 2008, has brought some tremendous opportunities, but also tremendous challenges. The four most serious are maybe; The housing shortage and cost; Longterm poverty among working families with children;
Longterm unemployment among the (London born) unskilled and over-skilled; Knife crime...
For England to become more competitive, London may need to offload half of its public sector employment not serving Londoners directly. And for institutions serving the 15 mn population of the East SouthEast to relocate to hubs like Ashford, Gatwick, Guildford, Reading, St Albans, Luton, Stevenage, Stansted. All places accessible by both concentric and radiant commuting. However, since 2010, the opposite has happened, national public organisations and institutions have cut more jobs throughout England than within Londonin percentage and absolute numbers (IfG).
Conceive five research & bio/science cities: With all larger parties working towards this goal over several decades. Where Silicon-Ouse-York transforms itself into an Oxbridge of the north, with a federal university, with additional colleges initially developed by the six largest colleges/universities in London and Oxbridge. With Silicon Preston, Teeside-Middlesbrough, Hull-Riding and PotteryTrent undertaking a similar but smaller transformation into B-STEM research cities. Tripling the number of school leavers and uni graduates doing B-STEM subjects, medicine, nursing, languages and construction in the six counties. Similarly, establish an elite B-STEM London Thames university, with a dock or riverside campus east of Blackwall.
Does London need to become a dual-capital, more like
the Netherlands, a comparable dense and compact nation? So that ten percent of economic activity leaves the city. So that the pressure on the housing market, public services, labour and skills shortages eases. So that the default tenure for working families with children over time returns to owner occupy. Where ten percent of premium private jobs, ten percent of premium public jobs, ten percent of students, ten percent of research leaves the city. Resulting in a win-win also for London and Londoners; The latter with better quality of life and social well being; Working families with children included.
Can England excel and prosper with a dinosaur London and East South East? The capital should move elsewhere, halfway between two metropolitan cities. Three options include, between Sheffield and Nottingham, Leeds and Bradford, Birmingham and Manchester. The latter implies Stoke-on-Trent, to become a superior accessible and connected city. Creating a premium economic growth corridor, on par with M4, CaMkOx, Randstad. For half of the London civil servants to relocate; within 30-60 min commuting distance of the tri-city Birmingham-Pottery Trent-Manchester conurbations. With the Treasury in Manchester, Ministry of Defence in Leeds, Foreign Office in Birmingham, Royal Navy in South Wales. And the remaining ministries within 90 min commuting distance.
The main political parties of England need to agree on structural reforms. Not ideally, but a requirement and a necessity. Similarly, make a mechanism where certain policies are in place for more than one election cycle. The structural reforms can be introduced by Labour, or the Tories, or ideally both. Within a decade, or within a quarter century. Delaying reforms beyond a quarter century, risks degrading even further the competitiveness and the productivity of England, for the long term.
The 2010-2024 merry-go-round of policy changes and prime ministers-turned out to be a lost 1½ decade. Yes, merry-go-round of policies and direction creates (social) media headlines. But the merry-go-round did not benefit the nations, economy, society, environment, employment, education, health, quality of life, well being, social mobility. Parliament knew that; and knows that.
How can a revised compulsory purchase compensation system, improve access and mobility within London and elsewhere in England? With all undeveloped and underdeveloped urban land to be nationalised. With the freehold land owner given a medium term leasehold of the land. A leasehold typically lasting 100 years minus twice the time the land has remained underdeveloped or vacant. With compensation payed as the land is developed. The freehold of smaller plots to be transferred to the local authority. The the dozen larger sites per authority to be divided equally between the local authority, housing associations, the Metro Mayor or county if applicable, and a (regional) development corporation. To manage, develop and pass the freehold to the new (shared) freeholders upon completion.
England has five prosperous dream cities outside the East
South East: Bristol, Birmingham, Leeds, Manchester, Nottingham. With Cardiff, Dublin and Edinburgh further a field. So next please, ensure that the five runner ups also reach this top tier within a quarter of a century: Bradford, Leicester, Liverpool, Newcastle, Sheffield.
So far, BBC, C4, ENO, ONS and PINS are five institutions that have (half) moved out of London. DVLA and GCHQ are two that were established away from the East South East. If a further 5+5 institutions (half) move to each of the above ten dream cities. That requires 93 to uproot and (half) move, including the big five museums/ galleries. And for no more token satellites in (eastern) London suburbs. But for the 93 to move to the No-Yo-Mid; More than half of the decision makers included.
Low/zero carbon and public realm issues for the London Mayor, the Assembly, and think thanks to investigate; And for the former to sponsor secondary legislation:
How can new large shallow inner London lidos, adjacent to intersecting deep tube station, floating ones included, cool platforms and tunnels*?
How can an outer borough blue-green mixed path network, for commuting and leisure trips, contribute to halving car commuting, and halving overweight? (PIL 103/17)
How can Swedish/Norwegian style urban road pricing work in London? How can Danish/Germany style lorry trunk road pricing work in the East South East?
How to promote thermal insulation, (vertical) solar panels and quality window design; Throughout all refurbished (social) housing?
How to promote heat pumps, solar panels, one floor roof extensions and/or street side dormer roof extensions; Throughout all post WW2 row housing neighbourhoods?
How to retrospect promote permeable surfaces, hedge rows and tree planting; between all front gardens used for car parking?
How to promote street trees in front of all new buildings; Both within (residential) front gardens-and with slightiy wider pavements-in front of all (urban) apartment and commercial buildings?
How to promote a minimum distance between fences, walls and hedge rows; Along all pavements and all paths; And tum all paths to shared bike-walk; Throughout London and the metropolitan green belt?
How to promote quality shop front facades and signage; Quality upper fioor window design; And quality public realm; Throughout high streets in all 32 boroughs?
How to promote friendliness, politeness and goodwill between Londoners-irrespective of age and backgroundsgeographical, ethnic and socio-economic?
*Cavendish Square; Embankment; Elephant & Caste; Euston; Finsbury Park; Green Park, Lincoln Inn; London Bridge; Monument/Bank; Russel Square; Soho Square.
The post 1979 model of 'accidental' concentration of a majority of everything public to London and the East South East, is an outdated model.
From 1994, accelerated by lottery grants. One quarter way into a century of globalisation and footicose information and knowledge. Where far a way China is the winner, with India
and maybe others catching up.
London can still continue to deliver upon its great heritage, for decades and generations to come. But only with an equally prosperous northern and middle England. Raising all three, to match other G7 and G20 nations; In social mobility and social well being.
The UK government may wish to pursue some of the below strategies, to bring the North, Yorkshire and the Midlands-where almost half the population live-as well as London, closer to other €7 and G20 nations in quality of Iife and social well being-working families with young children included:
Introduce a national community service, of 26+26 weeks, typically served between the ages of 18-23 and 6067;
Devote three of the two dozen cabinet members to the No-Yo-Mid as secretaries of state;
Move half of the 100 largest government agencies; And half of the 100 top state sponsored NGOs away from the EastSouthEast, And for the remaining haif, to move half of their activities;
-Reduce the royals, Army, Navy and RAF presence in the EastSouthEast by two thirds; To relocated to the No-YoMid;
Reduce foreign students numbers in London by two thirds; And triple the numbers in the cities of the No-Yo-Mid; Introduce peak hour e-car road pricing throughout London and the EastSouthEast; To half overweight and half car commuting; With half of the revenue towards public transport, E-bike commuting and B&R; And half for a complete and sound proofed strategic/motorway network; Produce more coastal and offshore wind power within the No-Yo-Mid-with UK assembled turbines-than the total regional power consumption; Heating, cooling, vehicles, construction and production combined; Built 1+1 million apartments for the 55+, half private, half public, most on public land (see PIL131/2024).
Afterword
The future of London and England is bright and promising; But only if national, regional and local decisions makers act together, Universities, research institutions, royals, churches, businesses, unions; professional, voluntary and non-goverment organisations included. Maybe for a quarter, third, or half of these organisations, to refocus their 'reason d'etre' away from London as we know it. And for half of these organisations to anchor their centre of activities in one of the dozen largest cities elsewhere in England, away from the East South East. The rich, academics, intellectuals and educated included. Will this be London's armageddon? Without parliament, government, lobbyist, political media, political NGOs, two dozen ministries; Altogether 50-100k high income people and professionals; Including their spending power and influence; Throughout London and the home counties? Or will London continue to succeed and prosper? Like non capital cities across the North Sea and beyond; Places such as Rotterdam, Hamburg, Frankfurt, Munich, Geneva, Zurich, Milano, Lyon and Barcelona. What do the above strategies mean for London? Is it the end of the metropolis as we know it since 1945, 1979 or 2000? Can London adapt, tweak and nudge itself into an accelerator of prosperity; Of not just itself, but also the nine largest cities of the North, Yorkshire and Midlands included? For London, this may result in one hundred thousand fewer superior paid jobs, a quarter million fewer households, and a hundred thousand fewer students. A apocalypse or armageddon? Or a manageable tweak of direction? Improving social mobility, social well being, and quality of life. Both for Londoners within a streamlined London. And for the inhabitants of the nine largest cities of northern and middle England. n
With conventional residential treading water, where is current investor focus in the housing sector? asks Robert Reeds
Housing investment in London
It is no secret that the housing sector, particularly in London, has faced turmoil over the past few years. Rising build costs, regulatory confusion, poor sales rates and political and economic risk have all played a part in a slow down of build out rates and housing delivery. Investor appetite in the sector, however, is still present and thriving with investors repositioning assets and de-risking exposure from Open Market Sale homes.
LSH’s UK Investment Transactions Bulletin (‘Living to the Max’) reported that 2024 was a record year for living sector investment, with £18.3bn transacted nationally, including £5.1bn into the Build to Rent (BTR) segment. Institutional investors have partly been attracted to BTR as a result of an acute supply/demand imbalance across the wider Private Rental Sector (PRS) and some have been looking to diversify portfolios. Tax and regulatory changes have pushed smaller private landlords out of the sector, while high interest rates have forced potential home buyers to rent for longer, driving significant rental growth in recent years.
Despite some high levels of investment, London’s affordability crisis is in full swing. In research published by London Councils, Londoners say they spend 42% of their personal monthly income on their rent or mortgage. With saving for a deposit for home ownership being extremely difficult for many younger (and increasingly older) inhabitants of the Capital, renters are searching hard for good quality, affordable rental homes in central urban locations.
One area of the BTR sub-sector is “co-living” and the LSH Research, Planning Consultancy and Living & Capital Markets teams have been monitoring the notable uptick in investment opportunities in this area.
The Surge in Co-Living
“Co-living” is still a relatively new housing concept in the UK, with the country’s first purpose-built co-living schemes being less than a decade old. However, due to the aforementioned factors, the sector is now growing at an accelerated pace and set to form an increasingly significant part of the overall BTR market as it becomes a more tested solution to the delivery of good quality, affordable urban homes.
At present, there are approximately 8,425 beds in large-scale purpose-built co-living schemes across the UK, representing just 7% of the UK’s total BTR stock. However, the sector is poised for rapid expansion with a further 16,534 beds in schemes either under construction or with planning approved, and an additional 9,694 proposed beds at earlier stages of planning. Co-living schemes represent more than 15% of the total BTR development pipeline.
London has been the main focus for co-living development to date, with 5,091 operational beds, or 60% of the total UK stock. Schemes under construction or with planning granted are set to provide London with an additional 8,837 co-living beds. Among those close to completion is The Rex, Kingston upon Thames (215 beds), which is due for delivery in 2025. Meanwhile, a recent spate of planning approvals has included Cornerstone (174 beds), which is noteworthy as the City of London’s first consented co-living scheme.
Why the appeal?
Co-living residents are typically characterised as young single tenants; primarily recent graduates, early-career professionals and international residents. Reflecting this, co-living operator VervLife reports that the average age of residents across its
Robert Reeds is director in Lambert Smith Hampton’s London Planning Consultancy team
RIGHT:
Built and Pipeline co-living Schemes in London
London portfolio is 28. However, other operator evidence indicates that the tenant profile is diversifying, and becoming older, as the sector becomes a more established option for renters.
The community and social aspects of co-living are among its key attractions. In addition to providing an array of shared spaces, co-living operators will often organise regular events, giving residents opportunities to meet new people. However, co-living also provides flexibility, allowing each tenant to use a mixture of private and shared areas in ways that suits them individually.
All-inclusive rents add to the appeal of co-living schemes, with rents usually including council tax, utility bills, wi-fi, room cleaning, and access to facilities such as gyms and co-working spaces. While this means that co-living rents can appear relatively high at first glance, the total all-in cost of living will usually be lower than in alternative PRS accommodation where these expenses are not covered by rents.
Location is key to the success of co-living schemes. With many residents reliant on public transport, close proximity to transit hubs, shops and other amenities is essential. The prime sites for co-living schemes are those that will provide tenants with opportunities to live in well-connected central areas lacking other affordable rental options.
Co-Living Investment
To date, a lack of cohesive planning policy and the relatively untested nature of the co-living concept have been the main barriers to investment into the sector. However, an increased volume of capital is now being attracted, as co-living becomes a more accepted model for the cost-effective delivery of city centre homes.
Co-living investment reached £250m in 2024, taking volume over the last five years to £1.1bn. Last year’s deals were concentrated in London and included CDL’s forward funding of Yardhouse, White City for £88m; and DTZ Investors’ funding of a £100m scheme at Brent Cross Town.
In addition, Realstar Group acquired Brixton Junction, a 63bed operational co-living asset, for more than £20m; while HUB and HIG acquired a plot in Lendlease’s Elephant Park masterplan for £42m, for a mixed-use development including co-living homes.
With stabilised assets in short supply, investment activity is likely to be concentrated on funding and development deals in the medium term. The pace of funding deals should accelerate as more development schemes are brought forward; and there are several live opportunities in the market from developers seeking funding partners for consented schemes.
What about planning?
As a relatively new form of housing delivery, much of the first
wave of co-living development has been delivered amid an absence of specific planning policy. There are no national-level planning policies relating to co-living development, and it is not referenced within the recently revised National Planning Policy Framework (NPPF).
Large-scale purpose-built co-living schemes are predominately treated as “Sui Generis”, meaning that Nationally Described Space Standards (NDSS) applying to residential (C3) schemes do not apply. Furthermore, conversions to co-living cannot be delivered using Permitted Development Rights. More detailed local planning policies are gradually emerging around the sector. Most notably:
• the London Plan introduced Policy H16 on co-living in 2021, terming it ‘Large-Scale Purpose-Built Shared Living (LSPBSL)’; and
• the Greater London Authority adopted guidance on how to apply this policy in February 2024. The guidance provides a relatively flexible framework for the delivery of co-living schemes. It includes recommended benchmarks for amenity space provision, and states that private units should be between 18-27 sq m.
An inconsistent approach to co-living planning policy is thus emerging across the country.
Developers will need to be aware of the level of support given locally; and to deliver good quality schemes that demonstrate to planning authorities that co-living is an appropriate form of housing delivery.
Will the sector grow?
The co-living pipeline is full of promise and the potential demand for these homes cannot be underestimated. Nonetheless, there will still be significant planning, funding and development challenges to overcome before schemes currently in the pipeline are brought to completion.
The barriers to co-living development should lower as the sector grows and becomes a more established style of city centre living.
Co-living is also increasingly recognised as a viable development option in London, and it is well placed to become a more mainstream proposition in regional cities over the next few years. n
ABOVE:
Summary of co-living investment transactions
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