Savills : London Plan Update

The Mayor wrote to the SoS on Wednesday 09 December setting out that, in the absence of any formal feedback on the GLA's proposed amendments to the March directions (we understand this to have been 22 tracked changes), he intended to publish a new London Plan based on his understanding of the SoS' views to date. The SoS very quickly responded yesterday (10 December), attaching a list where he has accepted the Mayor's wording changes and where he thinks that further revisions are needed to satisfy the purpose of the directions.

In short, the directions are broadly consistent with those made back in March and consist of the following key changes. For now, our view is that all the policies within the Plan that are not subject to directions can be given almost full weight.

Green Belt

The amendments to the Green Belt policies have been re-inserted by the SoS. This will allow for development in the Green Belt if there are very special circumstances and requires exceptional circumstances to be demonstrated in order to extend or de-designate Green Belt land. The Mayor's wording had sought to retain a stricter stance on development, that would mean that no harmful development would be allowed in the Green Belt, even in very special circumstances. The change brings the policy in line with national policy. Similar changes have been made with regard to the protection of Metropolitan Open Land.

Again, it is notable that there has been no insertion that would commit the Mayor to undertake a strategic review of the Green Belt, despite it being a recommendation by the Planning Inspectorate in October 2019. We remain of the view that a strategic approach to Green Belt review taking into account planning future infrastructure would be a sustainable way of Green Belt release.

Industrial Land

The requirement of 'no net loss' has again been removed from the industrial land polices. Whilst the directions maintain a need for industrial land release to be planned, monitored and managed, the removal of the 'no net loss' will give local authorities more freedom to release surplus land for other uses, especially housing.

Indeed, the SoS has added a further direction to this policy, with paragraph 6.4.8 (which encourages boroughs to assess whether the release of industrial land is appropriate) further amended to require industrial vacancy rates to only need to be 'above' as opposed to 'well above' the London average. The amendment goes even further to state that boroughs considering the release of Green Belt to accommodate their housing need may consider re-allocating industrial land instead, 'even where such land is in active employment use'.

Consolidation, release and substitution of industrial land is already forming part of some boroughs strategy to meeting housing need. For example, London Borough of Barking & Dagenham is currently consulting on a masterplan for the River Road/Thames Road area that envisages the intensification and substitution of parts of the Strategic Industrial Land to 'free up land to meet other planning objectives, such as housing and infrastructure.' With the removal of 'no net loss', boroughs will have much greater freedom and it remains inevitable that there will be a loss of industrial capacity should this approach be maintained.

Tall Buildings and Density

Tall buildings are defined in draft policy as those that 'are substantially taller than their surroundings and cause a significant change to the skyline'. The SoS has introduced a new direction that states that the definition of tall buildings cannot include those under six storeys (or 18m). The intention of this direction is to ensure that the tall building policy does not undermine the incremental densification of areas, which is considered to be an appropriate way to meet housing need.

The tall building policy otherwise maintains the need for boroughs to identify areas where tall buildings will be suitable in development plans.

The 18m threshold is consistent with the maximum height of the new Part 20 permitted development rights that allow for upwards extensions of terraced dwellinghouses and terraced commercial or mixed use buildings to provide new flats. Whilst the policy is clear that a six storey/ 18m building will not be 'automatically acceptable', it is clear that this change is intended to ensure that the national push to increase housing delivery by extending upwards and densifying is not undermined.

Parking

Minor revisions to parking standards have been maintained. These standards are essentially slightly less stringent (I.e. allow for slightly more parking) than the initial Intend to Publish standards and allow for boroughs to consider higher levels of parking provision where it would support the delivery of family homes.

Summary

The revised directions published yesterday are very similar to those issued in March and perhaps shows that there is still quite a difference in view, particularly with regard to the role that industrial land and Green Belt can play in meeting housing need. Whilst the SOS' letter reiterates the Mayor's urgency to get the new Plan published and recognises the benefits its adoption will bring to families, businesses and development in London, it does leave the Mayor with very little time to get the planned revised, published and adopted ahead of the pre-election period of the Mayoral Election on 06 May 2021.

Once the wording is agreed, our understanding is that adoption would still take at least a further two months for formalities to take place.

It is also our understanding that the GLA is intending to publish a note on the recent revisions to the Use Class Order, but that it does not consider that the use class revisions require changes to be made to the draft Plan itself.