Sounding board applauds London Plan goal to ‘urbanise the suburbs’

Monday 4 December 2017

The NLA Sounding Board gave a broad welcome to Sadiq Khan’s new draft London Plan last week as an attempt to ‘urbanise the suburbs’ and positive proof that the GLA was listening to the industry.

But there was criticism that, although the plan has shown more ‘muscle’ in changing ‘oughts’ to‘musts’, is more ‘concise’ and appears to broaden the scope of planning, it needs a greater clarity on how the housing shortfall will be delivered, while more needs to be done to ensure that the London Plan is fully accessible to Londoners. The board responded with a number of observations including a call for the use class system to be reviewed, recognising that the policy is often an obstruction to good, mixed city making.

The Board assigned key advisors to look at certain sections of the 524-page document that went out to public consultation on Friday. But first NLA chairman Peter Murray gave a broad overview, noting its 50% affordable homes target, the way it explained tangible policies with greater clarity than before and pointing out policies such as that design reviews should be held on tall buildings – which should have a ‘top, middle and bottom’ – before they are submitted for planning.

Watch: Fiona Fletcher Smith, Greater London Authority, summarises key points covering housing, density and opportunities in outer boroughs -

The first section was on Spatial Development Patterns, with a response from Savills’ director of World Research Yolande Barnes. ‘It does make sense if you see this plan as an attempt to start urbanising the suburbs’, said Barnes, signalling her pleasure that a density matrix had been ‘put to one side’, in line with a recommendation Savills made in a report on densifying transport nodes. Barnes also praised that the word ‘streets’ had been used and attention paid to it, but things will only work if they do at a fine grain, human level.

Design’s response was by Ben Derbyshire, President of the RIBA and managing partner of HTA Design. Derbyshire said he was happy that RIBA’s point made when A City for All Londoners was released – that not a page was deliverable without the contribution of designers – had clearly fed through. This is a good thing at a time when only 10% of housing in the UK is procured with any involvement of an architect and that figure drops to less than 1% when taken globally. ‘It’s fundamental that this document enshrines the role of designers’, he said. Also welcome was the spatial implication of plans locating appropriate positions for tall buildings, rather than opportunism, and design review is good if managed and resourced adequately. Derbyshire said he was happy to see a modal shift inherent in car free developments and increase in cycle parking, recognition of the need for design continuity in projects and Superbia’s findings showed how architects could influence policy.

A lot was already embedded already in the Housing Strategy, but Marcus Bate, investment director at Mount Anvil, said it was lacking on execution; the ‘how’ to deliver the 65,000 homes needed per year, and it was not clear who this was speaking to. On affordable housing the 35% threshold applies to normal sites of which there will be increasingly few, 50% for public sector, and 60% for strategic partners, which will be delivering some 60% of affordable housing programme to 2021. ‘It’s ambitious’, said Bate. Perhaps the most surprising policy, though was on diversification and the amount of emphasis the plan puts on small sites and encouragement of a broader range of developers. The document gives a thumbs-up to build to rent, but a thumbs-down to co-living, added sounding board chair Robert Evans.

If housing numbers are to be met, then social infrastructure will be needed to match. Haringey director of regeneration, planning and development Lyn Garner welcomed this subject having its own chapter, perhaps driven by shifting politics in the light of Grenfell and changing attitudes to regeneration, although there is little ‘teeth’ in terms of ‘the how’, she said. It also highlights problems in primary care in NHS and the difficulty in planning for places and planning for service delivery. Where is the funding that helps primary care, for example, make that leap into revenue funding.

Heritage and culture is another area in the plan with its own new separate section, showing its importance in driving good growth and welcomed as a ‘really positive’ step by Historic England’s London Planning Director Emily Gee, as was a new heritage KPI. Also welcomed are requirements for positive action for Heritage at Risk assets and considering significant archaeology in development, greater strength for local views, and an appreciation of context and character for new tall buildings.  We need to investigate more fully the implications for heritage in small sites and Opportunity Areas. ​

British Land’s head of sustainable places Sarah Cary looked at the Green Infrastructure, natural environment and sustainable infrastructure section of the plan. ‘Overall, there is a turning of the dial one notch to reduce environment impact further’ she said. Policy is simpler, with less ‘waffle’, said Cary, but on achieving zero carbon buildings the word ‘construction’ has snuck in – this would be a major step to include, while perceptions over carbon offsetting need careful attention.’ Could we have a better framework for this that stands up to scrutiny, asked Cary.  An Urban Greening Factor (UGF) will now become part of a ‘score’ for applications for new buildings, based on a system used in Europe call Green Space Factor.

Transport for London director, strategy and planning, surface transport Ben Plowden said there was a ‘very clear policy alignment’ between its draft transport strategy and the draft London Plan, highlighting particularly its ‘pretty clear’ thrust towards 80% of trips being sustainable ones – walking, cycling or public transport. Plowden commended too the plan’s healthy streets agenda and modal shift, putting transport alongside housing as potential beneficiary from Section 106s, the need to consider freight and significant tightening of parking standards for residential, retail and office.

Finally, Croydon’s director of planning and strategic transport Heather Cheesbrough welcomed the general promotion of tourism across the whole of the city, the plan’s recognition of the loss of industrial land, specific mentions of the contributions from arts and creative industries, and the ‘bit of a booting’ that permitted development rights gets throughout the economic chapter and claim that the residential that results is not intensive enough.

Design Council CABE chair Pam Alexander said that what was new about this plan was that planners had shown they had actually listened, but Daniel Moylan, councillor at Kensington and Chelsea sounded a cautionary note. While he welcomed what purports to be a densification of the suburbs, this has to sit alongside the latest TfL business plan of reduction in buses when the suburbs actually need increased bus services if they are to take the sort of densification mentioned, he said. An on Crossrail 2, Moylan suggested that the ‘slightly wobbly’ wording on the Green Belt in the plan is designed to accommodate the new line. What Crossrail 2 really needs to deliver its housing objectives is not so much conversion of Green Belt to residential but Strategic Industrial Land to residential, he suggested. ‘The SIL is the real issue the mayor has not grasped’. Finally, Moylan suggested that unless there was anything to encourage developers to think of new methods of construction they would not pursue it to any great degree. ‘We’re not going to get take-off in modular construction that will make some of these housing numbers more realisable’, he said.

Other points raised included the need to think in a national context, particularly in terms of London’s relationship with HS2 and the northern cities, not just a strategic alliance with the rest of the south east, the night time economy, and 3d modelling.

Finally, use classes. Fred Pilbrow said that in discussions on a project that he is working with the music sector on, it often felt like the use classes applied more to 1950s definitions of meat packing and tin bending. In clusters, it is often the co-location of some companies which is key to their success, but some don’t fall into the right planning class. Robert Evans said: ‘The crossover in use classes is becoming ever more complicated’; this might be the document to address that.

By David Taylor - Editor, New London Quarterly

Respond to the draft London Plan here before 2 March

NLA will be hosting a major public debate on the draft London Plan in February 2018, before final consultation responses are due in. Details to be announced shortly...

Sounding Board members in attendance Toggle

Pam Alexander, Chair, Design Council Cabe
Bob Allies, Partner, Allies and Morrison
Yolande Barnes, Director, World Research, Savills 
Andy von Bradsky, Design and Delivery Adviser, Housing-led Regeneration, DCLG
Marcus Bate, Investment Director, Mount Anvil
Sarah Cary, Head of Sustainable Places, British Land
Heather Cheesbrough, Director of Planning and Strategic Transport, LB Croydon 
James Clark, Senior Manager – Housing Strategy, Greater London Authority
Ben Derbyshire, President, RIBA and Managing Partner, HTA Design
Carolyn Dwyer, Director of Built Environment, City of London Corporation 
Robert Evans, Partner, Argent (Chair, New London Sounding Board)
Lyn Garner, Strategic Director, Regeneration, Planning & Development, LB Haringey 
Emily Gee, London Planning Director, Historic England
Robert Gordon Clark, Executive Chairman, London Communications Agency
Daniel Moylan, Councillor, RB Kensington and Chelsea
Peter Murray, Chairman, New London Architecture
Lucy Musgrave, Director, Publica 
Fred Pilbrow, Founding Partner, Pilbrow & Partners 
Ben Plowden, Director, Strategy and Planning, Surface Transport, Transport for London 
Ed Watson, Executive Director, West End Partnership

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