Episode 112 - The London Plan 2021

This week we be talking about the London Plan. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.london.gov.uk/programmes-strategies/planning/london-plan/past-versions-and-alterations-london-plan/london-plan-2016/london-plan-overview-and-introduction#:~:text=The London Plan is:,the next 20–25 years
• https://www.london.gov.uk/programmes-strategies/planning/london-plan/new-london-plan/london-plan-2021
• https://www.london.gov.uk/sites/default/files/london_plan_2021_presentation_planning_mar2021.pdf
• https://www.london.gov.uk/programmes-strategies/planning/implementing-london-plan/london-plan-guidance?ac-63512=63501

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Transcript

Episode 112:

Hello and Welcome to the Part3 with me podcast. 

The show that helps part 3 students jump-start into their careers as qualified architects and also provides refresher episodes for practising architects. I am your host Maria Skoutari and this week we will covering the London Plan. Today’s episode meets PC3 of the Part 3 Criteria.

It’s quite a large document so I will try and cover the key topics and policies of the plan to give you a general understanding of what the London Plan entails. 

Typically strategic planning in London is developed between the Mayor of London, 32 London Boroughs and the Corporation of the City of London. Under the legislation establishing the Greater London Authority, the Mayor has to produce a Spatial Development Strategy, which is the London Plan. 

The first London Plan was published in 2004 with a number of amended versions following after that. The latest 2021 version is a brand new London Plan and this latest version looks forward to 2036. This date has been chosen both because Government advice suggests a twenty-year planning period should be used, and because the Mayor believes a longer-term view of London’s development should be taken to inform decision-making, development and investment. However, some of the more detailed elements of the Plan, such as the annual housing targets, are set for only the first ten years of the Plan. This reflects the capacity of land suitable for residential development and intensification identified in the 2017 Strategic Housing Land Availability Assessment (SHLAA) which, due to the dynamic nature of London’s land market, does not attempt to identify capacity beyond 2029. 

Considered the formal guidance document for London, the Boroughs’ local development documents have to be ‘in general conformity’ with the London Plan, which is also legally part of the development plan that has to be taken into account when planning decisions are taken in any part of London unless there are planning reasons why it shouldn’t. The Plan provides the strategic framework in guiding boroughs’ Development Plans to ensure that they are working towards a shared vision for London, and it establishes policies that allow everyone involved in new developments to know what is expected from them. 

Neighbourhood plans are also required to conform with the policies set out in the London Plan. The London Plan aim is to be a useful resource and guidance to inform other plans and policies in London and should be taken into account when making relevant planning decisions such as determining planning applications. The Plan provides the framework to address the key planning issues facing London, allowing boroughs to spend time and resources on those issues that have a distinctly local dimension and on measures that will help deliver the growth London needs. This also includes area-based frameworks, action plans and Supplementary Planning Documents, site allocations, brownfield registers and design codes, as well as supporting neighbourhood planning. 

Therefore, to keep up to date, the Mayor is legally required to keep the London Plan under review, meaning to keep it updated to reflect the latest requirements. Government guidance also sets out the procedure to be followed when they decide that the Plan should be amended, or when there should be a completely new Plan. 

So the London Plan itself is:

• the overall strategic plan for London, setting out an integrated economic, environmental, transport and social framework for the development of London over the next 20–25 years
• Is the document that brings together the geographic and locational aspects of the Mayor’s other strategies – including those dealing with:
• Transport
• Economic Development
• Housing
• Culture
• a range of social issues such as children and young people, health inequalities and food
• a range of environmental issues such as climate change (adaptation and mitigation), air quality, noise and waste
• the framework for the development and use of land in London, linking in improvements to infrastructure; setting out proposals for implementation, coordination and resourcing; and helping to ensure joined-up policy delivery by the GLA Group of organisations 
• the strategic, London-wide policy context within which boroughs should set their detailed local planning policies
• the policy framework for the Mayor’s own decisions on the strategic planning applications referred to them
• an essential part of achieving sustainable development, a healthy economy and a more inclusive society in London 

Essentially, the Plan aims to deal with things of strategic importance to Greater London under the legislation setting up the Greater London Authority. The legislation also requires that the London Plan takes account of the:

• economic development and wealth creation
• social development; and
• improvement of the environment. 

A key part of reviewing the London Plan is undertaking a full Integrated Impact Assessment (IIA) and Habitats Regulations Assessment (HRA). The IIA approach addresses the Mayor’s legal duties to carry out a comprehensive assessment of the Plan and its proposed policies with one integrated process. The IIA incorporates the statutory requirements of: 

• Strategic Environmental Assessment 
• Sustainability Appraisal 
• Equalities Impact Assessment 
• Health Impact Assessment 
• Community Safety Impact Assessment 

And the HRA assesses any aspects of the Plan that would cause a likely significant effect on any European Habitats Sites. The IIA and HRA have helped shape the preparation of the London Plan ensuring that these key issues have been taken into account throughout the development process. 

In terms of the structure of the document itself, it includes:

• a chapter outlining the context for the Plan and its policies
• a clear spatial vision in a chapter on ‘Places’
• And topic-based chapters on London’s policies and implementation regarding:
• Design 
• Housing
• Social infrastructure
• Economy
• Heritage and Culture
• Green Infrastructure and Natural Environment
• Sustainable infrastructure
• Transport
• Funding the London Plan
• Monitoring and review.

1. So looking at the document itself in more detail, starting with Good Growth, each of the policy areas in the Plan are informed by six Good Growth objectives:

• GG1 Building strong and inclusive communities 
• GG2 Making the best use of land through development of brownfield land and well-connected sites  
• GG3 Creating a healthy city by using the healthy streets approach, improving air quality and access to green spaces and infrastructure
• GG4 Delivering the homes Londoners need by identifying suitable sites and ensuring more homes are delivered 
• GG5 Growing a good economy 
• GG6 Increasing efficiency and resilience by ensuring building and infrastructure are designed to adapt to a changing climate and improving energy efficiency moving towards a low carbon circular economy 

2. Then the Plan explores the spatial development patterns which consists of 10 policies:

First looking at Opportunity Areas: Covering the parts of London that will see significant development over the lifetime of the Plan and seeks to address how change will be managed for London’s most sensitive and complex places. 

By identifying opportunity areas and having Boroughs set out a clear path through their Development Plans. Opportunity Areas are identified as significant locations with development capacity to accommodate new housing, commercial development and infrastructure linked to existing or potential improvements in public transport connectivity and capacity. Many Opportunity Areas overlap with Strategic Areas for Regeneration and have the potential to promote inclusive growth that increases opportunity for all Londoners. The Mayor will put in place resources and support – such as the Good Growth Fund – to ensure that the potential of London’s growth corridors and Opportunity Areas is maximised.

This is aimed to be achieved through the Mayor’s London Housing Strategy and Transport Strategy. 

The London Housing Strategy promotes four key principles:

• Land assembly
• Investing in housing and infrastructure
• Diversifying the tenure mix of new homes
• Increasing capacity

And the Transport Strategy seeks to ensure that public transport and walking and cycling provisions are at the heart of planning for Opportunity Areas. It sets out that the Mayor will support growth in Opportunity Areas through transport investment and planning, and commits to setting ambitious mode share targets.

The Mayor also seeks to partner & collaborate across the Wider South East to address appropriate regional and sub-regional challenges and opportunities through strategy coordination arrangements. To secure an effective and consistent strategic understanding of the demographic, economic, environmental and transport issues facing the Wider South East. The Mayor supports joint working with WSE partners to ensure that plan-making is, as far as possible, informed by up-to-date, consistent technical evidence and monitoring. The new structure provides the basis for coordinated approaches to Government on pan-regional.

The Mayor will work with strategic and local authorities, Government and other interested partners to realise the growth potential of the Wider South East and beyond through investment in strategic infrastructure to support housing and business development particularly in growth locations to meet needs and secure mutual benefits for London and relevant partners. This Plan aims to accommodate the majority of London’s growth within its boundaries without intruding on its Green Belt or other protected open spaces. However, the Mayor does recognise that some expansion will be required to accommodate the growing housing requirements and is therefore interested in working with willing partners beyond London to explore if there is potential to accommodate more growth in sustainable locations outside the capital. The focus is on locations that are well-connected by public transport and where development can help meet local growth aspirations as well as wider requirements. 

The London Plan also takes a strong town centres first approach, in order to make the most of the agglomeration benefits and accessibility of Central London’s town centres and the Central Activities Zone ensuring sustainable patterns of development. 

Out-of-centre development can be particularly detrimental to town centres, undermining their economic performance, local character, and the accessibility they provide to a broad range of services, and encouraging increased trips by car. It is important, therefore, to take a sequential approach, focusing on sites within town centres before considering edge-of-centre sites. 

Borough’s local Development Plan Documents should, therefore, proactively plan to meet forecast needs for main town centre uses by allocating sites within or on the edge of town centres and through town centre boundary reviews, in order to support the town centres first approach and identifying the town centre network, local partnerships and implementation. Where town centre and edge-of-centre sites are not available, local Development Plan Documents should identify future potential town centres that could accommodate the forecasted additional need, and set appropriate policies, boundaries and site allocations for these areas. Where edge-of-centre developments of retail, leisure and office uses are proposed and are not as per the Development Plan, these should be accompanied by a robust and detailed impact assessment. 

Boroughs will also be required to undertake town centre health checks regularly which will be informed by the London-wide town centre health check and should be tailored to local circumstances. Town centre health checks should take information from a variety of sources, including desk-based research as well as on-the-ground surveys, to establish the overall health of the town centre. This should include an analysis of the performance of commercial premises in the town centre as well as wider issues such as environmental quality and accessibility.

Boroughs will also be expected to undertake area assessments to define the characteristics, qualities and value of different places within the plan area to develop an understanding of different areas’ capacity for growth. This involves offices, other strategic functions and residential development in the Central Activities Zone. 

3. In terms of Design, which consists of 14 policies:

London’s form, character and capacity for growth are at the forefront of the London Plan, promoting circular economy principles through building in layers, designing out waste, designing for longevity, adaptability, disassembly and using systems, elements or materials that can be reused and recycled. Large-scale developments in particular present opportunities for innovative building design that avoids waste, supports high recycling rates and helps London transition to a circular economy, where materials, products and assets are kept at their highest value for as long as possible. 

When putting forward a proposal to the relevant London Borough, masterplans and design codes should be used to help bring forward development and ensure it delivers high-quality design and place-making. Therefore, design and access statements submitted with development proposals should demonstrate that the proposal meets the design requirements of the London Plan. Ensuring infrastructure requirements are provided for sustainable densities.

To further promote good design, the London plan seeks to optimise site capacity through the design-led approach and deliver good design. Hence why the Mayor has also published a London Quality Review Charter which aims at promoting a consistent approach across London’s design review sector and promotes transparency of process. Fire Safety and inclusive design are also key to the design principles of the London Plan, as well as the Agent of Change principle which places the responsibility for mitigating the impact of noise and other nuisances firmly on the new development providing good housing quality and standards. 

Housing is also one of the vital sections within the London Plan and consists of 16 policies:

Increasing housing supply is key within the Plan, which sets the ten-year targets that each local planning authority should plan for and Boroughs are expected to include these targets within their Development Plan Documents. In order to promote and increase housing, the Mayor has carried out a London-wide strategic Housing Market Assessment and Strategic Housing Land Availability Assessment identifying the housing requirements targets per year.

Because of London’s ability to plan strategically, boroughs are not required to carry out their own housing needs assessment but must plan for, and seek to deliver, the housing targets outlined in the Plan by the Strategic Housing Market Assessment and Strategic Housing Land Availability Assessment. There is also the London Housing Strategy which sets out the Mayor’s proposals for working with boroughs and other partners to deliver the step change in housing supply required, encouraging boroughs to put in place clear plans to bring forward appropriate sites in their own ownership for housing delivery. Also set out in the London Housing Strategy, is the Mayor’s aim to ensure that Londoners have an opportunity to purchase new homes before they are marketed overseas and making more new homes available to Londoners before anyone else. 

The Mayor is also aiming to set out design principles for housing developments on small sites across London in design guidance, which boroughs should draw on and supplement when preparing housing design codes. Additionally, the London Plan sets a target for 50% of all new homes delivered across London to be genuinely affordable. Affordable housing should be delivered on-site to help deliver mixed and inclusive communities providing choice to a range of Londoners. There is also the option to provide affordable housing off-site but this should only be considered in exceptional circumstances where it can be robustly demonstrated that affordable housing cannot be delivered on-site or where an off-site contribution would better deliver mixed and inclusive communities than an on-site contribution. Such approaches will typically have to be delivered and recorded in line with a Section 106 agreement.

The Mayor has provided detailed guidance on viability assessments and Build to Rent developments in their Affordable Housing and Viability Supplementary Planning Guidance which is a key planning consideration for planning applications in London. The aim of the viability assessment is to establish whether the proposed level of affordable housing and other contributions is the maximum that can be reasonably supported or whether further obligations or a greater level of policy compliance could be achieved.

Boroughs are also required to promote efficient use of existing housing stock to reduce the number of vacant and under-occupied dwellings, alongside provisions for built-to-rent, student accommodation, care homes and gipsy and traveller accommodation. Boroughs are to use all the tools at their disposal such as Empty Dwelling Management Orders to bring long-term vacant stock back into use as affordable housing. Boroughs should also ensure a range of new homes are provided that meet the needs of those who wish to downsize and that tenants in affordable homes are supported to downsize where they wish to do so.

In order to support the housing and the spatial development plans envisioned for London, social infrastructure also forms a key part of the London Plan and consists of 7 policies:

Social infrastructure covers a range of services and facilities that meet local and strategic needs and contribute towards a good quality of life and improve Londoners everyday life. It includes health provision, education, community, play, youth, early years, recreation, sports, faith, criminal justice and emergency facilities. 

Boroughs are required to ensure the social infrastructure needs of London’s diverse communities are met, informed by a needs assessment of social infrastructure. Social infrastructure should be easily accessible by walking, cycling and public transport in accordance with the Healthy Streets Approach. 

In areas of major new development and regeneration, social infrastructure needs should be addressed via area-based planning such as Opportunity Area Planning Frameworks, Area Action Plans, Development Infrastructure Funding Studies, Neighbourhood Plans or master plans.

Another key part of the London Plan expands on Economy and consists of 11 policies:

It looks at the provision of necessary office and business facilities to grow and thrive in London meeting the diverse range of office markets. Therefore, it is important that the planning process does not compromise potential growth and provides a broad monitoring benchmark which needs to be set against other drivers such as development trends, employment densities, rents, take-up and vacancy.

Boroughs should, therefore, include policies in their Local Development Plan Documents that support the provision, and where appropriate, protection of a range of B Use Class business space, in terms of type, use and size, at an appropriate range of rents, to meet the needs of micro, small and medium-sized enterprises and to support firms wishing to start-up or expand.

Boroughs should consider including within their Development Plans detailed affordable workspace policies in light of local evidence of need and viability. These may include policies on site-specific locations or defining areas of need for certain kinds of affordable workspace.

Affordable workspace policies defined in Development Plans and the terms set out in Section 106 agreements should ensure to include evidence that the space will be managed by a workspace provider with a long-term commitment to maintaining the agreed or intended social, cultural or economic impact. Applicants are encouraged to engage with workspace providers at an early stage in the planning process to ensure that the space is configured and managed efficiently. Leases or transfers of space to workspace providers should also be at rates that allow providers to manage effective workspace with sub-market rents to meet the goal for London creating a fairer, more inclusive and equal city.

The Mayor is also encouraging the delivery of new workspace for SMEs, the creative industries, artists and the fashion industry within new residential and mixed-use developments, assisting artists and creative businesses through the Mayor’s Creative Enterprise Zones promoting schemes that provide linked affordable housing and affordable workspace in new housing developments.

In addition to office and workspaces, London depends on a wide range of industrial, logistics and related uses that are essential to the functioning of its economy and for servicing the needs of its growing population, as well as contributing towards employment opportunities for Londoners. This includes a diverse range of activities such as food and drink preparation, creative industry production and maker spaces, vehicle maintenance and repair, building trades, construction, waste management including recycling, transport functions, utilities infrastructure, emerging activities and an efficient storage and distribution system which can respond to business and consumer demands.

Where possible, therefore, all Boroughs should seek to deliver intensified floorspace capacity in either existing and/or new appropriate locations supported by appropriate evidence to support these uses. Boroughs are also encouraged to identify and support the growth of sustainably-located employment clusters in inner and outer London. 

The Mayor’s economic vision is for London to be a global test-bed for ‘smart city’ solutions, including improving the way people access public services and to support this, they will help to establish common standards for collecting data and make more data open to the public. 

Additionally, given London is the second most visited city in the world the Mayor wants to spread economic and regeneration benefits by working with London & Partners to promote tourism across the whole of the city, including outside central London. The London Plan supports the enhancement and extension of London’s attractions particularly to town centres and well-connected parts of outer London, complemented by supporting infrastructure including visitor accommodation, a high-quality public realm, public toilets and measures to promote access by walking, cycling and public transport.

Therefore, Boroughs in the Clean Air Zone are encouraged to direct strategically significant serviced accommodation towards the CAZ Opportunity Areas. Boroughs in outer and inner London beyond the CAZ are encouraged to plan proactively for new serviced accommodation in town centres to help spread the benefits of tourism to the whole of the capital. Serviced accommodation developments should, therefore, be developed to achieve the highest standards of accessible and inclusive design.

Now let’s look at London’s Heritage and Culture, which consists of 7 policies:

The London Plan states that Boroughs should, in consultation with Historic England, local communities and other statutory and relevant organisations, develop evidence that demonstrates a clear understanding of London’s historic environment. Development Plans and strategies should , therefore, demonstrate a clear understanding of the historic environment and the heritage values of sites or areas and their relationship with their surroundings. 

Development proposals are encouraged to avoid harm and identify enhancement opportunities by integrating heritage considerations early on in the design process identifying assets of archaeological significance and use this information to avoid harm or minimise it through design and appropriate mitigation.

Where heritage assets have been identified as being At Risk, boroughs should identify specific opportunities for them to contribute to regeneration and place-making, and they should set out strategies for their repair and re-use.

Development Plans and strategies should also demonstrate a clear understanding of the heritage values of a building, site or area and its relationship with its surroundings. Through proactive management from the start of the development process, planners and developers should engage and collaborate with stakeholders so that the capital’s heritage contributes positively to its future. To ensure a full and detailed understanding of the local historic environment, stakeholders should include Historic England, London’s Parks and Gardens Trust, The Royal Parks, boroughs, heritage specialists, local communities and amenity societies.

Boroughs with World Heritage Sites, and those that are neighbours to authorities with World Heritage Sites, should include policies in their Development Plans that conserve, promote, actively protect and interpret the Outstanding Universal Value of World Heritage Sites, which includes the authenticity and integrity of their attributes and their management. The consideration of views is part of understanding potential impacts on the setting of the World Heritage Sites. Many views to and from World Heritage Sites are covered, in part, by the London Views Management Framework. 

The Mayor will identify Strategically-Important Landmarks in the views that make a very significant contribution to the image of London at the strategic level or provide a significant cultural orientation point. Seeking to protect vistas towards Strategically-Important Landmarks by designating landmark viewing corridors and wider setting consultation areas. Where developments impose on these views, they should be supported wherever possible by the use of accurate 3D digital modelling and other best practice techniques to determine their viability. The Mayor has prepared a Supplementary Planning Guidance which should be followed on the management of the designated views – the London View Management Framework Supplementary Planning Guidance. 

In terms of culture, boroughs should use Cultural Quarters to seek synergies between cultural provision, schools, and higher and further education which can be used to nurture volunteering, new talent and audiences in opportunity areas, other areas for regeneration and large-scale developments. 

This then leads to the London Plans’ next section which looks at Green Infrastructure and the Natural Environment, which consists of 9 policies:

London’s network of green and open spaces, and green features in the built environment, should be protected and enhanced. Therefore, Boroughs are expected to prepare green infrastructure strategies that identify opportunities for cross-borough collaboration, ensure green infrastructure is optimised and consider green infrastructure in an integrated way and their development proposals should incorporate appropriate elements of green infrastructure that are integrated into London’s wider green infrastructure network. 

Part of this includes urban greening measures in new development which will increase green cover and should be integral to planning the layout and design of new buildings and developments. This can include street trees, green roofs, green walls and rain rain gardens. The Mayor has developed a generic Urban Greening Factor model to assist boroughs and developers in determining the appropriate provision of urban greening for new developments. Boroughs and developments should also assess biodiversity and access to nature, the potential for the creation for food growing amenities and geodiversity. 

This then leads to the London Plans’ next section which looks at Sustainable Infrastructure, which consists of 17 policies:

It focuses on improving air quality, whereby development plans, through relevant strategic, site-specific and area-based policies, should seek opportunities to identify and deliver further improvements to air quality and should not reduce air quality benefits that result from the Mayor’s or borough’s activities to improve air quality.

Additionally, the London Plan is seeking to become a zero-carbon city, this will require minimising greenhouse gas emissions in operation and minimising both annual and peak energy demand. Boroughs are, therefore, required to ensure that all developments maximise opportunities for on-site electricity and heat production from solar technologies and use innovative building materials and smart technologies. A zero-carbon target for major residential developments has been in place for London since October 2016 and applies to major non-residential developments.

Boroughs and developers should, therefore, engage at an early stage with relevant energy companies and bodies to establish the future energy and infrastructure requirements arising from large-scale development proposals such as Opportunity Areas, Town Centres, other growth areas or clusters of significant new development.

Development proposals should also cover the requirement for minimising adverse impacts on the urban heat island through design, layout, orientation, materials and the incorporation of green infrastructure.

Other items covered under Sustainable Infrastructure include water infrastructure, and digital connectivity infrastructure leading London to be a world-leading tech hub with world-class digital connectivity, as well as reducing waste and supporting the circular economy. 

To assist with the introduction of Circular Economy principles, the Mayor will be providing further guidance on Circular Economy Statements which are intended to cover the whole life cycle of a development. This will apply to referable schemes and be encouraged for other major infrastructure projects within London. Boroughs are encouraged to set lower local thresholds through their Development Plans and how waste capacity can be delivered at the local level and demonstrate how this can be provided for through the allocation of sufficient sites and the identification of suitable areas aiming to meet their waste apportionment as a minimum. 

When it comes to developments, developers should refer to the London Waste and Recycling Board’s design guide for ensuring adequate and easily accessible storage space for high-rise developments.

Flooding and sustainable drainage are also critical elements of sustainable infrastructure, whereby the London Sustainable Drainage Action Plan and boroughs are Lead Local Flood Authorities (LLFAs) and are responsible, for local surface water flood risk management and for maintaining a flood risk management assets register and they produce Local Flood Risk Management Strategies. 

And lastly let’s look at the final section of the London Plan looking at Transport, which consists of 9 policies:

Within this section, the London Plan seeks to facilitate methods to keep the city connected in a sustainable and efficient way. In order to help facilitate this, an integrated strategic approach to transport is needed, with an ambitious aim to reduce Londoners’ dependency on cars in favour of increased walking, cycling and public transport use. To achieve sustainable growth, Development Plans should support walking, cycling and public transport through policies that support mode shift and should facilitate sustainable travel through their location and design and supporting Healthy Streets. When preparing Development Plans, Local Authorities should engage with TfL to appropriately plan for sites and routes to deliver an enhanced or expanded transport network.

Under this section, the London Plan also sets out the parking standards for residential development, office, retail, hotel and leisure and non-residential disabled person parking. It also addresses delivery requirements and aviation ensuring any aviation additions or expansions do not worsen air quality or cause environmental harm and negative public health. 

In conclusion:

Through this Plan, the Mayor is determined to tackle the housing crisis and support London’s continued growth in a sustainable and inclusive way. The implementation, therefore, of the London Plan will be kept under constant review to ensure it still meets the city’s targets and growth ambitions of supplying new homes and affordable homes, increasing office capacity, protecting the Green Belt and Metropolitan Open Land, reduce carbon emissions and improve public health and air quality as well as retaining London’s heritage and cultural infrastructure. 

To sum up what I discussed today:

• The London Plan 2021 is the Spatial Development Strategy for Greater London. It sets out a framework for how London will develop over the next 20-25 years and the Mayor’s vision for Good Growth.
• And it aims to deal with things of strategic importance to Greater London under the legislation setting up the Greater London Authority. Taking into account the: economic development and wealth creation, social development; and improvement of the environment. 
• The document itself, consists of 12 Chapters covering topics like spatial development patterns, design, housing, social infrastructure, economy, heritage and culture, green infrastructure and the natural environment, sustainable infrastructure, transport, the funding of the London. Plan and monitoring