Draft London Plan Key Points

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Darren Higgins
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1 Draft London Plan Key Points Briefing paper London Planning 30/11/17 GL Hearn s executive summary of the Draft London Plan Mayor Sadiq Khan s much anticipated Draft London Plan was issued on Wednesday with the formal consultation period due to commence on Friday 1 st December 2017 and running until Friday 2 nd March The Mayor promised that the Plan would be ambitious ; a step change in approach; and, a blueprint for future development and growth in London. Sustainability, both social and environmental, features highly in the Mayor s concept of good growth. Addressing inequality and the perceived prosperity gap are also key considerations. The Plan is supposed to be composed of tangible policies that provide clarity. It is likely to provoke debate around the following topics: Ambitious housing growth without green belt release. Local character balanced against small sites delivering 0-25 homes. Scrapping the density matrix approach. Intensifying residential development in suburban locations. Affordable housing tenure mix. Requirement to provide 50% affordable on public sector portfolios rather than specific sites. Defined Build to Rent schemes to benefit from the 35% fast track route. A degree of encouragement for shared living developments. Extra care and supported living defined as C3 use rather than C2. Intensification of retail areas for residential use. No net loss of industrial floorspace in Strategic or Locally Significant Industrial Areas. Car free development. GL Hearn has summarised some of the key points in the new Plan as follows. Further detail sits behind this analysis and our experts would be happy to discuss the implications of these draft policies: Recognition of the housing crisis A minimum of 66,000 homes are targeted per annum Affordable housing is to account for half of all house building in London over the Plan period (20-25 years). Boroughs including Bexley, Bromley, Croydon, Ealing, Enfield, Greenwich, Hillingdon, Hounslow, Kingston, Merton, Richmond, If you have any queries please contact: Stewart Murray Head of Development Group stewart.murray@glhearn.com T +44 (0) Stuart Baillie Head of London Planning stuart.baillie@glhearn.com T +44 (0) Alex Christopher Tall Buildings and High Density Residential alex.christopher@glhearn.com T +44 (0) Chris Benham Hotels and Shared Living chris.benham@glhearn.com T +44 (0) Ben Wrighton Student Accommodation ben.wrighton@glhearn.com T +44 (0) Nick Diment Retail & Town Centres nick.diment@glhearn.com T +44 (0) Cat Fraser Retirement Living catriona.fraser@glhearn.com +44 (0) Edmund Couldrey Viability and Affordable Housing edmund.couldrey@glhearn.com T +44 (0) Matt Kinghan Industrial Land matt.kinghan@glhearn.com T +44 (0)

2 Sutton and Waltham Forest seeing their housing requirement increase by more than 100%. Growth Corridors and Opportunity Areas Identified as Crossrail 2, Thames Estuary, Bakerloo Line Extension, Central London, Elizabeth Line East, Heathrow, Elizabeth Line West, Trams Triangle/ London-Gatwick-Brighton mainline and HS2. Opportunity areas within these growth corridors to deliver at least 2,500 net additional homes and 5,000 ned additional jobs. Green Belt no surprises here The Plan will continue to protect the Green Belt and MOL. Aim to make London 50% green by 2050 the UK s first National Park City. Aim to make the Green Belt more accessible and better quality. Housing Delivery Housing delivery on small and large sites will need to approximately double compared to current average completion rates a step change in delivery. Emphasis on increasing supply through brownfield and windfall sites, car park and retail park redevelopment, increased density around transport hubs, surplus utilities/public sector sites. A new, added focus on small sites (1 25 units, less than 0.25 ha), which will have a presumption on favour of development (this includes upward extensions). Local Character will need to change in appropriate locations to accommodate delivery on small sites. Precision Manufactured housing is identified as a potential meanwhile use for large sites awaiting development, potentially allowing units to be moved from site to site over time. Flexible approach on mix, with an acknowledgement that 2 bed units contribute to family housing. No change to residential space standards. Optimising residential density Density matrix approach has been removed in favour of optimising housing density. Site by site design-led approach to be taken to assessing capacity. Accessibility including proposed infrastructure improvements, walking and cycling are all relevant considerations. Phasing of development where it is contingent on infrastructure or public transport provision to improve capacity (eg extension of Bakerloo Line Extension). Residential developments that do not optimise density will be refused. Higher density = higher qualitative and design scrutiny. Introduction of a Management Plan requirement to include running costs and service charges where beyond density thresholds as follows: units per hectare in areas of PTAL 0 to units per hectare in areas of PTAL 2 to units per hectare in areas of PTAL 4 to 6 To measure density - all schemes to provide number of units per hectare; number of habitable rooms per hectare; number of bedrooms per hectare; and number of bedspaces per hectare.

3 Major Applications to provide additional information on Floor Area Ration, Site Coverage Ratio and maximum building heights above AOD to be provided. Tall Buildings Mandatory design review by independent experts required where buildings exceed the density thresholds stated above or where buildings exceed 30m or whatever locally set definition of building height constitutes a tall building. Locations suitable for tall buildings to be identified in Borough Development Plans. GLA to work with Boroughs to provide a strategic overview of tall buildings and 3D virtual reality modelling to assist assessment and public consultation. Functional impact assessment to include: emergency exit; service and maintenance; ground floor uses; overcrowding; infrastructure capacity; and regeneration potential. Design considerations to include assessment of top, middle and base of tall building proposals. Viability & Affordable Housing largely as per SPG 50% strategic aim with 35% threshold approach (to be reviewed in 2021). 50% provision by RPs and Public sector but across their portfolio. Off-site contributions of Affordable or payment in lieu only in exceptional circumstances. 35% fast track approach = no viability submission and only a no progress review after two years or period agreed with LPA. 50% provision for Strategic or Locally Significant Industrial Land. Criteria to be applied to S73 Minor Material Amendments and any reduction in affordable to be referred to Mayor. Preference for EUV+ benchmark. In Opportunity Areas, Boroughs to consider a localised threshold that could be less than 35%. Specific policies for Build to Rent, Retirement, Student and Shared Living. 30/40/40 rule to be applied (Low Rent / Intermediate / TBC by Borough) (to be reviewed in 2021). London Living Rent & Discount Market Rent to have 60k household affordability cap. Shared Ownership and Discount Market Sale to have 90k household affordability cap. Vacant Building Credit must have been vacant for five years and been marketed for two years with no recent planning permission and not vacated solely for redevelopment. Build to Rent Growth in sector acknowledged with specific policy (H13) and noted that BTR can help accelerate delivery of housing. BTR is encouraged in town centres. There is no specific design criteria for BTR. BTR status subject to certain criteria i.e. a minimum of 50 self contained and separately let units; covenant for minimum of 15 years; clawback mechanism; unified ownership and management; no up front fees for prospective tenants and access to a complaints procedure. Affordable component can be solely Discount Market Rent but preferably London Living Rent BTR to qualify for 35% affordable fast track route where 30% is London Living Rent and the remainder at discounted rents. All other affordable combinations must follow Viability Tested Route. Schemes that do not meet the BTR definition will be treated as per build for sale schemes in regard to the assessment of affordable provision.

4 Hotels and Serviced Accommodation Encourages visitor attractions and hotels in outer London. Serviced accommodation for business visitors to be maintained and supported with a need for 58,000 additional bedrooms by Proposals for 20,000sqm plus serviced accommodation should be focused on Opportunity Areas in the CAZ and intensification of serviced accommodation in areas of existing concentration should be resisted. Serviced accommodation is not defined as including apart-hotels. Hotels must not impact upon strategic office space. Apart-hotels and short-term lettings to be supported where these do not compromise housing provision. Student halls being used as visitor accommodation can help address seasonal fluctuations. Shared Living Remains defined as sui-generis. If good quality and design then it may contribute to meeting housing needs in London. Design criteria are introduced which appear to offer some flexibility and may encourage developers / providers in this sector. Student Accommodation Acceptance for local and strategic need (3,500 units per annum across London) which has been considered as part of the GLA s SHMA, though schemes should keep clear of existing concentrations of student housing. Relationship with Higher Education Institution is crucial a formal agreement will be required before initial occupation for the majority of rooms. An acceptance that the provision of three bedspaces is equivalent to a conventional home accommodated by students this could potentially support the need case. 35% of the accommodation should be affordable for students (related to the prevailing maintenance loan) but purpose built accommodation should not provide conventional affordable housing. Temporary use of accommodation outside of term-time is generally supported Specialist Housing / Retirement Living Extra care / supported living for the elderly is now explicitly defined as C3 and consequently now applies to the same affordable housing policies as regular housing. This also has CIL implications as C3 is captured by CIL. Borough s annual targets for specialist older persons housing (C3) and are set out in Table 4.4 of the London Plan. Boroughs should support the delivery, retention and refurbishment of supported and specialised housing which meets an identified need with Boroughs cooperating with providers etc to undertake short and long-term needs assessments. The delivery of care for people with dementia in suitable accommodation is also specified in the Plan.

5 Retail and town centres Much more explicit support for residential as part of town centres. Strong support and encouragement for activities, particularly night-time economy. Encouragement for mixes of uses on existing edge and out-of-centre retail sites. Intensification of sites for residential (e.g. supermarket car parks and Shopping Frontages that are surplus to demand ). Specific encouragement of BTR and smaller homes in Town Centres. Presumption against takeaways (A5 uses) near schools. Flexibility to encourage temporary and meanwhile uses (e.g. pop ups). Encouragement of Article 4 Directions where justified to protect against commercial floorspace being lost to other uses via PD. Office Market The CAZ, Northern Isle of Dogs (NIOD), Tech City, Kensington & Chelsea and Royal Docks are recognised for their specialist office functions with future potential reserve identified at Stratford and Old Oak Common. Boroughs should consult upon and introduce Article 4 Directions to ensure that strategic and local office clusters including town centres and industrial areas are not undermined by permitted development rights. In areas where a shortage of low cost business space is identified, proposals for loss of B1 should demonstrate (evidence) a lack of demand; or reprovide B1 space (intensification); or identify suitable local alternative space and provide support business relocation. Any office (or industrial) development larger than 2,500 sqm (GEA) should consider the scope to provide flexible space for SMEs. Planning obligations may be used to secure affordable workspaces at below market rent to be used for social cultural or economic development purposes. Industrial Based on recent trends in industrial land losses and a positive net demand for industrial land over the period to 2041 (mostly driven by logistics demand); a general principle is established of no net loss of industrial floorspace in SIL (Strategic Industrial Locations) and LSIS (Locally Significant Industrial Sites) sites which remain focused on B1c, B2 and B8 provision and related uses. Boroughs are now allocated a retain, provide or limited release classification in terms of their industrial land position. Only Havering, Newham and Barking and Dagenham fall under limited release. Any release of industrial land should be facilitated through the processes of industrial intensification, co-location and substitution; and be centred on locations well connected by public transport and contribute to housing (particularly housing), schools and other infrastructure. Borough development plans and development proposals should be proactive and encourage the intensification of industrial uses through: (i) development of mezzanines; (ii) introduction of small units; (iii) development of multi-storey schemes; (iv) addition of basements; and (v) more efficient use of land through higher plot ratios. Intensification can facilitate residential development, town centre renewal or social infrastructure. For SIL and LSIS designations this can only be undertaken through a plan-led process or masterplanning in collaboration with the GLA and local borough. This must ensure:

6 - An increase (or at least no overall net loss) of capacity - defined as existing industrial floor area or 65% of plot (ratio), whichever is the greater. - The industrial and related activities on-site are not compromised; - The intensified industrial, storage and distribution uses are completed and operational in advance of any residential component being occupied. Substitution: Boroughs are encouraged to consider the substitution of industrial uses with neighbouring boroughs and local authorities within the same market area (within and outside of London). Mixed-use or residential development on Non-Designated Industrial Sites will be supported where: - there is no reasonable prospect of the site being used for the industrial and related uses; or - it has been allocated in a Development Plan for residential or mixed-use; or - industrial floorspace is provided as part of mixed-use intensification; or - suitable alternative accommodation is available nearby. Public Sector Land 50% affordable housing provision but this is to be applied across the portfolio rather than site specific. Surplus public sector land to be utilised for higher density, mixed use schemes where appropriate. Collaboration encouraged between Mayor, London Boroughs and wider South East Region s growth areas. Estate Regeneration no loss of affordable homes and an uplift where possible. Health sector A call for closer working between Boroughs, CCGs and the NHS in regard to more efficient estates and improved quality of care. Care provision to be more localised and move towards the community model. Surplus sites to be released for other uses primarily residential and to include up to 50% affordable housing. Sustainable Infrastructure Air quality assessments to be mandatory on major developments and development proposals should not lead to further deterioration of existing poor air quality. Mayor developments to include detailed energy strategy demonstrating how zero carbon target will be met. Energy masterplans encouraged for large scale development locations. BREEAM Excellent promoted. Protect water based transport infrastructure. Transport car free development The Mayor is committed to achieving healthy streets prioritising active transport over vehicles. New retail and office developments will be required to provide significantly more cycle parking. Student accommodation will require long stay cycle parking as one space per bedroom. Larger residential units will no longer require more car parking than smaller units.

7 Developments to provide for electric or ultra-low emission vehicle parking. The Plan further supports hydrogen refuelling or rapid charging infrastructure. Parking standards are to be significantly tightened. New developments in the most accessible parts of London will be encouraged to be car free only accomodating disabled parking and servicing requirements. Aspiration to ensure that 70 per cent of Londoners to live within 400 metres of a high quality, safe cycle routes by This review is not comprehensive. Much more detail sits behind the policies and content of the Draft Plan. GL Hearn s experts would be happy to assist our Clients in understanding their land and property specific implications of the draft Plan.

Draft London Plan Review

Draft London Plan Review Briefing Note Date: 04/12/2017 Ref No: 283 Introduction On the 29th November the Mayor of London, Sadiq Khan, published his draft London Plan for consultation (Regulation 19).