The New London Plan
This summer should see the publication of the new London Plan, which will replace the 2015 version. This will bring to an end a process that began in autumn 2016 with Mayor Sadiq Khan’s A City for All Londoners, followed by a first draft coming just over a year later. The ‘intend to publish’ version became available in December of last year, and not without snags along the way as part of the consultation process, which has included 300 organisations and individuals. Therefore, this is a good time to give some thought to what the thinking is behind it, and what it comprises.
First things first: it’s a statutory document required by the Greater London Authority Act 1999 (the GLA Act, as it’s known). The Act provides a framework for the plan, which is the authority’s Spatial Development Strategy (SDS): how it should be drawn up, altered and replaced. The mayor is required to outline his policies regarding land and spatial development, and comment on how they fit in with other strategies, such as national policies. In its final form, it will be part of the statutory development plan for Greater London, and will have accompanying Supplementary Planning Guidance. It covers the period up to 2041, though there will undoubtedly be updated versions in the coming 21 years.
It functions as a framework, covering economic, environmental, transport and the social issues pertaining to those areas. The aim is good growth, and with that in mind, the mayor has announced six ‘Good Growth’ policies, which function as an add-on to the GLA Act. Good Growth is that which is socially and economically inclusive and environmentally sustainable:
- Policy GG1 Building strong and inclusive communities
- Policy GG2 Making the best use of land
- Policy GG3 Creating a healthy city
- Policy GG4 Delivering the homes Londoners need
- Policy GG5 Growing a good economy
- Policy GG6 Increasing efficiency and resilience
Chapter one tells us about the mayor’s vision for London and explains what the aforementioned Good Growth is. Following that, chapter two sets out the overall spatial development plan for the city. Chapters three to twelve then set out the specific and spatially-specific policies that are required to deliver the Good Growth, for example in housing, transport and social infrastructure.
In this context, what does it tell us in headline terms about future London in terms of the general environment, housing, transport, energy, well-being, carbon emissions, and sustainability?
As you’d expect, the environment is discussed rather a lot, both generally and specifically in terms of the built environment; moreover, it is the overarching thinking behind the discrete policies on transport, housing, and so on, so it makes sense to limit our remarks to the big picture level. In terms of that, the plan’s principal objective is to promote the improvement of London’s environment and the physical and mental health of its inhabitants. As the Plan says in this context:
“A failure to consider the wider implications of London’s growth has increased car dependency, leading to low levels of physical activity, significant congestion, poor air quality and other environmental problems”
Another aim is to deliver more than 50% green cover across the city, with a view to London becoming a National Park city.
In terms of housing, there are 10-year net housing completion targets for local authorities. To achieve this, boroughs need to develop delivery-focussed development plans, optimise the potential for housing delivery on all suitable brownfield sites, and establish ambitious and achievable build-out rates at the planning stage, which incentivise build-out milestones in order to help ensure that homes are built quickly and to reduce the likelihood of permissions being sought to sell land on at a higher value. Transport needs and mixed-use development are prioritised.
Minimum space standards are set out for homes. Also, they must be fit for purpose for a changing world in terms of climate; therefore, the Plan helps meet the challenges of a changing climate by ensuring homes are suitable for warmer summers and wetter winters. The nature of a high-density city means a focus on tall buildings will form part of a sustainable approach to future growth. The mayor has carried out a London-wide Strategic Housing Market Assessment (SHMA) and Strategic Housing Land Availability Assessment (SHLAA). The former has identified the need for 66,000 additional homes per year.
Many of the city’s neighbourhoods lie within the 20% most deprived areas in England, and are consequently designated Strategic Areas for Regeneration in the Plan. Development plans should aid in creating mixed and inclusive neighbourhoods – a phrase used extensively in the Plan – in which communities collaborate in the development of planning policies that affects them.
Regarding overall design, the focus is again on Good Growth. This requires area assessments and an understanding of the importance of both respecting character and accommodating change.
To move on to transport, plans developed by boroughs should support and facilitate the mayor’s strategic target of 80% of all trips in London by 2041 being made by foot, cycle or public transport. To that end, the Plan suggests that:
“All development should make the most effective use of land, reflecting its connectivity and accessibility by existing and future public transport, walking and cycling routes, and ensure that any impacts on London’s transport networks and supporting infrastructure are mitigated.”
This requires an integrated approach, which is essential to the healthy functioning city in the 21st century. Moreover, getting Londoners out of their cars is the only realistic solution to the road congestion challenges the city faces. To this end, the mayor will work with partners to minimise freight trips on the road as well. All this will require sustained investment.
Above are the changes required in transport mode share in central, inner and outer London to achieve this shift to 80% share for public transport, walking and cycling.
The Plan also provides 10 Healthy Streets indicators that are intended to facilitate this mode share change with a view to promoting health and reducing health inequalities. The context? Streets are 80% of the city’s public spaces. A part of this is reducing road danger by promoting what the Plan is calling Vision Zero which involves “designing and managing a street system that accommodates human error and ensures impact levels are not sufficient to cause fatal or serious injury”.
As part of the aim of reducing emissions, development proposals must refer to the mayor’s nationally recognised Whole Life-Cycle Carbon Assessment and contain demonstrable actions. Guidance to this effect was released in April and considered on this site recently. The Whole Life-Cycle Carbon approach ensures that operational carbon emissions reduce year-on-year, as targets become more stringent. It also allows the capture of unregulated emissions (such as those from cooking and small appliances) and of embodied emissions, which includes those associated with raw material extraction, manufacture and transport of building materials and construction.
Furthermore, the Plan makes clear that the mayor is committed to London becoming a zero-carbon city by 2050. The city’s homes and places of work produce 78% of its greenhouse gases, of which carbon dioxide is the most prominent, and all new development needs to meet the requirements of this policy.
Of course, reducing the use of traditional forms of energy is a significant part of this aim, and boroughs should ensure that all developments maximise opportunities for on-site electricity and heat production from solar technologies. This will support London’s energy resilience and encourage the growth of green jobs. To provide a clear approach, the mayor has produced Energy Planning Guidance, with the hope of providing certainty to developers and all relevant stakeholders. Comprehensive monitoring is also required for assurance purposes. All this is driven by the need to increase efficiency and resilience. With that in mind, the Plan use four pithy phrases to sum up its approach to minimising emissions: be lean; be clean; be green; be seen.
But energy isn’t just about emissions: it’s also about reducing lighting on tall buildings, prioritising renewables and new technology, air quality, minimising demand, building design, and the appropriate use of BREEAM ratings, among other things.
The Plan needs to be seen in the context of the government’s overall planning policy and guidance; while it’s the key document in terms of the capital city, London is not separate from the rest of the country, and their needs required a conjoined approach. Moreover, constituent parts of the city’s infrastructure have their own planning documents and local plans, which sit within or need to take account of the London Plan.
What does the Plan have to say about social well-being? It is its overarching aim; its raison d’être, if you like. All development plans need to assess their potential impact on the well-being of communities. Well-being strategies speak to health and social care in the document, in particular, with a view to identifying priorities for action. Health Impact Assessments provide a framework to undertake this. Social well-being also requires the conservation and enhancement of historical sites, heritage and culture, and an appropriate approach to the night-time economy, for all of which London is deservedly famous.
Sustainability is also woven throughout the Plan and needs to be demonstrated in the areas discussed in this article. It forms a key element of the capital’s transformation plans, and for local plans, which must consider their impact upon the capital overall. These Sustainability and Transformation Plans (STPs) were published in October 2016 and set out how health and care services will evolve and become financially sustainable over the 5-year period to 2020/21.
This short overview can only scratch the surface of what is a document of over 600 pages; the length gives an idea of the depth of ambition. Only time will tell if reality meets the ambition.